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.

March 27, 1987

Mrs. Ellen A. Uhas
Route 1, Box 419G
Fitzgerald, Georgia 31750

Dear Ms. Uhas:

This is in response to your letter dated March 25 to the Public Health Service's Office of Disease Prevention and Health Promotion Health Information Center, which has been has referred to the Occupational Safety and Health Administration (OSHA) for a response.

In your letter you expressed your concern regarding your husband and his coworkers' exposure to lead and sulfuric acid. Your questions are answered as follows:

1) What happens to the men when they have a constant daily exposure [to lead]; but their levels stay in the 25-40 microgram (ug)/100 grams (g) of blood range?

Blood lead levels are indicators of risk for health effects. That means that the higher the blood level of lead, the higher the risk for disease related to lead. The organ systems most commonly associated with lead poisoning are the neurological, gastrointestinal, hematological, nephrological, and reproductive systems. In general the hematological system is the organ system most sensitive to lead exposure, and is known to be consistently affected in various was in the range of 25-40 ug/100g. The other organ systems may be affected in this blood lead range, but the risk of such problems (i.e., the chance that they will occur) is less.

2) Can they actually develop symptoms of lead poisoning in this range?

At least on report correlating symptoms of illness with blood lead levels has found that mild abdominal pain, fatigue, and joint pain are more common if blood lead levels are greater than 30ug/100g.

3) Is it possible that lead had caused mood changes, circulation, gastric and cardiac problems?

a) mood changes - Subtle changes in psychological function are known to occur with blood lead levels is difficult.

b) circulation - Some reports exist which state that increased blood pressure is associated with lead exposure. Again, the relationship to blood lead levels is not easily defined.

c) gastric - Peptic ulcers and colic are known consequences of lead toxicity. Generally the blood lead levels associated with these problems are reported to be higher than 25-40ug/100g.

d) cardiac - no known association.

Sulfuric acid is an irritant and can cause eye, nose, and throat irritation as well as rashes. Stomach ulcers are unlikely to be caused by sulfuric acid (more likely lead, as noted above).

Blood typing difficulties are unlikely to be of occupational origin.

OSHA's lead standard, 29 CFR 1910.1025, requires employers to monitor their employees' blood lead levels. For the most part, if an employee's blood lead level is at or above 50mg/100g of whole blood the employer would be required to remove the employee from exposure until the employee's blood lead level drops to a level at or below 40ug/100g of whole blood. It appears from your letter that the company is complying with this requirement.

The lead standard allows for employees who develop signs and symptoms commonly associated with lead intoxication to ask for medical advice regardless of what past blood lead exposures were. If the employer selects the initial physician the employee has the right to designate a second physician to review any findings, determinations or recommendations of the initial physician. The standard also has a mechanism of review if the two physicians disagree.

Under the Occupational Safety and Health Act of 1970 employees have the right to file a complaint with OSHA. In addition, the name of the employee can be withheld from the employer, upon request to OSHA, when a complaint is filed. If your husband or his coworkers feel that an unsafe or unhealthful condition exists a complaint can be filed with the local OSHA Area Office. The Delco Remy Division of General Motors in Fitzgerald, Georgia, would be covered by our Atlanta Area Office. If you wish, you may contact them at the following address:

Area Director
U.S. Department of Labor
Building 10, Suite 33
LaVista Perimeter Office
Park Tucker, Georgia 30084
Telephone: 404-331-4767

That office can also answer any additional questions you may have on OSHA regulations or activities. If you have additional medical questions regarding lead you may wish to contact Dr. Barbara Hardman, American Occupational Medical Association, 15 North Wacker Street, Chicago, Illinois 60606.

I hope your questions have been answered. If I can be of further assistance, please feel free to contact me again.


Leo Carey, Director
Directorate of Field Operations

April 2, 1987

P.O. Box 1133
Washington, D.C. 20113

Dear NHIC:

I'm one wife of many who are concerned about our husbands health.

Our husbands are employed at Delco Remy Div. of General Motors, Fitzgerald, Ga., manufacturing batteries.

All the workers are exposed to either sulfuric acid or lead, depending on what job the have in the process of manufacturing.

The workers exposed to lead have periodic blood drawn to check the lead concentration in their blood. If they test in the danger level they are moved till the level decreases.

When their level has decreased they return to their area.

The questions we have are:

1) What happens to the men when they have a constant daily exposure, but their levels stay in the 25-40 ug/100 g of blood range?

2) Can they actually develop symptoms of lead poisoning in this range?

3) Is it possible the lead has caused; mood changes, circulation; gastric & cardiac problems?

Men working with the sulfuric acid complain of nose, throat, & gastric discomfort, including stomach ulcers & skin rashes. Another problem that was discovered by accident is blood typing difficulties.

These are some of the problems we are seeing in our men.

The workers have asked for information on all these discomforts. Plant management has provided little or no information.

Is it possible for you to provide the information we need? Any type of printed material would be greatly appreciated, or the names of departments that will help.

Thank you.


Ellen A. Uhas

P.S. I have gone to our local library, but the encyclopedias were little help.