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February 26, 1993

MEMORANDUM FOR:  REGIONAL ADMINISTRATORS

ATTENTION:       REGIONAL RECORDKEEPING COORDINATORS

THRU:            LEO CAREY
                Director
                Office of Field Programs

FROM:            STEPHEN A. NEWELL
                Director
                Office of Statistics

SUBJECT:         Recording TB related cases on the OSHA 200 Log

For injury and illness recordkeeping purposes, if it seems likely that an exposure in the work environment either caused or contributed to the case, or aggravated existing symptoms to the point that they meet OSHA recordability criteria, the case is presumed to be work related. (See Q&A's C-8, page 34 and B- 17, page 32 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses.) A work related exposure to TB is presumed in the following industries: correctional facilities; health care facilities; homeless shelters; long-term care facilities; and drug treatment centers. (Please keep in mind that some of these industries are normally exempt from Federal OSHA injury and illness recordkeeping requirements. Correctional facilities, homes for destitute men and women, and drug rehabilitation centers with health care being incidental are all exempt).

However, if the condition was caused solely by a non-work related event or exposure off premises, the case would not be recordable. For example, if an employee is found to have a positive skin test, but has documentation that their skin test was also positive prior to employment, the current employer would not record the case.

If an employee tests positive for TB infection (and the case is work related and entered on the Log), and he/she subsequently develops tuberculosis disease during the 5 year maintenance period, the original case entry for the infection should be updated to reflect the new information. This updating requirement is true for any case entered on the Log. Because it is clinically impossible to determine if tuberculosis disease resulted from the source indicated by the skin test conversion or if it has resulted from subsequent exposures to other TB sources, only one case should be entered to avoid double counting.

When work related TB cases are recorded, incidence rates can be calculated that will enable employers to: (1) help identify the risk of TB transmission to various work groups, (2) look for causal connections between TB and the work environment, (3) evaluate the effectiveness of the exposure-control practices at the workplace, and (4) implement appropriate policy to afford employee protection.