Position Statements

Position Statements - Statements from 1994-2018:

2018 - NHCA Position Statement Prevention of Music-Induced Hearing Disorders (Click here)

2017 - NHCA Position Statement Recreational Firearms (Click here)

Guidelines for Audiometric Baseline Revision, Approved 2/20/2013 (Click here)

2011 NHCA Guidelines for Recording Hearing Loss on the OSHA 300 Log (Click here)

NHCA - Petitions OSHA to Lower Permissable Exposure Limits for Noise (Click here to see information presented by Rick Neitzel, 2009)

NHCA comments to the Environmental Protection Agency (EPA) regarding EPA's proposed changes to the hearing protector labeling regulation (Click here)

NHCA - OSHA - NIOSH Alliance releases Best Practices Bulletin on Individual Fit Testing for Hearing Protectors (Click here)

Comments and Recommendations to OSHA with ASHA 1994 (Click here)

HIPAA Privacy and Disclosure Statement:

Can I disclose the findings of employee fitness-for-duty exams, and the like, to the employer? Does the HIPAA Privacy Rule's public health provision permit covered health care providers to disclose protected health information concerning the findings of pre-employment physicals, drug tests, or fitness-for-duty examinations to an individuals employer? The public health provision permits covered health care providers to disclose an individual's protected health information to the individual's employer without authorization in very limited circumstances. First, the covered health care provider must provide the health care service to the individual at the request of the individual's employer or as a member of the employer's workforce. Second, the health care service provided must relate to the medical surveillance of the workplace or an evaluation to determine whether the individual has a work-related illness or injury. Third, the employer must have a duty under the Occupational Safety and Health Administration (OSHA), the Mine Safety and Health Administration (MSHA), or the requirements of a similar State law, to keep records on or act on such information. For example, OSHA requires employers to monitor employees' exposures to certain substances and to take specific actions when an employee's exposure level exceeds a specified limit. A covered entity which tests an individual for such an exposure level at the request of the individual's employer may disclose that test result to the employer without authorization. Generally, pre-placement physicals, drug tests, and fitness-for-duty examinations are not performed for such purposes. However, to the extent such an examination is conducted at the request of the employer for the purpose of such workplace medical surveillance or work-related illness or injury, and the employer needs the information to comply with the requirements of OSHA, MSHA, or similar State law, the protected health information the employer needs to meet such legal obligation may be discussed to the employer without authorization. Covered health care providers who make such disclosures must provide the individual with written notice that the information is to be disclosed to his or her employer (or by posting the notice at the worksite if the service is provided there). When a health care service does not meet the above requirements, covered entities may not disclose an individual's protected health information to the individual's employer without an authorization by other provisions of the Rule. However, nothing in the Rule prohibits an employer from conditioning employment on an individual providing an authorization for the disclosure of such information.

RE: www.hhs.gov

Features: Privacy of Health Information/HIPPA / FAQs / Question #32