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COHN: Management and Administration: Programs, Policy, and Regulatory Compliance

COHN · Work through your exam, one topic at a time.

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Management and Administration: Programs, Policy, and Regulatory Compliance

Program management

Sound occupational health programs follow a cycle: needs assessment, goal setting, planning, implementation, and evaluation. Objectives should be specific, measurable, and time-bound. Know the operational pieces - budget justification, staffing and coverage, written policies and procedures, standing orders or protocols consistent with the state nurse practice act, and quality improvement with benchmarking.

Regulatory framework

Understand the Occupational Safety and Health Act and the General Duty Clause; the recordkeeping rule (29 CFR 1904); substance-specific standards such as bloodborne pathogens and hazard communication; the access-to-exposure-and-medical-records rule; and the interaction of HIPAA, the ADA, and FMLA with workers' compensation. Each has a different trigger and a different audience.

Traps questions exploit

  • Recordability versus reportability. Recording goes on the OSHA 300 log when a case is work-related, is a new case, and meets a criterion (death, days away, restricted work or transfer, medical treatment beyond first aid, loss of consciousness, or significant diagnosis). Reporting to OSHA is separate, with tight timelines for fatalities and for in-patient hospitalization, amputation, or loss of an eye.
  • First aid versus medical treatment. Suture removal, wound closure, prescription drugs, and physical therapy generally count as medical treatment; tetanus shot, nonprescription drugs, and simple wound cleaning generally do not.
  • ADA. Requires individualized assessment; blanket exclusions based on a diagnosis are unlawful.

Rule of thumb

Record it if it is work-related, a new case, and crosses one of the recording criteria thresholds. Worked example: a nurse sustains a needlestick and receives post-exposure prophylaxis. It is recorded (medical treatment beyond first aid), and it is also a bloodborne pathogen exposure incident requiring source evaluation, follow-up, and a confidential sharps injury log entry.