Medical Surveillance – Construction
We’re wrapping up the remainder of the requirements. We’ve addressed the majority of the requirements in the first six segments, but there are a few additional things to cover.
Medical Surveillance – Physical Exam
This one seems simple, or so it appears. Employees who are doing silica work need to get a physical examination. Most occupational clinics should be able to handle this. At first glance, this is correct; however, there are several tests that the physical exam must include, and it’s the employer’s responsibility (not the physician’s responsibility) to make sure these tests are completed. The difficulty with this is that you, the employer, do not have access to the employee’s test results – that’s confidential information. All you receive from the medical provider is a statement indicating that the exam was completed, all required tests were conducted, and whether or not the employee can wear a respirator.
Employees Who Need a Physical
Employees who will be required to wear a respirator for 30 or more days per year (12-month period) because of silica work must be offered a silica physical exam. The employee can refuse, but he/she must be offered one. Additionally, the requirement states that the exam must be offered at no cost to the employee. This means that the employee is on the clock while taking the exam, and the exam cost is completely the employer’s responsibility.
What You Need to Provide the Physician
Remember, the silica standard will be new to the medical community too. Your regular occupational medical center may or may not know the silica requirements. This will change with time, so check with your medical provider to make sure they know what’s required for a silica physical exam. If they don’t know, forward them a copy of the OSHA Silica Standard (29 CFR 1926.1153).
When you send an employee for a physical, you need to send with him:
- A description of the employee’s duties related to silica. That is, what the employee will be doing.
- What the employee’s exposure level (or anticipated exposure) is or will be.
- What personal protective equipment (respirator, hard hat, safety glasses, etc.) the employee will wear and how long the employee will wear it (e.g., 6 hours per day, 10 hours per day, etc.)
- Any other employment-related medical exams that you have provided to the employee. For example, if you give your employees pre-employment physicals, that needs to be provided to the physician.
Develop a checklist for the silica physical exams. This checklist would be another appendix to the Silica Plan discussed in a previous post. Also in this appendix would be the physical exam results you receive from the physician for each employee.
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