Program checklist
OSHA medical surveillance: a checklist for running the programs.
Each OSHA standard sets its own trigger and schedule. Surveillance programs fail on the operational details: who is enrolled, when they are due, and whether anyone notices the ones who slipped.
By ClinicMira · Last reviewed September 25, 2026
This checklist summarizes common federal OSHA surveillance requirements to help occupational health providers plan their programs. It is not legal advice. State plans can add requirements, the linked standards are the source of truth, and clinical decisions rest with the responsible professionals.
The requirements at a glance
| Program | Who is covered | Exams and timing |
|---|---|---|
| Respirator use 29 CFR 1910.134(e) | Employees required to use a respirator. | Medical evaluation before fit testing or first use; re-evaluate when triggers occur (symptoms, a clinician's advice, changed conditions). Fit testing for tight-fitting respirators before use and at least annually. |
| Hearing conservation 29 CFR 1910.95 | Exposure at or above 85 dBA as an 8-hour average. | Baseline audiogram within 6 months of first exposure (1 year with mobile test vans, with hearing protectors after 6 months), after at least 14 hours without workplace noise; then annually. |
| Respirable crystalline silica 29 CFR 1910.1053 / 1926.1153 | General industry: at or above the 25 µg/m³ action level for 30+ days a year. Construction: required to wear a respirator for 30+ days a year. | Initial exam within 30 days of assignment (unless a qualifying exam was done in the last 3 years); then at least every 3 years. |
| Asbestos 29 CFR 1910.1001(l) | Exposure at or above 0.1 f/cc as an 8-hour average and/or the excursion limit. | Pre-placement exam, then annually, and within 30 days of leaving employment. |
| Lead 29 CFR 1910.1025(j) | At or above the 30 µg/m³ action level for more than 30 days a year. | Blood lead and ZPP at least every 6 months (every 2 months at 40 µg/100 g or higher); exam before assignment, and annually if any blood lead in the past 12 months was 40 or higher. |
| Bloodborne pathogens 29 CFR 1910.1030(f) | Employees with occupational exposure. | Hepatitis B vaccination offered free after training and within 10 working days of initial assignment; declinations signed on the Appendix A statement. |
Easy things to get wrong
- Respirator fit testing is annual; the respirator medical evaluation is not. It is repeated when a trigger occurs.
- Silica enrollment is triggered differently in general industry (exposure at the action level) and construction (required respirator use).
- OSHA has proposed easing some respirator, lead and asbestos evaluation requirements, but those proposals are not final. The current standards still apply.
A checklist for running the programs
- Keep an exposure register per employer and worksite, so enrollment follows the standard's trigger rather than memory.
- Record each worker's baseline and the date the next exam is due, by program.
- Book recalls ahead of the due date and chase the ones that slip, with the employer kept informed.
- Use exposure-specific questionnaires and forms, and compare results against the worker's baseline at clinical review.
- Report to employers only what they are entitled to see, and keep the full clinical record with the provider.
- Retain records for the long term: OSHA's records standard (1910.1020) requires employee medical records to be kept for the duration of employment plus 30 years.
- Review program-level reports regularly: who is overdue, which sites are behind, and which results need follow-up.
See how ClinicMira runs medical surveillance programs with exposure-specific forms, recalls and longitudinal worker histories.