Cadmium exposure health interview

Employers covered by the cadmium construction standard must use or make available the occupational health history interview as part of their medical surveillance program when employees are potentially exposed to cadmium. See 1926.1127AppD and the identical guidance in 1910.1027AppD. Employers with construction activities that create cadmium exposures are subject to the construction cadmium standard and its appendices.

No. The version of Appendix D that applies to construction is identical to Appendix D in the general industry cadmium standard. OSHA explicitly states that "the requirements applicable to construction work under this appendix D are identical to those set forth in [appendix D to 1910.1027]." See 1926.1127AppD and 1910.1027AppD.

Employers should use the cadmium occupational health history interview when conducting medical surveillance examinations required by the cadmium standard—typically at preplacement, periodic (as required by the standard), termination, and any time a licensed health care professional requests additional medical information related to cadmium exposure. See 1926.1127 and the illustrative interview form in 1926.1127AppD. The appendix is intended to help ensure consistent collection of exposure and medical history relevant to cadmium.

Appendix D provides a model occupational health history interview to help comply with the cadmium standard, but it functions as guidance to standardize information collection rather than imposing a single mandatory form; employers may adapt it so long as they obtain the information necessary for competent medical evaluation. See 1926.1127AppD and the corresponding 1910.1027AppD. Employers must still meet all requirements of the cadmium standard in 1926.1127.

A licensed or qualified health care professional (for example, the physician or other licensed health care professional (PLHCP) who conducts the medical surveillance) should review the completed interview to determine needed medical tests, follow-up, and work restrictions. See 1926.1127 and the model form in 1926.1127AppD. The PLHCP uses the history to make clinical and work-placement decisions related to cadmium exposure.

Yes. Medical information gathered under the cadmium standard must be treated as medical records and handled according to the recordkeeping and confidentiality provisions of the cadmium standard and related OSHA record rules; employers must retain employee medical records as required by the standard and make them available to employees and authorized representatives in accordance with OSHA requirements. See 1926.1127 and the interview guidance in 1926.1127AppD. (Employers should also follow record access rules set out elsewhere in OSHA standards when applicable.)

Yes. Employers may translate or format the Appendix D interview to match workforce language needs or recordkeeping systems, provided the adapted interview still captures the exposure, symptom, and medical history information necessary for the licensed health care professional to make appropriate medical determinations under the cadmium standard. See 1926.1127AppD and 1910.1027AppD.

Yes. If the work activities fall within the scope of the construction cadmium standard (for example, remediation, repair, or demolition tasks that generate cadmium exposure), employers must follow the construction requirements and appendices—even if they are not a traditional construction contractor. OSHA has applied construction standards to remediation-type work where the activity matches construction scopes; see OSHA's application of construction asbestos rules in Asbestos remediation protocols and the cadmium construction appendix in 1926.1127AppD.

Employers should provide the completed interview to the PLHCP so the clinician can combine the history with clinical exam results, laboratory values, and exposure information to decide on medical removal, restrictions, or monitoring. The interview is a tool to document symptoms, past occupational exposures, and health history relevant to cadmium and thereby inform the PLHCP's recommendations. See 1926.1127 and 1926.1127AppD.

The model occupational health history interview for cadmium is published in Appendix D of the cadmium construction standard; employers can access it at 1926.1127AppD. The same model also appears in 1910.1027AppD for general industry, and both appendices are identical.

Employers should obtain the occupational health history interview prior to or at the time of the medical examination so the PLHCP can use the information to decide which tests or follow-up are appropriate; the history is part of the medical evaluation process that informs laboratory and clinical testing. See 1926.1127 and the model interview in 1926.1127AppD.

Yes. Any employee (including temporary, part-time, or intermittent workers) who is covered by the cadmium standard because their work tasks create qualifying cadmium exposure must be included in medical surveillance and offered the occupational health history interview as part of that surveillance. See 1926.1127 and the guidance in 1926.1127AppD. Employers are responsible for ensuring all covered employees receive the required surveillance.