ASP Occupational Health and Medical Surveillance — Questions and Answers
Question 1: Under OSHA's Recordkeeping Rule (29 CFR 1904), which of the following criteria makes a work-related injury or illness OSHA recordable?
- It results in days away from work, restricted duty, job transfer, loss of consciousness, or medical treatment beyond first aid (Correct answer)
- It requires any visit to a medical clinic, including for first aid treatment
- It results in a workers' compensation claim being filed
- It occurs on company property regardless of whether medical care is needed
Correct answer: It results in days away from work, restricted duty, job transfer, loss of consciousness, or medical treatment beyond first aid
OSHA's recordkeeping standard requires logging work-related injuries/illnesses that result in: death, days away from work, restricted work or job transfer, medical treatment beyond first aid, loss of consciousness, or diagnosis of a significant injury/illness by a healthcare professional. First aid treatment alone does not make a case recordable.
Question 2: A medical surveillance program for workers exposed to lead would most likely include which biological monitoring test?
- Blood lead level (BLL) testing (Correct answer)
- Pulmonary function testing (spirometry)
- Audiometric testing
- Urinary creatinine measurement
Correct answer: Blood lead level (BLL) testing
Blood lead level (BLL) is the primary biological monitoring test for lead-exposed workers. OSHA's Lead Standard (29 CFR 1910.1025) requires BLL monitoring, with medical removal protections triggered at specific BLL thresholds. Spirometry monitors lung function (for respiratory hazards), audiometry monitors hearing (for noise), and urinary creatinine is used for kidney function or some solvent exposures.
Question 3: Which OSHA form is used to record supplementary information about each recordable occupational injury or illness case?
- OSHA Form 301 (Injury and Illness Incident Report) (Correct answer)
- OSHA Form 300 (Log of Work-Related Injuries and Illnesses)
- OSHA Form 300A (Summary of Work-Related Injuries and Illnesses)
- OSHA Form 302 (Annual Summary Certification)
Correct answer: OSHA Form 301 (Injury and Illness Incident Report)
The three OSHA recordkeeping forms are: Form 300 (the annual log listing all recordable cases), Form 300A (the annual summary posted Feb 1–Apr 30), and Form 301 (the incident report providing detailed information about each individual case—equivalent to a first report of injury). Form 302 does not exist in OSHA's standard recordkeeping system.
Question 4: An occupational health physician determines that a worker's carpal tunnel syndrome is 'work-related.' Under OSHA recordkeeping rules, this case is:
- Recordable as a musculoskeletal disorder if it results in days away, restricted duty, or medical treatment beyond first aid (Correct answer)
- Not recordable because musculoskeletal disorders are excluded from OSHA recordkeeping
- Recordable only if the worker files a workers' compensation claim
- Recordable only after a second physician confirms the diagnosis
Correct answer: Recordable as a musculoskeletal disorder if it results in days away, restricted duty, or medical treatment beyond first aid
Musculoskeletal disorders (MSDs), including carpal tunnel syndrome, are recordable under OSHA's general recordkeeping criteria when they are work-related and meet any of the recording criteria (days away, restricted duty, MBF, etc.). OSHA previously had an MSD column on the 300 log (removed in 2003) but MSDs remain recordable cases under the standard criteria.
Question 5: A fitness-for-duty (FFD) evaluation is most appropriately used when:
- An employee is returning from extended medical leave and there is a question about whether they can safely perform their essential job functions (Correct answer)
- Screening all job applicants before a conditional offer of employment is made
- Determining whether an employee's injury is work-related for OSHA recordkeeping
- Setting occupational exposure limits for a newly introduced chemical
Correct answer: An employee is returning from extended medical leave and there is a question about whether they can safely perform their essential job functions
A fitness-for-duty evaluation determines whether a specific employee can safely perform the essential functions of their specific job, typically after illness, injury, or when safety-sensitive concerns arise. Pre-employment medical exams (post-conditional offer) are a distinct process. FFD evaluations must comply with ADA requirements and focus on job-specific functional capacity.
Question 6: Under the Americans with Disabilities Act (ADA), an employer may require a medical examination of a current employee only when:
- The examination is job-related and consistent with business necessity (Correct answer)
- The employee has missed more than 10 days of work in a calendar year
- The employee requests a workplace accommodation
- The employer suspects drug or alcohol use
Correct answer: The examination is job-related and consistent with business necessity
The ADA permits medical examinations of current employees only when they are job-related and consistent with business necessity—typically when there is objective evidence that the employee's medical condition may affect their ability to perform essential functions or poses a direct threat to safety. Blanket or periodic exams not tied to job requirements are prohibited for current employees under the ADA.
ASP Occupational Health and Medical Surveillance
Under OSHA's Recordkeeping Rule (29 CFR 1904), which of the following criteria makes a work-related injury or illness OSHA recordable?