Federal OSHA · osha.gov
Aromatic Carcinogens

Benzene Medical Surveillance

Benzene causes leukemia, aplastic anemia, and bone-marrow suppression; affects workers in petrochemicals, refining, rubber/tire manufacturing, and solvent use.

Action Level0.5 ppm (8-hr TWA)
PEL1 ppm (8-hr TWA); STEL 5 ppm / 15 min

General Industry

Who is covered: Employees exposed at/above the AL 30+ days/year, OR at/above the PEL/STEL 10+ days/year, OR with prior exposure >10 ppm for 30+ days/year (historical), OR tire-building machine operators using solvents with >0.1% benzene

Evaluation performed by: Licensed physician (hematologist or internist on referral for persistent CBC abnormality)

🩺 Baseline / Pre-Placement

Before initial assignment to benzene work (or within 60 days of the standard's effective date for already-assigned employees)

  • Detailed occupational history
  • Complete physical examination
  • CBC: leukocyte count with differential, quantitative platelet (thrombocyte) count, hematocrit, hemoglobin, erythrocyte count, erythrocyte indices (MCV, MCH, MCHC)
  • Pulmonary function test if a respirator is worn 30+ days/year
🕒 Periodic / Routine

Interval-based while covered — NOT result-triggered

Schedule: Annually following the previous examination.

  • Updated occupational history
  • Complete physical examination
  • CBC: leukocyte count with differential, quantitative platelet (thrombocyte) count, hematocrit, hemoglobin, erythrocyte count, erythrocyte indices (MCV, MCH, MCHC)
  • Pulmonary function test if a respirator is worn 30+ days/year
Abnormal results & exposure-event protocols

Abnormal Results & Exposure-Event Protocols

  • Abnormal CBC: hemoglobin/hematocrit below the normal limit (outside the 95% C.I.) or a persistent downward trend from the individual's pre-exposure norm; platelet count >20% below the most recent value or outside normal limits; leukocytes <4,000/mm3 or an abnormal differential count 1910.1028(i)(5)(i): Repeat the complete CBC within 2 weeks. Tests: Repeat CBC: leukocyte count with differential, quantitative platelet (thrombocyte) count, hematocrit, hemoglobin, erythrocyte count, erythrocyte indices (MCV, MCH, MCHC)
  • CBC abnormality persists on the repeat test 1910.1028(i)(5)(ii): Examining physician refers the employee to a hematologist or internist for further evaluation, unless the physician has good reason to believe referral is unnecessary. Tests: Specialist (hematologist/internist) evaluation
  • Emergency / acute exposure to benzene 1910.1028(i)(4): Collect a urine sample at end of shift and perform a urinary phenol test within 72 hours. If urinary phenol is at or above 75 mg phenol/L (creatinine-corrected), provide a CBC at monthly intervals for 3 months following the emergency exposure; below 75 mg/L, no further testing required. Tests: End-of-shift urine collection, Urinary phenol test within 72 hours, Monthly CBC for 3 months if urinary phenol >=75 mg/L
  • Referral to hematologist/internist following persistent CBC abnormality (medical removal) 1910.1028(i)(8)-(9): Employee removed from areas where benzene exposure may exceed the action level and transferred to a comparable job with exposure at or below the AL, maintaining wage rate, seniority, and benefits. Within 6 months of removal the physician determines return to the former job or permanent removal. Employee receives up to 6 months of medical removal protection (MRP) benefits per removal. Tests: Periodic CBC during removal to determine return eligibility

Reporting Requirements

Who performs the evaluationLicensed physician (examining physician; hematologist or internist on referral for persistent CBC abnormality)
Reported to employerWritten opinion limited to: occupationally pertinent exam/test results; whether the employee has a greater-than-normal risk of material impairment from benzene; recommended exposure/PPE limitations; and a statement that the employee was informed of the results. Must NOT reveal specific records, findings, or diagnoses with no bearing on ability to work in a benzene-exposed workplace.
Reported to / for the employeeEmployee informed of exam results and any medical condition requiring further evaluation; furnished a copy of the written opinion.
Time limitsWritten opinion furnished within 15 days of the examination (1910.1028(i)(7)).
Second-opinion / multi-physician reviewNo multiple-physician-review scheme; on referral the examining physician and the hematologist/internist consult and communicate removal/return decisions in writing (1910.1028(i)(8)).
RecordkeepingMedical surveillance records retained for the duration of employment plus 30 years (29 CFR 1910.1020).

Medical Removal Protection

On referral to a hematologist/internist for a persistent CBC abnormality, the employee is removed from areas where exposure may exceed the AL and transferred to a comparable job at/below the AL with wage, seniority, and benefits maintained; up to 6 months of MRP benefits per removal (strongest MRP of the five aromatic carcinogens).

Construction

Who is covered: Construction work covered identically to 1910.1028 by incorporation by reference — '...requirements applicable to construction work under this section are identical to those set forth at 1910.1028.' All exam events, components, abnormal protocols, MRP, and reporting are governed by 1910.1028.

Evaluation performed by: Licensed physician (hematologist or internist on referral for persistent CBC abnormality)

🩺 Baseline / Pre-Placement

Before initial assignment to benzene work (per 1910.1028, incorporated by reference)

  • Detailed occupational history
  • Complete physical examination
  • CBC: leukocyte count with differential, quantitative platelet (thrombocyte) count, hematocrit, hemoglobin, erythrocyte count, erythrocyte indices (MCV, MCH, MCHC)
  • Pulmonary function test if a respirator is worn 30+ days/year
🕒 Periodic / Routine

Interval-based while covered — NOT result-triggered

Schedule: Annually following the previous examination (per 1910.1028, incorporated by reference).

  • Updated occupational history
  • Complete physical examination
  • CBC: leukocyte count with differential, quantitative platelet (thrombocyte) count, hematocrit, hemoglobin, erythrocyte count, erythrocyte indices (MCV, MCH, MCHC)
  • Pulmonary function test if a respirator is worn 30+ days/year
Abnormal results & exposure-event protocols

Abnormal Results & Exposure-Event Protocols

  • Abnormal CBC: hemoglobin/hematocrit below the normal limit (outside the 95% C.I.) or a persistent downward trend from the individual's pre-exposure norm; platelet count >20% below the most recent value or outside normal limits; leukocytes <4,000/mm3 or an abnormal differential count 1910.1028(i)(5)(i): Repeat the complete CBC within 2 weeks. Tests: Repeat CBC: leukocyte count with differential, quantitative platelet (thrombocyte) count, hematocrit, hemoglobin, erythrocyte count, erythrocyte indices (MCV, MCH, MCHC)
  • CBC abnormality persists on the repeat test 1910.1028(i)(5)(ii): Examining physician refers the employee to a hematologist or internist for further evaluation, unless the physician has good reason to believe referral is unnecessary. Tests: Specialist (hematologist/internist) evaluation
  • Emergency / acute exposure to benzene 1910.1028(i)(4): Collect a urine sample at end of shift and perform a urinary phenol test within 72 hours. If urinary phenol is at or above 75 mg phenol/L (creatinine-corrected), provide a CBC at monthly intervals for 3 months following the emergency exposure; below 75 mg/L, no further testing required. Tests: End-of-shift urine collection, Urinary phenol test within 72 hours, Monthly CBC for 3 months if urinary phenol >=75 mg/L
  • Referral to hematologist/internist following persistent CBC abnormality (medical removal) 1910.1028(i)(8)-(9): Employee removed from areas where benzene exposure may exceed the action level and transferred to a comparable job with exposure at or below the AL, maintaining wage rate, seniority, and benefits. Within 6 months of removal the physician determines return to the former job or permanent removal. Employee receives up to 6 months of medical removal protection (MRP) benefits per removal. Tests: Periodic CBC during removal to determine return eligibility

Reporting Requirements

Who performs the evaluationLicensed physician (examining physician; hematologist or internist on referral for persistent CBC abnormality)
Reported to employerWritten opinion limited to: occupationally pertinent exam/test results; whether the employee has a greater-than-normal risk of material impairment from benzene; recommended exposure/PPE limitations; and a statement that the employee was informed of the results. Must NOT reveal specific records, findings, or diagnoses with no bearing on ability to work in a benzene-exposed workplace.
Reported to / for the employeeEmployee informed of exam results and any medical condition requiring further evaluation; furnished a copy of the written opinion.
Time limitsWritten opinion furnished within 15 days of the examination (1910.1028(i)(7)).
Second-opinion / multi-physician reviewNo multiple-physician-review scheme; on referral the examining physician and the hematologist/internist consult and communicate removal/return decisions in writing (1910.1028(i)(8)).
RecordkeepingMedical surveillance records retained for the duration of employment plus 30 years (29 CFR 1910.1020).

Medical Removal Protection

Identical to 1910.1028 by reference: removal on referral, comparable transfer at/below AL, up to 6 months of MRP benefits.

How this compares to Cal/OSHA: Essentially aligned — California adopted the federal benzene standard with identical AL/PEL/STEL, CBC panel, abnormal-CBC repeat-and-refer protocol, and 6-month MRP. The only notable difference is the historical-exposure cutoff worded as 'before December 10, 1989' in CA. California has no separate construction benzene section (construction governed federally by 1926.1128, which incorporates 1910.1028 by reference).

Occu-Med handles Benzene surveillance end-to-end

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