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.
 
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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
 

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