Lead


For employees (carpenter, laborer, iron worker, plumber, electrician) using powder actuated tools, please take caution! There are possible airborne lead exposures during powder actuated tool use.

The best safety practice is to eliminate the hazard. In this case there are two easy alternatives;

  1. using lead-free loads, or
  2. using a pneumatic type nailer (like this one made by Pneutek, Hilti makes a CO2 type as well)

However, if you are an employee, I realize there are times that you are not given a choice. If this is the case, please consider:

    • asking for the MSDS for the primer loads (look for lead styphnate, or similar)
    • lead exposure can occur by inhalation and by ingestion (wash!)
    • wash & be diligent around eating & what you “take home” to your family
    • lead exposure to children is serious (they absorb lead better & it causes more detrimental health effects)
    • respirators might be required when using these tools (so wear one!)
    • working overhead (nailing into ceiling) might have higher airborne levels than other positions
    • bringing up these concerns with your safety professional onsite
    • performing air monitoring to determine airborne levels (although for the price of an industrial hygiene consultant, you could own a CO2 actuated tool)
    • reading more about it from my earlier post here.

When taking blood lead levels, the occupational health clinic will typically measure both the lead in the blood, and the zinc protoporphyrin (ZPP). The reason for this is the blood lead level measures just that, only the lead in the blood – which can come from previous exposures and whatever amount has been stored in your bones (soft tissues). It really only gives one piece of information. An early indicator of  lead exposure is the ZPP level.

The ZPP level indicates lead absorption. If your ZPP levels are elevated, this may mean that lead is being absorbed into your body (affecting the heme synthesis pathway). However, an elevated ZPP can be caused by other things, including iron deficiency anemia, etc.

If you have elevated ZPPs, you need to find out what is causing it. If you’re working with lead, you may have overexposure. If this is the case, your blood lead levels will most likely elevate in 2-6 weeks.

Ask your occupational health clinic for ranges of acceptable blood lead levels and ZPP levels.

You know those lead testing kits from the hardware store?  They seem extremely handy, however, they are a bit misleading.

LEAD CHECK ™ and LEAD ALERT ™ use a chemical (rodizonate-based) to instantly tell you if you have lead in your paint. If you use this kit, and the color changes, you have lead present.

They are quick and easy, but have a few HUGE downsides.

  • OSHA has stated in a letter of interpretation (7/2003) that these should not be used for determining if lead isn’t present. In other words, you can’t rely on a test that says, “no lead!”
  • These kits only check the “top layer” of paint – not the coat of paint below the one you are testing. You must test each layer.
  • These kits will not tell you how much lead you have (what percentage). You knew these kits didn’t do this already, but this is useful information!
  • Some chemicals may interfere with these type of kits. If you have chromium in your paint, the kit may say there is no lead present, but in fact, the chromium has interfered with the true results.

The biggest issue is that you need to have objective air monitoring to prove that your airborne levels of lead are not overexposing your employees.  A true bulk test (of paint) gives you great information. It tells you the percentage of lead in the paint. This, and your air sampling data, can be used again for future projects. It will also tell you which colors of paint have the highest lead.  Be safe out there!

I recently heard a very good summary of when (or alternatively when-you-DON’T) need to perform air monitoring when working with lead in construction.

Is there leaded-paint (lead based paint) in your project?

  • Then you MUST comply with the OSHA lead in construction rules.

On what occasion do I NOT have to perform air monitoring?

  • if you don’t have lead (see the first question)
  • if you want to provide the minimum required protection for all of your exposed employees (respirators, blood lead monitoring, etc. etc.)
  • if you have historical air monitoring data (from another project) that supports the methods you are using

Otherwise (in summary):

  • Take a bulk sample of the paint
  • Set up all engineering & administrative controls for controlling dust
  • Train your employees
  • Perform air monitoring during the FIRST day of actual work
  • Continue with all controls through the project
  • Notify everyone onsite of results
  • Require that all subcontractor do the same process

Leaded sheetrock is what the name says, sheetrock with a lead layer. It is used in hospital x-ray rooms and other health office clinics for containing / controlling the emitted x-rays while the machines are in use.

Plastering / Drywall companies who install this type of drywall need to follow the OSHA Construction Rules for lead work. I have heard of airborne exposures being at the exposure limits (50 ug/m3) during the installation due to the cutting and breaking of the drywall. My own personal monitoring has been below the Action Limit (30 ug/m3), but I have consistently found levels above the detection limit. This information should be taken as a caution to others.

For starters the employer will need to provide:

  • half face negative pressure tight fitting respirators with HEPA cartridges
  • protective clothing (like Tyvek (R))
  • containment (for the dust generated)
  • training (in lead and respirators)
  • hand washing / changing areas
  • HEPA vacuums for clean up
  • possibly air monitoring (by a qualified industrial hygienist)
  • possibly blood lead testing

The sheetrock should be contained during transport. Installation should be performed in a contained area with employees in respirators who are trained and competent. Clean-up should be done with HEPA vacuums. Air monitoring should be performed to assure that employees were adequately protected during their activities.

Working with this type of material is no excuse to cut corners (no pun intended). Protect your employees, the hospital, the patients, and others.

 

To simplify OSHA’s rules for lead in construction this is how I explain it:

Do you have lead (lead in paint usually) on the construction project? …Then you must comply with the entire rules.

How do you start? You start by listing the tasks where you will disturb the lead. For example, demolition, hand scraping, torch cutting.

After you’ve identified the tasks, then you can look at the OSHA rules and determine the minimum personal protective equipment (PPE) that will be necessary for your employees to wear while they’re performing each individual task.

Next, train your empoyee’s in lead awareness, which is the dangers, prevention and hazards of lead poisoning.

There is one other important aspect. Measuring your airborne levels of lead. This is done by air monitoring with a battery powered pump (and is typically one role of an industrial hygienist). Airborne lead results will indicate if you are generating a lot of lead into the air, or not. If you’re not, you can sometimes downgrade (bad word) the level of respiratory protection for your employees.

  • Caveat: this is not a complete summary of the rules. Please know and understand your local and federal rules entirely! This also does not cover the EPA’s Lead Rules which have specific items that you must do.

 

By definition, “if you work around, or near asbestos”.  Which leads to:

When do I work around it?

  • Answer: Buildings build before 1985 (some say 1980) might have it.

How do I know if I’m working around it?

  • Answer: Any structure build before 1985 must have an asbestos building survey performed and the contractor have a copy of it on hand. (and while the inspector is onsite they might as well check for lead (Pb)).

So what type of training do I need?

  • Answer: It depends. Either Class III or Class IV Training is required by OSHA (see earlier post).

We subcontract any asbestos work, and typically it’s already abated before we arrive onsite. Do we still need training?

  • Answer: Yes. OSHA does not define any training shorter (less involved) than Class IV (which is 2 hours). And, what I commonly see is that employers don’t train their employees, they find asbestos, disturb it and then get in trouble.

Any advice for how our company can avoid getting in these situations?

  • Answer: Train your office staff before you actually train your hands-on employees. If your estimators, project managers, superintendents and vice presidents know what to look for before bidding a job, then everyone has time to prepare and get the proper surveys, documentation, assistance, and training.

As I compiled information for a presentation titled, “Industrial Hygiene in Construction”, I wondered how to approach this topic. What I decided, is that I would start with the most frequent, the most common, with the most room for improvement. So, my list begins.

The caveat is that this list is NOT a list of the relative hazard compared to each other. This is just the IH hazards I see the most frequently. They should really NOT be compared to each other.

  1. Silica – in regards to airborne overexposures and lack of controls.
  2. Noise – in regards to overexposures and lack of adequate controls.
  3. Lead – in regards to compliance with OSHA / EPA.
  4. Asbestos – in regards to training employees and compliance with OSHA/EPA
  5. Welding – in regards to overexposures and lack of controls.

 

Many bridges and elevated highways have leaded paint. Lead and cadmium was (and sometimes still) added to paint for durability. Nowadays other heavy metals are used for durability. This particular bridge was near the coast and had already been repainted sometime in the past. Repainting requires the removal of the existing paint by sandblasting.  Since the bridge was previously  repainted with a non-leaded paint, in theory, there should not be any airborne levels of lead, or cadmium. However, I always find airborne levels of lead. Why?

The possibilities are:

  • not all of the leaded paint was removed
  • recycled blasting agent has trace amounts of lead
  • and possibly there are still levels of lead in the new paint that is supposedly “non-lead”

I always ask the laboratory to analyze my air sample for lead, and cadmium. Lead is usually the main contaminant, but occasionally I find cadmium. I will sometimes also have the lab check for zinc and chromium.  The sandblasters wear hooded powered air supply respirators, coveralls, and ear protection while blasting. Some other time I’ll talk about the noise from that activity (it’s LOUD!) and the fall protection issues they face.

Lead is a hazard in two forms: 1. airborne and 2. ingestion- from the transfer of contaminated hands/clothing to being eaten. Hygiene on a lead project is essential to preventing these exposures. A good safety practice, by which to verify that lead is not being transferred is to obtain wipe samples at random (or not-so-random) locations. Lunchrooms, shower/change areas, and pickup trucks are some of my favorite “random” locations.

The views around the area weren’t bad either…

As the saying goes, “if I had a penny for every time someone asked me…” Well, here are my most commonly (frequently) asked questions (FAQs) for dealing with asbestos and lead on a construction job-site.  These are my answers, so consult the appropriate governing body.

LEAD

  • Do I need to comply with EPA’s new lead rule? How do I?

If you are working in a public area, or specifically, with kids under the age of 6, you MUST comply. Go to EPA’s website (www.epa.gov) and take an accredited training class and get your company approved for leaded paint activities.

  • How do I know if I have leaded paint on my job-site?

If the building was built before 1978, a building survey (performed by an accredited inspector) should be taken. Rumor has it that leaded paint can be found in buildings up to 1985 or later. An accredited inspector can be found by calling the Construction Contractors Board, OSHA,  or the EPA/DEQ.

  • Can I use a do-it-yourself lead testing kit?

Yes, but they can sometimes be misleading. They only test the surface paint -not the other layers below. In addition, these kits cannot determine the amount of lead, or the airborne levels of lead on your jobsite.

  • I do have leaded paint on my construction project. Where can I find the current regulations on how to handle this situation?

OSHA (www.osha.gov), the Environmental Protection Agency (EPA) aka: Department of Environmental Quality (DEQ), the Construction Contractors Board (CCB), and sometimes Department of Human Services (DHS). Many of their rules overlap, but they all have unique rules that are designed for their particular jurisdiction.

  • We had a building survey for lead hazards performed. Our accredited inspector had the paint tested and found that it was only 0.3% total lead. It is less than 1%, do we need to comply with the regulations since it is such a small amount?

Yes. Any amount of lead found in lead paint requires that comply with OSHA’s regulations. Depending on the project, you may also need to comply with the standards of other governing bodies (see above).

ASBESTOS

  • How do I know if I have asbestos on my jobsite?

Buildings built before 1980 are required by DEQ to have a survey performed before any demolition or renovation.  The survey must be performed by an Asbestos Hazard Emergency Response Act (AHERA) accredited inspector.  They will take bulk samples of the material and determine the amount of asbestos present.

  • The accredited laboratory reported the asbestos had less than 1% but more than 0.001%. Does this mean it has asbestos?

Yes, it has asbestos (less than 1%), but OSHA considers it to be non-asbestos containing. However, even at 1% asbestos, you would want to control the possible exposures. Work practice procedures, training, and PPE should be used.

  • There is a small quantity (less than 10 linear feet) of asbestos on my jobsite. My employees may have to touch it. What type of training do they need?

There are four classes (or types) of asbestos work. Class I is the most hazardous and Class IV is the least hazardous. To answer your question-you need to compare your situation to the definition of Class III and Class IV asbestos work. Class III work is defined as, “repair and maintenance operations, where asbestos containing material, including thermal system insulation and surfacing asbestos containing material is likely to be disturbed”.  This type of training is 16 hours in length and must be done by a EPA/DEQ certified trainer. Class IV work is defined as, “maintenance and custodial activities during which employees contact but do not disturb asbestos containing materials and activities to clean up dust, waste and debris resulting from Class I, II and III activities”. This type of training is 2 hours in length and is the minimum. The particular type of training needed will depend on your situation.

  • We obtained a building survey before starting our job-site. After we started demolition we found some “questionable building materials” that did not look like they had been tested in this report. What do I do?

Stop work. Call an accredited building inspector for the material you need to test and have the material tested. Then report the results to the owner, and others on the jobsite, within 24 hours.

  • Our company policy is that we do not touch asbestos or lead. Do I need to write that down as “my company policy”?

Yes. Plus you should include what your employees should do if they run across a “questionable” material and whom they should contact.

  • We subcontract all asbestos and lead work. Do I need to have my employees trained in lead and asbestos awareness?

Yes.  There is still a good chance that your employees will see or have to deal with these hazards on the jobsite.

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