TABLE 4-1. Summary of Administrative Controls (other than diagnosis and treatment) Recommended by CDC for Health Care Facilities, with Notes (in italics) on How Proposed OSHA Rule Differs

Assigning Responsibility


Assigning responsibility for the control program to qualified person(s)


Ensuring that the program includes experts in infection control, occupational health, and engineering

NOTE: Assignment of responsibility to qualified individuals is implicit in the proposed OSHA rule.

Assessing Risk and Developing Tuberculosis Control Plans


Analyzing tuberculosis in the community: incidence, prevalence, drug resistance

NOTE: The proposed OSHA rule would require county-level information and assessment for facilities seeking exemption from certain of the rule’s provisions.


Analyzing tuberculosis in the facility: laboratory results, discharge diagnosis including data on drug resistance, medical record review; by location(s) of treatment


Analyzing worker tuberculin skin test conversions by work area or category

NOTE: The proposed OSHA rule would not require assessment of laboratory results, data on drug resistance, medical records, or data on skin test conversions.


Matching a facility or area within a facility to one of several risk categories based on skin test conversion data and other factors (see Figure 4-1)

NOTE: The proposed OSHA rule does not explicitly rank facility risk levels and does not consider skin test conversion data in matching work area or job category characteristics to regulatory requirements


Periodically reassessing risk based on new community data, review of patient records, observation of work practices, etc.


Preparing and implementing written tuberculosis control plans consistent with level of risk identified in the assessment

a. Writing plans for each area of a facility and each relevant worker category

b. Selecting infection-control protocols for each relevant work area or job category

c. Disseminating plans to relevant managers and workers

d. Evaluating implementation of plans and revising it as appropriate

NOTE: The proposed OSHA rule would require annual review of the written exposure control plan and updating of the plan when necessary to reflect changes in tasks, procedures, engineering controls, or job classifications.

Establishing a Screening and Surveillance Program Consistent with the Risk Assessment


Providing two-step baseline tuberculin skin testing for those without a documented positive test result or a documented negative test result within the past 12 months (exceptions: when results for such testing suggest that no boosting is occurring, the two-step approach can be foregone; baseline testing is optional for minimal-risk facilities)


Providing periodic retesting at 3-, 6-, or 12-month intervals consistent with the risk assessment, area of employment, and employee characteristics

NOTE: The proposed OSHA rule differs slightly on requirements for baseline skin testing and different frequencies of testing for certain workers. Unlike the CDC guidelines, the proposed rule would require skin testing within 30 days of termination of employment.

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