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Follow-up blood lead tests and medical removal thresholds

Summary An OSHA regional office asked how follow-up blood lead testing interacted with two medical-removal triggers. OSHA said a result above 60 micrograms per 100 grams of whole blood required a follow-up test within two weeks, but the separate rule based on the average of three tests at or above 50 did not require that two-week follow-up. The memo applies the standard's distinct testing and removal provisions.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1990-12-12
Date issued
December 12, 1990
Status
Active
Status last verified October 9, 2026
Topics
Workplace Safety OSHA 1910 Lead Exposure Medical Surveillance
Source
View the official document

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About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

December 12, 1990

MEMORANDUM FOR: MICHAEL G. CONNORS
REGIONAL ADMINISTRATOR

THROUGH: LEO CAREY, DIRECTOR
OFFICE OF FIELD PROGRAMS

FROM: PATRICIA K. CLARK, DIRECTOR
DIRECTORATE OF COMPLIANCE PROGRAMS

SUBJECT: Interpretation of Lead Standard

This is in response to your memorandum of October 9, requesting an interpretation of 29 CFR 1910.1025(j)(2)(ii) as read with 1910.1025(k)(1)(i)(C) and (D).

Paragraph (j)(2)(ii) states that whenever the results of a blood lead level test indicate that an employee's blood lead level exceeds the numerical criterion for medical removal under paragraph (k)(1)(i), the employer shall provide a second (follow-up) blood sampling test within two weeks after the employer receives the results of the first sampling test.

Paragraph (k)(1)(i)(C) requires medical removal when a periodic and a follow-up blood sample test indicate that the employee's blood lead level is at or above 60 ug/100g of whole blood.

Paragraph (k)(1)(i)(D) requires medical removal when the average of the last three blood sampling tests indicate the employee's blood lead level is at or above 50 ug/100g of whole blood, unless the last blood sampling test indicates a blood lead level at or below 40 ug/100g of whole blood.

It is the Agency's position, upon carefully reading the standard, that a follow-up blood lead level testing is required within two weeks of the receipt of the first blood sampling test which exceeds 60 ug/100 g of whole blood. The follow-up test is intended to assure that no unnecessary removals occur.

In response to your concerns, 29 CFR 1910.1025 paragraph (k)(1)(i)(C) , which references the follow-up test, is therefore applicable. By contrast, paragraph (k)(1)(i)(D) does not reference the follow-up test and requires an average of three tests of 50 ug/100 g of whole blood for medical removal. The lead standard does not require under paragraph (k)(1)(i)(D) any follow-up tests within two weeks. If you need further assistance, please do not hesitate to contact us again.

[The regional request and related case materials are reproduced on the OSHA page; omitted here.]

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