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 or above the action level. Two exemptions: (1) employees not exposed at or above the action level for 30 or more days in any 12 consecutive months AND not exposed on any day above 10 µg/m³ as an 8-hour TWA; (2) employees not exposed at or above the action level for 15 or more days in any 12 consecutive months AND not exposed on any day above 20 µg/m³ as an 8-hour TWA (8 CCR 5198(j)(1)).

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 teeth/gums, hematologic, GI, renal, neurologic, and cardiovascular systems; pulmonary status evaluated if respiratory protection will be used (5198(j)(3)(B)2)
  • Blood pressure measurement
  • Blood test measuring the amount of lead in your blood (BLL) (regulatory term: blood lead level)
  • Blood test (ZPP) that flags lead's effect on red-blood-cell production (required when the employee's last BLL was ≥20 µg/dl (5198(j)(3)(B)4.c)) (regulatory term: zinc protoporphyrin)
  • Hemoglobin, hematocrit, red-cell indices, peripheral blood smear
  • BUN and serum creatinine
  • Routine urinalysis with microscopic examination
🕒 Periodic / Routine

Interval-based while covered — NOT result-triggered

Schedule: BLL at least every 2 months for the first 6 months, then at least every 6 months (the 2-month cycle restarts after a change in work task or process likely to increase lead exposure). Accelerated: at least every 2 months while the last BLL is 10–19 µg/dl, until two consecutive results taken at least 30 days apart are below 10 µg/dl; at least monthly while the last BLL is ≥20 µg/dl and during any medical-removal period (8 CCR 5198(j)(2)(A)1-5).

  • Blood test measuring the amount of lead in your blood (BLL) (regulatory term: blood lead level)
  • Blood test (ZPP) that flags lead's effect on red-blood-cell production (with each medical exam when the last BLL was ≥20 µg/dl (8 CCR 5198(j)(3)(B)4.c)) (regulatory term: zinc protoporphyrin)
  • Annual full medical exam (when triggered): as soon as possible after any BLL ≥20 µg/dl if no lead-specific exam was done in the preceding 12 months, then at least annually until the BLL is below 20 µg/dl (8 CCR 5198(j)(3)(A)1) — repeats the full baseline history, physical examination, and lab panel
⚠ Emergency / Post-Exposure

As soon as possible upon employee notification of: signs or symptoms commonly associated with lead intoxication, a desire for medical advice about the effects of current or past lead exposure on the ability to procreate a healthy child, or difficulty in breathing during a respirator fit test or during use (8 CCR 5198(j)(3)(A)3); and as soon as possible, then as medically appropriate, following medical removal (5198(j)(3)(A)4)

  • Detailed work + medical history (prior lead exposure; reproductive history; GI, hematologic, neurologic, renal, cardiovascular status)
  • Physical examination — emphasis on teeth/gums, hematologic, GI, renal, neurologic, and cardiovascular systems; pulmonary status evaluated if respiratory protection will be used (5198(j)(3)(B)2)
  • Blood pressure measurement
  • Blood test measuring the amount of lead in your blood (BLL) (regulatory term: blood lead level)
  • Blood test (ZPP) that flags lead's effect on red-blood-cell production (required when the employee's last BLL was ≥20 µg/dl (5198(j)(3)(B)4.c)) (regulatory term: zinc protoporphyrin)
  • Hemoglobin, hematocrit, red-cell indices, peripheral blood smear
  • BUN and serum creatinine
  • Routine urinalysis with microscopic examination
  • Pregnancy testing or laboratory evaluation of male fertility — required if requested by the employee (5198(j)(3)(B)2)
Abnormal results & exposure-event protocols

Abnormal Results & Exposure-Event Protocols

  • BLL ≥10 µg/dl 8 CCR 5198(j)(2)(E): Employer establishes and implements a written elevated blood lead level response plan describing the specific means used to reduce and maintain the employee's BLL below 10 µg/dl, and provides training and instruction as needed to correct work practices identified in the plan. Exception: not required when a BLL ≥10 µg/dl is detected only in the employee's blood lead test done prior to their first assignment to covered work.
  • BLL 10–19 µg/dl 8 CCR 5198(j)(2)(A)4: BLL at least every 2 months until two consecutive results, taken at least 30 days apart, are below 10 µg/dl. Tests: Blood lead level (BLL)
  • BLL ≥20 µg/dl 8 CCR 5198(j)(2)(A)5; (j)(3)(A)1: BLL at least monthly (and at least monthly during any medical-removal period). Medical examination as soon as possible if none was done in the preceding 12 months, then at least annually until the BLL is below 20 µg/dl; exams include ZPP while the last BLL is ≥20 µg/dl. Tests: Blood lead level (BLL), ZPP (exam element), 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(k)(1); (k)(3)(A): 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.
Elevated blood lead level responseWhenever an employee's blood lead level is at or above 10 µg/dl, the employer must establish and implement a written elevated blood lead level response plan describing the specific means that will be used to reduce and maintain that employee's BLL below 10 µg/dl, and provide training and instruction as needed to correct any work practices identified in the plan (8 CCR 5198(j)(2)(E)). Exception: not required when a BLL at or above 10 µg/dl is detected only in the employee's blood lead test done prior to their first assignment to covered work.
Time limitsBlood lead level results: employer notifies in writing within 5 working days after receipt of blood lead test results for every employee, regardless of level (8 CCR 5198(j)(2)(C)). Written medical report: the examining PLHCP explains the results and provides each employee a written medical report within 30 days of each medical examination (8 CCR 5198(j)(5)). The 15-day figure in 5198 is the employee's window to initiate a second-physician opinion (8 CCR 5198(j)(3)(C)2), not a medical-surveillance notification deadline; the 15-day air/exposure monitoring figure is exposure monitoring, not medical surveillance.
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 teeth/gums, hematologic, GI, renal, neurologic, and cardiovascular systems; pulmonary status evaluated if respiratory protection will be used (1532.1(j)(3)(B)2)
  • Blood pressure measurement
  • Blood test measuring the amount of lead in your blood (BLL) (regulatory term: blood lead level)
  • Blood test (ZPP) that flags lead's effect on red-blood-cell production (required when the employee's last BLL was ≥20 µg/dl (1532.1(j)(3)(B)4.c)) (regulatory term: zinc protoporphyrin)
  • Hemoglobin, hematocrit, red-cell indices, peripheral blood smear
  • BUN and serum creatinine
  • Routine urinalysis with microscopic examination
🕒 Periodic / Routine

Interval-based while covered — NOT result-triggered

Schedule: BLL at least every 2 months for the first 6 months after initial placement, then at least every 6 months (the 2-month cycle restarts after a change in task likely to increase lead exposure). Accelerated: at least every 2 months while the last BLL is 10–19 µg/dl, until two consecutive results taken at least 30 days apart are below 10 µg/dl; at least monthly while the last BLL is ≥20 µg/dl, during any medical-removal period, while performing level 3 trigger tasks, and while airborne exposure is above 500 µg/m³ as an 8-hour TWA (8 CCR 1532.1(j)(2)(A)1-6).

  • Blood test measuring the amount of lead in your blood (BLL) (regulatory term: blood lead level)
  • Blood test (ZPP) that flags lead's effect on red-blood-cell production (with each medical exam when the last BLL was ≥20 µg/dl (8 CCR 1532.1(j)(3)(B)4.c)) (regulatory term: zinc protoporphyrin)
  • Annual full medical exam (when triggered): as soon as possible after any BLL ≥20 µg/dl if no lead-specific exam was done in the preceding 12 months, then at least annually until the BLL is below 20 µg/dl (8 CCR 1532.1(j)(3)(A)1) — repeats the full baseline history, physical examination, and lab panel
⚠ Emergency / Post-Exposure

As soon as possible upon employee notification of: signs or symptoms commonly associated with lead intoxication, a desire for medical advice about the effects of current or past lead exposure on the ability to procreate a healthy child, pregnancy, or difficulty in breathing during a respirator fit test or during use (8 CCR 1532.1(j)(3)(A)3); and as soon as possible, then as medically appropriate, following medical removal (1532.1(j)(3)(A)4)

  • Detailed work + medical history (prior lead exposure; reproductive history; GI, hematologic, neurologic, renal, cardiovascular status)
  • Physical examination — emphasis on teeth/gums, hematologic, GI, renal, neurologic, and cardiovascular systems; pulmonary status evaluated if respiratory protection will be used (1532.1(j)(3)(B)2)
  • Blood pressure measurement
  • Blood test measuring the amount of lead in your blood (BLL) (regulatory term: blood lead level)
  • Blood test (ZPP) that flags lead's effect on red-blood-cell production (required when the employee's last BLL was ≥20 µg/dl (1532.1(j)(3)(B)4.c)) (regulatory term: zinc protoporphyrin)
  • Hemoglobin, hematocrit, red-cell indices, peripheral blood smear
  • BUN and serum creatinine
  • Routine urinalysis with microscopic examination
  • Pregnancy testing or laboratory evaluation of male fertility — required if requested by the employee (1532.1(j)(3)(B)2)
Abnormal results & exposure-event protocols

Abnormal Results & Exposure-Event Protocols

  • BLL ≥10 µg/dl 8 CCR 1532.1(j)(2)(E): Employer establishes and implements a written elevated blood lead level response plan describing the specific means used to reduce and maintain the employee's BLL below 10 µg/dl, and provides training and instruction as needed to correct work practices identified in the plan. Exception: not required when a BLL ≥10 µg/dl is detected only in the employee's initial blood lead testing.
  • BLL 10–19 µg/dl 8 CCR 1532.1(j)(2)(A)3: BLL at least every 2 months until two consecutive results, taken at least 30 days apart, are below 10 µg/dl. Tests: Blood lead level (BLL)
  • BLL ≥20 µg/dl 8 CCR 1532.1(j)(2)(A)4; (j)(3)(A)1: BLL at least monthly (and at least monthly during any medical-removal period). Medical examination as soon as possible if none was done in the preceding 12 months, then at least annually until the BLL is below 20 µg/dl; exams include ZPP while the last BLL is ≥20 µg/dl. Tests: Blood lead level (BLL), ZPP (exam element), Full medical examination
  • Level 3 trigger task work, or airborne exposure above 500 µg/m³ as an 8-hour TWA (without regard to respirator use) 8 CCR 1532.1(j)(2)(A)5-6: BLL at least monthly while the condition continues, plus a blood test taken within 3 days after discontinuing all such work. Tests: Blood lead level (BLL)
  • Single BLL ≥30 µg/dl (eff. Jan 1, 2026 also: last two tests ≥20, or 6-month average ≥20 unless last <15) 8 CCR 1532.1(k)(1)(A); (k)(1)(C): 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.
Elevated blood lead level responseWhenever an employee's blood lead level is at or above 10 µg/dl, the employer must establish and implement a written elevated blood lead level response plan describing the specific means that will be used to reduce and maintain that employee's BLL below 10 µg/dl, and provide training and instruction as needed to correct any work practices identified in the plan (8 CCR 1532.1(j)(2)(E)). Exception: not required when a BLL at or above 10 µg/dl is detected only in the employee's initial blood lead testing.
Time limitsBlood lead level results: employer notifies each employee in writing within 5 working days after receipt of blood lead test results, regardless of level (8 CCR 1532.1(j)(2)(C)). Written medical report: the examining PLHCP explains the results and provides each employee a written medical report within 30 days of each medical examination (8 CCR 1532.1(j)(3)(E)). The 15-day figure in 1532.1 is the employee's window to initiate a second-physician opinion (8 CCR 1532.1(j)(3)(C)2), not a medical-surveillance notification deadline; air/exposure monitoring notification is exposure monitoring, not medical surveillance.
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 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. Shipyards: federal lead in shipyard employment is covered by 29 CFR 1915.1025, which applies the 1910.1025 general-industry requirements verbatim; California has no separate shipyard lead section (Title 8 Subchapter 18, Article 4 contains asbestos, chromium (VI), and beryllium sections only) — 8 CCR 5198 covers shipyard lead work.

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.