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Safety Management

Occupational Hazard Monitoring and Medical Surveillance

Quick Tips #405

According to the Bureau of Labor Statistics in 2019, cases of exposure to harmful substances or environment resulted in an average of four days away from work and made up about 4% (35,000) of the overall number (888,220) of days away cases in private industry. These cases involved exposure to radiation, noise, light, temperature extremes, harmful chemical substances, medical injection, and oxygen deficiency.4 Almost all of these workplace injuries and illnesses that were caused by these exposures can be classified as physical, biological or chemical in nature.

Hazard Type Injury Fact
Physical According to the Center for Disease Control (CDC) each year more than 22 million workers are exposed to harmful noise levels.1
Biological In 2016 there were 15.5 million visits to physician office with infectious and parasitic diseases as the primary diagnosis.2
Chemical American employees use tens of thousands of chemicals every day. While many of these chemicals are suspected of being harmful, relatively few chemicals are regulated in the workplace. As a result, employees suffer more than 190,000 illnesses and 50,000 deaths annually related to chemical exposures.3

All these statistics drive home the point that occupational illness and injuries are numerous. Action should be taken to reduce or mitigate these types of chronic illnesses and injuries through programs such as an occupational hazard monitoring plan and medical surveillance.

Occupational Hazard Monitoring Plan

The overall goal of an occupational hazard monitoring plan is to identify, quantify and ensure that measures to protect the employee from workplace health hazards are in place and remain effective. Two main objectives the plan should address are:

  • Anticipating and recognizing biological, physical and/or chemical health hazards present or likely to be present in the workplace, and
  • Monitoring techniques aligned to governing regulatory standards established by the Occupational Safety and Health Administration (OSHA).

The nature of how the exposure is determined is guided by medical surveillance requirements set by OSHA.

Hazard Type Description
Physical Temperature stress, radiation and noise
Biological Bacteria, viruses, insects, plants, birds, animals, and humans
Chemical Chemical substances that have the ability to create a physical or health hazard due to their properties of: toxicity, explosivity, flammability, reactivity, oxidizing, or corrosivity

Medical Surveillance

OSHA required medical surveillance requirements are comprised of medical examinations and tests designed to detect and monitor potential health effects from physical, biological, or chemical hazards in the workplace to alert the employer of exposure. This will enable the employer to institute early treatment or other steps to protect employee health. Thus, medical surveillance serves as a feedback loop to the employer. It typically uses screening results from the group of employees being evaluated to look for abnormal trends in health status and to identify potential problem areas and monitor the effectiveness of existing worksite preventive strategies.

Employers must have a medical surveillance program in workplace settings where employees may be exposed to occupational physical, biological or chemical health hazards. Systematic medical surveillance involves periodic medical examinations by licensed health professionals to establish baselines before and during exposure. Screening results are evaluated to look for abnormal trends, identify potential problem areas, and monitor the effectiveness of existing workplace preventive strategies.

Steps to ensure an effective medical surveillance program include:

1. Create a hazardous substance inventory of substances that exist in the workplace.

This step focuses on performing a hazard analysis to identify all of the hazardous substances used in the workplace. Once identified, employers can work with an industrial hygienist to monitor and quantify exposures to determine if any exposure levels pose a risk to employees or meet OSHA requirements for medical surveillance to determine if controls are effective in reducing exposure levels.

2. Know the applicable OSHA regulation(s).

This step is required to outline the OSHA permissible exposure limits (PELs) and action levels (ALs), as well as the medical screenings or surveillance measures that may be applicable. There is a finite number of OSHA regulations that cover chemical, physical, or biological hazards in the workplace. Most are out of date so employers may choose to use more up-to-date exposure levels provided by the National Institute for Occupational Safety and Health (NIOSH) or the American Conference of Governmental Industrial Hygienists (ACGIH).

3. Communicate key aspects of a medical surveillance program to all affected employees.

Employers must:

  • Preserve and maintain accurate medical and exposure records for each employee
  • Inform employees of the existence, location, and availability of medical and exposure records
  • Give employees any informational material requested
  • Make records available to employees, their designated representatives, and to OSHA, as required

General Industry OSHA Regulations

OSHA regulations can be categorized into hazard types of physical, biological, and chemical. OSHA’s general duty clause 5(a)(1) – employers must provide a workplace free from recognized hazards - applies across all three categories. OSHA standards that address medical surveillance categorized by hazard type are shown below.

Occupational Hazard Monitoring Requirements by Hazard Type
Physical Temperature stress – General duty clause 5(a)(1)
Nonionizing radiation – 29 CFR 1910.97(a)(2)
Noise – 29 CFR 1910.95(d)
Biological General duty clause 5(a)(1)
Bloodborne pathogens – 29 CFR 1910.1030(f)(3)(iii)
Communicable diseases – General duty clause 5(a)(1)
Chemical General duty clause 5(a)(1)
Hazardous waste operations and emergency response – 1910.120(c)(6)
Confined space – 29 CFR 1910.146(d)(5)
Air contaminants – 29 CFR 1910.1000 – Tables Z-1, Z-2, and Z-3
Substance specific – 29 CFR 1910.1001-1053 (See chemical list below)
Hazardous chemicals in labs – 29 CFR 1910.1450(d)


Federal Occupational Hazard Monitoring Requirements by Chemical
Asbestos 29 CFR 1910.1001(d) Vinyl Chloride 29 CFR 1910.1017(d)
Inorganic Arsenic 29 CFR 1910.1018(e) Beryllium 29 CFR 1910.1024(d)
Lead 29 CFR 1910.1025(d) Chromium VI 29 CFR 1910.1026(d)
Cadmium 29 CFR 1910.1027(d) Benzene 29 CFR 1910.1028(e)
Coke Oven Emissions 29 CFR 1910.1029(e) Cotton Dust 29 CFR 1910.1043(e)
1,2-dibromo-3-chloropropane 29 CFR 1910.1044(f) Acrylonitrile 29 CFR 1910.1045(e)
Ethylene Oxide 29 CFR 1910.1047(d) Formaldehyde 29 CFR 1910.1048(d)
Methylenedianiline 29 CFR 1910.1050(e) 1,3 Butadiene 29 CFR 1910.1051(d)
Methylene Chloride 29 CFR 1910.1052(d) Respirable Silica 29 CFR 1910.1053(d)


Federal Medical Surveillance Requirements
Description OSHA Regulation
Hazardous waste operations and emergency response 29 CFR 1910.120(f)
Respiratory protection 29 CFR 1910.134(e)
Asbestos 29 CFR 1910.1001(l)
13 Carcinogens 29 CFR 1910.1003(g)
Vinyl chloride 29 CFR 1910.1017(k)
Inorganic arsenic 29 CFR 1910.1018(n)
Beryllium 29 CFR 1910.1024(k)
Lead 29 CFR 1910.1025(j)
Chromium VI 29 CFR 1910.1026(k)
Cadmium 29 CFR 1910.1027((l)
Benzene 29 CFR 1910.1028(i)
Coke oven emissions 29 CFR 1910.1029(j)
Bloodborne pathogens 29 CFR 1910.1030(f)(3)
Cotton dust 29 CFR 1910.1043(h)
1,2,-dibromo-3-chloropropane 29 CFR 1910.1044(m)
Acrylonitrile 29 CFR 1910.1045(n)
Ethylene oxide 29 CFR 1910.1047(i)
Formaldehyde 29 CFR 1910.1048(l)
Methylenedianiline (MDA) 29 CFR 1910.1050(m)
1,3 Butadiene 29 CFR 1910.1051(k)
Methylene chloride 29 CFR 1910.1052(j)
Respirable crystalline silica 29 CFR 1910.1053(i)
Occupational exposure in a laboratory 29 CFR 1910.1450(g)

Frequently Asked Questions

Q: What is the purpose of medical surveillance?

A: The purpose of medical surveillance is to detect and eliminate the underlying causes of workplace health hazards or exposures. It ensures that measures to protect employees from such hazards are effective.

Q: What is the difference between medical surveillance and medical screening?

A: Medical screening and medical surveillance are two fundamental strategies for protecting employee health. Medical screening tests are administered to employees without current symptoms, but who may be at risk for exposure to physical, biological, or chemical health hazards. Medical surveillance uses screening results to look for abnormal health trends and underlying causes. Medical screening has a greater clinical focus on diagnosis and treatment. Medical surveillance has a prevention focus.

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The information contained in this article is intended for general information purposes only and is based on information available as of the initial date of publication. No representation is made that the information or references are complete or remain current. This article is not a substitute for review of current applicable government regulations, industry standards, or other standards specific to your business and/or activities and should not be construed as legal advice or opinion. Readers with specific questions should refer to the applicable standards or consult with an attorney.


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