Medical Surveillance

Medical surveillance programs are another key component of the Safety and Health Program. Employers must implement a medical surveillance program to aid in assessing the health and wellness of employees who work with hazardous substances. Medical surveillance programs review the screening results from groups of employees or individual employees to check for abnormal trends in health status. Reviewing these trends helps to identify potential problem areas, the effectiveness of safety procedures already in place, and how health and safety issues can be improved. Employers are required to establish a medical surveillance programs for the following types of employees:

• All employees who are exposed or potentially exposed to hazardous substances or health hazards above permissible exposure limits for more than 30 days per year
• Workers who are exposed to hazardous substances or health hazards above the published exposure levels (if there is no permissible exposure limit for these substances) for 30 days or more a year
• Workers who wear approved respirators for 30 or more days per year on site
• Workers who are exposed to unexpected or emergency releases of hazardous wastes above exposure limits (without wearing appropriate PPE); or who show signs, symptoms, or illness that may have resulted from exposure to hazardous substances
• Members of hazardous materials (HAZMAT) teams

Employees who are required to undergo medical surveillance will be provided the supervision of a licensed physician at no cost. Employees will not incur loss of pay, and the examination should be performed at a reasonable time and place. Physician examinations include both medical and work history, and the physician will pay close attention to any symptoms related to the handling of hazardous substances. In addition, the physician will assess the worker's ability to wear required PPE.

Employees must receive medical surveillance examinations under the following circumstances:

• Prior to the employee's job assignment and annually thereafter (or every two years if a physician determines that is sufficient)
• At the termination of employment
• Before reassignment to an area where medical examinations are not required
• If the examining physician believes that a periodic follow up is medically necessary
• As soon as possible for employees who are injured or who become ill from exposure to hazardous substances during an emergency, or for those who develop signs or symptoms of overexposure from hazardous substances

When an employee visits a physician for medical surveillance, the employer must furnish the doctor with the following information:

• A copy of the medical surveillance program and its appendices
• A description of the employee's duties relating to his or her exposure
• The hazardous waste exposure level or anticipated exposure level
• A description of any PPE and respiratory equipment that the employee has used or will use
• Any information from previous medical examinations

Following the examination, the physician must provide the employer with a written opinion that includes the results of the medical examination, as well as any medical conditions that may place the employee at increased risk to exposure of hazardous materials. The physician cannot reveal to the employer any examination results that are unrelated to the worker's employment.

To learn more about Hazardous Waste visit our Hazardous Waste Safety Online Training web page.