29 CFR
1910.1025 Lead in General Industry
1926.62 Lead in Construction
Shaheen
Safiullah
ile, Compliance
Officer
Utah OSHA
– (801)530Compliance
Assistance
Specialist
6901
Health Effects
• Routes of Entry
• Inhalation (breathing)
• Ingestion (swallowing)
Health Effects
• Acute effects
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Abdominal pain
Constipation
Limb pain
Hypertension
Vomiting
Coma
Respiratory arrest
Death
Health Effects (contd)
• Chronic effects
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Fatigue
Weight loss
Insomnia
Shaking of arms
Foot drop, wrist drop
Blue line on gums
Organs and systems affected
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Blood System (heme-synthesis inhibition)
Nervous System
Kidneys and Liver
Reproductive System
* Children and Lead
Medical Expenses
• Higher workers compensation premium
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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/m3 (8-hour time weighted average)
– OR, Allowable employee exposure in g/m3) =
400 divided by the number of hours worked in
the day
• AL (Action Level)
– 30g/m3 (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
Construction: Assumed
Exposures >PEL but < 10X PEL
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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
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 (1926.16)
• 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 1910.134)
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 - 1910.134
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/m3
• Remove PPE in change areas
only
• Put into closed, labeled
containers
• Inform cleaning personnel in
writing
(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
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: Www.osha.gov
– Click on “Technical Links” under
the outreach section
• Utah OSHA: www.uosh.utah.gov
• NIOSH: www.cdc.gov/niosh