- Standard Number:
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.
February 20, 1980
Mr. David M. Wassum
Corporate Safety Coordinator
1111 West Mockingbird Lane
Dallas, Texas 75247
Dear Mr. Wassum:
Assistant Secretary Eula Bingham has asked me to respond to your request for a clarification of 29 CFR 1904, as it pertains to medical removals made pursuant to the lead standard, 29 CFR 1910.1025. Please accept my apology for the delay in this reply.
The recordkeeping requirements of 29 CFR 1910.1025(n)(3) for recording cases of (a) employees removed from exposure to lead due to elevated blood lead levels and (b) employees removed because they have symptoms of lead poisoning, are separate from the OSHA occupational injury and illness recordkeeping system requirement (29 CFR 1904).
The lead standard does not specify a blood lead level limit for OSHA injury and illness recording. Medical removal cases of employees with symptoms of lead poisoning such as anemia and renal complications, or blood lead levels which the examining physician diagnosed as indicating illness, continue to be entered in the OSHA occupational injury and illness recordkeeping system (OSHA 200 log).
Therefore, some instances of removal where blood lead levels are below those specified for removal by 29 CFR 1910.1025(k) must be recorded in conformance with 29 CFR 1904; for example, when an examining physician has diagnosed the employee to be suffering adverse health effects. The record presented in the preamble to the lead standard demonstrates that adverse signs and symptoms have been observed in workers with blood leads as low as 40 ug/100g.
This information should aid in revising your proposed recordkeeping policy. In addition, I have enclosed a Bulletin of the United States Department of Labor, Bureau of Labor Statistics, which may provide additional clarifications of this matter.
If I can be of further assistance please contact my office.
Grover C. Wrenn Director,
Federal Compliance and State Programs