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a hospital, a review of the infection control data.
3. If the facility has had a suspect or confirmed TB case within the previous six months, the
CSHO shall proceed with the TB portion of the inspection. The CSHO shall verify
implementation of the employer’s plans for TB protection through employee interviews
and direct observation where feasible. Professional judgment shall be used to identify
which areas of a facility must be inspected during the walk through (e.g., emergency rooms,
respiratory therapy areas, bronchoscopy suites, and morgue). After review of the facility
plans for worker TB protection, employee interviews combined with an inspection of
appropriate areas of the facility, shall be used to determine compliance.
4. CSHOs who perform smoke-trail visualization tests should review the protocol in
Appendix B of this directive.
5. CSHOs should be prepared to present to the employer the material safety data sheet
(MSDS) for the smoke that is released on a smoke-trail visualization.
J. Compliance Officer Protection
1. Area Directors or Assistant Area Directors shall ensure that CSHOs performing TB related
inspections are familiar with the CDC Guidelines, terminology, and are adequately
trained through either course work or field/work experience in health care settings.
Consultation with the regional TB coordinators is encouraged prior to beginning such
inspections.
2. CSHOs shall not enter occupied respiratory isolation [AFB (acid fast bacilli)] rooms to
evaluate compliance unless, in their determination entry is required to document a
violation. Prior to entry CSHOs will discuss the need for entry with the Area Director.
Photographs or video taping where practical shall be used for case documentation.
Under no circumstances shall photographing or videotaping of patients be done. CSHO’s
must take all necessary precautions to assure and protect patient confidentiality.
3. CSHOs shall exercise professional judgement and extreme caution when engaging in
activities that may involve potential exposure to TB. CSHOs normally shall establish the
existence of hazards and adequacy of work practices through employee interviews and
shall observe them in a manner which prevents exposure (e.g., through an observation
window where available).
4. On rare occasions when entry into potentially hazardous areas is judged necessary (e.g.,
where the CSHO determines that direct observation of a high hazard procedure is
necessary), the CSHO shall be properly equipped as required by the facility, this directive,
and following consultation with the CSHO’s supervisor. Since CSHOs’ respiratory
protection is used in more than one type of industry they shall use their negative pressure
elastomeric face piece respirators equipped with HEPA filters as the minimum level of
respiratory protection.
5. CSHOs who conduct TB inspections shall have been offered the TB skin tests. CSHOs
exposed to an individual(s) with active infectious TB shall receive a follow-up
examination and follow Sections J. and K. of Appendix A beginning on page 37.
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