Safety&Health Fact Sheet
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Safety&Health Fact Sheet
L e a d i n C o n s t r u c t i o n
Special Emphasis Program
Cal/OSHA Consultation Service
California Department of Industrial Relations
P. O. Box 420603 San Francisco, CA 94142-0603
OSHA
CAL
SERVICE
CONSULTATION
April 2000
the U.S. Environmental Protection Agency National
Lead Laboratory Accreditation Program are listed at
www.leadlisting.org. Testing methods for lead must
meet requirements of Title 8 Section 1532.1(d)(9).
Step 2On all construction jobs where lead is
present the following is required:
Housekeeping. Lead dust on surfaces, espe-
cially in eating areas, must be controlled by HEPA
vacuuming, wet clean-up, or other effective methods.
Hand and face washing. Workers must have
washing facilities with soap and clean water.
Training. Workers must receive training on lead
hazards and how to protect themselves.
A written compliance program to assure
control of hazardous lead exposures.
Exposure determination. Employers must
assess the amounts of lead breathed by workers. This
is usually done by employee breathing-zone air
sampling.
[TIP: Employers can request a Cal/OSHA
Consultation Service industrial hygienist to come
to a job and show them how this sampling is
done.]
Air sampling results are used to determine if
the protective measures in Step 4 must be taken, as
well as the type of respirator that must be worn for
protection.
Step 3For certain highly hazardous tasks, called
trigger tasks, special protective measures must be
takenincluding specified respiratorsuntil the
employer determines that worker airborne exposures
to lead are below levels specified in Section 1532.1.
Level 1 trigger tasks
Any of the following with lead-containing coat-
ings or materials: spray painting, manual demolition,
manual scraping or sanding, use of heat gun, power
tool cleaning with dust collection system.
Minimum required respirator: half-mask respirator
with N-100, R-100 or P-100 filters.
Safety&Health Fact Sheet
Cal/OSHA is conducting a Special Emphasis Program
to reduce the hazard from lead in construction
affecting workers, their families and the public.
Why a Special Emphasis Program now?
Cal/OSHA is particularly concerned about lead in
construction because of:
Recognition of significant risk to children from
take-home lead, even at very low levels of exposure.
A boom in housing and public works renovation
and rehabilitation projects that disturb lead paint.
The need for greater protection for workers,
their families and the public through a focused
inspection and consultation effort.
What are the goals of this program?
Significantly reduce lead exposures for workers,
their families and the public by:
Increased enforcement and consultation to get
the word out to contractors, workers, and owners of
buildings and other structures that lead is a significant
hazard in the construction business.
Informing employers of regulations they must fol-
low when lead may be present on a construction job.
Informing workers of the hazards of lead on the
job, and to their families, especially children, from
lead carried into vehicles or homes on their bodies,
shoes or clothing.
What steps do I take to comply with the
Cal/OSHA regulation for lead in construction?
[TIP: Specially trained staff of the Cal/OSHA Consul-
tation Service and Dept. of Health Services Occupa-
tional Lead Poisoning Prevention Program are avail-
able at phone numbers on this fact sheet to help you
understand the requirements of this regulation.]
Section 1532.1 in Title 8 of the California Code of
Regulations makes construction employers respon-
sible, by law, for basic steps in compliance.
Step 1Recognize the hazard. Lead can be
present in a wide range of materials including paints
and other coatings, lead mortars, and base metals to
be welded on or treated with abrasive blasting. Look
at the age of the building or structure, the presence
of coatings and other materials that may contain lead,
and information from the property owner.
Send samples of materials to be disturbed to a
laboratory for lead analysis. Laboratories accredited by
Cal/OSHA Consultation Service Offices
For telephone assistance and to request
a no-cost consultation at your worksite:
Or toll-free
1-800-963-9424
San Bernardino 909-383-4567
San Diego 858-467-4071
Santa Fe Springs 562-944-9366
Van Nuys 818-901-5754
Fresno 559-454-1295
Oakland 510-622-2891
Sacramento 916-263-0704
Level 2 trigger tasks
Any of the following with lead-containing coat-
ings or materials: using lead-containing mortar, lead
burning, rivet busting, power tool cleaning without
dust collection system, clean-up activities using dry
expendable abrasives, abrasive blasting enclosure
movement or removal.
Minimum required respirator: air-supplied hood or
helmet, or loose fitting hood or helmet powered air-
purifying respirator with N-100, R-100 or P-100 filters.
Level 3 trigger tasks
Abrasive blasting, welding, cutting, or torch
burning on structures where lead-containing coatings
or materials are present.
Minimum required respirator: half-mask supplied
air respirator operated in a positive pressure mode.
Protective measures required for all trigger
tasks until worker airborne exposures are shown to
be below levels specified in Section 1532.1:
Respirators, protective equipment and clothing.
Clothing change areas.
Initial blood testing for lead and zinc protoporphyrin.
Basic lead hazard, respirator, and safety training.
Also, Section 1532.1(i)(6) requires regulated areas
with warning signs for all trigger tasks.
In addition to the specific trigger tasks, whenever
there is reason to believe that any other task may cause
a hazardous lead exposure, the above protective mea-
sures must be taken until the exposure is shown to be
below the airborne Permissible Exposure Limit (PEL).
More resources
Step 4Where air sampling shows employee
exposures above the PEL from any operation, the
following controls are required in addition to those
for trigger tasks: respirators appropriate to the levels
of exposure measured, clean areas for eating and
clothing change, showers, full worker training, and
medical monitoring with routine blood testing for
lead and zinc protoporphyrin (ZPP).
Certification. On jobs at residential and public
access buildings, workers exposed to lead above the
PELand their supervisorsmust receive state-
approved training and be certified by the California
Dept. of Health Services.
[TIP: Information on lead
worker certificationphone 800-597-LEADor go
to www.childlead.com and click on Prevention]
Whats in it for me?
Consider the alternatives to compliance: fines up to $25,000
per violation, medical removal payments to workers with
high blood lead levels, and costly job shutdowns.
Some companies find that following the Cal/OSHA
regulation increases their business because clients want
jobs that are safe for both workers and the environment.
Where can I get help?
The Cal/OSHA Consultation Service
helps employ-
ers at no cost. Employers can request on-site assis-
tance in employee training and air sampling. The
Consultation Service is independent of Cal/OSHAs
enforcement unit.
At the Cal/OSHA website you can find all Title 8
regulations, including Section 1532.1 for lead in
construction: www.dir.ca.gov/dosh
California Department of Health Services
Occupational Lead Poisoning Prevention Program
website: www.ohb.org/olppp.htm
phone: 510-622-4332
Questions frequently asked
Q.
Before starting work on a job that involves distur-
bance of paint or other coatings, am I required to have a
sample of the paint analyzed for lead content?
A.
This is the best way to begin assessing the lead
hazard at the jobsite. While not specifically required
by the Cal/OSHA regulation, material samplingcom-
bined with knowledge of the tasks being doneis the
best indicator of the chance of high airborne lead
levels, and can help guide the air sampling and
exposure control efforts and the choice of required
respirators.
Q.
If Im already doing air monitoring and protecting
workers with respirators during tasks with high exposures,
why do I also need to do blood lead and ZPP monitoring?
A.
Blood lead and ZPP monitoring are tools that help
assess workers total exposure to leadincluding
through ingestion, unmonitored operations, and lead
contamination in the vehicle and home. It is the most
important benchmark for answering the question:
Am I protecting my workers from the hazards of lead
on the job?
Q.
How do I get started with a lead medical monitor-
ing program and where do I find a physician to do this?
A.
The Dept. of Health Services Occupational Lead
Poisoning Prevention Program listed below can help
you get started with this program.
Painting and Decorating Contractors of America
website: www.pdca.org
phone: 800-332-7322
SSPC: Society for Protective Coatings
website: www.sspc.org phone: 412-281-2331
The National Lead Service Providers Listing System
website: www.leadlisting.org