Lead General Industry Compliance Plan — 29 CFR 1910.1025 Compliant
Written compliance program for general industry lead exposure — battery manufacturing, lead smelters, foundries, pigment manufacturing. Covers exposure determination, engineering controls, medical surveillance with BLL action levels, and MRP at the §1910.1025(k) thresholds.
When this template is required
Required of general industry employers (manufacturing, primary/secondary lead smelting, lead foundries, battery manufacturing, brass/bronze foundries, lead-containing pigment manufacturing, etc.) with employee exposure to lead. PEL: 50 µg/m³ 8-hour TWA; Action Level: 30 µg/m³. Written compliance program required when exposures exceed the PEL.
Why this template
Manufacturing-tailored vs. construction lead plan
Manufacturing operations have steady-state exposures and engineering controls that differ from construction. The plan is built for the general industry context — continuous operations, fixed engineering controls, larger workforces.
MRP at federal thresholds
1910.1025(k)(1)(i) MRP triggers: removal when a periodic and a follow-up blood test both show a level at or above 60 µg/100 g, or when the average of the last three tests (or of all tests over the previous six months, whichever is the longer period) is at or above 50 µg/100 g — unless the most recent test is below 40 µg/100 g. (The federal threshold is higher than recent state thresholds; the plan documents both.)
Battery / smelter-specific guidance
Battery manufacturing and lead smelting have specific engineering control expectations from OSHA enforcement. The plan documents typical controls.
BLL trending vs. individual results
Tracking individual BLLs misses workforce trends. The trending log identifies process areas where BLLs are increasing before reaching MRP triggers.
What you receive
- Lead General Industry Compliance Plan (Word .docx) — written program per (d)-(n)
- Initial exposure determination procedure (PEL: 50 µg/m³; Action Level: 30 µg/m³)
- Air monitoring schedule (initial + periodic + change-triggered)
- Methods of compliance — engineering & work practice controls hierarchy
- Respiratory protection program crosswalk (with 1910.134)
- Medical surveillance protocol (examination by or under the supervision of a licensed physician; blood lead and zinc protoporphyrin sampling on the 1910.1025(j)(2)(i) schedule)
- Lead work area designation and warning-sign procedure (29 CFR 1910.1025(m)(2) signage, with clothing, change room, shower and lunchroom controls)
- Housekeeping and hygiene procedures
- Employee training outline (annual refresher requirement)
- Recordkeeping requirements (exposure and medical records: at least 40 years, or duration of employment plus 20 years, whichever is longer)
- Battery manufacturing-specific controls (where applicable)
- Lead smelter/foundry controls
- Medical Removal Protection (MRP) procedure — 1910.1025(k)
- BLL trending log
- Annual training matrix
How you get it
This document is written and reviewed against the standard it cites, and it is ready now. The download link is emailed as soon as your payment clears.
Revisions included — if something about your operation changes what the document should say, reply to the delivery email and we will amend it.
Who buys this
- Lead-acid battery manufacturing
- Primary and secondary lead smelters
- Lead foundries and brass/bronze foundries
- Lead-containing pigment and ceramic manufacturing
- Radiator manufacturing and repair (with lead solder)
- Ammunition manufacturing
Frequently asked
Who's covered by 1910.1025?
Manufacturing and general industry employers with employees exposed to lead: primary/secondary lead smelters, lead-acid battery manufacturing, lead foundries, brass/bronze foundries, lead pigment manufacturing, ceramic glazing with lead, radiator manufacturing with lead solder, ammunition manufacturing, lead crystal manufacturing. Construction-only employers use 1926.62 instead. 1910.1025 applies to all occupational lead exposure except construction and agricultural operations covered by 29 CFR part 1928; construction is covered by 29 CFR 1926.62 (1910.1025(a)).
What's the difference between this and 1926.62?
Same PEL (50 µg/m³) and Action Level (30 µg/m³), but different scenarios. 1910.1025 covers manufacturing — steady-state, continuous operations, fixed engineering controls. 1926.62 covers construction — temporary, transient, trigger-task-driven. The compliance program content and methods differ between the two.
What's the MRP trigger under 1910.1025(k)?
Removal is required when a periodic and a follow-up blood test both show a level at or above 60 µg/100 g (1910.1025(k)(1)(i)(A)), or when the average of the last three tests — or of all tests over the previous six months, whichever period is longer — is at or above 50 µg/100 g, unless the most recent test is below 40 µg/100 g (1910.1025(k)(1)(i)(B)). The employee returns to former job status when two consecutive tests are below 40 µg/100 g (1910.1025(k)(1)(iii)(A)(1)). Note that these federal thresholds date from 1978 and sit well above contemporary medical guidance; several states have adopted lower removal thresholds. The plan documents the federal minimum alongside the applicable state requirement.
Does this cover battery manufacturing-specific controls?
Yes — battery manufacturing has specific engineering control expectations: paste mixing enclosures, grid casting ventilation, formation tank covers, plate cutting controls, charging area ventilation. The plan addresses these controls at a framework level; specific engineering designs come from facility-level engineering reviews.
How long do we keep records?
Exposure monitoring records: at least 40 years, or the duration of employment plus 20 years, whichever is longer (1910.1025(n)(1)(iii)). Medical records, including blood lead and ZPP results: the same period (1910.1025(n)(2)(iv)). 1910.1025 sets no separate retention period for training records — paragraph (n)(4) is Availability, which governs access to records rather than how long they are kept. The written compliance program is reviewed and updated at least annually (1910.1025(e)(3)(iv)), and records transfer to a successor employer under 1910.1025(n)(5).