Hazardous Material (HAZMAT) Medical Surveillance

Hazardous materials are generally defined as substances which represent a potential health risk to those who may be exposed to them. A hazardous material may be chemical or biological in nature. Some examples of hazardous materials include infectious waste, benzene, mercury, and radioactive materials. There are numerous regulations regarding the containment, handling, transport, and disposal of hazardous materials. These regulations typically mandate a surveillance program for employees who work with hazardous materials.

Businesses with employees that work around hazardous materials must investigate the workplace and screen workers for symptoms of potential exposure. Employers are required to identify all hazardous materials in the workplace and through industrial hygiene testing determine levels of exposure associated with specific job tasks and work areas.

When a measured exposure level for a hazardous material exceeds a substance-specific OSHA or Cal-OSHA standard — referred to as the permissible exposure limit (PEL) for that hazardous material — then training and personal protective equipment (PPE) are required for the employees working in that identified area. Employers must inform their employees about the presence of hazardous materials and train them on the appropriate safeguards intended to minimize exposure including the use of proper work procedures and the correct use of PPE.

Annual medical surveillance examinations are required for these employees intended to identify changes in health that would indicate excessive exposure to the hazardous material in question. Exposure may occur through either direct or indirect contact. Direct contact in the work area could include inhalation, ingestion, or skin contact. Similar routes of entry occur with indirect contact from contaminated tools, surfaces, or clothing as contrasted with direct exposure from source.

Baseline and annual exams are also used to identify which employees have personal medical diagnoses that limit their ability to safely work while wearing PPE, particularly where respirator use is required, or the work is very exertional or performed in extreme environmental heat or cold. These exams can also identify pre-existing personal illnesses that materially increase the risk of illness when exposed to hazardous substances. An example would be the employee who has chronic hepatitis being advised against work with chemicals that are known to cause liver damage and could predictably and precariously accelerate his/her pre-existing hepatitis.


  • Health History
  • Work History with emphasis on prior exposure or illness from hazardous materials
  • Physical exam
  • Blood and urine levels to monitor organ function or heavy metal exposure
  • Hearing testing
  • Spirometry
  • Chest X-Rays
  • EKG
  • Hepatitis B antibody testing and vaccination

Employers are asked to provide

  • Employee’s job description
  • Past or anticipated exposure levels
  • Description of PPE currently in use
  • Prior medical evaluation records if available


Post-offer exams are meant to identify personal health problems that are likely to preclude the safe use of PPE or increase the risk of illness following exposure to hazardous materials.

Baseline Examinations

Per OSHA Standard 1910.120 titled Hazardous Waste Operations and Emergency Responses (HAZWOPER): baseline examinations are required for HAZMAT team members and hazardous materials specialists.

Yearly Examinations

1910.120 (f): Annual medical examinations are required fo:

  1. employees working around hazardous materials where the exposure exceeds the permissible exposure limit (PEL) for that substance for 30 or more days per year
  2. HAZMAT teams members who are tasked with responding to actual or potential leaks or spills of hazardous materials
  3. employees that may have reasonably suffered actual or potential ill effects from hazardous materials exposure

Exposure Examinations

Emergency Response Team (ERT) members who exhibit signs or symptoms that may have been the result of exposure to hazardous substances should seek an immediate medical evaluation.

Exit Exams

A final exam is required at termination of employment if the employee has not had an examination within the last six months. Similarly an exit exam is required if an employee is reassigned to a position that no longer requires surveillance. Final exams are in part required to prevent employers from transferring symptomatic employees without determining whether the cause of illness is due to hazardous material exposure.

Specific Categories of Hazardous Substances

  • Toxic or Highly Toxic: produces death based on OSHA criteria for dose and duration of exposure.
  • Carcinogen: increases risk of a specific cancer as a result of exposure.
  • Irritant: produces reversible inflammation as a result of direct contact.
  • Corrosive: as a result of direct contact destroys or causes permanent changes to body tissues.
  • Sensitizer: causes allergic-type reactions in a substantial number of exposed individuals.
  • Target Organ Effects: organ-specific dysfunction or damage – most commonly the lungs, nervous system, liver, kidney, or bone marrow.