Lead Exposure for Construction

Health hazards of lead exposure v Pure lead (Pb) is a heavy metal and a chemical element v Lead can combine with other chemicals to form numerous lead compounds v Lead can enter the body by inhalation and ingestion 1a

Health hazards of lead exposure v Only a few lead compounds can be absorbed through the skin v When scattered through the air as a dust, fume, or mist, lead can be inhaled and absorbed through the lungs and upper respiratory tract 1b

Health hazards of lead exposure v Inhalation of airborne lead is generally the most important source of occupational lead absorption v Lead also can be absorbed through the digestive system if it enters the mouth and is ingested 1c

Health hazards of lead exposure v The lead stored in the tissues can slowly cause irreversible damage to: individual cellsindividual cells organsorgans whole body systemswhole body systems 1d

Health hazards of lead exposure v Lead causes health problems and disease after exposure periods: as short as days (acute exposure)as short as days (acute exposure) as long as several years (chronic overexposure).as long as several years (chronic overexposure). 1e

Health hazards of lead exposure v A short-term dose of lead exposure can lead to acute encephalopathy, a condition affecting the brain that develops quickly into: seizuresseizures comacoma death from cardiorespiratory arrestdeath from cardiorespiratory arrest 1f

Health hazards of lead exposure v Central nervous system damage is one of the most severe forms of lead poisoning v Long-term (chronic) overexposure to lead may damage the blood-forming, nervous, urinary, and reproductive systems 1g

Health hazards of lead exposure v Read the MSDS and the container’s label when you use any product that contains lead 1h

Potential for exposure You may be exposed to lead if you perform activities like: abrasive blastingabrasive blasting sandingsanding scrapingscraping cuttingcutting burningburning weldingwelding paintingpainting 2a

Potential for exposure v Operations that generate lead dust and fumes include: flame-torch cutting, welding, the use of heat guns, sanding, scraping and grinding of lead painted surfacesflame-torch cutting, welding, the use of heat guns, sanding, scraping and grinding of lead painted surfaces 2b

Potential for exposure v Operations that generate lead dust and fumes include: abrasive blasting of bridges and other structures containing lead- based paintsabrasive blasting of bridges and other structures containing lead- based paints maintaining process equipment or exhaust duct workmaintaining process equipment or exhaust duct work 2c

OSHA’s standard on lead v Lead includes metallic lead, all inorganic lead compounds, and organic lead soaps v Applies to all construction work where an employee may be exposed to lead on the job 3a

OSHA’s standard on lead Under the standard, construction includes the following: v Demolition or salvage of structures where lead or materials containing lead are present v Removal or encapsulation of materials containing lead 3b

OSHA’s standard on lead v New construction, alteration, repair, or renovation where lead is present v Installation of products containing lead v Lead contamination from emergency cleanup 3c

OSHA’s standard on lead v Transportation, disposal, storage, or containment of lead or materials containing lead v Maintenance operations associated with construction activities described above 3d

OSHA’s standard on lead v The standard includes requirements for: 3e

OSHA’s standard on lead v Exposure limits v Exposure assessment v Methods of compliance v Respiratory protection v Protective work clothing and equipment v Housekeeping 3f

v Hygiene facilities and practices v Medical surveillance v Medical removal protection v Employee Information and training v Signs v Recordkeeping v Observation of monitoring OSHA’s standard on lead 3g

OSHA’s standard on lead v Appendices that contain helpful information about lead’s hazards include: Appendix A - Substance Data Sheet for Occupational Exposure to LeadAppendix A - Substance Data Sheet for Occupational Exposure to Lead Appendix B - Employee Standard SummaryAppendix B - Employee Standard Summary Appendix C - Medical Surveillance GuidelinesAppendix C - Medical Surveillance Guidelines 3h

Permissible exposure limit (PEL) v The PEL is the limit of airborne lead to which you can be exposed v The PEL is 50 micrograms of lead per cubic meter of air averaged over an 8-hour workday 4a

Permissible exposure limit (PEL) v Short exposures above 50 micrograms per cubic meter are permitted if each 8-hour work day your average exposure does not exceed this level 4b

Permissible exposure limit (PEL) v Daily exposure to lead can extend beyond a typical 8-hour workday if: you work overtimeyou work overtime have other alterations in your work schedulehave other alterations in your work schedule 4c

Permissible exposure limit (PEL) v The standard contains a formula that calculates how much your exposure needs to be reduced when you are exposed more than 8 hours 4d

Assessing the exposure level v Employers must make an initial determination of whether any employee’s exposure to lead exceeds the standard’s action level v An action level is the level at which an employer must begin certain compliance activities 5a

Assessing the exposure level v The action level is an airborne concentration of 30 micrograms per cubic meter calculated as an eight-hour TWA v Respirators are not considered when the action level is being assessed 5b

Assessing the exposure level v Initial determination and results must be made available based on the following: Any information, observation, or calculation that indicates employee exposure to leadAny information, observation, or calculation that indicates employee exposure to lead Any previous measurements of airborne leadAny previous measurements of airborne lead 5c

Assessing the exposure level v Initial determination and results must be made available based on the following: Any employee complaints of symptoms attributable to lead exposureAny employee complaints of symptoms attributable to lead exposure Objective data regarding materials, processes, or operationsObjective data regarding materials, processes, or operations 5d

Assessing the exposure level v For the initial determination, a representative number of employees may be monitored 5e

When exposure results are not yet available v Employers must provide protection if you are performing certain tasks before the results of the exposure assessment are known 6a

When exposure results are not yet available v During certain tasks, until tests show that your exposure level is not above the PEL, you will need: respiratory protectionrespiratory protection protective clothing and equipmentprotective clothing and equipment change areaschange areas 6b

When exposure results are not yet available v During certain tasks, until tests show that your exposure level is not above the PEL, you will need: hand washing facilitieshand washing facilities biological monitoringbiological monitoring trainingtraining 6c

Monitoring requirements v If the initial determination proves that exposure is below the action level: testing does not need to be repeated unless there is a change in processes or controlstesting does not need to be repeated unless there is a change in processes or controls 7a

Monitoring requirements v If employee exposure is at or above the action level, but at or below the PEL: air monitoring tests must be performed at least every six months until at least two consecutive measurements (taken at least seven days apart) are below the action levelair monitoring tests must be performed at least every six months until at least two consecutive measurements (taken at least seven days apart) are below the action level 7b

Monitoring requirements v If employee exposure is above the PEL, monitoring must: be performed quarterlybe performed quarterly continue until at least two consecutive measurements (taken at least seven days apart) are at or below the PELcontinue until at least two consecutive measurements (taken at least seven days apart) are at or below the PEL 7c

Monitoring requirements v Additional monitoring is needed if there are changes to: equipmentequipment processesprocesses controlscontrols personnelpersonnel tasks that could increase exposuretasks that could increase exposure 7d

Monitoring requirements v Affected employees can observe monitoring v Employers must notify you in writing within 5 working days of the air monitoring results 7e

Monitoring requirements v If the results indicate that your exposure exceeds the PEL, information regarding corrective actions must be provided 7f

Written compliance programs v Compliance programs are required before starting any job where employee exposures may reach the PEL as an 8-hour TWA 8a

Written compliance program includes: v A description of each activity in which lead is emitted v Specific plans to achieve compliance 8b

Written compliance program includes: v Information on the technology considered to meet the PEL v Air monitoring data that documents the source of lead emissions 8c

Written compliance program includes: v A detailed schedule for implementing the program v A work practice program v An administrative control schedule for job rotation 8d

Written compliance program includes: v A description of arrangements made among contractors on multi-contractor sites to inform affected employees of potential lead exposure v Any other relevant information 8e

Written compliance programs v The compliance program must provide for frequent and regular inspections of: job sitesjob sites materialsmaterials equipmentequipment 8f

Control measures to reduce exposures v Employees must not be exposed to lead in excess of the PEL as an 8-hour TWA v Minimize exposure through the use of engineering controls and work practices 9a

Control measures to reduce exposures v Respirators are not to be used in lieu of engineering and work practices to reduce employee exposures v Respirators can only be used in combination with engineering controls and work practices to control employee exposures 9b

Control measures to reduce exposures v All feasible engineering controls and work practices must be in place if they are not sufficient to reduce exposure to or below the PEL 9c

Control measures to reduce exposures v Engineering controls reduce employee exposure in the workplace either by: removing or isolating the hazardremoving or isolating the hazard isolating the worker from exposure through the use of technologyisolating the worker from exposure through the use of technology 9d

Control measures to reduce exposures v Work practice controls reduce the likelihood of exposure by altering the manner in which a task is performed 9e

Engineering controls v Exhaust Ventilation v Enclosure/Encapsulation v Substitution 10a

Engineering controls v Component Replacement v Process/Equipment Modification v Isolation 10b

Housekeeping as a work practice control v Housekeeping is an important work practice control v Accumulations of lead dust and lead-containing debris must be removed at least daily 11a

Housekeeping as a work practice control v Vacuuming lead dust with filtered equipment (HEPA) or wetting it with water before sweeping are effective control measures v Conduct cleaning operations at the end of the day 11b

Housekeeping as a work practice control v Use suitable respiratory protection and personal protective clothing during cleanup 11c

Housekeeping as a work practice control v Place lead-containing debris and contaminated items into: sealed impermeable bagssealed impermeable bags other closed impermeable containersother closed impermeable containers 11d

Housekeeping as a work practice control v Bags and containers should be appropriately labeled as lead- containing waste 11e

Personal hygiene as work practice controls v Hand washing facilities must be provided where occupational exposure to lead occurs 12a

v Change areas, showers, and lunchrooms are to be made available to workers exposed to lead above the PEL Personal hygiene as work practice controls 12b

Personal hygiene as work practice controls v Lunchrooms or eating areas may not be entered unless you have removed any surface dust from your protective clothing or equipment 12c

Personal hygiene as work practice controls v Change rooms must have separate storage facilities for your protective clothing and equipment and street clothes 12d

Personal hygiene as work practice controls v Work clothing and protective equipment must not be worn away from the job site v Where showers are not provided, employees exposed to lead above the PEL must wash their hands and face at the end of the workshift 12e

Administrative controls v Administrative controls reduce employee exposure by removing the employee from the hazard v If administrative controls are being used, the employer must establish and implement a job rotation schedule 13a

Administrative controls v The program must: identify each affected employeeidentify each affected employee specify the duration and exposure level at each job or work stationspecify the duration and exposure level at each job or work station include other useful informationinclude other useful information v The job rotation schedule must be included in the written compliance plan 13b

Respirator requirements Employers must provide respiratory protection, at no cost to employees, and must ensure its use when: 14a

v employee exposure to lead exceeds the PEL v engineering and work practice controls are not sufficient to reduce exposure levels to or below the PEL 14b Respirator requirements

v an employee requests a respirator v interim protection is needed for employees performing some tasks before exposure results are available 14c

Respirator requirements v Respiratory protection program must be in accordance with 29 CFR v Respirators must be selected according to the standard’s Table 1 14d

Respirator requirements v Employer must provide a powered-air purifying respirator when an employee chooses to use one v If an employee has breathing difficulty during fit testing or respirator use, a medical examination must be performed 14e

Protective clothing and equipment v Employers must provide protective work clothing and equipment at no cost if you are exposed to lead: above the PEL as an 8-hour TWAabove the PEL as an 8-hour TWA compounds that can cause skin and eye irritationcompounds that can cause skin and eye irritation 15a

Protective clothing and equipment v Appropriate protective work clothing and equipment can include: coveralls or similar full-body work clothingcoveralls or similar full-body work clothing glovesgloves hatshats 15b

Protective clothing and equipment v Appropriate protective work clothing and equipment can include: shoes or disposable shoe coverletsshoes or disposable shoe coverlets face shields or vented gogglesface shields or vented goggles 15c

Protective clothing and equipment v Clean protective clothing must be provided at least weekly v Clothing must be provided daily if your airborne exposure to lead is greater than 200 micrograms per cubic meter 15d

Protective clothing and equipment v Employers are responsible for repairs, replacement, cleaning, laundering, and disposal 15e

Protective clothing and equipment – entering v Change into work clothing and shoe covers in the clean section of the designated changing areas v Use work garments and protective gear before entering the lead work area 15f

Protective clothing and equipment - leaving v HEPA vacuum heavily contaminated protective work clothing while it is still being worn v Remove shoe covers and disposable garments 15g

Protective clothing and equipment - leaving v Leave shoe covers in the lead work area where they will be collected for disposal v Remove protective clothing and gear in the dirty area of the designated changing area 15h

Protective clothing and equipment - leaving v Remove reusable protective coveralls by carefully rolling down the garment to reduce your exposure to dust v Remove respirators last v Wash hands and face 15i

Protective clothing and equipment - leaving v Where applicable, place disposable coveralls and shoe covers with the abatement waste v Contaminated clothing which is to be cleaned, laundered or disposed of must be placed in closed containers in the change room 15j

Protective clothing and equipment - leaving v Clean protective gear, including respirators, according to standard procedures v Wash hands and face again. 15k

Protective clothing and equipment - leaving v If showers are available, take a shower and wash your hair v If shower facilities are not available at the work site, shower immediately at home 15l

Protective clothing and equipment v Containers of contaminated clothing must be labeled with the following warning: 15m

Protective clothing and equipment v Inform the people who are responsible for handling or laundering contaminated clothing in writing about the potential hazards 15n

Warning signs v Post the following warning sign in work areas where the exposure to lead exceeds the PEL: 16a

Warning signs v All signs must be well lit and kept clean so that they are easily visible 16b

Medical surveillance v Medical surveillance program supplements the procedures that minimize exposure to lead v Medical surveillance determines if the other provisions of the standard have protected the workers 17a

Medical surveillance v Medical surveillance involves having periodic blood tests and may also include medical examinations v The frequency of the testing depends on your exposure, and previous blood test results 17b

Medical surveillance v The provision for having medical examinations depends on: your exposureyour exposure blood test resultsblood test results the development of symptoms of overexposurethe development of symptoms of overexposure 17c

Medical surveillance v Blood sampling v Medical exams v Multiple physician review v Chelation 17d

Medical removal protection benefits v Medical removal protects worker health by: stopping further occupational exposurestopping further occupational exposure enabling the worker to excrete the absorbed lead naturallyenabling the worker to excrete the absorbed lead naturally 18a

Medical removal protection benefits v Employers must remove employees with lead exposure at or above the action level each time: 18b

Medical removal protection benefits v a periodic and follow-up blood sampling test indicates a blood lead level at or above 50 micrograms per deciliter v a final medical determination indicates a detected medical condition that increases health risks from lead exposure 18c

Medical removal protection benefits v Employers must provide up to 18 months of medical removal protection benefits each time an employee is removed from lead exposure 18d

Medical removal protection benefits v As long as the position/job exists, the employer must maintain the: earningsearnings seniorityseniority other employment rights and benefitsother employment rights and benefits 18e

Medical removal protection benefits v Employers must return employees to their former job status when: two consecutive blood sampling tests indicate a blood lead level is at or below 40 micrograms per deciliter for employees removed due to a blood lead level at or above 50 micrograms per decilitertwo consecutive blood sampling tests indicate a blood lead level is at or below 40 micrograms per deciliter for employees removed due to a blood lead level at or above 50 micrograms per deciliter 18f

Medical removal protection benefits v Employers must return employees to their former job status when: a subsequent final medical determination indicates there is no longer a detected medical condition that increases health risks from lead exposurea subsequent final medical determination indicates there is no longer a detected medical condition that increases health risks from lead exposure 18g

Medical removal protection benefits v If a removed employee files a worker’s compensation claim for a lead-related disability, employers must continue medical removal protection benefits pending the disposition of the claim 18h

Medical removal protection benefits When the multiple physicians’ review has not yet resulted in a final medical determination, the employer must: 18i

Medical removal protection benefits v remove employees from lead exposure v provide special protective measures v place limitations on employees 18j

Medical removal protection benefits v return employees to their former job status v end special protective measures v remove limitations 18k

Recordkeeping v Employers must establish and maintain an accurate record of: all required monitoring and other data used to conduct employee exposure assessmentsall required monitoring and other data used to conduct employee exposure assessments 19a

Recordkeeping v Employers must establish and maintain an accurate record of: any objective data relied on to determine initial exposure if it was used in lieu of exposure monitoring for exposure assessment purposesany objective data relied on to determine initial exposure if it was used in lieu of exposure monitoring for exposure assessment purposes 19b

Recordkeeping v Employers must establish and maintain an accurate record of: information and medical records for each employee subject to medical surveillanceinformation and medical records for each employee subject to medical surveillance each employee subject to medical removaleach employee subject to medical removal 19c

Recordkeeping v Employer must make all records available upon request to: affected employeesaffected employees former employees designated representativesformer employees designated representatives 19d