COMPARISON OF GUIDELINES AND PROPOSED RULE: ADMINISTRATIVE CONTROLS

This and the next two sections of this chapter summarize and discuss the administrative, engineering, and personal respiratory protection provisions of the 1994 CDC guidelines for health care facilities. Because OSHA relied heavily on the CDC guidelines, in drafting its proposed rule, the summaries are organized around the guidelines with points of difference between the two noted in italics. The descriptions of control measures and differences in the guidelines and proposed rule were reviewed by both OSHA and CDC staff and revised as appropriate.

In its commentary on the proposal, OSHA identified some differences between the guidelines and the proposed rule. Other differences were identified in comments submitted to OSHA by various organizations including the American Hospital Association (AHA) (AHA, 1998) and the Association of Professionals in Infection Control and Epidemiology (APIC) (APIC, 1998). The committee’s own review of the CDC guidelines and the proposed OSHA rule found a few additional points of difference.

Some control measures are discussed in more detail elsewhere in this report. Tuberculin skin testing and diagnosis and treatment for latent tuberculosis infection and active disease are discussed in Chapter 3. Appendix B provides a more detailed examination of the skin test. Respiratory protections are discussed further in Appendix F.

The following discussion does not cover the 1992 CDC guidelines for those serving homeless people. The 1997 proposed OSHA rule would require homeless shelters to follow essentially the same procedures required for correctional facilities and hospitals that refer rather than treat people with suspected or confirmed tuberculosis. In 1999, acknowledging serious concerns about the practicality and cost of the requirements for homeless shelters, OSHA reopened the comment period and record on the proposed rule to solicit additional information and comments on requirements for homeless shelters. In a presentation to the committee, OSHA staff have suggested that the final rule may include fewer requirements for homeless shelters.

Administrative Controls Related to Risk Assessment, Surveillance, Worker Education, and Coordination

Table 4-1 summarizes most of the key elements of the administrative controls recommended in the 1994 CDC guidelines for health care facilities. (The elements related to patient management are summarized in the next section of this chapter.) The italicized comments in the table highlight the differences between the CDC guidelines and the proposed OSHA rule that might influence the effectiveness or the burdensomeness of a final rule. A discussion of some of the differences follows the table.



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