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OSHA 1910.1027AppA

Cadmium safety data sheet

Subpart Z

50 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.1027AppA - What is the OSHA 8-hour TWA PEL for cadmium listed on the Substance Safety Data Sheet?

The OSHA 8-hour time-weighted average permissible exposure limit (TWA PEL) for cadmium is 5 micrograms per cubic meter of air (5 µg/m3). This value is given in the Substance Safety Data Sheet for cadmium in Appendix A to 1910.1027.

Under 1910.1027AppA - Which routes of exposure to cadmium are significant for health concerns?

Inhalation and ingestion are significant routes of exposure for cadmium, and cadmium can also cause local skin or eye irritation. The Substance Safety Data Sheet states cadmium "can affect your health if you inhale it or if you swallow it," and notes local skin and eye irritation as possible routes of harm in Appendix A to 1910.1027.

Under 1910.1027AppA - What types of jobs are most likely to produce immediately dangerous cadmium exposures?

Jobs that handle large quantities of cadmium dust or fume, heat cadmium-containing compounds or cadmium-coated surfaces, weld with cadmium solders, or cut cadmium-containing materials are most likely to produce immediately dangerous cadmium exposures. The cadmium sheet explains these specific high‑risk activities in Appendix A to 1910.1027.

Under 1910.1027AppA - What are the early symptoms of acute inhalation exposure to cadmium fume?

Early symptoms of acute inhalation exposure include mild upper respiratory irritation, a sensation of constriction of the throat, a metallic taste, cough, followed after 1–10 hours by rapidly progressing shortness of breath, chest pain, and flu-like symptoms such as weakness, fever, headache, chills, sweating, and muscular pain. The Substance Safety Data Sheet describes this progression and warns acute pulmonary edema usually develops within 24 hours and peaks by about three days in Appendix A to 1910.1027.

Under 1910.1027AppA - What first aid steps should be taken for someone who has inhaled large amounts of cadmium?

Move the exposed person to fresh air immediately, start cardiopulmonary resuscitation (CPR) if breathing has stopped, administer oxygen if available, keep the person warm and at rest, and get medical attention right away. These emergency steps are specified for inhalation incidents in Appendix A to 1910.1027.

Under 1910.1027AppA - What should you do if cadmium gets in your eyes?

Flush the eyes immediately with large amounts of water, lifting the upper and lower eyelids, and seek medical attention right away. The cadmium safety data sheet includes this eye exposure first aid in Appendix A to 1910.1027.

Under 1910.1027AppA - What steps should be taken for skin contact with cadmium?

Remove contaminated clothing and shoes immediately, wash the affected skin with soap or mild detergent and large amounts of water, and get medical attention as needed. The Substance Safety Data Sheet provides these skin‑exposure procedures in Appendix A to 1910.1027.

Under 1910.1027AppA - Is therapeutic chelation an appropriate treatment for workplace cadmium exposure?

No; employers must not allow therapeutic chelation as treatment for cadmium exposure because it can move cadmium into the kidneys and increase harm. The cadmium sheet explicitly advises employers not to permit therapeutic chelation and to get medical attention immediately, as stated in Appendix A to 1910.1027.

Under 1910.1027AppA - When are respirators allowed or required for workers exposed to cadmium?

Respirators may be required for non-routine activities, emergencies, while engineering controls are being implemented, or where engineering controls are not feasible, and must be approved by MSHA and NIOSH. The cadmium safety sheet explains these situations and the requirement for a joint MSHA/NIOSH approval label in Appendix A to 1910.1027.

Under 1910.1027AppA - What should a worker do if they can detect a cadmium odor while wearing a respirator?

If you can smell cadmium while wearing a respirator, you should go to fresh air immediately because cadmium has no detectable odor at concentrations near the permissible limit, and smelling it suggests the respirator may not be protecting you. The guidance on odor and respirator action appears in Appendix A to 1910.1027.

Under 1910.1027AppA and 1910.1027(l) - When must an employer provide medical examinations and tests for cadmium-exposed employees?

An employer must provide medical examinations and laboratory tests without cost to employees who are exposed at or above the action level and in certain accidental exposures; this is part of the medical surveillance provisions under paragraph (l) of the cadmium standard. The appendix summarizes the requirement and you can find the medical surveillance provisions in 1910.1027(l) and the medical summary in Appendix A to 1910.1027.

Under 1910.1027AppA - Are cadmium medical tests provided at employer expense?

Yes; the cadmium safety data sheet states that required medical examinations and tests must be provided without cost to the employee. This employer obligation is summarized in Appendix A to 1910.1027 and is implemented in the standard's medical surveillance provisions at 1910.1027(l).

Under 1910.1027AppA - What biological monitoring tests are used to assess cadmium exposure and effects?

OSHA relies primarily on cadmium in urine (CdU) to estimate body burden, cadmium in blood (CdB) to monitor recent exposure, and urinary beta-2-microglobulin (β2‑M) to detect early kidney damage. The Substance Safety Data Sheet describes these biological markers and their purposes in Appendix A to 1910.1027.

Under 1910.1027AppA - What does a rise in urinary beta-2-microglobulin (β2‑M) indicate for a worker exposed to cadmium?

An increased urinary β2‑M usually indicates damage to the proximal tubules of the kidney and can be an early sign of cadmium-induced kidney dysfunction; high levels may be irreversible. The appendix explains that β2‑M and other low molecular weight proteins are markers of proximal tubule damage and notes studies showing that elevated β2‑M may not return to normal even after exposure stops in Appendix A to 1910.1027.

Under 1910.1027AppA - Can elevated proteinuria from cadmium exposure progress after exposure ends?

Yes; some studies indicate levels of low‑molecular‑weight proteinuria may increase over time even after exposure stops, and continued exposure after onset of proteinuria can lead to chronic nephrotoxicity. The Substance Safety Data Sheet discusses evidence for progression and the risks of ongoing exposure in Appendix A to 1910.1027.

Under 1910.1027AppA - What hygiene and housekeeping rules are required for workers in cadmium regulated areas?

Workers in cadmium regulated areas must not smoke, eat, drink, chew gum or tobacco, or apply cosmetics, and employers must provide cadmium-free eating facilities and handwashing so employees can practice proper hygiene before eating. The cadmium SDS explains these employee requirements and employer obligations in Appendix A to 1910.1027.

Under 1910.1027AppA - Are workers required to change out of work clothes and shower at work when exposed to cadmium?

Some workers will be required to change out of work clothes and shower as part of their workday to remove cadmium from skin and hair; the appendix says employers must provide appropriate facilities and clean garments when protective clothing is required. See the hygiene and protective clothing guidance in Appendix A to 1910.1027.

Under 1910.1027AppA - What protective clothing and equipment may be required when working with cadmium?

Employers may require impermeable clothing, gloves, footwear, face shields, and splash‑proof or dust‑resistant goggles to prevent skin and eye contact, and must provide clean garments and repair or replace damaged protective clothing. The PPE recommendations appear in Appendix A to 1910.1027.

Under 1910.1027AppA - What rights do employees have to observe exposure monitoring for cadmium?

Employees or their designated representatives are entitled to observe monitoring procedures, record the results, and must be provided with protective clothing and equipment if monitoring occurs in areas where such PPE is required. The appendix summarizes employee observation and recording rights in Appendix A to 1910.1027.

Under 1910.1027AppA - Are medical and exposure records confidential and may employees obtain copies?

Yes; all medical records are kept confidential, but employees or their representatives are entitled to see exposure measurement records and may have their medical records furnished to a personal physician or designated representative upon request. The appendix explains record confidentiality and access in Appendix A to 1910.1027 and the standard's medical provisions at 1910.1027(l).

Under 1910.1027AppA - What is the employer required to do after an accidental cadmium exposure that may be toxic?

If an accidental exposure is known or suspected to be toxic, the employer must make special medical tests available and provide prompt medical attention; the cadmium appendix refers to special tests and immediate medical care in such events. See the emergency and medical provisions summarized in Appendix A to 1910.1027 and the standard's medical surveillance rule at 1910.1027(l).

Under 1910.1027AppA - Why is cadmium inhalation more dangerous than ingestion according to the SDS?

Because cadmium causes more severe and rapid lung injury when inhaled — including acute pulmonary edema and respiratory failure — the appendix states cadmium is much more dangerous by inhalation than by ingestion. This acute hazard comparison is in Appendix A to 1910.1027.

Under 1910.1027AppA, what does an elevated beta-2 microglobulin (β2-M) level in urine tell a physician about cadmium exposure and kidney health?

An elevated urine beta-2 microglobulin (β2-M) indicates early damage to the kidney's proximal tubules and, when combined with abnormal cadmium-in-urine (CdU) or cadmium-in-blood (CdB) results, can show the kidney disease is likely cadmium-related.

  • The appendix explains that excess β2-M is a widely accepted indicator of proximal tubular dysfunction and that, together with CdU and CdB, it can establish that existing kidney disease is probably cadmium-related. See 1910.1027AppA.

Under 1910.1027AppA, what urine β2-M level is commonly considered abnormal and indicative of material impairment?

β2-M levels greater than about 300 µg β2-M per gram creatinine are generally considered abnormal and signify kidney dysfunction that can constitute material impairment of health.

  • The appendix states that most experts view β2-M levels above 300 µg/g Cr as abnormal. See 1910.1027AppA.

Under 1910.1027(l)(1)(iv), what responsibilities does an employer have for laboratories analyzing CdU, CdB and β2-M?

The employer must ensure that biological samples for CdU, CdB, and β2-M are collected and handled to assure reliable results and analyzed only in laboratories with demonstrated proficiency for those specific analytes.

  • Appendix A explains this employer obligation and refers directly to paragraph 1910.1027(l)(1)(iv) and to laboratory standardization guidance in 1910.1027AppF.

Under 1910.1027AppA and appendix F, how should urine samples for β2-M be handled to avoid degradation from acidic urine?

Buffer freshly voided urine samples to pH > 6 (measure pH before and after buffering) and then store or freeze as recommended to prevent β2-M degradation and false low results.

  • The appendix advises measuring pH of freshly voided samples, buffering to pH > 6 if necessary, remeasuring pH, and then freezing samples for storage/shipping as needed; see 1910.1027AppA and laboratory guidance in 1910.1027AppF.

Under 1910.1027AppA, what are the population-derived upper limits of normal for cadmium in urine (CdU) and cadmium in blood (CdB)?

The appendix identifies the population-based upper limits as 3 µg Cd per gram creatinine for CdU and 5 µg Cd per liter whole blood for CdB.

Under 1910.1027(l) and 1910.1027AppA, who is eligible for medical surveillance for cadmium exposure?

Employees exposed above the action level are eligible for the standard's medical surveillance; intermittent exposures are not covered.

  • Appendix A summarizes the medical surveillance provisions and states that workers exposed above the action level are covered and that intermittent exposures are excluded; see 1910.1027 and 1910.1027AppA.

Under 1910.1027AppA, what biological monitoring and exam schedule does OSHA recommend for cadmium-exposed workers?

OSHA recommends initial biological monitoring of CdB, CdU, and β2-M, then at least annual biological monitoring and full medical examinations every two years.

  • Appendix A explains this schedule: initial exam includes a medical questionnaire and monitoring of CdB, CdU, and β2-M; biological monitoring is performed at least annually and full medical exams biennially. See 1910.1027AppA and 1910.1027(l)(3).

Under 1910.1027AppA, what specific tests are part of the initial medical examination for cadmium exposure?

The initial medical exam must include a medical questionnaire plus biological monitoring of cadmium in blood (CdB), cadmium in urine (CdU), and beta-2 microglobulin in urine (β2-M).

Under 1910.1027AppA, how does acid urine (pH < 6) affect β2-M testing and what should employers/physicians do about it?

Acid urine can degrade β2-M and produce deceptively normal (low) results, so the pH must be measured and samples buffered to above pH 6 before storage/shipping.

  • The appendix warns that workers with acidic urine (pH < 6) might show β2-M within normal range despite tubular dysfunction and recommends measuring pH, buffering, and correct sample handling; see 1910.1027AppA and laboratory guidance in 1910.1027AppF.

Under 1910.1027AppA, what detection capability for β2-M do many laboratories have and what simple kit is cited?

Many laboratories can detect β2-M at or below 100 µg β2-M per gram creatinine using simple kits such as the Phadebas Delphia test.

  • The appendix notes that the Phadebas Delphia test and similar kits can accurately detect β2-M down to about 100 µg/g Cr; see 1910.1027AppA and related laboratory standardization guidance in 1910.1027AppF.

Under 1910.1027AppA, what are the interim medical removal trigger levels for CdU, CdB, and β2-M during the first five years after the standard takes effect?

Until five years after the standard's effective date, medical removal is required when CdU > 15 µg/g creatinine, or CdB > 15 µg/l whole blood, or β2-M > 1500 µg/g Cr together with CdB > 5 µg/l or CdU > 3 µg/g Cr.

  • Appendix A states these interim triggers for medical removal; see 1910.1027AppA and the medical removal provisions in 1910.1027(l).

Under 1910.1027AppA, how long must employers provide medical removal protection benefits to employees removed for cadmium-related medical reasons?

Employers must provide medical removal protection benefits for up to 18 months for employees removed under the medical removal provisions.

  • Appendix A specifies that medical removal protection benefits are to be provided for up to 18 months; see 1910.1027AppA and 1910.1027(l).

Under 1910.1027AppA, are past workers covered by biological monitoring after they leave cadmium work, and if so for how long?

Yes — past workers who were covered receive biological monitoring for at least one year after leaving cadmium exposure work.

  • Appendix A notes that past workers who are covered receive biological monitoring for at least one year; see 1910.1027AppA and the medical surveillance eligibility in 1910.1027(l)(1).

Under 1910.1027AppA, what medical counseling should physicians provide to workers with cadmium-related tubular proteinuria?

Physicians should counsel workers to stop smoking, avoid nephrotoxins (including certain prescription and over-the-counter drugs), control diabetes and blood pressure, and follow proper hydration, diet, and exercise guidance.

  • Appendix A strongly recommends counseling on these topics for patients with tubular proteinuria and includes a list of common nephrotoxins in the appendix attachments; see 1910.1027AppA.

Under 1910.1027AppA, does OSHA recommend chelation therapy for cadmium-induced kidney damage?

No — OSHA and cited experts strongly advise against chelation for cadmium-induced renal damage because chelating agents carry substantial risks and there is no safe, effective chelation treatment to reduce cadmium accumulation in the kidney.

  • Appendix A explicitly states "DO NOT CHELATE" and that experts have concluded no form of chelating agent can be used without substantial risk; see 1910.1027AppA.

Under 1910.1027AppA, what information must an employer provide to an examining physician after a worker's biological monitoring or medical exam?

The employer must provide the physician with an information sheet explaining the significance of the worker's biological monitoring or medical examination results and other required information specified in the standard.

  • Appendix A states the employer is required to provide an information sheet (appendix A Attachment-3) after biological monitoring results are reviewed by the physician; see 1910.1027AppA and the medical surveillance provisions in 1910.1027(l).

Under 1910.1027AppA and 1910.1027(l)(3), how are employees categorized from biological monitoring results and what do the categories mean?

Employees are assigned category A, B, or C based on where their CdU, CdB, and β2-M results fall; A is lowest concern, B indicates some abnormality, and C indicates results above the levels listed for category C that trigger more protective actions.

  • Appendix A explains the alphabetical categories and that actions required for each employee depend on the category as shown in appendix A Table B; see 1910.1027AppA and 1910.1027(l)(3).

Under 1910.1027AppA, what should physicians avoid prescribing for patients with cadmium tubular proteinuria?

Physicians should avoid prescribing chelating agents and be cautious with drugs that are nephrotoxins or associated with nephritis, since these can worsen kidney damage.

  • Appendix A explicitly warns "DO NOT CHELATE" and advises physicians to know which drugs are nephrotoxins; see 1910.1027AppA.

Under 1910.1027AppA, what types of respiratory and cancer risks does OSHA describe from long-term cadmium exposure?

OSHA describes increased risks of lung cancer, possible prostate cancer, acute pneumonitis from high-level inhalation, and chronic respiratory diseases including reduced pulmonary function and emphysema from prolonged exposure to cadmium dusts or fumes.

  • Appendix A summarizes epidemiological and animal evidence linking cadmium to lung and prostate cancers and describes acute and chronic respiratory effects; see 1910.1027AppA.

Under 1910.1027AppA, what are the Category A/B/C biological monitoring thresholds for cadmium in urine, cadmium in blood, and beta-2-microglobulin (before and beginning January 1, 1999)?

Category thresholds differ before and after 1/1/1999 and you must use the table appropriate to the date. For clarity, here are the values in Appendix A Table A:

  • Applicable Through 1998 (pre-1999):

    • Cadmium in urine (CdU): Category A ≤ 3 µg/g creatinine; B > 3 and ≤ 15 µg/g creatinine; C > 15 µg/g creatinine.
    • Beta-2-microglobulin (β2‑M): Category A ≤ 300 µg/g creatinine; B > 300 and ≤ 1500 µg/g creatinine; C > 1500 µg/g creatinine (with the footnote condition described below).
    • Cadmium in blood (CdB): Category A ≤ 5 µg/l whole blood; B > 5 and ≤ 15 µg/l; C > 15 µg/l.
  • Applicable Beginning January 1, 1999:

    • Cadmium in urine (CdU): Category A ≤ 3 µg/g creatinine; B > 3 and ≤ 7 µg/g creatinine; C > 7 µg/g creatinine.
    • Beta-2-microglobulin (β2‑M): Category A ≤ 300 µg/g creatinine; B > 300 and ≤ 750 µg/g creatinine; C > 750 µg/g creatinine (with the footnote condition described below).
    • Cadmium in blood (CdB): Category A ≤ 5 µg/l whole blood; B > 5 and ≤ 10 µg/l; C > 10 µg/l.

Note: Appendix A includes a footnote that if an employee's β2‑M is above the Category C cutoff (1500 µg/g pre‑1999 or 750 µg/g beginning 1999), mandatory medical removal is required only if either CdU is also > 3 µg/g creatinine or CdB is also > 5 µg/l whole blood. See the Appendix A table in the cadmium standard for the exact wording and dates.

Under 1910.1027(l)(3) and Appendix A Table B, how often must employers do biological monitoring for employees in Categories A, B, and C?

You must follow the Table B schedule in Appendix A: Category A employees get annual monitoring, Category B employees get semiannual monitoring, and Category C employees get quarterly monitoring.

  • Category A: annual biological monitoring.
  • Category B: semiannual biological monitoring.
  • Category C: quarterly biological monitoring.

These required frequencies are shown in Appendix A Table B and are implemented under the medical surveillance provisions in 1910.1027(l)(3).

Under 1910.1027(l)(4)(v) and Appendix A Table B, what medical examination schedule must employers provide for employees in Categories A, B, and C?

Follow Appendix A Table B: Category A employees get a biennial medical exam, Category B employees get annual medical exams (plus a medical exam within 90 days if triggered), and Category C employees get semiannual medical exams (and must also have a medical exam within 90 days if triggered).

  • Category A: medical exam every two years (biennial).
  • Category B: medical exam annually, and a medical exam within 90 days when indicated by the Table B triggers.
  • Category C: medical exam semiannually, and a medical exam within 90 days when indicated by the Table B triggers.

See Appendix A Table B for the full matrix of medical exam frequencies and the requirements discussed under 1910.1027(l)(4)(v).

Under 1910.1027AppA, if an employee's beta-2-microglobulin is above the Category C cutoff but their CdU is ≤ 3 µg/g creatinine and CdB ≤ 5 µg/l, is mandatory medical removal required?

No — an elevated beta‑2‑microglobulin alone (above the Category C cutoff) does not automatically trigger mandatory medical removal unless one of the cadmium measures is also above its low threshold. Appendix A states mandatory removal for a β2‑M above the Category C cutoff requires either CdU > 3 µg/g creatinine or CdB > 5 µg/l whole blood in addition to the β2‑M elevation.

  • In other words, β2‑M > (750 µg/g beginning 1/1/1999 or 1500 µg/g pre‑1999) alone is not sufficient for mandatory removal — you must also have CdU > 3 µg/g Cr or CdB > 5 µg/l wb.

See the footnote in Appendix A Table A and the associated actions in Appendix A Table B for the removal rules.

Under 1910.1027(l)(3)(i)(B) and 1910.1027(l)(4)(v)(A), what special rule applies to Category A employees who are under surveillance only because of exposures that occurred before the standard's effective date?

Employees covered for medical surveillance solely because of exposures before the standard's effective date and who fall in Category A must be treated under the specific surveillance frequencies in paragraphs (l)(3)(i)(B) and (l)(4)(v)(A): perform annual biological monitoring and biennial medical examinations as required for Category A in Appendix A Table B.

  • This means employers must continue the Category A schedule (annual biological monitoring and biennial medical exams) for those employees even though their coverage is based only on prior exposures.

See the advisory in Appendix A Table B and the reference to 1910.1027(l)(3)(i)(B) and 1910.1027(l)(4)(v)(A).

Under 1910.1027AppA, what workplace assessments and follow-up actions must an employer perform within two weeks and within 30 days when a worker falls into Category B or C?

You must assess several exposure and control factors within two weeks and correct identified deficiencies within 30 days for Category B and C results. Specifically, Appendix A Table B requires that, within two weeks, the employer assess: excess cadmium exposure, work practices, personal hygiene, respirator usage, smoking history, hygiene facilities, and engineering controls. Any identified problems must be corrected within 30 days.

  • Assess within two weeks: (a) excess cadmium exposure; (b) work practices; (c) personal hygiene; (d) respirator usage; (e) smoking history; (f) hygiene facilities; (g) engineering controls.
  • Correct deficiencies within 30 days; for Category C also periodically reassess exposures per Table B instructions.

See Appendix A Table B and the medical surveillance requirements in 1910.1027(l)(4)(v)(B)-(C).

Under 1910.1027(l)(4)(v)(B)-(C) and Appendix A Table B, when is medical removal discretionary versus mandatory for Category B and Category C employees?

For Category B the employer may use discretionary medical removal, while for Category C mandatory medical removal is required (subject to the β2‑M footnote condition described in Appendix A Table A).

  • Category B: discretionary medical removal — the employer may remove the employee from exposure if indicated.
  • Category C: mandatory medical removal — Appendix A directs mandatory removal actions for Category C results (note the β2‑M footnote that requires an accompanying CdU > 3 µg/g Cr or CdB > 5 µg/l for β2‑M alone to trigger mandatory removal).

See Appendix A Table B and 1910.1027(l)(4)(v)(B)-(C).

Under 1910.1027AppA Attachment 3, how should employers and physicians interpret a single mildly elevated cadmium or beta-2-microglobulin test result?

A single, mildly elevated biological result does not automatically mean long‑term harm and can be followed by repeat testing and workplace evaluation rather than immediate removal. Appendix A explains that one mildly elevated result may not be important if later testing returns to normal and the employer evaluates and reduces possible sources of cadmium exposure.

Practical steps to take:

  • Repeat the biological monitoring at the frequency required for the employee's category.
  • Evaluate workplace exposures, work practices, hygiene, and engineering controls for possible sources of cadmium.
  • Counsel the employee about minimization measures (e.g., hygiene, avoiding cadmium‑contaminated tobacco, medication review).

See the commentary and sample form in Appendix A Attachment 3 and the broader surveillance rules in 1910.1027.

Under 1910.1027AppA, what biological levels are identified as “high levels” that indicate a greater chance of developing kidney disease and what precautions should employers take?

Appendix A identifies ‘high levels’ associated with a much greater chance of kidney disease as CdU > 10 µg/g creatinine, CdB > 10 µg/l whole blood, or β2‑M > 1000 µg/g creatinine; when these high levels occur, employers should take prompt action to protect the worker’s kidneys and reduce exposure.

Recommended precautions from Appendix A include:

  • Counseling and medical follow‑up (physician review and possible removal).
  • Evaluate and reduce workplace exposure (engineering controls, work practices, hygiene, respirator use).
  • Advise workers about additional kidney‑protective measures: hydration, avoiding cadmium‑contaminated tobacco, reviewing nephrotoxic medications, and controlling other health risks (blood pressure, diabetes).

See the discussion of high levels and medical concerns in Appendix A and the medical surveillance provisions in 1910.1027.