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Tuberculosis risk assessment in health care

Summary A hospital asked how to classify TB risk and choose employee skin-test frequency. OSHA described the compliance memorandum it then used and CDC guidance for intermediate-risk facilities, while noting a replacement directive was under review. OSHA labels the letter an archive document.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1995-04-04-1
Date issued
April 4, 1995
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.
Status last verified October 9, 2026

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OSHA labels this an archive document and warns that it may no longer represent OSHA policy. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

April 4, 1995

James Perry, P.A.-C Manager,
Employee Health Services
Providence Hospital
[Recipient address omitted]
Dear Mr. Perry:

This letter is in response to your request for information concerning the Occupational Safety and Health Administration's (OSHA) protocol for risk assessment in healthcare facilities. For compliance purposes, OSHA is currently enforcing a compliance memorandum written in October of 1993. That memorandum is based upon the 1990 CDC Guidelines. I understand that you already have a copy of the memorandum. OSHA is currently reviewing a compliance directive that will replace the 1993 memorandum. The compliance directive incorporates the October 1994 CDC Guidelines.

The 1994 CDC Guidelines recommend PPD skin tests every six to twelve months for intermediate risk facilities. The guidelines offer no further recommendations on testing frequency at intermediate risk facilities. The classification of risk as used by the CDC applies to both a facility and areas within that facility. If a facility, as a whole, treats more than six patients with active TB per year then it would be considered an intermediate risk facility. This characterization would apply even if no department within that facility treated more than six patients per year.

We have examined the frequency of testing recommendations for intermediate risk facilities and interpret the guidelines as follows:

  1. If there are not individual departments within an intermediate risk facility where more than six TB patients per year are treated, the frequency of testing would be annually.

  2. Departments or areas within an intermediate risk facility that treat more than six TB patients per year must conduct PPD testing every six months. The remainder of the facility would fall back under the annual testing requirement.

If you have any further questions please contact Richard Fairfax of my staff at (202) 219-8036.

Sincerely,
Ruth McCully, Director
Office of Health Compliance Assistance

Enclosure

[Requester letter reproduced on OSHA page; omitted here.]

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