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

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 [1] 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.” [2] 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 [3] 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. [4]

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. [5]