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Directives - (Archived) Table of Contents
• Record Type: Instruction
• Directive Number: PER 04-00-002
• Old Directive Number: PER 8-2.4
• Title: CSHO Pre-Employment Medical Examination
• Information Date: 03/31/1989
• Status: Archived

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

OSHA Instruction PER 8-2.4 March 31, 1989 Directorate of Technical support

Subject: CSHO Pre-Employment Medical Examinations

A. Purpose. This Instruction implements the OSHA medical requirements standards for CSHO new hires.

B. Scope. This instruction applies OSHA-wide.

C. References.

1. Draft OSHA Instruction, April 6, 1987, Subject: OSHA Medical requirements standard.
2. Coronary Risk Handbook Estimating Risk of Coronary Heart Disease in Daily practice, American Heart association.
3. Memorandum to Regional Administrators, April 14, 1987, Subject: public Health Service contract for CSHO physicals, from Leo Carey and Edward Baier.

D. Action. OSHA Regional Administrators and National Office Directors shall ensure that the procedures described in this instruction are implemented.

E. Background. Early in 1985, OSHA applied for and later received from the Office of Personnel Management (OPM) a single Agency physical examination standard covering OSHA personnel. The standard is applicable to the OSHA employees described in section F. of this instruction as well as to new hires.

1. The implementation of a single Agency medical requirements standard ensures that the health of OSHA employees will be at a level which will permit them to perform job-related assignments under conditions that vary from sedentary to maximum exertion.

OSHA Instruction PER 8-2.4 March 31, 1989 Directorate of Technical Support

2. Normal work conditions also require the employee to perform in a reliable manner under adverse conditions. Routine assignments require employees to enter work sites and observe and evaluate conditions to which workers are exposed. This includes working at heights; working underground; working in confined spaces; working in emergency situations; and working in environments with chemical, physical, and biological hazards.
3. Many of these hazards are regulated by established OSHA standards which require the use of protective equipment and/or routine medical monitoring. The proper use of personal protective equipment requires an evaluation of the wearer's physical ability to utilize the equipment safely without adverse effect to the wearer's health. Adverse conditions sometimes occur unexpectedly while others are anticipated. In the latter case, appropriate steps can be taken in an orderly and controlled manner to protect oneself and safely leave the hazard area.
4. This instruction implements the physical requirements standard and establishes the OSHA pre-employment medical examination program for OSHA applicants to positions covered in section F.
5. OSHA contracted with the U.S. Public Health Service (PHS) to provide the mandatory pre-employment physical examinations required under this program. OSHA's national contract with a single agency to provide the medical examinations required under this program assures Agency-wide uniformity in the administration and quality control of the examinations given.
      F.  Coverage.  Specific positions by grade and series to which this
         instruction apply include:

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OSHA Instruction PER 8-2.4 March 31, 1989 Directorate of Technical Support

Position Series Grade
Student Trainee GS-099 4-5 Safety Specialist GS-018 5-13 Supervisory Safety Specialist GM-018 13 Safety and occupational Health Manager GM-018 13 Industrial Hygienist GS-690 5-13 Supervisory Industrial Hygienist GM-690 13 Safety Engineer GS-803 5-13 Supervisory Safety Engineer GM-803 13
1. All applicants to the above-classified positions who will be working in a OSHA Regional or Area Office are required to take the pre-employment medical examination specified under this program. Employees in these positions are required to make regular or occasional visits to industrial worksites where they may be exposed to potentially toxic chemicals and/or physical hazards.
2. Covered applicants must undergo the medical examination specified herein in order for the Agency to determine if they are physically and medically capable of performing the essential duties of the position efficiently and without hazard to themselves or others. Examination will be provided free of charge to the applicant.
      3.  Several OSHA standards require pre-employment and routine medical
         examinations in order to monitor the health of employees who may
         be exposed to potentially hazardous substances or physical hazards
         and who must be physically capable of safely utilizing personal
         protective equipment. This medical standard and annual physical
         examination program allows OSHA to ensure compliance with
         currently existing OSHA standards as they pertain to potential
         OSHA employees.

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OSHA Instruction PER 8-2.4 March 31, 1989 Directorate of Technical Support

4. Regional Office staff are included under the pre-employment examination requirement because they may have to provide on-site assistance to Area Office staff concerning specific inspections. Also, they are responsible for making on-site variance inspections and therefore face potential workplace exposures to hazardous situations.
5. Student trainees for the above classified positions are covered under this program.

G. Pre-Employment Examinations. The pre-employment examinations described in this instruction are mandatory for all individuals required to take them (see section F.), and all affected new hires are required to pass the examination.

1. Failure to meet the required physical and medical qualifications will be considered disqualifying.
2. The results of all examinations provided under this program are the property of the Office of Personnel Management (OPM) and will be safeguarded in accordance with the OPM regulations that all government agencies must follow to protect access to employee medical records. (See OPM regulations 5 CFR 293, Subpart E.) Additionally, the Director of the OSHA Office of Occupational Medicine is responsible for assuring that all procedures for review and handling of medical records are in accordance with OSHA standard 29 CFR 1910.20, "Access to Employee Exposure and Medical Records."

H. Procedures. All applicants to the positions covered in section F are required to take and pass the OSHA pre-employment medical examination. Failing to meet the requirements contained in the medical examination means that the individual does not meet the physical qualification requirements of the position. The specific physical and medical parameters are found in Appendix A of this Instruction.

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OSHA Instruction PER 8-2.4 March 31, 1989 Directorate of Technical Support I. Responsibilities.

1. Regional Administrators.
a. Regional Administrators are responsible for implementing the CSHO Medical Examination Program mandated by this instruction.
b. Regional Administrators are responsible for contacting the Public Health Service (PHS) medical facilities that will be utilized within the Region for providing the required examinations. Any difficulties or problems involving OSHA's national contract with PHS shall be brought by the Regional Administrator to the attention of the Director of Technical Support. In addition, each Region must coordinate and maintain a listing of contact persons in order to facilitate communication between OSHA and PHS.
c. Each Region is to coordinate the physical examinations of new hires who are located within its boundaries. This is so whether the candidate is to be hired by that Region or another one.
2. The Office of Occupational Medicine and Directorate of Technical Support.
a. The Director of Technical Support is responsible for negotiating and securing the national contract to provide the examinations required under this program. Any difficulties or problems that arise regarding the administration of the national contract with the Public Health Service will be resolved by the Directorate of Technical Support as the Agency's representative.
b. The Office of Occupational Medicine is responsible for reviewing all medical records of employees forwarded to it for accuracy and consistency.

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OSHA Instruction PER 8-2.4 March 31, 1989 Directorate of Technical Support

c. The Office of Occupational Medicine shall assure that all procedures for review and handling of OSHA medical records are in accordance with OSHA standard 29 CFR 1910.20 and the Office of Personnel Management's 5 CFR 293, Subpart E. This includes establishing and maintaining a confidential storage and retrieval system so that individual records can be kept.
d. The Directorate of Technical support shall establish a system that tracks the custody and status of the examination results. This will provide a check and balance system for the Regions.
3. The Directorate of administrative programs and the Office of Field Programs. The Directorate of Administrative Programs and the Office of Field programs shall provide guidance and assistance to the Regions for the application of this program.

John A. Pendergrass Assistant Secretary

DISTRIBUTION: National, Regional and Area Offices Compliance Officers

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OSHA Instruction PER 8-2.4 March 31, 1989 Directorate of Technical Support

Appendix A
OSHA PRE-EMPLOYMENT MEDICAL EXAMINATION PROGRAM

A. Purpose. Applicants to OSHA Compliance Safety and Health Officer (CSHO) and other specific OSHA positions are required to make inspections of industrial establishments to observe and evaluate conditions to which workers are exposed.

1. During these inspections CSHOs may be exposed to potentially hazardous situations and substances. The implementation and application of a single Agency medical requirements standard to all affected employees ensures that the health of OSHA employees will be at a level that permits them to perform job-related assignments safely, effectively, and without hazard to themselves or others.
2. OSHA has contracted with the U.S. Public Health Service (PHS) to provide the physical examinations required under the OSHA Medical Examination Program. OSHA's contract with a single agency to provide these examinations serves to ensure agency-wide uniformity in the administration and quality control of the necessary examinations.

B. Physical Requirements Rationale. Following is a general description of the physical requirements of the positions affected by the OSHA Medical Examination Program.

1. The duties of these positions require employees to perform under conditions that vary from sedentary to maximum exertion Normal work conditions also require the employee to perform in a reliable manner under adverse conditions. Employees must examine and report on potentially hazardous worksite conditions. This may include working at heights, underground, in confined spaces in poorly lighted facilities, in emergency situations, and working in environments with chemical, physical, and biological hazards which are regulated by the OSH Act.
2. Many of the hazards CSHOs may face are regulated by established OSHA standards which require the use of personal protective equipment and/or routine medical monitoring. The proper use of personal protective

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OSHA Instruction PER 8-2.4 March 31, 1989 Directorate of Technical Support

equipment requires an evaluation of the wearer's ability to utilize the equipment safely, without adverse effect to the wearer's health. Adverse conditions sometimes occur unexpectedly, while others are anticipated and appropriate steps can be taken in an orderly and controlled manner to protect oneself and safely leave the hazard area.
3. Before entrance on duty and routinely during employment, applicants and employees in these positions must undergo a medical examination and be physically and medically capable of performing the essential duties of the position efficiently and without hazard to themselves or others.
4. Routine medical evaluations serve to monitor the employee's health status to ensure that he or she maintains a condition which would meet the criteria of this standard. In addition, routine medical monitoring tracks conditions which may develop as a result of exposure to toxic materials which have latent periods for symptom development.
5. Failure to meet the required-physical and medical qualifications will usually be considered disqualifying.

C. Medical Examination Parameters.

1. Vision.
a. Physical Requirement.
Distant visual acuity must be at least 20/40 in each eye with or without corrective lenses; distant binocular acuity of at least 20/40 with or without corrective lenses. Near visual acuity must be corrected to at least 20/40 in each eye; near binocular acuity of at least 20/40 with or without corrective lenses. Field of vision at 90 degrees in the horizontal meridian in each eye. Ability to distinguish the colors red, amber, and green.

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OSHA Instruction PER 8-2.4 March 31, 1989 Directorate of Technical Support

b. Work Activity.
Routinely assigned to areas where: the reading of comprehensive literature is necessary; both near and far visual acuity are necessary for hazard recognition; potentially life threatening environments exist (therefore, accurate reading of the type of personal protective equipment is necessary); color coded warning signs represent hazardous conditions. Routine utilization of finely calibrated equipment.
c. Rationale.
A CSHO inspects workplaces where potential safety and health hazards exist or can spontaneously occur. Once these hazards occur, a compliance officer must be capable of determining what actions are appropriate in order to safeguard the safety and health of the CSHO and others. These actions will always require both near and far visual acuity. For example, quickly ascertaining the condition of a respirator to use in the case of an emergency egress situation. (This requires reading finely calibrated air gauges.) While making routine inspections, a compliance Officer will encounter situations where full field of vision will be necessary in order to avoid a serious accident. For example, while working on high scaffolding, it may be necessary to rapidly descend. Normal field of vision is necessary to perform this activity safely with a full-face respirator.
2. Hearing.
a. Requirement.
Average hearing loss in the better ear cannot be greater than 40 decibels at 500 Hz., 1,000 Hz., and 2,000 Hz., with or without a hearing aid.
b. Work Activity.

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OSHA Instruction PER 8-2.4 March 31, 1989 Directorate of Technical Support CSHOs are routinely assigned to areas where a broad spectrum of physical hazards exist, including environmental noise levels above 90 decibels.

c. Rationale.
It is important that a compliance officer have an established hearing level in order to communicate and give instructions in a noisy environment. During the course of daily activities, it is important for a compliance officer to hear instructions and communications in order to ensure safety. A greater than 40 decibel loss of speech frequency in the better ear may interfere with the CSHO's ability to communicate under noisy conditions.
3. Musculo-Skeletal.
a. Requirement.
Both hands, arms, legs, and feet. No impairment of the use of a leg, a foot, an arm, a hand, the fingers, back or neck which would most likely interfere with the functional requirements of this position. No established medical history or clinical diagnosis of rheumatic, arthritic, orthopedic, muscular, neuromuscular, or vascular disease which would interfere with the ability to perform the functional requirements of this position.
b. Work Activity.
A compliance officer is required to perform moderate lifting, carrying, walking and standing. A compliance officer will routinely be required to ascend or descend heights in order to safely egress from a potentially hazardous area. During routine activities, a compliance officer must carry portable scientific equipment.
c. Rationale.

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OSHA Instruction PER 8-2.4 March 31, 1989 Directorate of Technical Support

it is imperative that no established medical history of cardiac or pulmonary disease exists. It is known that carrying heavy equipment while ascending or descending great heights places an excess burden on the cardiopulmonary system. Therefore, it is imperative that the cardiovascular system be without pathology. Since a compliance officer is required to wear a negative pressure respirator, it is imperative and in compliance with OSHA standard 1930.134 that a physician medically qualify the applicant to wear such a respirator. It is known that pre-existing cardiac or respiratory disease can prevent an individual from wearing such a respirator.

D. Medical Examination Requirements

1. General. The medical examination required herein will be conducted by a physician experienced in occupational medicine preferably by a physician who is a member of the American College of Occupational Medicine. The examining physician or institution will provide special instructional material (such as necessary fasting periods or special eating instructions) to OSHA management which will in turn provide this information to the applicant prior to the examination.
2. History. Review of the applicant's history must be conducted in regard to personal and family medical history and a work history including occupational exposures to chemical and physical hazards.
a. Appropriate medical forms must be completed by the applicant and provided to the physician prior to the examination.
b. There shall be an examining room discussion between the applicant and the physician regarding medical history, with special attention given to the questionnaire on occupational exposures to chemical and physical hazards.
c. The development of the medical history is to be inclusive of what is commonly termed multi-phasic screening

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OSHA Instruction PER 8-2.4 March 31, 1989 Directorate of Technical Support

3. Specific Examination Tests and Requirements. The physical examination should include, but not be limited to a review of the following: head and neck, including visual tests, an examination of the ears, nose and throat, an examination of the respiratory, cardiovascular and central and peripheral nervous systems, an examination of the abdomen, rectum, and genitourinary system, an examination of the spine and other musculoskeletal systems, and an examination of the skin. Specific tests/measurement to be obtained include:
a. Height and weight.
b. Temperature, pulse, respiration rate, blood pressure.
c. Eye examination, including:
(1) Visual acuity, near and far. (2) Depth perception. (3) Accommodation. (4) Field of vision. (5) Fundiscopic.
d. Cardiopulmonary evaluation, which shall include the following:
(1) Resting twelve-lead electrocardiogram with interpretation.
(2) A sub-maximal exercise test with a twelve-lead EKG will be required of those applicants found to be in a category of risk greater than 18 per 100 according to the Coronary Risk Handbook published by the American Heart Association.

(3) Pulmonary function Evaluation:
(a) FVC, FEV1, FEV1/FVC ratio. (b) Permanent record of flow curves must be included in the patient's report.

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OSHA Instruction PER 8-2.4 March 31, 1989 Directorate of Technical Support

(4) Chest X-ray (PA) 14 x 17 inches as a baseline.
e. Comprehensive laboratory profile including:
(1) Urinalysis (including microscopic). (2) Hemocult. (3) CBC. (4) Test chemical groups (done after 12-hour fast) :
(a) Chloride, bicarbonate. (b) Glucose. (c) Blood urea nitrogen. (d) Creatinine. (e) Uric acid. (f) LDH, SGOT, SGPT, GGTP. (g) Alkaline phosphatase. (h) Bilirubin. (i) Total protein. (j) Albumin and globulin. (k) Cholesterol. (1) Triglycerides. (m) HDL Cholesterol.. (n) Potassium. (o) Calcium. (p) blood lead, if indicated. A blood lead and zinc protoporphyrin should be done when there is a history of lead exposure or when the test is indicated in the physician's judgment.
f. Audiometric Testing:
(1) An otoscopic examination, otological history, and audiometric test shall be administered by an otolaryngologist, audiologist, or certified audiometric technician.
(2) Audiometric facilities, equipment, calibration procedures, and technician certification shall meet the requirements outlined in 29 CFR 1910.95.
(3) The results of the otoscopic examination, otological history and audiometric tests

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OSHA Instruction PER 8-2.4 March 31, 1989 Directorate of Technical Support

shall be reviewed by an otolaryngologist, audiologist, or other qualified physician.
g. Personal Protective Equipment Evaluation. The examining physician will evaluate the following results to determine the applicant's ability to utilize personal protective equipment including a negative pressure air-purifying respirator and protective clothing.
(1) Medical Occupational History: Conditions such as myocardial infarction, angina, severe emphysema, or any significant cardiac or pulmonary condition should be disqualifying.
(2) Physical Examination: Findings such as severe facial asymmetry, beard, obvious cardiac or pulmonary pathology should also be disqualifying.
(3) Pulmonary Function Test: Evidence of moderate to severe restrictive or obstructive airway pattern should be disqualifying.
(4) Chest X-ray: Evidence of cardiopulmonary pathology should be disqualifying.
(5) Electrocardiogram: Obvious cardiac disease should be disqualifying.

E. Reporting Requirements.

1. Examining Physician (PHS) to the Applicant. The examining physician will generate personal medical reports for all applicants examined and mail them to their private residence within 15 working days of the date that the applicant is examined. The results will list each test, individually indicating whether a result is normal or abnormal and, it appropriate, a recommendation for referral to the applicant's private physician will be made. In addition, the personal medical report will contain:
a. The physician's opinion as to whether the applicant has any detected medical condition(s)

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OSHA Instruction PER 8-2.4 March 31, 1989 Directorate of Technical Support

which would place the applicant at increased risk of material health impairment from work exposures and practices.
b. Determination of the applicant's ability to wear a respirator or any other personal protective equipment.
2. Examining Physician to OSHA's Office of Occupational Medicine. The examining physician will forward to the Office of Occupational Medicine the following:
a. A written opinion as to whether the applicant's health would be at increased risk of material impairment from the OSHA work environment.
b. A written statement regarding the applicant's ability to wear a respirator or other protective equipment.
c. A written statement that the applicant has been informed in writing by the physician of the results of the medical examination.
d. The examining physician shall utilize the appropriate DOL medical forms developed for the OSHA Medical Program.

F. Medical Records.

1. Upon completion of the medical examination, the physician shall forward to the Office of Occupational Medicine, U.S. DOL/OSHA, 200 Constitution Ave., N.W. , Room N3653, Washington, D.C., 20210, each applicant's complete medical record. The envelope shall be marked CONFIDENTIAL and the package shall include:
a. Completed medical/occupational history forms.
b. Completed physical examination forms, including the OSHA-178 form.
c. All laboratory test results.
d. Chest X-ray (radiograph and interpretation).

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OSHA Instruction PER 8-2.4 March 31, 1989 Directorate of Technical Support

e. Pulmonary function test. f. Audiometric test results.
2. These documents shall be maintained in accordance with the Office of Personnel Management's 5 CFR 293, Subpart E, "Employee Medical File System Records." They shall be in a secured, central location within the Office of Occupational Medicine and under the supervision of the Medical Records Officer for the duration of the time period necessary for National Office review.
3. If the applicant is hired by the Agency, his or her file will be entered into and stored in OSHA's medical records computer system. Hard copies of an OSHA employee's records and records for former OSHA employees will be located in an Employee Medical Folder (EMF) and stored in the Federal Records Center operated by the National Archives and Records Administration (NARA) for a period of 30 years after employment in accordance with OSHA standard 29 CFR 1910.20.
4. If the applicant is not hired into the position, his or her records will be retained by the Agency for the duration of the time period necessary for National Office review, plus an additional year. If no legal or administrative challenges are made regarding the Agency's handling of the file, the file will be retained in a secured central location within the Office of Occupational Medicine, and will be destroyed after the one-year retention period. A log detailing the location and disposition of the records will be maintained by the Office of Occupational Medicine.

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Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

Directives - (Archived) Table of Contents

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