June 2014

Protecting remodelers from lead exposure

Understand the requirements to avoid exposures

By Ellis Brasch

Let's assume your employees are about to remodel a home built in 1970. Because the home was built before 1978, it's possible that some lead paint is present. How do you protect them?

First, determine if lead is present in areas where they will be working. You could hire a certified lead-based-paint inspector or have samples of the paint analyzed by an environmental lab. You could also use a lead check stick, but they may not be 100 percent reliable.

If lead is present, you must determine whether your employees' work will expose them at or above the action level, 30 micrograms of lead per cubic meter of air averaged over eight hours. The most common way to do this is to use air-monitoring equipment to sample the air your employees breathe while they are working. You can do air monitoring yourself if you know how 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 work: They could be overexposed, and you don't want that to happen unless they are protected.

While doing air monitoring, you must assume your employees are exposed to lead above the action level. You must do a minimum of six things (known as interim protective measures) to ensure that your employees are protected:

  1. Provide your employees with appropriate respirators.
  2. Provide your employees with appropriate protective clothing.
  3. Provide clean areas for your employees to change and store their clothing.
  4. Provide hand washing facilities for your employees.
  5. Ensure that your employees have their blood sampled for lead.
  6. Provide training for your employees that covers lead health hazards and all parts of Oregon OSHA's lead standard for the construction industry (1926.62).

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 continue the six protective measures, including additional air monitoring and medical surveillance.

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. For example, using a sander attached to a HEPA vacuum to reduce dust. Administrative controls change employees' work practices and temporarily reduce their exposures. For example, prohibiting workers from working in areas that expose them to lead above the action level. If engineering and administrative controls are not effective, then your employees must also use appropriate respirators.

For more information about assessing lead exposure levels, and to find out how to comply with Oregon OSHA's lead standard for the construction industry, see Oregon OSHA's fact sheet and Quick Guide to lead in construction. red square - end article

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