Medical Surveillance: What Are the Basic Requirements?

Although the terms medical screening and medical surveillance are often used interchangeably, they are actually distinct concepts.

• Medical screening is only one component of a comprehensive medical surveillance program. The fundamental purpose of screening is early diagnosis and treatment of the individual and thus has a clinical focus.
• The fundamental purpose of surveillance is to detect and eliminate the underlying causes such as hazards or exposures of any discovered trends and thus has a prevention focus.

Both can contribute significantly to the success of worksite health and safety programs.

OSHA medical surveillance requirements are generally clinically focused (medical and work histories, physical assessment, biological testing), with information obtained from the clinical processes used in the monitoring and analysis elements of medical surveillance.

Medical screening and surveillance are addressed in specific standards for the general industry:

• 1910.120, Hazardous waste operations and emergency response (HAWOPER)
• 1910.134, Respiratory protection
• Subpart Z, Toxic Substances and Hazardous Substances, 1910.1001-1018, 1025-1052, and 1450

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Who Needs to Be Involved?

• Medical surveillance programs should be designed by an experienced occupational health physician or other qualified occupational health consultant in conjunction with the site safety officer.
• The director of the site medical surveillance program should preferably be a physician who is board-certified in occupational medicine or a medical doctor who has had extensive experience managing occupational health services. If an occupational health physician is not available, the site medical program may be managed, and examinations performed, by a local physician with assistance from an occupational medicine consultant.
• Medical surveillance functions may be performed by a qualified registered nurse, preferably an occupational health nurse, under the direction of a suitably qualified physician who has overall responsibility for the program.
• Tests must be performed by a reputable laboratory with a proven track record.

Surveillance Schedule

Generally, medical surveillance programs establish the following examination and testing schedule:

• Before being assigned to a job that could expose the employee to the hazard identified in the relevant OSHA standard (usually a preemployment physical)
• Periodically thereafter (often annually, but may be more often depending on risk)
• When an employee reports symptoms or an exposure above the permissible exposure level
• When the examining doctor determines follow-up or additional examinations are required
• When employment is terminated or an employee is transferred to a job not covered by a medical surveillance requirement

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