- Standard Number:
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.
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
Due to the recent increase in work related tuberculosis, we feel it is necessary to specify the criteria for recording these cases on the OSHA Form 200. Our interpretation is as follows: Work related tuberculosis infections (positive skin tests) and tuberculosis disease are both recordable on the OSHA Form 200.
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.