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OSHA 1926.1127AppF

Biological monitoring protocol

Subpart Z

12 Questions & Answers
10 Interpretations

Questions & Answers

Under 1926.1127 App F, is the biological monitoring protocol mandatory for employers covered by the construction lead standard?

No. The protocol in 1926.1127 App F is explicitly nonmandatory—it is guidance that employers may follow to set up biological monitoring, but employers remain legally bound by the mandatory requirements of the lead standard itself (1926.1127).

Under 1926.1127 App F, are the protocols for construction identical to those in general industry?

Yes. The appendix states that the requirements applicable to construction work under 1926.1127 App F are identical to the procedures set forth in appendix F to 1910.1027, so construction employers can use the same nonmandatory protocol as general industry employers.

Under 1926.1127 App F, can an employer use the appendix protocol to design their biological monitoring program?

Yes. Employers may use the nonmandatory protocol in 1926.1127 App F as a practical template for biological monitoring programs, but adopting the appendix does not replace or relax the mandatory elements of the lead standard in 1926.1127.

Under 1926.1127 App F, does following the appendix relieve an employer from complying with the enforceable parts of the lead standard?

No. Using the guidance in 1926.1127 App F does not exempt an employer from meeting the mandatory requirements in 1926.1127; the appendix is advisory only and cannot substitute for regulatory obligations.

Under 1926.1127 App F, who is the intended audience for the nonmandatory biological monitoring protocol?

The appendix is intended for employers, safety and health professionals, medical reviewers, and others involved with biological monitoring of workers covered by the lead standards in both construction and general industry. For construction work, see 1926.1127 App F and for the identical guidance in general industry, see appendix F to 1910.1027.

Under 1926.1127 App F, can employers rely on the appendix when making medical or removal decisions for workers?

The appendix can inform medical monitoring practices and assist medical professionals, but it is advisory; final medical and removal decisions must follow the mandatory rules and medical requirements in the applicable lead standard (1926.1127) and applicable medical judgment. The appendix (1926.1127 App F) is not a substitute for those regulatory criteria.

Under 1926.1127 App F, does the appendix specify different procedures for construction than for general industry?

No. The appendix states that the procedures for construction are identical to those in general industry—1926.1127 App F expressly says the requirements applicable to construction work are identical to appendix F to 1910.1027.

Under 1926.1127 App F, should employers in State Plan states check state requirements before relying on the appendix?

Yes. Employers in States with OSHA-approved State Plans should confirm whether the State has its own biological monitoring guidance or more stringent rules, because State plans may adopt requirements that differ from or add to Federal guidance. OSHA has explained that State Plan states may have different or more stringent requirements in other contexts (see, for example, the asbestos interpretation discussing State Plans in the Asbestos remediation protocols letter). Employers should consult their State Plan authority in addition to 1926.1127 App F.

Under 1926.1127 App F, does the appendix replace the official lead standards at 1910.1027 or 1926.1127?

No. The appendix is advisory guidance and does not replace the enforceable regulatory language; the mandatory requirements remain in 1910.1027 for general industry and 1926.1127 for construction, while 1926.1127 App F provides nonmandatory procedures that mirror appendix F to 1910.1027.

Under 1926.1127 App F, if an employer adopts the appendix protocol, must they document that choice and their procedures?

Yes—employers should document the biological monitoring program they implement even if it follows the nonmandatory protocol, because clear documentation helps show how the employer meets legal obligations under the mandatory standard. While the appendix itself is guidance (1926.1127 App F), documentation is an essential part of compliance with the enforceable provisions in 1926.1127.

Under 1926.1127 App F, where can employers find the nonmandatory protocol text for use in building their biological monitoring program?

Employers can read the full, nonmandatory protocol in 1926.1127 App F; because the construction appendix is identical to the general industry version, they can also consult appendix F to 1910.1027 for the same guidance.