Federal OSHA · osha.gov
Fibrogenic Dusts

Cotton Dust Medical Surveillance

Cotton dust causes byssinosis (brown lung) and chronic respiratory impairment; affects workers in yarn manufacturing, cotton washing, textile waste houses, and slashing/weaving.

Action LevelYarn manufacturing/cotton washing: 100 µg/m³; textile waste houses: 250 µg/m³; slashing & weaving: 375 µg/m³ (8-hr TWA)
PELYarn manufacturing & cotton washing: 200 µg/m³; textile waste/lower-grade washed cotton: 500 µg/m³; slashing & weaving: 750 µg/m³ (8-hr TWA)
Who is covered: All employees exposed to cotton dust

Evaluation performed by: Licensed physician

🩺 Baseline / Pre-Placement

Prior to initial assignment to cotton-dust exposure

  • Medical and work history
  • Standardized byssinosis questionnaire (Appendix B, with Schilling byssinosis grading)
  • Pulmonary function test — FVC, FEV1, and FEV1/FVC ratio (compared to NHANES III reference values)
  • Across-shift spirometry: measured before the employee enters the workplace on the first day of the work week (after at least 35 hours of no cotton-dust exposure), and again no less than 4 and no more than 10 hours after the start of the work shift (captures the across-shift FEV1 change diagnostic of byssinosis)
🕒 Periodic / Routine

Interval-based by exposure level while covered — NOT result-triggered (result-triggered acceleration is in abnormal_protocols)

Schedule: At least annually for employees exposed above the action level; at least every 2 years for employees exposed at or below the action level (and for those exposed only to washed cotton or in cottonseed/waste processing).

  • Medical and work history update
  • Standardized byssinosis questionnaire (Appendix B)
  • Pulmonary function test — FVC, FEV1, FEV1/FVC ratio
  • Across-shift spirometry (pre-shift after ≥35 hours of no exposure, and 4–10 hours after shift start)
Abnormal results & exposure-event protocols

Abnormal Results & Exposure-Event Protocols

  • FEV1 decrement of 5% or 200 mL on the first working day, FEV1 below the lower limit of normal, or a significant change in the questionnaire or pulmonary function results 1910.1043(h)(3)(ii) (parallel CA 5190(h)(3)(B)): Increase the periodic examination frequency to at least every 6 months. Tests: Standardized byssinosis questionnaire (Appendix B), Pulmonary function test (FVC, FEV1, FEV1/FVC) with across-shift testing

Reporting Requirements

Who performs the evaluationLicensed physician
Reported to employerWritten opinion limited to: the results of the pulmonary function tests (FEV1, FVC, FEV1/FVC ratio); an opinion whether the employee has any detected medical condition that would place them at increased risk from cotton-dust exposure; recommended exposure limitations; a respirator-use determination; and a statement that the employee was informed of the results. Unrelated findings must not be revealed.
Reported to / for the employeeEmployee informed of the examination results and of any medical condition requiring further evaluation; furnished a copy of the written opinion.
Time limitsThe standard specifies no explicit deadline for furnishing the copy of the written opinion to the employee (see unverified note).
Second-opinion / multi-physician reviewNo formal multiple-physician review mechanism specified.
RecordkeepingMedical records retained for at least 20 years [1910.1043(k)(2)(iii)].

Medical Removal Protection

No medical removal protection scheme; abnormal-result protocol accelerates periodic testing to every 6 months. Physician's written opinion conveys PFT results and increased-risk findings.

How this compares to Cal/OSHA: Effectively identical — same three PELs (200/500/750 µg/m³), same action levels (100/250/375 µg/m³), the same Appendix B byssinosis (Schilling-grade) questionnaire, the same pre-shift/across-shift FEV1 methodology, and the same annual / biennial / every-6-month frequency tiers. No material divergence found.

Occu-Med handles Cotton Dust surveillance end-to-end

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