Ask the expert: OSHA potpourri—TB skin tests, postexpsoure evaluation, and HBV titers

By: March 29th, 2010 Email This Post Print This Post

Q: I just attended an OSHA course and I believe I was given incorrect info. I was told: dental offices must test employees yearly for TB;  an employee cannot refuse evaluation by a health care provider after a needlestick; titers are not required after a hepatitis B vaccination.  Can you clarify these topics?

A: I think you may have received some incorrect advice, at least if the instructor purported it to be OSHA-specific. Hopefully the information below will clear up some of your questions.

TB testing
OSHA does not have a TB standard so it is not in a position to make it a blanket requirement that all dental practices must test workers for TB every year. It is the CDC TB guidelines that recommend two-step baseline tuberculin skin test (TST) for new hires in all healthcare settings.

Serial TSTs after that is based on the risk level of the setting. Low risk does not require annual testing while moderate risk levels does.

Finally, dental practice may be required to test annually, but that requirement usually would come from the state department of health because it as adopted the CDC recommendations, not from federal OSHA.

Mandatory psotexposure evaluation
Concerning post-exposure management of needlesticks, an employee my decline treatment and evaluation.

OSHA requires that the employer offer an evaluation and explain that it is at no cost to the worker.

Be sure to document anytime an employee delines treatment of evaluation after a work-related injury.

Titering after HBV vaccination
Finally, OSHA is very clear about requiring titers after the hepatitis B vaccination. See the OSHA interpretation letter, “03/10/2000 – HBV antibody testing is required after vaccination series; HBV booster not required.” It doesn’t get any clearer.

The Updated U.S. Public Health Service (USPHS) Guidelines for the Management of Occupational Exposures to HBV, HCV, and HIV and Recommendations for Postexposure Prophylaxis reiterates this point. The Bloodborne Pathogens standard requires employers to follow USPHS recommendations in the areas of hepatitis B vaccination and postexposure management. See section (f)(1)(ii)(D) of the Bloodborne Pathogens standard.

When someone tells you that OSHA requires something, it’s always best to ask them to show you in writing where it says that, or at least site the reference. See my post Ask the Expert—Don’t fall for all red flags.


By Kimberly McHatton on April 6th, 2010 at 1:40 pm

What if an employee received 2 of the 3 vaccines and it has been >6 months since the 2nd dose- should you just give the 3rd dose or repeat the series? Thanks

By David LaHoda on April 6th, 2010 at 1:55 pm

Continue with the third dose then titer. If the titer shows the worker is a non-responder, repeat the series and titer again, according to Hepatitis B and the healthcare worker by the Immunization Action Coalition.

By Sandy Montgomery on April 6th, 2010 at 4:57 pm

We send all our staff to an occupational health center for follow-up post exposure, after the last sharps injury the employee was informed since her labs and the source labs were normal she did not have to return for follow-up labs at 6 weeks and 6 months, is this correct?

By David LaHoda on April 6th, 2010 at 5:34 pm

Depending on the circumstances of the needlestick, that could be correct.

When you contract out for occupational safety and health services, OSHA places the responsibility on you, the employer, to make sure that post-exposure management and evaluation contractors are following the Untied States Public Health Service (USPHS) guidelines. Essentially, you are responsible for making sure you are referring your staff to experts who know what they are doing.

Check your contract to see if it references USPHS guidelines, and if not, make sure that you have assurance that the services are being provided in accordance with:

Updated U.S. Public Health Service Guidelines for the Management of Occupational Exposures to HBV, HCV, and HIV and Recommendations for Postexposure Prophylaxis

Updated U.S. Public Health Service Guidelines for the Management of Occupational Exposures to HIV and Recommendations for Postexposure Prophylaxis

By Carolyn Weber on April 8th, 2010 at 9:45 am

If employees are hired and have proof of HBV vaccination from before hire, but never had a titer after vaccination, are we required to have them get a titer?

By David LaHoda on April 9th, 2010 at 9:02 am

Such a good question that I answered it in a separate post. Click here.

What if someone gave the wrong dose of the tb vaccine to a patient??? Like the whole vial of medication to the patient??

What is the standard for prescreening staff who will be handling chemotherapy drugs? Some facilities require baseline CBC/Retic count/BUN and some only test if there is an exposure and do follow up testing 10 days later. I am interested in what is best practice. When reviewing baseline and annuals on chemo staff and non chemo staff I find there are various changes in both. Is doing prescreening necessary?

By David LaHoda on August 25th, 2010 at 1:11 am

There are not definitive standards for prescreening staff for hazardous drug exposure and some of the recommendations that are out there are dated. I advise going to the NIOSH Hazardous Drugs Exposures in Health Care Web page since that organization at least seems to have the problem on its front burner. Also, see the Medical Surveillance sections in Preventing Occupational Exposure to Antineoplastic and Other Hazardous Drugs in Health Care Settings and the the OSHA Technical Manual, SECTION VI: CHAPTER 2:CONTROLLING OCCUPATIONAL EXPOSURE TO HAZARDOUS DRUGS.

If anyone knows of other links to best practices for concerning hazardous drug exposure in healthcare, post them in the comment section.


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