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OSHA 1928.1027

Cadmium in agriculture

Subpart M

19 Questions & Answers
10 Interpretations

Questions & Answers

Under 1928.1027 (Cadmium), what standard applies to protecting agricultural workers from cadmium exposure?

The cadmium protection requirements for agriculture are the same as those in the general industry cadmium standard: employers must follow 1910.1027.

  • 1928.1027 explicitly directs agricultural workplaces to comply with the cadmium provisions in 1910.1027.

Under 1910.1027 and 1928.1027, when does the cadmium standard apply in an agricultural workplace?

The cadmium standard applies when workers in agricultural operations may be exposed to cadmium through any activity (for example: handling fertilizers, soil amendments, or materials that contain cadmium). Employers must assess and control those exposures under 1910.1027, as referenced by 1928.1027.

  • If cadmium is present where employees work or could become airborne during tasks, the employer must treat the situation as a potential exposure under the cadmium standard.

Under 1910.1027, what must an agricultural employer do to find out whether workers are exposed to cadmium?

The employer must evaluate worker exposures by conducting exposure monitoring (air sampling) using valid methods and procedures in accordance with 1910.1027.

  • Initial monitoring is required to determine employee exposure levels.
  • If monitoring shows exposures above specified levels the standard requires periodic follow-up monitoring.
  • Use accurate, validated sampling and analytical methods as specified in the cadmium standard.

Under 1910.1027, what control measures must be used if agricultural worker cadmium exposure is too high?

Employers must first try to reduce cadmium exposure with engineering and work-practice controls, and if those do not lower exposures enough they must provide appropriate respiratory protection and other protective measures required by 1910.1027.

  • Engineering controls (ventilation, process enclosure) and safe work practices are the preferred methods.
  • Where controls cannot reduce exposure to required limits, the standard requires employers to supplement them with respiratory protection and other protective equipment as specified in 1910.1027.

Under 1910.1027, when must an employer provide medical surveillance to agricultural employees who may be exposed to cadmium?

Employers must provide medical surveillance when employee exposure meets the triggers set out in 1910.1027, for example when monitoring indicates exposures at or above the standard’s action level or when workers are assigned to respirators for cadmium exposures.

  • The cadmium standard details the conditions that trigger baseline and periodic medical exams and biological monitoring; follow those provisions in 1910.1027.

Under 1910.1027, does the cadmium standard require biological monitoring (blood or urine tests) for agricultural workers?

Yes. The cadmium standard requires biological monitoring when the standard’s conditions are met; employers must provide the tests and follow the schedules and actions set out in 1910.1027.

  • Biological monitoring (for example, blood or urine cadmium measurements) is used to detect internal uptake and to guide medical and work-placement decisions as specified in 1910.1027.

Under 1910.1027, what training must employers give agricultural employees about cadmium?

Employers must train employees about cadmium hazards, how exposures occur, required protective measures, monitoring results, symptoms, and emergency procedures as required by 1910.1027.

  • Training should be in a language and at a level workers understand and must be provided before initial assignment where exposures may occur and periodically afterward, per the standard.

Under 1910.1027, are agricultural employers required to provide and maintain protective clothing and facilities (washrooms, change rooms) for cadmium work?

Yes. The cadmium standard requires employers to provide appropriate protective clothing and to supply washing and changing facilities to prevent take-home contamination and skin exposure, as set out in 1910.1027.

  • Employers must ensure contaminated clothing is not taken home and must provide laundering or cleaning as required by the standard.

Under 1910.1027, what respiratory protection obligations do agricultural employers have when cadmium controls are insufficient?

When engineering and work-practice controls cannot reduce cadmium exposure to required levels, employers must provide appropriate respirators and a respiratory protection program as required in 1910.1027.

  • The cadmium standard requires use of respirators where controls are inadequate and specifies conditions for when respirators are required; employers must follow the program and exposure-determined respiratory assignments described in 1910.1027.

Under 1910.1027, do agricultural employers need to restrict eating, drinking, or smoking in areas where cadmium exposure may occur?

Yes. Employers must prohibit eating, drinking, smoking, chewing tobacco, or applying cosmetics in areas where cadmium exposure may occur and must provide clean areas for these activities as required in 1910.1027.

  • This is a standard hygiene control to prevent ingestion of cadmium and is described in the provisions of 1910.1027.

Under 1910.1027, what recordkeeping must agricultural employers keep for cadmium exposures and medical surveillance?

Employers must keep exposure monitoring results, employee medical records, and other records required by the cadmium standard as specified in 1910.1027.

  • The standard sets retention periods and access requirements for these records; follow the recordkeeping provisions in 1910.1027.

Under 1910.1027, how should agricultural employers manage contaminated waste or residues that contain cadmium?

Employers must manage cadmium-containing materials and residues to minimize worker exposure during handling, storage, and disposal and must follow the exposure control and safe-handling requirements in 1910.1027.

  • While disposal methods and environmental rules may also fall under EPA or state agency requirements, OSHA’s concern is preventing worker exposures during handling and cleanup; follow the safe work-practice, PPE, and hygiene provisions in 1910.1027.

Under 1910.1027, are contractors or temporary workers on farms covered by the cadmium standard?

Yes. Any employee—direct hire, temporary, or contractor—who is exposed to cadmium in the workplace is covered by the protections and requirements of 1910.1027, as the agricultural employer must ensure exposures are evaluated and controls are in place.

  • Host employers and contractors should coordinate to ensure monitoring, training, PPE, and medical surveillance obligations are met under the cadmium standard.

Under 1910.1027, when must an agricultural employer use signs or labels to notify workers about cadmium hazards?

The cadmium standard requires employers to communicate hazards and to post warnings or use labels where necessary to identify cadmium hazards and restricted areas, as described in 1910.1027.

  • Use clear signage and labeling to prevent unauthorized entry into high‑exposure areas and to inform employees of controls and PPE requirements in accordance with the standard.

Under 1910.1027, what should an agricultural employer do after discovering an accidental cadmium release or high-exposure incident?

The employer must take immediate steps to protect employees—remove them from the area if needed, provide first aid/medical attention, decontaminate personnel and surfaces, perform exposure monitoring, and implement corrective controls as required by 1910.1027.

  • The standard requires prompt action to prevent further exposure and to document and correct the cause of the incident per the provisions of 1910.1027.

Under 1928.1027 and 1910.1027, do normal farming tasks like spreading soil amendments containing cadmium require special controls?

If those tasks create airborne cadmium or otherwise expose workers, the employer must evaluate exposures and implement the controls and protections required by 1910.1027, as referenced by 1928.1027.

  • Routine farm activities that do not create worker exposure are not subject to unnecessary controls, but if handling or application can generate exposure the cadmium standard applies and the employer must follow its monitoring, controls, and hygiene provisions.

Under 1910.1027, how often must exposure monitoring be repeated for agricultural workers when cadmium exposures are near regulated levels?

The cadmium standard requires follow-up monitoring on a schedule set out in 1910.1027 whenever initial monitoring shows exposures at or above the standard’s action or permissible levels.

  • The standard specifies when periodic re-monitoring is required; consult 1910.1027 for the exact frequency and triggers.

Under 1910.1027, who must the agricultural employer notify about cadmium monitoring and medical results?

Employers must inform affected employees of monitoring results and provide medical examination results to the examined employee and to the responsible medical professional as required by 1910.1027.

  • The standard requires timely communication of exposure data, biological monitoring and medical findings to protect employees and to support any work-placement or removal decisions specified by the medical surveillance provisions in 1910.1027.

Under 1910.1027, can agricultural employers rely solely on personal protective clothing instead of engineering controls to limit cadmium exposure?

No. The standard requires employers to implement feasible engineering and work-practice controls first; PPE (including protective clothing) is required when those controls cannot adequately reduce exposure, as described in 1910.1027.

  • PPE is a supplemental control, not a substitute for feasible engineering controls, consistent with the control hierarchy in 1910.1027.