Medical Surveillance and Recordkeeping
Medical surveillance
OSHA requires medical surveillance for workers exposed at or above the PEL for 30 or more days per year, and for workers who wear negative-pressure respirators. Components typically include a medical and work history, physical exam, and pulmonary function test (spirometry); chest X-rays may be included. Exams are provided at no cost to the worker, at initial assignment and periodically.
Recordkeeping must preserve exposure monitoring records, medical records, training records, and respirator fit test records for the required retention periods. Medical records are confidential and kept separately from personnel files.
Traps
- Forgetting that medical surveillance is at no cost to the employee.
- Mixing up retention periods for exposure records versus medical records.
- Assuming medical surveillance is optional; it is triggered by exposure thresholds.
- Overlooking that the employer must inform workers of monitoring results.
Rule of thumb
Exposure records and medical records have different retention rules; when unsure, keep longer and consult the standard. Provide results to the worker.
Worked example
A worker is exposed above the PEL for 40 days in a year. The employer must offer medical surveillance at no cost, including history, exam, and spirometry, and keep the records with required retention.