Ask the expert: OSHA and TB skin tests
Q: What is the OSHA policy on TB skin tests?
A: OSHA does not have a specific standard for TB, but as a recognizable hazard, especially in healthcare settings, it looks to the CDC for guidance.
The current Guidelines for Preventing the Transmission of Mycobacterium tuberculosis in Health-Care Settings, 2005 calls for facilities to do a TB risk assessment annually. The results of that risk assessment will define the frequency, if any, for tuberculin skin testing (TST) of staff members.
If you are a low-risk facility, annual TSTs are not recommended, but baseline two-step testing is recommended for all new employees, according to the Guidelines (see Appendix C: CDC Risk Assessment Classification for Healthcare Settings).
This is not mandatory, as the CDC does not regulate, but if you have an exposure incident, you might be hard pressed to explain to OSHA, or more likely your state department of health, many of which have specific TST requirements, why you chose not to follow CDC guidelines.
Also, from an infection control and patient safety perspective, you would want baseline TB data on staff members should you have to respond to an exposure or outbreak in your facility.
The Guidelines have a risk assessment worksheet. The OSHA Healthcare Advisor tools page has a downloadable TB Risk Assessment for Ambulatory Settings that you might find easier to use for your setting.
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