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OSHA 1915.1001AppD

Mandatory medical questionnaires

Subpart Z

24 Questions & Answers
10 Interpretations

Questions & Answers

Under 1915.1001AppD, who must be given the Initial Medical Questionnaire?

All new hires who will be covered by the medical surveillance program because they are exposed above the asbestos PEL must be given the Initial Medical Questionnaire. See the mandatory Appendix D requirement in 1915.1001AppD and the medical surveillance rule in 1915.1001.

Under 1915.1001AppD, when must the Initial Medical Questionnaire be obtained for new employees?

The Initial Medical Questionnaire must be obtained when a new hire will be covered by the asbestos medical surveillance requirements—i.e., before or at the time they enter the surveillance program. This is specified in the mandatory Appendix D to 1915.1001 and ties to the medical surveillance provisions in 1915.1001.

Under 1915.1001AppD, who must receive the Periodic (abbreviated) Medical Questionnaire?

Every employee provided periodic medical examinations under the asbestos medical surveillance program must be administered the abbreviated Periodic Medical Questionnaire. Appendix D makes the periodic form mandatory for workers receiving periodic exams—see 1915.1001AppD and the main surveillance rule at 1915.1001.

Under 1915.1001AppD, which minerals and situations trigger use of these mandatory medical questionnaires?

The mandatory questionnaires apply when employees are exposed to asbestos, tremolite, anthophyllite, actinolite, or any combination of these minerals above the permissible exposure limit and are therefore included in medical surveillance. That scope is stated in 1915.1001AppD and is part of the medical surveillance requirements in 1915.1001.

Under 1915.1001AppD, what airborne concentration of asbestos triggers inclusion in the medical surveillance program (and thus these questionnaires)?

Employees exposed above 0.1 fibers per cubic centimeter (0.1 f/cc) are the ones covered by the surveillance program and must be given the questionnaires. Appendix D makes clear the threshold for inclusion is exposure above the PEL of 0.1 f/cc; see 1915.1001AppD and the surveillance provisions in 1915.1001.

Under 1915.1001AppD, may an employer change the wording or remove questions from the mandatory questionnaires?

No — the Appendix D questionnaires are mandatory and must be administered; employers should not delete required items or alter their intent. Appendix D is described as "mandatory" and contains the specific Initial and Periodic Medical Questionnaires that must be used for employees covered by medical surveillance (1915.1001AppD).

Under 1915.1001AppD, is an employee signature required on the Initial Medical Questionnaire?

Yes — the Initial Medical Questionnaire includes a place for the employee’s signature and date, so the form should be signed where indicated. That signature line appears on the Appendix D form (1915.1001AppD).

Under 1915.1001AppD, can the Initial Medical Questionnaire be completed orally by an interviewer instead of the employee writing answers?

Yes — the form includes an "Interviewer" field and is commonly administered by an interviewer when needed, so oral administration with answers recorded by the interviewer is acceptable provided all required questions are captured accurately. Appendix D itself contains an "Interviewer" entry and is intended to be administered as part of the surveillance process (1915.1001AppD).

Under 1915.1001AppD and 1915.1001, who is allowed to administer the questionnaire and review the responses?

The questionnaire may be administered by an interviewer or health professional and the responses should be reviewed by the medical provider (physician or other licensed health care professional) responsible for the medical surveillance. Appendix D includes an "Interviewer" field, and the broader medical surveillance and exam requirements are set out in 1915.1001 and the mandatory form in 1915.1001AppD.

Under 1915.1001AppD, does an employer need to provide the questionnaire in a language the employee understands?

Yes — employers must ensure the employee understands and can meaningfully respond to the mandatory medical questions, so providing translation or interpretation is necessary when the employee does not understand the questionnaire language. Appendix D is mandatory and must be administered to covered employees (1915.1001AppD), and the medical surveillance duties in 1915.1001 require practical, understandable administration of medical evaluations.

Under 1915.1001AppD, how often must the Periodic Medical Questionnaire be given?

The Periodic Medical Questionnaire must be administered whenever an employee is provided a periodic medical examination under the asbestos surveillance provisions — i.e., at each periodic medical surveillance encounter mandated by 1915.1001. Appendix D provides the abbreviated Periodic form to be used in those periodic examinations (1915.1001AppD).

Under 1915.1001AppD, does the Initial Medical Questionnaire ask about smoking and tobacco history?

Yes — the Initial Medical Questionnaire contains multiple detailed items on cigarette, pipe, and cigar smoking, including age started/stopped and quantities, so tobacco history must be collected. See the tobacco section of the Appendix D form (1915.1001AppD).

Under 1915.1001AppD, are detailed occupational history questions required on the form?

Yes — the Initial Medical Questionnaire includes detailed occupational history (past jobs, dusty jobs, exposure to asbestos, mines/quarries/foundries, usual occupation and years worked), and those items are part of the mandatory form. See the occupational history section in 1915.1001AppD.

Under 1915.1001AppD and related guidance, can employers use past medical questionnaires from a previous employer instead of giving the Initial Medical Questionnaire?

Only if the prior questionnaire fully covers the mandatory items; otherwise the employer must obtain the required Initial Medical Questionnaire for new hires who are covered by surveillance. Appendix D requires the Initial Medical Questionnaire for new hires (1915.1001AppD), so an existing equivalent questionnaire can be used only if it contains all required questions and is documented as meeting Appendix D content.

Under 1915.1001AppD, does the form include family medical history questions and must those be asked?

Yes — Appendix D includes family history items (Question 30 asks about parents told by a doctor that they had chronic lung conditions), and those mandatory items must be administered as part of the Initial Medical Questionnaire (1915.1001AppD).

Under 1915.1001AppD, does the questionnaire ask about prior chest X-rays and their results?

Yes — the Initial Medical Questionnaire contains questions asking when and where the employee last had a chest X-ray and what the outcome was (Questions 28 and 29), and those items must be completed (1915.1001AppD).

Under 1915.1001AppD, are the cough, phlegm, wheeze, and breathlessness sections required parts of the questionnaire?

Yes — Appendix D contains detailed sections on cough, phlegm, episodes of cough/phlegm, wheezing, and breathlessness (Questions 31–37), and those clinical symptom questions are required on the form for covered employees (1915.1001AppD).

Under 1915.1001AppD and 1915.1001, are employee questionnaire responses considered confidential medical records?

Yes — questionnaire responses used in medical surveillance are part of the employee's medical information and must be handled consistent with OSHA medical record requirements and confidentiality practices in the medical surveillance provisions of 1915.1001; Appendix D provides the mandatory content to collect (1915.1001AppD).

Under 1915.1001AppD, if an employee refuses to answer parts of the mandatory questionnaire, what should the employer do?

The employer should document the refusal and obtain the required information by other reasonable means (for example, through an interviewer or medical exam) because the Initial and Periodic Questionnaires are mandatory for surveillance-covered employees. Appendix D is mandatory for employees in the surveillance program (1915.1001AppD) and the broader medical surveillance duties are set out in 1915.1001.

Under 1915.1001AppD, may questionnaire answers be used to place an employee on work restrictions without medical review?

No — questionnaire answers inform the medical evaluation, but any work restrictions or fitness determinations must be made by the medical professional performing the surveillance (physician or other licensed health care professional) as provided in 1915.1001; Appendix D is intended to gather the information the clinician needs (1915.1001AppD).

Under 1915.1001AppD, does the mandatory questionnaire apply when a bulk material test shows 1% asbestos in a material?

Not automatically — Appendix D applies when the employee’s airborne exposure is above the PEL (0.1 f/cc) and the employee is included in medical surveillance; a bulk determination of 1% asbestos triggers asbestos control requirements for materials but does not by itself define airborne exposure. OSHA has explained that bulk results and ACM classifications are separate from exposure-based surveillance decisions; see the Appendix D surveillance requirement (1915.1001AppD) and OSHA discussion about point counting/bulk analysis and regulatory triggers in the letter on asbestos point counting regulations (https://www.osha.gov/laws-regs/standardinterpretations/2014-11-05-1).

Under 1915.1001AppD and OSHA guidance, can employers rely on non‑OSHA sampling protocols to decide who needs the questionnaires?

Employers must base surveillance decisions on reliable exposure data; OSHA does not endorse or approve proprietary sampling protocols as "objective data" for exposure determinations, so employers should use accepted exposure assessment methods when deciding who needs surveillance. See the requirement for the mandatory questionnaires in 1915.1001AppD and OSHA's guidance that it does not approve specific asbestos sampling protocols in the letter on asbestos sampling protocol requirements (https://www.osha.gov/laws-regs/standardinterpretations/2015-10-07).

Under 1915.1001AppD, does the Periodic Medical Questionnaire cover new medical conditions that developed in the past year?

Yes — the Periodic Medical Questionnaire includes recent medical history items (e.g., development of epilepsy, diabetes, jaundice, cancer) and is intended to capture new conditions since the last exam; that abbreviated periodic form is in 1915.1001AppD and ties into ongoing surveillance in 1915.1001.

Under 1915.1001AppD, what should an employer do if an employee has a history of dusty jobs or previous asbestos work?

The employer should record the detailed occupational history in the Initial Medical Questionnaire (jobs, years, dusty job history, prior asbestos work) so the medical reviewer can assess cumulative exposure and health risk; Appendix D requires those occupational history items (1915.1001AppD).