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Non-Construction Activities

Potential Workplace Exposures

While many exposures to lead are non-occupational, there are some potential workplace exposures. The majority of overexposures occur in the manufacturing sector, in industries that make batteries, aircraft, plumbing fixtures, etc. Examples of potential non-construction, occupational exposures include:

  • Disturbing lead-based paint on painted surfaces or structures without using wet methods or dust control; 
  • Dust or paint chips from deteriorating lead-based paint in the work area if the debris is disturbed or not handled properly;
  • Use of products containing lead (ex. solder, lead-acid batteries, plumbing, pottery glazes, paints, or ammunition);
    • Review the product Safety Data Sheet for suspect materials to determine if they contain lead.
  • Welding, cutting, brazing, or soldering with lead, or on lead-based paint on a substrate;
  • Foundry or metal-working (casting, grinding, polishing, buffing, smelting, and refining); or
  • Use of lead-containing chemicals.

Exposure Assessment

If lead is present in the workplace in any quantity and there is a potential for airborne, inhalable lead dust or fumes to be generated, an initial determination of whether or not the Action Level (AL) is exceeded for any employee must be made. Exposure monitoring for lead is conducted to determine if there is an employee exposure at or above 30 ug/m3, averaged over an 8-hour period. Employees selected to be included in monitoring are based upon information, observations, calculations, historical monitoring, or complaints of symptoms attributable to lead. 

Once monitoring has been completed by Environmental Health & Safety, employees will be notified in a timely manner of the results, and any necessary corrective actions to be taken to reduce or eliminate overexposure will be communicated to the department.

Initial Assessment

Initial monitoring to determine exposures may be limited to a representative sample of exposed employees who are reasonably believed to have the greatest airborne concentrations of lead exposure. 

  • Where monitoring results show a possibility of exposure at or above the Action Level, monitoring will be conducted for each employee exposed to lead. 
  • Where monitoring results indicate that employees are not exposed at or above the Action Level, results shall be documented, and future monitoring is not necessary unless there are changes in the production, process, controls, or new potential exposures to lead.
  • Where initial monitoring indicates employee exposure above the Permissible Exposure Limit (50 ug/m3), controls shall be implemented to reduce or eliminate exposure, and monitoring shall be repeated quarterly.
    • Monitoring shall be repeated every six months where exposure is above the Action Level, but below the Permissible Exposure Limit (PEL). 
    • Subsequent monitoring shall be in accordance with OSHA requirements specified in 1910.1025.

Preventative Measures

Preventative measures to minimize or eliminate potential exposures to lead include:

  • Reporting deteriorating paint in buildings to your facilities management contact for mitigation. 
  • Using approved work practices to clean up any dust or debris. 
  • Training individuals who may encounter lead-containing paint, or other lead materials, during their normal work activities so that precautions can be taken prior to exposures. 
  • Involving EHS in the evaluation of activities that involve the heating or handling of lead materials, such as solder, coated metals, glazes, lead chemicals or products, etc.
  • Developing standard work practices and procedures that will allow renovation, construction, or maintenance to be performed safely, and without exposing employees, building occupants, or members of the public to airborne or surface lead dust hazards. Procedures include:
    • Work Order Reviews
    • Standard Work Practices

Where any employee is exposed to lead above the Permissible Exposure Limit (PEL) for more than 30 days per year, engineering and administrative controls to reduce exposure to lead shall be implemented. Such controls include, but are not limited to:

  • Medial surveillance
  • Use of personal protective equipment, as necessary, including respiratory protection
  • Local exhaust ventilation
  • Dust control methods on power tools
  • HEPA-filtered vacuums
  • Wet methods for cleaning
  • Avoiding the use of prohibited methods of cleaning, such as the use of compressed air or shoveling and dry sweeping
  • Awareness level training
  • Warning signs where exposure is above the PEL