Cal/OSHA · dir.ca.gov
Aromatic Carcinogens

Vinyl Chloride Medical Surveillance

Vinyl chloride causes angiosarcoma of the liver, liver dysfunction, and acroosteolysis; affects workers in PVC/polymer manufacturing and polymerization operations.

Action Level0.5 ppm (8-hr TWA)
PEL1 ppm (8-hr TWA); ceiling 5 ppm / 15 min (maximum)
Who is covered: Each employee exposed above the action level, without regard to respirator use

Evaluation performed by: Licensed physician

🩺 Baseline / Pre-Placement

At the time of initial assignment, or upon institution of medical surveillance

  • Medical/work history covering alcohol intake, history of hepatitis, work history with exposure to hepatotoxic agents, blood transfusion history, and hospitalization history
  • General physical examination with specific attention to enlargement of or dysfunction in the liver, spleen, or kidneys, and to abnormalities of skin, connective tissue, and the pulmonary system
  • Serum/liver-function panel: total bilirubin; alkaline phosphatase; SGOT (AST); SGPT (ALT); gamma-glutamyl transpeptidase
🕒 Periodic / Routine

Interval-based while covered — NOT result-triggered

Schedule: Every 6 months (semiannual) for employees who have worked 10+ years in vinyl chloride manufacturing; at least annually for all other covered employees.

  • Medical/work history covering alcohol intake, history of hepatitis, work history with exposure to hepatotoxic agents, blood transfusion history, and hospitalization history
  • General physical examination with specific attention to enlargement of or dysfunction in the liver, spleen, or kidneys, and to abnormalities of skin, connective tissue, and the pulmonary system
  • Serum/liver-function panel: total bilirubin; alkaline phosphatase; SGOT (AST); SGPT (ALT); gamma-glutamyl transpeptidase
Abnormal results & exposure-event protocols

Abnormal Results & Exposure-Event Protocols

  • Liver-function tests abnormal on examination 8 CCR 5210(k): Additional examinations (e.g., liver scan, biopsy) are performed at the examining physician's discretion. Tests: Physician-directed follow-up studies (e.g., liver scan, liver biopsy)
  • Continued exposure would materially impair the employee's health 8 CCR 5210(k)(5): Employee shall be withdrawn from possible contact with vinyl chloride (no wage-protected MRP scheme).

Reporting Requirements

Who performs the evaluationLicensed physician
Reported to employerWritten statement of the employee's suitability for continued exposure to vinyl chloride, including use of protective equipment and respirators.
Reported to / for the employeeA copy of the physician's written statement is provided to each employee.
Time limitsPhysician's statement obtained promptly after any examination; copy provided to the employee.
Second-opinion / multi-physician reviewNo multiple-physician-review scheme codified in the standard.
RecordkeepingMedical records retained for the duration of employment plus 30 years (8 CCR 3204).

Medical Removal Protection

No formal wage-protected MRP. If continued exposure would materially impair the employee's health, the employee shall be withdrawn from possible contact with vinyl chloride (1910.1017(k)(5)).

How this compares to Federal OSHA: California explicitly codifies semiannual (every-6-month) periodic exams for employees with 10+ years in vinyl chloride manufacturing, whereas the federal text frames periodic exams as 'at least annually' without a codified tenure-based semiannual tier. AL/PEL/ceiling, the liver-function panel, and the withdrawal provision are otherwise equivalent. California has no separate construction VC section (construction governed federally by 1926.1117, incorporating 1910.1017 by reference).

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

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