ESTABLISHING THE RIGHT MEDICAL PROGRAM FOR YOUR WORKSITE: THE OCCUPATIONAL HEALTH DELIVERY SYSTEM
Are you remembering the "health" in your occupational safety and health program? The Occupational Safety and Health Act of 1970 aims "...to assure so far as possible every working man and woman in the Nation safe and healthful working conditions...." Toward this end, OSHA's Safety and Health Program Management Guidelines strongly urge the identification and control of health hazards and the implementation of a medical program.
A medical program is another name for the systems that employers put in place to ensure occupational health expertise within the overall safety and health program. Having a medical program does not necessarily mean that you must go out and hire a doctor to work at your company. There are many ways for you to find and use occupational health expertise. This chapter will help you decide what will work best for your business.
We call the medical program the occupational health delivery system, or OHDS. This term will help you remember that a comprehensive program is more than an after-the-fact response to work-related injuries and illnesses. It also includes the activities that uncover the safety and health hazards in your business and that help you formulate a plan for prevention or control. It is a management system in the same wy that the actions you take to promote safety are a management system.
You may find it more difficult to establish the goals and objectives for your OHDS than for the other parts of your safety and health program. The harm it prevents may not appear obvious at first. For example, an employee who is experiencing hand pain and who gradually is developing a cumulative trauma disorder (CTD) may seem to have a less serious problem than the employee who has a severe cut or broken bone from an accident. But OSHA's experience is that work-related health problems are no less serious in terms of human suffering and costs than the more obvious injuries.
An effective OHDS will help reduce all types of safety and health hazards and the resulting injuries and illnesses. The positive results from such a program will be measurable by a drop in lost workdays and workers' compensation costs. You also can expect this program to help increase worker productivity and morale.
WHO SHOULD MANAGE THE OHDS?
You will find that the OHDS works best when managed by occupational health professionals (OHPs). A physician or a registered nurse with specialized training, experience, and knowledge in occupational health works with you but not necessarily as your employee. This arrangement works best because safety professionals, industrial hygienists, occupational medicine physicians, and occupational health nurses all have their own areas of specialized knowledge. You cannot expect to get all the information and service your safety and health program needs from only one type of specialist. If you tried, you might overlook or misidentify a dangerous hazard in your business.
Appendix 10-3 contains a description of the different ways that physicians and registered nurses receive specialty training in occupational medicine and health and the different services that they can provide you. Chapter 7 contains information about some of the services you can get from safety professionals and industrial hygienists.
WHAT SERVICES DO YOU NEED FROM YOUR OHDS?
There is no such thing as a standard OHDS. There is no substitute for examining your business' special characteristics and developing an OHDS that is right for you. These special characteristics include:
- The actual processes in which your employees are engaged;
- The type of materials handled by your employees;
- The type of facilities where your employees are working;
- The number of employees at each site under consideration;
- The characteristics of your work force, such as age, gender, ethnic group and educational level; and
- The location of each operation and its distance from health care facilities.
As you look at the characteristics of your employees and workplace, you should be asking yourself questions such as:
- Are there hazards in the process, materials or facilities that make it likely that employees will get sick, hurt or will suffer abnormal health effects their work?
- Are there so few employees that onsite occupational health resources are less practical than off-site contract services? Are there so many employees that time and money will be saved by installing onsite resources?
- Are there special characteristics of the workers that make them more vulnerable to illness or injury or less likely to understand the safety and health hazards of the worksite?
You should be aware that, under the Americans with Disabilities Act (ADA), employers may require employees to submit to medical examination only when justified by business necessity. It is OSHA's judgement that a health and safety concern qualities as a business necessity. The results of any medical examination are subject to certain disclosure and record retention requirements (see Part 1910.20 of Title 29, Code of Federal Regulations), but also are subject to confidentiality requirements of the ADA. The ADA's employment-related provisions are enforced primarily by the U.S. Equal Employment Opportunity Commission.
- Is there anything about the workplace that makes it important to have occupational health assistance nearer or more rapidly obtainable?
Answering these questions will put you in a better position to decide which OHDS services you need. The services are listed below. Appendix 10-1 includes some examples of how different companies varied sizes tailor their OHDS activities.
THE RANGE OF OHDS FUNCTIONS
There are three basic types of OHDS activities:
- Prevention of hazards that cause illnesses and injuries,
- Early recognition and treatment of work-related illness and injury, and
- Limiting the severity of work-related illnesses and injury.
- Make sure that your safety and health policy shows that you are as concerned about your employees’ health as their safety. (See Chapter 2.)
- Make sure that qualified OHPs help you identify the hazards and potential hazards of your workplace. (See Chapter 7.)
- Use OHPs in the development and presentation of health training and other preventive activities, including the various measures required by OSHA’s Bloodborne Pathogens standard. (See Chapter 11 and OSHA Publication 2254, "Training Requirements in OSHA Standards and Training Guidelines").
- Remember that it is your responsibility to determine if you have employees who fall within the scope of the Bloodborne Pathogens standard and to make arrangements for compliance for these employees. Staff nurses, physicians, and emergency response personnel are covered by the standard, even where no other employees appear at risk of occupational exposure to infectious diseases. (For more information on this standard, see OSHA Publication 3127 (Revised 1993), "Occupational Exposure to Bloodborne Pathogens." See also OSHA Instruction CPL 202.44C, which deals with current enforcement policy regarding this standard."
- Provide professional occupational health expertise as a resource to your safety and health committee. (See Chapter 4.)
- Be sure to include you OHDS in your annual self-evaluation. (See Chapter 12.)
Early Recognition and Treatment
- Use OHPs to help you decide, on the basis of existing or potential hazards at your workplace, when you may need to conduct baseline and periodic testing of your employees and new hires for evidence of exposure. This is called "health surveillance" and is required by some OSHA standards for specific types of exposures.
- Use OHPs to do the testing needed for health surveillance.
- Make sure records are kept of employee visits to first aid stations, nurse’s office, contract clinic or hospital. Have an OHP review the symptoms reported and the diagnoses to see if there appear to be patterns that indicate an occupational health problem.
- Provide first aid and CPR assistance through properly trained employees on every shift. Make sure that these employees keep their certifications current and that they receive adequate training in the hazards specific to the worksite. The Occupational Exposure to Bloodborne Pathogens standard (29 CFR 1910.1030) outlines specific training requirements for employees expected to render first aid at work. It is essential that employees understand the hazards from bloodborne communicable diseases, including hepatitis B and AIDS, and how to protect themselves.
- Involve OHPs in alcohol and drug abuse interventions, smoking cessation programs, and any other company programs geared toward helping employees recognize and obtain treatment for substance abuse problems.
- Make sure that the OHPs whom you use have current credentials, have had recent occupational health continuing education, and understand the hazards of your worksite. These standards will help ensure their ability to recognize early symptoms of occupational health problems and begin prompt and appropriate treatment to prevent disability.
- Make sure that standardized procedures -- called "protocols" in the medical community -- are used throughout your occupational health delivery system, particularly if you are using more than one contractor for health services. (For more information, see Appendix 10-5).
- Have one of the OHPs keep your employee injury and illness records, whenever feasible. Make sure your recordkeeping system effectively ensures the confidentiality of individual employee medical records. (See Appendix 10-2.)
- Coordinate the emergency response of all responsible individuals or departments at your worksite and of all emergency organizations off the worksite, such as the fire department, any contractual organization or a nearby community hospital. Everyone needs to know exactly what to do and what to expect from others. (See Chapter 8 and OSHA Publication 3088 (revised 1991), "How to Prepare for Workplace Emergencies.")
- Maintain contact through your OHP (whether you are an employee or provided by contract) with any employee who is off work due to an occupational illness or injury. Keep in touch with the practitioner providing treatment and care to ensure that the treatment is appropriate and that the employee is responding as expected.
- Use your registered nurse or physician to help advise an employee who is off work for an extended period about workers’ compensation rights and benefits and ongoing care.
- Use these OHPs to provide evaluation aimed at determining whether an employee can resume full duty after injury or illness or whether work duties need to be modified.
- Consult your physician or registered nurse for help with the development of a modified duty position to ensure that the employee can perform the work and benefit from feeling productive again.
- Develop and deliver health care in accordance with Federal and state regulations, for example, OSHA standards, workers’ compensation laws and public health regulations.
Your business' medical program, what we call its occupational health delivery system, is an important part of your safety and health program. It can deliver services aimed at preventing hazards that can cause illness and injury, rapidly recognizing and treating illness and injury, and limiting their severity.
To determine which of these services are appropriate, you need to consider your business' special characteristics. These include the type of processes and materials your employees work with and the resulting or potential hazards. Other considerations are the type of facilities in which employees work, the number of workers at each site, and the characteristics of the work force, such as age, gender, cultural background, and educational level. The location of each operation and its proximity to a health care facility also are important.
Whether you hire or contract with an occupational health professional, make sure this person has specialized training, experience, and up-to-date credentials. Then use him/her to help you develop and deliver the services you have chosen.