Lead in the Workplace

Lead is a metal that occurs naturally in the earth's crust, but human activity (such as mining, burning fossil fuels, and manufacturing) has caused it to become more widespread. As a result, lead can be found in all parts of our environment including air, soil, water, and inside of building structures such as residential homes and work environments. Lead and lead compounds have been used in a wide variety of products in our homes and workplaces including paint, ceramics, pipes and plumbing materials, solders, gasoline, roofing materials, batteries, pottery, ammunition, and some cosmetics. Anytime your work scope includes working with lead or suspected lead sources, including a section in your Job Safety Analysis (JSA) or Job Hazard Analysis (JHA) is appropriate.

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Although there has been some benefit to using lead in these various products, exposure to lead can be toxic to humans and the environment leading to adverse health effects to humans, especially children and pregnant women. Most of the activities resulting in human exposure to lead include the past use of leaded gasoline and other fossil fuels, past use of lead-based paint in homes and workplaces, and some types of industrial facilities. Lead-based paints for homes, children's toys, and household furniture have been banned in the United States (U.S.) since 1978. But lead-based paint is still on walls and woodwork in many older homes and apartments. Most lead poisoning in children results from eating chips of deteriorating lead-based paint. Humans can also get lead into their bodies by breathing in dust containing lead and/or incidentally ingesting paint chips/dust or soil containing lead. Lead particles can be released into tap water from lead pipes, brass plumbing fixtures, and copper pipes soldered with lead. Lead pipes are more likely to be found in older cities and homes built before 1986. Although banned in the U.S., lead solder in food cans is still used in some countries.

Lead can affect almost every organ and system in the human body. Children six years old and younger are most susceptible to the effects of lead because their growing bodies absorb more lead than adults, and their brains and nervous systems are more sensitive to the damaging effects of lead. Babies and young children can also be more highly exposed to lead because they often put their hands and other objects into their mouths that can have lead from dust or soil on them. Children may also be exposed to lead by eating food and/or drinking water containing lead or from dishes or glasses that contain lead, inhaling lead dust from lead-based paint or lead-contaminated soil, or from playing with toys with lead-based paint. Even low levels of lead in the blood of children can result in:

• Behavior and learning problems.
• Learning difficulties, lower IQ, and hyperactivity.
• Slowed growth and developmental delay.
• Hearing problems.
• Anemia.
• Irritability.
• Loss of appetite.
• Weight loss.
• Sluggishness and fatigue.
• Abdominal pain.
• Vomiting.
• Constipation.
• Seizures.

In rare cases, ingestion of lead by children can cause the child to become comatose and even death.

Adults may be exposed to lead by eating food and drinking water containing lead or from dishes or glassware that contain lead. They may also breath lead dust by spending time in areas where lead-based paint is deteriorating, and during renovation or repair work that disturbs painted surfaces in older homes and buildings. Working in a job or engaging in hobbies where lead is used, such as making stained glass, can increase exposure as can certain folk remedies containing lead. A pregnant woman’s exposure to lead from these sources is of particular concern because it can result in exposure to her developing baby.

Lead can accumulate in our bodies over time, where it is stored in bones along with calcium. During pregnancy, lead is released from the mother's bones along with calcium and can pass from the mother to the fetus or to the breastfeeding infant. This can result in serious effects to the developing fetus and infant, including:

• Cause the baby to be born too early or too small.
• Harm the baby’s brain, kidneys, and nervous system.
• Increase the likelihood of learning or behavioral problems.
• Put the mother at risk for miscarriage, stillbirth, or premature birth.

Exposure to lead by other adults is also harmful and can result in:

• Cardiovascular effects, increased blood pressure, and hypertension.
• Joint and muscle pain.
• Difficulties with memory or concentration.
• Headache.
• Abdominal pain.
• Mood disorders.
• Reproductive problems (in both sexes), including reduced sperm count and abnormal sperm.
• Decreased kidney function.

Now that the hazards to human health from exposure to lead has been summarized, the remainder of this article will focus on regulations associated with lead in the workplace. Exposure to lead in the workplace does not only have potential adverse impacts to the health of the worker. The exposed worker can inadvertently take lead home on their clothes, hair, skin, tools, and in their vehicles, potentially exposing children and other adults to the lead hazards.

In the U.S., the Occupational Safety and Health Administration (OSHA) addresses the health and safety of workers potentially exposed to lead under the General Industry scenario in 29 Code of Federal Regulation (CFR) Part 1910.1025 and under the Construction Industry scenario in 29 CFR Part 1926.62. The reader is referred to these citations for detailed information addressed by the regulations, and for potential use in preparing a Job Safety Assessment (JSA). Nonetheless, the following are some selected information from these regulations.

General Industry

Under the OSHA’s General Industry scenario, 29 CFR Part 1910.1025 applies to all occupational exposure to lead, except to the construction industry covered by 29 CFR Part 1926.62 or to agricultural operations covered by 29 CFR Part 1928.

The “Action Level” established under this rule is employee exposure to an airborne concentration of lead of 30 micrograms per cubic meter of air (30 µg/m³) averaged over an 8-hour period, without the use of respirators. The Permissible Exposure Limit (PEL) for lead exposure to workers shall not exceed a concentration greater than 50 µg/m³ averaged over an 8-hour period. If an employee is exposed to lead for more than 8 hours in any workday, the PEL, as a time weighted average (TWA) for that day, shall be reduced according to the following formula:

Maximum PEL (in µg/m³) =400 divided by hours worked in the day.

An employer who has a workplace or work operation covered by this standard shall conduct an “initial determination” to evaluate whether any employee may be exposed to lead at or above the action level. 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.

If the initial determination indicates employee exposure to be less than the action level, the measurements need not be repeated except when there has been a production, process, control, or personnel change which may result in new or additional exposure to lead, or whenever the employer has any other reason to suspect a change which may result in new or additional exposures to lead. If the initial determination indicates the possibility of any employee exposure at or above the action level, the employer shall conduct monitoring which is representative of the exposure for each employee in the workplace who is exposed to lead.

If the initial determination or subsequent monitoring indicates employee exposure to be at or above the action level but below the PEL, the employer shall repeat monitoring at least every 6 months. The employer shall continue monitoring at the required frequency until at least two consecutive measurements, taken at least 7 days apart, are below the action level at which time the employer may discontinue monitoring for that employee.

If the initial monitoring reveals that employee exposure is above the PEL, the employer shall repeat monitoring quarterly until at least two consecutive measurements, taken at least 7 days apart, are below the PEL but at or above the action level at which time the employer shall repeat monitoring for that employee at the frequency specified.

The employer must, within 15 working days after the receipt of the results of any monitoring conducted under this section, notify each affected employee of these results either individually in writing or by posting the results in an appropriate location that is accessible to affected employees. Whenever the results indicate that the representative employee exposure exceeds the PEL, without the use of respirators, the employer shall include in the written notice a statement that the PEL was exceeded and a description of the corrective action taken or to be taken to reduce exposure to or below the PEL.

Whenever any employee is exposed to lead above the PEL for more than 30 days per year, the employer shall implement engineering and work practice controls (including administrative controls) to reduce and maintain employee exposure to lead, except to the extent that the employer can demonstrate that such controls are not feasible. Wherever the engineering and work practice controls which can be instituted are not sufficient to reduce employee exposure to or below the PEL, the employer shall nonetheless use them to reduce exposures to the lowest feasible level and shall supplement them using respiratory protection.

Whenever any employee is exposed to lead above the PEL for 30 days or less per year, the employer shall implement engineering controls to reduce exposures to 200 µg/m³, but thereafter may implement any combination of engineering, work practice (including administrative controls), and respiratory controls to reduce and maintain employee exposure to lead at or below 50 µg/m³.

Each employer shall establish and implement a written compliance program to reduce exposures to or below the PEL, and interim levels if applicable, solely by means of engineering and work practice controls. Written plans for these compliance programs shall include at a minimum, the components listed under 29 CFR Part 1910.1025(e)(3)(ii). Written compliance programs must be revised and updated at least annually to reflect the status of the program.

For employees who use respirators required by 29 CFR Part 1910.1025, the employer must provide each employee an appropriate respirator that complies with the requirements of 29 CFR Part 1910.1025(f). Respirators must be used during 1.) periods necessary to install or implement engineering or work-practice controls, 2.) work operations for which engineering and work-practice controls are not sufficient to reduce employee exposures at or below the PEL, and 3.) periods when an employee requests a respirator. The employer must implement a respiratory protection program which covers each employee required to use a respirator.

If an employee is exposed to lead above the PEL, excluding the use of respirators or where the possibility of skin or eye irritation exists, the employer shall provide at no cost to the employee and assure that the employee uses appropriate protective work clothing and equipment. The employer shall ensure that labels of bags or containers of contaminated protective clothing and equipment include the following information:

DANGER: CLOTHING AND EQUIPMENT CONTAMINATED WITH LEAD. MAY DAMAGE FERTILITY OR THE UNBORN CHILD. CAUSES DAMAGE TO THE CENTRAL NERVOUS SYSTEM. DO NOT EAT, DRINK OR SMOKE WHEN HANDLING. DO NOT REMOVE DUST BY BLOWING OR SHAKING. DISPOSE OF LEAD CONTAMINATED WASH WATER IN ACCORDANCE WITH APPLICABLE LOCAL, STATE, OR FEDERAL REGULATIONS.

Other requirements listed under 29 CFR Part 1910.1025 include those for housekeeping (1910.1025[h]), hygiene facilities and practices (1910.1025[i]), medical surveillance (1910.1025[j]), medical removal protection (1910.1025[k]), employee information and training (1910.1025[l]), communication of hazards (1910.1025[m]), recordkeeping (1910.1025[n]), and observation of monitoring (1910.1025[o]). The reader is referred to those applicable sections for specific information on OSHA regulations.

Construction Industry

The OSHA regulations under this section (29 CFR 1926.62) applies to all construction work where an employee may be occupationally exposed to lead. Construction work is defined as work for construction, alteration and/or repair, including painting and decorating. It includes but is not limited to the following:

• Demolition or salvage of structures where lead or materials containing lead are present.
• Removal or encapsulation of materials containing lead.
• New construction, alteration, repair, or renovation of structures, substrates, or portions thereof, that contain lead, or materials containing lead.
• Installation of products containing lead.
• Lead contamination/emergency cleanup.
• Transportation, disposal, storage, or containment of lead or materials containing lead on the site or location at which construction activities are conducted.
• Maintenance operations associated with the construction activities described in this paragraph.

The action level and PEL for lead under the construction industry standard is the same as for general industry (30 and 50 µg/m³, respectively). Similar to the general industry standard, an employer needs to conduct an exposure assessment to determine whether any employee would be exposed to lead at a concentration at or exceeding the action level, without the use of respirator protection. The employer shall collect personal samples representative of a full shift including at least one sample for each job classification in each work area either for each shift or for the shift with the highest exposure level.

Where lead is present, until the employer conducts an employee exposure assessment as required and documents that the employee conducting any of the listed tasks is not exposed above the PEL, the employer shall treat the employee as if the employee were exposed above the PEL, and not more than 10 times the PEL, and shall implement employee protective measures prescribed in the section. The tasks covered by this requirement are:

• Where lead containing coatings or paint are present, the manual demolition of structures (e.g, dry wall), manual scraping, manual sanding, heat gun applications, and power tool cleaning with dust collection systems.
• Spray painting with lead paint.
• Also, where the employer has any reason to believe that an employee conducting the task may be exposed to lead exceeding the PEL, until the employer conducts an employee exposure assessment and documents that the employee's lead exposure is not above the PEL, the employer shall treat the employee as if the employee were exposed above the PEL and shall implement employee protective measures as prescribed in the section.

With respect to the following listed tasks, where lead is present, until the employer conducts the required employee exposure assessment and documents that the employee conducting any of the listed tasks is not exposed exceeding 500 µg/m³, the employer shall treat the employee as if the employee were exposed to lead in excess of 500 µg/m³ and shall implement employee protective measures as prescribed in the section. Where the employer does establish that the employee is exposed to levels of lead below 500 µg/m³, the employer may provide the exposed employee with the appropriate respirator prescribed for such use at such lower exposures, in accordance with the section. The tasks covered by this requirement are:

• Using lead containing mortar; lead burning.
• Where lead containing coatings or paint are present: rivet busting; power tool cleaning without dust collection systems; cleanup activities where dry expendable abrasives are used; and abrasive blasting enclosure movement and removal.

With respect to the following listed tasks, where lead is present, until the employer conducts an employee exposure assessment and documents that the employee conducting any of the listed tasks is not exposed to lead exceeding 2,500 µg/m³ (50 times the PEL), the employer shall treat the employee as if the employee were exposed to lead exceeding 2,500 µg/m³ and shall implement employee protective measures as prescribed in the section. Where the employer does establish that the employee is exposed to levels of lead below 2,500 µg/m³, the employer may provide the exposed employee with the appropriate respirator prescribed for use at such lower exposures, in accordance with the section. Interim protection as described in this paragraph is required where lead containing coatings or paint are present on structures when conducting:

• Abrasive blasting
• Welding
• Cutting
• Torch burning

Until the employer conducts an employee exposure assessment as required in this section and determines actual employee exposure, the employer shall provide to employees conducting the tasks described in previous paragraphs of this section with interim protection as follows:

• Appropriate respiratory protection in accordance with this section.
• Appropriate personal protective clothing and equipment in accordance with this section.
• Change areas in accordance with this section.
• Hand washing facilities in accordance with this section.
• Biological monitoring in accordance with this section, to consist of blood sampling and analysis for lead and zinc protoporphyrin levels.
• Training as required under this section on 29 CFR 1926.59, Hazard Communication; training as required under this section on the use of respirators; and training in accordance with 29 CFR 1926.21, Safety Training and Education.

Other requirements listed by OSHA under 29 CFR Part 1926.62 include those for methods of compliance (1926.62[e]), respiratory protection (1926.62[f]), protective work clothing and equipment (1926.62[g]), housekeeping (1926.62[h]), hygiene facilities and practices (1926.62[i]), medical surveillance (1926.62[j]), medical removal protection (1926.26[k]), communication of hazards (1926.62[l]), signs (1926.62[m]), recordkeeping (1926.62[n]), and observation of monitoring (1926.62[o]). Many of these requirements are like those for general industry. The reader is referred to those applicable sections for specific information on OSHA regulations under the construction industry.

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