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OSHA 1926.1101AppI

Asbestos medical surveillance guidelines

Subpart Z

21 Questions & Answers
10 Interpretations

Questions & Answers

Under 1926.1101 App I, what diseases are linked to occupational asbestos exposure?

Occupational asbestos exposure is linked to lung cancer, pleural and peritoneal mesothelioma, gastrointestinal cancer, and asbestosis. The appendix also notes associations with increased rates of esophageal, kidney, laryngeal, pharyngeal, and buccal cavity cancers.

Under 1926.1101 App I, how long after first exposure do asbestos-related diseases usually appear?

Asbestos-related diseases are typically long-latency and often appear many years after first exposure—commonly about 20 years for most diseases. Mesothelioma has an even longer average latency (about 40 years), while lung cancer often appears after roughly 15–20 years.

  • The appendix explicitly notes the lengthy latency periods and that there are no known acute effects of asbestos exposure: 1926.1101 App I.

Under 1926.1101 App I, are there any acute health effects from asbestos exposure?

No — the appendix states there are no known acute effects associated with asbestos exposure; the health effects are generally chronic and appear many years later.

Under 1926.1101 App I, how does cigarette smoking affect a worker’s risk from asbestos exposure?

Smoking greatly increases the risk of lung cancer for workers exposed to asbestos, and quitting smoking will reduce that risk but not down to the level of someone who was never exposed to asbestos.

  • The appendix explains the synergistic effect between smoking and asbestos exposure and the benefit (but not full risk elimination) of smoking cessation: 1926.1101 App I.

Under 1926.1101 App I, what signs or symptoms should prompt medical follow-up for possible asbestos-related disease?

Shortness of breath, chest pain, abdominal pain (for mesothelioma), persistent cough, unexplained fatigue, and findings on chest X-ray such as pleural plaques, pleural calcification, pleural fibrosis, or small irregular parenchymal opacities should prompt further medical evaluation.

  • The appendix lists these clinical signs and symptoms and notes mesothelioma symptoms and typical radiologic findings: 1926.1101 App I.

Under 1926.1101 App I, what is asbestosis and how is it diagnosed?

Asbestosis is a fibrotic lung disease caused by asbestos fiber accumulation in the lungs; diagnosis is based on an asbestos exposure history, characteristic radiologic abnormalities, end-inspiratory crackles (rales), and other clinical features of pulmonary fibrosis.

  • The appendix provides this definition and diagnostic approach: 1926.1101 App I.

Under 1926.1101 App I, who must receive the employer’s medical surveillance program for asbestos?

The employer must provide a medical surveillance program 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.

Under 1926.1101 App I, who must perform the medical examinations and who pays for them?

All examinations and procedures must be performed by or under the supervision of a licensed physician and must be provided at a reasonable time and place at no cost to the employee.

Under 1926.1101 App I, what specific elements must be included in routine medical examinations for asbestos-exposed employees?

Routine exams must include: (i) medical and work histories with emphasis on respiratory, cardiovascular and digestive symptoms; (ii) completion of the respiratory disease questionnaire in Appendix D of the standard; (iii) a physical exam including a chest X‑ray and pulmonary function test measuring FVC and FEV1; and (iv) any other laboratory or tests the physician deems necessary.

Under 1926.1101 App I, how often must employers make medical surveillance tests available to covered employees?

Employers must make the prescribed medical tests available at least annually, more often if the examining physician recommends it, and upon termination of employment.

Under 1926.1101 App I, what information must the employer provide to the examining physician?

The employer must give the physician a copy of the asbestos standard and its 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 relevant prior medical examination information not otherwise available to the physician.

Under 1926.1101 App I, what must the written medical opinion from the examining physician contain and what must it not contain?

The written opinion must state the results of the examination, whether the employee has any medical conditions that increase risk of exposure-related disease, any recommended work limitations or PPE limitations, and that the employee has been informed of the exam results and any asbestos-related conditions needing follow-up. It must not reveal specific findings or diagnoses unrelated to asbestos exposure. A copy must be provided to the employee.

  • See the written opinion content and confidentiality requirement in 1926.1101 App I.

Under 1926.1101 App I, what should an employer do if the physician identifies that an active employee has been overexposed to asbestos?

If a physician identifies overexposure, the employer should take measures to eliminate or mitigate further exposure so as to lower the risk of serious long-term consequences for the employee.

  • This recommended action is described in 1926.1101 App I; employers must also follow the duties and exposure controls required by 1926.1101.

Under 1926.1101 App I, are chest X-rays and pulmonary function tests useful screening tools for asbestos exposure?

Yes — chest X‑rays and pulmonary function tests may indicate that an employee has been overexposed to asbestos and has increased risk of developing asbestos-related chronic disease, even though there are no adequate screening tests to reliably predict cancers caused by asbestos.

  • The appendix explicitly identifies chest X‑rays and pulmonary function tests as useful indicators: 1926.1101 App I.

Under 1926.1101 App I and OSHA guidance, does asbestos remediation work in residential property-restoration normally fall under the construction asbestos standard?

Yes — asbestos remediation activities involving asbestos-containing building materials performed during property remediation or restoration are covered by OSHA’s construction asbestos standard, 29 CFR 1926.1101, not the general industry asbestos standard.

  • See OSHA’s interpretation clarifying that remediation work involving ACBM is covered by the construction standard: "Asbestos remediation protocols" (OSHA Letter of Interpretation, Nov. 14, 2024) at https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14 and the construction asbestos standard at 1926.1101.

Under 1926.1101 App I, can the examining physician add tests beyond those OSHA prescribes?

Yes — OSHA gives the examining physician broad latitude to prescribe additional laboratory or other tests that the physician deems necessary according to sound medical practice.

  • The appendix states physicians may order any tests they consider necessary: 1926.1101 App I.

Under 1926.1101 App I, must employers provide the medical surveillance examinations at a reasonable time and place?

Yes — examinations and procedures must be performed at a reasonable time and place and must be provided at no cost to the employee.

Under 1926.1101 App I, is an employer required to follow physician recommendations for medical monitoring frequency?

Yes — if the examining physician recommends more frequent testing than annual, the employer is required to make those tests available as recommended.

  • The appendix states employers must provide tests more often than annually if the examining physician recommends it: 1926.1101 App I.

Under 1926.1101 App I and respirator guidance, how do exposure levels affect medical and respiratory protections for asbestos work?

Exposure levels influence both the need for medical surveillance (employer must provide surveillance at or above the PEL of 0.1 f/cc) and the level of respiratory protection required; for certain Class I asbestos tasks, higher measured exposures (for example, exceeding 1 f/cc as an 8‑hour TWA) trigger mandatory use of supplied‑air respirators with auxiliary SCBA, while lower exposures require different respirator options or negative exposure assessments.

  • Medical surveillance PEL guidance is in 1926.1101 App I and respirator selection and exposure thresholds are explained in OSHA’s "Respirator selection for asbestos work" interpretation (Jan. 4, 2024) at https://www.osha.gov/laws-regs/standardinterpretations/2024-01-04 and in 1926.1101.

Under 1926.1101 App I, what role should the physician’s familiarity with workplace conditions play in medical surveillance?

The physician should become familiar with the workplace operating conditions where asbestos exposure can occur because that information is important for evaluating medical and work histories and conducting appropriate physical examinations.

  • The appendix emphasizes the importance of physician familiarity with job conditions: 1926.1101 App I.

Under 1926.1101 App I, must the employer give the employee a copy of the physician’s written opinion?

Yes — the employer must provide a copy of the physician’s written opinion to the affected employee.

  • See the requirement for providing the written opinion to the employee in 1926.1101 App I.