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OSHA 1910.1051AppC

Medical screening for butadiene

Subpart Z

20 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.1051 App C, what are the main health risks from inhaling 1,3-butadiene (BD)?

Inhalation of 1,3-butadiene (BD) primarily increases the risk of blood cancers (like leukemia and lymphoma) and may damage reproductive organs and the fetus. This is stated in 1910.1051 App C, which explains BD’s toxicology and epidemiology showing links to lymphohematopoietic cancers and reproductive toxicity.

Under 1910.1051 App C, what immediate (acute) symptoms should workers and clinicians watch for after a high short-term BD exposure?

Acute inhalation of BD can irritate the eyes, nose, throat and lungs and at very high concentrations can cause narcosis, breathing paralysis, unconsciousness, or death. The guidance in 1910.1051 App C lists those acute effects and notes that severe acute exposures may require hospitalization and focused exams of the respiratory system, eyes, skin and nervous system.

Under 1910.1051 App C, what reproductive health concerns are associated with BD and when should workers get evaluated?

BD exposure is associated with potential reproductive toxicity, including effects on sperm and ovarian/testicular atrophy in animal studies, so workers with high exposure who have trouble conceiving, miscarriages, or stillbirths should receive medical and laboratory fertility evaluation. See 1910.1051 App C for guidance that physicians should identify and provide appropriate reproductive consultations and exams.

Under 1910.1051 App C, how often must the health questionnaire for BD-exposed workers be updated?

The health questionnaire for workers exposed to BD must be updated at least once every year. 1910.1051 App C states that after the initial administration the questionnaire should be repeated annually to elicit new signs, symptoms, or history related to lymphohematopoietic disorders or reproductive problems.

Under 1910.1051 App C, what specific blood test is required annually for workers with BD exposure?

An annual complete blood count (CBC) with differential and platelet count is required for each employee with BD exposure. 1910.1051 App C specifies that the CBC should be analyzed by an accredited laboratory and may be drawn from venous phlebotomy or, if technically feasible, a fingerstick capillary sample.

Under 1910.1051 App C, can a CBC sample for BD screening be collected by fingerstick instead of venous draw?

Yes — 1910.1051 App C allows CBC samples to be obtained by venous phlebotomy or, if technically feasible, from a fingerstick capillary blood sample; either must be analyzed by an accredited laboratory.

Under 1910.1051 App C, who decides whether an abnormal CBC is clinically significant and what should happen if it is?

The examining physician or other licensed health care professional (or medical specialist) is responsible for deciding whether a CBC abnormality is clinically significant, and a clinically significant abnormal CBC should lead to removal of the employee from further BD exposure. This process is described in 1910.1051 App C. Employers should follow the clinician’s recommendation, which may include temporary transfer to BD‑free duties.

Under 1910.1051 App C, how should clinicians handle small CBC changes that are only slightly outside population normal ranges?

Small CBC changes only slightly outside population-based normal ranges may not require immediate concern; clinicians should use clinical judgment, compare with prior CBCs for trends, and when appropriate repeat the CBC within about 6 weeks to see if values return to normal. This guidance comes from 1910.1051 App C.

Under 1910.1051 App C, what follow-up testing schedule is recommended after a severe acute BD exposure?

After a severe acute BD exposure, a CBC should be obtained within 48 hours and then repeated at one, two, and three months. 1910.1051 App C specifies this timeline because acute exposures can increase the risk of blood abnormalities.

Under 1910.1051 App C, how often should physical examinations be done for workers exposed to BD?

An initial physical examination is required and then repeated every three years for workers exposed to BD. 1910.1051 App C also states that additional exams should be done as needed for questionnaire responses, abnormal CBCs, reproductive concerns, or after acute exposures.

Under 1910.1051 App C, what should the physical exam focus on for BD-exposed workers?

The physical exam should establish baseline general health and look for signs of lymphohematopoietic disorders (for example, enlarged lymph nodes, splenomegaly, or hepatomegaly) and update those findings on repeat exams. This is described in 1910.1051 App C.

Under 1910.1051 App C, what specific steps should be taken if a worker with BD exposure plans to stop working in BD jobs?

Workers who will no longer be working in BD-exposed jobs should receive a physical examination to rule out lymphohematopoietic disorders before or soon after leaving BD exposure. 1910.1051 App C recommends this to document health status and identify any disorders that could be related to BD.

Under 1910.1051 App C, what role does the health questionnaire play in identifying workers at higher risk from BD?

The health questionnaire's main role is to identify symptoms and personal or family histories (such as immune deficiency, blood disorders, prior exposures to hematopoietic toxins, or reproductive difficulties) that raise a worker’s risk for leukemia, lymphoma or reproductive effects. 1910.1051 App C emphasizes annual updates and referral for appropriate medical follow-up based on responses.

Under 1910.1051 App C, should employers keep a flowsheet of CBC results for BD-exposed workers?

Yes — 1910.1051 App C suggests including a flowsheet of laboratory values in each employee’s medical record so trends and substantial changes over time can be easily identified by clinicians.

Under 1910.1051 App C, can a CBC abnormality be caused by things other than BD exposure, and how should clinicians proceed?

Yes — CBC abnormalities can result from many causes (viral illness, recent blood donation, menstruation, lab error, etc.), so clinicians should consider these possibilities, compare to prior CBCs, repeat testing within about 6 weeks if appropriate, and use clinical judgment to decide on removal from exposure. This is explained in 1910.1051 App C.

Under 1910.1051 App C, when should physical examinations or consultations for reproductive concerns be offered?

Physical exams and consultations for reproductive concerns should be offered when the physician identifies a need—particularly for workers with high BD exposures or those reporting infertility, miscarriages, stillbirths, or other reproductive problems. 1910.1051 App C advises healthcare professionals to provide reproductive-focused assessments when indicated.

Under 1910.1051 App C, are the medical screening and surveillance procedures for BD mandatory regulatory requirements or non-mandatory guidance?

The appendix titled "Medical Screening and Surveillance for 1,3-Butadiene" is non-mandatory guidance that supports compliance with the BD standard; it provides recommended medical program elements rather than binding regulatory text. See 1910.1051 App C and the main BD rule at 1910.1051 for the regulatory requirements.

Under 1910.1051 App C, what should employers do if a worker has a substantial change in CBC but still falls within population-based normal ranges?

If an individual shows a substantial change in their own CBC compared with prior personal measurements — even if still within population norms — clinicians should treat it as potentially abnormal, document and trend it (for example with a flowsheet), and consider further evaluation or removal from BD exposure if clinically indicated. 1910.1051 App C recommends comparing to the employee’s prior CBCs to detect meaningful changes.

Under 1910.1051 App C, who should perform and interpret the medical screening examinations for BD-exposed workers?

Physicians or other licensed health care professionals should perform and interpret the medical screening, and they are responsible for evaluating symptoms of lymphohematopoietic disorders and determining clinical significance of test results. 1910.1051 App C specifies that these licensed professionals handle diagnosis, follow-up and referrals.

Under 1910.1051 App C, what specific surveillance is recommended for workers after an acute exposure who require hospitalization?

Workers who suffer severe acute BD exposures and are hospitalized should receive focused medical management and a CBC within 48 hours, followed by repeat CBCs at one, two, and three months, as recommended in 1910.1051 App C because acute exposures increase the risk of blood abnormalities.