WASHINGTON, D.C. -- On
To the Editor:
I am writing in response to your
The article focuses in part on two OSHA regulatory measures intended to prevent tuberculosis (TB) exposure in healthcare settings. The first was a proposed TB rule that has since been withdrawn, due to the lack of science to support it; the second, is a new mandate requiring the annual fit-testing of respirators for occupational exposure to TB.
This requirement went into effect without first allowing a public comment period a blatant breach of the Administrative Procedures Act and is also without scientific merit. The Association for Professionals in Infection Control and Epidemiology (APIC) has long led the opposition to these OSHA policies, working with a cadre of well-respected nonprofit organizations that span the spectrum of health care. APIC has approximately 10,000 members, the majority of whom are nurses first and infection control professionals second. We want to be protected from occupational hazards such as TB but we are already protected by guidelines issued by the Centers for Disease Control and
Prevention (CDC) and as a result of the widespread implementation of these
recommendations, and the efforts of our public health community, TB in this country is at the lowest level in recorded history.
This is not an issue of jeopardizing worker safety through the reduction of regulations. The tail-end of the Post article mentions that health care groups now are fighting this OSHA annual respirator fit-testing mandate but what the public may not understand is that, like the proposed OSHA TB regulation (which has been withdrawn), this fit-testing mandate is not supported by scientific evidence.
Furthermore, this is not a worker vs. industry issue. We are healthcare workers and we know we are already protected by the CDC guidelines. How is it that the lay opinions of labor unions including the American Federation of Teachers and the United Steelworkers can overshadow the lack of scientific evidence for regulations in this area? Why did OSHA mandate annual respirator fit-testing for occupational exposure to TB without offering a period of public comment, and while ignoring the science? These are questions we are still grappling with but meanwhile, we do not want the public to
have a false perception about the level of risk that healthcare workers face for
contracting TB disease. Rather than mandating unproven, unreliable and unnecessary ritualistic practices such as annual fit-testing, the federal government should instead focus on ensuring dedicated funding for TB control efforts at the public health level efforts that are proven to be effective.
The control of TB in this country continues to depend upon the collaboration,
communication and dedication of the public health and healthcare communities.
However, the misdirection of our limited and precious healthcare dollars toward
unproven, unnecessary and unreliable practices is entirely unjustified.
A. Jeanne Pfeiffer, RN, MPH, CIC
2004 APIC President