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

4,4'-Methylenedianiline (MDA) Medical Surveillance

MDA is a hepatotoxin and probable carcinogen absorbed through skin; affects workers in epoxy/polyurethane manufacturing, coatings, and curing-agent handling.

Action Level5 ppb (8-hr TWA)
PEL10 ppb (8-hr TWA); STEL 100 ppb / 15 min
Who is covered: Same five triggers as federal: AL 30+ days/year; dermal exposure 15+ days/year; emergency; reasonably believed dermal-exposed; signs/symptoms (CAS 101-77-9)

Evaluation performed by: Licensed physician (by or under the supervision of)

🩺 Baseline / Pre-Placement

Before initial assignment (or within the standard's phase-in window)

  • Detailed occupational and medical history
  • Physical examination with particular attention to the skin and signs/symptoms of liver disease
  • Liver function tests
  • Urinalysis
  • Additional tests the physician deems necessary
🕒 Periodic / Routine

Interval-based while covered — NOT result-triggered

Schedule: At least annually.

  • Brief update of occupational/health history
  • Liver function tests
  • Skin examination
  • Additional tests the physician deems necessary
⚠ Emergency / Post-Exposure

Emergency / hazardous exposure

  • Medical examination as soon as possible after the exposure
  • History and physical emphasizing skin and liver
  • Liver function tests
  • Repeat liver function tests 2–3 weeks after the initial tests
Abnormal results & exposure-event protocols

Abnormal Results & Exposure-Event Protocols

  • Employee develops signs/symptoms associated with MDA exposure 8 CCR 5200 (signs/symptoms exam): Provide an additional examination including repeat liver function tests. Tests: Repeat liver function tests, Skin/liver-focused physical examination
  • Physician finds abnormal liver function tests or an increased-risk condition that could worsen with continued exposure 8 CCR 5200 — Medical Removal Protection: Remove from MDA exposure; maintain earnings/seniority/benefits (MRP) up to 6 months; return when signs resolve or physician advises. Tests: Liver function tests during removal to determine return eligibility

Reporting Requirements

Who performs the evaluationLicensed physician
Reported to employerWritten opinion with occupationally pertinent results, increased-risk determination, and recommended limitations; must not reveal findings unrelated to occupational exposure.
Reported to / for the employeeEmployer furnishes a copy of the written opinion to the employee.
Time limitsWithin 15 days of employer receipt [5200(m)(8)(A)].
Second-opinion / multi-physician reviewMultiple-physician review: the employee may designate a second physician [5200(m)(6)(A)]; if disagreement persists, a third physician is jointly designated to resolve it [5200(m)(6)(D)].
RecordkeepingMedical records retained for the duration of employment plus 30 years (8 CCR 3204).

Medical Removal Protection

Removal on abnormal LFTs / increased-risk finding; up to 6 months wage/benefit protection — mirrors federal.

How this compares to Federal OSHA: Substantively aligned — Cal/OSHA 5200 mirrors federal 1910.1050 (same limits, dermal trigger, liver-function-test + urinalysis baseline, annual LFT + skin-exam periodic, 6-month MRP). The federal construction variant 1926.60 is equivalent under paragraph (n). (CA reporting time limits/retention marked unverified — not separately confirmed in 5200 text.)

Occu-Med handles 4,4'-Methylenedianiline (MDA) surveillance end-to-end

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