Federal OSHA · osha.gov
Heavy Metals

Inorganic Arsenic Medical Surveillance

Inorganic arsenic causes lung and skin cancer, dermatitis, and nasal/respiratory irritation; affects workers in smelting, glass manufacturing, pesticide production, and wood treatment.

Action Level5 µg/m³ (8-hr TWA)
PEL10 µg/m³ (8-hr TWA)

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 (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
🚪 Exit / Termination

At termination of employment

  • Required medical examination(s) — provided at termination if the employee has not had the required exams within the 6 months prior to 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 evaluationLicensed physician
Reported to employerWritten 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 employeeEmployer provides a copy of the written opinion to the affected employee.
Time limitsNo specific timeframe for furnishing the written opinion is stated in the standard.
Second-opinion / multi-physician reviewNo multiple-physician review mechanism specified in the arsenic standard.
RecordkeepingMedical records maintained for at least 40 years, or for the duration of employment plus 20 years, whichever is longer.

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
🚪 Exit / Termination

At termination of employment

  • Required medical examination(s) — provided at termination if the employee has not had the required exams within the 6 months prior to 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 evaluationLicensed physician
Reported to employerWritten 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 employeeEmployer provides a copy of the written opinion to the affected employee.
Time limitsNo specific timeframe for furnishing the written opinion is stated in the standard.
Second-opinion / multi-physician reviewNo multiple-physician review mechanism specified in the arsenic standard.
RecordkeepingMedical records maintained for at least 40 years, or for the duration of employment plus 20 years, whichever is longer.
How this compares to Cal/OSHA: Materially different on periodic surveillance and required tests. Federal (1910.1018 / 1926.1118) sets a single periodic frequency of 'at least annually' with NO age/tenure split and mandates only history, posterior-anterior chest X-ray, and nasal/skin exam — sputum cytology, CBC, and lymph-node exams are NOT required by the federal regulatory text. California 8 CCR 5214 imposes a two-tier periodic frequency (annual for age <45 AND <10 years; semi-annual for age ≥45 OR ≥10 years), a broader physical exam (skin, nose, respiratory tract, lymph nodes, nervous system, liver), and a mandatory sputum cytology examination at the initial exam and at each semi-annual (high-risk) exam. AL (5 µg/m³) and PEL (10 µg/m³) are identical; neither jurisdiction has automatic medical removal protection. California has no separate construction arsenic section.

Occu-Med handles Inorganic Arsenic surveillance end-to-end

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