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Methylene Chloride Facts No. 2
Medical Surveillance Requirements
Occupational Safety and Health Administration (1998)
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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.
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