Lead has been one of the most important and widely-used metals in construction for thousands of years. Successive societies have dealt with the numerous acute and chronic health consequences of occupational exposure to lead for just as long. Despite its widespread availability and useful characteristics – historically used in construction materials such as plumbing materials, surface coatings, roofing materials, etc. – the United States has recognized lead as a dangerous substance. Although the Consumer Product Safety Council has banned the use of lead-containing paint in residences since 1978, lead-based paints and surface coatings are still used in outdoor applications, especially on large steel structures for its anti-corrosion and rust properties. The toxic properties of lead have spawned some innovation for material substitution, but lead remains in many new building materials and products as well.
While the United States Environmental Protection Agency is responsible for regulation and enforcement regarding the protection of public health and the environment, the Occupational Safety and Health Administration (OSHA) has the authority to protect the health and safety of workers. OSHA’s Lead in Construction standard, 29 CFR 1926.62, is applicable to any construction work with the potential to expose workers to lead. Lead in General Industry is covered in a separate OSHA standard in 29 CFR 1910.1025.
Procedures that commonly expose construction workers to lead include, but are not limited to: removal of lead-containing paints, coatings and finishes; plumbing work where lead pipe and “pigtails” are used; welding of lead-containing alloys; demolition of structures with materials containing lead; and installation of new products that contain lead.
Important Elements of the Standard
Employers are required to follow work practices and maintain documentation. Knowledge of the scope of OSHA 1926.62 is also valuable for property directors and project managers to verify contractors are following the procedures and policies detailed in the standard.
Employers must perform an “initial determination” – an exposure assessment to determine the amount of lead to which a worker is exposed. Workers may be exposed to lead not only by inhalation, but also by skin absorption or ingestion. The results of the exposure assessment are compared to the standard’s Action Level (AL) of an air concentration of 30 micrograms per cubic meter (30 µg/m3) and the Permissible Exposure Limit (PEL) of 50 µg/m3 – to determine what methods of compliance, if any, are prescribed in the standard. Both limits are expressed as eight-hour, time-weighted average exposures. Employers are required to maintain records of exposure assessments for a minimum of 30 years.
Methods of compliance, when exposures exceed the limits, include administrative controls, engineering controls, and personal protective equipment (PPE). Employees must be properly trained in lead work, receive a physical, and be included in the company’s Respirator Program. Projects with a high exposure potential may require containment to enclose the work, as well as the air to be filtered and ventilated. Common PPE for lead projects that exceed the Action Level include respirators with appropriate cartridges and disposable suits and gloves, in addition to general construction safety wear.
The standard also requires a Lead Compliance Program (including work practices, controls, air monitoring results, and the duration and exposure level for each affected employee) be written and updated at least annually. The compliance program must provide that frequent and regular inspections of job sites, materials, and equipment be made by a competent person (i.e., someone capable of identifying existing and predictable lead hazards in the surroundings or working conditions and who has authorization to take prompt corrective measures to eliminate them).
Employers must institute a medical surveillance program for workers who are exposed to lead at or above the AL for more than 30 days in a 12-month period. Biological testing for blood lead levels and zinc protoporphyrin will be performed on a specified periodic basis. If the results indicate elevated blood lead levels, the worker may be removed from service until blood results are consistently at or below the acceptable level.
The standard also addresses housekeeping, hygiene facilities and practices, signage, and communication of hazards. If contractors do not follow these requirements, fines, unplanned work stoppages, and bad publicity may result. State and local agencies may impose additional restrictions as well.
Additional Resources
In this edition of HETI Horizons, we are not able to discuss all of the requirements of the OSHA Lead in Construction standard, as it applies to everyone’s concerns, but can assist with specific needs. We can also refer employers to numerous public resources that are available – such as the on-line “Lead in Construction” guidance document (https://www.osha.gov/Publications/osha3142.pdf). The full standard may also be referenced at Title 29 Code of Federal Regulations Part 1926.62. Various other fact sheets concerning lead work and exposure can be found on the OSHA website (www.OSHA.gov). State Departments of Labor and Industry or environmental agencies may also have assistance available.
HETI: Lead in Construction Services
HETI’s Certified Industrial Hygienists and Engineers are available to assist employers comply with the OSHA Lead in Construction standard. Whether the need is for a written compliance program, training, workplace exposure assessments, or simply addressing questions on compliance, we are here to help.