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Publication Number: FHWA-RD-98-179

Bridge Lead Removal and General Site Safety

Occupational Safety and Health Administration Regulations

 

Table of Contents

Exposure Limits
 
Exposure Assessment
Methods of Compliance
Medical Surveillance

 

29 CFR 1926.62 Standard

All construction work involving exposure or potential exposure to lead is covered by the Standard. This includes lead paint abatement, work on bridges and steel structures that are coated with lead-containing materials, demolition of structures where lead or materials containing lead are present, and removing or encapsulating materials containing lead.

EXPOSURE LIMITS

AL (Action Level) The action level is 30 micrograms per cubic meter (µg/m³) of air calculated as an 8-hour time weighted average (TWA). If exposures are at or over the action level, your employer must begin to comply with the standard by implementing a number of provisions of the standard. These include periodic exposure monitoring, biological monitoring, and employee training. The purpose of the Action Level is to establish a lower level of exposure, which requires your employer to begin to provide you protection before your exposure goes over the Permissible Exposure Limit (PEL).

PEL (Permissible Exposure Limit) The PEL is a Time Weighted Average (TWA) exposure limit averaged over an 8-hour work shift. The PEL is 50 micrograms of lead per cubic meter (µg/m³) of air. If a worker is exposed to lead in excess of the PEL for 30 days or more per year, the employer must begin to find ways to reduce the air concentration of lead. If that is not possible, then approved respirators must be issued to each worker that is exposed.

EXPOSURE ASSESSMENT

Your employer is required to determine the airborne level of lead exposure you are exposed to in work involving lead. This is termed exposure assessment. Personal air monitoring is required in order to determine your exposure level.

Initial Assessment

An initial assessment of exposure must be conducted to determine whether workers are exposed over the Action Level for all work involving lead. One full shift of personal air samples for each job classification in each work area is required. Sampling must be representative of workers' regular daily exposure.

Periodic Assessments

If the initial assessment indicates exposures over the AL, or the PEL, the employer is required to conduct exposure assessments:

  • Every 6 months if the worker exposure is at or above the AL
  • Quarterly if exposure is above the PEL.

Additional assessments must be made whenever a change occurs in practices, procedures, equipment, personnel, or other factors that could be expected to result in a change in lead exposures.

Protection of Employees During Exposure Assessment

This standard is unique. It recognizes that there are a number of jobs and tasks in construction where exposure to lead will likely be over the PEL, in some cases at very high exposure levels. This is particularly true for work performed on bridges, steel structures, and demolition projects. The standard requires that, if a contractor is engaged in any presumed exposure activities, the workers must be protected by specified measures BEFORE exposure assessments are made. In other words, the contractor cannot assign jobs for these tasks, collect personal samples, wait for results from the lab, and then provide workers protection.

Categories of Presumed Exposure

1) Tasks for which exposures must be assumed to be over the PEL but less than 10 times the PEL. These include the following activities where lead-containing paint or coatings are present:

  • Manual demolition of structures (e.g., dry wall)
  • Manual scraping
  • Manual sanding
  • Heat gun application
  • Power tool cleaning with dust collection systems
  • Spray painting with leaded paint

2) Tasks where exposures are presumed to be greater than 10 times the PEL, but less than 50 times the PEL. These include the following activities where lead-containing paint or coatings are present:

  • Cleanup activities where dry expendable abrasives are used
  • Abrasive blasting enclosure movement or removal
  • Using lead-containing mortar

3) Tasks presumed to result in exposures greater than 50 times the PEL. These include the following activities where lead-containing paint or coatings are present:

  • Abrasive blasting
  • Welding
  • Cutting
  • Torch burning

For all three categories of work tasks with presumed exposures over the PEL, the employer is required, before doing the exposure assessment, to provide:

  • Appropriate respiratory protection
  • Appropriate personal protective clothing and equipment
  • Changing areas that are free of lead
  • Hand washing facilities
  • Biological monitoring that measures the amount of lead in the blood

Employee Notification

The employer is required to notify you in writing, within 5 working days after completion of exposure assessments, of the results that represent your individual exposure. If a coworker wore the personal air monitor and the results of that sample are intended to represent your exposure, you must be notified in writing.

The contractor also must allow workers or their designated representatives to observe any lead exposure monitoring that is conducted.

METHODS OF COMPLIANCE

The OSHA standard requires that your employer follow certain steps to reduce your exposure to lead. These must be followed in a specified order. If these steps are not sufficient or feasible to reduce exposures to or below the PEL, the employer must provide the workers with personal protective equipment.

Compliance Program

Prior to the start of a job involving lead exposure, the employer will establish and implement a written compliance program. That program must address a number of specific items, which are outlined in the standard at 1926.62(e)(2). The written program must include the following:

  • A description of each activity in which lead is released into the air.
  • The procedures that will be used to achieve compliance, including engineering controls.
  • Air monitoring results that identify where the lead is being released into the air.
  • The work practices to be used.
  • How contractors on multi-contractor sites will inform workers of exposure to lead.

In addition, the compliance program must provide for frequent and regular inspections of job sites, materials, and equipment by a competent person. The written program also must

be provided upon request to affected workers and their representatives.

Administrative Controls

One method to limit employee exposure to lead is to limit the time during which they are exposed. If administrative controls are used, the employer is required to maintain certain records, including the names and ID numbers of affected employees and the length of time the worker was on the job.

 

Respiratory Protection

Respirators must be provided at no cost to workers when:

  • Exposures exceed the PEL
  • An employee requests one

Where respirators are used, the employer must have a written respiratory protection program that complies with the OSHA respirator standard under 29 CFR 1910.134. That standard requires fit testing (for negative pressure respirators) and medical certification that the employee can safely use a respirator, among other requirements.

Protective Clothing and Equipment

The employer is required to provide protective clothing to each employee exposed to lead over the PEL. The clothing is to be provided at no cost to the employee The employer is responsible for cleaning, laundering, disposal, repair, and replacement of such gear.

The employer must also ensure that no worker wears contaminated clothing or equipment off the job and that such clothing and equipment is removed after the job only in the change areas provided

Housekeeping

The standard requires that all work areas covered by the standard be kept as free of lead accumulation as practicable through the recommended use of high efficiency particulate air (HEPA) vacuums.

Hygiene Facilities

The standard has a number of provisions that address the fact that lead is a health hazard to workers from routes of exposure other than breathing air that contains lead dust. These aspects of the standard are designed to protect workers from ingesting lead and from tracking lead around the job site and into their homes. Included are the requirements for clean:

  • Change areas
  • Showers
  • Eating facilities

Change Areas

Where workers are exposed over the PEL, or where workers are performing presumed exposure tasks, clean change areas must be provided. These must include separate storage areas for protective clothing and equipment and for street clothes. The employer is responsible for ensuring that workers do not leave the job wearing contaminated clothing or equipment.

Showers

Showers or hand washing facilities must be provided so workers may remove lead dust from themselves prior to eating, drinking, smoking, or leaving the site. The employer also must provide soap and clean towels.

Eating Facilities

Lead-free eating areas or lunchroom facilities must be provided for workers exposed over the PEL. Workers using these facilities must wash their hands and face prior to eating, drinking, smoking, or applying cosmetics, and they must not enter the area wearing contaminated clothing.

MEDICAL SURVEILLANCE

Medical surveillance is an important provision because the lead we inhale or ingest ends up in our blood. Therefore, the medical surveillance program centers around the determination of the level of lead in the worker's blood.

Initial Surveillance

Initial surveillance of your blood lead level must be made before you begin any work where there is lead exposure. This gives the employer a base line against which to judge future blood sample results. The initial test is required if you are exposed at or above the Action Level on any one day, or you are engaged in lead work covered by any of the three presumed exposure category work tasks.

Following the initial blood sample, additional blood samples are required on a schedule of every 2 months during the lead exposure job for the first 6 months, and every 6 months after that.

Medical Examinations

Medical examinations involve an examination by a licensed physician in accordance with criteria established in the standard. The employer must make available medical exams to those workers exposed to lead in excess of the action level for more than 30 days in any consecutive 12-month period based on the following schedule:

  • Annually for each worker whose blood lead level was at or above 40 µg/dl
  • When a worker has signs or symptoms of lead poisoning
  • When a worker wants medical advice about having children or a worker is pregnant
  • When a worker has problems breathing while wearing a respirator

Medical examinations must be made available to you at no cost and at reasonable times and places. Your employer is entitled to receive ONLY the physician's written medical opinion that addresses whether the worker has any medical condition that could put the worker's health at increased risk from exposure to lead. The employer must provide you a copy of this medical opinion.

Medical Removal Protection (MRP)

If your blood lead level is at or above 50 µg/dI, your employer must provide another blood lead test within 2 weeks. If the second test is also at or above 50 µg/dI, you qualify for Medical Removal Protection (MRP).

This means that you must be removed from any job with lead exposures. If the employer does not have any other job for you that does not involve lead exposure, the employer must pay you MRP benefits, which maintain your total earnings, seniority, and other employee rights and benefits for a period of up to 18 months (or as long as your job would have lasted) or until your blood lead level drops below 40 µg/dI.

If your employer moves you to a non-lead exposed job, your earnings, seniority, and benefits cannot be reduced. If you file for workers' compensation, the amount the employer must pay you is reduced by the amount of your compensation payment.

Employee Information and Training

The standard requires that your employer provide you training prior to and annually thereafter at the time of job assignment where you are subject to exposure to lead at or above the Action Level.

Signs

The employer is required to post the following sign in each work area where employees' exposure to lead is above the PEL:

WARNING:

LEAD WORK AREA

POISON

NO SMOKING OR EATING

Recordkeeping

Your employer is required to establish and maintain accurate records covering a number of matters, including exposure monitoring, medical surveillance, medical removals, and objective data used to establish the basis for avoiding the requirement to conduct initial exposure monitoring. All of these records must be available to you, whether you are a current or past employee, or to your designated representative.

 

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