RECORD ID	D95-04-051
STANDARD NUMBER	1926.62(j)
INFORMATION DATE	4/21/1995 12:00:00 AM
SUBJECT	initial blood lead monitoring
DISCLAIMER
The information contained in this response is a technical clarification to a DOE Rule or Directive and should only be applied to the specific conditions described in this response. These responses represent the best available technical knowledge available from the Department’s subject matter experts and are NOT binding upon the DOE. These responses DO NOT represent approval of a variance, exemption, or equivalence for any requirements. Requests for exemptions or equivalences for Directives requirements must follow the procedures in DOE O 251.1C. Interpretive rulings, that are binding on DOE, may only be made the Office of General Counsel.
QUESTION
If employees receive blood lead and zinc protoporphyrin (ZPP) monitoring as part of a pre-placement or annual medical surveillance program, can this testing serve as the initial medical surveillance required under 1926.62(j)(1)(i)? The question arises because the standard does not specify how much time may elapse between an initial blood test and the actual work place exposure to lead above the action level. Must they be re-tested for lead and ZPP closer in time than annually for the initial testing requirements? The caller is familiar with the schedule for follow-up testing.
REGULATORY REVIEW
A DOE Interpretation, D93-10-023, stated that, "At a minmum, initial testing should be conducted every 12 months." A copy is attached; see question No. (3). Initial blood lead and zinc protoporphyrin (ZPP) monitoring performed within the past year should be adequate to establish a baseline. These tests must, of course, be performed by an OSHA approved laboratory, per 1926.62(j)(2)(iii) and in order to be in compliance with 1926.62(j)(2)(iv), the results must be provided to the emplyee in writting within 5 days of the receipt of the test results. Both the lead standards, 1910.1025(j) and 1926.62(j), and the Compliance Directive, CPL 2-2.58, are silent on the question of the time interval allowable between initial monitoring and lead exposure above the action level. If lead exposure above the action level takes place before the initial blood lead and ZPP monitoring, then the initial monitoring must be completed promptly, which OSHA has interpreted as being within 48 hours. As stated by the caller, the advantage of routinely performing blood lead and ZPP tests in an annual medical testing program is that the employee is saved an additional trip to the clinic and the discomfort of another blood test if the employee is subsequently assigned to work which entails exposure above the action level. The risk to the employer in using an initial blood lead and ZPP test that is not recent, is that in the interval between the baseline test and the work place exposure, the employee may experience lead exposure off the job, for example, through hobbies or home remodelling, that create an elevated blood lead level. In such instances, the elevated blood lead levels that are subsequently measured after work place exposure might be attributed to work place exposure, rather than to the off work activities. The contractor's occupational medicine director should be involved in the decision regarding the timing of baseline monitoring. Once the employee does experience work-related lead exposure above the action level or elevated blood lead levels, then annual testing may no longer adequate. Depending upon the frequency of exposure above the action level or the employee's blood lead level, more frequent or comprehensive surveillance may be required under 1910.1025(j)(2) and (j)(3) or 1926.62(j)(2) and (j)(3).