Safety Tidbit #35 – Respirators for TB

Safety Tidbit #35 – Respirators for TB

I recently had a client at an emergency medical services facility ask me for more definitive information about why his emergency medical providers must wear respirators when they have a suspected patient with tuberculosis.  Actually, his headache started when I told him that the medical providers that wear respirators must be clean shaven so as not to interfere with the effective sealing of the respirator when worn. 

Since OSHA does not have a specific standard on Tuberculosis, let’s start out more generally and work to the specifics.  Section 5A of the OSH Act states: “(1) each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees; and (2) shall comply with occupational safety and health standards promulgated under this Act. Now, I believe we can all agree that TB can be infectious and is serious hazard.  However, if you prefer, the Centers for Disease Control (CDC) has provided extensive information on TB in Healthcare Settings which you can read that at your leisure.

Now, moving to more specifically, OSHA’s respirator standard, 1910.134(a)(1) states: “In the control of those occupational diseases caused by breathing air contaminated with harmful dusts, fogs, fumes, mists, gases, smokes, sprays, or vapors, the primary objective shall be to prevent atmospheric contamination. This shall be accomplished as far as feasible by accepted engineering control measures (for example, enclosure or confinement of the operation, general and local ventilation, and substitution of less toxic materials). When effective engineering controls are not feasible, or while they are being instituted, appropriate respirators shall be used pursuant to this section.”

Now, as far as I know, there is no feasible engineering control which can be installed in the ambulance to prevent atmospheric contamination.  Therefore, we are left with personal protective equipment, more specifically respirators and minimally N95-filtered respirators to meet 1910.134(d)(1)(i). Furthermore, the employer must establish and maintain a respiratory protection program (RPP) including all of the elements in 1910.134(c). Which, when the RPP is implemented, one requirement is to fit-test each user annually [1910.134(f)(2)]. Although this requirement has had a bit of a muddied past, currently, fit-testing is required as per a letter of interpretation dated March 24, 2008. And lastly, and most specifically, the employer can not allow workers to wear tight-fitting facepieces (e.g., N95 respirators) who have facial hair that comes between the sealing surface of the facepiece and the worker’s face [1910.134(g)(1)(i)(A)]. 

Ultimately, to answer the workers’ original concern, emergency medical response personnel can have exposure to TB (especially in the back of the response vehicle). Therefore, they must be protected and the currently feasible protection is to provide an N-95 respirator.  Which means the workers must be clean shaven to properly and effectively wear the respirator.  Remember TB is only one potentially infectious airborne disease (remember SARS?).

If you wish much more information please refer to OSHA’s Safety and Health Topics Page at https://www.osha.gov/SLTC/tuberculosis/index.html.

Hope this was helpful.  Thanks for reading!