Lead Exposure Control Program
Purpose
To establish a program to minimize employee exposure to concentrations of airborne and ground lead
when working with lead contaminated articles.
Scope
This program will apply to all employees who may be exposed to pure lead or any lead base compounds
above the limits set forth in 29 CFR 1926.62.
Exposure Limits
The following exposure limits are set forth by Occupational Safety and Health Administration, (OSHA),
in 29 CFR 1926.62. (c)
Airborne lead concentrations in excess of:
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30 micrograms per cubic meter is an indication of an exposure possibility. This level is
considered by OSHA to be the Action level. Exposure assessment and monitoring are required.
50 micrograms per cubic meter is identified by OSHA to be the Permissible Exposure Limit,
(PEL). 50 micrograms per cubic meter is based on an 8 hour Time Weighted Average, (TWA). It
is the policy of (company name) that no employee will endure lead exposure over the established
Permissible Exposure Limit.
Exposure Assessment
An exposure assessment will be completed during the Operation Analysis phase of the project, if there is
a possibility of lead exposure.
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In accordance with 29 CFR 1926.62. (d), lead that is encountered in unknown concentrations
while a project is in progress will be regarded as ten times the Permissible Exposure Limit, and
all appropriate actions will be taken in accordance with this policy until such time as an accurate
concentration determination is made.
Exposure assessment and determinations of exposure levels will be conducted by qualified
consultants.
All effected employees will be notified of a lead contaminated atmosphere within 5 working days
of a positive determination of the exposure assessment.
Compliance Program
A project specific lead control program as a part of the Project Safety and Health Planning, will be
developed before work is performed on projects where lead exposure is anticipated. This program will
include, but not be limited to:
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A description of each lead related activity.
A description of compliance procedures.
A report of the technology considered in meeting the PEL.
Air monitoring data.
A program implementation schedule.
A work practice procedure regarding protective clothing and equipment, housekeeping and
hygiene facilities and practices.
A procedure for communication of potential exposure to lead and a compliance plan, which
involves contractors on a multi employer site.
Methods Of Compliance
In accordance with 29 CFR 1926.62. (E), the possibility of employee exposure to lead at levels above the
Permissible Exposure Limit, (PEL), will be reduced by the following methods:
Area Isolation and Exclusion Zones
Upon the initial determination of a possible lead exposure hazard above the action level of 30 micrograms
per cubic meter, the possible radius of the hazard must be determined. The effected areas will be isolated
from general traffic and work by means of barricading devices and warning signs. Only authorized and
trained personnel will be allowed to enter these areas. The effected radius will be considered and
confirmed during exposure assessment.
Training
All employees that are assigned to work in areas that have been determined to have a lead contaminated
atmosphere at or above the action level of 30 micrograms per cubic meter of air will receive all applicable
training for lead exposure control, including but not limited to 4 hour lead awareness programs, (company
name) Safety polices concerning Hazard Communication, Personal Protective Equipment, Respirators,
and Employee Access to Exposure and Medical Records.
Regular Exposure Monitoring
In accordance with 29 CFR 1926.62,(j), all employees of (company name) that are assigned to work in
areas that have been determined to have a lead contaminated atmosphere at or above the action level of 30
micrograms per cubic meter of air will be required to participate in procedures to evaluate and monitor
lead exposure. This procedure will include:
Base line blood sampling
All employees that are assigned to work in areas that have been determined to have a lead contaminated
atmosphere at or above the action level of 30 micrograms per cubic meter of air will participate in a base
line blood sampling program prior to or within 48 hours of the initial exposure.
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The base line blood sampling program is the initial phase of medical surveillance and is designed to
provide data that will indicate blood lead levels prior to entering the lead contaminated atmosphere, and
provides a base to determine if blood lead levels are affected by lead exposure.
Base line blood samples and all other biological monitoring will be conducted by an (company name)
approved physician at no cost to the employee.
All obtained records and data regarding lead exposure will be included in the employees medical file as
well as the project medical file.
All data received will be made available to the employee in accordance with 29 CFR 1926.33.
Medical Surveillance
All medical surveillance will be performed by an (company name) approved physician at no cost to the
employee.
Medical surveillance is required when employees are occupationally exposed to a lead contaminated
atmosphere at or above the action level.
Medical surveillance will consist of blood testing and analysis for lead and Zinc Protoporphyrin, (ZPP),
on a regularly scheduled basis.
The schedule of medical surveillance will be:
The initial baseline blood sample.
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Re-sampling every 2 months for the first 6 months and then once every 6 months provided that
Blood Lead Levels, (BLL), remain below 40 micrograms/dl.
If BLL is determined to be in excess of the 40 microg/dllimit the employee must be re-sampled
on a scheduleof once every 2 months until BLL fall below 40 microg/dl limit.
If BLL is determined to be in excess of the 40 microg/dl limit (company name) is obligated to
inform the employee of the 50 microg/dl Medical Removal Standard, (29 CFR 1926.62 (k).
Medical Removal
All employees of (company name) that are assigned to work in areas that have a lead contaminated
atmosphere at or above the action level of 30 micrograms per cubic meter of air and have a BLL that has
been determined to be in equal to or in excess of 50 microg/dl must be removed from the lead
contaminated atmosphere and reassigned until BLL fall below the 40 microg/dl limit.
Personal Protective Equipment
Upon the initial determination of a possible lead exposure hazard the requirements for personal protective
equipment will be considered and determined in accordance with 29 CFR 1926.62(4)(g), and the
(company name) Personal Protective Equipment Program.
(Company name) will designate a clean area for the changing of clothing and protective equipment.
Contaminated clothing will be placed in sealed, air tight bags for cleaning or disposal.
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Items that are to be disposed of will be tagged lead contaminated and arrangements for disposal of lead
contaminated clothing or equipment will be made with vendors prior to disposal.
Respiratory Protection
Upon the initial determination of a possible lead exposure hazard above the action level of 30 micrograms
per cubic meter the requirements for respiratory protection equipment will be considered and determined
in accordance with 29 CFR 1926.62 (4)(f) and the (company name) Respiratory Protection Program.
Housekeeping
Isolated work areas that have been determined to have a lead contaminated atmosphere at or above the
action level of 30 micrograms per cubic meter of air will be required to follow housekeeping procedures
designed to reduce accumulations of lead contaminated dust. Housekeeping procedures will be considered
and determined in accordance with 29 CFR 1926.62(4)(h)(2,3,4,5).
Hygiene Facilities
Upon the initial determination of a possible lead exposure hazard above the action level of 30 micrograms
per cubic meter the requirements for hygiene facilities and clean eating areas will be considered and
determined in accordance with 29 CFR 1926.62 (4)(i).
Signs and Warnings
Isolated work areas that have been determined to have a lead contaminated atmosphere at or above the
Permissible Exposure Level of 50 micrograms per cubic meter of air will be barricaded or otherwise
isolated from non effected areas. Signs and warning devices will be considered and determined in
accordance with 29 CFR 1926.62(m).
Recordkeeping
The recordkeeping will include each of the following elements developed to the extent of their
applicability to the project:
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Exposure assessment
Medical surveillance
Medical removals
Exemption data verifying initial monitoring results
Records accessibility to employees.
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