Medical Surveillance vs Medical Screening

These are often used interchangeably, but there is a distinct difference which is frequently misunderstood.  

• By Karen Kono
• Sep 01, 2021

When companies are asked why they do medical screening or medical surveillance the typical answer is, “Because we have to.” Often, this is the correct answer, as OSHA and other regulatory agencies require medical surveillance and/or screening programs for certain workplace exposures. Companies across the United States spend a lot of money on these programs and the cost is on the rise. Unfortunately, many of them fail to manage their programs effectively, resulting in widespread failure to actually identify, reduce or eliminate hazards before serious damage is done to their employees, or until serious liability occurs. The best approach to prevent this and to realize the actual benefit of these programs is for companies to fully understand the program objectives and to have a working knowledge of the program’s complexities which takes a multi-disciplinary team of internal and external contributors.

One of the most basic things to be aware of is the difference between medical surveillance and medical screening programs. These are often used interchangeably, but there is a distinct difference which is frequently misunderstood.

Medical screening, in general, focuses on the individual worker and consists of a periodic “screening” examination and evaluation, which is performed not because an employee is exhibiting symptoms of illness, but because they are potentially exposed to a known workplace hazard(s). Medical screening may consist of a physical exam, a detailed personal and work history and any number of tests used for biological monitoring. It can include blood tests, radiological imaging, pulmonary function tests (spirometry), electrocardiograms and more. It provides a snapshot in time which may be useful in identifying potential health effects before the employee even exhibits any symptoms or has any idea that there may be an issue. Medical screening is helpful in early identification of illness, which allows early intervention (typically by way of removal from continued exposure) and/or treatment of the condition or key risk factors.

However, it is important to understand that medical screening is only a component of medical surveillance, which is a much more complex and systematic process.

Medical surveillance is the broader activity, and its focus is on the entire group, not just the individual. It is a systemic process of data collection over time, and this data is used to analyze trends in work groups, which, when used correctly, can lead to evidence-based intervention. Not only is surveillance useful in evaluating known exposures, but it can be critical in identifying new and emerging trends in the workplace. By effectively analyzing types and routes of exposure, medical surveillance can be critical in identifying ways to reduce or even eliminate exposures, thereby reducing morbidity within the occupation.

In addition to appreciating this basic difference between medical screening and surveillance, other program issues are critical to understand. Developing and maintaining a comprehensive medical surveillance program can be challenging, to say the least. A number of flaws in the current regulations make it difficult to properly implement programs for even the savviest employers. OSHA regulatory language has become more detailed and sophisticated over the years, but even recent regulations have a number of very “gray” areas. This is not likely to change any time soon.

For example, for many OSHA medical screening requirements, the regulatory language defers to whatever is deemed “appropriate” by the Primary Licensed Healthcare Professional (“PLHCP”). Though there are a number of accepted “standard practices” within the occupational health industry, the subjective opinion of the provider comes into play, resulting in some variance on recommended components. Employers without a medical director or trusted occupational health provider to act as their PLHCP can be left in the lurch. Many times, industrial safety professionals are charged with responsibility for these programs. They find themselves walking the fine line between maintaining compliance, for all the right reasons, and fears of knowing too much when it comes to sensitive medical information. It is not uncommon for employers to be too conservative, or too liberal in their approach.

In addition to that, employee suspicions of management conniving, especially when labor unions are involved, and the most appropriate efforts can become jaded. For well-meaning employers, finding that fine line can be tricky. It is often helpful to assign responsibility for this type of program to someone outside of the human resources department, for that reason, and so it often falls on safety professionals in businesses that do not employ internal occupational health nurses. This can be risky, despite the best efforts.

Often, employees get sent to different medical providers over time, and the previous records are not available to the examiner, making valid surveillance impossible. This often makes it necessary for employers to develop a way to track their employee’s information in both a secure and comprehensive manner.

Compounding this problem, program management technology in this area is lacking solutions that effectively meet the needs. There are a number of occupational health & safety solutions on the market, but none of them encompass the entirety of medical surveillance compliance needs. Many do an excellent job of scheduling, reminding and storing documentation, but few, if any, are actual intuitive program management tools.

If the information is not properly tracked, this can lead to difficulties with medical clearances. This is because most OSHA regulations require the employer to provide the examining healthcare professional with information about the job requirements and working conditions, PPE used and exposure levels in addition to prior medical records. This information is seldom provided by the employer, leaving the medical examiners (PLHCPs) with very little objective data on which to base their clearance determinations. Medical providers often find it exhausting to continually ask for the necessary information without appropriate response and ultimately work with whatever information they have available.  This can delay or prevent valid medical clearance of employees. Effective programs have strategies in place and access to expertise to handle issues like this. It really does “take a village.”

In summary, properly navigating and executing the complexities of medical screening and medical surveillance programs requires a detailed familiarity of the regulations and their issues (such as comprehensive and consistent record-keeping). Employers who partner with an experienced occupational health professional to help navigate this complicated process are more likely to prevail in compliance inspections and reap the benefits of early identification of illness and better long-term health outcomes for their employees.

This article originally appeared in the September 2021 issue of Occupational Health & Safety.