Medical Surveillance for Hazardous Waste Workers

The OSHA requirements for medical surveillance for hazardous waste workers are found at 29 CFR Part 1910.120 (f) Medical Surveillance.

• Individuals covered under this requirement are:
• Members of HAZMAT (Hazardous Materials) teams
• Members of Fire Brigades
• Employees engaged in emergency response operations who have potential for exposure to hazardous substances or health hazards above the PEL for a specified period of time
• Employees engaged in various hazardous waste occupations

Medical surveillance examinations for employees covered under this standard must be provided at no cost to the employee and conducted:

• Prior to assignment
• At least once every 12 months unless the examining physician believes that a longer interval is appropriate given the exposure scenario. However, no interval between examinations shall exceed 24 months.
• At termination of employment or reassignment to a non-covered position if the employee has not had an examination within the last six months.
• As soon as possible after an employee has developed signs or symptoms indicating possible overexposure to a hazardous substance
• On the recommendation of the examining physician
• As required by specific Standards for hazardous materials

Medical surveillance is the cornerstone of protection of hazardous waste workers. Prior exposure histories and evidence of previous effects from chemical exposures must be considered in recommending any limitations that should be placed on the employee. The physical examination must include an evaluation of the workers ability to wear respiratory protection and other personal protective equipment under the physical conditions of wear and exposure.

The actual content of the medical surveillance examination and consultation shall be determined by the attending physician but should include:

• History

1. Prior occupational and recreational chemical and physical agent exposures
2. Effects of wearing personal protective equipment
3. Complete past and current medical history and review of symptoms

• Physical evaluation

1. Should focus upon detection of cardiopulmonary, hepatic, renal, dermal, neurological and musculoskeletal disease and abnormalities
2. Should assess any factors that may potentially affect a worker's ability to wear a respirator or other protective clothing
3. Should address agility and strength as appropriate to the potential physical demands of the position

• There is no compelling evidence to suggest that exhaustive diagnostic tests are indicated unless specific chemical exposures are expected or known. Diagnostic tests should be targeted to the specific exposure in accordance with the accepted principles of medical surveillance. Exercise electrocardiography and chest x-rays should be performed only for specific indications.

General diagnostic tests recommended for hazardous materials workers include:

1. Vision screening
2. Spirometry
3. Audiometry
4. Liver function tests
5. Complete blood count
6. Urinalysis

The examining physician shall provide a copy of a written opinion to the employer stating any detected medical conditions that would place the employee at increased risk of material impairment of the employee's health from performing the duties of a hazardous waste worker. This opinion shall include any restrictions or limitations recommended for the employee as to the wearing of personal protective equipment or performance of HAZMAT duties. The employer must provide a copy of this written opinion to the employee. The results of the medical examination and tests shall be made available if requested by the employee.