Site PPE plans and annual HAZWOPER medical exams

August 11, 1995
Pamela B. Markelz
Corporate Environmental, Health &
Safety Director
Rust Environment & Infrastructure
[Recipient address omitted]
Dear Ms. Markelz:
This is in response to your letter dated May 11, 1995 requesting clarification of the OSHA Personal Protective Equipment (PPE) standard (29 CFR 1910.132) requirements of hazard assessment and employee training and the OSHA Hazardous Waste Operations and Emergency Response (HAZWOPER) standard (29 CFR 1910.120) requirements for annual medical surveillance examinations. The responses provided below confirm the verbal response provided to you by MaryAnn Garrahan of OSHA's [Office of Health Enforcement] during your telephone conversation in May, 1995.
Specifically, you indicated that for certain field operations covered under the OSHA HAZWOPER standard your company may have a written health and safety plan that includes a site-specific hazard analysis which identifies PPE requirements for each task to be performed onsite. You further indicated that each written plan is reviewed and signed by a safety specialist to indicate verification/certification and asked whether this existing procedure was sufficient to meet the hazard assessment and employee training requirements of OSHA's PPE standard.
OSHA does not expect employers to duplicate existing efforts to achieve compliance with an OSHA standard. If the signed health and safety plans that cover your company's field operations address each of the required elements of 29 CFR 1910.132(d), then no further documentation is necessary. Your letter did not identify your company's existing training procedures. However, if your company has a training program in place that addresses each of the PPE training elements of 29 CFR 1910.132(f), then similarly, no additional training efforts would be necessary to comply with this standard.
In your letter, you also asked if OSHA allows a grace period for completion of an employee's annual medical surveillance examinations required under 29 CFR 1910.120(f)(3)(i)(B). OSHA requires that medical examinations be provided to covered employees at least once every 12 months. This annual examination need not be performed on the exact anniversary date of the preceding examination, but rather should be provided on a date reasonably close to the anniversary date taking into consideration the company's and the employee's convenience in scheduling. If the annual physical examination is not completed by the anniversary date, the employer should maintain a record in the employee's file indicating why the examination has been delayed and when the examination will be provided.
We hope this information is helpful. If you have any further questions, please contact [the Office of Health Enforcement at (202) 693-2190].
Sincerely,
Ruth McCully, Director
[Office of Health Enforcement]

[Requester letter reproduced on OSHA page; omitted here.]

[Corrected 4/15/03]