Policy on Job-Related Health Requirements

I. PURPOSE

To establish standards of health requirements for prospective and current employees of New York Medical College (NYMC) in specific, enumerated roles, and for non-NYMC employees who work in an NYMC laboratory or in the NYMC Department of Comparative Medicine.

Standards in this policy are in accordance with Occupational Safety and Health Administration (OSHA) Title 29 of Code of Federal Regulations 29 CFR 1910.1030, in accordance with the Centers for Disease Control and Prevention guidance for Tier 1 Biological Select Agents and Toxins (42 CFR Part 73, 7 CFR Part 331, and 9 CFR Part 121), and in accordance with the Association for Assessment and Accreditation of Laboratory Animal Care (Guide for the Care and Use of Laboratory Animals" 8th Ed., National Research Council, The National Academies Press, Washington DC, 2011).

II. POLICY

It is the policy of NYMC to perform a job-related Pre-Employment Health Clearance through Health Services for job applicants for specific, enumerated roles prior to their employment at NYMC, and for non-NYMC employees prior to their access to a laboratory or to the Department of Comparative Medicine at NYMC. These requirements also pertain to current employees who transfer to such specific enumerated roles. Failure to comply with any of the Health Service requirements of this policy may result in the withdrawal of an offer of employment or immediate termination.

III. SCOPE

This policy applies to each of the following:

1. All NYMC employees on the NYMC
2. Non-NYMC employees (including visiting students, visiting scientists, contract space licensees and volunteers) who work in a NYMC laboratory or in the NYMC Department of Comparative Medicine.
3. This policy does not address the Health Service requirements of students (matriculated and non-matriculated) in studies at NYMC School of Medicine, School of Health Science and Practice, Graduate School of Biomedical Sciences and the Touro College of Dental Medicine and does not address the health requirements of employees of the Touro College of Dental Medicine.

IV. DEFINITIONS

1. BSL: Biosafety Level
2. OSHA Exposure Questionnaire: In accordance with the OSHA Blood Borne Pathogen Standard (OSHA Title 29 of Code of Federal Regulations 29 CFR 1030), persons with potential exposure to blood borne pathogens review the potential for exposure and are offered Hepatitis B vaccination if the person does not have immunity to Hepatitis B virus.
3. EEHS: The Department of Energy, Environmental Health and
4. COVID-19 Vaccination Requirements – Refer to Policy on Mandatory Campus COVID-19 vaccination.

IV. NEW EMPLOYEES:

1. All persons require compliance with the Policy on Mandatory Campus COVID-19 vaccination.
2. List of Covered Roles and the specific health requirements apart from COVID-19 vaccination:
   1. A list of job titles at NYMC that are within the scope of this policy can be found in Exhibit
   2. Human Resources, in consultation with EEHS and Health Services, will review and update the list of covered roles annually, each July, or when a new role requiring clearance is created.
   3. General roles that currently require a health clearance include:
      1. Any position requiring access to the Department of Comparative Medicine. This includes all Public Safety and Facilities staff that have regular access to the Department of Comparative Medicine. This does not include administrative positions that do not have any access to or exposure to animals, laboratories, substances, or materials used in the Department of Comparative Medicine.
      2. Any position involving husbandry.
      3. Any position working in a Biosafety Level (BSL) 3 laboratory and select positions involving working in a BSL 2 laboratory.
      4. Any position in which a determination of potential exposure to blood or body fluids is a Category 1 or Category 2 as defined by OSHA.
      5. Any position involving direct patient care as part of the NYMC employment.
      6. Other positions not covered by the above, where there are practical considerations based on the job duties or proximity to animals, laboratories, substances, or materials that would justify screening and/or vaccinations, as reasonably determined by EEHS, Health Services, and Human Resources and approved by the Chief Human Resources Officer.
   4. Procedures for NYMC Employees:
      1. Human Resources informs Health Services of the status of new employees using the Human Resources Employee Data Form which identifies the employee’s role.
      2. For Employees requiring a health clearance in addition to proof of COVID-19 vaccination: Prior to the start date of employment, or the date of transfer to a new position, Human Resources will provide the employee with the Health Services requirements as specified below in Table 1- NYMC Health Services Requirements for All Persons Except Students. For those positions requiring completion of the Health Services packet, Human Resources will send the packet with the Human Resources Employee Data Form to the prospective employee and schedule an appointment with Health Services. The packet contains a Medical History Questionnaire and Physical Exam form, the OSHA Exposure Questionnaire, and a cover letter explaining the other vaccine requirements and screening for Tuberculosis infection.
      3. At the point of requesting a Health Services appointment, Human Resources will also inform EEHS that the incoming employee will also require additional lab clearance.
      4. The completed requirements are due before Safety Training can be scheduled for the employee. Health Services informs Human Resources of an employee’s clearance 1-3 days after the original appointment. Notification is sent electronically from the electronic health record of Health Services.
      5. All health records must be in English. Documents that have been translated into English must be signed by a licensed health care provider.
   5. Procedures for Non-NYMC Employees working In a Laboratory or In the Department of Comparative Medicine:
      1. The Department Administrator provides the prospective non-employee with the Health Services Requirements which are located under Touro One, and under the Campus Resources header: Health Services – New York Medical College. Item #1: Non-Employee Health Packet for NYMC & TCDM. This packet includes the Health Service Requirements (see Table 1) for access to a laboratory or to the Department of Comparative Medicine.
      2. Health Services informs the Department Administrator and EEHS of Non-Employee Health Clearance. The completed requirements are due before the Department Administrator can schedule Safety Training.
      3. All health records must be in English. Documents that have been translated into English must be signed by a licensed health care provider.
3. Enrollment in the Occupational Health Program and Annual Surveillance:
   
   1. in accordance with Centers for Disease Control and Prevention guidance for Tier 1 Biological Select Agents and Toxins (42 CFR Part 73, 7 CFR Part 331, and 9 CFR Part 121), and in accordance. With the Association for Assessment and Accreditation of Laboratory Animal Care. Select NYMC employees and non-NYMC employees subject to this policy are required to enroll in an Occupational Health Program. This is based upon the specific nature of their role or activities. 
   2. The job categories requiring Occupational Health Program enrollment are:
      1. Access to Comparative Medicine (includes certain Facilities and Security personnel}
      2. Husbandry staff in the Department of Comparative Medicine
      3. BSL 3 Laboratory staff.
   3. The requirements for the Occupational Health Program at initiation are detailed in Table 2. These requirements are completed at the initial health clearance appointment or at enrollment into the Occupational Health program. The annual requirements are detailed in Table 3.
   4. Notification for the requirements for initial enrollment into the Occupational Health Program and for annual surveillance is performed by the EEHS Department, as follows:
      1. A risk assessment for job duties is reviewed by the individual performing the duties, the Principal Investigator and EEHS at the initiation into the program.
      2. EEHS then determines the requirements for the position and informs Health Services of the requirements through the Risk Assessment.
      3. Annually the Risk Assessment is reviewed and an attestation to the current risks is completed, or a new risk assessment is completed. EEHS determines the requirements for the position and informs Health Services of those requirements through the Attestation that the risks are unchanged or by a new Risk Assessment.
      4. All Health questionnaires, and if applicable, laboratory tests or physical exams are reviewed/performed at Health Services and maintained in the NYMC Health Services medical record. Completed questionnaires are sent to Health Services directly from the individual to the electronic health record.
      5. Health Services informs EEHS of the initial or annual clearance electronically by a letter generated from the medical record. In the case of annual surveillance, EEHS may access the task list required for annual surveillance that is housed in the electronic health record and can see the completed and incomplete items. Only the task list is visible to EEHS staff.
4. If during any of the health assessments described above, a medical problem is evident that would prohibit the person from meeting job requirements, the employee and Human Resources will be notified by Health Services
   
   Charges:
   1. Vaccinations, tuberculin skin tests and urine toxicology tests required for the job description of an NYMC employee are provided at no charge if required for employment.
   2. Space licensees are charged a fee for medical record review.
5. Clinical Services Provided at Health Services: Health Services provides assessment and follow up of occupational injury and will provide first aid/ assessment to individuals in the event of any injury (occupational or non-occupational). Health Services does not provide routine medical care to employees or non-employees working at New York Medical College.

VI. EFFECTIVE DATE:

This policy is effective immediately.

VII. POLICY RESPONSIBILITIES

1. Human Resources: New or transferring employees in roles covered by this policy will be informed of the Health Services requirements by Human Resources in accordance with the procedures of this policy.
2. Department Administrator: Non-Employees (For example, volunteers, visiting scientists, contractors) in roles covered by this policy will be informed of the Health Services requirements by the Department Administrator in accordance with the procedures of this policy. 

VIII. POLICY MANAGEMENT

Responsible Executive: Director, Health Services
Responsible Officers: Director of Human Resources, Director of EEHS, Department Administrators
Responsible Offices: Health Services

EXHIBIT A

List of Covered Roles as of September 2022

List of Covered Positions Requiring Health Clearance Before Employment:

A. Any personnel working in laboratories, including Comparative Medicine or potentially requiring access, including interns, per diem employees, volunteers and contractors.

Research Faculty and Chair
Director (Faculty), Associate Director
Research Assistants, Associates, Fellows and Technicians Public Safety Director, Associate Director and Public Safety Officers
Manager
Animal Caretaker
Vet Tech A, Vet Tech B,
Staff, Administrative Coordinator
Facilities - excludes Grounds & Adm. & Coordinator
Employed Visiting Student, Staff, Researcher
Clinical Research Project Coordinator
*anyone with access to Comp Med including non-NYMC Contractors and/or Volunteers

B. Positions that require Health Services clearance due to possibility of exposure to lab, blood or body fluids, animal care or patients as determined by EEHS, Health Services and Human Resources.

Family Health Center staff
Speech Language Pathology (SHSP) clinic
Nurses/Nurse Practitioner/Medical Assistant and Licensed Practical Nurse Health Services Staff-including Secretary Ill, Administrator, Director Nurse Research Coordinator, Manager Director of Lab, Lab Manager, Director Biolnc
Administrator
*Including per diem staff

C. BSL 3 Lab

Research Faculty
Energy Environmental Health and Safety staff, excluding Administrator Research Associates/Research Technicians

D. Union positions may require health screening and/or vaccinations. Please refer to the applicable collective bargaining agreement.