Lead
Inorganic lead causes neurological, renal, hematologic, reproductive, and cardiovascular harm; affects general-industry and construction workers in smelting, battery manufacturing, painting/abatement, welding, and demolition.
Federal OSHA osha.gov
General Industry
| Action Level | 30 µg/m³ (8-hr TWA) |
|---|---|
| PEL | 50 µg/m³ (8-hr TWA) |
| Covered | Employees exposed at/above the AL for >30 days/year; also on request (reproductive counseling, intoxication symptoms, respirator-fit breathing difficulty) |
| Physician Type | Licensed physician (employer-selected; multiple-physician review available to employee) |
| Removal (MRP) | Mandatory removal at single BLL ≥60, or rolling average ≥50 (unless last <40); return at two consecutive BLLs <40; MRP wage/benefit protection up to 18 months. |
🩺 Baseline / Pre-Placement
Before first job assignment in a lead work area at/above the AL
- Detailed work + medical history (prior lead exposure; reproductive history; and GI, hematologic, neurologic, renal, cardiovascular, pulmonary status)
- Physical examination — emphasis on teeth/gums, hematologic, GI, renal, neurologic, cardiovascular, and pulmonary systems
- Blood pressure measurement
- blood lead level — Blood test measuring the amount of lead in your blood (BLL)
- zinc protoporphyrin — Blood test (ZPP) that flags lead's effect on red-blood-cell production
- Hemoglobin, hematocrit, red-cell indices, peripheral blood smear
- BUN and serum creatinine
- Routine urinalysis with microscopic examination
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: BLL + ZPP at least every 6 months while at/above the AL. Accelerated to at least every 2 months when BLL is at or above 40 µg/100 g, continuing until two consecutive BLLs are below 40 µg/100 g; at least monthly during the removal period (29 CFR 1910.1025(j)(2)(i)).
- blood lead level — Blood test measuring the amount of lead in your blood (BLL)
- zinc protoporphyrin — Blood test (ZPP) that flags lead's effect on red-blood-cell production
- Annual full medical exam — required whenever any BLL during the preceding 12 months was at or above 40 µg/100 g (29 CFR 1910.1025(j)(3)(i)(A)): repeat the full baseline history, physical examination, and lab panel
⚠ Emergency / Post-Exposure
As soon as possible upon employee notification of: signs or symptoms commonly associated with lead intoxication, a desire for medical advice about the effects of current or past lead exposure on the ability to procreate a healthy child, or difficulty in breathing during a respirator fitting test or during use (29 CFR 1910.1025(j)(3)(i)(C)); and as medically appropriate following medical removal or limitation (1910.1025(j)(3)(i)(D))
- Medical examination or consultation — content determined by the examining physician (29 CFR 1910.1025(j)(3)(ii))
- Pregnancy testing or laboratory evaluation of male fertility — required if requested by the employee (29 CFR 1910.1025(j)(3)(ii))
Abnormal Results & Exposure-Event Protocols
- Most recent BLL ≥40 µg/dL 1910.1025(j)(2)(i)(B): Accelerate periodic biological monitoring to BLL every 2 months; continue until two consecutive BLLs are <40 µg/dL. Tests: Blood lead level (BLL), Zinc protoporphyrin (ZPP)
- BLL ≥60 µg/dL on a single sampling 1910.1025(j)(3)(ii): Provide a follow-up (confirmatory) blood sampling within 2 weeks of the employer receiving the result. Tests: Confirmatory blood lead level (BLL)
- Single BLL ≥60 µg/dL, OR average of the last three BLLs (or all in the prior 6 months) ≥50 µg/dL — unless the last BLL is <40 1910.1025(k) — Medical Removal Protection: Remove the employee from lead exposure. Maintain wage/benefit (MRP) protection up to 18 months. Return when two consecutive BLLs ≥7 days apart are both <40 µg/dL. Tests: Periodic BLL during removal to determine return eligibility
Reporting Requirements
| Who performs the evaluation | Licensed physician |
|---|---|
| Reported to employer | Written medical opinion limited to: any detected condition that increases risk from lead exposure, recommended exposure/respirator limitations, results of the exam and tests, and a statement that the employee was informed of medical-removal results. Must NOT reveal unrelated findings. |
| Reported to / for the employee | Blood lead level: employee notified in writing within 5 working days after receipt of biological monitoring results showing a blood lead level at or above 40 µg/100 g (1910.1025(j)(2)(iv)); employer furnishes the employee a copy of the physician's written medical opinion (no specific deadline stated). |
| Time limits | Blood lead level results: employer notifies in writing within 5 working days after receipt of biological monitoring results for any employee with BLL at or above 40 µg/100 g (29 CFR 1910.1025(j)(2)(iv)). Written medical opinion: no specific deadline stated in the standard for furnishing a copy to the employee. |
| Second-opinion / multi-physician review | Multiple-physician review: employee may designate a second physician; if opinions differ, a third (jointly designated) physician resolves. |
| Recordkeeping | Medical surveillance records retained for at least 40 years, or for the duration of employment plus 20 years, whichever is longer (29 CFR 1910.1025(n)(2)(iv)). |
Construction
| Action Level | 30 µg/m³ (8-hr TWA) |
|---|---|
| PEL | 50 µg/m³ (8-hr TWA) |
| Covered | Initial surveillance when exposed on any day at/above the AL; full program when exposed above the AL for >30 days in any consecutive 12-month period |
| Physician Type | Licensed physician (employer-selected; multiple-physician review available to employee) |
| Removal (MRP) | Mandatory removal at single BLL ≥50 (confirmed within 2 weeks); return at two consecutive BLLs <40; up to 18 months MRP benefits. Construction lacks the GI rolling-average trigger. |
🩺 Baseline / Pre-Placement
Before or at the start of a job with exposure at/above the AL
- Detailed work + medical history (prior lead exposure; reproductive history; GI, hematologic, neurologic, renal, cardiovascular, pulmonary status)
- Physical examination — emphasis on teeth/gums, hematologic, GI, renal, neurologic, cardiovascular, pulmonary systems
- Blood pressure measurement
- blood lead level — Blood test measuring the amount of lead in your blood (BLL)
- zinc protoporphyrin — Blood test (ZPP) that flags lead's effect on red-blood-cell production
- Hemoglobin, hematocrit, red-cell indices, peripheral blood smear
- BUN and serum creatinine
- Routine urinalysis with microscopic examination
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: For employees in the full program (exposed >30 days/12 months): BLL + ZPP at least every 2 months for the first 6 months of the program, then at least every 6 months thereafter. Accelerated to at least every 2 months whenever any BLL is at or above 40 µg/dl, continuing until two consecutive BLLs are below 40 µg/dl. At least monthly during the removal period (29 CFR 1926.62(j)(2)(i)(A)-(C)).
- blood lead level — Blood test measuring the amount of lead in your blood (BLL)
- zinc protoporphyrin — Blood test (ZPP) that flags lead's effect on red-blood-cell production
- Annual full medical exam — required whenever any BLL during the preceding 12 months was at or above 40 µg/dl (29 CFR 1926.62(j)(3)(i)(A)): repeat the full baseline history, physical examination, and lab panel
⚠ Emergency / Post-Exposure
As soon as possible upon employee notification of: signs or symptoms commonly associated with lead intoxication, a desire for medical advice about the effects of current or past lead exposure on the ability to procreate a healthy child, pregnancy, or difficulty in breathing during a respirator fitting test or during use (29 CFR 1926.62(j)(3)(i)(B)); and as medically appropriate following medical removal or limitation (1926.62(j)(3)(i)(C))
- Medical examination or consultation — content determined by the examining physician (29 CFR 1926.62(j)(3)(ii))
- Pregnancy testing or laboratory evaluation of male fertility — required if requested by the employee (29 CFR 1926.62(j)(3)(ii))
Abnormal Results & Exposure-Event Protocols
- Most recent BLL ≥40 µg/dL 1926.62(j)(2)(iii): Accelerate periodic biological monitoring to BLL every 2 months; continue until two consecutive BLLs are <40 µg/dL. Tests: Blood lead level (BLL), Zinc protoporphyrin (ZPP)
- Single BLL ≥50 µg/dL (confirmed by a second sampling within 2 weeks) 1926.62(k) — Medical Removal Protection: Remove the employee from lead exposure (construction has no GI rolling-average trigger). Maintain wage/benefit (MRP) protection up to 18 months. Return when two consecutive BLLs are both <40 µg/dL. Tests: Confirmatory BLL within 2 weeks, Periodic BLL during removal to determine return eligibility
Reporting Requirements
| Who performs the evaluation | Licensed physician |
|---|---|
| Reported to employer | Written medical opinion limited to: condition increasing risk from lead, recommended limitations, exam/test results, and a statement that the employee was informed of removal results. Must NOT reveal unrelated findings. |
| Reported to / for the employee | Employer provides a copy of the written opinion to the employee; employee informed of any condition needing further evaluation. |
| Time limits | Blood lead level results: employer notifies each employee in writing within 5 working days after receipt of biological (blood-lead) monitoring results, regardless of level (29 CFR 1926.62(j)(2)(iv)(A)); employees with a blood lead level at or above 40 µg/dl are additionally notified that the standard requires temporary medical removal with Medical Removal Protection benefits (1926.62(j)(2)(iv)(B)). Written medical opinion: no specific deadline stated in 1926.62(j)(3)(v)(A) for furnishing a copy to the employee. (The separate 5-working-day air-monitoring notice under 1926.62(d)(8)(i) is exposure monitoring, not medical surveillance.) |
| Second-opinion / multi-physician review | Multiple-physician review available to the employee (second and, if needed, jointly-designated third physician). |
| Recordkeeping | Medical surveillance records maintained in accordance with 29 CFR 1910.33 as referenced in 1926.62(n)(2)(iv). The construction lead standard does not specify its own numeric retention period. |
Shipyard / Maritime
| Action Level | 30 µg/m³ (8-hr TWA) |
|---|---|
| PEL | 50 µg/m³ (8-hr TWA) |
| Covered | Shipyard employment — 29 CFR 1915.1025 applies the 1910.1025 general-industry requirements verbatim. Employees exposed at/above the AL for >30 days/year; also on request (reproductive counseling, intoxication symptoms, respirator-fit breathing difficulty) |
| Physician Type | Licensed physician (employer-selected; multiple-physician review available to employee) |
| Removal (MRP) | Mandatory removal at single BLL ≥60, or rolling average ≥50 (unless last <40); return at two consecutive BLLs <40; MRP wage/benefit protection up to 18 months. |
🩺 Baseline / Pre-Placement
Before first job assignment in a lead work area at/above the AL
- Detailed work + medical history (prior lead exposure; reproductive history; and GI, hematologic, neurologic, renal, cardiovascular, pulmonary status)
- Physical examination — emphasis on teeth/gums, hematologic, GI, renal, neurologic, cardiovascular, and pulmonary systems
- Blood pressure measurement
- blood lead level — Blood test measuring the amount of lead in your blood (BLL)
- zinc protoporphyrin — Blood test (ZPP) that flags lead's effect on red-blood-cell production
- Hemoglobin, hematocrit, red-cell indices, peripheral blood smear
- BUN and serum creatinine
- Routine urinalysis with microscopic examination
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: BLL + ZPP at least every 6 months while at/above the AL. Accelerated to at least every 2 months when BLL is at or above 40 µg/100 g, continuing until two consecutive BLLs are below 40 µg/100 g; at least monthly during the removal period (29 CFR 1910.1025(j)(2)(i)).
- blood lead level — Blood test measuring the amount of lead in your blood (BLL)
- zinc protoporphyrin — Blood test (ZPP) that flags lead's effect on red-blood-cell production
- Annual full medical exam — required whenever any BLL during the preceding 12 months was at or above 40 µg/100 g (29 CFR 1910.1025(j)(3)(i)(A)): repeat the full baseline history, physical examination, and lab panel
⚠ Emergency / Post-Exposure
As soon as possible upon employee notification of: signs or symptoms commonly associated with lead intoxication, a desire for medical advice about the effects of current or past lead exposure on the ability to procreate a healthy child, or difficulty in breathing during a respirator fitting test or during use (29 CFR 1910.1025(j)(3)(i)(C)); and as medically appropriate following medical removal or limitation (1910.1025(j)(3)(i)(D))
- Medical examination or consultation — content determined by the examining physician (29 CFR 1910.1025(j)(3)(ii))
- Pregnancy testing or laboratory evaluation of male fertility — required if requested by the employee (29 CFR 1910.1025(j)(3)(ii))
Abnormal Results & Exposure-Event Protocols
- Most recent BLL ≥40 µg/dL 1910.1025(j)(2)(i)(B): Accelerate periodic biological monitoring to BLL every 2 months; continue until two consecutive BLLs are <40 µg/dL. Tests: Blood lead level (BLL), Zinc protoporphyrin (ZPP)
- BLL ≥60 µg/dL on a single sampling 1910.1025(j)(3)(ii): Provide a follow-up (confirmatory) blood sampling within 2 weeks of the employer receiving the result. Tests: Confirmatory blood lead level (BLL)
- Single BLL ≥60 µg/dL, OR average of the last three BLLs (or all in the prior 6 months) ≥50 µg/dL — unless the last BLL is <40 1910.1025(k) — Medical Removal Protection: Remove the employee from lead exposure. Maintain wage/benefit (MRP) protection up to 18 months. Return when two consecutive BLLs ≥7 days apart are both <40 µg/dL. Tests: Periodic BLL during removal to determine return eligibility
Reporting Requirements
| Who performs the evaluation | Licensed physician |
|---|---|
| Reported to employer | Written medical opinion limited to: any detected condition that increases risk from lead exposure, recommended exposure/respirator limitations, results of the exam and tests, and a statement that the employee was informed of medical-removal results. Must NOT reveal unrelated findings. |
| Reported to / for the employee | Blood lead level: employee notified in writing within 5 working days after receipt of biological monitoring results showing a blood lead level at or above 40 µg/100 g (1910.1025(j)(2)(iv)); employer furnishes the employee a copy of the physician's written medical opinion (no specific deadline stated). |
| Time limits | Blood lead level results: employer notifies in writing within 5 working days after receipt of biological monitoring results for any employee with BLL at or above 40 µg/100 g (29 CFR 1910.1025(j)(2)(iv)). Written medical opinion: no specific deadline stated in the standard for furnishing a copy to the employee. |
| Second-opinion / multi-physician review | Multiple-physician review: employee may designate a second physician; if opinions differ, a third (jointly designated) physician resolves. |
| Recordkeeping | Medical surveillance records retained for at least 40 years, or for the duration of employment plus 20 years, whichever is longer (29 CFR 1910.1025(n)(2)(iv)). |
Cal/OSHA dir.ca.gov
General Industry
| Action Level | 2 µg/m³ (8-hr TWA) |
|---|---|
| PEL | 10 µg/m³ (8-hr TWA) |
| Covered | Employees exposed at or above the action level. Two exemptions: (1) employees not exposed at or above the action level for 30 or more days in any 12 consecutive months AND not exposed on any day above 10 µg/m³ as an 8-hour TWA; (2) employees not exposed at or above the action level for 15 or more days in any 12 consecutive months AND not exposed on any day above 20 µg/m³ as an 8-hour TWA (8 CCR 5198(j)(1)). |
| Physician Type | Licensed physician (employer-selected; multiple-physician review available to employee) |
| Removal (MRP) | Removal at single BLL ≥30 µg/dl; (eff. Jan 1, 2026) two consecutive tests both ≥20, or 6-month average ≥20 unless last test <15; return at two consecutive tests ≥30 days apart both <15 µg/dl; up to 18 months benefits. |
🩺 Baseline / Pre-Placement
Prior to assignment, or when work first becomes covered — unless a BLL was tested within the prior 2 months
- Detailed work + medical history (prior lead exposure; reproductive history; GI, hematologic, neurologic, renal, cardiovascular status)
- Physical examination — emphasis on teeth/gums, hematologic, GI, renal, neurologic, and cardiovascular systems; pulmonary status evaluated if respiratory protection will be used (5198(j)(3)(B)2)
- Blood pressure measurement
- blood lead level — Blood test measuring the amount of lead in your blood (BLL)
- zinc protoporphyrin (required when the employee's last BLL was ≥20 µg/dl (5198(j)(3)(B)4.c)) — Blood test (ZPP) that flags lead's effect on red-blood-cell production
- Hemoglobin, hematocrit, red-cell indices, peripheral blood smear
- BUN and serum creatinine
- Routine urinalysis with microscopic examination
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: BLL at least every 2 months for the first 6 months, then at least every 6 months (the 2-month cycle restarts after a change in work task or process likely to increase lead exposure). Accelerated: at least every 2 months while the last BLL is 10–19 µg/dl, until two consecutive results taken at least 30 days apart are below 10 µg/dl; at least monthly while the last BLL is ≥20 µg/dl and during any medical-removal period (8 CCR 5198(j)(2)(A)1-5).
- blood lead level — Blood test measuring the amount of lead in your blood (BLL)
- zinc protoporphyrin (with each medical exam when the last BLL was ≥20 µg/dl (8 CCR 5198(j)(3)(B)4.c)) — Blood test (ZPP) that flags lead's effect on red-blood-cell production
- Annual full medical exam (when triggered): as soon as possible after any BLL ≥20 µg/dl if no lead-specific exam was done in the preceding 12 months, then at least annually until the BLL is below 20 µg/dl (8 CCR 5198(j)(3)(A)1) — repeats the full baseline history, physical examination, and lab panel
⚠ Emergency / Post-Exposure
As soon as possible upon employee notification of: signs or symptoms commonly associated with lead intoxication, a desire for medical advice about the effects of current or past lead exposure on the ability to procreate a healthy child, or difficulty in breathing during a respirator fit test or during use (8 CCR 5198(j)(3)(A)3); and as soon as possible, then as medically appropriate, following medical removal (5198(j)(3)(A)4)
- Detailed work + medical history (prior lead exposure; reproductive history; GI, hematologic, neurologic, renal, cardiovascular status)
- Physical examination — emphasis on teeth/gums, hematologic, GI, renal, neurologic, and cardiovascular systems; pulmonary status evaluated if respiratory protection will be used (5198(j)(3)(B)2)
- Blood pressure measurement
- blood lead level — Blood test measuring the amount of lead in your blood (BLL)
- zinc protoporphyrin (required when the employee's last BLL was ≥20 µg/dl (5198(j)(3)(B)4.c)) — Blood test (ZPP) that flags lead's effect on red-blood-cell production
- Hemoglobin, hematocrit, red-cell indices, peripheral blood smear
- BUN and serum creatinine
- Routine urinalysis with microscopic examination
- Pregnancy testing or laboratory evaluation of male fertility — required if requested by the employee (5198(j)(3)(B)2)
Abnormal Results & Exposure-Event Protocols
- BLL ≥10 µg/dl 8 CCR 5198(j)(2)(E): Employer establishes and implements a written elevated blood lead level response plan describing the specific means used to reduce and maintain the employee's BLL below 10 µg/dl, and provides training and instruction as needed to correct work practices identified in the plan. Exception: not required when a BLL ≥10 µg/dl is detected only in the employee's blood lead test done prior to their first assignment to covered work.
- BLL 10–19 µg/dl 8 CCR 5198(j)(2)(A)4: BLL at least every 2 months until two consecutive results, taken at least 30 days apart, are below 10 µg/dl. Tests: Blood lead level (BLL)
- BLL ≥20 µg/dl 8 CCR 5198(j)(2)(A)5; (j)(3)(A)1: BLL at least monthly (and at least monthly during any medical-removal period). Medical examination as soon as possible if none was done in the preceding 12 months, then at least annually until the BLL is below 20 µg/dl; exams include ZPP while the last BLL is ≥20 µg/dl. Tests: Blood lead level (BLL), ZPP (exam element), Full medical examination
- Single BLL ≥30 µg/dl (eff. Jan 1, 2026 also: two consecutive tests ≥20, or 6-month average ≥20 unless last <15) 8 CCR 5198(k)(1); (k)(3)(A): Remove from exposure; MRP wage/benefit protection up to 18 months. Return at two tests ≥30 days apart both <15 µg/dl. Tests: Periodic BLL during removal to determine return eligibility
Reporting Requirements
| Who performs the evaluation | Licensed physician |
|---|---|
| Reported to employer | Written medical opinion limited to fitness, recommended limitations, and removal/return recommendations; must not disclose unrelated findings. |
| Reported to / for the employee | Employee informed of exam results and of any condition needing further evaluation; furnished a copy of the written opinion. |
| Elevated blood lead level response | Whenever an employee's blood lead level is at or above 10 µg/dl, the employer must establish and implement a written elevated blood lead level response plan describing the specific means that will be used to reduce and maintain that employee's BLL below 10 µg/dl, and provide training and instruction as needed to correct any work practices identified in the plan (8 CCR 5198(j)(2)(E)). Exception: not required when a BLL at or above 10 µg/dl is detected only in the employee's blood lead test done prior to their first assignment to covered work. |
| Time limits | Blood lead level results: employer notifies in writing within 5 working days after receipt of blood lead test results for every employee, regardless of level (8 CCR 5198(j)(2)(C)). Written medical report: the examining PLHCP explains the results and provides each employee a written medical report within 30 days of each medical examination (8 CCR 5198(j)(5)). The 15-day figure in 5198 is the employee's window to initiate a second-physician opinion (8 CCR 5198(j)(3)(C)2), not a medical-surveillance notification deadline; the 15-day air/exposure monitoring figure is exposure monitoring, not medical surveillance. |
| Second-opinion / multi-physician review | Multiple-physician review available to the employee. |
| Recordkeeping | Medical records retained for the duration of employment plus 40 years (8 CCR 3204). |
Construction
| Action Level | 2 µg/m³ (8-hr TWA) |
|---|---|
| PEL | 10 µg/m³ (8-hr TWA); abrasive blasting capped at 25 µg/m³ until Jan 1, 2030 |
| Covered | Employees exposed at/above the AL or performing defined lead trigger tasks (limited exceptions for ≤30 days/yr at ≤10 µg/m³) |
| Physician Type | Licensed physician (employer-selected; multiple-physician review available to employee) |
| Removal (MRP) | Removal at BLL ≥30 µg/dl (eff. Jan 1, 2026 also: last two tests ≥20, or 6-month average ≥20); return at two tests ≥30 days apart both <15 µg/dl; up to 18 months benefits. |
🩺 Baseline / Pre-Placement
Before assignment or before trigger-task work — unless a BLL was tested within the prior 2 months
- Detailed work + medical history (prior lead exposure; reproductive history; GI, hematologic, neurologic, renal, cardiovascular status)
- Physical examination — emphasis on teeth/gums, hematologic, GI, renal, neurologic, and cardiovascular systems; pulmonary status evaluated if respiratory protection will be used (1532.1(j)(3)(B)2)
- Blood pressure measurement
- blood lead level — Blood test measuring the amount of lead in your blood (BLL)
- zinc protoporphyrin (required when the employee's last BLL was ≥20 µg/dl (1532.1(j)(3)(B)4.c)) — Blood test (ZPP) that flags lead's effect on red-blood-cell production
- Hemoglobin, hematocrit, red-cell indices, peripheral blood smear
- BUN and serum creatinine
- Routine urinalysis with microscopic examination
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: BLL at least every 2 months for the first 6 months after initial placement, then at least every 6 months (the 2-month cycle restarts after a change in task likely to increase lead exposure). Accelerated: at least every 2 months while the last BLL is 10–19 µg/dl, until two consecutive results taken at least 30 days apart are below 10 µg/dl; at least monthly while the last BLL is ≥20 µg/dl, during any medical-removal period, while performing level 3 trigger tasks, and while airborne exposure is above 500 µg/m³ as an 8-hour TWA (8 CCR 1532.1(j)(2)(A)1-6).
- blood lead level — Blood test measuring the amount of lead in your blood (BLL)
- zinc protoporphyrin (with each medical exam when the last BLL was ≥20 µg/dl (8 CCR 1532.1(j)(3)(B)4.c)) — Blood test (ZPP) that flags lead's effect on red-blood-cell production
- Annual full medical exam (when triggered): as soon as possible after any BLL ≥20 µg/dl if no lead-specific exam was done in the preceding 12 months, then at least annually until the BLL is below 20 µg/dl (8 CCR 1532.1(j)(3)(A)1) — repeats the full baseline history, physical examination, and lab panel
⚠ Emergency / Post-Exposure
As soon as possible upon employee notification of: signs or symptoms commonly associated with lead intoxication, a desire for medical advice about the effects of current or past lead exposure on the ability to procreate a healthy child, pregnancy, or difficulty in breathing during a respirator fit test or during use (8 CCR 1532.1(j)(3)(A)3); and as soon as possible, then as medically appropriate, following medical removal (1532.1(j)(3)(A)4)
- Detailed work + medical history (prior lead exposure; reproductive history; GI, hematologic, neurologic, renal, cardiovascular status)
- Physical examination — emphasis on teeth/gums, hematologic, GI, renal, neurologic, and cardiovascular systems; pulmonary status evaluated if respiratory protection will be used (1532.1(j)(3)(B)2)
- Blood pressure measurement
- blood lead level — Blood test measuring the amount of lead in your blood (BLL)
- zinc protoporphyrin (required when the employee's last BLL was ≥20 µg/dl (1532.1(j)(3)(B)4.c)) — Blood test (ZPP) that flags lead's effect on red-blood-cell production
- Hemoglobin, hematocrit, red-cell indices, peripheral blood smear
- BUN and serum creatinine
- Routine urinalysis with microscopic examination
- Pregnancy testing or laboratory evaluation of male fertility — required if requested by the employee (1532.1(j)(3)(B)2)
Abnormal Results & Exposure-Event Protocols
- BLL ≥10 µg/dl 8 CCR 1532.1(j)(2)(E): Employer establishes and implements a written elevated blood lead level response plan describing the specific means used to reduce and maintain the employee's BLL below 10 µg/dl, and provides training and instruction as needed to correct work practices identified in the plan. Exception: not required when a BLL ≥10 µg/dl is detected only in the employee's initial blood lead testing.
- BLL 10–19 µg/dl 8 CCR 1532.1(j)(2)(A)3: BLL at least every 2 months until two consecutive results, taken at least 30 days apart, are below 10 µg/dl. Tests: Blood lead level (BLL)
- BLL ≥20 µg/dl 8 CCR 1532.1(j)(2)(A)4; (j)(3)(A)1: BLL at least monthly (and at least monthly during any medical-removal period). Medical examination as soon as possible if none was done in the preceding 12 months, then at least annually until the BLL is below 20 µg/dl; exams include ZPP while the last BLL is ≥20 µg/dl. Tests: Blood lead level (BLL), ZPP (exam element), Full medical examination
- Level 3 trigger task work, or airborne exposure above 500 µg/m³ as an 8-hour TWA (without regard to respirator use) 8 CCR 1532.1(j)(2)(A)5-6: BLL at least monthly while the condition continues, plus a blood test taken within 3 days after discontinuing all such work. Tests: Blood lead level (BLL)
- Single BLL ≥30 µg/dl (eff. Jan 1, 2026 also: last two tests ≥20, or 6-month average ≥20 unless last <15) 8 CCR 1532.1(k)(1)(A); (k)(1)(C): Remove from exposure; MRP wage/benefit protection up to 18 months. Return at two tests ≥30 days apart both <15 µg/dl. Tests: Periodic BLL during removal to determine return eligibility
Reporting Requirements
| Who performs the evaluation | Licensed physician |
|---|---|
| Reported to employer | Written medical opinion limited to fitness, recommended limitations, and removal/return recommendations; must not disclose unrelated findings. |
| Reported to / for the employee | Employee informed of exam results and of any condition needing further evaluation; furnished a copy of the written opinion. |
| Elevated blood lead level response | Whenever an employee's blood lead level is at or above 10 µg/dl, the employer must establish and implement a written elevated blood lead level response plan describing the specific means that will be used to reduce and maintain that employee's BLL below 10 µg/dl, and provide training and instruction as needed to correct any work practices identified in the plan (8 CCR 1532.1(j)(2)(E)). Exception: not required when a BLL at or above 10 µg/dl is detected only in the employee's initial blood lead testing. |
| Time limits | Blood lead level results: employer notifies each employee in writing within 5 working days after receipt of blood lead test results, regardless of level (8 CCR 1532.1(j)(2)(C)). Written medical report: the examining PLHCP explains the results and provides each employee a written medical report within 30 days of each medical examination (8 CCR 1532.1(j)(3)(E)). The 15-day figure in 1532.1 is the employee's window to initiate a second-physician opinion (8 CCR 1532.1(j)(3)(C)2), not a medical-surveillance notification deadline; air/exposure monitoring notification is exposure monitoring, not medical surveillance. |
| Second-opinion / multi-physician review | Multiple-physician review available to the employee. |
| Recordkeeping | Medical records retained for the duration of employment plus 40 years (8 CCR 3204). |
Federal vs. California: California's 2025 revision slashed the AL to 2 µg/m³ and PEL to 10 µg/m³ (vs federal 30/50) and lowered the MRP removal/return thresholds dramatically (removal at BLL ≥30 vs federal 50–60) — far more protective than federal. California also adds tiered accelerated-monitoring triggers (10–19, ≥20) and a written elevated-BLL response plan. Shipyards: federal lead in shipyard employment is covered by 29 CFR 1915.1025, which applies the 1910.1025 general-industry requirements verbatim; California has no separate shipyard lead section (Title 8 Subchapter 18, Article 4 contains asbestos, chromium (VI), and beryllium sections only) — 8 CCR 5198 covers shipyard lead work.
Cadmium
Cadmium causes renal tubular damage, lung cancer, and respiratory disease; affects workers in smelting, battery manufacturing, plating, welding/brazing cadmium-coated steel, and demolition.
Federal OSHA osha.gov
General Industry
| Action Level | 2.5 µg/m³ (8-hr TWA) |
|---|---|
| PEL | 5 µg/m³ (8-hr TWA) |
| Covered | Employees exposed at/above the AL unless exposure occurs fewer than 30 days/year over 12 consecutive months; previously-exposed employees (pre-effective-date exposure at/above AL) unless fewer than 60 aggregated months in cadmium work |
| Physician Type | Licensed physician (familiar with App A health effects, App F sampling protocol, and App D questionnaire; employer-selected, multiple-physician review available to employee) |
| Removal (MRP) | Mandatory removal at post-1999 confirmed CdU >7 / CdB >10 / β₂-M >750 (with concurrent CdU >3 or CdB >5); return at CdU ≤3 AND CdB ≤5 AND β₂-M ≤300; MRP wage/benefit protection up to 18 months; quarterly biomonitoring and semiannual exams during removal. |
🩺 Baseline / Pre-Placement
Initial exam within 30 days of initial assignment (or 90 days after the standard's effective date, whichever is later); not required if an adequate exam was performed in the preceding 12 months
- Detailed medical + work history — emphasis on past, present, and anticipated cadmium exposure; renal, cardiovascular, respiratory, hematopoietic, reproductive, and musculo-skeletal dysfunction; current medications with nephrotoxic side-effects; smoking history and status
- Biological monitoring: Cadmium in urine (CdU), standardized to g creatinine (µg/g Cr)
- Biological monitoring: Beta-2-microglobulin in urine (β₂-M), standardized to µg/g Cr (pH specified)
- Biological monitoring: Cadmium in blood (CdB), standardized to liters whole blood (µg/lwb)
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: Biological monitoring (CdU, β2-M, CdB) at least annually. Full medical examination within 1 year after the initial examination, then at least biennially thereafter (29 CFR 1910.1027(l)(4)(i)).
- Biological monitoring at least annually: Cadmium in urine (CdU), standardized to g creatinine (µg/g Cr)
- Biological monitoring at least annually: Beta-2-microglobulin in urine (β₂-M), standardized to µg/g Cr (pH specified)
- Biological monitoring at least annually: Cadmium in blood (CdB), standardized to liters whole blood (µg/lwb)
- Biennial full exam — updated medical + work history (App D respirator questions 3-11 and 25-32 for respirator wearers)
- Biennial full exam — complete physical examination with emphasis on blood pressure, the respiratory system, and the urinary system
- Biennial full exam — posterior-anterior chest X-ray (14×17-inch or equivalent standard film/digital; subsequent frequency per examining physician)
- Biennial full exam — pulmonary function tests: forced vital capacity (FVC) and forced expiratory volume in 1 second (FEV₁)
- Biennial full exam — blood: blood urea nitrogen (BUN), complete blood count (CBC), serum creatinine
- Biennial full exam — urinalysis: albumin, glucose, and total and low-molecular-weight proteins
- Biennial full exam — prostate palpation (males over 40), or other at least as effective diagnostic test
- Any additional tests deemed appropriate by the examining physician
🚪 Exit / Termination
At termination of employment for employees under medical surveillance
- Termination medical examination including chest X-ray — required unless a qualifying periodic exam was completed within the preceding 6 months
- Biological monitoring: CdU, β₂-M, CdB
⚠ Emergency / Post-Exposure
As soon as possible following an acute cadmium exposure
- Full periodic-exam content with emphasis on the respiratory system, other organ systems the physician deems appropriate, and symptoms of acute overexposure
- Biological monitoring: CdU, β₂-M, CdB
Abnormal Results & Exposure-Event Protocols
- Initial biological result CdU >3 µg/g Cr, OR β₂-M >300 µg/g Cr, OR CdB >5 µg/lwb Elevated biomonitoring response: Within 2 weeks reassess occupational exposure (work practices, respirator use, hygiene, engineering controls, smoking); within 30 days correct deficiencies; within 90 days provide a full medical examination. If not removed, continue semiannual biological monitoring and annual full exams until CdU ≤3, β₂-M ≤300, and CdB ≤5. Tests: Repeat biological monitoring: CdU, β₂-M, CdB, Full medical examination within 90 days
- Mandatory removal when both the initial and confirmatory biological results show CdU >7 µg/g Cr, OR CdB >10 µg/lwb, OR β₂-M >750 µg/g Cr — AND concurrently CdU >3 or CdB >5. Pre-1999 absolute triggers (CdU >15, CdB >15, or β₂-M >1,500 with concurrent CdU >3 or CdB >5) also apply. Medical Removal Protection — post-1999 trigger levels (in force): Remove the employee from work where exposure is at/above the action level (or above the PEL if the basis is inability to wear a respirator). During removal, provide follow-up biological monitoring at least every 3 months and follow-up medical examinations at least every 6 months. Maintain MRP wage/benefit protection up to 18 months. Tests: Quarterly biological monitoring during removal: CdU, β₂-M, CdB, Semiannual follow-up medical examination during removal
- Employee removed under the MRP trigger levels Return to work / 18-month final determination: Return permitted only when CdU falls to ≤3 µg/g Cr AND CdB ≤5 µg/lwb AND β₂-M ≤300 µg/g Cr (physician may override with special-circumstances finding of no increased risk). After 18 months of unresolved removal, a final medical determination exam decides return-to-former-status vs. permanent removal. Tests: Confirmatory biological monitoring (CdU, CdB, β₂-M) to establish return eligibility
Reporting Requirements
| Who performs the evaluation | Licensed physician (familiar with App A, App D, App F) |
|---|---|
| Reported to employer | Prompt written medical opinion containing: the physician's diagnosis; whether the employee has a detected condition increasing risk of material impairment from cadmium (including potential cadmium toxicity); results of biological/other tests assessing cadmium absorption; any recommended removal or limitation on duties/PPE; and a statement that the physician explained the results (including all biomonitoring and any condition needing further evaluation, plus diet/medication limits) to the employee. Physician instructed NOT to reveal findings/diagnoses unrelated to cadmium. |
| Reported to / for the employee | Employer furnishes a copy of the physician's written medical opinion to the examined employee within two weeks after receipt thereof (29 CFR 1910.1027(l)(15)(i)). Biological monitoring results and an explanation sheet (plain-language explanation per Appendix D) furnished to the employee within two weeks after receipt thereof. |
| Time limits | Written opinion and biomonitoring explanation furnished to the employee within 2 weeks of employer receipt; employee must initiate second-physician review within 15 days of notice. |
| Second-opinion / multi-physician review | Multiple-physician review: employer must notify the employee of the right to a second opinion after each employer-arranged exam; employee designates a second physician; unresolved disagreements go to a jointly-designated third physician whose findings control. |
| Recordkeeping | Medical surveillance records retained for the duration of employment plus 30 years (29 CFR 1910.1020). |
Construction
| Action Level | 2.5 µg/m³ (8-hr TWA) |
|---|---|
| PEL | 5 µg/m³ (8-hr TWA) |
| Covered | Same coverage as GI 1910.1027; scope covers demolition, cutting/brazing cadmium-plated steel, cadmium welding, cadmium-painted surfaces, and electrical grounding with cadmium weld connections. Requirements are identical to 1910.1027. |
| Physician Type | Licensed physician (familiar with App A health effects, App F sampling protocol, and App D questionnaire; employer-selected, multiple-physician review available to employee) |
| Removal (MRP) | Mandatory removal at post-1999 confirmed CdU >7 / CdB >10 / β₂-M >750 (with concurrent CdU >3 or CdB >5); return at CdU ≤3 AND CdB ≤5 AND β₂-M ≤300; MRP wage/benefit protection up to 18 months; quarterly biomonitoring and semiannual exams during removal. |
🩺 Baseline / Pre-Placement
Initial exam within 30 days of initial assignment (or 90 days after the standard's effective date, whichever is later); not required if an adequate exam was performed in the preceding 12 months
- Detailed medical + work history — emphasis on past, present, and anticipated cadmium exposure; renal, cardiovascular, respiratory, hematopoietic, reproductive, and musculo-skeletal dysfunction; current medications with nephrotoxic side-effects; smoking history and status
- Biological monitoring: Cadmium in urine (CdU), standardized to g creatinine (µg/g Cr)
- Biological monitoring: Beta-2-microglobulin in urine (β₂-M), standardized to µg/g Cr (pH specified)
- Biological monitoring: Cadmium in blood (CdB), standardized to liters whole blood (µg/lwb)
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: Biological monitoring (CdU, β2-M, CdB) at least annually. Full medical examination within 1 year after the initial examination, then at least biennially thereafter (29 CFR 1926.1127(l)(4)(i)).
- Biological monitoring at least annually: Cadmium in urine (CdU), standardized to g creatinine (µg/g Cr)
- Biological monitoring at least annually: Beta-2-microglobulin in urine (β₂-M), standardized to µg/g Cr (pH specified)
- Biological monitoring at least annually: Cadmium in blood (CdB), standardized to liters whole blood (µg/lwb)
- Biennial full exam — updated medical + work history (App D respirator questions 3-11 and 25-32 for respirator wearers)
- Biennial full exam — complete physical examination with emphasis on blood pressure, the respiratory system, and the urinary system
- Biennial full exam — posterior-anterior chest X-ray (14×17-inch or equivalent standard film/digital; subsequent frequency per examining physician)
- Biennial full exam — pulmonary function tests: forced vital capacity (FVC) and forced expiratory volume in 1 second (FEV₁)
- Biennial full exam — blood: blood urea nitrogen (BUN), complete blood count (CBC), serum creatinine
- Biennial full exam — urinalysis: albumin, glucose, and total and low-molecular-weight proteins
- Biennial full exam — prostate palpation (males over 40), or other at least as effective diagnostic test
- Any additional tests deemed appropriate by the examining physician
🚪 Exit / Termination
At termination of employment for employees under medical surveillance
- Termination medical examination including chest X-ray — required unless a qualifying periodic exam was completed within the preceding 6 months
- Biological monitoring: CdU, β₂-M, CdB
⚠ Emergency / Post-Exposure
As soon as possible following an acute cadmium exposure
- Full periodic-exam content with emphasis on the respiratory system, other organ systems the physician deems appropriate, and symptoms of acute overexposure
- Biological monitoring: CdU, β₂-M, CdB
Abnormal Results & Exposure-Event Protocols
- Initial biological result CdU >3 µg/g Cr, OR β₂-M >300 µg/g Cr, OR CdB >5 µg/lwb Elevated biomonitoring response: Within 2 weeks reassess occupational exposure (work practices, respirator use, hygiene, engineering controls, smoking); within 30 days correct deficiencies; within 90 days provide a full medical examination. If not removed, continue semiannual biological monitoring and annual full exams until CdU ≤3, β₂-M ≤300, and CdB ≤5. Tests: Repeat biological monitoring: CdU, β₂-M, CdB, Full medical examination within 90 days
- Mandatory removal when both the initial and confirmatory biological results show CdU >7 µg/g Cr, OR CdB >10 µg/lwb, OR β₂-M >750 µg/g Cr — AND concurrently CdU >3 or CdB >5. Pre-1999 absolute triggers (CdU >15, CdB >15, or β₂-M >1,500 with concurrent CdU >3 or CdB >5) also apply. Medical Removal Protection — post-1999 trigger levels (in force): Remove the employee from work where exposure is at/above the action level (or above the PEL if the basis is inability to wear a respirator). During removal, provide follow-up biological monitoring at least every 3 months and follow-up medical examinations at least every 6 months. Maintain MRP wage/benefit protection up to 18 months. Tests: Quarterly biological monitoring during removal: CdU, β₂-M, CdB, Semiannual follow-up medical examination during removal
- Employee removed under the MRP trigger levels Return to work / 18-month final determination: Return permitted only when CdU falls to ≤3 µg/g Cr AND CdB ≤5 µg/lwb AND β₂-M ≤300 µg/g Cr (physician may override with special-circumstances finding of no increased risk). After 18 months of unresolved removal, a final medical determination exam decides return-to-former-status vs. permanent removal. Tests: Confirmatory biological monitoring (CdU, CdB, β₂-M) to establish return eligibility
Reporting Requirements
| Who performs the evaluation | Licensed physician (familiar with App A, App D, App F) |
|---|---|
| Reported to employer | Prompt written medical opinion containing: the physician's diagnosis; whether the employee has a detected condition increasing risk of material impairment from cadmium (including potential cadmium toxicity); results of biological/other tests assessing cadmium absorption; any recommended removal or limitation on duties/PPE; and a statement that the physician explained the results (including all biomonitoring and any condition needing further evaluation, plus diet/medication limits) to the employee. Physician instructed NOT to reveal findings/diagnoses unrelated to cadmium. |
| Reported to / for the employee | Employer furnishes a copy of the written opinion to the employee within 2 weeks of receipt; biological monitoring results plus an explanation sheet furnished within 2 weeks of receipt. |
| Time limits | Written opinion and biomonitoring explanation furnished to the employee within 2 weeks of employer receipt; employee must initiate second-physician review within 15 days of notice. |
| Second-opinion / multi-physician review | Multiple-physician review: employer must notify the employee of the right to a second opinion after each employer-arranged exam; employee designates a second physician; unresolved disagreements go to a jointly-designated third physician whose findings control. |
| Recordkeeping | Medical surveillance records retained for the duration of employment plus 30 years (29 CFR 1910.1020). |
Cal/OSHA dir.ca.gov
General Industry
| Action Level | 2.5 µg/m³ (8-hr TWA) |
|---|---|
| PEL | 5 µg/m³ (8-hr TWA) |
| Covered | Employees exposed at/above the AL unless exposure occurs fewer than 30 days/year (12-month period); previously-exposed employees with 60+ aggregated months in cadmium work before the effective date. Mirrors federal 1910.1027. |
| Physician Type | Licensed physician (familiar with App A health effects, App F sampling protocol, and App D questionnaire; employer-selected, multiple-physician review available to employee) |
| Removal (MRP) | Mandatory removal at post-1999 confirmed CdU >7 / CdB >10 / β₂-M >750 (with concurrent CdU >3 or CdB >5); return at CdU ≤3 AND CdB ≤5 AND β₂-M ≤300; MRP wage/benefit protection up to 18 months; quarterly biomonitoring and semiannual exams during removal. |
🩺 Baseline / Pre-Placement
Initial exam within 30 days of initial assignment (or 90 days after the standard's effective date, whichever is later); not required if an adequate exam was performed in the preceding 12 months
- Detailed medical + work history — emphasis on past, present, and anticipated cadmium exposure; renal, cardiovascular, respiratory, hematopoietic, reproductive, and musculo-skeletal dysfunction; current medications with nephrotoxic side-effects; smoking history and status
- Biological monitoring: Cadmium in urine (CdU), standardized to g creatinine (µg/g Cr)
- Biological monitoring: Beta-2-microglobulin in urine (β₂-M), standardized to µg/g Cr (pH specified)
- Biological monitoring: Cadmium in blood (CdB), standardized to liters whole blood (µg/lwb)
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: Biological monitoring (CdU, β2-M, CdB) at least annually. Full medical examination within 1 year after the initial examination, then at least biennially thereafter (8 CCR 5207(l)(4)(A)).
- Biological monitoring at least annually: Cadmium in urine (CdU), standardized to g creatinine (µg/g Cr)
- Biological monitoring at least annually: Beta-2-microglobulin in urine (β₂-M), standardized to µg/g Cr (pH specified)
- Biological monitoring at least annually: Cadmium in blood (CdB), standardized to liters whole blood (µg/lwb)
- Biennial full exam — updated medical + work history (App D respirator questions 3-11 and 25-32 for respirator wearers)
- Biennial full exam — complete physical examination with emphasis on blood pressure, the respiratory system, and the urinary system
- Biennial full exam — posterior-anterior chest X-ray (14×17-inch or equivalent standard film/digital; subsequent frequency per examining physician)
- Biennial full exam — pulmonary function tests: forced vital capacity (FVC) and forced expiratory volume in 1 second (FEV₁)
- Biennial full exam — blood: blood urea nitrogen (BUN), complete blood count (CBC), serum creatinine
- Biennial full exam — urinalysis: albumin, glucose, and total and low-molecular-weight proteins
- Biennial full exam — prostate palpation (males over 40), or other at least as effective diagnostic test
- Any additional tests deemed appropriate by the examining physician
🚪 Exit / Termination
At termination of employment for employees under medical surveillance
- Termination medical examination including chest X-ray — required unless a qualifying periodic exam was completed within the preceding 6 months
- Biological monitoring: CdU, β₂-M, CdB
⚠ Emergency / Post-Exposure
As soon as possible following an acute cadmium exposure
- Full periodic-exam content with emphasis on the respiratory system, other organ systems the physician deems appropriate, and symptoms of acute overexposure
- Biological monitoring: CdU, β₂-M, CdB
Abnormal Results & Exposure-Event Protocols
- Initial biological result CdU >3 µg/g Cr, OR β₂-M >300 µg/g Cr, OR CdB >5 µg/lwb Elevated biomonitoring response: Within 2 weeks reassess occupational exposure (work practices, respirator use, hygiene, engineering controls, smoking); within 30 days correct deficiencies; within 90 days provide a full medical examination. If not removed, continue semiannual biological monitoring and annual full exams until CdU ≤3, β₂-M ≤300, and CdB ≤5. Tests: Repeat biological monitoring: CdU, β₂-M, CdB, Full medical examination within 90 days
- Mandatory removal when both the initial and confirmatory biological results show CdU >7 µg/g Cr, OR CdB >10 µg/lwb, OR β₂-M >750 µg/g Cr — AND concurrently CdU >3 or CdB >5. Pre-1999 absolute triggers (CdU >15, CdB >15, or β₂-M >1,500 with concurrent CdU >3 or CdB >5) also apply. Medical Removal Protection — post-1999 trigger levels (in force): Remove the employee from work where exposure is at/above the action level (or above the PEL if the basis is inability to wear a respirator). During removal, provide follow-up biological monitoring at least every 3 months and follow-up medical examinations at least every 6 months. Maintain MRP wage/benefit protection up to 18 months. Tests: Quarterly biological monitoring during removal: CdU, β₂-M, CdB, Semiannual follow-up medical examination during removal
- Employee removed under the MRP trigger levels Return to work / 18-month final determination: Return permitted only when CdU falls to ≤3 µg/g Cr AND CdB ≤5 µg/lwb AND β₂-M ≤300 µg/g Cr (physician may override with special-circumstances finding of no increased risk). After 18 months of unresolved removal, a final medical determination exam decides return-to-former-status vs. permanent removal. Tests: Confirmatory biological monitoring (CdU, CdB, β₂-M) to establish return eligibility
Reporting Requirements
| Who performs the evaluation | Licensed physician (familiar with App A, App D, App F) |
|---|---|
| Reported to employer | Prompt written medical opinion containing: the physician's diagnosis; whether the employee has a detected condition increasing risk of material impairment from cadmium (including potential cadmium toxicity); results of biological/other tests assessing cadmium absorption; any recommended removal or limitation on duties/PPE; and a statement that the physician explained the results (including all biomonitoring and any condition needing further evaluation, plus diet/medication limits) to the employee. Physician instructed NOT to reveal findings/diagnoses unrelated to cadmium. |
| Reported to / for the employee | Employer furnishes a copy of the written opinion to the employee within 2 weeks of receipt; biological monitoring results plus an explanation sheet furnished within 2 weeks of receipt. |
| Time limits | Written opinion and biomonitoring explanation furnished to the employee within 2 weeks of employer receipt; employee must initiate second-physician review within 15 days of notice. |
| Second-opinion / multi-physician review | Multiple-physician review: employer must notify the employee of the right to a second opinion after each employer-arranged exam; employee designates a second physician; unresolved disagreements go to a jointly-designated third physician whose findings control. |
| Recordkeeping | Medical records retained for the duration of employment plus 30 years, in accordance with 8 CCR 5207(n)(3)(C) (citing section 3204 for access). Mirrors federal 1910.1027(n)(3)(iii). |
Construction
| Action Level | 2.5 µg/m³ (8-hr TWA) |
|---|---|
| PEL | 5 µg/m³ (8-hr TWA) |
| Covered | California construction cadmium standard; coverage and requirements mirror 8 CCR 5207 and federal 1926.1127. |
| Physician Type | Licensed physician (familiar with App A health effects, App F sampling protocol, and App D questionnaire; employer-selected, multiple-physician review available to employee) |
| Removal (MRP) | Mandatory removal at post-1999 confirmed CdU >7 / CdB >10 / β₂-M >750 (with concurrent CdU >3 or CdB >5); return at CdU ≤3 AND CdB ≤5 AND β₂-M ≤300; MRP wage/benefit protection up to 18 months; quarterly biomonitoring and semiannual exams during removal. |
🩺 Baseline / Pre-Placement
Initial exam within 30 days of initial assignment (or 90 days after the standard's effective date, whichever is later); not required if an adequate exam was performed in the preceding 12 months
- Detailed medical + work history — emphasis on past, present, and anticipated cadmium exposure; renal, cardiovascular, respiratory, hematopoietic, reproductive, and musculo-skeletal dysfunction; current medications with nephrotoxic side-effects; smoking history and status
- Biological monitoring: Cadmium in urine (CdU), standardized to g creatinine (µg/g Cr)
- Biological monitoring: Beta-2-microglobulin in urine (β₂-M), standardized to µg/g Cr (pH specified)
- Biological monitoring: Cadmium in blood (CdB), standardized to liters whole blood (µg/lwb)
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: Biological monitoring (CdU, β2-M, CdB) at least annually. Full medical examination within 1 year after the initial examination, then at least biennially thereafter (8 CCR 1532(l)(4)(A)).
- Biological monitoring at least annually: Cadmium in urine (CdU), standardized to g creatinine (µg/g Cr)
- Biological monitoring at least annually: Beta-2-microglobulin in urine (β₂-M), standardized to µg/g Cr (pH specified)
- Biological monitoring at least annually: Cadmium in blood (CdB), standardized to liters whole blood (µg/lwb)
- Biennial full exam — updated medical + work history (App D respirator questions 3-11 and 25-32 for respirator wearers)
- Biennial full exam — complete physical examination with emphasis on blood pressure, the respiratory system, and the urinary system
- Biennial full exam — posterior-anterior chest X-ray (14×17-inch or equivalent standard film/digital; subsequent frequency per examining physician)
- Biennial full exam — pulmonary function tests: forced vital capacity (FVC) and forced expiratory volume in 1 second (FEV₁)
- Biennial full exam — blood: blood urea nitrogen (BUN), complete blood count (CBC), serum creatinine
- Biennial full exam — urinalysis: albumin, glucose, and total and low-molecular-weight proteins
- Biennial full exam — prostate palpation (males over 40), or other at least as effective diagnostic test
- Any additional tests deemed appropriate by the examining physician
🚪 Exit / Termination
At termination of employment for employees under medical surveillance
- Termination medical examination including chest X-ray — required unless a qualifying periodic exam was completed within the preceding 6 months
- Biological monitoring: CdU, β₂-M, CdB
⚠ Emergency / Post-Exposure
As soon as possible following an acute cadmium exposure
- Full periodic-exam content with emphasis on the respiratory system, other organ systems the physician deems appropriate, and symptoms of acute overexposure
- Biological monitoring: CdU, β₂-M, CdB
Abnormal Results & Exposure-Event Protocols
- Initial biological result CdU >3 µg/g Cr, OR β₂-M >300 µg/g Cr, OR CdB >5 µg/lwb Elevated biomonitoring response: Within 2 weeks reassess occupational exposure (work practices, respirator use, hygiene, engineering controls, smoking); within 30 days correct deficiencies; within 90 days provide a full medical examination. If not removed, continue semiannual biological monitoring and annual full exams until CdU ≤3, β₂-M ≤300, and CdB ≤5. Tests: Repeat biological monitoring: CdU, β₂-M, CdB, Full medical examination within 90 days
- Mandatory removal when both the initial and confirmatory biological results show CdU >7 µg/g Cr, OR CdB >10 µg/lwb, OR β₂-M >750 µg/g Cr — AND concurrently CdU >3 or CdB >5. Pre-1999 absolute triggers (CdU >15, CdB >15, or β₂-M >1,500 with concurrent CdU >3 or CdB >5) also apply. Medical Removal Protection — post-1999 trigger levels (in force): Remove the employee from work where exposure is at/above the action level (or above the PEL if the basis is inability to wear a respirator). During removal, provide follow-up biological monitoring at least every 3 months and follow-up medical examinations at least every 6 months. Maintain MRP wage/benefit protection up to 18 months. Tests: Quarterly biological monitoring during removal: CdU, β₂-M, CdB, Semiannual follow-up medical examination during removal
- Employee removed under the MRP trigger levels Return to work / 18-month final determination: Return permitted only when CdU falls to ≤3 µg/g Cr AND CdB ≤5 µg/lwb AND β₂-M ≤300 µg/g Cr (physician may override with special-circumstances finding of no increased risk). After 18 months of unresolved removal, a final medical determination exam decides return-to-former-status vs. permanent removal. Tests: Confirmatory biological monitoring (CdU, CdB, β₂-M) to establish return eligibility
Reporting Requirements
| Who performs the evaluation | Licensed physician (familiar with App A, App D, App F) |
|---|---|
| Reported to employer | Prompt written medical opinion containing: the physician's diagnosis; whether the employee has a detected condition increasing risk of material impairment from cadmium (including potential cadmium toxicity); results of biological/other tests assessing cadmium absorption; any recommended removal or limitation on duties/PPE; and a statement that the physician explained the results (including all biomonitoring and any condition needing further evaluation, plus diet/medication limits) to the employee. Physician instructed NOT to reveal findings/diagnoses unrelated to cadmium. |
| Reported to / for the employee | Employer furnishes a copy of the written opinion to the employee within 2 weeks of receipt; biological monitoring results plus an explanation sheet furnished within 2 weeks of receipt. |
| Time limits | Written opinion and biomonitoring explanation furnished to the employee within 2 weeks of employer receipt; employee must initiate second-physician review within 15 days of notice. |
| Second-opinion / multi-physician review | Multiple-physician review: employer must notify the employee of the right to a second opinion after each employer-arranged exam; employee designates a second physician; unresolved disagreements go to a jointly-designated third physician whose findings control. |
| Recordkeeping | Medical records retained for the duration of employment plus 30 years (8 CCR 3204). |
Federal vs. California: Aligned. California (5207 GI, 1532 construction) mirrors federal (1910.1027, 1926.1127) on AL (2.5 µg/m³), PEL (5 µg/m³), the initial/biennial-exam + annual-biomonitoring schedule, the full exam content (history, physical, chest X-ray, FVC/FEV₁, CdU/β₂-M/CdB, BUN/CBC/creatinine, urinalysis, prostate palpation), and the post-1999 MRP trigger levels (7/10/750), return criteria (3/5/300), and 18-month benefit period. No substantive difference.
Hexavalent Chromium (Cr VI)
Cr VI causes lung cancer, nasal septum perforation/ulceration, dermatitis, and respiratory sensitization; affects workers in welding stainless steel, electroplating, chromate pigment/paint, and chrome-plating operations.
Federal OSHA osha.gov
General Industry
| Action Level | 2.5 µg/m³ (8-hr TWA) |
|---|---|
| PEL | 5 µg/m³ (8-hr TWA) |
| Covered | Employees occupationally exposed to Cr(VI) at/above the AL for 30 or more days per year; any employee who shows signs/symptoms of adverse Cr(VI) effects; any employee exposed in an emergency |
| Physician Type | PLHCP (physician or other licensed health care professional) |
🩺 Baseline / Pre-Placement
Within 30 days after initial assignment, unless the employee received a qualifying exam meeting these requirements within the prior 12 months
- Medical + work history covering past, present, and anticipated future exposure to Cr(VI); history of respiratory-system dysfunction; history of asthma, dermatitis, skin ulceration, or nasal septum perforation; and smoking status and history
- Physical examination of the skin and respiratory tract
- Any additional tests deemed appropriate by the examining PLHCP (no mandatory Cr biomarker)
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: At least annually.
- Medical + work history covering past, present, and anticipated future exposure to Cr(VI); history of respiratory-system dysfunction; history of asthma, dermatitis, skin ulceration, or nasal septum perforation; and smoking status and history
- Physical examination of the skin and respiratory tract
- Any additional tests deemed appropriate by the examining PLHCP
🚪 Exit / Termination
At termination of employment
- Termination medical examination — required unless the last qualifying exam was within the preceding 6 months
⚠ Emergency / Post-Exposure
Within 30 days after an emergency exposure (uncontrolled release); also whenever the employee shows signs or symptoms of adverse Cr(VI) health effects
- Medical + work history covering past, present, and anticipated future exposure to Cr(VI); history of respiratory-system dysfunction; history of asthma, dermatitis, skin ulceration, or nasal septum perforation; and smoking status and history
- Physical examination of the skin and respiratory tract
- Any additional tests deemed appropriate by the examining PLHCP
Abnormal Results & Exposure-Event Protocols
- Examining PLHCP recommends an additional medical examination Additional examination on PLHCP recommendation: Provide the recommended additional examination within 30 days of the written recommendation. Tests: Examination as specified by the PLHCP
Reporting Requirements
| Who performs the evaluation | PLHCP (physician or other licensed health care professional) |
|---|---|
| Reported to employer | Written opinion containing only: whether the employee has a detected medical condition that places the employee at increased risk from further Cr(VI) exposure; any recommended exposure limitations or PPE/respirator restrictions; and a statement that the PLHCP explained the results to the employee, including any condition requiring further evaluation. PLHCP must NOT reveal findings or diagnoses unrelated to occupational Cr(VI) exposure. |
| Reported to / for the employee | Employer provides a copy of the written opinion to the employee within 2 weeks of receiving it; PLHCP explains results directly to the employee. |
| Time limits | Employer must obtain the PLHCP's written medical opinion within 30 days of each examination (29 CFR 1910.1026(k)(5)(i)). Employer must provide a copy of the written opinion to the examined employee within two weeks after receiving it (29 CFR 1910.1026(k)(5)(iii)). |
| Second-opinion / multi-physician review | No multiple-physician review mechanism specified in the Cr(VI) standard. |
| Recordkeeping | Records maintained per 29 CFR 1910.1020 (duration of employment plus 30 years), including PLHCP written opinions. |
Construction
| Action Level | 2.5 µg/m³ (8-hr TWA) |
|---|---|
| PEL | 5 µg/m³ (8-hr TWA) |
| Covered | Identical to GI 1910.1026: at/above AL for 30+ days/year; signs/symptoms; emergency exposure |
| Physician Type | PLHCP (physician or other licensed health care professional) |
🩺 Baseline / Pre-Placement
Within 30 days after initial assignment, unless the employee received a qualifying exam meeting these requirements within the prior 12 months
- Medical + work history covering past, present, and anticipated future exposure to Cr(VI); history of respiratory-system dysfunction; history of asthma, dermatitis, skin ulceration, or nasal septum perforation; and smoking status and history
- Physical examination of the skin and respiratory tract
- Any additional tests deemed appropriate by the examining PLHCP (no mandatory Cr biomarker)
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: At least annually.
- Medical + work history covering past, present, and anticipated future exposure to Cr(VI); history of respiratory-system dysfunction; history of asthma, dermatitis, skin ulceration, or nasal septum perforation; and smoking status and history
- Physical examination of the skin and respiratory tract
- Any additional tests deemed appropriate by the examining PLHCP
🚪 Exit / Termination
At termination of employment
- Termination medical examination — required unless the last qualifying exam was within the preceding 6 months
⚠ Emergency / Post-Exposure
Within 30 days after an emergency exposure (uncontrolled release); also whenever the employee shows signs or symptoms of adverse Cr(VI) health effects
- Medical + work history covering past, present, and anticipated future exposure to Cr(VI); history of respiratory-system dysfunction; history of asthma, dermatitis, skin ulceration, or nasal septum perforation; and smoking status and history
- Physical examination of the skin and respiratory tract
- Any additional tests deemed appropriate by the examining PLHCP
Abnormal Results & Exposure-Event Protocols
- Examining PLHCP recommends an additional medical examination Additional examination on PLHCP recommendation: Provide the recommended additional examination within 30 days of the written recommendation. Tests: Examination as specified by the PLHCP
Reporting Requirements
| Who performs the evaluation | PLHCP (physician or other licensed health care professional) |
|---|---|
| Reported to employer | Written opinion containing only: whether the employee has a detected medical condition that places the employee at increased risk from further Cr(VI) exposure; any recommended exposure limitations or PPE/respirator restrictions; and a statement that the PLHCP explained the results to the employee, including any condition requiring further evaluation. PLHCP must NOT reveal findings or diagnoses unrelated to occupational Cr(VI) exposure. |
| Reported to / for the employee | Employer provides a copy of the written opinion to the employee within 2 weeks of receiving it; PLHCP explains results directly to the employee. |
| Time limits | Employer must obtain the PLHCP's written medical opinion within 30 days of each examination (29 CFR 1926.1126(i)(5)(i)). Employer must provide a copy to the examined employee within two weeks after receiving it (29 CFR 1926.1126(i)(5)(iii)). |
| Second-opinion / multi-physician review | No multiple-physician review mechanism specified in the Cr(VI) standard. |
| Recordkeeping | Records maintained per 29 CFR 1910.1020 (duration of employment plus 30 years). |
Cal/OSHA dir.ca.gov
General Industry
| Action Level | 2.5 µg/m³ (8-hr TWA) |
|---|---|
| PEL | 5 µg/m³ (8-hr TWA) |
| Covered | Employees exposed at/above the AL for 30+ days/year; signs/symptoms; emergency exposure. Exceptions: pesticide application regulated by CA DPR, portland cement exposures, and materials that cannot release Cr(VI) at ≥0.5 µg/m³ |
| Physician Type | PLHCP (physician or other licensed health care professional) |
🩺 Baseline / Pre-Placement
Within 30 days after initial assignment, unless the employee received a qualifying exam meeting these requirements within the prior 12 months
- Medical + work history covering past, present, and anticipated future exposure to Cr(VI); history of respiratory-system dysfunction; history of asthma, dermatitis, skin ulceration, or nasal septum perforation; and smoking status and history
- Physical examination of the skin and respiratory tract
- Any additional tests deemed appropriate by the examining PLHCP (no mandatory Cr biomarker)
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: At least annually.
- Medical + work history covering past, present, and anticipated future exposure to Cr(VI); history of respiratory-system dysfunction; history of asthma, dermatitis, skin ulceration, or nasal septum perforation; and smoking status and history
- Physical examination of the skin and respiratory tract
- Any additional tests deemed appropriate by the examining PLHCP
🚪 Exit / Termination
At termination of employment
- Termination medical examination — required unless the last qualifying exam was within the preceding 6 months
⚠ Emergency / Post-Exposure
Within 30 days after an emergency exposure (uncontrolled release); also whenever the employee shows signs or symptoms of adverse Cr(VI) health effects
- Medical + work history covering past, present, and anticipated future exposure to Cr(VI); history of respiratory-system dysfunction; history of asthma, dermatitis, skin ulceration, or nasal septum perforation; and smoking status and history
- Physical examination of the skin and respiratory tract
- Any additional tests deemed appropriate by the examining PLHCP
Abnormal Results & Exposure-Event Protocols
- Examining PLHCP recommends an additional medical examination Additional examination on PLHCP recommendation: Provide the recommended additional examination within 30 days of the written recommendation. Tests: Examination as specified by the PLHCP
Reporting Requirements
| Who performs the evaluation | PLHCP (physician or other licensed health care professional) |
|---|---|
| Reported to employer | Written opinion containing only: whether the employee has a detected medical condition that places the employee at increased risk from further Cr(VI) exposure; any recommended exposure limitations or PPE/respirator restrictions; and a statement that the PLHCP explained the results to the employee, including any condition requiring further evaluation. PLHCP must NOT reveal findings or diagnoses unrelated to occupational Cr(VI) exposure. |
| Reported to / for the employee | Employer provides a copy of the written opinion to the employee within 2 weeks of receiving it; PLHCP explains results directly to the employee. |
| Time limits | Employer obtains the written opinion within 30 days of each exam; furnishes a copy to the employee within 2 weeks of receipt. |
| Second-opinion / multi-physician review | No multiple-physician review mechanism specified in the Cr(VI) standard. |
| Recordkeeping | Records maintained per 8 CCR 3204, including PLHCP written opinions and information provided to the PLHCP. |
Construction
| Action Level | 2.5 µg/m³ (8-hr TWA) |
|---|---|
| PEL | 5 µg/m³ (8-hr TWA) |
| Covered | Construction-only scope: employees exposed at/above the AL for 30+ days/year; signs/symptoms; emergency exposure |
| Physician Type | PLHCP (physician or other licensed health care professional) |
🩺 Baseline / Pre-Placement
Within 30 days after initial assignment, unless the employee received a qualifying exam meeting these requirements within the prior 12 months
- Medical + work history covering past, present, and anticipated future exposure to Cr(VI); history of respiratory-system dysfunction; history of asthma, dermatitis, skin ulceration, or nasal septum perforation; and smoking status and history
- Physical examination of the skin and respiratory tract
- Any additional tests deemed appropriate by the examining PLHCP (no mandatory Cr biomarker)
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: At least annually.
- Medical + work history covering past, present, and anticipated future exposure to Cr(VI); history of respiratory-system dysfunction; history of asthma, dermatitis, skin ulceration, or nasal septum perforation; and smoking status and history
- Physical examination of the skin and respiratory tract
- Any additional tests deemed appropriate by the examining PLHCP
🚪 Exit / Termination
At termination of employment
- Termination medical examination — required unless the last qualifying exam was within the preceding 6 months
⚠ Emergency / Post-Exposure
Within 30 days after an emergency exposure (uncontrolled release); also whenever the employee shows signs or symptoms of adverse Cr(VI) health effects
- Medical + work history covering past, present, and anticipated future exposure to Cr(VI); history of respiratory-system dysfunction; history of asthma, dermatitis, skin ulceration, or nasal septum perforation; and smoking status and history
- Physical examination of the skin and respiratory tract
- Any additional tests deemed appropriate by the examining PLHCP
Abnormal Results & Exposure-Event Protocols
- Examining PLHCP recommends an additional medical examination Additional examination on PLHCP recommendation: Provide the recommended additional examination within 30 days of the written recommendation. Tests: Examination as specified by the PLHCP
Reporting Requirements
| Who performs the evaluation | PLHCP (physician or other licensed health care professional) |
|---|---|
| Reported to employer | Written opinion containing only: whether the employee has a detected medical condition that places the employee at increased risk from further Cr(VI) exposure; any recommended exposure limitations or PPE/respirator restrictions; and a statement that the PLHCP explained the results to the employee, including any condition requiring further evaluation. PLHCP must NOT reveal findings or diagnoses unrelated to occupational Cr(VI) exposure. |
| Reported to / for the employee | Employer provides a copy of the written opinion to the employee within 2 weeks of receiving it; PLHCP explains results directly to the employee. |
| Time limits | Employer obtains the written opinion within 30 days of each exam; furnishes a copy to the employee within 2 weeks of receipt. |
| Second-opinion / multi-physician review | No multiple-physician review mechanism specified in the Cr(VI) standard. |
| Recordkeeping | Records maintained per 8 CCR 3204, including PLHCP written opinions. |
Federal vs. California: Aligned. All four standards (federal 1910.1026 / 1926.1126; California 5206 / 1532.2) share AL 2.5 µg/m³, PEL 5 µg/m³, the same exam schedule (initial within 30 days, annual periodic, 30-day additional/emergency, 6-month termination window), the same history + skin/respiratory physical exam, no mandatory biomarker, and NO automatic medical-removal-protection trigger levels. The only protection mechanism is the PLHCP additional-exam recommendation. CA adds explicit pesticide/portland-cement/low-release exceptions.
Inorganic Arsenic
Inorganic arsenic causes lung and skin cancer, dermatitis, and nasal/respiratory irritation; affects workers in smelting, glass manufacturing, pesticide production, and wood treatment.
Federal OSHA osha.gov
General Industry
| Action Level | 5 µg/m³ (8-hr TWA) |
|---|---|
| PEL | 10 µg/m³ (8-hr TWA) |
| 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 |
| Physician Type | 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 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 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
| Action Level | 5 µg/m³ (8-hr TWA) |
|---|---|
| PEL | 10 µg/m³ (8-hr TWA) |
| 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 |
| Physician Type | 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 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. |
Cal/OSHA dir.ca.gov
General Industry
| Action Level | 5 µg/m³ (8-hr TWA) |
|---|---|
| PEL | 10 µg/m³ (8-hr TWA) |
| Covered | All employees exposed above the AL (without regard to respirator use) at least 30 days/year; and all employees exposed above the AL 30+ days/year for a total of 10+ years of combined employment |
| Physician Type | 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 and comprehensive medical history including smoking history
- Physical examination with attention to skin, nose, respiratory tract, lymph nodes, nervous system, and liver
- Posterior-anterior chest X-ray (14×17-inch)
- Sputum cytology examination
- Other tests the physician deems appropriate [8 CCR 5214(n)(2)]
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered. Frequency depends on a covered-status risk tier (age/tenure), not on a prior abnormal result.
Schedule: Annually for employees under age 45 AND with fewer than 10 years of arsenic exposure. Semi-annually for employees aged 45 or older OR with 10 or more years of exposure.
- Annual tier (age <45 AND <10 years exposure): interim work and medical history including smoking history; interim physical examination; other tests the physician deems appropriate [8 CCR 5214(n)(3)(A)]
- Semi-annual tier (age ≥45 OR ≥10 years exposure): all annual components PLUS chest X-ray and sputum cytology examination [8 CCR 5214(n)(3)(B)]
🚪 Exit / Termination
At termination of employment
- Opportunity for the required examination upon termination if the last exam was more than 6 months prior
⚠ Emergency / Post-Exposure
Employee develops signs or symptoms associated with inorganic arsenic exposure
- Additional medical examination as appropriate
Reporting Requirements
| Who performs the evaluation | Licensed physician |
|---|---|
| Reported to employer | Written report interpreting the results of each medical examination and providing recommendations; the physician is not to reveal specific findings or diagnoses unrelated to occupational arsenic exposure. |
| Reported to / for the employee | Employer provides a copy of the physician's written report to the affected employee. |
| Time limits | No specific timeframe for furnishing the written report is stated in the standard. |
| Second-opinion / multi-physician review | No multiple-physician review mechanism specified. |
| Recordkeeping | Medical records maintained for at least 40 years, or for the duration of employment plus 20 years, whichever is longer (records access per 8 CCR 3204). |
Construction
No separate Cal/OSHA construction inorganic-arsenic standard exists; California regulates inorganic arsenic for general industry under 8 CCR 5214. Construction work in California involving inorganic arsenic is addressed through general Title 8 toxic-substance and exposure-control provisions rather than a dedicated arsenic construction section.
Federal vs. California: 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.
Beryllium
Beryllium causes chronic beryllium disease (CBD), beryllium sensitization, and lung cancer; affects workers in machining, foundry/smelting, ceramics, dental labs, and aerospace/defense manufacturing.
Federal OSHA osha.gov
General Industry
| Action Level | 0.1 µg/m³ (8-hr TWA) |
|---|---|
| PEL | 0.2 µg/m³ (8-hr TWA); STEL 2.0 µg/m³ (15-min) |
| Covered | Employees (1) exposed at/above the AL for more than 30 days/year; (2) showing signs or symptoms of CBD or other beryllium-related health effects; (3) exposed to beryllium during an emergency; or (4) recommended for periodic surveillance in a PLHCP/physician's written opinion |
| Physician Type | PLHCP, with the written medical report authored by a licensed physician; CBD evaluation by a CBD diagnostic center (pulmonologist/pulmonary specialist with BAL and transbronchial biopsy capability) |
| Removal (MRP) | Removal for a confirmed positive beryllium sensitization, a CBD diagnosis, or a written removal recommendation; benefits = comparable below-AL position OR maintained base earnings/seniority/benefits for 6 months (or until comparable work is available) — notably shorter than lead/cadmium's 18 months. |
🩺 Baseline / Pre-Placement
Within 30 days after the employee meets an eligibility criterion, unless the employee received a beryllium medical exam within the preceding 2 years
- Medical and work history with emphasis on past and present airborne exposure to or dermal contact with beryllium, smoking history, and any history of respiratory-system dysfunction
- Physical examination with emphasis on the respiratory system
- Physical examination of the skin for rashes
- Pulmonary function tests per ATS guidelines: forced vital capacity (FVC) and forced expiratory volume in 1 second (FEV₁)
- Standardized BeLPT (or equivalent test) at the first examination
- Low-dose CT scan when recommended by the PLHCP after considering exposure history and other risk factors
- Any other test deemed appropriate by the PLHCP
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: At least every 2 years.
- Medical and work history with emphasis on past and present airborne exposure to or dermal contact with beryllium, smoking history, and any history of respiratory-system dysfunction
- Physical examination with emphasis on the respiratory system
- Physical examination of the skin for rashes
- Pulmonary function tests per ATS guidelines (FVC, FEV₁)
- Standardized BeLPT (or equivalent) at least every 2 years, unless the employee is confirmed positive
- Low-dose CT scan when recommended by the PLHCP
- Any other test deemed appropriate by the PLHCP
🚪 Exit / Termination
At termination of employment for an employee meeting an eligibility criterion
- Termination medical examination — required unless a beryllium medical exam was provided during the 6 months prior to termination
- Standardized BeLPT (per exam content)
⚠ Emergency / Post-Exposure
For employees without a beryllium medical exam in the preceding 2 years: within 30 days after meeting emergency exposure criteria (29 CFR 1910.1024(k)(2)(iv)(A)). For employees with an exam within the preceding 2 years: the next exam occurs at least 1 year but no more than 2 years after meeting those criteria (29 CFR 1910.1024(k)(2)(iv)(B)).
- Medical and work history with emphasis on past and present airborne exposure to or dermal contact with beryllium, smoking history, and any history of respiratory-system dysfunction
- Physical examination (respiratory system, skin)
- Pulmonary function tests (FVC, FEV₁)
- Standardized BeLPT
- Low-dose CT scan when recommended by the PLHCP
Abnormal Results & Exposure-Event Protocols
- BeLPT result is abnormal or borderline (and the employee is not already confirmed positive) Follow-up BeLPT on abnormal/borderline result: Offer a follow-up BeLPT within 30 days of receiving the result. Tests: Follow-up standardized BeLPT
- PLHCP recommends referral, or the employee presents a medical report showing a confirmed positive finding or a CBD diagnosis CBD diagnostic center referral: With the employee's authorization, the employer offers an evaluation at a CBD diagnostic center within 30 days; the center provides a written report. Tests: CBD diagnostic-center evaluation (pulmonary function testing, bronchoalveolar lavage, transbronchial biopsy as indicated)
- Employee working at/above the AL who provides a written medical report of a confirmed positive beryllium-sensitization finding or a CBD diagnosis, OR receives a written PLHCP/physician recommendation for removal Medical Removal Protection: Remove the employee from beryllium exposure. The employer either transfers the employee to comparable work below the AL (if available and the employee is qualified or can be trained within one month) or maintains the employee's base earnings, seniority, and other rights/benefits for 6 months from the time of removal, or until comparable below-AL work becomes available, whichever comes first. Tests: Continued medical surveillance per the standard during removal
Reporting Requirements
| Who performs the evaluation | PLHCP for the exam; a licensed physician authors the written medical report; CBD diagnostic center for CBD evaluation |
|---|---|
| Reported to employer | Within 45 days of each examination, a written medical opinion to the employer containing ONLY: (1) the date of the examination; (2) a statement that the examination meets the requirements of the standard; (3) any recommended limitations on the employee's use of respirators, protective clothing, or equipment; and (4) a statement that the PLHCP explained the results to the employee. Recommended limitations on airborne exposure, CBD-center referral, continued surveillance recommendation, and removal recommendation are included ONLY with the employee's written authorization (29 CFR 1910.1024(k)(6)(i)-(v)). |
| Reported to / for the employee | Within 45 days, a written medical report from the licensed physician containing exam results, any detected CBD/sensitization or related condition, recommendations (respirator/PPE/exposure limits), and — if confirmed positive or CBD — a recommendation for CBD-center referral, continued surveillance, and medical removal. Employee also receives a copy of the employer opinion within 45 days; CBD-center report copy within 30 days. |
| Time limits | Written medical report to the employee and written opinion to the employer within 45 days of the exam; CBD diagnostic-center report within 30 days. |
| Second-opinion / multi-physician review | No formal multiple-physician review; the CBD diagnostic-center evaluation serves as the specialist confirmation pathway. |
| Recordkeeping | Records maintained per 29 CFR 1910.1020 (duration of employment plus 30 years), including all licensed physicians' written medical opinions and information provided to the PLHCP. |
Construction
| Action Level | 0.1 µg/m³ (8-hr TWA) |
|---|---|
| PEL | 0.2 µg/m³ (8-hr TWA); STEL 2.0 µg/m³ (15-min) |
| Covered | Employees (1) exposed at/above the AL for more than 30 days/year; (2) showing signs or symptoms of CBD or other beryllium-related health effects; (3) exposed to beryllium during an emergency; or (4) recommended for periodic surveillance in a PLHCP/physician's written opinion |
| Physician Type | PLHCP, with the written medical report authored by a licensed physician; CBD evaluation by a CBD diagnostic center (pulmonologist/pulmonary specialist with BAL and transbronchial biopsy capability) |
| Removal (MRP) | Removal for a confirmed positive beryllium sensitization, a CBD diagnosis, or a written removal recommendation; benefits = comparable below-AL position OR maintained base earnings/seniority/benefits for 6 months (or until comparable work is available) — notably shorter than lead/cadmium's 18 months. |
🩺 Baseline / Pre-Placement
Within 30 days after the employee meets an eligibility criterion, unless the employee received a beryllium medical exam within the preceding 2 years
- Medical and work history with emphasis on past and present airborne exposure to or dermal contact with beryllium, smoking history, and any history of respiratory-system dysfunction
- Physical examination with emphasis on the respiratory system
- Physical examination of the skin for rashes
- Pulmonary function tests per ATS guidelines: forced vital capacity (FVC) and forced expiratory volume in 1 second (FEV₁)
- Standardized BeLPT (or equivalent test) at the first examination
- Low-dose CT scan when recommended by the PLHCP after considering exposure history and other risk factors
- Any other test deemed appropriate by the PLHCP
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: At least every 2 years.
- Medical and work history with emphasis on past and present airborne exposure to or dermal contact with beryllium, smoking history, and any history of respiratory-system dysfunction
- Physical examination with emphasis on the respiratory system
- Physical examination of the skin for rashes
- Pulmonary function tests per ATS guidelines (FVC, FEV₁)
- Standardized BeLPT (or equivalent) at least every 2 years, unless the employee is confirmed positive
- Low-dose CT scan when recommended by the PLHCP
- Any other test deemed appropriate by the PLHCP
🚪 Exit / Termination
At termination of employment for an employee meeting an eligibility criterion
- Termination medical examination — required unless a beryllium medical exam was provided during the 6 months prior to termination
- Standardized BeLPT (per exam content)
⚠ Emergency / Post-Exposure
Within 30 days after an emergency beryllium exposure, if no exam was provided within the preceding 2 years
- Medical and work history with emphasis on past and present airborne exposure to or dermal contact with beryllium, smoking history, and any history of respiratory-system dysfunction
- Physical examination (respiratory system, skin)
- Pulmonary function tests (FVC, FEV₁)
- Standardized BeLPT
- Low-dose CT scan when recommended by the PLHCP
Abnormal Results & Exposure-Event Protocols
- BeLPT result is abnormal or borderline (and the employee is not already confirmed positive) Follow-up BeLPT on abnormal/borderline result: Offer a follow-up BeLPT within 30 days of receiving the result. Tests: Follow-up standardized BeLPT
- PLHCP recommends referral, or the employee presents a medical report showing a confirmed positive finding or a CBD diagnosis CBD diagnostic center referral: With the employee's authorization, the employer offers an evaluation at a CBD diagnostic center within 30 days; the center provides a written report. Tests: CBD diagnostic-center evaluation (pulmonary function testing, bronchoalveolar lavage, transbronchial biopsy as indicated)
- Employee working at/above the AL who provides a written medical report of a confirmed positive beryllium-sensitization finding or a CBD diagnosis, OR receives a written PLHCP/physician recommendation for removal Medical Removal Protection: Remove the employee from beryllium exposure. The employer either transfers the employee to comparable work below the AL (if available and the employee is qualified or can be trained within one month) or maintains the employee's base earnings, seniority, and other rights/benefits for 6 months from the time of removal, or until comparable below-AL work becomes available, whichever comes first. Tests: Continued medical surveillance per the standard during removal
Reporting Requirements
| Who performs the evaluation | PLHCP for the exam; a licensed physician authors the written medical report; CBD diagnostic center for CBD evaluation |
|---|---|
| Reported to employer | Within 45 days, a written medical opinion containing only the date of the exam, a statement that the exam met the standard, any recommended PPE/respirator limitations, and confirmation that the PLHCP explained the results to the employee. Any further content (exposure limitations, CBD-center referral, removal recommendation) is included ONLY with the employee's written authorization. |
| Reported to / for the employee | Within 45 days, a written medical report from the licensed physician containing exam results, any detected CBD/sensitization or related condition, recommendations (respirator/PPE/exposure limits), and — if confirmed positive or CBD — a recommendation for CBD-center referral, continued surveillance, and medical removal. Employee also receives a copy of the employer opinion within 45 days; CBD-center report copy within 30 days. |
| Time limits | Written medical report to the employee and written opinion to the employer within 45 days of the exam; CBD diagnostic-center report within 30 days. |
| Second-opinion / multi-physician review | No formal multiple-physician review; the CBD diagnostic-center evaluation serves as the specialist confirmation pathway. |
| Recordkeeping | Records maintained per 29 CFR 1910.1020 (duration of employment plus 30 years), including written medical opinions. Identical to GI 1910.1024. |
Cal/OSHA dir.ca.gov
General Industry
| Action Level | 0.1 µg/m³ (8-hr TWA) |
|---|---|
| PEL | 0.2 µg/m³ (8-hr TWA); STEL 2.0 µg/m³ (15-min) |
| Covered | Employees (1) exposed at/above the AL for more than 30 days/year; (2) showing signs or symptoms of CBD or other beryllium-related health effects; (3) exposed to beryllium during an emergency; or (4) recommended for periodic surveillance in a PLHCP/physician's written opinion |
| Physician Type | PLHCP, with the written medical report authored by a licensed physician; CBD evaluation by a CBD diagnostic center (pulmonologist/pulmonary specialist with BAL and transbronchial biopsy capability) |
| Removal (MRP) | Removal for a confirmed positive beryllium sensitization, a CBD diagnosis, or a written removal recommendation; benefits = comparable below-AL position OR maintained base earnings/seniority/benefits for 6 months (or until comparable work is available) — notably shorter than lead/cadmium's 18 months. |
🩺 Baseline / Pre-Placement
Within 30 days after the employee meets an eligibility criterion, unless the employee received a beryllium medical exam within the preceding 2 years
- Medical and work history with emphasis on past and present airborne exposure to or dermal contact with beryllium, smoking history, and any history of respiratory-system dysfunction
- Physical examination with emphasis on the respiratory system
- Physical examination of the skin for rashes
- Pulmonary function tests per ATS guidelines: forced vital capacity (FVC) and forced expiratory volume in 1 second (FEV₁)
- Standardized BeLPT (or equivalent test) at the first examination
- Low-dose CT scan when recommended by the PLHCP after considering exposure history and other risk factors
- Any other test deemed appropriate by the PLHCP
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: At least every 2 years.
- Medical and work history with emphasis on past and present airborne exposure to or dermal contact with beryllium, smoking history, and any history of respiratory-system dysfunction
- Physical examination with emphasis on the respiratory system
- Physical examination of the skin for rashes
- Pulmonary function tests per ATS guidelines (FVC, FEV₁)
- Standardized BeLPT (or equivalent) at least every 2 years, unless the employee is confirmed positive
- Low-dose CT scan when recommended by the PLHCP
- Any other test deemed appropriate by the PLHCP
🚪 Exit / Termination
At termination of employment for an employee meeting an eligibility criterion
- Termination medical examination — required unless a beryllium medical exam was provided during the 6 months prior to termination
- Standardized BeLPT (per exam content)
⚠ Emergency / Post-Exposure
Within 30 days after an emergency beryllium exposure, if no exam was provided within the preceding 2 years
- Medical and work history with emphasis on past and present airborne exposure to or dermal contact with beryllium, smoking history, and any history of respiratory-system dysfunction
- Physical examination (respiratory system, skin)
- Pulmonary function tests (FVC, FEV₁)
- Standardized BeLPT
- Low-dose CT scan when recommended by the PLHCP
Abnormal Results & Exposure-Event Protocols
- BeLPT result is abnormal or borderline (and the employee is not already confirmed positive) Follow-up BeLPT on abnormal/borderline result: Offer a follow-up BeLPT within 30 days of receiving the result. Tests: Follow-up standardized BeLPT
- PLHCP recommends referral, or the employee presents a medical report showing a confirmed positive finding or a CBD diagnosis CBD diagnostic center referral: With the employee's authorization, the employer offers an evaluation at a CBD diagnostic center within 30 days; the center provides a written report. Tests: CBD diagnostic-center evaluation (pulmonary function testing, bronchoalveolar lavage, transbronchial biopsy as indicated)
- Employee working at/above the AL who provides a written medical report of a confirmed positive beryllium-sensitization finding or a CBD diagnosis, OR receives a written PLHCP/physician recommendation for removal Medical Removal Protection: Remove the employee from beryllium exposure. The employer either transfers the employee to comparable work below the AL (if available and the employee is qualified or can be trained within one month) or maintains the employee's base earnings, seniority, and other rights/benefits for 6 months from the time of removal, or until comparable below-AL work becomes available, whichever comes first. Tests: Continued medical surveillance per the standard during removal
Reporting Requirements
| Who performs the evaluation | PLHCP for the exam; a licensed physician authors the written medical report; CBD diagnostic center for CBD evaluation |
|---|---|
| Reported to employer | Within 45 days, a written medical opinion containing only the date of the exam, a statement that the exam met the standard, any recommended PPE/respirator limitations, and confirmation that the PLHCP explained the results to the employee. Any further content (exposure limitations, CBD-center referral, removal recommendation) is included ONLY with the employee's written authorization. |
| Reported to / for the employee | Within 45 days, a written medical report from the licensed physician containing exam results, any detected CBD/sensitization or related condition, recommendations (respirator/PPE/exposure limits), and — if confirmed positive or CBD — a recommendation for CBD-center referral, continued surveillance, and medical removal. Employee also receives a copy of the employer opinion within 45 days; CBD-center report copy within 30 days. |
| Time limits | Written medical report to the employee and written opinion to the employer within 45 days of the exam; CBD diagnostic-center report within 30 days. |
| Second-opinion / multi-physician review | No formal multiple-physician review; the CBD diagnostic-center evaluation serves as the specialist confirmation pathway. |
| Recordkeeping | Records maintained per 8 CCR 3204, including all licensed physicians' written medical opinions and information provided to the PLHCP. |
Construction
| Action Level | 0.1 µg/m³ (8-hr TWA) |
|---|---|
| PEL | 0.2 µg/m³ (8-hr TWA); STEL 2.0 µg/m³ (15-min) |
| Covered | Employees (1) exposed at/above the AL for more than 30 days/year; (2) showing signs or symptoms of CBD or other beryllium-related health effects; (3) exposed to beryllium during an emergency; or (4) recommended for periodic surveillance in a PLHCP/physician's written opinion |
| Physician Type | PLHCP, with the written medical report authored by a licensed physician; CBD evaluation by a CBD diagnostic center (pulmonologist/pulmonary specialist with BAL and transbronchial biopsy capability) |
| Removal (MRP) | Removal for a confirmed positive beryllium sensitization, a CBD diagnosis, or a written removal recommendation; benefits = comparable below-AL position OR maintained base earnings/seniority/benefits for 6 months (or until comparable work is available) — notably shorter than lead/cadmium's 18 months. |
🩺 Baseline / Pre-Placement
Within 30 days after the employee meets an eligibility criterion, unless the employee received a beryllium medical exam within the preceding 2 years
- Medical and work history with emphasis on past and present airborne exposure to or dermal contact with beryllium, smoking history, and any history of respiratory-system dysfunction
- Physical examination with emphasis on the respiratory system
- Physical examination of the skin for rashes
- Pulmonary function tests per ATS guidelines: forced vital capacity (FVC) and forced expiratory volume in 1 second (FEV₁)
- Standardized BeLPT (or equivalent test) at the first examination
- Low-dose CT scan when recommended by the PLHCP after considering exposure history and other risk factors
- Any other test deemed appropriate by the PLHCP
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: At least every 2 years.
- Medical and work history with emphasis on past and present airborne exposure to or dermal contact with beryllium, smoking history, and any history of respiratory-system dysfunction
- Physical examination with emphasis on the respiratory system
- Physical examination of the skin for rashes
- Pulmonary function tests per ATS guidelines (FVC, FEV₁)
- Standardized BeLPT (or equivalent) at least every 2 years, unless the employee is confirmed positive
- Low-dose CT scan when recommended by the PLHCP
- Any other test deemed appropriate by the PLHCP
🚪 Exit / Termination
At termination of employment for an employee meeting an eligibility criterion
- Termination medical examination — required unless a beryllium medical exam was provided during the 6 months prior to termination
- Standardized BeLPT (per exam content)
⚠ Emergency / Post-Exposure
Within 30 days after an emergency beryllium exposure, if no exam was provided within the preceding 2 years
- Medical and work history with emphasis on past and present airborne exposure to or dermal contact with beryllium, smoking history, and any history of respiratory-system dysfunction
- Physical examination (respiratory system, skin)
- Pulmonary function tests (FVC, FEV₁)
- Standardized BeLPT
- Low-dose CT scan when recommended by the PLHCP
Abnormal Results & Exposure-Event Protocols
- BeLPT result is abnormal or borderline (and the employee is not already confirmed positive) Follow-up BeLPT on abnormal/borderline result: Offer a follow-up BeLPT within 30 days of receiving the result. Tests: Follow-up standardized BeLPT
- PLHCP recommends referral, or the employee presents a medical report showing a confirmed positive finding or a CBD diagnosis CBD diagnostic center referral: With the employee's authorization, the employer offers an evaluation at a CBD diagnostic center within 30 days; the center provides a written report. Tests: CBD diagnostic-center evaluation (pulmonary function testing, bronchoalveolar lavage, transbronchial biopsy as indicated)
- Employee working at/above the AL who provides a written medical report of a confirmed positive beryllium-sensitization finding or a CBD diagnosis, OR receives a written PLHCP/physician recommendation for removal Medical Removal Protection: Remove the employee from beryllium exposure. The employer either transfers the employee to comparable work below the AL (if available and the employee is qualified or can be trained within one month) or maintains the employee's base earnings, seniority, and other rights/benefits for 6 months from the time of removal, or until comparable below-AL work becomes available, whichever comes first. Tests: Continued medical surveillance per the standard during removal
Reporting Requirements
| Who performs the evaluation | PLHCP for the exam; a licensed physician authors the written medical report; CBD diagnostic center for CBD evaluation |
|---|---|
| Reported to employer | Within 45 days, a written medical opinion containing only the date of the exam, a statement that the exam met the standard, any recommended PPE/respirator limitations, and confirmation that the PLHCP explained the results to the employee. Any further content (exposure limitations, CBD-center referral, removal recommendation) is included ONLY with the employee's written authorization. |
| Reported to / for the employee | Within 45 days, a written medical report from the licensed physician containing exam results, any detected CBD/sensitization or related condition, recommendations (respirator/PPE/exposure limits), and — if confirmed positive or CBD — a recommendation for CBD-center referral, continued surveillance, and medical removal. Employee also receives a copy of the employer opinion within 45 days; CBD-center report copy within 30 days. |
| Time limits | Written medical report to the employee and written opinion to the employer within 45 days of the exam; CBD diagnostic-center report within 30 days. |
| Second-opinion / multi-physician review | No formal multiple-physician review; the CBD diagnostic-center evaluation serves as the specialist confirmation pathway. |
| Recordkeeping | Records maintained per 8 CCR 3204, including written medical opinions. Mirrors federal 1926.1124 and CA GI 5205. |
Federal vs. California: Aligned. California (5205 GI, 1535.1 construction) adopted the federal beryllium standard (1910.1024 / 1926.1124) with no substantive medical-surveillance difference: AL 0.1 µg/m³, PEL 0.2 µg/m³, STEL 2.0 µg/m³; initial within 30 days (unless exam within 2 years), biennial periodic, standardized BeLPT at first exam and every 2 years with a 30-day follow-up BeLPT on abnormal results, PFTs, and low-dose CT when recommended; CBD diagnostic-center referral pathway; and Medical Removal Protection with a 6-month benefit period (verified identical in CA 5205 and 1535.1). Note section number is 5205 (not 5203).
Asbestos
Fibrogenic DustsAsbestos causes asbestosis, lung cancer, and mesothelioma; affects workers in construction/demolition, shipyards, insulation, brake/friction work, and abatement.
Federal OSHA osha.gov
General Industry
| PEL | 0.1 fiber/cc (8-hr TWA); excursion limit 1.0 fiber/cc averaged over 30 minutes |
|---|---|
| Covered | All employees exposed at or above the TWA and/or excursion limit [1910.1001(l)(1)(i)] |
| Physician Type | Licensed physician (employer-selected) |
| Removal (MRP) | No medical removal protection scheme. The physician's written opinion conveys increased-risk findings and PPE/respirator limitations. |
🩺 Baseline / Pre-Placement
Pre-placement, before assignment to an asbestos-exposed occupation
- Medical and work history
- respiratory disease standardized questionnaire (Part 1) — A standardized questionnaire about breathing symptoms, smoking history, and past job exposures ⓘ
- Complete physical examination of all systems — emphasis on the respiratory system, cardiovascular system, and digestive tract
- chest roentgenogram (posterior-anterior; 14×17-inch or other reasonably-sized standard film or digital) — Chest X-ray (29 CFR 1910.1001 Appendix E) ⓘ
- Pulmonary function tests — forced vital capacity (FVC) and forced expiratory volume in one second (FEV1)
- Any additional tests deemed appropriate by the examining physician
🕒 Periodic / Routine
Interval-based while covered (covered-status triggered) — NOT result-triggered
Schedule: Made available annually [1910.1001(l)(3)(i)]; chest X-ray at the frequency set by Table 1 (age × years since first exposure) — table shown in this section.
- Medical and work history
- respiratory disease standardized questionnaire (Part 2) — A standardized questionnaire about breathing symptoms, smoking history, and past job exposures ⓘ
- Complete physical examination of all systems — emphasis on the respiratory system, cardiovascular system, and digestive tract
- chest roentgenogram (posterior-anterior; 14×17-inch or other reasonably-sized standard film or digital) — Chest X-ray (29 CFR 1910.1001 Appendix E) ⓘ
- Pulmonary function tests — forced vital capacity (FVC) and forced expiratory volume in one second (FEV1)
- Any additional tests deemed appropriate by the examining physician
🚪 Exit / Termination
At termination of employment, for employees exposed at or above the TWA and/or excursion limit [1910.1001(l)(4)(i)]
- Termination medical examination within 30 calendar days before or after termination
- Medical and work history
- respiratory disease standardized questionnaire (Part 2) — A standardized questionnaire about breathing symptoms, smoking history, and past job exposures ⓘ
- Complete physical examination of all systems — emphasis on the respiratory system, cardiovascular system, and digestive tract
- chest roentgenogram (posterior-anterior; 14×17-inch or other reasonably-sized standard film or digital) — Chest X-ray (29 CFR 1910.1001) ⓘ
- Pulmonary function tests (FVC, FEV1)
- Any additional tests deemed appropriate by the examining physician
Reporting Requirements
| Who performs the evaluation | Licensed physician (employer-selected) |
|---|---|
| Reported to employer | Written opinion limited to: whether the employee has any detected medical condition that places them at increased risk of material health impairment from asbestos; any recommended limitations on the employee's use of personal protective equipment/respirators; a statement that the employee has been informed of the results of the medical examination; and a statement that the employee has been informed of the increased risk of lung cancer attributable to the combined effect of smoking and asbestos exposure. The opinion must NOT reveal specific findings or diagnoses unrelated to asbestos exposure. |
| Reported to / for the employee | Employee informed by the physician of the examination results and of the increased lung-cancer risk from combined smoking and asbestos exposure; employer furnishes a copy of the written opinion to the employee. Smoking-cessation program information (names, addresses, phone numbers of public health organizations) is provided as part of training. |
| Time limits | Employer must provide a copy of the physician's written opinion to the affected employee within 30 days of receipt [1910.1001(l)(7)(iii)]. |
| Second-opinion / multi-physician review | Standard does not establish a formal multiple-physician review mechanism; the employer selects the examining physician. |
| Recordkeeping | Medical surveillance records retained for the duration of employment plus 30 years [1910.1001(m)(3)(iii)]. |
Construction
| PEL | 0.1 fiber/cc (8-hr TWA); excursion limit 1.0 fiber/cc averaged over 30 minutes |
|---|---|
| Covered | Employees who, for a combined total of 30 or more days per year, engage in Class I, II, or III work or are exposed at or above the PEL [1926.1101(m)(1)(i)(A)] — days with one hour or less of Class II/III work on intact material under full required work practices do not count toward the 30 days. Employees otherwise required to wear a negative-pressure respirator must be determined physically able to perform the work and use the equipment, under the supervision of a physician [1926.1101(m)(1)(i)(B)] |
| Physician Type | Licensed physician (employer-selected) |
| Removal (MRP) | No medical removal protection scheme. The physician's written opinion conveys increased-risk findings and PPE/respirator limitations. |
🩺 Baseline / Pre-Placement
Prior to assignment to an area where negative-pressure respirators are worn [1926.1101(m)(2)(i)(A)]; otherwise within 10 working days following the 30th day of exposure [1926.1101(m)(2)(i)(B)]
- Medical and work history — special emphasis on the pulmonary, cardiovascular, and gastrointestinal systems
- respiratory disease standardized questionnaire (Part 1) — A standardized questionnaire about breathing symptoms, smoking history, and past job exposures ⓘ
- Physical examination directed to the pulmonary and gastrointestinal systems
- chest roentgenogram (at the discretion of the physician; posterior-anterior, 14×17-inch or other reasonably-sized standard film or digital) — Chest X-ray (29 CFR 1926.1101 Appendix E) ⓘ
- Pulmonary function tests — forced vital capacity (FVC) and forced expiratory volume at one second (FEV1)
- Any other examinations or tests deemed necessary by the examining physician
🕒 Periodic / Routine
Interval-based while covered (covered-status triggered) — NOT result-triggered
Schedule: At least annually [1926.1101(m)(2)(i)(C)]; chest X-ray administered at the discretion of the physician — 1926.1101 contains no X-ray frequency table.
- Medical and work history — special emphasis on the pulmonary, cardiovascular, and gastrointestinal systems
- respiratory disease standardized questionnaire (Part 2) — A standardized questionnaire about breathing symptoms, smoking history, and past job exposures ⓘ
- Physical examination directed to the pulmonary and gastrointestinal systems
- chest roentgenogram (at the discretion of the physician; posterior-anterior, 14×17-inch or other reasonably-sized standard film or digital) — Chest X-ray (29 CFR 1926.1101 Appendix E) ⓘ
- Pulmonary function tests — forced vital capacity (FVC) and forced expiratory volume at one second (FEV1)
- Any other examinations or tests deemed necessary by the examining physician
Reporting Requirements
| Who performs the evaluation | Licensed physician (employer-selected) |
|---|---|
| Reported to employer | Written opinion limited to: whether the employee has any detected medical condition that places them at increased risk of material health impairment from asbestos; any recommended limitations on the employee's use of personal protective equipment/respirators; a statement that the employee has been informed of the results of the medical examination; and a statement that the employee has been informed of the increased risk of lung cancer attributable to the combined effect of smoking and asbestos exposure. The opinion must NOT reveal specific findings or diagnoses unrelated to asbestos exposure. |
| Reported to / for the employee | Employee informed by the physician of the examination results and of the increased lung-cancer risk from combined smoking and asbestos exposure; employer furnishes a copy of the written opinion to the employee. Smoking-cessation program information (names, addresses, phone numbers of public health organizations) is provided as part of training. |
| Time limits | Employer must provide a copy of the physician's written opinion to the affected employee within 30 days from its receipt [1926.1101(m)(4)(iii)]. |
| Second-opinion / multi-physician review | Standard does not establish a formal multiple-physician review mechanism; the employer selects the examining physician. |
| Recordkeeping | Medical surveillance records retained for the duration of employment plus 30 years, in accordance with 29 CFR 1910.1020 [1926.1101(n)(3)(iii)]. The record must include a copy of the employee's medical examination results, including the medical history, questionnaire responses, test results, and physician's recommendations [1926.1101(n)(3)(ii)(B)]. |
Shipyard / Maritime
| PEL | 0.1 fiber/cc (8-hr TWA); excursion limit 1.0 fiber/cc averaged over 30 minutes |
|---|---|
| Covered | Employees who, for a combined total of 30 or more days per year, engage in Class I, II, or III work or are exposed at or above the PEL [1915.1001(m)(1)(i)(A)] — days with one hour or less of Class II/III work on intact material under full required work practices do not count toward the 30 days. Employees otherwise required to wear a negative-pressure respirator must be determined physically able to perform the work and use the equipment, under the supervision of a physician [1915.1001(m)(1)(i)(B)] |
| Physician Type | Licensed physician (employer-selected) |
| Removal (MRP) | No medical removal protection scheme. The physician's written opinion conveys increased-risk findings and PPE/respirator limitations. |
🩺 Baseline / Pre-Placement
Prior to assignment to an area where negative-pressure respirators are worn [1915.1001(m)(2)(i)(A)]; otherwise within 10 working days following the 30th day of exposure [1915.1001(m)(2)(i)(B)]
- Medical and work history — special emphasis on the pulmonary, cardiovascular, and gastrointestinal systems
- respiratory disease standardized questionnaire (Part 1) — A standardized questionnaire about breathing symptoms, smoking history, and past job exposures ⓘ
- Physical examination directed to the pulmonary and gastrointestinal systems
- chest roentgenogram (at the discretion of the physician; posterior-anterior, 14×17-inch or other reasonably-sized standard film or digital) — Chest X-ray (29 CFR 1915.1001 Appendix E) ⓘ
- Pulmonary function tests — forced vital capacity (FVC) and forced expiratory volume at one second (FEV1)
- Any other examinations or tests deemed necessary by the examining physician
🕒 Periodic / Routine
Interval-based while covered (covered-status triggered) — NOT result-triggered
Schedule: At least annually [1915.1001(m)(2)(i)(C)]; chest X-ray administered at the discretion of the physician — 1915.1001 contains no X-ray frequency table.
- Medical and work history — special emphasis on the pulmonary, cardiovascular, and gastrointestinal systems
- respiratory disease standardized questionnaire (Part 2) — A standardized questionnaire about breathing symptoms, smoking history, and past job exposures ⓘ
- Physical examination directed to the pulmonary and gastrointestinal systems
- chest roentgenogram (at the discretion of the physician; posterior-anterior, 14×17-inch or other reasonably-sized standard film or digital) — Chest X-ray (29 CFR 1915.1001 Appendix E) ⓘ
- Pulmonary function tests — forced vital capacity (FVC) and forced expiratory volume at one second (FEV1)
- Any other examinations or tests deemed necessary by the examining physician
Reporting Requirements
| Who performs the evaluation | Licensed physician (employer-selected) |
|---|---|
| Reported to employer | Written opinion limited to: whether the employee has any detected medical condition that places them at increased risk of material health impairment from asbestos; any recommended limitations on the employee's use of personal protective equipment/respirators; a statement that the employee has been informed of the results of the medical examination; and a statement that the employee has been informed of the increased risk of lung cancer attributable to the combined effect of smoking and asbestos exposure. The opinion must NOT reveal specific findings or diagnoses unrelated to asbestos exposure. |
| Reported to / for the employee | Employee informed by the physician of the examination results and of the increased lung-cancer risk from combined smoking and asbestos exposure; employer furnishes a copy of the written opinion to the employee. Smoking-cessation program information (names, addresses, phone numbers of public health organizations) is provided as part of training. |
| Time limits | Employer must provide a copy of the physician's written opinion to the affected employee within 30 days from its receipt [1915.1001(m)(4)(iii)]. |
| Second-opinion / multi-physician review | Standard does not establish a formal multiple-physician review mechanism; the employer selects the examining physician. |
| Recordkeeping | Medical surveillance records retained for the duration of employment plus 30 years, in accordance with 29 CFR 1910.1020 [1915.1001(n)(3)(iii)]. The record must include a copy of the employee's medical examination results, including the medical history, questionnaire responses, test results, and physician's recommendations [1915.1001(n)(3)(ii)(B)]. |
Cal/OSHA dir.ca.gov
General Industry
| PEL | 0.1 fiber/cc (8-hr TWA); excursion limit 1.0 fiber/cc over 30 minutes [5208(c)] |
|---|---|
| Covered | All employees exposed at/above the TWA and/or excursion limit [5208(l)(1)(A)] |
| Physician Type | Licensed physician (employer-selected) |
| Removal (MRP) | No medical removal protection scheme; physician's written opinion conveys increased-risk findings and limitations. |
🩺 Baseline / Pre-Placement
Pre-placement, before assignment to an asbestos-exposed occupation
- Medical and work history
- respiratory disease standardized questionnaire (Part 1) — A standardized questionnaire about breathing symptoms, smoking history, and past job exposures ⓘ
- Complete physical examination of all systems — emphasis on the respiratory system, cardiovascular system, and digestive tract
- chest roentgenogram (in accordance with Table 2) — Chest X-ray (8 CCR 5208 Appendix E) ⓘ
- Pulmonary function tests — forced vital capacity (FVC) and forced expiratory volume in one second (FEV1)
- Any additional tests deemed appropriate by the examining physician
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: Made available annually [5208(l)(3)(A)]; chest X-ray at the Table 2 frequency (age × years since first exposure) — table shown in this section.
- Medical and work history
- respiratory disease standardized questionnaire (Part 2) — A standardized questionnaire about breathing symptoms, smoking history, and past job exposures ⓘ
- Complete physical examination of all systems — emphasis on the respiratory system, cardiovascular system, and digestive tract
- chest roentgenogram (in accordance with Table 2; oblique x-rays need only be performed every 3 years (Table 2 footnote)) — Chest X-ray (8 CCR 5208 Appendix E) ⓘ
- Pulmonary function tests — forced vital capacity (FVC) and forced expiratory volume in one second (FEV1)
- Any additional tests deemed appropriate by the examining physician
🚪 Exit / Termination
At termination of employment, for employees exposed at or above the TWA and/or excursion limit [5208(l)(4)(A)]
- Termination medical examination within 30 calendar days before or after termination, in accordance with the periodic-examination requirements [5208(l)(4)(B)]
- Medical and work history
- respiratory disease standardized questionnaire (Part 2) — A standardized questionnaire about breathing symptoms, smoking history, and past job exposures ⓘ
- Complete physical examination of all systems — emphasis on the respiratory system, cardiovascular system, and digestive tract
- chest roentgenogram (in accordance with Table 2) — Chest X-ray (8 CCR 5208) ⓘ
- Pulmonary function tests (FVC, FEV1)
- Any additional tests deemed appropriate by the examining physician
Reporting Requirements
| Who performs the evaluation | Licensed physician (employer-selected) |
|---|---|
| Reported to employer | Written opinion limited to: whether the employee has any detected medical condition placing them at increased risk from asbestos; recommended PPE/respirator limitations; a statement that the employee was informed of exam results; and a statement that the employee was informed of the increased lung-cancer risk from combined smoking and asbestos exposure. Unrelated findings must not be revealed. |
| Reported to / for the employee | Employee informed of exam results and of the increased smoking+asbestos lung-cancer risk; furnished a copy of the written opinion. Smoking-cessation resources provided via training. |
| Time limits | Employer shall provide a copy of the physician's written opinion to the affected employee within 30 days of its receipt [5208(l)(7)(C)]. |
| Second-opinion / multi-physician review | No formal multiple-physician review mechanism specified. |
| Recordkeeping | Medical surveillance records maintained for the duration of employment plus thirty (30) years, in accordance with Section 3204 [5208(m)(3)(C)]. |
Construction
| PEL | 0.1 fiber/cc (8-hr TWA); excursion limit 1.0 fiber/cc over 30 minutes [1529(c)(1)/(c)(2)] |
|---|---|
| Covered | Employees who, for a combined total of 30 or more days per year, engage in Class I, II, or III work or are exposed at or above the PEL [1529(m)(1)(A)1.] — days with one hour or less of Class II/III work on intact material under full required work practices do not count toward the 30 days. Employees otherwise required to wear a negative-pressure respirator must be determined physically able to perform the work and use the equipment, under the supervision of a physician [1529(m)(1)(A)2.] |
| Physician Type | Licensed physician (employer-selected) |
| Removal (MRP) | No medical removal protection scheme; physician's written opinion includes an increased-risk determination [1529(m)(4)(A)]. |
🩺 Baseline / Pre-Placement
Prior to assignment to an area where negative-pressure respirators are worn [1529(m)(2)(A)1.]; otherwise within 10 working days following the 30th day of exposure [1529(m)(2)(A)2.]
- Medical and work history — special emphasis on the pulmonary, cardiovascular, and gastrointestinal systems
- respiratory disease standardized questionnaire (Part 1) — A standardized questionnaire about breathing symptoms, smoking history, and past job exposures ⓘ
- Physical examination directed to the pulmonary and gastrointestinal systems
- chest roentgenogram (administered in accordance with Table 2) — Chest X-ray (8 CCR 1529 Appendix E) ⓘ
- Pulmonary function tests — forced vital capacity (FVC) and forced expiratory volume at one second (FEV1)
- Any other examinations or tests deemed necessary by the examining physician
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: At least annually [1529(m)(2)(A)3.]; chest X-ray at the Table 2 frequency (age × years since first exposure) — table shown in this section.
- Medical and work history — special emphasis on the pulmonary, cardiovascular, and gastrointestinal systems
- respiratory disease standardized questionnaire (Part 2) — A standardized questionnaire about breathing symptoms, smoking history, and past job exposures ⓘ
- Physical examination directed to the pulmonary and gastrointestinal systems
- chest roentgenogram (administered in accordance with Table 2; oblique x-rays need only be performed every 3 years (Table 2 footnote)) — Chest X-ray (8 CCR 1529 Appendix E) ⓘ
- Pulmonary function tests — forced vital capacity (FVC) and forced expiratory volume at one second (FEV1)
- Any other examinations or tests deemed necessary by the examining physician
🚪 Exit / Termination
At termination of employment, for employees exposed at or above the PEL and/or excursion limit [1529(m)(2)(A)6.]. 1529 does not prescribe specific content for the termination examination (the (m)(2)(B) component list covers only pre-placement and annual examinations).
- Termination medical examination within 30 calendar days before or after termination [1529(m)(2)(A)6.]
- Medical and work history — special emphasis on the pulmonary, cardiovascular, and gastrointestinal systems
- respiratory disease standardized questionnaire (Part 2) — A standardized questionnaire about breathing symptoms, smoking history, and past job exposures ⓘ
- Physical examination directed to the pulmonary and gastrointestinal systems
- chest roentgenogram (administered in accordance with Table 2) — Chest X-ray (8 CCR 1529 Appendix E) ⓘ
- Pulmonary function tests — forced vital capacity (FVC) and forced expiratory volume at one second (FEV1)
- Any other examinations or tests deemed necessary by the examining physician
Reporting Requirements
| Who performs the evaluation | Licensed physician (employer-selected) |
|---|---|
| Reported to employer | Written opinion limited to: increased-risk determination from asbestos exposure; recommended PPE/respirator limitations; statement that the employee was informed of results and of the increased smoking+asbestos lung-cancer risk. Unrelated findings must not be revealed. |
| Reported to / for the employee | Employee informed of results and increased smoking+asbestos risk; furnished a copy of the written opinion. |
| Time limits | Employer shall provide a copy of the physician's written opinion to the affected employee within 30 days of its receipt [1529(m)(4)(C)]. |
| Second-opinion / multi-physician review | No formal multiple-physician review mechanism specified. |
| Recordkeeping | Medical records maintained for the duration of employment plus thirty (30) years, in accordance with Section 3204 [1529(n)(3)(C)]. The record must include a copy of the employee's medical examination results, including the medical history, questionnaire responses, results of any tests, and physician's recommendations [1529(n)(3)(B)2.]. |
Shipyard / Maritime
| PEL | 0.1 fiber/cc (8-hr TWA) [8358(c)(1)]; excursion limit 1.0 fiber/cc over 30 minutes [8358(c)(2)] |
|---|---|
| Covered | Employees who, for a combined total of 30 or more days per year, engage in Class I, II, or III work or are exposed at or above the PEL [8358(m)(1)(A)1.] — days with one hour or less of Class II/III work on intact material under full required work practices do not count toward the 30 days. Employees otherwise required to wear a negative-pressure respirator must be determined physically able to perform the work and use the equipment, under the supervision of a physician [8358(m)(1)(A)2.] |
| Physician Type | Licensed physician (employer-selected) |
| Removal (MRP) | No medical removal protection scheme; physician's written opinion conveys increased-risk findings and limitations. |
🩺 Baseline / Pre-Placement
Prior to assignment to an area where negative-pressure respirators are worn [8358(m)(2)(A)1.]; otherwise within 10 working days following the 30th day of exposure [8358(m)(2)(A)2.]
- Medical and work history — special emphasis on the pulmonary, cardiovascular, and gastrointestinal systems
- respiratory disease standardized questionnaire (Part 1) — A standardized questionnaire about breathing symptoms, smoking history, and past job exposures ⓘ
- Physical examination directed to the pulmonary and gastrointestinal systems
- chest roentgenogram (administered in accordance with Table 2) — Chest X-ray (8 CCR 8358 Appendix E) ⓘ
- Pulmonary function tests — forced vital capacity (FVC) and forced expiratory volume at one second (FEV1)
- Any other examinations or tests deemed necessary by the examining physician
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: At least annually [8358(m)(2)(A)3.]; chest X-ray at the Table 2 frequency (age × years since first exposure) — table shown in this section.
- Medical and work history — special emphasis on the pulmonary, cardiovascular, and gastrointestinal systems
- respiratory disease standardized questionnaire (Part 2) — A standardized questionnaire about breathing symptoms, smoking history, and past job exposures ⓘ
- Physical examination directed to the pulmonary and gastrointestinal systems
- chest roentgenogram (administered in accordance with Table 2; oblique x-rays need only be performed every 3 years (Table 2 footnote)) — Chest X-ray (8 CCR 8358 Appendix E) ⓘ
- Pulmonary function tests — forced vital capacity (FVC) and forced expiratory volume at one second (FEV1)
- Any other examinations or tests deemed necessary by the examining physician
🚪 Exit / Termination
At termination of employment — applies to all covered employees (no exposure qualifier) [8358(m)(2)(A)5.]. 8358 does not prescribe specific content for the termination examination (the (m)(2)(B) component list covers only pre-placement and annual examinations).
- Termination medical examination within 30 calendar days before or after termination [8358(m)(2)(A)5.]
- Medical and work history — special emphasis on the pulmonary, cardiovascular, and gastrointestinal systems
- respiratory disease standardized questionnaire (Part 2) — A standardized questionnaire about breathing symptoms, smoking history, and past job exposures ⓘ
- Physical examination directed to the pulmonary and gastrointestinal systems
- chest roentgenogram (administered in accordance with Table 2) — Chest X-ray (8 CCR 8358 Appendix E) ⓘ
- Pulmonary function tests — forced vital capacity (FVC) and forced expiratory volume at one second (FEV1)
- Any other examinations or tests deemed necessary by the examining physician
Reporting Requirements
| Who performs the evaluation | Licensed physician (employer-selected) |
|---|---|
| Reported to employer | Written opinion limited to: whether the employee has any detected medical condition placing them at increased risk from asbestos; recommended PPE/respirator limitations; a statement that the employee was informed of exam results and of the increased smoking+asbestos lung-cancer risk [8358(m)(4)(A)]. Unrelated findings must not be revealed. |
| Reported to / for the employee | Employee informed of exam results and of the increased smoking+asbestos lung-cancer risk; furnished a copy of the written opinion. |
| Time limits | Employer shall provide a copy of the physician's written opinion to the affected employee within 30 days of its receipt [8358(m)(4)(C)]. |
| Second-opinion / multi-physician review | No formal multiple-physician review mechanism specified. |
| Recordkeeping | Medical records maintained for the duration of employment plus thirty (30) years, in accordance with Section 3204 [8358(n)(3)(C)]. The record must include a copy of the employee's medical examination results, including the medical history, questionnaire responses, results of any tests, and physician's recommendations [8358(n)(3)(B)2.]. |
Federal vs. California: General industry standards are substantively aligned — same 0.1 f/cc PEL and 1.0 f/cc excursion limit, the same Appendix D respiratory questionnaire (Part 1 initial / Part 2 periodic), ILO-classified chest X-ray (Appendix E; standard film or digital), periodic examinations made available annually, and a termination exam within 30 calendar days of termination. They differ on chest X-ray frequency: federal Table 1 (1910.1001 only) reaches annual films only at age 45+ with 10+ years since first exposure (every other combination is every 5 years, except every 2 years at age 35+–45 with 10+ years), while California Table 2 requires annual films for every combination except employees under 40 with under 10 years since first exposure (every 3 years), and — California only — oblique x-rays need only be performed every 3 years. Outside general industry the gap widens: the federal construction (1926.1101) and shipyard (1915.1001) standards leave the chest X-ray to the physician's discretion, contain no X-ray frequency table, and require no termination examination, whereas all three California sections — 8 CCR 5208 (general industry), 1529 (construction), and 8358 (ship repairing, shipbuilding, and shipbreaking) — administer the X-ray in accordance with Table 2 and require a termination examination (examination content is prescribed only in 5208). Construction/shipyard coverage triggers match across jurisdictions: a combined total of 30+ days per year of Class I/II/III work or exposure at/above the PEL, plus a physician-supervised physical-ability determination for employees otherwise required to wear a negative-pressure respirator.
Definitions & Reference Tables
Table 2 — Frequency of chest X-ray (Cal/OSHA) 8 CCR 5208 Table 2; 8 CCR 1529 Table 2; 8 CCR 8358 Table 2
| Years since first exposure | Age under 40 | Age 40 and older |
|---|---|---|
| 0 to 10 years | Every 3 years | Every year |
| 10 or more years | Every year | Every year |
Oblique x-rays need only be performed every 3 years (Table 2 footnote, verbatim). Table 2 governs the pre-placement chest roentgenogram as well as periodic frequency.
Table 1 — Frequency of chest X-ray (Federal OSHA) 29 CFR 1910.1001, Table 1
| Age | 0 to 10 years since first exposure | 10 or more years since first exposure |
|---|---|---|
| 15 to 35 | Every 5 years | Every 5 years |
| 35+ to 45 | Every 5 years | Every 2 years |
| 45+ | Every 5 years | Every 1 year |
Applies to the general industry standard (1910.1001) only — the construction (1926.1101) and shipyard (1915.1001) standards contain no X-ray frequency table; there, the chest X-ray is administered at the discretion of the physician. The periodic examination itself is made available annually.
Appendix E — How the chest X-ray is read (B-reader / ILO) 29 CFR 1910.1001 / 1926.1101 / 1915.1001 App. E; 8 CCR 5208 / 1529 / 8358 App. E
The chest film is read by a physician certified by NIOSH as a "B-reader" and graded on the ILO International Classification 0-3 scale for small opacities and pleural changes. This standardized reading is what distinguishes the required film from an ordinary chest X-ray. Standard film or digital images are acceptable.
Appendix D — Standardized respiratory symptoms questionnaire 29 CFR 1910.1001 / 1926.1101 / 1915.1001 App. D; 8 CCR 5208 / 1529 / 8358 App. D
A standardized respiratory-symptom questionnaire (initial and periodic versions) covering shortness of breath, cough, phlegm, wheeze, chest illness, smoking history, and occupational exposure history. The physician administers it to detect early respiratory impairment.
Respirable Crystalline Silica
Fibrogenic DustsRespirable crystalline silica causes silicosis, lung cancer, COPD, and kidney disease; affects workers in construction, foundries, stone/countertop fabrication, sandblasting, and mining.
Federal OSHA osha.gov
General Industry
| Action Level | 25 µg/m³ (8-hr TWA) |
|---|---|
| PEL | 50 µg/m³ (8-hr TWA) |
| Covered | Each employee occupationally exposed at/above the action level for 30+ days/year [1910.1053(i)(1)(i)] |
| Physician Type | PLHCP (physician or other licensed health care professional); specialist (pulmonologist/B-Reader) on referral |
| Removal (MRP) | No medical removal protection scheme. Escalation is a specialist referral when the chest X-ray is classified 1/0 or higher. |
🩺 Baseline / Pre-Placement
Within 30 days of initial assignment, unless a qualifying exam was provided within the prior 3 years
- Medical and work history — current/past silica exposure, respiratory symptoms (shortness of breath, cough, wheezing), history of tuberculosis, and smoking status
- Physical examination with special emphasis on the respiratory system
- Chest X-ray (single PA radiograph) classified per the ILO International Classification by a NIOSH-certified B Reader
- Pulmonary function test — FVC, FEV1, and FEV1/FVC ratio, administered by a technician with a current NIOSH-approved spirometry course certificate
- Testing for latent tuberculosis infection [29 CFR 1910.1053(i)(2)(v)] — satisfied by a TB skin test (Mantoux tuberculin skin test/TST, historically PPD) or an interferon-gamma release assay (IGRA) blood test: QuantiFERON-TB Gold Plus (QFT-Plus) or T-SPOT.TB
- Any other tests deemed appropriate by the PLHCP
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: At least every 3 years (or more frequently if recommended by the PLHCP).
- Medical and work history (past/current silica exposure, respiratory symptoms, TB history, smoking status)
- Physical examination with emphasis on the respiratory system
- Chest X-ray — single posteroanterior radiographic projection, interpreted and classified per ILO International Classification by a NIOSH-certified B Reader
- Pulmonary function test — FVC, FEV1, and FEV1/FVC ratio by a spirometry technician with current NIOSH-approved certification
- Any other tests deemed appropriate by the PLHCP
- Note: latent TB testing is NOT required at periodic exams (excluded per 1910.1053(i)(3))
Abnormal Results & Exposure-Event Protocols
- Chest X-ray classified as 1/0 or higher by the B Reader, OR referral otherwise deemed appropriate by the PLHCP 1910.1053(i)(7) (parallel CA provisions): Refer the employee to a specialist (e.g., a pulmonary specialist / B-Reader specialist). The specialist examination must be made available within 30 days after the PLHCP's written opinion. (A low-dose CT is NOT a codified requirement; it may be ordered at the specialist's discretion.) Tests: Specialist examination, Specialist may order additional studies at their discretion
Reporting Requirements
| Who performs the evaluation | PLHCP (physician or other licensed health care professional); specialist referral on abnormal X-ray |
|---|---|
| Reported to employer | Written medical opinion within 30 days of the examination, limited to: the date of the exam; a statement that the exam met the requirements of the section; and any recommended respirator-use limitations. Exposure limitations and the specialist-referral statement are included ONLY with the employee's written authorization. |
| Reported to / for the employee | PLHCP's written medical report furnished to the employee within 30 days of each examination, including: exam results and any condition placing the employee at increased risk; recommended respirator-use and exposure limitations; and a statement (if applicable) that the employee should be examined by a specialist because the chest X-ray was classified 1/0 or higher. |
| Time limits | Written medical report to employee within 30 days of each examination [1910.1053(i)(5)]; written medical opinion to employer within 30 days of each examination [1910.1053(i)(6)]; specialist examination must be made available within 30 days of receiving the PLHCP's written opinion recommending specialist referral [1910.1053(i)(7)]. |
| Second-opinion / multi-physician review | No formal multiple-physician dispute mechanism; abnormal-result specialist referral is the codified escalation. |
| Recordkeeping | Medical surveillance records retained for the duration of employment plus 30 years (per 29 CFR 1910.1020). |
Construction
| Action Level | 25 µg/m³ (8-hr TWA) |
|---|---|
| PEL | 50 µg/m³ (8-hr TWA) |
| Covered | Each employee required to use a respirator for 30+ days/year (respirator-based trigger, NOT action-level based — differs from general industry) [1926.1153(h)(1)(i)] |
| Physician Type | PLHCP (physician or other licensed health care professional); specialist (pulmonologist/B-Reader) on referral |
| Removal (MRP) | No medical removal protection scheme. Escalation is a specialist referral when the chest X-ray is classified 1/0 or higher. |
🩺 Baseline / Pre-Placement
Within 30 days of initial assignment, unless a qualifying exam was provided within the prior 3 years
- Medical and work history — current/past silica exposure, respiratory symptoms (shortness of breath, cough, wheezing), history of tuberculosis, and smoking status
- Physical examination with special emphasis on the respiratory system
- Chest X-ray (single PA radiograph) classified per the ILO International Classification by a NIOSH-certified B Reader
- Pulmonary function test — FVC, FEV1, and FEV1/FVC ratio, administered by a technician with a current NIOSH-approved spirometry course certificate
- Testing for latent tuberculosis infection [29 CFR 1926.1153(h)(2)(v)] — satisfied by a TB skin test (Mantoux tuberculin skin test/TST, historically PPD) or an interferon-gamma release assay (IGRA) blood test: QuantiFERON-TB Gold Plus (QFT-Plus) or T-SPOT.TB
- Any other tests deemed appropriate by the PLHCP
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: At least every 3 years (or more frequently if recommended by the PLHCP).
- Medical and work history (respiratory symptoms, smoking status)
- Physical examination with emphasis on the respiratory system
- Chest X-ray classified per ILO by a NIOSH-certified B Reader
- Pulmonary function test — FVC, FEV1, FEV1/FVC ratio by a certified spirometry technician
- Any other tests deemed appropriate by the PLHCP
Abnormal Results & Exposure-Event Protocols
- Chest X-ray classified as 1/0 or higher by the B Reader, OR referral otherwise deemed appropriate by the PLHCP 1926.1153(h)(7) [mirrors 1910.1053(i)(7)]: Refer the employee to a specialist (e.g., a pulmonary specialist / B-Reader specialist). The specialist examination must be made available within 30 days after the PLHCP's written opinion. (A low-dose CT is NOT a codified requirement; it may be ordered at the specialist's discretion.) Tests: Specialist examination, Specialist may order additional studies at their discretion
Reporting Requirements
| Who performs the evaluation | PLHCP (physician or other licensed health care professional); specialist referral on abnormal X-ray |
|---|---|
| Reported to employer | Written medical opinion within 30 days of the examination, limited to: the date of the exam; a statement that the exam met the requirements of the section; and any recommended respirator-use limitations. Exposure limitations and the specialist-referral statement are included ONLY with the employee's written authorization. |
| Reported to / for the employee | PLHCP's written medical report furnished to the employee within 30 days of each examination, including: exam results and any condition placing the employee at increased risk; recommended respirator-use and exposure limitations; and a statement (if applicable) that the employee should be examined by a specialist because the chest X-ray was classified 1/0 or higher. |
| Time limits | Written report to employee within 30 days of each exam [(i)(5)]; written opinion to employer within 30 days of the exam [(i)(6)]; specialist exam available within 30 days after the PLHCP's written opinion [(i)(7)]. |
| Second-opinion / multi-physician review | No formal multiple-physician dispute mechanism; abnormal-result specialist referral is the codified escalation. |
| Recordkeeping | Medical surveillance records retained for the duration of employment plus 30 years (per 29 CFR 1910.1020). |
Cal/OSHA dir.ca.gov
General Industry
| Action Level | 25 µg/m³ (8-hr TWA) |
|---|---|
| PEL | 50 µg/m³ (8-hr TWA) |
| Covered | Exposed at/above the action level for 30+ days/year [5204(j)(2)(B)]. (5204 covers general industry/maritime; construction is excluded and covered under 1532.3.) |
| Physician Type | PLHCP (physician or other licensed health care professional); specialist (pulmonologist/B-Reader) on referral |
| Removal (MRP) | No medical removal protection scheme. Escalation is a specialist referral when the chest X-ray is classified 1/0 or higher. |
🩺 Baseline / Pre-Placement
Within 30 days of initial assignment, unless a qualifying exam was provided within the prior 3 years
- Medical and work history — current/past silica exposure, respiratory symptoms (shortness of breath, cough, wheezing), history of tuberculosis, and smoking status
- Physical examination with special emphasis on the respiratory system
- Chest X-ray (single PA radiograph) classified per the ILO International Classification by a NIOSH-certified B Reader
- Pulmonary function test — FVC, FEV1, and FEV1/FVC ratio, administered by a technician with a current NIOSH-approved spirometry course certificate
- Testing for latent tuberculosis infection, as part of the initial medical examination only [8 CCR 5204(j)(2)(C)5] — satisfied by a TB skin test (Mantoux tuberculin skin test/TST, historically PPD) or an interferon-gamma release assay (IGRA) blood test: QuantiFERON-TB Gold Plus (QFT-Plus) or T-SPOT.TB
- Any other tests deemed appropriate by the PLHCP
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: At least every 3 years (or more frequently if recommended by the PLHCP).
- Medical and work history (respiratory symptoms, smoking status)
- Physical examination with emphasis on the respiratory system
- Chest X-ray classified per ILO by a NIOSH-certified B Reader
- Pulmonary function test — FVC, FEV1, FEV1/FVC ratio by a certified spirometry technician
- Any other tests deemed appropriate by the PLHCP
Abnormal Results & Exposure-Event Protocols
- Chest X-ray classified as 1/0 or higher by the B Reader, OR referral otherwise deemed appropriate by the PLHCP 8 CCR 5204(j)(8)(A) [parallel to federal 1910.1053(i)(7)]: Refer the employee to a specialist (e.g., a pulmonary specialist / B-Reader specialist). The specialist examination must be made available within 30 days after the PLHCP's written opinion. (A low-dose CT is NOT a codified requirement; it may be ordered at the specialist's discretion.) Tests: Specialist examination, Specialist may order additional studies at their discretion
Reporting Requirements
| Who performs the evaluation | PLHCP (physician or other licensed health care professional); specialist referral on abnormal X-ray |
|---|---|
| Reported to employer | Written medical opinion within 30 days of the examination, limited to: the date of the exam; a statement that the exam met the requirements of the section; and any recommended respirator-use limitations. Exposure limitations and the specialist-referral statement are included ONLY with the employee's written authorization. |
| Reported to / for the employee | PLHCP's written medical report furnished to the employee within 30 days of each examination, including: exam results and any condition placing the employee at increased risk; recommended respirator-use and exposure limitations; and a statement (if applicable) that the employee should be examined by a specialist because the chest X-ray was classified 1/0 or higher. |
| Time limits | Written medical report to employee within 14 days of each examination [5204(j)(6)]; written medical opinion to employer within 14 calendar days of each examination [5204(j)(7)]; specialist exam available within 30 days after the PLHCP's written opinion [5204(j)(8)(A)]. |
| Second-opinion / multi-physician review | No formal multiple-physician dispute mechanism; abnormal-result specialist referral is the codified escalation. |
| Recordkeeping | Medical surveillance records retained for the duration of employment plus 30 years (8 CCR 3204). |
Construction
| Action Level | 25 µg/m³ (8-hr TWA) |
|---|---|
| PEL | 50 µg/m³ (8-hr TWA) |
| Covered | Each employee required to use a respirator for 30+ days/year (respirator-based trigger, same as federal construction) [1532.3(h)(1)(A)] |
| Physician Type | PLHCP (physician or other licensed health care professional); specialist (pulmonologist/B-Reader) on referral |
| Removal (MRP) | No medical removal protection scheme. Escalation is a specialist referral when the chest X-ray is classified 1/0 or higher. |
🩺 Baseline / Pre-Placement
Within 30 days of initial assignment, unless a qualifying exam was provided within the prior 3 years
- Medical and work history — current/past silica exposure, respiratory symptoms (shortness of breath, cough, wheezing), history of tuberculosis, and smoking status
- Physical examination with special emphasis on the respiratory system
- Chest X-ray (single PA radiograph) classified per the ILO International Classification by a NIOSH-certified B Reader
- Pulmonary function test — FVC, FEV1, and FEV1/FVC ratio, administered by a technician with a current NIOSH-approved spirometry course certificate
- Testing for latent tuberculosis infection, as part of the initial medical examination only [8 CCR 1532.3(h)(2)(E)] — satisfied by a TB skin test (Mantoux tuberculin skin test/TST, historically PPD) or an interferon-gamma release assay (IGRA) blood test: QuantiFERON-TB Gold Plus (QFT-Plus) or T-SPOT.TB
- Any other tests deemed appropriate by the PLHCP
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: At least every 3 years (or more frequently if recommended by the PLHCP).
- Medical and work history (respiratory symptoms, smoking status)
- Physical examination with emphasis on the respiratory system
- Chest X-ray classified per ILO by a NIOSH-certified B Reader
- Pulmonary function test — FVC, FEV1, FEV1/FVC ratio by a certified spirometry technician
- Any other tests deemed appropriate by the PLHCP
Abnormal Results & Exposure-Event Protocols
- Chest X-ray classified as 1/0 or higher by the B Reader, OR referral otherwise deemed appropriate by the PLHCP 8 CCR 1532.3(h)(7) [parallel to federal 1926.1153(h)(7)]: Refer the employee to a specialist (e.g., a pulmonary specialist / B-Reader specialist). The specialist examination must be made available within 30 days after the PLHCP's written opinion. (A low-dose CT is NOT a codified requirement; it may be ordered at the specialist's discretion.) Tests: Specialist examination, Specialist may order additional studies at their discretion
Reporting Requirements
| Who performs the evaluation | PLHCP (physician or other licensed health care professional); specialist referral on abnormal X-ray |
|---|---|
| Reported to employer | Written medical opinion within 30 days of the examination, limited to: the date of the exam; a statement that the exam met the requirements of the section; and any recommended respirator-use limitations. Exposure limitations and the specialist-referral statement are included ONLY with the employee's written authorization. |
| Reported to / for the employee | PLHCP's written medical report furnished to the employee within 30 days of each examination, including: exam results and any condition placing the employee at increased risk; recommended respirator-use and exposure limitations; and a statement (if applicable) that the employee should be examined by a specialist because the chest X-ray was classified 1/0 or higher. |
| Time limits | Written medical report to employee within 30 days of each examination [1532.3(h)(5)]; written medical opinion to employer within 30 days of the examination [1532.3(h)(6)]; specialist exam available within 30 days after the PLHCP's written opinion [1532.3(h)(7)]. |
| Second-opinion / multi-physician review | No formal multiple-physician dispute mechanism; abnormal-result specialist referral is the codified escalation. |
| Recordkeeping | Medical surveillance records retained for the duration of employment plus 30 years (8 CCR 3204). |
Federal vs. California: Nearly identical — same 50/25 µg/m³ PEL/AL, same every-3-year periodic interval, same B-Reader/ILO chest X-ray plus FVC/FEV1/FEV1·FVC PFT and initial latent-TB battery, and the same 1/0 specialist-referral trigger. The general-industry (action-level trigger) vs construction (respirator trigger) split is identical in both jurisdictions. The only structural difference is that California splits silica into two sections (5204 general industry / 1532.3 construction) whereas federal uses 1910.1053 / 1926.1153. Low-dose CT is NOT a codified requirement in any silica standard.
Cotton Dust
Fibrogenic DustsCotton dust causes byssinosis (brown lung) and chronic respiratory impairment; affects workers in yarn manufacturing, cotton washing, textile waste houses, and slashing/weaving.
Federal OSHA osha.gov
General Industry
| Action Level | Yarn manufacturing/cotton washing: 100 µg/m³; textile waste houses: 250 µg/m³; slashing & weaving: 375 µg/m³ (8-hr TWA) |
|---|---|
| PEL | Yarn manufacturing & cotton washing: 200 µg/m³; textile waste/lower-grade washed cotton: 500 µg/m³; slashing & weaving: 750 µg/m³ (8-hr TWA) |
| Covered | All employees exposed to cotton dust |
| Physician Type | Licensed physician |
| Removal (MRP) | 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. |
🩺 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
- 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
- Employee's FEV1 is less than 60 percent of the predicted value 1910.1043(h)(3)(iii): Refer the employee to a physician for a detailed pulmonary examination. Tests: Detailed pulmonary examination by a physician
Reporting Requirements
| Who performs the evaluation | Licensed physician |
|---|---|
| Reported to employer | Written 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 employee | Employee informed of the examination results and of any medical condition requiring further evaluation; furnished a copy of the written opinion. |
| Time limits | The standard specifies no explicit deadline for furnishing the copy of the written opinion to the employee (see unverified note). |
| Second-opinion / multi-physician review | No formal multiple-physician review mechanism specified. |
| Recordkeeping | Medical records retained for at least 20 years [1910.1043(k)(2)(iii)]. |
Cal/OSHA dir.ca.gov
General Industry
| Action Level | Yarn manufacturing/cotton washing: 100 µg/m³; textile waste houses: 250 µg/m³; slashing & weaving: 375 µg/m³ (8-hr TWA) |
|---|---|
| PEL | Yarn manufacturing & cotton washing: 200 µg/m³; textile waste/lower-grade washed cotton: 500 µg/m³; slashing & weaving: 750 µg/m³ (8-hr TWA) |
| Covered | All employees exposed to cotton dust |
| Physician Type | Licensed physician |
| Removal (MRP) | 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. |
🩺 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
- FEV1 decrement of 5% or 200 mL on the first working day (where FEV1 is greater than 80% of predicted); OR FEV1 of less than 80 percent of the predicted value; OR a significant adverse change in questionnaire findings, pulmonary function results, or other diagnostic tests [8 CCR 5190(h)(3)(B)] 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
- Employee's FEV1 is less than 60 percent of the predicted value 8 CCR 5190(h)(3)(C): Refer the employee to a physician for a detailed pulmonary examination. Tests: Detailed pulmonary examination by a physician
Reporting Requirements
| Who performs the evaluation | Licensed physician |
|---|---|
| Reported to employer | Written 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 employee | Employee informed of the examination results and of any medical condition requiring further evaluation; furnished a copy of the written opinion. |
| Time limits | The standard specifies no explicit deadline for furnishing the copy of the written opinion to the employee (see unverified note). |
| Second-opinion / multi-physician review | No formal multiple-physician review mechanism specified. |
| Recordkeeping | Medical records retained per 8 CCR 3204 (duration of employment plus 30 years). |
Federal vs. California: 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.
Definitions & Reference Tables
Appendix B — Standardized cotton-dust respiratory/byssinosis questionnaire 29 CFR 1910.1043 App. B; 8 CCR 5190 App. B
The mandatory standardized questionnaire administered at the initial and periodic exams of cotton-dust-exposed workers. It records respiratory-symptom and smoking/occupational history and supports grading of byssinosis on the Schilling classification scale.
Coke Oven Emissions
Fibrogenic DustsCoke oven emissions (PAH-rich particulate) cause lung and kidney cancer; affects workers on coke oven batteries in steel production within regulated areas.
Federal OSHA osha.gov
General Industry
| PEL | 150 µg/m³ (benzene-soluble fraction of total particulate matter), 8-hr TWA [1910.1029(c)] |
|---|---|
| Covered | All employees employed in a regulated area at least 30 days/year [1910.1029(j)(1)(i)] |
| Physician Type | Licensed physician (employer-selected) |
| Removal (MRP) | No medical removal protection scheme; physician's written opinion conveys results, increased-risk findings, and exposure/PPE limitations. |
🩺 Baseline / Pre-Placement
At initial assignment to a regulated area [1910.1029(j)(2)]
- Work and medical history including smoking history and presence/degree of respiratory symptoms (breathlessness, cough, sputum production, wheezing)
- 14×17 (or other reasonably-sized) standard-film or digital PA chest X-ray (no ILO classification mandated federally)
- Pulmonary function test — FVC and FEV1.0
- Weight measurement
- Skin examination
- Urinalysis (sugar, albumin, hematuria)
- Urinary cytology examination [1910.1029(j)(2)(vii)]
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: At least annually for the general regulated-area workforce [1910.1029(j)(3)(i)]. At least annually (NOT every 6 months) for employees 45+ years old OR with 5+ years employment in the regulated area, whose annual exam ADDS urinary cytology [1910.1029(j)(3)(ii)]. Both groups are annual federally.
- Work and medical history including smoking history and presence/degree of respiratory symptoms (breathlessness, cough, sputum production, wheezing)
- 14×17 (or other reasonably-sized) standard-film or digital PA chest X-ray (no ILO classification mandated federally)
- Pulmonary function test — FVC and FEV1.0
- Weight measurement
- Skin examination
- Urinalysis (sugar, albumin, hematuria)
- Urinary cytology — added annually for employees 45+ or with 5+ years in the regulated area
Reporting Requirements
| Who performs the evaluation | Licensed physician (employer-selected) |
|---|---|
| Reported to employer | Written opinion limited to: the results of the medical examination and tests; any detected medical condition that would place the employee at increased risk from coke-oven-emission exposure; recommended exposure/PPE limitations; and a statement that the employee has been informed of the results and any condition requiring further examination or treatment. Unrelated findings must not be revealed [1910.1029(j)(5)(i)]. |
| Reported to / for the employee | Employer provides a copy of the written opinion to the affected employee; the employee is informed of the exam results and any condition requiring further evaluation. |
| Time limits | The standard does not specify an explicit deadline for furnishing the copy of the written opinion to the employee (see unverified note). |
| Second-opinion / multi-physician review | No formal multiple-physician review mechanism specified. |
| Recordkeeping | Medical records retained for at least 40 years, or for the duration of employment plus 20 years, whichever is longer [1910.1029(m)(2)(iii)]. |
Cal/OSHA dir.ca.gov
General Industry
| PEL | 0.15 mg/m³ (= 150 µg/m³) averaged over any 8-hour period [5211(c)] |
|---|---|
| Covered | Each employee employed in a regulated area at least 30 days/year [5211(s)(1)(A)] |
| Physician Type | Licensed physician (employer-selected) |
| Removal (MRP) | No medical removal protection scheme; physician's written opinion conveys results, risk assessment, and exposure limitations. |
🩺 Baseline / Pre-Placement
At initial assignment to a regulated area [5211(s)(2)]
- Work and medical history including smoking history and respiratory symptoms
- PA chest X-ray with ILO U/C (UICC/Cincinnati) classification rating [5211(s)(2)(B)]
- Pulmonary function test — FVC and FEV1.0
- Weight measurement
- Skin examination
- Urinalysis (sugar, albumin, hematuria)
- Sputum cytology examination [5211(s)(2)(G)] (California-only; not required federally)
- Urinary cytology examination [5211(s)(2)(H)]
🕒 Periodic / Routine
Interval-based by age/tenure while covered — NOT result-triggered
Schedule: At least annually for the general regulated-area workforce [5211(s)(3)(A)]. At least semi-annually (every 6 months) for employees 45+ years old OR with 5+ years in regulated areas [5211(s)(3)(B)]; semi-annual exams continue after transfer out of the regulated area [5211(s)(3)(C)].
- Work and medical history
- 14×17 PA chest X-ray with ILO UICC/Cincinnati (U/C) classification rating
- Pulmonary function test (FVC and FEV1.0)
- Weight measurement
- Skin examination
- Urinalysis (sugar, albumin, hematuria)
- Sputum cytology examination
- Urinary cytology examination
- Note: all components of (s)(2) apply to periodic exams via 5211(s)(3)(A); for the 45+/5-yr group under (s)(3)(B), the full (s)(2) exam applies semi-annually
🚪 Exit / Termination
At termination of employment, if no qualifying exam was performed in the prior 6 months [5211(s)(3)(D)]
- Work and medical history including smoking history and respiratory symptoms
- PA chest X-ray with ILO U/C (UICC/Cincinnati) classification rating [5211(s)(2)(B)]
- Pulmonary function test — FVC and FEV1.0
- Weight measurement
- Skin examination
- Urinalysis (sugar, albumin, hematuria)
- Sputum cytology examination [5211(s)(2)(G)] (California-only; not required federally)
- Urinary cytology examination [5211(s)(2)(H)]
Reporting Requirements
| Who performs the evaluation | Licensed physician (employer-selected) |
|---|---|
| Reported to employer | Written opinion limited to: results of the examination; any detected condition placing the employee at increased risk from coke-oven emissions; recommended exposure limitations; and a statement that the employee was informed of the results and any condition needing further evaluation. Unrelated findings must not be revealed [5211(s)(5)(A)]. |
| Reported to / for the employee | Employer provides a copy of the written opinion to the employee; employee informed of results and of any condition needing further evaluation. |
| Time limits | The standard does not specify an explicit deadline for furnishing the copy to the employee (see unverified note). |
| Second-opinion / multi-physician review | No formal multiple-physician review mechanism specified. |
| Recordkeeping | Medical records retained for at least 40 years, or for the duration of employment plus 20 years, whichever is longer [8 CCR 5211(v)(2)(C)]. |
Federal vs. California: Largest divergence of the four substances. California 8 CCR 5211 is materially more stringent than federal 1910.1029 in three ways: (1) it requires SPUTUM cytology (5211(s)(2)(G)), which federal 1910.1029 does not require at all (federal requires URINARY cytology only); (2) it mandates SEMI-ANNUAL (every-6-month) exams for the 45+/5-year group (5211(s)(3)(B)), whereas federal is ANNUAL for that group (federal adds urinary cytology annually, not on a 6-month interval); and (3) it mandates ILO U/C classification of the chest X-ray (5211(s)(2)(B)), whereas federal 1910.1029 requires the X-ray but not ILO classification. Both jurisdictions agree on the 150 µg/m³ PEL, the 30-days/year regulated-area trigger, and urinary cytology.
Benzene
Aromatic CarcinogensBenzene causes leukemia, aplastic anemia, and bone-marrow suppression; affects workers in petrochemicals, refining, rubber/tire manufacturing, and solvent use.
Federal OSHA osha.gov
General Industry
| Action Level | 0.5 ppm (8-hr TWA) |
|---|---|
| PEL | 1 ppm (8-hr TWA); STEL 5 ppm / 15 min |
| Covered | Employees exposed at/above the AL 30+ days/year, OR at/above the PEL/STEL 10+ days/year, OR with prior exposure >10 ppm for 30+ days/year (historical), OR tire-building machine operators using solvents with >0.1% benzene |
| Physician Type | Licensed physician (hematologist or internist on referral for persistent CBC abnormality) |
| Removal (MRP) | On referral to a hematologist/internist for a persistent CBC abnormality, the employee is removed from areas where exposure may exceed the AL and transferred to a comparable job at/below the AL with wage, seniority, and benefits maintained; up to 6 months of MRP benefits per removal (strongest MRP of the five aromatic carcinogens). |
🩺 Baseline / Pre-Placement
Before initial assignment to benzene work (or within 60 days of the standard's effective date for already-assigned employees)
- Detailed occupational history
- Complete physical examination
- CBC: leukocyte count with differential, quantitative platelet (thrombocyte) count, hematocrit, hemoglobin, erythrocyte count, erythrocyte indices (MCV, MCH, MCHC)
- Pulmonary function test if a respirator is worn 30+ days/year
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: Annually following the previous examination.
- Updated occupational history
- Complete physical examination
- CBC: leukocyte count with differential, quantitative platelet (thrombocyte) count, hematocrit, hemoglobin, erythrocyte count, erythrocyte indices (MCV, MCH, MCHC)
- Pulmonary function test every 3 years if a respirator is worn 30+ days/year
Abnormal Results & Exposure-Event Protocols
- Abnormal CBC: hemoglobin/hematocrit below the normal limit (outside the 95% C.I.) or a persistent downward trend from the individual's pre-exposure norm; platelet count >20% below the most recent value or outside normal limits; leukocytes <4,000/mm3 or an abnormal differential count 1910.1028(i)(5)(i): Repeat the complete CBC within 2 weeks. Tests: Repeat CBC: leukocyte count with differential, quantitative platelet (thrombocyte) count, hematocrit, hemoglobin, erythrocyte count, erythrocyte indices (MCV, MCH, MCHC)
- CBC abnormality persists on the repeat test 1910.1028(i)(5)(ii): Examining physician refers the employee to a hematologist or internist for further evaluation, unless the physician has good reason to believe referral is unnecessary. Tests: Specialist (hematologist/internist) evaluation
- Emergency / acute exposure to benzene 1910.1028(i)(4): Collect a urine sample at end of shift and perform a urinary phenol test within 72 hours. If urinary phenol is at or above 75 mg phenol/L (creatinine-corrected), provide a CBC at monthly intervals for 3 months following the emergency exposure; below 75 mg/L, no further testing required. Tests: End-of-shift urine collection, Urinary phenol test within 72 hours, Monthly CBC for 3 months if urinary phenol >=75 mg/L
- Referral to hematologist/internist following persistent CBC abnormality (medical removal) 1910.1028(i)(8)-(9): Employee removed from areas where benzene exposure may exceed the action level and transferred to a comparable job with exposure at or below the AL, maintaining wage rate, seniority, and benefits. Within 6 months of removal the physician determines return to the former job or permanent removal. Employee receives up to 6 months of medical removal protection (MRP) benefits per removal. Tests: Periodic CBC during removal to determine return eligibility
Reporting Requirements
| Who performs the evaluation | Licensed physician (examining physician; hematologist or internist on referral for persistent CBC abnormality) |
|---|---|
| Reported to employer | Written opinion limited to: occupationally pertinent exam/test results; whether the employee has a greater-than-normal risk of material impairment from benzene; recommended exposure/PPE limitations; and a statement that the employee was informed of the results. Must NOT reveal specific records, findings, or diagnoses with no bearing on ability to work in a benzene-exposed workplace. |
| Reported to / for the employee | Employee informed of exam results and any medical condition requiring further evaluation; furnished a copy of the written opinion. |
| Time limits | Written opinion furnished within 15 days of the examination (1910.1028(i)(7)). |
| Second-opinion / multi-physician review | No multiple-physician-review scheme; on referral the examining physician and the hematologist/internist consult and communicate removal/return decisions in writing (1910.1028(i)(8)). |
| Recordkeeping | Medical surveillance records retained for the duration of employment plus 30 years (29 CFR 1910.1020). |
Construction
| Action Level | 0.5 ppm (8-hr TWA) |
|---|---|
| PEL | 1 ppm (8-hr TWA); STEL 5 ppm / 15 min |
| Covered | Construction work covered identically to 1910.1028 by incorporation by reference — '...requirements applicable to construction work under this section are identical to those set forth at 1910.1028.' All exam events, components, abnormal protocols, MRP, and reporting are governed by 1910.1028. |
| Physician Type | Licensed physician (hematologist or internist on referral for persistent CBC abnormality) |
| Removal (MRP) | Identical to 1910.1028 by reference: removal on referral, comparable transfer at/below AL, up to 6 months of MRP benefits. |
🩺 Baseline / Pre-Placement
Before initial assignment to benzene work (per 1910.1028, incorporated by reference)
- Detailed occupational history
- Complete physical examination
- CBC: leukocyte count with differential, quantitative platelet (thrombocyte) count, hematocrit, hemoglobin, erythrocyte count, erythrocyte indices (MCV, MCH, MCHC)
- Pulmonary function test if a respirator is worn 30+ days/year
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: Annually following the previous examination (per 1910.1028, incorporated by reference).
- Updated occupational history
- Complete physical examination
- CBC: leukocyte count with differential, quantitative platelet (thrombocyte) count, hematocrit, hemoglobin, erythrocyte count, erythrocyte indices (MCV, MCH, MCHC)
- Pulmonary function test every 3 years if a respirator is worn 30+ days/year
Abnormal Results & Exposure-Event Protocols
- Abnormal CBC: hemoglobin/hematocrit below the normal limit (outside the 95% C.I.) or a persistent downward trend from the individual's pre-exposure norm; platelet count >20% below the most recent value or outside normal limits; leukocytes <4,000/mm3 or an abnormal differential count 1910.1028(i)(5)(i): Repeat the complete CBC within 2 weeks. Tests: Repeat CBC: leukocyte count with differential, quantitative platelet (thrombocyte) count, hematocrit, hemoglobin, erythrocyte count, erythrocyte indices (MCV, MCH, MCHC)
- CBC abnormality persists on the repeat test 1910.1028(i)(5)(ii): Examining physician refers the employee to a hematologist or internist for further evaluation, unless the physician has good reason to believe referral is unnecessary. Tests: Specialist (hematologist/internist) evaluation
- Emergency / acute exposure to benzene 1910.1028(i)(4): Collect a urine sample at end of shift and perform a urinary phenol test within 72 hours. If urinary phenol is at or above 75 mg phenol/L (creatinine-corrected), provide a CBC at monthly intervals for 3 months following the emergency exposure; below 75 mg/L, no further testing required. Tests: End-of-shift urine collection, Urinary phenol test within 72 hours, Monthly CBC for 3 months if urinary phenol >=75 mg/L
- Referral to hematologist/internist following persistent CBC abnormality (medical removal) 1910.1028(i)(8)-(9): Employee removed from areas where benzene exposure may exceed the action level and transferred to a comparable job with exposure at or below the AL, maintaining wage rate, seniority, and benefits. Within 6 months of removal the physician determines return to the former job or permanent removal. Employee receives up to 6 months of medical removal protection (MRP) benefits per removal. Tests: Periodic CBC during removal to determine return eligibility
Reporting Requirements
| Who performs the evaluation | Licensed physician (examining physician; hematologist or internist on referral for persistent CBC abnormality) |
|---|---|
| Reported to employer | Written opinion limited to: occupationally pertinent exam/test results; whether the employee has a greater-than-normal risk of material impairment from benzene; recommended exposure/PPE limitations; and a statement that the employee was informed of the results. Must NOT reveal specific records, findings, or diagnoses with no bearing on ability to work in a benzene-exposed workplace. |
| Reported to / for the employee | Employee informed of exam results and any medical condition requiring further evaluation; furnished a copy of the written opinion. |
| Time limits | Written opinion furnished within 15 days of the examination (1910.1028(i)(7)). |
| Second-opinion / multi-physician review | No multiple-physician-review scheme; on referral the examining physician and the hematologist/internist consult and communicate removal/return decisions in writing (1910.1028(i)(8)). |
| Recordkeeping | Medical surveillance records retained for the duration of employment plus 30 years (29 CFR 1910.1020). |
Cal/OSHA dir.ca.gov
General Industry
| Action Level | 0.5 ppm (8-hr TWA) |
|---|---|
| PEL | 1 ppm (8-hr TWA); STEL 5 ppm / 15 min |
| Covered | Employees exposed at/above the AL 30+ days/year; at/above the PEL/STEL 10+ days/year; prior exposure >10 ppm for 30+ days/year before December 10, 1989 (CA-specific historical cutoff date); tire-building machine operators using solvents with >0.1% benzene |
| Physician Type | Licensed physician (hematologist or internist on referral for persistent CBC abnormality) |
| Removal (MRP) | On referral to a hematologist/internist for a persistent CBC abnormality, the employee is removed from areas where exposure may exceed the AL and transferred to a comparable job at/below the AL with wage, seniority, and benefits maintained; up to 6 months of MRP benefits per removal (strongest MRP of the five aromatic carcinogens). |
🩺 Baseline / Pre-Placement
Before initial assignment to benzene work (or within 12 months prior if the employee was recently examined to the equivalent requirements)
- Detailed occupational history
- Complete physical examination
- CBC: leukocyte count with differential, quantitative platelet (thrombocyte) count, hematocrit, hemoglobin, erythrocyte count, erythrocyte indices (MCV, MCH, MCHC)
- Pulmonary function test if a respirator is worn 30+ days/year
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: Annually following the previous examination.
- Updated occupational history
- Complete physical examination
- CBC: leukocyte count with differential, quantitative platelet (thrombocyte) count, hematocrit, hemoglobin, erythrocyte count, erythrocyte indices (MCV, MCH, MCHC)
- Pulmonary function test every 3 years if a respirator is worn 30+ days/year
Abnormal Results & Exposure-Event Protocols
- Abnormal CBC: hemoglobin/hematocrit below the normal limit (outside the 95% C.I.) or a persistent downward trend from the individual's pre-exposure norm; platelet count >20% below the most recent value or outside normal limits; leukocytes <4,000/mm3 or an abnormal differential count 8 CCR 5218(i)(5)(A): Repeat the complete CBC within 2 weeks. Tests: Repeat CBC: leukocyte count with differential, quantitative platelet (thrombocyte) count, hematocrit, hemoglobin, erythrocyte count, erythrocyte indices (MCV, MCH, MCHC)
- CBC abnormality persists on the repeat test 8 CCR 5218(i)(5)(B): Examining physician refers the employee to a hematologist or internist for further evaluation, unless the physician has good reason to believe referral is unnecessary. Tests: Specialist (hematologist/internist) evaluation
- Emergency / acute exposure to benzene 8 CCR 5218(i)(4): Collect a urine sample at end of shift and perform a urinary phenol test within 72 hours. If urinary phenol is at or above 75 mg phenol/L (creatinine-corrected), provide a CBC at monthly intervals for 3 months following the emergency exposure; below 75 mg/L, no further testing required. Tests: End-of-shift urine collection, Urinary phenol test within 72 hours, Monthly CBC for 3 months if urinary phenol >=75 mg/L
- Referral to hematologist/internist following persistent CBC abnormality (medical removal) 8 CCR 5218(i)(8)-(9): Employee removed from areas where benzene exposure may exceed the action level and transferred to a comparable job with exposure at or below the AL, maintaining wage rate, seniority, and benefits. Within 6 months of removal the physician determines return to the former job or permanent removal. Employee receives up to 6 months of medical removal protection (MRP) benefits per removal. Tests: Periodic CBC during removal to determine return eligibility
Reporting Requirements
| Who performs the evaluation | Licensed physician (examining physician; hematologist or internist on referral for persistent CBC abnormality) |
|---|---|
| Reported to employer | Written opinion limited to: occupationally pertinent exam/test results; whether the employee has a greater-than-normal risk of material impairment from benzene; recommended exposure/PPE limitations; and a statement that the employee was informed of the results. Must NOT reveal specific records, findings, or diagnoses with no bearing on ability to work in a benzene-exposed workplace. |
| Reported to / for the employee | Employee informed of exam results and any medical condition requiring further evaluation; furnished a copy of the written opinion. |
| Time limits | Written opinion furnished within 15 days of the examination. |
| Second-opinion / multi-physician review | No multiple-physician-review scheme; on referral the examining physician and the hematologist/internist consult and communicate removal/return decisions in writing (8 CCR 5218(i)(8)). |
| Recordkeeping | Medical records retained for the duration of employment plus 30 years (8 CCR 3204). |
Federal vs. California: Essentially aligned — California adopted the federal benzene standard with identical AL/PEL/STEL, CBC panel, abnormal-CBC repeat-and-refer protocol, and 6-month MRP. The only notable difference is the historical-exposure cutoff worded as 'before December 10, 1989' in CA. California has no separate construction benzene section (construction governed federally by 1926.1128, which incorporates 1910.1028 by reference).
Vinyl Chloride
Aromatic CarcinogensVinyl chloride causes angiosarcoma of the liver, liver dysfunction, and acroosteolysis; affects workers in PVC/polymer manufacturing and polymerization operations.
Federal OSHA osha.gov
General Industry
| Action Level | 0.5 ppm (8-hr TWA) |
|---|---|
| PEL | 1 ppm (8-hr TWA); ceiling 5 ppm / 15 min (maximum) |
| Covered | Each employee exposed above the action level, without regard to respirator use |
| Physician Type | Licensed physician |
| Removal (MRP) | No formal wage-protected MRP. If continued exposure would materially impair the employee's health, the employee shall be withdrawn from possible contact with vinyl chloride (1910.1017(k)(5)). |
🩺 Baseline / Pre-Placement
At the time of initial assignment, or upon institution of medical surveillance
- Medical/work history covering alcohol intake, history of hepatitis, work history with exposure to hepatotoxic agents, blood transfusion history, and hospitalization history
- General physical examination with specific attention to enlargement of or dysfunction in the liver, spleen, or kidneys, and to abnormalities of skin, connective tissue, and the pulmonary system
- Serum/liver-function panel: total bilirubin; alkaline phosphatase; SGOT (AST); SGPT (ALT); gamma-glutamyl transpeptidase
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: At least annually.
- Medical/work history covering alcohol intake, history of hepatitis, work history with exposure to hepatotoxic agents, blood transfusion history, and hospitalization history
- General physical examination with specific attention to enlargement of or dysfunction in the liver, spleen, or kidneys, and to abnormalities of skin, connective tissue, and the pulmonary system
- Serum/liver-function panel: total bilirubin; alkaline phosphatase; SGOT (AST); SGPT (ALT); gamma-glutamyl transpeptidase
Abnormal Results & Exposure-Event Protocols
- Liver-function tests abnormal on examination 1910.1017(k): Additional examinations (e.g., liver scan, biopsy) are performed at the examining physician's discretion. Tests: Physician-directed follow-up studies (e.g., liver scan, liver biopsy)
- Continued exposure would materially impair the employee's health 1910.1017(k)(5): Employee shall be withdrawn from possible contact with vinyl chloride (no wage-protected MRP scheme).
Reporting Requirements
| Who performs the evaluation | Licensed physician |
|---|---|
| Reported to employer | Written statement of the employee's suitability for continued exposure to vinyl chloride, including use of protective equipment and respirators. |
| Reported to / for the employee | A copy of the physician's written statement is provided to each employee. |
| Time limits | No specific number-of-days deadline is codified; the standard requires only that the physician's written statement be obtained 'promptly after any examination' and a copy provided to the employee (1910.1017(k)(4)). No day-count deadline exists in this standard. |
| Second-opinion / multi-physician review | No multiple-physician-review scheme codified in the standard. |
| Recordkeeping | Medical records retained for the duration of employment plus 20 years, or 30 years, whichever is longer (1910.1017(m)(2)(iii)). |
Construction
| Action Level | 0.5 ppm (8-hr TWA) |
|---|---|
| PEL | 1 ppm (8-hr TWA); ceiling 5 ppm / 15 min (maximum) |
| Covered | Construction work covered identically to 1910.1017 by incorporation by reference. All exam events, components, abnormal protocols, and reporting are governed by 1910.1017. |
| Physician Type | Licensed physician |
| Removal (MRP) | No formal wage-protected MRP. If continued exposure would materially impair the employee's health, the employee shall be withdrawn from possible contact with vinyl chloride (1910.1017(k)(5)). |
🩺 Baseline / Pre-Placement
At the time of initial assignment, or upon institution of medical surveillance (per 1910.1017, incorporated by reference)
- Medical/work history covering alcohol intake, history of hepatitis, work history with exposure to hepatotoxic agents, blood transfusion history, and hospitalization history
- General physical examination with specific attention to enlargement of or dysfunction in the liver, spleen, or kidneys, and to abnormalities of skin, connective tissue, and the pulmonary system
- Serum/liver-function panel: total bilirubin; alkaline phosphatase; SGOT (AST); SGPT (ALT); gamma-glutamyl transpeptidase
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: At least annually (per 1910.1017, incorporated by reference).
- Medical/work history covering alcohol intake, history of hepatitis, work history with exposure to hepatotoxic agents, blood transfusion history, and hospitalization history
- General physical examination with specific attention to enlargement of or dysfunction in the liver, spleen, or kidneys, and to abnormalities of skin, connective tissue, and the pulmonary system
- Serum/liver-function panel: total bilirubin; alkaline phosphatase; SGOT (AST); SGPT (ALT); gamma-glutamyl transpeptidase
Abnormal Results & Exposure-Event Protocols
- Liver-function tests abnormal on examination 1910.1017(k): Additional examinations (e.g., liver scan, biopsy) are performed at the examining physician's discretion. Tests: Physician-directed follow-up studies (e.g., liver scan, liver biopsy)
- Continued exposure would materially impair the employee's health 1910.1017(k)(5): Employee shall be withdrawn from possible contact with vinyl chloride (no wage-protected MRP scheme).
Reporting Requirements
| Who performs the evaluation | Licensed physician |
|---|---|
| Reported to employer | Written statement of the employee's suitability for continued exposure to vinyl chloride, including use of protective equipment and respirators. |
| Reported to / for the employee | A copy of the physician's written statement is provided to each employee. |
| Time limits | No specific number-of-days deadline is codified; the standard (incorporated by reference from 1910.1017(k)(4)) requires only that the physician's written statement be obtained 'promptly after any examination' and a copy provided to the employee. |
| Second-opinion / multi-physician review | No multiple-physician-review scheme codified in the standard. |
| Recordkeeping | Medical records retained for the duration of employment plus 20 years, or 30 years, whichever is longer (1910.1017(m)(2)(iii)). |
Cal/OSHA dir.ca.gov
General Industry
| Action Level | 0.5 ppm (8-hr TWA) |
|---|---|
| PEL | 1 ppm (8-hr TWA); ceiling 5 ppm / 15 min (maximum) |
| Covered | Each employee exposed above the action level, without regard to respirator use |
| Physician Type | Licensed physician |
| Removal (MRP) | No formal wage-protected MRP. If continued exposure would materially impair the employee's health, the employee shall be withdrawn from possible contact with vinyl chloride (8 CCR 5210(k)(5)). |
🩺 Baseline / Pre-Placement
At the time of initial assignment, or upon institution of medical surveillance
- Medical/work history covering alcohol intake, history of hepatitis, work history with exposure to hepatotoxic agents, blood transfusion history, and hospitalization history
- General physical examination with specific attention to enlargement of or dysfunction in the liver, spleen, or kidneys, and to abnormalities of skin, connective tissue, and the pulmonary system
- Serum/liver-function panel: total bilirubin; alkaline phosphatase; SGOT (AST); SGPT (ALT); gamma-glutamyl transpeptidase
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: Every 6 months (semiannual) for employees who have worked 10+ years in vinyl chloride manufacturing; at least annually for all other covered employees.
- Medical/work history covering alcohol intake, history of hepatitis, work history with exposure to hepatotoxic agents, blood transfusion history, and hospitalization history
- General physical examination with specific attention to enlargement of or dysfunction in the liver, spleen, or kidneys, and to abnormalities of skin, connective tissue, and the pulmonary system
- Serum/liver-function panel: total bilirubin; alkaline phosphatase; SGOT (AST); SGPT (ALT); gamma-glutamyl transpeptidase
Abnormal Results & Exposure-Event Protocols
- Liver-function tests abnormal on examination 8 CCR 5210(k): Additional examinations (e.g., liver scan, biopsy) are performed at the examining physician's discretion. Tests: Physician-directed follow-up studies (e.g., liver scan, liver biopsy)
- Continued exposure would materially impair the employee's health 8 CCR 5210(k)(5): Employee shall be withdrawn from possible contact with vinyl chloride (no wage-protected MRP scheme).
Reporting Requirements
| Who performs the evaluation | Licensed physician |
|---|---|
| Reported to employer | Written statement of the employee's suitability for continued exposure to vinyl chloride, including use of protective equipment and respirators. |
| Reported to / for the employee | A copy of the physician's written statement is provided to each employee. |
| Time limits | No specific number-of-days deadline is codified; 8 CCR 5210 requires only that the physician's written statement be obtained 'promptly after any examination' and a copy provided to the employee (8 CCR 5210(k)(4)). |
| Second-opinion / multi-physician review | No multiple-physician-review scheme codified in the standard. |
| Recordkeeping | Medical records retained for the duration of employment plus 20 years, or 30 years, whichever is longer (8 CCR 5210(m)(2)(B); 8 CCR 3204). |
Federal vs. California: California explicitly codifies semiannual (every-6-month) periodic exams for employees with 10+ years in vinyl chloride manufacturing, whereas the federal text frames periodic exams as 'at least annually' without a codified tenure-based semiannual tier. AL/PEL/ceiling, the liver-function panel, and the withdrawal provision are otherwise equivalent. California has no separate construction VC section (construction governed federally by 1926.1117, incorporating 1910.1017 by reference).
1,3-Butadiene
Aromatic Carcinogens1,3-Butadiene causes leukemia and other hematopoietic cancers; affects workers in synthetic rubber, plastics, and petrochemical manufacturing.
Federal OSHA osha.gov
General Industry
| Action Level | 0.5 ppm (8-hr TWA) |
|---|---|
| PEL | 1 ppm (8-hr TWA); STEL 5 ppm / 15 min |
| Covered | Employees exposed at/above the AL 30+ days/year OR at/above the PEL 10+ days/year; plus transferred employees with a qualifying exposure history (at/above the PEL 30+ days/year for 10+ years, or at/above the AL 60+ days/year for 10+ years); plus any employee exposed in an emergency |
| Physician Type | Licensed physician |
| Removal (MRP) | No MRP wage-protection scheme codified; the physician provides a written opinion with recommended exposure limitations. |
🩺 Baseline / Pre-Placement
Initial physical examination before/at the start of BD-exposure duties, if 12 months or more have elapsed since the last physical examination meeting these requirements
- Health questionnaire / comprehensive occupational and health history (Appendix C forms), updated annually, with particular emphasis on the hematopoietic and reticuloendothelial systems
- Complete physical examination with special emphasis on the liver, spleen, lymph nodes, and skin
- Complete blood count (CBC) as defined in 1910.1051: white blood cell count (WBC), hematocrit (Hct), red blood cell count (RBC), hemoglobin (Hgb), differential count of white blood cells, red blood cell morphology, red blood cell indices, and platelet count
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: Health questionnaire and CBC every year; a full physical examination every 3 years after the initial physical examination.
- Annual: health questionnaire (Appendix C) with hematopoietic/reticuloendothelial emphasis
- Annual: CBC as defined in 1910.1051: white blood cell count (WBC), hematocrit (Hct), red blood cell count (RBC), hemoglobin (Hgb), differential count of white blood cells, red blood cell morphology, red blood cell indices, and platelet count
- Every 3 years: complete physical examination with special emphasis on the liver, spleen, lymph nodes, and skin
🚪 Exit / Termination
At termination of employment, if 12 months or more have elapsed since the last physical examination
- Health questionnaire / comprehensive occupational and health history (Appendix C forms), updated annually, with particular emphasis on the hematopoietic and reticuloendothelial systems
- Complete physical examination with special emphasis on the liver, spleen, lymph nodes, and skin
- Complete blood count (CBC) with differential and platelet count
Abnormal Results & Exposure-Event Protocols
- Emergency exposure to BD 1910.1051(k)(4)(ii): Provide medical screening as quickly as possible, no later than 48 hours after exposure: a CBC within 48 hours of the exposure and then monthly for three months. Tests: CBC within 48 hours of the exposure, Monthly CBC for 3 months following the exposure
- Abnormal annual health questionnaire and/or CBC result on review 1910.1051(k)(3)(i)(D): Examining physician orders additional medical examinations or tests as warranted at the physician's discretion. Tests: Physician-directed additional examinations/tests
Reporting Requirements
| Who performs the evaluation | Licensed physician |
|---|---|
| Reported to employer | Written opinion limited to: occupationally pertinent results of the medical evaluation; whether the employee has any detected medical condition that would place health at increased risk of material impairment from BD; recommended limitations on BD exposure; and a statement that the employee was informed of the results. Must NOT reveal specific records, findings, or diagnoses with no bearing on ability to work with BD. |
| Reported to / for the employee | Employee informed of the results; furnished a copy of the written opinion. |
| Time limits | Written opinion provided within 15 business days of the evaluation (1910.1051(k)(7)(i)). |
| Second-opinion / multi-physician review | No multiple-physician-review scheme codified in the standard. |
| Recordkeeping | Medical records retained for the duration of employment plus 30 years (1910.1051(m)(4)(iii); 29 CFR 1910.1020). |
Construction
No construction medical-surveillance standard exists for 1,3-butadiene — 29 CFR 1926.1151 does not exist (returns HTTP 404). The BD surveillance requirement lives only in general industry (1910.1051); there is no 1926 parallel that incorporates it by reference.
Cal/OSHA dir.ca.gov
General Industry
| Action Level | 0.5 ppm (8-hr TWA) |
|---|---|
| PEL | 1 ppm (8-hr TWA); STEL 5 ppm / 15 min |
| Covered | Employees exposed at/above the AL 30+ days/year OR at/above the PEL 10+ days/year; plus transferred employees with a qualifying exposure history (at/above the PEL 30+ days/year for 10+ years, or at/above the AL 60+ days/year for 10+ years); plus any employee exposed in an emergency |
| Physician Type | Licensed physician |
| Removal (MRP) | No MRP wage-protection scheme codified; the physician provides a written opinion with recommended exposure limitations. |
🩺 Baseline / Pre-Placement
Initial physical examination before/at the start of BD-exposure duties, if 12 months or more have elapsed since the last physical examination meeting these requirements
- Health questionnaire / comprehensive occupational and health history (Appendix C forms), updated annually, with particular emphasis on the hematopoietic and reticuloendothelial systems
- Complete physical examination with special emphasis on the liver, spleen, lymph nodes, and skin
- Complete blood count (CBC) as defined in 8 CCR 5201: white blood cell count (WBC), hematocrit (Hct), red blood cell count (RBC), hemoglobin (Hgb), differential count of white blood cells, red blood cell morphology, red blood cell indices, and platelet count
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: Health questionnaire and CBC every year; a full physical examination every 3 years after the initial physical examination.
- Annual: health questionnaire (Appendix C) with hematopoietic/reticuloendothelial emphasis
- Annual: CBC as defined in 8 CCR 5201: white blood cell count (WBC), hematocrit (Hct), red blood cell count (RBC), hemoglobin (Hgb), differential count of white blood cells, red blood cell morphology, red blood cell indices, and platelet count
- Every 3 years: complete physical examination with special emphasis on the liver, spleen, lymph nodes, and skin
🚪 Exit / Termination
At termination of employment, if 12 months or more have elapsed since the last physical examination
- Health questionnaire / comprehensive occupational and health history (Appendix C forms), updated annually, with particular emphasis on the hematopoietic and reticuloendothelial systems
- Complete physical examination with special emphasis on the liver, spleen, lymph nodes, and skin
- Complete blood count (CBC) with differential and platelet count
Abnormal Results & Exposure-Event Protocols
- Emergency exposure to BD 8 CCR 5201(k)(4)(ii): Provide medical screening as quickly as possible, no later than 48 hours after exposure: a CBC within 48 hours of the exposure and then monthly for three months. Tests: CBC within 48 hours of the exposure, Monthly CBC for 3 months following the exposure
- Abnormal annual health questionnaire and/or CBC result on review 8 CCR 5201(k)(3)(i)(D): Examining physician orders additional medical examinations or tests as warranted at the physician's discretion. Tests: Physician-directed additional examinations/tests
Reporting Requirements
| Who performs the evaluation | Licensed physician |
|---|---|
| Reported to employer | Written opinion limited to: occupationally pertinent results of the medical evaluation; whether the employee has any detected medical condition that would place health at increased risk of material impairment from BD; recommended limitations on BD exposure; and a statement that the employee was informed of the results. Must NOT reveal specific records, findings, or diagnoses with no bearing on ability to work with BD. |
| Reported to / for the employee | Employee informed of the results; furnished a copy of the written opinion. |
| Time limits | Written opinion provided within 15 business days of the evaluation. |
| Second-opinion / multi-physician review | No multiple-physician-review scheme codified in the standard. |
| Recordkeeping | Medical records retained for the duration of employment plus 30 years (8 CCR 3204). |
Federal vs. California: Essentially aligned — California adopted the federal BD standard nearly verbatim (identical AL/PEL/STEL, annual CBC + questionnaire, triennial physical, 48-hour emergency CBC + monthly-for-3-months protocol). The meaningful jurisdictional note is structural: federal has NO construction variant (1926.1151 does not exist), so the requirement lives only in general industry; California likewise has a single general-industry section (5201).
Definitions & Reference Tables
Appendix C — Medical screening and surveillance for 1,3-butadiene 29 CFR 1910.1051 App. C; 8 CCR 5201 App. C
A non-mandatory guidance appendix describing the recommended medical screening for 1,3-butadiene: an annually updated health questionnaire, a complete blood count with differential and platelet count, and a physical exam, with emphasis on the hematopoietic and reticuloendothelial systems and guidance for interpreting abnormal results.
Acrylonitrile
Aromatic CarcinogensAcrylonitrile (vinyl cyanide) is a probable carcinogen causing lung/GI effects and CNS symptoms; affects workers in acrylic fiber, plastics, and resin manufacturing.
Federal OSHA osha.gov
General Industry
| Action Level | 1 ppm (8-hr TWA) |
|---|---|
| PEL | 2 ppm (8-hr TWA); ceiling 10 ppm / 15 min |
| Covered | Each employee who is or will be exposed at or above the action level, without regard to respirator use |
| Physician Type | Licensed physician |
| Removal (MRP) | No mandatory removal thresholds; the physician's written opinion may recommend limitations on AN exposure or PPE use. |
🩺 Baseline / Pre-Placement
At the time of initial assignment, or upon institution of the medical surveillance program
- Work and medical history with special attention to the skin, respiratory, and gastrointestinal systems, and to nonspecific symptoms such as headache, nausea, vomiting, dizziness, weakness, or other central-nervous-system dysfunction
- Complete physical examination giving particular attention to the peripheral and central nervous system, gastrointestinal system, respiratory system, skin, and thyroid
- 14x17-inch (or other reasonably-sized standard film or digital) posterior-anterior chest X-ray
- Further tests of the intestinal tract, including fecal occult blood screening, for all workers age 40 or older (and for any other affected employees for whom the physician deems it appropriate)
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: At least annually for all covered employees.
- Work and medical history with special attention to the skin, respiratory, and gastrointestinal systems, and to nonspecific symptoms such as headache, nausea, vomiting, dizziness, weakness, or other central-nervous-system dysfunction
- Complete physical examination giving particular attention to the peripheral and central nervous system, gastrointestinal system, respiratory system, skin, and thyroid
- 14x17-inch (or other reasonably-sized standard film or digital) posterior-anterior chest X-ray
- Further tests of the intestinal tract, including fecal occult blood screening, for all workers age 40 or older (and for any other affected employees for whom the physician deems it appropriate)
🚪 Exit / Termination
Prior to termination of employment, if the employee has not had an equivalent examination within the preceding 6 months
- Work and medical history with special attention to the skin, respiratory, and gastrointestinal systems, and to nonspecific symptoms such as headache, nausea, vomiting, dizziness, weakness, or other central-nervous-system dysfunction
- Complete physical examination giving particular attention to the peripheral and central nervous system, gastrointestinal system, respiratory system, skin, and thyroid
- 14x17-inch (or other reasonably-sized standard film or digital) posterior-anterior chest X-ray
- Further tests of the intestinal tract, including fecal occult blood screening, for all workers age 40 or older (and for any other affected employees for whom the physician deems it appropriate)
Abnormal Results & Exposure-Event Protocols
- Employee develops signs or symptoms that may be associated with exposure to AN 1910.1045(n)(4): Employer provides an appropriate medical examination and emergency medical treatment. Tests: Medical examination directed at presenting signs/symptoms (skin, respiratory, GI, CNS), Emergency medical treatment as indicated
Reporting Requirements
| Who performs the evaluation | Licensed physician |
|---|---|
| Reported to employer | Written opinion limited to: results of the medical examination and tests; whether the employee has any detected medical condition that would place health at increased risk of material impairment from AN; recommended limitations on AN exposure or on the use of protective clothing/equipment (e.g., respirators); and a statement that the employee was informed of the results and of any condition requiring further examination or treatment. Must NOT reveal specific findings or diagnoses unrelated to occupational AN exposure. |
| Reported to / for the employee | Employee informed by the physician of the results and any condition requiring further examination/treatment; furnished a copy of the written opinion. |
| Time limits | No explicit time limit for furnishing the written opinion is specified in 1910.1045(n). |
| Second-opinion / multi-physician review | No multiple-physician-review scheme codified in the standard. |
| Recordkeeping | Medical records retained for at least 40 years, or the duration of employment plus 20 years, whichever is longer (1910.1045(q)(3)(iii)). |
Construction
| Action Level | 1 ppm (8-hr TWA) |
|---|---|
| PEL | 2 ppm (8-hr TWA); ceiling 10 ppm / 15 min |
| Covered | Construction work covered identically to 1910.1045 by incorporation by reference. All exam events, components, abnormal protocols, and reporting are governed by 1910.1045. |
| Physician Type | Licensed physician |
| Removal (MRP) | No mandatory removal thresholds; the physician's written opinion may recommend limitations on AN exposure or PPE use. |
🩺 Baseline / Pre-Placement
At the time of initial assignment, or upon institution of the medical surveillance program (per 1910.1045, incorporated by reference)
- Work and medical history with special attention to the skin, respiratory, and gastrointestinal systems, and to nonspecific symptoms such as headache, nausea, vomiting, dizziness, weakness, or other central-nervous-system dysfunction
- Complete physical examination giving particular attention to the peripheral and central nervous system, gastrointestinal system, respiratory system, skin, and thyroid
- 14x17-inch (or other reasonably-sized standard film or digital) posterior-anterior chest X-ray
- Further tests of the intestinal tract, including fecal occult blood screening, for all workers age 40 or older (and for any other affected employees for whom the physician deems it appropriate)
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: At least annually for all covered employees.
- Work and medical history with special attention to the skin, respiratory, and gastrointestinal systems, and to nonspecific symptoms such as headache, nausea, vomiting, dizziness, weakness, or other central-nervous-system dysfunction
- Complete physical examination giving particular attention to the peripheral and central nervous system, gastrointestinal system, respiratory system, skin, and thyroid
- 14x17-inch (or other reasonably-sized standard film or digital) posterior-anterior chest X-ray
- Further tests of the intestinal tract, including fecal occult blood screening, for all workers age 40 or older (and for any other affected employees for whom the physician deems it appropriate)
🚪 Exit / Termination
Prior to termination of employment, if the employee has not had an equivalent examination within the preceding 6 months
- Work and medical history with special attention to the skin, respiratory, and gastrointestinal systems, and to nonspecific symptoms such as headache, nausea, vomiting, dizziness, weakness, or other central-nervous-system dysfunction
- Complete physical examination giving particular attention to the peripheral and central nervous system, gastrointestinal system, respiratory system, skin, and thyroid
- 14x17-inch (or other reasonably-sized standard film or digital) posterior-anterior chest X-ray
- Further tests of the intestinal tract, including fecal occult blood screening, for all workers age 40 or older (and for any other affected employees for whom the physician deems it appropriate)
Abnormal Results & Exposure-Event Protocols
- Employee develops signs or symptoms that may be associated with exposure to AN 1910.1045(n)(4): Employer provides an appropriate medical examination and emergency medical treatment. Tests: Medical examination directed at presenting signs/symptoms (skin, respiratory, GI, CNS), Emergency medical treatment as indicated
Reporting Requirements
| Who performs the evaluation | Licensed physician |
|---|---|
| Reported to employer | Written opinion limited to: results of the medical examination and tests; whether the employee has any detected medical condition that would place health at increased risk of material impairment from AN; recommended limitations on AN exposure or on the use of protective clothing/equipment (e.g., respirators); and a statement that the employee was informed of the results and of any condition requiring further examination or treatment. Must NOT reveal specific findings or diagnoses unrelated to occupational AN exposure. |
| Reported to / for the employee | Employee informed by the physician of the results and any condition requiring further examination/treatment; furnished a copy of the written opinion. |
| Time limits | No explicit time limit for furnishing the written opinion is specified in 1910.1045(n). |
| Second-opinion / multi-physician review | No multiple-physician-review scheme codified in the standard. |
| Recordkeeping | Medical records retained for at least 40 years, or the duration of employment plus 20 years, whichever is longer (1910.1045(q)(3)(iii)). |
Cal/OSHA dir.ca.gov
General Industry
| Action Level | 1 ppm (8-hr TWA) |
|---|---|
| PEL | 2 ppm (8-hr TWA); ceiling 10 ppm / 15 min |
| Covered | All occupational AN exposures, with exemptions for finished polymers and for materials demonstrably unable to release AN above 1 ppm under expected conditions of use |
| Physician Type | Licensed physician |
| Removal (MRP) | No mandatory removal thresholds; the physician's written opinion may recommend limitations on AN exposure or PPE use. |
🩺 Baseline / Pre-Placement
Within 30 days of the effective date of 8 CCR 5213 (for employees already employed when the standard took effect), or at the time of initial assignment (for subsequently hired employees) (8 CCR 5213(n)(2)).
- Work and medical history with special attention to the skin, respiratory, and gastrointestinal systems, and to nonspecific symptoms such as headache, nausea, vomiting, dizziness, weakness, or other central-nervous-system dysfunction
- Complete physical examination giving particular attention to the peripheral and central nervous system, gastrointestinal system, respiratory system, skin, and thyroid
- 14x17-inch (or other reasonably-sized standard film or digital) posterior-anterior chest X-ray
- Further tests of the intestinal tract, including fecal occult blood screening, for all workers age 40 or older (and for any other affected employees for whom the physician deems it appropriate)
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: At least annually for all covered employees.
- Work and medical history with special attention to the skin, respiratory, and gastrointestinal systems, and to nonspecific symptoms such as headache, nausea, vomiting, dizziness, weakness, or other central-nervous-system dysfunction
- Complete physical examination giving particular attention to the peripheral and central nervous system, gastrointestinal system, respiratory system, skin, and thyroid
- 14x17-inch (or other reasonably-sized standard film or digital) posterior-anterior chest X-ray
- Further tests of the intestinal tract, including fecal occult blood screening, for all workers age 40 or older (and for any other affected employees for whom the physician deems it appropriate)
🚪 Exit / Termination
Prior to termination of employment, if the employee has not had an equivalent examination within the preceding 6 months
- Work and medical history with special attention to the skin, respiratory, and gastrointestinal systems, and to nonspecific symptoms such as headache, nausea, vomiting, dizziness, weakness, or other central-nervous-system dysfunction
- Complete physical examination giving particular attention to the peripheral and central nervous system, gastrointestinal system, respiratory system, skin, and thyroid
- 14x17-inch (or other reasonably-sized standard film or digital) posterior-anterior chest X-ray
- Further tests of the intestinal tract, including fecal occult blood screening, for all workers age 40 or older (and for any other affected employees for whom the physician deems it appropriate)
Abnormal Results & Exposure-Event Protocols
- Employee develops signs or symptoms that may be associated with exposure to AN 8 CCR 5213(n)(4): Employer provides an appropriate medical examination and emergency medical treatment. Tests: Medical examination directed at presenting signs/symptoms (skin, respiratory, GI, CNS), Emergency medical treatment as indicated
Reporting Requirements
| Who performs the evaluation | Licensed physician |
|---|---|
| Reported to employer | Written opinion limited to: results of the medical examination and tests; whether the employee has any detected medical condition that would place health at increased risk of material impairment from AN; recommended limitations on AN exposure or on the use of protective clothing/equipment (e.g., respirators); and a statement that the employee was informed of the results and of any condition requiring further examination or treatment. Must NOT reveal specific findings or diagnoses unrelated to occupational AN exposure. |
| Reported to / for the employee | Employee informed by the physician of the results and any condition requiring further examination/treatment; furnished a copy of the written opinion. |
| Time limits | No explicit time limit for furnishing the written opinion is specified. |
| Second-opinion / multi-physician review | No multiple-physician-review scheme codified in the standard. |
| Recordkeeping | Medical records retained for at least 40 years, or the duration of employment plus 20 years, whichever is longer (8 CCR 5213(q)(3)(C); 8 CCR 3204). |
Federal vs. California: Essentially aligned — identical AL/PEL/ceiling, history/physical emphasis, chest X-ray, and FOBT-age-40+ requirement. California specifies the initial exam must occur within 30 days of assignment (an explicit deadline) whereas federal frames it as 'at the time of initial assignment.' California has no separate construction AN section (construction governed federally by 1926.1145, incorporating 1910.1045 by reference).
Ethylene Oxide
Aromatic CarcinogensEthylene oxide (EtO) causes cancer plus reproductive, hematologic, and neurologic harm; affects workers in medical-device/sterilization, fumigation, and chemical manufacturing.
Federal OSHA osha.gov
General Industry
| Action Level | 0.5 ppm (8-hr TWA) |
|---|---|
| PEL | 1 ppm (8-hr TWA); excursion limit (STEL) 5 ppm / 15 min |
| Covered | Employees exposed at/above the AL, without regard to respirator use, for at least 30 days/year; plus any employee exposed in an emergency |
| Physician Type | Licensed physician |
| Removal (MRP) | No formal MRP scheme; the physician's written opinion may state limitations on the employee or on PPE use. |
🩺 Baseline / Pre-Placement
Prior to assignment to an area where exposure may be at/above the AL for at least 30 days/year
- Medical and work history with emphasis on symptoms related to the pulmonary, hematologic, neurologic, and reproductive systems and to the eyes and skin
- Physical examination with emphasis on the pulmonary, hematologic, neurologic, and reproductive systems and to the eyes and skin
- Complete blood count: at minimum a white-cell count (including differential), red-cell count, hematocrit, and hemoglobin
- Any further laboratory or other test the examining physician deems necessary by sound medical practice
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: At least annually for employees exposed at/above the AL for at least 30 days in the past year.
- Medical and work history with emphasis on symptoms related to the pulmonary, hematologic, neurologic, and reproductive systems and to the eyes and skin
- Physical examination with emphasis on the pulmonary, hematologic, neurologic, and reproductive systems and to the eyes and skin
- Complete blood count: at minimum a white-cell count (including differential), red-cell count, hematocrit, and hemoglobin
- Any further laboratory or other test the examining physician deems necessary by sound medical practice
🚪 Exit / Termination
At termination of employment or reassignment to an area where EtO exposure is not at/above the AL for at least 30 days/year
- Medical and work history with emphasis on symptoms related to the pulmonary, hematologic, neurologic, and reproductive systems and to the eyes and skin
- Physical examination with emphasis on the pulmonary, hematologic, neurologic, and reproductive systems and to the eyes and skin
- Complete blood count: at minimum a white-cell count (including differential), red-cell count, hematocrit, and hemoglobin
Abnormal Results & Exposure-Event Protocols
- Emergency exposure to EtO 1910.1047(i)(2)(i)(D): Provide medical examination and consultation as medically appropriate following the emergency exposure. Tests: Medical examination and consultation as medically appropriate
- Employee reports signs or symptoms of possible overexposure to EtO 1910.1047(i)(2)(i)(E): Provide a medical examination/consultation addressing the reported signs or symptoms. Tests: Medical and work history with emphasis on symptoms related to the pulmonary, hematologic, neurologic, and reproductive systems and to the eyes and skin, Physical examination with emphasis on the pulmonary, hematologic, neurologic, and reproductive systems and to the eyes and skin, Complete blood count: at minimum a white-cell count (including differential), red-cell count, hematocrit, and hemoglobin
- Employee requests advice about reproductive effects, or the physician deems it medically appropriate 1910.1047(i)(2)(ii)(B): Make available medical consultation regarding reproductive effects; the physician may include pregnancy testing or laboratory evaluation of fertility on request when medically appropriate. Tests: Reproductive-effects consultation, Pregnancy testing or laboratory evaluation of fertility (on request, when medically appropriate)
Reporting Requirements
| Who performs the evaluation | Licensed physician |
|---|---|
| Reported to employer | Written opinion limited to: whether the employee has any detected medical condition that would place health at increased risk from EtO exposure; recommended limitations on the employee or on PPE use; and a statement that the employee was informed of the results and of any condition requiring further treatment. Must NOT reveal specific findings or diagnoses unrelated to occupational EtO exposure. |
| Reported to / for the employee | Employee informed of the results and of any condition requiring further treatment; furnished a copy of the written opinion. |
| Time limits | Copy of the written opinion provided to the employee within 15 days of the employer's receipt of the physician's written opinion (1910.1047(i)(4)(iii)). |
| Second-opinion / multi-physician review | No multiple-physician-review scheme codified in the standard. |
| Recordkeeping | Medical records retained for the duration of employment plus 30 years (1910.1047(k)(3)(iii); 29 CFR 1910.1020). |
Construction
| Action Level | 0.5 ppm (8-hr TWA) |
|---|---|
| PEL | 1 ppm (8-hr TWA); excursion limit (STEL) 5 ppm / 15 min |
| Covered | Construction work covered identically to 1910.1047 by incorporation by reference (58 FR 35282, June 30, 1993). All exam events, components, abnormal protocols, and reporting are governed by 1910.1047. |
| Physician Type | Licensed physician |
| Removal (MRP) | No formal MRP scheme; the physician's written opinion may state limitations on the employee or on PPE use. |
🩺 Baseline / Pre-Placement
Prior to assignment where exposure may be at/above the AL for at least 30 days/year (per 1910.1047, incorporated by reference)
- Medical and work history with emphasis on symptoms related to the pulmonary, hematologic, neurologic, and reproductive systems and to the eyes and skin
- Physical examination with emphasis on the pulmonary, hematologic, neurologic, and reproductive systems and to the eyes and skin
- Complete blood count: at minimum a white-cell count (including differential), red-cell count, hematocrit, and hemoglobin
- Any further laboratory or other test the examining physician deems necessary by sound medical practice
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: At least annually for employees exposed at/above the AL for at least 30 days in the past year.
- Medical and work history with emphasis on symptoms related to the pulmonary, hematologic, neurologic, and reproductive systems and to the eyes and skin
- Physical examination with emphasis on the pulmonary, hematologic, neurologic, and reproductive systems and to the eyes and skin
- Complete blood count: at minimum a white-cell count (including differential), red-cell count, hematocrit, and hemoglobin
- Any further laboratory or other test the examining physician deems necessary by sound medical practice
🚪 Exit / Termination
At termination of employment or reassignment to an area where EtO exposure is not at/above the AL for at least 30 days/year
- Medical and work history with emphasis on symptoms related to the pulmonary, hematologic, neurologic, and reproductive systems and to the eyes and skin
- Physical examination with emphasis on the pulmonary, hematologic, neurologic, and reproductive systems and to the eyes and skin
- Complete blood count: at minimum a white-cell count (including differential), red-cell count, hematocrit, and hemoglobin
Abnormal Results & Exposure-Event Protocols
- Emergency exposure to EtO 1910.1047(i)(2)(i)(D): Provide medical examination and consultation as medically appropriate following the emergency exposure. Tests: Medical examination and consultation as medically appropriate
- Employee reports signs or symptoms of possible overexposure to EtO 1910.1047(i)(2)(i)(E): Provide a medical examination/consultation addressing the reported signs or symptoms. Tests: Medical and work history with emphasis on symptoms related to the pulmonary, hematologic, neurologic, and reproductive systems and to the eyes and skin, Physical examination with emphasis on the pulmonary, hematologic, neurologic, and reproductive systems and to the eyes and skin, Complete blood count: at minimum a white-cell count (including differential), red-cell count, hematocrit, and hemoglobin
- Employee requests advice about reproductive effects, or the physician deems it medically appropriate 1910.1047(i)(2)(ii)(B): Make available medical consultation regarding reproductive effects; the physician may include pregnancy testing or laboratory evaluation of fertility on request when medically appropriate. Tests: Reproductive-effects consultation, Pregnancy testing or laboratory evaluation of fertility (on request, when medically appropriate)
Reporting Requirements
| Who performs the evaluation | Licensed physician |
|---|---|
| Reported to employer | Written opinion limited to: whether the employee has any detected medical condition that would place health at increased risk from EtO exposure; recommended limitations on the employee or on PPE use; and a statement that the employee was informed of the results and of any condition requiring further treatment. Must NOT reveal specific findings or diagnoses unrelated to occupational EtO exposure. |
| Reported to / for the employee | Employee informed of the results and of any condition requiring further treatment; furnished a copy of the written opinion. |
| Time limits | Copy of the written opinion provided to the employee within 15 days of the employer's receipt (1910.1047(i)(4)(iii)). |
| Second-opinion / multi-physician review | No multiple-physician-review scheme codified in the standard. |
| Recordkeeping | Medical records retained for the duration of employment plus 30 years (1910.1047(k)(3)(iii); 29 CFR 1910.1020). |
Cal/OSHA dir.ca.gov
General Industry
| Action Level | 0.5 ppm (8-hr TWA) |
|---|---|
| PEL | 1 ppm (8-hr TWA); excursion limit (STEL) 5 ppm / 15 min |
| Covered | Employees exposed at/above the AL, without regard to respirator use, for at least 30 days/year; plus any employee exposed in an emergency |
| Physician Type | Licensed physician |
| Removal (MRP) | No formal MRP scheme; the physician's written opinion may state limitations on the employee or on PPE use. |
🩺 Baseline / Pre-Placement
Prior to assignment to an area where exposure may be at/above the AL for at least 30 days/year
- Medical and work history with emphasis on symptoms related to the pulmonary, hematologic, neurologic, and reproductive systems and to the eyes and skin
- Physical examination with emphasis on the pulmonary, hematologic, neurologic, and reproductive systems and to the eyes and skin
- Complete blood count: at minimum a white-cell count (including differential), red-cell count, hematocrit, and hemoglobin
- Any further laboratory or other test the examining physician deems necessary by sound medical practice
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: At least annually for employees exposed at/above the AL for at least 30 days in the past year.
- Medical and work history with emphasis on symptoms related to the pulmonary, hematologic, neurologic, and reproductive systems and to the eyes and skin
- Physical examination with emphasis on the pulmonary, hematologic, neurologic, and reproductive systems and to the eyes and skin
- Complete blood count: at minimum a white-cell count (including differential), red-cell count, hematocrit, and hemoglobin
- Any further laboratory or other test the examining physician deems necessary by sound medical practice
🚪 Exit / Termination
At termination of employment or reassignment to an area where EtO exposure is not at/above the AL for at least 30 days/year
- Medical and work history with emphasis on symptoms related to the pulmonary, hematologic, neurologic, and reproductive systems and to the eyes and skin
- Physical examination with emphasis on the pulmonary, hematologic, neurologic, and reproductive systems and to the eyes and skin
- Complete blood count: at minimum a white-cell count (including differential), red-cell count, hematocrit, and hemoglobin
Abnormal Results & Exposure-Event Protocols
- Emergency exposure to EtO 8 CCR 5220(i)(2)(i)(D): Provide medical examination and consultation as medically appropriate following the emergency exposure. Tests: Medical examination and consultation as medically appropriate
- Employee reports signs or symptoms of possible overexposure to EtO 8 CCR 5220(i)(2)(i)(E): Provide a medical examination/consultation addressing the reported signs or symptoms. Tests: Medical and work history with emphasis on symptoms related to the pulmonary, hematologic, neurologic, and reproductive systems and to the eyes and skin, Physical examination with emphasis on the pulmonary, hematologic, neurologic, and reproductive systems and to the eyes and skin, Complete blood count: at minimum a white-cell count (including differential), red-cell count, hematocrit, and hemoglobin
- Employee requests advice about reproductive effects, or the physician deems it medically appropriate 8 CCR 5220(i)(2)(ii)(B): Make available medical consultation regarding reproductive effects; the physician may include pregnancy testing or laboratory evaluation of fertility on request when medically appropriate. Tests: Reproductive-effects consultation, Pregnancy testing or laboratory evaluation of fertility (on request, when medically appropriate)
Reporting Requirements
| Who performs the evaluation | Licensed physician |
|---|---|
| Reported to employer | Written opinion limited to: whether the employee has any detected medical condition that would place health at increased risk from EtO exposure; recommended limitations on the employee or on PPE use; and a statement that the employee was informed of the results and of any condition requiring further treatment. Must NOT reveal specific findings or diagnoses unrelated to occupational EtO exposure. |
| Reported to / for the employee | Employee informed of the results and of any condition requiring further treatment; furnished a copy of the written opinion. |
| Time limits | Copy of the written opinion provided to the employee within 15 days of the employer's receipt of the physician's written opinion (8 CCR 5220(i)(5)(C)). |
| Second-opinion / multi-physician review | No multiple-physician-review scheme codified in the standard. |
| Recordkeeping | Medical records retained for the duration of employment plus 30 years (8 CCR 3204). |
Federal vs. California: Essentially aligned — California adopted the federal EtO standard with identical AL/PEL/STEL, CBC panel, exam-event structure (baseline, annual, explicit termination/reassignment exit exam), and the reproductive-effects consultation-on-request. No material numeric difference. California has no separate construction EtO section (construction governed federally by 1926.1147, incorporating 1910.1047 by reference).
Formaldehyde
Other Organics & CarcinogensFormaldehyde causes nasopharyngeal cancer, respiratory/skin sensitization, and mucous-membrane irritation; affects workers in resin/plastics, textiles, embalming, and wood-products manufacturing.
Federal OSHA osha.gov
General Industry
| Action Level | 0.5 ppm (8-hr TWA) |
|---|---|
| PEL | 0.75 ppm (8-hr TWA); STEL 2 ppm / 15 min |
| Covered | All employees exposed at/above the action level OR exceeding the STEL; employees who develop signs/symptoms of overexposure; and employees exposed in emergencies |
| Physician Type | Licensed physician (employer-selected) |
| Removal (MRP) | Removal/transfer triggered by physician-attributed significant eye/upper-airway irritation, respiratory sensitization, or dermal irritation/sensitization; optional 2-week evaluation/remediation period; transfer to comparable work at exposure ≤ action level maintaining earnings/seniority/benefits until comparable work is available, the employee returns, or 6 months elapse. |
🩺 Baseline / Pre-Placement
Prior to job assignment for covered employees
- Medical disease questionnaire (Appendix D) — standardized form covering work history, smoking history, eye/nose/throat irritation, chronic or hyperreactive airway disease, allergic skin conditions/dermatitis, and upper/lower respiratory problems [1910.1048(l)(3)(i)]
- Physician-administered medical examination (only if the questionnaire or physician indicates the employee may be at increased risk, or for respirator wearers) emphasizing irritation/sensitization of skin and respiratory system, shortness of breath, and eye irritation [1910.1048(l)(4)(i)]
- Baseline pulmonary function tests — FVC, FEV1, FEF — for employees required to wear respirators [1910.1048(l)(4)(ii)]
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: Medical disease questionnaire (Appendix D) administered at least annually for all covered employees. For employees required to wear respirators, a medical examination including annual pulmonary function tests (FVC, FEV1, FEF) at least annually. [1910.1048(l)(3), (l)(4)]
- Annual medical disease questionnaire (Appendix D)
- Physician physical examination (respirator wearers / flagged employees) emphasizing skin and respiratory irritation/sensitization, shortness of breath, eye irritation [1910.1048(l)(4)(i)]
- Annual pulmonary function tests — FVC, FEV1, FEF — for respirator wearers [1910.1048(l)(4)(ii)]
- Any other test the examining physician deems necessary [1910.1048(l)(4)(iii)]
⚠ Emergency / Post-Exposure
Emergency exposure (uncontrolled release)
- Medical examination as soon as possible after the emergency exposure [1910.1048(l)(5)]
- Physical examination emphasizing skin/respiratory irritation and sensitization and eye irritation
- Tests the examining physician deems necessary
Abnormal Results & Exposure-Event Protocols
- Questionnaire response or physician judgment indicates the employee may be at increased risk from formaldehyde exposure 1910.1048(l)(4): Provide a physician-administered medical examination (history, physical, and any tests the physician deems necessary). Tests: Physical examination emphasizing skin and respiratory irritation/sensitization, shortness of breath, eye irritation, Pulmonary function tests if indicated, Other tests the physician deems necessary, Counseling for employees with conditions aggravated by formaldehyde exposure [1910.1048(l)(4)(iv)]
- Examining physician determines the employee has significant irritation of the eyes or upper-airway mucosa, respiratory sensitization, or dermal irritation/sensitization attributed to workplace formaldehyde 1910.1048(l)(8)(i): Employer may, at its option, allow a 2-week evaluation and remediation period [(l)(8)(ii)] before a formal medical-removal examination; earnings, seniority, and benefits are unchanged during that period. If the condition persists, remove or transfer the employee. Tests: Follow-up medical evaluation to determine whether the condition has resolved with reduced exposure
- Medical removal required because the condition does not resolve 1910.1048(l)(8)(vi)-(vii): Transfer the employee to comparable work where exposure is at or below the action level, maintaining current earnings, seniority, and benefits until comparable work is available, the employee is found unable to return, the employee is found able to return to the original job, or 6 months elapse — whichever comes first. A follow-up examination is provided within 6 months after removal. Tests: Follow-up medical examination within 6 months after removal [1910.1048(l)(8)(vii)]
Reporting Requirements
| Who performs the evaluation | Licensed physician |
|---|---|
| Reported to employer | Written medical opinion stating whether the employee has any medical condition that would place them at increased risk of material impairment of health from formaldehyde exposure, and any recommended limitations on exposure or use of PPE/respirators [1910.1048(l)(7)(i)(A)-(B)]. The opinion must NOT disclose specific findings or diagnoses unrelated to occupational exposure to formaldehyde. |
| Reported to / for the employee | Physician must inform the employee of any medical condition that may be aggravated by formaldehyde exposure and of the need for further examination or treatment [1910.1048(l)(7)(i)(C)]. Employer furnishes a copy of the physician's written opinion to the affected employee. |
| Time limits | Employer furnishes the copy of the written opinion to the affected employee within 15 days of its receipt [1910.1048(l)(7)(iii)]. Note: monitoring results notification under (d)(5)(i) uses 'working days'; this medical opinion deadline uses calendar days. |
| Second-opinion / multi-physician review | Standard does not establish a formal multiple-physician review mechanism; physician selection is by the employer. |
| Recordkeeping | Medical records kept for the duration of employment plus 30 years [1910.1048(o)(5)(ii); 29 CFR 1910.1020]. |
Cal/OSHA dir.ca.gov
General Industry
| Action Level | 0.5 ppm (8-hr TWA) |
|---|---|
| PEL | 0.75 ppm (8-hr TWA); STEL 2 ppm / 15 min |
| Covered | Employees exposed at/above the action level OR exceeding the STEL; employees who develop signs/symptoms; employees exposed in emergencies [5217(l)(1)(A)-(B)] |
| Physician Type | Licensed physician (employer-selected) |
| Removal (MRP) | Removal/transfer to comparable work at exposure ≤ action level with maintained earnings/seniority/benefits, triggered by physician-attributed irritation/sensitization [5217(l)(8)(E)-(F)] — equivalent to federal. |
🩺 Baseline / Pre-Placement
Prior to job assignment for covered employees
- Medical disease questionnaire (content identical to federal Appendix D) — work/smoking history, eye/nose/throat irritation, chronic/hyperreactive airway disease, allergic skin conditions/dermatitis, upper/lower respiratory problems [5217(l)(3)(A)]
- Physician medical examination (when flagged or for respirator wearers) emphasizing skin and respiratory irritation/sensitization, shortness of breath, eye irritation
- Baseline pulmonary function tests — FVC, FEV1, FEF — for respirator wearers [5217(l)(4)(B)]
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: Medical disease questionnaire administered at least annually; for respirator wearers, an annual medical examination including pulmonary function tests (FVC, FEV1, FEF). [5217(l)(3)-(l)(4)]
- Annual medical disease questionnaire (identical content to federal Appendix D)
- Physician physical examination (respirator wearers / flagged employees) emphasizing skin and respiratory irritation/sensitization
- Annual pulmonary function tests — FVC, FEV1, FEF — for respirator wearers [5217(l)(4)(B)]
- Other tests the physician deems necessary
⚠ Emergency / Post-Exposure
Emergency exposure
- Medical examination as soon as possible after the emergency exposure [5217(l)(5)]
- Physical examination emphasizing skin/respiratory irritation and sensitization
- Tests the physician deems necessary
Abnormal Results & Exposure-Event Protocols
- Questionnaire response or physician judgment indicates the employee may be at increased risk 8 CCR 5217(l)(4): Provide a physician-administered medical examination. Tests: Physical examination emphasizing skin/respiratory irritation and sensitization, Pulmonary function tests if indicated, Counseling for conditions aggravated by formaldehyde
- Physician attributes significant eye/upper-airway irritation, respiratory sensitization, or dermal irritation/sensitization to workplace formaldehyde 8 CCR 5217(l)(8)(E)-(F): Remove/transfer to comparable work at exposure ≤ action level with maintained earnings, seniority, and benefits; optional evaluation/remediation period may precede formal removal. Tests: Follow-up medical evaluation to determine resolution
Reporting Requirements
| Who performs the evaluation | Licensed physician |
|---|---|
| Reported to employer | Written medical opinion stating whether the employee has a condition placing them at increased risk from formaldehyde and any recommended exposure/PPE limitations; must not disclose findings unrelated to occupational formaldehyde exposure. |
| Reported to / for the employee | Physician informs the employee of any condition aggravated by formaldehyde and need for further evaluation; employer furnishes a copy of the written opinion. |
| Time limits | Written opinion furnished to the employee within 15 days of employer receipt [8 CCR 5217(l)(7)(C)]. |
| Second-opinion / multi-physician review | Multiple-physician review: the employee may designate a second physician to review or conduct exams; if the two physicians disagree, a third (specialist) physician is jointly designated to resolve the dispute [5217(l)(9)]. |
| Recordkeeping | Medical records retained for the duration of employment plus 30 years (8 CCR 3204). |
Federal vs. California: Substantively aligned — identical limits (AL 0.5 ppm, PEL 0.75 ppm, STEL 2 ppm), identical questionnaire-based triage (Appendix D), identical PFT triggers for respirator wearers (FVC/FEV1/FEF), and equivalent removal/transfer protections. California uses lettered subsections [(l)(1)(A)] where federal uses roman numerals; the difference is cosmetic. (CA 15-day written-opinion furnishing time marked unverified — not separately confirmed in 5217 text.)
Definitions & Reference Tables
Appendix D — Medical Disease Questionnaire (formaldehyde) 29 CFR 1910.1048 App. D; 8 CCR 5217 App. D
A non-mandatory standardized medical disease questionnaire covering identification, medical history and update, occupational history, smoking/alcohol use, and a symptom review emphasizing eye/nose/throat irritation, airway/respiratory disease, and skin conditions. It is administered at the baseline exam and at least annually.
Methylene Chloride
Other Organics & CarcinogensMethylene 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.
Federal OSHA osha.gov
General Industry
| Action Level | 12.5 ppm (8-hr TWA) |
|---|---|
| PEL | 25 ppm (8-hr TWA); STEL 125 ppm / 15 min |
| 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)] |
| Physician Type | Physician or other licensed health care professional (PLHCP) [1910.1052(j)(3)] |
| Removal (MRP) | 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. |
🩺 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
- 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 evaluation | Physician or other licensed health care professional (PLHCP) |
|---|---|
| Reported to employer | Written 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 employee | Employee 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 limits | PLHCP provides the written opinion within 15 days of completion of the evaluation of medical and laboratory findings, but in no case more than 30 days after the examination [1910.1052(j)(9)(i)]. |
| Second-opinion / multi-physician review | Three-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)]. |
| Recordkeeping | Medical surveillance records maintained for the duration of employment plus 30 years [1910.1052(m)(3)(iii); 29 CFR 1910.1020]. |
Cal/OSHA dir.ca.gov
General Industry
| Action Level | 12.5 ppm (8-hr TWA) |
|---|---|
| PEL | 25 ppm (8-hr TWA); STEL 125 ppm / 15 min |
| Covered | Exposed at/above the AL on 30+ days/year or above PEL/STEL on 10+ days/year; physician-identified at-risk employees who request inclusion; emergencies [5202(j)(1)(A)-(C)] |
| Physician Type | Physician or other licensed health care professional (PLHCP) |
| Removal (MRP) | Removal/transfer on PLHCP recommendation with earnings/seniority/benefits maintained up to 6 months [5202(j)(11)] — equivalent to federal. |
🩺 Baseline / Pre-Placement
Before initial assignment
- Standardized medical/work history questionnaire — neurological symptoms, skin conditions, hematologic/liver disease history, cardiac risk factors [5202(j)(5)]
- 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
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: Age-stratified: employees aged 45 or older every 12 months; employees under 45 every 36 months [5202(j)(4)(B)].
- Updated medical/work history (standardized questionnaire)
- Physical examination emphasizing lungs, cardiovascular, 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 examination
- Updated history and physical examination
⚠ Emergency / Post-Exposure
Emergency exposure
- Decontamination
- Comprehensive examination emphasizing nervous, cardiovascular, pulmonary, hepatic, and dermal systems
- Updated history; laboratory studies as indicated (carboxyhemoglobin / CO assessment)
Abnormal Results & Exposure-Event Protocols
- PLHCP recommends removal because continued MC exposure may aggravate existing cardiac/hepatic/neurological/dermal disease 8 CCR 5202(j)(11): Transfer to comparable work (≤ action level) or remove from MC exposure; maintain earnings/seniority/benefits up to 6 months. Tests: Follow-up examination at PLHCP-recommended frequency to determine return eligibility
Reporting Requirements
| Who performs the evaluation | Physician or other licensed health care professional (PLHCP) |
|---|---|
| Reported to employer | Written opinion on whether MC exposure may aggravate existing cardiac/hepatic/neurological/dermal disease and any recommended exposure/respirator limitations; must not reveal records/findings unrelated to occupational MC exposure. |
| Reported to / for the employee | Employee informed MC is a potential occupational carcinogen, of cardiac risk factors, and of examination results and any MC-related conditions. |
| Time limits | PLHCP provides the written opinion within 15 days of completion of the evaluation of medical and laboratory findings, but in no case more than 30 days after the examination [5202(j)(9)(A)]. |
| Second-opinion / multi-physician review | Multiple-health-care-professional review mechanism mirroring federal (second PLHCP of employee's choice; jointly designated specialist as definitive determination). |
| Recordkeeping | Medical records retained for the duration of employment plus 30 years (8 CCR 3204). |
Federal vs. California: 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.)
Definitions & Reference Tables
Appendix B — Medical surveillance for methylene chloride 29 CFR 1910.1052 App. B; 8 CCR 5202 App. B
A guidance appendix on methylene-chloride medical surveillance. It explains the toxicology (CNS depressant that metabolizes to carbon monoxide, suspected carcinogen) and sets out the medical-evaluation components: a standardized work and medical history focused on neurological, cardiac, skin, and liver findings, a physical exam with pulmonary function testing, and laboratory tests.
4,4'-Methylenedianiline (MDA)
Other Organics & CarcinogensMDA is a hepatotoxin and probable carcinogen absorbed through skin; affects workers in epoxy/polyurethane manufacturing, coatings, and curing-agent handling.
Federal OSHA osha.gov
General Industry
| Action Level | 5 ppb (8-hr TWA) |
|---|---|
| PEL | 10 ppb (8-hr TWA); STEL 100 ppb / 15 min |
| 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)] |
| Physician Type | Licensed physician (examinations performed by or under the supervision of a licensed physician) [1910.1050(m)(1)(ii)] |
| Removal (MRP) | 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. |
🩺 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 (the standard does not enumerate specific assays; the typical panel (ALT/AST, alkaline phosphatase, total bilirubin) is at physician discretion) — Blood test panel checking how well your liver is working (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 — Blood test panel checking how well your liver is working (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 — Blood test panel checking how well your liver is working
- liver function tests (repeat 2–3 weeks after the initial tests) — Blood test panel checking how well your liver is working (1910.1050(m)(4))
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 evaluation | Licensed physician |
|---|---|
| Reported to employer | Written 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 employee | Employer 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 limits | Employer 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 review | Standard does not establish a formal multiple-physician review mechanism. |
| Recordkeeping | Medical surveillance records maintained for the duration of employment plus 30 years [1910.1050(n)(4)(iv); 29 CFR 1910.1020]. |
Construction
| Action Level | 5 ppb (8-hr TWA) |
|---|---|
| PEL | 10 ppb (8-hr TWA); STEL 100 ppb / 15 min |
| 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)] |
| Physician Type | Licensed physician (by or under the supervision of) |
| Removal (MRP) | Mirrors general industry — remove on acute signs or worsening abnormal LFTs; MRP up to 6 months; return when signs resolve. |
🩺 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 — Blood test panel checking how well your liver is working
- 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 — Blood test panel checking how well your liver is working
- 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 — Blood test panel checking how well your liver is working
- liver function tests (repeat 2–3 weeks after the initial tests) — Blood test panel checking how well your liver is working (1926.60(n)(4))
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 evaluation | Licensed physician |
|---|---|
| Reported to employer | Written 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 employee | Employer furnishes a copy of the written opinion to the employee. |
| Time limits | Within 15 days of employer receipt [1926.60(n)(8)]. |
| Second-opinion / multi-physician review | Multiple-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)]. |
| Recordkeeping | Medical surveillance records maintained for the duration of employment plus 30 years (29 CFR 1910.1020). |
Cal/OSHA dir.ca.gov
General Industry
| Action Level | 5 ppb (8-hr TWA) |
|---|---|
| PEL | 10 ppb (8-hr TWA); STEL 100 ppb / 15 min |
| Covered | Same five triggers as federal: AL 30+ days/year; dermal exposure 15+ days/year; emergency; reasonably believed dermal-exposed; signs/symptoms (CAS 101-77-9) |
| Physician Type | Licensed physician (by or under the supervision of) |
| Removal (MRP) | Removal on abnormal LFTs / increased-risk finding; up to 6 months wage/benefit protection — mirrors federal. |
🩺 Baseline / Pre-Placement
Before initial assignment (or within the standard's phase-in window)
- Detailed occupational and medical history
- Physical examination with particular attention to the skin and signs/symptoms of liver disease
- liver function tests (the standard does not enumerate specific assays; the typical panel (ALT/AST, alkaline phosphatase, total bilirubin) is at physician discretion) — Blood test panel checking how well your liver is working (8 CCR 5200(m)(2)(A))
- Urinalysis
- Additional tests the physician deems necessary
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: At least annually.
- Brief update of occupational/health history
- liver function tests — Blood test panel checking how well your liver is working
- Skin examination
- Additional tests the physician deems necessary
⚠ Emergency / Post-Exposure
Emergency / hazardous exposure
- Medical examination as soon as possible after the exposure
- History and physical emphasizing skin and liver
- liver function tests — Blood test panel checking how well your liver is working
- liver function tests (repeat 2–3 weeks after the initial tests) — Blood test panel checking how well your liver is working
Abnormal Results & Exposure-Event Protocols
- Employee develops signs/symptoms associated with MDA exposure 8 CCR 5200 (signs/symptoms exam): Provide an additional examination including repeat liver function tests. Tests: Repeat liver function tests, Skin/liver-focused physical examination
- Physician finds abnormal liver function tests or an increased-risk condition that could worsen with continued exposure 8 CCR 5200 — Medical Removal Protection: Remove from MDA exposure; maintain earnings/seniority/benefits (MRP) up to 6 months; return when signs resolve or physician advises. Tests: Liver function tests during removal to determine return eligibility
Reporting Requirements
| Who performs the evaluation | Licensed physician |
|---|---|
| Reported to employer | Written opinion with occupationally pertinent results, increased-risk determination, and recommended limitations; must not reveal findings unrelated to occupational exposure. |
| Reported to / for the employee | Employer furnishes a copy of the written opinion to the employee. |
| Time limits | Within 15 days of employer receipt [5200(m)(8)(A)]. |
| Second-opinion / multi-physician review | Multiple-physician review: the employee may designate a second physician [5200(m)(6)(A)]; if disagreement persists, a third physician is jointly designated to resolve it [5200(m)(6)(D)]. |
| Recordkeeping | Medical records retained for the duration of employment plus 30 years (8 CCR 3204). |
Federal vs. California: 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.)
1,2-Dibromo-3-chloropropane (DBCP)
Other Organics & CarcinogensDBCP is a reproductive toxicant causing male infertility and a probable carcinogen; affects workers in pesticide/fumigant manufacturing and handling.
Federal OSHA osha.gov
General Industry
| PEL | 1 ppb (8-hr TWA); no skin or eye contact permitted; no ceiling/STEL specified |
|---|---|
| Covered | Employees who work in regulated areas (where DBCP exposure exceeds the PEL) and employees who are exposed in emergencies [1910.1044(m)(1)(i)] |
| Physician Type | Licensed physician (examinations by or under the supervision of) [1910.1044(m)(1)(ii)] |
| Removal (MRP) | No automatic medical removal protection. The physician's written opinion identifies any increased-risk condition and recommended exposure/PPE limitations, which guide but do not mandate removal. |
🩺 Baseline / Pre-Placement
At the time of initial assignment to a regulated area [1910.1044(m)(2)]
- Complete medical and occupational history, including reproductive history [1910.1044(m)(2)(i)]
- Physical examination including the genitourinary tract, testicle size, and body habitus, with a determination of sperm count [1910.1044(m)(2)(ii)]
- Serum hormone determinations by radioimmunoassay (NIH-specific antigen or equivalent sensitivity): serum follicle-stimulating hormone (FSH), serum luteinizing hormone (LH), and serum total estrogen (females) [1910.1044(m)(2)(iii)]
- Any other tests the examining physician deems appropriate [1910.1044(m)(2)(iv)]
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: At least annually after the initial examination [1910.1044(m)(2)].
- Updated medical/occupational and reproductive history
- Physical examination including genitourinary tract, testicle size, body habitus, and sperm count determination
- Serum FSH, LH, and total estrogen (females) by radioimmunoassay
- Other tests the physician deems appropriate
⚠ Emergency / Post-Exposure
Emergency exposure
- Sperm count determination as soon as practicable after the exposure [1910.1044(m)(6)]
- If the employee has had a vasectomy or is otherwise unable to produce a specimen, serum FSH, LH, and total estrogen (females) by radioimmunoassay instead
- Repeat of the same tests 3 months later [1910.1044(m)(6)]
Abnormal Results & Exposure-Event Protocols
- Employee develops signs or symptoms commonly associated with DBCP exposure 1910.1044(m)(3): Provide an additional medical examination including the reproductive battery and any tests the physician deems appropriate. Tests: Sperm count determination, Serum FSH, LH, total estrogen (females) by radioimmunoassay, Genitourinary physical examination
- Physician detects a medical condition that places the employee at increased risk from DBCP exposure 1910.1044(m)(5)(i): No automatic medical-removal criteria. The physician's written opinion states any detected increased-risk condition [(m)(5)(i)(b)] and any recommended limitations on exposure or PPE use [(m)(5)(i)(c)]; these guide but do not mandate employer action. Tests: Follow-up reproductive testing as the physician recommends
Reporting Requirements
| Who performs the evaluation | Licensed physician |
|---|---|
| Reported to employer | Written opinion including the results of the medical examination and tests, the physician's assessment of whether the employee has any detected medical condition that places them at increased risk from DBCP exposure, and any recommended limitations on exposure or PPE use [1910.1044(m)(5)(i)]. The employer must instruct the physician NOT to reveal in the written opinion specific findings or diagnoses unrelated to occupational exposure [1910.1044(m)(5)(ii)]. |
| Reported to / for the employee | Employer provides the employee with a copy of the written opinion; physician informs the employee of any condition that may require further examination or treatment. |
| Time limits | Employer furnishes a copy of the written opinion to the employee (standard requires provision but a specific day-count is not stated in (m)(5)). |
| Second-opinion / multi-physician review | Standard does not establish a formal multiple-physician review mechanism. |
| Recordkeeping | Medical surveillance records maintained for at least 40 years, or the duration of employment plus 20 years, whichever is longer [1910.1044(p)(2)(iii)]. |
Cal/OSHA dir.ca.gov
General Industry
| PEL | 1 ppb (8-hr TWA); no eye or skin contact permitted |
|---|---|
| Covered | Employees in regulated areas plus employees exposed in emergencies; additional exams when signs/symptoms develop [5212(m)(1)(A), (m)(3)]. NOTE: Cal/OSHA DBCP is 8 CCR 5212, NOT 5215 (5215 regulates MBOCA/MOCA, a different chemical). |
| Physician Type | Licensed physician (by or under the supervision of) |
| Removal (MRP) | No explicit MRP; physician recommends exposure/PPE limitations only — equivalent to federal. |
🩺 Baseline / Pre-Placement
At the time of initial assignment [5212(m)(2)]
- Complete medical and occupational history, including reproductive history
- Physical examination including genitourinary tract, testicle size, body habitus, and sperm count determination [5212(m)(2)(B)]
- If a sperm count is unavailable, serum FSH and LH by radioimmunoassay [5212(m)(2)(C)]
- Serum total estrogen by radioimmunoassay on females [5212(m)(2)(D)]
- Other tests the physician deems appropriate
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: At least annually after the initial examination [5212(m)(2)].
- Updated medical/occupational and reproductive history
- Physical examination including genitourinary tract, testicle size, body habitus, sperm count
- Serum FSH/LH if sperm count unavailable; serum total estrogen (females) by radioimmunoassay
- Other tests the physician deems appropriate
⚠ Emergency / Post-Exposure
Emergency exposure
- Sperm count determination as soon as practicable [5212(m)(6)]
- Serum FSH/LH (and total estrogen for females) by radioimmunoassay if sperm count unavailable
- Repeat of the same tests 3 months later [5212(m)(6)]
Abnormal Results & Exposure-Event Protocols
- Employee develops signs/symptoms associated with DBCP exposure 8 CCR 5212(m)(3): Provide an additional medical examination including the reproductive battery. Tests: Sperm count / serum FSH, LH, total estrogen (females) by radioimmunoassay, Genitourinary physical examination
- Physician detects an increased-risk condition 8 CCR 5212(m)(5)(A)(3): No explicit medical removal protection; physician recommends limitations on exposure or PPE use, which guide but do not mandate employer action. Tests: Follow-up reproductive testing as the physician recommends
Reporting Requirements
| Who performs the evaluation | Licensed physician |
|---|---|
| Reported to employer | Written opinion with examination/test results, any increased-risk determination, and recommended exposure/PPE limitations [5212(m)(5)(A)]; must not reveal findings unrelated to occupational exposure. |
| Reported to / for the employee | Employer furnishes a copy of the written opinion to the employee. |
| Time limits | No specific day-count for furnishing the written opinion to the employee is stated in 8 CCR 5212(m)(5); the standard requires provision without specifying a deadline. |
| Second-opinion / multi-physician review | No formal multiple-physician review mechanism specified. |
| Recordkeeping | Medical records retained for at least 40 years or the duration of employment plus 20 years, whichever is longer (consistent with federal; 8 CCR 3204). |
Federal vs. California: Substantively equivalent — both mandate the same reproductive battery (sperm count, plus serum FSH/LH and total estrogen for females by radioimmunoassay) and the same emergency sperm-count protocol repeated at 3 months; neither imposes automatic medical removal. The key practitioner pitfall is the Cal/OSHA section number: DBCP = 8 CCR 5212, NOT 5215 (5215 is MBOCA). (CA recordkeeping retention and written-opinion timing marked unverified — not separately confirmed in 5212 text.)
13 Carcinogens
Other Organics & CarcinogensA group of 13 no-PEL carcinogens (e.g., benzidine, beta-naphthylamine, bis-chloromethyl ether) regulated by a regulated-area / no-detectable-contact model; affects research, chemical-manufacturing, and laboratory workers handling these substances.
Federal OSHA osha.gov
General Industry
| Covered | Employees considered for assignment to enter regulated areas and authorized employees. No air PEL — regulation is by contact/regulated area wherever a covered carcinogen is manufactured, processed, used, repackaged, released, handled, or stored [1910.1003(c), (g)] |
|---|---|
| Physician Type | Physician (licensed) |
| Removal (MRP) | No medical removal protection program. The standard relies on the physician's suitability statement and increased-risk-factor evaluation rather than result-triggered removal. |
🩺 Baseline / Pre-Placement
Before an employee enters (is assigned to) a regulated area [1910.1003(g)(1)(i)]
- Preassignment physical examination by a physician
- Personal history of the employee and family and occupational background, including genetic and environmental factors [1910.1003(g)(1)(i)]
- Physician consideration of conditions of increased risk — reduced immunological competence, treatment with steroids or cytotoxic agents, pregnancy, and cigarette smoking [1910.1003(g)(1)(iii)]
- NOTE: the standard imposes NO substance-specific laboratory panel; specific tests are left to the physician's judgment
🕒 Periodic / Routine
Interval-based while authorized — NOT result-triggered
Schedule: Periodic physical examinations not less often than annually following the preassignment examination [1910.1003(g)(1)(ii)].
- Physical examination by a physician
- Updated personal/family/occupational history including genetic and environmental factors
- Physician consideration of increased-risk conditions (reduced immunological competence, steroid/cytotoxic treatment, pregnancy, cigarette smoking)
- NOTE: NO substance-specific laboratory panel is mandated
⚠ Emergency / Post-Exposure
Employee present in the potentially affected area at the time of an emergency [1910.1003(d)(2)(iii)]
- Special medical surveillance by a physician instituted within 24 hours of the emergency
- Examination and history as the physician determines (no enumerated lab panel)
Reporting Requirements
| Who performs the evaluation | Physician |
|---|---|
| Reported to employer | The examining physician furnishes the employer a statement of the employee's suitability for employment in the specific exposure [1910.1003(g)(2)(iii)]. The standard does not prescribe a detailed limited written-opinion content list as the substance-specific standards do. |
| Reported to / for the employee | Standard does not specify a separate employee-notification timetable beyond access to records under 29 CFR 1910.1020. |
| Time limits | No specific day-count for furnishing the suitability statement is stated in (g)(2)(iii). |
| Second-opinion / multi-physician review | No multiple-physician review mechanism specified. |
| Recordkeeping | Complete and accurate records of medical examinations maintained for the duration of the employee's employment [1910.1003(g)(2)(i)]. |
Cal/OSHA dir.ca.gov
General Industry
| Covered | Covers the same 13 carcinogens under the same regulated-area model; program for employees considered for assignment to, and authorized to enter, regulated areas [5209(g)] |
|---|---|
| Physician Type | Licensed physician |
| Removal (MRP) | No medical removal protection program — relies on physician suitability evaluation and increased-risk-factor consideration. |
🩺 Baseline / Pre-Placement
Before an employee enters a regulated area [5209(g)(1)(A)]
- Preassignment medical examination by a licensed physician
- Personal and family history with respect to genetic and occupational factors [5209(g)(1)(A)]
- Physician consideration of conditions of increased risk — reduced immunological competence, steroid/cytotoxic treatment, pregnancy, cigarette smoking [5209(g)(1)(C)]
- NOTE: no substance-specific laboratory panel mandated
🕒 Periodic / Routine
Interval-based while authorized — NOT result-triggered
Schedule: Periodic examinations not less often than annually [5209(g)(1)(B)].
- Physical examination by a licensed physician
- Updated personal/family history re genetic/occupational factors
- Physician consideration of increased-risk conditions (reduced immunological competence, steroid/cytotoxic treatment, pregnancy, cigarette smoking)
- NOTE: no substance-specific laboratory panel mandated
⚠ Emergency / Post-Exposure
Employee present at the time of an emergency [5209(d)]
- Special medical surveillance by a physician within 24 hours of the emergency
- Examination and history as the physician determines (no enumerated lab panel)
Reporting Requirements
| Who performs the evaluation | Licensed physician |
|---|---|
| Reported to employer | Physician furnishes a statement of the employee's suitability for the specific exposure; no detailed limited-written-opinion content list as in substance-specific standards. |
| Reported to / for the employee | No separate employee-notification timetable specified beyond records access under 8 CCR 3204. |
| Second-opinion / multi-physician review | No multiple-physician review mechanism specified. |
| Recordkeeping | Records maintained for the duration of the employee's employment; upon termination, retirement, or death, records (or notarized copies) are forwarded by registered mail to the Director, NIOSH [8 CCR 5209(g)(2)(A)]. |
Federal vs. California: Substantively aligned — Cal/OSHA 5209 is a close analog of federal 1910.1003: same 13 substances, same preassignment + at-least-annual physical examination, the same genetic/family-history and increased-risk-factor framework, and the same 24-hour emergency surveillance. Critically, NEITHER standard mandates a substance-specific laboratory panel — exam content is physician-determined. (CA recordkeeping detail marked unverified — retention duration not separately confirmed in 5209 text.)
4,4'-Methylenebis(2-Chloroaniline) (MBOCA/MOCA)
Other Organics & CarcinogensMBOCA (MOCA) is a probable bladder/liver carcinogen absorbed through skin; affects workers in polyurethane elastomer/casting and curing-agent operations. Surveillance keys on a urinary biological exposure limit rather than airborne sampling.
Federal OSHA osha.gov
General Industry
No direct federal OSHA substance-specific MBOCA standard exists. (MBOCA was among substances OSHA addressed by separate rulemaking that did not survive as a discrete substance standard.) Federal coverage is general only — Hazard Communication (1910.1200) and the General Duty Clause. Documented here primarily to prevent citation confusion: Cal/OSHA regulates MBOCA at 8 CCR 5215, which is distinct from DBCP at 8 CCR 5212.
Cal/OSHA dir.ca.gov
All Covered Work
| Action Level | Use-based trigger (no airborne AL/PEL framework). Biological exposure limit: urine MBOCA ≤ 100 µg per liter of urine, specific gravity adjusted to 1.024 [5215(c)(1)] |
|---|---|
| Covered | Employers using more than one kilogram of MBOCA (regardless of concentration, dilution, or form, except frozen premix) in any 6-month period; authorized persons handling MBOCA [5215(d)(1)] |
| Physician Type | Licensed physician (examinations by or under the supervision of) [5215(k)] |
| Removal (MRP) | No mandatory medical removal protection criterion. Abnormal biological (urine MBOCA) results prompt repeat testing and exposure-control review; withdrawal is at physician discretion. |
🩺 Baseline / Pre-Placement
Prior to the time of initial assignment, or within 90 days of the standard's effective date [5215(k)(1)]
- Comprehensive medical history with emphasis on pertinent medical, occupational, genetic, and environmental factors [5215(k)(2)]
- Comprehensive physical examination with emphasis on detecting abnormalities of the liver, pulmonary system, urinary system, breasts, and hematologic system [5215(k)(2)]
- Chest X-ray (14×17 PA)
- Complete blood count (CBC)
- Complete urinalysis
- Liver function tests: serum total bilirubin, alkaline phosphatase, and SGOT/SGPT
- NOTE: urine cytology is NOT required by this standard
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: At least every 3 years for the first 10 years of employment involving the use of MBOCA, and annually thereafter [5215(k)(1)].
- Updated comprehensive medical history (medical/occupational/genetic/environmental factors)
- Comprehensive physical examination emphasizing liver, pulmonary, urinary, breast, and hematologic systems
- Chest X-ray (14×17 PA)
- Complete blood count (CBC)
- Complete urinalysis
- Liver function tests: total bilirubin, alkaline phosphatase, SGOT/SGPT
- NOTE: NO urine cytology
Abnormal Results & Exposure-Event Protocols
- Urine MBOCA exceeds the 100 µg/L biological exposure limit (or another abnormal biological result) 8 CCR 5215(c)/(k) — biological monitoring response: Repeat the abnormal biological measurement as soon as practicable within 30 days and investigate exposure controls [8 CCR 5215 Appendix B(1)]; if abnormalities persist, consideration should be given to withdrawing the employee from contact. No mandatory medical-removal criterion is established. Tests: Repeat urine MBOCA determination, Physician evaluation of liver/urinary/hematologic status
Reporting Requirements
| Who performs the evaluation | Licensed physician |
|---|---|
| Reported to employer | Written opinion of the examining physician regarding the employee's medical status relative to MBOCA exposure (occupationally pertinent findings). |
| Reported to / for the employee | Physician must provide a copy of the written opinion to the affected employee [5215(k)]. |
| Time limits | Standard requires the written opinion be provided to the employee; a specific day-count is not stated in the verified text. |
| Second-opinion / multi-physician review | No multiple-physician review mechanism specified. |
| Recordkeeping | Physician opinions/records retained for the duration of employment plus 20 years, or 30 years, whichever is longer [8 CCR 5215(l)(6)]. |
Federal vs. California: California-only — 8 CCR 5215 regulates MBOCA via a urinary biological exposure limit (urine MBOCA ≤ 100 µg/L) with comprehensive liver/pulmonary/urinary/breast/hematologic exams, chest X-ray, CBC, urinalysis, and liver function tests; there is NO direct federal OSHA substance-specific MBOCA standard (federal coverage is HazCom + General Duty Clause only). Critically, this standard requires NO urine cytology. Note the common citation trap: 5215 (MBOCA) is distinct from 5212 (DBCP).
Respiratory Protection — Medical Evaluation
Program-Based StandardsRespirator use imposes physiological burden (cardiopulmonary stress) requiring medical clearance; affects any worker required to wear a respirator across general industry and construction.
Federal OSHA osha.gov
General Industry
| Covered | Every employee required to use a respirator must receive a medical evaluation to determine ability to use a respirator before fit testing or use; also when re-evaluation triggers arise. |
|---|---|
| Physician Type | PLHCP — physician or other licensed health care professional |
| Removal (MRP) | No medical removal protection — this is a medical clearance/evaluation to use a respirator, not a removal-based surveillance program. There is NO fixed periodic interval; re-evaluation is trigger-based (see abnormal_protocols). |
🩺 Baseline / Pre-Placement
Before the employee is fit tested or required to use a respirator in the workplace — 1910.134(e)(1)
- OSHA Respirator Medical Evaluation Questionnaire — Appendix C (Mandatory), Part A Section 1 (mandatory for all): today's date, name, age, sex, height, weight, job title, contact phone, best time to call, confirmation employer communicated PLHCP contact info, respirator type to be used, previous respirator experience and types
- Part A Section 2, Questions 1–9 (mandatory for all users): Q1 tobacco use; Q2 seizures/diabetes/breathing allergies/claustrophobia/smell impairment; Q3 prior lung conditions (asthma, emphysema, TB, silicosis, lung cancer, rib fractures); Q4 current pulmonary symptoms (exertional dyspnea, cough, wheeze, hemoptysis, chest pain); Q5 prior cardiovascular conditions (heart attack, stroke, angina, heart failure, arrhythmia, hypertension); Q6 current cardiovascular symptoms; Q7 current medications for breathing, heart, BP, or seizures; Q8 prior respirator-related problems; Q9 desire to discuss with PLHCP (Q9 does not trigger a medical examination per Appendix C preamble)
- Part A Section 2, Questions 10–15 (additionally mandatory for full-facepiece and SCBA users): Q10 prior vision loss; Q11 current eye issues (contact lenses, glasses, color blindness); Q12 prior ear injuries (ruptured eardrum); Q13 current hearing problems; Q14 prior back injury; Q15 current musculoskeletal limitations
- Part B questions at PLHCP discretion
- PAPR provision — 1910.134(e)(6)(ii): if a PLHCP medical evaluation finds an employee cannot use a negative-pressure respirator, but can use a powered air-purifying respirator (PAPR), the employer shall provide a PAPR
Abnormal Results & Exposure-Event Protocols
- Employee gives a positive response to any question among questions 1 through 8 in Section 2, Part A of Appendix C (note: a 'yes' to Q9 — desire to discuss with PLHCP — does not by itself require a medical examination), OR the initial medical exam indicates a need for follow-up — 1910.134(e)(3)(i)-(ii) 1910.134(e)(3)(i)-(ii): Employer provides a FOLLOW-UP medical examination by the PLHCP; the follow-up exam includes any medical tests, consultations, or diagnostic procedures the PLHCP deems necessary to make a determination of fitness to use a respirator. Tests: Medical examination by the PLHCP, Any medical tests, consultations, or diagnostic procedures the PLHCP deems necessary (e.g., spirometry or chest X-ray ONLY if the PLHCP deems them necessary — not mandated by the standard)
- Additional medical re-evaluation required when: (i) the employee reports medical signs/symptoms related to ability to use a respirator; (ii) a PLHCP, supervisor, or respirator program administrator informs the employer that re-evaluation is needed; (iii) information from the respiratory protection program (including observations during fit testing or program evaluation) indicates a need; or (iv) a workplace change occurs that may substantially increase the physiological burden on the employee. 1910.134(e)(7): Provide an additional medical evaluation (questionnaire or exam as appropriate) to re-determine the employee's ability to use the respirator. Tests: Repeat medical evaluation via Appendix C questionnaire or examination, as indicated by the trigger
Reporting Requirements
| Who performs the evaluation | PLHCP (physician or other licensed health care professional whose scope of practice permits the services in paragraph (e)) |
|---|---|
| Reported to employer | PLHCP provides a WRITTEN RECOMMENDATION limited to: (1) any limitations on respirator use related to the employee's medical condition OR relating to the workplace conditions in which the respirator will be used, including whether or not the employee is medically able to use the respirator; (2) the need, if any, for follow-up medical evaluations; and (3) a statement that the PLHCP has provided the employee a copy of the written recommendation — 1910.134(e)(6)(i). No clinical findings or diagnoses are disclosed. |
| Reported to / for the employee | PLHCP must provide the employee a copy of the PLHCP's written recommendation. |
| Time limits | Evaluation must be completed before fit testing or first respirator use. No fixed turnaround stated for the recommendation beyond that it precede respirator use. |
| Recordkeeping | Medical evaluation records (questionnaire and PLHCP recommendation) retained per 29 CFR 1910.1020 — duration of employment plus 30 years. The completed questionnaire is confidential to the PLHCP; the employer is not given the questionnaire itself. |
Construction
| Covered | Construction respiratory protection standard (1926.103) incorporates 1910.134 by reference — the SAME medical evaluation requirements apply to construction workers required to use respirators. |
|---|---|
| Physician Type | PLHCP — physician or other licensed health care professional |
| Removal (MRP) | No medical removal protection — this is a medical clearance/evaluation to use a respirator, not a removal-based surveillance program. There is NO fixed periodic interval; re-evaluation is trigger-based (see abnormal_protocols). |
🩺 Baseline / Pre-Placement
Before the employee is fit tested or required to use a respirator in the workplace — 1910.134(e)(1)
- OSHA Respirator Medical Evaluation Questionnaire — Appendix C (Mandatory), Part A, Section 1 (basic info: name, age, height, weight, job title, respirator type) and Section 2 (mandatory medical-history/symptom questions, Q1-8 cardiopulmonary; Q10-15 mandatory for full-facepiece/SCBA users) — covering tobacco use; seizures/diabetes/allergies/claustrophobia; pulmonary conditions (asthma, emphysema, TB, lung cancer); current respiratory symptoms (shortness of breath, cough, wheeze, chest pain); cardiovascular history/symptoms (heart attack, angina, arrhythmia); current cardiac/respiratory/BP/seizure medications; prior respirator-use problems
- Alternatively, an initial medical examination that obtains the SAME information as the Appendix C questionnaire (equivalent entry pathway)
- Appendix C Part B questions at the PLHCP's discretion (occupational exposures, work intensity/duration, environmental conditions, additional protective clothing)
- PAPR provision — 1910.134(e)(6)(ii) (incorporated by reference via 29 CFR 1926.103): if a PLHCP medical evaluation finds an employee cannot use a negative-pressure respirator, but can use a powered air-purifying respirator (PAPR), the employer shall provide a PAPR
Abnormal Results & Exposure-Event Protocols
- Employee answers 'yes' to any of questions 1-8 in Section 2, Part A of Appendix C, OR the initial medical exam shows a need 1910.134(e)(3)(i)-(ii): Employer provides a FOLLOW-UP medical examination by the PLHCP; the follow-up exam includes any medical tests, consultations, or diagnostic procedures the PLHCP deems necessary to make a determination of fitness to use a respirator. Tests: Medical examination by the PLHCP, Any medical tests, consultations, or diagnostic procedures the PLHCP deems necessary (e.g., spirometry or chest X-ray ONLY if the PLHCP deems them necessary — not mandated by the standard)
- Additional medical re-evaluation required when: (i) the employee reports medical signs/symptoms related to ability to use a respirator; (ii) a PLHCP, supervisor, or respirator program administrator informs the employer that re-evaluation is needed; (iii) information from the respiratory protection program (including observations during fit testing or program evaluation) indicates a need; or (iv) a workplace change occurs that may substantially increase the physiological burden on the employee. 1910.134(e)(7): Provide an additional medical evaluation (questionnaire or exam as appropriate) to re-determine the employee's ability to use the respirator. Tests: Repeat medical evaluation via Appendix C questionnaire or examination, as indicated by the trigger
Reporting Requirements
| Who performs the evaluation | PLHCP (physician or other licensed health care professional whose scope of practice permits the services in paragraph (e)) |
|---|---|
| Reported to employer | PLHCP provides a WRITTEN RECOMMENDATION limited to: whether the employee is medically able to use the respirator; any limitations on respirator use (including for emergency/high-burden conditions); the need for a follow-up medical evaluation; and a statement that the PLHCP has provided the employee a copy of the recommendation. No clinical findings or diagnoses are disclosed. |
| Reported to / for the employee | PLHCP must provide the employee a copy of the PLHCP's written recommendation. |
| Time limits | Evaluation must be completed before fit testing or first respirator use. No fixed turnaround stated for the recommendation beyond that it precede respirator use. |
| Recordkeeping | Medical evaluation records (questionnaire and PLHCP recommendation) retained per 29 CFR 1910.1020 — duration of employment plus 30 years. The completed questionnaire is confidential to the PLHCP; the employer is not given the questionnaire itself. |
Cal/OSHA dir.ca.gov
All Covered Work
| Covered | Every employee required to use a respirator must receive a medical evaluation before fit testing or use. 8 CCR 5144 applies across covered work (general industry and construction) — Cal/OSHA does not split respiratory protection into separate GI/construction sections; medical-evaluation provisions in 5144(e) track 1910.134(e) nearly verbatim. |
|---|---|
| Physician Type | PLHCP — physician or other licensed health care professional (California licensure scope) |
| Removal (MRP) | No medical removal protection — medical clearance to use a respirator, not removal-based surveillance. No fixed periodic interval; re-evaluation is trigger-based (see abnormal_protocols). |
🩺 Baseline / Pre-Placement
Before the employee is fit tested or required to use a respirator — 8 CCR 5144(e)(1)
- OSHA Respirator Medical Evaluation Questionnaire — Appendix C (Mandatory), Part A, Section 1 (basic info: name, age, height, weight, job title, respirator type) and Section 2 (mandatory medical-history/symptom questions, Q1-8 cardiopulmonary; Q10-15 mandatory for full-facepiece/SCBA users) — covering tobacco use; seizures/diabetes/allergies/claustrophobia; pulmonary conditions (asthma, emphysema, TB, lung cancer); current respiratory symptoms (shortness of breath, cough, wheeze, chest pain); cardiovascular history/symptoms (heart attack, angina, arrhythmia); current cardiac/respiratory/BP/seizure medications; prior respirator-use problems
- Alternatively, an initial medical examination that obtains the SAME information as the Appendix C questionnaire (equivalent entry pathway)
- Appendix C Part B questions at the PLHCP's discretion (occupational exposures, work intensity/duration, environmental conditions, additional protective clothing)
- PAPR provision — 8 CCR 5144(e)(6)(B): if a PLHCP medical evaluation finds an employee cannot use a negative-pressure respirator, but can use a powered air-purifying respirator (PAPR), the employer shall provide a PAPR
Abnormal Results & Exposure-Event Protocols
- Employee answers 'yes' to any of questions 1-8 in Section 2, Part A of Appendix C, OR the initial medical exam shows a need 8 CCR 5144(e)(3): Employer provides a FOLLOW-UP medical examination by the PLHCP; the follow-up exam includes any medical tests, consultations, or diagnostic procedures the PLHCP deems necessary to make a determination of fitness to use a respirator. Tests: Medical examination by the PLHCP, Any medical tests, consultations, or diagnostic procedures the PLHCP deems necessary (e.g., spirometry or chest X-ray ONLY if the PLHCP deems them necessary — not mandated by the standard)
- Additional medical re-evaluation required when: (i) the employee reports medical signs/symptoms related to ability to use a respirator; (ii) a PLHCP, supervisor, or respirator program administrator informs the employer that re-evaluation is needed; (iii) information from the respiratory protection program (including observations during fit testing or program evaluation) indicates a need; or (iv) a workplace change occurs that may substantially increase the physiological burden on the employee. 8 CCR 5144(e)(7): Provide an additional medical evaluation (questionnaire or exam as appropriate) to re-determine the employee's ability to use the respirator. Tests: Repeat medical evaluation via Appendix C questionnaire or examination, as indicated by the trigger
Reporting Requirements
| Who performs the evaluation | PLHCP (physician or other licensed health care professional whose scope of practice permits the services in paragraph (e)) |
|---|---|
| Reported to employer | PLHCP provides a WRITTEN RECOMMENDATION limited to: whether the employee is medically able to use the respirator; any limitations on respirator use (including for emergency/high-burden conditions); the need for a follow-up medical evaluation; and a statement that the PLHCP has provided the employee a copy of the recommendation. No clinical findings or diagnoses are disclosed. |
| Reported to / for the employee | PLHCP must provide the employee a copy of the PLHCP's written recommendation. |
| Time limits | Evaluation must be completed before fit testing or first respirator use. No fixed turnaround stated for the recommendation beyond that it precede respirator use. |
| Recordkeeping | Medical evaluation records retained per 8 CCR 3204 — duration of employment plus 30 years. The completed questionnaire is confidential to the PLHCP; the employer is not given the questionnaire itself. |
Federal vs. California: Essentially aligned — 8 CCR 5144(e) tracks 29 CFR 1910.134(e) nearly verbatim (same pre-use evaluation, same PLHCP definition, same Appendix C questionnaire pathway, same follow-up and four re-evaluation triggers). Difference is jurisdictional/administrative only. Federal splits the requirement across general industry (1910.134) and construction-by-reference (1926.103); California applies a single 5144 across covered work.
Definitions & Reference Tables
Appendix C — OSHA Respirator Medical Evaluation Questionnaire (Mandatory) 29 CFR 1910.134 App. C; 8 CCR 5144 App. C
The mandatory respirator medical evaluation questionnaire. Part A Section 1 collects basic information and respirator-use history; Part A Section 2 asks mandatory cardiopulmonary medical-history and symptom questions (with additional mandatory questions for full-facepiece/SCBA users); Part B contains optional questions the PLHCP may add. An equivalent initial medical exam obtaining the same information may be used instead.
Occupational Noise / Hearing Conservation
Program-Based StandardsOccupational noise causes permanent noise-induced hearing loss; affects workers exposed at or above an 8-hour TWA of 85 dBA in manufacturing, construction, and other high-noise settings.
Federal OSHA osha.gov
General Industry
| Action Level | 85 dBA (8-hr TWA / 50% dose) — triggers the hearing conservation program and audiometric monitoring — 1910.95(c)(1) |
|---|---|
| PEL | 90 dBA (8-hr TWA / 100% dose) — for engineering/administrative-control purposes |
| Covered | Employees whose noise exposures equal or exceed the 85 dBA 8-hr TWA Action Level. |
| Physician Type | Audiologist, otolaryngologist, or other physician (with CAOHC-certified technician permitted to administer tests under their responsibility) |
| Removal (MRP) | No MRP. On a Standard Threshold Shift, the employer must refit/retrain hearing protectors (greater attenuation if needed) and refer for clinical/otological evaluation when indicated (see abnormal_protocols). No exit audiogram is mandated by 1910.95. |
🩺 Baseline / Pre-Placement
Within 6 months of an employee's first exposure at/above the Action Level (up to 1 year if a mobile test van is used, with hearing protectors worn after 6 months until the baseline is obtained) — 1910.95(g)(5)
- Pure-tone, air-conduction audiometric test of each ear at 500, 1000, 2000, 3000, 4000, and 6000 Hz — 1910.95(h)(1)
- Preceded by at least 14 hours without workplace noise exposure (hearing protectors may substitute for that quiet period) — 1910.95(g)(5)(iii)
- Audiometer functional/calibration checks; test room meeting Appendix D ambient-noise limits
🕒 Periodic / Routine
Interval-based while exposed at/above the Action Level — NOT result-triggered
Schedule: A new audiogram at least ANNUALLY after the baseline — 1910.95(g)(6)
- Pure-tone, air-conduction audiometric test of each ear at 500, 1000, 2000, 3000, 4000, and 6000 Hz — 1910.95(h)(1)
- Comparison of the annual audiogram against the baseline to determine whether a Standard Threshold Shift (STS) has occurred (average shift of 10 dB or more at 2000, 3000, and 4000 Hz in either ear) — 1910.95(g)(10)(i)
Abnormal Results & Exposure-Event Protocols
- Standard Threshold Shift (STS) identified on an annual audiogram (avg ≥10 dB at 2000/3000/4000 Hz in either ear), unless a physician/audiologist determines the STS is not work-related or aggravated by occupational noise 1910.95(g)(8)(ii): Within the required timeframes: (1) fit/refit affected employees with hearing protectors, train them, and require use; for employees already using protectors, refit/retrain and provide protectors with greater attenuation if needed; (2) refer the employee for a clinical audiological evaluation or otological examination if additional testing is needed or if a medical pathology of the ear is suspected as caused/aggravated by hearing protector use; (3) inform the employee of the need for a medical evaluation if a medical ear pathology unrelated to protector use is suspected. Notify employee in writing within 21 days of the determination. Tests: Written notification to employee within 21 days — 1910.95(g)(8)(i), Hearing-protector fitting/refitting, training, and required use (with greater attenuation if indicated), Referral for clinical audiological evaluation or otological examination when indicated, Retest of the audiogram permitted to confirm a persistent STS
- Persistent STS that the professional determines may be reported as a recordable hearing-loss case 1910.95(g)(9): Employer MAY (at its option) obtain a retest audiogram within 30 days and consider those results as the annual audiogram — 1910.95(g)(7)(ii). Separately, an annual audiogram MAY be substituted for the baseline audiogram (baseline revision) when, in the judgment of the audiologist, otolaryngologist, or physician, the STS is persistent — 1910.95(g)(9). Both retest and baseline revision are discretionary, not mandatory. Record on the OSHA 300 log if work-related hearing-loss criteria are met. Tests: Confirmation audiogram within 30 days, Baseline revision when STS persists
Reporting Requirements
| Who performs the evaluation | Audiometric tests performed by a licensed/certified audiologist, otolaryngologist, or other physician, OR by a technician certified by the Council for Accreditation in Occupational Hearing Conservation (CAOHC) who is responsible to the audiologist/physician (microprocessor-audiometer operators need not be certified but must be supervised). Audiogram review and STS/work-relatedness determinations made by an audiologist, otolaryngologist, or physician — 1910.95(g)(3). |
|---|---|
| Reported to employer | No employer-directed written fitness opinion under 1910.95. The professional reviewing audiograms determines whether an STS occurred and whether it is work-related; the employer acts on STS follow-up obligations. |
| Reported to / for the employee | Employee must be informed IN WRITING within 21 days of the determination that a Standard Threshold Shift (STS) has occurred — 1910.95(g)(8)(i). |
| Time limits | STS written notification to employee within 21 days of the determination. |
| Recordkeeping | Audiometric test records retained for the DURATION of the affected employee's employment — 1910.95(m)(3). (Noise-exposure measurement records: 2 years.) |
Construction
Construction noise standards (29 CFR 1926.52 permissible exposure and 29 CFR 1926.101 hearing protection) require feasible controls and provision/fitting/use of hearing protectors (plain cotton not acceptable) when exposures exceed Table D-2 (90 dBA/8 hr). They reference a 'continuing, effective hearing conservation program' in the abstract but PRESCRIBE NO audiometric monitoring program — no baseline/annual audiograms, no STS provisions, and no PLHCP medical evaluation. From a medical-surveillance standpoint there is NO mandated audiometric exam requirement in construction. (Sources: https://www.osha.gov/laws-regs/regulations/standardnumber/1926/1926.52 ; https://www.osha.gov/laws-regs/regulations/standardnumber/1926/1926.101)
Cal/OSHA dir.ca.gov
General Industry
| Action Level | 85 dBA (8-hr TWA) action level — 8 CCR 5097. PEL: 90 dBA (8-hr TWA) — 8 CCR 5096 Table N-1 (not 'Table 5-3'). |
|---|---|
| PEL | 90 dBA (8-hr TWA) PEL |
| Covered | Employees exposed at/above the 85 dBA 8-hr TWA Action Level; audiometric/HCP medical provisions live in 8 CCR 5097. |
| Physician Type | Audiologist, otolaryngologist, or other physician (CAOHC-certified or equivalent technician permitted under their responsibility) |
| Removal (MRP) | No MRP. On a Standard Threshold Shift (avg ≥10 dB at 2000/3000/4000 Hz in either ear — 8 CCR 5097(d)(8)), refit/retrain hearing protectors and refer for clinical/otological evaluation when indicated (see abnormal_protocols). |
🩺 Baseline / Pre-Placement
Within 6 months of first exposure at/above the Action Level (1 year if a mobile test van is used; hearing protectors worn until the baseline is completed) — 8 CCR 5097(c)(8)-(9)
- Pure-tone, air-conduction audiometric test of each ear at 500, 1000, 2000, 3000, 4000, and 6000 Hz — 8 CCR 5097/5098
- Preceded by at least 14 hours without workplace noise exposure (hearing protectors may substitute for that quiet period) — 8 CCR 5097
- Audiometer functional/calibration checks; test room meeting the applicable ambient-noise limits ambient-noise limits
🕒 Periodic / Routine
Interval-based while exposed at/above the Action Level — NOT result-triggered
Schedule: A new audiogram at least ANNUALLY after the baseline — 8 CCR 5097(c)(10)
- Pure-tone, air-conduction audiometric test of each ear at 500, 1000, 2000, 3000, 4000, and 6000 Hz — 8 CCR 5097/5098
- Comparison of the annual audiogram against the baseline to determine whether a Standard Threshold Shift (STS) has occurred (average shift of 10 dB or more at 2000, 3000, and 4000 Hz in either ear) — 8 CCR 5097(d)(8)
Abnormal Results & Exposure-Event Protocols
- Standard Threshold Shift (STS) identified on an annual audiogram (avg ≥10 dB at 2000/3000/4000 Hz in either ear), unless a physician/audiologist determines the STS is not work-related or aggravated by occupational noise 8 CCR 5097(d): Within the required timeframes: (1) fit/refit affected employees with hearing protectors, train them, and require use; for employees already using protectors, refit/retrain and provide protectors with greater attenuation if needed; (2) refer the employee for a clinical audiological evaluation or otological examination if additional testing is needed or if a medical pathology of the ear is suspected as caused/aggravated by hearing protector use; (3) inform the employee of the need for a medical evaluation if a medical ear pathology unrelated to protector use is suspected. Notify employee in writing within 21 days of the determination. Tests: Written notification to employee within 21 days of the STS determination — 8 CCR 5097(d)(4)., Hearing-protector fitting/refitting, training, and required use (with greater attenuation if indicated), Referral for clinical audiological evaluation or otological examination when indicated, Retest of the audiogram permitted to confirm a persistent STS
- Persistent STS that the professional determines may be reported as a recordable hearing-loss case 8 CCR 5097(d): Employer may obtain a confirmation audiogram within 30 days and revise the baseline (audiogram revision) when the STS is persistent; record on the OSHA 300 log if criteria met. Tests: Confirmation audiogram within 30 days, Baseline revision when STS persists
Reporting Requirements
| Who performs the evaluation | Audiometric tests performed by a licensed/certified audiologist, otolaryngologist, or other physician, or by a CAOHC-certified (or equivalent) technician responsible to the audiologist/physician — 8 CCR 5097. STS/work-relatedness determined by audiologist, otolaryngologist, or physician. |
|---|---|
| Reported to employer | No employer-directed written fitness opinion under 1910.95. The professional reviewing audiograms determines whether an STS occurred and whether it is work-related; the employer acts on STS follow-up obligations. |
| Reported to / for the employee | Employee must be informed IN WRITING within 21 days of the determination that a Standard Threshold Shift (STS) has occurred — 8 CCR 5097(d)(4). |
| Time limits | STS written notification to employee within 21 days of the determination — 8 CCR 5097(d)(4). |
| Recordkeeping | Audiometric test records retained for the duration of employment (8 CCR 5097 / records per 8 CCR 3204). |
Construction
California construction noise is governed by Cal/OSHA construction safety orders; the audiometric/hearing-conservation medical provisions are set out in the general-industry noise sections (8 CCR 5095-5100, audiometric content in 5097) applied to covered employees at/above the 85 dBA Action Level. A construction-specific audiometric carve-out is NOT separately detailed here; confirm the precise construction cross-reference against the enrolled construction safety orders before relying on it for a construction-only employer.
Federal vs. California: Essentially aligned for the medical/audiometric requirements — 8 CCR 5097 tracks 29 CFR 1910.95 (same 85 dBA Action Level, same baseline-within-6-months and annual-audiogram timing, same STS definition of avg ≥10 dB at 2000/3000/4000 Hz). Key structural differences: California splits the noise rule across 5095-5100 (audiometric content in 5097) whereas federal packs it into a single 1910.95; and federal CONSTRUCTION (1926.52/1926.101) mandates only hearing protectors with NO audiometric program — the largest sector gap.
Definitions & Reference Tables
Appendix D — Audiometric Test Rooms 29 CFR 1910.95 App. D
Sets the maximum allowable ambient (background) octave-band sound-pressure levels for rooms used to conduct audiometric testing, given in Table D-1 across the 500 Hz to 8,000 Hz frequencies. It ensures the test environment is quiet enough for accurate hearing tests.
Bloodborne Pathogens
Program-Based StandardsOccupational exposure to blood/OPIM risks HBV, HCV, and HIV transmission; affects healthcare, laboratory, custodial, first-responder, and other workers with reasonably anticipated exposure.
Federal OSHA osha.gov
All Covered Work
| Covered | All employees with reasonably anticipated occupational exposure to blood or other potentially infectious materials (OPIM). The standard reaches exposed workers across general industry and is applied to exposed construction workers as well (no GI/construction split for the medical provisions). |
|---|---|
| Physician Type | Licensed physician or other licensed healthcare professional |
| Removal (MRP) | No MRP. The program is vaccination + post-exposure evaluation/follow-up (see abnormal_protocols). No routine periodic surveillance schedule; HBV is a one-time series (boosters only if USPHS later recommends). |
🩺 Baseline / Pre-Placement
Hepatitis B vaccination made available within 10 working days of initial assignment to all employees with occupational exposure (after required training) — 1910.1030(f)(2)(i)
- Hepatitis B vaccine and full vaccination series MADE AVAILABLE at no cost (unless previously vaccinated, immune by antibody testing, or contraindicated) — 1910.1030(f)(1)(i)
- Performed by or under the supervision of a licensed physician or other licensed healthcare professional, per current USPHS recommendations — 1910.1030(f)(1)(ii)
- No antibody prescreening may be required as a condition of receiving vaccination — 1910.1030(f)(2)(ii)
- If the employee declines, a signed Hepatitis B Vaccine Declination statement (Appendix A) — 1910.1030(f)(2)(iv)
- If USPHS later recommends routine booster doses, they must be made available — 1910.1030(f)(1)(ii)
Abnormal Results & Exposure-Event Protocols
- An EXPOSURE INCIDENT (specific eye, mouth, mucous-membrane, non-intact skin, or parenteral contact with blood/OPIM) 1910.1030(f)(3): Make immediately available a confidential post-exposure medical evaluation and follow-up: document route(s) and circumstances; identify and test the SOURCE individual's blood for HBV and HIV as soon as feasible (consent obtained, or where law allows without consent; not repeated if source already known infected); collect the EXPOSED employee's blood as soon as feasible and test after consent (if the employee declines HIV testing, the sample is preserved at least 90 days for later testing on request); provide post-exposure prophylaxis when medically indicated per USPHS; provide counseling and evaluation of reported illnesses. Tests: Documentation of route(s) of exposure and circumstances — 1910.1030(f)(3)(i), Source-individual blood testing for HBV and HIV infectivity (as soon as feasible, after consent) — 1910.1030(f)(3)(ii). Note: The federal regulatory text names only HBV and HIV; HCV source testing is guided by current USPHS recommendations but is not explicitly enumerated in the federal source-testing panel (contrast California 8 CCR 5193, which explicitly names HCV)., Exposed-employee baseline blood collection and testing after consent; sample preserved ≥90 days if HIV testing declined — 1910.1030(f)(3)(iii), Post-exposure prophylaxis when medically indicated per USPHS — 1910.1030(f)(3)(iv), Counseling and evaluation of reported illnesses — 1910.1030(f)(3)(v)-(vi), Information provided to the evaluating healthcare professional: copy of the standard, employee's duties, route/circumstances, source test results, relevant medical records — 1910.1030(f)(4)(ii)
Reporting Requirements
| Who performs the evaluation | Licensed physician or other licensed healthcare professional (HBV vaccination performed by or under the supervision of a licensed physician/healthcare professional; post-exposure evaluation by a licensed healthcare professional) — 1910.1030(f)(1)(ii), (f)(3). |
|---|---|
| Reported to employer | Employer receives the healthcare professional's WRITTEN OPINION, limited to: (HBV) whether vaccination is indicated and whether the employee has received it; (post-exposure) that the employee was informed of evaluation results and of any medical condition resulting from the exposure that requires further evaluation or treatment. ALL OTHER findings/diagnoses remain confidential and are NOT in the written report — 1910.1030(f)(5). |
| Reported to / for the employee | Employer provides the employee a copy of the healthcare professional's written opinion; post-exposure evaluation results communicated to the employee — 1910.1030(f)(5). |
| Time limits | Employer provides the written opinion to the employee within 15 days of completion of the evaluation — 1910.1030(f)(5)(i). [No change from current text — 15 days confirmed; no 'working days' qualifier in the federal standard.] |
| Recordkeeping | Confidential medical records (HBV status, post-exposure evaluation/testing results, written opinions, info provided to the healthcare professional) retained for the DURATION of employment PLUS 30 YEARS; not disclosed without the employee's written consent — 1910.1030(h)(1). |
Cal/OSHA dir.ca.gov
All Covered Work
| Covered | All employees with reasonably anticipated occupational exposure to blood/OPIM. Mirrors federal with explicit HCV in post-exposure source testing. |
|---|---|
| Physician Type | Licensed physician or other licensed healthcare professional (California licensure scope) |
| Removal (MRP) | No MRP. Vaccination + post-exposure evaluation/follow-up (see abnormal_protocols). No routine periodic schedule. |
🩺 Baseline / Pre-Placement
Hepatitis B vaccination made available within 10 working days of initial assignment to all employees with occupational exposure — 8 CCR 5193(f)(2)
- Hepatitis B vaccine and full vaccination series MADE AVAILABLE at no cost (unless previously vaccinated, immune by antibody testing, or contraindicated) — 8 CCR 5193(f)(1)
- Performed by or under the supervision of a licensed physician or other licensed healthcare professional, per current USPHS recommendations — 8 CCR 5193(f)(1)/(f)(2)
- No antibody prescreening may be required as a condition of receiving vaccination — 8 CCR 5193(f)(2)
- If the employee declines, a signed Hepatitis B Vaccine Declination statement (Appendix A) — 8 CCR 5193(f)(2)
- If USPHS later recommends routine booster doses, they must be made available — 8 CCR 5193(f)(1)/(f)(2)
Abnormal Results & Exposure-Event Protocols
- An EXPOSURE INCIDENT (eye, mouth, mucous-membrane, non-intact skin, or parenteral contact with blood/OPIM) 8 CCR 5193(f)(3): Make immediately available a confidential post-exposure medical evaluation and follow-up: document route(s) and circumstances; identify and test the SOURCE individual's blood AS SOON AS FEASIBLE for HBV, HCV, AND HIV (California explicitly names HCV in the source-testing panel); collect and test the EXPOSED employee's blood after consent (sample preserved if HIV testing declined); provide post-exposure prophylaxis when medically indicated; provide counseling and evaluation of reported illnesses. Tests: Documentation of route(s) of exposure and circumstances, Source-individual blood testing for HBV, HCV, and HIV (as soon as feasible) — HCV explicit in California text — 8 CCR 5193(f)(3), Exposed-employee baseline blood collection and testing after consent; sample preserved if HIV testing declined, Post-exposure prophylaxis when medically indicated, Counseling and evaluation of reported illnesses, Information provided to the evaluating healthcare professional (copy of standard, duties, route/circumstances, source results, relevant records)
Reporting Requirements
| Who performs the evaluation | Licensed physician or other licensed healthcare professional — 8 CCR 5193(f). |
|---|---|
| Reported to employer | Employer receives the healthcare professional's WRITTEN OPINION, limited to: (HBV) whether vaccination is indicated and whether the employee has received it; (post-exposure) that the employee was informed of evaluation results and of any medical condition resulting from the exposure that requires further evaluation or treatment. ALL OTHER findings/diagnoses remain confidential and are NOT in the written report — 8 CCR 5193(f)(5). |
| Reported to / for the employee | Employer provides the employee a copy of the healthcare professional's written opinion; post-exposure evaluation results communicated to the employee — 8 CCR 5193(f)(5). |
| Time limits | Employer provides the written opinion to the employee within 15 days of completion of the evaluation — 8 CCR 5193(f)(5). |
| Recordkeeping | Confidential medical records retained for the duration of employment plus 30 years; not disclosed without written consent — 8 CCR 5193(h). |
Federal vs. California: California 8 CCR 5193 names HCV EXPLICITLY in the post-exposure source-testing panel (alongside HBV and HIV), whereas federal 1910.1030(f)(3)(ii) enumerates HBV and HIV (HCV handled via USPHS-guided follow-up) — both result in HBV/HCV/HIV management but California's text is more explicit. California additionally maintains a separate Aerosol Transmissible Diseases standard (8 CCR 5199) covering airborne pathogens, with no federal equivalent. Vaccination timing (10 working days), the 15-day written-opinion limit, and duration+30-year record retention are the same.
Definitions & Reference Tables
Appendix A — Hepatitis B Vaccine Declination (Mandatory) 29 CFR 1910.1030 App. A; 8 CCR 5193(f)
The mandatory declination statement an employee signs when refusing the offered, no-cost hepatitis B vaccination. By signing, the employee acknowledges the risk of HBV infection, that vaccination was offered free of charge, and that they may still receive it later at no cost if they change their mind.
HAZWOPER Medical Surveillance
Program-Based StandardsHazardous-waste operations and emergency response expose workers to varied hazardous substances; affects cleanup workers, treatment/storage/disposal employees, and HAZMAT team members.
Federal OSHA osha.gov
General Industry
| Covered | Covered employees (1910.120(f)(2)): (i) exposed at/above the PEL or published exposure level (without regard to respirator use) for 30+ days/year; (ii) wear a respirator 30+ days/year or as required by 1910.134; (iii) injured, ill, or developing signs/symptoms of overexposure from an emergency or hazardous-waste operation; (iv) members of HAZMAT teams. |
|---|---|
| Physician Type | Licensed physician (exam by or under the supervision of a licensed physician) |
| Removal (MRP) | No MRP. Physician-discretion exam content; physician written opinion on fitness for duty and PPE use. Emergency/post-symptom exams are handled as soon as possible (see abnormal_protocols). |
🩺 Baseline / Pre-Placement
Prior to assignment to covered work — (f)(3)(i)(A)
- Medical and work history with special emphasis on symptoms related to handling hazardous substances and health hazards, and on fitness for duty including the ability to wear required PPE under expected work conditions — 1910.120(f)(4)
- Physical examination and the specific tests/studies the ATTENDING PHYSICIAN determines are appropriate for the exposures (no fixed mandatory test panel) — 1910.120(f)(4)(ii)
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: At least once every 12 months for each covered employee, UNLESS the attending physician believes a longer interval (not greater than biennial / every 2 years) is appropriate — (f)(3)(i)(B)
- Medical and work history with special emphasis on symptoms related to handling hazardous substances and health hazards, and on fitness for duty including the ability to wear required PPE under expected work conditions — 1910.120(f)(4)
- Physical examination and the specific tests/studies the ATTENDING PHYSICIAN determines are appropriate for the exposures (no fixed mandatory test panel) — 1910.120(f)(4)(ii)
🚪 Exit / Termination
At termination of employment or reassignment to an area without medical-surveillance coverage, if the employee has not had an exam within the last 6 months — (f)(3)(i)(C)
- Medical and work history with special emphasis on symptoms related to handling hazardous substances and health hazards, and on fitness for duty including the ability to wear required PPE under expected work conditions — 1910.120(f)(4)
- Physical examination and the specific tests/studies the ATTENDING PHYSICIAN determines are appropriate for the exposures (no fixed mandatory test panel) — 1910.120(f)(4)(ii)
Abnormal Results & Exposure-Event Protocols
- Employee notifies the employer that they have developed signs or symptoms indicating possible overexposure to hazardous substances or health hazards, or that they have been injured or exposed above the permissible exposure limits or published exposure levels in an emergency situation 1910.120(f)(3)(i)(D): Provide a medical examination as soon as possible; content determined by the attending physician based on the exposure. Tests: Medical and work history with emphasis on symptoms related to the exposure and fitness for duty, Physical examination and any tests the attending physician determines are indicated by the exposure (no fixed panel)
- As soon as possible following an emergency incident or the development of signs or symptoms of overexposure 1910.120(f)(3)(ii): Provide a medical examination as soon as possible following the emergency incident or development of signs/symptoms, with follow-up examinations if the examining physician determines them medically necessary. Tests: Medical and work history with emphasis on symptoms related to the exposure and fitness for duty, Physical examination and any tests the attending physician determines are indicated by the exposure (no fixed panel)
Reporting Requirements
| Who performs the evaluation | Licensed physician (examinations performed by or under the supervision of a licensed physician, at no cost, without loss of pay, at a reasonable time and place) — 1910.120(f)(5). |
|---|---|
| Reported to employer | Employer obtains the physician's WRITTEN OPINION covering: any detected medical condition that would increase the employee's risk of material health impairment from work; recommended exposure/work limitations and on respirator/PPE use; results of the exam (if the employee requests); and a statement that the employee was informed of the results and of any condition requiring further evaluation/treatment. Findings unrelated to occupational exposure are NOT included — 1910.120(f)(7). |
| Reported to / for the employee | Employee informed of exam results and of any medical condition requiring further evaluation or treatment; a copy of the written opinion is provided — 1910.120(f)(7). |
| Time limits | No fixed numeric turnaround stated; written opinion obtained before the employer assigns/continues the employee in the covered work. |
| Recordkeeping | Medical surveillance records retained for the duration of employment plus 30 years per 29 CFR 1910.1020 — 1910.120(f)(8) cross-references the records rule. |
Construction
| Covered | Covered employees — 1926.65(f)(2): (i) exposed at or above the PEL or published exposure level (without regard to respirator use) for 30 days or more per year; (ii) wear a respirator for 30 days or more per year or as required by 1926.103; (iii) injured, become ill, or develop signs or symptoms of overexposure from an emergency response or hazardous waste operation; (iv) members of HAZMAT teams. |
|---|---|
| Physician Type | Licensed physician (exam by or under the supervision of a licensed physician) |
| Removal (MRP) | No MRP. Physician-discretion exam content; physician written opinion on fitness for duty and PPE use. Emergency/post-symptom exams are handled as soon as possible (see abnormal_protocols). |
🩺 Baseline / Pre-Placement
Prior to assignment to covered work — (f)(3)(i)(A)
- Medical and work history with special emphasis on symptoms related to handling hazardous substances and health hazards, and on fitness for duty including the ability to wear required PPE under expected work conditions — 1926.65(f)(4)
- Physical examination and the specific tests/studies the ATTENDING PHYSICIAN determines are appropriate for the exposures (no fixed mandatory test panel) — 1926.65(f)(4)(ii)
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: At least once every 12 months for each covered employee, UNLESS the attending physician believes a longer interval (not greater than biennial / every 2 years) is appropriate — (f)(3)(i)(B)
- Medical and work history with special emphasis on symptoms related to handling hazardous substances and health hazards, and on fitness for duty including the ability to wear required PPE under expected work conditions — 1926.65(f)(4)
- Physical examination and the specific tests/studies the ATTENDING PHYSICIAN determines are appropriate for the exposures (no fixed mandatory test panel) — 1926.65(f)(4)(ii)
🚪 Exit / Termination
At termination of employment or reassignment to an area without medical-surveillance coverage, if the employee has not had an exam within the last 6 months — (f)(3)(i)(C)
- Medical and work history with special emphasis on symptoms related to handling hazardous substances and health hazards, and on fitness for duty including the ability to wear required PPE under expected work conditions — 1926.65(f)(4)
- Physical examination and the specific tests/studies the ATTENDING PHYSICIAN determines are appropriate for the exposures (no fixed mandatory test panel) — 1926.65(f)(4)(ii)
Abnormal Results & Exposure-Event Protocols
- Employee notifies the employer of signs/symptoms indicating possible overexposure to hazardous substances/health hazards, OR an emergency/incident involving exposure above PEL/published level without respiratory protection 1926.65(f)(3)(i)(D), (f)(3)(ii): Provide a medical examination AS SOON AS POSSIBLE; content determined by the attending physician based on the exposure. Tests: Medical and work history with emphasis on symptoms related to the exposure and fitness for duty, Physical examination and any tests the attending physician determines are indicated by the exposure (no fixed panel)
Reporting Requirements
| Who performs the evaluation | Licensed physician (examinations performed by or under the supervision of a licensed physician, preferably one knowledgeable in occupational medicine, at no cost, without loss of pay, at a reasonable time and place) — 1926.65(f)(5). |
|---|---|
| Reported to employer | Employer obtains the physician's WRITTEN OPINION covering: any detected medical condition that would increase the employee's risk of material health impairment from work; recommended exposure/work limitations and on respirator/PPE use; results of the exam (if the employee requests); and a statement that the employee was informed of the results and of any condition requiring further evaluation/treatment. Findings unrelated to occupational exposure are NOT included — 1926.65(f)(7). |
| Reported to / for the employee | Employee informed of exam results and of any medical condition requiring further evaluation or treatment; a copy of the written opinion is provided — 1926.65(f)(7). |
| Time limits | No fixed numeric turnaround stated; written opinion obtained before the employer assigns/continues the employee in the covered work. |
| Recordkeeping | Medical surveillance records retained for the duration of employment plus 30 years per 29 CFR 1910.1020 — 1910.120(f)(8) cross-references the records rule. |
Cal/OSHA dir.ca.gov
All Covered Work
| Covered | Covered employees (8 CCR 5192(f)(2)): (i) exposed at/above the PEL or published exposure level (without regard to respirator use) for 30+ days/year; (ii) wear a respirator 30+ days/year or as required by 8 CCR 5144; (iii) injured, ill, or developing signs/symptoms of overexposure from an emergency or hazardous-waste operation; (iv) members of HAZMAT teams. California applies a single section 5192 across general industry and construction. |
|---|---|
| Physician Type | Licensed physician (exam by or under the supervision of a licensed physician) |
| Removal (MRP) | No MRP. Physician-discretion exam content; physician written opinion on fitness for duty and PPE use. Emergency/post-symptom exams are handled as soon as possible (see abnormal_protocols). |
🩺 Baseline / Pre-Placement
Prior to assignment to covered work — (f)(3)(i)(A)
- Medical and work history with special emphasis on symptoms related to handling hazardous substances and health hazards, and on fitness for duty including the ability to wear required PPE under expected work conditions — 8 CCR 5192(f)(4)
- Physical examination and the specific tests/studies the ATTENDING PHYSICIAN determines are appropriate for the exposures (no fixed mandatory test panel) — 8 CCR 5192(f)(4)(ii)
🕒 Periodic / Routine
Interval-based while covered — NOT result-triggered
Schedule: At least once every 12 months for each covered employee, UNLESS the attending physician believes a longer interval (not greater than biennial / every 2 years) is appropriate — (f)(3)(i)(B)
- Medical and work history with special emphasis on symptoms related to handling hazardous substances and health hazards, and on fitness for duty including the ability to wear required PPE under expected work conditions — 8 CCR 5192(f)(4)
- Physical examination and the specific tests/studies the ATTENDING PHYSICIAN determines are appropriate for the exposures (no fixed mandatory test panel) — 8 CCR 5192(f)(4)(ii)
🚪 Exit / Termination
At termination of employment or reassignment to an area without medical-surveillance coverage, if the employee has not had an exam within the last 6 months — (f)(3)(i)(C)
- Medical and work history with special emphasis on symptoms related to handling hazardous substances and health hazards, and on fitness for duty including the ability to wear required PPE under expected work conditions — 8 CCR 5192(f)(4)
- Physical examination and the specific tests/studies the ATTENDING PHYSICIAN determines are appropriate for the exposures (no fixed mandatory test panel) — 8 CCR 5192(f)(4)(ii)
Abnormal Results & Exposure-Event Protocols
- Employee notifies the employer of signs/symptoms indicating possible overexposure to hazardous substances/health hazards, OR an emergency/incident involving exposure above PEL/published level without respiratory protection 8 CCR 5192(f)(3): Provide a medical examination AS SOON AS POSSIBLE; content determined by the attending physician based on the exposure. Tests: Medical and work history with emphasis on symptoms related to the exposure and fitness for duty, Physical examination and any tests the attending physician determines are indicated by the exposure (no fixed panel)
Reporting Requirements
| Who performs the evaluation | Licensed physician (exam by or under the supervision of a licensed physician, no cost, no loss of pay) — 8 CCR 5192(f)(5). |
|---|---|
| Reported to employer | Employer obtains the physician's WRITTEN OPINION covering: any detected medical condition that would increase the employee's risk of material health impairment from work; recommended exposure/work limitations and on respirator/PPE use; results of the exam (if the employee requests); and a statement that the employee was informed of the results and of any condition requiring further evaluation/treatment. Findings unrelated to occupational exposure are NOT included — 8 CCR 5192(f)(7). |
| Reported to / for the employee | Employee informed of exam results and of any medical condition requiring further evaluation or treatment; a copy of the written opinion is provided — 8 CCR 5192(f)(7). |
| Time limits | No fixed numeric turnaround stated; written opinion obtained before the employer assigns/continues the employee in the covered work. |
| Recordkeeping | Medical surveillance records retained for the duration of employment plus 30 years per 8 CCR 3204 — 8 CCR 5192(f)(8). |
Federal vs. California: Essentially aligned — 8 CCR 5192(f) tracks 29 CFR 1910.120(f) (same four covered groups; baseline prior to assignment; periodic at least every 12 months with biennial max on physician approval; exit exam at termination/reassignment if none in prior 6 months; emergency/post-symptom exam as soon as possible; content at physician discretion; physician written opinion on fitness and PPE use). Federal splits across general industry (1910.120) and construction (1926.65, substantively identical); California uses a single 5192 across both. No substantive medical difference.
Aerosol Transmissible Diseases (ATD)
Program-Based StandardsAerosol-transmitted pathogens (TB, measles, varicella, novel respiratory pathogens) threaten healthcare and high-risk-facility workers; this is a California-only standard with no federal equivalent.
Federal OSHA osha.gov
All Covered Work
No dedicated federal OSHA aerosol/airborne-transmissible-disease standard exists. Airborne-pathogen risk is addressed only indirectly under federal OSHA — e.g., the respiratory protection standard (1910.134), recordkeeping, and the General Duty Clause (Section 5(a)(1)) — not by a specific federal ATD medical-surveillance standard. There is no federal baseline/annual TB testing or post-exposure ATD evaluation mandate. (California analog: 8 CCR 5199.)
Cal/OSHA dir.ca.gov
All Covered Work
| Covered | Health care facilities (hospitals, skilled nursing, clinics, outpatient medical offices, home health, hospice, paramedic/EMS); high-risk facilities (correctional facilities, homeless shelters, drug-treatment programs); public-health operations (contact tracing, screening); police during transport/detention of suspected ATD cases; laboratories handling aerosol-transmissible pathogens; cadaver-handling operations (pathology labs, medical examiners, coroners, mortuaries); and contaminated air-handling maintenance. Limited exceptions for certain outpatient dental/specialty practices with screening — 8 CCR 5199(a). |
|---|---|
| Physician Type | PLHCP knowledgeable in occupational TB/ATD evaluation (TB management referrals to a PLHCP knowledgeable in TB diagnosis/treatment) |
| Removal (MRP) | No MRP. Program is baseline + annual TB surveillance plus event-triggered TB-conversion evaluation and post-exposure response (see abnormal_protocols). Medical records may be combined with the 5193 (bloodborne) medical record — 8 CCR 5199(j)(1)(A) — though the two standards cover non-overlapping disease routes (airborne vs. bloodborne). |
🩺 Baseline / Pre-Placement
On hire/assignment into an ATD exposure-risk classification — 8 CCR 5199(h)
- Baseline TB screening/testing for new hires in exposure-risk job classifications (TB skin test or IGRA blood test, per the facility's program) — 8 CCR 5199(h)
- Vaccines listed in Appendix E of 8 CCR 5199 made available at no cost to all susceptible health care workers with occupational exposure within 10 working days of initial assignment (unless previously vaccinated, immune, or medically contraindicated) — 8 CCR 5199(h)(5)(A). [Appendix E vaccine list must be confirmed against enrolled California Code of Regulations text — Appendix E was not fully reproduced in independently fetched source.]
- Medical-history/screening as part of program enrollment
🕒 Periodic / Routine
Interval-based for exposed employees — NOT result-triggered
Schedule: Annual TB testing/assessment for all exposed employees — 8 CCR 5199(h)(3)
- Annual TB testing/assessment for exposed employees [8 CCR 5199(h)(3)(A)]
- Employees with a negative baseline TB test: annual TB test using either a Tuberculin Skin Test (TST) or a Blood Assay for M. Tuberculosis (BAMT)/Interferon Gamma Release Assay (IGRA) (FDA-approved and CDC-recommended)
- Employees with a baseline-positive TB test: annual symptom screen only (not a repeat TST/IGRA)
- More frequent testing required if applicable public health guidelines or the local health officer recommends it
Abnormal Results & Exposure-Event Protocols
- Employee TB test conversion (new positive) 8 CCR 5199(h)(3): Provide a medical evaluation and refer the employee to a PLHCP knowledgeable in the diagnosis/treatment of TB for further evaluation and management. Tests: Medical evaluation of the TB conversion, Referral to a PLHCP knowledgeable in TB diagnosis and treatment, Symptom assessment and chest imaging as clinically indicated by the PLHCP
- Significant exposure incident / suspected or confirmed ATD case exposure 8 CCR 5199(h)(6): Conduct an exposure analysis within 72 hours; provide a post-exposure MEDICAL EVALUATION within 96 hours of the exposure; report suspected reportable ATD cases to the local health officer; notify other potentially exposed employers within 72 hours. Tests: Exposure incident analysis (determination of which employees had significant exposures) within 72 hours of the employer's report to the local health officer or receipt of notification [8 CCR 5199(h)(6)(C)1], Notification of employees with significant exposures of the date, time, and nature of the exposure within 96 hours of becoming aware of the potential exposure [8 CCR 5199(h)(6)(C)2], Post-exposure medical evaluation provided 'as soon as feasible' to all employees with significant exposures (no fixed-hour deadline) [8 CCR 5199(h)(6)(C)3], Reporting of suspected/confirmed ATD case to the local health officer, Notification of other potentially exposed employers within 72 hours of the report to the local health officer [8 CCR 5199(h)(6)(B)], Post-exposure prophylaxis/treatment as recommended by the PLHCP
Reporting Requirements
| Who performs the evaluation | PLHCP (referrals for TB conversion to a PLHCP knowledgeable in TB diagnosis/treatment) — 8 CCR 5199(h). |
|---|---|
| Reported to employer | Employer receives the PLHCP's written opinion/recommendation on work status and any work restrictions related to ATD exposure; clinical details remain confidential. |
| Reported to / for the employee | Employee informed of TB test results, conversion status, exposure-incident findings, and any need for further evaluation/treatment; copy of the written opinion provided. |
| Time limits | Written opinion from PLHCP provided to employee within 15 working days of completion of all required medical evaluations — 8 CCR 5199(h)(9)(A). |
| Recordkeeping | Confidential ATD medical records retained per 8 CCR 5199(j)(1)(A): at least the duration of employment plus 30 years; may be combined with the 8 CCR 5193 medical record. |
Federal vs. California: California-only standard. 8 CCR 5199 mandates baseline and ANNUAL TB testing/assessment, TB-conversion medical evaluation/referral, Appendix E vaccination offers, and a structured post-exposure pathway (72-hour exposure analysis, 96-hour post-exposure medical evaluation, local-health-officer reporting). There is NO federal OSHA equivalent — federal airborne-pathogen risk is covered only indirectly via 1910.134 and the General Duty Clause.
Definitions & Reference Tables
Appendix E — Vaccination recommendations for susceptible health care workers 8 CCR 5199 App. E (Mandatory)
The Cal/OSHA list of vaccine doses the employer must make available at no cost to susceptible health care workers with occupational exposure: influenza (annual), measles (2 doses), mumps (2 doses), rubella (1 dose), Tdap (1 dose with recommended boosters), and varicella-zoster (2 doses), unless the worker is already immune or vaccination is medically contraindicated.