RECORD ID	D95-05-019
STANDARD NUMBER	1926.62(j)
INFORMATION DATE	5/8/1995 12:00:00 AM
SUBJECT	zinc protoporphyrin criteria under 1926.62
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
1. The medical surveillance requirements of the lead standard, 1926.62(j) require testing blood lead and zinc protoporphyrin(ZPP), but what are the criteria for ZPP? For blood lead, the standard mandates actions at specified levels. Are there any comparable actions based upon ZPP levels? 2. The caller recalls seeing a reference to crawl spaces in the Preamble to the permit required confined space standard, but cannot find it. Is there such a reference?
REGULATORY REVIEW
1. Appendix C to 1926.62, Medical Surveillance Guidelines discusses the interpretation of ZPP results. A copy of this discussion from the 58 Federal Register, No. 84, May 4, 1993, page 26645 is attached. 2. A word search of the Preamble to 1910.146 and of the body of the regulation itself using the search word "crawl" found no matches. The OSHA CD-ROM, December, 1994 edition was used. "Crawl" was found in 1915.11 (confined spaces in shipyard employment) in the context of the definition of the word "spaces".