Lead Standards

It shall be the policy of ESCO Group to implement the various requirements of the lead exposure regulation as required by the U.S. Department of Labor, Occupational Safety and Health Administration.

1. Background

a) The interim final rule, published on May 4th, 1993, amends the OSHA standards for occupational health and environmental controls in Subpart D of the title 29 Code of Federal Regulations (CFR) 1926 by adding a new section 1926.62, containing employee protection requirements for construction workers exposed to lead.

2. Scope and Application

a) ESCO Group shall assume that no employee is exposed to lead at concentrations greater than fifty micrograms per cubic meter of air (50 ug/m3) averaged over an 8hour period.

b) For the purpose of our program, lead includes metallic lead, all inorganic lead compounds and organic lead soaps.

c) ESCO Group Incorporated’s lead in construction program applies to all construction work where an employee may be occupationally exposed to lead.  All work related to construction, alteration or repair including painting and decorating – is included.  Under our plan, construction includes, but is not limited to, the following:

i. Demolition or salvage where lead or material containing lead are present;

ii. Removal of encapsulation of materials containing lead;

iii. New construction, alteration, repair, or renovation of structures, substances, or portions containing lead;

iv. Installation of products containing lead;

v. Lead contaminated from emergency cleanup;

vi. Transportation, disposal, storage or containment of lead or materials containing lead on the site of location at which construction activities are performed;

vii. Maintenance operations associated with construction activities described above.

3. Limits

a) ESCO Group programs establish maximum limits of exposure to lead for all workers covered, including permissible exposure limits and action level.  The permissible exposure limit, or PEL, sets the maximum workers exposure to lead.  For example, no employee may be exposed to lead at airborne concentrations greater than 50ug/m3 averaged over an 8hour period.  If employees are exposed to lead for more than 8 hours in any workday, the following formula must be used to reduce exposure as a TWA:

b) Employee exposure (in ug/m3) = 400 divided by hours worked in the day.

4. Action Level

a) Action level is the level at which ESCO Group will begin compliance activities.  The action level, regardless of respirator use, for the lead in ESCO Group’s program is an airborne concentration of 30ug/m3 calculated as an 8 hour TWA.

5. Assessing Exposures

a) Where initial employee exposure is at or above the action level ESCO Group will collect samples representative of a full work shift, including at least one sample for each shift or for the shift with the highest exposure level for each job classification in each work area.  These samples represent the monitored employee’s regular, daily exposure to lead.  Measurement made within the previous 12 months also may be used to determine how far above the action level employee exposure may be.

b) An initial determination of whether employees are exposed to lead at or above the action level and the results of that determination will be made available based on the following:

i. Any information, observation, or calculation that indicates employee exposure to lead;

ii. Any previous measurements of airborne lead;

iii. Any employee complaints of symptoms attributable to lead exposure and objective data regarding materials, processes and operations.

c) ESCO Group may discontinue required monitoring when at least two consecutive measurements, taken at least 7 days apart, are below the action level.

d) Monitoring for the initial determination whether employees are exposed at or above the action level may be limited to a representative sample of those employees exposed to the greatest concentrations of airborne lead.  Measurements made within the preceding 12 months, which were performed by the same employer and applicable to the same employees’ tasks, may be used.

e) ESCO Group will establish and maintain an accurate record documenting the nature and relevancy of previous exposure date, and may rely on objective data that demonstrates that a particular lead containing material or product does not result in employee exposure at or above the action level when processing, using or handling.

f) Until ESCO Group performs an exposure assessment and documents that employees are not exposed above the PEL providing respiratory protection, protective work clothing and equipment, change areas, hand washing facilities, biological monitoring and training for the following tasks:

i. Manual demolition of structures (i.e.: dry wall), manual scraping, manual sanding, and the use of a heat gun where lead-containing containers or paints are present;

ii. Abrasive blasting enclosure movement or removal;

iii. Power tool cleaning;

iv. Using lead-containing mortar or spray painting with lead-containing paint;

v. Abrasive blasting, rivet busting, or welding, cutting, or burning on any structure where lead-containing coatings or paint are present;

vi. Clean-up activities where dry expendable abrasives are used and any other tasks the employer believes may cause exposures in excess of the PEL

6. Information and Training

a) ESCO Group will inform employees about lead hazards according to the requirements of OSHA’s Hazards Communication standard for the construction industry, 29 CFR 1926.59, including but not limited to the requirements for warning signs and labels, material safety data sheets (MSDS’s) and employee information and training.

b) The following warning signs will be posted in each area where employee exposure to lead is above the PEL:

WARNING
LEAD WORK AREA
POISON
NO SMOKING OR EATING

c) The ESCO Group will provide a training program prior to the time of job assignment for each employee who is subject to lead or lead compound exposure at or above the action level on any day.  Training will be repeated annually and will include the following:

i. The content of the standard and its appendices.

ii. The specific nature of operation that could lead to lead exposure above the action level.

iii. The purpose, proper selection, fit, use and limitation of respirators.

iv. The purpose and description of the medical surveillance program, and the medical removal protection program.

v. The engineering and work practice controls associated with the employee’s job.

vi. The contents of the compliance plan in effect.

vii. The right to access record under “Access to Employee Exposure and Medical Records,” CFR 1910.20.

d) All materials relating to the training program and a copy of the standard will be made readily available to all employees and training will be documented.

e) Health effects of being exposed to lead or lead containing materials:  Some common symptoms of overexposure include loss of appetite, metallic taste in the mouth, anxiety, constipation, nausea, pallor, excessive tiredness, weakness, insomnia, headache, nervous irritability, muscle and join pain or soreness, fine tremors, numbness, dizziness, and hyperactivity.

7. The System

a) ESCO Group will establish a comprehensive system to regulate and protect workers from hazards in lead exposure.  All work must be posted or otherwise identified to inform workers of the danger.

8. Safety Equipment

a) Employees will use OSHA required protective equipment.

9. Compliance Program

a) Prior to each job where exposure exceeds the PEL, ESCO Group will establish an implement in written program to reduce employee exposure to the PEL or below.  The compliance program will provide the following:

i. A description of each activity in which lead is emitted.

ii. Specific plans to achieve compliance and engineering plans and studies where engineering controls are required.

iii. Information on the technology considered to meet the PEL.

iv. Air monitoring data that documents the source of lead emissions.

v. A detailed schedule for implementing the program, including copies of documentation.

vi. A work place practice program including regulations for the use of protective work clothing and equipment and housekeeping any hygiene facility guidelines.

vii. An administrative control schedule for job rotation.

viii. A description of arrangements made among contractors on multi-contractor sites to inform affected employees of potential exposure to lead and their responsibility to comply with this standard.

ix. Any other relevant information.

10. Engineering, Work Practice and Administrative Control

a) When all feasible controls have been instituted, but are not sufficient to reduce employee exposure to or below the PEL, ESCO Group will use respirators to reduce exposure to the lowest feasible level.

i. Engineering Controls – mechanical ventilation may be used to control lead exposure.

ii. Work Practice Controls – safe work practices require maintenance of separate hygiene facilities (change rooms, showers, hand wash facilities (employees shall wash hands, arms, and face if exposed to lead materials at any time), and lunch area) and require proper housekeeping practices.

iii. Housekeeping – all surfaces will be maintained as free as practical of accumulations of lead.

iv. Administrative Controls – will be used to reduce employee exposure by removing the employee from the hazard (for example rotation).

11. Respirators

a) ESCO Group will provide respiratory protection to the employee, and must ensure it is used when:

i. Employee exposure to lead exceeds the PEL.

ii. Engineering and work practices are not sufficient to reduce exposure levels to or below the PEL.

iii. An employee requests a respirator.

iv. As interim protection for employees performing the tasks listed under “Assessing Exposures” section of this publication and section (d) (2) of the standard.

12. Protective Clothing and Equipment

a) ESCO Group will provide and ensure the proper use of personal protective equipment where employees are exposed to lead above the PEL.

13. Record-keeping

a) ESCO Group will establish and maintain an accurate record of all monitoring and other data used to conduct employee exposure assessments.

b) Effective management of worker safety and health protection is a decisive factor in reducing the extent and severity of work related injuries and illnesses and their related costs.  ESCO Group is committed to this process.

14. Lead Storage Areas

a) ESCO Group will post the following warning sign in each work area where lead is being stored:

Lead Storage Area
After Handling Avoid Contamination
Wash Your Hands Before Eating,
Drinking or Using Tobacco Products