Medical surveillance is the program of medical exams, tests and written medical opinions that specific US federal OSHA standards require employers to make available to workers exposed to particular hazards, such as respirable crystalline silica or lead. Each standard sets its own trigger, schedule and test content, as the silica and lead examples below show. OSHA notes that its medical surveillance requirements are “generally clinically focused (e.g., medical and work histories, physical assessment, biological testing).”
Medical screening vs medical surveillance
OSHA’s Medical Screening and Surveillance page says the two terms are often used interchangeably but are distinct:
- Medical screening has a clinical focus: early diagnosis and treatment of the individual. It is “only one component of a comprehensive medical surveillance program.”
- Medical surveillance has a prevention focus: detecting trends and eliminating their underlying causes, such as hazards or exposures.
What a standard requires: the silica example
The general industry silica standard, 29 CFR 1910.1053(i), shows the usual building blocks:
- Who is covered. The employer must make medical surveillance available to each employee exposed at or above the action level for 30 or more days per year, at no cost to the employee and at a reasonable time and place.
- Who performs it. A physician or other licensed health care professional (PLHCP): someone whose license, registration or certification allows them to provide the required services.
- Initial exam. A baseline exam within 30 days after initial assignment, unless a qualifying exam was done in the last three years. It includes a medical and work history, a physical exam, a chest X-ray read by a NIOSH-certified B Reader, a pulmonary function test (see spirometry surveillance) and testing for latent tuberculosis infection.
- Periodic exams. At least every three years, or more often if the PLHCP recommends.
- Reporting. The worker receives a written medical report within 30 days of each exam. The employer obtains a written medical opinion within 30 days that contains only the exam date, a statement that the exam met the standard, and any recommended limits on respirator use. Limits on silica exposure and a specialist referral are added only with the worker’s written authorization.
- Records. The employer must keep an accurate record for each worker covered and maintain medical records under 29 CFR 1910.1020 (see OSHA employee medical records).
Other standards differ in the detail. The lead standard, 1910.1025(j) covers workers exposed at or above the action level for more than 30 days per year, requires exams by or under the supervision of a licensed physician, and adds blood lead and zinc protoporphyrin sampling at least every 6 months.
Medical surveillance vs health surveillance
In Great Britain the umbrella term is health surveillance. HSE uses medical surveillance for a narrower case: exams by an HSE appointed doctor, which the law requires for certain hazards such as asbestos, lead and ionizing radiation.
MyC keeps one record per worker, with surveillance by exposure group, fitness-to-work and decades of history, in an occupational health EHR.
Related terms
- Health surveillance: Health surveillance is a program of repeated health assessments for workers still exposed to a hazard after controls, to identify ill health caused by work.
- Spirometry surveillance: Spirometry surveillance is the repeated lung function testing of workers exposed to respiratory hazards, comparing results with each worker's own baseline.
- Employee medical record: Employee medical record, under OSHA 29 CFR 1910.1020, means a record of an employee's health status made or kept by a physician, nurse or health care staff.
- Similar exposure group (SEG): A similar exposure group (SEG) is a group of workers expected to share the same exposure profile, used to plan monitoring and read surveillance results.