Federal OSHA · osha.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 Level30 µg/m³ (8-hr TWA)
PEL50 µg/m³ (8-hr TWA)

General Industry

Who is covered: Employees exposed at/above the AL for >30 days/year; also on request (reproductive counseling, intoxication symptoms, respirator-fit breathing difficulty)

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

🩺 Baseline / Pre-Placement

Before first job assignment in a lead work area at/above the AL

  • Detailed work + medical history (prior lead exposure; reproductive history; and GI, hematologic, neurologic, renal, cardiovascular, pulmonary status)
  • Physical examination — emphasis on teeth/gums, hematologic, GI, renal, neurologic, cardiovascular, and pulmonary systems
  • Blood pressure measurement
  • Blood lead level (BLL)
  • Zinc protoporphyrin (ZPP)
  • 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 + ZPP at least every 6 months while at/above the AL (at least every 2 months during the first 6 months of exposure). Full medical examination at least annually if any BLL ≥40 µg/dL was recorded in the preceding 12 months; otherwise on request.

  • Blood lead level (BLL)
  • Zinc protoporphyrin (ZPP)
  • Annual full medical exam (when triggered): repeat the full baseline history, physical examination, and lab panel
🚪 Exit / Termination

At termination of employment in lead work

  • Termination medical examination — required if a periodic exam was not completed within the 6 months prior to job end
  • Blood lead level (BLL)
⚠ Emergency / Post-Exposure

Acute overexposure, signs/symptoms of lead intoxication, employee report of pregnancy, or difficulty breathing during respirator fit-test/use

  • Medical consultation and examination as indicated
  • Blood lead level (BLL)
Abnormal results & exposure-event protocols

Abnormal Results & Exposure-Event Protocols

  • Most recent BLL ≥40 µg/dL 1910.1025(j)(2)(i)(B): Accelerate periodic biological monitoring to BLL every 2 months; continue until two consecutive BLLs are <40 µg/dL. Tests: Blood lead level (BLL), Zinc protoporphyrin (ZPP)
  • BLL ≥60 µg/dL on a single sampling 1910.1025(j)(3)(ii): Provide a follow-up (confirmatory) blood sampling within 2 weeks of the employer receiving the result. Tests: Confirmatory blood lead level (BLL)
  • Single BLL ≥60 µg/dL, OR average of the last three BLLs (or all in the prior 6 months) ≥50 µg/dL — unless the last BLL is <40 1910.1025(k) — Medical Removal Protection: Remove the employee from lead exposure. Maintain wage/benefit (MRP) protection up to 18 months. Return when two consecutive BLLs ≥7 days apart are both <40 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: any detected condition that increases risk from lead exposure, recommended exposure/respirator limitations, results of the exam and tests, and a statement that the employee was informed of medical-removal results. Must NOT reveal unrelated findings.
Reported to / for the employeeEmployee notified in writing within 5 working days of any finding indicating a medical condition; employer furnishes a copy of the written opinion to the employee.
Time limitsWritten opinion furnished to the employee within 5 working days of the employer receiving it.
Second-opinion / multi-physician reviewMultiple-physician review: employee may designate a second physician; if opinions differ, a third (jointly designated) physician resolves.
RecordkeepingMedical surveillance records retained for the duration of employment plus 30 years (29 CFR 1910.1020).

Medical Removal Protection

Mandatory removal at single BLL ≥60, or rolling average ≥50 (unless last <40); return at two consecutive BLLs <40; MRP wage/benefit protection up to 18 months.

Construction

Who is covered: Initial surveillance when exposed on any day at/above the AL; full program when exposed above the AL for >30 days in any consecutive 12-month period

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

🩺 Baseline / Pre-Placement

Before or at the start of a job with exposure at/above the AL

  • Detailed work + medical history (prior lead exposure; reproductive history; GI, hematologic, neurologic, renal, cardiovascular, pulmonary status)
  • Physical examination — emphasis on teeth/gums, hematologic, GI, renal, neurologic, cardiovascular, pulmonary systems
  • Blood pressure measurement
  • Blood lead level (BLL)
  • Zinc protoporphyrin (ZPP)
  • 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 + ZPP at least every 6 months (at least every 2 months during the first 6 months for employees in the full program). Full medical examination at least annually if any BLL ≥40 µg/dL was recorded in the preceding 12 months.

  • Blood lead level (BLL)
  • Zinc protoporphyrin (ZPP)
  • Annual full medical exam (when triggered): repeat the full baseline history, physical examination, and lab panel
🚪 Exit / Termination

At termination of employment in lead work

  • Termination medical examination — required if a periodic exam was not completed within the 6 months prior to job end
  • Blood lead level (BLL)
⚠ Emergency / Post-Exposure

Signs/symptoms of lead intoxication, reproductive counseling request, employee report of pregnancy, or respirator breathing difficulty

  • Medical consultation and examination as indicated
  • Blood lead level (BLL)
Abnormal results & exposure-event protocols

Abnormal Results & Exposure-Event Protocols

  • Most recent BLL ≥40 µg/dL 1926.62(j)(2)(iii): Accelerate periodic biological monitoring to BLL every 2 months; continue until two consecutive BLLs are <40 µg/dL. Tests: Blood lead level (BLL), Zinc protoporphyrin (ZPP)
  • Single BLL ≥50 µg/dL (confirmed by a second sampling within 2 weeks) 1926.62(k) — Medical Removal Protection: Remove the employee from lead exposure (construction has no GI rolling-average trigger). Maintain wage/benefit (MRP) protection up to 18 months. Return when two consecutive BLLs are both <40 µg/dL. Tests: Confirmatory BLL within 2 weeks, Periodic BLL during removal to determine return eligibility

Reporting Requirements

Who performs the evaluationLicensed physician
Reported to employerWritten medical opinion limited to: condition increasing risk from lead, recommended limitations, exam/test results, and a statement that the employee was informed of removal results. Must NOT reveal unrelated findings.
Reported to / for the employeeEmployer provides a copy of the written opinion to the employee; employee informed of any condition needing further evaluation.
Time limitsWritten opinion furnished to the employee within 5 working days of the employer receiving it.
Second-opinion / multi-physician reviewMultiple-physician review available to the employee (second and, if needed, jointly-designated third physician).
RecordkeepingMedical surveillance records retained for the duration of employment plus 30 years (29 CFR 1910.1020).

Medical Removal Protection

Mandatory removal at single BLL ≥50 (confirmed within 2 weeks); return at two consecutive BLLs <40; up to 18 months MRP benefits. Construction lacks the GI rolling-average trigger.

How this compares to Cal/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 Federal OSHA requirements.