This provision of the draft standard would, based on the type and level of service(s) established by the Emergency Service Organizations (ESO), require the ESO to establish minimum medical requirements based on the tiers of responder duties, tasks, and responsibilities. A qualified healthcare professional would perform the medical evaluation of the responders. The medical evaluation would include a medical and vaccination history, physical examination, and any laboratory tests required to detect physical or medical conditions that could adversely affect the responder’s ability to safely perform the essential job functions. Components of the medical evaluation program would comply with the corresponding requirements of §1910.95, Occupational noise exposure; §1910.134, Respiratory protection; and §1910.1030, Bloodborne pathogens. The medical evaluation would be performed on each responder as a baseline for surveillance and annually thereafter. Also, each responder would be evaluated following an occupational exposure, illness, injury, or protracted absence from the job. The draft standard would also require the ESO to
- establish minimum physical performance requirements for responders and ensure responders meet the requirements before beginning training or becoming a responder if already trained
- develop and maintain a level of fitness that allows responders to safely perform their duties,
- implement a health and fitness program as determined by a qualified health care professional
The program would include at least the following components:
- assignment of a health and fitness coordinator; periodic (not to exceed 3 years) fitness assessment of each responder;
- exercise training; education and counseling regarding health promotion; and
- a process for collecting and maintaining health-related fitness data.
OSHA has never before required a health and fitness program in the workplace. These provisions of the draft standard are based on NFPA provisions and were recommended by the NACOSH subcommittee.
OSHA’s draft standard as written assumes that ESOs would follow the NFPA 1582 standard’s requirements for medical screening and surveillance. It is possible that some types of medical screening and surveillance may have a minimal impact on protecting responders from significant occupational risks. If this was determined to be the case, some tests or groups of tests could remain as recommended by the consensus standard but would not be required under an OSHA standard.
This provision of the draft standard would also require ESOs to provide access for responders to a confidential behavioral health and wellness program that would include the following
components as a minimum: the capability to provide assessment; access or referral to basic counseling (at this time, OSHA does not intend to require ESOs to bear the costs for responders to attend counseling); crisis intervention training; referral to services that would provide an assessment that includes alcohol and substance abuse, stress and anxiety, depression, and personal problems that affect work performance; prevention strategies and health promotion activities related to identified risk factors for emergency responders’ health and safety; and protocols to address occupational exposure to atypically stressful events. OSHA has never before required behavioral health and wellness programs in the workplace. These provisions of the draft standard are based on NFPA provisions and were recommended by the NACOSH subcommittee.
Under the draft standard, the ESO would also maintain a permanent health database for analysis of factors pertaining to the overall group of its responders, as well as a confidential file for each responder.