We do the same as Bruce, use an outside
lab and then house information in our internal EH/OH system.
Octavia Williams-Blake
AVP, Occupational Health
McLeod Health
(843) 777-5355
From:
| "Cunha, Bruce E." <cunha.bruce@marshfieldclinic.org>
|
To:
| MCOH/EH <mcoh-eh@mylist.net>
|
Date:
| 06/18/2014 02:44 PM
|
Subject:
| Re: [MCOH-EH] [Bulk] OSHA REGULATIONS
|
Sent by:
| "MCOH-EH" <mcoh-eh-bounces@mylist.net> |
We use what amounts to an
outside lab at our system (run in our lab, but the results are not stored
in our Medical Record system). We get the results electronically
sent to us from the lab . These are then merged with the employee incident
report and store them in our employee health file system. We
also have our own server on our IS system. This prevents access by
anyone other than EHS personnel.
Bruce E. Cunha RN MS COHN-S
Manager, Employee Health
and Safety
Marshfield Clinic
Marshfield WI.
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From: MCOH-EH [mailto:mcoh-eh-bounces+cunha.bruce=marshfieldclinic.org@mylist.net]
On Behalf Of Subin, Kenneth MD
Sent: Wednesday, June 18, 2014 12:06 PM
To: MCOH/EH
Subject: Re: [MCOH-EH] [Bulk] OSHA REGULATIONS
If I may ask, your process
would seem to eliminate confidentiality issues during the testing and reporting
processes, but where do you maintain record of the results? And how
do you “lock” those records from unauthorized access?
Thanks.
Kenneth P. Subin, MD, MPH,
CIME, CMRO
Clinical Medical Director
Occupational Medicine
ArnotHealth
Elmira, NY
(607) 737-4539
(607) 737-7783 fax
From: MCOH-EH [mailto:mcoh-eh-bounces@mylist.net]
On Behalf Of Cunha, Bruce E.
Sent: Wednesday, June 18, 2014 12:38 PM
To: MCOH/EH
Subject: Re: [MCOH-EH] [Bulk] OSHA REGULATIONS
That is one of the reasons
we do not use the Clinical lab and do not put names on the lab slips. (Our
lab has an outreach process for providers requesting labs from outside
our system and these do not get into the medical record system of our facility.
We use this for our employee exposures.).
By assuring no one but EHS
knows who is being tested, we hopefully have reduced the issue of someone
in the lab seeing who the test is being run on.
Of course this also raises
issues with our State public health. Since the lab reports
all positive tests for HIV, Hep B and Hep C to public health; Public
Health does not like that they cannot identify the person that the positive
result is on. We have had multiple discussions on this issue and
try to notify public health as soon as we have a reportable result that
is confirmed positive.
Bruce E. Cunha RN MS COHN-S
Manager, Employee Health
and Safety
Marshfield Clinic
Marshfield WI.
ATTENTION: This e-mail
is confidential and may contain confidential and /or personal information.
If you are not the intended recipient, you must not disclose
or use the information contained in it. Please notify the sender
of this e-mail and promptly delete this e-mail.
From: MCOH-EH [mailto:mcoh-eh-bounces+cunha.bruce=marshfieldclinic.org@mylist.net]
On Behalf Of Swift, Melanie
Sent: Wednesday, June 18, 2014 11:24 AM
To: MCOH/EH
Subject: Re: [MCOH-EH] [Bulk] OSHA REGULATIONS
In my reading of it, the
interpretive letter is not about the “separate from personnel records”
part as much as it is about “confidential, not disclosed without written
permission of employee.” I don’t think it was about HIV stigma in particular.
The question specifically
put to them outlined the separate nature of the medical record as distinct
from personnel records, the need for a secure log in, and the punishment
associated with unauthorized viewing of a coworker’s record. Their response
was that those protections only kick in AFTER you catch someone looking
at the record – but by then they’ve seen it. So employees may not report
if they know coworkers technically have the ability to see their labs.
They insisted on a system that actually will not allow unauthorized people
to see the record.
I have not seen any more
recent interpretations.
Here’s how I see it: if
I work in the lab and I am exposed, I can choose to report it or not report
it. We know underreporting is a big problem. If I know that my coworkers
in the lab are going to see my result come through their system and say
“Hey, that’s Melanie! Oh, she had virology testing done. Wonder what
that was about” then I may be less inclined to report, than if I know
my results cannot be seen by them.
Melanie Swift, MD
Director, Vanderbilt Occupational
Health Clinic
http://occupationalhealth.vanderbilt.edu
From: MCOH-EH [mailto:mcoh-eh-bounces@mylist.net]
On Behalf Of Fair, Susan
Sent: Wednesday, June 18, 2014 11:10 AM
To: 'MCOH/EH'
Subject: Re: [MCOH-EH] [Bulk] OSHA REGULATIONS
The section under medical
records below only states that they must be kept confidential and separate
from other personnel records. I still have difficulty understanding
how that means we have to code the HIV testing because it is only kept
in systems that ARE confidential and separate from personnel records
(HR has no access to this). Since the CDC recommends HIV testing
on everyone between 16 and 64 yo, it appears that the previous stigma attached
to testing has been mitigated. Does OSHA have any relevant interpretation
that is more recent than 12 years ago? What am I missing here?
Susan Fair, MPAS, PA-C
Yale New Haven Hospital
Occupational Health Plus
New Haven, CT
From: MCOH-EH [mailto:mcoh-eh-bounces@mylist.net]
On Behalf Of Kathy Dayvault
Sent: Tuesday, June 17, 2014 1:26 PM
To: 'MCOH/EH'
Subject: Re: [MCOH-EH] [Bulk] OSHA REGULATIONS
Look at the blood borne pathogen
exposure regulation. I use the hospital etool…. It helps you find specifics
faster.
https://www.osha.gov/SLTC/etools/hospital/index.html
BBP reg: https://www.osha.gov/SLTC/etools/hospital/hazards/bbp/bbp.html
- Employer should establish and maintain both
medical and training records [29
CFR 1910.1030(h)(1) and 29
CFR 1910.1020].
- If an exposure incident occurs, employer
should add reports to the medical record to document the incident, including
testing results following the incident, follow-up procedures, and the written
opinion of the health care professional.
- Medical Records must be preserved
and maintained for each employee with an occupational exposure to bloodborne
pathogens [29
CFR 1910.1030(h)(1)] and for at
least the duration of employment plus 30 years. They must be kept confidential
(not disclosed without written permission of employee, except by law) and
separate from other personnel records and must also include:
- The employee's name and social security
number, hepatitis B vaccination status, including the dates of vaccination
and medical records related to the employee's ability to receive vaccinations.
Hope
you find this helpful…. Very quick resource once you click on the hazard
that you want.
Kathy Dayvault, RN, BSN,
MPH, COHN-S/CM
Independent OHN Consultant
From: MCOH-EH [mailto:mcoh-eh-bounces+kdayvault11=att.net@mylist.net]
On Behalf Of Senior, Cathy (DRMC)
Sent: Tuesday, June 17, 2014 1:08 PM
To: 'MCOH/EH'
Subject: [Bulk] [MCOH-EH] OSHA REGULATIONS
Can anyone direct me
where I can find the OSHA regulation pertaining to the Duty to ensure
privacy of employees exposed to blood and body fluid. I
know some facility use psuedo names in order to protect their employees
privacy when the test are done in their facility. I want to do this,
however our lab is not agreeable as they are not sure how to register the
employee and keep everything straight. The lab informed me that
they checked the state regulations (we are in PA) and there is nothing
that says we must give psuedo names. Therefore , I am looking for
any information that would assist my mission to provide privacy to our
employees. I thought there was an OSHA regulation if the test was
done within the facility such as the rapid HIV suds test that we could
not use their name. Can anyone direct me on this?
Cathy Senior RN BSN
CDE
Employee Health Director
Penn Highlands DuBois
100 Hospital Avenue
P.O. Box 447
DuBois Pa 15801
Phone 814-375-3392
Fax 814-372-2610
cesenior@phhealthcare.org
www.phhealthcare.org
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