OSHA Medical Surveillance & Monitoring | ICA Colorado Injury Care AssociatesOccupational Medicine Return to Home Page Book Appointment Book
Clinician and patient at an Injury Care Associates clinic in the Denver metro

Occupational Medicine · Medical Surveillance & Monitoring

Once an exposure crosses the line, the standard has already written the exam. We run it.

Silica, lead, asbestos, noise, respirators, HAZWOPER. Each OSHA standard spells out who gets examined, what the exam includes, and how often it repeats. ICA builds the protocol from the standard, performs the exams and reads the monitoring between them, and sends you the written opinion your file needs.

Built to the standardExam components come from the regulation, not a generic physical.
Physician written opinionThe document OSHA asks you to keep, in the form it asks for.
Protocol in writingWhich exams each role needs and how often the standard repeats them, so your calendar has the dates.
Records held 30 yearsRetained for the period the access-to-records rule requires.

What it is

A physical is about the person. Surveillance is about the exposure.

A pre-placement physical asks whether someone can do the job. Medical surveillance asks a different question, over and over: is this job starting to affect them? It is triggered by what an employee is exposed to, not by when they were hired, and the standard that governs the exposure sets the exam, the cycle and the paperwork.

Monitoring is the part that happens between exams: blood lead and ZPP every six months, an annual audiogram compared against a baseline, urine cadmium. A single result can shorten the cycle or trigger medical removal, so someone has to be reading them as they come in.

We do both from one chart: the same clinic performs the exam, reads each result against the baseline, and signs the written opinion.

What triggers a program

  • Exposure at or above an action levelYour air sampling or exposure assessment puts a role over the threshold the standard names, usually for 30 or more days a year.
  • Required respirator useAnyone who must wear a respirator needs a medical evaluation first; under silica and asbestos, 30 days of required use starts surveillance.
  • A hazardous-waste or emergency-response roleHAZWOPER crews and designated responders are examined on assignment, on a cycle, and at termination.
  • A contract or insurer asks for itGeneral contractors and facility owners increasingly want proof of surveillance before a crew is badged on site.

Not sure whether a role is over the line? Bring us your exposure data and we will tell you which standards apply before any exam is scheduled.

By exposure

What each standard asks for

Summaries of the federal requirement, so you know what you are signing up for. Your exposure levels, state rules and contract terms can add to this — confirming that is the first thing we do together.

29 CFR 1926.1153 · 1910.1053

Respirable crystalline silica

Who is covered: Employees required to wear a respirator for 30 or more days a year because of silica exposure.

Concrete cutting, drilling, demolition, masonry and countertop fabrication are the usual sources. The standard requires a chest X-ray read by a NIOSH-certified B Reader and spirometry by a certified technician. We perform the spirometry, coordinate the imaging at a partner facility, and read the B Reader report into the exam.

Exam or testCycle
Initial examWithin 30 days
Periodic examEvery 3 yrs
Chest X-ray, referred out, B Reader readEach exam
SpirometryEach exam
TB testInitial only

Specialist referral details and most findings go to the employee; the employer opinion covers respirator limitations only unless the employee authorizes more.

How it runs

From your exposure data to a protocol you can run your calendar on

  1. 1

    First call

    Tell us what your people are exposed to

    Your exposure assessment, air sampling results, or simply the tasks and materials involved. If you have not sampled yet, we can tell you which standards are likely in play and what to measure.

  2. 2

    Next

    We write the protocol

    For each covered role: the standard that applies, the exam components it requires, the monitoring between exams, and the cycle. You see it in writing before anyone is examined.

  3. 3

    Setup

    Baselines first

    Everyone currently exposed gets an initial exam. Noise baselines are scheduled after a quiet period; silica and asbestos files start with spirometry and the imaging referral the standard requires.

  4. 4

    Ongoing

    You send people when they are due

    Six-month lead draws, annual audiograms, three-year silica exams: the protocol tells your coordinator what repeats and when. Send the employee in, and the exam is read against everything already in the chart.

  5. 5

    Every result

    Monitoring is read, not filed

    A provider compares each result against the baseline and the standard’s thresholds. If a result shortens the cycle or requires removal, you hear from us with the written determination as soon as it is made.

  6. 6

    Year round

    Records and written opinions stay current

    Each exam produces the physician’s written opinion for your file. The full medical record stays with us for the retention period, and comes out when an auditor, an employee or OSHA asks for it.

Monitoring

The results between exams are where the program earns its keep

Most surveillance standards do not wait for the next exam. A blood lead level, a threshold shift on an audiogram, or a change in pulmonary function can change the cycle immediately, and in some cases the employee’s assignment.

Every result that comes back to ICA is read by a provider against the employee’s baseline and the standard’s thresholds, not just filed. When something moves, you hear from us as soon as the provider has made the determination.

  • Biological monitoringBlood lead and ZPP, urine and blood cadmium, CBC for benzene. Drawn on the cycle and compared against the action thresholds in the standard.
  • Audiometric comparisonEvery annual read against the baseline. Standard threshold shifts confirmed by retest, then reported with the recordability question answered.
  • Pulmonary function trendsSpirometry tracked over years for silica, asbestos and fume exposures, so a decline shows up before it becomes a diagnosis.
  • Medical removal and returnWhen a level crosses the removal threshold we document it, advise on reassignment, and set the retest schedule that clears the employee to return.
  • Cycle changes flagged for youWhen a result moves someone from six-month to two-month draws, the written determination says so and names the new interval, so your calendar changes with it.

The written opinion

What lands in your file, and what does not

Surveillance standards are specific about this. The employer gets a physician’s written opinion limited to the exposure in question. Everything else the exam turns up goes to the employee and stays in the medical record.

You receive

  • The physician’s written opinion for each exam, dated, stating the exam met the standard
  • Any limitation on the employee’s exposure or on respirator use
  • Medical removal determinations and return-to-exposure clearances
  • Standard threshold shift notices with the recordability question addressed
  • A roster of who is current, on request

Stays in the medical record

  • Diagnoses and medical conditions not related to the exposure
  • Imaging reports, lab values and spirometry detail beyond what the opinion requires
  • Specialist referral information, unless the employee authorizes release
  • The full medical record, retained for the period the access-to-records rule sets

Recordkeeping

How long each record has to exist

Surveillance records outlive the job, the clinic contract and often the company. We retain them on our side for the full period and produce them when an employee, an auditor or OSHA asks.

30 yrs

Medical records

Duration of employment plus 30 years for employees with more than one year of service.

30 yrs

Exposure records

Air sampling, biological monitoring and material safety data tied to an exposure.

Employment

Audiometric test records

Kept for the duration of the employee’s employment under the noise standard.

2 yrs

Noise exposure measurements

The sampling that established who is in the hearing conservation program.

Common questions

How do we know whether surveillance is required at all?

It turns on exposure, not job title. Each standard names an action level and, usually, a 30-days-per-year threshold. If you have air sampling data we can read it against those thresholds; if you do not, we can tell you which tasks commonly cross them and what to measure first.

Can you do the silica exam, including the B Reader chest X-ray?

Yes. The silica standard requires chest imaging interpreted by a NIOSH-certified B Reader and spirometry by a certified technician. We perform the spirometry in the clinic, order the imaging at a partner facility, follow up on the report and read it into the exam. You do not need to arrange the imaging yourself; we do not perform it on site.

What exactly do we get after an exam?

The physician’s written opinion the standard describes: the date, a statement that the exam met the requirements, and any limitation on exposure or respirator use. Clinical findings go to the employee. This is deliberate and it is how the standards are written.

What happens if a blood lead level comes back high?

We notify you with the written determination as soon as the provider makes it. Over 40 µg/dL, draws move to every two months and an annual exam is added. At the removal threshold for your industry the employee has to come off exposure with medical removal protection, and the determination names the retest that clears them to return.

Do audiogram shifts have to go on the OSHA 300 log?

Sometimes. A standard threshold shift that meets the recording criteria is recordable. We confirm the shift by retest, tell you whether the criteria are met, and leave the recording decision with you.

Who keeps the records?

We retain the full medical record for the period the access-to-records rule requires, which for most surveillance is 30 years past employment. You keep the written opinions and your exposure data. Either side can produce them when an employee, an auditor or OSHA asks.

Can monitoring happen at our site?

Hearing tests, respirator evaluations and fit testing can run at your location under our on-site plans; which other components can depends on the exam. Imaging is always referred out, and the report comes back to us. Worth discussing when pulling a crew off the floor is the real cost.

Can this run alongside our other ICA services?

Yes. Surveillance sits inside your employee health program with physicals and testing, on the same account and the same contact. If we also treat your injuries, the surveillance baselines are in the same chart.

What does it cost?

It depends on the standards involved and headcount. Your coordinator quotes per-component rates against the written protocol so you can see the annual cost per covered employee before anything starts.

Next step

Send us your exposure data. We will send back the protocol.

A coordinator and a provider will review which standards apply to your roles and come back with the exam components, the cycle, and what it costs to run. If no surveillance is required, we will tell you that too.

Set up a surveillance program

Surveillance can run as one part of an employee health program, alongside physicals and testing, on the same account.