Cal/OSHA · dir.ca.gov
Heavy Metals

Hexavalent Chromium (Cr VI) Medical Surveillance

Cr VI causes lung cancer, nasal septum perforation/ulceration, dermatitis, and respiratory sensitization; affects workers in welding stainless steel, electroplating, chromate pigment/paint, and chrome-plating operations.

Action Level2.5 µg/m³ (8-hr TWA)
PEL5 µg/m³ (8-hr TWA)

General Industry

Who is covered: Employees exposed at/above the AL for 30+ days/year; signs/symptoms; emergency exposure. Exceptions: pesticide application regulated by CA DPR, portland cement exposures, and materials that cannot release Cr(VI) at ≥0.5 µg/m³

Evaluation performed by: PLHCP (physician or other licensed health care professional)

🩺 Baseline / Pre-Placement

Within 30 days after initial assignment, unless the employee received a qualifying exam meeting these requirements within the prior 12 months

  • Medical + work history covering past, present, and anticipated future exposure to Cr(VI); history of respiratory-system dysfunction; history of asthma, dermatitis, skin ulceration, or nasal septum perforation; and smoking status and history
  • Physical examination of the skin and respiratory tract
  • Any additional tests deemed appropriate by the examining PLHCP (no mandatory Cr biomarker)
🕒 Periodic / Routine

Interval-based while covered — NOT result-triggered

Schedule: At least annually.

  • Medical + work history covering past, present, and anticipated future exposure to Cr(VI); history of respiratory-system dysfunction; history of asthma, dermatitis, skin ulceration, or nasal septum perforation; and smoking status and history
  • Physical examination of the skin and respiratory tract
  • Any additional tests deemed appropriate by the examining PLHCP
🚪 Exit / Termination

At termination of employment

  • Termination medical examination — medical + work history covering past, present, and anticipated future exposure to Cr(VI); history of respiratory-system dysfunction; history of asthma, dermatitis, skin ulceration, or nasal septum perforation; and smoking status and history
  • Termination medical examination — physical examination of the skin and respiratory tract
  • Termination medical examination — any additional tests deemed appropriate by the examining PLHCP
  • Entire termination examination is required unless the last examination satisfying 8 CCR 5206(k) was less than six months prior to the date of termination
⚠ Emergency / Post-Exposure

Within 30 days after an emergency exposure (uncontrolled release); also whenever the employee shows signs or symptoms of adverse Cr(VI) health effects

  • Medical + work history covering past, present, and anticipated future exposure to Cr(VI); history of respiratory-system dysfunction; history of asthma, dermatitis, skin ulceration, or nasal septum perforation; and smoking status and history
  • Physical examination of the skin and respiratory tract
  • Any additional tests deemed appropriate by the examining PLHCP
Abnormal results & exposure-event protocols

Abnormal Results & Exposure-Event Protocols

  • Examining PLHCP recommends an additional medical examination Additional examination on PLHCP recommendation: Provide the recommended additional examination within 30 days of the written recommendation. Tests: Examination as specified by the PLHCP

Reporting Requirements

Who performs the evaluationPLHCP (physician or other licensed health care professional)
Reported to employerWritten opinion containing only: whether the employee has a detected medical condition that places the employee at increased risk from further Cr(VI) exposure; any recommended exposure limitations or PPE/respirator restrictions; and a statement that the PLHCP explained the results to the employee, including any condition requiring further evaluation. PLHCP must NOT reveal findings or diagnoses unrelated to occupational Cr(VI) exposure.
Reported to / for the employeeEmployer provides a copy of the written opinion to the employee within 2 weeks of receiving it; PLHCP explains results directly to the employee.
Time limitsEmployer obtains the written opinion within 30 days of each exam; furnishes a copy to the employee within 2 weeks of receipt.
Second-opinion / multi-physician reviewNo multiple-physician review mechanism specified in the Cr(VI) standard.
RecordkeepingRecords maintained per 8 CCR 3204, including PLHCP written opinions and information provided to the PLHCP.

Construction

Who is covered: Construction-only scope: employees exposed at/above the AL for 30+ days/year; signs/symptoms; emergency exposure

Evaluation performed by: PLHCP (physician or other licensed health care professional)

🩺 Baseline / Pre-Placement

Within 30 days after initial assignment, unless the employee received a qualifying exam meeting these requirements within the prior 12 months

  • Medical + work history covering past, present, and anticipated future exposure to Cr(VI); history of respiratory-system dysfunction; history of asthma, dermatitis, skin ulceration, or nasal septum perforation; and smoking status and history
  • Physical examination of the skin and respiratory tract
  • Any additional tests deemed appropriate by the examining PLHCP (no mandatory Cr biomarker)
🕒 Periodic / Routine

Interval-based while covered — NOT result-triggered

Schedule: At least annually.

  • Medical + work history covering past, present, and anticipated future exposure to Cr(VI); history of respiratory-system dysfunction; history of asthma, dermatitis, skin ulceration, or nasal septum perforation; and smoking status and history
  • Physical examination of the skin and respiratory tract
  • Any additional tests deemed appropriate by the examining PLHCP
🚪 Exit / Termination

At termination of employment

  • Medical + work history covering past, present, and anticipated future exposure to Cr(VI); history of respiratory-system dysfunction; history of asthma, dermatitis, skin ulceration, or nasal septum perforation; and smoking status and history
  • Physical examination of the skin and respiratory tract
  • Any additional tests deemed appropriate by the examining PLHCP
  • Termination medical examination — required unless the last examination satisfying 8 CCR 1532.2(i) was less than 6 months prior to the date of termination
⚠ Emergency / Post-Exposure

Within 30 days after an emergency exposure (uncontrolled release); also whenever the employee shows signs or symptoms of adverse Cr(VI) health effects

  • Medical + work history covering past, present, and anticipated future exposure to Cr(VI); history of respiratory-system dysfunction; history of asthma, dermatitis, skin ulceration, or nasal septum perforation; and smoking status and history
  • Physical examination of the skin and respiratory tract
  • Any additional tests deemed appropriate by the examining PLHCP
Abnormal results & exposure-event protocols

Abnormal Results & Exposure-Event Protocols

  • Examining PLHCP recommends an additional medical examination Additional examination on PLHCP recommendation: Provide the recommended additional examination within 30 days of the written recommendation. Tests: Examination as specified by the PLHCP

Reporting Requirements

Who performs the evaluationPLHCP (physician or other licensed health care professional)
Reported to employerWritten opinion containing only: whether the employee has a detected medical condition that places the employee at increased risk from further Cr(VI) exposure; any recommended exposure limitations or PPE/respirator restrictions; and a statement that the PLHCP explained the results to the employee, including any condition requiring further evaluation. PLHCP must NOT reveal findings or diagnoses unrelated to occupational Cr(VI) exposure.
Reported to / for the employeeEmployer provides a copy of the written opinion to the employee within 2 weeks of receiving it; PLHCP explains results directly to the employee.
Time limitsEmployer obtains the written opinion within 30 days of each exam; furnishes a copy to the employee within 2 weeks of receipt.
Second-opinion / multi-physician reviewNo multiple-physician review mechanism specified in the Cr(VI) standard.
RecordkeepingRecords maintained per 8 CCR 3204, including PLHCP written opinions.

Shipyard / Maritime

Who is covered: Employees in shipyards, marine terminals, and longshoring who are or may be occupationally exposed to Cr(VI) at/above the AL for 30+ days a year; employees experiencing signs or symptoms of adverse Cr(VI) health effects; employees exposed in an emergency. Exceptions: pesticide application regulated by CA DPR, U.S. EPA, or another federal agency; exposures to portland cement; and materials/processes with objective data showing they cannot release Cr(VI) at or above 0.5 µg/m³ as an 8-hour TWA under any expected conditions of use

Evaluation performed by: PLHCP (physician or other licensed health care professional)

🩺 Baseline / Pre-Placement

Within 30 days after initial assignment, unless the employee has received a Cr(VI)-related medical examination meeting the requirements of 8 CCR 8359(i) within the last twelve months

  • Medical + work history covering past, present, and anticipated future exposure to Cr(VI); history of respiratory-system dysfunction; history of asthma, dermatitis, skin ulceration, or nasal septum perforation; and smoking status and history
  • Physical examination of the skin and respiratory tract
  • Any additional tests deemed appropriate by the examining PLHCP (8359 mandates no biomarker, chest X-ray, or pulmonary function test)
🕒 Periodic / Routine

Interval-based while covered by medical surveillance under 8 CCR 8359(i) — NOT result-triggered

Schedule: Annually.

  • Medical + work history covering past, present, and anticipated future exposure to Cr(VI); history of respiratory-system dysfunction; history of asthma, dermatitis, skin ulceration, or nasal septum perforation; and smoking status and history
  • Physical examination of the skin and respiratory tract
  • Any additional tests deemed appropriate by the examining PLHCP (8359 mandates no biomarker, chest X-ray, or pulmonary function test)
🚪 Exit / Termination

At the termination of employment

  • Medical + work history covering past, present, and anticipated future exposure to Cr(VI); history of respiratory-system dysfunction; history of asthma, dermatitis, skin ulceration, or nasal septum perforation; and smoking status and history — required unless the last examination satisfying 8 CCR 8359(i) was less than six months prior to the date of termination
  • Physical examination of the skin and respiratory tract — required unless the last examination satisfying 8 CCR 8359(i) was less than six months prior to the date of termination
  • Any additional tests deemed appropriate by the examining PLHCP — required unless the last examination satisfying 8 CCR 8359(i) was less than six months prior to the date of termination (8359 mandates no biomarker, chest X-ray, or pulmonary function test)
⚠ Emergency / Post-Exposure

Within 30 days after exposure during an emergency which results in an uncontrolled release of Cr(VI); also whenever an employee shows signs or symptoms of the adverse health effects associated with Cr(VI) exposure

  • Medical + work history covering past, present, and anticipated future exposure to Cr(VI); history of respiratory-system dysfunction; history of asthma, dermatitis, skin ulceration, or nasal septum perforation; and smoking status and history
  • Physical examination of the skin and respiratory tract
  • Any additional tests deemed appropriate by the examining PLHCP (8359 mandates no biomarker, chest X-ray, or pulmonary function test)
Abnormal results & exposure-event protocols

Abnormal Results & Exposure-Event Protocols

  • A PLHCP's written medical opinion recommends an additional examination 8 CCR 8359(i)(2)(C): Employer makes the recommended additional medical examination available within 30 days after the PLHCP's written medical opinion. Tests: Additional medical examination as recommended by the PLHCP, Medical + work history covering past, present, and anticipated future exposure to Cr(VI); history of respiratory-system dysfunction; history of asthma, dermatitis, skin ulceration, or nasal septum perforation; and smoking status and history, Physical examination of the skin and respiratory tract, Any additional tests deemed appropriate by the examining PLHCP
  • PLHCP identifies a detected medical condition placing the employee at increased risk of material impairment from further Cr(VI) exposure 8 CCR 8359(i)(5)(A)2.: PLHCP states any recommended limitations upon the employee's exposure to Cr(VI) or upon the use of personal protective equipment such as respirators in the written medical opinion; 8 CCR 8359 establishes no medical removal protection or removal-triggering exposure level. Tests: Written recommendation of limitations on Cr(VI) exposure, Written recommendation of limitations on use of personal protective equipment such as respirators

Reporting Requirements

Who performs the evaluationPLHCP (physician or other licensed health care professional)
Reported to employerWritten medical opinion containing only: the PLHCP's opinion whether the employee has any detected medical condition(s) that would place the employee at increased risk of material impairment to health from further Cr(VI) exposure; any recommended limitations upon the employee's exposure to Cr(VI) or upon the use of PPE such as respirators; and a statement that the PLHCP has explained the results to the employee, including any Cr(VI)-related conditions requiring further evaluation or treatment and any special provisions for use of protective clothing or equipment. The PLHCP shall not reveal to the employer specific findings or diagnoses unrelated to occupational Cr(VI) exposure.
Reported to / for the employeePLHCP explains the examination results directly to the employee; the employer provides a copy of the PLHCP's written medical opinion to the examined employee within two weeks after receiving it.
Time limitsEmployer obtains the written medical opinion within 30 days of each medical examination; employer provides the copy to the employee within two weeks after receiving it.
Second-opinion / multi-physician review8 CCR 8359 specifies no multiple-physician review or second-opinion mechanism.
RecordkeepingEmployer establishes and maintains an accurate record for each employee covered by medical surveillance under 8 CCR 8359(i), including name and social security number, a copy of the PLHCP's written opinions, and a copy of the information provided to the PLHCP. Records maintained and made available in accordance with 8 CCR 3204.
How this compares to Federal OSHA: Aligned. All six standards (federal 1910.1026 / 1926.1126 / 1915.1026; California 5206 / 1532.2 / 8359) share AL 2.5 µg/m³, PEL 5 µg/m³, the same exam schedule (initial within 30 days, annual periodic, 30-day additional/emergency, 6-month termination window), the same medical-and-work-history plus skin/respiratory physical exam, no mandatory biomarker, and no medical-removal-protection provision at all — the only protection mechanism anywhere in the Cr(VI) family is the PLHCP's written recommendation for an additional examination. The two shipyard standards (federal 1915.1026; California 8359) are standalone texts, not incorporations of their general-industry counterparts — each carries its own PEL, its own action level, and its own exam-contents provision, and each reaches shipyards, marine terminals, and longshoring rather than shipyards alone. Both place medical surveillance at paragraph (i) (exam contents at (i)(3)) rather than at 1910.1026's paragraph (k), but the substance of the requirement is the same as general industry. The pesticide, portland-cement, and low-release (objective data below 0.5 µg/m³ 8-hr TWA) scope exceptions are common to both jurisdictions rather than a California addition — federal 1910.1026(a)(2)-(4) and 1915.1026(a) carry them as well; California's only distinction is that its pesticide exception is framed around CA DPR-regulated applications.

Occu-Med handles Hexavalent Chromium (Cr VI) surveillance end-to-end

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