Rsr Corporation v. William E. Brock, Secretary of Labor and Occupational Safety and Health Review Commission

764 F.2d 355, 12 OSHC (BNA) 1413, 1985 U.S. App. LEXIS 30775, 12 BNA OSHC 1413
CourtCourt of Appeals for the Fifth Circuit
DecidedJuly 1, 1985
Docket83-4083
StatusPublished
Cited by18 cases

This text of 764 F.2d 355 (Rsr Corporation v. William E. Brock, Secretary of Labor and Occupational Safety and Health Review Commission) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rsr Corporation v. William E. Brock, Secretary of Labor and Occupational Safety and Health Review Commission, 764 F.2d 355, 12 OSHC (BNA) 1413, 1985 U.S. App. LEXIS 30775, 12 BNA OSHC 1413 (5th Cir. 1985).

Opinion

RANDALL, Circuit Judge:

The Occupational Safety and Health Administration cited RSR Corporation for violations of OSHA’s lead standard at three of the corporation’s secondary lead refining plants. RSR Corporation contested the citations, and three separate enforcement proceedings were conducted before administrative law judges. The Occupational Safety and Health Review Commission granted discretionary review of each of the administrative law judges’ decisions and consolidated the three cases for consideration. The Commission ultimately found that RSR Corporation willfully violated an OSHA regulation which requires disclosure to employees of certain safety and health data and provisions of the lead standard which require the payment of regular wages to employees who, because of elevated levels of lead in the blood, have been temporarily removed from the workplace. The Commission assessed penalties against RSR Corporation and remanded the cases to the administrative law judges for determination of the amount of benefits owed to various employees who, because of missed workdays attributable to lead exposure, have suffered a loss of wages.

RSR Corporation petitioned for review of the Commission’s orders in the consolidated cases. The Secretary of Labor moved to dismiss the petition for lack of jurisdiction on the ground that, because of the remands to determine the amount of wages owed to various employees, the Commission’s orders are not final. A screening panel of *357 this court denied the motion. See RSR Corp. v. Donovan, 733 F.2d 1142 (5th Cir. 1984). We have since heard oral argument, and we turn now to an analysis of the merits of RSR Corporation’s petition for review. Because we find that the Commission’s interpretation of the lead standard is reasonable and that its findings of fact are supported by substantial evidence, we affirm the orders in all respects.

I. FACTUAL AND PROCEDUREAL BACKGROUND

A. The Lead Standard

In November 1978, the Occupational Safety and Health Administration (“OSHA”) issued a new standard (the “lead standard”) designed to protect workers from the hazards of exposure to lead in the workplace. 1 The lead standard has been the subject of extensive public comment and judicial review; a comprehensive analysis of its provisions is not necessary in this proceeding. We note generally that the standard seeks to reduce the harmful effects of lead exposure by requiring employers to reduce the amount of airborne lead to which employees are exposed and to remove from the workplace altogether those employees for whom continued lead exposure is unsafe. To implement these controls, the lead standard requires both environmental monitoring of the workplace and biological monitoring of employees. This case is primarily concerned with the provisions of the lead standard dealing with the removal of individual employees from lead exposure.

The lead standard provides that, if the amount of airborne lead in the workplace exceeds the “action level” 2 for more than thirty days per year, employers must periodically cheek the blood-lead levels of employees and conduct full-scale medical examinations. The standard further provides that, if monitoring reveals lead in the blood in excess of the applicable trigger level, 3 or if a medical examination results in “a final medical determination” 4 that an employee “has a detected medical condition which places the employee at increased risk of material impairment to health from exposure to lead,” the employee must be temporarily removed from lead exposure. 29 C.F.R. § 1910.1025(k)(l)(i)-(ii). The latter ground for temporary removal is intentionally stated in imprecise terms so as to provide flexibility to examining physicians. Examples of the employees it is designed to cover include those with signs of lead poisoning despite low levels of lead in the *358 blood, those who have medical conditions unrelated to work that may be aggravated by exposure to lead, and those who are pregnant or are planning to become so. See 43 Fed.Reg. 54,462-63 (1978). An employee who has been temporarily removed may return to his regular work when the amount of lead in his blood falls below certain prescribed levels or when another final medical determination reveals that he no longer has a medical condition which places him at increased risk. 29 C.F.R. § 1910.1025(k)(l)(iii)(A)(l)-(4).

An employee who has been temporarily removed from his regular job because of an elevated blood-lead level or because of a final medical determination that he is at increased risk from lead exposure may be reassigned to a low-exposure position or may be placed on medical leave. During the period of temporary removal, the employer must, however, provide him with “medical removal protection” (“MRP”) benefits, i.e., “the earnings, seniority and other employment rights and benefits” that he would have earned if he had been able to continue working in his regular position. Id. § 1910.1025(k)(2)(ii). 5 If an employer voluntarily removes an employee from the workplace because of “the effect of lead exposure on the employee’s medical condition,” the employer must nonetheless pay MRP benefits even though the removal was not mandated by the lead standard. Id. § 1910.1025(k)(2)(vii). 6

The duration of the employer’s duty to pay MRP benefits is one of the disputed questions in this case. The lead standard provides that, if an employee has been removed from lead exposure because of an excess amount of lead in the blood, the employer must provide MRP benefits for at least eighteen months. Id. § 1910.-1025(k)(2)(vi). 7 If, after eighteen months, *359 the employee’s blood-lead level has not decreased below the standard’s return level, the employer shall obtain a final medical determination with respect to the employee’s ability safely to return to work. If the doctors determine that the employee cannot yet, but may in the future, safely return to his former job, the employer must continue to pay MRP benefits. If, on the other hand, the doctors conclude that “the employee is incapable of ever safely returning to his or her former job status,” the employer may then cease payment of MRP benefits. Id. As we develop later in this opinion, all parties agree that, under some circumstances, MRP benefits may also be terminated before the expiration of eighteen months of temporary removal. There is, however, considerable disagreement with respect to what those circumstances are.

OSHA scheduled the lead standard to become effective on March 1, 1979.

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764 F.2d 355, 12 OSHC (BNA) 1413, 1985 U.S. App. LEXIS 30775, 12 BNA OSHC 1413, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rsr-corporation-v-william-e-brock-secretary-of-labor-and-occupational-ca5-1985.