A description of the proposed changes are as follows:

1. TITLE 8:

CONSTRUCTION SAFETY ORDERS
Chapter 4, Subchapter 4, Article 14, Section 1532.1

Lead

INITIAL STATEMENT OF REASONS


INFORMATIVE DIGEST OF PROPOSED ACTION/PLAIN ENGLISH OVERVIEW

Title 8, Section 1532.1 of the Construction Safety Orders includes requirements addressing exposure assessment, methods of compliance, respiratory protection, protective clothing and equipment, hygiene facilities and practices, medical surveillance, medical removal protection, employee information and training, signs, recordkeeping, and observation of monitoring. Subsection (f) of Section 1532.1 specifies requirements for the use of respirators in construction work involving employee exposure to lead. This subsection specifies maximum use concentrations for various classes of respirators in Table I. Table I specifies that type CE hood or helmet continuous flow abrasive blasting respirators may be used in concentrations not exceeding 1250 g/m3. This is a concentration which is equivalent to 25 times the Permissible Exposure Limit (PEL) of 50 g/m3.

The proposed change amends Section 1532.1(f) to increase the limit for type CE continuous flow abrasive blasting respirators to concentrations not exceeding 50,000 g/m3. This is a concentration which is equivalent to 1000 times the PEL of 50 g/m3. The effect of this proposed change would be to permit the use of type CE continuous flow abrasive blasting respirators in higher levels of airborne lead which are often encountered in abrasive blasting operations.

Title 29, Code of Federal Regulations, Part 1926.62, Lead, is the Federal standard applicable to lead exposure in construction work. Paragraph (f) of Part 1926.62 specifies maximum use concentrations for various classes of respirators in Table I. Table I specifies that type CE hood or helmet continuous flow abrasive blasting respirators may be used in concentrations not exceeding 1250 g/m3. This is the same concentration limit specified in the current Section 1532.1. Federal OSHA has, however, granted higher limits for this type respirator in two enforcement policy memoranda dated August 30, 1995 and March 31, 1997. The memoranda permit this type of respirator to be used in lead concentrations not exceeding 1000 times the PEL. This proposed amendment would change the California construction lead standard to permit the same concentration limit for these respirators as is permitted by Federal enforcement policy and would therefore result in California’s construction lead standard being as effective as its Federal equivalent. It is not possible for California’s enforcement agency, the Division of Occupational Safety and Health, to grant similar relief for the use of these types of respirators through the mechanism of an enforcement memorandum.

 

NONCONTROLLING PLAIN ENGLISH SUMMARY

See Attachment No. 5.

 

DOCUMENTS INCORPORATED BY REFERENCE

None.

 Attachments