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Publication Number: FHWA-RD-98-180

Safety and Health on Bridge Repair, Renovation and Demolition Projects

Chapter 5

Lead Compliance Guideline

 

Table of Contents

Section 1: Introduction

Section 2: Assessing Exposures

Section 3: Engineering and Work Practice Controls

Section 4: Respiratory Protection

Section 5: Other Personal Protection Equipment

Section 6: Housekeeping and Personal Hygiene Practices

Section 7: Medical Surveillance

Section 8: Employee Information and Training

Section 9: Recordkeeping

References

 

SECTION 1: INTRODUCTION
This section of the guideline discusses the specific elements covered in the OSHA lead-in-construction standard, 29 CFR 1926.62, which aims to protect all workers from the potentially harmful effects of lead exposure.  A copy of 1926.62 and its appendices is found in appendix J.  Additional requirements may be required by State and local regulations.

Lead is a well-known poison that will severely and permanently damage blood, kidneys, and the central nervous and reproductive systems. Extreme caution must be taken whenever working on lead-coated surfaces because of the high exposures that can be expected while performing most tasks that involve work on structural steel.

Operations that generate lead dust and fumes when performed on lead-painted surfaces include the following:

  • Flame-torch cutting.
  • Welding.

  • The use of heat guns.

  • Sanding, scraping, and grinding.
  • Abrasive blasting.

The employer of construction workers is responsible for the development and implementation of a worker protection program in accordance with 29 CFR 1926.20 and 29 CFR 1926.62(e).  This program is essential in minimizing worker risk of lead exposure. Construction projects vary in their scope and potential for exposing workers to lead and other hazards.  Some bridge projects may involve limited exposure, such as the removal of paint from a small area for inspection or repair.  Others may involve the removal, or stripping off, of substantial quantities of lead -based paints on large bridges.  The employer should, as needed, consult a qualified safety and health professional* to develop and implement an effective worker protection program.

The most effective way to protect workers is to minimize exposure through the use of engineering controls and good work practices. It is OSHA policy that respirators are not to be used in lieu of engineering and work practices to reduce employee exposures to below the PEL.  Respirators can only be used in combination with engineering controls and work practices to control employee exposures.

OSHA's PEL for lead in construction limits worker exposures to 50 µg/m³ of air averaged over an 8-hour workday.

At the minimum, the following elements should be included in the employer's worker protection program for employees exposed to lead:

  • Hazard determination, including exposure assessment.

  • Engineering and work practice controls.

  • Respiratory protection.

  • Protective clothing and equipment.
  • Housekeeping.
  • Hygiene facilities and practices.

  • Medical surveillance and provisions for medical removal.

  • Training.

  • Signs.

  • Recordkeeping.

To implement the worker protection program properly, the employer needs to designate a competent person, i.e., one who is capable of identifying existing and predictable hazards or working conditions that are hazardous or dangerous to employees, in accordance with the general safety and health provisions of OSHA's construction standards.  The competent person must have the authorization to take prompt corrective measures to eliminate such problems.  Qualified medical personnel must be available to advise the employer and employees on the health effects of employee lead exposure and supervise the medical surveillance program.

*  Sources for professional safety and health advice include insurance carriers, trade organizations, State 7(c)(1) on -site consultation programs, and consultants.

 

SECTION 2: ASSESSING EXPOSURES
OSHA requires employers to do an initial exposure assessment to determine the levels of exposure for employees on the job.  There are two ways to do this:
  • Task-based assessment.

  • Data-based assessment.

Task-Based Assessment

This method uses OSHA's breakout of tasks and mandatory interim protective measures to determine the levels of exposure for employees on each job.  OSHA has identified certain tasks, including many common operations, that have the potential to create exposures at the PEL or above.  These tasks are grouped into three lists according to their potential exposure level.

Each task group is associated with a list of mandatory interim protective measures to protect employees while exposure assessment monitoring is being done.  OSHA requires these interim protective measures to be implemented during the initial exposure assessment period.  The measures can only be discontinued if monitoring results show that the exposure level on the job is below the PEL.  Once the exposure monitoring is completed, the interim protective measures can be tailored to fit the measured exposure levels.

The task-based assessment assumes a level of exposure that may be higher than the levels that actually exist, so the protective measures listed will offer maximum protection for employees.

If the task performed is in one of the following OSHA groups, the protective measures you need to take during exposure assessment are listed here.  Note the respirator level change in each group.

Group 1 Tasks:

  • Manual demolition of building components (e.g., dry wall) coated with lead-based paint.
  • Manual dry scraping and dry sanding of surfaces coated with lead-based paint.

  • Heat gun applications on surfaces coated with lead-based paint.

  • Power tool cleaning with dust collection systems.

  • Spray painting with lead-based paint.

  • When employer has reason to believe employee is doing job activity where lead exposure may be above PEL.

Protective Measures:

  • Appropriate personal protective clothing and equipment.
  • Change areas.
  • Handwashing facilities and showers.

  • Biological monitoring for lead and ZPP.

  • Appropriate training under the Hazard Communication Standard, in respiratory protection, and in safety.

* Respiratory protection rated for exposures up to 500 µg/m³ (minimum protection factor of 10) such as an air-purifying, half-mask respirator with twin N, P, or R 100 cartridges. (A simple dust facemask is NOT sufficient.)

Group 2 Tasks:

  • Using mortar that contains lead.
  • Lead burning.

  • Rivet busting on steel coated with lead-based paint.

  • Power tool cleaning without dust collection systems where surfaces are coated with lead-based paint.

  • Cleanup activities where dry, expendable abrasives are used on surfaces coated with lead-based paint.

  • Abrasive blasting enclosure movement and removal on structures coated with lead-based paint.

Protective Measures:

  • Appropriate personal protective clothing and equipment.

  • Change areas.

  • Handwashing facilities and showers.

  • Biological monitoring for lead and ZPP.

  • Appropriate training under the Hazard Communication Standard, in respiratory protection, and in safety.

* Respiratory protection rated for exposures of 500-2,500 µg/m³ (minimum protection factor of 25) such as a powered air purifying respirator (PAPR).

Group 3 Tasks:

  • Abrasive blasting of structures coated with lead-based paint.

  • Welding, cutting, torch burning of structures coated with lead-based paint.

Protective Measures:

  • Appropriate personal protective clothing and equipment.
  • Change areas.
  • Handwashing facilities and showers.

  • Biological monitoring for lead and ZPP.

  • Appropriate training under the Hazard Communication Standard, in respiratory protection, and in safety.

* Respiratory protection rated for exposures greater than 2,500 µg/m³ (protection factor above 50) such as a supplied-air positive pressure respirator.

Data-Based Assessment

This type of assessment may be handled in a number of ways.  Depending on the nature of the job, initial exposure assessment may be based on:

  • Air monitoring done under current on-site job conditions.
  • Air monitoring results obtained under essentially the same conditions on another job within the past 12 months.

  • Objective data from outside industry sources where exposures are consistently below the PEL (trade associations, insurance companies, and suppliers).

If the data demonstrate conclusively that no employee, using the specific materials and processes under the conditions of the work site, can be exposed to lead above the action level (30 µg/m³ TWA), an employer is not required to take any further measures unless conditions change.

Previous Air Monitoring

If the task performed is on one of the OSHA lists, the employer can use results of previous on-site air monitoring done by his/her company:

  • Within the past 12 months.

  • Under workplace conditions closely resembling those of the current job (including processes, type of  material, control methods, work practices, and environmental conditions).

Although monitoring data may indicate different exposure levels than OSHA's assumptions, the employer is still required to implement protective measures that are appropriate to the level of exposure indicated by the monitoring data. (See Section 3 for more details on specific protective measures.)

Objective Data from Outside Sources

IF THE TASK PERFORMED IS NOT ON ONE OF OSHA'S LISTS:

The employer can use objective data from outside sources (trade associations, insurance companies and suppliers), to establish exposure levels.  In all cases where previous air monitoring data or outside objective data are used, an employer is required to maintain accurate records showing how the data are relevant to the conditions of the job being done.

It is very important to remember that initial air monitoring must still be performed, whether or not the work that is taking place falls within the three trigger tasks or not.

 Below is a summary of the protective measures that are required based on the concentration of lead in the breathing zone of all workers.

 

Table 2.  Lead  protection measures by exposure levels.

Control Practice Exposure below
30 µg/m³ (AL)
Exposure between
AL and PEL
Exposure above
50 µg/m³  (PEL)
Determination of the Presence of Lead
X
X
X
Competent Person
 
 
X

Exposure Monitoring and Associated Recordkeeping¹

X
X
X
Mechanical  Ventilation
 
 
X
Local Exhaust Ventilation
 
 
X
Enclosures/Containment Systems²
 
 
X
HEPA Vacuums
X
X
X
Wetting Agents
X
X
X
Written Compliance Program
 
 
X
Warning Signs    
X
Worker Training  
X
X
Notification of Other Employers
X
X
X
Respiratory Protection
 
 
X
Protective Clothes/Gloves/Shoe Covers      
Handwashing Facilities Only
X
X
X
Change Areas with Storage Facilities    
X
Decontamination Facilities Including Showers    
X
Eating Areas and Facilities    
X
Biological Monitoring and Associated Recordkeeping  
X
X
Medical Examinations and Associated Recordkeeping³    
X

¹ Exemption is possible if objective data show that exposures are below the action level or if the employer has relevant data from the past 12 months.

² Enclosures are only assumed to be needed indoors on projects using mechanical ventilation.  Outdoor enclosures are covered by EPA regulations on environmental release of lead. 

³ Medical removal is dependent on worker blood level.

 

SECTION 3: ENGINEERING AND WORK PRACTICE CONTROLS
Because lead is a cumulative and persistent toxic substance and because lead-related illnesses may result from low levels of exposure over prolonged periods of time, engineering controls and good work practices must be used where feasible to minimize employee exposure to lead.  At a minimum, exposures must not exceed the OSHA interim final PEL of 50 µg/m³ averaged over an 8-hour period.  When feasible engineering controls and work practice controls cannot reduce worker exposure to lead to or below 50 µg/m³, respirators must be used to supplement the use of engineering and work practice controls.

Engineering Controls

A competent person should review all site operations and stipulate the specific engineering controls and work practices designed to reduce worker exposure to lead.  Engineering measures include local and general exhaust ventilation, process and equipment modification, material substitution, component replacement, and isolation or automation.  Examples of recommended engineering controls that can be used to reduce worker exposure to lead are as follows: 

  • Exhaust Ventilation

    Power tools used for the removal of lead-based paint should be equipped with dust collection shrouds or other attachments exhausted through a HEPA vacuum system.  Operations such as welding, cutting/burning, and heating should be provided with local exhaust ventilation.  HEPA vacuums should be used during cleanup activities.
    For abrasive blasting operations where full containment exists or is required, the containment structure should be designed to optimize the flow of ventilation air past the worker(s), so that the airborne concentration of lead is reduced and the visibility is increased.  The affected area should be maintained under negative pressure to reduce the chances that lead dust will contaminate areas outside the enclosure.  A containment structure should be equipped with dust collection and an air- cleaning device to control emissions of particulate matter to the environment.
    Mini-enclosures that contain only that portion of a structure that can be blasted and painted in 1 day should be used where possible.  These mini-enclosures are moved as the work progresses.

  • Encapsulation

    Perhaps the structural steel does not need to have the coatings removed down to the metal substrate.  Lead-based paint can be made inaccessible by encapsulating it with a material that bonds to the surface, such as acrylic or epoxy coatings.
    In cases where the lead-based coatings have not been removed, the  owner, or other responsible person, should ensure that maintenance staffs and contractors doing subsequent work on the bridge are aware that lead hazards still exist on the bridge with dust or fume-creating tasks.

  • Substitution

    Zinc-containing primers covered by an epoxy intermediate coat and polyurethane topcoat are commonly used instead of lead-containing coatings.
    Mobile hydraulic shears can be substituted for torch cutting under certain circumstances.
    Surface preparation equipment, such as needle guns with multiple reciprocating needles completely enclosed within an adjustable shroud, can be substituted for abrasive blasting under certain operations.  The shroud captures dust and debris at the cutting edge and can be equipped with a HEPA vacuum filtration system with a self-drumming feature.  One such commercial unit can remove lead-based paint from flat steel and concrete surfaces, outside edges, inside corners, and pipes.
    Chemical strippers can be used on surfaces involving carvings or molding, or intricate iron works,  in place of hand scraping or using a heat gun.  Chemical removal generates less airborne lead dust. These strippers, however, can be hazardous and the material safety data sheets (MSDSs) for the products used must be reviewed by the employer for information on worker exposure hazards from the chemical ingredients and protective measures recommended by the manufacturer.

  • Component Replacement

    Some lead-based painted bridge components (i.e., guardrails, expansion joints, light fixtures, etc.) can be replaced either with new components free of lead-containing paint or with the same components after the paint has been removed off-site. 

  • Process/Equipment Modification

  • Blasting techniques that are less dusty than abrasive blasting and that can be effective under some conditions include: 

checkmarkWet-blasting using high-pressure water with an abrasive, or surrounding the blast nozzle with a ring of water.

checkmarkVacuum blasting where a vacuum hood for material removal is positioned around the exterior of the blasting nozzle.

checkmarkHigh- and ultra-high pressure water jetting using water pressures  from 20,000  to 50,000 psi (137,900 - 344,750 kPa) to remove loose paint and rust.

checkmarkSponge jetting using specialized blasting equipment that propels a combination of abrasive material encased in a soft sponge (form) medium. The high-density foam cleaning medium is absorptive and can be used wet or dry.

checkmarkCarbon dioxide (dry ice) blasting using dry ice pellets propelled at a high velocity through a blasting nozzle. These pellets remove the paint from the surface and, when the dry ice evaporates, only the leaded debris remains.

When vacuum blasting, care should be taken to ensure that the configuration of the heads on the blasting/vacuum nozzle match the configuration of the substrate so that the vacuum is effective in containing debris.

Heat guns can be used to remove lead-based paints in small areas or on combustible substrates.  The guns used should be the flameless electrical softener type.  Heat guns should have electronically controlled temperature settings to allow usage below 700°F (371°C).  Heat guns should be equipped with various nozzles to cover all common applications and to limit overheating the work area.

The use of longer cutting torches increases the distance between the worker and the source of lead, and decreases lead exposures.

Using pneumatic tools, whenever possible, to remove  nuts and bolts or rivets rather than burning or torch-cutting eliminates the creation of lead-containing fumes.

Brush/roller application of lead paints or other lead-containing coatings is a safer method than spraying.  (Note:  Most States and the Federal government prohibit the use of lead-based paints to repaint bridges after lead-based coatings have been removed.)  This method of application introduces little or no paint mist into the air where the mist can present a lead inhalation hazard.

Non-silica-containing abrasive (e.g., steel or iron shot/grit) should be used where practical instead of sand in abrasive blasting operations.  The free silica portion of the dust presents a respiratory health hazard.

  • Isolation

    Although it is not feasible to completely enclose and ventilate some abrasive blasting operations, it is possible to isolate many operations to help reduce the potential for exposure to lead. Isolation, in this instance, consists of keeping employees not involved in the blasting operations as far away as possible from the work area.  By placing the employees at a greater distance from the source of lead exposure, their exposures will be reduced. 

Work Practice Controls

Work practices involve the way a task is performed. Good work practices can be a vital aid in achieving compliance with the PEL.  Some fundamental and easily implemented work practices are:  (1) housekeeping, (2)  periodic inspection and maintenance of process and control equipment, (3) proper procedures to perform a task, (4) supervision to ensure that the proper procedures are followed, and  (5) administrative controls.

  • Housekeeping

    A rigorous housekeeping program is necessary in many jobs to keep airborne lead levels below permissible limits. This involves a regular housekeeping schedule to remove accumulations of lead dust and lead-containing debris, and should be adapted to exposure conditions at a particular site.

    All surfaces should be maintained as free as practicable of accumulations of lead dust.  Lead dust in the workplace on overhead ledges, equipment, floors, and other surfaces must be removed before some disruption such as traffic, vibration, or random air currents causes the dust to become airborne again.  A regularly scheduled cleanup is important because it minimizes the accumulation of lead dust.

    Cleaning operations should be conducted during regularly scheduled cleanups or whenever large amounts of dust or debris build up. In general, cleanup operations can create significant lead exposures to workers.  All persons doing the cleanup should be provided with suitable respiratory protection and personal protective clothing to protect themselves from airborne lead.

    Vacuuming is considered to be the most reliable method of cleaning surfaces on which dust accumulates, but any effective method that minimizes the likelihood of lead becoming airborne may be used (for example, a wet floor scrubber). When vacuuming equipment is used, the vacuums must be equipped with HEPA filters. Blowing with compressed air is generally prohibited as a cleaning method, unless the compressed air is used in conjunction with a ventilation system designed to capture the airborne dust created by the compressed air (e.g., dust "blowdown" inside a contaminant structure).

    All lead-containing debris and contaminated items accumulated for disposal should be collected and put into sealed impermeable bags or other closed impermeable containers. Bags and containers must be appropriately labeled as lead-containing waste, and properly disposed of according to local environmental regulations.

  • Periodic Inspection and Maintenance

    Periodic inspection and maintenance of process equipment and control equipment, such as ventilation systems, is another important work practice control.  At worksites where total containment is used as an engineering control, the failure of the ventilation system for the containment area can result in hazardous exposures in the enclosure.  Breaches in the containment structures themselves may cause an increase in the lead exposures to workers outside the containment, as well as an increase in lead emissions from fugitive dusts.  Frequently, equipment that is near failure or is in disrepair will not perform normally.  Regular inspections can detect abnormal conditions so that timely maintenance can then be performed.  If equipment is routinely inspected, maintained, and repaired, or replaced before failure is likely, there is less chance that hazardous exposures will occur.

  • Proper Performance of Task

    In addition to the above work practice controls, workers must know the proper way to perform their job tasks to minimize their exposure to lead and to maximize the effectiveness of engineering controls.  For example, if a worker inappropriately performs a task away from an exhaust hood, the control measure will be of no use. Wetting surfaces with water mist prior to sanding, scraping, or sawing lead-containing structural components will minimize airborne lead dust generations.  Removing paints and coatings within 4 in (10.2 cm) of all areas to be torch cut, welded, or heated will also decrease exposures.  For thin pieces of steel, it may be necessary to remove an even larger area of paint.   Failure to properly operate engineering controls may also contaminate the work area.  Workers can be alerted to safe operating procedures through fact sheets, discussions at safety meetings, and other educational means.

  • Supervision

    Good supervision is another important work practice.  It provides needed support for ensuring that proper work practices are followed by workers.  By directing a worker to position the exhaust hood properly or to improve work practices, such as having the worker stand to the side or upwind of the cutting torch to avoid the smoke plume (whenever the configuration of the job permits), a supervisor can do much to minimize unnecessary exposure to airborne contaminants.  Furthermore, the current OSHA standard requires frequent and regular inspections of job sites, materials, and equipment by a competent person.  A competent person is one who is capable of identifying existing and predictable lead hazards and who has authorization to take prompt corrective measures to eliminate them.

  • Administrative Controls

    Administrative controls are another form of work practice controls that can be used to influence the way a task is performed.  For example, employees' exposures can be controlled by scheduling production and/or workers' tasks in ways that minimize employee exposure levels.  One method the employer can use is to schedule certain operations at a time when the fewest employees are present.  Thus, clean-up operations to remove lead dust and debris might be performed at night or other times when the production staff is not present.

    Another method is worker rotation, which circulates employees into and out of contaminated areas during a shift, thereby reducing the exposure to the individual employee.  These workers can be rescheduled to different areas of the worksite after a period of time to control the cumulative effects of lead exposure.  If this method is used to control worker exposure to lead, the lead standard requires that the employer implement a job rotation schedule that: (1) identifies each affected worker, (2) lists the duration and exposure levels at each job or work station where each affected employee is located, and (3) lists any other information that may be useful in assessing the reliability of administrative controls to reduce exposure to lead.

 

SECTION 4: RESPIRATORY PROTECTION
Although engineering and work practice controls are the primary means of protecting workers, controlling lead dusts and fumes at their source is often not sufficient to keep workers' lead exposures below the PEL.  Currently, in the construction industry, respirators must often be used to supplement engineering controls and work practices whenever these controls are technologically incapable of reducing worker exposures to lead to or below 50 µg/m³.

There are generally two major classes of respirators:  air purifying and air supplying respirators.  Air purifying respirators have an air cleaning filter or scrubbing medium in cartridges or canisters to remove contaminants from ambient air.  The ambient air can be drawn through the cartridges or canisters by breathing, or by a battery-powered air pump in the case of powered air purifying respirators.  To get air to move through the cartridges or canister by breathing, a negative pressure is created inside the respirator facepiece when the wearer inhales.  Because of the suction created inside the respirator facepiece during inhalation, these types of respirators are called negative pressure respirators.  Powered air purifying respirators suck air through the cleaners, then blow filtered air into the facepiece at a pressure that is theoretically greater than the negative pressure created in breathing, hence they are called positive pressure type respirators.

Air supply respirators use regulators to control the flow of clean supply air into the wearer’s respirator.  Supply air must be Compressed Gas Association Grade D breathing quality (see 1926.103), and usually comes from compressed air tanks, or compressors with special air cleaning features.  Some regulators allow a continuous flow of air to constantly flow through the facepiece, and these are called continuous flow respirators.   Some regulators allow air only to enter the facepiece when a negative suction pressure is created inside the facepiece by breathing in.  These are demand type respirators.  Some regulators maintain a constant positive pressure inside the respirator facepiece at all times, and let more air in during inhalation.  These types of respirators are known as pressure-demand respirators.  These terms are used in the respirator selection chart for lead hazards later in this section.

To provide adequate respiratory protection, respirators must be donned before entering the work area and should not be removed until the worker has left the area, or as part of a decontamination procedure.  Employers must ensure that the respirator issued to the employee is properly selected and properly fitted so that it exhibits minimum facepiece leakage. Respirators must be supplied by the employer at no cost to employees.

Employers must perform either qualitative or quantitative fit tests for each employee wearing negative pressure respirators.  Fit testing is to be performed at the time of the initial fitting and at least semi-annually thereafter.  In qualitative fit testing, the user wears the respirator in a test atmosphere containing identifiable substances such as isoamyl acetate or irritant smoke, and reports whether or not the test material is smelled or sensed during a variety of exercises.  In quantitative fit testing, a probe is placed inside the respirator facepiece to measure the leakage of the test atmosphere into the facepiece during several exercises such as talking, jogging, and moving the head.  A numerical fit-factor is then calculated.  See appendix D of 1926.62 for a complete description of fit-testing respirators.

Respirator Program

When respirators are provided, the employer must establish a respiratory protection program in accordance with the OSHA standard on respirator protection, 29 CFR 1926.103.

 Minimum requirements for an acceptable respirator program for lead include the following elements:

  • Written standard operating procedures governing the selection and use of respirators.

  • Selection of respirators on the basis of hazards to which the worker is exposed.

  • Instruction and training in the proper use of respirators and their limitations.

  • Regular inspection and cleaning, maintenance, and disinfection; worn or deteriorated parts must be replaced, including replacement of the filter element in an air purifying respirator whenever an increase in breathing resistance is detected.
  • Storage in a convenient, clean, and sanitary location, and protection against sunlight and physical damage.
  • Appropriate surveillance of work area conditions and degree of worker exposure or stress (physiological or psychological) must be maintained.
  • Evaluation to determine the continued effectiveness of the program.

  • Physician's determination that the employee is physically able to perform the work and wear a respirator while performing the work (respirator user's medical capacity to wear and work with a respirator should be reviewed annually).

  • Use of MSHA/NIOSH certified respirators.

  • Fit testing of negative-pressure respirators.
  • No facial hair such as beards and long mustaches that could interfere with the fit of a tight-fitting elastomeric respirator facepiece.

  • Breathing air used for supplied-air respirators that meets the requirements prescribed in 1926.103(f).

  • Standing permission for employees to leave the work area to wash their faces and respirator facepieces whenever necessary to prevent skin irritation associated with respirator use.

Respirator Selection

Lead concentrations may vary substantially throughout a workshift as well as from day to day. The highest anticipated work concentration is to be used in the initial selection of an appropriate respirator.

The table below provides specific recommendations for the type of respirator to use when the actual workplace exposure reaches certain multiples of the 50 µg/m³ PEL.  When an employer finds that exposures are lower or higher by personal air monitoring, then respirator selection can be adjusted accordingly.

 

 Table 3.   NIOSH - recommended respiratory protection for lead aerosols.

Airborne concentration of lead or condition of use

Required respirator¹

Not in excess of 500 µg/m³

- ½  mask air purifying respirator with high efficiency filters ²,³
- ½ mask supplied-air respirator operated in demand (negative pressure) mode.

Not in excess of 1,250  µg/m³

- Loose fitting hood or helmet powered air purifying respirator with high efficiency filters³.
- Hood or helmet supplied-air respirator operated in a continuous-flow mode, e.g., Type CE abrasive blasting respirators operated in a continuous-flow mode.

Not in excess of 2,500 µg/m³

- Full facepiece air purifying respirator with high efficiency filters³.
- Tight fitting powered air purifying respirator with high efficiency filters³.
- Full facepiece supplied-air respirator operated in demand mode.
- ½ mask or full facepiece supplied-air respirator operated in a continuous-flow mode.
- Full facepiece self-contained breathing apparatus (SCBA) operated in demand mode.

Not in excess of 50,000 µg/m³

- ½ mask supplied-air respirator operated in pressure demand or other positive pressure mode.

Not in excess of 100,000 µg/m³

- Full facepiece supplied-air respirator operated in pressure demand or other positive-pressure mode, e.g., Type CE abrasive blasting respirators operated in a positive pressure mode

Greater than 100,000 µg/m³

- Full facepiece SCBA operated in pressure demand or other positive pressure mode.

¹ Respirators specified for higher concentrations can be used at lower concentrations of lead.

² Full facepiece is required if the lead aerosols cause eye or skin irritation at the use concentrations.

³ A HEPA filter means a filter that is a 99.97 percent efficient against particles of 0.3 micron size or larger.

If exposure monitoring or experience indicates airborne exposures to contaminants other than lead, such as solvents or polyurethane coatings, these exposures must be considered when selecting respiratory protection as well.  A reevaluation of the respiratory protection program is required when a worker demonstrates a continued increase in blood lead levels.

Abrasive Blasting and Related Operations

NIOSH Type CE respirators are required for use by abrasive blasting operators. Currently, NIOSH certifies both continuous-flow and positive pressure respirators for abrasive blasting operations.  Most continuous-flow respirators are recommended by NIOSH only for airborne lead concentrations less than or equal to 25 times the OSHA PEL (i.e., up to 1250 µg/m³).  However, some manufacturers have shown that their continuous-flow Type CE respirators can offer protection greater than 25 times the PEL.

OSHA has accepted the use of some continuous-flow Type CE abrasive blasting respirators for exposures up to 1,000 times the PEL, when the manufacturer has proven that the respirator affords the greater protection factor.  Before selecting a Type CE continuous-flow abrasive blasting respirator for use on a bridge RR&D site, it would be wise to call the nearest OSHA Area Office to determine if the respirator is acceptable for exposures greater than 25 times the PEL.

Positive pressure respirators are recommended by NIOSH for airborne concentrations less than 2,000 times the OSHA PEL (50 µg/m³).  Furthermore, manufacturer's instructions regarding quality of air, air pressure, and inside diameter and length of hoses must be strictly followed.  Use of longer hoses or smaller inside diameter hoses than the manufacturer's specifications, or hoses with bends or kinks, may restrict the flow of air to a respirator and negate the NIOSH approval.

 

SECTION 5: OTHER PERSONAL PROTECTIVE EQUIPMENT
At no cost to employees, employers must provide workers who are exposed to lead above the PEL and for whom the possibility of skin contamination or skin or eye irritation exist, clean, dry protective work clothing and equipment.  Appropriate changing facilities must also be provided.  Appropriate protective work clothing and equipment used on construction sites can include:
  • Coveralls or other full-body work clothing.

  • Gloves.

  • Vented goggles or face shields with protective spectacles or goggles.

  • Welding or blasting helmets, when required.

Disposable coveralls and separate shoe covers may be used, if appropriate, to avoid the need for laundering.  Non-disposable coveralls must be replaced daily if exposure levels exceed 200 µg/m³, and weekly for exposure levels from 50 to 200 µg/m³.   If an employee leaves the work area wearing protective clothing, the clothing should be cleaned with HEPA filter vacuum equipment to remove loose particle contamination; or as an alternative, the coveralls should be removed.  Before respirators are removed, HEPA vacuuming or another suitable method, such as damp wiping, shall be used to remove loose particle contamination on the respirator and at the face-mask seal.  Use work garments of appropriate size, and use duct tape to reinforce their seams (e.g., underarm, crotch, and back).

Contaminated clothing that is to be cleaned, laundered, or disposed of shall be placed in closed containers.  Containers shall be labeled with the following warning:


CAUTION:  Clothing contaminated with lead.  Do not  remove dust by blowing or shaking.  Dispose of lead-contaminated wash water in accordance with applicable local, State, or Federal regulations.

Persons responsible for handling contaminated clothing shall be informed of the potential hazard in writing.  At no time shall lead be removed from protective clothing or equipment by any means that disperses lead into the work area, such as brushing, shaking, or blowing.

At no time shall workers be allowed to leave the worksite wearing lead-contaminated clothing or equipment, e.g., shoes, coveralls, or head gear.

All contaminated clothing and equipment shall be prevented from reaching the worker's home or vehicle.  This is an essential step in reducing the movement of lead contamination from the workplace into a worker's home and provides added protection to employees and their families.

Gloves and protective clothing should be appropriate for the specific chemical exposure (e.g., solvents and caustics).  Cotton gloves provide some protection against the contamination of hands and cuticles with lead dust.  Workers should wear clothing that is appropriate for existing weather and temperature conditions under the protective clothing.

Heat stress:  Workers wearing protective clothing can face risk from heat stress.  Additionally, heat stress may be an important concern when working in a hot environment or within containment structures.  Heat stress is caused by a number of interacting factors, including environmental conditions, type of protective clothing worn, the work activity required, and the individual characteristics of the employee.

In situations where heat stress is a concern, employers should use appropriate work/rest regimens and provide heat stress monitoring that includes measuring employee's heart rates, body temperatures, and weight loss. (See chapter 4)

 A source of water or electrolytic drink shall be close to the work area (in a non-contaminated eating/drinking area) so that it will be used often.  Workers should wash their hands and face prior to drinking any fluid.  Frequent fluid intake throughout the day will replace body fluids lost to evaporation.  If such measures are used to control heat stress, protective clothing can be safely worn to provide the needed protection against lead exposure.  The possibility of heat stress and its signs and symptoms should be discussed with all workers.

 

SECTION 6: HOUSEKEEPING AND PERSONAL HYGIENE PRACTICES


Lead is a cumulative and persistent toxic substance that poses a serious health risk.  A rigorous housekeeping program and adherence to basic personal hygiene practices will minimize employee exposure to lead.  In addition, these two elements of the worker protection program will help to prevent taking lead-contaminated dust out of the worksite and home to the workers' families, thus ensuring that the duration of lead exposure does not extend beyond the workshift and providing added protection to employees and their families.

Housekeeping

An effective housekeeping program involves at least daily removal of accumulations of lead dust and lead-containing debris. Vacuuming lead dust with HEPA filtered equipment or wetting it with water before sweeping are effective control measures.  Such cleaning operations should be conducted, whenever possible, at the end of the day, after normal operations cease.  Furthermore, all persons doing the clean up should be provided with suitable respiratory protection and personal protective clothing to prevent contact with lead. 

In addition, all lead-containing debris and contaminated items accumulated for disposal should be collected and put into sealed impermeable bags or other closed impermeable containers.  Bags and containers should be appropriately labeled as lead- containing waste.  These measures are especially important as they minimize additional sources of exposure that engineering controls generally are not designed to control.

Personal Hygiene Practices

To minimize exposure to lead, special attention should be given to workers' personal hygiene.  The employer must provide and ensure that workers use washing facilities.  Clean change areas, and separate non-contaminated eating areas must also be provided. Cars should be parked where they will not be contaminated with lead.  These measures will reduce the worker's period of exposure to lead and the ingestion of lead, ensure that the duration of lead exposure does not extend beyond the workshift, significantly reduce the movement of lead from the worksite, and provide added protection to employees and their families.

Change Areas:  The employer must provide a clean change area equipped with storage facilities for street clothes and a separate area with facilities for the removal and storage of lead-contaminated protective work clothing and equipment.  This separation is essential in preventing cross-contamination of the employee's clothing.

Clean change areas are to be used for taking off street clothes, suiting up in clean working clothes (protective clothing), donning respirators prior to beginning work, and dressing in street clothes after work.  No lead-contaminated items should enter this area.

Work clothing must not be worn away from the jobsite.  Under no circumstances shall lead-contaminated work clothes be laundered at home or be taken from the worksite, except to be laundered professionally or properly disposed of following applicable Federal, State, and local regulations.

Showers:  When there is potential for extensive contamination of the employees' skin, hair, and protective clothing, shower facilities must be provided if feasible so that exposed employees can wash lead from their skin and hair prior to leaving the worksite.  Where showers are provided, employees must change out of their work clothes and shower before changing into their street clothes and leaving the worksite.

Workers who do not change into clean clothing before leaving the worksite may contaminate their homes and automobiles with lead dust.  Other members of the household may then be exposed to harmful amounts of lead.

Because of  lead contamination, some environmental jurisdictions may require that shower wash water be treated before disposal to decrease lead levels in the water.

Personal Practices (eating, drinking, etc.):  The employer must ensure that employees who work with lead either clean or remove their protective clothing and wash their hands and face prior to eating, drinking, smoking, or applying cosmetics and that these latter practices are never permitted while in the work area or in areas subject to the accumulation of lead.  HEPA vacuuming can be used to remove loose contamination from the work clothing prior to eating.

Washing Facilities:  Adequate washing facilities shall be provided for employees.  Such facilities shall be in near proximity to the worksite and be provided with water, soap, and clean towels to enable employees to remove lead contamination from their skin.  Contaminated water from washing facilities and showers must be disposed of in accordance with applicable local, State, or Federal regulations.

 End-of-Day Procedures:  Workers who are exposed to lead should follow these procedures upon finishing work for the day:

  • Place disposable coveralls and shoe covers in labeled waste containers.
  • Place lead-contaminated clothes, including work shoes, and personal protective equipment for laundering/cleaning (by the employer) in a closed container.

  • Take a shower and wash hair.

  • Change into street clothes.

 

SECTION 7: MEDICAL SURVEILLANCE
Introduction

Establishing a medical surveillance program for lead in the construction industry is challenging.  The constantly changing nature of the work and transitory personnel can make it difficult to administer a medical surveillance program; however, a basic understanding of the medical surveillance requirements is essential in designing a program that will work for each construction situation. 

Blood lead levels are currently the best indicator of personal lead exposure.  By monitoring blood lead levels, an employer can determine whether all of the prevention measures, such as engineering and work practice controls, respiratory protection, and good hygiene practices, are preventing lead poisoning in employees.  When employees are  known or presumed to be exposed to lead levels at or above the action level of 30 µg/m³,  blood tests that monitor for lead and an enzyme called zinc protoporphyrin (ZPP) must be provided for workers.  The results of these blood monitoring tests then guide whether further medical follow-up actions such as a referral to a physician for a medical examination, need to be taken.  Other factors such as health complaints and reproductive concerns voiced by lead-exposed workers can also trigger medical examinations.

Appendix C, Part II of the OSHA Lead Standard provides a good summary of the adverse health effects associated with various blood lead levels.   Excessive exposure to lead affects many of the body’s organ systems, including the blood formation, nervous, gastrointestinal, renal, and reproductive systems.  The purpose of a medical surveillance program is to protect workers from these adverse health effects through regular blood monitoring tests, medical examinations, and even removal of workers from lead exposure when necessary.  This chapter discusses the basic principles of medical surveillance for lead.

Medical Surveillance Service Providers

Prior to beginning any medical surveillance program, it is essential that the employer identify a medical provider who can provide both biological monitoring and medical examinations so that the program can be organized and coordinated.  It is often helpful to interview several physicians to assess their familiarity with lead-in-construction issues and to determine their past experience levels in administering lead medical surveillance and examination programs.  All medical examinations and consultations shall be performed by or under the direct supervision of a qualified physician.  A qualified physician is a doctor of medicine (M.D.) or osteopathy (D.O.) familiar with the objectives and requirements of a medical surveillance program for lead exposure.

It is also important to ensure that the laboratory providing an analysis of the blood is approved by OSHA.  A current list of approved labs in your area may be obtained from the OSHA Technical Center at (801) 487-0267, or at the following address:

OSHA Technical Center
P.O. Box 65200
Salt Lake City, UT 84165.

 Overview of Lead Medical Surveillance Procedures

 The primary driver of the medical surveillance program is biological monitoring for blood lead and ZPP levels.  ZPP is a chemical substance in the blood that becomes elevated when lead has interfered with the body’s blood forming mechanism.  It is a better indicator of long-term lead absorption than blood lead levels.  Blood lead measurements typically reflect shorter-term lead absorption that has occurred over the past days or weeks of exposure. 

 The blood lead and ZPP monitoring are done prior to exposure to lead above the action level, during exposure, and after exposure has ended.  Medical exams need not be provided unless blood lead levels rise above 40 µg/dl, or when lead-related medical signs, symptoms, illnesses, or other medical issues arise.  All medical surveillance procedures and exams must be made available to employees; however, participation by employees in the program is not mandatory.  If employees do not participate in the program, it is useful to have the employee sign a waiver declining participation in the program.  As a result of high blood lead levels or a physician’s examination findings, employees may be required to be removed from lead exposure areas. 

Initial Surveillance

The standard requires that baseline blood lead and ZPP levels must be determined for all workers that are exposed to airborne lead levels greater than the action level

(30 µg/m³) on any one day, or are engaged in lead work covered by any one of the three presumed exposure category work tasks. (Some States, such as Maryland, have different participation criteria.)

The blood lead and ZPP levels should be determined prior to, or no later than the end of the second day of lead exposure. This baseline sample serves as a reference to which all future samples can be compared.

Periodic Biological Monitoring Requirements

For workers exposed to lead at or above the action level for more than 30 days annually, biological monitoring is required once every 2 months during the lead exposure job for the first 6 months and once every 6 months thereafter.

In the event that any worker’s blood lead increases to or above 40 µg/dl, biological monitoring needs to continue every 2 months until the blood lead level drops below 40 µg/dl for two consecutive samples taken less than 2 weeks apart.

Employees must be informed of the blood test results in writing within 5 working days after the employer receives the information. Anyone whose blood lead level exceeds 40 µg/dl shall also be notified of the need for medical follow-up.

Medical Examination and Consultation

Medical examinations are provided to all workers who are exposed to lead at or above the action level more than 30 days in any consecutive 12-month period in accordance with the following schedule:

  • Immediately, when a worker has a blood lead level greater than or equal to 40 µg/dl.

  • Annually for each worker who had a blood lead level of 40 µg/dl or more during the preceding 12 months.

  • When a worker has signs or symptoms associated with lead poisoning, or believes he or she may be lead poisoned.

  • When a worker requests medical advice on reproductive effects of lead that he/she may be experiencing.

  • When a worker has problems breathing when wearing a respirator.

  • When a worker is pregnant.

  • When a worker has other medical conditions, unrelated to lead poisoning, that can possibly become worse with lead exposure.

Medical examinations must be provided to the worker free of charge and during normal work hours.

Content of Medical Examinations

The medical examination for anyone whose blood lead level reaches or exceeds 40 µg/dl or who experiences the medical issues above, must consist of the following elements:

  • A detailed work and medical history with particular attention to past lead exposure (occupational and non-occupational), personal habits such as smoking and hygiene, and past gastrointestinal, hematologic, renal, cardiovascular, reproductive, and neurological problems.
  • A thorough physical exam with particular attention to teeth, gums, gastrointestinal, hematologic, renal, cardiovascular, reproductive and neurological systems. Pulmonary status should be evaluated if respiratory protection is used.

  • Blood pressure measurement. 
  • A blood test that determines:

    checkmarkBlood lead level.

    checkmarkHemoglobin and hematocrit determinations, red cell indices, and examination of peripheral smear morphology.

    checkmarkZinc protoporphyrin.

    checkmarkBlood urea nitrogen.

    checkmarkSerum creatinine.

  • A routine urinalysis with microscopic examination. 
  • Any other test that the examining physician deems necessary by sound medical practice. 

The content of other medical exams shall be determined by the examining physician, and, if requested by the employee, shall include pregnancy testing or laboratory evaluation of male fertility.

Information Provided to Examining and Consulting Physicians

The initial physician conducting a lead-related examination or consultation must be provided with the following information:

  •  A copy of the applicable regulation for lead.

  •  A description of the employee's duties as they relate to lead exposure.

  • The employee's exposure level to lead and any other toxic substances (if applicable).

  • A description of personal protective equipment used.

  • The employee's prior blood lead levels.
  • All prior written medical opinions concerning the employee's lead exposure.

This information must also be provided to other physicians involved in the case, if requested by the employee or his or her physician.

Medical Opinion

The employee must be provided with a written medical opinion from each examining or consulting physician that contains the following information:

  • Any detected medical conditions that increase the risk of harm to the employee, if he/she is exposed to lead. 
  • Any recommended special protective measures or limitations to control the employee's exposure to lead. 
  • Any limitation on the use of respirators. Can the employee wear a negative pressure respirator? If not, can he/she wear a powered air purifying respirator?  
  • The results of blood lead levels.

To protect both the health and privacy of the employees, physicians shall be instructed to directly advise an employee of any medical condition (occupational or non-occupational) that requires further medical care. Physicians shall not reveal to the employer any information unrelated to the employee's occupational lead exposure.

Multiple Physician Review

If the employer selects the initial physician to conduct any of the required medical examinations or consultations, then the employee may select a second physician to review the findings, determinations, and recommendations of the initial physician. This second physician may perform whatever examinations, consultations, and laboratory tests are necessary to complete this review.

Each employee must be promptly notified in writing of the right to obtain a second opinion after each exam or consultation provided by the company-selected physician. The employee has 15 days after receiving both this notification and a written medical opinion from the initial physician to take steps to obtain a second opinion. During this 15-day period, he/she must notify his/her superintendent that he/she intends to obtain a second opinion and must call a doctor to set up an appointment.  The employer need not pay for the second opinion or abide by its findings, if the employee does not meet these requirements.

If the findings, determinations, or recommendations of the second physician differ from those of the initial physician, then the employer shall request the two physicians to resolve any disagreement. If the two physicians are unable to quickly resolve their disagreement, then they shall designate a third physician to review the findings, determinations, and recommendation of the prior physicians.

This third physician shall conduct any examinations, consultations, tests, and discussions with the prior physicians that he/she deems necessary to resolve the disagreement. The employer shall act consistently with the findings, determinations and recommendations of the third physician unless the employer reaches an agreement with the employee that agrees with the recommendations of at least one of the three physicians.

Medical Removal Protection

An employee must be removed from lead exposure when any of the following conditions exists:

  1. The latest blood test and a follow-up test done within 2 weeks indicates a blood lead level at or above 50 µg/dl.

  2. When the initial physician or the final determination of a multiple physician review decides that the employee shall be removed from lead exposure due to a medical condition that increases his or her risk of harm from lead.

For an employee removed due to condition “a”, that employee may not return to work involving lead exposure until two consecutive blood lead tests indicate blood lead levels less than or equal to 40 µg/dl.  For condition “b”, the employee may return when the initial physician authorizes the return. If the employee has sought a second opinion, then he/she cannot return until the multiple physician review panel makes that determination.

Medical Removal Benefits

The contractor must provide medical removal benefits each time an employee is removed from lead exposure. These benefits apply even in cases where an employee is removed from lead exposure before the regulations actually require removal.

Medical removal protection benefits consist of maintaining the earnings, seniority, and other rights and benefits of an employee as though he or she had not been removed from lead exposure. The contractor can provide these benefits by transferring the employee to a job that has no lead exposure greater than what is normally found off the job.

Medical removal benefits cannot be halted until at least one of the following conditions exists:

  • The employee fails to participate in the medical surveillance program provided by the company physician.
  • When two consecutive blood lead samples taken at least 2 weeks apart are below 40 µg/dl.

  • The company physician--or, when the employee obtains a second opinion, the final determination of the multiple physician review-authorizes the employee's return to lead work.

  • The company physician--or when the employee obtains a second opinion, the final determination of the "multiple physician review"--determines that the employee may never return to work involving lead exposure. In this case, a settlement will be reached through worker's compensation.

Putting It All Together

Employers who have little changeover in personnel and a steady stream of lead-exposing projects can set up an ongoing year-after-year medical surveillance program.  Other employers who have sporadic lead-exposing jobs and greater turnover in personnel will have to tailor the medical surveillance program to their needs within the parameters of the lead standard.  For the latter employers, it is sometimes helpful to identify a core group of workers who will most likely be on any lead-exposing jobsite and place them in an ongoing medical surveillance program.  This ongoing "core group program"  can be coupled with a "seasonal or job-specific" medical surveillance program for employees who are temporarily hired or who move between lead-exposing and non-lead-exposing jobs.  Nevertheless, each company must find a system for providing medical services to all employees who are exposed to lead above the action level.

Prior to beginning a medical surveillance program, it is essential that the employer identify and establish a good working relationship with a medical provider.  Arrangements should be made with the provider regarding scheduling of employee visits and the content of medical exams as discussed above. Pertinent information should be shared with the provider as discussed above.   Each employer should also discuss with the physician(s) how the following issues will be handled:

  • Medical confidentiality related to medical exams.
  • Procedures for medical removal because of high blood lead levels or lead intoxication symptoms.

  • Reproductive health issues for lead-exposed employees.

  • Procedures for a multiple physician review process.

  • Procedures for dealing with non-compliant personnel.

Regardless of the exposure level or the duration of time that employees are exposed to lead, all new employees should be provided with biological monitoring before the start of a job to determine that they are not coming into the job with elevated lead levels.  Failure to take this precaution may result in the employer having to remove the blood-lead elevated employee from lead exposure areas soon after beginning the job, and provide him/her with full wages and benefits until blood lead levels drop below 40 µg/dl.  In addition, employees should be given exit blood lead testing to document their blood lead and ZPP levels before they leave employment.

 

SECTION 8: EMPLOYEE INFORMATION AND TRAINING

Each employer is required to provide an information and training program for all employees exposed to lead above the action level or who may suffer skin or eye irritation from lead compounds such as lead arsenate or lead azide.  The training should begin with basic right-to-know training on the hazards of lead.  The trainer can use an MSDS for lead or a lead-based paint as a starting point.  In addition, training must provide the following information and cover the following items:

  • Copies of the 1926.62 lead standard, its appendices, and all applicable State regulations.
  • A list of specific operations (burning, welding, etc.) that result in lead exposure.

  • The purpose, proper selection, fitting, use, and limitations of respirators.
  • The purpose and a description of the medical surveillance and medical removal protection programs.

  • Information on health problems associated with excessive lead exposure. Particular emphasis should be placed on the reproductive problems that lead can cause in both men and women.

  • Engineering controls and work practices that will be used to control lead exposure.

  • The contents of the company's lead exposure control program.

  • A warning that chelating agents should not routinely be used to remove lead from employees’ bodies and should only be used under the direction of a licensed physician.

All employees must be trained prior to initial assignment to areas where there is a possibility of exposure over the action level.  This training program must also be provided at least annually thereafter unless further exposure above the action level will not occur.

In designing a training program, employees should be given an opportunity to actually perform in the training session what the  employees are expected to do on the jobsite.  For instance, employees using supplied-air type airline respirators should demonstrate that they know how to properly set up the airlines and filters, check carbon monoxide levels and wear the respirator.  Employees should be able to demonstrate the proper use of exposure-reducing controls such as vacuum blasting equipment.  The correct use of other personal protective equipment such as coveralls, protective eyewear and headwear should be demonstrated by each employee. 

Employees should show that they know how to remove contaminated PPE without exposing themselves to lead.  Finally, employees should actually perform their work functions utilizing all the lead-control measures in a non-hazardous atmosphere to show that they can perform the work safely.

 

SECTION 9: RECORDKEEPING
Each employer is required to keep all records of exposure monitoring for airborne lead.  These records must include:
  • The name, Social Security Number, and job classification of employees measured and the employee group the exposure monitoring represents.

  • Details of the sampling and analytical techniques, including a description of the sampling and analytical methods and their accuracies.

  • The results of sampling, including dates, numbers of samples, locations, personal versus area sampling, sampling results, TWAs and durations of samples.

  • The type of respiratory protection being worn by the person sampled.

  • Descriptions of environmental barriers that could affect the sampling results.

  • The name and contact information of the person(s) taking the samples.

Such records are to be retained for at least 30 years. 

Each employer is also required to keep all records of biological monitoring and medical examination results.  These records must include:

  • The names, Social Security Numbers, and job duties of the employees receiving biological monitoring and medical exams. 
  • A copy of the physician's written opinion following a medical exam.

  • Results of any airborne exposure monitoring done on or for an employee who receives a medical exam.

  • Any employee medical complaints related to lead.

In addition,  the employer or the physician must keep (subject to by medical confidentiality principles):

  • A copy of the results of the medical examination and work history.

  • A brief description of lab procedures and copies of standards or guidelines used to interpret test results.

  • Copies of biological monitoring results.

Medical records must be preserved and maintained for the duration of employment plus 30 years. However, if the employee's duration of employment is less than 1 year, the employer need not retain that employee's medical records beyond the period of employment if the records are provided to the employee upon termination of employment.

Recordkeeping is also required if an employee is temporarily removed from his/her job under the medical removal protection program.  This record must include:

  • The name and Social Security Number of the removed employee.
  • The date of removal and return.

  • How the removal was or is being accomplished.

  • Whether or not the reason for the removal was an elevated blood lead level.

The employer is required to keep each medical removal record only for as long as the duration of an employee's employment.

The lead standard also requires that if an employee requests to see or copy environmental monitoring, blood lead level monitoring, or medical removal records, they must be made available to the requesting employee or a representative authorized by that employee.

The employee's union also has access to these records.  Medical records other than blood lead levels must also be provided upon request to an employee, to his/her physician, or to any other person designated by that employee.  A union does not have access to an employee's personal medical records, including medical exam results, unless authorized by the employee.

 

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