Page 61 - OHS, September 2021

tosensitivemedicalinformation.Itisnotuncommonforemployers to be too conservative, or too liberal in their approach. In addition to that, employee suspicions of management conniving, especially when labor unions are involved, and the most appropriate efforts can become jaded. For well-meaning employers, finding that fine line can be tricky. It is often helpful to assign responsibility for this type of program to someone outside of the human resources department, for that reason, and so it often falls on safety professionals in businesses that do not employ internal occupational health nurses. This can be risky, despite the best efforts.
Often, employees get sent to different medical providers over time, and the previous records are not available to the examiner, making valid surveillance impossible. This often makes it necessary for employers to develop a way to track their employee’s information in both a secure and comprehensive manner.
Compounding this problem, program management technology in this area is lacking solutions that effectively meet the needs. There are a number of occupational health & safety solutions on the market, but none of them encompass the entirety of medical surveillance compliance needs. Many do an excellent job of scheduling, reminding and storing documentation, but few, if any, are actual intuitive program management tools.
If the information is not properly tracked, this can lead to difficulties with medical clearances. This is because most OSHA regulations require the employer to provide the examining
healthcare professional with information about the job requirements and working conditions, PPE used and exposure levels in addition to prior medical records. This information is seldom provided by the employer, leaving the medical examiners (PLHCPs) with very little objective data on which to base their clearance determinations. Medical providers often find it exhausting to continually ask for the necessary information without appropriate response and ultimately work with whatever information they have available. This can delay or prevent valid medical clearance of employees. Effective programs have strategies in place and access to expertise to handle issues like this. It really does “take a village.”
In summary, properly navigating and executing the complexities of medical screening and medical surveillance programs requires a detailed familiarity of the regulations and their issues (such as comprehensive and consistent recordkeeping). Employers who partner with an experienced occupational health professional to help navigate this complicated process are more likely to prevail in compliance inspections and reap the benefits of early identification of illness and better long-term health outcomes for their employees.
Karen Kono, RN, COHN is Director of Medical Services at Examinetics, a leading provider of workforce health and regulatory compliance solutions.
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