Published: March 2003 Department of Labour GUIDE LEAD REGULATIONS 2001 Chief Directorate of Occupational Health and Safety NO: OHC 2 FOREWORD The purpose of this guide is to help all persons responsible for, or concerned with the control and prevention of exposure to lead, employees and the public alike, within the context of the working environment. This guide does not replace the Lead Regulations of 2001. It is a supplement to the Lead Regulations and it was written to give practical insight into the Regulations to persons concerned with lead in the workplace. Therefore, it should not be taken as the only source of guidance, but it should always be read in conjunction with the Lead Regulations and the Occupational Health and Safety Act of 1993. 2 CONTENTS Regulation 2 Regulation 3 Regulation 4 Regulation 5 Regulation 6 Regulation 7 Regulation 8 Regulation 9 Regulation 10 Regulation 11 Regulation 12 Regulation 13 Regulation 14 Regulation 15 Regulation 16 Regulation 17 INTRODUCTION Scope of Application Exposure to Airborne Lead Information and Training Duties of Persons Who May be Exposed Assessment of Potential Exposure Air Monitoring Medical Surveillance Respirator Zone Records Control of Exposure to lead Personal Protective Equipment and Facilities Cleanliness of Premises and Plant Maintenance of Control Measures Prohibitions Labelling, Packaging, Transportation and Storage Disposal of Lead Waste Table 2 and 3 4 4 5 5 5 6 6&7 7-9 9 9&10 10-12 12-14 14 14 15 15 15&16 17&18 3 Introduction Exposure to high levels of lead can affect worker’s health and results in far more serious symptoms such as: Kidney damage Nerve and brain damage. Lead and its compounds can enter the body in the following three ways: Inhalation Lead can be breathed in when dust, fumes or vapour containing lead are in the air. Inhalation of these tiny lead particles is the most common source of exposure to lead at work. Ingestion Lead particles such as powder or dust, can be ingested from contaminated clothing, hands, beard or moustache. These particles can also be ingested if food or beverage is contaminated with lead. Smoking contaminated cigarettes is particularly risky, because lead particles can be inhaled and ingested. Absorption Tetra-ethyl and tetra-methyl lead, also known as lead alkyls, can enter the body through the skin. The Lead Regulations, 2001 were published on 28 February 2002 in Government Gazette No. 23175 with the aim of protecting employees against the dangers associated with the effect of lead on the human health. Throughout this guide, the Act means the Occupational Health and Safety Act of 1993 and Lead Regulations means Lead Regulations, 2001. The aim of these guidance notes is to explain in simple language the provisions of the Lead Regulations. Regulation 2: Scope of application The aim of regulation 2 is to ensure that the level of protection from lead exposure in every given case is appropriate and practical in relation to the nature and degree of exposure. To whom do these regulations apply? The Lead Regulations apply to all employers and self-employed person at workplaces where lead and lead compounds could enter the body of any person. This includes lead as a component of a substance or material. 4 Regulation 3: Exposure to airborne lead It is the duty of employers to ensure that the concentration of lead inhaled by employees does not exceed the exposure limit for lead as shown in Table 1 TABLE 1: OCCUPATIONAL EXPOSURE LIMITS FOR LEAD Tetra-ethyl lead and (Known as lead alkyl) Tetra-methyl Lead other than tetra-ethyl lead lead 0, 10 mg/m3 air 0, 15 mg/m3 air Regulation 4: Information and training Education and training of any person who has potential exposure to lead is of paramount importance, in order to assist employers and employees in reducing the risk of exposure to lead. The employer must ensure that he obtains suitable information and training in order to train employees effectively. Alternatively obtain the services of a person who has the requisite competence. Competence in relation to these regulations infers that the person has practical experience relating to the correct handling, hygiene and work practices relating to work with lead. Additionally the person must have a theoretical knowledge of the toxic effects of lead. Education and training must be planned carefully and presented on commencement of employment, and at least annually thereafter. It is of the utmost importance that health and safety representatives or committees are thoroughly trained and educated with regards to work with lead. This is to ensure that the health and safety representatives or committees are able to make informed decisions relating to their discretionary powers. It is the duty of employers to ensure that all employees have thorough knowledge of the provisions of the Act and these regulations. Regulation 5: Duties of persons who may be exposed Employees or any other person exposed to lead has a moral and legal duty to comply with any lawful instruction and procedure (written or oral) given by or on behalf of employers. In addition, employees must comply with the requirements laid down by the Act and other regulations under the Act. Failure to do so could result in an increased risk to his health and safety and that of others and may lead to his prosecution. 5 These instructions and procedures may differ from one workplace to another because workplaces are not identical. Employees should be informed that they are legally required to provide blood or urine samples to the doctor for testing of the effects of lead. Employees must be informed of this before appointment. These blood samples will only be used for this purpose and not for AIDS or any other test not prescribed by the Act Regulation 6: Assessment of potential exposure This regulation requires the employer to establish if any person is exposed or is likely to be exposed to lead at the workplace. Assessment is the first step in the process of collecting information in order to make decisions with regard to the risk to health of workers and measures necessary to control lead hazards. The onus is on the employer (or self-employed person) to ensure that a proper assessment is conducted. Who should conduct the assessment? The person conducting the assessment should be conversant with the work environment, the processes relating to working with lead and the risks associated with lead exposure. Assessments must be conducted in consultation with health and safety representatives or committee to ensure that their inputs are taken into considerations and ensure transparency. This assessment can be a complex scientific process and it is recommended that references such as the SAIOH 21 or UK HSE, COSHH Essentials be consulted. Re-assessments The re-assessment is intended to confirm the validity of the previous assessment and ascertain that the control measures have been implemented and are effective. The re-assessment need not repeat the previous assessment procedure but would be designed specifically to address a range of concerns outlined in this regulation. Tables 2 and 3 at the back of the guide, can be used as guidelines to see whether there is a possibility of exposure or not. Regulation 7: Air monitoring If the assessment indicates (the indication is determined by application of the ‘initial appraisal’ approach described in HSG 173) that the exposure is in excess of half the OEL2, air monitoring3 should be 1 SAIOH means the South African Institute for Occupational Hygienist The OEL (Occupational Exposure Limit) for lead alkyls (e.g. tetra-alkyl lead) is 0.1mg lead per cubic meter of air and for lead other than the lead alkyls is 0.15mg lead per cubic meter of air. 2 6 conducted. An initial appraisal approach described in HSG 173 incorporates combination of qualitative and semi-quantitative determination methods. The one complements the other. Air monitoring shows how effective engineering control methods can be in reducing the level of airborne lead, while biological monitoring gives information about the practice of personal hygiene by the employee and general housekeeping in the workplace. The monitoring of airborne lead is a complex process, which requires advanced knowledge and insight. Due to the highly technical nature of the air monitoring programme, the person undertaking the task should preferably be an approved lead inspection authority for airborne lead. Alternatively a knowledgeable employee registered with SAIOH, whose competence has been verified by an approved lead inspection authority may monitor the air. Such a person should have the knowledge and skills to determine the concentration of airborne lead in accordance with HSG 173 and OESSM plus the South African Bureau of Standards' Standard Method for the Determination of Lead (Inorganic and Tetra-alkyl) in Workplace Air by Atomic Absorption and Spectrophotometry, SABS 1164-1989. These guidelines do not go into specific details. As a general guideline, however: The employer must first inform the relevant health and safety representative or health and safety committee of the proposed monitoring and give them a reasonable opportunity to comment; The AIA is accountable for the entire process of monitoring and takes full responsibility for the validity, accuracy and correctness of measurement results. The decision regarding the number and duration of samples lies with the AIA. The sampling strategy must, however, be representative of the exposure of employees. If measurement of a representative employee shows that the exposure is above the OEL, then the exposure of all employees that will have the same exposure must be measured. Representative measurements must be done at least every 12 months. The representative measurement can be achieved as follows─ group measurement as contemplated in chapter 3 and 4 and table A-2 of Technical Appendix A of the OESSM; or taking the measurements of the most exposed employee. If the exposure of the most exposed person exceeds the OEL for lead then every employee whose exposure could be above the OEL is identified and representative measurement is carried out on every identified persons. Employers who make use of a knowledgeable employees registered with SAIOH to monitor the exposure of employees to airborne lead must obtain the services of an approved lead inspection authority to act at least once a year as a neutral party or person in order to─ investigate the measuring programme, measuring apparatus and analysing equipment; evaluate the ability of the person doing measurements to act in that capacity; carry out the required measurements for one shift; and record the results of the investigation and measurements as required by regulation 9. (See Information Brochure No. 1 for Approved Inspection Authorities for Occupational Hygiene for more information available from the DOL provincial office). 3 A formal measurement program to establish the airborne concentration of lead in a particular work place when there is a possibility that workers could be exposed to any form of lead in excess of half the OEL 7 Regulation 8: Medical surveillance The need for medical surveillance and the nature thereof is based on both the risk assessment and air monitoring results. It should be noted that persons exposed to lead alkyls should be under medical examination regardless of the levels of exposure. Medical Surveillance should be conducted by an Occupational Medicine Practitioner (OMP) who taking into account the nature of the work and the risks associated with it, should draft a structured surveillance programme. The initial medical examination should include any other biological tests necessary to determine the most appropriate work circumstances for the individual. For example the ability to wear a respirator and conditions that might aggravate a pre-existing medical disorders. The OMP may also request that certain medical investigations and tests, over and above those prescribed in the regulations, be carried out if he or she considers it to be in the interest of the health or safety of a person. Biological monitoring The only acceptable way of determining lead exposure via absorption through the digestive tract or the skin is by means of biological monitoring4. Absorption of lead through the skin only applies in the case of tetra- ethyl and tetra-methyl lead (both are known as lead alkyls), while ingestion through the digestive tract can be affected by airborne lead and non-airborne lead (or larger lead particles). The following tests are used to determine the level of exposure of a person to lead: Blood lead analysis Blood lead concentration is the best available indicator of lead exposures. Normally the blood lead level should be checked every three months, especially if the employee is a woman capable of having children (procreation). Urine lead analysis Alkyl lead compounds used as additives in motor fuels may be absorbed by inhalation, ingestion or skin contact. Absorbed organic lead is rapidly excreted in the urine, partially metabolised to inorganic lead. Blood lead levels are considered not to be adequate indicator of exposure to alkyl lead. Zinc Protoporphyrin (ZPP) ZPP is a biological response test useful in assessing lead related biological effects. Lead exposure results in an increase in ZPP in the red blood cells and although there is no correlation between ZPP and blood lead at low exposures, it gives an estimate of exposure over the previous three months. It is recommended for screening purpose and is used as a biochemical indicator of lead exposure. 4 Biological monitoring- for the purpose of these regulations relates to a planned programme of periodic collection and analysis of blood or urine in order to detect and quantify the exposure to or absorption of any form of lead by persons. 8 Employer should ensure that they act on the decision of the OMP and not allow employees with blood level exceeding 60μg/100ml or 150μg/l in case of urinary lead, to work in an environment where they will be exposed to lead. Separate approach is adopted for women who are of childbearing age (Capable of procreation) when measuring lead concentration because lead can be passed on to the unborn child. Occupational exposure to lead has been associated with decreased fertility, spontaneous abortion, stillbirths, and increased infant mortality. Lead readily passes the placenta and accumulates in the fetus and there is strong evidence that a mother’s lead burden can cause serious effects on cognitive development of her child. Women should therefore be removed from the workplace where they are exposed to lead as soon as it is confirmed that they are pregnant or when their blood lead exceeds 40μg/100ml or 75 μg/l in case of urinary lead. Regulation 9: Respirator zone A respirator zone is an area where the concentration of lead in the air is, or is likely to be greater than the OEL for asbestos. No persons should be allowed to enter the area without wearing respiratory protective equipment and protective clothing. Respirator zones must be clearly demarcated and identified to prevent accidental and chance, albeit brief, entry. Even if a person only passes through the area or there is little work being conducted in that area, a respirator must be worn. Floor markings or chevron tape are examples of demarcation where the area is not defined by walls. In addition, all access routes should be demarcated and identified by SABS symbolic warning signs that are clearly visible. Respirator zones should only be regarded as a temporary control measure. The employer should therefore investigate the use of control measures other than respiratory protective equipment and protective clothing to reduce the concentrations of lead to below the OEL. As a precaution lead-painting operations (e.g. Stripping) should be regarded as respirator zone. Regulation 10: Records The benefit of keeping records as specified in the regulation are as follows: Protects both employer and employees Research What must be recorded? Thorough, complete and up to date records must be kept of the following: Medical surveillance for a minimum period of 40 years; 9 Maintenance of control measures for a period of 3 years; Training given to employee in terms of Lead Regulations for as long as the employee remains employed at the workplace in which he or she is being exposed to lead; and Assessments and air monitoring for a period of 40 years. What information must the records contain? Records must contain at least the following basic information: Name, gender, date of birth, name of spouse or closest relative and address of the employee; Type of work carried out; Period of employment of exposure; Average duration of exposure in hour per week; Date and results of assessment, air monitoring or biological monitoring; Name of equipment repaired and date; Signature of approved inspection authority and occupational medical practitioner; and Corrective steps to be taken Where must the records be kept? Records must be kept on the premises where work with lead is done. However, this excludes outdoor work such as construction work. In such a case, the records may be kept in an office designated by the employer. Who may see the records? The following specified records should be made available to the inspector from the Department of Labour, employee’s personal occupational health practitioner or health and safety representatives and committees: Inspectors from the Department of Labour- all record an employer is required to keep, excluding personal medical records. The personal medical records (excluding personal biological monitoring records) may only be made available to the inspector with the written consent of the employee concerned; The employee personal occupational health practitioner- the personal medical records, when called for in writing by the employee concern; and Health and safety representatives and committees- records of assessments and air monitoring. 10 Regulation 11: Control of exposure to lead The aim of this regulation is to prevent the exposure of employees to airborne lead. Prevention of exposure can be achieved by applying the following measures: (1) Minimum quantity of a substance Only minimum quantity of a substance that can release airborne lead into the atmosphere must be kept on the premises. A reasonable quantity would be the average quantity used per day. The balance of stock must be kept in tightly sealed containers or in a store for hazardous chemical substances. (2) Minimum number of exposed persons The number of exposed persons must be restricted by─ (3) the demarcation of the workplace; the restriction of unauthorised entry; and the restriction of those substances that can release airborne lead to certain areas. Good engineering control measures The following engineering control measures may be implemented: Isolation of processes. Where possible, dangerous processes must be isolated from the rest of the workplace to prevent the pollution of non-lead areas, for example, by encapsulation of high toxicity processes. Ventilation Where there are several lead pollution sources throughout the workplace, local extraction ventilation-hoods must be positioned as close as possible to the different sources. Emissions through chimneys must meet the provisions of the Air Pollution Prevention Act, 1965. (4) Good working practices Good working practices refers to the procedure to be followed in the execution of a specific task in such a way that the exposure of employees to lead is limited. Good housekeeping and the application of work procedures are examples of good working practices. The following are examples of good housekeeping─ 11 (5) providing clean areas for eating and storing of food regular cleaning of workplaces and equipment limit the number of workers exposed to lead develop and enforce work procedures aimed at improving health and safety Substitutes This is referring to using substances that do not contain lead e.g. petrol-leaded and unleaded. The employer must also ensure that when the exposure is controlled in one part of the workplace, it does not contaminate the other workplaces in the premises or to other premises. Regulation 12: Personal protective equipment and facilities Employers must provide effective personal protective equipment and facilities free of charge. The equipment must also be properly selected, maintained, cleaned, undamaged and properly used. Some manufacturers of respirators give specific instructions in this regard. Personal Protective Clothing All employees who are exposed to lead must be provided with protective clothing. The protective clothing issued to employees who are exposed to tetra-alkyl lead, which is absorbed through the skin, must be made of impermeable material, to prevent skin contact and thus absorption. Respiratory Protective Equipment5 All employees in respirator zones, and any other employees who by the nature of their work may be exposed to greater than the OEL for lead, must be provided with respirators. Only respirators that have been approved/homologated by the South African Bureau of Standard (SABS) may be used. When selecting a respirator, the following must be kept in mind: The concentration of airborne lead; The duration of exposure; The exposure limit for the lead; The safety factor of the respirator; and 5 Respiratory protective equipment: a device which is worn over at least the mouth and nose to prevent the inhalation of air which is not safe and which furthermore conforms to a standard approved by the South African Bureau of Standard 12 The protection factor of the respirator as shown in the SABS Code of Practice 1455: Parts I, II and III. Respirators can spread contagious diseases. It is advisable to provide respirators for personal use by specific employees. But, if respirators are used in turn by more than one employee, they must be cleaned and disinfected according to the manufacturer's instructions after every use. No employee should be allowed to remove personal protective clothing and respirators from workplace. This is to prevent lead being spread to private households. Personal protective clothing and respiratory protective equipment may only be removed from the premises for repair or washing under controlled conditions. The employer or self-employed person has a responsibility to ensure that when contaminated personal protective equipment is sent off the premises to a contractor for cleaning, that: Equipment is packed in impermeable containers; The container is tightly sealed; The container is clearly marked to indicate that it contains lead; and The contractor is fully informed of the following: a) The requirements of these regulations; and b) Precautions to be taken for handling the lead contaminated equipment. This requirement also put the responsibility on the employer to train the contractor on the danger of exposure to lead. When the contaminated equipment is removed from the workplace it must not pose a danger to employees or the public. Cleaning And Storage Of Personal Protective Equipment All cleaned personal protective equipment must be stored in a place or container where it will be safe from lead contamination and damage. Separate storage facilities must be provided for used personal protective equipment and personal property of employees. Typically, such equipment consists of lockers or any similar type of repository. The wash and change room facilities must consist of at least the following: A clean change room This is a room where employees take off their own clothes and put on clean protective clothing and equipment. In this room, facilities must also be provided for the protection of clean protective equipment as well as private clothes. Showers and washing facilities No employee may enter a clean change room from a lead area or respirator zone without showering. The showers should preferably have cold and hot water mixed, in other words, coming 13 out of the same tap, and be activated immediately when a person passes under it. Soap should also be provided for each employee. A dirty change room All lead-contaminated protective clothing and equipment must be removed and left in this room. Facilities for the protection and removal of protective equipment and clothing must also be provided. * to or from respirator zone Regulation 13: Cleanliness of premises and plant Because dust settles on equipment, machinery, floors, windowsills, etc, these parts of the workplace must be kept in a clean condition. Accidental spillage can lead to an increased concentration of airborne lead. In such a case, corrective steps must be taken immediately so that employees may proceed with their work. Cleaning must be done in such a manner that lead dust cannot escape or be released into the atmosphere. Vacuum cleaning equipment should preferably be used. The equipment should have a filtering efficiency of at least 99% for dust particles of 1 um in size. Alternatively, a process should be used whereby dust is sprinkled with water before it is swept and picked up. In such a case, the employees concerned must be provided with suitable protective clothing as required in regulation 12. Under no circumstances may compressed air be used to blow surfaces clean, because this method of cleaning can increase the concentration airborne lead. 14 Regulation 14: Maintenance of control measures It is essential to maintain all control equipment and facilities. Engineering controls should be tested and examined at intervals not exceeding 24 months by approved inspection authority approved for such examination and test. It should be noted that the approved inspection authority referred to in this regulation is not the approved lead inspection authority. Regulation 15: Prohibitions This regulation prohibits the following: The use of compressed air to clean objects. This method of cleaning creates a danger because lead dust is airborne and it has the potential to settle elsewhere. Instead, use vacuum-cleaning equipment, or sprinkle the dust with water before sweeping or removing it. Smoking, eating and drinking, and the keeping or foodstuffs or beverages in zoned areas. Because lead can enter the body through the digestive tract, this prohibition, as well as any other matters regarding personal hygiene in zoned areas must be given priority. Certain processes associated with lead paint. Many cases of lead poisoning have been reported which were caused by using lead paint on toys, furniture and the interior walls of buildings, particularly domestic homes. Lead paints should not be removed by burning. Processes whereby lead paint is removed by scraping or sandpapering must be avoided. Rather use a suitable paint remover. Flame cutting of steel, which has been coated with lead paint, must be avoided. Also, any process whereby lead paint is heated above 480 °C must be avoided, because lead fumes can be released at this temperature. Regulation 16: Packaging, transport and storage Lead can be spread by air, water and human beings. For this reason, all lead that has the potential to contaminate, must be─ controlled; kept in containers or a similar suitable manner of containment that makes it difficult to be spread to other areas of the workplace or to other premises; by wind or by water; and contained during transport and clearly marked to be able to identify that it contains lead. The manner of containment or the kinds of containers to be used will depend on the kind of material being packaged, transported or stored. 15 Regulation 17: Disposal of lead waste Lead waste has a potential to pollute the environment and pose a health risk to human beings. Therefore, industry must strive to attain maximum reclamation and recycling of lead waste. However, lead waste must not be used in products that normally do not contain lead. If lead waste is not used for reclamation or recycling the employer must have it dumped safely by ensuring that─ lead dust is not released during transportation to the dumping ground. Instead, use tightly sealing containers; lead sludge is put in tightly sealing containers or dried out as it can easily be spilled during transport; lead waste is dumped on dumping sites specifically approved for lead waste in terms of the Environmental Conservation Act, 1989(Act No. 73 of 1989) and the National Environmental Management Act, 1998 (Act No. 107 of 1998); all employees who are involved in the transportation and dumping of lead waste are provided with the required respirators and protective clothing and they are properly trained in the procedure to be followed in the event of spillage or similar emergency or situation that could arise by accident; all equipment is thoroughly cleaned after dumping. This includes vehicles and protective clothing; all incidental spillage of lead waste be cleaned up immediately. The driver of the vehicle carrying lead waste must have the necessary training and be conversant with the instructions to handle such cases; and Contractors, and owners of dumping grounds where lead waste is disposed, must also comply with the provisions of this regulation. 16 TABLE 2: KINDS OF LEAD WORK WHERE EXPOSURE IS LIKELY KINDS OF LEAD WORK WHERE EXAMPLES OF INDUSTRIES AND SIGNIFICANT EXPOSURE IS LIKELY PROCESSES WHERE SUCH WORK IS (except where acceptable control measures PERFORMED are applied) Lead dust and fumes Working with lead at a high temperature Lead smelting and refining: casting of certain non(above 500 °C), for example, lead smelting, iron containing metals, for example, metal, steel refining, casting and recovery processes. (lead containing), scrap metal. Wire-fencing processes: lead burning, welding and cutting of lead coated and painted installations and surfaces in repair and demolition work. Shipbuilding. Chemical industry Working with lead compounds, which set lead dust free in the atmosphere, for example, any work process which requires the use of a wide range of lead compounds, except lead compounds which are not easily soluble. Manufacturing of lead paints, batteries, pigments, compounds, rubber products, and mixing and smelting processes in the glass industry. Breaking up of certain batteries. Manufacturing of certain detonators in the explosives industry. Buffing of lead resulting in lead dust being Various industries, for example, manufacturing of set free in the atmosphere, for example, motor vehicle bodies and repairs to vehicle bodies 'Grinding and cutting with machine tools. containing lead. Firing of small arms in undercover ranges Spraypainting compounds. of lead paint and lead Painting of buildings, bridges, etc 17 Lead alkyls Production of concentrated lead alkyls. Manufacturing of lead alkyls. Inspection, cleaning and maintenance work in Oil refineries, oil transport terminals and certain tanks containing leaded fuel, for example, occupations where tankers are inspected and rail, road and sea tankers repaired TABLE 3 KINDS OF LEAD WORK WHERE SIGNIFICANT EXPOSURE IS UNLIKELY (except where acceptable control measures are applied) KINDS OF LEAD WORK WHERE EXAMPLES OF INDUSTRIES AND SIGNIFICANT EXPOSURE IS LIKELY PROCESSES WHERE SUCH WORK IS (except where acceptable control measures PERFORMED are applied) Lead dust and fumes Work with galantine (lead sulphide). Mining of and working with galantine when its character and composition does not change. Smelting of lead at a low temperature (lower Plumbing, soldering, linotype and monotype casting than 500 °C). Such low temperatures control processes in the printing industry. the vapour. but any particles of leaded slag must be carefully controlled. Working with inorganic lead compounds Painting with low soluble lead paint which are not easily soluble. Workings with lead emulsions or in glue form Painting Work with oil-based lead paints and the having such moisture content that lead dust use of stabilisers in plastics. and fumes cannot be released during work. Handling of clean, solid lead metals, for Various metal industries and distributors. Plumbers example, pipes, ingots, plates, etc. working with lead plate. Lead emission from petrol-driven vehicles Testing of petrol-driven engines, for example, (products of ignition such as carbon vehicles in garages for repair. monoxide is the main risk). Lead alkyls Any exposure to lead alkyl fumes of lead containing fuel, the lead content of which is restricted under the motor vehicle fuel regulations (lead content of petrol). Working with lead containing fuel, including, for example, filling petrol-driven vehicles at service stations (except for work in a tank containing leadcontaining fuel). 18