The long battle against lead exposures

By Bill Noone

Last summer OSHA announced a national emphasis program (NEP) designed to get the lead out. Literally. The program, which applies to all workplaces under OSHA's jurisdiction including general industry, construction and others, is aimed at reducing occupational lead exposure, one of the leading causes of workplace illnesses.

Lead, of course, is found in industrial paints because of its characteristic to resist corrosion. Industries that are particularly high at risk include: construction work involving such tasks as welding, cutting, brazing and blasting on lead paint surfaces; most smelter operations; secondary lead smelters where lead is recovered from batteries; radiator repair shops; and firing ranges.

The fight against lead, a systemic poison that can cause damage to a person's blood-forming, nervous, urinary or reproductive systems if chronically exposed to it, has been ongoing for decades. In 1996 OSHA began a five-year plan to reduce occupational lead exposures by 15 percent by the end of FY2002, a goal established in the agency's Strategic Plan. The NEP (Directive Number CPL 2-0.130) issued in July 2001 gives direction to OSHA's field inspectors and is intended to demonstrate improved performance in addressing lead exposure and devising a system for measuring results.

As part of the initiative, OSHA is collecting sample data to see if its efforts are making a difference in decreasing lead exposures. The primary reason for the NEP, which formalizes the program to sample the data, is to see how and if OSHA is affecting change in lead exposures in industry.

Exposure is down

Based on the sampling data accumulated through this program, OSHA reports a decrease of 35 percent in measured airborne lead exposure from 2000 compared to the baseline year (1996), according to an OSHA spokesperson. This is more than twice the 15 percent goal. In general, industry knows that the agency is focusing on this particular hazard, and the program has raised awareness of occupational lead exposure.

Despite gains made in the battle against lead exposure, certain work environments still are very much at risk (see sidebar below). So what can a company do to protect its workers against lead? OSHA says respirators must often be used to supplement engineering controls and work practices whenever these controls are technologically incapable of reducing worker exposures to lead to or below 50 ug/m(3) (Fact Sheet No. 93-51).

Multi-faceted defense

Removing lead through engineering controls is the ideal way to combat lead exposure, according to OSHA. These controls include local exhaust ventilation, general dilution ventilation and substituting lead materials with less toxic materials in work processes. NIOSH, in a 1997 report to Congress on protecting workers exposed to lead-based paint hazards, also recommends engineering controls as the primary means of protecting workers.

Not surprisingly, personal hygiene also plays a role in limiting lead exposure. OSHA suggests that when working in environments where there may be airborne lead exposures, employees should avoid eating, drinking, smoking, chewing gum or tobacco, or even applying cosmetics. They should also wash their hands and face before eating, take a shower at end of the day and leave any contaminated work clothes at work - don't take them home.

After incorporating engineering controls and emphasizing personal hygiene, the next line of defense is personal protective equipment such as respirators and gloves. When respirators are used, the employer must establish a comprehensive respiratory protection program as required by the OSHA respiratory protection standard (29 CFR 1910.134) and the construction lead standard (29 CFR 1926.62).

A proper program

To provide adequate respiratory protection in environments where there's high exposure to lead, OSHA recommends that respirators be donned before entering the work area, and they should not be removed until the worker has left the area, or as part of a decontamination procedure. Employers must supply properly selected and fitted respirators at no cost to employees, and employers must perform either qualitative or quantitative fit tests for each employee wearing negative-pressure respirators. Fit testing is to be performed at the time of the initial fitting and at least semiannually thereafter.

Minimum requirements for an acceptable respirator program for lead include the following characteristics:

Written standard operating procedures. These are necessary for governing the selection and use of respirators. Not only do written procedures need to be in place, but managers must see to it that they are strictly adhered to.
Knowledge of hazards. Respirators must be selected on the basis of hazards to which the worker is exposed. Basically, know the hazards of the industry you're working in. If you're creating a particulate in the process of your work, know what the potential hazards and levels of that exposure are. Lead environments require a 100-series filter (N-100).
Instruction and training. Employees must be trained in the proper use of respirators, including their limitations. Outreach and training is a key element of the OSHA national emphasis program on reducing lead exposure.
Regular inspection, cleaning and maintenance. Respirators need to be disinfected on a regular basis. Worn or deteriorated parts must be replaced, including the filter element in an air-purifying respirator whenever an increase in breathing resistance is detected.
Proper storage. Respirators should be stored in a convenient, sanitary location and protected against sunlight and physical damage.
Work area surveillance. Work area conditions and the degree of worker exposure or stress (physiological or psychological) should be surveyed regularly.
Program evaluation. From time to time the respiratory program needs to be evaluated to determine its continued effectiveness.
Physician's approval. A physician should annually determine whether the employee is physically able to perform the work and wear a respirator while performing the work.
Certification. Respirators need to be certified by the Mine Safety and Health Administration/National Institute for Occupational Safety and Health (MSHA/NIOSH).
Fit testing. This is needed for negative-pressure respirators.
Proper breathing air. Breathing air used for supplied-air respirators must meet the requirements prescribed in 1910.134(d)(1).
Wash breaks. Employers should give employees standing permission to leave the work area to wash their faces and respirator face pieces whenever necessary to prevent skin irritation associated with respirator use.

When selecting a respirator remember that lead concentrations can vary substantially throughout a workshift as well as from day-to-day. The highest anticipated work concentration is to be used in the initial selection of an appropriate respirator.

SIDEBAR: Lead hot spots

The following industries (categorized by Standard Industrial Classifications) are known to produce historically high levels of employee exposure to lead, according to OSHA: