Lead Exposure Assessment & Incident Reporting

Exposure Assessment

Employers are required to establish and maintain accurate records of exposure assessments which need to include the following details:

  • Exposure Monitoring:
    • Date(s) when samples were taken
    • Number of samples collected
    • Duration of each sampling event
    • Location where the samples were taken
    • Results of each sample
    • Description of the sampling procedure used to determine representative employee exposure
  • Sampling and Analytical Methods:
    • A description of the methods used for sampling and analysis
    • Evidence of the accuracy of these methods
  • Respiratory Protective Devices:
    • Information about any respiratory protective devices worn by employees during monitoring
  • Employee Details:
    • Name and another unique identifier (like the employees' birthdate or identification number) for the employee being monitored
    • Job classification of the employee
    • Information about other employees whose exposure the measurement is intended to represent
  • Work Operations and Conditions:
    • Details of the work operations performed by the monitored employees
    • Workplace conditions during the monitored operations, including:
      • Processes involved
      • Types of material handled
      • Control methods in place
      • Work practices followed
      • Environmental conditions prevailing at the time
    • Employers must retain these monitoring records for at least 40 years or for the duration of employment plus 20 years, whichever is longer.

Employer's Notification to Employees

Within five working days of getting blood lead test results, employers must inform employees in writing about:

  • Their blood lead level (BLL)
  • The need for employer provided medical exams and consultations for employees exposed to lead at or above the action level, and as interim protection for those doing trigger tasks, unless an exception applies. This must be done quickly if an employee:
    • Reports lead exposure symptoms
    • Seeks advice about its impact on procreation
    • Has trouble breathing while using a respirator
  • The need for temporary medical removal (with benefits) if an employee's:
    • BLL is 30 μg/dl or higher
    • Their last 2 monthly BLLs are at or above 20 μg/dl
    • Average BLL over the last 6 months is at or above 20 μg/dl

PLHCP's Notification to Employees

Employers must ensure that the employee's PLHCP:

  • Explains the findings and informs the employee about:
    • Their BLL test results.
    • Any recommended follow-up testing and its schedule.
    • Recommendations for a medical exam by a PLHCP, when required

Responding to Elevated Blood Lead Levels

Whenever an employee has a BLL at or above 10 μg/dl, the employer must:

  • Create and implement a written plan (BLL Response Plan) to reduce and maintain the employee's BLL below 10 μg/dl.
  • Provide necessary training and instructions to address any work practices highlighted in the plan.

Exception: A written BLL Response Plan, training and instruction, are not needed if the employee's elevated blood lead level is only detected in the employee's initial BLL test.

Medical Exams and Consultations

Employers need to arrange medical exams and consultations for employees at the following frequency:

  • As soon as possible:
    • For employees with a BLL of 20 μg/dl or more (unless the employee had a lead-specific medical exam in the past 12 months)
      • At least yearly until the BLL drops below 20 μg/dl
  • Before assigning any trigger task(s) to an employee:
    • Except if the employee has had a lead-specific medical examination in the past two months
  • As soon as possible if an employee notifies the employer that the employee:
    • Has developed signs and symptoms common with lead exposure
    • Seeks medical advice about lead exposure and on the employee's ability to procreate a healthy child
    • Is pregnant
    • Experiences breathing issues while using a respirator
  • As soon as possible and as medically needed for employees:
    • Removed from lead exposure due to elevated BLL, or
    • Whose exposure is limited after getting a final medical determination

Per T8 CCR 1532.1 requirements, medical exams must include:

  • A detailed work and medical history
  • A thorough physical exam
  • Blood pressure measurement
  • Blood testing and laboratory analysis for:
    • BLL
    • Hemoglobin and hematocrit determinations, red cell indices, and examination of peripheral smear morphology
    • Zinc protoporphyrin for each employee whose last BLL was 20 μg/dl or higher
    • Blood urea nitrogen
    • Serum creatinine
  • Routine urinalysis with microscopic examination
  • Any other tests the PLHCP considers to be necessary

If therapeutic or diagnostic chelation is to be performed on an employee, it must be:

  • Performed only after the employee has been notified in writing
  • Performed by a PLHCP

Employers need to inform employees of their right to a second opinion by another PLHCP if the employer selects the first PLHCP.

  • If the first and second PLHCPs disagree, a third PLHCP will need to review and resolve the disagreement.
  • Employers must follow the third PLHCP's recommendations unless another agreement is reached.

November 2024