August 20, 2013
In Oregon, construction industry employers receive more citations for violations of lead, asbestos, hazard communication, and respiratory protection standards than other health standards. Typically, one or two paragraphs in each standard account for most of the citations.
This is the first in a series of articles in the Construction Depot that explain the requirements of each standard's most frequently cited paragraphs.
Your employees are about to start a major remodeling project on an older home. Do you know how to assess their exposure?
You need to determine if lead is present in the home. If the home was built before 1978, it's possible that lead paint is present. To be certain that lead is present, you should do one of the following: hire a certified lead-based paint inspector or a risk assessor, have samples of the paint analyzed by an environmental lab, or use a lead check stick (lead check sticks can be helpful, but they may not be 100 percent reliable).
If lead is present, you need to determine whether your employees' work will expose them to lead at or above what's called the action level (30 micrograms per cubic meter of air averaged over eight hours). The most common way to do this is to sample the air your employees breathe with air-monitoring equipment while they are working. You can do air monitoring yourself if you know how to do it and if you have the right equipment, which you can rent. You can also hire a consultant, or your workers' compensation insurance carrier may be able to help.
There's a big problem, however, with monitoring your employees' exposure to lead while they are working: they could be overexposed to lead – and you don't want that to happen unless they are protected.
So, while you are doing air monitoring, you must assume that your employees are exposed to lead above the action level and you must do a minimum of SIX things (known as interim protective measures) to ensure that your employees are protected. These six things are:
If your employees do any of the following jobs, you must also do the minimum six protective measures.
Your employees' air monitoring results will tell you the level of their exposure to lead while they are doing the remodeling work. If they are exposed at or above the action level, you must provide protective measures, including additional air monitoring, medical surveillance, and training.
You must also ensure that your employees are not exposed to lead at levels greater than 50 micrograms per cubic meter of air averaged over eight hours – that's the maximum permissible exposure limit (PEL). You can use engineering and administrative controls to keep your employees' exposures to lead at or below the PEL.
Engineering controls include tools that can reduce your employees' exposure to lead. Using a sander attached to a HEPA vacuum to reduce dust is an example. Administrative controls change employees' work practices and temporarily reduce their exposures. Prohibiting workers from working in areas that expose them to lead above the action level is an example. If engineering and administrative controls are not effective, then your employees must also use appropriate respirators.
For more information about controlling lead hazards in construction work, see A quick guide to 1926.62 Oregon OSHA's construction industry rule for controlling exposure to lead.
Reprinting, excerpting, or plagiarizing any part of this publication is fine with us!
But remember: the information in this newsletter is intended to highlight safe work practices, but it does not replace Oregon OSHA workplace safety and health rules.
For information about Oregon OSHA services and answers to technical questions, call (503) 378-3272 or toll-free within Oregon, (800) 922-2689.