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OSHA 1926.62AppB

Lead exposure summary

Subpart D

47 Questions & Answers
10 Interpretations

Questions & Answers

Under 1926.62 App B, what is the permissible exposure limit (PEL) for lead and how is it measured?

The permissible exposure limit (PEL) for lead is 50 micrograms per cubic meter of air (50 μg/m3) averaged over an 8-hour workday (an 8-hour time-weighted average). This PEL is stated in 1926.62 App B and represents the highest allowable 8‑hour average airborne lead concentration to which an employee may be exposed.

Under 1926.62 App B, what is the action level for lead and when must my employer act on it?

The action level for lead is 30 μg/m3 averaged over an 8-hour day, and the employer must determine whether any employee's exposure exceeds this level and set up monitoring if a reasonable possibility exists that exposures are above it. 1926.62 App B explains that the employer must perform an initial exposure determination (or rely on objective data) to decide if monitoring or further controls are required.

Under 1926.62 App B, how does the PEL change if an employee works more than 8 hours in a day?

When an employee works more than 8 hours in a day, the standard uses a formula to reduce the permissible exposure so that the 8‑hour equivalent is maintained (for example, a 10-hour day reduces the maximum permitted average to 40 μg/m3). 1926.62 App B describes this approach to account for extended work schedules.

Under 1926.62 App B, can my employer use "objective data" instead of air monitoring to show exposures are below the action level?

Yes — an employer may use objective data that conclusively demonstrates no employee will be exposed above the action level instead of initial personal monitoring, but must keep accurate records documenting the relevancy of that data to current job conditions. 1926.62 App B explains acceptable sources of objective data and the recordkeeping requirements.

Under 1926.62 App B, if air monitoring is required, does my employer have to test every employee?

No — the employer does not have to monitor every employee but must monitor a representative number of employees and job types reasonably expected to have the highest exposures, using enough sampling to represent each employee's full shift. 1926.62 App B outlines that sampling must reflect normal, daily work conditions and may use prior suitable sampling from the past 12 months when applicable.

Under 1926.62 App B, how and when must my employer notify me of lead air monitoring results?

Your employer must notify you in writing within 5 working days of the monitoring results that represent your exposure, and if your exposure exceeds the PEL (without regard to respirators) the notice must include the corrective actions taken or planned. 1926.62 App B sets this notification requirement.

Under 1926.62 App B, how often must my employer repeat air monitoring for lead if my exposure is at or above the action level but below the PEL?

If your exposure is at or above the action level but below the PEL, your employer must recheck exposure at least every six months. If exposures are at or over the PEL, monitoring must be repeated every three months until two consecutive measurements (taken at least 7 days apart) are below the PEL but above the action level; then monitoring can shift to every six months and may be discontinued only after measurements drop to or below the action level. 1926.62 App B explains these frequencies and the conditions to discontinue monitoring.

Under 1926.62 App B, what triggers new air monitoring besides routine schedules?

Any change in equipment, processes, controls, personnel, or the addition of a new job that may result in new or additional lead exposure requires additional monitoring. 1926.62 App B instructs employers to re-evaluate exposures whenever workplace conditions change in ways that could affect lead exposure.

Under 1926.62 App B, when must an employer implement a written compliance program for lead?

An employer must develop and implement a written compliance program before starting any job where employee exposures may reach the PEL as an 8‑hour TWA. 1926.62 App B lists required elements such as descriptions of operations, engineering/control plans, job responsibilities, and means to achieve compliance.

Under 1926.62 App B, what must be included in a compliance plan if job rotation is used as an administrative control?

If job rotation is used to reduce employee lead exposure, the job rotation schedule must be included in the compliance plan, along with details on protective clothing, housekeeping, hygiene practices, and any engineering controls used. 1926.62 App B requires the plan to be available upon request to affected employees and reviewed at least every 6 months.

Under 1926.62 App B and 1926.62(f), when must my employer provide a respirator and who pays for it?

The employer must provide and assure use of respirators when exposures cannot be reduced below the PEL by engineering and work-practice controls, and the employer must pay for respirators. 1926.62 App B and 1926.62(f) require employer-provided respiratory protection and payment for the equipment.

Under 1926.62 App B and 1910.134(d), can I request a respirator even if my measured exposure is below the PEL?

Yes — the employer must provide a respirator upon your request even if your measured exposure is below the PEL (for example, for medical or reproductive concerns). 1926.62 App B explains this requirement and references the Respiratory Protection standard 1910.134 for program elements.

Under 1926.62 App B and 1926.62(f)(3), what are the respirator selection requirements and approvals?

Respirators must be selected according to 1926.62(f)(3) and the referenced portions of 1910.134; any respirator chosen must be NIOSH‑approved under 42 CFR Part 84. 1926.62 App B emphasizes the need to match respirator protection to airborne lead concentrations and allows employers to provide more protective devices (e.g., PAPRs) where appropriate.

Under 1926.62 App B and 1910.134 App A, what fit testing and training must an employer provide for respirator users?

The employer must provide either qualitative or quantitative fit testing as specified in Appendix A of 1910.134 and must train employees on respirator use, limitations, cleaning, and maintenance. 1926.62 App B references these Respiratory Protection program requirements and requires medical evaluation if the worker has difficulty breathing during fit testing or use.

Under 1926.62 App B and 1926.62(g), when must my employer provide protective clothing and how often must it be cleaned?

If you are exposed above the PEL (without regard to respirator use) or to skin‑irritating lead compounds, the employer must provide appropriate protective work clothing and equipment at no cost, and if clothing is provided it must be clean and dry at least weekly — or daily if airborne exposure exceeds 200 μg/m3. 1926.62 App B and 1926.62(g) cover these requirements.

Under 1926.62 App B, what housekeeping and hygiene practices should my employer require in lead work areas?

The employer must assure good work practices and provide housekeeping and hygiene measures appropriate to the hazard, such as changing and laundering protective clothing, providing change areas and hand washing facilities, and preventing take‑home contamination. 1926.62 App B describes these employer responsibilities and the types of protective clothing and hygiene practices to be used.

Under 1926.62 App B, how long must monitoring or objective data records be kept when used for initial exposure determinations?

When objective data or previous monitoring is used in lieu of current sampling, the employer must establish and maintain an accurate record documenting the relevancy of that data to current job conditions; the standard requires recordkeeping but the Appendix stresses that records must show applicability to current conditions. See 1926.62 App B for the documentation requirement and 1926.62(f) for monitoring program elements.

Under 1926.62 App B, what specific steps should workers follow when changing into work clothing and before entering the lead work area?

Workers must change into work clothing and put on protective gear, including respirators, in the clean section of designated changing areas before entering the lead work area.

  • Change into work clothing and shoe covers in the clean section of the designated changing area.
  • Put on required protective garments and respirators before entering the work area.
  • Store any street clothing or personal items in the designated clean area (separate from contaminated storage).

These hygiene and changing-room practices are described in Appendix B to 1926.62 and are part of the employer’s obligations under 1926.62(i).

Under 1926.62 App B, what actions should workers take when leaving the lead work area for a short break?

When leaving the lead work area for a break, workers should HEPA-vacuum heavily contaminated protective clothing while still wearing it, remove shoe covers in the work area, then remove protective clothing and respirators in the dirty section of the changing area, and wash hands and face.

  • HEPA-vacuum heavy contamination while clothing is still worn; do not remove lead by methods that disperse dust into the air.
  • Remove and leave shoe covers in the work area.
  • Remove protective clothing in the dirty area, rolling coveralls down carefully to limit dust spread.
  • Remove respirators last and then wash hands and face before eating or smoking.

These steps are recommended in Appendix B to 1926.62 and support compliance with the hygiene provisions in 1926.62(i).

Under 1926.62 App B, what extra procedures must workers follow at the end of the workday?

At the end of the day, workers must additionally ensure disposable coveralls/shoe covers are placed with abatement waste (where applicable), place contaminated clothing for laundering or disposal in closed containers, clean protective gear, and shower and wash hair if facilities are available.

  • Put disposable coveralls and shoe covers with abatement waste if the work allows.
  • Place contaminated clothing to be laundered or disposed of in closed containers in the change room.
  • Clean protective gear and respirators per procedures and wash hands and face again.
  • Take a shower and wash hair at the site if available; if not, shower immediately upon arriving home.

These end-of-day hygiene steps are described in Appendix B to 1926.62 and are intended to prevent take-home contamination under the requirements in 1926.62(i).

Under 1926.62(h) and App B, what housekeeping methods are required to control lead dust on surfaces?

Employers must maintain surfaces as free as practicable of lead dust, using HEPA-equipped vacuuming as the preferred method and generally prohibiting compressed air and dry sweeping unless equally effective methods fail.

  • Vacuuming with a HEPA filter is the preferred method and vacuums must be emptied so lead is not reintroduced into the workplace.
  • Compressed air to clean surfaces is generally prohibited unless used with ventilation systems that contain dispersal.
  • Dry/wet sweeping, shoveling, or brushing may only be used when vacuuming or equally effective methods have been tried and found ineffective.

This housekeeping requirement appears in 1926.62(h) and is explained in Appendix B to 1926.62.

Under 1926.62(i) and App B, what hygiene facilities must an employer provide when airborne lead exposure exceeds the PEL?

When airborne lead exposures exceed the PEL, employers must provide hand-washing facilities, change areas, showers (where feasible), and lunchrooms or eating areas, and must prohibit food, beverages, tobacco, and cosmetics outside those areas.

  • Hand-washing facilities must be available where occupational lead exposure occurs.
  • Change rooms with separated storage for street clothes and protective clothing must be provided.
  • Showers should be made available where feasible, and lunch/eating areas must be provided for workers exposed above the PEL.
  • Except in those designated facilities, food, beverages, tobacco products, and cosmetics may not be present or used where airborne exposures exceed the PEL, and employees must wash hands and faces before eating or applying cosmetics.

These facility and practice requirements are described in 1926.62(i) and elaborated in Appendix B to 1926.62.

Under 1926.62(i) and App B, can workers enter lunchrooms or eating areas while wearing contaminated protective clothing?

No—workers may not enter lunchrooms or eating areas wearing protective clothing or equipment unless surface dust has been removed by vacuuming, a downdraft booth, or another effective cleaning method.

  • Protective clothing must be removed in the dirty changing area and not worn into eating areas unless cleaned.
  • Workers exposed above the PEL must wash hands and faces before eating, drinking, or applying cosmetics.

This prohibition and the cleaning requirement are explained in Appendix B to 1926.62 and relate to the hygiene provisions in 1926.62(i).

Under 1926.62(j) and App B, who must be offered full medical surveillance and when is the employer’s obligation triggered?

Full medical surveillance must be made available to employees who are or may be exposed above the action level for more than 30 days a year and whose blood lead level exceeds 40 µg/dl; the employer’s obligation is triggered by the results of air monitoring and blood lead testing.

  • Initial medical surveillance (blood lead and zinc protoporphyrin tests) is required for any employee exposed above the action level even for one day.
  • Full surveillance is required for employees exposed above the action level for more than 30 days a year and whose blood lead exceeds 40 µg/dl.
  • The medical surveillance program must be provided by or under the supervision of a licensed physician and provided at no cost and at a reasonable time and place.

These medical-surveillance triggers and requirements are set out in 1926.62(j) and explained in Appendix B to 1926.62.

Under 1926.62(j) and App B, what blood tests are required and how often must biological monitoring be performed?

Employers must provide blood lead level (BLL) testing and zinc protoporphyrin (ZPP) testing, with monitoring at least every 2 months for the first 6 months and every 6 months thereafter until BLLs are below 40 µg/dl; more frequent testing is required if BLLs exceed 40 µg/dl.

  • Initial testing: blood lead and ZPP must be provided prior to assignment if exposure equals or exceeds the action level at any time.
  • Monitoring frequency: at least every 2 months for the first 6 months, then every 6 months until BLL is below 40 µg/dl.
  • If a worker’s BLL exceeds 40 µg/dl, monitoring must increase to at least every 2 months and remain at that frequency until two consecutive BLLs are below 40 µg/dl.

These testing and frequency requirements are described in 1926.62(j) and summarized in Appendix B to 1926.62.

Under 1926.62(j) and (k) and App B, when must an employer provide medical removal and what protections must they offer?

If a worker’s confirmed blood lead level exceeds 50 µg/dl, the employer must provide temporary medical removal with economic protection and make follow-up BLL testing available; removal and protections are required under the standard.

  • The employer must offer a second follow-up BLL test within two weeks of receiving a BLL over 50 µg/dl to confirm the result.
  • If two tests both exceed 50 µg/dl and the worker is removed, the employer must provide monthly BLL tests during the removal period.
  • Medical removal must include economic protection as required by [1926.62(k)], and employers must follow the removal and return-to-work criteria in the standard.

See 1926.62(j), 1926.62(k), and the explanation in Appendix B to 1926.62.

Under 1926.62(j) and App B, what must an employer do when a worker’s blood lead level is found to be over 40 µg/dl?

When a worker’s blood lead level (BLL) exceeds 40 µg/dl, the employer must notify the employee in writing within five working days of receiving the test results.

  • The employer must inform the worker in writing of the BLL result and that the standard requires temporary medical removal if the BLL exceeds 50 µg/dl.
  • The employer must increase monitoring frequency (to at least every 2 months) until two consecutive BLLs are below 40 µg/dl.

This notification and required actions are described in 1926.62(j) and explained in Appendix B to 1926.62.

Under 1926.62(j) and App B, what must pre-assignment and annual medical examinations include?

Pre-assignment and annual medical examinations must include a detailed work and medical history, a thorough physical exam (including pulmonary evaluation if respirators are used), blood pressure, and laboratory tests checking blood chemistry and kidney function.

  • The minimum content includes: (1) detailed work and medical history; (2) complete physical exam including pulmonary status when respirators will be used; (3) blood pressure measurement; and (4) laboratory tests for blood chemistry and kidney function.
  • Additional tests (male fertility or pregnancy testing) must be made available on request.

These specific medical-exam content requirements are set out in 1926.62(j) and explained in Appendix B to 1926.62.

Under 1926.62 App B, may workers wear contaminated protective clothing home after their shift?

No—workers must not wear required protective clothing or equipment home after showering; contaminated items must be removed in the change area and not taken home because this can spread lead to family and home environments.

  • Change rooms must provide separate storage for protective clothing and street clothes to avoid cross-contamination.
  • Contaminated clothing or equipment to be cleaned or disposed of must be bagged and kept in closed containers in the change room.

These prohibitions and reasons are explained in Appendix B to 1926.62 and implement the hygiene requirements in 1926.62(i).

Under 1926.62 App B, how must contaminated clothing and protective gear be handled and stored for laundering or disposal?

Contaminated clothing and gear to be laundered or disposed of must be placed in closed containers in the change room, and heavily contaminated clothing should be HEPA-vacuumed while still worn; respirators and protective gear must be cleaned by standard procedures.

  • HEPA-vacuum heavy contamination while the garment is still worn; do not use methods that disperse lead into the air.
  • Place contaminated items for laundering or disposal into closed containers in the change room to prevent spread.
  • Clean reusable protective gear and respirators according to established cleaning procedures.

These handling and storage steps are required or recommended in Appendix B to 1926.62 and relate to the hygiene and change-room provisions in 1926.62(i).

Under 1926.62(j) and App B, what information must an employer give the physician who conducts medical surveillance?

The employer must provide the physician with the lead standard and appendices, a description of the worker’s duties and exposure or anticipated exposure levels, personal protective equipment used, prior blood lead test results, and prior written medical opinions the employer has.

  • Required information includes: (1) the standard and its appendices; (2) job duties related to lead exposure; (3) the employee’s exposure level or anticipated exposure; (4) PPE used by the employee; (5) prior BLL results; and (6) any prior written medical opinions.

This list of information the employer must supply to the physician is specified in 1926.62(j) and explained in Appendix B to 1926.62.

Under 1926.62(j) and App B, what must the physician include in the written medical report after examining a worker?

The physician’s written report must state whether the worker has any medical condition that increases risk of material impairment from lead, recommend any special protective measures, report any blood lead determinations, and note any limitations on respirator use (including whether a PAPR is appropriate).

  • The written report must contain: (1) the physician’s opinion on increased-risk medical conditions; (2) recommended special protective measures; (3) blood lead level determinations; and (4) recommendations or limitations regarding respirator use, including whether a PAPR is suitable if a negative-pressure respirator is not.

These required report elements are described in 1926.62(j) and elaborated in Appendix B to 1926.62.

Under 1926.62(j) and App B, does OSHA allow prophylactic chelation therapy for workers as a preventive measure?

No—OSHA’s lead standard prohibits prophylactic chelation of any employee by any person the employer retains, supervises, or controls.

  • Chelation therapy is recognized as a treatment for severe lead poisoning but may have serious side effects; prophylactic (preventive) chelation is specifically prohibited under the standard.

This prohibition is explained in Appendix B to 1926.62 in the medical surveillance discussion tied to 1926.62(j).

Under 1926.62AppB, what is "prophylactic chelation" and is it allowed for lead-exposed workers?

Prophylactic chelation is the routine use of chelating drugs to prevent or routinely lower blood lead levels, and it is not allowed. The Appendix explains that giving chelating or similarly acting drugs solely to reduce a worker’s blood lead level (even if done by a physician or in a hospital) will generally be considered prophylactic chelation and is unacceptable under 1926.62AppB.

  • Therapeutic chelation (to treat severe, symptomatic lead poisoning) or diagnostic chelation (as a diagnostic aid under monitoring) is permitted only when administered under a licensed physician in a clinical setting with proper medical monitoring. See 1926.62AppB.
  • If a physician determines chelation is appropriate, you must be notified in writing before treatment begins.

Under 1926.62AppB, may an employer send an asymptomatic worker to a physician for chelation solely to lower the worker’s blood lead level?

No — sending an asymptomatic worker for chelation solely to lower blood lead levels is considered prophylactic chelation and is prohibited. The Appendix states that routine chelation to prevent increased or to lower current blood lead levels is unacceptable regardless of whether it is done inside or outside a hospital, or by a physician (1926.62AppB).

  • Only therapeutic chelation for marked symptomatic poisoning or diagnostic chelation (with full clinical monitoring) is allowed. If a physician decides chelation is appropriate, you must receive written notice before treatment begins (1926.62AppB).

Under 1926.62(k), what triggers Medical Removal Protection (MRP) and how long can MRP benefits last?

MRP can be triggered by an elevated blood lead level or a physician’s medical opinion, and benefits can last up to 18 months or for as long as the removed job lasts. The Appendix explains that temporary removal can result from either an elevated blood lead level or a medical opinion and that protection is provided for up to 18 months or for the duration of the removed job (1926.62(k)).

  • Many workers return to their former jobs long before the 18-month limit. The standard also allows removal for medical reasons even if blood lead is below 50 µg/dL if the physician so determines (1926.62(k)).

Under 1926.62(k), what benefits and protections must an employer provide while a worker is on Medical Removal Protection (MRP)?

While on MRP, the employer must maintain the worker’s earnings, seniority, and other rights and benefits, and provide appropriate follow-up medical surveillance. The Appendix specifies that MRP means temporary removal to a place of significantly lower exposure without loss of earnings, seniority, or other employment rights or benefits, and that removed employees must receive appropriate follow-up medical surveillance (1926.62(k)).

  • "Earnings" includes base pay, overtime, shift differentials, incentives, and other compensation the employee would have earned (1926.62(k)).
  • If removed for elevated blood lead levels, the employee must be provided a monthly blood test; if removal was due to a medical opinion, the employer must provide the medical tests the doctor deems appropriate (1926.62(k)).
  • Failure to participate in required follow-up medical surveillance can jeopardize continued MRP benefits.

Under 1926.62(k) and 1926.62(l), can an employer use respirators instead of medically removing an employee required to be removed by the standard?

No — respirators cannot be used as a substitute for medical removal when removal is required by the standard. The Appendix explicitly states that respirators may be used before removal becomes necessary, but not as an alternative to transfer to a low-exposure job or a layoff with MRP benefits (1926.62(k); 1926.62(l)).

  • Employers may use respirators as an interim control, but once removal is required under the standard, the employer must provide the removal and associated MRP benefits (1926.62(k)).

Under 1926.62(k), what must an employer do if the examining physician issues a final written opinion recommending removal or other protective measures?

If a physician issues a final written opinion recommending removal or special protective measures, the employer must implement the physician’s recommendation and may return the employee only when the doctor indicates it is safe. The Appendix states the employer must follow the physician’s final written recommendations, and returned employees may only go back when the physician says it's safe (1926.62(k)).

  • Job assignment during removal must be worked out consistent with collective bargaining agreements and existing employer discretion; the employer has broad discretion provided it does not override agreements (1926.62(k)).
  • MRP preserves, but does not expand, the employee’s rights — when eligible to return, the employee gets the wages, position, and benefits they would have had absent removal (1926.62(k)).

Under 1926.62(m), who must receive lead information and training, and when must it be provided?

Employees exposed to lead above the action level or who may suffer skin or eye irritation from lead compounds must be trained before initial assignment and at least annually thereafter unless further exposure above the action level will not occur. The Appendix explains this requirement and states training must be provided prior to initial assignment and at least annually while exposures continue above the action level (1926.62(m); 1926.62AppB).

  • Training is required for those who may have skin or eye irritation from lead compounds (e.g., lead arsenate, lead azide) even if airborne exposure is not the main concern (1926.62(m)).

Under 1926.62(m), what topics must the required lead information and training cover?

The training must cover the specific hazards of the work, protective measures (including the compliance plan), the danger of lead to the body (including reproductive effects), and employee rights under the standard. The Appendix lists these required training topics and emphasizes training on hazards and protections in the employee’s work environment (1926.62(m); 1926.62AppB).

  • Training must be specific to the employee’s job and exposures and include the contents of any compliance plan in effect (1926.62(m)).

Under paragraph (M) of 1926.62, what warning sign must be posted where airborne lead exposure exceeds the PEL?

When exposure to lead is above the PEL, the employer must post a warning sign that reads: “DANGER LEAD WORK AREA MAY DAMAGE FERTILITY OR THE UNBORN CHILD CAUSES DAMAGE TO THE CENTRAL NERVOUS SYSTEM DO NOT EAT, DRINK OR SMOKE IN THIS AREA.” The Appendix specifies this required legend and notes a previous alternative legend allowed prior to June 1, 2016 (1926.62; 1926.62AppB).

  • Prior to June 1, 2016, employers could use the shorter legend: “WARNING LEAD WORK AREA POISON NO SMOKING OR EATING,” but the Appendix now identifies the current required wording (1926.62AppB).

Under 1926.62(n), what exposure monitoring and medical recordkeeping does an employer have to keep and for how long?

Employers must retain all exposure monitoring records for at least 30 years and medical records (other than blood lead levels when applicable) for the duration of employment plus 30 years. The Appendix states air monitoring records must include employee names, job classification, sampling details, results, and respirator type, and must be kept for at least 30 years; medical records must be preserved for the duration of employment plus 30 years (1926.62(n); 1926.62AppB).

  • If an employee’s employment is less than one year, the employer need not retain that employee’s medical records beyond the period of employment if the records are provided to the employee upon termination (1926.62(n)).

Under 1926.62(n) and 1926.62AppB, what records must be kept when an employee is temporarily removed under MRP and how long are those records kept?

When an employee is temporarily removed under MRP, the employer must keep a medical removal record that includes the employee’s name, dates of removal and return, how removal was accomplished, and whether removal was for an elevated blood lead level; that record must be kept for the duration of the employee’s employment. The Appendix states these specific elements for MRP recordkeeping and that each medical removal record is retained only for as long as the employee remains employed (1926.62(n); 1926.62AppB).

  • This MRP recordkeeping retention is shorter than other medical records: MRP records are kept only for the duration of employment (1926.62(n)).

Under 1926.62(n), what access do employees and unions have to environmental monitoring, blood lead, and medical records?

Employees have the right to see or copy environmental monitoring, blood lead, and medical removal records, and employers must provide them to an authorized representative; unions only have access to personal medical records if the employee authorizes it. The Appendix states these records must be made available to the employee or an authorized representative and that a union may access records only with the employee’s specific authorization (1926.62(n); 1926.62AppB).

  • Medical records other than blood lead levels must also be provided to the employee, the employee’s physician, or anyone the employee specifically designates (1926.62(n)).

Under 1926.62(o), can an employee observe workplace air monitoring for lead and what protections apply to the observer?

Yes — employees or their designated representatives may act as observers during air monitoring, and employers must explain the measurement procedure, allow recording of results, and provide any required personal protective equipment. The Appendix explains that observers are entitled to an explanation of the procedure, may record results (and receive the lab results later), and must be provided and required to wear any PPE required for employees in the monitored area (1926.62(o); 1926.62AppB).

  • Observers must comply with applicable safety and health procedures while in the area, and the employer must ensure they use the same protective devices as other workers in the area (1926.62(o)).

Under 1926.62AppB, does an employer’s voluntary removal of an employee from lead exposure (when not required by the standard) require MRP benefits?

Yes — if an employer voluntarily removes a worker from lead exposure for medical reasons, MRP benefits must be provided as though removal were required by the standard. The Appendix explicitly states that voluntary removals due to the effects of lead on a worker’s medical condition trigger MRP benefits in the same way mandatory removals do (1926.62AppB).

  • The employer’s MRP obligations apply even if the standard did not require removal; benefits (earnings, seniority, medical surveillance, etc.) must be provided during the removal period (1926.62AppB).