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Office of the Assistant Secretary for Policy
  - OSHA Cadmium Biological Monitoring Advisor

The OSHA Cadmium Biological Monitoring Advisor makes determinations required by the general industry Cadmium Standard, and cites the applicable provisions of that Standard. The construction industry Cadmium Standard uses the same criteria used in the general industry Cadmium Standard to make determinations based on biological monitoring. However, this Advisor does not reference or cite the applicable provisions of the construction industry Cadmium Standard. Consequently, anyone using this Advisor in association with the construction industry Cadmium Standard must find the corresponding provisions manually. (You can use Ctrl + F to find a line of text once in 29 CFR 1926.1127.)

Furthermore, there are important differences between the general industry and construction Cadmium Standards, especially concerning:

  • the timing of actions triggered by medical surveillance, and
  • an employee's duties to inform the employee regarding the lab results.

The following table describes these differences:

Medical surveillance provisions are equivalent except for the following:

General Industry

Construction Industry

29 CFR 1910.1027(l)(5)(i)

The employer within 30 days shall reassess the employee’s occupational exposure to cadmium.

29 CFR 1910.1027(l)(5)(i)(B)

Within 30 days after the reassessment, take all reasonable steps to correct the deficiencies found in the reassessment that may be responsible for the employer’s excess exposure to cadmium.

29 CFR 1926.1127(l)(5)(i)

No time limit

29 CFR 1910.1027(l)(11)(i)(D)

Employer shall provide biological monitoring in accordance with (l)(2)(ii)(B) quarterly and follow up medical examinations semi-annually.

29 CFR 1926.1127(l)(11)(i)(D)

Employer shall provide follow up medical examinations semi-annually.

29 CFR 1910.1027(l)(15)(i)

The employer shall provide a copy of the physician's written medical opinion to the examined employee within two weeks after receipt thereof.

29 CFR 1910.1027(l)(15)(ii)

The employer shall provide the employee with a copy of the employee’s biological monitoring results and an explanation sheet explaining the results within two weeks after receipt thereof.

29 CFR 1926.1127(l)(15)(i)

The employer shall provide a copy of the physician’s medical opinion to the examined employee within five working days after receipt thereof.

29 CFR 1926.1127(l)(15)(ii)

The employer shall provide the employee with a copy of the employee’s biological monitoring results and an explanation sheet explaining the results within five working days after receipt thereof.

Therefore, anyone who uses this Advisor to analyze biological monitoring results for workers exposed to cadmium in the construction industry should be highly familiar with specific requirements of the construction industry Cadmium Standard. They must be able to find, manually, the biological monitoring provisions in the construction industry Cadmium Standard that correspond to the biological monitoring provisions in the general industry Cadmium Standard, and recognize how biological monitoring results relate to other provisions of the construction industry Cadmium Standard that may differ from corresponding provisions in the general industry Cadmium Standard.