Lead

The next Steps cover Cal/OSHA safety regulations for Lead. Where appropriate, we have referenced the code from Title 8 of the California Code of Regulations.

The topics we will cover in this Navitent are:

-Health Risks of Lead Exposure
-Employer Responsibility
-Permissible Exposure Limits
-Trigger Tasks
-Protective Requirements
-Blood Lead Monitoring
-Employer Notifications
-Engineering And Work Practice Controls
-Written Compliance Program
-State-Approved Training
-Keeping Records
-Notification Of Lead Work
-Accessing Cal/OSHA Forms

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Health Risks of Lead Exposure

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 the serious, and in many cases, life-threatening health effects of lead, the employer must be thoroughly knowledgeable about the regulations to protect people from lead exposure before their employees engage in any work exposing them to lead. 1532.1

Employer Responsibility

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

-For each jobsite the lead hazard must be assessed

-Where lead is present the following is required:
a. Lead dust must be controlled by High-Efficiency Particulate Air (HEPA) vacuuming, wet cleanup, or other effective methods. 1532.1(h).
b. The employer shall assure that food, beverage, and tobacco products are not present or used in areas where employees are exposed to lead above the Permissible Exposure Limits (PEL). The employer shall provide hygiene facilities for changing, showering, eating, and hand washing. 1532.1(i).
c. Workers shall have access to labels on containers of lead and safety data sheets, and must be trained as per 5194 and 1532.1, 1532.1(l)(1)(A).
d. The employer shall implement a written compliance program to ensure control of hazardous lead exposures. 1532.1(e).
e. The employer shall provide the worker with and require the use of appropriate personal protective equipment. 1532.1(f),(g).
f. The employer shall assure that all protective clothing is removed at the completion of a work shift only in change areas provided for that purpose. 1532.1(g).

Permissible Exposure Limits

The Permissible Exposure Limits (PELs) for airborne lead are 0.05 milligrams per cubic meter of air (mg/m3) and an action level of .03 mg/m3, both as an 8 hour time-weighted-average (TWA). 1532.1(b)(c)

Trigger Tasks

Trigger tasks are certain highly hazardous tasks that carry the presumption of airborne exposure above the Permissible Exposure Limit (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 as provided in the Cal/OSHA’s “Lead in Construction” fact-sheet involving lead-containing materials and associated respirator requirements:

-Level 1 trigger tasks: spray painting, manual demolition, manual scraping or sanding, using a heat gun, and power tool cleaning with dust collection system.
• Minimum respirator requirement: a half-mask respirator with N100, R100, or P100 filters

-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 N100, R100, or P100 filters; a supplied- air hood or helmet; or a loose-fitting hood or helmet with a powered air purifying respirator with N100, R100, or P100 filters

-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

Protective Requirements

Protective requirements for all trigger tasks and any other task that may cause a lead exposure above the Permissible Exposure Limit (PEL) include the following:

-Respirators, protective equipment, and protective clothing

-Clothing change areas and a shower

-Initial blood tests for lead and zinc protoporphyrin

-Basic lead hazard, respirator, and safety training

-The employer shall post the following warning signs in each regulated area or work area where an employee’s exposure to lead is above the PEL:

DANGER
LEAD WORK AREA
MAY DAMAGE FERTILITY OR THE UNBORN CHILD CAUSES DAMAGE TO THE CENTRAL NERVOUS SYSTEM DO NOT EAT, DRINK OR SMOKE IN THIS AREA

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

Blood Lead Monitoring

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 benefits for 18 months or until the job from which they were removed is discontinued, whichever occurs first.

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

Employer Notifications

Employer shall notify an employee whose blood lead level is at or above 40 μg/dl that medical removal protection with benefits is required when a blood lead level is at or above 50 μg/dl. 1532.1(j)(2)(D)(2)

Note: many physicians are now choosing to place employees on medical removal protection at blood lead levels above 20 μg/dl, rather than 50 μg/dl. Thus, employers should target for the 20 μg/dl level as they evaluate the BLL results.

Engineering And Work Practice Controls

Feasible engineering and work practice controls must be implemented to maintain employee exposures to lead below the Permissible Exposure Limits (PELs).

Written Compliance Program

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

State-Approved Training

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

Keeping Records

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

Notification Of Lead Work

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

Cal/OSHA Forms

The “LEAD-WORK PRE-JOB NOTIFICATION” form with required information is available from Cal/OSHA at: www.dir.ca.gov/dosh/ReqPermitReg
CertNotificatio.htm

The form is available at: www.dir.ca.gov/DOSH/
leadnotification.pdf

How much did this Navitent help you to understand the Cal/OSHA safety regulations for Lead, including:

-Health Risks of Lead Exposure
-Employer Responsibility
-Permissible Exposure Limits
-Trigger Tasks
-Protective Requirements
-Blood Lead Monitoring
-Employer Notifications
-Engineering And Work Practice Controls
-Written Compliance Program
-State-Approved Training
-Keeping Records
-Notification Of Lead Work
-Accessing Cal/OSHA Forms

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