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HAZMAT Team members MUST have an EXIT PHYSICAL PDF Print E-mail
Safety Info Posts - Emergency Response
Written by Bryan Haywood   
Monday, 02 April 2012 18:36

This is NOT an April Fool's joke, but a fact.  It is not a well known requirement, but we have seen OSHA use this from time to time when teams have been disbanded - me being one of those they used to make an example of.  But 1910.120(q)(9) refers us back to 1910.120(f) in regards to medical evaluations team members must receive.  And 1910.120 (q)(9) and (f) state...

parts highlighted in red are critical - the sections below are not in alphabetical order on purpose as this is how the sections would flow for fixed industrial facilities...

Medical surveillance and consultation.
1910.120(q)(9)(i) Members of an organized and designated HAZMAT team and hazardous materials specialist shall receive a baseline physical examination and be provided with medical surveillance as required in paragraph (f) of this section.
1910.120(q)(9)(ii) Any emergency response employees who exhibit signs or symptoms which may have resulted from exposure to hazardous substances during the course of an emergency incident either immediately or subsequently, shall be provided with medical consultation as required in paragraph (f)(3)(ii) of this section.

Medical surveillance --
1910.120(f)(1) General. Employees engaged in operations specified in paragraphs (a)(1)(i) through (a)(1)(iv) of this section and not covered by (a)(2)(iii) exceptions and employers of employees specified in paragraph (q)(9) shall institute a medical surveillance program in accordance with this paragraph.

1910.120(f)(2) Employees covered. The medical surveillance program shall be instituted by the employer for the following employees:
1910.120(f)(2)(i) All employees who are or may be exposed to hazardous substances or health hazards at or above the established permissible exposure limit, above the published exposure levels for these substances, without regard to the use of respirators, for 30 days or more a year;
1910.120(f)(2)(ii) All employees who wear a respirator for 30 days or more a year or as required by 1910.134;
1910.120(f)(2)(iii) All employees who are injured, become ill or develop signs or symptoms due to possible overexposure involving hazardous substances or health hazards from an emergency response or hazardous waste operation; and
1910.120(f)(2)(iv) Members of HAZMAT teams.

1910.120(f)(3) Frequency of medical examinations and consultations. Medical examinations and consultations shall be made available by the employer to each employee covered under paragraph (f)(2) of this section on the following schedules:
1910.120(f)(3)(i) For employees covered under paragraphs (f)(2)(i), (f)(2)(ii), and (f)(2)(iv);
1910.120(f)(3)(i)(A) Prior to assignment;
1910.120(f)(3)(i)(B) At least once every twelve months for each employee covered unless the attending physician believes a longer interval (not greater than biennially) is appropriate;
1910.120(f)(3)(i)(C) At termination of employment or reassignment to an area where the employee would not be covered if the employee has not had an examination within the last six months.
1910.120(f)(3)(i)(D) As soon as possible upon notification by an employee that the employee has developed signs or symptoms indicating possible overexposure to hazardous substances or health hazards, or that the employee has been injured or exposed above the permissible exposure limits or published exposure levels in an emergency situation;
1910.120(f)(3)(i)(E) At more frequent times, if the examining physician determines that an increased frequency of examination is medically necessary.

Click Here for all of 1910.120

The only times I have seen OSHA use this is when management disbands the team because of lack of participation and the response team is being used as a political tool by the workforce.  Someone calls OSHA to complain and OSHA comes in an "educates management" (e.g. me and other safety managers!)  But it is a requirement and if we think about it, this is just another requirement that demonstrates why tightly managing our response teams is a very good idea.  Any team with a lot of turn-over is a concern, but as evident by this requirement it can be costly as well.  We invest around $10,000 per HAZMAT team member when we break down all the testing, training, and equipping them.  Annual physicals, fit tests, and training can add up quickly and if we have members quitting we can DOUBLE our costs for the physicals as we have to provide the exiting member a physical (if there last one was over six months ago) AND provide their replacement with a physical.  And as I have written before, these HAZMAT and Fire Brigade physicals MUST BE MORE THAN respirator physicals to meet the HAZWOPER requirements.  Please see my other articles in the Emergency Response Section regarding medical, testing, and training requirements.



#2 Bryan 2012-04-04 20:57
the requirements are in no way based on expsoure vs. no expsoure. That is covered in 1910.120(f)(2)(iii).
1910.120(f)(2)(iv) is a stand alone requirement and is not based on exposures.

Here is what the CPL states:
Medical Surveillance and Consultation – 1910.120(q)(9). Paragraph (q)(9)(i) requires that members of an organized and designated HAZMAT team and HAZMAT specialists receive a baseline physical examination and medical surveillance in accordance with paragraph (f). A HAZMAT team refers to a group of individuals who are expected to control actual or potential leaks or spills of hazardous substances requiring close approach to the substance. Examinations must be provided prior to initial assignment, at least yearly thereafter, and at termination of employment. Medical examinations must also be provided in cases where employees are injured or develop signs or symptoms of overexposure to health hazards.
#1 Jeff Z 2012-04-04 20:40
It is my understanding that an exit physical is only required for those members who have only participated in a response. As stated in the standard, physicals are required if an exposure occurs. The employer would have a defensible position if they could demonstrate this fact.

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