29 CFR 1910.1025 Lead in General Industry 1926.62 Lead in Construction ile, Compliance Officer Utah...

29 CFR1910.1025 Lead in General Industry

1926.62 Lead in Construction

ile, Compliance OfficerUtah OSHA – (801)530-

6901

Shaheen Safiullah

Compliance Assistance Specialist

Health Effects

• Routes of Entry

• Inhalation (breathing)

• Ingestion (swallowing)

Health Effects

• Acute effects– Abdominal pain

– Constipation

– Limb pain

– Hypertension

– Vomiting

– Coma

– Respiratory arrest

– Death

Health Effects (contd)

• Chronic effects– Fatigue– Weight loss– Insomnia– Shaking of arms– Foot drop, wrist drop– Blue line on gums

Organs and systems affected

• Blood System (heme-synthesis inhibition)

• Nervous System

• Kidneys and Liver

• Reproductive System

* Children and Lead

Medical Expenses

• Higher workers compensation premium– Liability Lawsuits– Loss of Productivity– Loss in earning power– Lost time by supervision– Lost time by fellow workers– Cost of training new personnel– Economic loss to injured worker’s family

Exposure Limits

• PEL (permissible exposure limit)– 50g/m3 (8-hour time weighted average)– OR, Allowable employee exposure in g/m3) =

400 divided by the number of hours worked in the day

• AL (Action Level)– 30g/m3 (8 hour time weighted average)

• Blood Lead Level (BLL)– 50 g/dl

Exposure Assessment

• Employers shall initially determine if any employee may be exposed to lead at or above the action level. Do not use the protection factor of respirators during exposure assessment.– Collect personal samples representative of a full shift

• At least one sample for each job classification in each work area with the highest exposure

– Exception: Any data obtained within the past 12 months under closely resembling work conditions such as processes, type of material, control methods, work practices, environmental conditions, is acceptable in place of personal air samples in the current workplace.

Construction: Provide Protection During Exposure Assessment

• Appropriate respiratory protection• Protective work clothing & equipment• Change areas• Handwashing facilities• Training• Initial medical surveillance: BLL &

ZPP

Construction: Assumed Exposures >PEL but < 10X PEL

• Manual scraping/sanding• Heat gun applications• General clean up• Power tool cleaning w/dust

collection systems• Spray painting with lead-based

paint

Construction: Assumed Exposures

>10X PEL but <50X PEL • Lead-containing mortar; lead burning• Rivet busting• Power tool cleaning w/out dust

collection systems• Clean up of dry expendable abrasives• Abrasive blasting enclosure movement

and removal

Construction: Assumed Exposures>50X PEL

• Abrasive blasting

• Welding

• Cutting

• Torch burning

Basis of initial determination

• Employer shall conduct initial monitoring based on the following observations:– Employee exposure monitoring results– Any information, observations or calculations

which would indicate lead exposure– Previous monitoring– Employee complaints of symptoms related to

lead exposure

Initial determination exception• Objective data showing that a particular product containing

lead or a process, operation or activity involving lead cannot result in employee exposure to lead at or above the action level during processing, use or handling, the employer may rely upon such data instead of implementing initial monitoring. – Maintain an accurate record documenting the nature and relevancy

of objective data. This record must be maintained for 30 years.

• Any data obtained within the past 12 months under closely resembling conditions.

• Objective data cannot be used for exposure assessment during interim protection.

Positive initial determination

• If there is possibility of exposure above the action level then representative monitoring must be conducted.– If above the AL but below the PEL monitoring

shall be done every 6 months– If above the PEL then every 3 months

Additional Exposure Assessments Required When

• Changes that may result in increased exposure:–Equipment–Process/new task–Control–Personnel

(e) Methods of compliance

Hierarchy of Controls

• Goal: reduce exposures to PEL• Must institute engineering and

work practice controls• May use administrative controls• May supplement with respiratory

protection after achieving lowest feasible level

Compliance Program

• Required if PEL

• Revised/updated every 6 months

Compliance Program Components

• Description of lead-emitting processes– Equipment, material, controls, crew size,

job description, SOPs, maintenance procedures

• How compliance will be achieved• Technology considered to achieve PEL• Air monitoring data documenting lead

emission source• Schedule for implementation

Compliance Program Components (cont’d)

• Work practice program– Protective clothing

– Housekeeping

– Hygiene facilities

– Work practices as described in App B where relevant

Compliance Program Components (cont’d)

• Administrative controls– Implement a job rotation schedule:

• ID of employee

• Duration and exposure levels of each job

• Any other information useful in assessing reliability of administrative controls

Compliance Program Components (cont’d)

• Arrangements made among contractors on multi-contractor sites (1926.16)

• Provisions for frequent and regular inspections of job sites, materials and equipment by a competent person

• Revise the program at least every six months

No Apparent Controls for Lead Exposure

Engineering ControlIsolation / Containment

Engineering ControlsShrouded Tools w/HEPA

vacuum

Other Engineering & Work Practice Controls

• Substitution

• Ventilation

• Processes than minimize dust generation– Chemical paint strippers

– Wet methods

Chemical Paint Removers

(f) Respiratory Protection

Implement a written respiratory protection program

(29 CFR 1910.134)

Air-Purifying Respirator (APR)Cleanses the contaminated atmosphere

Can’t be worn: in unknown/IDLH atmospheres where prohibited

Powered Air-Purifying Respirator (PAPR)

An air-purifying respirator that uses a blower to force the ambient air through air-purifying elements to the inlet covering.

Atmosphere-Supplying Respirators

• Supplies breathing air

• Includes:– Supplied air

respirators– SCBA– Combination SAR /

SCBA units

Two Basic Classes of Contaminants

• Aerosols/particulates–Airborne solid or liquid particles

–Dusts, fumes, mists, fog, smoke, fibers

• Gases/Vapors

High Efficiency Particulate Air Filter (HEPA)

Filter that is at least 99.97% efficient in removing monodisperse particles of 0.3 micrometers in diameter.

Equivalent NIOSH 42 CFR 84 particulate filters are the N100, R100, and P100 filters.

Medical Evaluations

• Before fit testing and use

• Performed by PLHCP –medical questionnaire - 1910.134

Appendix C

–an initial medical examination

Fit Testing

Assess respirator fit prior to use

Use of RespiratorsFacepiece Seal Protection

• No facial hair or any condition that interferes with the face-to-facepiece seal or valve function

• Corrective glasses or goggles or other PPE must be worn in a manner that does not interfere with the face-to-facepiece seal

• User seal check each time

User Seal Check

An action conducted by the respirator user to determine if the respirator is properly seated to the face.

Positive Pressure Positive Pressure CheckCheck

Negative Pressure Negative Pressure CheckCheck

Maintenance and Care

• Clean and disinfect• Storage

– Cartridges/filtersseparately– Plastic bags orcoffee cans

Respirator Selection

• Based on exposure level

• Select using Table 1

• PAPRs must be provided if–Employee chooses and

–Provides adequate protection

(g) Protective Work Clothing and Equipment

Provision and Use

• Prevent employee contamination• Provide and maintain at no cost

when– > PEL– Skin/eye irritation– Interim protection

• Ensure use

Cleaning & Replacement

• Clean at least weekly; daily if >200g/m3

• Remove PPE in change areas only• Put into closed, labeled containers• Inform cleaning personnel in writing• No blowing, shaking, or otherwise

dispersing in air

(h) Housekeeping – for all exposures!

• Keep all surfaces free from lead• Use HEPA filter when vacuuming • Shoveling, dry or wet sweeping used only

where vacuuming or an equal method is not effective

• Compressed air not allowed unless used with exhaust ventilation system

(i) Hygiene Facilities & Practices

Lead on Hands & Blood Lead Levels

• Positive correlation between lead on hand tested and blood lead levels

Hygiene Facilities & Practices

• Required when exposure > PEL

• No food, drinks, cigs, cosmetics – Wash hands/face prior

• Eating facilities/areas: provide– Free from lead– Enter after removing surface Pb dust

Signs Required in Areas >PEL

Hygiene Facilities & Practices - cont

• Provide clean change rooms– Separate work and street clothes– Ensure workers don’t wear PPE

home

• Showers: provide and ensure use when > PEL– If unfeasible, handwashing facilities– Provide cleansing agents and towels

Hygiene Facilities & Practices - cont

D-Lead Cleaning Products

Lead Check Swabs

D-Lead Lead Test Kits

Spray Solution 1, then Solution 2

Yellow means lead is present

(j) Medical Surveillance

Medical Surveillance

• Biological Monitoring when = or >AL–Blood lead levels (BLL)–Zinc Protoporphyrin (ZPP)

• Medical Examinations by licensed physician

Medical Surveillance – cont

• When =/ > AL for more than 30 days in any consecutive 12 months

• No cost to employees, reasonable time and place

• Requirements vary according to– Workplace type– Exposure level– BLL level

(k) Medical Removal Protection(MRP)

50 g/dl whole blood

Temporary Removals

• Final medical determination: Any medical finding that the employee has a medical condition increasing risk of material impairment to health from exposure to lead

Temporary Removals - cont

• Remove from Pb exposures 50 g/dl

• Return when two consecutive BLL tests are 40 g/dl whole blood

MRP Benefits

• Maintain–Normal earnings–Seniority–Other rights and benefits

• Benefits continue for up to 18 mos on each occasion

(l) Training Requirements

• Prior to start of job

• At least annually

• Extent of training depends on exposure

(m) Recordkeeping

• Keep for at least 40 years or duration of employment + 20 years (30 yrs construction)– Exposure assessment data

– Objective data for monitoring exemption

– Medical surveillance ( duration of employment + 30 years, construction)

OSHA website

• Federal OSHA: Www.osha.gov– Click on “Technical Links” under

the outreach section

• Utah OSHA: www.uosh.utah.gov

• NIOSH: www.cdc.gov/niosh