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.

December 1, 1999

[Name & Address Withheld]

Dear [Name Withheld]:

Thank you for your letter of May 11, 1999 to the Occupational Safety and Health Administration's (OSHA's) Office of Statistics. Your letter has been referred to the [Office of Health Enforcement] for response. You have questions regarding the handling of lead, which you described as lead balls or buckshot. We apologize for this delay in providing you with a response.

The OSHA standard which regulates exposure to lead in general industry is 29 CFR 1910.1025. This standard requires that employers ensure that the airborne levels of lead remain below the permissible exposure limit (PEL) of 50 µg/m3 as averaged over an time period. Lead becomes airborne when it is heated or abraded. It is unlikely that solid lead buckshot would produce an airborne-exposure level above the PEL or the action level of 30 µg/m3. However, it is advisable to wear gloves while handling the lead shot and to always wash your hands before eating, drinking, or smoking.

Under the lead standard, your employer is required to evaluate employee airborne exposure by conducting an initial determination. In general, this initial determination is based on data which is collected by monitoring, even if the monitoring results come from other, similar plants and operations. In the absence of monitoring data, the employer must be able to clearly demonstrate that the usage or handling of lead will not create airborne concentrations in excess of the action level and the employer must have a written explanation as to why exposures are not expected to exceed the action level. This data and information must be maintained by and available through your employer.

Additionally, all employers whose workplaces present a potential airborne exposure to lead at any level must inform their employees of the content of appendices A and B of the lead standard. The employer may use any method which effectively apprises employees of this content, including posting, group discussions, verbal or written notification. These appendices, Substance Exposure Sheet for Occupational Exposure to Lead and Employee Standard Summary, are enclosed for your convenience.

For further information or inquiries, or to register a complaint, the OSHA Area Office closest to your address is:

US Department of Labor - OSHA
Wilkes-Barre Area Office
The Stegmaier Building
7 North Wilkes-Barre Boulevard, Suite 410
Wilkes-Barre, PA 18702-5241
Phone: (570) 826-6538
Fax: (570) 821-4170 FAX

Thank you for your interest in occupational safety and health. If you have any further questions, please feel free to contact the [Office of Health Enforcement at (202) 693-2190].


Richard E. Fairfax, Director
[Directorate of Enforcement Programs]

[Corrected 6/2/2005]