Are blood lead laboratories required to report to healthcare providers any blood lead levels at which additional employer obligations are triggered by OSHA?

Blood lead laboratories will send a report of blood lead testing results to clinicians or healthcare providers. However, there is no requirement under either of OSHA’s lead standards (29 CFR 1910.1025 and 1926.62) that blood lead laboratories also send a report of the OSHA blood lead levels at which additional employer obligations are triggered. Likewise, there is no requirement in these standards to send a report a blood lead level (BLL) of 40µg/dL as “normal.” The standards require that blood lead level sampling and analysis be conducted by a laboratory licensed by the CDC that has received a satisfactory grade in blood lead proficiency testing from CDC in the prior twelve months.

The geometric mean BLL in the U.S. for adults is far below the workplace exposure level of 40µg/dL, which triggers additional medical monitoring and laboratory evaluations. While 40µg/dL is a reference for the purposes of the OSHA standards and the employer’s obligation, it is understandable that presentation of this information and use of the term “reference” may be confusing to clinicians and healthcare providers who are unfamiliar with lead toxicity.

Although OSHA lead standards do not cover the reports provided by laboratories to clinicians and healthcare providers, OSHA says it would consider it beneficial that laboratories use this opportunity to educate the clinician or healthcare provider regarding both:

• The OSHA requirements (levels which trigger additional employer obligations under the lead standards), and
• Other pertinent levels.

This will ensure that the most useful information is presented to those responsible for treatment and subsequent action — the family physician, the occupational physician, and the employer.

Ultimately, responsibility for complying with the medical surveillance, recordkeeping, and blood lead proficiency testing requirements of the lead standards belongs to the employer whose workers are exposed to lead. Source: April 5, 2004, OSHA Letter of Interpretation.