September 24, 2012

Michael J. Hodgson, MD, MPH
Office of Public Health and Environmental Hazards
U.S. Dept. of Veterans Affairs, Veterans Health Administration
810 Vermont Avenue, NW
Washington, DC 20420

Dear Dr. Hodgson:

This is a follow-up to the Occupational Safety and Health Administration (OSHA) letter to you, August 18, 2009, and signed by Richard E. Fairfax, Director of Enforcement Programs, which responded to your May 19, 2009, letter regarding medical exams and chest roentgenograms (or x-rays) under OSHA's Asbestos Standards. I am attaching our 2009 letter for reference.

I am writing now to inform you that the International Labour Organization (ILO), the National Institute for Occupational Safety and Health (NIOSH), and the American College of Radiology have completed their work in developing standard reference images for digital radiography. The revised (2011) edition of the Guidelines for the use of the ILO International Classification of Radiographs of Pneumoconioses extends the applicability of the ILO scheme to classifications of results from digital radiographic images of the chest. (See http://www.ilo.org/safework/info/publications/WCMS_168260/lang--en/index.htm)

According to a recent ILO fact sheet, "This edition of the Guidelines supplements the preceding 2000 edition with an entirely new Chapter 6. This chapter extends the applicability of the ILO scheme to classifications of results from digital radiographic images of the chest. The ILO Standard Digital Images (ILO 2011-D), which derive from the ILO (2000) standard radiographs, have been produced for this purpose. The new text in chapter 6 identifies principles for viewing digitally acquired images of the chest and covers effective acquisition, display and storage of digital images. The Foreword to this revised edition defines the nomenclature used to distinguish different types of chest images. The earlier (2000) Guidelines for classification of conventionally acquired 'film-screen' radiography remain applicable." (See http://www.ilo.org/safework/info/publications/WCMS_168217/lang--en/index.htm)

In light of this development, OSHA will allow, but will not require, digital radiography in place of traditional chest roentgenograms for medical surveillance exams under the Asbestos Standards for general industry, construction, and shipyards. The specific provisions still apply: 29 CFR 1910.1001(l)(2)(ii) and Appendix E to §1910.1001; 29 CFR 1926.1101(m)(2)(ii)(C) and Appendix E to §1926.1101; and 29 CFR 1915.1001(m)(2)(ii)(C) and Appendix E to §1915.1001.

Paragraph (c) of mandatory Appendix E to §1910.1001 states, "All interpreters, whenever interpreting chest roentgenograms made under this section, shall have immediately available for reference a complete set of the ILO-U/C International Classification of Radiographs for Pneumoconioses, 1980." See also paragraphs (c) of Appendix E to §1926.1101 and to §1915.1001. The "set" of ILO reference radiographs referred to in paragraph (c) of Appendix E generally means the 1980 edition, or any later edition. But if using digital radiography, interpreters must use the 2011 version of the ILO reference radiographs, or any later edition that similarly addresses digital images.

I hope you find this information helpful. OSHA requirements are set by statute, standards, and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website, www.osha.gov. If you have any more questions, please contact the OSHA Directorate of Enforcement Programs, 202-693-2100.

Sincerely,

David Michaels, PHD, MPH

[Attachment: OSHA Letter to Dr. Michael J. Hodgson, August 18, 2009]