Section C-4 Procedures

Use these procedures when employee exposure assessment shows average airborne lead level will be over 50,000 ug/m3 for the work day.  All alternatives should be explored before working in exposure levels such as these! 

Exp​osure Assessment

All affected employees must be notified of air monitoring results within 5 days of receiving them.

Include a statement that exposure was above 50 ug/m3 (PEL) and describe corrective action to reduce exposure to below that level.

Re-monitoring is required every 3 months or if conditions change such that lead exposure levels may increase.

May discontinue monitoring if 2 consecutive tests 7 or more days apart are below 30 ug/m3.

Must re-monitor after discontinuing if changes may result in higher employee exposure levels.

Metho​ds of Compliance

Implement all feasible engineering and work practice controls to reduce and maintain exposure at or below 50 ug/m3.  If exposure not below 50 ug/m3 with controls, supplement with respirators.

Establish a written program that is revised and updated every 6 months and includes necessary elements per OSHA regulations.

Maintain mechanical ventilation as necessary.

If used, establish and implement administrative controls including assessing their reliability.

Ensure good work practices from OSHA 29 CFR1926.62 Appendix B are followed.

Respiratory Protection

Provide all potentially exposed workers a NIOSH approved pressure-demand SCBA  respirator at no cost to the employee.

Perform medical surveillance on each respirator user.

Assure respirator fits properly and has minimum leakage.

Perform initial and annual fit tests for tight fitting respirators following 29 CFR 1926.62  Appendix D.

Have respirator program per 29 CFR 1910.134.

Protective Clothing and Equipment

Provide at no cost and require use of:

  • Coveralls or similar fully-body work clothing.
  • Gloves, hats, and shoes or disposable shoe coverlets.
  • Face shields, vented goggles, and other appropriate equipment per 1910.133.
  • Provide clean protective clothing daily.
  • Provide for cleaning, laundering, or disposal of PPE.
  • Repair or replace PPE to maintain effectiveness.
  • Employees remove work clothing at end of shift in change areas provided.
  • Contaminated clothing into closed container for cleaning, or disposal.
  • Inform laundry of potential harmful effects of lead exposure.
  • Containers of contaminated clothing and equipment are properly labeled.
  • Prohibit lead removal from PPE by blowing, shaking, or any method that disperses it into the air.

Housekeeping

Keep all surfaces as free of lead as possible using methods that minimize airborne lead.

Shoveling, dry or wet sweeping, and brushing can only be used if vacuuming and other effective  methods were tried and found not effective.

Use vacuums with HEPA filters, and use and empty in a manner to minimize reentry of lead.

No compressed air to remove lead except with an adequate ventilation system to collect the dust.

Hygiene Facilities and Practices

No food, beverage, tobacco, or cosmetics allowed or used in areas above 50 ug/m3.

Clean change areas with separate storage of work and street clothes to prevent contamination required for employees.

Ensure employees do not leave workplace wearing clothing or equipment required during the work shift.

Provide showers where feasible, have workers shower at end of work shift, provide towels and cleaners.

Eating facilities

Provide readily accessible lunchroom or eating areas as free of lead contamination as feasible.

Make sure workers wash hands and face prior to eating, drinking, smoking or applying cosmetics.

Workers do not enter lunchroom or eating areas wearing PPE unless surface lead dust was removed.

Hand washing facilities

Provide adequate hand washing facilities for exposed employees.

Where no showers are present, ensure employees wash hands and face at end of shift.

Medical surveillance

Make initial medical surveillance available to exposed employees.

Provide employee results of biological monitoring within 5 days of receipt.

Notify employee with a blood lead exceeding 40 ug/m3 of temporary medical removal.

Other issues to be determined with medical provider include medical exams and consultations, possible use of chelating agents, and medical removal protection.

Medical evaluation of respirator use.

Employee information and training

Communicate lead hazard information and training to employees per Hazard Communication

Standard, including warning signs, labels, MSDS, and information and training. 

Also provide initial and annual training on the following:

  • Content of lead standard and appendices.
  • Specific nature of operations that can cause exposure to lead above action level.
  • Elements of respirator program and purpose, proper selection, fitting, use, and limits of respirators.
  • Medical surveillance program, medical removal protection program including adverse health
  • effects of excessive lead exposure (reproductive effects, fetus hazards, and pregnancy precautions).
  • Engineering and work practice controls associated with job assignment including relevant good  work practices in OSHA 29 CFR 1926.62 Appendix B.
  • Contents of any compliance plan in effect.
  • Instruction that chelating agents should not be used routinely and only under doctor direction.
  • Employee right to access records.

Access to information and training materials

Make copy of standard and appendices available to affected employees.

Provide all lead hazard information and training to employees per Hazard Communication Standard.

Signs

Post clear legible warning signs with the following information at entrances to areas where lead exposure exceeds 50 ug/m3.

Illuminate and clean signs as necessary so readily visible.

Recordkeeping

Maintain the following records as required by OSHA:

  • Exposure assessment.
  • Exposure assessment monitoring.
  • Maintain records until no longer needed but at least 30 years.
  • Written documentation of respirator program and fit tests must be kept.  
  • Medical surveillance
  • Medical removals.
  • Availability of records.   
  • Make available to employees, former employees, employee representatives, and OSHA.
  • Transfer records to successor employers and to OSHA if no successor employer.
  • Notify OSHA 3 months before disposal of records.
  • Comply with requirements of 29 CFR 1910.20(h).

Observation of monitoring

Provide affected employees or designated representatives opportunity to observe lead monitoring.

Observer can enter regulated area if required provided he/she complies with safety and health procedures uses appropriate PPE provided by employer.

Without interfering with monitoring observer can:

  • Receive explanation of measurement procedures.
  • Observe all steps related to monitoring.
  • Record or receive copy of laboratory results.