OSHA's Final TB Ruling

OSHA's Final TB Ruling

By David Willyard

New OSHA TB Standard

On October 17, 1997, OSHA released its proposed TB standard, based on CDC guidelines,in the Federal Register. Following a lengthy comment and review period, OSHA is scheduledto issue its final TB standard, or final ruling, by the end of this year. This standardwill take effect 90 days after it is published. In the meantime, OSHA is still inspectinghospitals' TB programs in accordance with CPL2.016, OSHA's TB inspection criteria. Thisdiscussion of the proposed OSHA standard concentrates on engineering controls,specifically negative pressure and HEPA filtration systems. The ruling also deals withfrequency of skin testing, respiratory protection, and other areas of concern inprotecting healthcare workers from exposure to TB.

According to the proposed standard, many more facilities are at risk of occupationalexposure to TB than previously thought. Facilities that have not seen a confirmed TB casein the past two years may still be required to comply with the standard. Unless a facilitycan consistently transfer patients in less than five hours after the point ofidentification in a suspect case, the employer may want to consider adding at least onenegative-pressure isolation room. Also, high-hazard procedures such as endoscopy, sputuminduction, and bronchoscopy, among others, must be conducted in isolation rooms or areaswith negative-pressure capabilities.

TB Engineering Controls

OSHA does not specify required ventilation methods for achieving negative pressure,instead OHSA allows "any workable design" as long as the engineering controlsare capable of creating a negative-pressure isolation room. In other words, OSHA considersengineered TB isolation rooms and HEPA (High-Efficiency Particulate Arrestance) filtrationdevices, or HFDs, to be equivalent solutions, as long as they achieve the requiredresults. This is extremely good news, especially for budget-strapped healthcare facilitiesas they can opt for the use of fixed or portable devices in lieu of much more costlyfacility engineering solutions.

Designing and building a negative-pressure isolation room or converting an existingpatient room for this purpose can drive the cost to $55,000 or more. HFDs, which can befixed units that mount into the ceiling or onto a wall, or portable devices that can bewheeled from room to room, generally cost $2,000 to $5,000. As a result, an increasingnumber of healthcare facilities are choosing to use HFDs to achieve the six to 12 airchanges per hour (ACH) as recommended by the CDC. Portable HFDs are especially popular asthey can be used to convert quickly and economically a standard patient room into a TBisolation room or treatment room and can be moved from room to room as needed.

Exhaust air from HFDs can be ducted through a side wall, ceiling plenum, or patient'swindow in accordance with state and local regulations concerning environmental discharges.Also included in the proposed regulation is use of a continuous monitoring device, backedup by a monthly smoke-trail test to confirm the presence of negative pressure. HFDs mustalso be maintained and inspected for filter loading and leakage every six months, wheneverfilters are changed, and more often if necessary to maintain effectiveness.

Evaluating HFDs

When evaluating an HFD, the performance factors required for the specific application,not just initial cost, should be considered. Operational airflow, filter efficiency,security, ease of operation, overall quality, performance verification, manufacturer'sreputation, and total operating costs are all important considerations.

When considering the purchase of a HEPA filtration system, review the quality of thematerials and workmanship. Look at the installation and operating manuals if possible.Request information about the manufacturer's product warranty. UL, CSA, or anothernationally recognized testing laboratory (NRTL) should approve the system. Also, determinehow long the manufacturer has been in business and ask for references from at least 10health facilities using their equipment. Ask the appropriate individuals at the facilitiesabout performance, installation, maintenance, and energy consumption.

The concern for controlling TB in the healthcare community will continue to rise.Failure to provide the necessary protection to healthcare workers, currently enforcedunder OSHA's "general duty clause" has resulted in hospital fines ranging from$5,000 to $150,000. Healthcare facilities must become proactive to control the risk ofinfection to workers and patients alike.¹ In-room HEPA filtration devicesprovide an economical and efficient alternative for meeting national standards andproviding protection for healthcare workers, patients, and visitors. The flexibility ofthese units appears to be endless in the attack on TB and other airborne pathogens. Awell-designed system is an important component of every healthcare facility's infectioncontrol program.P

David Willyard, vice president of Abatement Technologies, Inc., (Duluth, Ga), amanufacturer of HEPA filtration devices. Abatement Technologies' HFDs are used by morethan 500 healthcare facilities throughout North America for controlling TB and otherairborne pathogens.

1. OSHA Memorandum: Enforcement policy and procedures for occupational exposure to tuberculosis, memorandum to regional administrators from directorate of compliance programs. October 8, 1993.

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