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Workers are exposed to lead as a result of the production, use, maintenance, recycling, and disposal of lead material and products. Lead exposure occurs in most industry sectors including construction, manufacturing, wholesale trade, transportation, remediation and even recreation.
Lead enters the body primarily through inhalation and ingestion. Today, adults are mainly exposed to lead by breathing in lead-containing dust and fumes at work, or from hobbies that involve lead. Lead passes through the lungs into the blood where it can harm many of the body’s organ systems. While inorganic lead does not readily enter the body through the skin, it can enter the body through accidental ingestion (eating, drinking, and smoking) via contaminated hands, clothing, and surfaces. Workers may develop a variety of ailments, such as neurological effects, gastrointestinal effects, anemia, and kidney disease.
Scope
OSHA’s requirement applies to all general industry occupational exposure to lead.
Regulatory citations
- 29 CFR 1910.1025 — Lead, including Appendices A, B, C, and D
Key definitions
- Action level: Employee exposure, without regard to the use of respirators, to an airborne concentration of lead of 30 micrograms per cubic meter of air (30 μg/m3) averaged over an 8-hour period.
- Lead: Metallic lead, all inorganic lead compounds, and organic lead soaps. Excluded from this definition are all other organic lead compounds.
- Permissible exposure limit or PEL: 50 micrograms of lead per cubic meter of air, as averaged over an 8-hour period.
Historical note
Research on workplace lead exposure shows adverse health effects can occur in adults at blood lead levels (BLLs) that are lower than the medical removal levels specified in OSHA’s lead standards. Now the agency is considering a rulemaking to reduce the current BLL triggers in the medical surveillance and medical removal protection provisions of 29 CFR 1910.1025.
OSHA issued a pre-proposal on June 28, 2022, on BLL triggers for medical removal protection; medical surveillance provisions, including triggers and frequency of blood lead monitoring; permissible exposure limit; and ancillary provisions for personal protective equipment, housekeeping, hygiene, and training.
Summary of requirements
Employers must:
- Monitor employee exposures to lead and determine if any employee may be exposed to lead at concentrations at or above the action level.
- Establish and implement a written compliance program to reduce exposures at or below the permissible exposure limit (PEL), and interim levels if applicable, solely by means of engineering and work practice controls.
- Provide exposed employees with respirators and train according to 1910.134.
- Provide exposed employees with protective work clothing and equipment.
- Establish cleaning, laundering, or disposal procedures for contaminated protective clothing and equipment.
- Where employees are exposed to lead above the PEL, do not allow the presence or consumption of food or beverages, tobacco products, or the application of cosmetics.
- Provide separate change rooms, shower facilities, and lunchrooms.
- Post warning signs in each area where the PEL is exceeded.
- Institute a medical surveillance program for affected employees.
- Establish and maintain an accurate record for each employee subject to medical surveillance.
- Provide the physician conducting a medical examination or consultation with the information required in the Lead standard and furnish the employee with a copy of the written medical opinion.
- Establish a training program for all affected employees. Provide the training prior to the initial job assignment and at least annually thereafter.
- If ventilation is used to control lead exposure, take measurements at least every three months which demonstrate the effectiveness of the system in controlling exposure. Additionally, take measurements when there is a change in production, process, or control which could alter the lead level within 5 days of the change.
- If administrative controls are used to control lead exposure, implement a job rotation schedule.