Lead exposure summary

The PEL under 1910.1025(c) is 50 micrograms of lead per cubic meter of air (50 µg/m3) as an 8-hour time-weighted average, and working longer than 8 hours reduces the allowed average exposure. See 1910.1025(c) and the employee summary in 1910.1025AppB.

• Example: the summary explains that if you are exposed for 10 hours in a day, the maximum permitted average would be 40 µg/m3 for that workday.

An employer must perform an initial determination whenever lead is present in the workplace in any quantity, and it must include instrument air monitoring that covers a representative number of employees reasonably believed to have the highest exposure. See 1910.1025(d) and the worker summary in 1910.1025AppB.

• The initial determination must consider recent sampling (within the past year), employee complaints, or other observations suggesting exposure, and sampling must represent employees' normal daily exposure.

If any employee may be exposed above the action level (30 µg/m3), the employer must begin an air monitoring program and then monitor employees at prescribed intervals: every 6 months when exposures are above the action level but below the PEL, and every 3 months when exposures exceed the PEL. See 1910.1025(d) and the employee summary in 1910.1025AppB.

• Monitoring must use full-shift (at least 7-hour) samples under conditions that represent each employee’s regular exposure.

An employer may discontinue monitoring for an employee if two consecutive measurements, taken at least two weeks apart, are below the action level. See 1910.1025(d) and 1910.1025AppB.

• Monitoring must be repeated whenever there is a change (production, process, control, or personnel) that could increase lead exposure or whenever there is reason to suspect increased exposure.

An employer must ensure no employee is exposed above the PEL and must use a priority of methods (engineering controls, work practices, then respirators when necessary) to achieve that result. See 1910.1025(e) and the worker summary in 1910.1025AppB.

• This means employers should first try to eliminate or reduce airborne lead by engineering (ventilation, enclosure) and safe work practices before relying on respirators as a control.

The employer must provide and ensure the use of respirators whenever exposures are not controlled below the PEL by other means, and the employer must pay for the respirators. See 1910.1025(f) and the summary in 1910.1025AppB.

• Employers also must provide a respirator if an employee requests one even when exposures are below the PEL (for example, for medical or reproductive reasons).

The employer must implement a written Respiratory Protection Program that covers selection, use, cleaning, storage, maintenance, and medical evaluations; the employer must also ensure respirator facepieces fit properly through qualitative or quantitative fit tests specified in the Respiratory Protection standard. See 1910.1025(f) and the Respiratory Protection standard at 1910.134 with fit-test procedures in 1910.134AppA.

• Employers must also provide medical evaluations if a worker has difficulty breathing during fit test or respirator use, as described in 1910.1025AppB.

Yes—an employer may choose respirators that provide greater protection than required, and powered air-purifying respirators (PAPRs) may be provided and can be more comfortable for long use. See 1910.1025(f) and the summary in 1910.1025AppB.

• Any respirator selected must be NIOSH-approved per the standard.

When employees are exposed above the PEL or to certain irritating lead compounds, the employer must provide appropriate protective clothing and equipment—such as coveralls, gloves, hats, shoe covers, face shields or vented goggles—at no cost to the employee. See 1910.1025(g) and the worker summary in 1910.1025AppB.

• The employer is responsible for repair, replacement, and cleaning or disposal of this clothing and equipment.

Employer-provided work clothing must be supplied clean and dry at least weekly, and provided daily if airborne lead exposure is greater than 200 µg/m3. See 1910.1025(g) and 1910.1025AppB.

• The employer must also handle contaminated clothing in closed containers in the change room and must not use cleaning methods that disperse lead into the workroom air.

No—contaminated work clothing and equipment must be removed in change rooms and may not be worn home, because doing so can expose your family and home to lead. See 1910.1025(g) and the guidance in 1910.1025AppB.

• Contaminated items to be cleaned, laundered, or disposed of must be placed in closed containers in the change room.

The employer must have a housekeeping program to keep surfaces as free as practicable of lead dust; vacuuming with appropriate vacuums is preferred and the use of compressed air for cleaning is absolutely prohibited. See 1910.1025(h) and 1910.1025AppB.

• Dry or wet sweeping, shoveling, or brushing may be used only when vacuuming or equally effective methods do not work, and vacuums must be emptied in a way that minimizes lead reentry into the workplace.

When exposures exceed the PEL, the employer must provide change rooms, showers, and filtered-air lunchrooms and must prevent food, beverages, tobacco products, and cosmetics from being present or used except in those facilities. See 1910.1025(i) and the worker summary in 1910.1025AppB.

• Protective clothing or equipment must not be worn into lunchrooms unless surface dust has been removed (for example by vacuuming or downdraft booths).

Yes—employees exposed above the PEL must wash both hands and face before eating, drinking, smoking, or applying cosmetics. See 1910.1025(i) and the employee summary in 1910.1025AppB.

Medical surveillance must be made available to all employees who are exposed in excess of the action level (30 µg/m3) for more than 30 days a year. See 1910.1025(j) and the summary in 1910.1025AppB.

• The program includes biological monitoring (blood lead and related tests) and medical examinations performed by or under the supervision of a licensed physician.

The employer must provide required medical surveillance at no cost to employees and at a reasonable time and place, with services performed by or under the supervision of a licensed physician. See 1910.1025(j) and 1910.1025AppB.

Workers should use employer-provided change rooms and showers, remove contaminated clothing at work (not wear it home), place contaminated items in closed containers for laundering or disposal, and carefully launder their own non-work clothes to avoid contaminating the home. See the practical guidance in 1910.1025AppB and the clothing rules in 1910.1025(g).

• These steps minimize take-home lead that can expose family members.

Vacuuming is the preferred method to control lead dust, and vacuums must be used and emptied in a manner that minimizes reentry of lead into the workplace. See 1910.1025(h) and the employee summary in 1910.1025AppB.

• The standard absolutely prohibits using compressed air to clean floors or surfaces where it would disperse lead into the air.

If you have difficulty breathing during a fit test or while using a respirator, the employer must make a medical examination available to determine whether you can safely wear a respirator and whether alternatives (such as a positive-pressure respirator) are needed. See 1910.1025(f) and the fit-test guidance in 1910.134AppA.

When air sampling is performed, the employer must promptly notify employees in writing of the monitoring results that represent their exposure; if results indicate exposure exceeds the PEL (without regard to respirators), the employer must also provide a written description of corrective actions to reduce exposure. See 1910.1025(d) and 1910.1025AppB.

Medical surveillance is important because workplace controls may not adequately protect individuals who have high body burdens of lead from past exposures, additional non-occupational lead sources, unusual absorption rates, or medical conditions (like renal disease or anemia) that could be aggravated by lead exposure. See 1910.1025(j) and the explanation in 1910.1025AppB.

• Periodic medical checks help detect control failures and protect reproductive health.

The initial phase of medical surveillance for covered employees had to be completed no later than August 28, 1979. Employers were to prioritize employees at greatest risk (for example, those with the longest prior exposure or highest current exposure) during that first round of surveillance and thereafter make periodic biological monitoring and medical exams available to all covered employees (1910.1025AppB).

Priority in the first round of medical surveillance must be given to employees the employer believes are at greatest risk from continued lead exposure. Examples include workers with the longest prior exposure to lead or those with the highest current exposure levels (1910.1025AppB).

• This priority helps focus limited early testing resources on people most likely to have elevated blood lead levels and adverse effects.

Employers must provide blood lead level (PbB) testing at least every 6 months after the initial PbB test. If a worker's PbB exceeds 40 µg/100 g, testing frequency must increase to at least every 2 months and stay at that frequency until two consecutive PbBs are below 40 µg/100 g (1910.1025AppB).

• Zinc protoporphyrin (ZPP) is noted as a useful effect measure, but biological monitoring under the standard is currently limited to PbB testing.

The employer must notify the worker in writing within five working days after receiving blood lead test results that show a PbB over 40 µg/100 g. Each time a worker's PbB is over 40 µg/100 g this written notification requirement applies (1910.1025AppB).

• Prompt written notice ensures the worker and employer can take timely steps such as increased monitoring or medical evaluation.

If a worker's PbB exceeds 80 µg/100 g (the first-year removal criterion), the employer must make a prompt follow-up PbB test available; if two tests both exceed 80 µg/100 g and the worker is temporarily removed, the employer must provide monthly PbB tests during removal (1910.1025AppB; 1910.1025(k).

• These steps support prompt confirmation of elevated lead absorption and ongoing monitoring while the worker is removed from lead exposure.

Employers must make annual medical examinations available if a worker's blood lead level exceeded 40 µg/100 g at any time during the preceding year. Employers must also provide an initial pre-assignment examination before assigning an employee to an area where airborne lead equals or exceeds the action level, and must provide an exam or consultation if a worker reports symptoms of lead poisoning or respirator problems (1910.1025AppB; see also 1910.1025(j)).

• The initial exam establishes a baseline; annual exams track changes tied to elevated exposures or symptoms.

Yes. If an employee notifies the employer that they want medical advice about how current or past lead exposure might affect their ability to have a healthy child, the employer must provide a medical examination or consultation (1910.1025AppB).

• This includes access to laboratory evaluations of male fertility (sperm microscopy) or pregnancy tests upon request.

Pre-assignment and annual medical examinations must include a detailed work and medical history, a thorough physical exam, and laboratory tests to check blood chemistry and kidney function. Upon employee request, a sperm analysis or pregnancy test must be provided (1910.1025AppB).

• These elements create a baseline and track organ systems commonly affected by lead exposure.

No. The standard does not require employees to participate in medical procedures or tests the employer makes available, although participation is strongly encouraged because medical surveillance helps protect health (1910.1025AppB).

• Employers must still make the surveillance available even if an employee declines.

If an employee is dissatisfied with the employer-chosen physician's examination, the employee can select a second physician for an independent analysis; if the two physicians disagree, they try to resolve differences and select a third physician to resolve any remaining dispute. Generally the employer selects the physician unless the employer and employee agree otherwise (1910.1025AppB).

• Pre-arranged agreements (e.g., panels or independent labs) are allowed if they provide the required surveillance.

The employer must give the physician the lead standard and its appendices, a description of the employee's duties as they relate to lead exposure, the employee's exposure level, a description of personal protective equipment used, prior blood lead results, and any prior written medical opinions the employer has about the employee (1910.1025AppB).

• Supplying this information helps the physician interpret test results and make informed recommendations.

The physician's written report must state whether the employee has any medical condition that increases risk of material impairment from lead exposure, any recommended special protective measures, any blood lead level determinations, and any recommended respirator limitations (including whether the employee can use a PAPR if they cannot wear a negative pressure respirator) (1910.1025AppB).

• These written opinions guide employer actions on removal, restrictions, and protective equipment.

Prophylactic chelation — routine use of chelating drugs to prevent elevated blood lead levels or to routinely lower blood lead to a preset "safe" level — is prohibited when done by any person the employer retains, supervises, or controls. Routine chelation solely to reduce blood lead levels is generally considered unacceptable (1910.1025AppB).

• Therapeutic or diagnostic chelation is allowed only under a licensed physician in a clinical setting with appropriate monitoring, and the employee must be notified in writing before such treatment.

Medical removal protection can provide up to 18 months of temporary removal from lead exposure, and during removal the worker must not lose earnings, seniority, or other employment rights and benefits; the employer must also provide appropriate follow-up medical surveillance (including monthly PbB tests if removal was due to high PbB) (1910.1025AppB; 1910.1025(k).

• Employers may transfer employees to lower-exposure jobs, reduce hours, or temporarily lay off employees, but must preserve pay and benefits as if the employee had not been removed.

The standard sets a schedule where removal and return blood lead criteria become more stringent over time: During the first year the removal level was 80 µg/100 g; after March 1, 1980 removal became 70 µg/100 g (return at or below 50); after March 1, 1981 removal became 60 µg/100 g (return at or below 40); and after March 1, 1983 removal became 50 µg/100 g averaged over six months (return criteria consistent with prior step) (1910.1025AppB).

• The standard also allows removal at lower blood lead levels if a physician's final written opinion recommends removal for medical reasons.

If an employee refuses required follow-up medical surveillance, they may lose eligibility for MRP benefits. The appendix states, “If you do not participate in this follow up medical surveillance, you may lose your eligibility for MRP benefits.” See 1910.1025 App B. Employers should inform employees of this consequence when explaining MRP procedures and rights under the standard.

“Return to former job status” means the employee gets the position, wages, benefits, and other job conditions they would have had if they had not been removed. The appendix explains that when you are medically eligible to return, “your employer must return you to your 'former job status'” — that is, the job you would still hold had no removal occurred, or otherwise consistent with the employer’s normal assignment discretion. See 1910.1025 App B. Employers must not use MRP to expand or diminish an employee’s pre-removal rights.

Yes — the employer’s obligation to provide MRP benefits is reduced by the amount the employee actually receives from other compensation sources while removed. The appendix states that if you receive workers’ compensation or other compensation for lost wages (or obtain other employment) during MRP layoff, “your employer's MRP benefits obligation is reduced by the amount that you actually receive from these other sources.” See 1910.1025 App B. Employers must calculate the reduction based on actual payments received by the employee.

Yes — if an employer voluntarily removes an employee from lead exposure for medical reasons, the employer must provide MRP benefits as if the standard required removal. The appendix explicitly states that voluntary removals for medical reasons are treated the same and “MRP benefits must still be provided as though the standard required removal.” See 1910.1025 App B. Employers cannot avoid MRP obligations by labeling a removal as voluntary when it is because of an employee’s medical condition related to lead.

No — respirators cannot be used as a substitute for transfer to a low-exposure job or layoff with MRP benefits when removal is required. The appendix clearly says that in cases where removal is required, “respirators cannot be used as a substitute.” See 1910.1025 App B and the main rule at 1910.1025. Employers must follow the removal and MRP provisions rather than relying on respirators as an alternative.

Yes — employers may provide respirators before removal becomes necessary, but respirators are not allowed as an alternative to transferring the employee to a lower-exposure job or to a layoff with MRP benefits when removal is required. The appendix states, “Respirators may be used before removal becomes necessary, but not as an alternative to a transfer to a low exposure job, or to a lay-off with MRP benefits.” See 1910.1025 App B and 1910.1025. Use respirators only as an interim control and ensure respiratory program requirements are met.

Employers must provide an information and training program to all employees exposed above the action level or who may have skin or eye irritation from lead, and training must be given before initial assignment and at least annually thereafter. The appendix explains the training requirement: employees exposed above the action level or who may suffer skin/eye irritation must be trained, new employees must be trained prior to assignment to potentially exposed areas, and the training must be provided at least annually. See 1910.1025(l) and 1910.1025. Employers must also have completed the initial program for all covered employees by August 28, 1979, and make the standard and appendices readily available to employees.

The employer must explain the specific hazards of the workplace, protective measures, the dangers of lead to the body (including reproductive effects), and employees’ rights under the standard. The appendix requires training to inform employees of: the specific hazards associated with their work environment, protective measures that can be taken, the danger of lead to their bodies (including their reproductive systems), and their rights under the standard. See 1910.1025(l) and 1910.1025. Employers must also make the standard and OSHA materials available to employees and distribute any OSHA-provided materials.

When exposure exceeds the PEL, the employer must post a warning sign that reads the danger legend about fertility and nervous system damage and prohibiting eating, drinking, or smoking; prior to June 1, 2016, an alternative legend was permitted. The appendix specifies the required sign: “DANGER LEAD MAY DAMAGE FERTILITY OR THE UNBORN CHILD CAUSES DAMAGE TO THE CENTRAL NERVOUS SYSTEM DO NOT EAT, DRINK OR SMOKE IN THIS AREA.” It also states that before June 1, 2016, employers could use the older legend: “WARNING LEAD WORK AREA POISON NO SMOKING OR EATING.” See 1910.1025(m) and 1910.1025. Post the current required legend in areas exceeding the PEL.

Employers must keep records of airborne lead monitoring, biological monitoring, and medical examinations, and most of these records must be kept for 40 years or at least 20 years after employment ends, whichever is longer. The appendix lists required exposure monitoring records (employee name and job classification, sampling details, results, and type of respirator worn) and medical/biological records (employee names, physician's written opinion, and exam results). It states these records must be kept for 40 years or for at least 20 years after termination, whichever is longer. See 1910.1025(n) and 1910.1025. Note: medical removal records have a different retention rule (see next question).

Medical removal records must be kept for the duration of the employee’s employment, while employees (or authorized representatives) and unions have access to exposure and certain medical records upon request. The appendix says the medical removal record must include the employee’s name, removal and return dates, how removal is being accomplished, and whether removal was due to elevated blood lead; these records are kept only for the duration of employment. It also requires employers to make environmental monitoring, blood lead monitoring, or medical removal records available to the employee or an authorized representative; unions have access to exposure and medical removal records, but unions do not have access to other personal medical records without employee authorization. See 1910.1025 App B and 1910.1025(n). Employers should respond promptly to written requests and follow the standard’s access rules.

Employees (or their designees) have the right to observe air monitoring for lead, receive an explanation of the measurement procedure, and obtain the results when available; the employer must provide any required personal protective equipment and require the observer to wear it and follow safety procedures. The appendix states that when air monitoring is performed, the employer must allow you or someone you designate to act as an observer, provide an explanation of the measurement procedure, and allow recording of results (and provide results once the lab returns them). It also requires the employer to provide the observer with any personal protective devices required for employees in the monitored area and to require the observer to comply with safety procedures. See 1910.1025(o) and 1910.1025 App B. Observers should be prepared to wear the provided PPE and follow instructions for their safety.