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What are the fundamental elements of the medical surveillance requirements?

The fundamental elements of the medical surveillance requirements include biological monitoring, medical examination, and medical removal.

Biological monitoring

Employees exposed at or above the action level at least one day per year must be given a blood lead test and a ZPP test. Employees exposed at or above the action level for more than 30 days per year must receive additional blood lead and ZPP tests at least every 2 months for the first 6 months of the job and every 6 months afterwards.

For employees with blood lead levels at or above 50 ug/dl, a follow-up test must be given within 2 weeks after the employer receives the results of the first blood sampling test. For employees on medical removal from exposure due to an elevated blood lead level, monthly tests must be given.

Medical examinations

Medical exams must be made available according to the following schedule to all employees exposed at or above the action level for more than 30 days in any consecutive 12 months.

  • At least annually for employees who have had a blood lead level at or above 40 ug/dl at any time during the preceding 12 months;

  • As soon as possible for employees with signs or symptoms of lead intoxication, pregnant employees, and employees who demonstrate difficulty in breathing during a respirator fit test or during respirator use; and

  • As medically appropriate for employees removed from lead exposure.

Medical removal

Employers must remove employees who are exposed at or above the action level on each occasion that a periodic and follow-up blood sampling test indicates the employee's blood levels are at or above 50 ug/dl and/or a physician makes a determination indicating a detected medical condition increasing health risks from lead exposure.

When workers who have been exposed to lead and were covered by the medical surveillance program are no longer exposed, can medical surveillance be discontinued?

Workers who are no longer exposed at or above the action level are not subject to medical surveillance requirements. The Lead in Construction Standard does not have a termination medical exam requirement.

Once medical surveillance is discontinued, what further obligations does the employer have?

The employer has to maintain the medical records as specified in 1910.1020.


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