Occupational healthcare professionals play a vital role in promoting and maintaining the health, safety, and productivity of the workforce. Therefore, establishing a strong alliance between employers and qualified healthcare professionals is essential for fostering a “healthy” workplace and safe work culture. This partnership ensures that employees receive timely, evidence-based medical treatment and preventive medical care, enabling employers to manage employee health risks while staying compliant with required occupational health regulations .
Qualified physicians or licensed healthcare professionals (PLHCPs) are legally permitted to independently provide, or be delegated the responsibility to provide, some or all of the healthcare services for employees. They may be physicians, occupational medicine specialists, nurses, physician assistants, audiologists, optometrists, physical/occupational therapists, or even chiropractors. They specialize in preventing and managing work-related illnesses, conducting health assessments, and ensuring compliance with occupational health regulations. By working seamlessly with employers and employees, they not only support employee well-being but help to reduce the overall cost of workplace health issues.
Scope
Healthcare professionals may be qualified through licensing or credentialing, specialized training, and experience in occupational health, knowledge of regulatory standards, and have the highest of ethical standards. OSHA requires PLHCPs to be legally permitted by their professional license to conduct the type of medical evaluation required by regulatory standards. The scope of practice for any PLHCP is determined by their state license, registration, or certification.
In facilities covered by OSHA’s federal jurisdiction, PLHCPs must be licensed by a state; however, they are not required to be licensed in the state in which they are practicing. OSHA allows any PLHCP who is not licensed in a state but is working in a federally-covered facility to conduct medical evaluations only if the person is working under the supervision of a PLHCP .
Regulatory citations
GENERAL INDUSTRY
- 29 CFR 1910 Subpart Z – Toxic and hazardous substances
- 29 CFR 1910.95 — Occupational noise exposure
- 29 CFR 1910.1020 – Access to employee exposure and medical records
- 29 CFR 1910.1030 — Bloodborne pathogens
- 29 CFR 1910.134 – Respiratory protection
- 29 CFR 1910.1450 — Occupational exposure to hazardous chemicals in laboratories
CONSTRUCTION
- 29 CFR 1926 Subpart Z – Toxic and hazardous substances
- 29 CFR 1926.33 – Access to employee exposure and medical records
- 29 CFR 1926.52 — Occupational noise exposure
- 29 CFR 1926.65 — Hazardous Waste Operations and Emergency Response (HAZWOPER)
- 29 CFR 1926.103 – Respiratory protection
MARITIME
- 1915.1025 – Lead
- 1915.1027 – Cadmium
- 1915.1028 – Benzene
- 1915.1001 – Asbestos
- 1915.1050 – Methylenedianiline (MDA
- 1915.120 – Hazardous Waste Operations and Emergency Response (HAZWOPER)
Key definitions
- Evidence-based: Founded in extensive research, analysis, or other fact-gathering methods.
- Occupational: Being related to the workplace.
- Physician or other licensed health care professional (PLHCP): An individual whose license, registration, or certification legally authorizes them to independently perform, or accept delegated responsibility for performing, some or all of the healthcare services required by a specific OSHA standard.
- Qualified: One who, through a recognized degree, certificate, professional standing, or extensive knowledge, training, and experience, has demonstrated the ability to address and resolve issues related to the subject matter, work, or project.
- Written medical opinion: A document provided by the examining physician or other legally permitted PLHCP after a required medical examination under an OSHA standard. A written medical opinion must not include unrelated medical findings or diagnoses to protect employee confidentiality but will typically include:
- The date of the examination,
- The results of the medical evaluation relevant to the employee’s ability to work safely,
- Any recommended limitations or restrictions on the employee’s exposure or use of personal protective equipment.
- A statement that the employee has been informed of the results of the examination and any medical conditions that require further evaluation or treatment.
Summary of requirements
Employers must work with qualified PLHCPs to:
- Maintain strict confidentiality to protect employee personal health information according to Health Insurance Portability and Accountability Act (HIPAA) requirements.
- Ensure written medical opinions are obtained from the PLHCP in the OSHA-required timeframe and include only the required elements per the applicable OSHA standard.
- Ensure each employee receives a copy of the written medical opinion within the timeframe specified in the applicable OSHA standard.
- Provide prompt follow-up on any health-related restrictions or recommended accommodations.
- Provide any follow-up procedures or periodic medical exams and tests indicated in the written medical opinion and the applicable OSHA standard .
- Provide employees with termination exams as required by the applicable OSHA standard.
Also, employers must:
- Ensure employees understand the employer’s medical surveillance/evaluation program, if it is part of employee training and information requirements of an applicable OSHA standard.
- Inform employees annually of the information listed in 1910.1020(g).
- Provide employees with medical-removal protections as required by an applicable OSHA standard.
- Make and maintain an accurate record for each employee covered by any medical surveillance requirements.
- Maintain employee medical records and make them available as required by applicable OSHA standards, including 1910.1020.
