Cadmium 

OSHA 3136-06R 2004

Occupational

Safety and Health

Administration

www.osha.gov
This informational booklet provides a 

general overview of a particular topic 

related to OSHA standards. It does not alter

or determine compliance responsibilities in

OSHA standards or the Occupational Safety

and Health Act of 1970. Because interpretations and enforcement policy may change

over time, you should consult current OSHA

administrative interpretations and decisions

by the Occupational Safety and Health

Review Commission and the Courts for 

additional guidance on OSHA compliance

requirements.

This publication is in the public domain 

and may be reproduced, fully or partially,

without permission. Source credit is 

requested but not required.

This information is available to sensory

impaired individuals upon request.

Voice phone: (202) 693-1999; teletypewriter

(TTY) number: (877) 889-5627.

OSHA’s role is to assure the safety and

health of America’s workers by setting and

enforcing standards; providing training,

outreach, and education; establishing 

partnerships; and encouraging continual

improvement in workplace safety and

health.
U.S. Department of Labor

Occupational Safety and Health Administration

OSHA 3136-06R

2004

Cadmium 
2

Contents

Introduction...3

How OSHA protects workers exposed to cadmium...3

Exposure limits for cadmium...4

The action level...4

The PEL...4

The SECALs...5

Communicating cadmium hazards to employees...6

Employee training...7 

Requirements for air monitoring for cadmium...8

Notifying employees of monitoring results...9

Mechanical ventilation...9

Requirements for a compliance program...9

Requirements for protective equipment...10

Special cleaning requirements for protective clothing...11

Types of respirators...12

Requirements for medical monitoring...12

Table 1: Respiratory Protection for Cadmium...13

Required periodic medical examinations...16

Access to and protection of medical information...17

Exposures created through emergencies...18

Procedures to remove an employee from duty...18

Recordkeeping requirements...19

Air monitoring records...19

Medical surveillance records...20

Training records...20

OSHA assistance...21

Safety and health program management guidelines...21

State programs...22

Consultation services...22

Voluntary Protection Programs (VPP)...23

Strategic Partnership Program...23

Alliance Programs...24

OSHA training and education...24

Information available electronically...25

OSHA publications...25

Contacting OSHA...26

OSHA Regional Offices...27
Introduction

Cadmium, a naturally occurring element found in the earth’s

crust, was discovered in 1817, but was not used commercially until

the end of the 19th century. This soft, silver-white metal was first

used in paint pigments and as a substitute for tin in World War I.

Today, about three-fourths of cadmium is used as an electrode

component in alkaline batteries, with the remainder used in

pigments, coatings, and platings and as a stabilizer for plastics. 

Workers in many industries face potential exposure to cadmium.

The potential for exposure is highest among workers in electroplating, metal machining, plastics, ceramics, paint, and welding

operations. The main exposure routes are through inhalation of

dust and fumes and the incidental ingestion of dust from contaminated hands, food, or cigarettes.

Workers may also be exposed to cadmium from the smelting

and refining of metals or from air in industrial plants that

manufacture batteries, coatings, or plastics. The Agency for Toxic

Substances and Disease Registry estimates that more than 500,000

workers in the United States face exposure to cadmium each year. 

How OSHA protects workers 

exposed to cadmium

The primary and most serious adverse health effects of longterm exposure to cadmium include kidney dysfunction, lung cancer,

and prostate cancer. Cadmium may cause local skin or eye

irritation and can affect long-term health if inhaled or ingested.

Workers face a greater danger of cadmium exposure from

inhalation than from ingestion. Exposure to cadmium that may be

dangerous to life or health may occur in jobs in which workers are

exposed to cadmium dust or fumes, where they heat compounds

or surfaces that contain cadmium, or where workers weld or cut

with materials or solders that contain cadmium.

OSHA moved to protect workers exposed to cadmium more than

30 years ago when it adopted the American National Standards

Institute’s (ANSI) threshold limit values (TLVs) for cadmium as a

national consensus standard under the authority of the Occupational

Safety and Health Act of 1970, Section 6(a) in 1971. In 1992, OSHA

reduced the exposure limits after a quantitative risk assessment and

3
a long-term evaluation of epidemiological studies of lung cancer and

renal dysfunction among workers and animal studies. The revised

exposure limits were published in the Federal Register (Title 29 CFR,

Part 1910.1027) and took effect on December 14, 1992.

The full OSHA standard relating to cadmium (applicable to

general industry, agriculture, and maritime) is found at 29 CFR

1910.1027. This booklet should not be used as a substitute for the

full regulatory requirements of the cadmium standard. The construction industry has a separate cadmium standard, found in 29

CFR 1926.1127.

Exposure limits for cadmium

There are three exposure limits an employer must observe

under the OSHA cadmium standard. The first is the action level, or

AL, which is defined as the airborne level of cadmium that creates a

need for airborne exposure monitoring, a medical surveillance

program for employees who are at or above the AL on 30 or more

days per year, and the provision of a respirator to any employee

that requests one. The second limit is the Permissible Exposure

Limit, or PEL, which defines the limit to which an employee may be

exposed to cadmium in the workplace. The third limit level is

known as a Separate Engineering Control Air Limit, or SECAL, and

may be one of several specific and unique exposure limits that

apply to select and defined industries and processes. The employer

must achieve the PEL through engineering controls and work

practices in all industries not designated with a separate SECAL.

The action level

The action level for workplace exposure to cadmium is 2.5

micrograms per cubic meter of air (2.5 μg/m3) calculated as an 

8-hour time-weighted average (TWA) exposure.

The PEL

The PEL is a time-weighted average concentration that must not

be exceeded during any 8-hour work shift of a 40-hour work week.

The standard sets a PEL of 5 micrograms of cadmium per cubic

meter of air (5 μg/m3) for all cadmium compounds, dust, and fumes.

4
The SECALs

The SECAL is a separate exposure limit to be achieved in

specified processes and workplaces where it is not possible to

achieve the PEL of 5 μg/m3 through engineering and work practices

alone. The SECAL for cadmium is 15 μg/m3 or 50 μg/m3,

depending on the processes involved. The employer covered by

the SECAL is required to achieve that limit by engineering and work

practice controls to the extent feasible and to protect employees

from exposures above the PEL by any combination of compliance

methods, including engineering and work practice controls and

respirators.

The industries that have separate SECALs identified for specific

processes include nickel cadmium battery production, zinc/

cadmium refining, pigment and stabilizer manufacturing, lead

smelting, and plating.

The SECAL is set at 50 μg/m3 for the following industries and

processes:

■ Nickel cadmium battery industry

Plate making, plate preparation process

■ Zinc/cadmium refining

Cadmium refining, casting melting, oxide production, sinter plant

■ Pigment manufacturing

Calcine, crushing, milling, and blending

■ Stabilizer production

Cadmium oxide charging, crushing, drying, and blending

■ Lead smelting

Sinter plant, blast furnace, baghouse, and yard area

The SECAL is set at 15 μg/m3 for the following industries and

processes:

■ Nickel cadmium battery industry

All processes not identified above 

■ Pigment manufacturing

All processes not identified above

■ Plating manufacturing

Mechanical plating

5
Communicating cadmium hazards to employees

Employees must be made aware of the dangers associated

with exposure to cadmium in the workplace. The employer 

must comply with the requirements of the OSHA Hazard

Communication Standard (29 CFR 1910.1200), including the

placement of warning signs and labels in visible locations, access

to material safety data sheets (MSDS), and providing appropriate

employee training.

Warning signs must be displayed in regulated areas and in all

approaches to regulated areas. (A regulated area is defined as 

the area in which an employee may face exposure to cadmium at

levels above the PEL.) The signs must be illuminated, cleaned, and

maintained so that the legend is readily visible, and they must

include the following words:

■ Danger

■ Cadmium

■ Cancer hazard

■ Can cause lung and kidney disease

■ Authorized personnel only

■ Respirators required in this area

Shipping and storage containers that contain cadmium,

cadmium compounds, or cadmium-contaminated clothing,

equipment, waste, scrap, or debris must be labeled with the

following information:

■ Danger

■ Contains cadmium

■ Cancer hazard

■ Avoid creating dust

■ Can cause lung and kidney disease

Installed cadmium products must have a visible label or other

indication that cadmium is present, where feasible.

6
Employee training

Employees must receive training prior to or at the time of their

initial assignment to a position that involves potential exposure to

cadmium and at least annually thereafter. Required training

elements include:

■ Explanation of the health hazards associated with cadmium 

exposure (See Appendix A of the cadmium standard at 29 CFR 

1910.1027).

■ Information about where and how cadmium is used, stored, and

released at the worksite, including processes or operations that 

involve potential cadmium exposure, especially above the PEL.

■ Explanation of engineering controls and work practices for the 

employee’s job assignment to control exposure to cadmium 

associated with the employee’s job assignment.

■ Description of measures employees can take to protect 

themselves from cadmium exposure, such as modification of 

smoking, personal hygiene precautions, and appropriate work 

practices.

■ Explanation of emergency procedures.

■ Information on the purpose, selection, fitting, use, and 

limitations of personal protective equipment.

■ Explanation of the medical surveillance program.

■ Make a copy of the cadmium standard and its appendices 

readily available and provide employees with a copy of the 

standard if requested.

■ Informing employees of their rights of access to records.

The employer must ensure that employees understand that they

are prohibited from eating, drinking, smoking, chewing tobacco or

gum, or applying cosmetics of any kind in regulated areas. This

also includes a prohibition on carrying or storing these materials or

items in a regulated area.

The employer must make information about the company

training program available to the Assistant Secretary of Labor for

Occupational Safety and Health or the Director of the National

Institute for Occupational Safety and Health upon request.

7
Requirements for air monitoring for cadmium

If your business or workplace has the potential to expose

employees to cadmium, the first step is to determine whether that

exposure will be at or above the action level of 2.5 μg/m3. Levels of

exposure are measured by taking breathing zone air samples that

reflect an employee’s regular, daily TWA exposure over an eighthour period. The monitoring method and analysis must have an

accuracy rate of not less than plus or minus 25 percent with a

confidence level of 95 percent. 

The breathing zone samples must be taken for every employee

on each shift, for each job classification, in each work area. Where

several employees perform the same job tasks, in the same job

classification, on the same shift, in the same work area, for the

same duration, and levels of cadmium exposures are similar, the

employer may sample a representative fraction of employees

instead of all employees. Those selected for sampling are expected

to have the highest exposure levels.

If air monitoring shows that employees are exposed at or

above the action level, periodic monitoring must be performed at

least every six months. If periodic air monitoring shows levels of

exposure below the action level and a repeat test at least seven

days later also shows levels below the action level, the employer

may discontinue the semi-annual air monitoring for those

employees whose exposures are represented by such monitoring. 

If new equipment is added, raw materials are changed, new

personnel are hired, work practices and final products are altered

that may result in additional employees being exposed to

cadmium at or above the action level, additional monitoring must

be performed. If, at any time, the employer has reason to

suspect that exposure to cadmium may increase and employees

already exposed to cadmium at or above the action level will 

be exposed above the PEL, additional air monitoring should 

be undertaken.

If the employer has “objective data”, which means information

that demonstrates that a specific product, material, or process

involving cadmium cannot release dust or fumes in concentrations

at or above the action level based on an industry-wide study or

8
laboratory product test results that closely resemble conditions in

the employer’s facilities, then the employer may rely on this data

instead of implementing initial monitoring as described above. 

Notifying employees of monitoring results

Within 15 days after the receipt of the air monitoring results,

each affected employee must be notified of these results individually and in writing. The results must also be posted where all affected

employees can view them. Employees exposed to cadmium above

the PEL must be informed in writing that the PEL has been exceeded, along with a written explanation of the corrective actions being

taken by the employer to reduce the employee exposure level to or

below the PEL. 

Mechanical ventilation

If mechanical ventilation is used to control exposure, measurements that demonstrate the effectiveness of the system in

controlling exposure, such as capture velocity, duct velocity, or

static pressure, must be made as necessary, to maintain the

system’s effectiveness. Any change in production processes or

controls that might increase cadmium exposure requires the effectiveness of the ventilation system to be reevaluated within five

working days of the change.

If air is recirculated from exhaust ventilation into the workplace,

the system must be equipped with a high efficiency filter and be

monitored periodically to ensure effectiveness.

Requirements for a compliance program

In any workplace or business that experiences exposure levels

above the PEL or SECAL, a written compliance program must be

established and implemented to reduce employee exposure to or

below the PEL by means of engineering and work practice controls.

If engineering and work practice controls cannot reduce exposure

to or below the PEL, the employer must include the use of

appropriate respiratory protection in the written compliance

program to achieve compliance with the PEL. This written program

must be updated at least annually (more often, if necessary) and

9
must be available for examination and copying to employees as

well as the Assistant Secretary of Labor for Occupational Safety and

Health and the Director of the National Institute for Occupational

Safety and Health upon request. 

A written compliance program must contain the following

elements:

■ A description of each operation that involves the emission of 

cadmium, the type of machinery used, the material processed, 

controls in place, and crew size.

■ Description of operating and maintenance procedures and 

employee job responsibilities.

■ Description of how the employer will achieve compliance, such 

as engineering plans and studies and the use of respiratory 

protection.

■ A report on the technology used or considered for use to meet 

the PEL.

■ Air monitoring data to document the sources of cadmium 

emissions.

■ A schedule for implementation of the program that includes 

documentation such as copies of purchase orders for equipment

and construction contracts.

■ A plan for emergency situations that includes the use of 

respirators and personal protective equipment and methods to 

restrict access to an area to non-essential employees until the 

problem is corrected.

Requirements for protective equipment

Employees working in areas where exposure to cadmium is

expected to exceed the PEL or where skin or eye irritation can result

from cadmium exposure at any level must be provided with

respiratory protection and other protective work clothing and

equipment to prevent contamination of both the employee and the

employee’s clothes. If skin or eye irritation is associated with

cadmium exposure at any level, the worker must be provided with

equipment that protects the worker’s skin and eyes. Examples of

10
appropriate personal protective equipment include coveralls,

gloves, head coverings, boots, face shields, and goggles. The

employer must provide and maintain necessary personal protective

equipment to employees at no cost and provide changing rooms,

hand washing facilities, and showers.

The following precautions must be taken to protect workers:

■ Employees must remove all protective work clothing and 

equipment at the end of a shift in a changing area designated for

this purpose, taking care not to shake or blow any cadmium 

residue from the clothing or equipment.

■ Changing rooms must have separate storage areas for street 

clothes and for cadmium-contaminated protective clothing.

■ The employer must clean and maintain protective work clothing 

and equipment, which includes washing at least once a week 

and repairing or replacing as necessary; tears or rips in protective clothing must be repaired immediately or the item replaced.

■ Employees exposed to cadmium above the PEL must shower at 

the end of a work shift when exposure occurred and may not 

eat, drink, smoke, chew tobacco or gum, or apply cosmetics 

before washing their hands and face.

Special cleaning requirements for protective clothing

Cleaning or laundering cadmium-contaminated work clothing

requires special precautions. The employer must ensure that any

person designated to handle protective clothing and equipment

contaminated with cadmium understands the potential harmful

effects of exposure and knows how to launder or clean such items

in a safe manner that prevents the release of cadmium at levels

above the PEL. 

An important step in this process is to ensure that only

authorized employees remove cadmium-contaminated clothing or

equipment from the workplace for any purpose, including

laundering, cleaning, or disposal. Items removed from the work

area for cleaning, maintenance, or disposal must be placed in

sealed, impermeable bags designed to prevent dispersion of

11
cadmium dust. These bags must be labeled as described in the

section on communicating hazards to employees.

Types of respirators

The respiratory protection program must comply with 29 CFR

1910.134 (Respiratory Protection), including the need for a written

respiratory protection program administered by a trained administrator. Respirators must be used any time employees are exposed

to cadmium at levels above the PEL, including maintenance and

repair activities as well as normal operations. 

The following table (page 13) depicts specific requirements for

respirators, depending on the exposure level, but respirators

assigned for higher environmental concentrations may be used at

lower exposure levels. Quantitative fit testing is required for all

tight-fitting air purifying respirators when the airborne concentration of cadmium exceeds 10 times the PEL. If there is any indication of eye irritation, a full face piece respirator is required.

Requirements for medical monitoring

The employer must institute a medical surveillance program for

all employees who are or may be exposed to cadmium at or above

the action level for 30 or more days per year (or in a 12-month

consecutive period). All medical examinations related to this

requirement must be provided at no cost to the employee at a

reasonable time and convenient place, and they must be performed

by or under the supervision of a licensed physician who is familiar

with the regulatory text of the cadmium standard, including

appendices that provide details on health effects and protocols for

sample handling and laboratory selection. Biological samples must

be collected in a manner that assures their reliability, and analyses

must be performed in laboratories with demonstrated proficiency in

the testing performed.

The employer must promptly inform the employee of the option

to seek a second medical opinion after any medical examination or

consultation provided by a physician provided by the employer to

review any findings, determinations, or recommendations or to

12
13

Airborne Concentration Required Respirator Type

Less than 10 times the PEL A half mask, air purifying equipped with a 

high-efficiency particulate air (HEPA) filter.

Up to 25 times the PEL A powered air-purifying respirator (PAPR) with a 

loose-fitting hood or helmet equipped with a 

HEPA filter or a supplied-air respirator with a 

loose-fitting hood or helmet face piece operated 

in the continuous flow mode.

Up to 50 times the PEL A full face piece air-purifying respirator equipped 

with a HEPA filter or a powered air-purifying 

respirator with a tight-fitting half mask equipped 

with a HEPA filter or a supplied-air respirator 

with a tight-fitting half mask operated in the 

continuous flow mode

Up to 250 times the PEL A powered air-purifying respirator with a tight 

fitting full face piece equipped with a HEPA filter 

or a supplied-air respirator with a tight-fitting 

full face piece operated in the continuous 

flow mode.

Up to 1,000 times the PEL A supplied air respirator with half mask or full

face piece operated in the pressure demand or 

other positive pressure mode.

More than 1,000 times A self-contained breathing apparatus with a

the PEL or unknown levels full face piece operated in the pressure demand 

of concentration or other positive pressure mode, or a suppliedair respirator with a full face piece operated in 

the pressure demand or other positive pressure 

mode and equipped with an auxiliary escape 

type self-contained breathing apparatus 

operated in the pressure demand mode.

Fire Fighting A self-contained breathing apparatus with full

face piece operated in the pressure demand or 

other positive pressure mode.

Source: Respiratory Decision Logic, NIOSH, 1987

Table 1: Respiratory Protection for Cadmium
conduct examinations, consultations, or laboratory tests. The

employer may require the employee to notify the employee that he

or she intends to seek a second medical opinion and to initiate

steps to make an appointment within 15 days of being told of this

option or of receiving the physician’s written opinion from an

employer-provided examination, whichever is later, as a condition

of providing payment for a second medical opinion. 

Medical surveillance begins with an initial examination for each

employee covered by this requirement within 30 days of employment in a position that involves exposure to cadmium. The only

exception is for employees who can show that they have had an

examination that includes all required elements in the last 12

months. Results from a qualifying examination within the last 12

months must be maintained as part of the employee’s medical

record and are treated as the initial examination. The examination

must include:

■ Medical and work history

❍ Any past, present, or anticipated future exposure to cadmium

❍ History of renal, cardiovascular, respiratory, hematopoietic, 

reproductive or musculoskeletal system dysfunction

❍ Current use of medication with potential nephrotoxic side 

effects

❍ Smoking history and current status

■ Biological monitoring

❍ Cadmium in urine (CdU), standardized to grams of 

creatinine (g/Cr)

❍ Beta-2 microglobulin in urine (β2-M), standardized to grams 

of creatinine (g/Cr), with pH specified

❍ Cadmium in blood (CdB), standardized to liters of whole 

blood (lwb)

The following parameters will determine what level of medical

surveillance will follow the initial examination. Levels at or below

the levels specified below require only the minimum level of

periodic medical surveillance, which includes a follow-up exam

within one year of the initial exam and a periodic exam every two

14
years from that point forward. Biological sampling must be provided at least annually.

Trigger levels for medical surveillance:

■ CdU level: at or below 3 μg/g Cr

■ β2-M level: at or below 300 μg/g Cr

■ CdB level: at or below 5 μg/lwb

If the initial biological monitoring tests for an employee show

levels exceeding any of the above parameters, then the employer

must reassess the employee’s occupational exposure to cadmium

within two weeks of receiving the results of the tests. This reassessment must include a reevaluation and reassessment of the

employee’s work practices and personal hygiene, respirator use (if

any) and respirator program, smoking history and current usage, as

well as available hygiene facilities and engineering controls in use.

If any deficiencies are noted during this reevaluation, the employer

must correct them within 30 days. 

An employee who shows biological test results elevated relative

to the trigger levels noted above must receive a full medical

examination within 90 days after receiving the results from the

initial testing. At this point, the examining physician should make a

decision whether to medically remove the employee from cadmium

exposure. If the physician decides not to medically remove the

employee, biological monitoring must continue on a semiannual

basis along with an annual medical exam. 

If an employee shows biological testing results during both the

initial and follow-up medical examination elevated above the

following trigger levels, that employee must be medically removed

from exposure to cadmium at or above the action level:

(1) CdU level: above 7 μg/g Cr

or

(2) CdB level: above 10 μg/liter of whole blood

or

(3) β2-M level: above 750 μg/g Cr

and

15
(a) CdU exceeds 3 μg/g Cr

or

(b) CdB exceeds 5 μg/liter of whole blood

Employee removal is mandatory if the second set of biological

monitoring results from the medical examination shows that one of

the above mandatory removal trigger levels has been exceeded.

The employer must continue to monitor the employee with

biological monitoring on a quarterly basis along with semiannual

medical examinations until such time as the employee’s levels 

fall within the acceptable trigger levels for medical surveillance.

Employee removal is also required if the examining physician

determines that the employee needs removal from exposure to

cadmium based on other findings from the examination regardless

of the above testing results. 

Required periodic medical exams

The minimum level of medical surveillance for employees who

face exposure to cadmium but who do not test above trigger limits

during biological sampling includes an exam within one year after

the initial exam and thereafter an exam at least every two years.

This exam must include the following:

■ Detailed medical and work history.

■ Complete physical examination, emphasizing blood pressure, 

the respiratory system, and the urinary system.

■ A 14 x 17 inch or a reasonably-sized posterior-anterior chest x-ray

(frequency to be determined by the examining physician).

■ Pulmonary function tests.

■ Blood analysis.

■ Urinalysis.

■ Prostate exam for males over 40 years old.

■ Other tests deemed appropriate by the physician.

Annual biological sampling is required, either as part of the

medical exam or separately as periodic biological monitoring.

When an employee who has been previously provided with

medical surveillance is terminated or voluntarily leaves

16
employment, the employer must provide a medical examination

that includes a chest x-ray. If the last periodic or other required

exam was less than six months prior to the date of termination or

departure, no further exam is required.

Access to and protection of medical information

The employer must provide the examining physician with a

copy of the OSHA cadmium standard and all appendices, a

description of each affected employee’s former, current, and

anticipated duties and exposure levels as they relate to the

employee’s occupational exposure to cadmium, results of any

previous medical and biological monitoring, and a description of

personal protective equipment used by each employee. 

The employer shall obtain from the examining physician a

written medical opinion for each medical examination performed

on each employee. The physician must be told not to reveal any

findings or diagnoses unrelated to occupational exposure to

cadmium to the employer. The written opinion must include:

■ A diagnosis for the employee.

■ A written opinion as to whether the employee has any medical 

condition that places him or her at increased risk of material 

impairment to health from further exposure to cadmium, 

including evidence of cadmium toxicity.

■ Results of biological tests.

■ Any recommended removal from or limitation on the activities 

or duties of the employee, or on the employee’s use of personal 

protective equipment, such as respirators.

■ A statement that the physician has clearly and carefully 

explained the results of the medical examination to the 

employee, including results of biological tests.

A copy of this written opinion and the results of the biological

monitoring tests (including an explanation of the results) must be

provided to the employee within two weeks after the employer

receives it. If the employee requests access to the information

provided by the employer to the physician, this information must

be provided within 30 days.

17
Exposures created through emergencies

In the case of an emergency that may result in acute cadmium

exposure for an employee, the employer must provide a medical

examination equivalent to the standard periodic medical exam as

soon as possible, with special emphasis on the respiratory system,

other organ systems considered appropriate by the examining

physician, and monitoring for symptoms of overexposure.

Procedures to remove an employee from duty

The employer must temporarily remove any employee from

work where there is excess exposure to cadmium if biological

monitoring tests show that employee to have reached any specific

trigger zones or on each occasion that a physician determines in a

written medical opinion that the employee must be removed. The

employer must place that employee in another position where

exposure to cadmium is below the action level. If such a position is

not immediately available, the employer must provide one as soon

as it becomes available. An employee must also be removed from

excess cadmium exposure if a physician recommends this action,

which can be based on biological monitoring results, an employee’s

inability to wear a respirator, evidence of illness or other signs or

symptoms of cadmium-related dysfunction, or any other reason

deemed medically appropriate by the physician. Inability to wear a

respirator requires removal of the employee from work where

exposure to cadmium is above the PEL; any other reason for

removal requires removal of the worker from work where exposure

to cadmium is below the action level.

Follow-up biological monitoring must be provided for any

employee removed from duty at least every three months with

follow-up medical examination semiannually until the examining

physician provides a written opinion that the employee may be

returned to the former job status or that the employee must be

permanently removed from excess cadmium exposure.

The employer must provide Medical Removal Protection

Benefits (MRPB) for up to a maximum of 18 months to an

employee each time the employee is temporarily medically

removed from a position because of excess cadmium exposure.

18
This requires the employer to sustain the normal earnings,

seniority, and all other employee rights and benefits, including the

right to former job status during this period. In return, the

employer may require the employee to participate in medical surveillance. If an employee is unable to return to the former position

by the end of the 18-month period, the employer must provide the

employee with a medical examination to obtain a final medical

determination regarding whether the employee can return to the

former position or needs permanent removal from excess cadmium

exposure. 

Recordkeeping requirements

There are three distinct types of records required for an employer who operates a facility with the potential for occupational

exposure to cadmium: air monitoring, medical surveillance, and

training records.

Air monitoring records

The record of air monitoring must include the following:

■ The date, duration, and results of air monitoring tests, in terms 

of an 8-hour TWA for each sample.

■ The name, social security number, and job classification of the 

employees monitored as well as all employees the monitoring is

intended to represent.

■ A description of the sampling and analytical methods used and 

evidence of their accuracy.

■ The type, if any, of respiratory protection worn by the monitored

employee(s).

■ A notation of any conditions that may affect the outcome of the 

monitoring results.

The employer must maintain these records for 30 years. 

The employer may use “objective data” as an exemption from

the requirement for initial monitoring under the OSHA standard.

OSHA defines “objective data” as “information demonstrating that

a particular product or material containing cadmium or a specific

19
process, operation, or activity involving cadmium cannot release

dust or fumes in concentrations at or above the action level even

under the worst-case release conditions.” Such information may be

obtained from industry wide studies or from laboratory test results

conducted under conditions similar to those used by the employer

in current operations. If the employer chooses to use objective

data, records to substantiate this decision must be maintained for

30 years. 

Medical surveillance records

The employer must maintain records for every employee subject

to medical surveillance that includes the following:

■ The name and social security number of the employee.

■ A description of the employee’s duties.

■ A copy of the physician’s written opinions and an explanation 

sheet for biological monitoring results.

■ A copy of the medical history and results of the physical 

examination and all test results.

■ A description of any employee symptoms that might be related 

to cadmium exposure.

■ A copy of the information provided to the physician.

These records must be maintained for the duration of the

employee’s employment with the company plus 30 years. Upon

request of the employee, an employee’s designated representative,

anyone having the written consent of the employee, and members

of the employee’s family after the employee’s death or incapacitation, the employer must provide copies of these records within 15

days of such a request. 

Training records

The employer must create a certification record showing that

employees have been trained, to include the identity of the trained

employee, the signature of the trainer or the employer, and the date

the training was completed. These records must be retained for

one year after the training. 

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If an employer ceases to do business and no successor employer

is available to retain the records required to be maintained by the

business, the employer must comply with the requirements for

transferring records contained in 29 CFR 1910.1020 (h).

OSHA assistance

OSHA can provide extensive help through a variety of programs,

including technical assistance about effective safety and health

programs, state plans, workplace consultations, voluntary

protection programs, strategic partnerships, and training and

education, and more. An overall commitment to workplace safety

and health can add value to your business, to your workplace, and

to your life.

Safety and health program management guidelines

Effective management of worker safety and health protection is

a decisive factor in reducing the extent and severity of work-related

injuries and illnesses and their related costs. In fact, an effective

safety and health program forms the basis of good worker

protection and can save time and money (about $4 for every dollar

spent) and increase productivity and reduce worker injuries,

illnesses, and related workers’ compensation costs.

To assist employers and employees in developing effective

safety and health programs, OSHA published recommended Safety

and Health Program Management Guidelines (54 Federal Register

(16): 3904-3916, January 26, 1989). These voluntary guidelines can

be applied to all places of employment covered by OSHA.

The guidelines identify four general elements critical to the

development of a successful safety and health management

system:

■ Management leadership and employee involvement.

■ Work analysis.

■ Hazard prevention and control.

■ Safety and health training.

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The guidelines recommend specific actions, under each of 

these general elements, to achieve an effective safety and health

program. The Federal Register notice is available online at

www.osha.gov. 

State programs

The Occupational Safety and Health Act of 1970 (OSH Act)

encourages states to develop and operate their own job safety and

health plans. OSHA approves and monitors these plans. There are

currently 26 state plans: 23 cover both private and public (state and

local government) employment; 3 states, Connecticut, New Jersey,

and New York, cover the public sector only. States and territories

with their own OSHA-approved occupational safety and health

plans must adopt standards identical to, or at least as effective as,

the Federal standards. 

Consultation services

Consultation assistance is available on request to employers

who want help in establishing and maintaining a safe and healthful

workplace. Largely funded by OSHA, the service is provided at no

cost to the employer. Primarily developed for smaller employers

with more hazardous operations, the consultation service is

delivered by state governments employing professional safety and

health consultants. Comprehensive assistance includes an appraisal

of all-mechanical systems, work practices, and occupational safety

and health hazards of the workplace and all aspects of the

employer’s present job safety and health program. In addition, the

service offers assistance to employers in developing and implementing an effective safety and health program. No penalties are

proposed or citations issued for hazards identified by the

consultant. OSHA provides consultation assistance to the employer

with the assurance that his or her name and firm and any

information about the workplace will not be routinely reported to

OSHA enforcement staff.

Under the consultation program, certain exemplary employers

may request participation in OSHA's Safety and Health

Achievement Recognition Program (SHARP). Eligibility for participa22
tion in SHARP includes receiving a comprehensive consultation

visit, demonstrating exemplary achievements in workplace safety

and health by abating all identified hazards, and developing an

excellent safety and health program.

Employers accepted into SHARP may receive an exemption

from programmed inspections (not complaint or accident investigation inspections) for a period of 1 year. For more information

concerning consultation assistance, visit OSHA’s website at

www.osha.gov.

Voluntary Protection Programs (VPP)

Voluntary Protection Programs and onsite consultation services,

when coupled with an effective enforcement program, expand

worker protection to help meet the goals of the OSH Act. The three

levels of VPP are Star, Merit, and Demonstration designed to

recognize outstanding achievements by companies that have successfully incorporated comprehensive safety and health programs

into their total management system. The VPP motivate others to

achieve excellent safety and health results in the same outstanding

way as they establish a cooperative relationship between employers, employees, and OSHA.

For additional information on VPP and how to apply, contact the

OSHA regional offices listed at the end of this publication.

Strategic Partnership Program

OSHA’s Strategic Partnership Program, the newest member of

OSHA’s cooperative programs, helps encourage, assist, and

recognize the efforts of partners to eliminate serious workplace

hazards and achieve a high level of worker safety and health.

Whereas OSHA’s Consultation Program and VPP entail one-on-one

relationships between OSHA and individual work sites, most

strategic partnerships seek to have a broader impact by building

cooperative relationships with groups of employers and

employees. These partnerships are voluntary, cooperative relationships between OSHA, employers, employee representatives, and

others (e.g., trade unions, trade and professional associations, universities, and other government agencies). 

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For more information on this and other cooperative programs,

contact your nearest OSHA office, or visit OSHA’s website at

www.osha.gov.

Alliance Programs

Alliances enable organizations committed to workplace safety

and health to collaborate with OSHA to prevent injuries and

illnesses in the workplace. OSHA and its allies work together to

reach out to, educate, and lead the nation’s employers and their

employees in improving and advancing workplace safety and

health. 

Alliances are open to all, including trade or professional organizations, businesses, labor organizations, educational institutions,

and government agencies. In some cases, organizations may be

building on existing relationships with OSHA through other

cooperative programs. 

There are few formal program requirements for alliances, which

are less structured than other cooperative agreements, and the

agreements do not include an enforcement component. However,

OSHA and the participating organizations must define, implement,

and meet a set of short- and long-term goals that fall into three

categories: training and education; outreach and communication;

and promotion of the national dialogue on workplace safety and

health. 

OSHA training and education

OSHA area offices offer a variety of information services, such as

compliance assistance, technical advice, publications, audiovisual

aids and speakers for special engagements. OSHA’s Training

Institute in Arlington Heights, IL, provides basic and advanced

courses in safety and health for federal and state compliance

officers, state consultants, federal agency personnel, and private

sector employers, employees, and their representatives.

The OSHA Training Institute also has established OSHA Training

Institute Education Centers to address the increased demand for its

courses from the private sector and from other Federal agencies.

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These centers are nonprofit colleges, universities, and other organizations that have been selected after a competition for participation

in the program.

OSHA also provides funds to nonprofit organizations, through

grants, to conduct workplace training and education in subjects

where OSHA believes there is a lack of workplace training. Grants

are awarded annually. Grant recipients are expected to contribute

20 percent of the total grant cost.

For more information on grants, training, and education, contact

the OSHA Training Institute, Office of Training and Education, 2020

South Arlington Heights Rd., Arlington Heights, IL 60005, (847) 297-

4810. For further information on any OSHA program, contact your

nearest OSHA area or regional office listed at the end of this

publication.

Information available electronically

OSHA has a variety of materials and tools available on its

website at www.osha.gov. These include e-Tools such as Expert

Advisors, Electronic Compliance Assistance Tools (e-cats), Technical

Links; regulations, directives, publications; videos, and other

information for employers and employees. OSHA’s software

programs and compliance assistance tools walk you through

challenging safety and health issues and common problems to find

the best solutions for your workplace.

OSHA’s CD-ROM includes standards, interpretations, directives,

and more and can be purchased on CD-ROM from the U.S.

Government Printing Office. To order, write to the Superintendent

of Documents, P.O. Box 371954, Pittsburgh, PA 15250-7954 or phone

(202) 512-1800, or order online at http://bookstore.gpo.gov.

OSHA publications

OSHA has an extensive publications program. For a listing of

free or sales items, visit OSHA’s website at www.osha.gov or

contact the OSHA Publications Office, U.S. Department of Labor,

200 Constitution Avenue, NW, N-3101, Washington, DC 20210.

Telephone (202) 693-1888 or fax to (202) 693-2498. 

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26

Contacting OSHA

To report an emergency, file a complaint, or seek OSHA advice,

assistance, or products, call (800) 321-OSHA or contact your nearest

OSHA regional or area office listed at the end of this publication.

The teletypewriter (TTY) number is (877) 889-5627.

You can also file a complaint online and obtain more

information on OSHA federal and state programs by visiting

OSHA’s website at www.osha.gov.

For more information on grants, training, and education, contact

the OSHA Training Institute, Office of Training and Education, 2020

South Arlington Heights Rd., Arlington Heights, IL 60005, (847) 297-

4810, or see “Outreach” on OSHA’s website at www.osha.gov.
*These states and territories operate their own OSHA-approved job safety and health

programs (Connecticut, New Jersey, and New York plans cover public employees

only). States with approved programs must have a standard that is identical to, or at

least as effective as, the Federal standard.

Note: Please visit www.OSHA.gov or call (800) 321-OSHA for information on OSHA

area offices, OSHA-approved state plans, and OSHA consultation projects.

OSHA Regional Offices

Region I

(CT,* ME, MA, NH, RI, VT*)

Boston, MA 02203

(617) 565-9860

Region II

(NJ,* NY,* PR,* VI*)

201 Varick Street, Room 670

New York, NY 10014

(212) 337-2378

Region III

(DE, DC, MD,* PA,* VA,* WV)

The Curtis Center

170 S. Independence Mall West

Suite 740 West

Philadelphia, PA 19106-3309

(215) 861-4900

Region IV 

(AL, FL, GA, KY,* MS, NC,* 

SC,* TN*)

Atlanta Federal Center

61 Forsyth Street SW, Room 6T50

Atlanta, GA 30303

(404) 562-2300

Region V

(IL, IN,* MI,* MN,* OH, WI)

230 South Dearborn Street 

Room 3244

Chicago, IL 60604

(312) 353-2220

Region VI

(AR, LA, NM,* OK, TX)

525 Griffin Street, Room 602

Dallas, TX 75202

(214) 767-4731 or 4736 x224

Region VII

(IA,* KS, MO, NE)

City Center Square

1100 Main Street, Suite 800

Kansas City, MO 64105

(816) 426-5861

Region VIII

(CO, MT, ND, SD, UT,* WY*)

1999 Broadway, Suite 1690

P.O. Box 46550

Denver, CO 80202-5716

(303) 844-1600

Region IX

(American Samoa, AZ,* CA,* HI,

NV,* Northern Mariana Islands)

71 Stevenson Street, Room 420

San Francisco, CA 94105

(415) 975-4310

Region X

(AK,* ID, OR,* WA*)

1111 Third Avenue, Suite 715

Seattle, WA 98101-3212

(206) 553-5930

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