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United States Department of Agriculture Forest Service Technology & Development Program | |
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| March 1997 | 9771-2307-MTDC |
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 7100 |
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United States Department of Agriculture Forest Service Technology & Development Program | |
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| March 1997 | 9771-2307-MTDC |
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7100 |
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This is the fifth in a series of Tech Tips dealing with lead-based paint. This Tech Tip describes the Occupational Safety and Health Administration's (OSHA) Lead Exposure in Construction rule (29 CFR 1926.62).
OSHA regulations covering occupational lead exposure have been in effect since the early 1970's for both construction and general industries. In the construction industry, workers most often overexposed to lead work in the trades such as welding, plumbing, and painting. Responding to a 1992 Congressional mandate, OSHA made significant changes in the Lead Exposure in Construction standard that affect the way the Forest Service and our contractors should approach work on facilities with materials that contain lead.
The construction rule covers all occupational exposure to lead occurring in the course of construction work. Construction work is defined as construction, alteration or repair, (including painting and decorating). The standard does not apply to routine cleaning and repainting when there is little damage, corrosion, or wear of the existing material. Examples of construction work include:
The standard does not set a minimum amount of lead to define a lead-containing material and the potential for occupational exposure. The Environmental Protection Agency (EPA) and Department of Housing and Urban Development (HUD) definition of lead-based paint (paint containing at least 1 milligram of lead per square centimeter or 0.5% lead by weight) does not apply to the OSHA standard. The employer must test all potential sources of lead using a valid detection method for the presence of lead. If detectable levels of lead are found, the standard applies. The OSHA Technical Center recommends using a lab analysis to determine the lead concentration. Chemical spot test kits, often available in hardware stores, should not be used because they are not reliable enough to test lead concentration.
Employers subject to this standard are responsible for having a worker protection program. Maximum limits of exposure to lead are set by the permissible exposure limit (PEL) and the action level. The permissible exposure limit limits worker exposures to 50 micrograms of lead per cubic meter of air, averaged over an 8-hour workday. The action level of 30 micrograms of lead per cubic meter of air triggers certain compliance activities such as personal air monitoring and medical surveillance.
At a minimum, a worker protection program for employees exposed to lead should include:
The worker protection program should be written and overseen by a competent person--one who has specific training in lead hazards and who has the authority to take corrective measures when necessary.
Hazard determination--The employer must determine if any employees may be exposed at or above the action level by considering:
If air monitoring data are not available from similar jobs, air samples representative of the highest exposure in a work area must be collected. The Forest Service must provide protective control measures while the employees or contractors make initial exposure assessments. Employees should be in protective clothing with respiratory protection until the actual employee exposures have been determined to be below the action levels.
In some situations, previous air monitoring from similar jobs can be substituted for the initial exposure monitoring. This historic work data must be from jobs with conditions similar to the current project.
Engineering and work practice controls--The most effective way to protect workers is to minimize their exposure through the use of engineering controls and good work practices. Some examples of engineering controls that can be used to reduce worker exposure to lead are:
Protective clothing and equipment--The employer must provide (at no cost to the employee) protective work clothing such as coveralls, gloves, hats, shoe covers, and face shields. Protective gear should be removed at the end of the work day in special change areas and contained to prevent lead from dispersing.
Respiratory protection--Respirators should be used only in addition to engineering and work practices to reduce employee exposures to below the permissible exposure limit. At a minimum, the respirator must be a half-mask, air-purifying respirator with HEPA filters. All elements of a respiratory protection program, such as medical approval, fit testing and training, must be in effect.
Housekeeping--Surfaces must be kept free of lead and lead dust. HEPA-filtered vacuums should be used to keep surfaces and areas clean.
Hygiene facilities and practices--The employer must provide adequate hand washing facilities, showers (where feasible), and changing rooms so workers do not contaminate themselves and their environment outside of work.
Medical surveillance--When employees are exposed to lead at or above the action level for more than 1 day per year the employer must make blood lead testing available. For employees with exposure more than 30 days per year, the blood testing must be periodic and medical exams must be provided.
Training--Employers must provide training so workers understand lead hazards and the requirements of this standard. OSHA requires training even if the exposure does not exceed the action level, but more thorough training if the level is exceeded.
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| Example of a warning sign. |
Recordkeeping--Employers must keep records for at least 30 years of all exposure monitoring, medical surveillance, training, and other data used to determine whether the standard applies.
The first step in responding to this standard is determining whether a demolition, remodeling, or repainting project will affect materials that contain lead. The Forest Service is responsible for having a paint sample analyzed to determine the lead content. This information must be factored into the approach to the project, whether the work is done by Forest Service employees or by a contractor.
If the work is done inhouse, a trained Forest Service employee, a consulting industrial hygienist, or an environmental technician will need to provide supervision. Training must be provided to all workers on the project. Exposure monitoring (and perhaps medical monitoring) will have to be arranged. A written worker protection plan, detailing the background information and exposure controls, should be developed and implemented. Examples of worker protection plans are available from OSHA or from Andy Trent at MTDC.
Full details on the Lead Exposure in Construction standard are available from the OSHA national office in Washington, DC, phone (202) 219-8036. OSHA also has a Technical Center in Salt Lake City, UT, phone (801) 487-0073. Several fact sheets on the Lead Exposure in Construction standard, the standard itself, and other supporting documents are available electronically on the Internet at http://www.osha-slc.gov.
About the Authors...
Andy Trent is a mechanical engineer at MTDC.
Bev Young is an environmental engineer at the Forest Service's Northern Regional Office in Missoula.
Next in the Lead-Based Paint Series...
Lead-Based Paint: Wastes will cover the requirements for handling and disposing of potentially hazardous lead-based paint wastes.
Hard copies of this document may be ordered from:
USDA Forest Service
Missoula Technology & Development Center
Building 1, Fort Missoula
Missoula, MT 59804-7294
Phone: (406) 329-3900
Fax: (406) 329-3719
For further technical information, contact Andy Trent at the address above.
Phone: (406) 329-3912
Fax: (406) 329-3719
DG: A.Trent:R01A
E-mail: /s=a.trent/ou1=r01a@mhs-fswa.attmail.com
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since October 1, 1999