Dietary zinc compounds are not a violation of the lead standard.
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.
August 31, 1984
W. Scott Railton
Reed, Smith, Shaw, and McClay
1150 Connecticut Avenue, N.W.
Washington, D.C. 20036
Dear Mr. Railton:
This is in response to your letter of June 19, concerning the applicability of the lead standard's prophylactic chelation prohibition (29 CFR 1910.1025(J)(4)) to the administration of a dietary zinc compound.
Based on your assertion that the compound contemplated for use blocks lead absorption, it appears that chelation is not involved. Therefore, a violation of 29 CFR 1910.1025(J)(4) would not exist.