General Industry
Who is covered: Employees exposed above the AL (without regard to respirator use) at least 30 days/year; employees with prior exposure above the AL 30+ days/year for a total of 10+ years of combined employment; plus additional exams for any employee developing arsenic-related signs/symptoms
Evaluation performed by: Licensed physician (employer-provided, at no cost)
🩺 Baseline / Pre-Placement
At the time of initial assignment to an area where the employee is likely to be exposed above the AL at least 30 days/year
- Work history and medical history including a smoking history and the presence and degree of respiratory symptoms such as breathlessness, cough, sputum production, and wheezing
- Standard film or digital posterior-anterior chest X-ray
- A nasal and skin examination
- Other examinations the physician believes appropriate because of the employee's arsenic exposure or required respirator use
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: At least annually (29 CFR 1910.1018(n)(3)(i)).
- Work history and medical history including a smoking history and the presence and degree of respiratory symptoms such as breathlessness, cough, sputum production, and wheezing
- Standard film or digital posterior-anterior chest X-ray
- A nasal and skin examination
- Other examinations which the physician believes appropriate because of the employee's exposure to inorganic arsenic or because of required respirator use
🚪 Exit / Termination
At termination of employment — 29 CFR 1910.1018(n)(3)(ii) scopes the termination examination to the elements of paragraphs (n)(2)(i) and (n)(2)(ii)(B) and (C); the (n)(2)(ii)(A) chest X-ray is not among the elements it incorporates
- Work history and medical history including a smoking history and the presence and degree of respiratory symptoms such as breathlessness, cough, sputum production, and wheezing
- A nasal and skin examination
- Other examinations the physician believes appropriate because of the employee's arsenic exposure or required respirator use
- Provided by the employer upon termination of employment unless the employee has taken the examinations listed above within the 6 months preceding termination
⚠ Emergency / Post-Exposure
Employee develops signs or symptoms commonly associated with inorganic arsenic exposure
- Additional medical examination as appropriate
- Emergency medical treatment as appropriate
Reporting Requirements
| Who performs the evaluation | Licensed physician |
|---|---|
| Reported to employer | Written opinion containing: the results of the medical examination and tests; an opinion as to whether the employee has any detected medical condition that places the employee at increased risk of material impairment from arsenic exposure; any recommended limitations on the employee's arsenic exposure or use of protective clothing/equipment; and a statement that the employee was informed of the results and of any condition requiring further examination or treatment. The physician is instructed not to reveal in the written opinion specific findings or diagnoses unrelated to occupational arsenic exposure. |
| Reported to / for the employee | Employer provides a copy of the written opinion to the affected employee. |
| Time limits | No specific timeframe for furnishing the written opinion is stated in the standard. |
| Second-opinion / multi-physician review | No multiple-physician review mechanism specified in the arsenic standard. |
| Recordkeeping | Medical records maintained for at least 40 years, or for the duration of employment plus 20 years, whichever is longer (29 CFR 1910.1018(q)(2)(iv)). |
Construction
Who is covered: Requirements identical to 1910.1018: exposed above the AL 30+ days/year; prior exposure 30+ days/year for 10+ combined years; plus signs/symptoms
Evaluation performed by: Licensed physician (employer-provided, at no cost)
🩺 Baseline / Pre-Placement
At the time of initial assignment to an area where the employee is likely to be exposed above the AL at least 30 days/year
- Work history and medical history including a smoking history and the presence and degree of respiratory symptoms such as breathlessness, cough, sputum production, and wheezing
- Standard film or digital posterior-anterior chest X-ray
- A nasal and skin examination
- Other examinations the physician believes appropriate because of the employee's arsenic exposure or required respirator use
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: At least annually (no age-45 / 10-year semiannual split in the federal standard).
- Work history and medical history including a smoking history and the presence and degree of respiratory symptoms such as breathlessness, cough, sputum production, and wheezing
- Standard film or digital posterior-anterior chest X-ray
- A nasal and skin examination
- Other examinations the physician believes appropriate because of the employee's exposure to inorganic arsenic or because of required respirator use
🚪 Exit / Termination
At termination of employment
- Work history and medical history including a smoking history and the presence and degree of respiratory symptoms such as breathlessness, cough, sputum production, and wheezing
- A nasal and skin examination
- Other examinations the physician believes appropriate because of the employee's exposure to inorganic arsenic or because of required respirator use
- All of the above are provided upon termination of employment — required only where the employee has not taken these examinations within the six (6) months preceding termination
⚠ Emergency / Post-Exposure
Employee develops signs or symptoms commonly associated with inorganic arsenic exposure
- Additional medical examination as appropriate
- Emergency medical treatment as appropriate
Reporting Requirements
| Who performs the evaluation | Licensed physician |
|---|---|
| Reported to employer | Written opinion containing: the results of the medical examination and tests; an opinion as to whether the employee has any detected medical condition that places the employee at increased risk of material impairment from arsenic exposure; any recommended limitations on the employee's arsenic exposure or use of protective clothing/equipment; and a statement that the employee was informed of the results and of any condition requiring further examination or treatment. The physician is instructed not to reveal in the written opinion specific findings or diagnoses unrelated to occupational arsenic exposure. |
| Reported to / for the employee | Employer provides a copy of the written opinion to the affected employee. |
| Time limits | No specific timeframe for furnishing the written opinion is stated in the standard. |
| Second-opinion / multi-physician review | No multiple-physician review mechanism specified in the arsenic standard. |
| Recordkeeping | Medical records maintained for at least 40 years, or for the duration of employment plus 20 years, whichever is longer, per 29 CFR 1910.1018(q)(2)(iv) as incorporated by 29 CFR 1926.1118. |
Shipyard / Maritime
Who is covered: Shipyard employment is covered, not excluded — 29 CFR 1915.1018 consists of a single provision stating that the requirements applicable to shipyard employment are identical to those set forth at 29 CFR 1910.1018. Medical surveillance is therefore required for: employees who are or will be exposed above the action level, without regard to respirator use, at least 30 days per year; and employees who have been exposed above the action level, without regard to respirator use, for 30 or more days per year for a total of 10 or more years of combined employment with the employer or predecessor employers. Additional examinations are required for any employee who develops signs or symptoms commonly associated with inorganic arsenic exposure. The incorporated standard applies to all occupational exposures to inorganic arsenic except employee exposures in agriculture or resulting from pesticide application, the treatment of wood with preservatives, or the utilization of arsenically preserved wood.
Evaluation performed by: Licensed physician — all medical examinations and procedures performed by or under the supervision of a licensed physician, provided without cost to the employee, without loss of pay, and at a reasonable time and place
🩺 Baseline / Pre-Placement
At the time of initial assignment to an area where the employee is likely to be exposed over the action level at least 30 days per year
- A work history and a medical history — including a smoking history and the presence and degree of respiratory symptoms such as breathlessness, cough, sputum production, and wheezing
- Standard film or digital posterior-anterior chest X-ray
- A nasal and skin examination
- Other examinations which the physician believes appropriate because of the employee's exposure to inorganic arsenic or because of required respirator use
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: At least annually (29 CFR 1910.1018(n)(3)(i), as incorporated by 29 CFR 1915.1018).
- A work history and a medical history — including a smoking history and the presence and degree of respiratory symptoms such as breathlessness, cough, sputum production, and wheezing
- Standard film or digital posterior-anterior chest X-ray
- A nasal and skin examination
- Other examinations which the physician believes appropriate because of the employee's exposure to inorganic arsenic or because of required respirator use
🚪 Exit / Termination
Upon termination of employment
- A work history and a medical history — including a smoking history and the presence and degree of respiratory symptoms such as breathlessness, cough, sputum production, and wheezing
- A nasal and skin examination
- Other examinations which the physician believes appropriate because of the employee's exposure to inorganic arsenic or because of required respirator use
- These examinations are required unless the covered employee has taken them within the six (6) months preceding the termination of employment
⚠ Emergency / Post-Exposure
Employee for any reason develops signs or symptoms commonly associated with exposure to inorganic arsenic
- An appropriate medical examination
- Emergency medical treatment
Reporting Requirements
| Who performs the evaluation | Licensed physician |
|---|---|
| Reported to employer | Written opinion containing: the results of the medical examination and tests performed; the physician's opinion as to whether the employee has any detected medical conditions which would place the employee at increased risk of material impairment of the employee's health from exposure to inorganic arsenic; any recommended limitations upon the employee's exposure to inorganic arsenic or upon the use of protective clothing or equipment such as respirators; and a statement that the employee has been informed by the physician of the results of the medical examination and any medical conditions which require further explanation or treatment. The employer must instruct the physician not to reveal in the written opinion specific findings or diagnoses unrelated to occupational exposure. |
| Reported to / for the employee | The employer provides a copy of the written opinion to the affected employee. |
| Time limits | No specific timeframe for furnishing the written opinion is stated in the standard. |
| Second-opinion / multi-physician review | No multiple-physician review mechanism is specified in the arsenic standard. |
| Recordkeeping | Medical records maintained for at least 40 years, or for the duration of employment plus 20 years, whichever is longer (29 CFR 1910.1018(q)(2)(iv), as incorporated by 29 CFR 1915.1018). The record must include the name and description of duties of the employee, a copy of the physician's written opinions, results of any exposure monitoring done for that employee and the representative exposure levels supplied to the physician, and any employee medical complaints related to exposure to inorganic arsenic. The employer must also keep, or assure that the examining physician keeps, a copy of the medical examination results including medical and work history, a description of laboratory procedures and any standards or guidelines used to interpret test results, the initial X-ray, the X-rays for the most recent 5 years, and any X-rays with a demonstrated abnormality and all subsequent X-rays. |