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Methylene Chloride Facts No. 2
Medical Surveillance Requirements

Occupational Safety and Health Administration (1998)
On January 10, 1997, the Occupational Safety and Health Administration (OSHA) issued a standard that lowered the limit on worker exposures to methylene chloride (MC). This new standard greatly reduces the chance of developing health problems from working in facilities that use MC.

Worker exposures to MC occur mainly through breathing its vapors. MC can also pass through workers' skin if it gets on their bodies or clothes. Occasionally, workers can swallow small amounts of MC if they don't wash their face and hands before eating, or if they eat in contaminated work areas. Short-term exposure to high levels of MC can cause dizziness, headaches, a lack of coordination, and irritation of the skin, eyes, mucous membranes, and respiratory system. Long-term exposure causes cancer in laboratory animals. Studies in workers suggest an association between MC exposures and certain types of cancer. OSHA considers MC to be a potential occupational carcinogen. Exposure to MC may also make the symptoms of heart disease (e.g., chest pains, angina) worse.

Medical surveillance enables employers to determine if exposure to MC is adversely impacting employee health. OSHA's MC standard requires that under certain conditions, facilities using MC have a medical surveillance program. This fact sheet provides only general information on how to implement a medical surveillance program in your facility and should not be considered to be a complete summary of the MC medical surveillance requirements. For specific medical surveillance requirements, please refer to the OSHA MC standard (Title 29 of the Code of Federal Regulations, Part 1910.1052(j)). The MC standard can be accessed at OSHA's web site.

Step 1: Identifying Employees

The first step in implementing a medical surveillance program is to identify those people who require medical surveillance. Employers must make medical surveillance available to employees who are exposed to MC:
  • At or above the action level (12.5 ppm, 8-hour time-weighted average (TWA)) for 30 or more days per year;
  • At or above the short-term exposure limit (STEL) (125 ppm, measured over a 15 minute period), or the 8-hour TWA permissible exposure limit (PEL) (25 ppm) for 10 or more days per year; or
  • During an emergency situation.
In addition, employers must make medical surveillance available upon request to employees with cardiac disease or other MC-related health conditions, regardless of the duration of MC exposure.

Before requiring any employee to wear a respirator, employers must also have a physician or licensed health care professional determine and state in writing the employee's ability to wear respiratory protection.

Note: A physician or other licensed health care professional is defined as a person whose legally permitted scope of practice allows him or her to independently provide, or be delegated the responsibility to provide, some or all of the health care services required by the final rule.

Note: Employers must make required medical surveillance available to affected employees at no cost, without loss of pay, and at a convenient time and place.

Step 2: Establishing a Schedule

The next step is to establish a schedule for providing initial and periodic medical surveillance.

Initial Medical Surveillance:
  • Employers with fewer than 20 employees must make initial medical surveillance available to affected employees by April 10, 1998.
  • Polyurethane foam manufacturers with 20 to 99 employees must make initial medical surveillance available to affected employees by January 5, 1998.
  • All other employers must make initial medical surveillance available to affected employees by December 21, 1997.
  • If the applicable start-up date stated above has already passed, employers must make initial medical surveillance available before the employee is assigned to work which involves potential MC exposure.
Initial surveillance is not required if the employee has received medical surveillance equivalent to that required by the MC standard within 12 months prior to the effective date of the standard (April 10, 1997).

Periodic Medical Surveillance:
  • Employers must make periodic physical exams and appropriate laboratory surveillance available based on the following age-based frequency:
    • Annually for employees 45 years of age or older.
    • Every three years for employees under the age of 45.
  • Employers must update each employee's medical and work history annually.
Additional Medical Surveillance:
  • Employers must make additional medical surveillance available to employees when determined necessary by the examining physician or licensed health care professional.
Employers may stop making medical surveillance available to an employee at the end of employment or when the employee has been reassigned to an area where MC exposures are consistently below the action level and STEL. In such cases, however, the employer must make medical surveillance available to the employee if six months or more has passed since the employee last received medical surveillance.

Step 3: Gathering and Providing Information

Prior to the performance of medical procedures, the employer must provide the physician or licensed health care professional with the following:
  • Copy of the MC standard and related appendices.
  • Description of the affected employee's past, current, and future duties that involve MC exposure.
  • Employee's former, current, and/or anticipated MC exposure levels and exposure frequency, as well as the frequency and exposure levels anticipated for emergencies.
  • Description of any personal protective equipment, such as respirators, that is currently used or will be used in future work assignments.
  • Information from previous employment-related medical surveillance.
Step 4: Ensuring Proper Medical Surveillance

Employers must ensure that the physician or licensed health care professional performs the following medical surveillance procedures.

Initial and routine medical exams must include:
  • Comprehensive evaluation of the employee's medical and work history (see Appendix B of the MC standard for detailed guidance).
  • Physical exam with special emphasis on the lungs, cardiovascular system (including blood pressure and pulse), liver, nervous system and skin.
  • Laboratory surveillance tests as deemed necessary by the physician or licensed health care professional (see Appendix B of the MC standard for detailed guidance).
  • Any additional information or reports deemed necessary by the physician or licensed health care professional.
Emergency medical surveillance must include:
  • Appropriate medical treatment and decontamination of the exposed employee.
  • Comprehensive physical exam with special emphasis on the nervous system, cardiovascular system (including blood pressure and pulse), lungs, liver, and skin.
  • Updated medical history as appropriate for the employee's medical condition.
  • Laboratory surveillance as indicated by the employee's health status.
Step 5: Providing Exam Results

Employers must ensure that the physician or licensed health care professional provides, to both the employee and the employer, a written opinion regarding the examination results within 15 days of evaluating all related test results and findings, and not more than 30 days after the examination. The written opinion must inform the employer of any increased health risk the employee might experience due to MC exposure and of the employee's ability to use PPE. The written opinion must confirm that the employee has been advised of the examination results and of the potential health effects of MC exposure, and must contain only information related to the employee's occupational exposures.

Note: The employer must tell the physician or licensed health care professional not to reveal to him/her, orally or in writing, any specific records, findings, or diagnoses that have no bearing on occupational exposures to MC.

Step 6: Medical Removal Protection

The revised final standard published September 22, 1998 (FR 63; 50712-50732) contains requirements for temporary medical removal protection. Under these requirements, the employer must provide medical removal protection benefits to the employee when a medical determination recommends that an employee be removed from MC exposures because such exposure may contribute to or aggravate the employee's existing cardiac, hepatic, neurological, or skin disease. The revised standard must be consulted for complete requirements on items such as job transfer of the employee, voluntary removal, and benefits retention.

Step 7: Recordkeeping

Employers must, at a minimum, keep the following records for the duration of each employee's employment plus 30 years:
  • Employee's name, social security number, and description of duties.
  • Written medical opinions.
  • Any medical conditions related to MC exposure.
Additional Resources

For more information concerning consultation assistance, contact the nearest OSHA office (look under state listings for the Department of Labor), refer to the listings on OSHA's web site, or contact OSHA's Office of Information at (202) 219-8151.