Chapter X

ESTABLISHING THE RIGHT MEDICAL PROGRAM FOR YOUR WORKSITE: THE OCCUPATIONAL HEALTH DELIVERY SYSTEM

INTRODUCTION

Are you remembering the "health" in your occupational safety and health program?  The Occupational Safety and Health Act of 1970 aims "...to assure so far as possible every working man and woman in the Nation safe and healthful working conditions...."  Toward this end, OSHA's Safety and Health Program Management Guidelines strongly urge the identification and control of health hazards and the implementation of a medical program.

A medical program is another name for the systems that employers put in place to ensure occupational health expertise within the overall safety and health program.  Having a medical program does not necessarily mean that you must go out and hire a doctor to work at your company.  There are many ways for you to find and use occupational health expertise.  This chapter will help you decide what will work best for your business.

We call the medical program the occupational health delivery system, or OHDS.  This term will help you remember that a comprehensive program is more than an after-the-fact response to work-related injuries and illnesses.  It also includes the activities that uncover the safety and health hazards in your business and that help you formulate a plan for prevention or control.  It is a management system in the same wy that the actions you take to promote safety are a management system.

You may find it more difficult to establish the goals and objectives for your OHDS than for the other parts of your safety and health program.  The harm it prevents may not appear obvious at first.  For example, an employee who is experiencing hand pain and who gradually is developing a cumulative trauma disorder (CTD) may seem to have a less serious problem than the employee who has a severe cut or broken bone from an accident.  But OSHA's experience is that work-related health problems are no less serious in terms of human suffering and costs than the more obvious injuries.

An effective OHDS will help reduce all types of safety and health hazards and the resulting injuries and illnesses.  The positive results from such a program will be measurable by a drop in lost workdays and workers' compensation costs.  You also can expect this program to help increase worker productivity and morale.

WHO SHOULD MANAGE THE OHDS?

You will find that the OHDS works best when managed by occupational health professionals (OHPs).  A physician or a registered nurse with specialized training, experience, and knowledge in occupational health works with you but not necessarily as your employee.  This arrangement works best because safety professionals, industrial hygienists, occupational medicine physicians, and occupational health nurses all have their own areas of specialized knowledge.  You cannot expect to get all the information and service your safety and health program needs from only one type of specialist.  If you tried, you might overlook or misidentify a dangerous hazard in your business.

Appendix 10-3 contains a description of the different ways that physicians and registered nurses receive specialty training in occupational medicine and health and the different services that they can provide you.  Chapter 7 contains information about some of the services you can get from safety professionals and industrial hygienists.

WHAT SERVICES DO YOU NEED FROM YOUR OHDS?

There is no such thing as a standard OHDS.  There is no substitute for examining your business' special characteristics and developing an OHDS that is right for you.  These special characteristics include:

As you look at the characteristics of your employees and workplace, you should be asking yourself questions such as:

You should be aware that, under the Americans with Disabilities Act (ADA), employers may require employees to submit to medical examination only when justified by business necessity.  It is OSHA's judgement that a health and safety concern qualities as a business necessity.  The results of any medical examination are subject to certain disclosure and record retention requirements (see Part 1910.20 of Title 29, Code of Federal Regulations), but also are subject to confidentiality requirements of the ADA.  The ADA's employment-related provisions are enforced primarily by the U.S. Equal Employment Opportunity Commission.

Answering these questions will put you in a better position to decide which OHDS services you need.  The services are listed below.  Appendix 10-1 includes some examples of how different companies varied sizes tailor their OHDS activities.

THE RANGE OF OHDS FUNCTIONS

There are three basic types of OHDS activities:

  1. Prevention of hazards that cause illnesses and injuries,
  2. Early recognition and treatment of work-related illness and injury, and
  3. Limiting the severity of work-related illnesses and injury.

Preventing Hazards

Early Recognition and Treatment

Limiting Severity

SUMMARY

Your business' medical program, what we call its occupational health delivery system, is an important part of your safety and health program.  It can deliver services aimed at preventing hazards that can cause illness and injury, rapidly recognizing and treating illness and injury, and limiting their severity.

To determine which of these services are appropriate, you need to consider your business' special characteristics.  These include the type of processes and materials your employees work with and the resulting or potential hazards.  Other considerations are the type of facilities in which employees work, the number of workers at each site, and the characteristics of the work force, such as age, gender, cultural background, and educational level.  The location of each operation and its proximity to a health care facility also are important.

Whether you hire or contract with an occupational health professional, make sure this person has specialized training, experience, and up-to-date credentials.  Then use him/her to help you develop and deliver the services you have chosen.