[MCOH-EH] [Bulk] OSHA REGULATIONS
Cunha, Bruce E.
cunha.bruce at marshfieldclinic.org
Wed Jun 18 12:31:35 PDT 2014
We have an electronic file folder for each employee. In that folder we have separate sub-folders for the various employee health issues (injuries/illnesses, exposures, vaccinations, new hire screening, etc.).
In our system, employee health is not allowed to access the regular electronic health record system. If there is an issue that we need information on a patient on , we have to go through our infection prevention section to have the record reviewed.
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 at mylist.net] On Behalf Of Subin, Kenneth MD
Sent: Wednesday, June 18, 2014 2:07 PM
To: MCOH/EH
Subject: Re: [MCOH-EH] [Bulk] OSHA REGULATIONS
Are these separate medical record systems used for all employee work-related injuries/illnesses or only for blood and body fluid exposures? Do the EH providers also have access to the electronic personal health records within the hospital system, or only the EH records?
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 Davis, Sue
Sent: Wednesday, June 18, 2014 2:53 PM
To: 'MCOH/EH'
Subject: Re: [MCOH-EH] [Bulk] OSHA REGULATIONS
We use our lab with a coded ID number, lab sends the results to us, we keep the results in EH Medical Record.
Thanks,
Sue Davis MS, BSN, RN, CVRN - BC, NE-BC
Service Leader, Learning Center & Employee Health
Methodist Health System
8601 West Dodge Road, Suite 18, Omaha, NE 68114
Phone: (402) 354-5694
Learning Center Fax: (402) 354-5466
Employee Health Fax: (402) 354-8819
sue.davis at nmhs.org<mailto:sue.davis at nmhs.org>
"No one of us is as smart as all of us."-Ken Blanchard
From: MCOH-EH [mailto:mcoh-eh-bounces at mylist.net] On Behalf Of OWilliams at mcleodhealth.org<mailto:OWilliams at mcleodhealth.org>
Sent: Wednesday, June 18, 2014 1:48 PM
To: MCOH/EH
Cc: MCOH/EH; MCOH-EH
Subject: Re: [MCOH-EH] [Bulk] OSHA REGULATIONS
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<mailto:cunha.bruce at marshfieldclinic.org>>
To:
MCOH/EH <mcoh-eh at mylist.net<mailto: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<mailto: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.
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 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.
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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<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)<https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10051> and 29 CFR 1910.1020<https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10027>].
* 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)<https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10051#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<mailto:cesenior at phhealthcare.org>
www.phhealthcare.org<http://www.phhealthcare.org/>
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