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Compliance program elements
  • Employers who work with lead should work with a qualified safety and health professional to develop a worker protection program.

The employer should, as needed, consult a qualified safety and health professional to develop and implement an effective, site-specific worker protection program. These professionals may work independently or may be associated with an insurance carrier, trade organization, or on-site consultation program.

For each job where employee exposure exceeds the permissible action limit (PEL), the employer must establish and implement a written compliance program to reduce employee exposure to the PEL or below. The compliance program must provide for frequent and regular inspections of job sites, materials, and equipment by a competent person. Written programs, which must be reviewed and updated at least annually to reflect the current status of the program, must include:

  • A description of each activity in which lead is emitted (such as equipment used, material involved, controls in place, crew size, employee job responsibilities, operating procedures, and maintenance practices).
  • The means to be used to achieve compliance and engineering plans and studies used to determine the engineering controls selected where they are required.
  • Information on the technology considered to meet the PEL.
  • Air monitoring data that document the source of lead emissions.
  • A detailed schedule for implementing the program, including copies of documentation (such as purchase orders for equipment, construction contracts).
  • A work practice program.
  • An administrative control schedule, if applicable.
  • Arrangements made among contractors on multi-contractor sites to inform employees of potential lead exposure.