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.

October 22, 1981

Mr. Alvin Starr
President, U.A.W. #1049
General Battery Corporation
2040 Amelia Street
Dallas, Texas 75235

Dear Mr. Starr:

OSHA's Dallas Regional Office requested us to respond to your inquiry of August 18, 1981, as to whether General Battery's policy of ten minutes of paid shower time is in agreement with OSHA's lead standard, 29 CFR 1910.1025. Please accept my apology for our delay in replying.

The basic intent of the provision dealing with showers (29 CFR 1910.1025(i)(3)(i)) is to assure that employees shower at the workplace after their exposure to lead ends for the day. The lead standard does not address the issue of whether and how much time workers should be paid for showering. The standard did not deal with this issue because it was OSHA's expectation that employers would pay workers for the time needed to take showers required by the standard.

General Battery's action of requiring employees to shower partly on their own time may, however, violate the Fair Labor Standards Act (FLSA). Further information concerning the FLSA is available at the following address and telephone number:

Office of Fair Labor Standards
Employment Standards Administration
Room S3502
Department of Labor
200 Constitution Ave., N.W.
Washington, D.C. 20210
Telephone: (202) 523-8353

Thank you for your inquiry. If we can serve you in the future, we shall be glad to do so.


Bruce Hillenbrand
Acting Director
Federal Compliance and State Programs