Entries tagged with “leaded paint”.


Unfortunately this website has taken a backseat to actual work. My apologies for not updating the information, and especially to trusted subscribers of this site.

In the coming months, I plan to publish more posts with the same type of information. Thanks for hanging on. – Alden

As a preview: Did you notice that the State of Michigan OSHA (MIOSH) has updated (lowered) their lead (Pb) blood level mandates? Sadly, it took a lot of people being overexposed to lead (remember Flint, MI?) in order to make this simple change. I hope other states follow.

Looking back at my lead in construction posts, I realized I did an inadequate job of summarizing why construction activities are dangerous when working with lead.

If you work in construction, here’s are the quick points as to why you should be concerned about lead.

  • There has been A LOT of lead added to paint over the years. (it can vary 0.01% to upwards of 20%, and there’s no way to tell by looking)
  • The activities we do in construction disturb this paint (some worse than others)
  • You can be exposed to paint by inhaling it (if it is airborne), and if you happen to get it on your hands and you eat it (by transfer).
  • The real concern is kids. (your kids, the kids who might be there after you’re gone, AND, the kids unborn (lead exposure can go from mom to baby)

The solution is simple (and, of course, more complicated as you dig in):

  • test the paint to see if there’s lead in it
  • if you disturb it, follow the rules (OSHA, EPA, HUD, City, etc.)
  • train your employees (and measure the lead in their blood)
  • prevent the dust from going everywhere (containment)
  • measure the air to see if you are really screwing it up, or doing a good job.
  • finally clean up. (the area, you, your hands, the perimeter) and dispose properly

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.

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)