What constitutes enrollment in exposure monitoring programs for which the contractor must provide occupational medicine services?
Appendix A, Section 8(a)(2) requires contractors to establish and provide comprehensive occupational medicine services to workers who are enrolled for any length of time in a medical or exposure monitoring program required by the Rule, other applicable regulation, or other obligation. Medical monitoring is a component of occupational medicine so it is clear that the contractor must provide occupational medicine services to workers enrolled in a medical monitoring program. However, limited exposure monitoring conducted to quantify hazard assessment exposure estimates may not constitute an exposure monitoring program for which the contractor must provide occupational medicine services to the monitored workers. Appendix A, Section 8(a)(2) does not say “all exposure monitoring.” The term “enrolled . . . in a(n) exposure monitoring program” in 8(a)(2) refers to a consistent regimen of monitoring the exposure that workers receive while performing specific tasks. A contractor’s hazard assessm
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