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OSHA 1910.1025

Lead exposure scope and definitions

Subpart Z

50 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.1025(a)(1) and (a)(2), to which workplaces does the Lead standard apply and what are the exceptions?

The Lead standard applies to all occupational exposures to lead in general industry but does not cover construction or agricultural operations covered by 29 CFR part 1928.

  • Employers must follow the requirements in 1910.1025(a)(1).
  • The standard explicitly excludes the construction industry and agricultural operations covered by [29 CFR part 1928] from coverage in 1910.1025(a)(2).

Under 1910.1025(b), what does the term 'action level' mean for lead exposure monitoring?

The action level means an employee's airborne lead exposure, without regard to respirator use, of 30 micrograms per cubic meter (30 µg/m3) averaged over an 8-hour period.

  • This definition appears in 1910.1025(b).
  • Employers use the action level to determine when to start medical surveillance, monitoring, and other program elements under the standard.

Under 1910.1025(b), how does OSHA define 'lead' for the purposes of the standard?

For this standard, 'lead' means metallic lead, all inorganic lead compounds, and organic lead soaps; it excludes all other organic lead compounds.

  • The definition is given in 1910.1025(b).
  • Use this definition to determine whether a material or exposure scenario is covered by the lead standard.

Under 1910.1025(c)(1), what is the permissible exposure limit (PEL) for lead in air?

The permissible exposure limit (PEL) for lead is 50 micrograms per cubic meter (50 µg/m3) averaged over an 8-hour period.

  • Employers must ensure employee exposures do not exceed this 8-hour TWA as stated in 1910.1025(c)(1).
  • If exposures exceed the PEL, employers must implement controls under the standard to reduce exposures.

Under 1910.1025(c)(2), how do you adjust the PEL when an employee works more than 8 hours in a workday?

When an employee works more than 8 hours in a day, the PEL must be reduced using the formula Maximum permissible limit (µg/m3) = 400 ÷ hours worked in the day.

  • This adjustment is required by 1910.1025(c)(2).
  • Example: For a 10-hour workday the adjusted PEL = 400 ÷ 10 = 40 µg/m3.

Under 1910.1025(c)(3), when can employers consider respirator protection in determining compliance with the PEL?

Employers may consider the protection factor of respirators (for the periods respirators are worn) to determine compliance with the PEL only if engineering and work-practice controls are used first and all requirements of paragraph (f) are met.

  • This option is described in 1910.1025(c)(3).
  • Periods when the respirator is worn can be averaged with non-respirator periods to determine the employee's daily TWA exposure, but employers must still implement feasible engineering and work-practice controls and comply with the respiratory protection provisions in paragraph (f).

Under 1910.1025(d)(1)(ii) and (d)(1)(iii), what are the basic sampling requirements for exposure monitoring?

Employers must collect full-shift personal samples (at least 7 continuous hours) that are representative of each monitored employee's regular daily exposure, including at least one sample for each shift for each job classification in each work area.

  • See the sampling rules in 1910.1025(d)(1)(ii) and the representativeness requirement in 1910.1025(d)(1)(iii).
  • Use personal sampling (not area sampling) to reflect the employee's actual exposure without respirators.

Under 1910.1025(d)(2) and (d)(3), how should an employer perform the initial determination of whether employees are exposed at or above the action level?

Employers must determine if any employee may be exposed at or above the action level by monitoring exposures and basing the initial determination on monitoring results plus relevant considerations such as observations, prior measurements, and employee complaints.

Under 1910.1025(d)(3)(ii), when may monitoring be limited to a representative sample of employees for the initial determination?

For the initial determination, monitoring may be limited to a representative sample of employees the employer reasonably believes are exposed to the highest airborne lead concentrations.

  • This option is allowed by 1910.1025(d)(3)(ii).
  • If this sampling indicates potential exposures at/above the action level, the employer must then perform representative monitoring for each employee exposed (see 1910.1025(d)(4)(i)).

Under 1910.1025(d)(3)(iii) and (d)(4)(ii), when can prior measurements satisfy monitoring requirements?

Measurements of airborne lead taken in the preceding 12 months may be used to satisfy initial or required monitoring if the sampling and analytical methods used meet the accuracy and confidence criteria in [1910.1025(d)(9)].

Under 1910.1025(d)(4)(i), what must an employer do if the initial determination shows any employee could be exposed at or above the action level?

If the initial determination shows any possibility of exposure at or above the action level, the employer must conduct monitoring that is representative of the exposure for each employee in the workplace who is exposed to lead.

  • The requirement is stated in 1910.1025(d)(4)(i).
  • Representative monitoring normally means full-shift personal samples for each employee or a scientifically valid representative sampling strategy for groups of similar-exposed employees.

Under 1910.1025(d)(5), what must an employer record when the initial determination is negative (no exposures at or above the action level)?

When the initial determination finds no employee exposures at or above the action level, the employer must make a written record that includes the information specified in paragraph (d)(3) plus the date of determination, location within the worksite, and the name and number of each employee monitored.

  • The negative determination record requirement is described in 1910.1025(d)(5).
  • Keep this record as part of your compliance documentation.

Under 1910.1025(d)(6), how often must employers repeat monitoring when exposures are below the action level, at or above the action level but below the PEL, or above the PEL?

If initial monitoring shows exposures below the action level, no repeat monitoring is required except as in (d)(7). If exposures are at/above the action level but below the PEL, repeat monitoring at least every 6 months until two consecutive measurements (≥7 days apart) are below the action level. If exposures are above the PEL, repeat monitoring quarterly.

  • See the frequency rules in 1910.1025(d)(6)(i)-(iii).
  • Continue monitoring at the required frequency until the applicable conditions for reduction or discontinuation are met.

Under 1910.1025(d)(7), when is additional monitoring required outside the regular schedule?

Additional monitoring is required whenever there has been a production, process, control, or personnel change that may result in new or additional lead exposures, or whenever the employer has reason to suspect a change that may increase exposures.

  • The trigger for extra monitoring is in 1910.1025(d)(7).
  • Examples include new equipment, changed work practices, different materials, or worker complaints of lead-related symptoms.

Under 1910.1025(d)(8)(i)-(ii), how and when must employers notify employees of monitoring results, and what additional information is required if the PEL was exceeded?

Employers must notify affected employees of monitoring results within 15 working days after receiving them, either individually in writing or by posting results in an accessible location. If the results show exposures exceed the PEL, the notice must state that the PEL was exceeded and describe corrective actions taken or planned.

Under 1910.1025(d)(9), what accuracy and confidence requirements apply to lead air monitoring methods?

Monitoring and analysis methods must have an accuracy of ±20% at a 95% confidence level for airborne lead concentrations equal to or greater than 30 µg/m3.

  • This accuracy standard is specified in 1910.1025(d)(9).
  • Ensure laboratories and sampling procedures meet these performance criteria before relying on results for compliance decisions.

Under 1910.1025(e)(1)(i) and (e)(1)(ii), when are engineering and work-practice controls required and what if they can't lower exposures to the PEL?

Employers must implement engineering and work-practice controls to reduce and maintain lead exposure at or below the PEL when employees are exposed above the PEL for more than 30 days per year; if controls alone cannot achieve the PEL, the employer must use them to reduce exposure to the lowest feasible level and supplement with respirators that meet paragraph (f). If exposures are above the PEL for 30 days or less per year, the employer must at least implement engineering controls to reduce exposure to 200 µg/m3, after which a combination of controls and respirators may be used to reach the PEL.

  • The general control requirements are in 1910.1025(e)(1)(i) and the shorter-duration rule is in 1910.1025(e)(1)(ii).
  • When respirators are needed, employers must comply with the respiratory protection requirements in paragraph (f).

Under 1910.1025(e)(3)(i)-(ii)(A), what must a written compliance program include at minimum?

A written compliance program must be established and implemented to reduce exposures to the PEL solely by engineering and work-practice controls according to the implementation schedule, and the written plan must include at least a description of each operation in which lead is emitted.

  • The requirement for a written program is in 1910.1025(e)(3)(i).
  • The content requirement (including describing operations that emit lead) is in 1910.1025(e)(3)(ii)(A).
  • Make the plan specific to your workplace processes, sources, and timeline for implementing controls.

Under 1910.1025(d)(6)(ii), how can an employer discontinue routine monitoring after exposures were at or above the action level?

An employer may discontinue routine monitoring for an employee after obtaining at least two consecutive measurements, taken at least 7 days apart, that are below the action level; thereafter the employer repeats monitoring at the frequency specified for below-action-level conditions unless paragraph (d)(7) calls for additional monitoring.

  • See the discontinuation rule in 1910.1025(d)(6)(ii).
  • Keep records of the measurements and continue to watch for changes that would trigger new monitoring under 1910.1025(d)(7).

Under 1910.1025(c)(3) and (f), what is required before an employer can rely on respirators to achieve compliance with the PEL?

Before using respirators to count toward PEL compliance, the employer must first implement feasible engineering and work-practice controls; then respirators may be used only if all requirements of paragraph (f) (the respiratory protection program) are met.

  • The rule allowing respirator credit after controls and program compliance is in 1910.1025(c)(3).
  • The respirator program requirements are found in paragraph (f) of 1910.1025; employers must follow those procedures (selection, fit testing, training, maintenance, etc.) before applying respirator protection factors to compliance calculations.

Under 1910.1025(d)(8)(i), how should an employer post monitoring results if they choose not to notify employees individually?

If not notifying individually, the employer may post monitoring results in an appropriate location accessible to affected employees within 15 working days after receiving the results.

  • The posting option and 15-working-day deadline are in 1910.1025(d)(8)(i).
  • Ensure the posting location is reasonably accessible and visible to all employees whose exposures were monitored.

Under 1910.1025(d)(9), what should an employer verify about the laboratory or method used for lead air sample analysis?

An employer should verify that the sampling and analytical method used provides an accuracy of ±20% at a 95% confidence level for concentrations ≥30 µg/m3, meaning the lab and method meet the performance criteria in the standard.

  • This verification requirement is in 1910.1025(d)(9).
  • Ask the laboratory for performance data or accreditation demonstrating the method meets these accuracy/confidence levels before relying on results.

Under 1910.1025(e)(3)(ii)(B), what must the written compliance plan say about engineering plans and studies?

The written compliance plan must describe the specific engineering plans and studies used to choose methods for controlling lead exposure. Employers must include the engineering design or study details that show why particular controls were selected and how they will reduce employee exposure to lead (Requirement in 1910.1025(e)(3)(ii)(B).

  • Include the engineering drawings, calculations, or study summaries (e.g., local exhaust design, enclosure plans).
  • Explain how the plans reduce worker exposure (capture points, expected capture velocities, filtration).
  • Keep documentation that supports the selection of controls so it can be reviewed by OSHA or employee representatives (1910.1025(e)(3)(iii)).

Under 1910.1025(e)(3)(ii)(D), what air monitoring data must be included in the written program?

The written program must include air monitoring data that documents the source(s) of lead emissions and the measured employee exposures. Employers should attach monitoring results showing where lead is released, concentrations measured, sampling methods, dates, and locations (Requirement in 1910.1025(e)(3)(ii)(D).

  • Provide full sampling reports (method, sampling time, analyzer/lab), and spatial/temporal context.
  • Use the data to justify control choices, administrative schedules, and medical surveillance decisions.
  • Keep records available at the worksite for examination (1910.1025(e)(3)(iii)).

Under 1910.1025(e)(3)(iv), how often must the written lead compliance program be revised and updated?

Written lead compliance programs must be revised and updated at least once every 12 months to reflect the current status of the program. Employers are required to review and update the plan annually, and also whenever changes in processes or controls affect exposures (Requirement in 1910.1025(e)(3)(iv).

  • Document the date of each revision and what changed (new controls, updated monitoring, maintenance).
  • Keep the current version available at the worksite for employees and OSHA (1910.1025(e)(3)(iii)).

Under 1910.1025(e)(3)(iii), who must be allowed to examine and copy the written program and where must it be kept?

The written lead compliance program must be kept at the worksite and made available for examination and copying by the Assistant Secretary, the Director, any affected employee, or authorized employee representatives. Employers must maintain current written programs at the workplace so those parties can review them (Requirement in 1910.1025(e)(3)(iii).

  • Keep either a paper copy or an accessible electronic copy at the facility where exposed employees work.
  • Make it available promptly on request for inspection or copying by employees or OSHA representatives.

Under 1910.1025(e)(4)(i), if ventilation is used to control lead exposure, how often must measurements of the system's effectiveness be made?

When ventilation is used to control lead exposure, measurements demonstrating the system's effectiveness must be made at least every 3 months and within 5 days of any change in production, process, or control that might change exposures. Employers must document capture velocity, duct velocity, static pressure, or similar measurements on that schedule (Requirement in 1910.1025(e)(4)(i).

  • Re-test within 5 days after process changes (new machinery, increased crew size, different materials).
  • Keep records of the measurements and any corrective actions taken.

Under 1910.1025(e)(4)(ii), what requirements apply if exhaust ventilation air is recirculated into the workplace?

If exhaust air is recirculated into the workplace, the system must have a high-efficiency filter with a reliable backup filter and automatic monitoring and bypass controls that stop recirculation if the controls fail. Employers must ensure HEPA-level filtration and automatic protection to prevent contaminated air from returning to the work area (Requirement in 1910.1025(e)(4)(ii)(A) and (B).

  • Use HEPA or equivalent high-efficiency filters and keep a functional backup.
  • Install and maintain sensors and automatic bypasses that remove recirculation if lead concentrations exceed safe levels or the filtration fails.
  • Test and document the monitoring and bypass functions regularly per the ventilation measurement schedule (1910.1025(e)(4)(i)).

Under 1910.1025(e)(5), what must a job rotation schedule for administrative controls include?

A job rotation schedule used as an administrative control must list each affected employee, the duration and exposure levels at each job or workstation where they work, and any other information useful for assessing the control's reliability. Employers must document who is rotated, for how long, and the measured exposures at each position (Requirement in 1910.1025(e)(5)(i)–(iii).

  • Include employee names/IDs, start and stop times at each station, and corresponding exposure measurements.
  • Keep this schedule and exposure data to demonstrate that rotations actually reduce individual time-weighted average exposures.

Under 1910.1025(f)(1), when must employers provide and require respirators for employees?

Employers must provide appropriate respirators when installing or implementing engineering or work-practice controls, for operations where controls can't keep exposures at or below the PEL, and whenever an employee requests a respirator. Respirators are required during the transition to controls, for tasks where controls are insufficient, and for voluntary employee requests (Requirement in 1910.1025(f)(1)(i)–(iii).

  • Respirators must be appropriate to the hazard and provided at no cost.
  • When respirators are used, employers must follow the respirator program requirements in 1910.1025(f)(2) and the Respiratory Protection standard (1910.1025(f)(2)).

Under 1910.1025(f)(2)(i), what must the employer's respirator program cover?

The employer must implement a respirator program that meets the requirements of 1910.134(b) through (d) (except (d)(1)(iii)), and (f) through (m) for every employee required to use a respirator under this lead standard. The program must address selection, medical evaluation, fit testing, training, use, maintenance, and recordkeeping as required by 1910.134 and 1910.1025(f)(2)(i) (Respirator program requirement in 1910.1025(f)(2)(i) and Respiratory Protection, 1910.134).

  • Conduct medical evaluations before fit testing or respirator use, provide fit testing, and train workers on limitations and care.
  • Maintain program documentation and respirator maintenance/cleaning procedures.

Under 1910.1025(f)(2)(ii), what must an employer do if an employee has breathing difficulty during fit testing or respirator use?

If an employee experiences breathing difficulty during fit testing or respirator use, the employer must provide a medical examination to determine whether the employee can safely use a respirator while performing the required duties. The exam must follow the procedures in paragraph (j)(3)(i)(C) of the lead standard (Requirement in 1910.1025(f)(2)(ii)).

  • Arrange the medical exam promptly and at no cost to the employee.
  • Use the medical determination to guide respirator assignment or work restrictions per the lead standard (1910.1025(j)(3)(i)(C)).

Under 1910.1025(f)(3)(i), how should employers select respirators and when must full facepieces or HEPA filters be provided?

Employers must select respirators specified in 1910.134(d)(3)(i)(A), provide full facepiece respirators when lead aerosols at use concentrations can cause eye or skin irritation, and equip air-purifying respirators with HEPA filters. Selection must follow the Respiratory Protection standard and the lead standard's specific requirements (Respirator selection in 1910.1025(f)(3)(i) and 1910.134(d)(3)(i)(A).

  • Choose respirators based on hazard, concentration, and job tasks.
  • Provide full facepieces if aerosols can irritate eyes/skin and supply HEPA filters for powered and non-powered air-purifying respirators (1910.1025(f)(3)(i)(B)-(C)).

Under 1910.1025(g)(1), what protective clothing and equipment must employers supply when employees are exposed above the PEL or face skin/eye irritation?

When exposures exceed the PEL or where skin or eye irritation may occur, employers must provide, at no cost, appropriate protective clothing and equipment such as coveralls or full-body clothing, gloves, hats, shoes or disposable shoe covers, and face shields or vented goggles that comply with 1910.133. Employers must ensure employees use this equipment (Requirement in 1910.1025(g)(1).

  • Ensure face and eye protection meets 1910.133 consensus standards.
  • Provide and enforce use of protective clothing whenever measurable overexposure or potential irritation exists.

Under 1910.1025(g)(2)(i)–(iv), how often must protective clothing be provided clean and where must it be removed?

The employer must provide required protective clothing clean and dry at least weekly, and daily for employees whose unprotected exposure exceeds 200 µg/m3 (8-hour TWA), and ensure protective clothing is removed only in designated change rooms at the end of the shift. Employers must also arrange for cleaning, laundering, disposal, and repair or replacement as needed (Requirements in 1910.1025(g)(2)(i)–(iv).

  • Provide daily clean clothing when exposures without respirators exceed 200 µg/m3 as an 8-hour TWA.
  • Keep change rooms for removal and store street clothes separately to prevent cross-contamination (1910.1025(i)(2)(ii)).

Under 1910.1025(g)(2)(v)–(vii), how must contaminated protective clothing be handled, labeled, and how must laundries be notified?

Contaminated protective clothing must be placed in closed containers in the change room to prevent dispersion, employers must inform in writing any person who launders or cleans the clothing about lead hazards, and labels on bags or containers must include the specified danger warning (or the prior caution label allowed before June 1, 2015). Employers must prevent removal of lead by blowing or shaking (Requirements in 1910.1025(g)(2)(v)–(vii)).

  • Use closed, labeled containers marked: DANGER: CLOTHING AND EQUIPMENT CONTAMINATED WITH LEAD. MAY DAMAGE FERTILITY OR THE UNBORN CHILD... (1910.1025(g)(2)(vii)(A)).
  • Provide written hazard information to any laundry service handling contaminated items (1910.1025(g)(2)(vi)).

Under 1910.1025(h)(2), what cleaning methods are allowed for floors and other surfaces where lead accumulates?

Floors and surfaces where lead accumulates may not be cleaned with compressed air; vacuuming or other equally effective methods are preferred, and shoveling or dry/wet sweeping or brushing may only be used when vacuuming is found ineffective. Employers must choose methods that minimize airborne lead during housekeeping (Requirements in 1910.1025(h)(2)(i)–(ii).

  • Avoid compressed air for cleaning lead-contaminated surfaces.
  • Use HEPA-filter vacuums or wet methods first; only resort to sweeping/shoveling when vacuuming is proven ineffective.

Under 1910.1025(h)(3) and 1910.1025(i), how must vacuums be used and emptied to prevent reentry of lead into the workplace?

When vacuuming is used, vacuums must be operated and emptied in ways that minimize reentry of lead dust into the workplace. Employers should use HEPA-filtered vacuums, follow manufacturer emptying procedures in controlled areas, and prevent dust escape during maintenance or disposal (Vacuuming requirement in 1910.1025(h)(3) and 1910.1025(i).

  • Use HEPA-filter vacuum systems and empty them in contained areas or outdoors away from workers.
  • Train staff on safe disposal methods and keep records of vacuum maintenance to prevent recontamination.

Under 1910.1025(i)(1)–(4), what hygiene facilities and practices are required when employees are exposed above the PEL?

When employees are exposed to lead above the PEL (without regard to respirator use), employers must prohibit food, beverages, tobacco, and cosmetics in those areas; provide clean change rooms with separate storage for protective and street clothes; provide showers at shift end; and provide lunchrooms with temperature-controlled, positive-pressure filtered air that are readily accessible (Requirements in 1910.1025(i)(1)–(4)).

  • Require washing of hands and face before eating, smoking, or applying cosmetics (1910.1025(i)(4)(iii)).
  • Ensure change rooms have separate, contamination-protective storage (1910.1025(i)(2)(ii)).

Under 1910.1025(i)(3)(iii) and 1910.1025(i)(4)(iv), can employees leave the workplace wearing contaminated clothing or carry protective clothing into lunchrooms?

Employees required to shower at shift end may not leave the workplace wearing any clothing or equipment worn during the work shift, and employees may not enter lunchroom facilities with protective work clothing or equipment unless surface lead dust has been removed by vacuuming, downdraft booth, or other cleaning method. Employers must enforce these rules to prevent take-home contamination (Requirements in 1910.1025(i)(3)(iii) and (i)(4)(iv)).

  • Require showering and changing into clean street clothes before leaving when applicable (1910.1025(i)(3)(i)).
  • Clean protective clothing before allowing entry to lunchrooms to keep eating areas free of lead dust.

Under 1910.1025(j)(1), who must be included in medical surveillance for lead and who must perform the exams?

Employers must institute a medical surveillance program for all employees who are or may be exposed at or above the action level for more than 30 days per year, and all medical examinations and procedures must be performed by or under the supervision of a licensed physician. The employer must provide these services at no cost and at a reasonable time and place (Requirements in 1910.1025(j)(1)(i)–(iii)).

  • Enroll workers who meet the exposure-time criteria in ongoing surveillance.
  • Ensure medical examinations, recordkeeping, and physician oversight meet the standard's requirements.

Under 1910.1025(j)(2)(i), what biological monitoring must employers provide for lead exposure?

Employers must provide blood lead and zinc protoporphyrin (ZPP) level sampling and analysis as part of the biological monitoring required for medical surveillance of lead-exposed employees. These tests must be performed under the medical surveillance program and interpreted by the supervising physician (Biological monitoring requirement in 1910.1025(j)(2)(i)).

  • Ensure blood samples are collected and analyzed by qualified labs and results are included in medical records.
  • Use these biological results to guide medical removal, follow-up testing, and employee counseling per the standard.

Under 1910.1025(j)(2)(i), what blood sampling schedule must my workplace provide for employees covered by the lead standard?

Employers must provide biological monitoring on the specific schedules set by the standard. Specifically, you must provide:

  • at least every 6 months to each employee covered under 1910.1025(j)(1)(i) as required by 1910.1025(j)(2)(i)(A);
  • at least every 2 months for any employee whose most recent blood test showed a blood lead level ≥ 40 µg/100 g, continuing every 2 months until two consecutive tests are below 40 µg/100 g, per 1910.1025(j)(2)(i)(B); and
  • at least monthly during the period an employee is removed from exposure because of an elevated blood lead level, per 1910.1025(j)(2)(i)(C).

These monitoring frequencies are mandatory parts of the blood sampling program in the lead standard and must be followed for covered employees.

Under 1910.1025(j)(2)(ii), what must an employer do if an employee's blood lead test meets the medical-removal numerical criterion?

If a blood lead test meets or exceeds the medical-removal numerical criterion, the employer must provide a follow-up blood test within two weeks after they receive the first test result.

This requirement is set out in 1910.1025(j)(2)(ii), and ensures a timely confirmation test when results indicate the level that triggers medical removal consideration under 1910.1025(k)(1)(i)(A).

Under 1910.1025(j)(2)(iii), what accuracy and laboratory qualifications are required for blood lead testing?

Blood lead sampling and analysis must meet specified accuracy and be performed by qualified laboratories.

  • The tests must have an accuracy (95% confidence) within ±15% or ±6 µg/100 ml, whichever is greater.
  • The analysis must be performed by a laboratory licensed by the CDC or a laboratory that received a satisfactory grade in CDC blood lead proficiency testing in the prior 12 months.

Those requirements are found in 1910.1025(j)(2)(iii), and they ensure reliable blood lead results for medical and removal decisions.

Under 1910.1025(j)(2)(iv), when and how must an employer notify employees whose blood lead level is at or above 40 µg/100 g?

The employer must notify affected employees in writing within five working days after receiving the biological monitoring results.

  • The written notice must tell the employee their blood lead level, as required by 1910.1025(j)(2)(iv)(A).
  • The notice must also state that the standard requires temporary medical removal with Medical Removal Protection benefits when an employee's blood lead level meets or exceeds the medical-removal numerical criterion under 1910.1025(k)(1)(i), as required by 1910.1025(j)(2)(iv)(B).

Meeting the five-working-day deadline and providing the two required pieces of information are mandatory steps under the standard.

Under 1910.1025(j)(3)(i), which events require the employer to make medical examinations and consultations available?

Employers must make medical exams and consultations available on the specific schedules listed in the standard.

You must provide medical exams:

  • at least annually for any employee whose blood sampling in the prior 12 months showed a blood lead level ≥ 40 µg/100 g (1910.1025(j)(3)(i)(A));
  • before assigning an employee for the first time to a job where airborne lead is at or above the action level (1910.1025(j)(3)(i)(B));
  • as soon as possible when an employee reports signs or symptoms of lead intoxication, requests advice about reproductive effects, or has trouble breathing during respirator fit or use (1910.1025(j)(3)(i)(C)); and
  • as medically appropriate for employees removed from exposure or otherwise limited by a final medical determination (1910.1025(j)(3)(i)(D)).

These scheduled triggers are mandatory under the lead standard.

Under 1910.1025(j)(3)(ii), what tests and information must be included in the medical examinations for lead-exposed employees?

Medical examinations must include a detailed history, a focused physical exam, and specific laboratory tests as listed by the standard.

Required elements include:

  • a detailed work and medical history (past lead exposures, personal habits, relevant organ-system history) per 1910.1025(j)(3)(ii)(A);
  • a thorough physical exam focused on teeth, gums, hematologic, gastrointestinal, renal, cardiovascular, and neurological systems per 1910.1025(j)(3)(ii)(B);
  • pulmonary evaluation if respiratory protection will be used (1910.1025(j)(3)(ii)(C)); and
  • blood and laboratory tests including blood lead level, hemoglobin/hematocrit and red cell indices, zinc protoporphyrin, blood urea nitrogen, serum creatinine, and a routine urinalysis (1910.1025(j)(3)(ii)(D)–(F)).

The examining physician may also order any additional tests deemed necessary by sound medical practice, and examinations prompted by symptoms or reproductive concerns may include pregnancy testing or fertility evaluation if requested.

Under 1910.1025(j)(3)(iii), what rights do employees have to a second or third physician review and what must employers do if physicians disagree?

Employees can obtain a second physician review and, if necessary, a third physician decision, and employers must follow the third physician's findings if the two earlier physicians cannot quickly resolve their disagreement.

Key points under the multiple-physician mechanism:

  • An employee may designate a second physician to review findings and perform further exams or tests if the employer selected the initial physician (1910.1025(j)(3)(iii)(A)).
  • The employer must promptly notify the employee of the right to seek a second opinion after each medical exam or consultation, and may condition payment on the employee notifying the employer and initiating an appointment within 15 days (1910.1025(j)(3)(iii)(B)).
  • If the two physicians disagree and cannot quickly resolve it, the parties shall designate a third physician to review and resolve the disagreement; the employer must act consistently with the third physician's findings unless both parties agree otherwise (1910.1025(j)(3)(iii)(C)–(E)).

This mechanism protects employees' access to independent medical review and describes how disagreements are resolved.

Under 1910.1025(j)(4)(i), can an employer or their agents perform prophylactic chelation on employees?

No — the employer must assure that no one they retain, employ, supervise, or control engages in prophylactic chelation of any employee at any time.

This absolute prohibition is stated in 1910.1025(j)(4)(i), and means employers cannot arrange or permit chelation treatments intended to prevent lead effects as a workplace practice.