23.1 Purpose. Pre-placement, periodic and termination medical exams will be provided at no charge to employees who, as part of their normal work activities, are to exposed hazardous agents or conditions. These exams may also be required for positions that have physical qualification standards because the work is either hazardous or physically demanding. Participation in a medical surveillance program when required by policy or regulation is mandatory and is a condition of employment. This policy specifies the minimum Occupational Safety and Health Program requirements to monitor the effectiveness of control measures that protect employees from chemical, physical and/or biological stressors, such as noise, chemical exposures, excessive temperatures, dusts, mists, and vapors. Medical monitoring will be based on measured exposures that exceed the Occupational Safety and Health Administration's (OSHA) permissible exposure limits or in certain cases action levels, which by regulation, trigger the inclusion of exposed employees into a medical surveillance program.
23.2 References.
A. Executive Orders 12196, Occupational Safety and Health Programs for Federal Employees, February 26, 1980.B. 29 Code of Federal Regulations 1910, Labor Standards, July 1, 2001.
C. Department of the Interior. Occupational Medicine Handbook, July 2000.
D. Departmental Manual, Part 370, Chapter 792 (7.1), Medical Surveillance Program.
E. Departmental Manual, Part 485, Safety and Health Program, Chapter 17, Industrial Hygiene and Chapter 18 (18.3D), Occupational Medical Program.
F. Survey Manual 445-2-H, Occupational Safety and Health Program Requirements Handbook, 30 November 2001.
G. Appendix 23-1 Positions That Have Mandatory Surveillance Requirements
H. Appendix 23-2 OSHA Required Medical Surveillance and Recommended Testing
I. Appendix 23-3 OSHA Regulated Occupational Groups
J. Appendix 23-4 CDC Immunization Recommendations
23.3 Scope. USGS policy is to monitor workplace exposures for chemical, physical, and biological hazards, and perform follow-up medical surveillance for personnel who are occupationally exposed to hazards above established exposure levels. This chapter applies to USGS personnel whose duties may require occupational exposure to toxic chemicals, physical agents, or biological hazards above OSHA's Permissible Exposure Limits (PEL) or, when OSHA standards are absent or less stringent American Conference of Governmental Industrial Hygienist's (ACGIH) Threshold Limit Values (TLV). Contractor employees and cooperative volunteers will also be required to participate in a medical monitoring program when required by OSHA regulation. Some examples of USGS activities that may require medical surveillance are pesticide handlers, inspectors, contaminant specialists, chemical spill clean-up personnel, fire fighters, field personnel and staff working with hazardous waste site activities. Volunteers under the age of 18 will not be permitted to perform activities that require medical surveillance.
23.4 Requirements.
A. The USGS shall provide a medical surveillance program for personnel who are exposed to chemical, physical and/or biological stressors at concentrations exceeding the applicable OSHA Action Level. When contractor personnel or cooperative volunteers will be working in environments requiring medical surveillance and monitoring it is the responsibility of the USGS COR to see that this is adequately addressed in the language of the contract. Any decision to provide medical monitoring services or to perform personal exposure monitoring for either contractors or cooperative volunteers should be evaluated by the appropriate DOI legal representative. The written medical monitoring program will comply with current OSHA regulations, as a minimum. Medical evaluations of such personnel shall be conducted prior to employee assignment to the hazard area and should be performed consistent with guidelines in the Department of the Interior Occupational Medicine Program Handbook and OSHA regulation. Medical monitoring in mandatory for any employee with an occupational exposure that exceeds or could have the potential to exceed regulatory standards based on the professional judgment of the safety and health professional making the assessment. Participation in pre-placement exams with periodic follow-up based on these standards is a condition of employment.
B. Appropriate medical surveillance will be scheduled for affected personnel and will be conducted by a licensed physician or registered nurse under the supervision of a licensed physician in accordance with any required OSHA, DOI, and USGS policies, incorporating IH surveys and safety and health practices.
23.5 Medical Exams/Medical Monitoring.
Pre-placement or baseline examinations. The purpose of pre-placement exams is to determine medical status of the employee at the time of hire to ensure that they do not have any physical or mental conditions that might preclude them from safely performing the job that they have been hired to do. Pre-placement exams should also be performed on individuals that are transferring to hazardous or physically demanding positions within the organization that are significantly different from the position that they are vacating. These exams allow the licensed physician to establish a baseline by which subsequent exams can be compared to determine in changes in health occur over time from occupational exposure. Baseline exams are important because a prospective employee may already have a pre-existing condition, for example hearing loss, which has developed prior to their hire, which the government should not be held accountable for in terms of workers compensation. It is also important for these conditions to be identified so that the government can insure that the employee is well protected so that their condition does not worsen due to further occupational exposure. The nature of these exams will depend on the job series and the specific nature of the job to be performed. A completed job hazard analysis will help ensure that appropriate medical exams are conducted. See Appendix 23-1 for a list of USGS positions that may require medical surveillance.
(1) Medical Determinations and Recommendations. A medical examination alone cannot determine an individual's ability to perform the essential duties of a particular position. The responsibility for making this determination rests solely with the appointing official. Employment-related decisions involving health are fundamentally managerial, not medical. However, medical information may be an essential element in determining an individual's suitability for job tasks. Management has the obligation to consider issues that are not strictly medical (e.g., reasonable accommodation or assessment of undue hardship on the operation of the agency's operations).
The role of occupational medical personnel in addressing employment decisions is limited to determining whether the individual meets the medical requirements of the position and can, from a medical standpoint, perform the job capably and safely.
(2) To assist managers in making employment and placement decisions, medical determinations should fall in one of the following three categories.
(a) Qualified - The individual meets the medical requirements of the position and is (from a medical standpoint) capable of performing the required tasks. Allowing the individual to perform the job will not pose a significant risk to personal health and safety or the health and safety of others.
(b) Qualified with Restriction -The individual meets the medical requirements of the position and is capable of performing the job without risk to personal health or others only with some accommodation or restriction. (When this determination is made, the practitioner should provide a list of recommended accommodations or restrictions and the expected duration of this requirement and therapeutic or risk-avoiding benefit.)
(c) Not Qualified - The individual is incapable of performing essential tasks, will be unsafe, or fails to meet medical requirements for the job.
(3) Recommended Disqualification Procedure. A disqualifying or not qualified medical determination is legitimate if:
(a)A medical condition prevents the worker from performing the essential functions of the job and no reasonable accommodation would enable the worker to perform the job.
(b) Allowing the worker to perform the job would endanger the health or safety of other workers or the public.
(c) Placing (or retaining) the individual in the job poses a significant risk to the worker's personal health or safety.
(d) The individual fails to meet a medical standard or physical requirement for placement in the position.
(4) Case Summary. The examining practitioner should prepare a case summary on all workers determined to be medically unsuited for their job and file this case summary in the workers medical record. The appointing official must be informed of the disqualifying recommendation. The case summary, as confidential medical information, should be provided to management only when necessary and authorized. The following information should be included in all case summaries:
(a) Diagnosis. The diagnosis must be justified in accordance with established diagnostic criteria.
(b) History. The history of disqualifying condition(s) including references to findings from previous examinations, treatment, and responses to treatment, must be provided.
(c) Clinical findings. The clinical findings including results of any laboratory tests, x-rays, or special evaluations performed.
(5) Prognosis. The prognosis must clearly state the medical basis for concluding that the individual is incapable or unsafe, plans or recommendations for future treatment, and an estimate of the expected date of full or partial recovery. If recovery is not expected this should also be clearly indicated. The prognosis must also include an explanation of the impact of the medical condition on overall activities both on and off the job, the reason(s) why restrictions or accommodations will not enable the individual to perform the job, and an explanation of the medical basis for any conclusions.
B. Periodic exams/medical monitoring. Ongoing, periodic exams, when required by regulation are necessary to ensure that individuals working in potentially hazardous jobs are being adequately protected from the hazards. Periodic measurements will detect abnormalities in workers exposed to work-related health hazards early enough to prevent or limit disease progression by exposure modification or medical intervention. Medical surveillance examinations are secondary prevention measures. They are effective only if useful screening techniques (history questionnaires, medical exams, or lab tests) are available to identify abnormalities in the target organ system at a stage when modifying exposure or providing medical treatment can arrest progression or prevent recurrence. These exams indirectly evaluate the effectiveness of control measures such as personal protective equipment, mechanical controls and administrative controls put in place to prevent acute or chronic occupational exposures that may permanently affect their health. Certain OSHA standards have specific tests and exams that must be performed at regular intervals to monitor occupational exposures to hazardous agents or conditions for example chemicals, respirable dust, asbestos, lead, and noise. Appendix 23-2 lists the OSHA required and recommended exams and laboratory tests based on exposure and target organ for chemical exposures. Specific job series also require periodic exams due to the intense physical requirements of these jobs (e.g. Law enforcement or firefighters).
C. Special Exams.
(1) Personnel Policy Enforcement Exams. Personnel policy enforcement examinations medically assess workers to determine if they meet established physical standards and conditions of employment. Drug use screening exams are one example of this type of exam. Fitness for duty physicals are another type of exam which can be requested by supervisory personnel if an employee has in some way become incapacitated and the supervisor believes that the employee can no longer perform his job safely.
(2) Bloodborne Pathogens. Employees that are potentially exposed to Bloodborne Pathogens must be offered the Hepatitis B Series. Hepatitis A may also be offered for employees working in polluted waters (for example, downstream from a wastewater treatment plant) that may have the potential for exposure to HEP A. Employees will be asked to read a short fact sheet on the benefits and risks of immunization. Those wishing to be immunized will be asked to sign a consent form. Those not wishing to be immunized must sign a declination form. Either form will be maintained in their employee medical record. Examples of these forms are found in Appendix 25-1 of SM 445-2H. Employees that experience a bloodborne pathogen exposure incident will complete the BBP exposure incident form found in Appendix 25-2 of SM 445-2H. Healthcare professionals will follow the protocol and complete the report provided in SM 445-2H Appendix 25-3.
(3) Routine Immunizations. Routine immunizations will be provided to employees as part of the employee wellness program as required for fieldwork and international travel. See Appendix 23-4 for CDC Immunization recommendations. The host nation or State Department should be consulted concerning current immunization requirements for the country you will be traveling to.
D. Termination examinations.
(1) Termination of employment physical examinations. A termination exam will be performed whenever an individual enrolled in medical surveillance is transferred to another agency, is terminated or retires. This exam is conducted to identify medical conditions, which are related to an occupational exposure, that may require future medical treatment for which the government may be responsible.
(2) Termination of exposure examinations. This exam would be conducted when an employee is no longer exposed to a particular hazard in the workplace. Exposures to specific hazards may cease when a worker is reassigned or when a process is changed.
E. Recordkeeping.
(1) Employee medical records shall be maintained in accordance with current OSHA regulations and the Privacy Act. Current guidance on maintenance of employee medical record can be found in the DOI Occupational Medicine Program Handbook.
(2) Medical and exposure records are filed by the servicing Human Resources Office, in accordance with personnel, medical surveillance, medical records, and maintenance rules and regulations.
(3) Medical and exposure records will be placed in the employee's medical folder in the servicing Human Resources Office apart from other personnel records.
23.6 Responsibilities.
A. Bureau Safety Manager/Bureau Industrial Hygienist.
(1) Oversees the USGS medical surveillance program.
(2) Evaluates Regional Headquarter and science medical surveillance programs during on-site visits.
(3) Assists Regional Safety Managers in establishing medical monitoring contracts.
B. Regional Safety Managers.
(1) Provide oversight for the region-wide medical surveillance program responsible to the Regional Director through the Chief, Office of Regional Services.
(2) Assist Regional Safety Officers in identification and quantification chemical, physical, and biological workplace exposures.
(3) Coordinate study results and air sampling data to ensure abatement, as appropriate.
(4) Provide supporting data and recommendations for consideration on how to eliminate or minimize worker occupational exposures.
(5) Assist Regional Safety Officers in developing medical surveillance programs and establishing contractual services, as applicable.
C. Regional Safety Officer.
(1) Provides oversight for their respective regional science medical surveillance program.
(2) Assists Collateral Duty Safety Program Coordinators (CDSPC’s) in identifying and quantifying chemical, physical, and biological exposures to workers during on-site reviews, as necessary, and provides abatement recommendations to eliminate or minimize worker occupational exposures, as applicable
(3) Coordinates study results and air sampling data to ensure abatement, as appropriate.
(4) Assists Regional field location CDSPC’s in establishing local contractual services and developing medical surveillance programs.
(5) Provide up to date guidance to Human Resources staff and supervisors on medical surveillance requirements based on Occupational Safety and Health Administration requirements.
(6) Provide a list of job types that require pre-placement and periodic physicals to Human Resources and Supervisors.
(7) Conduct surveys and investigations when occupational health identifies abnormal physical results (related to their occupational exposures).
D. Collateral Duty Safety Program Coordinator (CDSPC).
(1) Provides technical assistance to project leaders in implementing this policy.
(2) Provides guidance to supervisors and project chiefs, upon request, in finding an OHP.
(3) Works with supervisors and project chiefs to ensure appropriate sampling data are included in the personnel medical folder (SF 66D). (NOTE: For the purposes of this chapter, appropriate sampling data are information collected for compliance with specific Occupational Safety and Health Administration (OSHA) regulations [e.g., audiograms, asbestos sampling data, etc.]).
(4) Work with supervisors and project chiefs in applying or implementing engineering or administrative controls when workers are or may be occupationally exposed to chemical, physical, or biological hazards above established PEL or TLV.
(5) Work with supervisors and project chiefs in the acquisition and proper use of personal protective equipment (PPE) when engineering or administrative controls are in the process of being implemented, are not feasible, or are not effective in protecting workers from occupational exposures to chemical, physical, or biological hazards.
E. Organizational Managers and Supervisors/Project Chiefs/ Laboratory Supervisors.
(1) Oversee development of job hazard analyses (JHA) for operations where chemical, physical, or biological hazards may affect USGS personnel. The JHA will be consistent with Chapter 14 of this Handbook.
(2) Identify personnel who require medical surveillance and advise the Regional Office in developing a medical surveillance contract with a health provider (U.S. Public Health Service [USPHS]).
(3) Utilize OHP's for medical surveillance. If an OHP cannot be found through the USPHS, the project leader will coordinate with the CDSPC to contact the representative Regional Safety Officer or Regional Safety Manager for assistance in locating an OHP.
F. Employee. (1) Cooperate by completing any required forms and by providing appropriate medical history to medical personnel performing the exam.
(2) Participate in any required testing and exams necessary to determine health status and fitness to be assigned to or to continue performance in a particular position
G. Human Resources.
(1) Notify safety and health staff of new hires, terminations or job re-assignments so it can be determined whether or not medical exams are necessary.
(2) Maintain any contracts or memorandums of agreement for medical monitoring services.
(3) Maintain employee exposure and medical records.
H. Medical Personnel.
(1) Schedule and conduct physical exams to determine fitness for duty and to monitor occupational exposures.
(2) Utilize workplace sampling to determine the appropriate type and frequency of medical surveillance for workers.
(3) Inform workers receiving occupational medical examinations of any specific health risks that can result from their particular occupational exposures. Provide informal counseling concerning the methods to protect against particular occupational exposures.
(4) Provide a copy of the physical exam results to the employee and explain the implications of any abnormal tests.
Appendices