Occupational Health and Medical Surveillance Programs

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Policy Number:
UW-2104
Responsible Office:
Environmental & Occupational Health

University Policy

Rationale/​Purpose:

The Environmental & Occupational Health (EOH) program is dedicated to the well-being of employees and students. In alignment with federal regulations and accrediting and funding agencies, this policy establishes parameters for monitoring and maintaining occupational health associated with employment, research, and study at the University of Wisconsin-Madison.

Definitions:
Adherence Tracking
Monitoring by Occupational Health of compliance with recommended guidelines and policies.
Affiliate
For purposes of this policy, an individual (e.g., contractor, emeritus faculty, researcher, vendor, visitor) with certain privileges and/or access to UW-Madison resources and facilities or systems who is not an employee or student.
Department Environmental Health and Safety Coordinator
Individual in a unit responsible for ensuring compliance with EOH policies and offering employees and students surveillance services.
Employee
An individual as defined in UW-5000 Employment Categories.
EOH Records
Documents that include one or more of the following:
  • Patient medical records: Detailed and confidential documents of a patient's health history, treatments, and interactions with healthcare providers. These documents, stored securely within a HIPAA-compliant electronic medical system, are only released with the patient's permission, and an accounting of all disclosures is maintained to ensure transparency and compliance.
  • Occupational health records: Documents that capture information about an employee's health concerning their job, including workplace conditions, work-related injuries, and any health issues. These documents do not include specific medical information and are only released to supervisors or other UW-Madison agencies as "Medical Clearance Reports" or "Adherence with Occupational Health Programming".
  • Employee substance use records: For purposes of this policy, documents that capture the results of routine, eight-panel drug screenings ordered through Environmental & Occupational Health (EOH) providers, and used as part of the Select Agent Suitability and Reliability Assessments (SASRA) program.
Medical Surveillance
The analysis of individual health information to detect any issues related to hazards in the classroom, laboratory, and/or workplace.
Occupational Health Surveillance
The collection and analysis of data on hazards in the classroom, laboratory, and/or workplace.
Personal Protective Equipment (PPE)
For purposes of this policy, specialized clothing or equipment worn for protection against a hazard (e.g., gloves, gowns, face shields, masks, protective eyewear, mouthpieces and resuscitation bag, or other ventilation devices). 
Scope:

This policy applies to employees, students, and affiliates of the University of Wisconsin-Madison.

Policy:

  1. Roles and Responsibilities in Occupational Health and Medical Surveillance

    1. Occupational Health is responsible for:
      1. Determining whether an individual's job duties, educational, or other university activities require enrollment in occupational health programs;
      2. Communicating requirements and reminders;
      3. Training requirements;
      4. Adherence tracking;
      5. Maintaining relevant records; and
      6. Contacting the Office of Human Resources to determine consequences for non-compliant employees, or the schools/colleges to determine consequences for non-compliant students.
    2. Supervisors are responsible for communicating specific occupational health program requirements to employees.
      1. Position descriptions must include surveillance criteria when surveillance is mandatory.
      2. Discloure statements must be provided to employees indicating risks for participation in or declination of surveillance.
        1. Employees who decline to participate in offered services must complete a consent or declination statement.
        2. A record of offered services and declination must be maintained in the employee occupational health record in the Environmental & Occupational Health (EOH) program, separate from the personnel record.
    3. School/college leadership and/or instructors are responsible for communicating specific occupational health program requirements to students.
      1. Educational activities must include surveillance criteria when surveillance is mandatory.
      2. Disclosure statements must be provided to students indicating risk for participation in or declination of surveillance.
        1. Students who decline to participate in offered services must complete a consent or declination statement.
        2. A record of offered servies and declination must be maintained in the student's occupational health record in the Environmental & Occupational Health (EOH) program, separate from the student academic or University Health Services record.
    4. Departments and units are responsible for maintaining health records specific to programs in their area (e.g, hearing conservation, respiratory protection) and ensuring no records contain personal health information (e.g., medical diagnoses or test results).
    5. Affiliates are responsible for completing the Affiliate Enrollment form available from EOH.

  2. Mandatory Participation in Occupational Health and Medical Surveillance

    1. Surveillance is required to protect the health of the UW-Madison community, affiliates, and visitors, and to comply with federal Occupational Safety and Health Administration (OSHA) standards.
    2. Surveillance requirements must apply equally to all members of the UW-Madison community.
    3. Services must be provided equitably to all members of the UW-Madison community.
    4. Per UW-4121 Animal Program: Occupational Health Program Enrollment, active participation in the occupational health program, including annual submission of the Animal Contact Risk Questionnaire (ACRQ) and engagement in surveillance programs, is mandatory for any teaching, research, or training activities involving animal contact.
    5. Provision of occupational health surveillance services must be supplemented with training and provision of appropriate personal protective equipment (PPE).

  3. Confidentiality and Environmental & Occupational Health (EOH) Records

    1. All individuals have a right to maintain the confidentiality of their EOH records including:
      1. Patient medical records:
        1. Services rendered by licensed clinics and health agencies
        2. Occupational Medicine services provided by EOH staff
          1. Tuberculosis risk assessment and symptom screening
          2. Tuberculosis testing, vaccinations, and related medical assessments
          3. Respiratory Fit Testing (RFT) results
          4. Respiratory Medical Evaluation Questionnaire (RMEQ)
          5. Animal Contact Risk Assessment Questionnaire (ACRQ)
          6. Service Personnel Limited Animal Area Access Form (SPLAAAF)
          7. Measles immunity statements
          8. Residential Youth Activity (RYA) Staff Health History form
        3. Services reimbursed by federal or state emergency services funding
        4. Medical records for worker's compensation evaluations
      2. Occupational health records:
        1. First aid records of job injuries causing loss of work time
        2. Safety and exposure records
        3. Enrollment in required Occupational Health programming including, but not limited to:
          1. Animal contact
          2. Hearing conservation
          3. Respiratory protection
          4. Respirable crystalline silica
        4. Assignment of PPE
        5. Declination statements
        6. Employee fitness for duty statement as required by the Occupational Safety and Health Administration (OSHA)
      3. Employee substance abuse records
    2. In compliance with the Health Insurance Portability and Accountability Act (HIPAA), EOH regards health records as confidential and will only release information:
      1. When required by law, or
      2. In aggregate when overriding public health considerations, or
      3. To the individual or to healthcare providers at the request of the individual, or 
      4. For purposes of occupational health management (i.e., limited to fitness for duty statements and surveillance program procedures), and
      5. Only with the prior written authorization of the individual, unless otherwise required by law.
    3. Department environmental health and safety coordinators are entitled to know whether employees and students meet the standards for fitness of duty in relation to the unit's work or educational activities but are not entitled to diagnostic results or findings for specific individuals.

  4. Employee or Student Health Status

    1. Employees or students may have underlying health conditions (e.g., pregnancy, organ transplantation, cancer, diabetes, asthma, allergies, or HIV infection) for which certain hazards and risks in their jobs or educational activities could adversely affect their health. Where possible, UW-Madison will make reasonable accommodations.
      1. Employees who experience changes in health status or who have underlying health conditions that may affect their ability to safely perform tasks related to their job must contact their Divisional Disability Representative (DDR) to determine whether accommodations are available to minimize health risks.
      2. Students who need accommodations to safely participate in educational activities must contact the McBurney Disability Resource Center to explore available accommodations.
    2. Employees and students are encouraged to discuss occupational health related concerns with the EOH occupational medicine physician, an occupational health officer, or their person physician.
Related UW-Madison Policies:
Related UW–Madison Documents, Web Pages, or Other Resources:
External References:

Policy Administration

Approval Authority:
Associate Vice Chancellor Facilities Planning & Management
Policy Manager:
Director of Environmental and Occupational Health
Contact:
Director of Environmental and Occupational Health -- Joel Malak, JOEL.MALAK@WISC.EDU, (608) 438-5851
Effective Date:
07-10-2015
Revised Dates:

06-05-2018, 07-07-2025

Retrieved:
07-17-2025 21:49:24