October 28, 2022
Douglas L. Parker
Assistant Secretary of Labor for Occupational Safety and Health
Occupational Safety and Health Administration
200 Constitution Ave., N.W.
Washington, DC 20210
Docket No. OSHA–2018–0004
Dear Assistant Secretary Parker:
The American College of Occupational and Environmental Medicine (ACOEM) welcomes the opportunity to provide comments on the Advance Notice of Proposed Rule Making (ANPRM)—Blood Lead Level for Medical Removal.
ACOEM is a national medical society representing over 4,000 occupational medicine physicians and other health care professionals devoted to the prevention and management of occupational injuries.
ACOEM supports OSHA’s objective to update its lead standard to adequately protect American workers. In 2010, ACOEM sent a letter to OSHA urging the Agency to update its lead standard and to align itself with the overwhelming scientific evidence of adverse health effects in adults exposed below the current OSHA limits.
In 2016, ACOEM issued a position statement Workplace Lead Exposure
which recommended that a lead exposure standard be applied to all workers who have the potential for significant lead exposure by inhalation or ingestion, even in the absence of documented elevations in airborne lead levels. Any exposure that is known to cause, or is reasonably anticipated to cause, an elevated BLL is considered significant, regardless of airborne lead dust levels. OSHA revisions should include more protective action levels, PELs for airborne and surface lead dust, workplace hygiene requirements, and medical removal protection provisions.1
Attached please find responses to many of the questions posed by the agency in the in the ANPRM.
Thank you for your consideration of these comments.
Douglas W. Martin, MD, FAADEP, FAAFP, FACOEM