The Disease
Hepatitis B is a viral infection caused by the Hepatitis B virus (HBV) which causes death in 1-2% of those infected. Most people with HBV recover completely, but approximately 5-10% become chronic carriers of the virus. Most of these people have no symptoms, but can continue to transmit the disease to others. Some may develop chronic active hepatitis and cirrhosis. HBV may be a causative factor in the development of liver cancer. Immunization against HBV can prevent acute hepatitis and its complications.

The Vaccine
The HBV vaccine is produced from yeast cells. It has been extensively tested for safety and effectiveness in large scale clinical trials.

Approximately 90 percent of healthy people who receive two doses of the vaccine and a third dose as a booster achieve high levels of surface antibody (anti-HBs) and protection against the virus. The HBV vaccine is recommended for workers with potential for contact with blood or body fluids. Full immunization requires three doses of the vaccine over a six-month period, although some persons may not develop immunity even after three doses.

There is no evidence that the vaccine has ever caused Hepatitis B. However, persons who have been infected with HBV prior to receiving the vaccine may go on to develop clinical hepatitis in spite of immunization.
Dosage and Administration

The vaccine is given in three intramuscular doses in the deltoid muscle. Two initial doses are given one month apart and the third dose is given six months after the first.

Possible Vaccine Side Effects
The incidence of side effects is very low. No serious side effects have been reported with the vaccine. Ten to 20 percent of persons experience tenderness and redness at the site of injection and low grade fever. Rash, nausea, joint pain, and mild fatigue have also been reported. The possibility exists that other side effects may be identified with more extensive use.

 

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CONSENT OF HEPATITIS B VACCINATION

I have knowledge of Hepatitis B and the Hepatitis B vaccination. I have had an opportunity to ask questions of a qualified nurse or physician and understand the benefits and risks of Hepatitis B vaccination. I understand that I must have three doses of the vaccine to obtain immunity. However, as with all medical treatment, there is no guarantee that I will become immune or that I will not experience side effects from the vaccine. I give my consent to be vaccinated for Hepatitis B.

______________________________________________
Signature of Employee (consent for Hepatitis B vaccination)

_________________
Date

______________________________________________
Signature of Witness

_________________
Date

 

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REFUSAL OF HEPATITIS B VACCINATION

I understand that due to my occupational exposure to blood or other potentially infectious materials I may be at risk of acquiring the Hepatitis B virus infection. I have been given the opportunity to be vaccinated with Hepatitis B vaccine at no charge to myself. However, I decline the Hepatitis B vaccination at this time. I understand that by declining this vaccine, I continue to be at risk of acquiring Hepatitis B, a serious disease. If in the future I continue to have occupational exposure to blood or other potentially infectious materials and I want to be vaccinated with the Hepatitis B vaccine, I can receive the vaccination series at no charge to me.

______________________________________________
Signature of Employee (refusal for Hepatitis B vaccination)

________________
Date

 

_____________________________________________
Signature of Witness

________________
Date

    

I refuse because I believe I have (check one)

_____ started the series _____ completed the series

 

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RELEASE FOR HEPATITIS B MEDICAL INFORMATION

 

I hereby authorize _____________________ (individual or organization holding Hepatitis B records and address) to release to the _____________________ Community School District, my Hepatitis B vaccination records for required employee records.

I hereby authorize release of my Hepatitis B status to a health care provider, in the event of an exposure incident.

 

_____________________________________________
Signature of Employee

_________________
Date

 

_____________________________________________
Signature of Witness

_________________
Date

 

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CONFIDENTIAL RECORD

                                                                                                                                                                                                       
_____________________________________________
Employee Name (last, first, middle)                                                              

 

_____________________________________________
Social Security No.

 

_____________________________________________
Job Title:                                                                                                        

 

 

Additional Hepatitis B status information:

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

 

Post-exposure incident: (Date, time, circumstances, route under which exposure occurred)

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

 

Identification and documentation of source individual:

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

Source blood testing consent:

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

Description of employee's duties as related to the exposure incident:

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

Copy of information provided to health care professional evaluating an employee after an exposure incident:

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

Attach a copy of all results of examinations, medical testing, follow-up procedures, and health care professional's written opinion.
Training Record: (date, time, instructor, location of training summary)

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

____________________________________________________________________

 

 

  Approved: 03/15/2021                        Reviewed: 02/15/2021                       Revised: 02/15/2021

 

Universal precautions (UP) are intended to prevent transmission of infection, as well as decrease the risk of exposure for employees and students. It is not currently possible to identify all infected individuals, thus precautions must be used with every individual. UP pertain to blood and other potentially infectious materials (OPIM) containing blood. These precautions do not apply to other body fluids and wastes (OBFW) such as saliva, sputum, feces, tears, nasal secretions, vomitus and urine unless blood is visible in the material. However, these OBFW can be sources of other infections and should be handled as if they are infectious. The single most important step in preventing exposure to and transmission of any infection is anticipating potential contact with infectious materials in routine as well as emergency situations. Based on the type of possible contact, employees and students should be prepared to use the appropriate precautions prior to the contact. Diligent and proper hand washing, the use of barriers, appropriate disposal of waste products and needles, and proper decontamination of spills are essential techniques of infection control. All individuals should respond to situations practicing UP followed by the activation of the school response team plan. Using common sense in the application of these measures will enhance protection of employees and students.

Hand Washing
Proper hand washing is crucial to preventing the spread of infection. Textured jewelry on the hands or wrists should be removed prior to washing and kept off until completion of the procedure and the hands are rewashed. Use of running water, lathering with soap and using friction to clean all hand surfaces is key. Rinse well with running water and dry hands with paper towels.

•  Hands should be washed before physical contact with individuals and after contact is completed.
•  Hands should be washed after contact with any used equipment.
•  If hands (or other skin) come into contact with blood or body fluids, hands should be washed immediately before touching anything else.
• Hands should be washed whether gloves are worn or not and, if gloves are worn, after the gloves are removed.

Barriers
Barriers anticipated to be used at school include disposable gloves, absorbent materials and resuscitation devices. Their use is intended to reduce the risk of contact with blood and body fluids as well as to control the spread of infectious agents from individual to individual. Gloves should be worn when in contact with blood, OPIM or OBFW. Gloves should be removed without touching the outside and disposed of after each use.

Disposal of Waste
Blood, OPIM, OBFW, used gloves, barriers and absorbent materials should be placed in a plastic bag and disposed of in the usual procedure. When the blood or OPIM is liquid, semi-liquid or caked with dried blood, it is not absorbed in materials, and is capable of releasing the substance if compressed, special disposal as regulated waste is required. A band-aid, towel, sanitary napkin or other absorbed waste that does not have the potential of releasing the waste if compressed would not be considered regulated waste. It is anticipated schools would only have regulated waste in the case of a severe incident. Needles, syringes and other sharp disposable objects should be placed in special puncture-proof containers and disposed of as regulated waste. Bodily wastes such as urine, vomitus or feces should be disposed of in the sanitary sewer system.

Clean up
Spills of blood and OPIM should be cleaned up immediately. The employee should:

• Wear gloves.
• Clean up the spill with paper towels or other absorbent material.
• Use a solution of one part household bleach to one hundred parts of water (1:100) or other EPA-approved disinfectant and use it to wash the area well.
• Dispose of gloves, soiled towels and other waste in a plastic bag.
• Clean and disinfect reusable supplies and equipment.

Laundry
Laundry with blood or OPIM should be handled as little as possible with a minimum of agitation. It should be bagged at the location. If it has the potential of releasing the substance when compacted, regulated waste guidelines should be followed. Employees who have contact with this laundry should wear protective barriers.

Exposure
An exposure to blood or OPIM through contact with broken skin, mucous membrane or by needle or sharp stick requires immediate washing, reporting and follow-up.

• Always wash the exposed area immediately with soap and water.
• If a mucous membrane splash (eye or mouth) or exposure of broken skin occurs, irrigate or wash the area thoroughly.
• If a cut or needle stick injury occurs, wash the area thoroughly with soap and water.

The exposure should be reported immediately, the parent or guardian is notified, and the person exposed contacts a physician for further health care.
 
 

Approved: 03/15/2021                        Reviewed: 02/15/2021                       Revised: 02/15/2021

 

EMPLOYEES ARE HEREBY NOTIFIED it is a violation of the Substance-Free Workplace policy for an employee to unlawfully manufacture, distribute, dispense, possess, use, or be under the influence of in the workplace any narcotic drug, hallucinogenic drug, amphetamine, barbiturate, marijuana or any other controlled substance or alcohol, as defined in Schedules I through V of section 202 of the Controlled Substances Act (21 U.S.C. 812) and as further defined by regulation at 21 C.F.R. 1300.11 through 1300.15 and Iowa Code Chapter 124.

"Workplace" is defined as the site for the performance of work done in the capacity as an employee.  This includes school district facilities, other school premises or school district vehicles.  Workplace also includes non-school property if the employee is at any school-sponsored, school-approved or school-related activity, event or function, such as field trips or athletic events where students are under the control of the school district or where the employee is engaged in school business.

Employees who violate the terms of the Substance-Free Workplace policy may be required to successfully participate in a substance abuse treatment program approved by the board at the employee’s expense. The superintendent retains the discretion to discipline an employee for violation of the Substance-Free Workplace policy.  If the employee fails to successfully participate in such a program the employee is subject to discipline up to and including termination.

EMPLOYEES ARE FURTHER NOTIFIED it is a condition of their continued employment that they comply with the above policy of the school district and will notify their supervisor of their conviction of any criminal drug statute for a violation committed in the workplace, no later than five days after the conviction.

 

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SUBSTANCE-FREE WORKPLACE ACKNOWLEDGMENT FORM

I,___________________________, have read and understand the Substance-Free Workplace policy.  I understand that if I violate the Substance-Free Workplace policy, I may be subject to discipline up to and including termination or I may be required to participate in a substance abuse treatment program.  If I fail to successfully participate in a substance abuse treatment program, I understand I may be subject to discipline up to and including termination.  I understand that if I am required to participate in a substance abuse treatment program and I refuse to participate, I may be subject to discipline up to and including termination.  I also understand that if I am convicted of a criminal drug offense committed in the workplace, I must report that conviction to my supervisor within five days of the conviction.

____________________________________        ______________________________
(Signature of Employee)                    (Date)

 

 

Approved: 03/15/2021                        Reviewed: 02/15/2021                       Revised: 02/15/2021

 

A superintendent who suspects an employee has a substance abuse problem will follow these procedures:

1.    Identification - the superintendent will document the evidence the superintendent has which leads the superintendent to conclude the employee has violated the Substance-Free Workplace policy.  After the superintendent has determined there has been a violation of the Substance-Free Workplace policy, the superintendent will discuss the problem with the employee.

2.    Discipline - if, after the discussion with the employee, the superintendent determines there has been a violation of the Substance-Free Workplace policy, the superintendent may recommend discipline up to and including termination or may recommend the employee seek substance abuse treatment.  Participation in a substance abuse treatment program is voluntary.

3.    Failure to participate in referral – if the employee refuses to participate in a substance abuse treatment program or if the employee does not successfully complete a substance abuse treatment program, the employee may be subject to discipline up to and including termination.

4.    Conviction - if an employee is convicted of a criminal drug offense committed in the workplace, the employee must notify the employer of the conviction within five days of the conviction.

 

 

Approved: 03/15/2021                        Reviewed: 02/15/2021                       Revised: 02/15/2021

 

EMPLOYEES GOVERNED BY THE DRUG AND ALCOHOL TESTING POLICY ARE HEREBY NOTIFIED they are subject to the school district’s drug and alcohol testing program for pre-employment drug testing and random, reasonable suspicion, post-accident, return-to-duty, and follow-up drug and alcohol testing as outlined in the Drug and Alcohol Testing Program policy, its supporting documents and the law.

Employees who operate school vehicles are subject to drug and alcohol testing if a commercial driver’s license is required to operate the school vehicle and the school vehicle transports sixteen or more persons including the driver or the school vehicle weighs twenty-six thousand, one pounds or more.  For purposes of the drug and alcohol-testing program, “employees” also includes applicants who have been offered a position to operate a school vehicle.  The employees operating a school vehicle are subject to the drug and alcohol-testing program beginning the first day they operate or are offered a position to operate a school vehicle and continue to be subject to the drug and alcohol-testing program.

It is the responsibility of the superintendent to inform employees of the drug and alcohol testing program requirements.  Employees with questions regarding the drug and alcohol testing requirements will contact the school district contact person.

EMPLOYEES GOVERNED BY THE DRUG AND ALCOHOL TESTING POLICE ARE FURTHER NOTIFIED that employees violating this policy, its supporting documents or the law may be subject to discipline up to and including termination.  

EMPLOYEES GOVERNED BY THE DRUG AND ALCOHOL TESTING POLICY ARE FURTHER NOTIFIED  it is a condition of their continued employment to comply with the Drug and Alcohol Testing Program policy, its supporting documents and the law.  It is a condition of continued employment for employees operating a school vehicle to notify their supervisor of any prescription medication they are using.  Drug and alcohol testing records about a driver are confidential and are released in accordance with this policy, its supporting documents or the law.

EMPLOYEES GOVERNED BY THE DRUG AND ALCOHOL TESTING POLICY ARE HEREBY NOTIFIED they are subject to the school district’s drug and alcohol testing program for pre-employment drug testing and random, reasonable suspicion, post-accident, return to duty, and follow-up drug and alcohol testing as outlined in the Drug and Alcohol Testing Program policy, its supporting documents and the law.

EMPLOYEES GOVERNED BY THE DRUG AND ALCOHOL TESTING POLICY ARE FURTHER NOTIFIED  that employees violating this policy, its supporting documents or the law may be subject to discipline up to and including termination at the discretion of the school district.  As a condition of continued employment, employees violating this policy, its supporting documents or the law will be required to successfully participate in a substance abuse evaluation and a substance abuse treatment program recommended by a substance abuse professional.  Employees required to participate in and who fail to or refuse to successfully participate in a substance abuse evaluation or recommended substance abuse treatment program may be subject to discipline up to and including termination.

 

 Approved: 03/15/2021                        Reviewed: 02/15/2021                       Revised: 02/15/2021

 

 

COLO-NESC O COMMUNITY SCHOOL DISTRICT
DRUG AND ALCOHOL TESTING PROGRAM
ACKNOWLEDGEMENT FORM

I, ________________________________, have received a copy, read and understand the Drug and Alcohol Testing Program policy of the Colo-NESCO Community School District and its supporting documents.

I understand that if I violate the Drug and Alcohol Testing Program policy, its supporting documents or the law, I may be subject to discipline, up to and including termination or I may be required to successfully participate in a substance abuse evaluation and a substance abuse treatment program if recommended by the substance abuse professional.  If I am required to and fail to refuse to successfully participate in a substance abuse evaluation or recommended substance abuse treatment program, I understand I may be subject to discipline, up to and including termination.

I also understand that I must inform my supervisor of any prescription medication I use.

In addition, I have received a copy of the U.S. DOT publication, “What Employees Need to Know about DOT Drug & Alcohol Testing,” and have read and understand its contents.

Furthermore, I know and understand that I am required to submit to a controlled substance (drug) test, the results of which must be received by this employer before being employed by the school district and before being allowed to perform a safety-sensitive function.  I also understand that if the results of the pre-employment test are positive, that I will not be considered further for employment with the school district.

I further understand that drug and alcohol testing records about me are confidential and may be released in accordance with this policy, its supporting administration regulations or the law.

 

___________________________________       
Signature of Employee 

_________________________________
Printed Name of Employee

 

 Approved: 03/15/2021                        Reviewed: 02/15/2021                       Revised: 02/15/2021

 

I, ________________________________, understand that as part of my employment in a position that requires a commercial driver’s license in the COLO-NESCO District, I grant consent for the District to conduct queries of the Federal Motor Carrier Safety Administration (“FMCSA”) Commercial Driver’s License Drug and Alcohol Clearinghouse to determine whether drug or alcohol violation information about me exists in the Clearinghouse.  I further consent to the District sharing information related to my drug and alcohol testing results with prior, current and future employers, as well as the FMCSA Clearinghouse in accordance with state and federal laws.

I understand that the District will check and perform queries of my drug and alcohol testing results prior to my employment in any position which requires the use of a commercial driver’s license.  I further understand the District will check and perform queries of my testing results annually and is required to report any drug and alcohol violations of this policy to FMCSA Clearinghouse.

I understand that I am not required to consent to the query of the FMCSA Clearinghouse or the District sharing of drug and alcohol testing information with past, present or future employers or the FMCSA Clearinghouse; but that without my consent I understand I will be prohibited from performing safety sensitive functions, including driving a commercial motor vehicle, as required by FMCSA’s drug and alcohol program regulations.

I hereby give my consent to the District to perform queries of the FMCSA Clearinghouse and share my drug and alcohol testing results with past, present and future employers, as well as the FMCSA Clearinghouse.

 

___________________________________       
Signature of Employee 

_________________________________
Printed Name of Employee

 

 

Approved: 03/15/2021                        Reviewed: 02/15/2021                       Revised: 02/15/2021

 

 EMPLOYEE PERSONAL ATTESTATION OF VACCINATION STATUS

 

I, ____________________ as an employee of the District do personally attest to the following:

1.      My vaccination status for COVID-19 is ________________ [fully vaccinated or partially vaccinated].

2.      To the best of my recollection, I can provide the following information about my vaccination status:  ___________________________ [type of vaccine administered, date(s) of administration, name of health care providers and clinic site]

3.      I have lost proof of my vaccination status and am otherwise unable to provide proof of my vaccination status.

4.      I declare that this statement about my vaccination status is true and accurate.  I understand that knowingly providing false information regarding my vaccination status on this form may subject me to criminal penalties. 

 

 

 

___________________________________                           ________________________

Employee                                                                                Date

 

 

MEDICAL ACCOMMODATION REQUEST FORM

(1)     What is the basis for the medical accommodation that you are requesting?

(2)     What are you requesting an accommodation from?

 

 

___________________________________              ________________________________

Employee Signature                                                                Date

 

 

 

---

 Office Use

This request has been:

 ______________________________                        ________________________________

Approved                                                                                Denied

 

_________________________________                  ______________________________

Administrator                                                                          Date

 

RELIGIOUS ACCOMMODATION REQUEST FORM

 

(1)     Please identify the policy requirement or practice that conflicts with your sincerely held religious observance, practice or belief:

 

 

(2)     Please describe the nature of your sincerely held religious beliefs or religious practice or observance that conflict with the policy or practice you have identified above:

 

 

(3)     What are you requesting an accommodation from?

 

  

___________________________________              ________________________________

Employee Signature                                                                Date

 

 

---

Office Use

 

This request has been: 

______________________________                        ________________________________

Approved                                                                                Denied

 

__________________________________                ______________________________

Administrator                                                                          Date

 

Acceptable Proof of Vaccination Status
To satisfy the vaccination requirement within this policy, employees must submit to the Superintendent or Superintendent’s designee acceptable proof of vaccination status no later than December 6, 2021.  Acceptable proof of vaccination status includes:

1. Immunization records from a healthcare provider or pharmacy;
2. A copy of a COVID-19 Vaccination Record Card;
3. A copy of medical records documenting immunization;
4. A copy of immunization records from a public health, state or tribal immunization information system;
5. Any other official documentation that contains the type of vaccine administered, dates of administration, and the name of the administering health provider or clinic;
6. If any other records are unavailable a signed and dated personal attestation statement.

Any employee who fails to provide acceptable proof of vaccination status may face disciplinary action up to and including termination.

Record Keeping
The district is required by law to keep a roster of the vaccination status of all employees. Any records showing proof of employee vaccination status the district maintained prior to November 5, 2021 will be considered sufficient proof of the employee’s vaccination status.

Any records related to an employee’s vaccination status, including the employee vaccination status roster, will be considered confidential employee medical records not subject to public disclosure and stored as employee medical records consistent with law.  These records will be maintained by the district for as long as 29 C.F.R. 1910.501 remains in effect.

Testing
Beginning January 4, 2022, employees who are not fully vaccinated must submit proof of negative COVID-19 test results every 7 days.  Documentation of negative test results must be provided to the district no later than every 7 days.  Employees who are not fully vaccinated and do not report to work for longer than 7 days (ex. an employee on vacation or on leave) must provide documentation of a negative test result upon their return to work.  If the employee fails to provide proof of a negative test result, the district must keep the employee removed from the workplace until the negative test result documentation is provided.

Employees who receive a positive COVID-19 test result or have been diagnosed with COVID-19 by a licensed healthcare provider; are not required to produce another test result for 90 days from the date of their positive result.  

Positive Test Results
Regardless of vaccination status, employees must report any positive COVID-19 test results or a diagnosis of COVID-19 by a licensed healthcare provider to the district.  Any employee so reporting will be immediately removed from the workplace and will stay removed from the workplace until any of the following occur:

• The employee receives a negative result on a COVID-19 nucleic acid amplification test (NAAT) following a positive result on a COVID-19 antigen test if the employees chooses to seek the confirmatory test
• The employee meets the return to work criteria in the CDC’s “Isolation Guidance” listed here: https://www.cdc.gov/coronavirus/2019-ncov/your-health/quarantine-isolation.html
• The employee receives a recommendation to return to work from a licensed healthcare provider.

New Employees
New employees will be subject to the provisions of this policy upon hire as soon as practicable.  Within 7 days of hire, new employees will provide proof of their vaccination status to the district in accordance with the requirements of this policy.  Unless fully vaccinated, new employees will abide by the testing and face-covering requirements of this policy within 7 days of hire.  

Leave
As required by 29 C.F.R. 1910.501, the district will provide up to 4 hours of paid leave to cover the time required to travel to and obtain each dose of the primary vaccination for COVID-19.  If additional time is required, the employee may use other accrued leave available.  The district will also provide reasonable paid sick leave to employees to recover from any effects of each primary dose of COVID-19 vaccine.  The district may require employees to use previously accrued paid sick leave first.

Employees Excluded
Employees who work fully remote from the job site; employees working from home; and employees who work exclusively outdoors are excluded from the vaccination, testing and face-covering requirements of this policy.  Employees fully remote from the job site does not include employees whose work requires them to work off-site from the district but in the presence of students or employees of the district.  Employees who work exclusively outdoors means those individuals who do not spend any part of their work time indoors.

Face Coverings
Beginning December 5, 2021, face coverings must be worn by all employees who have not provided proof of full vaccination status to the district.  Face coverings will be worn when employees are working indoors, in vehicles or other enclosed spaces.  Face coverings are not required to be worn when employees are: working alone in a room with floor to ceiling walls and a closed door; verifying identity for security purposes or eating/drinking; when an employee is wearing a respirator or facemask; or where the district can show that the use of a face covering is infeasible or creates a greater hazard.  The face-covering must fully cover the employee’s nose and mouth; and be replaced when wet, soiled or damaged.

Reporting Requirements of the District
The district will report to OSHA:

• Each work-related COVID-19 fatality within 8 hours of the employer learning about the fatality;
• Each work-related COVID-19 inpatient hospitalization within 24 hours of the employer learning about the inpatient hospitalization.

The district will report to individual employees or anyone having written authorized consent of the employee by the end of the next business day after the request is made:

• Documentation of any COVID-19 test results for that employee;
• The aggregate number of fully vaccinated employees at a workplace along with the total number of employees at that workplace.

The district will provide to the Assistant Secretary of Labor for Occupational Safety and Health, U.S. Department of Labor, or their designee:

• A copy of this policy, and the aggregate number of fully vaccinated employees at a workplace along with the total number of employees at that workplace, to be provided within 4 business hours of the request being made; and
• All other records and supporting documents related to this policy by the end of the next business day of the request being made.
   

For additional information on COVID-19 vaccine efficacy, safety, and the benefits of being vaccinated, please consult the following document “Key Things to Know About COVID-19 Vaccines” https://www.cdc.gov/coronavirus/2019-ncov/vaccines/keythingstoknow.html

 29 C.F.R. 1904.34(b)(1)(iv) prohibits the employer from discharging or in any manner discriminating against an employee for reporting a work-related injury or illness.

11(c) of the Occupational Safety and Health Act prohibits the employer from discriminating against an employee for exercising rights under, or as a result of actions that are required by, this policy.  11(c) also protects employees from retaliation by the employer for filing an occupational safety or health complaint, reporting a work-related injury or illness, or otherwise exercising any rights provided by the OSH Act. 

18 U.S.C. 1001 and section 17(g) of the OSH Act provide for criminal penalties associated with knowingly supplying false statements or documentation in accordance with this policy.