Lead


You must follow both. (I’ve mentioned this before)

OSHA’s rules are very detailed and apply to any amount of lead in paint (even less than 0.5%) if you are disturbing it. The only time OSHA rules do not apply is:

  • if you are working as a sole-proprietor (no employees), or
  • if you are in some other country.

EPA’s rules are just a start. They apply to any residential facility where there are kids under the age of 6. OSHA’s rules are much more comprehensive and protective. (in some instances, overkill)

To EPA’s credit, they have done a great job of marketing and letting contractors know they insist on compliance. OSHA, on the other hand, only inspects 2% of businesses/year and does virtually no marketing. The chances of OSHA showing up on any given jobsite, is nearly 0%.

OSHA’s rules are very complete and comprehensive. You WILL need air monitoring, blood monitoring, PPE, change areas, water/sanitation, and training. The worst thing you can do is NOT follow the OSHA rules, find overexposures, and then try to “make up” for it. From my experience this scenario is a bad place to be, and happens all the time.

The answer is Yes.

If you are working with lead (in any amount) and you are performing any of the “trigger tasks” in construction = you must follow OSHA rules. Trigger tasks are demolition, removal, encapsulation, new construction, installation, cleanup, abrasive blasting, welding, cutting, torch burning, transporting, storing, heat gun work, sanding, scraping, spray painting, burning, welding, etc. What about the EPA rules (RRP)? Look here.

The only exceptions to not measuring employees blood lead are:

  1. On the first day of work activity, you perform air sampling (for the full shift) and can prove the airborne levels are below the Action Limits (<30 ug/m3)…or,
  2. OR…If you have relevant historical data and can prove your airborne levels during the same tasks are below the Action Limit (within the last 12 months). Relevant historical data must be REALLY relevant. Like, same work activity, same amount of lead in the paint, same general size/location, etc, etc.
These are the only exceptions.
If you choose to NOT perform blood lead monitoring the downsides are:
  • employees might already have dangerous levels of lead in their system, and you expose them to more
  • measuring blood lead levels after the exposure may indicate higher baseline blood lead levels -and you might have to pay for exposure which wasn’t your fault
  • if overexposed, and they have high blood levels – you might have to also check their family’s blood lead levels

More information on blood lead testing from my earlier post.

I’ve mentioned this before.

If you’re using these tools in construction please be careful.

Quick summary:

  • the powder contains lead (Pb)
  • you can be exposed to lead when it is airborne, AND if it gets on your hands & you eat it.
  • lead is not healthy for kids
  • Wash!

You already knew it. There is a lot to do in industrial hygiene. At times this occupation feels like a safety middleman trying to keep people out of trouble. Occasionally I’m rewarded with really helping someone. In the United States, there is still a lot of occupational hygiene issues and concerns. Overseas, particularly in developing countries, there is even more.

It is hard to obtain accurate exposure data, or illness rates, from these underdeveloped countries. (How does a village of 1,000 people in Kenya report that they’ve had lead exposure to battery recycling?) How these exposures are brought to light is by either a massive death (# of people, quickly) or, someone with a camera able to actually photograph the pollution. As we know, what it looks like doesn’t necessarily correlate with hazardous levels of exposure. But, in some cases, it’s pretty obvious.

I ran across this photo story on pollution (The Guardian, UK). They estimate 125 million people are exposed to industrial pollutants (generic term, I know). This makes occupational related exposures a health risk as big as TB and Malaria! The article is based upon a report from the Blacksmith Institute which included this map of the worst pollution with associated disease.

How does this apply to construction? The worst offenders are lead (Pb) (and other metals), and asbestos.

What can you do? Here’s their recommendation, from the report (p50):

Developing countries need the support of the international community
to design and implement clean up efforts, improve pollution control technologies, and provide educational
trainings to industry workers and the surrounding community

Another NPR article about lead poisoning can be found here.

Chinese made pirate costumes were seized due to high lead (Pb) being found in them. CNN reported that levels were 11x over the allowable level (100 parts per million) by the consumer safety products division. The NBC news video can be found here, and they reported 40x the limits.

 

When performing air monitoring it can be useful to take multiple samples on the same individual throughout the day. Here are some reasons to change out the filters:

  • build up of dust on filter – can cause overloading
  • break-out the exposure data. Morning versus afternoon, or by job tasks, or the physical area the employee is working in, controls vs. no-controls, etc.
  • if you question the employees motives. If you think the employee might skew the results, multiple samples might give you better control- or at least tell you if one is way-out-of-line.

Once you have your data results, how do you combine them?

If you’re taking particulate (dust, lead, cadmium, silica, etc) and you have the concentrations (from the lab) here is what to do.

  1. note the time (in minutes!) and the concentration results (mg/m3, ug/m3, etc) for each sample
  2. multiply the time and concentration for each – then add each number together
  3. finally, divide the above number by the total number of minutes sampled. This is your time weighted average (TWA).

Simple?! Yes. …And it’s really easy to make a mistake too. Check your math, and then eyeball the results and see if they make sense logically.

Here’s an example:

Andrew took three samples during one shift while Shelley was rivet busting through leaded paint. The first sample (118 minutes) was reported as 6.8 ug/m3 of lead, the second was for 245 minutes and had a concentration of 18 ug/m3. The last sample was taken for 88 minutes and was reported a level of 29 ug/m3. The overall results is 17.2 ug/m3 for the total time sampled. (Side: if you sampled for their entire exposure, and they worked longer hours, you could add those hours (assuming zero exposure) into the final time-in step three)

See the math below:

I was asked to perform asbestos training…and, “…maybe talk a little on lead”. However, I knew the employees needed to hear something totally different.

The firm requesting the training was a large excavation company that does a lot of road work. The training was at their bi monthly company wide meeting . I was given one hour.

So, my idea: Give them a quick overview of asbestos and lead, and then talk to them about silica. I called the training, “IH Health Topics in Construction”. And, as suspected, the questions that were posed all dealt with either: 1. “in my home I have…” or 2. silica and how to protect themselves.

I have made it my personal aim to talk about silica to as many employees as I can. I throw it into any training (even if I have just 5 minutes). Chances are, these guys WILL have overexposure to silica.  The owner did not mind since I told him we were going to talk about a few different kinds of health issues in construction.

My suggestion: see if you can work Silica into your conversations and trainings.

The big industrial hygiene conference (AIHCe) is held in a different city each year. This year was Indy, Indiana. Below is my personal top ten list  of “lessons learned” from last week.

  1. IH’s need to do a better job of sharing. We don’t share data, experiences, information, knowledge or our ideas well.
  2. CPWR is trying to share. Center for Construction Research & Training.  I’m looking forward to seeing their published independent review of local exhaust ventilation (LEV) units.
  3. The minimum exhaust rate for a portable exhaust unit must be 106 cfm (cubic feet per min) to capture particulates (dust, silica) during tuckpointing with a 5 in grinder (but it’s also a good rule of thumb).
  4. Asphalt milling machines are still a huge silica problem. Water controls are NOT enough. You need a local exhaust system too. (here’s an earlier post I made on it)
  5. GHS Safety Data Sheets – it’s not as complicated as you think. There are some significant changes, but don’t worry, OSHA’s here to help (ha). Seriously, more information will be available soon.
  6. Ignite. Have you seen these before? Short, stand up speeches about their ideas/passions. Similar to TED. Some were better than others. But, did I mention they were short?
  7. Committees. Be careful when you open your mouth. My idea was so great, they are making me do it.
  8.  ANSI A10.49! A health standard for construction. Great idea, but lots of work.
  9. Check out Environment for Children. I don’t know much about it, but they have a great mission.  Believe me, in the US, we’re WAY ahead.
  10. Presentation. It’s all up to you to make it. I will not cast blame on those who had bad presentations. BUT, it reminds me that I should work on this skill. Even if you have something good to say, if you give a horrible presentation, it’s likely no one will notice. On the other side, if your presentation is good, people will listen, even if you’re talking about nothing!  My favorite of the week: Dr. Mike Morgan (Univ. of Washington) on Chromium VI. He was very factual, not too flashy, and make the point without needless details.

 

As you may know, sometimes tin knockers (aka sheetmetal workers)  use sheet lead, or lead soldering, to make flashing on roof vents. Here is a picture of what these commonly look like (if there is (?) a common one).

The lead iron is heated up. Lead solder, or sometimes lead/zinc solder is used. Muratic acid (or similar) is used to clean the stainless steel. The iron is used to heat up the solder and drip it on the stainless surface. Anyways, the process creates lead fumes. This is dangerous both from airborne inhalables to the contact surfaces surrounding the area.

The surfaces around these areas are usually very high in lead content. There is not a OSHA standard for lead wipe tests. However, in the past OSHA has used the HUD standards and cited employers under the general duty clause. If you are performing these tasks, please make sure you are doing everything you can to limit the airborne, dermal, and ingestion exposure.

  • Follow OSHA Lead Standard (1926.62).
  • Train your employees.
  • Ventilation (downdraft is best). This is the best way to control the fumes.
  • Post signs in the area “lead work and hazardous”.
  • Perform air monitoring. I have found levels both above, and below, the exposure limits.
  • Wear a respirator (1/2 face negative air with HEPA).
  • Do not: eat, drink or smoke in this area.
  • Good hygiene. Wash after doing these activities.
  • Use a plastic sheeting on all surfaces. This makes it 100x easier to clean up.

in other words, don’t do what is in this picture below:

Who has jurisdiction over lead based paint? Are the EPA’s lead rules all I need to follow? Or, do I follow OSHA?

Well, the short answer (for those in construction) is YES. Usually OSHA, but maybe both EPA and OSHA (*and others, HUD, etc).

OSHA’s focus (as I’m sure you know) is to protect employees. If you are removing leaded on your own home, OSHA has no jurisdiction. However, if you have employees and are working with lead based paint, you must follow OSHA.

The EPA is focused on the environment (of course). They have implemented (April 22, 2008) a rule called the Renovation, Repair & Painting Rule. This rule applies when you are working on any facility which effects kids under the age of 6. If you are contractor looking to work on a project (s) with this demographic, you need to be certified by the EPA. Here is a good starting spot.

It is interesting (maybe just to me) but the EPA has very little enforcement, compared to OSHA. Yet, most people are very aware of the EPA rule. In contrast, I find contractors working with leaded paint who don’t know that they are under OSHA’s rules. I suppose the EPA has done a great job of marketing.

Another interesting comparison is that the EPA and OSHA rules are actually very similar. There are differences, but in general, if you are following the OSHA rules correctly, you are most likely very close to complying with the EPA. (one difference: the EPA requires certification)

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