Federal OSHA · osha.gov
Other Organics & Carcinogens

Methylene Chloride Medical Surveillance

Methylene chloride (dichloromethane) is a probable carcinogen and metabolizes to carbon monoxide, stressing the cardiovascular and nervous systems; affects workers in paint stripping, degreasing, foam blowing, and solvent use.

Action Level12.5 ppm (8-hr TWA)
PEL25 ppm (8-hr TWA); STEL 125 ppm / 15 min
Who is covered: Employees exposed at/above the AL on 30+ days/year, OR above the PEL or STEL on 10+ days/year [(j)(1)(i)]; employees a physician identifies as having cardiac disease or another serious MC-related condition who request inclusion [(j)(1)(ii)]; employees exposed in emergencies [(j)(1)(iii)]

Evaluation performed by: Physician or other licensed health care professional (PLHCP) [1910.1052(j)(3)]

🩺 Baseline / Pre-Placement

Before initial assignment, or per the phase-in schedule in (n)(2)(iii), whichever is later [1910.1052(j)(4)]

  • Standardized medical questionnaire / work and medical history covering neurological symptoms, skin conditions, history of hematologic or liver disease, and cardiac risk factors [1910.1052(j)(5)(i)] (the standardized questionnaire content is set out in Appendix B)
  • Physical examination giving particular attention to the lungs, cardiovascular system (including blood pressure and pulse), liver, nervous system, and skin [1910.1052(j)(5)(ii)]
  • Laboratory studies at the PLHCP's discretion, which may include carboxyhemoglobin (COHb), electrocardiogram (ECG), hematocrit, liver function tests, and total cholesterol [1910.1052(j)(5)(iii)]
🕒 Periodic / Routine

Interval-based while covered — NOT result-triggered

Schedule: Age-stratified update of the medical/work history and physical examination: employees aged 45 or older every 12 months; employees under age 45 every 36 months [1910.1052(j)(4)]. Additional examinations at any frequency recommended in the PLHCP's written medical opinion [1910.1052(j)(4)(iv)].

  • Updated medical/work history (standardized questionnaire) — neurological symptoms, skin, hematologic/liver disease history, cardiac risk factors
  • Physical examination emphasizing lungs, cardiovascular system (BP/pulse), liver, nervous system, skin
  • Laboratory studies at PLHCP discretion — carboxyhemoglobin (COHb), ECG, hematocrit, liver function tests, total cholesterol
🚪 Exit / Termination

Termination of employment or reassignment out of MC exposure

  • Termination medical examination — provided if 6 or more months have elapsed since the last MC medical examination [1910.1052(j)(4)(iii)]
  • Updated medical/work history and physical examination (lungs, cardiovascular, liver, nervous system, skin)
⚠ Emergency / Post-Exposure

Emergency exposure

  • Decontamination [1910.1052(j)(6)]
  • Comprehensive medical examination emphasizing the nervous, cardiovascular, pulmonary, hepatic, and dermal systems
  • Updated medical/work history
  • Laboratory studies as indicated (e.g., carboxyhemoglobin / CO assessment given MC metabolism to carbon monoxide)
Abnormal results & exposure-event protocols

Abnormal Results & Exposure-Event Protocols

  • PLHCP recommends removal because continued MC exposure may contribute to or aggravate the employee's existing cardiac, hepatic, neurological (including stroke), or dermal disease 1910.1052(j)(11)(i): Transfer the employee to comparable work where MC exposure is at or below the action level, or remove the employee from MC exposure, as recommended. Tests: Follow-up examination at the frequency the PLHCP recommends to determine return eligibility
  • Employee removed or transferred under (j)(11) 1910.1052(j)(12)(i): Maintain the employee's earnings, seniority, and other benefits (medical removal protection) for up to 6 months or until the employee can return / is reassigned, whichever comes first.

Reporting Requirements

Who performs the evaluationPhysician or other licensed health care professional (PLHCP)
Reported to employerWritten medical opinion stating whether MC exposure may contribute to or aggravate the employee's existing cardiac, hepatic, neurological (including stroke), or dermal disease, and any recommended limitations on exposure (including removal) or on respirator/PPE use [1910.1052(j)(9)(i)(A)-(B)]. The employer must instruct the PLHCP NOT to reveal any specific records, findings, or diagnoses that have no bearing on occupational MC exposure [1910.1052(j)(9)(ii)].
Reported to / for the employeeEmployee must be informed that MC is a potential occupational carcinogen, of MC-related cardiac risk factors, and of the results of the examination and any medical conditions resulting from MC exposure [1910.1052(j)(9)(i)(C)-(D)].
Time limitsPLHCP provides the written opinion within 15 days of completing the evaluation, and in no case more than 30 days after the examination [1910.1052(j)(9)(i)].
Second-opinion / multi-physician reviewThree-tier multiple-health-care-professional review: employee notified of the right to a second opinion each time given a copy of the PLHCP opinion; if the employee disagrees within 15 days, the employer pays for a second PLHCP of the employee's choice; if disagreement persists, the two PLHCPs jointly designate a specialist whose written opinion is the definitive medical determination [1910.1052(j)(14)].
RecordkeepingMedical surveillance records maintained for the duration of employment plus 30 years [1910.1052(m)(3)(iii); 29 CFR 1910.1020].

Medical Removal Protection

Transfer to comparable work (≤ action level) or removal on PLHCP recommendation when MC may aggravate cardiac/hepatic/neurological/dermal disease; MRP earnings/seniority/benefits maintained up to 6 months; three-tier multiple-health-care-professional review available.

How this compares to Cal/OSHA: Substantively equivalent — California adopted the federal MC standard with identical limits, the same coverage triggers, the same age-stratified periodic schedule (≥45: 12 months / <45: 36 months), the same history/physical content, and the same removal/transfer MRP. (CA written-opinion timing and recordkeeping retention marked unverified — not separately confirmed in 5202 text.)

Occu-Med handles Methylene Chloride surveillance end-to-end

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