OCCUPATIONAL MEDICINE ABCs
(DICO), then treatment may be delayed or
unnecessary treatment ordered. Your designated officer needs to be able to access these
records at any time in an exposure situation.
compliance monitoring. Compliance monitoring is a required component of OSHA’s
exposure control plan.
The CDC and OSHA also have requirements for annual data collection as part
of annual education and training and
exposure control plan updates. Annual
reporting of sharps-related injuries, TB risk
assessment and airborne/droplet exposures should occur.
There’s also a need to support the TB risk
assessment by conducting TB conversion
rates. TB conversion rates are new positive
TB tests in department personnel since the
last testing period.
This information should be provided by
the occupational medicine practice, especially if they are administering TB testing.
Departments should also be provided with
information regarding the percent of personnel that do not return in time to have
their TB skin tests read at 72 hours and have
to have them repeated.
This adds to department cost and may
enter into a decision to switch over to one
of the TB blood test that doesn’t require a
return visit or a two-step testing process. A
department’s need to perform annual TB
testing depends on the number of active
untreated TB patients that the department
transported in the previous 12 months.
Many occupational medicine groups aren’t
aware of this and are still advising annual
skin testing. Is it better to just do annual testing anyway? No. Continuing annual testing
when not needed may lead to false positive
test results. More is not always better.
The CDC is now asking that compliance
rates with annual flu vaccine be reported
annually and that this information be incorporated into annual training in an effort
to boost participation. This information
should also be tracked and provided by the
occupational medicine group. Occupational
medicine groups should be spearheading
the effort to increase participation rates.
Exposure data should be reviewed on
an annual basis and determination made
regarding the number that may have been
preventable, and recommendations for prevention and educational needs be offered.
This may assist in the identification of
purchasing needs and serves as a form of
WORK RESTRICTION GUIDELINES
When should you be at work and when
should you stay home due to illness? Work
restriction guidelines were originally published by the CDC in 1997 and were updated
in November 2011, and should be part of
each department’s exposure control plan
used by the occupational medicine group.
The guidelines offer clear information on
when staff is fit for duty or when they should
be off duty. Working when ill increases your
risk because your immune response is lowered and poses a risk for transmission of
your illness to co-workers.
Are these guidelines in place in your
department? Vaccine declination forms
are an OSHA requirement and are also
addressed by the CDC and in NFPA 1581.
Is your occupational medicine group collecting them? Your department should get
a report on the percent of declination forms
signed and an evaluation of the reasons for
no oversight to ensure compliance and no
cost analysis. Is your department being told
you need annual TB testing no matter what
your risk assessment shows? Similarly, is
your department being told that annual
hepatitis B titers are needed annually or
that hepatitis B titers are to be performed on
all new hires?
If the answer to any of these questions is
“yes,” then there’s a problem. None of these
is recommended by the CDC, and an audit
for OSHA and CDC compliance is in order.
The department’s DICO officer can play
an important role in performing this audit,
and a relationship should be established
between the DICO and occupational medicine service.
The DICO serves as a liaison between the
department and the treating entity for compliance and quality monitoring. The DICO
works to benefit department members, but
they also work for administration to ensure
compliance and quality of care. Remember,
the CDC guidelines set the standard of care,
and OSHA enforces most of them, but ultimately, the department is held responsible
The practice of occupational medicine is
much more than simply the administration of hepatitis B vaccine, flu vaccine and
TB testing. It also involves the collection of
data important to maintaining health and
safety of personnel in a department. Because
the occupational medicine practice works
for your department on a contract basis,
conducting an audit for OSHA compliance
and ensuring the CDC guidelines are being
followed is important. OSHA is responsible
for enforcing many of the CDC guidelines,
and if they’re not followed, a citation is given
to the department.
When contracting with an occupational
medicine group, your department should
present a list of identified needs, and ask if
they can be delivered and at what cost. Using
a letter of agreement is also a good idea.
The letter should state that the practice will
adhere to the CDC guidelines. This offers
added legal protection for your department
because the CDC guidelines are the medical
standard of care.
Many departments put these responsibilities and compliance in the hands of
the occupational medicine practice with
1. Occupational Health & Safety Administration.
CPL 02.-02.069: Enforcement procedures for the
occupational exposure to bloodborne pathogens, occupational health & safety administration, Nov. 27, 2001. In U.S. Department of
Labor.Re trieved Nov. 1 2012, from www.osha.
2. Advisory Committee on Immunization Practices:
Centers for Disease Control and Prevention
(CDC). Immunization of health-care personnel,
recommendations of the advisory committee on
immunization practices (ACIP).MMWR Recomm
Rep.2011; 11( 60): 1–3.
3. Jensen P, Lambert L, Iademarco M, et al. Guidelines
for preventing the transmission of
mycobacterium tuberculosis in health-care settings.
Morb Mortal Wkly Re. 2005; 12( 54):1–141.
4.Center for Disease Control & Prevention.
Evaluation of results from occupational tuberculin skin tests: Mississippi, 2006. MorbMortalWkly
Re. 2007; 56( 50): 1,316–1,318.
Katherine West, BSN, MSEd, CIC, is an infections control
consultant for Infection Control/Emerging Concepts,
Inc. and a member of the JEMS Editorial Board. Contact
her at Kwest8388@earthlink.net.