Model Medical Surveillance Program - 08-16-12

1 Ohio Hazardous Materials Technical Advisory Committee Tox-Medic Sub-Committee Medical Surveillance Program for Hazmat/WMD Response Teams 1 Model Medical Surveillance Program The Ohio Hazardous Materials and Decontamination Technical Advisory Committee (HAZMAT TAC) Tox-Medic Sub-Committee, with the generous assistance of Michael D. Jacobson, MD, has developed a Model Medical Surveillance Program for Hazmat Team Members. The committee had received several requests for information on what is required for Medical Surveillance for hazmat team members. Dr. Jacobson and members of the committee reviewed the existing requirements from Occupational Health and Safety Administration (OSHA), as well as recommendations from National Institute for Occupational Safety and Health (NIOSH), the United States Environmental Protection Agency (USEPA) and National Fire Protection Association (NFPA), the Ohio Revised Code and Ohio Administrative Codes.

2 It is the belief of the committee that the attached recommendations comply with the current applicable standards of OSHA 29 CFR (hazmat), OSHA 29 CFR (respiratory protection), OSHA 29 CFR (hearing), 1985 NIOSH Guidance Manual, and the Ohio Administrative Code. This document is provided as a baseline recommendation for consideration by each team s Medical director. Individual circumstances, local hazard and risk assessments, previous experience and other variables may suggest expanding the nature and complexity of the examination and testing required. Mark Vedder Co-Chairman Ohio Hazmat TAC Ohio Hazardous Materials Technical Advisory Committee Tox-Medic Sub-Committee Medical Surveillance Program for Hazmat/WMD Response Teams 2 Medical Surveillance Program Members of Hazmat Teams are required to participate in an employer provided Medical Surveillance Program in compliance with OSHA (f).

3 Medical Surveillance programs are designed to: 1. Establish the baseline Medical condition of employees and fitness for duty 2. Determine the ability to work while wearing protective equipment 3. Track the physiological conditions of employees on an established schedule and at termination of the project or employment 4. Ensure documentation of employee exposure and Medical conditions is provided and maintained as a part of the employee's Medical record. Frequency of Evaluations OSHA (f) requires that the Medical evaluations be made available by the employer to the employee: 1. Prior to assignment to the hazmat team 2. At least once every two years while on the hazmat team 3. At termination or reassignment if the employee has not had an exam in the past six months 4. Following an over exposure (exceeds PEL) or development of sign and/or symptoms 5. More frequently if the examining physician deems it to be medically necessary.

4 Content of Examinations OSHA (f) requires that the Medical evaluation shall be performed by or under the supervision of a licensed physician, preferably one who is knowledgeable in occupational medicine, and shall be provided without cost to the employee. The content of the examination shall be determined by the attending physician, but the following is recommended by this committee as a minimum baseline of the Medical examinations: 1. Detailed Medical and work history (required by OSHA (f)) 2. OSHA Respirator Medical Evaluation Questionnaire (required by OSHA ) 3. Annual Physical examination, or not less than every two years at physician s discretion, including: a. Vision test b. Audiogram c. Update vaccinations for TB, Hepatitis B, tetanus, etc. d. Labs to include: i. Complete blood count (CBC) ii. Urinalysis with microscopy iii. Standard Blood Chemistry Panel to include kidney and liver function iv. Lipids e.

5 Chest X-Ray f. Pulmonary Function Test g. Resting EKG 4. Stress test (if indicated by patient s physical condition or age). Ohio Hazardous Materials Technical Advisory Committee Tox-Medic Sub-Committee Medical Surveillance Program for Hazmat/WMD Response Teams 3 Information Provided to the Physician OSHA (f) requires that the employer (the hazmat team) must provide the physician with the following documents: 1. Copy of OSHA and it s appendices 2. A description of the employee's duties as they relate to the employee's exposures 3. The employee's exposure levels or anticipated exposure levels 4. A description of any personal protective equipment used or to be used 5.

6 Information from previous Medical examinations of the employee which is not readily available to the examining physician 6. A copy of OSHA and it s appendices 7. The following information which is required by OSHA a. The type and weight of the respirator to be used by the employee b. The duration and frequency of respirator use (including use for rescue and escape) c. The expected physical work effort to be exerted while wearing a respirator d. Additional protective clothing and equipment to be worn; and e. Temperature and humidity extremes that may be encountered. Physician s Written Opinion OSHA requires that the physician provide the following to the employer for each employee examination: 1. The physician's opinion as to whether the employee has any detected Medical conditions which would place the employee at increased risk of material impairment of the employee's health from work in hazardous waste operations or emergency response, or from respirator use 2.

7 The physician's recommended limitations upon the employees assigned work 3. A statement that the employee has been informed by the physician of the results of the Medical examination and any Medical conditions which require further examination or treatment 4. The written opinion obtained by the employer shall not reveal specific findings or diagnoses unrelated to occupational exposure OSHA requires that the physician provide the following to the employee for each employee examination: 1. The physician shall inform the employee of the results of the Medical examination and any Medical conditions which require further examination or treatment 2. Copies of any of the above documents which were provided to the employer, if requested by the employee 3. The results of the Medical examination, tests and other Medical records related to the employee s examination, if requested by the employee Ohio Hazardous Materials Technical Advisory Committee Tox-Medic Sub-Committee Medical Surveillance Program for Hazmat/WMD Response Teams 4 Recordkeeping OSHA requires that the Medical record for each employee shall be preserved and maintained for at least the duration of employment plus thirty (30) years.

8 The employer shall insure that a system is in place to retain and recall the record if needed. It is the recommendation of the sub-committee that the physician retains the Medical Surveillance records for each employee, and that it should contain at least the following: 1. The name and social security number of the employee 2. Physicians' written opinions, recommended limitations and results of examinations and tests 3. Any employee Medical complaints related to exposure to hazardous substances 4. A copy of the information provided to the examining physician by the employer, with the exception of the standard and its appendices 5. A copy of the information provided to the examining physician by the employee, such as history, Medical questionnaires, exposure records and work history 6. A copy of the completed OSHA Respirator Medical Questionnaires 7. All of the above shall meet the criteria of 29 CFR It is recommended that the employer (Hazmat Team) preserve and maintain the following records for at least the duration of employment plus thirty (30) years: 1.

9 The name and social security number of the employee 2. Physicians' written opinions and recommended limitations 3. Any employee reports related to exposure to hazardous substances 4. A copy of the information provided to the examining physician by the employer, with the exception of the standard and its appendices Sample Documents The Tox-Medic Sub-Committee has provided the attached documents as examples for your use. The use of these documents is not required, but they may be helpful in developing or improving your Medical Surveillance Program . 1. Sample Letter to Physician 2. Copy of OSHA 29 CFR 3. Copy of OSHA 29 CFR 4. Hazmat Technician Job Description 5. Description of Hazmat Personal Protective Equipment 6. Sample Letter of Agreement from Physician 7. Sample Suggested Physical Exam Content 8. Sample Physician s Opinion Fitness to Wear Respiratory Protection 9. Sample Physician s Opinion Fitness for Hazmat Team Use your hazmat team letterhead Regional Hazardous Materials Response Team 1234 Main Street, Anytown, Ohio 44444 Anytown Hazardous Materials Response Team Phone 440-999-9999 Fax 440-999-9999 August 12, 2012 Dr.

10 XXXX YYYYY, MD 5678 Main Street Anytown, OH 44444 Dr. XXXXX: Thank you for your interest in performing Medical examinations as part of the XXXXXX Hazmat Team Medical Surveillance Program . There are very strict federal regulations regarding Hazmat physical exams, therefore we must ask your assistance in completing and documenting compliance with the Medical Surveillance regulations of OSHA 29 CFR and OSHA 29 CFR We are required by these regulations to provide you with a number of documents, which you will find enclosed. Please carefully review the enclosed materials and then SIGN and RETURN the Verification of Compliance. If you have any questions, please feel free to contact me at the number below. Thanks again for your assistance! Sincerely, Chief Hazmat Guy Anytown Hazmat Team HG/abm enclosures Newsletter RSS Feeds Print This Page Text SizeWhat's New | Offices Regulations (Standards - 29 CFR) - Table of Contents Part Number:1910 Part Title:Occupational Safety and Health Standards Subpart:H Subpart Title:Hazardous Materials Standard Title:Hazardous waste operations and emergency response.