In 1977, the U.S. government’s Consumer Product Safety Commission banned lead-based paint (LBP). Though banned more than 30 years ago, LBP is still prevalent throughout residential, commercial and industrial buildings. Therefore, it is important to recognize and protect against potential occupant and employee exposure hazards associated with lead.

It is very likely painted surfaces in structures built prior to 1978 contain LBP and the older the structure; the more likely LBP is present. Even if lead-containing paint has been painted over and encapsulated, lead dust can still become airborne during renovation or restoration activities. It is common for companies doing renovation work fail to recognize the potential for LBP on the surfaces they are impacting. This potential lead exposure can be avoided with general awareness.

The most common cause of lead-containing dust is due to construction of commercial or residential structures. These renovation and demolition activities that disturb LBP can present a hazard for the workers. Currently, the Occupational Safety and Health Administration (OSHA) Lead in Construction Standard 29 CFR 1926.62 covers these employees and it is the employer’s responsibility to implement the standard. In addition to having lead hazards protocol as part of a company’s general health and safety plan, project-specific plans must be developed describing how lead hazards will be reduced and how employees will be protected.

At a minimum, lead awareness training is required for those employees that may come into contact with LBP or lead containing products (e.g., solders, piping, etc.). In addition, an exposure assessment must be performed in all workplaces where employees may be exposed to lead. This monitoring should include at least one sample for each job classification in each work area either for each shift or for the shift with the highest exposure level. If the initial determination shows exposures less than the action level (AL), no further assessment is needed until there has been a change of equipment, process, control, personnel or a new task has been initiated. If the initial determination is at or above the AL but at or below the PEL, then monitoring shall be done at least every six months. If the initial determination is above the permissible exposure limit (PEL), then monitoring shall be done quarterly.

Currently, the OSHA AL for lead is 30 µg/m3 and the OSHA PEL is 50 µg/m3. For those employees who may be exposed at or above the action level for a single day must be enrolled into a medical surveillance program. This medical program requires the employee to be given a physical by a licensed physician and have his/her blood drawn to determine the baseline for his/her blood lead level (BLL), which is then monitored periodically. Also, the physician will need to evaluate the employee for respirator use and determine he/she is physically fit to wear one. Once this is complete, a respirator fit test must be performed for the exact respirator(s) he/she will be using.

The type of respirators to be used and the level of medical surveillance required are based on exposure assessments performed on the employee performing a specific task. Exposure assessments are based primarily on personal air sampling results, but other data can be used to help determine the potential exposure to lead. The other types of data may include past air samples (no older than one year), paint chip bulk sample results, building specifications, verbal information and X-ray Fluorescence (XRF) results. Until the exposure assessment is concluded, the employer must protect the employee based on the task he/she will be performing. This interim protection is required and includes hand washing facilities, medical surveillance, training and providing the appropriate personal protective equipment (PPE).

Construction tasks have been generally categorized to identify the correct type of respirator that may be needed to protect the employee during the task until the exposure assessment is completed. For easy understanding, the tasks have been labeled based on their risk:  low, medium and high. An example of a low risk activity is manual demolition, scraping and sanding. A medium risk activity would be the use of a power tool (e.g., grinder) that does not have a dust collection system; while an example of a high-risk activity would be abrasive blasting, welding and cutting. If conditions change, such as personnel, equipment or procedures, then additional exposure assessment(s) must be conducted.

In addition to air monitoring in order to establish a negative exposure, lead safe work practices are very important on the job site. These work practices consist of occupant protection, worksite preparation and containment. There are a number of prohibited methods of paint removal including, but not limited to: no open flame burning or torching, no machine sanding or grinding without proper exhaust control, no abrasive blasting or sandblasting without proper exhaust control, no heat guns above 1,100 degrees Fahrenheit, no dry sanding or dry scraping.

The key is by controlling lead dust both worker and occupant exposure will be reduced. The use of engineering controls also will aid in the reduction of lead dusts and the potential for exposure. Some of the basic engineering controls include barriers, enclosures, ventilation or the use of power tools which utilize dust collection systems. When finished with a task, keeping any waste appropriately contained and labeled will also be important in controlling exposures.

In addition to the OSHA Lead in Construction Standard, as of April 22, 2010, the Lead Renovation, Repair and Painting (RRP) rule must be followed.  This rule affects any company or individual performing work on LBP in target housing and child-occupied facilities where more than six square feet per room or 20 square feet outside will be "disturbed" by worker(s) being compensated for the job. The rule requires individual certification, firm certification, on-the-job training, paint testing, use of lead safe work practices and cleaning verification.

Sometimes we do not realize lead is still in our environment. Being aware of the hazards at home and ensuring employers are complying with OSHA standards, and now the RRP rule, at work can greatly reduce lead hazards as well as prevent incidents of worker and occupant lead poisoning.