Date First Published on SafetySmart Compliance: February 21st, 2012
You must implement a medical surveillance program for certain types of employees (Sec. 1910.120(f)). Medical exams and procedures required under the standard must be performed by a licensed physician, preferably one who’s knowledgeable in occupational medicine, and be provided without cost or loss of pay to employees at “a reasonable time and place.
When Is a Medical Surveillance Program Required
You must implement a medical surveillance program if you have employees who:
- Are or may be exposed to hazardous substances or health hazards at or above PELs for the substance;
- Are or may be exposed to hazardous substances or health hazards at or above the published exposure levels for the substance, without regard to respirator use, for 30 days or more per year;
- Are or may be exposed to hazardous substances or health hazards at or above PELs for the substance, without regard to respirator use 30 days or more per year;
- Wear a respirator 30 days or more per year as required by the OSHA respiratory protection standard;
- Are injured, become ill or develop signs and symptoms from possible overexposure involving hazardous substances or health hazardsfrom an emergency response or hazardous waste operations; and/or
- Are members of HAZMAT teams.
How Often Medical Exams & Consultations Are Required
Medical exams and consultations must be made available to the above employees:
- Prior to assignment;
- At least once every 12 months unless the attending physician believes a longer interval is appropriate—up to once every 2 years;
- Upon termination of employment or reassignment to an area where the employee wouldn’t be covered if he hasn’t had an exam within the last 6 months;
- As soon as possible upon notification by the employee that he has developed signs or symptoms of possible overexposure to hazardous substances or health hazards;
- As soon as possible upon notification by the employee has been injured or exposed above the PEL or published exposure level of a hazardous substance or health hazard in an emergency situation;
- At more frequent intervals if the examining physician says it’s medically necessary; and
- As soon as possible upon notification by the employee that he has developed signs or symptoms of possible overexposure to hazardous substances or health hazards.
Medical exams and consultations must be made available for employees who are injured, become ill or develop signs and symptoms from possible overexposure involving hazardous substances or health hazardsfrom an emergency response or hazardous waste operations:
- As soon as possible after the emergency incident or development of signs or symptoms; and/or
- At additional times if the examining physician thinks that follow-up consultation or exam is medically necessary.
What Medical Exams and Consultations Must Include
Medical exams must include a medical and work history (or updated history if there’s one in the employee’s file with special emphasis on symptoms related to handling hazardous substances or health hazards, and fitness for duty including the ability to wear required PPE under expected work conditions.
The attending physician must determine the content of medical exams or consultation made available to the employee in accordance with the Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities, National Institute for Occupational Safety and Health (NIOSH), Occupational Safety and Health Administration (OSHA), U.S. Coast Guard (USCG), and Environmental Protection Agency (EPA); October 1985.
Information You Must Give to Physician
The employer must provide the attending physician a copy of the Hazwoper standard and the following information for each employee:
- A description of the employee’s duties involving exposure;
- Employee’s exposure or anticipated exposure levels;
- A description of PPE to be used;
- Information from previous medical exams that’s not readily available to the attending physician; and
- Information that the employer is required to provide to physicians under the OSHA Respiratory Protection Standard (29 CFR 1910.134) as part of respirator medical surveillance.
Physician’s Written Opinion
The employer must get and provide to the employee a copy of the written opinion from the examining physician containing the following:
- The physician’s opinion about whether employee has any medical conditions putting him at increased risk of “material impairment” to health from the work in hazardous waste operations or emergency response;
- The physician’s opinion about whether employee has any medical conditions putting him at increased risk of “material impairment” to health from respirator use;
- Recommended limitations on the assigned work;
- The results of exams and tests requested by the employee; and
- A statement that the physician has informed the employee of the results of any exams and medical conditions requiring further examination or treatment.
To protect the employee’s privacy, the written opinion obtained by the employer may not reveal specific findings or diagnoses unrelated to occupational exposure.
Medical Surveillance Recordkeeping
Employers must retain medical surveillance records listing:
- The employee’s name;
- The employee’s social security number;
- The physician’s written opinions, recommended limitations and results of tests and exams;
- Any employee medical complaints related to exposure to hazardous substances; and
- A copy of the information the employer provides the examining physician about the employee (listed above).
Records generated by medical surveillance are subject to the accessibility requirements of the Access to Employee Exposure and Medical Records standard (29 CFR 1910.1020).
Compliance Guidelines (Appendix C)
Hazardous Materials References (Appendix D)
Other OSHA Standards Incorporated by Reference
Respiratory Protection Standard (1910.134)
Access to Employee Exposure and Medical Records Standard (1910.1020)