Lead Safety and Compliance Program

A written lead safety and compliance program documents the process of evaluating and controlling lead exposure.

Description:

Workers who perform abrasive blasting, welding or torch cutting, painting, demolition, lead abatement work, plumbing work or electrical work have the potential to be exposed to hazardous levels of lead. Exposure can cause a variety of health problems. In adults, lead can cause memory loss, headache, irritability, cognitive dysfunction, kidney damage, joint pain, birth defects, digestive issues, high blood pressure, and other cardiovascular effects. The International Agency for Research on Cancer (IARC) has described inorganic lead compounds as “probably carcinogenic to humans,” (WHO, 2006). Lead enters the body by breathing it in or swallowing it. A small amount of lead may also enter the body through the skin, especially if it is damaged.

It is estimated that about 838,000 construction workers in the United States come into contact with lead on the job (OSHA, 2017). Research indicates that children living in these households have blood lead levels about three times as high as children in the general population (Roscoe et al, 1999). This is most likely due to workers unintentionally bringing lead dust home on their clothing. Although lead is hazardous to people of all ages, it is especially dangerous to children and women who are or may become pregnant. Lead’s neurological effects are most pronounced in children under 6, who absorb 4-5 times more lead than adults (WHO, 2017). Lead exposure in pregnant women has also been associated with miscarriage, stillbirth, and mental retardation.

The Occupational Safety and Health Administration (OSHA) permissible exposure limit (PEL) for lead requires that exposures be kept under 50 µg/m3 as an 8-hour time-weighted average (TWA). The OSHA Action Level (AL) of 30 µg/m3 TWA also triggers monitoring, training, and medical surveillance requirements. Medical surveillance includes testing your blood for lead, which is the only way to see if you've been exposed to lead recently. It is important to note that OSHA has recognized that lead-related health problems can arise even when exposures are kept below the legal limits.

In addition to other requirements, OSHA’s lead standard requires that workplaces where there is a potential for overexposure institute a lead safety and compliance program. This program is an effective administrative control that documents the process of protecting workers’ health. 

 

A written lead safety and compliance program must be designed with the goal of keeping lead exposures below the OSHA PEL of 50 μg/m3 by using engineering and work practice controls. The program must contain the following elements at a minimum:

  • Detailed information on each lead-emitting operation.
  • A description of how compliance will be achieved.
  • Technology that will be employed to achieve compliance.
  • Exposure measurements for each lead-emitting operation.
  • An implementation schedule.
  • Information on available personal protective equipment (PPE), housekeeping practices, and hygiene facilities.
  • A description of any other administrative controls.
  • Any other information that may be relevant to preventing lead exposures in the workplace.

These written programs must be available on demand and updated at least every six months, or whenever anything in the work environment changes.  More detailed information is available in section 1910.1025(e)(3) of the OSHA standard for lead in construction: https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1025.

Risks Addressed:

Working in demolition, bridge renovation, residential remodeling, or any other area where paint is scraped, sprayed, sanded, or blasted, raises the risk of being exposed to lead. Performing hot work such as welding, brazing, soldering, or thermal cutting on surfaces that may have been coated in lead paint can release large quantities of lead fumes. Lead can also be present in solder, mortar, tank linings, batteries, and glazes. If you are not sure if the substance you are working with contains lead, consult the Safety Data Sheet (SDS). However, it is important to keep in mind that SDS are not always 100% accurate, and may not exist when performing remodeling or demolition work. The best way to tell if lead is present is to have paint chips analyzed by an accredited lab.

Air sampling is also necessary if employees are working with or altering materials that contain or may contain lead. A pump and filter can be attached to a worker’s clothing during their shift, and an accredited lab will analyze the filter for lead content. Sampling should always be done under the supervision of a professional industrial hygienist. 

Studies have not yet established the exact relationship between airborne lead dust concentrations and levels of lead in the blood (commonly measured in µg of lead per deciliter of blood, or µg/dL), but 95% of reported elevated blood lead levels (BLL) are work-related (CDC, 2009). Before 2015, an elevated BLL was defined as 10 µg/dL or higher. In 2015, the National Institute for Occupational Safety and Health (NIOSH) recognized that this was not protective enough and lowered the reference level to 5 µg/dL. However, studies have shown that health risks exist even below 5 µg/dL. An increase in death from cardiovascular causes, such as stroke or heart attack, was demonstrated at levels as low as 2 µg/dL (Menke et al, 2006). In elderly populations, BLLs below 10 µg/dL but higher than 0 µg/dL were tied to poor performance on neurobehavioral tests (ATSDR, 2007).

Studies of workers in the construction industry show a high level of variability in BLLs depending on the worker’s trade and primary task. Workers involved in lead-based paint removal were shown to have a mean BLL of 18 µg/dL, while workers doing welding, brazing, soldering, or thermal cutting had a mean BLL of 24 µg/dL (Koh et al, 2015). This contrasts sharply with the mean BLL of 0.84 µg/dL among all Americans in 2013-2014 (Tsoi et al, 2016). In fact, airborne concentrations of lead in construction are the highest of any industry (Henn, 2011), and although exposure to lead has decreased over time for general industry, construction exposures have remained more or less steady (Okun, 2004).

 

How Risks are Reduced:

A written lead safety and compliance program calls for a baseline assessment of employee exposure to lead. It also documents the specific steps that must be undertaken to minimize this exposure.  By formalizing the most effective ways to protect workers in one easily-accessible document, these programs greatly reduce the risk of lead exposure. 

Monitoring requirements ensure that the employer determines exposure for each job and area. They are then required to use the hierarchy of controls to implement the most effective preventive measures.  Engineering controls must be evaluated, and if they are not feasible, the reason must be documented.
 
A lead safety and compliance program also requires the provision of hygiene facilities to help workers protect themselves and their families. Handwashing stations must be provided near break rooms and lunch areas. Showers and clean changing rooms must also be available before and after workers’ shifts. Lead-contaminated clothing needs to be laundered professionally and separately or disposed of, and employers should provide disposable shoe covers so that workers do not track lead dust into their vehicles or homes. 
 
Lead safety and compliance programs must be evaluated at least every six months to make sure all information is current.
 

Additional Considerations:

When creating a lead safety and compliance program, it is important to remember that eliminating the hazardous material or substituting in a less hazardous material are the most effective ways to prevent exposure to lead. In situations where this is not possible (for example, a residential lead remediation project) engineering controls such as local exhaust ventilation, water suppression, or encapsulation are preferred. PPE should be used as a last resort when all other methods have failed to reduce exposures to acceptable levels.

Surfaces containing lead paint may sometimes be treated with a heat gun or chemical stripper to make the paint removal process easier. Heat guns soften the paint, reducing the amount of force needed to remove it from the surface.  However, heat guns must be used with caution as they can easily generate lead fumes. Workers should only use flameless electrical heat guns operated under 700 F°.

Although chemical strippers are usually preferred to heat guns, they often consist of strong solvents and other hazardous substances.  If the use of chemical strippers is absolutely necessary, workers should closely consult the Safety Data Sheet (SDS), work in areas with good ventilation, and wear appropriate respiratory protection to avoid breathing in the fumes. Paint strippers containing methylene chloride are not recommended.  

Contributors:

Sara Brooks, MPH, CPH - The Center for Construction Research and Training
Bruce Lippy, Ph.D., CIH - The center for Construction Research and Training
Mike Cooper, CIH

Hazards Addressed:

  • Residential Construction
    • Install and finish flooring
    • Install electrical systems
    • Install plumbing
    • Install roofing shingles or tiles
    • Paint interior and exterior walls, ceilings, trim, etc.
    • Perform surface grinding or cutting
    • Prepare surfaces with hand tools
    • Refinish bathtubs
    • Rig, load and transport construction debris

Availability

Occupational Safety and Health Administration
To obtain information, visit Lead in Construction

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