Regulatory Agencies and Occupational Health in Physical Therapy

Rationale for Regulatory Agencies

  • Purpose: The primary reason for the existence of regulatory agencies is to protect the safety of populations.

International Regulatory Level

  • World Health Organization (WHO):
    • Sub-division of the United Nations.
    • Administers the International Health Regulations (IHR).
    • These regulations are legally binding on 196 countries, including the 194 WHO Member States.
    • Establishes rights and obligations for countries regarding public health events.
    • Requires countries to maintain core capacities for surveillance and response to public health risks.
    • The WHO must be notified of all significant public health risks.
    • Handles health documentation for international travelers.

National Regulatory Agencies: Occupational Health

  • Occupational Safety and Health Administration (OSHA):
    • Administers the Occupational Safety and Health Act.
    • Serves as the regulatory body for most private industries.
    • Administers the Whistleblower Protection program to protect employees who report hazardous conditions.
    • Functions include bloodborne pathogen training, Material Safety Data Sheets (MSDS) management, and infectious disease prevention (e.g., COVID-19).
    • Key focus areas: ergonomics, safe patient handling/movement, and specific safety protocols (e.g., forklift operation, trench safety).
  • National Institute for Occupational Safety and Health (NIOSH):
    • A research agency within the Centers for Disease Control and Prevention (CDC).
    • Primarily focused on the study of worker safety and health through research.
  • NIOSH Hierarchy of Controls:
    • Elimination (Most Effective): Physically remove the hazard.
    • Substitution: Replace the hazard with something less dangerous.
    • Engineering Controls: Isolate people from the hazard.
    • Administrative Controls: Change the way people work (e.g., procedural changes).
    • Personal Protective Equipment (PPE) (Least Effective): Protect the worker with equipment such as masks or gloves.

National Regulatory Agencies: Food and Medication

  • Food and Drug Administration (FDA):
    • Regulates packaged food, rugs, medical devices, vaccines, blood, biologics, veterinary cosmetics, and tobacco products.
  • U.S. Department of Agriculture (USDA):
    • Oversees food safety and recalls.
    • Manages Supplemental Nutrition Assistance Programs (SNAP).
    • Responsible for livestock inspection and regulation (e.g., historical and re-emerging management of pests like the flesh-eating screwworm).

State Regulatory Agencies

  • State Licensure Boards:
    • Manage licensure for Physical Therapists and other medical professionals.
    • Maintain the State Practice Act, which defines the scope of practice.
    • Adjudicate disciplinary issues for licensees.
  • Federation of State Boards of Physical Therapy (FSBPT):
    • Administers the National Physical Therapy Exam (NPTE).
    • Provides a central database of state-level requirements.
    • Provides score reports and verification to state licensure boards.
  • New York State Education Department (NYSED) Office of the Professions:
    • The specific body managing licensure in New York.
  • State Departments of Health:
    • Individual states hold primary public health authority.
    • Organizational Structure: In 55%55\% of states, the health department is an independent agency; in 45%45\% of states, the department is part of a larger umbrella agency.
    • Common Duties: Disease surveillance and prevention services (Tobacco, HIV/AIDS, STD counseling, nutrition, and physical activity).
    • Immunization: Greater than 90%90\% of vaccine management and inventory for childhood immunizations is handled by state health departments.

Professional Accreditation Agencies

  • Commission on Accreditation in Physical Therapy Education (CAPTE):
    • Ensures minimum academic quality of Doctor of Physical Therapy (DPT) programs.
    • Protects three groups: 1. Patients, 2. Students, 3. Faculty.
    • Voluntary, non-governmental, and nationally recognized by the US Department of Education.
  • Hospital and Facility Accreditors:
    • The Joint Commission (formerly JCAHO):
      • Independent, not-for-profit organization.
      • Sets strict performance and safety standards.
      • Approval is required to receive Medicare and Medicaid funding.
      • Surveys occur every 3 years and are unannounced.
    • Det Norske Veritas (DNV): An alternative to the Joint Commission whose approval is also accepted by Medicare.
    • Commission on Accreditation of Rehabilitation Facilities (CARF):
      • International non-profit.
      • Regulates institutional services including aging, behavioral health, addiction, child services, rehabilitation, and prosthetics/orthotics.
      • Medical Rehabilitation Standards include specialty areas: Pediatric, Amputation, Brain Injury, Cancer Rehab, Spinal Cord, Stroke, and Disorders of Consciousness.

Joint Commission Regulations in Physical Therapy

  • Pain must be assigned a numerical value (0−100-10) at every visit.
  • Two-patient identifiers (Name and Date of Birth) must be used at every visit.
  • Strict evaluation of infection control and standard precautions.
  • Equipment must be regularly inspected, maintained, and calibrated.
  • Exits and walkways must remain unblocked by therapy equipment.

Occupational Health and Vocational Wellness

  • Definition of Occupational Health PT: Addressing work-related musculoskeletal (MSK) issues that lead to high costs for employers, including absenteeism, lost productivity, healthcare costs, disability, and Workers' Compensation (WC).
  • OSHA Act of 1970: Law requiring employers to provide a work environment "free from recognized hazards that are causing or are likely to cause death or serious physical harm."
  • Occupational Health Special Interest Group (OHSIG):
    • Part of the Orthopedic Section of the APTA.
    • 2020 Vision: To "lead the world in optimizing movement, musculoskeletal health, and work participation from hire to retire."
    • Developed Work Rehab Clinical Practice Guidelines (CPG) in 2021.
  • Role of the PT in Occupational Health:
    • Requires continuing education and specialized competencies in prevention, evaluation, and management of work-related injuries.
    • Patient populations include musculoskeletal/ortho, post-cancer, cardiopulmonary, neurologic, and developmental conditions.

Areas of Practice within Occupational Health

  • Workforce Health Promotion: Employer-based programs and wellness initiatives.
  • Injury Prevention: Developing ergonomic solutions and work accommodations.
  • Chronic Disease Management: Handling long-term conditions in the work setting.
  • Workplace Ergonomic Program Consultation: Identifying risk factors and ensuring compliance with guidelines (e.g., CDC COVID-19 guidelines).
  • Functional Job Analysis (FJA): Assessing job activity demands and designing/administering functional employment examinations.
  • Functional Capacity Evaluation (FCE):
    • A comprehensive performance-based medical assessment of a person's ability to participate in work/lifestyle.
    • Can be job-specific or exploratory for suitable occupations.
  • Rehab Programs for Complex Health Behaviors: Addressing the biopsychosocial nature of illness and comorbidities that impact work performance. Includes preparing students with disabilities for employment.

Ergonomic Principles and Recommendations

  • Definition: A "prevention-through-design" approach aimed at fitting the work task or environment to the capacities of the worker.
  • Injury Risk Factors:
    • Injury-prone posture.
    • Forceful exertions.
    • Repetitive motions.
    • Contact stresses.
    • Vibration.
  • Computer Workstation Guidelines:
    • Monitor: Top 1/31/3 of the screen at eye level. Distance should be 18/24 in18/24 \text{ in} (45−70 cm45-70 \text{ cm}). Slightly tilted.
    • Dual Monitors: No more than 1010 degrees of cervical rotation in either direction.
    • Hands/Wrists: Hands at or below elbow height with wrists straight (minimal bend).
    • Posture: Relaxed shoulders, forearms parallel to the floor.
    • Chair: Must have backrest and armrests; height should be adjustable.
    • Legs/Feet: Thighs parallel to the ground (90−120∘90-120^\circ angle at hip/knee). Feet supported by floor or footrest.
    • Telephone: Use hands-free headsets/microphones.
    • Elbow Angle: Correct sitting position involves an elbow angle of approximately 90−120∘90-120^\circ.