Answer Library / Chemicals & HazCom OSHA letter · 2018-10-01

Can we use a CLIA-approved lab for blood lead testing since CDC no longer licenses labs?

Quick answer

Yes. OSHA now recognizes a CLIA-approved blood lead analysis laboratory as fully satisfying the laboratory requirements of both the general industry and construction lead standards (29 CFR 1910.1025(j)(2)(iii), 29 CFR 1926.62(j)(2)(iii)). Any technical proficiency-testing violation with a CLIA-approved lab is treated as de minimis — no citation, no penalty.

This memorandum to OSHA Regional Administrators addresses a practical problem: the lead standards' blood testing requirements reference programs that no longer exist. The general industry Lead Standard (1978) required blood lead testing by a laboratory licensed by the Center for Disease Control, or one with a satisfactory grade in CDC blood lead proficiency testing in the prior twelve months (29 CFR 1910.1025(j)(2)(iii)). The construction Lead Standard (1993) required a laboratory approved by OSHA (29 CFR 1926.62(j)(2)(iii)).

But the CDC stopped licensing laboratories for blood lead analysis in 1986 and stopped administering its proficiency testing program, leaving employers unable to comply with the standards' literal wording.

OSHA's fix: the agency announced it will recognize a CLIA-approved blood lead analysis laboratory as fully satisfying the requirements of both standards. Where an employer's laboratory is CLIA-approved, any technical violation regarding the outdated proficiency testing language is classified as a de minimis condition that has no direct relationship to safety or health — meaning compliance officers issue no citation and no penalty.

29 CFR 1910.102529 CFR 1910.1025(j)(2)(iii)29 CFR 1926.6229 CFR 1926.62(j)(2)(iii)
Source: OSHA Standard Interpretation letter, 2018-10-01 — read the official letter on osha.gov →
Interpretation letters explain how OSHA applies its rules to specific situations. Always verify current requirements — regulations and enforcement policies change.

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