Policy on Job-Related Health Requirements

I. PURPOSE

The purpose of this policy is 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 (“DCM”).

Standards in this policy are in accordance with the 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 (“CDC”) 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 (“AAALAC”) (Guide for the Care and Use of Laboratory Animals, 8th Edition, 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 (“Health Clearance”) through Health Services for job applicants for specific, enumerated positions prior to their employment at NYMC, and for non-NYMC employees (contractors, volunteers, visiting scientists, and visiting students) prior to their access to a laboratory or to DCM. These requirements also pertain to current employees who transfer to such specific enumerated roles. Failure to comply with any of the Health Services’ requirements of this policy may result in the withdrawal of an offer of employment, restricted access, or immediate termination.

III. SCOPE

This policy applies to each of the following:  (1) all NYMC employees; and (2) Non-NYMC Employees (visiting students, visiting scientists, contract space licensees and volunteers) who perform work in an NYMC laboratory or in the DCM). This policy does not address the Health Services’ requirements of NYMC or Touro College of Dental Medicine (TCDM) students.

IV. DEFINITIONS

BSL:  Biosafety Level

OSHA Exposure Questionnaire:  In accordance with the OSHA Blood Borne Pathogen Standard (OSHA Title 29 of Code of Federal Regulations 29 CFR 1910.1030), 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 the Hepatitis B virus.

EEHS:  The Department of Energy, Environmental Health and Safety

Non-NYMC employees: contractors (including individuals occupying space at NYMC pursuant to the Space License Agreement), volunteers, visiting scientists, and visiting students

V. NEW EMPLOYEES

A. All employees are required to comply with the health requirements for his/her position.

1. 1. 1. A list of job titles at NYMC that are within the scope of this policy can be found in Exhibit A attached hereto.
      2. Human Resources, in consultation with EEHS and Health Services, will review and update the list of job titles annually in July, or when a new position requiring Health Clearance is created.
      3. Positions that require initial Health Clearance include:

a. any position requiring access to DCM, including all Public Safety and Facilities staff that have regular access;

b. any position working in a BSL-3 laboratory and select positions involving working in a BSL-2 laboratory;

c. any position in which a determination of potential exposure to blood or bodily fluids is Category 1 or Category 2, as defined by OSHA; and

d. any position involving direct patient care.

B. Procedures for Requests for Health Services reviews for NYMC Employees:

1. 1. 1. Human Resources informs Health Services of new employees by submitting a completed Human Resources Employee Data Form. This form serves to provide demographic information and to identify the employee’s position.
      2. Prior to the start date of employment, or the date of transfer to a new position, Human Resources will provide the individual with the Health Services requirements, as specified in Table 1 below entitled “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 or transferring employee and schedule an appointment with Health Services. The packet contains a Medical History Questionnaire and Physical 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 or transferring employee will also require additional lab clearance.
      4. The completed requirements are due before EEHS-mandated safety training can be scheduled for the employee. Health Services will inform Human Resources of an employee’s clearance (or non-clearance) electronically from the electronic health record.
      5. All health records sent to Health Services must be in English. Documents translated into English must be signed by a licensed health care provider.

VI. PROCEDURES FOR NON-NYMC EMPLOYEES WORKING IN A LABORATORY OR IN THE DEPARTMENT OF COMPARATIVE MEDICINE

A. The department administrator shall provide the prospective non-employee with the Health Services requirements located in the Non-Employee Health Packet for NYMC and the Non-Employee Health Packet for TCDM. These packets include the Health Services requirements (see Table 1 below) for access to a laboratory or to DCM.

B. Health Services shall inform the department administrator and EEHS of the status of the Non-NYMC Employee’s Health Clearance.

C. All health records must be in English. Documents translated into English must be signed by a licensed health care provider.

VII. ENROLLMENT IN THE OCCUPATION HEALTH PROGRAM AND ANNUAL SURVEILLANCE

A. In accordance with the CDC 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 AAALAC, select NYMC employees and Non-NYMC Employees subject to this policy are required to enroll in an Occupational Health Program offered by NYMC. This is based upon the specific nature of their role or activities.

B. The job categories requiring Occupational Health Program enrollment are:

1. 1. 1. Those which require access to DCM, including Public Safety and Facilities; and
      2. BSL-3 laboratory staff

C. The requirements for the Occupational Health Program at initiation are detailed below 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 below in Table 3.

1. 1. 1. Notification for the requirements for initial enrollment into the Occupational Health Program and for annual surveillance is performed by EEHS, as follows:

a. 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.

b. EEHS then determines the requirements for the position and informs Health Services of the requirements through the risk assessment.

c. Annually, a risk assessment is submitted to Health Services to determine ongoing clearance (surveillance).

d. All health questionnaires, and, if applicable, laboratory tests or physical exams, are reviewed and/or performed at Health Services and maintained in the NYMC Health Services electronic medical records. Completed questionnaires are sent to Health Services directly from the individual to their health record to be reviewed by the Health Services clinical staff.

e. Health Services will inform EEHS of the initial or annual clearance electronically via a letter generated from the medical record.

f. 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.

VIII. CHARGES

A. Vaccinations, tuberculin skin tests, and urine toxicology required for the job description of an NYMC employee are provided at no cost to the employee, if required for employment.

B. Contractors enrolled in the Occupational Health Program will be charged a fee for risk assessment and health record review.

IX. CLINICAL SERVICES PROVIDED AT HEALTH SERVICES

Health Services provides assessments and follow-up of occupational injuries and will provide first aid/assessment to individuals in the event of any injury (occupational or non-occupational) to NYMC employees only. Health Services does not provide routine medical care to employees or Non-c Employees.

X. EFFECTIVE DATE

This policy is effective immediately.

XI. POLICY RESPONSIBILITIES

A. Human Resources – new or transferring employees in roles covered by this policy will be informed of the Health Services requirements, in accordance with the procedures of this policy.

B. Department Administrators – for non-employees (volunteers, visiting scientists, visiting students, or contract space licensees) 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.

XII. POLICY MANAGEMENT

Executive Stakeholder: Director of Health Services
Oversight Office:  Health Services

EXHIBIT A

List of Covered Roles as of September 2024

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 ResearchCoordinator, 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.