Employee Medical Monitoring Program

Scope

Medical physical examinations are required for employees in the following categories:

  • Police Officers, pre-employment per California Peace Officer Standards and Training
  • Employees exposed to specific chemical and physical agents as defined in the CCR and CFR

Employees with occupational exposure to the following conditions and chemicals may be placed on the Employee Medical Monitoring Program (EMMP). Those on the EMMP should have a physical during probation and annually thereafter. Here are the programs that would require an EMMP.

Respirator UseExposure Control Plan

Regulatory Authority

Code of Federal Regulations (CFR) Title 29 §1910, Title 40; California Code of Regulations (CCR) Title 3, Title 8 §5139 – 5223 Control of Hazardous Substances, and Title 8 §3203 Injury and Illness Prevention Program; CSU Employee Medical Monitoring Plan Management §1.3 and 1.4; CSU Executive Order 1039 §C

Administrative Agency

California Division of Occupational Safety and Health (DOSH), Department of Industrial Relations (CalOSHA)

Background

Medical surveillance in the occupational setting is the systematic collection and analysis of the health information on groups of workers potentially exposed to harmful agents, for the purpose of identifying health effects at an early and hopefully reversible stage. Biological monitoring, or the measurement of tissue levels of contaminants or metabolites, is often included as part of a medical monitoring program, even though these tests do not measure adverse health effects.

The California Code of Regulations (CCR) requires that employees with potential exposures to certain harmful agents shall receive medical monitoring examinations. These examinations serve the purpose of detecting adverse health effects which could possibly be related to workplace exposures. Early detection of disease will result in earlier treatment and will allow for cessation of additional exposures that could aggravate a potentially serious medical condition. In addition to monitoring of employee health, biological monitoring may also be necessary. Biological monitoring provides a correlation between external exposures and internal exposure. Biological monitoring provides a reliable indication of health risk to an individual worker.

Policy

It is the policy of the CSU that medical examinations mandated by federal and state laws and regulations be enforced by each campus. Failure or refusal of an employee to undergo required medical testing, as determined by campus management, shall constitute a failure or refusal to perform the normal and reasonable duties of the position. In such event, the campus has the authority to commence appropriate disciplinary action up to and including termination of employment.

Objectives
  • Evaluate the health status of potential employees, and determine whether they can perform the job in a safe and effective manner.
  • Detect exposure-related adverse health effects at an early and hopefully reversible stage so that occupational diseases can be prevented, and proper medical care can be rendered, if necessary.
  • Periodically assess employee suitability for ongoing or new assignments that involve potential contact with hazardous agents.
  • Correlate past occupational or environmental exposures with future workplace activities and exposures, to arrive at an opinion on the risk that the job might represent to the health status of the individual.
  • Provide a medical monitoring program that complies with all the pertinent Federal, State, and local regulations.
  • Identify unrecognized effects of exposure by continually evaluating group employee health data to detect possible adverse health trends.

Employee Medical Records and Confidentiality

Access

Employees, their designated representatives, and authorized representatives of Cal/OSHA have full right of access to relevant exposure and medical records. Designated representatives must be given the employees written authorization to exercise the right of access. The legal representative of a deceased or legally incapacitated employee may exercise full right of access to all of an employee’s medical record.

All requests for employee medical or exposure records shall be in writing to Environmental, Health & Safety. EH&S will either have a secure Dropbox with records, or they will be with the medical provider where the employee was seen and a copy can be requested from that provider. A copy or the requested records shall be provided to the employee or designated representative at no cost and no later than fifteen (15) days after the request is made. In the case of an original x-ray, access shall be restricted to on-site examination. Whenever a record has previously been provided without cost to the employee or designated representative, the university may charge for the record search and the cost of additional copies.

In the rare case that a request for records is denied, the employee may appeal the denial to the Division of Occupational Safety and Health (DOSH), State of California. The Chief of DOSH will make a decision on the appeal and may issue an order to release the information to the employee or their designated representative. Designated representatives must be given the employee’s written authorization to exercise rights of access. A written authorization shall contain the following:

  1. The name and signature of the employee authorizing the release of the medical information.
  2. The date of the written authorization.
  3. The name of the individual or organization authorized to release the medical information.
  4. The name of the individual or organization authorized to receive the medical information.
  5. A general description of the medical information that is authorized to be released.
  6. A general description of the purpose for release of the medical information, and a date or condition upon which the written authorization will expire. The employee or representative will be provided a copy of the requested medical records at no charge to the employee.

Retention, Recordkeeping and Confidentiality

An important part of the Employee Medical Monitoring Program (EMMP) is the confidentiality of the medical and exposure records generated by the program. This program has been carefully designed to ensure that the medical information for individual employees be made available only to medical professionals (including medical records services personnel) and the employee. Specifically, individual medical information is not available to CSU Dominguez Hills management personnel, and in the absence of a subpoena, will not be made available to any person other than the employee or their designated representative of State or Federal regulatory agencies, e.g. Cal/OSHA.

The only information kept on file at the University is a cover-letter describing the employee’s medical qualification to perform regular work, a description of work restrictions (if any) and the names of tests completed by the occupational medicine provider.

To ensure that the employee has a complete understanding of these confidentiality procedures and the limited uses that will be made of the employee’s medical data, each CSU Dominguez Hills employee enrolled in the EMMP is given an Authorization for Use or Disclosure of Health Information form by the occupational medicine provider. Employees are asked to sign the form before beginning an exam. The signed authorization form allows the occupational medicine provider to send the records to the campus. In cases where the medical provider will maintain those records, then this form will not be required as the records are kept with the health professional, which could include the CSUDH Student Health Center.

Often, an employee may have undergone a previous medical examination. This information may be of value to the physician performing the exam. If the employee authorizes, copies of these old records may be obtained. The form, Authorization for Use or Disclosure of Health Information, is to be used for this purpose. Medical and exposure records are maintained for 30 years after the termination of employment at California State University, Dominguez Hills.

Definition of Medical and Exposure Records

a. Medical records include the following

  1. Medical and employment questionnaires and histories.
  2. The results of medical examinations and laboratory tests.
  3. Medical opinions and diagnosis, progress rates and recommendations.
  4. First aid records.
  5. Description of treatment and prescriptions.
  6. Employee medical complaints.

b. Medical records do not include medical information in the form of:

  1. Physical specimens (e.g. blood or urine samples) which are routinely discarded as part of normal medical practice.
  2. Records created solely in preparation for litigation which are protected from discovery under applicable rules of procedure on evidence.
  3. Records concerning voluntary employee assistance programs.

c. Exposure records

  1. A record containing measurements or monitoring results of the amount of a toxic substance or harmful physical agent to which the employee is or has been exposed.
  2. In the absence of directly relevant records, records of other employees with past or present job duties or working conditions related to or similar to those of the employee, may be used to indicate the amount and nature of the toxic substances or harmful physical agents to which the employee is or has been subjected.
  3. Exposure records to the extent necessary to reasonably indicate the amount and nature of the toxic substance or harmful physical agent at workplaces or working conditions to which the employee is being assigned or transferred.
Medical Monitoring Program Operations

Administration

  1. Supervisors determine the potential need for employee physicals based on job description and hazard analysis.
  2. Once need is determined, supervisors coordinate with the EHS Office and provide pertinent employee information.
  3. The EHS Director will coordinate the exams with the contracted occupational medicine provider(s) and notify the supervisor and employee of date/time/instructions.
  4. The Department, for whom the employee works, is financially responsible for the total cost of exams, screening, tests, etc.

Examination Frequency

  1. The Initial Baseline Examination - The purpose of the baseline examination is pre-placement or probationary screening. All affected employees shall be given a baseline examination before being assigned to work with respirators or in occupations with known potentially hazardous exposures or Cal/OSHA regulated substances.
  2. Periodic/Annual Examination - All personnel who have taken the initial pre-placement examination and have reviewed clearance by the examining physician shall be re-examined periodically in accordance with hazard-specific regulations. The date of each periodic examination should fall on or as closely as possible to, the anniversary of the previous examination.

Any employee who has not participated in potentially hazardous work or who is no longer required to use a respirator during the 12 month period following his/her last annual examination, and who is not expected to continue to participate, may discontinue participation in the medical monitoring program as determined by the EHS Office and the employee’s appropriate administrator/supervisor.

Record must be kept by EHS clearly documenting the reasoning and approval for each individual discontinuation of participation.

  1. Exit Examination - An exit examination shall be given to any employee whose   employment has included contact with OSHA regulated agents and who has been a participant in medical monitoring. If a medical exam has been administered within one year of exit, this requirement may be waived in certain cases
  2. Special / Emergency Examination (situational medical clearance) - Special testing may be required on certain projects due to the potential for exposure to specific substances. This may be necessary where the potential for heat or cold stress exists, or after an exposure that results in a toxicity reaction. The need for special testing will be assessed on an ongoing basis. Emergency testing may be necessary in the event the of employee exposure.
  3. Physician’s reports - Examining physicians will use the information provided by the employee in the questionnaire, the examination results, and the results of the laboratory tests to determine if any work restrictions or occupational health problems appear to be present. The physician must send a report of the examination directly to the employee as well to EH&S for secure storage if applicable. Alternatively, the medical provider may inform the employer of a simple pass, fail or work restrictions required for the employee and all medical records will be kept at the medical providers’ location. These records are confidential and can only be viewed by the employee, the employee’s representative, and authorized representatives of the Chief of the Division of Occupational Safety and Health.

Non-work related health issues may arise during the course of the medical evaluation. The examining physician may recommend that employees see their family doctor or a specialist. Any additional tests required to investigate non-work related health issues will be the employee’s responsibility.

Routine Examinations

  1. EHS identifies employees covered by these regulations and coordinates the completion of baseline, periodic / annual and exit examinations with the employee or his or her supervisor.
  2. EHS assigns the correct exam or treatment on the authorization for examination or treatment form, which includes the type of exam or treatment the employee is required. The employee fills out their personal information at the top and takes the form to the medical center.
  3. EHS will provide the medical questionnaire to any employee needing medical review to wear a respirator. The medical questionnaire is derived from Cal/OSHA respiratory protection standard appendix C.
  4. The employee completes all applicable forms prior to the examination and observes the pre- exam instructions.
  5. The employee attends the appointment.
  6. The examining Physician completes Patient Status Report Form(s) and forwards it to EHS, if applicable.
  7. The examining Physician prepares any Employee Medical Findings Form and forwards it directly. The examining Physician forwards records to EH&S as needed, or reports pass, fail or any restrictions needed via a work status report. to the employee.
  8. The examining Physician forwards records to EHS as needed, or reports pass, fail or any restrictions needed via a work status report.
  9. Environmental Health and Safety reviews the records or work status report. This may include review with Workers Compensation.

Special Examinations

If situations arise in which an employee may have experienced a hazardous exposure or alleges symptoms, EH&S will evaluate the potential workplace problems and arrange for appropriate medical diagnosis and treatment if indicated or required.

EH&S will contact the examining physician who will coordinate investigations and treatment to determine if overexposure to a hazardous substance has occurred.

An Incident Report detailing the hazardous exposure will be completed by the appropriate administrator and forwarded to EHS.

Examination Protocols

Comprehensive Medical Examination

  1. Identification Provided: Name, birth date, gender, job title, department, etc.
  2. Personal medical history:
  1. Medications
  2. Allergies
  3. Illness, injuries, hospitalizations, surgeries
  4. Smoking, alcohol, drug histories
  5. Medical conditions-specifically lung disease, heart disease, liver disease, skin conditions neurological diseases
  1. Family medical history: specifically cancers and lung heart liver disease, skin conditions,
  2. General Appearance and Physically Development and Posture: Height and weight are recorded.
  3. Head-Eyes: Titmus vision testing including near, far, color vision and depth, lateral phoria, esophoric, exophoric and vertical phoria (right and left hemisphere) and peripheral vision. Also noting ptosis, discharge, visual fields, ocular muscle imbalance, presence of corneal scarring, exophthalmos or srabismus uncorrected by corrective lenses. If the applicant wears contact lenses, it will be noted whether they have good tolerance and has adapted to their use. All vision testing is done without corrective lenses and then with the corrective lenses. This is done in order to determine a baseline vision as well as effectiveness of corrective lenses. Note that certain positions do not allow the use of contact lenses.
  4. Ears: Audiometric tests shall be pure tone, air conduction, hearing threshold examinations with test frequencies including as a minimum, 500, 1000, 2000, 3000, 4000 and 6000 Hz. Tests at each frequency shall be taken separately for each ear. Audiometric screening should meet specifications of, and be maintained and used in accordance with ANSI, S 3.6-1969. Audiometry testing room should meet the requirements for maximum allowable octave-band sound pressure levels for audiometric test rooms. In addition, audiometric calibration should be checked acoustically on an annual basis according to Title 8 California Code of Regulations, Section  5097 Appendix D. Ear examination also includes noting any evidence of mastoid or middle ear disease, discharge symptoms of aural vertigo or Meniere’s Syndrome.
  5. Throat: Examination includes detection of any deformities of the throat, larynx, masses or nodes which may interfere with normal breathing and eating.
  6. Heart: Auscultation by stethoscope for heart sounds, presence of murmurs, clicks, rubs, additional heart sounds and dysrhythmias. PMI will be ascertained and full cardiac history is obtained for symptoms such as dyspnea, palpitations, syncope. Blood pressure determinations are also made.
  7. Pulmonary: Examination of lungs and thoracic area. Breath sounds are examined specifically noting any signs of chronic obstructive pulmonary disease, congestive heart failure and history of lung disease like asthma or bronchitis.
  8. Gastrointestinal System: Complete history, and current signs and symptoms will be noted. Noting will be made specifically for presence of hernia, scars, weakness or injuries, location, size and character of any abdominal masses. Bowl sounds will also be noted. A rectal examination with stool guaiac will be obtained on all male employees over 50 years of age.
  9. Genitourinary: Examination for presence of infection or other abnormal findings including urinalysis (noting uncontrolled diabetes, presence of albumin).
  10. Neurological: Examination includes pupil reflexes for light and accommodation, sensory, vibratory and positional movements.
  11. Extremities: Close examination of all extremities for color, warmth, presence of peripheral pulses and skin tugor. Any deformities, paralysis or varicose veins and leg muscle weakness will be documented.
  12. Spine: History of pain, injuries, and physical examination for deformities will be performed.

Additional Tests as Required

  1. Resting 12-lead Electrocardiogram: Electrocardiograms will be read by a Board Certified Cardiologist. 
  2. Treadmill EKG: or MASTER TEST
  3. Pulmonary Function Testing: To include (at the discretion of the examining physician):
  1. FVC- Forced Vital Capacity
  2. FEV 1.0-Forced Expired Volume in one second
  3. FEV 3.0-Forced Expired Volume in three seconds
  4. FEF 25-75 - Forced Expiratory flow
  5. RV - Residual Volume

Results of pulmonary function testing are calibrated in prediction equations. Degree of respiratory impairment is assessed. Some obstructive diseases that may be associated with abnormal findings include: chronic bronchitis, asthma and emphysema. Restrictive diseases like pleural thickening, pulmonary fibrosis and congestive heart failure are associated with other abnormalities found in pulmonary function testing. All pulmonary function testing equipment must be approved by the American Thoracic Society and the operators must be certified by NIOSH (National Institute for Occupational Safety and Health).

  1. Complete Blood Count (RBC, Hgb, HCT, WBC, differential)
  2. Blood Chemistry Panel, Requiring any/all of the following tests:
    GlucoseSodiumPotassium
    ChlorideCreatinineBUN
    PhosphateUric acidCholesterol
    Total proteinCalciumGlobulin
    TriglyceridesAlbuminTotal Bilirubin
    Alkaline PhosphataseG-Glutamyl TranspepTransaminase (AST ALT)
    LDHSickle Cell IndexLead
    MercuryCadmiumCobalt

All laboratory testing is performed by a CLIA approved and licensed clinical laboratory.

  1. Chest X-Rays: Posterior / anterior view x-rays. Radiologist interpretation should be done by a Board Certified Radiologist. For employees with potential asbestos exposure, Certified “B” readers will interpret x-rays.
  2. Urinalysis (with Microscopy) to test for:
Specific GravitypH
Albumin GlucoseAcetone Protein
  1. Biological Monitoring for Lead:

Blood lead level

Hemoglobin and hematocrit, red cell indices and peripheral smear morphology. Zinc protoporphyrin (ZPP)
Blood Urea nitrogen and creatinine

  1. Red blood cell and Plasma Cholinesterase Tests
  2. Stool Specimen

Submitted for culture and examination for OVA and parasites

ANNEX - SPECIFIC STANDARDS AND PROTOCOLS

Respiratory Protection (8 CCR 5144)

B.1    Covered employees

Any employee who has the occasion to use any form of respiratory protective equipment

B.2    Examinations

Persons should not be assigned to tasks requiring the use of respirators unless it has been determined that they are physically able to perform the work while using the required respiratory equipment. A licensed physician shall determine what health and physical conditions are pertinent.

B.3    Frequency

The medical status of persons assigned use of respiratory equipment shall be reviewed annually.

B.4    Standard Respirator Clearance

  1. OSHA’s Respirator Medical Evaluation Questionnaire (mandatory)
  2. Respirator physical exam if deemed necessary by the Health Care Professional
  3. PFT at discretion of Health Care Professional, or at employers preference
  4. Chest X-ray at discretion of Health Care Professional
  5. Authorization for any additional testing/exam as deemed necessary by the Health Care Professional
  6. Health Care Professional written statement for respirator use
  7. Qualitative or quantitative fit testing depending on type of respirator, as requested by the employer. Alternatively can be performed by the employer

B.5    Physicians Report

Shall indicate if there are any restrictions to the wearing of respiratory protective equipment; shall indicate what levels of respiratory equipment may be worn.

Blood Borne Pathogens (8 CCR 5193)

D.1    Employees covered

All employees who could be “reasonably anticipated” to have occupational exposure to blood or other potentially infectious materials (OPIMs).

D.2    Examinations

All medical evaluations and procedures are to be conducted under the supervision of a licensed physician or another licensed healthcare professional. A “licensed healthcare professional” is defined as a person whose legally permitted scope of practice allows them to independently perform the activities required.

D.3    Program

  1. Voluntary hepatitis vaccinations shall be offered to all employees who have occupational exposure to blood or OPIM’s within 10 working days of appointment or assignments
  2. An employee declining a Hepatitis B Vaccination must sign a Hepatitis B declination form.
  3. An employee who initially declines hepatitis B vaccination but at a later date decides to accept the vaccination, shall receive that hepatitis vaccination at that time.
  4. If a routine booster dose (titer) of hepatitis B vaccine is recommended by the U.S. Public Health Service at a future date, such booster dose(s) shall be made available to identified employees.
  5. Following an exposure incident, a confidential medical evaluation must be performed to include documentation regarding circumstances of exposure, source testing if feasible, testing exposed employees blood (with consent), post-exposure prophylaxis, counseling and evaluation of reported illness.
  6. See the CSUDH Exposure Control Plan for required forms.