Medical Surveillance, Exposure Records, and Training Documentation
Medical surveillance
OSHA requires medical surveillance for employees exposed at or above the permissible exposure limit or excursion limit and for employees required to wear negative-pressure respirators. The program includes a medical questionnaire, physical examination, exposure and smoking history, and work-related medical tests as required. Examinations are provided before assignment and annually thereafter while exposure continues. Medical clearance for respirator use is not the same as the full asbestos medical surveillance examination, although the evaluations may overlap.
Records and training
Exposure monitoring records are retained for 30 years. Medical records are retained for the duration of employment plus 30 years. Training is provided initially and annually, covers health effects, work practices, respirators, decontamination, and waste handling, and must be documented. Respirator fit test records, training records, and accreditation certificates should be kept current and available for inspection. Maryland accreditation and contractor licensing documents are separate from OSHA training documentation.
Worked example
An employee's personal sample is 0.08 f/cc, below the 0.1 f/cc permissible exposure limit, but the job requires a negative-pressure half-mask respirator. Medical surveillance is still required because the employee wears a negative-pressure respirator. The employer must also provide annual fit testing, respirator training, and asbestos training, and retain the exposure record for 30 years. Being below the PEL does not eliminate the respirator-related medical requirement.
Traps that cost marks
- Assuming exposure below the PEL eliminates all medical surveillance.
- Confusing respirator medical clearance with the full asbestos examination.
- Retaining exposure records for only a few years.
- Treating Maryland accreditation as a substitute for annual OSHA training.