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

Methylene Chloride Medical Surveillance

Methylene chloride (dichloromethane) is a probable carcinogen and metabolizes to carbon monoxide, stressing the cardiovascular and nervous systems; affects workers in paint stripping, degreasing, foam blowing, and solvent use.

Action Level12.5 ppm (8-hr TWA)
PEL25 ppm (8-hr TWA); STEL 125 ppm / 15 min
Who is covered: Exposed at/above the AL on 30+ days/year or above PEL/STEL on 10+ days/year; physician-identified at-risk employees who request inclusion; emergencies [5202(j)(1)(A)-(C)]

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

🩺 Baseline / Pre-Placement

Before initial assignment

  • Standardized medical/work history questionnaire — neurological symptoms, skin conditions, hematologic/liver disease history, cardiac risk factors [5202(j)(5)]
  • Physical examination emphasizing lungs, cardiovascular system (BP/pulse), liver, nervous system, skin
  • Laboratory studies at PLHCP discretion — carboxyhemoglobin (COHb), ECG, hematocrit, liver function tests, total cholesterol
🕒 Periodic / Routine

Interval-based while covered — NOT result-triggered

Schedule: Age-stratified: employees aged 45 or older every 12 months; employees under 45 every 36 months [5202(j)(4)(B)].

  • Updated medical/work history (standardized questionnaire)
  • Physical examination emphasizing lungs, cardiovascular, liver, nervous system, skin
  • Laboratory studies at PLHCP discretion — carboxyhemoglobin (COHb), ECG, hematocrit, liver function tests, total cholesterol
🚪 Exit / Termination

Termination of employment or reassignment out of MC exposure

  • Termination medical examination — provided if 6 or more months have elapsed since the last MC examination
  • Updated history and physical examination
⚠ Emergency / Post-Exposure

Emergency exposure

  • Decontamination
  • Comprehensive examination emphasizing nervous, cardiovascular, pulmonary, hepatic, and dermal systems
  • Updated history; laboratory studies as indicated (carboxyhemoglobin / CO assessment)
Abnormal results & exposure-event protocols

Abnormal Results & Exposure-Event Protocols

  • PLHCP recommends removal because continued MC exposure may aggravate existing cardiac/hepatic/neurological/dermal disease 8 CCR 5202(j)(11): Transfer to comparable work (≤ action level) or remove from MC exposure; maintain earnings/seniority/benefits up to 6 months. Tests: Follow-up examination at PLHCP-recommended frequency to determine return eligibility

Reporting Requirements

Who performs the evaluationPhysician or other licensed health care professional (PLHCP)
Reported to employerWritten opinion on whether MC exposure may aggravate existing cardiac/hepatic/neurological/dermal disease and any recommended exposure/respirator limitations; must not reveal records/findings unrelated to occupational MC exposure.
Reported to / for the employeeEmployee informed MC is a potential occupational carcinogen, of cardiac risk factors, and of examination results and any MC-related conditions.
Time limitsWritten opinion within 15 days of evaluation, no more than 30 days after examination (mirroring federal).
Second-opinion / multi-physician reviewMultiple-health-care-professional review mechanism mirroring federal (second PLHCP of employee's choice; jointly designated specialist as definitive determination).
RecordkeepingMedical records retained for the duration of employment plus 30 years (8 CCR 3204).

Medical Removal Protection

Removal/transfer on PLHCP recommendation with earnings/seniority/benefits maintained up to 6 months [5202(j)(11)] — equivalent to federal.

How this compares to Federal OSHA: Substantively equivalent — California adopted the federal MC standard with identical limits, the same coverage triggers, the same age-stratified periodic schedule (≥45: 12 months / <45: 36 months), the same history/physical content, and the same removal/transfer MRP. (CA written-opinion timing and recordkeeping retention marked unverified — not separately confirmed in 5202 text.)

Occu-Med handles Methylene Chloride surveillance end-to-end

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