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OSHA Lead in Construction Advisor

GENERAL/BACKGROUND

What is OSHA's Interim Final Standard for Lead in Construction?

On May 4, 1993, OSHA published an interim final rule governing occupational exposure to lead in the construction industry (58 FR 26590). This standard is designed to reduce the risks from exposure to lead.

The Lead in Construction Standard limits worker exposures to 50 micrograms of lead per cubic meter of air averaged over an eight-hour workday (50ug/m3).

Why is lead in construction subject to regulation?

Lead is a cumulative and persistent toxic substance that poses a serious health risk. Lead has been poisoning workers for thousands of years. One of the oldest known occupational hazards, hundreds of years ago it was recognized that lead was harmful when inhaled or ingested. The absorption of excessive quantities of lead may cause diseases of the kidney, as well as of the peripheral and central nervous systems.

The effects of lead on the nervous system range from mild behavioral symptoms to fatal brain damage. Lead exposure also can result in impotence and sterility in men as well as decreased fertility in women. If proper workplace hygiene practices are not followed, the lead on workers! Clothing may expose their families at home.

Traditionally in the construction industry, most over-exposures to lead have been found in the trades, such as plumbing, welding and painting.

In building construction, lead is frequently used for roofs, cornices, tank linings and electrical conduits. In plumbing, soft solder, used chiefly for soldering tinplate and copper pipe joints, is an alloy of lead and tin. Soft solder, in fact, has been banned for many uses in the United States. The use of lead-based paint in residential application also has been banned by the Consumer Product Safety Commission. However, since lead-based paint inhibits the rusting and corrosion of iron and steel, it is still used on bridges, railways, ships, lighthouses and other steel structures, although substitute coatings are available.

Significant lead exposures also can arise from removing paint from surfaces previously coated with lead-based paint, such as in bridge repair, residential renovation and demolition. With the increase in highway work, including bridge repair, residential lead abatement and residential remodeling, the potential for exposure to lead-based paint has become more common. Certain trades or "jobs" potentially exposed to lead include iron work, demolition work, painting, lead-based paint abatement work, plumbing, heating/airconditioning, electrical work and carpentry/renovation/remodeling.

What is the role of OSHA?

OSHA was established pursuant to the Occupational Safety and Health Act of 1970 (OSH Act) to help assure safe and healthful workplaces throughout the nation. The OSH Act authorizes OSHA to promulgate safety and health standards, conduct inspections to enforce those standards, and to assist employers and employees in removing workplace hazards by offering training, education and consultative services. The OSH Act also allows states that wish to operate their own occupational safety and health programs to do so. Twenty-three states and jurisdictions administer comprehensive OSHA programs, and three other states operate OSHA programs for their public employees only.

The OSH Act applies, with certain exceptions, to most workplaces--an estimated 6.9 million establishments employing more than 105 million persons. The agency addresses not only typical workplace safety hazards, such as those associated with electrocutions and unguarded machinery, but also workplace health hazards, such as those associated with exposures to toxic substances, including asbestos, airborne chemicals and lead.

What are the benefits of regulating lead in construction?

Because exposure to lead causes a number of different adverse health effects, there are potential benefits associated with this requirement of the Standard.

OSHA expects near-term benefits to include reductions in the incidence of acute lead poisoning and adverse neurologic and biochemical effects, and reductions in the incidence of blood lead levels above 50 ug/dl. There also should be decreases in the annual number of cases of reduced nerve conduction velocity, reduced blood ALA-D levels and increased urinary ALA, which indicate reduced ability to produce blood cells, gastrointestinal disturbances, and blood lead levels above the medical removal trigger level.

Benefits that accrue over longer time horizons include reductions in the incidence of lead-induced hypertension, which may increase the risk of myocardial (fatal/nonfatal) infarction or stroke and renal disease.

Other potential benefits are expected, such as reductions in the incidence of lead-induced male and female reproductive effects. Improved hygiene practices will likely yield other benefits such as reductions in worker blood lead levels.

What are key provisions of the Standard?

Biological Monitoring and Associated Recordkeeping
Change Areas with Storage Facilities
Competent Person
Decontamination Facilities Including Showers
Determination of the Presence of Lead
Eating Areas and Facilities
Enclosures/Containment Systems
Exposure Monitoring and Associated Recordkeeping
Hand-washing Facilities Only
HEPA Vacuums
Local Exhaust Ventilation
Mechanical Ventilation
Medical Examinations and Associated Recordkeeping
Medical Removal Protection Requirements
Notification of Other Employers
Protective Clothing/Gloves/Shoe Covers
Respiratory Protection
Warning Signs
Wetting Agents
Worker Training
Written Compliance Program

Where can I find professional safety and health advice?

Sources for professional safety and health advice include insurance carriers, trade organizations, state on-site consultation programs (known as state 7(c)(1) programs) and consultants.

The OSHA Web pages on the Internet also provide sources of information and training information. The addresses for the web pages are:

What are common sources of lead exposure in construction?

In building construction, lead is frequently used for roofs, cornices, tank linings and electrical conduits. In plumbing, soft solder, used chiefly for soldering tinplate and copper pipe joints, is an alloy of lead and tin. Soft solder, in fact, has been banned for many uses in the United States. The use of lead-based paint in residential application also has been banned by the Consumer Product Safety Commission. However, since lead-based paint inhibits the rusting and corrosion of iron and steel, it is still used on bridges, railways, ships, lighthouses and other steel structures, although substitute coatings are available.

Significant lead exposures also can arise from removing paint from surfaces previously coated with lead-based paint, such as in bridge repair, residential renovation and demolition. With the increase in highway work, including bridge repair, residential lead abatement and residential remodeling, the potential for exposure to lead-based paint has become more common. The trades potentially exposed to lead include iron work, demolition work, painting, lead-based paint abatement work, plumbing, heating/airconditioning, electrical work and carpentry/renovation/remodeling. Operations that generate lead dust and fumes include the following:

  • Flame-torch cutting, welding, the use of heat guns, sanding, scraping and grinding of lead painted surfaces in repair, reconstruction, dismantling and demolition work;
  • Abrasive blasting of bridges and other structures containing lead-based paints;
  • Use of torches and heat guns, and sanding, scraping and grinding lead-based paint surfaces during remodeling or abating lead-based paint; and
  • Maintaining process equipment or exhaust duct work.

What is the responsibility of the employer with regard to establishing a lead program?

The employer of construction workers is responsible for the development and implementation of a worker protection program in accordance with 29 CFR 1926.20 and 29 CFR 1926.62.

This program is essential for minimizing worker risk of lead exposure. Construction projects vary in their scope and potential for exposing workers to lead and other hazards. Many projects may involve limited exposure, such as the removal of paint from a few interior residential doors. Others may involve the removal, or stripping off, of substantial quantities of lead-based paints on large bridges. The employer should, as needed, consult a qualified safety and health professional(*) to develop and implement an effective worker protection program. The employer must designate a Competent Person to implement the program and monitor compliance.

What is the technological feasibility of compliance with the Lead Exposure in Construction Standard?

Compliance with the PEL and ancillary provisions of the Interim Final Standard is technologically feasible for all affected industries. Existing engineering control types, including mechanical dilution, ventilation, local exhaust ventilation, shrouded tools, HEPA vacuums and wetting agents are already uses in the construction industry. Furthermore, employee rotation is permitted under the standard to achieve compliance with the PEL prior to using respirators. For the activities in which high exposures to lead are generated, however, supplemental respirator use may be necessary when engineering controls are used.

In order to analyze the technological feasibility of the Standard, data on lead exposures were examined by the type of activity generating the potential for exposure to lead. The exposure data reviewed by OSHA were obtained from the following sources: OSHA Integrated Management Information System (IMIS); various National Institute for Occupational Safety and Health (NIOSH) Health Hazard Evaluation reports; various Department of Housing and Urban Development (HUD) Lead Abatement Demonstration Projects; Maryland's Department of Occupational Safety and Health; site visits conducted by CONSAD Research (a private company) for OSHA and other published reports and studies. The exposure data obtained from each of these sources were the best available at the time the standard was being developed and are believed to be representative and reliable exposure estimates for the construction activities being examined.

What is the most effective way to protect construction workers?

The most effective way to protect workers is to minimize exposure through the use of engineering controls and good work practices. It is OSHA policy that respirators are not to be used in lieu of engineering and work practices, including administrative controls, to reduce employee exposures to below the PEL. Respirators must be used during: (1) periods when an employee's exposure to lead exceeds the PEL, (2) work operations for which engineering and work practice controls are not sufficient to reduce employee exposures to or below the PEL, and (3) periods when an employee requests a respirator.

What types of projects are likely to expose construction workers to lead?

Lead exposure is most common among project types that involve the disturbance of lead or lead-containing materials during additions, alterations, reconstruction, demolition and repairs. Some examples of potential sources of exposure in these project types include lead-based paint (LBP) and paint dust, lead pipes, leaded solder, the leaded support rods in stained glass windows and some mineral wool insulation.

In contrast, project types involving exposure to lead during new construction are comparatively rare. This is in part due to government regulations that have banned specific uses of once common lead-containing construction materials. An example is the Consumer Product Safety Commission's 1977 ban on "lead containing paint" prohibiting the use of such paint on products to which consumers are exposed after sale (42 FR44199). Another example is the Environmental Protection Agency's 1986 ban on further use of lead pipes and solder in residential plumbing.

In most new construction projects involving lead use, lead and lead-containing materials are used in limited quantities for specialized applications. Examples include terne (leaded-steel) roofing and the use of lead foil sheet in the walls of hospital x-ray suites.

What if a construction employer who has been subject to the Interim Final Lead in Construction Standard goes out of business?

The Interim Final Lead in Construction Standard requires that OSHA have access to the employer's compliance plan (1926.62(e)(2)(iv)), employee information and training records (1926.62(l)(3)(ii)), as well as the employee's medical and monitoring records (1926.62(n)(5)). If an employer ceases business operation and there is no successor employer to receive these records, the employer is required to transmit the records to the Director of the National Institute for Occupational Safety and Health as per 1926.62(n)(6)(ii).

What construction industries are likely to be affected by the Interim Final Standard for Lead Exposure in Construction?

Commercial and Institutional Remodeling, Commercial and Industrial Demolition, Electrical Cable Splicing, Elevator Cable Babbitting, Highway and Railroad Bridge Repainting, Highway and Railroad Bridge Rehabilitation Housing Lead Abatement (Private Housing), Housing Lead Abatement (Public Housing), In-place Management (Public Housing), In-place Management (Private Housing), Industrial Process Equipment Manufacturing/Maintenance/Repair, Indoor Industrial Facility Maintenance/Renovation, Industrial Vacuuming, Installation of Radiation Shielding, Installation of Terne Roofing, Lead Joint Work on Cast Iron Soil Pipes, Outdoor Industrial Facility Maintenance/Renovation, Petroleum Tank Repainting, Reinsulation Over Existing Mineral Wool, Repair and Removal of Water Lines, Residential Remodeling, Stained Glass Window Removal, Transmission and Communication Tower Maintenance, Underground Storage Tank Demolition, Water Tank Repainting

What are the key elements of an employer's required written worker protection program for employees exposed to lead above the PEL?

At the minimum, the following elements must be included in the employer's worker protection program for employees exposed to lead above the PEL:

  • Hazard determination, including exposure assessment;
  • Engineering and work practice controls;
  • Respiratory protection;
  • Protective clothing and equipment;
  • Housekeeping;
  • Hygiene facilities and practices;
  • Medical surveillance and provisions for medical removal;
  • Training;
  • Signs; and
  • Recordkeeping.

In addition, OSHA requires that the employer designate a competent person to implement the program and monitor compliance.

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OSHA | OSHA Lead in Construction Advisor
UNITED STATES
DEPARTMENT OF LABOR