Fit to be (tied and) tested

I’m sure many of you are watching, with various degrees of trepidation, the pending federal budget that, among other things, will once again let loose the hounds of the Occupational Safety and Health Administration in pursuit of fresh fines. I’m talking about Congress letting OSHA enforce annual tuberculosis fit-testing for respirators.

We could probably spend a good long time (and mayhap one day we will) discussing the efficacy of the practical application of the respiratory protection standard (CFR 1910.134) as a function of managing occupational exposures to TB, or indeed whether there was a significant shortcoming in the nondevelopment of a TB standard for healthcare workers. That said, it appears that enforcement of annual TB fit-testing is going to become a way of life for hospitals.

Hopefully—and you definitely want to do a little assessment here to make sure—you have your new hire process under control from a fit-testing perspective (though I do know of more than a few organizations that are a little soft in this area). Clearly starting at the front end of the process is the way to establish a solid foundation for your program.

Ideally, you will be able use the practical experience from the new hire process to identify an appropriate level of resources for expanding the respiratory protection program to include annual TB fit-testing and all its component pieces (medical evaluations, pulmonary function tests, and the like).

I’m guessing that there aren’t many of you out there with sufficient existing resources to carry this off (if you do—good for you!). It is more than likely that in the near future, you will have to submit some sort of business plan to your organization’s leaders in order to obtain those additional resources, including a fairly well-detailed accounting of the process (this is likely going to be a shared responsibility within the organization, but, make no mistake, this is the organization’s responsibility).

My best advice would be to get a group together, flowchart the process, determine a per-unit expense, and get that request to your organization’s leaders before the compliance canines beset your house.