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OSHA 1910.1001AppD

Asbestos medical questionnaires

1910 Subpart Z

34 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.1001AppD Part 1, who must be given the Initial Medical Questionnaire?

Yes — employers must obtain the Initial Medical Questionnaire for every new hire who will be covered by the asbestos medical surveillance program because they are exposed to asbestos above the permissible exposure limit. See the mandatory statement in 1910.1001 App D that the appendix contains the medical questionnaires that "must be administered to all employees who are exposed to asbestos above permissible exposure limit, and who will therefore be included in their employer's medical surveillance program."

Under 1910.1001AppD Part 2, which employees must be given the Periodical Medical Questionnaire?

The Periodical Medical Questionnaire must be administered to all employees who are provided periodic medical examinations under the asbestos medical surveillance provisions. The appendix states that Part 2 includes the abbreviated Periodical Medical Questionnaire and that it "must be administered to all employees who are provided periodic medical examinations under the medical surveillance provisions of the standard in this section." See 1910.1001 App D.

Under 1910.1001AppD, is the Appendix D questionnaire mandatory or optional?

It is mandatory — Appendix D contains the medical questionnaires that must be administered as part of the asbestos medical surveillance requirements. The appendix itself begins by saying this is a mandatory appendix and that the questionnaires "must be administered" to covered employees. See 1910.1001 App D.

Under 1910.1001AppD Part 1, does the Initial Medical Questionnaire ask whether an employee has previously worked with asbestos?

Yes — the Initial Medical Questionnaire explicitly asks whether the employee has ever worked with asbestos. The occupational history items include a direct question about past work "With asbestos?" as part of the job history section. See the occupational history items in 1910.1001 App D.

Under 1910.1001AppD Part 1, which types of occupational history does the form collect that are relevant to lung disease risk?

The form collects detailed occupational history relevant to lung disease risk — it asks about full‑time work lasting six months or more, work for a year or more in dusty jobs (including job/industry, total years worked, and exposure severity), exposure to gas or chemical fumes (job/industry, years, severity), and whether the employee worked in specific industries such as mines, quarries, foundries, pottery, cotton/flax/hemp mills, or with asbestos. These items appear in the occupational history section. See the occupational history questions in 1910.1001 App D.

Under 1910.1001AppD Part 1, does the Initial Medical Questionnaire collect demographic information and identifiers?

Yes — the Initial Medical Questionnaire collects demographic and identifying information such as name, clock number, present occupation, plant, address, telephone number, interviewer, date, date of birth, place of birth, sex, marital status, and race. These items are present at the start of the form. See the form fields listed in 1910.1001 App D.

Under 1910.1001AppD Part 1, what kinds of past medical conditions does the Initial Medical Questionnaire ask about?

The form asks whether the employee considers themselves in good health and requests information on defects of vision or hearing; it asks about a range of past medical conditions including epilepsy, rheumatic fever, kidney or bladder disease, diabetes, and jaundice, and also covers chest illnesses (bronchitis, pneumonia, hay fever, chronic bronchitis, emphysema, asthma), other chest operations or injuries, and heart trouble or high blood pressure. These questions are in the past medical history and chest illness sections. See the medical history and chest illness questions in 1910.1001 App D.

Under 1910.1001AppD Part 1, does the Initial Medical Questionnaire ask about chest X‑rays and their outcomes?

Yes — the questionnaire asks when the employee last had a chest X‑ray (year), where it was done (if known), and what the outcome was. These questions are included in the chest illness and medical history sections of the form. See the chest X‑ray questions in 1910.1001 App D.

Under 1910.1001AppD Part 1, does the Initial Medical Questionnaire collect family history of chronic lung disease?

Yes — the questionnaire asks whether either natural parent was ever told by a doctor that they had chronic lung conditions such as chronic bronchitis, emphysema, asthma, lung cancer, or other chest conditions, and requests the parent's current status, age if living, age at death, and cause of death. See the family history section in 1910.1001 App D.

Under 1910.1001AppD Part 1, how does the questionnaire evaluate cough, phlegm, and wheeze symptoms?

The form uses a stepwise symptom evaluation — it asks whether the employee usually has a cough and then follows with frequency, timing (morning, during day/night), duration (e.g., most days for 3 consecutive months), and years with the symptom; similarly it asks about phlegm (frequency, duration), episodes of increased cough and phlegm, wheeze (with colds, apart from colds, most days/nights), and breathlessness questions. These structured symptom sections are included to document respiratory symptoms relevant to asbestos surveillance. See the cough, phlegm, wheeze, and breathlessness sections in 1910.1001 App D.

Under 1910.1001AppD, does the form ask about past lung trouble before age 16?

Yes — the Initial Medical Questionnaire asks whether the employee had any lung trouble before the age of 16. That question appears in the chest illness section to help establish past respiratory history. See the relevant item in 1910.1001 App D.

Under 1910.1001AppD, are employers limited to using only the exact words and layout of Appendix D when conducting medical surveillance?

The appendix identifies the mandatory questionnaire content that "must be administered," but the text provided does not state whether employers may use an equivalent form or electronic version that captures the same information. The safe approach is to ensure any alternative form fully captures the required questions shown in 1910.1001 App D. If you need guidance on whether a different format is acceptable in your specific situation, consider consulting OSHA or a compliance specialist.

Under 1910.1001AppD and OSHA's 'Asbestos remediation protocols' letter, which OSHA asbestos standard typically applies to property remediation work that involves asbestos?

For many property remediation activities involving asbestos-containing building materials, OSHA indicates the construction asbestos standard often applies — even for companies not traditionally in the construction trade. The OSHA letter "Asbestos remediation protocols" explains that remediation activities that involve ACBM are typically covered by the construction standard [29 CFR 1926.1101] rather than the general industry standard [29 CFR 1910.1001], so employers doing remediation should confirm which standard applies to their work. See the interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14 and the medical questionnaire requirement in 1910.1001 App D.

Under 1910.1001AppD Part 1, does the Initial Medical Questionnaire request the interviewer’s name and the date of interview?

Yes — the top portion of the Initial Medical Questionnaire includes fields for the interviewer and the date, along with other identifiers (name, clock number, telephone, etc.). Those fields are part of the administrative section of the form. See the header fields in 1910.1001 App D.

Under 1910.1001AppD, does the Initial Medical Questionnaire record whether chest illnesses kept the employee off work?

Yes — the questionnaire asks whether the employee had chest illnesses in the past three years that kept them off work, indoors at home, or in bed, and then follows with related questions about phlegm production and number of such illnesses. This is part of the chest illness section. See the related items in 1910.1001 App D.

Under 1910.1001AppD Part 1, does the Initial Medical Questionnaire collect specific details about chronic bronchitis, emphysema, and asthma?

Yes — the form asks whether the employee has had chronic bronchitis, emphysema, or asthma; for each it asks follow‑up questions about current status (do you still have it?), whether it was confirmed by a doctor, and the age at onset. These items appear in the chronic respiratory disease section. See those disease questions in 1910.1001 App D.

Under 1910.1001AppD, does the Initial Medical Questionnaire include questions about heart trouble and high blood pressure?

Yes — the questionnaire asks whether a doctor has ever told the employee they had heart trouble and whether they have had treatment for heart trouble in the past 10 years; it also asks whether a doctor told the employee they had high blood pressure and about treatment for it in the past 10 years. These are included in the medical history portion of the form. See the heart and blood pressure items in 1910.1001 App D.

Under 1910.1001AppD Part 1, are there questions about specific past workplace industries (e.g., mine, foundry) that are relevant to asbestos exposure?

Yes — the occupational history includes checkboxes asking whether the employee has ever worked in a mine, quarry, foundry, pottery, or cotton/flax/hemp mill, and it also includes a specific item asking whether the employee has worked "With asbestos." These industry items help identify prior exposures relevant to asbestos surveillance. See the occupational history checklist in 1910.1001 App D.

Under 1910.1001AppD, what is the purpose of collecting the information about cough duration and frequency?

The purpose is to document respiratory symptoms that could indicate chronic or occupational lung disease — the questionnaire asks about cough frequency, whether it occurs in the morning or during the day, whether it lasts for periods such as 3 consecutive months, and how many years the symptom has been present, which helps clinicians and occupational health professionals assess potential work‑related respiratory issues. These symptom questions are part of the medical surveillance content in 1910.1001 App D.

Under 1910.1001AppD, who is the intended respondent for the Asbestos Medical Questionnaire?

The questionnaire is intended to be completed by the employee who is under medical surveillance for asbestos exposure. The form fields (name, clock number, occupation, plant, address, telephone, interviewer and date) and the instruction headings such as "PERIODIC MEDICAL QUESTIONNAIRE" show it is designed for employee self-reporting during an occupational medical interview as provided in 1910.1001AppD.

Under 1910.1001AppD, does the asbestos medical questionnaire ask about cigarette smoking?

Yes. The sample form includes detailed cigarette smoking questions and follow-ups (e.g., "Have you ever smoked cigarettes?", current smoking status, age started, age stopped, cigarettes per day, inhalation depth), so employers may collect comprehensive smoking history on the medical questionnaire in 1910.1001AppD.

Under 1910.1001AppD, does the questionnaire require asking about pipe and cigar smoking?

Yes. The appendix contains separate sections for pipe and cigar use that ask whether an employee ever smoked these products, ages of start/stop, amounts smoked, and whether the employee inhaled the smoke; these items are part of the sample form in 1910.1001AppD.

Under 1910.1001AppD, are questions about recent medical history and specific diagnoses included?

Yes. The sample form includes a Recent Medical History section that asks if the employee considers themselves in good health and asks yes/no about conditions such as epilepsy, rheumatic fever, kidney disease, bladder disease, diabetes, jaundice and cancer as part of the medical history in 1910.1001AppD.

Under 1910.1001AppD, does the questionnaire include questions about chest colds, chest illnesses, and phlegm?

Yes. The form specifically asks whether colds usually go to the chest, whether the employee had chest illnesses in the past year that kept them off work or in bed, whether they produced phlegm with those illnesses, and how many such illnesses lasted a week or more, as shown in 1910.1001AppD.

Under 1910.1001AppD, are respiratory system symptoms such as asthma, bronchitis, and shortness of breath asked about on the form?

Yes. The sample asks about a list of respiratory and related symptoms and conditions (asthma, bronchitis, hay fever, other allergies, pneumonia, tuberculosis, chest surgery, other lung problems, heart disease, frequent colds, chronic cough, shortness of breath, wheeze, and cough up phlegm) in 1910.1001AppD.

Under 1910.1001AppD, does the form collect occupational history and information about dusty jobs or exposure to gases and fumes?

Yes. The questionnaire includes an Occupational History section that asks if the employee worked full time for 6 months or more in the past year, whether they worked in a dusty job, the severity of dust and gas/chemical fume exposures, and the employee's job title—this is included in 1910.1001AppD.

Under 1910.1001AppD, does the sample periodic questionnaire require a signature and date from the employee?

Yes. The form includes a line for the employee's signature and date at the end of Part 1 and again after the respiratory section, indicating that the sample medical questionnaire anticipates the employee will sign and date the completed form in 1910.1001AppD.

Under 1910.1001AppD, is there space on the form to record the interviewer and the date of the interview?

Yes. The form contains fields labeled INTERVIEWER and DATE so the employer can record who conducted the medical interview and when it took place, as shown in 1910.1001AppD.

Under 1910.1001AppD, does the questionnaire provide "Does not apply" options for certain items?

Yes. The sample uses "Does not apply" checkboxes on multiple items (for example smoking and activity questions) so employees can indicate when a particular question is not applicable to them in 1910.1001AppD.

Under 1910.1001AppD, can the smoking questions capture inhalation depth and lifetime average use?

Yes. The form asks about inhalation depth (options from "Not at all" to "Deeply") and asks for the average number of cigarettes smoked per day over the entire time the employee smoked, allowing clinical assessment of exposure intensity as provided in 1910.1001AppD.

Under 1910.1001AppD, is tuberculosis specifically included among the medical history items the form asks about?

Yes. The Respiratory System section of the form lists Tuberculosis as one of the conditions to be answered (yes or no), so TB is explicitly asked about on the sample in 1910.1001AppD.

Under 1910.1001AppD, does the appendix itself set the timing intervals (for example, annual) for administering the periodic medical questionnaire?

No. Appendix D provides a sample "PERIODIC MEDICAL QUESTIONNAIRE" form but does not itself specify the exact intervals for medical surveillance; timing and frequency requirements are set by the main standard and implementing provisions of 1910.1001.

Under 1910.1001AppD, can employers rely on this form when employees have potential asbestos exposure from property remediation work?

Possibly—but scope matters. Appendix D is a sample form in the general industry asbestos standard; however, OSHA has advised that many property remediation activities involving asbestos-containing building materials are covered under the construction asbestos standard [29 CFR 1926.1101], not the general industry standard, so employers performing remediation should consult the construction standard as explained in the OSHA interpretation "Asbestos remediation protocols" (November 14, 2024) at https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14 and consider using the medical surveillance procedures required by the applicable standard.

Under 1910.1001AppD, is the form intended to identify respiratory symptoms that could trigger further medical evaluation?

Yes. The detailed respiratory and chest-illness questions (shortness of breath, chronic cough, production of phlegm, chest illnesses requiring time off) are intended to surface symptoms and medical history that would prompt follow-up clinical evaluation or further medical testing as part of asbestos medical surveillance described in 1910.1001AppD.