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Tuberculosis in the Workplace
Cleaning, repairing, and replacing respirators as appropriate
Providing respirators to those who are visiting patients with tuberculosis in isolation rooms and instructing visitors in their use
NOTE: The proposed OSHA rule does not mention visitors.
SOURCES: CDC (1994b), and 62 FR 201 (October 17, 1997).
must have a respiratory protection program as required by OSHA. The guidelines include a supplement that discusses considerations in selecting a respirator and developing a personal respiratory protection program. In addition to referring to OSHA regulations, the 1994 guidelines also refer to a 1987 NIOSH guide. NIOSH issued a new users guide for respirators in 1998 (NIOSH, 1999; see also NIOSH, 1995, 1996).
Respirator Use Outside Isolation Rooms
The 1997 proposed OSHA rule requires respirator use when workers are either transporting unmasked individuals with suspected or confirmed infectious tuberculosis or when they are working outside isolation rooms in areas where such unmasked individuals are confined (e.g., while awaiting transport to another facility). The CDC guidelines call for masking of patients in these situations, but they also provide more generally for the use of respirators “where administrative and engineering controls are not likely to protect them” (CDC, 1994b, p. 33). The proposed rule states that OSHA cannot require masking of patients and notes that some combative individuals may not accept masking. If a known or suspected infectious person cannot be masked, then the worker transporting him or her must have personal respiratory protection.12 In the latter situation (patients not masked), protection would not be provided to others who come near the patient (e.g., including workers, visitors, and other patients who share an elevator). The proposed rule has other provisions intended to protect such individuals, for example, the requirement that exposure control plans include policies to delay the moving of patients until they are no longer infectious unless a delay would compromise care.
Reflecting its broader perspective, the CDC guidelines stress that respiratory protections used by health care workers should protect both the worker and patients. For example, workers involved in surgical proce-
Although OSHA arguably could require employers to make a practice of masking patients when necessary to create a safe workplace, it could not require patients or other nonregulated persons to comply with such requirements. If a patient refuses to wear a mask or otherwise comply with the institution’s rules, the institution can (and, arguably under OSHA, must) take action to either secure compliance or eject the person from the facility. Such action would be based on the institution’s proprietary authority or on public health law or some other body of law that gives it the power to act against a dangerous or unruly person.