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Policy No.: 2011
Effective Date: 02/15/2011
Revised Date:11/10/21 draft
Reviewed Date:

Medical Surveillance Policy

Policy

The purpose of the medical surveillance program is to evaluate the health of employees related to their potential occupational exposures to hazardous agents. This program will also assure compliance with various regulations which require medical monitoring when employees use certain materials, are exposed to certain biological, chemical, radiological or physical hazards or are members of certain regulated occupational groups. This policy does not include ergonomic-related illnesses and work-related injuries/illnesses (worker's compensation claims) covered under the University Workers Compensation Program.

Those working with animals should refer to the IACUC Policy for Occupational Health and Safety for Personnel with Animal Exposure.

Responsibility

Employee

1. Complete the pre-employment medical surveillance based upon the position description or as determined following a review of the employee job tasks against the medical surveillance criteria.
2. Participate in an ongoing medical surveillance program based upon the position description or as determined following a review of the employee job tasks against the medical surveillance criteria.
3. Following an exposure or other adverse event, notify your supervisor/manager and follow the reporting guidance on the UNMC Incident Reporting webpage.

Supervisor/Manager

1. Update position descriptions as needed to accurately reflect the elements of the job including exposures, personal protective equipment, physical requirements, etc.
   1. Based on the requirements of some positions at UNMC, the offer of employment is contingent upon successful completion of post-offer, pre-employment health services/examinations conducted through Nebraska Medicine Employee Health (EH).
   2. To determine if a position requires pre-employment health services/examinations, review the Compliance/Occupational Health Requirements section of the candidate’s position description in PeopleAdmin.
   3. Information indicating whether a service/examination is required based on the responsibilities and working environment of the position can be found on the NU Values - Employee Health Services webpage.
2. Review the Medical Screening and Surveillance Requirements in OSHA Standards: A Guide to determine if the employee job tasks require any medical screening or surveillance.
3. Coordinate with EH when medical screening and surveillance is indicated for an employee.
4. Encourage employees to self-identify to EH any medical concerns involving occupational exposure risks.
5. Contact Environmental Health and Safety (EHS) for questions about this process or for additional guidance.

Environmental Health and Safety

1. Serves as program administrator and works with EH to coordinate the campus medical surveillance program.
2. Acts as liaison with EH personnel and other employees.
3. Provides exposure evaluations when deemed necessary.
4. Provides feedback to supervisors/managers on medical surveillance inquiries.
5. Reviews Injury and Illness Reports and provides follow-up as needed.

Employee Health

1. Provides initial medical screening and ongoing employee surveillance based upon the position description or as determined following a risk assessment.
2. Makes recommendations based on exam results.
3. Maintains medical records and makes them available to employees.
4. Provides post-exposure follow-up and referral as needed.

Procedures/Guidelines

Pre-Employment Medical Surveillance Criteria

Departments will review and update position descriptions prior to posting to assure they accurately reflect the elements of the job including exposures, personal protective equipment and physical requirements. Employees' inclusion in the medical surveillance program will be based on the elements of the job and safety surveys in which exposures to various stressors are evaluated.

Departments are responsible for scheduling periodic exams as required and, when necessary, medical surveillance examinations will be scheduled for affected employees with the EH.

Affected employees will undergo a work history, a medical history, and a medical examination; these elements are used to establish a baseline of the employees' health and then used to monitor their future health as it relates to their potential occupational exposures to hazardous substances.

Specific test results and other personal medical information generated by these exams will be kept confidential. The employee can contact the health care professional who performed the exam with any questions regarding the test results. According to federal law, employees have the right to request copies of their medical or exposure records at any time by contacting EH for medical records and EHS for exposure records. EHS has adopted these criteria based on OSHA requirements. The criteria are subject to modification upon periodic review.

More information on medical screening and surveillance can be found in the Medical Screening and Surveillance Requirements in OSHA Standards: A Guide.

Medical screening and surveillance will be implemented in accordance with OSHA standards for those who:

1. Have exposure to noise levels exceeding 85 dBA in an 8-hour time weighted average exposure.
2. Wear a respirator.
3. Have exposure to asbestos above the permissible limit or excursion limit for 30 days/year; perform Class 1, 2 or 3 asbestos work for 30 days/year.
4. Use any of the following 13 OSHA regulated human carcinogens (OSHA 49 CFR 1910-1003):
   1. 4-Nitrobiphenyl, CAS 92933;
   2. alpha-Naphthylamine, CAS No. 134327;
   3. methyl chloromethyl ether, CAS No. 107302;
   4. 3,3' Dichlorobenzidine (and its salt), CAS No. 91941;
   5. bis-Chloromethyl ether, CAS No. 542881;
   6. beta-Naphthylamine, CAS No. 91598;
   7. Benzidine, CAS No. 92875;
   8. 4-Aminodiphenyl, CAS No. 92671;
   9. Ethyleneimine, CAS No. 151564;
   10. beta-Propiolactone, CAS No. 57578;
   11. 2-Acetylaminofluorene, CAS No. 53963;
   12. 4-Dimethylaminoazo-benzene, CAS No. 60117; or
   13. N-Nitrosodimethylamine, CAS No. 62759.
5. Use Vinyl Chloride and are exposed above the action level (OSHA CFR 49 1910.1017 (b)(1)).
6. Use Inorganic Arsenic and are exposed above the action level for at least 30 days/year and based on previous exposure (OSHA CFR 49 1910.1018 (b)).
7. Use Metallic Lead, Inorganic Lead or Organic Lead Soaps and are exposed above the action level for greater than 30 days/year.
8. Use Benzene and are exposed above the action level for greater than 30 days/year and based on additional requirements (OSHA 29 CFR 1910.1028 (b)).
9. Are exposed to or use biohazardous agents as a part of their job activities (to include "occupational exposure" to Bloodborne Pathogens (see UNMC Bloodborne Pathogen Exposure Control Plan).

   NOTE: The Institutional Biosafety Committee "Protocol for Research Involving Biohazardous Materials" must be completed and approved by the campus IBC prior to conducting research on campus with biohazardous agents or in any situation where select agents are used in research or diagnostic procedures. This protocol includes completion of a section entitled, "Risk for Occupational Exposure" which requires the primary investigator to describe precautions necessary to prevent occupational exposure to the biohazardous agent and to list the specific training(s) and vaccination(s) required, if necessary, to handle the biohazardous agents. In addition, the PI or laboratory supervisor is required to obtain a copy of the Post Exposure Agent Specific Protocol for the biohazardous agent being used in the laboratory.

10. Use 1,2 - Dibromo-3-Chloropropane, working in a regulated area or may be exposed in an emergency situation (OSHA 29 CFR 1910.1044).
11. Are exposed to Acrylonitrile above the action level (OSHA 29 CFR 1910.1044 (b)).
12. Are exposed to Ethylene Oxide at or above the action for at least 30 days/year (OSHA 29 CFR 1910.1047 (b)).
13. Are exposed to Formaldehyde greater than the action level or greater than the short-term exposure limit (OSHA 29 CFR 1910.1048 (b) and 1910.1048 (c)(1)).
14. Are exposed to Methylenedianiline greater than or equal to the action level for 30 days/year (OSHA 29 CFR 1910.1050 (b).
15. Are exposed to Cadmium greater than or equal to the action level for 30 days/year (OSHA 29 CFR 1910.1027 (b)).
16. Are members of a hazardous waste and emergency response (HAZMAT) team.

More information on medical screening and surveillance can be found in the Medical Screening and Surveillance Requirements in OSHA Standards: A Guide.

Exposures - Radioactive Materials

1. For incidences not involving personal injury, contact Radiation Safety during business hours at 402-559-6356 and after hours at 402-559-5555.
2. For contamination involving personal injury (e.g., open wounds, cuts, etc.) the procedure is as follows:
   1. Provide first aid and medical stabilization to the extent possible.
   2. Contact the Radiation Health Center Emergency number at 402-559-5299 for immediate help.
      

This information is included in the Emergency Preparedness Guide.

Exposures - Chemicals

Contact the Campus Emergency Number 402-559-5555 (off campus 911) if the exposure has resulted in the person being grossly contaminated, injured or incapable of rending aid to themselves or if providing assistance to the injured party would put the rescuer at risk. The Poison Control Center can provide some guidance but will need to know the name of the chemical/substance. In the Omaha area, call 402-955-5555 or call toll-free 1-800-222-1222.

This information is included in the Emergency Preparedness Guide.

Exposures - Biological Agents and Materials

Contact 402-559-OUCH (402-559-6824) or 402-888-OUCH (402-888-6824, a pager) for guidance. This number will be answered 24/7 by an EH nurse who will determine where the employee should report for follow-up care. Expert consultation will guide the triage process. Case management for all biologic exposures will be completed through EH.

A post-exposure treatment algorithm and agent-specific protocols have been developed for biological agents and materials (referred to as the Post Exposure Agent Specific Protocols). Protocols have been established to address agents for the types of exposures that could occur on campus. All IBC applications involving research with biological agents must include information for post-exposure management. Information regarding biological incidents and spills is included in the Emergency Preparedness Guide.

Incident Reporting

UNMC employees, students, and volunteers are required to complete an Incident Report for all accidents/incidents involving injury. Unsafe conditions or "Near-Miss" incidents that did not result in injury, did not involve patients, or occur in clinical areas may be reported to UNMC EHS using the Near Miss/Potential Hazard Form. See Reporting of Research-Related Adverse Event SOP#UNMC-IBC 24 for additional steps for reporting Research-Related Adverse Events.

Confidentiality and Access to Medical Records

Each person included as a part of the Medical Surveillance Program will have a confidential medical record including documentation of immunizations and other medical services received through the program. These records will be maintained in EH.

The EH clinic is authorized to share information, when necessary and as it pertains to safety, and/or job duties, with EHS professionals at UNMC. EHS personnel are also bound by confidentiality and privacy regulations and assist with risk assessment and mitigation, training, program enrollment and compliance tracking.

Additional Information

• Contact UNMC Environmental Health and Safety or 402-559-6356
• UNMC Environmental Health and Safety
• UNMC Environmental Health and Safety Policies, Plans and Guidelines
• Radiation Safety, 402-559-6356 (during business hours) or 402-559-5555 (after normal business hours)
• Emergency Preparedness Guide
• UNMC Bloodborne Pathogen Exposure Control Plan
• IACUC Policy for Occupational Health and Safety for Personnel with Animal Exposure
• UNMC Incident Reporting
• UNMC Incident Report
• [https://app1.unmc.edu/forms/ehs/ehs_incident_report.cfm Near Miss/Potential Hazard Form
• Reporting of Research-Related Adverse Event SOP#UNMC-IBC 24
• Medical Screening and Surveillance Requirements in OSHA Standards: A Guide

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