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)
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 attention to skin, nose, respiratory tract, lymph nodes, nervous system, and liver
  • Posterior-anterior chest X-ray (14×17-inch)
  • Sputum cytology examination
  • Other tests the physician deems appropriate [8 CCR 5214(n)(2)]
🕒 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.

  • Annual tier (age <45 AND <10 years exposure): interim work and medical history including smoking history; interim physical examination; and other examinations the physician believes appropriate because of arsenic exposure or required respirator use [8 CCR 5214(n)(3)(A)]
  • Semi-annual tier (age ≥45 OR ≥10 years exposure): interim work and medical history including smoking history; interim physical examination; other examinations the physician believes appropriate because of arsenic exposure or required respirator use; chest X-ray; and sputum cytology examination [8 CCR 5214(n)(3)(B)]
🚪 Exit / Termination

At termination of employment

  • Termination examination, annual tier (age <45 AND <10 years exposure) — interim work and medical history including smoking history; interim physical examination; and other examinations the physician believes appropriate because of arsenic exposure or required respirator use — required unless the applicable periodic examination was taken within the 6 months preceding termination [8 CCR 5214(n)(3)(C), (n)(3)(A)]
  • Termination examination, semi-annual tier (age ≥45 OR ≥10 years exposure) — interim work and medical history including smoking history; interim physical examination; other examinations the physician believes appropriate because of arsenic exposure or required respirator use; chest X-ray; and sputum cytology examination — required unless the applicable periodic examination was taken within the 6 months preceding termination [8 CCR 5214(n)(3)(C), (n)(3)(B)]
⚠ 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. The two jurisdictions are also structured differently by sector: federal maintains three sector-specific inorganic arsenic sections — general industry (1910.1018), construction (1926.1118), and shipyard employment (1915.1018) — where the shipyard section adds no independent requirements but incorporates the general industry standard wholesale, providing only that 'The requirements applicable to shipyard employment under this section are identical to those set forth at § 1910.1018 of this chapter.' California has one. Title 8 Subchapter 18 (Ship Building, Ship Repairing and Ship Breaking Safety Orders, sections 8345–8399) contains no arsenic section, so California has no separate shipyard arsenic standard. This is a structural difference in how the two schemes are organized, not a difference in coverage: 8 CCR 5214 is written by activity rather than by sector, applying to the 'manufacture, reaction, release, packaging, repackaging, storage, handling, disposal or other use of inorganic arsenic,' so arsenic work performed in California shipyards is regulated by 5214 itself rather than by a sector-specific 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.