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.

January 24, 1985

Gary E. Wynn
Acting Supervisor
Hazardous Materials Department
General Dynamics Land Systems Division
P. O. Box 1901
Warren, Michigan 48090

Dear Mr. Wynn:

This is in response to your letter of December 6, 1984, requesting the definition of "organic lead soap," a term used in the standard for occupational exposure to lead, 29 CFR 1910.1025.

An "organic lead soap" is the lead salt of an organic acid, the latter usually being a fatty acid. Lead naphthenate would be an organic lead soap and, therefore, would be a substance regulated by 29 CFR 1910.1025.

Thank you for contacting the Occupational Safety and Health Administration. If we can assist you again in the future, we shall be glad to do so.


John B. Miles, Jr.
Directorate of Field Operations