Medical Surveillance Program Audit Checklist [FREE PDF]

Medical surveillance programs are required under multiple OSHA standards to detect early signs of occupational disease, monitor the effectiveness of exposure controls, and ensure workers exposed to specific hazards receive timely medical evaluations. Key standards driving these requirements include OSHA 29 CFR 1910.95 for noise-exposed workers, 29 CFR 1910.134 for respiratory protection program participants, and 29 CFR 1910.1020 for medical records retention. A comprehensive audit verifies that

Industry: Industrial Hygiene
Frequency: Annually
Estimated Time: 60-90 minutes
Role: Industrial Hygienist
Total Items: 38
Compliance: OSHA 29 CFR 1910.95 Occupational Noise Exposure, OSHA 29 CFR 1910.134 Respiratory Protection, OSHA 29 CFR 1910.1020 Access to Employee Exposure and Medical Records, NIOSH RELs for Chemical and Physical Agents, ACGIH TLVs and BEIs (Threshold Limit Values and Biological Exposure Indices)

Program Administration and Governance

Evaluate the overall structure, written documentation, and administrative oversight of the medical surveillance program.

Is a written medical surveillance program document in place and reviewed within the past 12 months?
Is a qualified occupational health physician or licensed health care professional (PLHCP) designated to oversee the program?
Does the program identify all job categories and employees requiring medical surveillance based on exposure assessments?
Are surveillance triggers (e.g., exposure levels, action levels) clearly defined and documented in the program?
Are corrective actions from the previous program audit documented, tracked, and resolved?

Hearing Conservation Program

Assess compliance with OSHA noise standard requirements including monitoring, audiometric testing, and hearing protection use.

Has a noise exposure monitoring program been established to identify employees exposed at or above the 85 dBA 8-hour TWA action level?
Are baseline audiograms conducted within 6 months of an employee's first exposure at or above the action level?
Are annual audiograms conducted and compared to the baseline to detect standard threshold shifts (STS)?
Are employees notified in writing within 21 days of a confirmed standard threshold shift determination?
Is hearing protection provided at no cost, and do employees exposed at or above 85 dBA select from at least one type of plug and one type of muff?
Are audiometric test records retained for the duration of each affected employee's employment?

Respiratory Protection Medical Evaluations

Verify that medical evaluations for respirator use are conducted by a PLHCP and that questionnaire results are properly managed.

Do all employees required to wear a respirator receive a medical evaluation prior to initial fit testing and use?
Is the Appendix C medical questionnaire or equivalent completed confidentially and reviewed by a PLHCP?
Are additional medical evaluations provided when an employee reports signs or symptoms related to respirator use?
Does the PLHCP provide a written recommendation on each employee's ability to wear the respirator under workplace conditions?
Are medical evaluation records treated as confidential employee medical records and stored separately from personnel files?

Chemical and Hazardous Substance Exposure Surveillance

Review biological monitoring, exposure assessments, and medical evaluations related to chemical hazard exposures in the workplace.

Have industrial hygiene exposure assessments been conducted for all chemical agents with OSHA PELs, NIOSH RELs, or ACGIH TLVs?
Are biological exposure monitoring (BEI) tests conducted for employees exposed to substances with established ACGIH BEIs?
Are pre-placement medical examinations conducted for employees assigned to jobs with known chemical exposure hazards?
Are periodic medical examinations conducted at intervals specified by the applicable OSHA standard or ACGIH/NIOSH guidance?
Are employees notified of exposure monitoring results and medical surveillance findings within the required timeframes?
Are employees with confirmed overexposures referred for additional medical evaluation and removed from exposure as required?

Examination Content and Quality Assurance

Ensure medical examinations include appropriate components for detected hazards and that examination quality is routinely assessed.

Are occupational health examinations tailored to specific exposure profiles for each job category rather than using a generic protocol?
Do examination protocols include occupational and medical history, physical examination, and targeted laboratory or diagnostic testing?
Are examination findings trended over time at the group level to detect emerging occupational disease patterns?
Are abnormal examination findings communicated to relevant EHS management (in aggregate, de-identified) to trigger hazard control improvements?
Is the examining PLHCP provided with a description of the employee's job duties, relevant exposure data, and applicable OSHA standards before examinations?

Medical Records Management and Employee Rights

Verify compliance with medical records retention, confidentiality, and employee access requirements under OSHA 29 CFR 1910.1020.

Are employee medical records maintained for at least the duration of employment plus 30 years?
Are exposure records and related monitoring data retained for at least 30 years?
Are employees informed annually of their right to access their medical and exposure records?
Are medical records accessible to employees or their designated representatives within 15 working days of a request?
Are medical records transferred to NIOSH if the employer ceases to do business and no successor employer exists?
Are electronic medical records protected by access controls to prevent unauthorized disclosure of confidential health information?

Program Effectiveness and Continuous Improvement

Assess metrics, employee participation rates, and management review processes to confirm the program is achieving its occupational health objectives.

Are participation rates in required medical surveillance examinations tracked, and is non-compliance followed up?
Are occupational illness and injury rates reviewed in conjunction with medical surveillance data to evaluate program effectiveness?
Is the medical surveillance program reviewed by senior EHS or occupational health leadership at least annually?
Are findings from medical surveillance used to inform the industrial hygiene hazard control hierarchy, including engineering and administrative controls?
Is employee feedback on the medical surveillance process solicited and incorporated into program improvements?

Related Occupational Health Checklists

Related Medical Surveillance Checklists

Why Use This Medical Surveillance Program Audit Checklist [FREE PDF]?

This medical surveillance program audit checklist [free pdf] helps industrial hygiene teams maintain compliance and operational excellence. Designed for industrial hygienist professionals, this checklist covers 38 critical inspection points across 7 sections. Recommended frequency: annually.

Ensures compliance with OSHA 29 CFR 1910.95 Occupational Noise Exposure, OSHA 29 CFR 1910.134 Respiratory Protection, OSHA 29 CFR 1910.1020 Access to Employee Exposure and Medical Records, NIOSH RELs for Chemical and Physical Agents, ACGIH TLVs and BEIs (Threshold Limit Values and Biological Exposure Indices). Regulatory-aligned for audit readiness and inspection documentation.

Frequently Asked Questions

What does the Medical Surveillance Program Audit Checklist [FREE PDF] cover?

This checklist covers 38 inspection items across 7 sections: Program Administration and Governance, Hearing Conservation Program, Respiratory Protection Medical Evaluations, Chemical and Hazardous Substance Exposure Surveillance, Examination Content and Quality Assurance, Medical Records Management and Employee Rights, Program Effectiveness and Continuous Improvement. It is designed for industrial hygiene operations and compliance.

How often should this checklist be completed?

This checklist should be completed annually. Each completion takes approximately 60-90 minutes.

Who should use this Medical Surveillance Program Audit Checklist [FREE PDF]?

This checklist is designed for Industrial Hygienist professionals in the industrial hygiene industry. It can be used for self-assessments, team audits, and regulatory compliance documentation.

Can I download this checklist as a PDF?

Yes, this checklist is available as a free PDF download. You can also use it digitally in the POPProbe mobile app for real-time data capture, photo documentation, and automatic reporting.