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 30, 1996

Mr. David A. Klemenz
Outokumpu American Brass
Department of Environment, Safety and
Post Office Box 981 - 70 Sayre St.
Buffalo, New York 14240-0981

Dear Mr. Klemenz:

This is in response to your letter to the Occupational Safety and Health Administration (OSHA) requesting a definition of the word 'ingot' as it applies to 29 CFR 1910.1025, Occupational Exposure to Lead - Final Rule.

OSHA provides an interpretation of the word 'ingot' on page 6189 of Federal Register, Vol. 46, No. 13, published January 21, 1981, titled "Occupational Exposure to Lead; Supplemental Statement of Reasons and Amendments of Standard; Final Rule." The word 'ingot' for the brass and bronze ingot manufacturing industry is expressed in terms of its end use, as copper-based ingots of specific alloy compositions produced and sold primarily to nonferrous foundries. The shape of the ingot is not the distinguishing characteristic in defining an ingot as it applies to 29 CFR 1910.1025. When the ingots are sold to a nonferrous foundry for further processing, then the ingot manufacturer must comply with the requirements under 29 CFR 1910.1025(e)(1) for the brass and bronze ingot manufacture industry.

Thank you for seeking clarification on this issue and for your interest in safety and health in the workplace.


Ruth McCully, Director
Office of Health Compliance Assistance

October 23, 1995

Occupational Safety and Health Administration
U.S. Department of Labor
Attn. Mr. John Miles
Director of Compliance
Room N-3462
200 Constitution Avenue NW
Washington, DC 20210

Re: Occupational Exposure to Lead
October 11, 1995
Amendments to Final Rule

Dear Mr. Miles,

After a telephone discussion with Mr. Richard Fairfax of your office, I am writing to obtain a formal definition of the word, "ingot" as it applies to this standard.

The dictionary definition of the word, "a mass of metal cast into a convenient shape for storage or transportation to be later processed" is fairly broad. For instance, although it is obvious that a facility casting prismatic shapes is casting ingots, what about a facility casting hollow, cylindrical shapes such as is the case of bushings? This hollow, cylindrical shape is convenient and will be further processed.

Thank you for your consideration and I look forward to your response.


David A. Klemenz
Mechanical Engineer/Outokumpu
American Brass