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OSHA Lead in Construction Standard

Effective 03 Jun 93, Michigan (MIOSHA) Implementation 18 Oct 93.

Applies to "all construction work " where lead or materials containing lead are present.

  • AL (Action Level) = 30 ug/m3 (micrograms per cubic meter) as 8 hour Time-Weighted Average (TWA) without a respirator.
  • PEL (Permissible Exposure Limit) = 50 ug/m3 as 8 hour TWA, again without a respirator. For exposures longer than 8 hours in one day, the limit is reduced to [400 divided by hours worked].

Definition of LBP = 1.0 mg/cm2, but the requirements apply even if lesser amounts of lead are in the paint. The employer is responsible for assuring that the requirements are met. This can be done by air monitoring (not practical except for large commercial projects), or through a Negative Exposure Assessment (NEA). Here's how an NEA works:

IF experience has shown that performing "Work Practice A" on a surface with X mg/cm2 lead produces an airborne lead level of Y ug/m3,

THEN doing the same work on a surface with Z mg/cm2 lead should produce proportionately more or less airborne lead, i.e. (Z / X) * Y ug/m3.

The National Association of Homebuilders and others have data that may be useful, but be warned that an NEA is only valid if your work practices are identical to those used in compiling the data, and that the burden of proof is on you, the employer. OSHA expects you to hire an industrial hygienist to perform measurements on your own crews.

Presumption that PEL (and therefore AL also) is exceeded if LBP is present:

  • Manual demolition
  • Manual scraping/sanding
  • Heat guns
  • Power tool cleaning

If a worker is ever exposed to the AL, employer must provide:

  • Annual training
  • Medical surveillance
  • Recordkeeping

Until/unless employer proves that PEL is not exceeded, employer must provide:

  • Free respiratory protection (note: elaborate rules!)
  • Free protective clothing at least once/week
  • Clothes changing area
  • Handwash facilities, and shower "if feasible"
  • A competent person making frequent inspections
  • Signs
  • Written compliance plan

Employer must use all feasible engineering, administrative and work practice controls to hold exposure below the PEL. Employer must also "assure" the following employee actions:

  • Wash hands before eating, drinking, smoking or applying cosmetics
  • Stay out of lunch areas while wearing protective clothing/equipment
  • Wash hands and face at end of shift

Mandatory housekeeping measures:

  • Keep all surfaces as free of lead dust as practicable
  • Cleanup floors by vacuuming "or other methods that minimize airborne dust

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