29 CFR Lead in General Industry Lead in Construction ile, Compliance Officer Utah OSHA – (801) Shaheen Safiullah Compliance Assistance Specialist

Health Effects Routes of Entry Inhalation (breathing) Ingestion (swallowing)

Health Effects Acute effects –Abdominal pain –Constipation –Limb pain –Hypertension –Vomiting –Coma –Respiratory arrest –Death

Health Effects (contd) Chronic effects –Fatigue –Weight loss –Insomnia –Shaking of arms –Foot drop, wrist drop –Blue line on gums

Organs and systems affected Blood System (heme-synthesis inhibition) Nervous System Kidneys and Liver Reproductive System * Children and Lead

Medical Expenses Higher workers compensation premium –Liability Lawsuits –Loss of Productivity –Loss in earning power –Lost time by supervision –Lost time by fellow workers –Cost of training new personnel –Economic loss to injured worker’s family

Exposure Limits PEL (permissible exposure limit) –50  g/m 3 (8-hour time weighted average) –OR, Allowable employee exposure in  g/m 3 ) = 400 divided by the number of hours worked in the day AL (Action Level) –30  g/m 3 (8 hour time weighted average) Blood Lead Level (BLL) –50  g/dl

Exposure Assessment Employers shall initially determine if any employee may be exposed to lead at or above the action level. Do not use the protection factor of respirators during exposure assessment. –Collect personal samples representative of a full shift At least one sample for each job classification in each work area with the highest exposure –Exception: Any data obtained within the past 12 months under closely resembling work conditions such as processes, type of material, control methods, work practices, environmental conditions, is acceptable in place of personal air samples in the current workplace.

Construction: Provide Protection During Exposure Assessment Appropriate respiratory protection Protective work clothing & equipment Change areas Handwashing facilities Training Initial medical surveillance: BLL & ZPP

Construction: Assumed Exposures >PEL but < 10X PEL Manual scraping/sanding Heat gun applications General clean up Power tool cleaning w/dust collection systems Spray painting with lead-based paint

Construction: Assumed Exposures >10X PEL but <50X PEL Lead-containing mortar; lead burning Rivet busting Power tool cleaning w/out dust collection systems Clean up of dry expendable abrasives Abrasive blasting enclosure movement and removal

Construction: Assumed Exposures >50X PEL Abrasive blasting Welding Cutting Torch burning

Basis of initial determination Employer shall conduct initial monitoring based on the following observations: –Employee exposure monitoring results –Any information, observations or calculations which would indicate lead exposure –Previous monitoring –Employee complaints of symptoms related to lead exposure

Initial determination exception Objective data showing that a particular product containing lead or a process, operation or activity involving lead cannot result in employee exposure to lead at or above the action level during processing, use or handling, the employer may rely upon such data instead of implementing initial monitoring. –Maintain an accurate record documenting the nature and relevancy of objective data. This record must be maintained for 30 years. Any data obtained within the past 12 months under closely resembling conditions. Objective data cannot be used for exposure assessment during interim protection.

Positive initial determination If there is possibility of exposure above the action level then representative monitoring must be conducted. –If above the AL but below the PEL monitoring shall be done every 6 months –If above the PEL then every 3 months

Additional Exposure Assessments Required When Changes that may result in increased exposure: –Equipment –Process/new task –Control –Personnel

(e) Methods of compliance

Hierarchy of Controls Goal: reduce exposures to  PEL Must institute engineering and work practice controls May use administrative controls May supplement with respiratory protection after achieving lowest feasible level

Compliance Program Required if  PEL Revised/updated every 6 months

Compliance Program Components Description of lead-emitting processes –Equipment, material, controls, crew size, job description, SOPs, maintenance procedures How compliance will be achieved Technology considered to achieve PEL Air monitoring data documenting lead emission source Schedule for implementation

Compliance Program Components (cont’d) Work practice program –Protective clothing –Housekeeping –Hygiene facilities –Work practices as described in App B where relevant

Compliance Program Components (cont’d) Administrative controls –Implement a job rotation schedule: ID of employee Duration and exposure levels of each job Any other information useful in assessing reliability of administrative controls

Compliance Program Components (cont’d) Arrangements made among contractors on multi-contractor sites ( ) Provisions for frequent and regular inspections of job sites, materials and equipment by a competent person Revise the program at least every six months

No Apparent Controls for Lead Exposure

Engineering Control Isolation / Containment

Engineering Controls Shrouded Tools w/HEPA vacuum

Other Engineering & Work Practice Controls Substitution Ventilation Processes than minimize dust generation –Chemical paint strippers –Wet methods

Chemical Paint Removers

(f) Respiratory Protection Implement a written respiratory protection program (29 CFR )

Air-Purifying Respirator (APR) Cleanses the contaminated atmosphere Can’t be worn: in unknown/IDLH atmospheres where prohibited

Powered Air-Purifying Respirator (PAPR) An air-purifying respirator that uses a blower to force the ambient air through air-purifying elements to the inlet covering.

Atmosphere-Supplying Respirators Supplies breathing air Includes: –Supplied air respirators –SCBA –Combination SAR / SCBA units

Two Basic Classes of Contaminants Aerosols/particulates –Airborne solid or liquid particles –Dusts, fumes, mists, fog, smoke, fibers Gases/Vapors

High Efficiency Particulate Air Filter (HEPA) Filter that is at least 99.97% efficient in removing monodisperse particles of 0.3 micrometers in diameter. Equivalent NIOSH 42 CFR 84 particulate filters are the N100, R100, and P100 filters.

Medical Evaluations Before fit testing and use Performed by PLHCP –medical questionnaire Appendix C –an initial medical examination

Fit Testing Assess respirator fit prior to use

Use of Respirators Facepiece Seal Protection No facial hair or any condition that interferes with the face-to-facepiece seal or valve function Corrective glasses or goggles or other PPE must be worn in a manner that does not interfere with the face-to-facepiece seal User seal check each time

User Seal Check An action conducted by the respirator user to determine if the respirator is properly seated to the face. Positive Pressure Check Negative Pressure Check

Maintenance and Care Clean and disinfect Storage –Cartridges/filters separately –Plastic bags or coffee cans

Respirator Selection Based on exposure level Select using Table 1 PAPRs must be provided if –Employee chooses and –Provides adequate protection

(g) Protective Work Clothing and Equipment

Provision and Use Prevent employee contamination Provide and maintain at no cost when –> PEL –Skin/eye irritation –Interim protection Ensure use

Cleaning & Replacement Clean at least weekly; daily if >200  g/m 3 Remove PPE in change areas only Put into closed, labeled containers Inform cleaning personnel in writing No blowing, shaking, or otherwise dispersing in air

(h) Housekeeping – for all exposures! Keep all surfaces free from lead Use HEPA filter when vacuuming Shoveling, dry or wet sweeping used only where vacuuming or an equal method is not effective Compressed air not allowed unless used with exhaust ventilation system

(i) Hygiene Facilities & Practices

Lead on Hands & Blood Lead Levels Positive correlation between lead on hand tested and blood lead levels

Hygiene Facilities & Practices Required when exposure > PEL No food, drinks, cigs, cosmetics –Wash hands/face prior Eating facilities/areas: provide –Free from lead –Enter after removing surface Pb dust

Signs Required in Areas >PEL

Hygiene Facilities & Practices - cont Provide clean change rooms –Separate work and street clothes –Ensure workers don’t wear PPE home Showers: provide and ensure use when > PEL –If unfeasible, handwashing facilities –Provide cleansing agents and towels

Hygiene Facilities & Practices - cont

D-Lead Cleaning Products

Lead Check Swabs

D-Lead Lead Test Kits Spray Solution 1, then Solution 2 Yellow means lead is present

(j) Medical Surveillance

Medical Surveillance Biological Monitoring when = or >AL –Blood lead levels (BLL) –Zinc Protoporphyrin (ZPP) Medical Examinations by licensed physician

Medical Surveillance – cont When =/ > AL for more than 30 days in any consecutive 12 months No cost to employees, reasonable time and place Requirements vary according to –Workplace type –Exposure level –BLL level

(k) Medical Removal Protection (MRP)  50  g/dl whole blood

Temporary Removals Final medical determination: Any medical finding that the employee has a medical condition increasing risk of material impairment to health from exposure to lead

Temporary Removals - cont Remove from Pb exposures  50  g/dl Return when two consecutive BLL tests are  40  g/dl whole blood

MRP Benefits Maintain –Normal earnings –Seniority –Other rights and benefits Benefits continue for up to 18 mos on each occasion

(l) Training Requirements Prior to start of job At least annually Extent of training depends on exposure

(m) Recordkeeping Keep for at least 40 years or duration of employment + 20 years (30 yrs construction) –Exposure assessment data –Objective data for monitoring exemption –Medical surveillance ( duration of employment + 30 years, construction)

OSHA website Federal OSHA: –Click on “Technical Links” under the outreach section Utah OSHA: NIOSH: