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LEAD
A. Standards
1. Federal standards regarding lead have been set by the National
Institute of Occupational Safety and Health (NIOSH), U.S. Dept.
of Health and Human Services, and other State and Environmental
Agencies including Cal/OSHA. These standards regulate the safe
handling of, exposure to, and protection from lead toxicity; they
specify information, monitoring, and investigation of lead and
its toxicity in the workplace, and stipulate requirements for
education about, and records kept on, employees who are exposed
to or may be exposed to lead at work.
2. Leadwork prejob notification: {COMPANY} must provide
written notification to the nearest Division District Office (see
Chapter 3's Cal/OSHA Directory) when working with lead is planned,
with the following exceptions:
a. The amount of lead is less than 100 square or linear feet.
b. The only task to be performed is less than 1 hour of torchcutting
or welding.
c. The percentage of lead in the materials to be worked with is
less than 0.5%, 5,000 parts per million or 1.0 mg/cm2.
3. Leadwork notification must be received by the nearest District
Office at least 24 hours prior to the beginning of the work, by
letter, fax, email or phone; phone notification must be followed
by written notification sent within 24 hours of placing the call.
4. The written notification can be submitted using the form provided
in Chapter 4 from Cal/OSHA entitled "LeadWork PreJob Notification."
5. An employer conducting ongoing leadrelated operations and maintenance
on stationary steel structures
a. need only make notification once for each structure if the
duration of the job is less than one year.
b. must submit a supplemental written notification updating all
the information required at least once per year for each structure.
B. Definition and Properties
1. Pure lead (Pb) is a heavy metal and is a chemical element.
It combines with numerous other substances to form compounds.
2. Compounds covered by these standards are: metallic lead, all
inorganic lead compounds and organic lead soaps.
3. Excluded are all other organic lead compounds.
C. Exposure Limits
1. This information applies to work where an employee may be exposed
to lead. It includes but is not limited to those who do any of
these processes involving leadcontaining products:
a. construction
b. demolition
c. salvage
d. spraypainting
e. welding
f. torchburning
g. abrasive blasting
h. cutting
i. alteration and repair
j. installation
k. lead containment/emergency cleanup
l. transportation
m. disposal
n. storage
o. maintenance
2. The permissible exposure limit (PEL) set by Cal/OSHA standards
specifies that exposure be limited to 50 micrograms of lead per
cubic meter of air (50mg/m3) averaged over an 8hour workday, or
Time Weighted Average (TWA).
D. Identification
1. {COMPANY} must initially determine who may be exposed
to lead in the work place. Employee exposure is that which would
occur if the employee were NOT using a respirator.
2. Sampling:
a. Where monitoring is required, {COMPANY} must collect
samples representing a full shift, including one sample per job
classification in each work area.
b. Until such sampling is performed, {COMPANY} must treat the
employee as if they were exposed above the PEL (see C.2), i.e.
in excess of 50mg/m3.
E. General Protection Practices
1. Until above sampling (as outlined in D.2 above) is performed,
{COMPANY} must provide the following:
a. A respirator.
b. Personal protective clothing.
c. Clotheschanging area(s).
d. Biological monitoring consisting of blood level analysis of
lead and zinc.
e. Safety instructions, signage, and training for employees.
f. A safe zone to eat.
F. Safe Work Practices
1. Employer Responsibilities
a. {COMPANY} will establish a specific work area where
airborne exposure is above the PEL, or where leadrelated tasks
are performed.
b. Appropriate work clothing and equipment preventing contamination
will be provided to all employees where lack of such protection
would expose the employee to unhealthy levels of lead, skin, or
eye irritation due to lead compounds.
c. {COMPANY} will implement a written compliance program
prior to starting any job where excess exposure may be reached.
i. The plan will describe operations where lead is emitted, the
type of equipment used, the type of material involved, the employees'
responsibilities, and operating and maintenance procedures.
ii. If job rotation is used to reduce employee exposure, such
plans will be included in the compliance plan.
iii. The plan will detail the type of protective gear, equipment,
respirators, housekeeping and hygiene practices that will be used
for protection against lead exposure.
iv. This written plan must be reviewed and updated every 6 months.
2. Employee Responsibilities
a. All employees must cooperate with all aspects of the {COMPANY}
Written Compliance Program including:
i. Attending all training sessions and meetings.
ii. Being willing to adopt and comply with all safety precautions
and practices set by the {COMPANY} Written Compliance Program.
iii. Participation in medical surveillance and biological monitoring
in the event that they are exposed to lead above the acceptable
level at any time. This includes periodic blood sampling and evaluation,
and monthly blood tests for employees who have been removed from
the workplace due to elevated levels of lead already detected
in the blood.
iv. Being willing to undergo a medical examination that will be
provided as soon as possible after notification by any employee
of symptoms of excess lead exposure.
vi. Understanding that {COMPANY} must provide medical consultation
regarding any employee's condition or any complaint regarding
lead exposure, especially pertaining to pregnancy and procreation.
This applies to both men and women.
vii. Understanding that {COMPANY} must provide medical
consultation to the employee regarding any difficulty breathing
while using or testing a respirator, or for any other protective
measure the employee feels is detrimental to his or her health.
b. NIOSH and Cal/OSHA have established that a spectrum of health
effects caused by lead exposure ranges from normal, physiological
reactions of uncertain significance to obvious symptoms and even
death. These reactions are not distinctly divided but are on a
subtle continuum. There is a wide variation of individual responses,
and an understanding of these responses is required by each employee.
Some of the symptoms may not be immediately obvious. Following
are some symptoms/effects for the employee to be aware of:
i. Nervous system: irritability, sleep disorders, fatigue, vertigo,
headaches, poor memory, tremor, depression, peripheral neuropathy,
stupor, hallucinations, delirium, convulsions, seizures and coma.
ii. Reproductive problems: decreased sex drive, decreased ability
to produce healthy sperm, sterility, low sperm count, dysmenorrhea
(painful menstruation), failure to implant, miscarriage, stillbirth,
and a variety of infant nervous system and other disorders and
defects.
iii. Other adverse health effects may include hypertension, vascular
changes, impaired thyroid function, renal problems or failure,
weight loss, metallic taste in the mouth, tinnitus, shortness
of breath, chest pains, palpitations, nausea, vomiting, heartburn,
abdominal pain, constipation, pallor, or muscle or joint pain.
c. Employees are expected to have a full understanding of their
rights when working with lead in their vicinity. This includes:
i. The right of access to written material and records about lead
exposure, toxicity and safety standards set by NIOSH and other
State and Environmental Agencies including Cal/OSHA.
ii. Awareness that results of biological monitoring or a physician's
recommendation may require that an employee be removed from further
lead exposure according to the standard's Medical Removal Program
(MRP).
iii. Knowledge that during the period of removal, {COMPANY}
must maintain the employee's earnings, seniority and other employment
rights and benefits (as if the employee had not been removed)
for 18 months, or for as long as the job would have lasted if
less than 18 months. These provisions may be contingent upon the
employee's participation in medical surveillance.
iv. Knowledge that any examining or consulting physician is not
permitted to share any other medical findings or diagnoses of
the employee with {COMPANY} which are not felt to be related
to occupational lead exposure.
v. Access to any written medical opinion from any consulting or
examining physician regarding the employee's exposure to lead
in the workplace, including blood levels, the physician's opinion
as to whether the employee is at risk of health impairment, recommended
protective measures if future exposure is permitted, and any recommended
limitations on that employee's use of a respirator.
G. Respirators
1. {COMPANY} must provide and pay for a respirator when
necessary.
2. {COMPANY} must provide a respirator when requested,
even if that person's air exposure level is not above the PEL.
For example, a person who is planning to become pregnant or who
has an impaired immune system is entitled to a respirator if they
request it.
3. Any respirator chosen must be approved by NIOSH.
4. The respirator must fit properly. Employees must be trained
in its use, and if it requires filters, {COMPANY} must provide
time to change filters. Employees must be able to leave the work
area periodically to wash their faces to prevent skin irritation.
5. {COMPANY} may select a respirator that provides greater
protection than the standard requires, such as a powered air purifying
respirator (PAPR); an employee must be able to obtain a PAPR upon
request.
6. The respirator must not restrict the employee's breathing,
or another respirator must be provided.
7. Further information on Respirators is found in the Personal
Protective Equipment section of the General Codes of Safe Work
Practices earlier in this manual.
H. Protective Clothing and Equipment
1. Employers must provide special clothing to be worn where concentrations
of lead exceed the permissible limit. This clothing must be clean
and dry.
2. Clothing may include fullbody covering, gloves, hats, shoes,
disposable shoe coverlets, face shields and/or covered goggles.
3. A changing area must be designated for changing into and out
of and storing protective clothing.
4. Upon removal of protective clothing, certain procedures must
be followed so that no lead will be released into the air. Clothing
is vacuumed to remove particles and respirators are removed last.
Employees must then wash their hands and faces.
5. Contaminated clothing must be placed in closed containers in
the changing room. Separate storage must be provided for protective
work clothing and street clothing to prevent crosscontamination.
6. Additional information on clothing is found in the Personal
Protective Equipment section of the General Codes of Safe Work
Practices earlier in this manual.
I. Hygiene
1. In contaminated areas, use of food, alcohol and cosmetics must
be prohibited.
2. For employees who have worked in areas of high exposure to
lead, showers and an adequate supply of soap and towels must be
provided.
3. Lunchroom facilities or eating areas uncontaminated with lead
must be provided. Employees wearing contaminated protective gear
must be prohibited from these areas unless surface lead dust has
been removed by vacuuming or by another cleaning method that eliminates
lead dust particles and fumes.
J. Training Programs
1. {COMPANY} must assure that each employee exposed to
lead at a dangerous level be trained by providing access to information
and certification materials, signage, and an annual training program
conducted by a training provider accredited by the California
Department of Health Services.
2. Each employee must be trained in the following:
a. Specific operations and locations that could result in employee
overexposure.
b. The use of respirators and other protective clothing.
c. The purpose of the medical surveillance program described in
Section L below concerning adverse health effects of lead overexposure,
with particular attention paid to the danger of adverse effects
on the reproductive systems of men and women, including hazards
and precautions specifically pertaining to the fetus of any employee
who might be pregnant.
d. The employee's right to access records under Section 3024 of
the California Code of Regulations, Title 8.
e. Instructions regarding the prohibition of chelating agents
(substances administered orally which lower the blood levels of
lead) by employers, and the fair use of such agents by a licensed
physician.
3. Upon request, {COMPANY} shall provide ALL materials
relating to the employee information training program and certification
to affected employees, their representatives, and NIOSH and/or
Cal/OSHA representatives.
K. Posted Signs
1. {COMPANY} must post the following signs in areas where
employee exposure to lead may be above the PEL. These signs must
be welllit, clean and legible:
a. WARNING LEAD WORK AREA
b. POISON
c. NO SMOKING OR EATING
L. Recordkeeping
1. {COMPANY} must establish and maintain an accurate record
of all monitoring, medical surveillance and other data gathered
in employee exposure assessment for every susceptible employee.
These records must include:
a. Date, number, duration and result of each sample taken to determine
employee exposure.
b. A description of the sampling method used.
c. The type of protective devices and clothing worn, if any.
d. Name, social security number, job classification and description
of the employee monitored and of all other employees this measurement
is intended to represent, if applicable.
e. Results of any airborne exposure monitoring.
f. Any medical complaints by the employee related to exposure
to lead.
g. Transfer of records:
i. If {COMPANY} goes out of business, these records must
be transferred to the new owner.
ii. If there is no successor employer these records must be transmitted
to NIOSH.
h. See (3g above) regarding medical surveillance records re: Medical
Removals.
2. Employer must keep records on:
a. Employee medical and work history.
b. Lab procedures used.
c. Any standards or guidelines used to interpret the tests.
d. A copy of the medical exam results, including physician's opinions
and the results of biological monitoring.
3. Medical Removals
a. The results of biological monitoring or a physician's recommendation
may necessitate the removal of an employee from further lead exposure
according to the NIOSH and Cal/OSHA Medical Removal Program (MRP).
The object of this program is to temporarily remove workers from
contaminated premises who have elevated blood lead levels or who
are otherwise at risk of physical impairment due to sustained
exposure to lead.
b. A worker is to be removed from any eighthour TWA exposure to
lead of 30mg/m3, when the blood lead level reaches 50mg/dl and
is confirmed by a follow up test within two weeks of the receipt
of the first results.
c. During the period of removal, {COMPANY} must maintain the worker's
earnings, seniority and other employment rights and benefits (as
if the worker had not been removed) for 18 months, or for as long
as the job would have lasted if less than 18 months. These provisions
may be contingent upon the employee's participation in medical
surveillance.
d. The return of an employee to the job depends on a worker's
blood lead level declining to 40mg/dl.
e. {COMPANY} must notify in writing each employee whose
blood lead level exceeds 40 mg/dl.
f. {COMPANY} must maintain an accurate record for each
employee removed from duty due to exposure to lead according to
NIOSH and U.S. Department of Health standards.
g. Each of these records must include the name and social security
number of the employee, removal and returntowork date (if any),
the reason for the removal, a statement regarding the employee's
blood level and whatever medical assessment was provided, and
other data summarizing the process, use, location, activities,
control methods, precautionary measures and protection from the
leadexposing activity of the employee.
h. Medical surveillance records must be kept for the duration
of employment plus 30 years, except in cases where employment
was less than one year, in which case the record need not be kept
past the term of employment if provided to the employee upon termination
of employment.
i. {COMPANY} must make all this information available to affected
employees and their representatives upon request, and NIOSH and/or
Cal/OSHA representatives for examination and copying.
M. Physician Reviews
1. A "second opinion" from a second physician must be
provided if the employee wishes one concerning potential lead
toxicity or poisoning. This second opinion can be with the physician
of the employee's choice, and all relevant documents must be submitted
to this physician. If the first and second physicians do not agree
on an assessment, they must try to resolve differences, or must
designate a third physician to resolve the dispute.
2. {COMPANY} must provide all consulting and examining physicians
with the following:
a. Copies of lead regulations and appendices.
b. A description of the employee's duties regarding lead exposure.
c. The exposure level or anticipated exposure level to lead and
any other toxins (if applicable).
d. A description of personal protective equipment used, blood
levels, and access to all prior written materials regarding the
employee at work.
e. An agreement that the physician will not be allowed to share
any medical findings or diagnoses of an employee with {COMPANY}
which are not felt to be related to occupational lead exposure.
3. {COMPANY} must provide the employee with:
a. A written medical opinion from the physical including blood
levels, physician's opinion as to whether the employee is at risk
of health impairment, any recommended protective measures for
the employee if future exposure is permitted, and any recommended
limitations on the employee's use of a respirator.
b. Knowledge that the physician understands that they will not
be allowed to share any medical findings or diagnoses of an employee
with {COMPANY} which are not felt to be related to occupational
lead exposure.
N. Employee Observation
1. {COMPANY} must provide affected employees and their
representatives an opportunity to observe the monitoring of employee
lead exposure.
2. Observers of such monitoring are to be protected from exposure
themselves with the use of respirators, protective clothing, and
so on, provided by {COMPANY}, and observers must comply
with all applicable safety procedures.
3. Observers are entitled to explanations of procedures, access
to the place of exposure, and to record the results or obtain
copies of lab reports.
