victuals, whether masked or not, in enclosed vehicles, or (4) otherwise work in areas where they may be exposed to contaminated air.4
The 1994 CDC guidelines are ambiguous for one low-risk situation involving facilities that are located in communities with tuberculosis, that have a policy of referring tuberculosis patients, and that have not admitted a tuberculosis patient within the preceding year. Workers in such facilities may be exposed to infectious tuberculosis while evaluating a patient in an emergency department or other area. The guidelines advise that these workers “may” need to be included in a respiratory protection program. The 1997 proposed OSHA rule appears to require explicitly that employers provide respirators to such workers if a patient is being evaluated because tuberculosis is suspected.
Although the proposed OSHA rule seems to require the use of personal respirators for workers in a few situations that are not clearly covered by the CDC guidelines, the committee could not determine how many additional employers or employees might be affected. In general, both the proposed rule and the guidelines focus their respirator use provisions on the worker’s reasonably anticipated risk of exposure rather than the facility’s risk category.
Requirements for Fit Testing As described in Chapter 4, both the 1994 CDC guidelines and the 1997 proposed OSHA rule provide for initial training and fit testing for workers who use personal respirators. Consistent with the then-applicable 1987 OSHA respiratory protection standard, the 1994 guidelines do not mention annual fit testing. Consistent with the 1998 respiratory protection standard (see Chapter 4), the 1997 proposed OSHA rule provides for an overall respiratory protection program that includes both initital and annual fit testing.
In general, it seems rather a common-sense proposition that any workers who are provided with new safety equipment (such as a personal respiratory device) should also be provided some initial training in the equipment’s proper use and maintenance and some continuing education to remind them about when and how it is to be used. Likewise, if the equipment differs by size, shape, or other characteristics to accommodate individual physical differences, then some kind of initial fit evaluation also seems generally plausible.
Administratively, a program for fit of testing personal respirators requires trained personnel to conduct a complicated series of tests. New
The CDC guidelines do not specifically mention workers repairing air systems likely to contain airborne M. tuberculosis. Such workers would, however, seem to be covered under the guideline’s more general language specifying the use of personal respirators by workers in “other settings where administrative and engineering controls are not likely to protect them from inhaling infection airborne droplet nuclei” (CDC, 1994b, p. 97).