HAZWOPER guide · 2 min read · Updated 2026-11-03
HAZWOPER Medical Surveillance Requirements (1910.120(f))
HAZWOPER requires employers to run a medical surveillance program for certain workers, under 29 CFR 1910.120(f). Exams are done by or under the supervision of a licensed physician, at no cost to the employee, without loss of pay, and at a reasonable time and place.
Who must be in the program
- Employees who are or may be exposed to hazardous substances or health hazards at or above the permissible exposure limit (or published exposure levels, if there is no PEL) for 30 days or more a year, without regard to respirator use
- Employees who wear a respirator for 30 days or more a year, or as required by 1910.134
- Employees who are injured, become ill or develop symptoms from possible overexposure in an emergency or at a hazardous waste site
- Members of HAZMAT teams
When exams happen
- Before assignment (baseline)
- At least once every 12 months, unless the physician decides a longer interval (no more than two years) is appropriate
- At termination of employment or reassignment out of the program, unless an exam was done within the last six months
- As soon as possible after signs or symptoms of overexposure, or after an unprotected exposure in an emergency
- More often if the physician decides it is medically necessary
What the exam covers
A medical and work history, with special emphasis on symptoms related to handling hazardous substances and on fitness for duty, including the ability to wear required PPE under expected conditions such as temperature extremes. The physician decides what tests to add based on the employee's exposures.
Information the employer gives the physician
- A copy of the HAZWOPER standard and its appendices
- A description of the employee's duties as they relate to exposures
- Exposure levels, actual or expected
- A description of the PPE used or to be used
- Information from previous medical exams that the physician can't readily get
The physician's written opinion
The employer gets a written opinion stating whether the employee has any condition that puts them at increased risk from work with hazardous substances, any recommended limits on the employee's work or respirator use, and that the employee has been told the results. It must not reveal specific findings or diagnoses unrelated to occupational exposure. The employee gets a copy.
Recordkeeping
Medical records must be kept for the duration of employment plus 30 years, under 29 CFR 1910.1020.
Frequently asked questions
How often are HAZWOPER medical exams required?
Before assignment, at least every 12 months (or up to every two years if the physician decides), at termination, and after symptoms of overexposure.
Who pays for HAZWOPER medical surveillance?
The employer. Exams must be provided at no cost to the employee, without loss of pay, and at a reasonable time and place.
How long must HAZWOPER medical records be kept?
For the duration of employment plus 30 years, under 29 CFR 1910.1020.
This guide summarizes federal OSHA, Cal/OSHA and EPA rules for training purposes. It is not legal advice. Always check the current regulation text and your site safety and health plan.