MEDICAL SURVEILLANCE-OSHA REQUIRED STANDARDS 2015

Taken from the federal OSHA standards-Title 29 of the Code of Federal Regulations (29CFR).

The purpose of the medical surveillance program is to identify medical conditions that could lead to an increased risk of adverse health effects related to the task being performed. The goal is to then prevent an occupational disease. If an occupational disease is identified, proper treatment to minimize its health effects is undertaken. The secondary objective is to assure compliance with federal and state regulations which require medical monitoring when employees use certain materials. OSHA standards having an OSHA "medical surveillance" requirements are generally clinically focused (e.g., medical and work histories, physical assessment, biological testing) and based on the type of work being performed. Factors to be considered include duration of the task, the materials being used, and the potential for exposure, medical surveillance is then either recommended or required for the job.
QCOH and COH can help you develop a Medical Surveillance program to fit your particular company’s needs based on exposures you provide. A basic medical surveillance program will be recommended. The physician will determine the scope of the evaluation, and then inform the company of their recommendations based on the known exposures, the standards and each individual employee’s exam. The employee can contact the physician who performs the exam with any questions regarding the test results. According to federal law, employees have the right to request copies of their medical or exposure records at any time by contacting their supervisor or Human Resources.

An example of a typical medical surveillance program on Lead, a common industrial exposure, is:

Physical exam-

  • Teeth
  • Gums
  • Hematologic-CBC with diff
  • Renal-UA with microscopic exam
  • Cardiovascular exam-BP
  • Neurologic exam
  • Pulmonary exam for respirator clearance if required by exposure


Lead hygiene discussion
Work and medical history
  • Reproductive history
  • Past lead exposure-work and non-work
  • General medical history


PFT if requested by physician-baseline is commonly recommended
CBC with diff and peripheral smear
BUN/CR
PB, ZPP testing
UA with micro
Pregnancy testing upon request by employee
Male fertility testing upon request by employee
Written Medical opinion

Follow-up testing

  • If exposed at or above the action level for more than 30 days per year-needs retesting every 6 months.
  • If testing of blood lead levels at or above 40 ug/100g needs retesting of lead/ZPP every 2 months, until 2 consecutive blood samples are below 40ug/100g of whole blood.
  • If employee has been medically removed from exposure to lead then PB/ZPP levels need to be repeated at 2 wks and monthly during removal.
  • Removal level of greater than or equal to 60ug/100 g or if average blood level above 50 ug/100g when blood sampling tests averaged over past 6 months. Can RTW when their level is below 40 ug/100g.
  • The employer may condition benefits on whether or not the employee participates in follow-up medical surveillance.


To see other OSHA standard Requirements: https://www.osha.gov/Publications/osha3162.pdf