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Safety Blog

Chemical Hygiene Program: Employee Medical Exam and Consultation

By Ken Roy

Posted on 2022-06-01

Chemical Hazards and Risks

Science and STEM laboratories can be unsafe teaching and learning sites, especially given the potential chemical hazards and resulting health and safety risks. In response, the Occupational Safety and Health Administration (OSHA) requires employers to meet the requirements of the Medical and First Aid standard (29 CFR 1910.151). The employer must provide medical and first-aid personnel, and supplies commensurate with the workplace hazards. The details of a workplace medical and first-aid program depend on the circumstances of each workplace and employer. The complete 29 CFR 1910.151 standard can be found at

OSHA also provides two resources on First Aid including the following:

Best Practice Guide: Fundamentals of a Workplace First Aid Program, publication 3317

Medical and First Aid

Follow-Up Medical Attention

In addition to medical first aid, OSHA addresses resulting medical attention in their Occupational Exposure to Hazardous Chemicals in Laboratories standard (a.k.a. OSHA Laboratory Standard; 29 CFR 1910.1450). The standard states the following:

“The employer shall provide all employees who work with hazardous chemicals an opportunity to receive medical attention, including any follow-up examinations which the examining physician determines to be necessary, under the following circumstances:

  • When an employee develops signs or symptoms associated with a hazardous chemical to which that employee may have been exposed;
  • Where exposure monitoring reveals an exposure level routinely above the action level or Permissible Exposure Limit (PEL) for an OSHA-regulated substance; and
  • Whenever an event takes place in the work area such as a spill, leak, or explosion resulting in the likelihood of a hazardous exposure.”

Teachers and supervisors should note that this standard does stipulate that the employer must provide employees working with hazardous chemicals the opportunity to receive medical attention. That would include follow-up examinations, under certain circumstances. Those circumstances include the following:

I.     When an employee develops signs or symptoms associated with a hazardous chemical to which the employee may have been exposed in the laboratory; 
II.     When exposure monitoring reveals an exposure level routinely above the Action Level, or in the absence of an Action Level, the PEL; 
III.     When a substance is regulated by OSHA and requires exposure monitoring and/or medical surveillance regardless of exposure level; and 
IV.     When an event takes place in the work area resulting in the likelihood of a hazardous exposure (spill, leak, explosion, or other situation).

The medical examination and consultations must be performed by or under the supervision of a licensed physician with no cost to the employee. This includes no loss of pay and at a reasonable time and place. A written opinion shall be obtained from the physician. In this instance, the employer is required to provide the following information to the physician:

  1. Identify the hazardous chemical(s) to which the employee has been exposed.
  2. Describe the conditions under which the exposure occurred.
  3. Describe any signs and symptoms the employee is experiencing.

Once the employee is examined by the physician, the employer is entitled to a written opinion that must include this information:

  1. Recommendations for further medical action;
  2. Results of examination and any tests associated with the activity;
  3. Information about any medical condition revealed during the examination that may place the employee at increased risk as a result of exposure in the workplace;
  4. Statement that the employee was informed by the physician of the  examination results, including any medical condition requiring further inquiry or treatment; and
  5. The physician’s opinion cannot reveal specific findings unrelated to the occupational exposure.

Final Thought

Science/STEM teachers should also be aware that the science supervisor or Chemical Hygiene Officer (CHO) may represent the employer when the employee requires medical assistance. The employer’s representative takes an active role in facilitating medical examinations for employees. The employer needs to provide clear guidelines or standard operating procedures relative to their responsibilities in these cases. This information should be noted in the school’s Chemical Hygiene Plan.

Submit questions regarding safety to Ken Roy at

Follow Ken Roy on Twitter: @drroysafersci.

Administration General Science Safety Middle School High School Postsecondary

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