Issue:
- The Institute for Health Metrics and Evaluation (IHME) estimated that in 2021 there were more than 1.5 million deaths globally and more than 33 million years of life lost (disability-adjusted life years, or DALYs) from lead exposure.
- Lead is distributed to the brain, liver, kidney and bones. It is stored in the teeth and bones, where it can accumulate over time.
- Exposure to lead can affect multiple bodily systems and is particularly harmful to young children and women of child-bearing age.
- There is no level of exposure to lead that is known to be without harmful effects for individuals but OSHA regulations set a Permissible Exposure Limit (PEL) of 50 micrograms of lead per cubic meter of air (50 ug/m3) in an 8-hour time-weighted average (TWA).
- There are two types of lead exposure:
Acute exposure, measured by micrograms of lead per deciliter of blood,
Chronic exposure, measured by micrograms of lead per gram of bone. - The damage lead causes cannot be reversed, but there are medical treatments to reduce the amount of lead in the body. The most common is a process called chelation – a patient ingests a chemical that binds to lead, allowing it to be excreted from the body. If not removed in time it is fatal.
- The harmful impacts on health from lead exposure are entirely preventable.
Sources:
- Chipping and flaking paint.
- Lead-acid batteries, pigments, solder, stained glass assemblies, gasoline, ammunition, ceramic glazes, jewelry, toys, some traditional cosmetics, and some traditional medicines.
- Working with raw lead. Usually found in rooms designed to protect others from radiation, ex: hospitals, clinics and certain power generation control rooms.
Routes of Exposure and Causes
Inhalation:
- Lead particles generated by grinding, welding, sanding, heat guns and torches become airborne. Even dismantling and demolition work cause lead particles to become airborne.
- Burning materials containing lead, for example: during burning construction debris, smelting, recycling, air particles stripping leaded paint and plastic cables.
Ingestion of contaminated dust: From particles on
clothing, and in soil, water or food.
Absorption: From touching your eyes, nose or mouth.
Current Test Results:
We regularly test both airborne and contact exposure to employees
Airborne Results: Current observations have been below acceptable levels unless employees are sanding, grinding, or heating lead, creating an off gas, ex: rotor zip cutting, welding or heating.
On Contact: Current observations are 5 times the acceptable levels, ex: physical touching, deposits on clothing (gloves, work attire, shoes) or by residue left behind after disturbance.
Regulations:
OSHA Standard Subpart D 1926.62(a) Scope. This section applies to all construction work where an employee may be occupationally exposed to lead. All construction work excluded from coverage in the general industry standard for lead by 29 CFR 1910.1025(a)(2) is covered by this standard. Construction work is defined as work for construction, alteration and/or repair, including painting and decorating. It includes but is not limited to the following: 1926.62(a)(1) Demolition or salvage of structures where lead or materials containing lead are present; 1926.62(a)(2) Removal or encapsulation of materials containing lead; 1926.62(a)(3) New construction, alteration, repair, or renovation of structures, substrates, or portions thereof, that contain lead, or materials containing lead; 1926.62(a)(4) Installation of products containing lead; 1926.62(a)(5) Lead contamination/emergency cleanup; 1926.62(a)(6) Transportation, disposal, storage, or containment of lead or materials containing lead on the site or location at which construction activities are performed.
OSHA Standard Subpart D 1926.62(b) Action level means employee exposure, without regard to the use of respirators, to an airborne concentration of lead of 30 micrograms per cubic meter of air (30 ug/m3) calculated as an 8-hour time-weighted average (TWA).
OSHA Standard Subpart D 1926.62(b) Permissible exposure limit.1926.62(c)(1) The employer shall assure that no employee is exposed to lead at concentrations greater than fifty micrograms per cubic meter of air (50 ug/m3) averaged over an 8-hour period.1926.62(c)(2) If an employee is exposed to lead for more than 8 hours in any work day the employees’ allowable exposure, as a time weighted average (TWA) for that day, shall be reduced according to the following formula: Allowable employee exposure (in ug/m3) = 400 divided by hours worked in the day.
OSHA Standard Subpart D 1926.62(d)(4) Positive initial determination and initial monitoring. 1926.62(d)(4)(i) Where a determination conducted under paragraphs (d) (1), (2) and (3) of this section shows the possibility of any employee exposure at or above the action level the employer shall conduct monitoring which is representative of the exposure for each employee in the workplace who is exposed to lead. 1926.62(d)(4)(ii) Where the employer has previously monitored for lead exposure, and the data were obtained within the past 12 months during work operations conducted under workplace conditions closely resembling the processes, type of material, control methods, work practices, and environmental conditions used and prevailing in the employer’s current operations, the employer may rely on such earlier monitoring results to satisfy the requirements of paragraph (d)(4)(i) of this section if the sampling and analytical methods meet the accuracy and confidence levels of paragraph (d)(9) of this section. 1926.62(d)(7) Additional exposure assessments. Whenever there has been a change of equipment, process, control, personnel or a new task has been initiated that may result in additional employees being exposed to lead at or above the action level or may result in employees already exposed at or above the action level being exposed above the PEL, the employer shall conduct additional monitoring in accordance with this paragraph.
Control Priorities:
1. Recognize – (STOP WORK) immediately.
2. Control Area – establish a CAZ (Control Access Zone).
3. Report to supervisor for the following actions to be completed:
Evaluation – preliminary and, if positive, requirement of an official assessment
Establishment of a written plan for abatement if lead hazard is confirmed
4. Follow all SOPs to the absolute listed procedure if you are involved with the task.
5. Assure clean-up and help with documented testing as directed.
6. If instructed, assist with a documented chain of custody for disposal.
7. Monitor yourself for symptoms.
What You Need to Know About Lead Exposure
Here are important Do’s to keep in mind when working with lead:
- Do treat it the same as you would with asbestos exposure and abatement.
- Do report and investigate suspected materials – initial test can be performed with kit from Home Depot/Lowes/local hardware store. If positive Stop Work insist that an exposure assessment be performed – it is required 1926.62(d)(2)(v).
- Do work with a lead team leader for guiding and monitoring exposure and controls.
- Do remove lead dust from surfaces through wet cleaning methods, including damp mopping or wiping, and use a HEPA-filtered vacuum to pick up any remaining dust and particles.
- Do follow an established plan to avoid exposure to raw lead (windows, lead drywall, and lead sheets).
- Do wear a tyvek suite, N95 mask, gloves, and safety glasses or goggles. 1926.62(d)(2)(v)(B)
- Do abstain from exposing food, drink, and tobacco in areas with lead exposure.
- Do utilize the required recon area for changing and disposing of PPE and clothing.
- Do wash with soap and use individual disposable towels. 1926.62(d)(2)(v)(C)
Here are important Don’ts to keep in mind when working with lead:
- Don’t guess on exposure content.
- Don’t minimize it as only a small amount.
- Don’t expose to heat.
- Don’t breathe dust or fumes or touch any quantity with your unprotected skin.
- Don’t touch anything with contaminated clothing, ex: food, drinks, or tobacco.
- Don’t touch your mouth or eyes with contaminated clothing or exposed skin.
- Don’t ignore required PPE.
- Don’t wear any clothing home that has been exposed to lead. Children are up to 5 times more susceptible to lead poisoning.
- Don’t take any amount home for personal recycling.
If You Have Any Symptoms of Lead Poisoning Report to Your Supervisor and Seek a Medical Evaluation:
- Symptoms include but are not limited to: headaches, stomach cramps, constipation, muscle/joint pain, trouble sleeping, fatigue, and irritability.
- Seek medical attention immediately for a professional evaluation.
- Report to you supervisor and the SRMS team.
