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Recording lead-related medical removals

Summary A company asked how lead-related medical removals fit OSHA's injury and illness log. OSHA said lead-standard removal records were separate, but removals tied to diagnosed illness or symptoms of lead poisoning also belonged in the occupational injury and illness log. OSHA archives the letter.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1980-02-20
Date issued
February 20, 1980
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.
Status last verified October 10, 2026

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

February 20, 1980

Mr. David M. Wassum
Corporate Safety Coordinator
RSR Corporation
[Recipient address omitted]
Dear Mr. Wassum:

Assistant Secretary Eula Bingham has asked me to respond to your request for a clarification of 29 CFR 1904, as it pertains to medical removals made pursuant to the lead standard, 29 CFR 1910.1025. Please accept my apology for the delay in this reply.

The recordkeeping requirements of 29 CFR 1910.1025(n)(3) for recording cases of (a) employees removed from exposure to lead due to elevated blood lead levels and (b) employees removed because they have symptoms of lead poisoning, are separate from the OSHA occupational injury and illness recordkeeping system requirement (29 CFR 1904).

The lead standard does not specify a blood lead level limit for OSHA injury and illness recording. Medical removal cases of employees with symptoms of lead poisoning such as anemia and renal complications, or blood lead levels which the examining physician diagnosed as indicating illness, continue to be entered in the OSHA occupational injury and illness recordkeeping system (OSHA 200 log).

Therefore, some instances of removal where blood lead levels are below those specified for removal by 29 CFR 1910.1025(k) must be recorded in conformance with 29 CFR 1904; for example, when an examining physician has diagnosed the employee to be suffering adverse health effects. The record presented in the preamble to the lead standard demonstrates that adverse signs and symptoms have been observed in workers with blood leads as low as 40 ug/100g.

This information should aid in revising your proposed recordkeeping policy. In addition, I have enclosed a Bulletin of the United States Department of Labor, Bureau of Labor Statistics, which may provide additional clarifications of this matter.

If I can be of further assistance please contact my office.

Sincerely,
Grover C. Wrenn Director,
Federal Compliance and State Programs

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