It is not sufficient to simply provide a handwashing station, since a citation will be issued if the employees are not conscientious in using it. The same holds true for showers. Air tests of worker exposure and follow-up blood tests are not just important for a filing cabinet. Within five working days after completion of the exposure assessment, the employer did not notify each employee in writing of the results which represent the employee's exposure. The employer did not notify each employee in writing of his or her blood lead level within five working days after receipt of biological monitoring results.
Some companies are now including such test results in the envelope with employee paychecks.
Others are requiring signatures on all test result forms to prove the employee reviewed the data. Regardless of how such communication is accomplished, documentation must establish an audit trail proving that the employees received the results in a timely manner to satisfy OSHA personnel, as well as possible attorneys working on behalf of disgruntled employees. This brief review of the consequences of failing to fully comply with the OSHA lead standard has probably not brightened your day. Note that not a single negative comment was provided regarding the fairness or technical merit of a particular citation. This is because it really does not matter what anyone thinks about these regulations.