Employers use work physicals, medical screening, and medical surveillance in jobs with physical demands or hazardous exposure, but these terms are often mixed together. OSHA only requires medical action when a specific hazard or exposure exists, which may involve a one time medical evaluation or ongoing medical surveillance.
Do OSHA Regulations Require Work Physicals?
OSHA sets workplace safety standards. It does not approve healthcare providers, certify employees, or mandate general employment physicals. Most OSHA requirements focus on hazard control, training, and how work is performed.
Certain OSHA standards do require medical evaluations. These requirements are hazard based and written directly into the standard. In some cases, the requirement is a one time medical evaluation. In other cases, the standard requires ongoing medical surveillance tied to continued exposure. These evaluations are job related and limited in scope.
When a standard requires medical evaluation or medical surveillance, the employer is responsible for implementing it. OSHA expectations come from hazards, not job titles. Employers may choose to use work physicals more broadly, but when a standard requires medical review, it is mandatory.
When Employers Are Expected to Use Each
Employers rely on different types of medical assessments depending on the hazard and the purpose.
Work physicals and one time medical evaluations are commonly used pre employment, post offer, or when an employee is returning to work after injury or illness. These evaluations answer a limited question: can the employee safely perform the defined job tasks at the time of the evaluation?
Medical screening is often required before employees participate in certain programs or tasks, such as respirator use or confined space entry. In OSHA standards, this is typically referred to as a medical evaluation and is intended to identify conditions that could make the task unsafe.
Medical surveillance is ongoing and exposure based. It is required by specific OSHA standards when employees are exposed to certain hazards over time. Medical surveillance may include baseline examinations, periodic follow up exams, biological monitoring, trend analysis, and review by a licensed healthcare professional.
Job Specific Physical Requirements
Work physicals and medical evaluations should be based on actual job demands. Employers need to understand the physical and environmental requirements of the job before sending an employee for evaluation. An evaluation might address:
- Lifting, pushing, force requirements
- Balance, movement, range of motion
- Endurance for extended tasks or shifts
- Vision / hearing needs related to the work
- Respiratory capacity when airborne hazards are present
Generic physicals often miss these details. Evaluations tied to real job tasks provide clearer guidance and better placement decisions.
OSHA Standards that Trigger Medical Screening and Medical Surveillance
Several OSHA standards include medical evaluation or medical surveillance requirements as part of compliance. These requirements are hazard specific. Here are some examples:
- 29 CFR 1910.134 – Respiratory Protection: Requires a medical evaluation before respirator use and when conditions change.
- 29 CFR 1910.1001 – Asbestos: Requires ongoing medical surveillance for employees exposed above action levels.
- 29 CFR 1910.1025 – Lead: Requires baseline and periodic medical surveillance based on exposure.
- 29 CFR 1910.1450 – Occupational Exposure to Hazardous Chemicals in Laboratories: Requires medical consultation and examinations under defined conditions.
Respiratory protection programs are often the first place employers encounter required medical evaluations. Chemical exposure standards are where medical surveillance is most commonly required.
DOT regulated positions are governed by separate federal rules. Non DOT positions remain subject to OSHA standards and employer policy.
Employer Responsibilities During the Medical Evaluation Process
Employers are responsible for defining job demands and hazard exposures. Incomplete or vague job information leads to ineffective medical evaluations.
Healthcare providers should be given task descriptions, exposure details, and required PPE. (Job titles alone aren’t sufficient.)
Medical information must remain confidential. Employers should receive only a written determination of fitness for duty and any work restrictions, as permitted by the applicable standard.
When medical surveillance is required, employers must ensure evaluations are conducted at the required frequency, written medical opinions are reviewed, and followup actions are taken when indicated.
Medical evaluations and surveillance results should be used to support safe job placement and task assignment. They should not be used as a substitute for hazard control.
What Work Physicals Do Not Replace
Work physicals and medical surveillance do not replace:
- OSHA safety training
- Engineering and administrative controls
- Safe work procedures
- Supervision and enforcement
Medical evaluation does not eliminate hazards. It only determines whether an employee can perform work as designed.
Employer Recordkeeping Responsibilities
Recordkeeping is a fairly frequent problem. Under 29 CFR 1910.1020, employers must retain employee medical and exposure records. In most cases, these records must be maintained for the duration of employment plus 30 years, with limited exceptions. Employees have specific rights to access these records.
Incomplete/missing/improperly retained records can result in OSHA citations even when medical evaluations were performed correctly.
How Work Physicals, Medical Screening, and Medical Surveillance Fit into a Larger Safety Program
Work physicals, medical screening, and medical surveillance are tools within a larger safety program. When used correctly, they support job placement and help identify early signs of exposure related health effects. They are most effective when coordinated with ergonomics, task design, training, and hazard controls.
Treating medical evaluations as a stand alone solution does not address the underlying hazards. They must be integrated into how work is planned, controlled, and supervised.
How Safety by Design Supports Employers
Safety by Design works with employers to identify job demands, understand OSHA medical requirements, and determine when medical evaluations or medical surveillance are required. Our safety consultants can help integrate these requirements into existing safety programs so they are applied consistently and documented correctly.
Contact Safety by Design to discuss how work physicals and medical surveillance can support compliance and safer work practices.
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