Medical surveillance program: build it by exposure group

A medical surveillance program is the set of exams, tests and written medical opinions an employer provides to workers exposed to specific workplace hazards, run on a schedule and recorded for each worker. In the US, specific OSHA standards require employers to make medical surveillance available to exposed workers, and each standard sets its own trigger, tests and timing, so a practical way to build a medical surveillance program is surveillance by exposure group: assess exposures, group workers who share them, map each group to the rules that apply, then schedule and track every worker individually.

This guide covers federal OSHA general industry standards. State Plans may have different or more stringent requirements, and Great Britain and the EU are covered separately below.

Step 1: start from the exposure assessment

For most OSHA chemical and noise standards, the trigger is an exposure level, so the program starts with knowing who is exposed to what, and how much. The triggers differ:

• Asbestos: at or above the permissible exposure limit (0.1 f/cc, 8-hour average) and/or the excursion limit (1 f/cc over 30 minutes) (1910.1001(c), (l)(1)).
• Lead: at or above the action level of 30 µg/m³ for more than 30 days per year (1910.1025(b), (j)(1)).
• Respirable crystalline silica: at or above the action level of 25 µg/m³ for 30 or more days per year (1910.1053(b), (i)(1)).
• Formaldehyde: at or above the action level of 0.5 ppm, or above the 2 ppm short-term limit (1910.1048(b), (c), (l)(1)).
• Noise: at or above an 8-hour average of 85 dBA (1910.95(c), (g)(1)).

Keep the measurements: each employee exposure record is kept for at least 30 years unless a specific standard says otherwise (1910.1020(d)(1)(ii)).

Step 2: group workers into similar exposure groups

A similar exposure group brings together workers expected to share an exposure profile, so monitoring and surveillance can be planned once per group. NIOSH’s Occupational Exposure Sampling Strategy Manual recommends measuring the “maximum risk employee” for each work operation and, where that worker cannot be picked with reasonable certainty, randomly sampling a group whose members have a similar expected exposure risk (sections 3.1.1 and 3.1.2). It warns that groups built from job title alone can misclassify workers (Technical Appendix I).

OSHA’s standards use the same logic. Under the formaldehyde standard, an employer that does not measure every potentially exposed worker must sample enough exposures in each job classification on each shift not to underestimate anyone’s exposure “within each exposure group”, and repeat initial monitoring after changes that may bring new or additional exposure (1910.1048(d)(2)). Silica allows sampling a representative fraction of workers doing the same tasks on the same shift in the same work area, and the sample must include those expected to have the highest exposure (1910.1053(d)(3)(i)).

Across sites, define each group by task, agent and controls, not by site or job title: grinder operators at two plants with the same process and controls can share a group, two welders with different ventilation may not. Groups plan the work; the legal duties attach to each exposed employee.

Step 3: map each group to the standard that triggers surveillance

OSHA’s list of standards with medical screening and surveillance provisions runs from asbestos and lead to benzene, cadmium and bloodborne pathogens. Construction has its own, such as 29 CFR 1926.1153 for silica (1910.1053(a)(1)(i)).

The lung function tests in the asbestos, silica and formaldehyde rows are a form of spirometry surveillance, read against earlier results. One worker can sit in several rows. For respirators, OSHA proposed in July 2025 to remove some medical evaluation requirements for filtering facepiece respirators and loose-fitting powered air-purifying respirators; it reopened comments in June 2026, and no final rule had been published as of early November 2026.

Step 4: set the provider, the information pack and the written opinion

Asbestos and lead exams are performed by or under the supervision of a licensed physician; silica exams and respirator evaluations by a physician or other licensed health care professional (PLHCP). Asbestos, lead and silica surveillance is provided at no cost to the employee and at a reasonable time and place.

The employer briefs the provider: silica, for example, requires the worker’s former, current and anticipated duties and exposure levels, protective equipment, and earlier employment-related exam information within the employer’s control (1910.1053(i)(4)). Build one pack per exposure group, plus each worker’s history.

What comes back to the employer is limited by design:

• Silica: only the exam date, a statement that the exam met the standard, and any limits on respirator use; more only with the worker’s written authorization (1910.1053(i)(6)).
• Asbestos and lead: the physician is instructed not to reveal findings or diagnoses unrelated to the exposure (1910.1001(l)(7)(ii); 1910.1025(j)(3)(v)(B)).
• Respirators: only limitations on respirator use, any need for follow-up, and a statement that the worker received a copy (1910.134(e)(6)).

The worker gets a copy too: within 30 days of receipt for asbestos, 15 days of receipt for formaldehyde, 30 days of each exam for silica. That outcome feeds fitness-to-work decisions. In MyC, the outcome, such as fitness-to-work, is shared with HR, HSE and managers, while the medical basis stays confidential.

Step 5: schedule and recall each worker, not each group

Groups set the requirements; due dates are individual. Lead sampling moves from every 6 months to every 2 months when a result reaches 40 µg/100 g, and back only after two consecutive results below that level (1910.1025(j)(2)(i)). Asbestos X-ray frequency depends on the worker’s age and years since first exposure.

Plan for exams no calendar predicts: lead exams on reported symptoms, respirator re-evaluations, formaldehyde exams after an emergency, the asbestos exam at the end of employment. Some rules spare a repeat: no asbestos exam is required if adequate records show one under the standard in the past year, though a pre-employment exam the employer required counts only if the employer paid for it (1910.1001(l)(5)). Either way, the earlier record has to be found.

A working recall process needs a due date per worker per requirement, an overdue list per site, and an owner for each overdue item. In MyC’s health surveillance software, surveillance is scheduled per worker from their exposure group, with due dates and expiry alerts, and medical leaders and safety teams spot overdue checks by site without seeing personal medical details.

Step 6: handle job changes, site moves and contractors

Under the OSHA records standard, “employee” includes a worker being assigned or transferred to work where there will be exposure (1910.1020(c)(4)), and the lead, asbestos and formaldehyde rules start surveillance before assignment. Treat every transfer as a change of exposure group: close requirements that no longer apply, open new ones, and make prior results available to the next examiner, within confidentiality rules. A site move should not restart the file: the silica three-year exception, the asbestos one-year rule and every baseline comparison depend on earlier results.

For contractors, decide before mobilization who runs surveillance, who keeps the records and what the host receives; the answer differs by jurisdiction (see contractor health records). In MyC, contractors and employees use the same health record system, fitness-to-work rules and reporting, and their health surveillance history follows them between sites.

Step 7: keep the records for decades

Under 29 CFR 1910.1020(d)(1), each employee medical record is kept for at least the duration of employment plus 30 years, unless a specific standard sets a different period. Asbestos and formaldehyde medical records follow the same period, and silica defers to 1910.1020. Two differ:

• Lead medical records: at least 40 years or the duration of employment plus 20 years, whichever is longer (1910.1025(n)(2)(iv)).
• Noise: audiometric test records for the duration of the worker’s employment, and noise exposure measurements for two years (1910.95(m)(3)).

An employer ceasing to do business transfers the records to the successor employer, which must keep them (1910.1020(h)(1)). See OSHA employee medical records and how long to keep occupational health records.

Great Britain and the EU are separate regimes

In Great Britain, the term is health surveillance. COSHH regulation 11, which extends to England, Wales and Scotland, requires suitable health surveillance where it is appropriate, including where an identifiable disease or adverse health effect may be related to the exposure, is reasonably likely under the conditions of the work, and can be detected by valid, low-risk techniques. For substances and processes in Schedule 6, medical surveillance runs under the supervision of a relevant doctor at intervals of not more than 12 months. The employer keeps a COSHH health record for at least 40 years from the last entry. When surveillance finds an effect of exposure, regulation 11(9)(e) requires a review of the health of any other employee who has been similarly exposed: the regulation itself thinks in exposure groups.

HSE asks employers to set up a scheme where the risk assessment shows it is necessary, know which workers could be exposed to each hazard, and plan for shift and remote workers (HSE). For certain hazards, including asbestos, lead and ionizing radiation, health surveillance includes medical surveillance by an HSE appointed doctor, with an exception for some lower-risk asbestos work (HSE overview). HSE separates the health record from the medical record, held in confidence by the occupational health professional (record keeping).

In the EU, the framework Directive 89/391/EEC, Article 14, leaves health surveillance to national law and practice, with each worker able to receive it at regular intervals if they wish. For carcinogens, mutagens and reprotoxic substances, Directive 2004/37/EC requires surveillance arrangements for workers whose risk assessment reveals a risk, so that each can undergo surveillance, if appropriate, before exposure and at regular intervals; if a worker shows an abnormality suspected to result from exposure, the doctor or authority may require similarly exposed workers to undergo surveillance (Article 14). Medical records are kept at least 40 years after exposure ends for carcinogens and mutagens, five years for reprotoxic substances (Article 15).

A checklist for multi-site programs

• An exposure assessment per site, repeated when processes or controls change.
• Similar exposure groups defined by task, agent and controls, reviewed when results spread.
• Due dates per worker, including event-driven exams and exit exams.
• Written opinions limited to what the standard allows, with worker copies on time.
• Transfers and contractor arrivals treated as triggers.
• Retention set by the strictest applicable rule, with a plan for site sales and closures.

In MyC’s health surveillance software, teams set requirements by substance, job and site, and exposure groups apply specific test and questionnaire templates. Exams and results stay in one record per worker across sites and rotations. See it for manufacturing and mining, or book a demo.

Questions

Who must be included in a medical surveillance program?

Under federal OSHA, each standard sets its own trigger, usually an exposure level and, for lead and silica, a number of days per year. Workers required to use a respirator currently need a medical evaluation under 1910.134 before fit testing or use, whatever the substance.

How often are medical surveillance exams required?

It depends on the standard: annually for asbestos, at least every three years for silica, blood lead at least every 6 months for lead, and an annual audiogram for noise. Results and events can shorten the interval.

Can the employer see the exam results?

Not in full, and each standard sets what the employer’s written opinion contains. For silica, it is the exam date, a statement that the exam met the standard and any limits on respirator use, unless the worker authorizes more in writing. For respirators, it is limits on respirator use, any need for follow-up and a statement that the worker received a copy. The asbestos, lead and formaldehyde standards keep out findings and diagnoses unrelated to the exposure.

Sources

1. Medical Screening and Surveillance: Overview (OSHA)
2. Medical Screening and Surveillance: Standards (OSHA)
3. 29 CFR 1910.1001: Asbestos (OSHA)
4. 29 CFR 1910.1025: Lead (OSHA)
5. 29 CFR 1910.1053: Respirable crystalline silica (OSHA)
6. 29 CFR 1910.1048: Formaldehyde (OSHA)
7. 29 CFR 1910.134: Respiratory protection (OSHA)
8. 29 CFR 1910.95: Occupational noise exposure (OSHA)
9. 29 CFR 1910.1020: Access to employee exposure and medical records (OSHA)
10. DHEW (NIOSH) Publication 77-173: Occupational exposure sampling strategy manual (NIOSH)
11. Control of Substances Hazardous to Health Regulations 2002, regulation 11 (legislation.gov.uk)
12. Setting up a health surveillance scheme (HSE)
13. Health surveillance: overview (HSE)
14. Health surveillance: record keeping (HSE)
15. Council Directive 89/391/EEC on safety and health of workers at work (EUR-Lex)
16. Directive 2004/37/EC on carcinogens, mutagens or reprotoxic substances at work, consolidated text (EUR-Lex)
17. Proposed rule: Amending the medical evaluation requirements in the respiratory protection standard (Federal Register, July 1, 2025)
18. Additional comment period on the respirator medical evaluation proposal (Federal Register, June 3, 2026)

Written by Lisa Bardet, VP Marketing at MyC. Every factual claim in this article is checked against primary sources, such as regulations, regulators and peer-reviewed studies, in three passes before publication, and the sources are listed above.

This article is general information for employers and occupational health teams. It is not legal or medical advice for a specific situation.