Lead Exposure at Work: OSHA 1910.1025 Requirements, Blood Lead Monitoring, and Medical Removal

Lead hasn’t gone away. It’s still present in older building paint, in battery plants, in foundries, in radiator shops, and on bridges with decades-old coatings. Workers in these environments face real exposure risk, and OSHA’s lead standards set hard requirements that go well beyond handing out respirators.

The general industry standard is 29 CFR 1910.1025. The construction standard is 29 CFR 1926.62. Both share the same permissible exposure limit and action level, but 1926.62 has additional requirements for specific high-hazard tasks that come up in construction work.

Where Lead Exposure Still Happens

Construction gets a lot of attention because of lead paint in pre-1978 buildings. Renovation, demolition, and abrasive blasting on older structures can generate significant airborne lead. Bridge rehabilitation work is one of the highest-risk categories, especially when workers are grinding, torch cutting, or blasting coated steel.

Outside construction, battery manufacturing and recycling operations carry heavy lead burdens. Smelting and foundry work, radiator repair, and shooting ranges are also common exposure settings. At indoor shooting ranges, spent ammunition releases lead particles into the air with every shot fired. OSHA has cited range operators under 1910.1025 for inadequate ventilation and failure to provide biological monitoring.

The exposure route is primarily inhalation of lead dust and fumes. Ingestion matters too, which is why hygiene practices are part of the standard, not an afterthought.

The Numbers: PEL and Action Level

The OSHA PEL for lead is 50 micrograms per cubic meter (µg/m³) as an 8-hour time-weighted average. That’s the same number in both 1910.1025 and 1926.62.

The action level is 30 µg/m³ as an 8-hour TWA. Crossing the action level, even if you’re below the PEL, triggers a set of requirements including air monitoring, biological monitoring, and medical surveillance.

Worth noting: the PEL dates from 1978. NIOSH’s recommended exposure limit is also 50 µg/m³, but NIOSH has called for a lower limit based on more recent health data. The ACGIH threshold limit value is 20 µg/m³. Many industrial hygienists treat the ACGIH TLV as the practical target rather than the OSHA PEL, because the health effects of chronic lead exposure are well-documented at levels below 50 µg/m³.

Air Monitoring Requirements

If workers might be exposed to lead at or above the action level, you need to conduct air monitoring to determine actual exposure. Initial monitoring is required before or at the time of job initiation.

If monitoring shows exposure is below the action level, you can stop monitoring, but you have to conduct periodic monitoring whenever there’s a change in production, process, control equipment, personnel, or work practices that might affect exposure.

If exposure is at or above the action level but below the PEL, monitoring is required every 6 months. If exposure is at or above the PEL, monitoring is required every 3 months until two consecutive measurements, taken at least 7 days apart, show exposure below the PEL.

Biological Monitoring: Blood Lead Testing

This is where the lead standard goes further than most OSHA standards. It requires biological monitoring, meaning blood lead level (BLL) testing, not just air sampling.

Blood lead monitoring is required when workers are exposed at or above the action level for more than 30 days per year. Initial testing happens before or at the first exposure. After that, the frequency depends on results.

If your blood lead level is below 40 µg/dL, testing continues every 6 months. If it’s between 40 and 60 µg/dL, testing moves to every 2 months. Above 60 µg/dL, testing is monthly. The schedule is spelled out in 1910.1025(j).

These tests have to be performed by or under the supervision of a licensed physician, at no cost to the employee.

Medical Removal Protection

Medical removal protection (MRP) is one of the most significant parts of the lead standard, and it’s the part that catches employers off guard.

MRP is triggered when a worker’s blood lead level reaches 60 µg/dL on a single test, or averages 50 µg/dL over the previous 12 months, or when a physician recommends removal for medical reasons. At that point, the worker must be removed from the lead-exposure environment.

Here’s the part that matters: removed workers keep their current pay, seniority, and benefits. You can’t cut their wages because they’ve been medically removed. The standard calls it “earnings maintenance,” and OSHA enforces it. The worker returns to lead work when two consecutive blood tests, taken at least 4 weeks apart, show a level below 40 µg/dL.

The medical removal protection applies for up to 18 months. If the worker can’t return to their original job after 18 months, the employer’s MRP obligations end, but the worker still can’t be terminated solely for that reason.

Engineering Controls Come First

The hierarchy matters here. The standard requires employers to implement engineering and work practice controls to reduce exposure below the PEL before relying on respirators as the main protection.

Engineering controls that work: local exhaust ventilation on grinding, cutting, and abrasive blasting equipment; wet methods to suppress dust during demolition and cleanup; enclosed or semi-enclosed operations for high-exposure processes; and HEPA-filtered vacuum systems for cleanup instead of dry sweeping or compressed air blowdown.

Substitution is worth considering where it’s practical. Some surface coatings and materials can replace lead-containing versions. Not always feasible, but worth evaluating as part of a solid industrial hygiene program.

When engineering controls can’t get exposure below the PEL, respiratory protection is required. Check the respiratory protection guide for fit test and medical clearance requirements. For most lead dust applications, a half-face air-purifying respirator with N100 filters is the minimum. Abrasive blasting on lead-painted structures requires supplied-air respirators.

PPE Beyond Respirators

Lead settles on skin and clothing. Workers need protective clothing, including coveralls, gloves, and shoe covers or dedicated work boots, when working in lead-exposure areas. The employer provides and launders this clothing. Workers can’t take contaminated clothing home, because that transfers lead exposure to their families.

For gloves, nitrile is generally adequate for dust work. When handling lead-acid batteries or liquid lead, heavier chemical-resistant gloves are needed. See the PPE guide for selection criteria and documentation requirements.

Eye and face protection depends on the task. Grinding and abrasive blasting require full-face protection regardless of lead considerations, but the lead standard doesn’t add specific eye protection requirements beyond what the task hazard warrants.

Hygiene Practices

Lead ingestion through hand-to-mouth contact is a real route. The standard requires employers to provide wash facilities, change rooms, and lunchrooms that are separate from lead-contaminated areas.

Workers can’t eat, drink, smoke, or apply cosmetics in lead-exposure areas. This sounds basic, but it’s commonly cited by OSHA inspectors who find lunch eaten at contaminated work surfaces.

Change rooms need to be separate from street clothes storage. The idea is to prevent contaminated work clothing from contaminating personal clothing. Showers are required when workers are exposed above the PEL.

Training Requirements

The lead standard requires annual training for workers who are exposed at or above the action level. Training has to cover the health effects of lead exposure, the specific nature of operations that could result in exposure above the action level, the purpose, proper selection, fitting, use, and limitations of respiratory protection, engineering controls and work practices, the purpose and description of the medical surveillance program, and the content of the lead standard itself.

The standard also requires written hazard communication. Containers of lead and lead-containing materials need GHS labels. The SDS for lead materials must be accessible.

Medical Surveillance Program

Beyond blood lead testing, workers exposed above the action level for more than 30 days per year get a full medical surveillance program. This includes a pre-placement medical exam and periodic exams at least annually.

The examining physician needs to know the worker’s work history, medical history, and the results of all prior blood lead tests. The employer gets a written opinion from the physician that includes any recommended limitations on the worker’s exposure. The physician’s opinion goes to the employee as well, including any findings that might indicate increased susceptibility to lead’s health effects.

The physician’s opinion can’t include specific findings or diagnoses unrelated to lead occupational exposure, protecting the worker’s medical privacy.

If you’re building out a written exposure control plan for lead, the industrial hygiene program guide covers the program structure, and the new employee safety orientation explains how to get exposure monitoring and medical surveillance requirements into your onboarding process before the first day of lead work.