Cal/OSHA · dir.ca.gov
Aromatic Carcinogens

Ethylene Oxide Medical Surveillance

Ethylene oxide (EtO) causes cancer plus reproductive, hematologic, and neurologic harm; affects workers in medical-device/sterilization, fumigation, and chemical manufacturing.

Action Level0.5 ppm (8-hr TWA)
PEL1 ppm (8-hr TWA); excursion limit (STEL) 5 ppm / 15 min
Who is covered: Employees exposed at/above the AL, without regard to respirator use, for at least 30 days/year; plus any employee exposed in an emergency

Evaluation performed by: Licensed physician

🩺 Baseline / Pre-Placement

Prior to assignment to an area where exposure may be at/above the AL for at least 30 days/year

  • Medical and work history with emphasis on symptoms related to the pulmonary, hematologic, neurologic, and reproductive systems and to the eyes and skin
  • Physical examination with emphasis on the pulmonary, hematologic, neurologic, and reproductive systems and to the eyes and skin
  • Complete blood count: at minimum a white-cell count (including differential), red-cell count, hematocrit, and hemoglobin
  • Any further laboratory or other test the examining physician deems necessary by sound medical practice
🕒 Periodic / Routine

Interval-based while covered — NOT result-triggered

Schedule: At least annually for employees exposed at/above the AL for at least 30 days in the past year.

  • Medical and work history with emphasis on symptoms related to the pulmonary, hematologic, neurologic, and reproductive systems and to the eyes and skin
  • Physical examination with emphasis on the pulmonary, hematologic, neurologic, and reproductive systems and to the eyes and skin
  • Complete blood count: at minimum a white-cell count (including differential), red-cell count, hematocrit, and hemoglobin
  • Any further laboratory or other test the examining physician deems necessary by sound medical practice
🚪 Exit / Termination

At termination of employment or reassignment to an area where EtO exposure is not at/above the AL for at least 30 days/year

  • Medical and work history with emphasis on symptoms related to the pulmonary, hematologic, neurologic, and reproductive systems and to the eyes and skin
  • Physical examination with emphasis on the pulmonary, hematologic, neurologic, and reproductive systems and to the eyes and skin
  • Complete blood count: at minimum a white-cell count (including differential), red-cell count, hematocrit, and hemoglobin
Abnormal results & exposure-event protocols

Abnormal Results & Exposure-Event Protocols

  • Emergency exposure to EtO 8 CCR 5220(i)(2)(i)(D): Provide medical examination and consultation as medically appropriate following the emergency exposure. Tests: Medical examination and consultation as medically appropriate
  • Employee reports signs or symptoms of possible overexposure to EtO 8 CCR 5220(i)(2)(i)(E): Provide a medical examination/consultation addressing the reported signs or symptoms. Tests: Medical and work history with emphasis on symptoms related to the pulmonary, hematologic, neurologic, and reproductive systems and to the eyes and skin, Physical examination with emphasis on the pulmonary, hematologic, neurologic, and reproductive systems and to the eyes and skin, Complete blood count: at minimum a white-cell count (including differential), red-cell count, hematocrit, and hemoglobin
  • Employee requests advice about reproductive effects, or the physician deems it medically appropriate 8 CCR 5220(i)(2)(ii)(B): Make available medical consultation regarding reproductive effects; the physician may include pregnancy testing or laboratory evaluation of fertility on request when medically appropriate. Tests: Reproductive-effects consultation, Pregnancy testing or laboratory evaluation of fertility (on request, when medically appropriate)

Reporting Requirements

Who performs the evaluationLicensed physician
Reported to employerWritten opinion limited to: whether the employee has any detected medical condition that would place health at increased risk from EtO exposure; recommended limitations on the employee or on PPE use; and a statement that the employee was informed of the results and of any condition requiring further treatment. Must NOT reveal specific findings or diagnoses unrelated to occupational EtO exposure.
Reported to / for the employeeEmployee informed of the results and of any condition requiring further treatment; furnished a copy of the written opinion.
Time limitsCopy of the written opinion provided to the employee within 15 days of the employer's receipt.
Second-opinion / multi-physician reviewNo multiple-physician-review scheme codified in the standard.
RecordkeepingMedical records retained for the duration of employment plus 30 years (8 CCR 3204).

Medical Removal Protection

No formal MRP scheme; the physician's written opinion may state limitations on the employee or on PPE use.

How this compares to Federal OSHA: Essentially aligned — California adopted the federal EtO standard with identical AL/PEL/STEL, CBC panel, exam-event structure (baseline, annual, explicit termination/reassignment exit exam), and the reproductive-effects consultation-on-request. No material numeric difference. California has no separate construction EtO section (construction governed federally by 1926.1147, incorporating 1910.1047 by reference).

Occu-Med handles Ethylene Oxide surveillance end-to-end

Scheduling, exams, lab panels, physician review, removal/return determinations, and audit-ready recordkeeping — fully compliant with Cal/OSHA requirements.