Abstract-1

**NOTE: Minor changes {{in double brackets}} were made to this directive on October 1, 

2017, to update OIS coding instructions, references, and to make LEPs optional. Also, 

minor changes {in brackets} were made on January 1, 2016, after the revision to OSHA’s 

Hazard Communication standard. These changes do not impact this directive’s 

enforcement policy.

ABSTRACT

Purpose: This Instruction transmits policies and procedures for implementing a 

National Emphasis Program to reduce occupational exposures to lead.

Scope: OSHA-wide.

References: OSHA Instruction {{CPL 02-00-103, Field Inspection Reference Manual,

September 26, 1994 CPL 02-00-160, Field Operations Manual, August 2, 

2016}};

OSHA Instruction TED 01-00-015, OSHA Technical Manual, January 20, 

1999 {{and latest revision}};

OSHA Instruction CPL 02-02-058, 29 CFR 1926.62, Lead Exposure In 

Construction; Interim Final Rule-Inspection and Compliance Procedures, 

December 13, 1993;

OSHA Instruction STD 03-08-001, Welding, Cutting, or Heating of 

Metals Coated with Lead-Bearing Paint, October 30, 1978; 

{{OSHA Notice 08-03 (CPL 02) Site-Specific Targeting 2008 (SST-08), 

May 19, 2008}}.

See other references in Section III below.

Cancellations: OSHA Instruction CPL 02-00-130; National Emphasis Program: Lead, 

July 20, 2001 is cancelled.

State Impact: This Instruction describes a Federal program change for which State 

adoption is not required. [State Adoption Summary]

Action Offices: OSHA Regional, Area Offices, and Consultation Offices.

 

U.S. DEPARTMENT OF LABOR Occupational Safety and Health Administration

 

DIRECTIVE NUMBER: CPL 03-00-009 EFFECTIVE DATE: August 14, 2008

SUBJECT: National Emphasis Program – Lead
Abstract-2

Originating 

Office: Office of Health Enforcement 

Contact: Directorate of Enforcement Programs

Office of Health Enforcement

200 Constitution Avenue, NW, N3119

Washington, DC 20210

By and Under the Authority of

Edwin G. Foulke, Jr.

Assistant Secretary
Abstract-3

Executive Summary

This NEP is implemented to direct OSHA's field inspection efforts to address lead exposures in 

the workplace, including General Industry (1910), Construction (1926), Shipyards (1915), 

Marine Terminals (1917), and Longshoring (1918). These efforts meet the Department’s 

Strategic Plan goals in addressing the requirements of the Government Performance and Results 

Act (GPRA). As a result of this Act, Federal agencies must demonstrate improved performance 

and devise a system for measuring results. As stated in the DOL’s Strategic Plan 2006-2011 

“...DOL will continue to direct inspections and outreach at establishments and industries with 

the highest injury, illness, and fatality rates and will respond to complaints of serious workplace 

hazards. ...These efforts will be supplemented by National and Local Emphasis Programs 

designed to target unsafe conditions or high hazard industries.” The reduction of occupational 

illnesses and employee exposures to lead continues to be one of the Agency’s goals.

Significant Changes

This document supercedes the previous OSHA Instruction for a National Emphasis Program: 

Lead, CPL 02-00-130, formerly, CPL 02-0.130, dated July 20, 2001. Appendix A is a list of 

industries included to assist OSHA’s field offices in determining industries for targeting. The 

data for this appendix were provided by the National Institute for Occupational Safety and 

Health under the Adult Blood Lead Epidemiology and Surveillance Program for the calendar 

year 2002. OSHA has analyzed this data to determine those industries where elevated blood lead 

levels indicate a need for increased focus in evaluation of airborne lead exposures. 
i

Table of Contents

I. Purpose.....................................................................................................................1

II. Scope........................................................................................................................1

III. References................................................................................................................1

IV. Cancellations............................................................................................................2

V. Action Offices..........................................................................................................2

VI. Federal Program Change..........................................................................................2

VII. Background..............................................................................................................2

VIII. National Emphasis Program Inspections.................................................................3

IX. National Emphasis Program Goals..........................................................................4

X. Program Procedures.................................................................................................4

XI. Inspection Procedures..............................................................................................9

XII. Program Evaluation ...............................................................................................11

XIII. {{IMIS OIS}} Coding ...........................................................................................12

XIV. Full Service Program Support................................................................................13

Appendix A: Targeting: SIC/Industry Lists

Appendix B: Medical Surveillance Flow Charts
1

I. Purpose. This instruction describes policies and procedures for implementing a 

National Emphasis Program (NEP) to reduce occupational exposures to lead.

II. Scope. This instruction applies OSHA-wide.

III. References.

A. OSHA Instruction {{CPL 02-00-103, Field Inspection Reference Manual 

(FIRM), September 26, 1994. CPL 02-00-160, Field Operations Manual, 

August 2, 2016}}.

B. OSHA Instruction TED 01-00-015: Occupational Safety and Health 

Administration Technical Manual; January 20, 1999 {{and latest 

revision}}.

C. OSHA Instruction CPL 02-02-058, 29 CFR 1926.62, Lead Exposure in 

Construction; Interim Final Rule-Inspection and Compliance Procedures, 

December 13, 1993.

D. OSHA Instruction STD 03-08-001, October 30, 1978, Welding, Cutting, 

or Heating of Metals Coated with Lead-Bearing Paint, October 30, 1978.

E. {{OSHA Notice OSHA Notice 08-03, (CPL 02) Site-Specific Targeting 

2008 (SST-08), May 19, 2008.}}

F. {{Memorandum for Regional Administrators, From OSHA National 

Office Directorates; November 17, 2003, Subject: Coding Instruction 

Update for the 2003-2008 Strategic Management Plan.}}

G. OSHA Instruction, CPL 02-00-051, Enforcement Exemptions and 

Limitations under the Appropriations Act, May 28, 1998 {{and latest 

revision}}.

H. OSHA Instruction, CPL 02-00-025, Scheduling System for Programmed 

Inspections, January 4, 1995.

I. Rosenman, K.D, et al., Evaluation of the Effectiveness of Following Up 

Laboratory Reports of Elevated Blood Leads in Adults; AIHAJ; 62:371-

378 (2001).

J. Enander, R.T., et al., Lead and Methylene Chloride Exposures among 

Automotive Repair Technicians; J Occ Env Hyg; 1: 119-125 (2004).

K. Enander, R.T., et al., Chemical Characterization of Sanding Dust and 

Methylene Chloride Usage in Automotive Refinishing: Implications for 
2

Occupational and Environmental Health; AIHAJ; 63(6): 741-749 (2002).

L. Coyle, P., Kosnett, M.J., Hipkins, K., Severe Lead Poisoning in the 

Plastics Industry: A Report of Three Cases; Am. J. Ind. Med., 47:172-175 

(2005).

{{M. OSHA Instruction CPL 02-00-155, September 6, 2013, Inspection 

Scheduling for Construction.

N. OSHA Instruction CPL 04-00-001, November 10, 1999, Procedures for 

Approval of Local Emphasis Programs (LEPs).

O. OSHA Instruction CPL 02-00-158, June 26, 2014, Inspection Procedures

for the Respiratory Protection Standard.}} 

IV. Cancellations.

A. OSHA Instruction CPL 02-00-130; National Emphasis Program: Lead, 

July 20, 2001.

V. Action Offices.

A. Responsible Office. Office of Health Enforcement, Directorate of 

Enforcement Programs.

B. Action Offices. OSHA Regional Offices, Area Offices, and Consultation 

Offices.

C. Information Offices. OSHA National Office Directorates.

VI. Federal Program Change. This instruction describes a Federal Program Change 

for which State adoption is not required. States with a similar {{Strategic Plan}}

goal targeting lead may wish to implement procedures analogous to those 

contained in this directive and are encouraged to use the {{IMIS Performance 

Measurement tracking system by submitting the necessary}} Coding Instructions 

and appropriately coding all related activities.

VII. Background. The toxic effects of occupational exposure to lead are well 

established. Lead is a potent, systemic poison that serves no known useful 

function once absorbed by the body. Lead adversely affects numerous body 

systems and causes forms of health impairment and disease which can arise from 

acute or chronic exposure, including damage to blood-forming, nervous, urinary, 

and reproductive systems. In 1990, the National Institute for Occupational Safety 

and Health (NIOSH) set as a national goal the elimination of lead exposures that 

result in workers having blood lead concentrations greater than 25 μg/dL of whole 

blood.
3

This NEP is being implemented to direct OSHA's field inspection efforts to 

address lead exposures in the workplace, including General Industry (1910), 

Construction (1926), Shipyard (1915), Marine Terminals (1917), and 

Longshoring (1918). These efforts continue to assist the Department in meeting 

the goals of DOL{{’s Strategic Plan 2006-2011}}.

DOL’s {{Strategic Plan}} goals are to effect a reduction in occupational fatalities, 

injuries, and illnesses. The Agency continues to be committed to the reduction of 

the most prevalent types of workplace injuries and illnesses. To achieve these 

goals, the Agency focuses inspection resources on serious workplace hazards 

including amputations, and the occurrences of silica and lead exposures. The 

purpose of this NEP is to outline an effective strategy for decreasing occupational 

lead exposures. 

NIOSH provided the 2002 Adult Blood Lead Epidemiological Survey (ABLES) 

data to OSHA to assist in providing a diverse list of industries to be selected by 

the Regional and/or Area Offices when developing their targeting strategies under 

this NEP. During the NEP revision period, the 2004 ABLES data was reviewed 

by OSHA and was found to be less inclusive of specific industry identifiers than 

was the 2002 data. It was determined that providing a list of industries selected 

from the 2002 data, as opposed to the 2004 data, would afford a more

representative and comprehensive selection of industries to be used by OSHA 

field offices in the implementation of this NEP.

VIII. NEP Inspections. All inspections, regardless of the industry, where the 

compliance officer determines that there is potential employee exposure to lead 

are to be counted under this NEP {{as a Strategic Plan inspection}}.

OSHA will measure its progress toward meeting a reduction in lead poisoning by 

conducting inspections to evaluate employee exposures to airborne lead. In 

addition, during these inspections, Compliance Officers may evaluate surface 

concentrations of lead as well as the employer’s programs related to the 

availability of hygiene facilities, practices and engineering controls, personal 

protective equipment, and medical surveillance.

The activities covered under this NEP include inspections and inquiries conducted 

in any industry or at any work site where the Agency determines that there is 

potential employee exposure to lead. Compliance Officers must make an initial 

determination of whether or not the potential exists for employee exposure to 

lead. As an example, if the employer is removing lead sewer pipes or is engaged 

in bridge work, a potential exposure to lead exists if the employees are engaged in 

activities which generate dust or fumes, such as sawing, grinding, abrasive 

blasting or torch cutting. In such potential exposure situations, the inspection 

would be coded as a {{strategic plan,}} lead-related NEP inspection. If, in the 

case of the above example, the sewer pipes are removed without the generation of 

dust or fumes, there would not be potential employee exposure and the inspection 
4

would not be so coded.

NEP inspections must be designated as such in the {{OSHA Information System 

(OIS). For recording inspections under this NEP, the CSHO shall select “Lead” 

from the National Emphasis Program drop-down menu within OIS from the 

Inspection Type tab. If the NEP is the primary emphasis program that initiated 

the inspection, then the CSHO shall select Lead from the Primary Emphasis 

Program drop-down menu IMIS by marking "Strategic Plan Activity" and 

"National Emphasis Program" on the OSHA 1 (see Section XIV, "IMIS 

Coding").}} This guidance applies to all OSHA inspections (programmed and 

unprogrammed) in all industries, regardless of whether sampling was conducted. 

{{See also Section XIII, OIS Coding, below.}}

IX. National Emphasis Program Goals. Under this NEP, OSHA’s progress in 

meeting the {{Strategic Plan Agency}} goals in relation to occupational lead

exposures will be determined by measuring airborne exposures to lead and 

evaluating employers’ efforts to minimize or eliminate the hazards from the 

workplace. 

To accomplish this goal, OSHA will direct resources towards inspections of 

industries in which lead exposures occur. Subsequent to the initial inspection, 

follow-up site visits will be conducted in all establishments where exposures were 

measured at or above the permissible exposure limit (PEL) or above the action 

level where the employer has not taken preventive/corrective action (as required 

by the standard). Inspections will also be conducted in establishments where 

reported employee blood lead levels (submitted to OSHA by referral from other 

government agencies or others such as clinics, physicians, or other licensed 

healthcare professionals etc.) were at or above 25 μg/dL. 

Employee exposure to airborne lead will be sampled, whenever possible, during 

both the initial and follow-up inspection. Medical surveillance records will be 

reviewed, whenever available, by CSHOs during NEP lead inspections. 

In addition, during both the initial and follow-up inspections, Compliance 

Officers will evaluate training, use of personal protective equipment, surface 

concentrations of lead and the availability of hygiene facilities, work practices and 

engineering controls.

X. Program Procedures.

A. LEP Development.

Inspections conducted under this NEP will focus on industries where employees 

are potentially exposed to levels of lead in excess of the permissible exposure 

limit (PEL). To assist the Area Office in their selection, a list of industries and 

their SICs is provided in Appendix A. Appendix A to this document provides a 

list of SIC codes for industries where employees exhibit high blood lead levels. 
5

This blood lead data was obtained from the 2002 Adult Blood Lead 

Epidemiological Survey (ABLES) which was provided to OSHA from NIOSH. 

This list is by no means comprehensive, but is intended as a resource. Each Area 

Office (AO) or Regional Office (RO) {{that does not already have may use their 

discretion to develop}} a Local Emphasis Program (LEP) for lead, {{will develop 

and implement an LEP for lead}} based on one or more of the industries in 

Appendix A.

1. Industry Selection.

Each Area Office (AO) or Regional Office (RO) will identify the 

industry sectors that are to be selected by the AO or RO and shall 

then prepare a master list of SIC codes from those listed in 

Appendix A. The rational for selecting each industry shall be 

documented, and may include information such as, but not limited 

to:

a. History of overexposures, based on previous local 

inspection history within a RO or AO’s jurisdiction of

industries listed in Appendix A. 

b. Limited or no local inspection history of an industry listed 

in Appendix A. 

c. Industries that are not included in Appendix A, but are 

known by the AO or RO, based on local knowledge (i.e., a 

documented history of referrals from local agencies or 

healthcare providers, or previous inspection histories, etc.), 

to have demonstrated a pattern of lead overexposures or 

reports of employees experiencing elevated blood lead 

levels.

2. Site Selection.

a. Master List Generation.

After identifying the relevant industries, each Regional or 

Area Office, using all available information, will prepare a 

master list of establishments within the designated 

industries. These lists shall be prepared using either the 

procedures set forth in CPL 02-00-025 (CPL 2.25I) 

Scheduling Systems for Programmed Inspections, or 

{{CPL 04-00-001 CPL 02-00-155}}, Inspection 

Scheduling for Construction. 

Establishments with fewer than 10 employees shall also be 

included in this NEP. Establishments will be placed on the 

list in alphabetical order, and appropriate deletions shall be 

made in accordance with OSHA Instruction CPL 02-00-

025 (CPL 2.25I), Scheduling System for Programmed 
6

Inspections, at B.1.b.(1)(b)(6). Establishment sources may 

include:

1) the {{Dun & Bradstreet employer list Establishment 

Targeting List-Generation System (ListGen)}}

(available from the National Office);

2) commercial directories;

3) telephone listings;

4) local knowledge of establishments; and

5) Dodge reports for construction sites.

b. Deletions.

The Area Office may delete from their list any facility/site 

that meets the applicable deletion criteria listed in CPL 02-

00-025. Further, the Regional and Area Offices may delete 

any establishment that has had an inspection where 

exposures to lead have been evaluated within the current 

year or previous three (3) fiscal years Where: no serious 

violations were cited related to lead; a subsequent 

inspection documented employer efforts to abate all serious 

hazards; or no cases of increased blood lead levels were 

identified. In the event an establishment meeting these 

criteria is not deleted, the decision shall be documented and 

the reasons for including it shall be stated.

c. Cycle Generation.

Each establishment on the corrected list will be assigned a 

sequential number, starting at the top of the list with 

number one. A random number table will then be applied 

to create the first inspection cycle of five or more 

establishments. Subsequent cycles will be created in the 

same way until the expiration of the LEP or until all 

establishments on the list have been assigned to a cycle. 

Cycles may be created all at once or as needed, and need 

not be of the same size.

Whenever an office becomes aware of a previously 

unknown establishment in one of the identified SICs, that 

establishment shall be added to the master list for inclusion 

in the next inspection cycle.

When using the construction site list, the Area Office may 

check with state agencies such as the DOT to determine 

whether or not the selected site is active.
7

3. {{Site-Specific Targeting (SST-08):

Targeted establishments which also appear on the Site-Specific 

Targeting (SST) list will undergo a DART/DAFWII evaluation. The 

evaluation of the establishment’s DART and DAFWII rates shall be 

made in accordance with OSHA Notice CPL 08-03 (CPL 02), May 

19, 2008, Site-Specific Targeting 2008 (SST-08). If the evaluation 

shows that the site has DART/DAFWII rates below the SST-08 cut 

points, the inspection will be conducted focused on only the hazards 

related to lead, otherwise the lead inspection should be done 

concurrently with the SST Plan. If this is not possible, the SST plan 

inspections have priority and are to be conducted prior to NEP 

inspections. Refer to OSHA Notice CPL 08-03 (CPL 02), May 19, 

2008, Site-Specific Targeting 2008 (SST-08).

4.}} LEP Evaluation.

{{If any LEPs for lead are issued in response to this NEP, one 

One}} year from implementation, each LEP will be evaluated and 

a determination made as to the effectiveness of the LEP using 

Appendix A of CPL 04-00-001 - Procedures for Approval of Local 

Emphasis Programs (LEPs). If the LEP is determined to be 

ineffective, different industries from Appendix A {{will may}} be 

selected and a new LEP developed and implemented. If the LEP is 

determined to be effective but the master list of establishments has 

been depleted to the point of having too few work sites for each 

cycle, different industries from Appendix A {{will may}} be 

selected and a new LEP developed and implemented. If the LEP is 

determined to be effective and the master list of establishments still 

contains enough employers, the LEP may be renewed.

B. General Industry Complaints and Referrals. 

Every complaint or referral for any general industry operation where there 

exists the potential for lead exposure must be handled as follows:

1. Based upon the information provided, all potential lead work 

sites/establishments brought to the attention of the Area Office 

must be handled in accordance with the procedures outlined in 

{{CPL 02-00-140, Complaint Policies and Procedures CPL 02-00-

160, FOM, Chapter 9.}}

2. Referrals received from States' Departments of Health, Labor or 

Industry alleging elevated employee blood lead levels (defined as 

blood lead levels at or above 25 μg/dL) and/or involving takehome exposures, shall be considered high-gravity, serious and 

must be handled by inspection.
8

Referrals of elevated employee blood leads (which report one or 

more worker blood lead level(s) which equals or exceeds 25 μg/dL 

of whole blood) will be inspected. At the discretion of the Area 

Director, worksites may be inspected even if the employee's blood 

lead level is below 25 μg/dL when the Area Office is aware of 

unusual circumstances which would warrant an inspection. Such 

unusual circumstances may include pregnancy or possible 

poisoning of family members. 

C. Construction Inspection Complaints and Referrals.

Every complaint or referral for any construction operation where there 

exists the potential for lead exposure must be handled as follows:

1. Whenever a CSHO observes or the Area Office receives 

information (through any source or means) regarding work 

operations where the potential for exposure to lead exists, the 

CSHO must:

a. Document the status and condition of the work operation as 

far as they are known, noting any serious hazard(s). 

Documentation of the events leading up to the observation 

must be maintained in the file.

b. Note the location of the worksite and the name and address 

of the employer(s) performing the operation.

c. Provide the Team Leader (Assistant Area Director) or Area 

Director with the information. Based upon the information 

provided, all potential lead work sites brought to the 

attention of the Area Office must be handled in accordance 

with the procedures outlined in {{CPL 02-00-140, 

Complaint Policies and Procedures the FOM}}.

2. Referrals received from States' Departments of Health, Labor, or 

Industry alleging elevated employee blood lead levels, that is blood 

lead levels at or above 25 μg/dL, and/or involving take-home 

exposures, shall be considered high-gravity, serious and must be 

handled by inspection.

Referrals from other official bodies (clinics, physicians, or other 

licensed health care professionals) reporting one or more 

employee blood lead level(s) which equals or exceeds 25 μg/dL of 

whole blood will be inspected. At the discretion of the Area 

Director, referred worksites may be inspected even if the 

employee's blood lead level is below 25 μg/dL when the Area 

Office is aware of unusual circumstances which would warrant an 
9

inspection. Such unusual circumstances may include pregnancy or 

possible poisoning of family members. 

3. The discovery of work sites to be inspected under this NEP may be 

the result of a search to find a specific type of operation, at the 

discretion of the Regional Administrator. Such searches will 

consist of observations that normally occur during the course of 

routine travel during duty or non-duty hours. When including such 

sites, the reasons for the search and the manner in which it was 

conducted shall be documented.

4. If during the course of any construction inspection (including 

programmed inspections) a safety CSHO encounters a site where 

lead exposures exist, appropriate health referrals will be made.

XI. Inspection Procedures.

A. All inspections under this NEP must address all aspects of any potential 

lead work or exposure and include a review of all related written 

documentation (i.e., recordkeeping, monitoring, compliance program, 

medical, respirator fit testing and procedures, hazard communication, and 

training materials). 

1. During the normal conduct of an NEP inspection, the CSHO will 

review the employer’s medical surveillance program for lead. All 

blood lead information, where available, will be reviewed as part

of the inspection.

2. The CSHO will perform a detailed assessment of the employer’s 

hazard communication program as it relates to the operations and 

chemicals used in the processes where lead exposures may occur. 

The evaluation will include an {MSDS SDS} review in accordance 

with OSHA’s current policy on {MSDS SDS} review.

3. All inspections conducted under this NEP will include an 

evaluation of the employer’s engineering controls for the processes 

where lead exposures above the permissible exposure limit occur. 

Administrative controls put in place by the employer will also be 

evaluated as to their effectiveness in reducing exposures.

4. A detailed evaluation of the employer’s personal protective 

equipment (PPE) and respiratory protection programs will be 

conducted on every inspection where lead hazards exist. 

Evaluation of the employer’s respirator program will be done in 

accordance with OSHA Instruction {{CPL 02-00-120 (CPL 2-

0.120) CPL 02-00-158}}, Inspection Procedures for the 
10

Respiratory Protection Standard.

5. The employer’s hygiene program will be reviewed to determine if 

hand-to-mouth contact may be contributing to employee exposure 

to lead. The housekeeping procedures and evaluation and use of 

PPE will be assessed and documented.

6. CSHOs will conduct personal air monitoring and collect wipe 

samples, as appropriate, to document exposures (see OSHA 

Instruction TED 01-00-015) for all inspections under this NEP 

where it is possible to sample for lead exposures. Monitoring may 

not be necessary, however, if at the time of the inspection, the 

employer provides reliable and recent data showing employees’ 

exposures are below the action level and the conditions in the work 

place are the same as when the employer completed sampling. 

Additionally if, during a follow-up inspection, the employer’s 

sampling data shows that engineering controls have reduced the 

employee exposures to below the AL and the data is reliable, air 

sampling may not be necessary. 

7. In any inspection where the decision is made to utilize the 

employer’s monitoring data to characterize employee exposures,

documentation related to this decision must be included in the case 

file, including copies of the employer’s exposure data. Where it is 

not possible to obtain copies of the employer’s sampling results, 

the CSHO will conduct the necessary air monitoring.

8. In certain circumstances, the Area Director may use the employer’s 

monitoring data in issuing proposed citations for employee 

overexposures to lead. However, employer-generated data may 

only be used where personal air sampling is not possible and the 

employer’s data meets the requirements of 29 CFR 1910.1025(d) 

or 29 CFR 1926.62(d). It is expected that this will occur only 

rarely and the Area Director will be responsible for ensuring that 

adequate documentation related to that decision is included in the 

case file. 

9. Where air monitoring is conducted during a construction 

inspection, the area office will request expedited sample analyses 

from the SLCTC.

B. While evaluating employee exposures to lead, CSHOs also need to be 

aware of and evaluate potential exposures to other metals including, but 

not limited to, arsenic, manganese, chromium, cadmium, copper, and 

magnesium. CSHOs should not request an ICP (inductively coupled 

plasma) analysis for abrasive blasting operations or when an arsenic 

analysis is needed without first contacting the inorganic lab of the Salt 
11

Lake Technical Center. Atomic Absorption (AA) Spectroscopy can be 

requested for arsenic and any three of the following metals: lead, 

cadmium, iron, copper, or zinc, or the other specific metals. With AA 

spectroscopy a total of four metals can be requested per sampling filter.

C. During inspections conducted under this NEP, CSHOs will provide the 

employer with informational documents regarding the appropriate lead 

standard, the health effects of lead, effective control measures, and 

employer and employee rights and responsibilities. Documents of this 

nature may be obtained from OSHA's Office of Publications, {{the 

Directorate of Technical Support,}} or from OSHA's web site.

D. Joint Safety and Health Inspections - Industrial hygienists conducting 

construction inspections should consult with safety CSHOs on serious 

safety hazards such as falls, electrocution, struck-by, or caught-in hazards 

and should file referrals where appropriate. Where resources permit, a 

joint safety and health inspection should be conducted.

E. The Compliance Safety and Health Officer (CSHO) may expand the scope 

of the inspection beyond the areas related to occupational exposures to 

lead if other hazards or violative conditions are observed and/or brought to 

their attention. The CSHO shall follow the guidelines in {{Chapter II 

A.1.b. of the FIRM the FOM}} when expanding the scope of the 

inspection.

F. The protection of CSHOs during any inspection is an issue of importance. 

In order to ensure adequate protections, Compliance Officers shall conduct 

a hazard determination to establish the presence of lead (or other 

hazardous substances) prior to initiating the walkaround. This hazard 

determination will rely on information such as previous inspection history, 

{material} safety data sheets, professional judgment, and/or previous 

exposure monitoring surveys. Personal protective equipment to be used 

during the inspection, such as respirators, gloves, and/or protective 

clothing is to be made available to the CSHO prior to the inspection and 

will be worn based upon the CSHOs determination of a hazard. 

G. Area Directors are instructed to ensure that Compliance Officers 

understand how their own PPE is to be handled after an inspection, 

including provisions for laundering and equipment decontamination.

XII. Program Evaluation.

A. Follow-up inspections will be conducted for all cases with documented 

exposures above the permissible exposure limit (PEL) for lead and for all 

cases with documented exposures above the action level where the 

employer has failed to take appropriate action. The follow-up inspection 
12

will be conducted within two to three months after the final abatement 

date for the cited violations. During the follow-up visit the CSHO shall 

verify the employer’s abatement documentation/verification by carefully 

evaluating any and all air monitoring results, implemented engineering 

controls, personal protective equipment requirements (including 

respiratory protection), housekeeping and employee information and 

training. Procedures for follow-up inspections will be in accordance with 

the {{Field Inspection Reference Manual (FIRM), OSHA CPL 2.103, 

Chapter II.B.1.a FOM}}.

Personal air sampling will be conducted by OSHA staff in all situations 

unless the job task or job site is no longer active. Use of employergenerated monitoring data is not permitted for the purpose of abatement 

verification under this NEP unless an exception applies (see Section 

XI.A.6.).

B. Abatement documentation/verification will be submitted to or otherwise 

collected by the Area Office for all other violations of the lead standards 

or other OSHA regulations. The abatement information must be included 

in the case file in a timely manner. Whenever possible, case files are to be 

closed in the fiscal year in which the intervention was conducted to allow 

the data to be applied to the Agency’s {{Strategic Goal}}

accomplishments. In cases where implementation of engineering controls 

extends beyond the fiscal year in which the intervention was conducted, 

the case files will be closed as soon as possible. 

XIII. {{IMIS OIS}} Coding.

A. {{The following instructions remove the requirement for recording 

"Optional Information" for lead on IMIS forms.}} The instructions which 

follow are for recording lead inspections under this Lead NEP {{and the 

Strategic Plan}}. This instruction does not affect the coding of approved 

LEPs. Coding for approved LEPs will continue as before. The following 

instructions {{for completing enforcement forms OSHA-1, OSHA-7, 

OSHA-36, OSHA-55 and OSHA-90 and Consultation Request Form-20 

and Visit Form-30}} must be applied when recording inspections or 

consultation visits conducted under this NEP:

{{OSHA-1: Select Lead from both choice lists in Item 25d, 

National Emphasis Program and in Item 25f, Strategic Plan 

Activities.

OSHA-7: Complete in the normal manner. It is not necessary to 

code for this NEP on the OSHA-7.

OSHA-36: Complete in the normal manner. It is not necessary to 
13

code for this NEP on the OSHA 36.

OSHA-55: Select Lead from both choice lists in Item 15, National 

Emphasis Program and in Item 17, Strategic Plan Activities.

OSHA-90: Complete in the normal manner. It is not necessary to 

code for this NEP on the OSHA 90.

- All enforcement activities (inspections, complaints, and referrals) 

and compliance assistance conducted under this NEP must be 

coded with the NEP code, “Lead,” entered in the OIS.

- All inspections conducted under this NEP will be “Health” 

inspections and should be coded as such. 

- If, during safety-related inspections, exposures to lead are

observed, the NEP code “Lead” should be recorded.}} 

B. OSHA Consultation Project Offices in Federal Enforcement States.

1. Whenever a visit is made in response to this NEP, Consultation 

Request and/or Visit forms are to be completed {{.as follows:

"National Emphasis Program," Item No. 25, when a request is 

being scheduled in response to the NEP.

Complete the Visit Form-30 in the normal manner and enter with 

the NEP code “Lead.” in "National Emphasis Program," Item No. 

28, when a visit has been made and findings are appropriate to this 

NEP (potential or actual lead exposures have been found).}}

XIV. Full Service Program Support.

A. For states that have enacted requirements for mandatory reporting of 

elevated blood lead levels, the Area or Regional Office should contact the 

state agencies responsible for these programs and request information on 

workplace exposures associated with elevated blood lead levels. Regional 

and Area Offices are strongly encouraged to develop alliances, 

memoranda of understanding, or other agreements which will forge 

cooperative relationships and result in information sharing with the state’s 

Departments of Health and/or Labor.

B. Each Area Office/Region/Consultation Program Office is encouraged to 

develop outreach programs that will support the efforts of the Agency in 

meeting {{the Strategic Plan its}} goals. Such programs could include 

letters to employers, professional associations, local safety councils, 

apprenticeship programs, local hospitals and occupational health clinics, 
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and/or other industry employer organizations that work with or potentially 

generate lead exposures. Speeches, training sessions, and/or news releases 

through the local newspapers, safety councils and/or industrial hygiene 

organizations can provide another avenue for dissemination of 

information. Regional/Area Office Alliances developed with industries 

would also be an effective way to reach out to affected employers and 

employees.

C. The Directorate of {{Science, Technology and Medicine Technical 

Support and Emergency Management}} has prepared materials which will 

be of assistance in this outreach effort. A variety of online resources can 

be accessed through OSHA’s public webpage, www.osha.gov. There is a 

technical link page specific to lead under the alphabetical “Site Index”. 

Also included to provide additional assistance (as Appendix B) in this 

document are medical surveillance flow charts. 
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Appendix A - Targeting

The goal of the NEP is to affect a reduction in employee blood lead levels by reducing 

lead exposures throughout industry. To meet this goal, and to effectively manage 

OSHA’s limited resources, Appendix A provides a list of industries where lead exposures 

occur. Area and Regional Offices will focus enforcement efforts on the industries from 

this list. They will select the industries to be included by following the procedures 

previously outlined in this document.

The industries listed in the table in this appendix are provided to assist area offices in 

targeting. The industry list was culled from the Adult Blood Lead Epidemiological 

Surveillance (ABLES) database for 2002. The ABLES data was provided to OSHA by 

the National Institute for Occupational Safety and Health (NIOSH). This data includes 

employee blood lead levels reported by laboratories in states who participate in the 

ABLES program. OSHA has analyzed this information resulting in the identification of 

industries where there was a tendency for elevated employee blood lead levels.

The NIOSH ABLES database for 2002 uses SIC codes for industry designation. While it 

is understood that the NAICS system is currently in use to identify industries, those codes 

were not available as part of the ABLES data for 2002. NIOSH is adding a NAICS field 

as part of the data collection. The NAICS system for industry identification will be 

available for this NEP in future years.

The NAICS system correlates to the SIC codes in some cases but some industry SICs do 

not translate directly to a single NAICS code. OSHA’s NCR system has a drop down list 

for NAICS codes and there is a link to the NAICS US Census web site within the 

Inspection Preparation section of OSHA’s home page. The industry data will be updated 

when future data becomes available. 

SIC Selection Criteria: In 2002, laboratories for 35 states reported individual blood lead 

levels to the NIOSH ABLES program. Of these, 27 states reported blood lead levels 

along with the SIC code for the industry in which the employee worked. The blood lead 

data for these 27 states was evaluated to determine industries for targeting. The data was 

first sorted by SIC, then by each individual’s peak BLL. The SICs chosen for targeting 

were those demonstrating that within the industry sector, 40 or more individuals had peak 

blood lead levels at or above 25 μg/dl. 

Additionally, Appendix A includes some SICs which did not meet the selection criteria 

described above, but were included due to historical significance; similarity to the 

selected (or “sister”) SIC; or were flagged due to other considerations as described in the 

table. These industries are denoted by symbols and explanations provided below the 

table. Please also note the explanation for SICs 7997/7999, as this industry classification 

covers a broad range of employment, most of which will not be targeted by this NEP. 

SIC TABLE
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SIC Industry Historical

Previous 

ABLES Other

1521 GC Single Family Residential Construction Y-Operations#

1522 GC Other Residential Construction Y-Operations#

1541 GC Non Residential Construction

1622 Bridge Tunnel Construction Y

1629 Heavy Construction, NEC Y

1721 Painting & Paper Hanging Y

1791 Steel Erection Y *

1795 Wrecking and Demolition Work Y

1799 Special Trade Contractors NEC Y

2816 Manufacturing: Inorganic Pigments Y *

2819 Manufacturing: Inorganic Chemicals NEC Y *

2821 Plastics Materials, Synthetic Resins, & NonVulcanizable Elastomers Y Y-Paper

2851 Mfr of Paints, Varnishes, Lacquers, Enamels

3053 Mfr of Gaskets, Packing and Sealing Devices

3211 Manufacturing: Flat Glass Y Y-MI data

3229 Manufacturing: Pressed & Blown Glass Products Y

3231 Mfr of Glass Products Made of Purchased Glass

3312 Steel Works-Blast Furnaces

3331 Primary Smelting of Copper Y *

3339 Primary Smelting of Non Ferrous Metals Y

3341 Secondary Smelting of Non-Ferrous Metals Y

3351 Rolling, Drawing, Extruding of Copper

3356 Rolling of Non Ferrous Metals Except Cu and Al

3366 Copper Foundries Y

3369 Non-Ferrous Foundries Except Cu and Al

3399 Primary Metal Products, NEC

3489 Ordinance & Accessories, NEC

3491 Manufacture of Industrial Valves

3492 Manufacture of Fluid Power Valves Y-Operations#

3568 Mechanical Power Transmission Equipment NEC

3675 Manufacture of Electronic Capacitors Y *

3691 Storage Batteries Y

3692 Primary Batteries Y

3713 Manufacture of Truck/Bus Bodies Y *

3715 Manufacture of Truck Trailers Y *

5093 Scrap and Waste Materials Y

7532 Automotive Repair & Painting Y- Papers

7539 Automotive Repair Shops NEC Y Y

7997 Membership Sports & Recreation Clubs Y-Operations#

7999 Misc. Sports, Recreation & Amusement, NEC Y

* These industries were selected for targeting as they are SICs which are 

historically significant for lead exposures. They did not meet the selection criteria 
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for this revision of the NEP, but are considered important for targeting purposes, 

nonetheless. 

# SIC selections marked as indicated were added based on the close link in 

industrial application between one SIC and the other “sister” SIC. 

MI Data – Although this SIC (3211) did not meet the selection criteria under this 

NEP, it appeared on the previous targeting list, and data provided by the State of 

Michigan indicated that this SIC remains of concern for elevated blood lead levels 

in that State. 

Papers Referenced for SIC 7532 – Enander, R.T., et al., Lead and Methylene 

Chloride Exposures among Automotive Repair Technicians; J Occ Env Hyg; 1: 

119-125 (2004). Enander, R.T., et al., Chemical Characterization of Sanding Dust 

and Methylene Chloride Usage in Automotive Refinishing: Implications for 

Occupational and Environmental Health; AIHAJ; 63(6): 741-749 (2002). Also, 

information provided by the Commonwealth of Massachusetts flagged this SIC, as 

elevated airborne exposures have been measured in automotive repainting 

operations. Many {material} safety data sheets for auto paint do not indicate lead 

as a component. Inspections in automotive repainting operations should include air 

sampling for lead and evaluation of the information on the {MSDS SDS}. 

Paper Referenced for SIC 2821 – Coyle, P., Kosnett, M.J., Hipkins, K., Severe Lead 

Poisoning in the Plastics Industry: A Report of Three Cases; Am. J. Ind. Med., 

47:172-175 (2005). This SIC was also flagged in the targeting list for the previous 

Lead NEP. 

7997 is Membership Sport and Recreation Clubs and includes gun clubs, shooting 

clubs and hunt clubs as well as such establishments as aviation clubs, beach clubs 

and yacht clubs. Similarly, 7999 is Amusement and Recreation Services, Not 

Elsewhere Classified and includes shooting galleries and shooting ranges as well as 

such establishments as baseball instruction schools, moped rental and yoga 

instruction. It is assumed that the occupational lead exposure to employees in these 

two SIC codes are from gun clubs and shooting ranges and galleries. Under this 

NEP, OSHA would not be interested in inspecting establishments within these SIC 

codes unless lead exposure is suspected, such as at shooting ranges. (Also, OSHA 

does not have jurisdiction with respect to exposure of non-employee members or 

participants of these, but only with respect to exposures of employees.) In this 

regard, Area Offices should be aware that armories and law enforcement 

organizations may house shooting ranges as well. Federal law enforcement 

facilities would fall under Federal OSHA jurisdiction, while municipal facilities 

would fall under State control.
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