Page 60 - OHS, September 2021

SAFETY & HEALTH
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These are often used interchangeably, but there is a distinct difference which is frequently misunderstood.
BY KAREN KONO
When companies are asked why they do medical screening or medical surveillance the typical answer is, “Because we have to.” Often, this is the correct answer, as OSHA and other regulatory agencies require medical surveillance and/or screening programs for certain workplace exposures. Companies across the United States spend a lot of money on these programs and the cost is on the rise. Unfortunately, many of them fail to manage their programs effectively, resulting in widespread failure to actually identify, reduce or eliminate hazards before serious damage is done to their employees, or until serious liability occurs. The best approach topreventthisandtorealizetheactual benefit of these programs is for companies to fully understand the program objectives and to have a working knowledge of the program’s complexities which takes a multi-disciplinary team of internal and external contributors.
One of the most basic things to be aware of is the difference between medical surveillance and medical screening programs. These are often used interchangeably, but there is a distinct difference which is frequently misunderstood.
Medical screening, in general, focuses on the individual worker and consists of a periodic “screening” examination and evaluation, which is performed not because an employee is exhibiting symptoms of illness, but because they are potentially exposed to a known workplace hazard(s). Medical screening may consist of a physical exam, a detailed personal and work history andanynumberoftestsusedforbiological monitoring. It can include blood tests, radiological imaging, pulmonary function tests (spirometry), electrocardiograms and more. It provides a snapshot in time which may be useful in identifying potential health effects before the employee even exhibits any
symptomsorhasanyideathattheremaybe an issue. Medical screening is helpful in early identification of illness, which allows early intervention (typically by way of removal fromcontinuedexposure)and/ortreatment of the condition or key risk factors.
However, it is important to understand that medical screening is only a component of medical surveillance, which is a much more complex and systematic process.
Medical surveillance is the broader activity, and its focus is on the entire group, not just the individual. It is a systemic process of data collection over time, and this data is used to analyze trends in work groups, which, when used correctly, can lead to evidence-based intervention. Not only is surveillance useful in evaluating known exposures, but it can be critical in identifying new and emerging trends in the workplace. By effectively analyzing types and routes of exposure, medical surveillance can be critical in identifying ways to reduce or even eliminate exposures, thereby reducing morbidity within the occupation.
In addition to appreciating this basic difference between medical screening and surveillance, other program issues are critical to understand. Developing and
maintaining a comprehensive medical surveillance program can be challenging, to say the least. A number of flaws in the current regulations make it difficult to properly implement programs for even the savviest employers. OSHA regulatory language has become more detailed and sophisticated over the years, but even recent regulations have a number of very “gray” areas. This is not likely to change any time soon.
For example, for many OSHA medical screening requirements, the regulatory language defers to whatever is deemed “appropriate” by the Primary Licensed Healthcare Professional (PLHCP). Though there are a number of accepted “standard practices” within the occupational health industry, the subjective opinion of the provider comes into play, resulting in some variance on recommended components.
Employers without a medical director or trusted occupational health provider toactastheirPLHCPcanbeleftinthe lurch. Many times, industrial safety professionals are charged with responsibility for these programs. They find themselves walking the fine line between maintaining compliance, for all the right reasons, and fears of knowing too much when it comes
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56 Occupational Health & Safety | SEPTEMBER 2021
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