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OSHA 1910.1001AppH

Asbestos medical surveillance guidelines

Subpart Z

22 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.1001 App H, what is the main route(s) of entry for asbestos into the body?

Inhalation is the primary route of entry for asbestos; ingestion can also occur but is not the principal pathway for occupational disease. See Appendix H to 1910.1001 which identifies inhalation (and ingestion) as routes of entry, and review the 1910.1001 asbestos standard for controls to limit airborne exposure.

Under 1910.1001 App H, are there any known acute health effects from asbestos exposure?

No, there are no known acute effects associated with asbestos exposure; the adverse diseases are chronic and generally appear long after exposure. Appendix H states that disease associated with asbestos typically appears about 20 years after first exposure and that there are no known acute effects; see Appendix H to 1910.1001 and the 1910.1001 asbestos standard.

Under 1910.1001 App H, how long is the typical latency period before asbestos-related disease appears?

Most asbestos-related diseases generally appear about 20 years after first exposure, while mesothelioma can have a much longer latency (around 40 years). Appendix H explains that disease usually appears about 20 years after first exposure and notes mesothelioma's longer average latency of about 40 years; see Appendix H to 1910.1001.

Under 1910.1001 App H, how does cigarette smoking affect the risk of lung cancer for workers exposed to asbestos?

Smoking greatly increases the risk of lung cancer for workers exposed to asbestos compared with nonsmoking exposed workers, and quitting smoking reduces but does not eliminate that increased risk. Appendix H states epidemiological studies show the risk of lung cancer is greatly increased among asbestos-exposed workers who smoke and that smoking cessation will reduce but not return risk to that of a never‑smoker; see Appendix H to 1910.1001 and the 1910.1001 asbestos standard.

Under 1910.1001 App H, what are the common signs and symptoms that might suggest asbestos‑related disease?

Shortness of breath, chest pain, abdominal pain (for mesothelioma), persistent cough, fatigue, and general malaise can be signs of asbestos-related disease. Appendix H lists shortness of breath and chest or abdominal pain as mesothelioma symptoms and notes cough, fatigue, and vague sickness for asbestosis; chest X-rays may show pleural plaques, calcification, pleural fibrosis, or small irregular parenchymal opacities; see Appendix H to 1910.1001.

Under 1910.1001 App H, is mesothelioma considered fatal and how does its latency compare with lung cancer?

Yes, mesothelioma is described as a fatal disease and it generally has a much longer latency than lung cancer—about 40 years versus approximately 15–20 years for lung cancer. Appendix H explicitly states mesothelioma is fatal and notes its longer average latency; see Appendix H to 1910.1001.

Under 1910.1001 App H, what clinical features support a diagnosis of asbestosis?

A diagnosis of asbestosis is commonly based on a history of asbestos exposure, characteristic radiologic abnormalities (chest X‑ray), end‑inspiratory crackles (rales), and other clinical features of fibrosing lung disease. Appendix H describes these diagnostic elements and notes pleural plaques and thickening may be observed on chest X‑rays; see Appendix H to 1910.1001.

Under 1910.1001 App H, are there adequate screening tests to detect asbestos‑induced cancers early?

No, adequate screening tests to determine an employee’s potential for developing serious chronic diseases like cancer from asbestos exposure do not presently exist. Appendix H states that adequate screening tests for asbestos-induced cancer are not available, although chest X‑rays and pulmonary function tests may indicate overexposure; see Appendix H to 1910.1001.

Under 1910.1001 App H, when must an employer institute a medical surveillance program for asbestos?

An employer must institute medical surveillance for all employees who are or will be exposed to asbestos at or above the permissible exposure limit of 0.1 fiber per cubic centimeter of air. Appendix H states the employer is required to institute a medical surveillance program for employees exposed at or above the PEL (0.1 f/cc); see Appendix H to 1910.1001 and the 1910.1001 asbestos standard.

Under 1910.1001 App H, who must perform the medical examinations and tests in the surveillance program?

All examinations and procedures must be performed by or under the supervision of a licensed physician. Appendix H requires that medical exams and procedures be performed by or under the supervision of a licensed physician, at reasonable times and places, and at no cost to the employee; see Appendix H to 1910.1001 and 1910.1001.

Under 1910.1001 App H, what specific elements must be included in the routine medical examination for asbestos surveillance?

The routine examination must include a medical and work history focused on respiratory, cardiovascular, and digestive symptoms; completion of the respiratory disease questionnaire in [Appendix D]; a physical exam including a chest X‑ray and pulmonary function test measuring FVC and FEV1; and any other lab or tests the physician deems necessary. Appendix H lists these required elements and references the respiratory questionnaire in Appendix D; see Appendix H to 1910.1001 and 1910.1001.

Under 1910.1001 App H, how often must employers make prescribed medical tests available to covered employees?

Employers must make the prescribed medical tests available at least annually, more often if the physician recommends, and upon termination of employment. Appendix H requires annual availability, at the physician's recommendation more frequently, and at termination; see Appendix H to 1910.1001 and 1910.1001.

Under 1910.1001 App H, what information must the employer provide to the examining physician?

The employer must provide the physician a copy of the asbestos standard (including appendices), a description of the employee’s duties related to asbestos exposure, the employee’s representative exposure level, a description of personal protective and respiratory equipment used, and available prior medical exam information. Appendix H lists these required items employers must give to the physician to aid evaluation; see Appendix H to 1910.1001 and 1910.1001.

Under 1910.1001 App H, what must the physician include in the required written opinion to the employer and employee?

The physician must provide a written opinion stating the results of the medical exam, whether the employee has any medical conditions that increase risk from asbestos exposure, any recommended limitations (including on PPE), and confirmation that the employee was informed of the results and any exposure-related medical conditions needing further explanation or treatment. Appendix H specifies these required components and that the opinion must not reveal unrelated specific findings or diagnoses; see Appendix H to 1910.1001 and 1910.1001.

Under 1910.1001 App H, can the physician’s written opinion include specific unrelated diagnoses?

No, the written opinion must not reveal specific findings or diagnoses unrelated to asbestos exposure. Appendix H explicitly forbids including unrelated specific findings or diagnoses in the written opinion provided to the employer; see Appendix H to 1910.1001 and 1910.1001.

Under 1910.1001 App H, must the written physician opinion be given to the employee, and who pays for medical surveillance?

Yes, a copy of the physician’s written opinion must be provided to the affected employee, and all examinations and procedures must be provided at no cost to the employee. Appendix H requires supplying the employee a copy of the opinion and states exams must be at no cost to the employee; see Appendix H to 1910.1001 and 1910.1001.

Under 1910.1001 App H, how should the examining physician use workplace information when evaluating an employee?

The physician should become familiar with the operating conditions and the employee’s duties and exposures so they can interpret medical and work histories correctly and assess fitness to wear PPE. Appendix H highlights the importance of the physician understanding workplace conditions, exposures, and protective equipment when evaluating employees; see Appendix H to 1910.1001 and 1910.1001.

Under 1910.1001 App H, can medical surveillance findings prompt workplace changes, and who is responsible for reducing employee exposure?

Yes; when an active employee is identified as overexposed, employer measures to eliminate or mitigate further exposure should be taken because reducing exposure also lowers long‑term health risks. Appendix H notes that employer actions to eliminate or mitigate exposure upon identification of overexposure should lower the risk of long-term consequences; see Appendix H to 1910.1001 and 1910.1001.

Under 1910.1001 App H, what specific pulmonary function measures must be included in the asbestos medical exam?

The pulmonary function test must include measurement of Forced Vital Capacity (FVC) and Forced Expiratory Volume in one second (FEV1). Appendix H specifically requires the PFT to include FVC and FEV1 measurements as part of the routine exam; see Appendix H to 1910.1001 and 1910.1001.

Under 1910.1001 App H, is the respiratory questionnaire mandatory and where is it found?

Yes, completion of the respiratory disease questionnaire is required and it is located in [Appendix D to 1910.1001]. Appendix H requires completing the respiratory disease questionnaire contained in Appendix D as part of the routine medical exam; see Appendix H to 1910.1001.

Under 1910.1001 App H, does Appendix H apply to construction-related asbestos remediation activities?

Appendix H provides non‑mandatory medical surveillance guidance for asbestos under the general industry standard, but many asbestos remediation activities—especially those involving building removal, repair, or cleanup—may be covered by OSHA’s construction asbestos standard, 29 CFR 1926.1101, rather than the general industry standard. OSHA’s recent interpretation about asbestos remediation protocols explains that remediation work involving asbestos-containing building materials is generally covered by 29 CFR 1926.1101 rather than 1910.1001; see the interpretation at Asbestos remediation protocols and Appendix H to 1910.1001.

Under 1910.1001 App H, can medical surveillance detect overexposure to asbestos before disease develops?

Medical surveillance tests such as chest X‑rays and pulmonary function tests may indicate that an employee has been overexposed and therefore has an increased risk, but they cannot reliably screen for cancer or predict who will develop disease. Appendix H says that while adequate cancer screening tests don't exist, chest X‑rays and PFTs may show evidence of overexposure and increased risk; see Appendix H to 1910.1001.