We sincerely apologize for the delay in our response. The employer is not required to bring those retirees back for testing. Except for recordkeeping provisions, the employer's responsibility under the standard does not extend beyond the employee's period of employment. The employer's obligation is to provide protection to those workers who are presently in their employ.
Retirement is one form of termination of employment.
In addition, you requested affirmation of additional guidance concerning the provision of medical surveillance benefits to previously exposed employees provided to you by Lewis Ligon, of the Office of Health Compliance Assistance during your telephone conversation of September 9, 1993. This provision triggers medical surveillance independently of the current action level. Thus, in addition to having to provide medical surveillance to certain employees who are currently exposed, employers are also required to provide medical surveillance to employees who were or might have been previously exposed at or above the action level by the current employer for a specified period of time, regardless of whether they are currently exposed at or above the action level. This means that if permanent abatement of the cadmium hazard has taken place such that there is no measurable occupational exposure to cadmium for previously exposed employees, then the medical surveillance requirements of the standard do not apply. As you may know the Cadmium standard applies to all occupational exposures to cadmium and cadmium compounds, in all forms.