Standard Interpretations - Table of Contents|
| Standard Number:||1910.1027|
|This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any situation not delineated within the original correspondence. OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.|
OSHA relies in this final standard on a specific provision requiring the employer to also provide medical surveillance to certain employees who prior to this standard were exposed to cadmium. This provision triggers medical surveillance independently of the current action level. Thus, in addition to having to provide medical surveillance to certain employees who are currently exposed, employers are also required to provide medical surveillance to employees who were or might have been previously exposed at or above the action level by the current employer for a specified period of time, regardless of whether they are currently exposed at or above the action level.This means that if permanent abatement of the cadmium hazard has taken place such that there is no measurable occupational exposure to cadmium for previously exposed employees, then the medical surveillance requirements of the standard do not apply. On the other hand, if the previously exposed employees are still at the same workplace where the past cadmium exposure occurred, and are experiencing measurable occupational exposures to cadmium below the action level, then the employer's obligation to provide medical surveillance under paragraph 1910.1027(l)(1)(i)(B) is maintained.
|Standard Interpretations - Table of Contents|
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