1910.1025(n): Lead Exposure and Medical Records
Employers must keep accurate records of all lead exposure monitoring, including dates, sample details, methods, respirators worn, employees represented and conditions affecting results, for at least 40 years or employment plus 20 years, whichever is longer. They must also keep medical surveillance records for each covered employee, including duties, physician opinions, exposure results and lead-related complaints.
Key takeaways
- 1910.1025(n) is part of OSHA's general industry standards (29 CFR Part 1910).
- OSHA cited it 19 times in the last 3 years, in 12 inspections, with $5,348 in current penalties.
- Most citations: MI (6), TN (5), ME (4).
- Related part: 1910.1025(n)(1) Exposure monitoring (11 citations).
- Free 5-minute toolbox talk for your crew below.
In this article
What this rule covers
29 CFR 1910.1025(n) ("Recordkeeping") is one requirement inside 1910.1025 Lead, an OSHA general industry standard (Part 1910). It includes 35 sub-paragraphs. The official text below is copied word for word from the Electronic Code of Federal Regulations (eCFR). The numbers, injury cases and training on this page show how OSHA enforces it on real job sites.
Official text
(n) Recordkeeping — 19 citations
(1) Exposure monitoring. Open (n)(1) 11 citations
(i) The employer shall establish and maintain an accurate record of all monitoring required in paragraph (d) of this section. Open (n)(1)(i) 5 citations
(ii) This record shall include: Open (n)(1)(ii) 6 citations
(A) The date(s), number, duration, location and results of each of the samples taken, including a description of the sampling procedure used to determine representative employee exposure where applicable; 1 citations
(B) A description of the sampling and analytical methods used and evidence of their accuracy;
(C) The type of respiratory protective devices worn, if any; 1 citations
(D) Name and job classification of the employee monitored and of all other employees whose exposure the measurement is intended to represent; and Open (n)(1)(ii)(d) 1 citations
(E) The environmental variables that could affect the measurement of employee exposure. 1 citations
(iii) The employer shall maintain these monitoring records for at least 40 years or for the duration of employment plus 20 years, whichever is longer.
(2) Medical surveillance. 2 citations
(i) The employer shall establish and maintain an accurate record for each employee subject to medical surveillance as required by paragraph (j) of this section.
(ii) This record shall include: 1 citations
(A) The name and description of the duties of the employee;
(B) A copy of the physician's written opinions;
(C) Results of any airborne exposure monitoring done for that employee and the representative exposure levels supplied to the physician; and
(D) Any employee medical complaints related to exposure to lead.
(iii) The employer shall keep, or assure that the examining physician keeps, the following medical records:
(A) A copy of the medical examination results including medical and work history required under paragraph (j) of this section;
(B) A description of the laboratory procedures and a copy of any standards or guidelines used to interpret the test results or references to that information;
(C) A copy of the results of biological monitoring.
(iv) The employer shall maintain or assure that the physician maintains those medical records for at least 40 years, or for the duration of employment plus 20 years, whichever is longer. 1 citations
(3) Medical removals. Open (n)(3) 4 citations
(i) The employer shall establish and maintain an accurate record for each employee removed from current exposure to lead pursuant to paragraph (k) of this section.
(ii) Each record shall include: 4 citations
(A) The name of the employee;
(B) The date on each occasion that the employee was removed from current exposure to lead as well as the corresponding date on which the employee was returned to his or her former job status; 1 citations
(C) A brief explanation of how each removal was or is being accomplished; and 1 citations
(D) A statement with respect to each removal indicating whether or not the reason for the removal was an elevated blood lead level. 1 citations
(iii) The employer shall maintain each medical removal record for at least the duration of an employee's employment.
(4) Availability. 2 citations
(i) The employer shall make available upon request all records required to be maintained by paragraph (n) of this section to the Assistant Secretary and the Director for examination and copying. 2 citations
(ii) Environmental monitoring, medical removal, and medical records required by this paragraph shall be provided upon request to employees, designated representatives, and the Assistant Secretary in accordance with 29 CFR 1910.1020 (a)-(e) and (2) - (i). Medical removal records shall be provided in the same manner as environmental monitoring records.
(5) Transfer of records.
(i) Whenever the employer ceases to do business, the successor employer shall receive and retain all records required to be maintained by paragraph (n) of this section.
(ii) The employer shall also comply with any additional requirements involving transfer of records set forth in 29 CFR 1910.1020(h).
Source: eCFR, text current as of 2026-10-15. Read all of 1910.1025.
Where and how often it was cited
| Year | Citations |
|---|---|
| 2024 | 6 |
| 2025 | 7 |
| 2026 | 6 |
Top states: MI (6), TN (5), ME (4), VA (2), OH (1)
Largest penalties
| Employer | Location | Penalty for this rule |
|---|---|---|
| SUPERIOR PAWN OF LYNNHAVEN, INC. | VIRGINIA BEACH, VA | $2,095 |
| HANKOOK & COMPANY ES AMERICA CORP. | CLARKSVILLE, TN | $1,500 |
| THE FEDERAL METAL COMPANY | OAKWOOD VILLAGE, OH | $1,453 |
| 77357 - H - A BURNERS LLC | PRAIRIEVILLE, LA | $300 |
| ROANOKE RANGE AND TRAINING | ROANOKE, VA | $0 |
Free toolbox talk
A 5-minute crew talk on 1910.1025(n), plus alerts when this rule changes. Free.
OSHA interpretation letters
- Clarification of employer's obligation to include social security numbers on employee exposure records. (2008-03-27)
- Recordkeeping requirements for medical removals made pursuant to the lead standard. (1980-02-20)
Related parts of this rule
- 1910.1025(n)(1) Exposure monitoring 11 citations
- 1910.1025(n)(1)(ii) 6 citations
- 1910.1025(n)(1)(i) 5 citations
- 1910.1025(n)(3) Medical removals 4 citations
- 1910.1025(n)(1)(ii)(D) 1 citations
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Frequently asked questions
How long must lead monitoring records be kept?
For at least 40 years or for the duration of employment plus 20 years, whichever is longer.
What goes in a monitoring record?
Sample dates, number, duration, location and results, sampling and analysis methods, respirators worn, names and job classifications of employees covered, and environmental variables.
What goes in a medical surveillance record?
The employee's name and duties, the physician's written opinions, exposure monitoring results given to the physician, and any lead-related medical complaints.
About this page
Sources
- 29 CFR 1910.1025 (eCFR), text current as of 2026-10-15
- U.S. Department of Labor enforcement data: OSHA inspections, citations and accident records, copied nightly; data as of 2026-10-23
3-year window. Federal OSHA only; state-plan rules are not counted. Plain-language text is a summary, not legal advice; the official text controls. Black Belt Safety is not part of OSHA or the Department of Labor.