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June 06, 2012
DOSH Updates Guidance on Lead in Construction; Know the Compliance Triggers

Lead is one of the most common chemical exposures in industry and a leading cause of workplace illness. It is also a serious public health risk. Children are at high risk for lead poisoning, particularly children under the age of 6, and parents who work with lead may not realize that they can expose their children by carrying lead dust home on their clothes.

Lead-contaminated dust is often encountered when remodeling or renovating older structures, which may have lead-painted surfaces. Employees renovating, repairing, or remodeling buildings and equipment constructed before 1978 can be exposed to lead-based paint.

Cal/OSHA adopted its lead in construction standard, Construction Safety Orders Section 1532.1, in 1993 and has recently updated its Lead in Construction fact sheet. The standard applies to all construction work that may expose an employee to lead.

The Hazards of Lead

Lead is highly toxic and can cause poisoning when inhaled or ingested, even at very low levels of exposure. The health effects of chronic exposures in adults include high blood pressure, muscle and joint pain, impotence and infertility in men, decreased fertility in women, kidney disease, nerve damage, and problems with memory and concentration. In developing children, even low levels of lead exposure can cause permanent brain damage.

Symptoms of lead overexposure include loss of appetite, a metallic taste in the mouth, excessive tiredness, weakness (especially in the wrists and ankles, causing "wrist drop" or "foot drop"), nervous irritability, fine tremors, numbness, dizziness, hyperactivity, and severe abdominal pain.

Basic Compliance Measures

To protect workers and their families from lead hazards, you must first identify where lead may be present at the worksite. Potential sources of lead include paints and other coatings, lead mortars, and base metals that will be welded on or treated with abrasive blasting.

Buildings constructed before 1978 are likely to have progressively higher levels of lead, depending on their age. Paints and coatings that pre-date the 1950s have the highest lead levels. Lead may also be present in materials being used in the renovation; be sure to check your safety data sheets (SDSs).

To find out for sure whether a substance contains lead, you can send samples to a laboratory accredited by the U.S. EPA National Lead Laboratory Accreditation Program. Accredited labs are listed here.

If workers could be exposed to lead above the action level of 30 micrograms per cubic meter of air, calculated as an eight-hour time-weighted average, you must:

Notify Cal/OSHA. For all but the smallest jobs involving lead, you must provide a written Pre-Job Notification to the nearest Cal/OSHA office within 24 hours of the work starting (see the article on reporting in this issue for additional details).

Develop a written compliance program. Employers must develop a written compliance program before the job begins. The written program must describe the job in detail, together with the control measures that will be used and the schedule for inspections. The written program must be updated at least every six months.

Keep lead levels low. Cal/OSHA requires you to keep lead levels low on all construction jobs where lead is present using:

  • Housekeeping. Keep work surfaces and eating areas lead dust-free with HEPA vacuuming, wet cleanup, or other effective methods.

  • Hand and face washing. To prevent accidental ingestion of lead, washing facilities with soap and clean water must be available to workers.

  • Training. Workers must be trained in lead hazards and how to protect themselves.

Practice Tip

California's Department of Public Health maintains a resource page for California's Lead-Related Construction Program that provides important information for employers that do lead-related construction work.

Highly Hazardous 'Trigger Tasks'

Certain highly hazardous tasks, called "trigger tasks," come with specific respiratory protection requirements for employers, until the employer determines that worker airborne exposures to lead are below the levels specified in Table 1 of the standard:

Level 1 trigger tasks. When workers spray paint with lead paint, or where lead-containing coatings or materials are present during manual demolition, manual scraping or sanding, heat gun applications, or power tool cleaning with dust collection systems, you must provide workers with, at a minimum, a half-mask respirator with N-100, R-100, or P-100 filters.

Level 2 trigger tasks. When workers use lead-containing mortar or conduct lead burning—or when lead-containing coatings or materials are present during rivet busting, power tool cleaning without dust collection systems, clean-up activities using dry expendable abrasives, or abrasive blasting enclosure movement or removal—you must provide them with, at a minimum, an air-supplied hood or helmet, or a loose fitting hood or helmet powered air-purifying respirator with N-100, R-100, or P-100 filters.

Level 3 trigger tasks. Where lead-containing coatings or materials are present on structures during abrasive blasting, welding, cutting, or torch burning, you must provide, at a minimum, a half-mask supplied-air respirator operated in a positive pressure mode.

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