The lead standard does not address pay for showering.
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.
October 22, 1981
Mr. Alvin Starr
President, U.A.W. #1049
General Battery Corporation
2040 Amelia Street
Dallas, Texas 75235
Dear Mr. Starr:
OSHA's Dallas Regional Office requested us to respond to your inquiry of August 18, 1981, as to whether General Battery's policy of ten minutes of paid shower time is in agreement with OSHA's lead standard, 29 CFR 1910.1025. Please accept my apology for our delay in replying.