Deborah, Karl,

 I completely agree that we must strive for a unitary high standard of care. Medical Center OH&S programs serving higher educational institutions also occasionally face organizational challenges in addition to the distinctions created by OSHA, workers compensation, and FERPA coverage regulations.


Unlike community-based OH&S centers for which the number of students is limited, the number of students in these institutions far exceeds the number of employees. In addition, there may be several different clinical service providers-  student health service, employee health service, and (sometimes) a hospital employee health service. This unfortunately leads to significant gaps and duplications. Funding streams also differ.


(Both of the locations at which I worked in the past 20 years even had distinctions between institutional employees providing health services and those in other institutional units. It would be interesting to hear the structures and experiences of MCOH's in other higher education institutions).


We therefore need to consistently advocate for providing high quality occupational health services even to “nonemployees” exposed to hazards.


(Of course, providing the “OSHA questionnaire” is only useful if interpreted by someone who understands respirators and the work conditions in which they will be used)


Phil Harber

Philip Harber MD MPH

email: or 

Office Phone: 520-626-1263


On Mon, Mar 22, 2021 at 10:16 AM Auerbach, Karl <> wrote:

Sadly, while there are plenty of moral/ethical rationales,  financial rationales supported by regulations that don’t call for doing it, seem to guide actions in many settings.


Karl Auerbach MD

Albany, NY


My opinions, noting more…





From: MCOH-EH <> On Behalf Of Deborah a Sampson via MCOH-EH
Sent: Saturday, March 20, 2021 6:55 PM
To: MCOH-EH <>
Cc: Deborah a Sampson <>
Subject: [EXTERNAL] Re: [MCOH-EH] OSHA form for students


Goodness…..isn’t there a moral/ethical rationale to protect all persons who provide any  service in a facility regardless of (often somewhat arbitrary) employee/student/contractor designations?


When we see Admins, physicians, and managers  receiving millions in “bonuses”  isn’t it a bit disingenuous to even question who gets protected and who doesn’t.

Just my 2 cent.

Deb Sampson




Sent from Mail for Windows 10


From: Philip Harber
Sent: Saturday, March 20, 2021 2:01 PM
Subject: Re: [MCOH-EH] OSHA form for students


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 Occupational 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: or 

Office Phone: 520-626-1263




On Thu, Mar 18, 2021 at 7:24 PM Smith, Kevin <> wrote:



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 <> on behalf of Cockrum, MD David S <>
Sent: Tuesday, March 16, 2021 4:15 PM
To: MCOH-EH <>
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).









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