Medical surveillance is a planned program of medical exams, tests and health monitoring for workers exposed to specific workplace hazards, such as noise, lead, silica, asbestos or respirator use. Its purpose is to detect work-related health effects early, decide whether a worker can safely do the job, and check whether exposure controls are working.
Medical surveillance matters because many occupational diseases, such as hearing loss, lead poisoning and silicosis, develop slowly and without obvious symptoms until damage is serious. Several OSHA standards make medical surveillance mandatory, with specific triggers, exam contents, schedules and recordkeeping rules.
What Is Medical Surveillance?
Medical surveillance is related to, but different from, two other activities:
- Medical screening is testing individual workers to detect disease early, such as an audiogram or chest X-ray.
- Medical surveillance includes screening but also analyzes results over time and across groups to spot trends and weaknesses in controls.
- Exposure monitoring measures the hazard in the workplace, such as air sampling or noise dosimetry. Exposure monitoring often determines who must be in a medical surveillance program.
Medical surveillance supports, but never replaces, controlling the hazard at its source using the hierarchy of controls.
Which OSHA Standards Require Medical Surveillance?
Many OSHA health standards include medical surveillance requirements. Common examples include:
- Occupational noise, 29 CFR 1910.95: an audiometric testing program for employees exposed at or above an 8-hour time-weighted average of 85 dBA, with a baseline audiogram within 6 months of first exposure (or within 1 year when a mobile test van is used) and annual audiograms after that. See baseline audiogram.
- Respiratory protection, 29 CFR 1910.134(e): a medical evaluation to determine whether an employee can use a respirator before fit testing or first use.
- Respirable crystalline silica, 29 CFR 1910.1053 and 1926.1153: medical exams for employees required to wear a respirator under the standard for 30 or more days a year, with periodic exams at least every three years.
- Lead, 29 CFR 1910.1025 and 1926.62: blood lead and zinc protoporphyrin testing and medical exams for exposed employees, plus medical removal protection.
- Asbestos, 29 CFR 1910.1001: exams for employees exposed at or above the PEL or excursion limit for 30 or more days a year.
- Bloodborne pathogens, 29 CFR 1910.1030: hepatitis B vaccination offered to employees with occupational exposure, and post-exposure evaluation and follow-up after an exposure incident.
- HAZWOPER, 29 CFR 1910.120(f): medical surveillance for certain hazardous waste and emergency response workers.
- Other substance-specific standards: including benzene, cadmium, formaldehyde, methylene chloride and beryllium.
Each standard has its own triggers, exam contents and frequency, so always check the specific standard. OSHA's medical surveillance page links to the screening and surveillance requirements in each standard.
What a Medical Surveillance Exam Includes
Contents depend on the hazard, but programs typically include:
- A medical and work history, focused on exposures and symptoms.
- A physical exam targeted at the organs the hazard affects.
- Specific tests, such as audiograms, spirometry, chest X-rays, blood lead levels or tuberculosis testing.
- A written opinion from the physician or licensed health care professional (PLHCP) to the employer.
The employer generally receives a limited written opinion stating whether the worker has conditions that increase risk, any recommended limitations and confirmation that the worker was informed of the results. Under most standards, specific diagnoses unrelated to the exposure are not shared with the employer.
Who Pays and Medical Removal
OSHA standards that require medical surveillance generally require it to be provided at no cost to the employee, at a reasonable time and place.
Some standards also include medical removal protection. Under the general industry lead standard, an employee must be removed from exposure when a periodic and follow-up blood lead test is at or above 60 µg/100 g, or when the average of the last three tests is at or above 50 µg/100 g. The employee may return once two consecutive blood lead tests are at or below 40 µg/100 g. During removal, the employer must maintain the employee's earnings, seniority and benefits for up to 18 months. The construction lead standard and other standards, such as cadmium, have their own removal criteria.
Recordkeeping
Under 29 CFR 1910.1020, employee medical records must generally be kept for the duration of employment plus 30 years, and exposure records for at least 30 years. Employees and their designated representatives have a right to access their records. See our employee exposure and medical records guide. Medical records must be kept confidential and separate from personnel files.
How to Run a Medical Surveillance Program Step by Step
- Identify exposures. Use exposure monitoring and hazard assessments to determine which hazards are present and at what levels.
- Determine which standards apply. Match exposures to OSHA standards and note each trigger, exam content and frequency.
- Select a PLHCP. Choose a qualified occupational health provider and give them the information each standard requires, such as job descriptions and exposure data.
- Enroll workers. Schedule initial exams before or soon after assignment, as required.
- Track schedules. Set reminders for periodic exams, annual audiograms and follow-up tests.
- Act on results. Follow PLHCP recommendations, apply work restrictions or medical removal and investigate exposure controls when results show a problem.
- Keep records. Store results confidentially for the required retention period.
- Review trends. Look at group results to find control failures and improve the program.
Common Mistakes to Avoid
- Not knowing which workers have crossed a trigger level, such as 85 dBA or the silica 30-day threshold.
- Missing periodic exam dates for workers who change jobs or sites.
- Charging employees for exams or requiring them to attend on their own time.
- Keeping medical records in personnel files.
- Treating surveillance as a substitute for reducing exposures.
How SMS360 Helps
SMS360's Compliance Management module helps teams track recurring obligations such as periodic exams and audiograms, with reminders before they are due. Related training, such as respirator and hearing conservation training, can be recorded in Training Management, and program documents can be stored in the Document Library.
Frequently Asked Questions
Is medical surveillance required by OSHA?
Yes, for workers covered by specific standards, such as noise, respiratory protection, silica, lead, asbestos and bloodborne pathogens. Each standard sets its own trigger and requirements.
Who pays for medical surveillance?
The employer. OSHA standards that require medical surveillance generally require it at no cost to the employee and at a reasonable time and place.
How long must medical surveillance records be kept?
Generally for the duration of employment plus 30 years, under 29 CFR 1910.1020, unless a specific standard sets a different period.
Does the employer see an employee's full medical results?
Usually not. Under most standards the employer receives a limited written opinion from the PLHCP. Detailed medical information stays confidential.
