What OSHA medical surveillance requires
Medical surveillance is ongoing medical monitoring of employees exposed to specific workplace hazards, required so health effects are caught early. It is triggered by exposure crossing an action level, not by job title, and the duty to schedule exams, act on results, and retain records sits with the employer, not the clinic.
- Triggered by measured exposure crossing an action level
- Each standard sets the required exams, frequency, and provider reporting
- Most records kept for employment plus 30 years (29 CFR 1910.1020)
- Compliance and recordkeeping are the employer's legal burden
Which OSHA standards require it
Dozens of standards mandate surveillance. The ones employers encounter most often are below — select any standard for the exposure explained in full detail.
- Respiratory Protection (29 CFR 1910.134)Medical evaluation before an employee wears any respirator, and re-evaluation when health or working conditions change.
- Occupational Noise (29 CFR 1910.95)Baseline and annual audiograms once noise reaches the 85 dBA action level, with follow-up on any standard threshold shift.
- Lead (29 CFR 1910.1025 & 1926.62)Blood-lead and ZPP monitoring with periodic medical exams; construction thresholds differ from general industry.
- Respirable Crystalline Silica (29 CFR 1910.1053 & 1926.1153)Exams including chest X-ray and spirometry for workers above the action level 30 or more days a year.
- Asbestos (29 CFR 1910.1001 & 1926.1101)Periodic medical examinations and long-term recordkeeping for exposed workers.
- Bloodborne Pathogens (29 CFR 1910.1030)Hepatitis B vaccination and confidential post-exposure evaluation and follow-up.
- HAZWOPER (29 CFR 1910.120)Baseline, annual, and exit examinations for hazardous-waste and emergency-response workers.
- Substance-Specific StandardsBenzene, cadmium, formaldehyde, hexavalent chromium, methylene chloride, and more — each with its own exam triggers and frequency.
Bespoke program design, implementation, and management
Every workforce and exposure profile is different, so we build your program around your operations instead of forcing you into a template — and we run it from design through day-to-day management.
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Bespoke program design
We map your job tasks, exposures, and sites to the exact standards that apply, then design the exam schedule, triggers, and provider plan around them.
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Implementation
We stand the program up: enroll your workforce, line up providers across every location, and run the first surveillance cycle end to end.
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Ongoing management
We track who is due, schedule and chase each exam to completion, record results and fitness determinations, and keep the program current as your workforce changes.
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Turnkey for you
The result is a turnkey program: one accountable partner runs the entire surveillance lifecycle while your team stays focused on the work.
We directly manage cost, turnaround, impact, and legal defensibility
Occu-Med does more than book appointments. We directly manage the four things that decide whether a surveillance program actually works for you:
Cost
We manage program cost head-on: the right exam with the right provider, no duplicate or unnecessary testing, and pricing we hold our network to.
Turnaround time
We drive scheduling and results to completion on a defined timeline, so fitness decisions are never waiting on paperwork.
Operational impact
We coordinate around your shifts and sites so surveillance happens with the least possible disruption to production and to your people.
Legal defensibility
Every determination and notice is documented to the governing standard and retained for the full required period, so your records stand up to an OSHA audit or a challenge.
California employers: Cal/OSHA goes further
If you operate in California, federal compliance is not the finish line. Cal/OSHA's Title 8 standards can be stricter than their federal counterparts, and some have no federal equivalent, so an employer fully compliant under federal OSHA can still fall short in California. Occu-Med is headquartered in Fresno and builds California programs to the state requirement, not the federal floor.
- Cal/OSHA Title 8 can exceed federal OSHA requirements
- California-only programs apply, including Aerosol Transmissible Diseases (8 CCR 5199)
- Occu-Med is Fresno-based and coordinates California programs daily
Wherever your people work, we coordinate the exams
Your OSHA obligations follow your employees, even when the work doesn't stay in the United States. If you are a US employer, workers posted or traveling overseas can still fall under OSHA medical-surveillance requirements, and the duty to schedule exams, act on results, and keep records stays with you.
Occu-Med facilitates these evaluations globally. We coordinate the required exams in the countries where your people are, then bring the results back into one consistent, audit-ready program. We don't position this as a foreign OSHA-equivalent — we fulfill your US OSHA obligations wherever your workforce happens to be.
- US employers remain responsible for OSHA surveillance even for employees working abroad
- We arrange the required exams in-country, near where your people are based
- Results and records flow back into one program, in the same audit-ready format
Who needs a program
If your workforce is exposed to regulated substances or conditions, you likely have surveillance obligations. We run programs across:
- Construction & remediationLead, silica, asbestos, and HAZWOPER surveillance across demolition, abatement, and cleanup sites.
- Manufacturing & heavy industryNoise, metals, and chemical-exposure programs on the production floor.
- Healthcare & laboratoriesBloodborne pathogens, aerosol transmissible diseases, and formaldehyde surveillance.
- Oil, gas & energyRespirator, noise, and chemical surveillance for field and plant operations.
- Public agencies & utilitiesRespirator and hearing-conservation programs for crews and first responders.
Related surveillance programs we also administer
OSHA is not the only framework that mandates medical surveillance. We administer these related programs as well — each is covered in depth on its own page.
Frequently Asked Questions
What is OSHA medical surveillance?
OSHA medical surveillance is the ongoing medical monitoring of employees exposed to specific workplace hazards, required by individual OSHA standards so exposure-related health effects are detected early. A program defines which exams are required, how often they repeat, what the provider must report to the employer, and how long records are kept. It is monitoring tied to exposure, not a one-time pre-hire physical.
When is a medical surveillance program required, and what triggers it?
A program is required when employees are exposed to a regulated hazard at or above the action level in the applicable standard. Examples: any employee who must wear a respirator needs a medical evaluation under 29 CFR 1910.134; occupational noise at the 85 dBA action level triggers audiometric testing under 1910.95; respirable silica above the action level 30 or more days a year triggers exams under 1910.1053. The trigger is measured exposure, not job title.
What tests are included in a surveillance program?
It depends on the hazard. Noise programs use baseline and annual audiograms; respirator programs use a medical evaluation questionnaire and, when indicated, an exam; lead programs use periodic blood-lead testing; silica and asbestos programs use exams that can include chest imaging and lung-function (spirometry) testing. Each OSHA standard specifies its own required tests and schedule, which is what Occu-Med maps for your specific exposures.
How long must medical surveillance records be kept?
Most employee exposure and medical records must be kept for the duration of employment plus 30 years under 29 CFR 1910.1020. A few programs use different retention periods, but the long horizon is why durable, audit-ready recordkeeping is a core part of every program Occu-Med runs, and why scattered records across multiple clinics become a liability at inspection time.
Whose responsibility is OSHA medical surveillance compliance?
The employer. The employer is legally responsible for ensuring required exams happen on schedule, that results are acted on, and that records are retained for the full period. The clinic performs the exam, but the compliance and recordkeeping obligation stays with the employer, which is exactly the burden Occu-Med takes on as your program coordinator.
Does Occu-Med perform the medical exams?
Occu-Med coordinates the program and directs it around the clinics and licensed providers in our nationwide network, who perform the exams. We manage who needs testing, scheduling, results, fitness determinations, and recordkeeping, so you have one accountable partner for the entire program rather than juggling individual clinic relationships.
Can Occu-Med manage surveillance across multiple states and sites?
Yes. Occu-Med runs one consistent program across every location through a national provider network, so a multi-site employer gets the same protocols, quality, and recordkeeping everywhere, instead of managing a separate clinic relationship at each site and reconciling records by hand.
How is Cal/OSHA medical surveillance different from federal OSHA?
Cal/OSHA enforces Title 8 standards that can be stricter than federal OSHA, and it has programs with no federal equivalent, such as the Aerosol Transmissible Diseases standard (8 CCR 5199) covering tuberculosis screening in healthcare and other settings. An employer compliant under federal rules can still fall short in California, so California programs must be built to the state requirement. As a Fresno-based coordinator, Occu-Med works in both frameworks daily.
Can Occu-Med design a custom medical surveillance program for our operations?
Yes. Occu-Med designs a bespoke program around your specific job tasks, exposures, and sites — mapping each to the OSHA standards that apply — then implements it and manages it on an ongoing basis as a turnkey program.
Can Occu-Med manage OSHA medical surveillance for employees who work overseas?
Yes. US employers remain responsible for OSHA medical surveillance even for employees working abroad. Occu-Med facilitates the required evaluations globally, coordinating exams in-country and returning the results into one audit-ready program. This fulfills your US OSHA obligations and is not a foreign OSHA-equivalent.
Make your surveillance program someone else's full-time job
Tell us the hazards your workforce faces and where you operate. We'll map your OSHA and Cal/OSHA obligations and run the program end-to-end, so exams happen on schedule and your records are always inspection-ready.
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