Safety Tidbit #2.25 - Lead Control

Safety Tidbit #2.25 – Lead Control

Sources:           OSHA Lead Control Standard 1910.1025

OSHA’s Standard on Lead came about in 1996. Just about since that time they have had a National Emphasis Program to gain access to work sites to enforce this standard. The national emphasis program persists to this day. First, lead is not very prevalent in the workplace anymore. However, if it identified a few initial items must be in place. Let’s review the basics that must be in place once you have identified that lead is present

1. The employer shall assure that no employee is exposed to lead at concentrations greater than fifty micrograms per cubic meter of air (50 µg/m³) averaged over an 8-hour period. [1910.1025(c)(1)]

2. Monitoring for the initial determination may be limited to a representative sample of the exposed employees who the employer reasonably believes are exposed to the greatest airborne concentrations of lead in the workplace. [1910.1025(d)(3)(ii)]

3. If workers are exposed to lead above the PEL for more than 30 days per year exposures must be reduced using engineering and administrative controls. [1910.1025(e)(1)(i)] However, prudently I recommend reducing to below the Action Level (0.030 mg/m3) and always reduce the exposure even if it’s for less than 30 days per year.

4. Anytime the exposure is above 50 µg/m³ (the PEL and prudently the action level 30 µg/m³) you need to supplement any controls with respiratory protection. [1910.1025(e)(2)] This means implementing a whole respiratory protection program. Yes, more standards to follow!

Next is the real kicker.

5. If you have the lead exposure you must establish and implement a written compliance program to reduce exposures to or below the permissible exposure limit, and interim levels if applicable, solely using engineering and work practice controls. [1910.1025(e)(3)(i)]

The Written must include at least the following:

·       A description of each operation in which lead is emitted; e.g. machinery used, material processed, controls in place, crew size, employee job responsibilities, operating procedures and maintenance practices;

·       A description of the specific means that will be employed to achieve compliance, including engineering plans and studies used to determine methods selected for controlling exposure to lead;

·       A report of the technology considered in meeting the permissible exposure limit;

·       Air monitoring data which documents the source of lead emissions;

·       A detailed schedule for implementation of the program, including documentation such as copies of purchase orders for equipment, construction contracts, etc.;

·       A work practice program which includes items required under paragraphs (g), (h) and (i) of this regulation;

·       An administrative control schedule required by paragraph (e)(6), if applicable;

·       Written programs shall be submitted upon request to the Assistant Secretary and the Director and shall be available at the worksite for examination and copying by the Assistant Secretary, Director, any affected employee or authorized employee representatives.

·       Written programs must be revised and updated at least annually to reflect the current status of the program. This part is often neglected.

When ventilation is used to control exposure, measurements which demonstrate the effectiveness of the system in controlling exposure, such as capture velocity, duct velocity, or static pressure shall be made at least every 3 months. [1910.1025(c)(4)(i)] You know, once you put ventilation in place and quantitatively document that it is effectively controlling exposure to below the PEL (and really the Action Level and for more safety-minded companies below 10% of the PEL) a Magnehelic gauge can be installed for continual monitoring. This will exceed the every 3-months monitoring required by this section.

Hope this was helpful and thanks for reading my Safety Tidbits ~ Bryan