OSHA Lead in Construction Advisor

Glossary

ABATEMENT

Abatement includes measures that put an employer in compliance with OSHA requirements.

In the lead-control industry, lead abatement means any set of measures designed to permanently eliminate lead-based paint hazards.

This includes:

(a) the removal of lead-based paint and lead-contaminated dust, the permanent containment or encapsulation of lead-based paint, the replacement of lead-based painted surfaces or fixtures, and the removal or covering of lead-contaminated soil; and

(b) all preparation, cleanup, disposal and post abatement clearance testing activities associated with such measures.

ABRASIVE BLASTING

Abrasive blasting refers to the use of any of a variety of abrasives delivered under pressure to remove rust, scale, dirt and paint from surfaces. Typical abrasives used include sand, steel grit, steel shot, aluminum oxide and "Black Beauty".

OSHA has determined that workers performing abrasive blasting may be exposed to airborne lead levels which exceed the PEL. Until an exposure assessment is completed, workers must be treated as if they were exposed to OVER 2,500 ug/m3 of lead as an 8-hour time-weighted average and be given:

1. Appropriate respirators
2. Appropriate personal protective clothing and equipment
3. Change areas
4. Hand-washing facilities
5. Biological monitoring
6. Training

ACCSH

ACCSH is an abbreviation for OSHA's Advisory Committee on Construction Safety and Health.

ACTION LEVEL (AL)

The "action level" is an airborne lead level which triggers employer actions to comply with the Lead in Construction Standard. The Lead in Construction standard's action level is 30 ug/m3 (micrograms per cubic meter of air) calculated as an 8-hour time-weighted average.

The use of an action level permits employers to focus compliance resources on employees performing tasks associated with the potential for high lead exposures.

ADMINISTRATIVE CONTROLS

Administrative controls include employee rotation. If the employer chooses to use employee rotation to reduce employee exposure, he must include the rotation schedule as part of the written compliance plan.

AIR MONITORING

Air monitoring is the process of collecting samples of air in order to determine the concentration of contaminants in the air. Worker exposure is best determined by collecting personal samples. The Occupational Safety and Health Administration (OSHA) requires monitoring to be done using personal samples. Area sampling may provide information on environmental exposure or background exposure.

AIR MONITORING ACCURACY REQUIREMENTS

The employer must use a method of monitoring and analysis which has an accuracy (to a confidence level of 95%) of not less than plus or minus 25 percent for airborne concentrations of lead equal to or greater than 30 ug/m3.

AIR SAMPLING PUMP

An air sampling pump is a device which draws air through a collection filter to measure levels of contaminants present in air. Worker exposure is measured by collecting a sample of air from the worker's breathing zone.

Employers may purchase or rent air sampling pumps, calibration equipment and other necessary supplies from manufacturers and/or suppliers of industrial hygiene products. Employers may conduct air monitoring using their own staff or consultants. Workers who conduct air monitoring (such as those designated as "Competent Persons") should be trained in the proper use and calibration of the air sampling equipment.

ASSISTANT SECRETARY

Assistant Secretary means the Assistant Secretary of Labor for Occupational Safety and Health, U.S. Department of Labor or designee.

ATOMIC ABSORPTION SPECTROMETRY

A laboratory analytical method for bulk samples which determines the percent of lead in paint chips, dust samples, soil and water. The results are reported in parts per million (ppm) and/or in % lead for amount of material tested.

BIOLOGICAL MONITORING

Biological monitoring refers to blood lead and zinc protoporphyrin (ZPP) level [or free erythroyte protoporphyrin (FEP)] sampling and analysis. The employer must make available biological monitoring in the form of blood sampling and analysis for lead and ZPP (or FEP) levels to each employee covered.

BREATHING ZONE

The breathing zone is within a ten inch radius of the worker's nose and mouth. OSHA requires that worker exposure monitoring air samples be collected in the breathing zone. Air sampling filters may be attached to the collar or lapel.

Worker exposure monitoring air samples must always be collected outside of any respiratory protection equipment. Samples must be collected outside of respirators to determine the level of exposure and consequent level of protection that the employer must implement.

BUILDING/FACILITY OWNER

The legal entity that controls the management and recordkeeping functions relating to a building in which activities covered by this standard take place.

CERTIFIED INDUSTRIAL HYGIENIST (CIH)

A Certified Industrial Hygienist is a professional Industrial Hygienist who has been certified in the comprehensive practice of industrial hygiene by the American Board of Industrial Hygiene.

CIH

CIH is an abbreviation for Certified Industrial Hygienist.

CLEANUP WHERE DRY EXPENDABLE ABRASIVES ARE USED

OSHA has determined that workers performing cleanup where dry expendable abrasives are used may be exposed to airborne lead levels which exceed the PEL. Until an exposure assessment is completed, workers must be treated as if they were exposed to more than 500 ug/m3 of lead as an 8-hour time-weighted average and be given:

1. Appropriate respirators
2. Appropriate personal protective clothing and equipment
3. Change areas
4. Hand-washing facilities
5. Biological monitoring
6. Training

COMPETENT PERSON

The employer is responsible for designating a "competent person".

A competent person is capable of identifying existing and predictable lead hazards in the surroundings or working conditions

In addition, the competent person must have the authorization to take prompt corrective measures to eliminate such problems.

Compliance programs, which employers must develop under the Lead in Construction Standard, must provide that the competent person make inspections of job sites, materials and equipment.

CONDITIONS SUFFICIENTLY SIMILAR TO CURRENT CONDITIONS

Historical data must have been collected under conditions sufficiently similar to current conditions. These conditions are as follows:

1. The data upon which employee exposure assessments are based are scientifically sound and collected using methods that are sufficiently accurate and precise.
2. The processes and work practices in use when the historical data were obtained are essentially the same as those to be used during the job.
3. The characteristics of the lead containing material being handled when the historical data were obtained are essentially the same as those of the job.
4. Environmental conditions prevailing when the historical data were obtained are essentially the same as those of the job.

CONSTRUCTION

Construction work is defined as work involving construction, alteration and/or repair, including painting and decorating as per 29 CFR 1910.12(b).

Construction work covered under the Lead in Construction Standard includes any repair or renovation activities.

Specifically, construction includes but is not limited to the following:

1. Demolition or salvage of structures where lead or materials containing lead are present;
2. Construction activities that involve removal or encapsulation of materials containing lead;
3. New construction, alteration, repair or renovation of structures, or significant portions thereof, that contain lead or materials containing lead (e.g., steel structure renovation and repair);
4. Installation during construction of products containing lead;
5. Lead contamination/emergency cleanup during construction;
6. Transportation, disposal, storage or containment of lead or materials containing lead on the site or location at which construction activities are performed; and
7. Maintenance operations associated with the construction activities described in items (1)-(6).

These activities do not include routine cleaning and repainting (for example, minor surface preparation and repainting of rental apartments between tenants or at scheduled intervals) where there is insignificant damage, wear or corrosion of existing lead-containing paint and coating or substrates.

Maintenance activities covered by the General Industry Standard are those which involve making or keeping a structure, fixture or foundation in proper condition in a routine, scheduled, or anticipated fashion.

The three major divisions of the construction industry are identified by two-digit Standard Industrial Classification (SIC) codes: SIC 15, General Building Contractors; SIC 16, Heavy Construction Contractors, Excluding Building Contractors; and SIC 17, Special Trade Contractors.

CONSUMER PRODUCT SAFETY COMMISSION

The Consumer Product Safety Commission regulates the content of lead in paint used for residential painting purposes. This level has been set at .06% by weight.

CONTROLS

Engineering controls include:

• local and general exhaust ventilation;
• enclosure/encapsulation;
• process and equipment modification;
• material substitution;
• component replacement with new components; and
• isolation or automation.

Administrative controls include employee rotation.

If administrative controls are used as a means of reducing employees TWA exposure to lead, the employer must establish and implement a job rotation schedule which includes:

1. Name or identification number of each affected employee;
2. Duration and exposure levels at each job or work station where each affected employee is located; and
3. Any other information which may be useful in assessing the reliability of administrative controls to reduce exposure to lead.

If the employer chooses to use employee rotation to reduce employee exposure, he or she must include the rotation schedule as part of the written compliance plan.

CP

CP is an abbreviation for competent person.

CUTTING

Cutting typically involves use of an oxyacetylene torch. Workers use torches to soften steel prior to removing old rivets or to cut beams into smaller sections.

OSHA has determined that workers performing cutting on structures where lead-based paint or coatings are present may be exposed to airborne lead levels which exceed the PEL. Until an exposure assessment is completed, workers must be treated as if they were exposed OVER 2,500 ug/m3 of lead as an 8-hour TWA and be given:

1. Appropriate respirators
2. Appropriate personal protective clothing and equipment
3. Change areas
4. Hand-washing facilities
5. Biological monitoring
6. Training

DEMOLITION

Demolition refers to construction activities that involve dismantling, razing, or wrecking activities, and to demolition activities during rehabilitation, repair, or remodeling where structural members of the structure are not removed.

DIRECTOR

Director means the Director, National Institute for Occupational Safety and Health (NIOSH), U.S. Department of Health and Human Services, or designee.

EFFECTIVE DATE

The effective date of the interim final standard for Lead Exposure in Construction was June 3, 1993.

EMPLOYEE INFORMATION AND TRAINING

Employers must provide an information and training program for all employees exposed to lead at or above the action level or subject to exposure to lead compounds which may cause skin or eye irritation (e.g., lead arsenate, lead oxide). The employer must inform the employee of the specific hazards associated with his or her work environment, protective measures which can be taken, and his or her rights under the Standard.

Training must include the following:

1. content of the Standard and its appendices
2. specific nature of the operations which could result in exposure to lead above the action level
3. purpose, proper selection, fitting, use and limitations of respirators
4. purpose and a description of the medical surveillance program and medical removal protection program
5. engineering controls and work practices associated with the employee's job assignment, including training of employees to follow relevant good work practices
6. contents of any compliance plan in effect
7. instructions to employees that chelating agents should not be used routinely to remove lead from their bodies
8. employee's right of access to records under 29 CFR 1910.1020 [(1)(2)(i)-(viii)]
9. hazard communication information

EMPLOYEE NOTIFICATION

Within 5 working days after receipt of the results of the exposure assessment, the employer must notify each employee in writing of the results which represent that employee's exposure. In addition, whenever the results indicate exposure at or above the PEL, the employer must include in the written notice a statement that the employee's exposure was at or above that level and a description of the corrective action taken or to be taken to reduce the exposure below the PEL.

EMPLOYEES

Employees include all persons who work at the work/job site and who are subject to the direction of the employer regarding schedule, methods and materials. Wage status and tax status are not the determining factors. Persons who may be considered to be independent contractors for tax purposes may be employees for OSHA purposes.

ENGINEERING AND WORK PRACTICE CONTROLS

OSHA requires employers to use all feasible engineering controls and work practice controls, including administrative controls, prior to implementing respiratory protection. Feasible engineering controls are those suitable on the basis of such factors as site conditions, scale of the job, and their effectiveness.

Additional considerations include (but are not limited to): work area dimensions, ventilation positioning and airflow, crew size, tools and application or removal methods, containment, wet methods, and duration of the work shift.

EXPOSURE ASSESSMENT

Each employer who has a workplace or work operation covered by this standard, is required to conduct an exposure assessment to determine if any employees may be exposed at or above the action level of 30 ug/m3 measured as an 8-hour TWA. The employer must conduct an initial exposure assessment of all workplaces and operations where lead or lead-containing materials are being used, disturbed or removed. Exposure assessments must meet the requirements of 1926.62(d)(1)(i-iv).

An exposure assessment also considers other information, including levels of worker training, supervision and previous monitoring results. A conclusion that the planned work will not exceed the PELs and will be conducted under situations closely resembling other similar jobs is called a negative exposure assessment. While this exposure assessment is conducted, the employer must assume that exposures exceed the PELs and use appropriate control methods. The assessment must be completed in time to provide information necessary to assure that all controls planned for the work start-up are appropriate for that operation and will work properly.

EXPOSURES ABOVE THE PEL

If the initial determination reveals that employee exposure is above the PEL, the employer must perform monitoring quarterly.

Exposures above the PEL require implementation of feasible engineering and work practice controls, and provision of personal protective equipment and hygiene facilities supplemented by the use of respirators, if necessary, to reduce exposures to below 50 ug/m3.

For employees exposed above the action level of 30 ug/m3, see EXPOSURES AT OR ABOVE THE ACTION LEVEL.

EXPOSURES AT OR ABOVE THE ACTION LEVEL, BUT AT OR BELOW THE PEL

If the initial determination or subsequent determination reveals employee exposure to be at or above the action level, but at or below the PEL, the employer must perform monitoring at least every 6 months.

For employees exposed at or above the action level of 30 ug/m3 for more than 30 days per 12 consecutive months, employers must provide biological monitoring. Additional medical examinations are required for those with elevated blood-lead levels, and, upon development of signs of lead intoxication, for employees exposed above the action level. Exposures at or above the action level also require implementation of exposure monitoring and training.

HEAT GUN APPLICATIONS

Heat gun applications involve the use of a heat gun that produces a stream of hot air which is directed toward a painted surface to soften and blister the paint. The paint is then scraped off.

OSHA has determined that workers using heat guns on lead-painted surfaces may be exposed to airborne lead levels which exceed the PEL. Until an exposure assessment has been completed, workers must be treated as though they were exposed to between 51 and 500 ug/m3 of lead as an 8-hour TWA and be provided with:

1. Half-mask air purifying respirators with high efficiency filters or half-mask supplied air respirators operated in demand (negative pressure) mode
2. Appropriate personal protective clothing and equipment
3. Change areas
4. Hand-washing facilities
5. Biological monitoring
6. Training

HEPA FILTERS

High-efficiency particulate air (HEPA) filters are capable of trapping and retaining at least 99.97 percent of particles in the air that are greater than or equal to 0.3 micrometers in diameter.

This type of filter is used in respirators, HEPA vacuums, and other air filtering devices.

HEPA VACUUM

A vacuum cleaner equipped with HEPA filters.

HISTORICAL DATA

Historical data refers to actual employee monitoring data collected within the last 12 months. The employer must have performed an exposure assessment using these data.

See OBJECTIVE DATA.

HOUSEKEEPING ACTIVITIES

These activities include cleanup of floors and other surfaces where lead accumulates. Where possible, employeers must use vacuuming or other equally effective methods such as wet floor scrubbers to clean surfaces on which dust accumulates. Where an employer uses vacuums, the vacuums must be equipped with HEPA filters. Blowing with compressed air is generally prohibited as a cleaning method, unless the compressed air is used in conjunction with a ventilation system designed to capture the airborne dust created by the compressed air.

HUD

The Department of Housing and Urban Development. HUD has published guidelines for the testing and risk assessment of lead in housing, aimed toward reducing lead poisoning primarily in children and women of child-bearing age.

INDICATIONS OF EMPLOYEE EXPOSURE TO LEAD

Symptoms of chronic overexposure to lead include loss of appetite, metallic taste in the mouth, anxiety, constipation, nausea, pallor, excessive tiredness, weakness, insomnia, headache, nervous irritability, muscle and joint pain or soreness, fine tremors, numbness, dizziness, hyperactivity and colic. In lead colic, there may be severe abdominal pain.

Damage to the central nervous system in general and the brain (encephalopathy) in particular is one of the most severe forms of lead poisoning. The most severe, often fatal, form of encephalopathy may be preceded by vomiting, a feeling of dullness progressing to drowsiness and stupor, poor memory, restlessness, irritability, tremor and convulsions. It may arise suddenly with the onset of seizures, followed by coma and death. There is a tendency for muscular weakness to develop at the same time. This weakness may progress to paralysis often observed as a characteristic "wrist drop" or "foot drop" and is a manifestation of a disease to the nervous system called peripheral neuropathy.

Chronic overexposure to lead also results in kidney disease with few, if any, symptoms appearing until extensive and most likely permanent kidney damage has occurred. Routine laboratory tests reveal the presence of this kidney disease only after about two-thirds of kidney function is lost. When overt symptoms of urinary dysfunction arise, it often is too late to correct or prevent worsening conditions, and progression to kidney dialysis or death is possible.

Chronic overexposure to lead impairs the reproductive systems of both men and women. Overexposure to lead may result in decreased sex drive, impotence and sterility in men. Lead can alter the structure of sperm cells, thus raising the risk of birth defects. There is evidence of miscarriage and stillbirth in women whose husbands were exposed to lead or who were exposed to lead themselves. Lead exposure also may result in decreased fertility and abnormal menstrual cycles in women. The course of pregnancy may be adversely affected by exposure to lead, since lead crosses the placental barrier and poses risks to developing fetuses. Children born of parents either one of whom were exposed to excess lead levels are more likely to have birth defects, mental retardation and behavioral disorders or die during the first year of childhood.

Overexposure to lead also disrupts the blood-forming system resulting in decreased hemoglobin (the substance in the blood that carries oxygen to the cells) and ultimately anemia. Anemia is characterized by weakness, pallor and fatigue as a result of decreased oxygen-carrying capacity in the blood.

Source:
1926.62 App A - Substance Data Sheet for Occupational Exposure to Lead

INDUSTRIAL HYGIENIST

This is a professional qualified by education, training, and experience to anticipate, recognize, evaluate and develop controls for occupational health hazards.

INITIAL DETERMINATION

Each employer who has a workplace or operation covered by the Lead in Construction Standard must make an initial determination concerning whether any employee may be exposed to lead at or above the action level.

Employee exposure levels must be determined based on full-shift, personal air monitoring samples.

Each full-shift personal sample collected must be representative of the regular daily exposure pattern of the employee being monitored.

The Lead in Construction Standard defines employee exposure as that exposure that would occur if the employee were not wearing a respirator. You are not permitted to adjust air monitoring data to account for the protection provided by respirators when determining whether employees are exposed to airborne lead.

INTERIM CONTROLS

The term interim controls means a set of measures designed to reduce temporarily human exposure or likely exposure to lead-based paint hazards. Interim controls include specialized cleaning, repairs, maintenance, painting, temporary containment, ongoing monitoring of lead-based paint hazards or potential hazards, and the establishment and operation of management and resident education programs.

INTERIM PROTECTIVE MEASURES

In many instances in the construction industry, the exposure assessment required under the Standard may not be completed until after lead operations have begun or even ended. The need for interim protective measures is, therefore, presumed for three groups of high exposure or lead-related tasks/operations. These three task groupings also are referred to as "trigger tasks". Interim protective measures include provision of respirators, protective clothing and equipment, hygiene facilities, training and biological monitoring.

JOB SITE

Location at which construction activities will be performed by employees.

LEAD

Lead means metallic lead, all inorganic lead compounds and organic lead soaps. Excluded from this definition are all other organic lead compounds.

LEAD-BASED PAINT

Paints which contain lead are lead-based paint. The American Society for Testing Materials defines lead paint as paint containing 2 parts per million of lead. The Consumer Products Safety Commission determined that paint with greater than 600 parts per million of lead may not be used in household applications. Such paint is still sold for marine and other uses. HUD defines lead paint as having greater than 1 microgram per square centimeter of surface or 0.5% by weight. OSHA does not define lead paint based on content. Any detectable lead in a paint makes it lead paint for purposes of complying with OSHA regulations to determine worker exposure.

LEAD BURNING

Lead burning involves torch melting or fusing of lead or alloyed lead to another lead object.

OSHA has determined that workers performing lead burning may be exposed to airborne lead levels which exceed the PEL. Until an exposure assessment is completed, employers must treat workers as if they were exposed to more than 500 ug/m3 of lead as an 8-hour TWA and provide them:

1. Appropriate respirators
2. Appropriate personal protective clothing and equipment
3. Change areas
4. Hand-washing facilities
5. Biological monitoring
6. Training

Lead-containing materials are any materials which contain lead. There is no minimum concentration required.

MAINTENANCE

Maintenance activities not associated with construction work are covered by the General Industry Standard for lead, 29 CFR 1910.1025 instead of the Lead in Construction Standard. Maintenance activities covered by the General Industry Standard are those which involve making or keeping a structure, fixture or foundation in proper condition in a routine, scheduled or anticipated fashion.

Maintenance includes routine cleaning and repainting (e.g., minor surface preparation and repainting of rental apartments between tenants or at scheduled intervals) where there is insignificant damage, wear or corrosion of existing lead-containing paint and coatings or substrates. Construction work that is not considered maintenance includes any repair or renovation activities.

MAINTENANCE WORKERS

Workers engaged in maintenance activities. See MAINTENANCE.

MANUAL DEMOLITION

Manual demolition refers to dismantling, razing or wrecking activities, and repair, or remodeling where structural members of the structure are not removed. (This definition is based on the American National Standards Institute A10.6-1990 standard which defines "demolition" as dismantling, razing, or wrecking any fixed building or structure or any part thereof.)

OSHA has determined that workers performing manual demolition on lead painted structures may be exposed to airborne lead levels which exceed the PEL. Until an exposure assessment has been completed, employers must treat workers as though they were exposed above the PEL and not in excess of 500 ug/m3 of lead as an 8-hour TWA and provide them:

1. Half-mask air purifying respirators with high efficiency filters or half-mask supplied air respirators operated in demand (negative pressure) mode
2. Appropriate personal protective clothing and equipment
3. Change areas
4. Hand-washing facilities
5. Biological monitoring
6. Training

MANUAL SANDING

Manual sanding tasks are those which involve dry sanding. OSHA has determined that workers performing dry manual sanding on lead-painted surfaces may be exposed to airborne lead levels which exceed the PEL. Until an exposure assessment has been completed, employers must treat workers as though they were exposed above the PEL and not in excess of 500 ug/m3 of lead as an 8-hour TWA and provide them:

1. Half-mask air purifying respirators with high efficiency filters or half-mask supplied air respirators operated in demand (negative pressure) mode
2. Appropriate personal protective clothing and equipment
3. Change areas
4. Hand-washing facilities
5. Biological monitoring
6. Training

Manual sanding and manual scraping refers to dry sanding and dry scraping. Where wet methods are used, the employer may base the protection provided on the results of the initial exposure assessment, without having to provide interim protection.

MANUAL SCRAPING

Dry manual scraping involves the use of hand-held scraping tools on dry painted surfaces containing lead.

OSHA has determined that workers performing dry manual scraping on lead painted surfaces may be exposed to airborne lead levels which exceed the PEL. Until an exposure assessment has been completed, employers must treat workers as though they were exposed above the PEL and not in excess of 500 ug/m3 of lead as an 8-hour TWA and provide them:

1. Half-mask air purifying respirators with high efficiency filters or half-mask supplied air respirators operated in demand (negative pressure) mode
2. Appropriate personal protective clothing and equipment
3. Change areas
4. Hand-washing facilities
5. Biological monitoring
6. Training

Manual sanding and manual scraping refers to dry sanding and dry scraping. Where wet methods are used, the employer may base the protection provided on the results of the initial exposure assessment, without having to provide interim protection.

MEDICAL REMOVAL

The Lead in Construction Standard requires that a result of 50ug/dl (micrograms per deciliter) or more on two consecutive blood lead tests requires temporary medical removal of the employee and compensation with medical removal protection benefits (MRPB). Employers are not permitted to average blood lead test results to determine eligibility for medical removal.

MEDICAL SURVEILLANCE

A medical surveillance program involves biological monitoring and medical examinations and consultations.

Biological monitoring, in the form of blood sampling and analysis for lead and zinc protoporphyrin levels, must be made available to employees exposed on any day to lead at or above the action level.

Medical surveillance must be made available no later than the 31st day of performing work where employee exposures are at or above the action level within that period. Where the employer anticipates employee exposure at or above the action level, the medical surveillance program should include a pre-assignment medical examination consistent with the requirements of Appendix C of 29 CFR 1926.62 and 29 CFR 1910.1025. The employer must establish and maintain an accurate record for each employee subject to medical surveillance as required by the Standard. This record must include:

• The employee's name, social security number and description of duties;
• A copy of the physician's written opinions;
• Results of any airborne exposure monitoring done on or for that employee and provided to the physician; and
• Any employee medical complaints related to lead exposure.

The employer must keep, or ensure that the examining physician keeps, the following medical records:

• A copy of the medical examination results including medical and work history;
• A description of the laboratory procedures and a copy of any standards or guidelines used to interpret the test results or references to that information; and
• A copy of the results of biological monitoring.

METHODS OF COMPLIANCE

The employer must institute engineering and work practice controls, including administrative controls, to the extent feasible to reduce exposures to or below the PEL. OSHA requires that feasible engineering and work practice controls must be instituted before being supplemented with respiratory protection where controls are not sufficient to reduce exposures to or below the PEL.

MOVEMENT AND REMOVAL OF ABRASIVE BLASTING ENCLOSURES

Abrasive blasting enclosure movement and removal involves the movement and removal of blasting enclosure and containment units that are typically made of flexible nylon, plastic or burlap tarpaulins. Lead dust may accumulate on these tarpaulins and be disturbed when the tarpaulins are moved.

OSHA has determined that workers performing abrasive blasting enclosure movement and removal may be exposed to airborne lead levels which exceed the PEL. Until an exposure assessment is completed, the employer must treat workers as if they were exposed to more than 500 ug/m3 of lead as an 8-hour TWA and provide them:

1. Appropriate respirators
2. Appropriate personal protective clothing and equipment
3. Change areas
4. Hand-washing facilities
5. Biological monitoring
6. Training

MRPB

MRPB is an abbreviation for Medical Removal Protection Benefits.

MULTI-EMPLOYER WORKSITE

This means a worksite where several employers, each with their own employees, are working.

NEGATIVE EXPOSURE ASSESSMENT

A valid exposure assessment which concludes that the work covered by the Lead in Construction standard is unlikely to result in exposures that reach or exceed the action level (AL) is called a negative exposure assessment. It demonstrates that the planned work activity is unlikely, under all foreseeable conditions, to result in exposures at or above the AL. When a negative exposure assessment is made, there is no need for further air monitoring, protective work clothing or respirators.

For any specific lead-exposed job, the employer may assess employee exposures by using data which conform to one of the following criteria:

1. Objective monitoring data that demonstrate the work being performed cannot release airborne lead in concentrations above the AL under work conditions closely resembling current conditions;
2. Results of the initial monitoring data of the current job obtained from 8-hour TWA breathing zone air samples. These monitoring data must cover those operations which are most likely, during the performance of the entire job, to result in exposures at or above the AL; or
3. The employer has monitored similar jobs during the past 12 months and the results have shown that exposures were below the AL. The jobs monitored must closely resemble workplace conditions, the level of training and supervision, process, type of material, control methods, work practices and environmental conditions prevailing in the employer's current operations.

NIOSH is an abbreviation for the National Institute of Occupational Safety and Health, an agency within the U.S. Department of Health and Human Services.

NOTIFICATION

see EMPLOYEE NOTIFICATION.

OBJECTIVE DATA

Objective data are data which demonstrate that a particular product or material containing lead or a specific process, operation or activity involving lead, cannot result in employee exposure to lead, at or above the action level during processing, use or handling under any expected conditions of use.

If an employer chooses to rely on objective data, rather than perform initial monitoring, the employer must establish and maintain a record documenting the nature and relevancy of the objective data. Certain specific tasks, the high exposure or "trigger tasks," are treated differently.

see also RECORDKEEPING.

OBSERVATION OF MONITORING

The employer must provide employees or their representatives with the opportunity to observe monitoring of employee exposures to lead. Observers are entitled to an explanation of the measurement procedure, to observe all steps related to the measurement procedure, and to record the results obtained.

OSHA

OSHA is the abbreviation for the Occupational Safety and Health Administration, an agency of the U.S. Department of Labor.

PAPR

PAPR is an abbreviation for powered air-purifying respirators. Employees required to wear respirators can obtain a powered air-purifying respirator, upon request, if such a respirator provides adequate protection.

PEL

PEL is the abbreviation for the Permissible Exposure Limit.

PERMISSIBLE EXPOSURE LIMIT

The Permissible Exposure Limit (PEL) for lead in construction is an airborne concentration of fifty micrograms of lead per cubic meter of air (50ug/m3) as an 8-hour time-weighted average (TWA). This PEL is the same as the PEL provided for in OSHA's General Industry Lead Standard (29 CFR 1910.1025). The PEL is an eight-hour average of exposure for any work day.

PF

PF is an abbreviation for Protection Factor.

POWER TOOL CLEANING USING DUST COLLECTION SYSTEMS

OSHA has determined that workers performing power tool cleaning with dust collection systems on lead painted structures may be exposed to airborne lead levels which exceed the PEL. Until an exposure assessment has been completed, the employer must treat workers as though they were exposed above the PEL and not in excess of 500 ug/m3 of lead as an 8-hour TWA and provide them:

1. Half-mask air purifying respirators with high efficiency filters or half-mask supplied air respirators operated in demand (negative pressure) mode
2. Appropriate personal protective clothing and equipment
3. Change areas
4. Hand-washing facilities
5. Biological monitoring
6. Training

OSHA has determined that workers using power tools without dust collection systems may be exposed to airborne lead levels which exceed the PEL. Until an exposure assessment is completed, the employer must treat workers as if they were exposed to more than 500 ug/m3 of lead as an 8-hour TWA and provide them:

1. Appropriate respirators
2. Appropriate personal protective clothing and equipment
3. Change areas
4. Hand-washing facilities
5. Biological monitoring
6. Training

The employer must privide powered air-purifying respirators (PAPRs) to employees who request them. Where respirators are required, the PAPR provides adequate protection.

PPE

PPE is an abbreviation for Personal Protective Equipment and includes Protective Work Clothing.

PROCESSES

Work area dimensions, containment, wet methods, crew size, tools and application or removal methods.

PROTECTIVE WORK CLOTHING

Protective work clothing and equipment used on construction sites can include:

• coveralls or other full-body work clothing;
• gloves;
• hats and shoes or disposable shoe coverlets;
• vented goggles or face shields with protective spectacles or goggles
• welding or blasting helmets, when required.

At no cost to employees, employers must provide clean, dry protective work clothing and equipment and appropriate changing facilities to workers who are exposed to lead above the PEL and for whom the possibility of skin contamination or skin or eye irritation exists.

The employer is responsible for the cleaning, laundering and disposal of protective clothing and equipment. Contaminated clothing that is to be cleaned, laundered or disposed of must be placed in closed containers. Containers must be labeled with the following warning:

CAUTION: Clothing contaminated with lead. Do not remove dust by blowing or shaking. Dispose of lead-contaminated wash water in accordance with applicable local, state, or Federal regulations.

RECORD KEEPING

Records of all exposure monitoring and other data used in conducting the employee exposure assessment, including objective data, must be established and maintained. The records must include the name and job classification of employees monitored, details of the sampling and analytic techniques, results and type of respiratory protection worn. These records must be kept for 30 years. Retaining records is required due to the long latency period of some diseases caused by lead exposure.

The Standard also requires employers to establish and maintain records of medical surveillance (biological monitoring and medical examination results). These records must include the names of employees, the physicians written opinion, exposure data provided to the physician, and any employee medical complaints associated with lead exposure.

In addition, the employer must keep, or assure that the examining physician keeps, a record of the results of medical examinations, a description of laboratory procedures and a copy of the results of biological monitoring. These records must be kept for at least the duration of employment plus 30 years, except that medical records of employees who have worked for less than one year for the employer need not be retained beyond the term of employment, if they are provided to the employee upon termination of employment.

The employer must establish and maintain an accurate record for each employee removed from current exposure to lead. The record must contain four entries each time an employee is removed:

1. Employee's name and social security number;
2. Dates of removal and return;
3. Brief explanation of how each removal was or is being accomplished; and
4. Whether the reason for removal was an elevated blood lead level. Records must be transferred to a successor employer whenever the employer ceases to do business. Medical removal records must be maintained for at least the duration of employment.

RENOVATION

This means modifying any existing structure or part of a structure.

REPAIR ACTIVITIES

This means overhauling, rebuilding, reconstructing, or reconditioning of structures or substrates.

REPRESENTATIVE SAMPLE

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.

An example follows. A particular task on a given work site involves the following workers:

4 Abrasive Blasters on each of 2 8-hour shifts;
3 Iron Workers on 1 8-hour shift; and
6 Laborers on each of 2 8-hour shifts.

For an initial determination, a representative sample of the greatest exposed employees consists of 1 Abrasive Blaster from the shift with the highest presumed exposure and 1 Laborer from the shift with the highest presumed exposure.

For initial monitoring, one worker must be sampled for each job in each work area by shift or for the highest exposure level shift. This would consist of 1 Abrasive Blaster from the shift with the highest exposure; 1 Iron Worker; and 1 Laborer from the shift with the highest exposure.

RESPIRATORS

See RESPIRATORY PROTECTION.

RESPIRATORY PROTECTION