['Toxic and Hazardous Substances - OSHA']
['Toxic and Hazardous Substances - OSHA']
11/12/2025
...
An effective medical surveillance program relies on a variety of tools and methodologies designed to monitor and protect worker health in environments where occupational hazards are present. These tools include:
- Clinical examinations,
- Biological monitoring,
- Exposure assessments, and
- Data management systems.
Clinical examination tools are used as routine health assessments and for the early detection of occupational illnesses and include:
- Chest x-rays — for silica, asbestos, and other air contaminant exposure
- Vision screening — to detect vision or eye irregularities
- Audiometry — for hearing levels
- Spirometry — for lung function
- Skin examinations — to detect skin defects
- Electrocardiograms (ECG) — for cardiovascular health
Biological monitoring measures the presence of hazardous substances in bodily fluids to assess internal exposure levels. Tools used for biological monitoring include:
- Urine tests — for benzene, mercury, cadmium, etc.
- Blood tests — for lead
- Breath analysis — for volatile organic compounds, alcohol, etc.
- Carboxyhemoglobin tests — for carbon monoxide exposure
- Cholinesterase tests — for pesticide exposure
Exposure assessment tools are used to correlate health outcomes with workplace hazards and exposures. Assessment tools are typically categorized by how exposures are measured, which include direct measurement (where the worker interacts with their environment), point-of-contact (direct exposure over a specific time period), or observation.
Calibrated exposure assessment tools are essential for accurately assessing exposure levels and include:
- Air sampling pumps
- Personal exposure monitors
- Noise dosimeters and sound meters
- Radiation detectors
- Surface contamination swabs
Medical surveillance information is only as useful as the analysis that follows. Constructive, user-friendly data collection and analysis tools such as online platforms are essential for tracking health trends, evaluating the effectiveness of workplace controls, and ensuring compliance with OSHA’s regulatory standards.
Scope
Any industry with workers that may be exposed to hazardous chemicals or materials can be subject to medical surveillance requirements found throughout the regulations in 29 CFR 1910. Employers must follow applicable regulations and their medical surveillance requirements.
Regulatory citations
- 29 CFR 1910 Subpart Z — Toxic and hazardous substances
- 29 CFR 1910 Subpart I — Personal protective equipment (PPE)
- 29 CFR 1910.95 - Occupational noise exposure
- 29 CFR 1910.120 - Hazardous Waste Operations and Emergency Response (HAZWOPER)
- 29 CFR 1910.1200 — Hazard communication (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.
- Exposure: Subjecting a worker to a hazardous chemical by any route of entry, such as inhalation, ingestion, skin contact, or absorption. Exposure includes potential (e.g., accidental or possible) exposure.
- Industrial hygienist: A person trained in the science of anticipating, identifying, analyzing, and controlling environmental factors in the workplace that may negatively impact worker safety and health.
- 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.
- Surveillance: Monitoring an individual and their environment in order to detect, eliminate, and protect the person from harmful exposures.
- Time-weighted average (TWA): A calculation of a worker’s average exposure to a hazardous material or substance over a given period of time, typically 8 hours.
Summary of requirements
- Conduct hazard assessments to identify operations or activities that may expose, or potentially expose, employees to toxic or hazardous substances.
- Consult with industrial hygienists or other occupational health and safety professionals for guidance, as necessary.
- Develop an exposure control plan to ensure workers are protected from hazardous exposures.
- Implement procedures for safe handling, disposal, and inspection of facilities, equipment, and tools used for processes involving toxic or hazardous substances.
- Perform medical surveillance for exposed or potentially exposed employees, following the applicable regulations in 29 CFR 1910.
- Ensure hazardous materials are properly inventoried, equipment is labeled, and that safety data sheets (SDSs) are readily accessible to workers.
- Train workers in chemical and material handling hazards and required protective measures.
- Investigate any worker incidents, spills, or near misses to find root causes and implement corrective actions to prevent future occurrences.
['Toxic and Hazardous Substances - OSHA']
['Toxic and Hazardous Substances - OSHA']
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