6.09 – Tuberculosis Control Plan
Purpose
The purpose of this plan is to document all components of Open Door tuberculosis control program developed to prevent the spread of TB to employees and the general community.
Responsibility
The Medical Services Manager is responsible for coordinating the TB Control Program throughout the company. A master copy of this plan will be kept in the Executive Director’s office and additional copies distributed to all policy manuals. This plan will be reviewed and revised at least annually and more often as needed by the Infection Control Committee.
Hierarchy of Control
In accordance with the recommendations from the CDC, this plan is based upon hierarchy of controls. While each is important, the first level of protection includes administrative controls to include policies and procedures for early identification, isolation, evaluation, and treatment of persons known or suspected of having TB and proper work practices to protect the health care provider.
The second level of control measures include engineering controls such as ventilation and exhaust controls and filtration.
The last level of defense to be used when the above two measures cannot render the environment free from the hazards of contamination from TB organisms is a respiratory protection program.
Exposure Determination and Task Identification
All employees would have the potential for occupational exposure; however, no active TB individuals are admitted to the departments of Open Door.
This facility has been determined to be very low risk based upon the CDC recommended risk assessment protocol. The risk assessment was conducted and evaluated by the Infection Control Committee.
Early Identification of Persons with TB
Employees have been trained in the epidemiology of TB and the need to report to their supervisors themselves or any person who has symptoms suggestive of TB. The supervisor must immediately evaluate the situation and take steps to prevent the potential transmission of TB to others. He supervisor will seek assistance from the Medical Services Coordinator. Additionally, it may be necessary to seek consultation with the local or state TB control staff. Symptoms of TB are: persistent cough greater than 2 week duration, hemoptysis, weight loss, chills and/or night sweats, anorexia, and fever. The index of suspicion should be higher for immunosuppressed persons (e.g. HIV infected person) who exhibit any pulmonary symptoms and they should be evaluated for co-existing TB.
During the initial evaluation process, the employee is placed on administrative leave until such time that a determination is made regarding communicability and insurance that the employee does not constitute a risk of TB transmission.
Personal Respiratory Protection Program
A respiratory protection program is not applicable to this facility due to the very low risk factor and no individual are admitted with active TB.
Employee Surveillance, Evaluation, Management and Counseling
- Routine Surveillance – all employees shall be offered TB skin tests (at no cost to the employee). Medical surveillance, follow-up evaluation and medical management are coordinated by the Medical Services Coordinator.
- Health Care Work Screening – TB Skin Testing and Interpretation Initial Hire – Mantoux PPD Skin test is done at the time of employment using the two-step method. If the first step is negative the second step must be given within 21 days or no longer than 3 weeks after the first step was administered. If either the first or the second PPD is positive, a follow-up chest x-ray must be done and the employee evaluated for active disease within 5 working days. Medical Services Coordinator is responsible for immediately evaluating the need for work restrictions during his/her evaluation process. It may be necessary to consult with state and local TB control staff for assistance. Interpretation and follow-up management and/or preventative therapy will be made according to the current CDC Guidelines. (These guidelines will be updated as new information is provided). If the new employee can show documentation that he/she has had a 2-Step Mantoux PPD skin test done within the past year, their annual PPD will follow.
Employee with a Documented History of a Positive PPD
Employees with a documented history of a positive Mantoux PPD are exempt from the tuberculin skin test (TST) and instead, are evaluated on initial hire for active disease by a chest x-ray and health assessment. Annually thereafter and more often if necessary, employees with a positive skin test are medically evaluated for the presence of symptoms for pulmonary disease and followed up accordingly. The employee is counseled at the time of hire on the importance of reporting symptoms suggestive of TB to his/her supervisor who will refer the employee for proper follow-up. The health assessments are kept on file in the employee’s health records. Following the initial chest x-ray for PPD positive employees, routine chest films are not required nor recommended for the asymptomatic employee. Chest x-rays need only be repeated if the employee develops symptoms suggestive of TB. At that time an evaluation will also be made by the medical practitioner or designee responsible for employee health assessments regarding the need for work restriction and sputum examination for the presence of AFB.
BCF Vaccine
BCG Vaccine is not a contraindication for TST and a positive test of greater than 10mm of induration should be interpreted as a positive test and the employee evaluated for active disease.
Pregnancy
TST is not contraindicated during pregnancy. Both CDC and the Ohio Department of Health recommend testing pregnant females because of the increased risk of TB disease for infected females following delivery.
Counseling Regarding TB and the Immunosuppressed Employee
Immunosuppressed employees are counseled about the potential risks associated with caring for patients with any transmissible infection, including TB, and are informed of the importance of following good infection control practices and complying with the facility’s existing infection control policies to minimize the risk of exposure to infectious agent.
Work Restrictions for Confirmed/Suspected Active TB Disease
Health care workers with active disease such as pulmonary or laryngeal TB should be excluded from work until determined to be non-infectious. A non-infectious state is generally determined by a reduction in symptoms and three consecutive sputum smears negative for AFB. It may be necessary to consult with state or local TB control staff for assistance. Interpretation and follow-up management and/or preventative therapy will be made according to the CDC Guidelines by Medical Services Coordinator. These guidelines will be updated as new information is provided.
Engineering Controls
There are no high-hazard procedures performed by employees at this facility. Therefore, no engineering controls are in place.
Employee Notification of TB Hazards
When an exposure incident is suspected, the employee must immediately notify his/her supervisor. The supervisor will notify the Medical Services Coordinator who is responsible for investigating the circumstances and coordinating the follow-up as necessary. The follow-up is coordinated with consultation from the local or state TB staff.
Patient Care Practices
Since Open Door employees do not provide direct patient care to TB patients, this section will not be addressed.
Health Care Workers TB Training and Education
All employees who have the potential for exposure to TB are trained at the time of hire and updated annually regarding the hazards and control of TB. The training is conducted by the Medical Services Coordinator/designee and includes at least the following elements: hazards of TB transmission in health care facilities, epidemiology of TB (include signs and symptoms, distinction between TB disease and TB infection, preventative therapy and treatment for active disease, risk factors, information about multi-drug resistant TB), medical surveillance and therapy policies, and the purpose and proper use of TB controls specified to this facility.
Coordination with the Public Health Department
As required by OAC 3701-3-02, all suspected or confirmed cases of TB will be reported within 24 hours (one working day) by the Medial Services Coordinator to the local TB control staff. All evaluation and follow-up activities will be done by the Medical Services Coordinator in consultation with the local TB control agency.
Record Keeping
Employee exposure records and medical records are handled according to OSHA Enforcement Policy on Occupational Exposure to TB, 29CFR 1913.10 and 1910.20 (refer to OSHA Enforcement Policy for TB). All aspects of the employee’s assessment and/or management are confidential and will be filed in the health management record. This will include employee exposures, TB skin testing results, medical evaluations and treatment. All TB infections (positive TB Mantoux skin tests) and TB disease are recorded on the OSHA 200 log. A positive skin test even on baseline (pre-employment screens not required) is recorded on the OSHA 200 log. If an employee with TB infection (originally entered on the OSHA 200 log) progresses to active TB disease during the 5 year maintenance period, the original entry for the infection shall be updated to reflect the new information.
Glossary
AFB – Acid fast bacillus
BCG – Bacillus of Calmette-Guerin vaccination, an attenuated bovine organism used primarily in countries other than the U.S. to induce an immune response prior to TB infection. Used primarily for infants to prevent morality from military and meningeal TB
CDC – Center for Disease Control and Prevention
Mantoux – Intracutaneous method of skin testing for TB (preferred method)
MRD-TB – Multiple drug resistant TB
MTB – Mycobacterium tuberculosis
NIOSH – National Institute for Occupational Safety and Health
OSHA – Occupational Safety and Health Association
PPD – Purified Protein Derivative
TB – Tuberculosis
TST – Tuberculin Skin Test
UVGI – Ultraviolet germicidal irradiation
Last Revised: 6/6/22
