facilities under its general duty (which provides that employers maintain a safe workplace) and its respiratory protection standard.3 In addition, many state governments and private agencies periodically inspect health care and other facilities to determine compliance with regulations or voluntary standards. As described in Chapter 4, some of these regulations and standards include provisions related to tuberculosis control measures, although the committee found no overall summary of state regulatory requirements or accreditation requirements. Committee members were aware of institutions that had been cited or questioned by state agencies or accrediting organizations about tuberculosis control measures during visits by the state licensure agencies and the Joint Commission on the Accreditation of Healthcare Organizations.
In addition to such routine inspections, inspections may also be prompted by complaints by patients, families, health care workers, or others. The facilities involved in these kinds of complaint-generated inspections may not be representative. In addition, a few on-site inspections were specifically prompted by state concern about facility readiness to cope with the increasing rates of tuberculosis seen in the late 1980s and early 1990s.
Although inspectors often rely on responses to written questions and written records, they may have the opportunity to conduct more flexible, open-ended interviews with facility personnel and to view or test the physical plant, equipment, and work practices. Such inspections are laborintensive and expensive, which limits their number and scope.
Between May 1992 and October 1994, OSHA inspected 272 health care, correctional, and other facilities to assess compliance with the tuberculosis control measures that were described first in a May 1992 OSHA Region 2 directive and then in a nationwide enforcement policy (McDiarmid et al., 1996). Inspections in New York and New Jersey accounted for a substantial proportion of the total. Worker or union complaints prompted most inspections (71 percent). Hospitals accounted for almost half of the workplaces inspected. Basic citation data were available for nearly all the facilities, but detailed questionnaire data were available for only 149 facilities.
Inspectors found compliance with recommended tuberculosis control measures to be quite variable. It was best, overall, for administrative controls. For example, annual tuberculin skin testing was reported for better than three-quarters of hospitals, prisons, shelters, and nursing homes.
As described in Chapter 4, OSHA revised its 1987 respiratory protection standard in 1998. Pending publication of the standard on occupational tuberculosis, the 1998 general standard did not cover tuberculosis, which instead was covered by special interim regulations.