Who is covered: Employees exposed at/above the AL 30+ days/year; at/above the PEL/STEL 10+ days/year; prior exposure >10 ppm for 30+ days/year before December 10, 1989 (CA-specific historical cutoff date); tire-building machine operators using solvents with >0.1% benzene
Evaluation performed by: Licensed physician (hematologist or internist on referral for persistent CBC abnormality)
🩺 Baseline / Pre-Placement
Before initial assignment to benzene work (or within 12 months prior if the employee was recently examined to the equivalent requirements)
- Detailed occupational history
- Complete physical examination
- CBC: leukocyte count with differential, quantitative platelet (thrombocyte) count, hematocrit, hemoglobin, erythrocyte count, erythrocyte indices (MCV, MCH, MCHC)
- Pulmonary function test if a respirator is worn 30+ days/year
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: Annually following the previous examination.
- Updated occupational history
- Complete physical examination
- CBC: leukocyte count with differential, quantitative platelet (thrombocyte) count, hematocrit, hemoglobin, erythrocyte count, erythrocyte indices (MCV, MCH, MCHC)
- Pulmonary function test if a respirator is worn 30+ days/year
Abnormal results & exposure-event protocols
Abnormal Results & Exposure-Event Protocols
- Abnormal CBC: hemoglobin/hematocrit below the normal limit (outside the 95% C.I.) or a persistent downward trend from the individual's pre-exposure norm; platelet count >20% below the most recent value or outside normal limits; leukocytes <4,000/mm3 or an abnormal differential count 8 CCR 5218(i)(5)(A): Repeat the complete CBC within 2 weeks. Tests: Repeat CBC: leukocyte count with differential, quantitative platelet (thrombocyte) count, hematocrit, hemoglobin, erythrocyte count, erythrocyte indices (MCV, MCH, MCHC)
- CBC abnormality persists on the repeat test 8 CCR 5218(i)(5)(B): Examining physician refers the employee to a hematologist or internist for further evaluation, unless the physician has good reason to believe referral is unnecessary. Tests: Specialist (hematologist/internist) evaluation
- Emergency / acute exposure to benzene 8 CCR 5218(i)(4): Collect a urine sample at end of shift and perform a urinary phenol test within 72 hours. If urinary phenol is at or above 75 mg phenol/L (creatinine-corrected), provide a CBC at monthly intervals for 3 months following the emergency exposure; below 75 mg/L, no further testing required. Tests: End-of-shift urine collection, Urinary phenol test within 72 hours, Monthly CBC for 3 months if urinary phenol >=75 mg/L
- Referral to hematologist/internist following persistent CBC abnormality (medical removal) 8 CCR 5218(i)(8)-(9): Employee removed from areas where benzene exposure may exceed the action level and transferred to a comparable job with exposure at or below the AL, maintaining wage rate, seniority, and benefits. Within 6 months of removal the physician determines return to the former job or permanent removal. Employee receives up to 6 months of medical removal protection (MRP) benefits per removal. Tests: Periodic CBC during removal to determine return eligibility
Reporting Requirements
| Who performs the evaluation | Licensed physician (examining physician; hematologist or internist on referral for persistent CBC abnormality) |
|---|---|
| Reported to employer | Written opinion limited to: occupationally pertinent exam/test results; whether the employee has a greater-than-normal risk of material impairment from benzene; recommended exposure/PPE limitations; and a statement that the employee was informed of the results. Must NOT reveal specific records, findings, or diagnoses with no bearing on ability to work in a benzene-exposed workplace. |
| Reported to / for the employee | Employee informed of exam results and any medical condition requiring further evaluation; furnished a copy of the written opinion. |
| Time limits | Written opinion furnished within 15 days of the examination. |
| Second-opinion / multi-physician review | No multiple-physician-review scheme; on referral the examining physician and the hematologist/internist consult and communicate removal/return decisions in writing (1910.1028(i)(8)). |
| Recordkeeping | Medical records retained for the duration of employment plus 30 years (8 CCR 3204). |
Medical Removal Protection
On referral to a hematologist/internist for a persistent CBC abnormality, the employee is removed from areas where exposure may exceed the AL and transferred to a comparable job at/below the AL with wage, seniority, and benefits maintained; up to 6 months of MRP benefits per removal (strongest MRP of the five aromatic carcinogens).