Cal/OSHA · dir.ca.gov
Heavy Metals

Inorganic Arsenic Medical Surveillance

Inorganic arsenic causes lung and skin cancer, dermatitis, and nasal/respiratory irritation; affects workers in smelting, glass manufacturing, pesticide production, and wood treatment.

Action Level5 µg/m³ (8-hr TWA)
PEL10 µg/m³ (8-hr TWA)

General Industry

Who is covered: All employees exposed above the AL (without regard to respirator use) at least 30 days/year; and all employees exposed above the AL 30+ days/year for a total of 10+ years of combined employment

Evaluation performed by: Licensed physician (employer-provided, at no cost)

🩺 Baseline / Pre-Placement

At the time of initial assignment to an area where the employee is likely to be exposed above the AL at least 30 days/year

  • Work and comprehensive medical history, including smoking history
  • Physical examination with special attention to skin, nose, respiratory tract, lymph nodes, nervous system, and liver
  • Posterior-anterior chest X-ray (14×17-inch)
  • A sputum cytology examination
  • Other examinations the physician believes appropriate
🕒 Periodic / Routine

Interval-based while covered — NOT result-triggered. Frequency depends on a covered-status risk tier (age/tenure), not on a prior abnormal result.

Schedule: Annually for employees under age 45 AND with fewer than 10 years of arsenic exposure. Semi-annually for employees aged 45 or older OR with 10 or more years of exposure.

  • Interim work and medical history, including smoking history
  • Interim physical examination
  • Sputum cytology examination — included in the semi-annual (high-risk: age ≥45 OR ≥10 years exposure) examination
  • Other examinations the physician believes appropriate
🚪 Exit / Termination

At termination of employment

  • Opportunity for the required examination upon termination if the last exam was more than 6 months prior
⚠ Emergency / Post-Exposure

Employee develops signs or symptoms associated with inorganic arsenic exposure

  • Additional medical examination as appropriate

Reporting Requirements

Who performs the evaluationLicensed physician
Reported to employerWritten report interpreting the results of each medical examination and providing recommendations; the physician is not to reveal specific findings or diagnoses unrelated to occupational arsenic exposure.
Reported to / for the employeeEmployer provides a copy of the physician's written report to the affected employee.
Time limitsNo specific timeframe for furnishing the written report is stated in the standard.
Second-opinion / multi-physician reviewNo multiple-physician review mechanism specified.
RecordkeepingMedical records maintained for at least 40 years, or for the duration of employment plus 20 years, whichever is longer (records access per 8 CCR 3204).
How this compares to Federal OSHA: Materially different on periodic surveillance and required tests. Federal (1910.1018 / 1926.1118) sets a single periodic frequency of 'at least annually' with NO age/tenure split and mandates only history, posterior-anterior chest X-ray, and nasal/skin exam — sputum cytology, CBC, and lymph-node exams are NOT required by the federal regulatory text. California 8 CCR 5214 imposes a two-tier periodic frequency (annual for age <45 AND <10 years; semi-annual for age ≥45 OR ≥10 years), a broader physical exam (skin, nose, respiratory tract, lymph nodes, nervous system, liver), and a mandatory sputum cytology examination at the initial exam and at each semi-annual (high-risk) exam. AL (5 µg/m³) and PEL (10 µg/m³) are identical; neither jurisdiction has automatic medical removal protection. California has no separate construction arsenic section.

Occu-Med handles Inorganic Arsenic surveillance end-to-end

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