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Lead

Occupational exposures to lead can occur in construction activities, such as plumbing system retrofits; the spraying, removal, or heating of paint that contains lead; and the welding, cutting, and grinding of lead containing construction materials.

Occupational lead exposures can affect workers as well as family members and friends who come into contact with the “take -home” lead on the worker’s clothing, hair, hands, etc. The toxic effects of lead on the human body have been well documented and include damage to the kidneys, brain, and reproductive organs that in turn causes the loss of kidney function, sterility, decreased fertility, and birth defects and mental retardation in offspring.

Because of these serious and, in many cases, life-threatening health effects, laws and regulations have been enacted to protect people from lead exposure.

A. Cal/OSHA enforces the “Lead in Construction Safety Orders” that make employers responsible for the following:

  1. Before engaging in any work during which an employee may be exposed to lead, the employer must be thoroughly knowledgeable about the requirements of CSO 1532.1.
  2. For each job site the lead hazard must be assessed. 1532.1(d)(1)
  3. Where lead is present the following is required:
    1. Lead dust must be controlled by HEPA vacuuming, wet cleanup, or other effective methods. 1532.1(h)
    2. Workers must be provided with washing facilities that are supplied with soap and clean water. 1532.1(i)
    3. Workers must receive appropriate training. 1532.1(l)
    4. The employer must implement a written compliance program to ensure control of hazardous lead exposures. 1532.1(e)
    5. The employer must provide the worker with and require the use of appropriate personal protective equipment. 1532.1(e),(g)

B. The permissible exposure limits (PELs) for airborne lead are 0.05 milligrams per cubic meter of air (mg/m3) and an action level of 0.03 mg/m3, both as an 8hour time-weighted-average (TWA). 1532.1(b),(c)

C. Trigger tasks are certain highly hazardous tasks that carry the presumption of airborne exposure above the PEL. They require special protective measures until it is determined that worker airborne exposures to lead are below levels specified in 1532.1. Following are the three levels of trigger tasks involving lead-containing materials and associated respirator requirements:

  1. Level 1 trigger tasks: spray painting, manual demolition, manual scraping or sanding, using a heat gun, and powertool cleaning with dust collection system
    • Minimum respirator requirement: a half-mask respirator with N - 100, R - 100, or P - 100 filters
  2. Level 2 trigger tasks: using lead containing mortar; burning lead; rivet busting; cleaning power tools without a dust collection system; using dry, expendable abrasives for clean-up procedures; moving or removing an abrasive blasting enclosure
    • Minimum respirator requirement: a full-face mask respirator with N-100, R-100, or P-100 filters; a supplied-air hood or helmet; or a loose-fitting hood or helmet with a powered air purifying respirator with N - 100, R - 100, or P - 100 filters
  3. Level 3 trigger tasks: abrasive blasting, welding, cutting, or torch burning on structures
    • Minimum respirator requirement: a half mask, supplied-air respirator operated in a positive pressure mode

D. Protective requirements for all trigger tasks and any other task that may cause a lead exposure above the PEL include the following:

  1. Respirators, protective equipment, and protective clothing
  2. Clothing change areas and a shower
  3. Initial blood tests for lead and zinc protoporphyrin
  4. Basic lead hazard, respirator, and safety training
  5. The establishment of a regulated area and warning signs as shown below:

WARNING
LEAD WORK AREA
— POISON —
NO SMOKING OR EATING

Note: The above protective requirements must be enforced until worker airborne exposures are shown to be below levels specified in 1532.1

E. Blood lead monitoring is especially important to evaluating work and hygiene practices that may result in lead ingestion. Employees whose blood lead levels exceed specified limits must be removed from the work with exposure to lead at or above the action level. These workers must be provided with normal earnings, seniority, and other employee rights and beneitts for 18 months or until the job from which they were removed is discontinued, whichever occurs first. Starting in January 2002, mandatory medical removal of an employee due to lead (or other regulated chemicals) must be recorded on the Log 300 with a check in the “poisoning” column. 1532.1(k)(2), 14300.9

F. Feasible engineering and work practice controls must be implemented to maintain employee exposures to lead below the PELs.

G. A written compliance program that details how lead exposures will be controlled is required. 1532.1(e)

H. On jobs at residential and public-access buildings, workers whose exposures to lead measure above the PELs and their supervisors must receive state-approved training and certification by the California Department of Health Services.

I. Records of air monitoring, blood lead testing, and medical removal must be maintained. 1532.1(n)

J. Employers who conduct lead work listed in subsection (d)(2) of the standard must notify the Division, in writing, at least 24 hours before the start of work. 1532.1(n)

Note: A sample notification form with required information is available from Cal/OSHA’s web page at www.dir.ca.gov/DOSH/Permits.html (Excel and PDF formats).