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The General Industry Standard for Occupational Exposure to lead does not apply to lead inspectors who are conducting lead sampling before, during or after a lead abatement project. The General Industry Standard for lead applies where there is a fixed location, such as a foundry, or a welding shop. Inspectors move from site to site, which is characteristic of construction.
The location of the inspector and the exposure potential is the key to when the Construction Standard would apply. The inspector who enters regulated areas to conduct sampling while the abatement work is in progress is “engaged in work” and is at risk of being “exposed.” They are required to be protected the same as the workers doing the removal. For instance, a lack of personal protective equipment (PPE) can be a violation of the Construction Lead Standard. The inspector is typically not in the regulated area for very long, perhaps 20 to 30 minutes, so the existing initial determination data taken from the workers can be adopted by the inspector.
Typically, inspectors that are in the regulated area for short periods do not conduct sampling to establish an initial determination for themselves. The inspector could use the sampling data collected from the workers as representative of their own exposure (a worst case scenario) initial determination. OSHA recognizes that the removal workers have been in the regulated area for a much longer time. Other provisions of the standard may apply and would be evaluated on a case by case basis.