Standard Interpretations - Table of Contents|
| Standard Number:||1910.120; 1920.1020 ; 1926.1101|
|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.|
June 14, 1991
Douglas C. Scott, M.D., M.P.H.
Western Center for Occupational and Environmental Medicine
2425 South Colorado Blvd, Suite 150
Denver, Colorado 80222
Dear Dr. Scott:
Thank you for writing to the Occupational Safety and Health Administration (OSHA). I am responding to your letter of May 2, 1991 to the OSHA Regional Office in Denver, Colorado regarding 29 CFR 1910.120 and [29 CFR 1926.1101].
The employer is required to establish and maintain a record for each employee that is subject to medical surveillance. In actual practice, the physician's office maintains physical custody of the records under agreement with the employer. Procedures need to be established to allow access, storage, transfer, and disposal of these records in accordance with 29 CFR 1910.1020, while keeping personal medical information confidential.
The employee medical record in custody of the physician should include:
- medical and employment questionnaires or histories including
job description and occupational exposures,
- the results of medical examinations and laboratory tests
including X-rays, spirometry, audiograms, etc.,
- medical opinions, diagnoses, and recommendations,
- first aid records,
- descriptions of treatments and prescriptions, and
- employee medical complaints.
- whether the employee has any medical condition that would
place the employee at increased risk from occupational
- limitations to assigned work or use of protective
- a statement that the employee has been informed of the
results of the medical examination, and
- (for [29 CFR 1926.1101]) a statement that the employee has
been informed of the increased risk of lung cancer attributable
to the combined effect of smoking and asbestos exposure.
- a copy of the applicable standard and appendices,
- a description of the employee's duties,
- the employee's representative or anticipated exposure
- a description of personal protective equipment, and
- information from previous medical examinations.
Richard F. Kuehne, M.D., M.P.A., M.P.H.
Office of Occupational Medicine
|Standard Interpretations - Table of Contents|