Cal/OSHA · dir.ca.gov
Heavy Metals

Lead Medical Surveillance

Inorganic lead causes neurological, renal, hematologic, reproductive, and cardiovascular harm; affects general-industry and construction workers in smelting, battery manufacturing, painting/abatement, welding, and demolition.

Action Level2 µg/m³ (8-hr TWA)
PEL10 µg/m³ (8-hr TWA)

General Industry

Who is covered: Employees exposed at/above the AL (two narrow minimal-exposure exemptions apply — confirm against enrolled text)

Evaluation performed by: Licensed physician (employer-selected; multiple-physician review available to employee)

🩺 Baseline / Pre-Placement

Prior to assignment, or when work first becomes covered — unless a BLL was tested within the prior 2 months

  • Detailed work + medical history (prior lead exposure; reproductive history; GI, hematologic, neurologic, renal, cardiovascular status)
  • Physical examination — emphasis on hematologic, GI, renal, neurologic, cardiovascular systems
  • Blood pressure measurement
  • Blood lead level (BLL)
  • Hemoglobin, hematocrit, red-cell indices
  • BUN and serum creatinine
  • Routine urinalysis with microscopic examination
🕒 Periodic / Routine

Interval-based while covered — NOT result-triggered

Schedule: BLL at least every 6 months while covered (at least every 2 months during the first 6 months of exposure).

  • Blood lead level (BLL)
  • Zinc protoporphyrin (ZPP) — when a prior BLL was ≥20 µg/dL
🚪 Exit / Termination

At termination of employment in lead work

  • Termination medical examination — required unless a periodic exam was completed within the 6 months prior to job end
⚠ Emergency / Post-Exposure

Employee reports signs/symptoms of lead exposure, or following a medical removal

  • Full medical examination
  • Blood lead level (BLL)
Abnormal results & exposure-event protocols

Abnormal Results & Exposure-Event Protocols

  • BLL ≥10 µg/dL 8 CCR 5198 — elevated-BLL response: Employer must implement a written elevated-blood-lead response plan (exposure assessment + controls).
  • BLL 10–19 µg/dL 8 CCR 5198 — accelerated monitoring: BLL at least every 2 months until two consecutive results are <10 µg/dL. Tests: Blood lead level (BLL)
  • BLL ≥20 µg/dL 8 CCR 5198 — accelerated monitoring + exam: BLL at least monthly while Level-3 trigger tasks are performed; provide a full medical examination at least annually. Tests: Blood lead level (BLL), ZPP, Annual full medical examination
  • Single BLL ≥30 µg/dL (eff. Jan 1, 2026 also: two consecutive tests ≥20, or 6-month average ≥20 unless last <15) 8 CCR 5198 — Medical Removal Protection: Remove from exposure; MRP wage/benefit protection up to 18 months. Return at two tests ≥30 days apart both <15 µg/dL. Tests: Periodic BLL during removal to determine return eligibility

Reporting Requirements

Who performs the evaluationLicensed physician
Reported to employerWritten medical opinion limited to fitness, recommended limitations, and removal/return recommendations; must not disclose unrelated findings.
Reported to / for the employeeEmployee informed of exam results and of any condition needing further evaluation; furnished a copy of the written opinion.
Time limitsWritten opinion furnished to the employee within 5 working days of employer receipt.
Second-opinion / multi-physician reviewMultiple-physician review available to the employee.
RecordkeepingMedical records retained for the duration of employment plus 40 years (8 CCR 3204).

Medical Removal Protection

Removal at single BLL ≥30 µg/dl; (eff. Jan 1, 2026) two consecutive tests both ≥20, or 6-month average ≥20 unless last test <15; return at two consecutive tests ≥30 days apart both <15 µg/dl; up to 18 months benefits.

Construction

Who is covered: Employees exposed at/above the AL or performing defined lead trigger tasks (limited exceptions for ≤30 days/yr at ≤10 µg/m³)

Evaluation performed by: Licensed physician (employer-selected; multiple-physician review available to employee)

🩺 Baseline / Pre-Placement

Before assignment or before trigger-task work — unless a BLL was tested within the prior 2 months

  • Detailed work + medical history (prior lead exposure; reproductive history; GI, hematologic, neurologic, renal, cardiovascular status)
  • Physical examination — emphasis on hematologic, GI, renal, neurologic, cardiovascular systems
  • Blood pressure measurement
  • Blood lead level (BLL)
  • Hemoglobin, hematocrit, red-cell indices
  • BUN and serum creatinine
  • Routine urinalysis with microscopic examination
🕒 Periodic / Routine

Interval-based while covered — NOT result-triggered

Schedule: BLL at least every 6 months while covered (at least every 2 months during the first 6 months of exposure).

  • Blood lead level (BLL)
  • Zinc protoporphyrin (ZPP) — when the last BLL was ≥20 µg/dL
⚠ Emergency / Post-Exposure

Airborne lead >500 µg/m³, or during Level-3 trigger tasks

  • Blood lead level (BLL) at least monthly during the triggering condition
Abnormal results & exposure-event protocols

Abnormal Results & Exposure-Event Protocols

  • BLL 10–19 µg/dL 8 CCR 1532.1 — accelerated monitoring: BLL at least every 2 months until two consecutive results are <10 µg/dL. Tests: Blood lead level (BLL)
  • BLL ≥20 µg/dL 8 CCR 1532.1 — accelerated monitoring: BLL at least monthly. Tests: Blood lead level (BLL), ZPP
  • BLL ≥30 µg/dL (eff. Jan 1, 2026 also: last two tests ≥20, or 6-month average ≥20) 8 CCR 1532.1 — Medical Removal Protection: Remove from exposure; MRP wage/benefit protection up to 18 months. Return at two tests ≥30 days apart both <15 µg/dL. Tests: Periodic BLL during removal to determine return eligibility

Reporting Requirements

Who performs the evaluationLicensed physician
Reported to employerWritten medical opinion limited to fitness, recommended limitations, and removal/return recommendations; must not disclose unrelated findings.
Reported to / for the employeeEmployee informed of exam results and of any condition needing further evaluation; furnished a copy of the written opinion.
Time limitsWritten opinion furnished to the employee within 5 working days of employer receipt.
Second-opinion / multi-physician reviewMultiple-physician review available to the employee.
RecordkeepingMedical records retained for the duration of employment plus 40 years (8 CCR 3204). Note: 1532.1 specifies no termination blood-lead test.

Medical Removal Protection

Removal at BLL ≥30 µg/dl (eff. Jan 1, 2026 also: last two tests ≥20, or 6-month average ≥20); return at two tests ≥30 days apart both <15 µg/dl; up to 18 months benefits.

How this compares to Federal OSHA: California's 2025 revision slashed the AL to 2 µg/m³ and PEL to 10 µg/m³ (vs federal 30/50) and lowered the MRP removal/return thresholds dramatically (removal at BLL ≥30 vs federal 50–60) — far more protective than federal. California also adds tiered accelerated-monitoring triggers (10–19, ≥20) and a written elevated-BLL response plan.

Occu-Med handles Lead surveillance end-to-end

Scheduling, exams, lab panels, physician review, removal/return determinations, and audit-ready recordkeeping — fully compliant with Cal/OSHA requirements.