[MCOH-EH] OSHA form for students

Philip Harber philharber at gmail.com
Fri Mar 19 19:39:05 PDT 2021

Another opinion-While OSHA 1910.134 may not apply to "non-employees", many
feel it is not a good practice to have two people working side-by-side, one
of whom benefits from protections and the other does not. Also, as noted,
the distinction between student and employee is sometimes ambiguous.

Incidentally, these issues are discussed in a new book we will be releasing
in several months on O*ccupational Health in Higher Education and Research
Institutions*. This developed from an MCOH project, and most of the authors
of this 74 chapter book are active in MCOH. It will discuss both the
clinical/technical and the programmatic issues for this industry. A high
proportion of the issues for this industry overlap considerably with those
of Medical Center occupational health.

Phil Harber

*Philip Harber MD MPH*

email:  philharber at gmail.com or pharber at email.arizona.edu

Office Phone: 520-626-1263


On Thu, Mar 18, 2021 at 7:24 PM Smith, Kevin <kmsmith at phoebehealth.com>

> David,
> My thought would be to require it, but I would have the college be
> responsible for doing it (co-employment issues), of have it clearly spelled
> out in the contract/memorandum of understanding, that they are
> responsible for it, but they are contracting you to do it, and paying for
> the services. Might want to discuss with your organizations legal dept to
> avoid issues setting it up.
> Good luck.
> ------------------------------
> *From:* MCOH-EH <mcoh-eh-bounces at mylist.net> on behalf of Cockrum, MD
> David S <dcockrum at frhs.org>
> *Sent:* Tuesday, March 16, 2021 4:15 PM
> *To:* MCOH-EH <mcoh-eh at mylist.net>
> *Subject:* [MCOH-EH] OSHA form for students
> Fellow Medical Occ Health experts-
> Do you require students to complete the OSHA Respirator Questionnaire when
> they are mask fitted for rotating in your facilities? My inclination is to
> do it as it is tied to successful fitting of the N-95 respirator, but I was
> wondering if anyone has ever found any legitimate exemption or waiver for
> students (that are not sponsored by your facility, i.e. from a local
> college).
> Thanks,
> David
> Physician
> Faith Regional Physician Services
> Occupational Health
> *(402) 844 8300* <(402)%20844%208300>
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