Lead for construction activities

Scope

This section applies to all construction work where an employee may be occupationally exposed to lead. All construction work excluded from coverage in the general industry standard for lead by 29 CFR 1910.1025(a)(2) is covered by this standard. 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 performed; and
• Maintenance operations associated with construction activities.

Occupational exposure to lead is possible through inhalation of dust or fumes or skin contact with lead-containing materials. Inadvertent ingestion of lead can occur from exposed food or beverages or when employees eat, drink, or smoke without washing their hands thoroughly. Without proper controls, this exposure can lead to serious health effects, including neurological damage, kidney dysfunction, and reproductive issues.

In building construction, lead is frequently used for roofs, cornices, tank linings, and electrical conduits. In plumbing, soft solder, used chiefly for soldering tinplate and copper pipe joints, is an alloy of lead and tin. Soft solder, along with lead-based paint, has been banned for many uses in the United States. However, since lead-based paint inhibits the rusting and corrosion of iron and steel, it is still used on bridges, railways, ships, lighthouses, and other steel structures, although substitute coatings are available. The action level (AL) for lead is 30 micrograms per cubic meter of air (30 µg/m3) averaged over an 8-hour period. OSHA has also established a permissible exposure limit (PEL) for lead, which is 50 micrograms per cubic meter of air (50 µg/m3), averaged over any 8-hour period.

Employers must make available blood sampling tests and analysis for lead and zinc protoporphyrin levels to each employee covered under the standard, including:

• At least every 2 months for the first 6 months and every 6 months thereafter;
• At least every two months for employees whose last blood sample test analysis indicated a blood lead level at or above 40 µg/100 g of whole blood. (NOTE: This frequency must continue until two consecutive blood sample test analyses show a blood lead level below 40 µg/100 g of whole blood); and
• At least monthly during the removal period when blood lead levels indicate the need to remove employees from exposure.

To protect workers, employers must deploy stringent engineering and administrative controls, provide effective personal protective equipment (PPE), and perform regular monitoring to minimize exposure and ensure compliance with OSHA’s lead standards. Understanding and mitigating these hazards is essential to protecting worker health and maintaining safety on each construction site.e with OSHA’s lead standards. Understanding and mitigating these hazards is essential to protecting worker health and maintaining on each construction site.

Regulatory citations

• 29 CFR 1926.62 — Lead
• 29 CFR 1926.95 — Personal Protective Equipment (PPE)
• 29 CFR 1904 — Recording and reporting occupational injuries and illnesses
• 29 CFR 1910.1020 — Access to employee exposure and medical records
• 29 CFR 1910.1200 — Hazard communication

Key definitions

• Action level: The point at which a task or activity should be proactively changed to prevent an injury, illness, or other negative consequence.
• Chronic: Over an extended time period, such as from continuous or repeated exposure.
• Construction industry: Industries with work involving construction, alteration, and/or repair, including painting and decorating.
• Exposure: Subjecting a worker to a hazardous drug by any route of entry, such as inhalation, ingestion, skin contact, or absorption. Exposure includes potential (e.g., accidental or possible) exposure.
• Lead: Metallic lead, all inorganic lead compounds, and organic lead soaps. Excluded from this definition are all other organic lead compounds.
• Permissible exposure limit (PEL): The legal regulatory limit of a substance that a worker can be exposed to without adverse health effects.
• Time-weighted average (TWA): A calculation of a worker’s average exposure to a hazardous material or substance over a given period of time, typically 8 hours.
• Toxic: A material or substance from which exposure can cause illness, disease, or death.

Summary of requirements

Employers must:

• Conduct hazard assessments to identify operations or activities that may expose, or potentially expose, an employee to lead or lead-containing materials.
• Consult with industrial hygienists or other occupational health and safety professionals for guidance, as necessary.
• Develop and implement a written program to reduce exposures to or below the permissible exposure limit by means of engineering and work practice controls.
• Establish surveillance and exposure monitoring protocols to determine potential exposure levels that are representative of each employee’s exposure to lead over an 8-hour period.
• Ensure employees are provided with blood sampling tests at required frequencies.
• Establish regulated areas where it is necessary to reduce worker exposure to lead.
• Notify affected employees of these monitoring results either individually in writing or by posting the results in an appropriate, accessible location.
• Implement controls and procedures for safe handling, disposal, and inspection of materials, equipment, and tools used for processes containing lead.
• Establish housekeeping and hygiene practices to maintain all surfaces as free as practicable of accumulations of lead. This includes ensuring that employees who work in areas where their airborne exposure to lead is above the PEL, without regard to the use of respirators, shower at the end of the work shift and have an adequate supply of cleansing agents and towels available for use.
• Provide appropriate PPE, including respirators, necessary to protect workers from exposure.
• Ensure hazardous materials are properly inventoried and labeled and that safety data sheets (SDSs) are readily accessible for workers.
• Train workers in chemical and material handling hazards and required protective measures.
• Investigate any worker incidents or near misses to find root causes and implement corrective actions to prevent future occurrences.