stands that new recommendations may be published sometime in 2002. OSHA could adapt its requirements for tuberculin skin testing to changes in CDC recommendations, for example, by declaring departures from the testing requirements in the standard to be de minimus violations (i.e., unimportant and not subject to citation or penalty). More straightforward, the standard could be revised to state that OSHA requirements for skin testing would follow CDC recommendations.

Requirements for Respiratory Protection Program

Much of the concern about the 1997 proposed OSHA rule has focused on the requirements for personal respiratory protection. When the CDC guidelines were published in 1994, they, too, were criticized for their recommendations for respiratory protection. Some of the criticism involved the cost and complexity of the limited choice of personal respirators that met the criteria set forth by the CDC in 1994. Much of that criticism abated soon thereafter when the National Institute for Occupational Safety and Health approved the relatively inexpensive and simple N95 respirators.

Earlier sections of this report describe personal respiratory protections as the third element in CDC’s hierarchy of tuberculosis control measures. As discussed in Chapter 6, outbreak studies support this hierarchy and suggest that most of the benefit of control measures comes from administrative and engineering controls. Modeling exercises support the tailoring of personal respiratory protections to the level of risk faced by workers—that is, more stringent protection for those in high-risk situations and less stringent measures for others.

The following discussion considers first the workers targeted for respirator use by the 1994 CDC guidelines and the 1997 proposed OSHA rule. It then examines the requirements for fit testing of personal respirators.

Requirements for Respirator Use Although the respiratory protection requirements of the 1997 proposed OSHA rule have been criticized for inflexibility, the proposed rule and the 1994 CDC guidelines mostly target the same types of workers for use of personal respirators. The wording differs, but both essentially call for workers to be provided personal respirators if they (1) enter isolation rooms housing people with known or suspected infectious tuberculosis, (2) are present when certain high-hazard procedures such as bronchoscopies are performed on individuals with known or suspected tuberculosis,3 (3) transport such indi-


The CDC guidelines (but not the proposed OSHA rule) also mention that workers performing such procedures might sometimes need more protective respirators (e.g., powered air-purifying respirators).

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