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29 CFR 1926.1153

Respirable Crystalline Silica Medical Surveillance

OSHA's construction silica standard requires you to offer medical surveillance to any employee who wears a respirator for silica exposure on 30 or more days in a year. Not 30 days of exposure - 30 days of respirator use. That distinction…

Who has to be offered it

OSHA's construction silica standard requires you to offer medical surveillance to any employee who wears a respirator for silica exposure on 30 or more days in a year. Not 30 days of exposure - 30 days of respirator use. That distinction catches people out, because crews doing intermittent cutting, grinding or drilling often cross the threshold without anyone tracking it. If you are not counting respirator days, you do not yet know whether you owe this.

What the exam actually includes

A work and medical history covering respiratory symptoms and past dust exposure. A physical examination with emphasis on the respiratory system. A chest x-ray read by a NIOSH B Reader. A spirometry test administered by a technician with a current NIOSH course certificate. A tuberculosis test at the initial exam. And any other test the examining physician judges necessary. The standard sets that list - we do not shorten it.

The written medical opinion, and what your copy contains

Within 30 days, the PLHCP issues a written medical opinion. Yours names the date of the exam, states whether the employee has any detected medical condition that places them at increased risk from further silica exposure, and lists any recommended limitations on respirator use. It does NOT contain the employee's diagnosis or test results unless the employee gives written authorisation. Employers sometimes expect the full report; the standard deliberately does not give it to you.

Frequency, and the part people forget

Initial exam within 30 days of assignment unless the employee has had an equivalent exam in the previous three years, then every three years thereafter. The forgotten part is that the offer must be documented even when declined. An employee who refuses is not a violation. An employee who was never offered is.

How we run it on an active site

The mobile unit needs a level parking area roughly the size of two spaces and a 20-amp circuit, or we run off our own generator. Spirometry needs the subject reasonably rested, so we do not schedule crews straight off a shift of heavy exertion if it can be avoided. Expect about 25 minutes per person, and tell us the shift pattern in advance - we would rather build the day around your pours than around our convenience.

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Sources

Primary regulations and standards referenced above. Where a standard is published commercially it is named in full rather than linked to a copy.