When is an employee medically removed under the medical surveillance requirements of any OSHA standard?

Medical surveillance refers to the process of monitoring employee conditions when there are known, or suspected, exposures to hazardous chemicals that can accumulate (accumulate where?). Analysis of health information is done to look for problems in the workplace that may require targeted prevention. This surveillance serves as a feedback loop to the employer. Surveillance may be based on a single case or multiple events, 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 work site preventive strategies.

The common hazardous substances are lead, cadmium, methylene chloride, formaldehyde, and benzene. OSHA publication 3162 provides a breakdown of requirements based on hazardous substances and is a good reference point.

For example, lead can build up in an employee’s bloodstream through minuscule exposures over time. Employers typically require employees who are, or could be, exposed to lead go through a medical screening to establish a baseline metric. Monitoring is then done periodically. If the employee’s blood level indicates their exposure is too high then they have to be medically removed from the job. This may be temporary or long-term. Any required (by OSHA standard) medical removal must be recorded on the OSHA 300 log as a medical removal, whether they are transferred to another role, have restricted duties, or have lost time days.

1904.9(a) Basic requirement. If an employee is medically removed under the medical surveillance requirements of an OSHA standard, you must record the case on the OSHA 300 Log.

1904.9(b) Implementation - 1904.9(b)(1) How do I classify medical removal cases on the OSHA 300 Log? You must enter each medical removal case on the OSHA 300 Log as either a case involving days away from work or a case involving restricted work activity, depending on how you decide to comply with the medical removal requirement. If the medical removal is the result of a chemical exposure, you must enter the case on the OSHA 300 Log by checking the “poisoning” column.

1904.9(b)(2) Do all of OSHA’s standards have medical removal provisions? No, some OSHA standards, such as the standards covering bloodborne pathogens and noise, do not have medical removal provisions. Many OSHA standards that cover specific chemical substances have medical removal provisions. These standards include, but are not limited to, lead, cadmium, methylene chloride, formaldehyde, and benzene.

1904.9(b)(3) Do I have to record a case where I voluntarily removed the employee from exposure before the medical removal criteria in an OSHA standard are met? No, if the case involves voluntary medical removal before the medical removal levels required by an OSHA standard, you do not need to record the case on the OSHA 300 Log.