List members,

We are doing a periodic eval on an LPN working in a county jail (not an employee of our hospital). She has been in this facility for about a year. We did not see her for the initial/pre-placement evaluation.

She has chronic LBP, and sees pain management, and apparently is on hydrodocone 10 mg qid, and has been for several years. We are requesting further information from the treating provider as part of an individualized assessment as per ADA.

I'm familiar with recommendations in other safety sensitive environments (i.e. FMCSA, NFPA, FRA, FAA, etc), with regulatory guidance, but do not recall seeing any specific or consensus guidelines covering medical personnel. Concern would be for sedation/cognitive issues, keeping in mind tolerance issues, and the fact that she has apparently been working successfully to the best of our knowledge to date.

With the assistance of our legal team, we reviewed positions of the state regulatory boards (i.e licensing prohibitions, impaired provider programs, etc,,) and have not come up with blanket prohibitions or guidance.

With the lack of specific guidance at the State level, I wanted to reach out to this group to see if anyone is aware of national consensus guidelines or standards that may inform our decision.

Thank you in advance, and hope you have a great weekend!

Kevin M. Smith, MD, MPH, FACOEM

Medical Director

Phoebe Corporate Health

Phoebe Employee Health Services

229-312-9220

229-889-7074 Fax

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