Cal/OSHA · dir.ca.gov
Other Organics & Carcinogens

4,4'-Methylenebis(2-Chloroaniline) (MBOCA/MOCA) Medical Surveillance

MBOCA (MOCA) is a probable bladder/liver carcinogen absorbed through skin; affects workers in polyurethane elastomer/casting and curing-agent operations. Surveillance keys on a urinary biological exposure limit rather than airborne sampling.

Action LevelUse-based trigger (no airborne AL/PEL framework). Biological exposure limit: urine MBOCA ≤ 100 µg per liter of urine, specific gravity adjusted to 1.024 [5215(c)(1)]
Who is covered: Employers using more than one kilogram of MBOCA (regardless of concentration, dilution, or form, except frozen premix) in any 6-month period; authorized persons handling MBOCA [5215(d)(1)]

Evaluation performed by: Licensed physician (examinations by or under the supervision of) [5215(k)]

🩺 Baseline / Pre-Placement

Prior to the time of initial assignment, or within 90 days of the standard's effective date [5215(k)(1)]

  • Comprehensive medical history with emphasis on pertinent medical, occupational, genetic, and environmental factors [5215(k)(2)]
  • Comprehensive physical examination with emphasis on detecting abnormalities of the liver, pulmonary system, urinary system, breasts, and hematologic system [5215(k)(2)]
  • Chest X-ray (14×17 PA)
  • Complete blood count (CBC)
  • Complete urinalysis
  • Liver function tests: serum total bilirubin, alkaline phosphatase, and SGOT/SGPT
  • Urine MBOCA biological monitoring (specific gravity adjusted to 1.024)
  • NOTE: urine cytology is NOT required by this standard
🕒 Periodic / Routine

Interval-based while covered — NOT result-triggered

Schedule: At least every 3 years for the first 10 years of employment involving the use of MBOCA, and annually thereafter [5215(k)(1)].

  • Updated comprehensive medical history (medical/occupational/genetic/environmental factors)
  • Comprehensive physical examination emphasizing liver, pulmonary, urinary, breast, and hematologic systems
  • Chest X-ray (14×17 PA)
  • Complete blood count (CBC)
  • Complete urinalysis
  • Liver function tests: total bilirubin, alkaline phosphatase, SGOT/SGPT
  • Urine MBOCA biological monitoring
  • NOTE: NO urine cytology
Abnormal results & exposure-event protocols

Abnormal Results & Exposure-Event Protocols

  • Urine MBOCA exceeds the 100 µg/L biological exposure limit (or another abnormal biological result) 8 CCR 5215(c)/(k) — biological monitoring response: Repeat the abnormal biological measurement (recommended within ~30 days) and investigate exposure controls; the standard provides no mandatory medical-removal criterion, so withdrawal from exposure is discretionary based on physician judgment. Tests: Repeat urine MBOCA determination, Physician evaluation of liver/urinary/hematologic status

Reporting Requirements

Who performs the evaluationLicensed physician
Reported to employerWritten opinion of the examining physician regarding the employee's medical status relative to MBOCA exposure (occupationally pertinent findings).
Reported to / for the employeePhysician must provide a copy of the written opinion to the affected employee [5215(k)].
Time limitsStandard requires the written opinion be provided to the employee; a specific day-count is not stated in the verified text.
Second-opinion / multi-physician reviewNo multiple-physician review mechanism specified.
RecordkeepingPhysician opinions/records retained for the duration of employment plus 20 years, or 30 years, whichever is longer [5215(l)(6)].

Medical Removal Protection

No mandatory medical removal protection criterion. Abnormal biological (urine MBOCA) results prompt repeat testing and exposure-control review; withdrawal is at physician discretion.

How this compares to Federal OSHA: California-only — 8 CCR 5215 regulates MBOCA via a urinary biological exposure limit (urine MBOCA ≤ 100 µg/L) with comprehensive liver/pulmonary/urinary/breast/hematologic exams, chest X-ray, CBC, urinalysis, and liver function tests; there is NO direct federal OSHA substance-specific MBOCA standard (federal coverage is HazCom + General Duty Clause only). Critically, this standard requires NO urine cytology. Note the common citation trap: 5215 (MBOCA) is distinct from 5212 (DBCP).

Occu-Med handles 4,4'-Methylenebis(2-Chloroaniline) (MBOCA/MOCA) surveillance end-to-end

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