Federal OSHA · osha.gov
Other Organics & Carcinogens

4,4'-Methylenedianiline (MDA) Medical Surveillance

MDA is a hepatotoxin and probable carcinogen absorbed through skin; affects workers in epoxy/polyurethane manufacturing, coatings, and curing-agent handling.

Action Level5 ppb (8-hr TWA)
PEL10 ppb (8-hr TWA); STEL 100 ppb / 15 min

General Industry

Who is covered: Employees exposed at/above the AL on 30+ days/year; employees with dermal exposure on 15+ days/year; employees exposed in an emergency; employees reasonably believed (by visual monitoring) to have dermal exposure; and employees who show signs/symptoms of MDA exposure [1910.1050(m)(1)(i)]

Evaluation performed by: Licensed physician (examinations performed by or under the supervision of a licensed physician) [1910.1050(m)(1)(ii)]

🩺 Baseline / Pre-Placement

Within 150 days of the standard's effective date, or before the time of initial assignment [1910.1050(m)(2)(i)]

  • Detailed occupational and medical history [1910.1050(m)(2)(i)(A)]
  • Physical examination giving particular attention to the skin and to signs and symptoms of liver disease [1910.1050(m)(2)(i)(B)]
  • Liver function tests [1910.1050(m)(2)(i)(C)]
  • Urinalysis [1910.1050(m)(2)(i)(C)]
  • Additional tests the examining physician deems necessary [1910.1050(m)(2)(i)(D)]
🕒 Periodic / Routine

Interval-based while covered — NOT result-triggered

Schedule: At least annually for each covered employee [1910.1050(m)(3)(i)].

  • Brief update of the occupational and health history [1910.1050(m)(3)(i)(A)]
  • Liver function tests [1910.1050(m)(3)(i)(B)]
  • Skin examination [1910.1050(m)(3)(i)(B)]
  • Additional tests the examining physician deems necessary
⚠ Emergency / Post-Exposure

Emergency / hazardous exposure

  • Medical examination as soon as possible after the exposure [1910.1050(m)(4)]
  • Detailed history and physical examination emphasizing skin and liver
  • Liver function tests
  • Repeat liver function tests 2–3 weeks after the initial tests [1910.1050(m)(4)]
Abnormal results & exposure-event protocols

Abnormal Results & Exposure-Event Protocols

  • Employee develops signs or symptoms commonly associated with MDA exposure 1910.1050(m)(5): Provide an additional medical examination, including repeat liver function tests and other appropriate tests. Tests: Repeat liver function tests, Skin and liver-focused physical examination, Additional tests the physician deems necessary
  • Physician finds acute exposure signs OR abnormal liver function tests that could be worsened by continued MDA exposure 1910.1050(m)(9)(i)(A): Remove the employee from MDA exposure. Maintain earnings, seniority, and other rights/benefits (medical removal protection) for up to 6 months [(m)(9)(v)]. Return the employee when the signs resolve or the physician advises [(m)(9)(ii)(A)]. Tests: Liver function tests during removal to determine return eligibility

Reporting Requirements

Who performs the evaluationLicensed physician
Reported to employerWritten opinion containing occupationally pertinent results of the examination and tests; the physician's opinion as to whether the employee has any detected medical condition that places them at increased risk of material impairment from MDA exposure; any recommended limitations on MDA exposure or on PPE/respirator use; and a statement that the employee has been informed of the results and of any condition requiring further explanation or treatment [1910.1050(m)(8)(i)]. The opinion must NOT reveal specific findings or diagnoses unrelated to occupational exposure [1910.1050(m)(8)(ii)].
Reported to / for the employeeEmployer provides the employee with a copy of the written opinion; physician informs the employee of any MDA-related medical condition requiring further explanation or treatment.
Time limitsEmployer furnishes a copy of the written opinion to the employee within 15 days of its receipt [1910.1050(m)(8)(i)].
Second-opinion / multi-physician reviewStandard does not establish a formal multiple-physician review mechanism.
RecordkeepingMedical surveillance records maintained for the duration of employment plus 30 years [1910.1050(n)(4)(iv); 29 CFR 1910.1020].

Medical Removal Protection

Remove on acute exposure signs or abnormal LFTs that could worsen with continued exposure; MRP earnings/seniority/benefits maintained up to 6 months; return when signs resolve or the physician advises.

Construction

Who is covered: Same five triggers as general industry under construction-specific paragraph (n): AL 30+ days/year; dermal exposure 15+ days/year; emergency; reasonably believed dermal-exposed; signs/symptoms [1926.60(n)(1)(i)]

Evaluation performed by: Licensed physician (by or under the supervision of)

🩺 Baseline / Pre-Placement

Within 150 days of the standard's effective date, or before initial assignment [1926.60(n)(2)(i)]

  • Detailed occupational and medical history
  • Physical examination with particular attention to the skin and signs/symptoms of liver disease
  • Liver function tests
  • Urinalysis
  • Additional tests the physician deems necessary
🕒 Periodic / Routine

Interval-based while covered — NOT result-triggered

Schedule: At least annually [1926.60(n)(3)(i)].

  • Brief update of occupational/health history
  • Liver function tests
  • Skin examination
  • Additional tests the physician deems necessary
⚠ Emergency / Post-Exposure

Emergency / hazardous exposure

  • Medical examination as soon as possible after the exposure [1926.60(n)(4)]
  • History and physical examination emphasizing skin and liver
  • Liver function tests
  • Repeat liver function tests 2–3 weeks after the initial tests [1926.60(n)(4)]
Abnormal results & exposure-event protocols

Abnormal Results & Exposure-Event Protocols

  • Employee develops signs/symptoms associated with MDA exposure 1926.60(n)(5): Provide an additional medical examination including repeat liver function tests. Tests: Repeat liver function tests, Skin/liver-focused physical examination
  • Physician finds acute exposure signs OR abnormal LFTs that could worsen with continued exposure 1926.60(n)(9)(i)(A): Remove the employee from MDA exposure; maintain earnings/seniority/benefits (MRP) up to 6 months [(n)(9)(v)]; return when signs resolve or physician advises. Tests: Liver function tests during removal to determine return eligibility

Reporting Requirements

Who performs the evaluationLicensed physician
Reported to employerWritten opinion with occupationally pertinent results, increased-risk determination, recommended limitations, and a statement the employee was informed — must not reveal findings/diagnoses unrelated to occupational exposure [1926.60(n)(8)].
Reported to / for the employeeEmployer furnishes a copy of the written opinion to the employee.
Time limitsWithin 15 days of employer receipt [1926.60(n)(8)].
Second-opinion / multi-physician reviewMultiple-physician review: the employee may designate a second physician; if the second disagrees with the first, the two designate a third physician to resolve the disagreement [1926.60(n)(6)].
RecordkeepingMedical surveillance records maintained for the duration of employment plus 30 years (29 CFR 1910.1020).

Medical Removal Protection

Mirrors general industry — remove on acute signs or worsening abnormal LFTs; MRP up to 6 months; return when signs resolve.

How this compares to Cal/OSHA: Substantively aligned — Cal/OSHA 5200 mirrors federal 1910.1050 (same limits, dermal trigger, liver-function-test + urinalysis baseline, annual LFT + skin-exam periodic, 6-month MRP). The federal construction variant 1926.60 is equivalent under paragraph (n). (CA reporting time limits/retention marked unverified — not separately confirmed in 5200 text.)

Occu-Med handles 4,4'-Methylenedianiline (MDA) surveillance end-to-end

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