Recordability of workplace-related PCB blood levels

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

June 30, 1998

Kenneth W. Gerecke
Assistant Regional Administrator
Occupational Safety and Health Administration
[Recipient address omitted]
Dear Mr. Gerecke:

Thank you for your letter of June 10, 1998 requesting clarification if detectable levels of chemicals in the blood are recordable under the illness criteria only when associated with health effects. The letter to Mr. Ronnie Powell, dated September 2, 1992, to which you referred, represents OSHA's position on this matter.

Tests performed during a routine or event induced medical examination which result in values outside the range of normality indicate an abnormal condition. This abnormal condition will be considered to be work related for OSHA injury and illness recordkeeping purposes if an event or exposure in the workplace either caused or contributed to the abnormal condition. If the abnormal condition is related to a single instantaneous event, the case must be evaluated using the injury criteria. If it is related to a non-instantaneous exposure(s) or event(s), it must be recorded as an occupational illness.

The case you describe, in which polychlorinated biphenyls (PCBs) were detected in the blood of an employee exposed over time to PCBs, would be recordable as an illness if the level were above that expected in nonoccupational populations. Ninety-five percent (95%) of the general population have levels less than 20 ng/mL (ppb) (Kreiss, K. 1985. "Studies on Populations Exposed to Polychlorinated Biphenyls." Environmental Health Perspective 60:193-199). Therefore any level above 19 ng/mL (ppb) would be abnormal and constitute a recordable illness if work related. The presence of health effects in this situation does not impact on the recordability of this case under OSHA injury and illness recordkeeping regulations. This position is analogous to our longstanding interpretation regarding elevated blood-lead levels.

I hope you find this information useful. If you have any further questions or comments, please contact the Division of Recordkeeping Requirements, at Area Code: (202) 219-6463.

Sincerely,

Ruth McCully
Acting Information Technology Coordinator