Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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



August 10, 1990

Ms. Beth Purcell
Director of Industrial Hygiene
Ohio Bureau of Workers Compensation
246 North High Street
Columbus, Ohio 43266-0581

Dear Ms. Purcell:

This is in response to your letter of July 19, requesting a written interpretation of the Occupational Safety and Health Administration's (OSHA) Occupational Exposure to Lead Standard; Final Rule, 29 CFR 1910.1025(e)(1), Table 1, published January 30, 1990 in the Federal Register.

The permissible exposure limit (PEL) for inorganic lead is 50 ug/m(3). At this time, employers in the non-ferrous foundry industry may use any combination of controls, including respirators, to achieve the 50 ug/m(3) limit. In addition, these employers must use administrative or engineering controls to the extent feasible, to achieve 200 ug/m(3).

Within five years from the date the United States Court of appeals for the District of Columbia Circuit lifts the stay on the implementation of paragraph (e)(l) for this industry, large non-ferrous foundries, those with 20 or more employees, are required to achieve the 50 ug/m(3) PEL by means of engineering and work practice controls. However, within five years of the lifting of the stay, small non-ferrous foundries, those with fewer than 20 employees, will be required only to achieve a 75 ug/m(3) level using engineering and work practice controls. The Agency has found that this control requirement is economically feasible for small non-ferrous foundries. In order for the small non-ferrous foundries to meet the 50 ug/m(3) PEL in accordance with 29 CFR 1910.1025(e)(2), engineering and work practice controls instituted to achieve 75 ug/m(3) must be supplemented with respirators.

We hope this information clarifies your uncertainties with the standard. Should you require further interpretations of this or other OSHA standards, please contact the following office:

Directorate of Compliance Programs
U.S. Department of Labor, OSHA
200 Constitution Avenue N.W.
Washington, D.C. 20210
(202) 523-9308


John Martonik, Deputy Director
Health Standards Programs