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 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 (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 + ZPP at least every 6 months while at/above the AL. Accelerated to at least every 2 months when BLL is at or above 40 µg/100 g, continuing until two consecutive BLLs are below 40 µg/100 g; at least monthly during the removal period (29 CFR 1910.1025(j)(2)(i)).

  • 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 (regulatory term: zinc protoporphyrin)
  • Annual full medical exam — required whenever any BLL during the preceding 12 months was at or above 40 µg/100 g (29 CFR 1910.1025(j)(3)(i)(A)): repeat 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 fitting test or during use (29 CFR 1910.1025(j)(3)(i)(C)); and as medically appropriate following medical removal or limitation (1910.1025(j)(3)(i)(D))

  • Medical examination or consultation — content determined by the examining physician (29 CFR 1910.1025(j)(3)(ii))
  • Pregnancy testing or laboratory evaluation of male fertility — required if requested by the employee (29 CFR 1910.1025(j)(3)(ii))
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 employeeBlood lead level: employee notified in writing within 5 working days after receipt of biological monitoring results showing a blood lead level at or above 40 µg/100 g (1910.1025(j)(2)(iv)); employer furnishes the employee a copy of the physician's written medical opinion (no specific deadline stated).
Time limitsBlood lead level results: employer notifies in writing within 5 working days after receipt of biological monitoring results for any employee with BLL at or above 40 µg/100 g (29 CFR 1910.1025(j)(2)(iv)). Written medical opinion: no specific deadline stated in the standard for furnishing a copy to the employee.
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 at least 40 years, or for the duration of employment plus 20 years, whichever is longer (29 CFR 1910.1025(n)(2)(iv)).

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 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 (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: For employees in the full program (exposed >30 days/12 months): BLL + ZPP at least every 2 months for the first 6 months of the program, then at least every 6 months thereafter. Accelerated to at least every 2 months whenever any BLL is at or above 40 µg/dl, continuing until two consecutive BLLs are below 40 µg/dl. At least monthly during the removal period (29 CFR 1926.62(j)(2)(i)(A)-(C)).

  • 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 (regulatory term: zinc protoporphyrin)
  • Annual full medical exam — required whenever any BLL during the preceding 12 months was at or above 40 µg/dl (29 CFR 1926.62(j)(3)(i)(A)): repeat 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 fitting test or during use (29 CFR 1926.62(j)(3)(i)(B)); and as medically appropriate following medical removal or limitation (1926.62(j)(3)(i)(C))

  • Medical examination or consultation — content determined by the examining physician (29 CFR 1926.62(j)(3)(ii))
  • Pregnancy testing or laboratory evaluation of male fertility — required if requested by the employee (29 CFR 1926.62(j)(3)(ii))
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 limitsBlood lead level results: employer notifies each employee in writing within 5 working days after receipt of biological (blood-lead) monitoring results, regardless of level (29 CFR 1926.62(j)(2)(iv)(A)); employees with a blood lead level at or above 40 µg/dl are additionally notified that the standard requires temporary medical removal with Medical Removal Protection benefits (1926.62(j)(2)(iv)(B)). Written medical opinion: no specific deadline stated in 1926.62(j)(3)(v)(A) for furnishing a copy to the employee. (The separate 5-working-day air-monitoring notice under 1926.62(d)(8)(i) is exposure monitoring, not medical surveillance.)
Second-opinion / multi-physician reviewMultiple-physician review available to the employee (second and, if needed, jointly-designated third physician).
RecordkeepingMedical surveillance records maintained in accordance with 29 CFR 1910.33 as referenced in 1926.62(n)(2)(iv). The construction lead standard does not specify its own numeric retention period.

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.

Shipyard / Maritime

Who is covered: Shipyard employment — 29 CFR 1915.1025 applies the 1910.1025 general-industry requirements verbatim. 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 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 (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 + ZPP at least every 6 months while at/above the AL. Accelerated to at least every 2 months when BLL is at or above 40 µg/100 g, continuing until two consecutive BLLs are below 40 µg/100 g; at least monthly during the removal period (29 CFR 1910.1025(j)(2)(i)).

  • 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 (regulatory term: zinc protoporphyrin)
  • Annual full medical exam — required whenever any BLL during the preceding 12 months was at or above 40 µg/100 g (29 CFR 1910.1025(j)(3)(i)(A)): repeat 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 fitting test or during use (29 CFR 1910.1025(j)(3)(i)(C)); and as medically appropriate following medical removal or limitation (1910.1025(j)(3)(i)(D))

  • Medical examination or consultation — content determined by the examining physician (29 CFR 1910.1025(j)(3)(ii))
  • Pregnancy testing or laboratory evaluation of male fertility — required if requested by the employee (29 CFR 1910.1025(j)(3)(ii))
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 employeeBlood lead level: employee notified in writing within 5 working days after receipt of biological monitoring results showing a blood lead level at or above 40 µg/100 g (1910.1025(j)(2)(iv)); employer furnishes the employee a copy of the physician's written medical opinion (no specific deadline stated).
Time limitsBlood lead level results: employer notifies in writing within 5 working days after receipt of biological monitoring results for any employee with BLL at or above 40 µg/100 g (29 CFR 1910.1025(j)(2)(iv)). Written medical opinion: no specific deadline stated in the standard for furnishing a copy to the employee.
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 at least 40 years, or for the duration of employment plus 20 years, whichever is longer (29 CFR 1910.1025(n)(2)(iv)).

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.

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. 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 Federal OSHA requirements.