The Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard applies to employers whose employees respond, investigate, or clean up hazardous materials. The HAZWOPER standard provides employers, emergency response workers, and other employees potentially exposed to hazardous substances, information and training aimed at improving workplace safety and health and reducing workplace injuries and illnesses. Employers are responsible for developing a comprehensive medical surveillance program to identify any health hazards and develop health and safety programs for their employees.
According to OSHA, employees who meet the following requirements must be included in a medical surveillance program:
- Employees who are or may be exposed to hazardous substances or health hazards at or above the permissible exposure limits (PELs) as set by OSHA
- Employees who wear a respirator for 30 days or more a year or as required by personal protective equipment (PPE) regulations
- 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
- Members of HAZMAT teams
What does the HAZWOPER physical exam consist of?
A HAZWOPER physical, much like many other medical surveillance exams, includes review of the employees medical and work history. The employee will be responsible for filling out a medical questionnaire which will then be reviewed by the health practitioner conducting the exam. The health care provider will also carry out a basic physical exam, review of the employee’s bodily systems and their ability to properly wear PPE, as well as an assessment of any abnormalities in function, agility, and strength.
In a HAZWOPER exam special attention is given to how potential overexposure may impact different parts of the body. The HAZWOPER physical can include different components depending on the industry and role of the employee. While the medical questionnaire, physical exam, and assessment of the ability to wear PPE are required components by OSHA, other services included could be:
- A vision screening
- Physical abilities assessment
- Respirator fit testing
- Spirometry (lung function assessment)
- Liver function tests
Employees must complete the HAZWOPER physical at baseline, before starting their assignments. Physical exams should continue to be conducted annually to track any health changes over time, and upon exit of employment. These exams may occur more often in situations where employees are exposed to hazardous materials or begin to exhibit signs of illness. Conversely, if a healthcare provider deems it appropriate based on the worker’s overall health and exposure risk, the exam can be performed biennially.
What must employers provide?
In order to ensure the safety and health of their employees, employers must provide specific documentation at the time of the physical. Employers must provide the following:
- Employee’s job description
- Past or anticipated exposure levels
- A detailed description of PPE currently in use by the employee
In addition to the planning and implementation of medical surveillance testing, employers are also responsible for the follow up treatment for any employee who is experiencing illness due to exposure to hazardous materials. These treatment plans must consider both emergency treatments and non-emergency treatments.
It is also required that employers maintain detailed records of the physical exam results, and any subsequent treatment as well as complete worker injury, illness, compensation records as required by OSHA’s general industry, HAZWOPER, and recordkeeping standards. It is important to collect and maintain these records as it will provide employees with the necessary medical record history but also provides usable data that can be analyzed over time to prevent and treat future illness or injuries. As always, when collecting, reviewing, and maintaining these records, it is important to preserve employee privacy and adhere to regulations related to sharing and using personal health records.
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