How Well Do You Know Your Employees?

Monitor the health and physical condition of workers periodically to make certain workplace conditions aren't causing medical problems.

KNOWING who your employees are begins at the time when you hire them. Many do's and don'ts must be considered, but in the final analysis, we must take our employees as we find them--with all their physical limitations, disabilities, job skills, etc.--and assign them.

Finding a good match can be a difficult task that is almost always compounded if you do not know their physical condition. There is no "average employee" who has the physical ability to perform all assigned job duties. There is only the employee whom you hired, and each must be evaluated individually. Do you know whom you hired?

As important as the initial evaluation is, there is also a need to periodically monitor the health and physical condition of employees to make certain workplace conditions are not causing medical problems. This is particularly true when chemicals, solvents, and airborne particulates are present in the work environment. Bench assembly, computer operations, and secretarial jobs intensify concerns about repetitive motion injuries. Hearing loss can become an issue in noisy work areas. Other issues include exposure to temperature extremes, heights, vibration, and radiation. Each has the potential to cause insidious health deterioration. Do you know how your workplace is affecting your employees? Do you know the potential injury and illness costs that workplace exposures can have on your business?

Non-job-related activities also can have a negative impact in the workplace if they are not monitored (e.g., communicable diseases, traumas that produce residual disabilities, and family problems). While it is not possible to know all of the potential problems, one must be monitored: drug and/or alcohol use. Do you have an effective substance abuse program?

The key elements to an effective medical surveillance program include:
1. Knowing the physical limitations of those you hire.
2. Establishing an Accommodation Review Team (ART).
3. Identifying occupational health exposures.
4. Monitoring and documenting health exposure levels.
5. Enforcing personal protective equipment programs.
6. Providing prompt injury treatment and follow-up.
7. Expanding medical data gathering programs.
8. Implementing drug/alcohol abuse testing programs.
9. Offering wellness programs to employees.

Evaluating with an Eye on ADA
The best method to evaluate the physical condition of prospective employees is to have them complete a medical history questionnaire followed by a pre-placement physical examination. The objective is to determine physical limitations, documented disabilities, and individual sensitivities. Take care to make certain the data you gather are not used to preclude employment, but rather to ensure proper job placement. Individual medical files must be created and a data tracking system for physical limitations developed.

The Americans with Disabilities Act explains that prospective employees can be evaluated only for their ability to perform "essential job functions." The specific physical requirements of each job must be established and a physician must be able to use these data, as well the results of a physical examination, to evaluate an applicant's ability to perform essential job requirements (e.g., frequency and duration of standing, walking, sitting, lifting, stooping). If employment is rescinded, it must be because the individual does not have the physical ability to perform the "essential job functions" with reasonable accommodation.

Some accommodation issues can be resolved with simple observation. For example, a 300-pound applicant cannot fit into a confined work space if the opening into the space only accommodates a 150-pound person. Likewise, an applicant 6 feet tall cannot safely perform work in a low-clearance work area. These are physical characteristics that accommodation cannot improve. Some examples of reasonable accommodations might include providing additional means of access to the work area, special hand tools, additional lighting, and modifications or changes in work procedures.

The Accommodation Review Team
It is essential all job applicants be given an equal employment opportunity. Someone who meets the requirements for the essential job functions may require a job accommodation. Establishing an ART that includes medical expertise is an effective technique for addressing accommodation.

Physical disabilities must be evaluated to determine the feasibility of accommodations. In many cases, state-of-the-art technology and/or the services of a rehabilitation consultant may be required. When getting the individual to the job is an issue, alternative transportation must be evaluated (e.g., installing an elevator; moving the job to the first floor; special parking privileges). In other cases, continuous or periodic medical assistance may be required during the regular work day. These are circumstances that require medical expertise. Do you have an ART or other program to evaluate accommodation? Is there participation by employees who are handicapped or who have been accommodated?

Occupational Health Risk Assessments
Workplace health standards established by agencies such as OSHA and NIOSH establish exposure levels that indicate the extent to which an "average worker" can be exposed without significant health risk. Compliance with these standards does not preclude development of adverse health effects. Periodic monitoring of each worker's health conditions is required. The objective is to prevent occupational disease, and the associated personal and financial losses to the individual, the individual's family, and the company.

Adverse occupational health information can result from a broad range of workplace exposures and for many reasons. Workers can be exposed to elements in three ways: absorption, inhalation, and ingestion. The key fact in exposure is that, while the exposure is initially anticipated, it is not always considered to be an issue until after an injury or illness has occurred. A comprehensive evaluation of new processes or procedures before they are implemented can identify safety and health issues and provide alternative methods that can prevent major injury and illness losses.

Occupational health exposures such as excessive noise, solvent or paint exposure, and exposure to dust, airborne particulates, and radiation must be documented and a medical evaluation program that targets specific body organs needs to be developed. Examination results should be tracked and deterioration in body functions should be documented and used to identify jobs and work areas where specific controls are needed to prevent additional injury and illness.

Take special care to ensure typical non-job-related diseases are not diagnosed as occupational. When examination results clearly indicate a non-job-related problem, the worker should be referred to a private physician. If the condition is clearly job-related, yet no causative exposure exists in the workplace, the worker and the worker's compensation carrier must be advised. Cases that are clearly occupational should be referred to a medical specialist who should act as your worker's compensation "gatekeeper."

X-ray results, spirometry and audiometry evaluations, and other occupational health examination data should be maintained in individual medical files. Exposure profiles should be developed, tracked and evaluated, and additional occupational health evaluations and/or more frequent evaluations should be scheduled if the data indicate a need to do so.

The identification of occupational health issues and the prevention of occupational disease are the primary objectives of industrial hygiene monitoring. Monitoring establishes exposure levels and provides information about each employee's health exposure. This data is essential to any "occupational health risk assessment." When combined with examination data, the information can pinpoint work areas where corrective action to prevent health problems is required.

Industrial hygiene monitoring consists of activities such as sampling air for respirable dust, metal fumes, organic vapors, and gases; measuring noise exposure; assessing ventilation and air exchange rates; and evaluating ionizing radiation. The potential work-related hazard and the likelihood it may change or increase determine monitoring frequency. Exposures that fluctuate (such as paint spraying, noise, or radiation) may require continuous monitoring. The effective integration of examination results and industrial hygiene monitoring data into a medical surveillance program can keep employees out of harm's way. The result becomes a useful tool in preventing unwanted worker's comp losses.

Use of personal protective equipment provides reasonable safeguards against occupational health exposures, provided the hazards are identified and the equipment is properly matched to the potential hazard (e.g., respirator cartridges or gloves) and the worker uses the equipment as instructed. Establishing such a program may require the controlled distribution of protective equipment by a first aid/medical center. Enforcing usage rules is essential. As a last resort, examination results usually can identify areas where additional enforcement is needed.

Injury Treatment and Return-to-Work
Medical surveillance helps control worker's comp losses that result from job injuries. Effective programs are able to reduce claims and even eliminate them before they get started. However, once a claim is established, a return-to-work program that reduces malingering and ensures proper job placement of employees with work restrictions or residual disabilities is essential.

Effective programs result from the collection and review of comprehensive employee medical data. Frequent contact with the medical community is necessary; physicians must understand their role is to determine physical limitations or work restrictions and that the employer always reserves the right to determine employability. Specific internal controls that establish a central clearing point for return-to-work following a job-related injury or illness or extended absence, vacation excluded, may be necessary.

Placement of employees who have work restrictions is generally performed as part of a light duty work program. Such a program permits the employer to stop paying disability payments while utilizing the employee in a restricted capacity. These programs are usually temporary, with a date established for returning to regular work duties. Close monitoring is required to make certain that light duty work does not become a way of life. Employees with residual disabilities should be referred to the ART so their capabilities can be identified in functional terms. This will aid in the design of modified work programs and/or permanent job placement.

Medical leave-of-absence and/or insurance benefit programs are an effective means of monitoring an employee's health conditions if the medical information remains confidential and is available for use at a facility medical center. Very often this does not occur, and individual claims are processed without the employer's knowledge. This can cause job placement issues that remain unknown until a temporary disability results and a medical leave-of-absence is necessary. Expanding in-house medical programs to include basic non-job-related services can sometimes remedy this situation by increasing employee confidence in the facility medical center.

Employee Assistance Programs are another source for employee medical information. Unfortunately, this information also remains confidential and is not always available to the employer.

Drug and/or Alcohol Abuse
There should be a clear policy, communicated to all employees, regarding drug and/or alcohol abuse. Publish action levels; make data about sample collection, identification, and evaluation processes available for review; explain chain of custody procedures; and establish consistent procedures for conducting collections. Management should have a solid understanding of the procedures to be followed, and employees must clearly understand the enforcement provisions.

Programs to consider include pre-employment drug screening, random drug testing, reasonable cause or suspicion drug and/or alcohol screening, post-accident screening, and federal or state testing requirements. The turn-around time for sample analysis should be less than 48 hours. All positive test results should be reviewed and confirmed by a medical review physician. In addition, the testing laboratory should be visited at least once each year to ensure samples are processed properly.

Wellness Programs
Keeping healthy employees healthy is another function of a good medical surveillance program. Periodic programs such as cholesterol screening, stress reduction, mammograms, blood pressure readings, weight loss workshops, and others can provide early warnings of possible medical problems. In most cases, these programs can be conducted at no cost during lunch hours, break periods, or after regular work hours.

The data collected can be used to direct employees to medical specialists where they can obtain additional evaluation and treatment.

The success of medical surveillance programs results from the interaction of many elements. The primary element is always management commitment to providing the highest level of occupational health in the workplace.

Program costs of effective medical surveillance are minuscule in relation to the money saved in downtime, employee turnover, poor quality, and other intangible losses. How effective is your program? How well do you know your employees?

This article originally appeared in the April 2003 issue of Occupational Health & Safety.

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