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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:
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:
Periodic 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:
Employers must ensure that the physician or licensed health care professional performs the following medical surveillance procedures.
Initial and routine medical exams must include:
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:
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.