Suggestions, criticisms growing in comments
Does standard penalize CDC-compliant hospitals?
The tuberculosis standard proposed by the Occupational Safety and Health Administra tion is drawing blistering criticism and suggestions for considerable revisions in written comments gleaned from the docket at the agency in Washington, DC.
Comments from several infection control professionals questioned the need for the rule, saying they were having no problems with TB and have implemented the TB guidelines by the Centers for Disease Control and Prevention.
"In essence, OSHA is penalizing hospitals that have adopted the CDC [TB] guidelines in good faith and rewarding those employers who were slack in health care worker safety," wrote Lorraine C. Krasinski, RN, MA, CIC, infection control coordinator for Mid-Hudson Health in Poughkeepsie, NY. "Hospitals that adopted CDC guidelines have to rewrite and reorganize their entire TB control program. The hospitals that did nothing can now begin to implement the OSHA standard without having wasted’ time and money implementing a program that is no longer useful’ to OSHA but in fact has been protecting health care workers since implementation."
Having to rewrite and reorganize TB control programs is "busy work" of the worst kind, she added, noting that the changes will confuse health care workers.
"Unnecessary expenditure cannot be justified trying to make the work environment totally safe’ from TB," she advised OSHA. "That will never happen. Scarce resources need to be spent responsibly. The CDC guidelines provide a measure of safety that approaches very nearly totally safe’ and is easily upgraded to address an increase in exposures from an unexpected occurrence or trend."
How do you skin-test outgoing employees?
Commenting on specific provisions in the proposed rule, Krasinski notes that the requirement to TB skin-test employees within 30 days of job termination was problematic because employers have no authority over outgoing workers.
"It is also a useless measurement," she noted. "Health care workers can convert up to 12 weeks after exposure, so what does this 30-day measurement prove?"
Likewise, requiring that workers be able to choose an "acceptable" respirator from several styles imposes an undue burden on the facility, she wrote.
"Having to keep a variety of styles in stock as well as having to provide whatever the health care worker chooses’ as acceptable will be costly as well as labor-intensive," she commented.
Echoing similar concerns were two infection control professionals from Riverside Mercy Hospital in Toledo, OH: Brenda L. Dubilzig, RN, CIC, manager of infection control/occupational health, and Karen B. Christie, RN, CIC, infection control practitioner.
"It is truly our opinion that the OSHA proposed rules are too late, redundant, and should be discarded," they noted. "The CDC has addressed the TB issue adequately and appropriately, and any further recommendations should come directly from them, as they are the experts in this arena."
Following the publication of the CDC guidelines, Riverside implemented a TB control plan over the next year that included engineering changes, education of staff, and adoption of a 12-page policy overseen by the infection control committee.
"It is our strong opinion that we have addressed the problem of the TB epidemic during its peak years," they stated in the comments. "Published data show that the rate of TB has since declined [to] lower than it has been in thirty years. The proposed OSHA rule is redundant and untimely. In our opinion, the epidemic is well under control. Adapting current policy to meet the OSHA proposed rule would require an inordinate amount of time, effort, and expense which we prefer not to do during a time when controlling costs in a competitive marketplace is vitally important."
The comments submitted by Dubilzig and Christie also took issue with the requirements of the proposed rule in the following areas:
• Our institution is considered "low risk" according to our policy and CDC guidelines. Only annual PPD skin testing is currently required. To implement every-six-months testing, in our opinion, is unnecessary, and would require an increase in the occupational health nurse’s time.
• We have determined departments, or certain people in departments, as potentially exposed to TB. To list all job classifications, as well as listing tasks and procedures for those only intermittently exposed, would be a very time-consuming task. It is our opinion we have identified all potentially exposed employees, and they are PPD-tested annually according to policy.
• Our policy requires repeat fit-test of respirators if facial shape has changed to warrant a change in size of respirator. To fit-test yearly, as the new rule suggests, is totally ridiculous. A simple question on the annual PPD test form would suffice. Anything beyond that would require an increase in occupational health nursing time, and in fact, may require a second nurse.
You have reached your article limit for the month. Subscribe now to access this article plus other member-only content.
- Award-winning Medical Content
- Latest Advances & Development in Medicine
- Unbiased Content