Medical Surveillance Change to OSHA’s Silica Standard

Obligations and enforcement for medical surveillance within the OSHA silica standard changed on June 23, 2020. Employers in general industry and maritime operations must now provide medical surveillance for employees who will be exposed at or above the action level (AL) for 30 or more days a year starting on June 23. The AL for respirable silica is 25 μg/m³ over an 8-hour period. Previous regulations only required medical surveillance for workers exposed to the permissible exposure limit (PEL) of 50 μg/m³ over an 8-hour period for 30 or more days a year from June 23, 2018, through June 22, 2020.

Because of this change, you may find yourself in need of silica medical surveillance. Want to know more?

Medical surveillance within the silica standard means: a free medical exam within 30 days of initial assignment, unless the employee has had an exam that qualifies within the last 3 years, and one every 3 years from the last examination, unless the physician or other licensed health care provider (PLHCP) recommends a higher frequency.

• Initial exams must include:
  1. A medical work history that focuses on the employee’s past, present, and projected exposure to silica, dust, or other agents affecting the respiratory system, and a history of their respiratory problems.
  2. A physical exam by the PLHCP that focuses on the respiratory system.
  3. A chest x-ray interpreted by a certified reader.
  4. A spirometry test, also known as a pulmonary function test, administered by a NIOSH spirometry trained technician.
  5. Testing for latent tuberculosis infection.
  6. Respiratory protection fit testing.
  7. Any other test that the PLHCP deems medically necessary or appropriate.
• Periodic exams conducted every 3 years will include each of the tests within the initial exam except for latent tuberculosis testing.

Additionally, the PLHCP must provide the employer with a written medical opinion to the employer and a written medical report  for the employee, both within 30 days.

Additional and more in-depth requirements surrounding medical surveillance can be viewed in Appendix B to 29 CFR 1910.1053.