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Construction Lead: Identification, Remediation and Personal Protection, 29 CFR 1926

Quick Tips #165

Introduction

In October 1992, President Bush signed Section 1031 of Title X of the Housing and Community Development Act. This act required the Occupational Safety and Health Administration (OSHA) to develop an interim standard for lead in the construction industry and provide guidelines for protecting construction workers from occupational exposure to lead. Later, in May of 1993, OSHA unveiled the final interim rule for lead in the construction industry, 29 Code of Federal Regulations (CFR) 1926.62.

Where Is Lead Found

Within the construction industry, OSHA estimates nearly 840,000 workers are potentially exposed to lead each year. The construction lead standard applies to all construction work where employees may be exposed to lead. Examples of activities covered by this Standard include:

  • Disturbing paint on structures built before 1978
  • Doing demolition and salvage work
  • Removing or encapsulating materials containing lead
  • Installing products containing lead
  • Renovating structures that contain lead
  • Emergency cleanup of lead-contaminated materials
  • Transporting, storing or disposing of lead-containing materials where construction activities are performed
  • Doing Maintenance operations associated with these activities

 

The following tasks can expose employees to extreme amounts of lead and are considered trigger tasks – cutting with a torch, heat gun work, manual sanding, manual scraping of dry materials, sanding with or without a dust collection system, spray painting, manual demolition of structures (dry wall, windows and siding), abrasive blasting and welding.

Lead Testing

The lead standard for construction recognizes the same permissible exposure limit (PEL) of 50 micrograms per cubic meter (μg/m3) and action level of 30 μg/m3 as the lead standard for general industry, 29 CFR 1910.1025.

If lead is present at a worksite in any quantity, OSHA requires the employer to make an initial determination of whether the action level of lead is exceeded for any employee by conducting air monitoring. This initial determination must include at least one sample for each job classification in each work area either for each shift or for the shift with the highest exposure levels. If any employee has reported symptoms of lead overexposure, or if there are any observations or indications that conditions suggest lead overexposure, the employer must include this information in the initial determination. The air samples taken must be representative of each employee’s regular, daily exposure to lead.

If the initial determination reveals employee exposure to be below the action level no further action is needed. If the initial determination reveals the exposure to be at or above the action level but at or below the permissible exposure limit (PEL) employers must perform monitoring at least every six months. This monitoring must continue until at least two consecutive measurements, taken at least seven days apart, are below the action level.

If the initial determination reveals that employee exposure is above the PEL the employer must perform monitoring quarterly until at least two consecutive measurements, taken at least seven days apart, are at or below the PEL. If this sampling shows levels at or above the action level the employer must repeat monitoring for that employee at the frequency specified above. The employer must continue monitoring at the required frequency until at least two consecutive measurements, taken at least seven days apart, are below the action level.

Whenever there has been a change of equipment, process, control, personnel or a new task has been initiated that may result in additional employees being exposed to lead at or above the action level or may result in employees already exposed at or above the action level to being exposed above the PEL, the employer must conduct additional monitoring as specified above.

Within five working days after the receipt of the results of any monitoring performed, the employer must notify each affected employee of the results either individually in writing or by posting the results in an appropriate location. If the exposure was at or above the PEL the employer must include in the written notice a statement that the employees exposure was at or above that level and a description of the corrective action taken or to be taken to reduce exposure to below that level.

Safe Work Practices

Employers must have a written program that describes how they will keep their employees’ potential lead exposures at or below the PEL. Safe work practices for personal protective equipment, housekeeping and hygiene facilities must be included in the written program and some suggestions are outlined below:

  • Use only high-efficiency particulate absolute (HEPA) vacuums for clean-up
  • Do not use compressed air to remove lead from surfaces unless there is a ventilation system that captures the airborne dust at the source
  • Provide employees with appropriate respirators when they are doing trigger work, their exposure is greater than the PEL or if they request a respirator
  • Have a respirator program that meets the requirements of 29 CFR 1910.134 in place
  • Do not eat, drink or smoke in lead-contaminated areas
  • Use proper personal protection including protective clothing, shoe covers and gloves
  • Wash hands thoroughly before eating
  • Shower and change into clean clothes before leaving worksite

Respiratory Protection

Airborne Concentration of Lead or Condition of Use Required Respirator
Up to 0.5 mg/m³ (10 X PEL) Any air-purifying respirator with a N100, R100 or P100 filter (including filtering facepieces) except quarter-mask respirators.
Up to 1.25 mg/m³ (25 X PEL) Any supplied-air respirator operated in a continuous-flow mode. Any powered air-purifying respirator with a high-efficiency particulate filter.
Up to 2.5 mg/m³ (50 X PEL) Any air-purifying, full-facepiece respirator with a N100, R100 or P100 filter. Any supplied-air respirator that has a tight-fitting facepiece and is operated in a continuous-flow mode. Any powered, air-purifying respirator with a tight-fitting facepiece and a high-efficiency particulate filter. Any self-contained breathing apparatus with a full facepiece. Any supplied-air respirator with a full facepiece.
Up to 50 mg/m³ (1000 X PEL) Any supplied-air respirator operated in a pressure-demand or other positive-pressure mode.
Up to 100 mg/m³ (2000 X PEL) Any supplied-air respirator that has a full facepiece and is operated in a pressure-demand or other positive-pressure mode
Emergency or planned entry into unknown concentrations or immediately dangerous to life or health (IDLH) conditions Any self-contained breathing apparatus (SCBA) that has a full facepiece and is operated in a pressure-demand or positive pressure mode or Any supplied-air respirator that has a full facepiece and is operated in a pressure-demand or other positive-pressure mode in combination with an auxiliary self-contained positive-pressure breathing apparatus

Source: Centers for Disease Control and Prevention – National Institute for Occupational Safety and Health Pocket Guide to Chemical Hazards - Lead

For additional information on OSHA’s requirements for establishing a respiratory protection program, see Quick Tips #195, Starting a Respiratory Protection Program.

Training

OSHA guidelines require comprehensive training for everyone who might potentially be exposed to lead. All employees must be informed about the lead hazards, following the requirements of 1926.59, Hazard Communication. For employees who are exposed to lead at or above the action level, employers must provide at least annual training that covers:

  • The content of 1926.62 and its appendices
  • The nature of the work that could result in exposure to lead above the action level
  • The purpose, selection, fitting, use, and limitations of respirators
  • The purpose of the medical surveillance and the medical removal protection programs
  • The engineering controls and work practices associated with employees’ jobs
  • The content of any compliance plan in effect
  • Instructions to employees that they should not use chelating agents except under the direction of a licensed physician
  • Employees’ right to access records under 1910.1020, Access to Employee Exposure and Medical Records

 

Signs and Labels

Signs must be posted in each work area where the PEL is exceeded. These signs must be illuminated and cleaned as necessary to ensure legibility (29 CFR Part 1926.62(m).

OSHA has updated the language for workplace signs to incorporate guidance from the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The update is effective June 1, 2016 for signs. The language for signs required after June 1, 2016 is:

DANGER
LEAD WORK AREA
MAY DAMAGE FERTILITY OR THE UNBORN CHILD
CAUSES DAMAGE TO THE CENTRAL NERVOUS SYSTEM
DO NOT EAT, DRINK OR SMOKE IN THIS AREA

Prior to June 1, 2016, employers may use the following legend in lieu of that specified above:

WARNING
LEAD WORK AREA
POISON
NO SMOKING OR EATING

Per the protective work clothing and equipment cleaning and replacement guidelines (1926.62(g), as of June 1, 2015, employers are required to label bags or containers of contaminated protective clothing and equipment with the following:

DANGER
CLOTHING AND EQUIPMENT CONTAMINATED WITH LEAD. MAY DAMAGE FERTILITY OR THE UNBORN CHILD. CAUSES DAMAGE TO THE CENTRAL NERVOUS SYSTEM. DO NOT EAT, DRINK OR SMOKE WHEN HANDLING. DO NOT REMOVE DUST BY BLOWING OR SHAKING. DISPOSE OF LEAD CONTAMINATED WASH WATER IN ACCORDANCE WITH APPLICABLE LOCAL, STATE OR FEDERAL REGULATIONS.

Prior to June 1, 2015, employers may have elected to include the following information on bags or containers of contaminated protective clothing and equipment in lieu of the labeling requirements outlined above:

CAUTION
CLOTHING CONTAMINATED WITH LEAD. DO NOT REMOVE DUST BY BLOWING OR SHAKING. DISPOSE OF LEAD CONTAMINATED WASH WATER IN ACCORDANCE WITH APPLICABLE LOCAL, STATE OR FEDERAL REGULATIONS.

For additional information on lead safety in occupational environments, see our Quick Tips #341, Lead: Identification, Testing and Protection, 29 CFR 1910.1025.


Commonly Asked Questions

Q.   Is lead poisoning reversible?
A.   Some health effects of lead poisoning are reversible but others are permanent. This is why lead exposure prevention is so important.
 
Q.   What are N100, R100 and P100 respirator filters?
A.   N100, R100 and P100 are particulate respirators (filtering facepiece respirators) or filters with the highest level of filter efficiency 99.97%. N means not resistant to oil; R means resistant to oil; and P means oil proof.
 
Q.   When measuring airborne concentrations of lead in the workplace what degree of accuracy is required?
A.   Employers must use a method of monitoring and analysis which has an accuracy to a confidence level of 95% of not less than plus or minus 20 percent for airborne concentrations of lead equal to or greater than 30 ug/m³.

 

Sources

For more information please visit:

Coalition to Prevent Lead Poisoning:
Lead-Safe Work Practices

29 CFR Part 1926, Lead

National Institute for Occupational Safety and Health (NIOSH)
Workplace Safety and Health Topics - Lead

Centers for Disease Control and Prevention – NIOSH Pocket Guide to Chemical Hazards

EPA: Lead in Paint, Dust and Soil

(Rev. 8/2015)


Find even more information you can use to help make informed decisions about the regulatory issues you face in your workplace every day. View all Quick Tips Technical Resources at www.grainger.com/quicktips.

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Please Note:
The information contained in this publication is intended for general information purposes only and is based on information available as of the initial date of publication. No representation is made that the information or references are complete or remain current. This publication is not a substitute for review of the current applicable government regulations and standards specific to your location and business activity, and should not be construed as legal advice or opinion. Readers with specific questions should refer to the applicable standards or consult with an attorney.


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