Standard Interpretations - Table of Contents
• Standard Number: 1910.1025(l)(1)(i); 1910.1025(d)

January 19, 1981

MEMORANDUM FOR:   DAVID H. RHONE
                 Regional Administrator

ATTENTION:        Kenneth Gerecke

THRU:             JOHN B. MILES
                 Director Field Coordination

FROM:             BRUCE HILLENBRAND
                 Acting Director, Federal Compliance and
                   State Programs

SUBJECT:          Lead Standard Enforcement Clarification
This is in response to your memorandum (enclosed) requesting a clarification of compliance procedures for implementing 29 CFR 1910.1025(d) and (l)(1)(i).

1. 29 CFR 1910.1025(l)(1)(i).

Employers are required to provide an information and training program for all employees subjected to lead above the action level, or who may suffer skin or eye irritation from lead. For employees who are occupationally exposed to lead below the action level, employers need only inform them of the content of appendices A and B of the lead standard. Thus, an employer may comply with the informational requirement of 29 CFR 1910.1025(l)(1)(i) by using any method which will effectively apprise employees of the content of appendices A and B, including posting, group discussions, or individual notification (oral or written).

When investigating compliance with (l)(1)(i), the industrial hygienist shall use professional judgment in the evaluation of the employer's monitoring data, conditions, and any other information collected during the walkaround to determine which employees have potential occupational exposure to lead and whether OSHA sampling is necessary. Where sample results below the action level are used to support a violation of (l)(1)(i), there must be additional supporting information that the employee's exposure to lead is occupationally related (such as