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Appendix 10-3

Appendix 10-3

APPENDIX 10-3

QUALIFICATIONS OF OHDS PERSONNEL

Once you have decided which safety and health services you want to provide through your OHDS, you need to decide who will provide the services. There are several factors to consider:

  • Your OHDS must be organized so that the personnel providing the services are not working alone when State law requires that they be supervised by a registered nurse or physician.
  • The occupational health professionals you use must have specialized, up-to-date training or experience in the methods of occupational health care.
  • You must choose whether to hire OHDS personnel as your own employees or whether to contract outside your company for their services.

OCCUPATIONAL HEALTH PROFESSIONALS

Occupational health professionals are medical doctors (MD), doctors of osteopathy (DO), and registered nurses (RN). They hold a license to practice their professions, and they are entitled to practice independently under this license, using the standard procedures described in Appendix 10-5.

Occupational Medicine Specialists

Occupational medicine specialists are medical doctors (MD) or doctors of osteopathy (DO) who have additional training or experience in the treatment of work-related illnesses and injuries. This training or experience can be acquired in different ways:

  • A number of universities offer residency programs that enable MDs and DOs to become board certified in occupational medicine through the American Board of Preventive Medicine.
  • Professionals graduating from schools of medicine or osteopathy before January 1, 1984, may qualify for board certification by the "alternative pathway." This involves a combination of education and practical experience in the field of occupational medicine.
  • Shorter programs, called mini-residencies, offer academic training in occupational medicine.
  • MDs and DOs can obtain advanced education in occupational medicine by taking continuing education courses.
  • There are MDs and DOs working in occupational medicine who have gained advanced knowledge through experience working in the field for extended periods.

A qualified occupational medicine specialist should be capable of performing or managing all the OHDS activities described in Appendix 10-1.

Occupational Health Nurses

Occupational health nurses are registered nurses (RN) who have received specialized training in occupational health. Like physicians with specialties in occupational medicine, occupational health nurses may gain this training through formal college programs, continuing education, or experience working in the field. A registered nursing license allows nurses to perform many health evaluation and care functions independently. An occupational health nurse should be capable of performing or managing most of the OHDS activities described in Appendix 10-1.

Nurse Practitioners

Nurse Practitioners are registered nurses who have completed formal advanced training in physical assessment and the management of minor, stable illnesses and injuries. In most States, they are licensed or certified for advanced practice by State licensing boards. Nurse Practitioners perform many health evaluation and care activities independently. They perform physical exams; diagnose health problems using laboratory tests, x-rays, or other tests; and treat employees who are ill or injured. In most States, Nurse Practitioners can prescribe medications. Additionally, Nurse Practitioners perform many other activities using written protocols developed collaboratively with a physician. Nurse practitioners can take additional training and specialize in the treatment of occupational illnesses and injuries. When working with standard procedures, nurse practitioners should be capable of performing all the OHDS program activities described in Appendix 10-1.

SUPPORT PERSONNEL

Support personnel can provide more limited services. They have received specific training and usually are certified or licensed by the educational institution where they received the training. Sometimes licensing or certification is granted by the State. The scope of practice for support personnel requires that they work under the supervision of licensed health professionals except when delivering first aid. Licensed vocational nurses (LVNs), licensed practical nurses (LPNs), emergency response personnel (sometimes called emergency medical technicians, or EMTs), and first aid personnel are in this category.

Licensed Vocational and Licensed Practical Nurses

LVNs and LPNs are licensed by State agencies to perform certain health care activities. These include taking blood pressures and applying dressings. These persons must practice under the supervision of a physician or a registered nurse.

First Aid and Emergency Response Personnel

"First aiders" perform the function of first response. They provide temporary treatment until care of the ill or injured person can be transferred to someone with more advanced training. This includes performing treatments such as splinting and applying ice or pressure dressings, and also transporting the ill or injured. A person does not need a background of formal health care education to be trained in first aid and cardiopulmonary resuscitation (CPR). A certification in first aid usually is granted by training providers such as the American Red Cross after the student completes a standard curriculum and demonstrates competence. When employers assign first aid responsibilities to their employees, proper training, certification, and regular updating of the instruction are important: even first aid techniques can be harmful when done incorrectly.

CPR sometimes is included in first aid courses, but a separate class may have to be taken. CPR is the act of providing temporary, life-sustaining artificial circulation and respiration when these functions have stopped. It is performed before and during the stricken person's transfer to a medical facility. As with first aid, persons completing CPR training are certified by the organization offering the training. CPR performed incorrectly can injure the person receiving it. When employers use employees as "first aiders" and expect them to perform CPR, the employees must be thoroughly trained, and this training must be updated at least annually.

Warning: It is possible for persons rendering first aid or CPR to be exposed to the viruses that cause hepatitis B and AIDS. This is because the "first aider" can come in contact with body fluids, such as blood, that might contain these viruses. Because of this potential for exposure, all employees with employer-designated first aid or CPR duties are covered by the full scope of OSHA's Bloodborne Pathogens standard, 29 CFR 1910.1030. The standard requires that an employer train these employees in how to protect themselves from potentially infectious body fluids. It also requires that the employer provide personal protective equipment, offer the hepatitis B vaccine1, provide medical follow-up of any occupational exposure, and meet other requirements.

Emergency response personnel, sometimes called emergency medical technicians (EMTs), have received advanced training in first aid, CPR, and other life support techniques. With certain restrictions, they can perform sophisticated emergency procedures and transport ill and/or injured people.

Like other employees with first aid responsibilities, EMTs are covered by the full scope of OSHA's Bloodborne Pathogens standard (but see footnote below).

The OHDS should retain records of the original training, licenses, update courses, and certification of all employees participating in the delivery of occupational health services, including first aid, CPR, and/or emergency response activities. For all training related to the Bloodborne Pathogens standard, the standard requires that records be kept for 3 years, and that the records contain training dates, the content or a summary of the training, names and qualifications of trainers, and names and job titles of trainees.

FOOTNOTE

1OSHA allows employers to offer hepatitis B vaccinations to certain employees after they have given first aid rather than requiring pre-exposure vaccinations. This exception to the Bloodborne Pathogens standard applies to employees who render first aid only as a collateral duty, responding solely to injuries resulting from workplace incidents. These employees must be offered the full immunization series as soon as possible, but in no event later than 24 hours after rendering assistance in any situation involving the presence of blood or other potentially infectious materials. If an exposure incident as defined in the standard has taken place, other post-exposure follow-up procedures must begin immediately. This exception to the hepatitis B vaccination requirement does not apply to employees who provide first aid on a regular basis, for example, at a first aid station, clinic, or dispensary. Nor does the exception apply to health care, emergency response, or public safety personnel expected to render first aid in the course of their work. Information on this policy is contained in OSHA News Release USDL 92-436, July 6, 1992, available from OSHA's Office of Information, telephone (202) 219-8151.