[MCOH-EH] [Bulk] OSHA REGULATIONS

[OWilliams at mcleodhealth.org]

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 at marshfieldclinic.org>
To:
MCOH/EH <mcoh-eh at mylist.net>
Date:
06/18/2014 02:44 PM
Subject:
Re: [MCOH-EH] [Bulk]  OSHA REGULATIONS
Sent by:
"MCOH-EH" <mcoh-eh-bounces at 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 at 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 at 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 at 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 at 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 at 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 at 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 at phhealthcare.org
www.phhealthcare.org
 



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