Cadmium exposure requirements

Yes. The cadmium standard at 1910.1027(a) applies to all occupational exposures to cadmium in general industry but explicitly excludes construction-related industries, which are covered under 29 CFR 1926.63.

Employee exposure is defined as the airborne cadmium concentration the worker would experience if they were not using respiratory protection. This means monitoring and compliance decisions use unprotected breathing zone concentrations as described in 1910.1027(b).

The Action Level (AL) for cadmium is 2.5 micrograms per cubic meter (2.5 µg/m3) as an 8-hour TWA, and the Permissible Exposure Limit (PEL) is 5 micrograms per cubic meter (5 µg/m3) as an 8-hour TWA, as set in 1910.1027 and the standard text describing the PEL.

Employers must use breathing zone air samples that reflect each employee's regular daily 8-hour TWA and base determinations on personal full-shift samples for each shift and job classification. Specifically, 1910.1027(d)(1)(ii)-(iii) requires personal breathing zone samples for the full shift and allows representative sampling (sampling the highest-exposed workers) when employees perform similar tasks.

An employer may sample a representative fraction of employees when several workers perform the same job tasks, in the same classification and shift, in the same area, and exposures are similar; the employer must sample those expected to have the highest exposures. This option is provided in 1910.1027(d)(1)(iii).

An employer may rely on monitoring performed after September 14, 1991 that closely resembles current conditions and meets accuracy and confidence requirements, or on objective data showing exposures will not exceed the Action Level under expected conditions. These alternatives are described in 1910.1027(d)(2)(ii)-(iii).

If monitoring shows exposures at or above the Action Level, employers must monitor as often as needed to represent employee exposures and at least every six months; if two consecutive measurements (at least seven days apart) show exposures below the Action Level, monitoring for those employees may be discontinued. See 1910.1027(d)(3) and 1910.1027(d)(3)(ii).

Additional monitoring must be instituted whenever changes in raw materials, equipment, personnel, work practices, finished products, or any other change may reasonably be expected to cause exposures at or above the Action Level or above the PEL. These triggers are listed in 1910.1027(d)(4).

Employers must notify each affected employee of monitoring results within 15 working days after receipt of results, either in writing or by posting in an accessible location, and if the PEL was exceeded the notice must state that fact and describe corrective action being taken. This requirement is laid out in 1910.1027(d)(5)(i)-(ii).

Monitoring and analysis methods for cadmium must have an accuracy of at least ±25% with a 95% confidence level for airborne concentrations at or above the Action Level and PEL. This measurement requirement is specified in 1910.1027(d)(6).

An employer must establish a regulated area wherever employee exposure to airborne cadmium is, or can reasonably be expected to be, in excess of the PEL, and the area must be demarcated in any manner that adequately establishes and alerts employees to its boundaries. These duties are required by 1910.1027(e)(1)-(2).

Access to regulated areas must be limited to authorized persons, each person entering must be supplied and required to use a respirator selected per [1910.1027(g)(2)], and eating, drinking, smoking, chewing tobacco or gum, and applying cosmetics is prohibited in those areas. These requirements are in 1910.1027(e)(3)-(5).

Employers must implement engineering and work practice controls to reduce exposures to the PEL (or SECAL where applicable) unless they can demonstrate infeasibility; if controls cannot reduce exposures to the PEL, employers must still reduce exposures as much as feasible and supplement with respiratory protection per [1910.1027(g)]. These requirements are described in 1910.1027(f)(1)(i)-(iv).

SECALs apply to specified processes in certain industries listed in Table I, and where a SECAL exists the employer must control exposures to the SECAL unless infeasible; for example, the SECAL for nickel-cadmium battery plate making is 50 µg/m3 and for most other plating processes is 15 µg/m3, as shown in 1910.1027(f)(1)(ii).

The engineering and work practice control requirement does not apply if the employee is only intermittently exposed and is not exposed above the PEL on 30 or more days per year (12 consecutive months). This exception is set out in 1910.1027(f)(1)(iii)(A)-(B).

No. Employers are prohibited from using employee rotation as a method of compliance with the PEL for cadmium, as stated in 1910.1027(f)(1)(v).

When the PEL is exceeded, the employer must establish a written compliance program that describes operations emitting cadmium, the means to achieve compliance (including engineering plans and respiratory protection if needed), the technology considered, monitoring data, an implementation schedule, required work practices, an emergency plan, and other relevant information; the program must be reviewed and updated at least annually. These requirements are detailed in 1910.1027(f)(2)(ii)-(iii).

The written compliance program must include a work practice program that incorporates the requirements of paragraphs (h), (i), and (j) (such as housekeeping, hygiene, and training) and a written plan for emergency situations as specified in paragraph (h). These elements are required in 1910.1027(f)(2)(ii)(F)-(G).

If monitoring shows exposures exceed the PEL, the employer's written notice to affected employees must state that the PEL has been exceeded and describe the corrective action being taken to reduce exposures to or below the PEL, as required by 1910.1027(d)(5)(ii).

Every person entering a regulated area must be supplied with and required to use a respirator selected in accordance with [1910.1027(g)(2)], meaning employers must choose respirators appropriate to the exposure based on the respirator selection rules in the cadmium standard. See 1910.1027(e)(4) and 1910.1027(g)(2).

A HEPA filter is defined as one capable of trapping at least 99.97% of mono-dispersed particles 0.3 micrometers in diameter, and this definition is used where the standard requires high-efficiency filtration for control measures or respiratory protection cleanup. The HEPA definition appears in 1910.1027(b).

You must measure parameters that demonstrate the system is effectively capturing cadmium, such as capture velocity, duct velocity, or static pressure. Employers are required to make these measurements as necessary to maintain the effectiveness of ventilation systems used to control cadmium exposure (1910.1027(f)(3)(i).

• Measure whichever metric (capture velocity, duct velocity, static pressure) is appropriate for your control design and location.
• Repeat measurements anytime performance appears to change or on a schedule that ensures continued effectiveness.

You must make measurements within five working days after any change in production, process, or control that might significantly increase employee cadmium exposure. The rule requires timely re-measurement to confirm the ventilation still protects workers (1910.1027(f)(3)(ii).

• If the change could raise exposures, schedule re-measurement within five working days.
• If measurements show the system is no longer effective, implement fixes immediately and re-verify.

You may recirculate exhaust air only if the system uses a high efficiency filter and the recirculation is monitored to assure continued effectiveness. The standard requires a HEPA or equivalent filter and monitoring when exhaust air is returned to the workplace (1910.1027(f)(3)(iii).

• Use HEPA filters for recirculated air.
• Set up a monitoring program (e.g., periodic testing or visual/pressure checks) to confirm filters and system performance.

You must develop and implement procedures that minimize employee exposure to cadmium during ventilation maintenance and filter changes. The rule requires written procedures and controls for these maintenance tasks (1910.1027(f)(3)(iv).

• Use work practices that avoid dispersing cadmium (e.g., local containment, wet methods, HEPA vacuuming).
• Provide appropriate PPE and respiratory protection during maintenance.
• Train maintenance staff on safe filter-change procedures and decontamination.

Yes — written compliance programs must be provided on request to affected employees, designated employee representatives, the Assistant Secretary, and the Director. Employers must make the program available for examination and copying (1910.1027(f)(2)(iv).

• Provide copies or allow review in a reasonable place and time.
• Keep the written program up to date so the information provided reflects current controls and procedures.

Respirators are required in several situations, including while installing engineering controls, during maintenance and brief operations when controls are not feasible, work in regulated areas, when feasible controls can't reduce exposures to the PEL, when an employee requests one at or above the action level, and in emergencies. The standard lists specific circumstances when respirator use is required (1910.1027(g)(1).

• Examples: temporary work to install controls, maintenance that can't be fully engineered, and emergency releases.

You must implement a respiratory protection program that meets the requirements of 1910.134(b)–(d), (f)–(m) and covers every employee required by the cadmium standard to use a respirator, as specified in 1910.1027(g)(2).

• The program must include medical evaluations, fit testing, training, maintenance, and program administration per 1910.134.
• Document procedures and keep records as required by 1910.134.

If the examining physician determines an employee cannot use a respirator, the employee must not use one and must be limited or removed in accordance with the medical surveillance provisions; if an employee experiences breathing difficulty during fit testing or use, the employer must provide a medical exam under the cadmium standard's medical procedures. The standard requires medical evaluation and appropriate job restrictions when respirator use is medically contraindicated or causes difficulty (1910.1027(g)(2)(ii); 1910.1027(g)(2)(iii).

• Follow the medical limitation/removal procedures in paragraphs (l)(11) and (l)(12) of the cadmium standard.
• Provide alternative protective measures or job reassignment if needed.

You must select and provide the respirators specified in 1910.134(d)(3)(i)(A), provide full facepiece respirators when employees have eye irritation, and provide HEPA filters for powered and non-powered air-purifying respirators. The cadmium standard specifically requires HEPA filtration and full facepieces when needed for eye protection (1910.1027(g)(3)(i)(A)-(C).

• Use HEPA filters on APRs and PAPR units when filtering airborne cadmium.
• Provide full facepieces whenever eye irritation from cadmium exposure occurs.

Yes — if the employee is entitled to a respirator and a PAPR provides adequate protection, the employer must provide it when the employee chooses to use that type. The cadmium standard allows employee-chosen PAPRs as long as they provide adequate protection (1910.1027(g)(3)(ii).

• The selected PAPR must still meet the respirator program rules in 1910.134.
• Ensure fit testing, medical clearance, and training are provided consistent with 1910.134 requirements.

Your written emergency plan must deal with substantial releases of airborne cadmium and include provisions for the use of appropriate respirators and personal protective equipment, restrict nonessential employees from the area, and halt normal operations in the area until the emergency is abated (1910.1027(h).

• Identify responders, PPE and respirator types, evacuation and decontamination procedures.
• Specify who is authorized to re-enter and how the area is cleared for normal operations.

You must provide, at no cost, appropriate protective work clothing and equipment whenever an employee is exposed to airborne cadmium above the PEL or when skin or eye irritation is associated with cadmium exposure at any level (1910.1027(i)(1).

• Protective items include coveralls, gloves, head coverings, boots, face shields, and vented goggles that meet 1910.133 standards.

Employees must remove contaminated clothing at the end of their shift only in change rooms provided under paragraph (j)(1), and contaminated items may not be taken from the workplace except by authorized persons for laundering, cleaning, maintenance, or disposal at approved locations; contaminated items removed for servicing must be placed in sealed, impermeable bags or containers to prevent dispersion of cadmium dust (1910.1027(i)(2)(i)-(iii).

• Provide separate storage for street clothes and contaminated clothing as required under paragraph (j)(2).
• Use sealed impermeable bags/containers to move contaminated clothing off-site.

You must provide protective clothing in clean, dry condition as often as necessary to maintain effectiveness but at least weekly; you must repair or replace damaged clothing immediately; and you must prohibit removal of cadmium from clothing by blowing, shaking, or any other means that disperses cadmium into the air (1910.1027(i)(3)(i)-(iii).

• Establish a cleaning schedule (minimum weekly) and inspection process.
• Use methods that do not disperse dust (HEPA vacuuming, wet cleaning) and ban shaking or blowing contaminated garments.

If laundering or cleaning occurs on-site, you must do it in a way that prevents release of airborne cadmium above the PEL; you must inform any person or facility who launders the contaminated clothing about the harmful effects of cadmium and the need to prevent releasing airborne cadmium above the PEL (1910.1027(i)(3)(iv)-(v).

• Communicate hazards and required cleaning controls to outside laundries in writing.
• Ensure the laundering process includes controls (local exhaust, HEPA filtration) that prevent airborne releases above the PEL.

When airborne cadmium exposure is above the PEL, you must provide clean change rooms, handwashing facilities, showers, and lunchroom facilities that comply with [1910.141]; and you must assure that affected employees shower at the end of the work shift (1910.1027(j)(1) and (j)(3)(i).

• Ensure separate storage for street clothes and protective clothing per 1910.1027(j)(2).
• Provide convenient handwashing and shower facilities and require end-of-shift showers for those above the PEL.

Employees exposed to cadmium above the PEL must wash their hands and faces prior to eating, drinking, smoking, chewing tobacco or gum, or applying cosmetics (1910.1027(j)(3)(ii).

• Provide sinks and soap and make handwashing mandatory before breaks and meals for affected workers.

Lunchroom facilities must be readily accessible, have tables maintained free of cadmium, and no employee in the lunchroom may be exposed to cadmium at or above 2.5 µg/m3; employees must not enter lunchrooms wearing protective work clothing or equipment unless surface cadmium has been removed by HEPA vacuuming or other non-dispersing cleaning (1910.1027(j)(4)(i)-(ii).

• Keep lunchroom surfaces clean using HEPA vacuums or wet cleaning that won't make dust airborne.
• Enforce policy preventing entry with contaminated clothing unless decontaminated by approved methods.

Surfaces must be kept as free as practicable of cadmium, spills cleaned up promptly, and contaminated surfaces cleaned by vacuuming or other methods that minimize airborne cadmium; HEPA-filtered vacuuming or equally effective filtration must be used (1910.1027(k)(1)-(4).

• Prefer HEPA vacuuming and wet methods; avoid dry sweeping and compressed air except under controlled conditions.
• Clean spills immediately with methods that prevent dust clouds.

Shoveling, dry or wet sweeping, and brushing may be used only when vacuuming or other minimizing methods are tried and found ineffective; compressed air may not be used to remove cadmium unless it is used with a ventilation system designed to capture the resulting dust cloud; and contaminated waste, scrap, PPE, and clothing must be collected and disposed of in sealed impermeable bags or containers labeled per paragraph (m) (1910.1027(k)(5)-(7).

• Use HEPA vacuuming first; document why sweeping was needed if you must use it.
• Never use compressed air without a capture ventilation system.
• Seal and label contaminated waste for disposal as required.

You must institute medical surveillance for employees who are or may be exposed at or above the action level unless you can demonstrate they are not exposed at or above the action level on 30 or more days per year, and for employees who prior to the standard's effective date might previously have been exposed at or above the action level unless you can show they did not work in such jobs for a total of more than 60 months (1910.1027(l)(1)(i)(A)-(B).

• Current exposure: include those at/above the action level ≥30 days/year unless documented otherwise.
• Previously exposed: include workers with prior aggregated exposures >60 months before the effective date unless you can document otherwise.

All required medical examinations and procedures must be performed by or under the supervision of a licensed physician who has read the health effects section of appendix A, the cadmium regulatory text, the sample handling protocol in appendix F, and the questionnaire in appendix D (1910.1027(l)(1)(iii).

• Ensure the physician is familiar with the cadmium standard's appendices and protocol before conducting exams and reviewing results.

The employer must provide the initial (preplacement) medical examination within 30 days after the employee is first assigned to a job with cadmium exposure or no later than 90 days after the standard's effective date, whichever is later. See 1910.1027(l)(2).

• These examinations must be provided without cost to the employee and at a reasonable and convenient time and place.
• An initial exam is not required if adequate records show the employee already received the required tests within the past 12 months; those records must be kept as part of the employee's medical record and treated as the initial exam for later requirements (see 1910.1027(l)(2)(iii).

The initial biological monitoring must include cadmium in urine (CdU) standardized to grams of creatinine (µg/g Cr), beta-2 microglobulin in urine (β2-M) standardized to grams of creatinine with pH specified (µg/g Cr), and cadmium in blood (CdB) standardized to liters of whole blood (µg/lwb). See 1910.1027(l)(2)(ii)(B) and its subparts: CdU, β2-M, and CdB.

• Report CdU and β2-M results as micrograms per gram of creatinine (µg/g Cr) and report CdB as micrograms per liter of whole blood (µg/lwb).
• Sample collection and analysis must assure reliability and be performed in laboratories with demonstrated proficiency for that analyte (see 1910.1027(l)(1)(iv) and appendix F to 1910.1027).

If initial biological monitoring shows CdU exceeds 3 µg/g Cr or β2-M exceeds 300 µg/g Cr or CdB exceeds 5 µg/lwb, the employer must reassess exposure within two weeks, correct deficiencies within 30 days, and provide a full medical examination within 90 days. See 1910.1027(l)(3)(ii).

Key steps and timelines:

• Within 2 weeks: Reassess the employee's occupational exposure, including work practices and hygiene, respirator use and the respirator program, hygiene facilities, maintenance and effectiveness of engineering controls, and the employee's smoking history (1910.1027(l)(3)(ii)(A)).
• Within 30 days after the reassessment: Take reasonable steps to correct any deficiencies that may have caused the elevated levels (1910.1027(l)(3)(ii)(B)).
• Within 90 days of receiving the results: Provide a full medical examination in accordance with the periodic exam requirements (1910.1027(l)(3)(ii)(C) and 1910.1027(l)(4)(ii)).

Very high biological monitoring levels trigger a prompt full medical exam and may lead to medical removal if confirmed: initial CdU > 15 µg/g Cr, CdB > 15 µg/lwb, or β2-M > 1,500 µg/g Cr require immediate action and a full medical exam within 90 days; beginning January 1, 1999, lower trigger levels (CdU > 7 µg/g Cr, CdB > 10 µg/lwb, or β2-M > 750 µg/g Cr) also require a full medical exam within 90 days. See 1910.1027(l)(3)(iii) and 1910.1027(l)(3)(iv)(C).

• If both the initial result and the confirmatory result obtained during the medical examination exceed the stated removal-trigger levels (for example, both initial and medical-exam CdU > 15 µg/g Cr, and additionally CdU > 3 µg/g Cr), the physician must medically remove the employee from exposure at or above the action level (see 1910.1027(l)(3)(iii) and 1910.1027(l)(3)(iv)).
• If the confirmatory medical-exam results do not meet the mandatory removal criteria, removal is not required by the mandatory provisions, but the physician may still recommend removal based on clinical judgment.

If the physician does not order medical removal, the employer must continue enhanced monitoring: semiannual biological monitoring and annual medical examinations until the employee's levels fall to or below CdU ≤ 3 µg/g Cr, β2-M ≤ 300 µg/g Cr, and CdB ≤ 5 µg/lwb. See 1910.1027(l)(3)(ii)(C) and 1910.1027(l)(4)(ii).

• Biological monitoring: provided on a semiannual basis (1910.1027(l)(3)(ii)(C)(1)).
• Medical examinations: provided annually while elevated levels persist (1910.1027(l)(3)(ii)(C)(2)).

These steps continue until the specified biological markers are at or below the action-level values.

For currently exposed employees covered under paragraph (l)(1)(i)(A), the employer must provide periodic medical examinations within one year after the initial exam and at least biennially thereafter; biological sampling must be provided at least annually. See 1910.1027(l)(4)(i) and 1910.1027(l)(4)(iii).

For previously exposed employees under paragraph (l)(1)(i)(B), surveillance may be discontinued if both the initial biological monitoring and the follow-up biological monitoring one year later show CdU ≤ 3 µg/g Cr, CdB ≤ 5 µg/lwb, and β2-M ≤ 300 µg/g Cr; in that case the employer may stop periodic medical surveillance for that employee. See 1910.1027(l)(4)(v)(A).

• Periodic biological sampling must be provided at least annually either as part of the periodic exam or separately (1910.1027(l)(4)(ii)(E)).

The employer must ensure that collection and handling of cadmium biological samples (CdU, CdB, β2-M) are done so their results are reliable and that analyses are performed in laboratories with demonstrated proficiency for the particular analyte. See 1910.1027(l)(1)(iv) and appendix F to 1910.1027.

Practical items employers should do:

• Use sample collection procedures that prevent contamination and preserve sample integrity (follow guidance in appendix F).
• Send samples to laboratories that can demonstrate proficiency for CdU, CdB, or β2‑M testing (document laboratory qualifications and proficiency testing).
• Ensure that urine-based tests reporting use creatinine-standardized units and that β2‑M results include pH as required (1910.1027(l)(2)(ii)(B)(2)).