What is Medical Surveillance?
Medical surveillance, as required by the Occupational Safety and Health Administration (OSHA), is a program of medical examinations and tests designed to detect and monitor potential health effects from hazardous chemical or physical exposures in the workplace to enable early treatment or other steps to protect employee health. Medical surveillance is conducted in conjunction with other employer measures – such as workplace practices and engineering controls – to prevent occupational injury and illness. American employees use tens of thousands of chemicals every day. While many of these chemicals are suspected of being harmful, relatively few chemicals are regulated in the workplace.
As a result, employees suffer more than 190,000 illnesses and 50,000 deaths annually related to chemical exposures.1 Workplace chemical exposures have been linked to cancers and other lung, kidney, skin, heart, stomach, brain, nerve, and reproductive diseases. Regulated substances are subject to numerous rules, such as:
- Permissible exposure limit (PEL) – The legal limit for employee exposure to a regulated chemical substance. This limit is the airborne workplace concentration of a substance frequently expressed as a time-weighted average over an eight-hour day or a 40-hour work week. Many PELs have not been updated since 1971, and current scientific data suggest that, in many instances, the outdated PELs are not sufficiently protective of employee health. The required resource-intensive analysis has slowed the PEL rulemaking process to a crawl. Since 1971, OSHA has been successful in establishing or updating PELs for only about 30 chemicals.
- Action level – This is what OSHA uses to determine whether the employer must offer employees medical surveillance and increased exposure monitoring. Action level pertains to employee exposure, without regard to the use of respirators, to an airborne concentration of a substance, averaged over an eight-hour period.
- Excursion limit – The limit on the time an employee’s exposure during a single workday may exceed the PEL or time-weighted average. Excursion limits are enforced in some states and, on the federal level, for asbestos.
Concentra® provides compliant medical surveillance evaluations that meet OSHA requirements. In addition, Concentra can provide recommendations to go beyond OSHA’s minimum requirement for all major workplace exposure monitoring, including, but not limited to:
- Hazardous waste operations and emergency response
OSHA Standard 1910.120
- Respiratory protection
OSHA Standard 1910.134
OSHA Standard 1910.1001
OSHA Standard 1910.1024
- Bloodborne pathogens
OSHA Standard 1910.1030
- Respirable crystalline silica
OSHA Standard 1910.1053
Medical Surveillance: First Steps
Before turning attention to medical surveillance physical exams and testing services you might need, there are four steps that help in creating a medical surveillance program. These can be done either by the employer alone or while working with an occupational health provider, like Concentra.
- Determine which hazardous substances exist in your workplace.
This step includes hazard analysis of the substances used as a necessary part of production processes or hazardous substances that are a byproduct of your operations. Employers may either work with an industrial hygienist or perform their own area and personal monitoring of identified hazards to determine if the measured levels expose employees to health and safety risks or meet OSHA requirements for medical surveillance.
- Become familiar with the pertinent OSHA regulation(s).
OSHA regulations will outline the permissible exposure limit (PEL) and action levels (ALs), as well as the medical screenings or surveillance measures that must occur at each level. Many employers choose to go above and beyond OSHA’s minimum requirements and use more up-to-date exposure levels provided by the National Institute for Occupational Safety and Health (NIOSH) and the American Conference of Governmental Industrial Hygienists (ACGIH).
- Determine the necessary components of your medical surveillance program, including examinations and tests.
Every substance has unique properties and every employee group can be different, so the details that need to be considered to protect employee health are complicated.
- Identify employees who need medical surveillance and communicate key aspects of the program to them.
You are probably familiar with OSHA’s basic requirement that employers must provide a safe workplace free from recognized hazards, provide safe and well-maintained tools, equipment, and protective gear, and offer safety training that all employees can understand. Reviewing these Employer Responsibilities is a good idea.
You should also be aware that OSHA outlines employer responsibilities regarding medical surveillance and employees’ access to medical and exposure records. Employers are required to:
- Preserve and maintain accurate medical and exposure records for each employee. In general, the Americans with Disabilities Act requires employee medical information to be kept confidential.
- Inform employees of the existence, location, and availability of medical and exposure records.
- Give employees any informational material that OSHA makes available to you.
- Make records available to employees, their designated representatives, and to OSHA, as required.
Without a doubt, these four “first steps” in creating a medical surveillance program are a heavy lift for many employers. The good news is you don’t have to do it alone. Concentra has been providing medical surveillance examinations and other occupational health programs and services for more than 40 years. All of our medical centers, currently in 44 states, are ready to serve you. When you contact Concentra, you can set up your medical surveillance examination services faster than going it alone and with assurance of full compliance.
Medical Surveillance for the Growing Threat
Manufacturers and importers of chemicals listed on the Toxic Substances Control Act inventory – and meeting certain thresholds – are required to report this information to the federal Environmental Protection Agency (EPA) every four years. The EPA released its latest report (the 2016 Chemical Data Reporting) in stages. It shows production/use of 8,707 chemicals, with 4,917 sites and 2,247 companies reporting.2 This is up from 7,970 chemicals in the last report four years earlier.
OSHA medical screening and surveillance standards address numerous hazardous substances – including a variety of chemical compounds, such as metal oxides, aromatic amines, industrial agents and solvents, and more. Concentra provides medical surveillance examination services that also include silica dust, bloodborne pathogens and, although there is no federal standard, exposure to heat.
Concentra develops guidelines, interprets regulatory standards and laws, and fulfills compliance requirements for all regulated exposures pertinent to the employers and industries we serve. This includes respiratory protection, bloodborne pathogens, asbestos, lead, beryllium, crystalline silica and a host of other exposures.
We continuously update our guidance documents for clinicians in Concentra community-based medical centers, and also offer recommendations for specific worksite examinations, such as Hazmat, Firefighter, Law Enforcement Officer, and Commercial Driver. You can read about the components of each of our physical exams in our article, “What does a physical consist of?”
Concentra provides a range of medical surveillance services:
- Baseline surveillance exams
- Follow-up exams (for pesticides only)
- Periodic surveillance exams
- Biologic monitoring
- Exit exams upon leaving an employer
For respiratory protection, Concentra uses the mandated OSHA Respirator Medical Clearance Evaluation Questionnaire and recommends a targeted physical exam. In addition, if indicated, the evaluating clinician may conduct ancillary tests (spirometry, chest X-ray, or resting electrocardiogram).
After reviewing the questionnaire responses, conducting a physical exam, and reviewing test results, the clinician will provide a written medical opinion to the employer to address the employee’s ability to wear a respirator. Concentra also provides respirator fit tests to ensure the respirator fits well for adequate protection.
Concentra’s Unrivaled Expertise
Concentra has a resource for medical surveillance that other occupational health providers lack. It’s our Regulatory, Testing, and Examination (RTE) Medical Expert Panel (MEP), a team of clinicians and colleagues with special expertise that focuses on keeping the employers we serve up-to-date on the latest medical surveillance requirements and compliance.
The RTE Medical Expert Panel is chaired by Ronda McCarthy, MD, MPH, FACOEM, Concentra’s national director of medical surveillance services. Dr. McCarthy’s renown in medical surveillance is seen in journal publications of her original research, national and international speaking engagements, and her leadership roles in health care, scientific, academic and professional forums focused on medical surveillance and occupational health for 20 years. Dedicated to workforce health and safety, Dr. McCarthy works closely with other members of the RTE Medical Expert Panel, including clinicians, a safety representative, and a representative from Concentra’s product development team.
- https://www.osha.gov/dsg/safer_chemicals/index.html This number is derived using the methodology from "Green Chemistry in California: A Framework for Leadership in Chemicals Policy and Innovation," (http://coeh.berkeley.edu/docs/news/06_wilson_policy.pdf [PDF*]) to estimate illness and deaths attributable to workplace chemical exposures.
- 2016 Chemical Data Reporting Results, U.S. Environmental Protection Agency. Accessed September 30, 2019. https://www.epa.gov/chemical-data-reporting/2016-chemical-data-reporting-results