Tuberculosis

Scope

TB outbreaks are likely to occur in healthcare facilities, correctional institutions, homeless shelters, nursing homes, and residential care facilities for AIDS patients.

Regulatory citations

• 29 CFR 1904 — Recording and reporting occupational injuries and illnesses
• 29 CFR 1910 Subpart I — Personal protective equipment
• 29 CFR 1910.145 — Specifications for accident prevention signs and tags
• 29 CFR 1910.1020— Access to employee exposure and medical records
• 29 USC 654(a)(1) — General duty clause of the Occupational Safety and Health Act

Key definitions

• Infection control program: A multidisciplinary program that includes activities to ensure that recommended practices for the prevention of infections are implemented and followed by workers to prevent the spread of infection.
• TB skin test (TST): TST is the standard method of determining whether a person is infected with M. tuberculosis. The TST is performed by injecting tuberculin purified protein derivative (PPD) into the inner surface of the forearm. The skin test reaction should be measured by trained personnel between 48 and 72 hours after administration.
  

Summary of requirements

Employers are required to:

• Provide respirators to each employee when such equipment is necessary to protect the health of the employee. In such cases, the employer must establish and maintain a respiratory protection program.
• Conduct a hazard assessment to determine the need for personal protective equipment (PPE), document a hazard assessment certification, and provide and ensure the use of necessary PPE, along with PPE training.
• Post signs informing employees about any hazards that are of a nature such that failure to designate them may lead to accidental illness to employees or the public, or both.
• Keep injury/illness records. Covered employers must keep injury and illness records using the OSHA Form 300 Log, the Form 300A Summary, and the Form 301 Incident Reports, or equivalent forms.
• Certify and post the annual summary of injuries/illnesses. This must be posted from February 1 through April 30.
• Submit injury and illness data electronically to OSHA or OSHA’s designee, if required, by March 2 every year, if applicable.
• Keep exposure/medical records. Employers with employees exposed to biological agents (including bacteria like tuberculosis) must keep exposure records. Exposure records must be kept for 30 years. Medical records must be kept for the duration of employment plus 30 years.
• Report to OSHA. All employers, even those who may be exempt from other recordkeeping requirements, must promptly report to OSHA all work-related fatalities, in-patient hospitalizations, amputations, and losses of an eye.

When conducting a TB-related inspection, OSHA directive CPL 02-02-078, “Enforcement Procedures and Scheduling for Occupational Exposure to Tuberculosis,” June 30, 2015, explains that OSHA officers may evaluate whether the employer has implemented appropriate abatement measures to reduce the hazard. The directive adds that OSHA may cite under the General Duty Clause if any one of the following are found to be deficient:

• TB infection control program;
• TB risk assessment;
• Medical surveillance;
• Case management of infected employees;
• Employee education and training; and
• Engineering controls.

Directive CPL 02-02-078 summarizes some widely accepted standards of practice and refers OSHA officers to the Centers for Disease Control and Prevention (CDC) “Guidelines for Preventing the Transmission of Mycobacterium tuberculosis in Health-Care Settings,” December 30, 2005. Employers should consult the 2005 guidelines, along with any more recent guidelines. The CDC indicates that its “Tuberculosis Screening, Testing, and Treatment of U.S. Health Care Personnel: Recommendations from the National Tuberculosis Controllers Association and CDC,” May 17, 2019, updates the recommendations for screening, testing, and treatment of U.S. healthcare personnel.