Critics get another crack at proposed TB standard
Critics get another crack at proposed TB standard
OSHA reopens record for limited comments
For nearly two months this summer, critics and supporters of the Occupational Safety and Health Administration’s (OSHA) proposed tuberculosis standard had an unexpected opportunity to submit further comments on the document when the agency reopened the record.1,2
Some 41 additional comments were received during the limited reopening, but many of them contained nothing new, says Amanda Edens, OSHA project officer for the TB standard.
Edens cites two purposes for inviting more comments on OSHA’s proposal for regulating occupational exposure to TB some eight months after the post-hearing comment period closed.
First, "several pertinent studies and reports became available to us after the close back in October ’98," she says. They include four previously unavailable documents related to issues addressed during the public hearings, including costs of respiratory protection and fit-testing programs.3
Other newly acquired reports included information related to the risk of occupational exposure to TB in homeless shelters and medical waste treatment facilities. For the latter, OSHA is considering whether laboratories covered by the TB standard, which would include hospital labs, should be required to decontaminate their TB wastes before sending them off site for disposal.
Second, OSHA wanted to provide another opportunity to comment on the proposed standard’s risk assessment provisions "to see if there were some new studies we needed to look at or some issues we needed to include in terms of preparing our final risk assessment for the TB standard," Edens explains.
While many of the comments received during the summer were similar to those previously submitted, Edens says "nothing is carved in stone. We’re evaluating the different sides of the stories from all the groups [that commented] and will make the changes that seem reasonable where we can."
The American Hospital Association (AHA) in Chicago was among those taking the opportunity to comment on new developments. Focusing on the controversial issue of respirator fit-testing, with its associated costs that many hospitals and professional organizations have contended would be prohibitive, the AHA supports flexible fit-testing programs that allow employees who use respirators to be evaluated annually for the need to be fit-tested.
"Maintaining flexibility in the standard regarding the use of annual fit-testing would support good management and promote a cost-effective respiratory protection and fit-testing program," says Rick Pollack, AHA executive vice president, in comments to OSHA.
Specifically, the AHA asserts that OSHA should adhere to the approach outlined in the proposed standard, which accepts medical surveillance criteria in lieu of requiring annual fit tests. After an initial fit test, employees would be evaluated during their annual TB assessments to determine if significant facial changes or changes in respirator type or design warrant another fit test.4
Major costs are labor-related
Roslyne Schulman, senior associate director for policy development at the AHA, explains that while the N95 respirators now considered standard for TB protection are less expensive than the high-efficiency particulate air respirators that have been required in the past, the major costs for fit-testing programs are labor-related.
"Overall, hospital budgets are finite, and many other employee safety initiatives have to be budgeted, so there is a need to use resources wisely and effectively for employee health," Schulman says. "Requiring employees to go through annual fit-testing when it’s not necessary is not a wise use of resources."
The AHA’s comments credit hospital occupational/employee health services as a resource that allows a more flexible approach to respirator fit-testing.
"Occupational health services have the opportunity to assess individuals each year at a minimum, and are in a unique position to assess health care workers for TB," the AHA states. "Thus, hospitals have an opportunity to ensure employees are questioned systematically and carefully for the very changes that help determine whether or not further fit-testing is needed."
Edens says OSHA has no plans to reopen the standard again. Release of the final rule is still planned for spring 2000, "but I can’t predict those kinds of things," she says.
References
1. Occupational Safety and Health Administration. Occu pational exposure to tuberculosis. 64 Fed Reg 32,447-32,449 (June 17, 1999).
2. Occupational Safety and Health Administration. Occu pational exposure to tuberculosis. 64 Fed Reg 34,625-34,626 (June 28, 1999).
3. Kellerman S, Tokars JI, Jarvis WR. The cost of healthcare worker respiratory protection and fit-testing programs. Infect Control Hosp Epidemiol 1998; 19:629-634.
4. Occupational Safety and Health Administration. Occu pational exposure to tuberculosis; proposed rule. 62 Fed Reg 54,159-54,307 (Oct. 17, 1997).
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