OSHA MODIFIES ITS TB REGULATIONS

OSHA has finally modified and strengthened their regulations for occupational exposure to TB. The regulation CPL2.106 of February 9th, 1996 contains the latest revisions. Important points of the new regulation that you can use in your discussions with concerned professionals and potential customers are:

  • This regulation refers to CDC 10/26/94 Guidelines for Preventing the Transmission of Mycobacterium Tuberculosis in Health Care Facilities as the primary technical reference "OSHA believes these guidelines reflect an industry recognition of the hazard as well as appropriate, recognized and accepted standards of practice to be followed by employers in carrying our their responsibilities under the OSH Act."

  • This is a federal program change, which will require state programs to update their practices within 70 days. (until that time and even after, you may find lack of understanding among state-level OSHA people)

  • Evaluations will be in response to employee complaints, related fatality/catastrophes or as a part of all industrial hygiene inspections conducted in workplaces where CDC has identified workers as having greater incidences of infection than the general population.:

    1. Health care facilities

    2. Correctional institutions

    3. Long term care facilities for the elderly

    4. Homeless shelters

    5. Drug treatment centers

  • Violations of these requirements are normally classified as serious, and are cited under the general duty clause of the OSHA regulations -Section 5(a)(1)- one of the most comprehensive and general sections.

  • Engineering controls are addressed, and briefly summarize the CDC guidelines. Negative pressure isolation rooms, HEPA filtration of return (exhaust) air, exhaust directly to the outside, assurance that the rooms are under negative pressure (monitoring), testing to assure HEPA effectiveness is maintained, and the use of purge time between use of any room with TB exposure and other uses. OSHA specifically mentions that "the use of UV radiation as the sole means of decontamination may not be used." However, UV is stated to be able to be used in other areas such as waiting rooms. CDC, of course, allows the use of UV with HEPA filtration.

This regulation indicates there is growing pressure on employers to do something significant to reduce exposure to TB. In addition to the primary benefits our NQ units brings to the healthcare environment, you can add another, compliance with OSHA regulations and avoidance of costly and embarrassing citations! This should help you in explaining the benefits of Nature’s Quarters units, and in closing sales more quickly.

Don’t forget the CDC table S3-2 ‘Hierarchy of Ventilation Methods’ has our NQ-type of filter units listed in three out of the four solution methods! This was mentioned in a previous flash message.

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