Medical surveillance

ez Explanations

Medical surveillance is a fundamental strategy for optimizing employee health. It is defined by OSHA as the analysis of health information to look for problems that may be occurring in the workplace, and that require targeted prevention, thereby serving as a feedback loop to the employer.

Surveillance may be based on a single case or repeated event, but more typically uses screening results from the group of employees being evaluated to look for abnormal trends in health status. Surveillance can also be conducted on a single employee over time. Review of group results helps to identify potential problem areas and the effectiveness of existing worksite preventive strategies.

The fundamental purpose of surveillance is to detect and eliminate the underlying causes (i.e., hazards/exposures) of any discovered trends and, therefore, has a prevention focus.

Medical screening is one component of a comprehensive medical surveillance program. It is a method for detecting disease or body dysfunction before an individual would normally seek medical care. Screening tests are usually administered to individuals without current symptoms, but who may be at high risk for certain adverse health outcomes.

The fundamental purpose of screening is early diagnosis and treatment of the individual and thus has a clinical focus.

Scope

Any industry with workers that may be exposed to hazardous chemicals or materials can be subject to medical surveillance and/or screening requirements. Employers must systematically assess the health of employees who may be exposed to these occupational hazards.

Preventative controls should be implemented once exposure levels reach action levels (ALs) set for individual substances. Protective controls are required when exposure levels reach permissible exposure limits (PELs) set for individual substances.

Specific hazards and hazardous materials that have a medical surveillance requirement include the following:

Acrylonitrile
Arsenic, Inorganic
Asbestos
Benzene
Bloodborne Pathogens
1,3-Butadiene
Cadmium
13 Carcinogens
Coke Oven Emissions
Compressed Air Environments
Cotton Dust
1,2-Dibromo, 3-Chloropropane (DBCP)
Ethylene Oxide (EtO)
Formaldehyde
Hazardous waste and emergency operations (HAZWOPER)
Hazardous Chemicals in Laboratories
Hexavalent Chromium (Chrom VI)
Lead
4,4’ Methylenedianiline (MDA)
Methylene Chloride (MC)
Noise and Hearing Conservation
Respiratory Protection
Silica, Crystalline
Tuberculosis
Vinyl Chloride (chloroethene)

Regulatory citations

29 CFR 1910 Subpart Z — Toxic and hazardous substances
29 CFR 1910.120 — Hazardous waste operations and emergency response (HAZWOPER)
29 CFR 1910 Subpart I — Personal Protective Equipment (PPE)
29 CFR 1910.1200 — Hazard Communications (HazCom)
29 CFR 1904 — Recording and reporting occupational injuries and illnesses
29 CFR 1910.1020 — Access to employee exposure and medical records
29 USC 654 — General duty clause of the OSH Act

Key definitions

Action limit (AL): The point at which a task or activity should be proactively changed to prevent an injury, illness, or other negative consequence.
Clinical: Relating to the health or physical and mental well-being of a living person.
Permissible exposure limit (PEL): The legal regulatory limit of a substance that a worker can be exposed to without adverse health effects.
Preventative control: An action, process, or procedure set in place to prevent an incident or event from occurring.
Protective control: An action, process, or procedure set in place to protect or shield a worker from exposures that are present.
Screening: A medical evaluation or review used as a means of early diagnosis and treatment for an individual.
Surveillance: Monitoring an individual and their environment in order to detect, eliminate, and protect the person from harmful exposures.

Summary of requirements

Conduct hazard assessments to identify hazardous materials or substances to which employees may be exposed. Update chemical inventories as required.
Provide medical surveillance and screening as required for each hazardous substance an employee may be exposed.
Implement controls and procedures designed to eliminate or substitute harmful substances in the workplace and protect workers when elimination or substitution are not possible.
Investigate any workplace incidents or near misses to find root causes and implement corrective actions to prevent future occurrence.
Train supervisors and workers on hazardous material exposures, medical surveillance and screening requirements, and mandatory protective measures.

See our quick reference guide

Finding medical surveillance regulations related to workplace toxic and hazardous substances can be challenging. Our Medical Surveillance quick reference guide breaks down exposure limits and references applicable standards to help ensure compliance.

['Toxic and Hazardous Substances - OSHA', 'Bloodborne Pathogens', 'Medical and Exposure Records', 'HAZWOPER']

['Bloodborne Pathogens Recordkeeping', 'Hazardous Waste Cleanup Operations', 'Toxic and Hazardous Substances - OSHA', 'Bloodborne Pathogens', 'HAZWOPER', 'Hazardous Waste Treatment, Storage, and/or Disposal', 'Medical and Exposure Records', 'HAZWOPER Emergency Response']

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