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Lead: Identification, Testing and Protection, 29 CFR 1910.1025

Quick Tips #341
Background

Although the hazards of lead have been known since ancient times, only recently have the hazards been taken seriously. It was not until modern times that preventative measures of limiting exposure were researched and tested. Modern tests, such as urinary and blood level measurements, have led to establishing acceptable air levels, as well as control methods for occupational exposure to lead. A common industry goal of 150μg/m3 (micrograms per cubic meter of air) averaged over an 8-hour time period was accepted in 1933 by the U.S. Public Health Service and remained consistent throughout the 1940s into the 1950s.

150μg/m3 remained the same until 1957 when the American Conference of Governmental Industrial Hygienists (ACGIH) raised the level to 200μg/m3 based on national consensus standards found in the American National Standards Institute (ANSI) Z37.11-1969 (adopted by OSHA and found in table Z-2 of 29 CFR 1910.1000). In 1971, the ACGIH lowered lead exposure levels back to150μg/m3; this due to national consensus standards not based on any type of clear rationale and the ACGIH could not find enough evidence to support the fact that the exposure level was raised in the first place.

The final rule on occupational exposure to lead for the general industry was issued in November 1978. This can be found in Title 29 CFR 1910.1025, which took effect on February 1, 1979. The new standard made the Z-2 table of 29 CFR 1910.1000 invalid and also changed the permissible exposure limit (PEL) for lead from 150μg/m3 to 50 μg/m3 averaged over an 8-hour workday. This standard, however, did not cover the construction industry (29 CFR 1926.62) and this was not until over a decade later that the construction industry would establish its own standards for protection from lead exposures. For more information on the construction standard.

Lead Identification

Lead exposure occurs in a variety of industries including primary and secondary lead smelting, automotive manufacturing, shipbuilding and repair and solder manufacturing. Although the OSHA PEL is 50μg/m3, CFR 1910.1025 also implements an action level for lead of 30μg/m3 where the employer is required to fulfill certain requirements of the standard such as exposure monitoring, medical surveillance and training and education but not others. For example, if initial monitoring reveals lead levels above the action level but below the PEL, the employer is required to repeat monitoring every six months; if lead is detected above the PEL, the employer would be required to repeat monitoring quarterly (every three months). 1910.1025(d)(6).

How Lead is Absorbed into the Body

When lead is absorbed into the body in certain doses (above the action level or PEL) it can be toxic. Although there are some immediate effects that occur from prolonged exposure to lead in those doses, some of the most serious toxic effects may not become apparent until several years after initial exposure.

There is a common misconception that lead can be absorbed through skin; lead itself is not normally absorbed through the skin (except for certain organic compounds not covered by this standard such as tetraethyl lead). Lead is absorbed into the body through inhalation (breathing) and ingestion (eating). When lead is present in the air as a dust, fume or mist, it can be inhaled through your lungs and upper respiratory tract. The most common source of lead absorption in industry is inhalation. Generally, lead that is absorbed through ingestion stems from using or handling a product that may contain lead such as make-up, cigarettes, chewing tobacco or food.

Effects of Lead Absorbed into the Bloodstream

Once lead is absorbed into the bloodstream, it circulates throughout the body and is stored in various organs and body tissue. While some of the lead will excrete, some will stay in the organs and body tissue. As the exposure to lead continues, the amount stored in the body increases, while the amount you excreted decreases. Lead stored in the tissues slowly causes irreversible damage to the individual cells then to the organs and eventually all body systems.

In large enough doses, lead can cause immediate health problems and possibly even death. A condition affecting the brain called acute encephalopathy can be deadly in a matter of days if a person inhales or ingests a large enough dose of lead; this condition progresses from seizures to coma to death by cardio respiratory arrest. The chance that a dose large enough to cause immediate problems occurring in industry is unlikely but not impossible; it is more likely however that a person who is exposed to lead in small doses over a long period of time could develop problems such as acute encephalopathy in the long-term. Chronic overexposure to lead could also damage blood-forming, nervous, urinary and reproductive systems. Kidney disease and failure are also common.

Common symptoms of overexposure include loss of appetite, metallic taste in the mouth, skin discoloration (pallor), anxiety, nausea, a feeling of dullness progressing to drowsiness and stupor, anxiety and muscle and joint pain.

If certain levels of lead are reached in the bloodstream, an employee may have to be removed from the work area until the blood level returns to normal. The following table shows the levels in which person(s) would have to be removed from the work environment and again at levels where they can return to the work environment.

Please refer to 1910.1025 Appendix C, Table 2 for more information on blood level requirements for lead.

Lead Testing

If any lead is present in the workplace in any quantity, OSHA requires the employer to make an initial determination of whether the action level of lead is exceeded for any employee. This initial determination must include instrument monitoring of the air for the presence of lead and must cover the exposure of a representative number of employees who are reasonably believed to be exposed the highest lead 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. If the initial testing shows lead levels above the action level (30μg/m3) then an air monitoring program must be set up by the employer to determine the exposure level for every employee in the workplace.

OSHA does not require that each individual employee be tested; rather it requires the employer to test a representative number of employees and job types. The air samples taken must be representative of the each employees regular, daily exposure to lead. Enough sampling must be done to make sure that each employees exposure level is reasonably represented by at least one full-shift (at least 7 hours) sample.

If the results of the monitoring indicate a presence of lead greater than the PEL (without regard to the use of respirators) the employer is required to notify the employee in writing and provide a description of the action which will be taken to protect the employee from lead hazards.

Lead levels must be rechecked every six months if the exposure level exceeds the action level and every three months if it is exceeds the PEL. Monitoring can stop if the employer has monitored for lead twice, testing at least two weeks apart, with results lower than the action level.

Lead testing can be done in the following ways:

  1. Determination of air concentrations. (Follow NIOSH testing method 7082 or an equivalent.) Two pieces of equipment are needed for this, a personal air sampling pump and a membrane filter. These can be attached to an employee for personal monitoring or used for area monitoring. NOTE: Employers shall assure that no employee is exposed to lead at concentrations greater than 50μg/m3 (fifty micrograms per cubic meter) of air averaged over an eight-hour period.
  2. Determination of water concentration. Obtain a water test kit or submit a sample to an analytical laboratory of your choice.
  3. Determination of soil concentration. Obtain a soil test kit or submit a sample to an analytical laboratory of your choice.
  4. Determination of blood leads level. Determined by blood sample taken by physician.
    NOTE: The exposure level for lead in blood is 50μg/dl (micrograms per deciliter).
  5. Determination of surface lead level. Can be determined by convenient test kits.
    NOTE: Once the lead level is determined, it should be compared with the recommended level.
Lead Protection

The employer is required to provide respiratory protection and protective clothing for those that are exposed to lead levels above the PEL (50μg/m3)_. If an employee requests respiratory protection at any time, the employer must also provide that to the employee even if the air exposure level that the employee endures is less than the PEL. Common reasons for an employee requesting respiratory protection would be if they received medical advice that required them to lower their lead exposure levels or if they would like to have children in the near future.

For more information on respiratory protection please refer to 29 CFR 1910.1025(f) and for personal protection clothing refer to 1910.1025(g).

Safe Lead Work Practices

When working with lead, these practices apply (29 CFR 1910.1025):

  1. Provide exhaust ventilation.
  2. Use only HEPA (High-Efficiency Particulate Absolute) vacuums for cleanup.
  3. Use a NIOSH/MSHA-approved respirator. (The type will be determined by the exposure level.)
  4. Do NOT eat, drink or smoke in lead-contaminated areas.
  5. Use proper protective clothing, shoe covers and gloves.
  6. Wash hands thoroughly before eating.
  7. Shower and change into clean clothes before leaving worksite.
Lead Prevention Training

OSHA guidelines require comprehensive training for everyone who may be potentially exposed to lead. (29 CFR Part 1910.1025(l)).

Lead Signs

Signs must be posted to warn employees of the danger of lead in the area. The signs should state the following: "Warning," "Lead Work Area," "Poison" and "No Smoking or Eating." These signs shall be illuminated and cleaned as necessary to ensure legibility (29 CFR Part 1910.1025(m)).

OSHA has updated the language for workplace signage and labels to incorporate the Globally Harmonized System in substance-specific health standards. The update will take full effect on June 1, 2016. Prior to that date, current language can be used. With the GHS revision, this standard retains the requirements for specific warning language for specific signs; however, OSHA has modified the language to be compatible with GHS and consistent throughout all OSHA standards. The language for signs and labels 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

For more information about GHS, please refer to Quick Tips document #374, Globally Harmonized System.

Containers of contaminated personal protective clothing and equipment should also be labeled as follows: 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. (29 CFR Part 1910.1025(g)(2)(vii)).

Commonly Asked Questions
Q.   Is lead poisoning reversible?
A.   Medical treatment may reduce the amount of lead in the bloodstream; however the damage which as already occurred to the person is irreversible. This is why prevention is so important.
 
Q.   Can lead poisoning be prevented?
A.   Lead poisoning can be prevented in a variety of ways. One way is to remove lead hazards in the child's environment immediately. The second is to educate public and health professionals as the hazards of lead poisoning and how to prevent it. The third is to get tested and seek treatment if necessary should you or your child be at risk for lead poisoning.
 
Q.   What do I do if my child has put lead toys in their mouth or I feel they may have been exposed to lead toys?
A.   See your health care provider. He or she can perform a blood test to see whether your child has been exposed to lead and if so recommend treatment. A blood test is the only way to know for sure if your child has an elevated lead level. Most children with elevated blood lead levels do not have any symptoms. However, there is no safe level of lead in blood. As blood lead levels increase, lead has a larger effect on a child's learning and behavior.
 
Q.   How do I get more information about recent recalls?
A.   The U.S. Consumer Product Safety Commission (CPSC) asks parents to keep up to date on toy recalls and to take toys away immediately if they have been recalled. Photos and descriptions of recalled toys can be found at http://www.cpsc.gov or call 1-800-638-2772.
 
Q.   What are the symptoms of lead poisoning?
A.   Symptoms of lead poisoning are not always easily recognized. Some symptoms that may occur in adults include: high blood pressure, digestive and nerve disorders, memory and concentration problems and joint and muscle pain. In children, symptoms are more severe: damage to the brain and nervous system, behavior and learning disabilities, developmental delays and slow growth.

 

Sources

For more information please visit:

Lead-Safe Work Practices

29 CFR Part 1910.1025, Lead Toxic and Hazardous Substances.

National Institute for Occupational Safety and Health (NIOSH)
4676 Columbia Pkwy.
Cincinnati, OH 45226
800-356-4674

EPA: Lead in Paint, Dust and Soil

(Rev. 8/2014)

 


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 content in this newsletter is intended for general information purposes only. This publication is not a substitute for review of the applicable government regulations and standards, and should not be construed as legal advice or opinion. Readers with specific compliance questions should refer to the cited regulation or consult with an attorney.


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