Exposure to lead dust may occur during target shooting, gun cleaning, and during
range maintenance activities. Poorly designed ventilation systems and the use of
improper range cleaning practices, such as dry sweeping of settled
lead-contaminated dust, can result in high airborne concentrations. The use of
poor hygiene practices can result in additional exposures. Employees can also
track lead dust on flooring of a firing range to areas outside of the range such
as to their vehicles or homes. High concentrations of lead on surfaces and in
the air have been found in firing ranges within the state. In one case, a lead
concentration over 10,000 micrograms per square foot (µg/ft²) was found on
flooring at the 3 yard mark in a firing range. A lead concentration of 900
µg/ft² was found on flooring at the 10 yard mark and over 200 µg/ft² was found
on a tabletop inside the range.
To minimize exposure to contaminants resulting from
weapons firing, ensure that adequate ventilation is maintained in the range. The
ventilation system should be in operation at all times while the range is in use
as well as during clean-up. The range should be maintained under negative
pressure relative to adjacent areas. Also, air should move downrange in as
laminar (non-turbulent) a flow as possible.
An appropriate schedule and method of cleaning should
be implemented to eliminate settled lead dust inside the firing range. Surfaces
should be cleaned with a vacuum cleaner equipped with a high efficiency
particulate air filter. Use of compressed air or a hand broom should be
prohibited. Wet methods should be used to clean surfaces which cannot be cleaned
adequately with a vacuum.
The consumption of food and beverage should be
prohibited where working surfaces may be contaminated by lead dust. Good
personal hygiene practices should be stressed. Employees should wash their hands
upon leaving a range and prior to eating, drinking, or smoking.
Also, the use of jacketed bullets and/or lead-free
bullets should be considered to reduce exposures resulting from the bullets
themselves.
Lead in Ceramic Glazes
Ceramics
instructors, custodians, and other employees who work in ceramics rooms may be
at risk of exposure to lead from lead-containing glazes and stains used on
pottery pieces. Ceramics studios often contain pre-molded pottery pieces and a
variety of stains and glazes. Patrons select a pre-fired ceramic piece and
decorate/color it with a stain and/or glaze. The glazed pottery is then baked in
a kiln to vitrify the glazes. Acrylic stains and nontoxic glazes may be used.
However, lead-containing glazes may also be used. Semi-opaque gloss, opaque
gloss, and crystal glazes containing lead have been found in ceramics studios in
the state. Surface contaminations with lead have been found in senior centers
and other facilities where ceramic workshops are held. In one case at a senior
center, a lead concentration of over 70,000 micrograms per square foot (µg/ft²)
was found on flooring near shelves where stains and glazes were stored. A lead
concentration of almost 3,000 µg/ft² was found on a tabletop and a lead
concentration of 8,500 µg/ft² was found on a shelf in the room. Additionally, a
lead concentration of 1,800 µg/ft² was found on flooring by the kiln. These
results indicate high surface contamination with lead. It should be noted that
food and drink are often permitted in ceramics rooms which could result in
additional lead exposures via the ingestive route. Lead-containing
glazes should be replaced with lead-free glazes where possible. Also, consider
having an evaluation conducted for surface contamination if lead-containing
glazes have historically been used.
Lead
in Drinking Water
Lead
can pose an ingestion hazard when present in drinking water as a result of wear
and corrosion of lead-containing materials in the water distribution and
plumbing systems. Sources of lead include lead solder used in pipes, lead water
pipes, and plumbing fittings and faucets made from brass or bronze which may
contain lead.
Evaluations for lead in drinking water may be considered for facilities which
have lead pipes or where there are signs of corrosion in old plumbing systems.
Additional measures to take include flushing tap water prior to use and avoiding
the use of hot tap water for food and drink preparation.
Other Sources of Lead Exposures
Due to
the extensive use of lead in industry, there are numerous other occupational
settings where lead exposures may occur including, but not limited to, bridge
repair, plating operations, scrap metal recycling, furniture refinishing,
machining lead-containing metals, and the manufacturing of batteries, leaded
glass, ammunition, explosives, leaded dyes, inks, glazes, and pigments.
OSHA’s General
Industry Lead Standard
OSHA’s general industry
lead standard applies to all occupational exposure to lead with the exception of
the construction industry and agriculture industry which are regulated
separately. The standard is designed to protect workers from the hazards of lead
exposure.
The standard established
two threshold levels for exposure to airborne lead. The Permissible Exposure
Limit (PEL) is the maximum concentration of lead that an employee can be exposed
to averaged over an eight-hour period. The PEL for lead is set at 50 micrograms
of lead per cubic meter of air (50 µg/m³) as an eight-hour time-weighted
average. Employers are required to ensure that no employee is exposed to
airborne concentrations of lead over the PEL.
The action level (AL)
for lead is set at 30 µg/m³ as an eight-hour time-weighted average. The AL is
the level which triggers additional requirements under the lead standard such as
periodic exposure monitoring, biological monitoring, medical surveillance, and
employee training.

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Each employer who has a workplace or work
operation covered by the standard must perform an initial assessment to
determine if any employee may be exposed to lead over the action level.
Exposures above the action level (30 µg/m³) require exposure monitoring
every 6 months, the institution of a medical surveillance program (for
employees exposed above the action level for more than 30 days per year)
and the institution of a training program. Exposures above the
permissible exposure limit (50 µg/m³) require the implementation of a
written compliance program; engineering, work practice & administrative
controls; hygiene facilities and practices; respiratory protection;
personal protective equipment and clothing; posting of warning signs,
and exposure monitoring every 3 months.
Employees subject to airborne lead at any level must
be informed of the content of Appendices A (“Substance data sheet for
occupational exposure to lead”) and B (“Employee standard summary”) of the Lead
Standard. Inadequately informed employees are unaware of the hazards the
workplace may present to them, and therefore may not adequately protect
themselves.
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OSHA’s Construction
Industry Lead Standard
OSHA’s
lead in construction standard applies to all construction work where an employee
may be exposed to lead. Activities related to construction, alteration, and
repair, including painting and decorating, are covered under this standard.
Each
employer who has a workplace or operation covered by this standard must
initially determine if any employees may be exposed to lead at or above the
action level. Until the employer performs an employee assessment as required
under paragraph (d) of the standard and determines actual employee exposure, the
employer must provide employees performing certain tasks which are identified in
the standard (i.e. manual scraping/sanding of lead-based paint; abrasive
blasting, welding, and torch burning on materials with lead-containing coatings;
etc.) with interim protective measures. These measures include appropriate
respiratory protection, appropriate personal protective clothing, change areas,
hand washing facilities, and biological monitoring (blood sampling and analysis
for lead and zinc protoporphyrin levels). Interim protective measures for
exposure to lead also include training as required under paragraph (l)(1)(i) of
the standard regarding Hazard Communication; training as required under
paragraph (l)(2)(ii)(C) of the standard, regarding use of respirators; and
training in accordance with 1926.21, safety training and education.
For each employee who is
subject to exposure to lead at or above the action level (30 µg/m³) on any day,
based on the exposure assessment, the employer must also provide and assure
employee participation in a training program in accordance with paragraph (l)(2)
of the standard. The training must include:
-
The content of the Lead Standard and its
appendices;
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The specific nature of the operations which could result in exposure to
lead above the action level;
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The purpose, proper selection, fitting, use,
and limitations of respirators;
-
The purpose and a description of the medical
surveillance program, and the medical removal protection program including
information concerning the adverse health effects associated with excessive
exposure to lead;
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The engineering controls and work practices
associated with the employee’s job assignment including training of employees to
follow relevant good work practices described in Appendix B of the standard;
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The
contents of any compliance plan in effect;
Instructions to employees that chelating agents
should not routinely be used to remove lead from their bodies and should not be
used at all except under the direction of a licensed physician;
It should be noted that most of the provisions of the lead standard are
triggered by lead exposure levels. Exposures above the action level (30 µg/m³),
in addition to the training requirements noted above, also require exposure
monitoring and blood sampling every 6 months. Exposures above the permissible
exposure limit (50 µg/m³) require the implementation of a written compliance
program; engineering, work practice & administrative controls; hygiene
facilities and practices; respiratory protection; personal protective equipment
and clothing; posting of warning signs; and exposure monitoring every 3 months
CONN-OSHA Citations
and Report of Hazards for Lead
In
the public sector, CONN-OSHA has issued 270 citations and report of hazards for
lead hazards under the Lead Standards, 1910.1025 and 1926.62. Of these,
approximately 50% were issued for Public Safety Departments including Police,
Fire, Corrections, and Courts. Forty-two citations and reports of hazards were
issued for public schools and libraries and thirty were issued for general
government offices. Additionally, twenty-three citations and report of hazards
were issued to public works and transportation services and twenty-two were
issued for maintenance garages. The remaining were in electric, gas and sanitary
services as well as other public sector units.
Some recommendations for employers include:
-
Identify
areas where employees may be exposed to lead. Check for work processes which
could generate lead dust or fume.
-
Perform an initial assessment to determine if any employee may be exposed
to lead at or above the action level. Appropriate protective measures, as
identified in the Lead Standards, should be taken based on exposure levels.
-
Maintain
all surfaces in the workplace as free as practicable of lead accumulations.
Develop a plan to address any chipping and peeling paint in facilities.
-
You
may also request a free consultation visit from CONNOSHA to help address any
concerns regarding lead exposures in the workplace. For more information
regarding OSHA’s Lead Standards for General Industry and Construction Industry,
visit OSHA’s web site at
www.osha.gov.
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Hazard Corner...Lead Exposure
Occupational lead exposure can occur in more than 100
industries and include operations such as battery manufacturing or recycling,
scrap metal handling, ceramics or plastics manufacturing, metal radiator repair,
demolition of old structures, renovating firing ranges, abrasive blasting, lead
abatement, and welding on metal structures. In addition to being exposed at
work, workers carry lead home on their body, clothes, shoes, or in personal
vehicles. This “take-home” exposure endangers their family members.
Exposure to lead can adversely affect multiple organ
systems and can cause permanent damage, including hypertension, renal
dysfunction, cognitive dysfunction, and birth defects or miscarriages. Early
symptoms are non-specific and include fatigue, headache, sleep disturbance,
depression, hypertension, and central nervous system deficits. Children under 6
years of age and fetuses are especially sensitive to neurological damage. Lead
exposure becomes a concern with a Blood Lead Level (BLL) of 10 μg/dL (micrograms
of lead per deciliter of whole blood). For pregnant women, the level of concern
drops to a BLL of 5 μg/dL. OSHA regulations require written notification and
medical examination of employees with a BLL of 40 µg/dL; medical removal from
exposure is required at a BLL of 60 µg/dL
Case Study
A worker in scrap metal-recycling saw his personal
physician for muscle pains of a few months’ duration. His (BLL) was 37 μg/dL.
He went home twice daily in his work clothes. When tested , his 10month-old
child’s BLL was 26 μg/dL. The worker informed his employer; 16 co-workers were
tested. In all, 10 of 17 workers had BLLs ≥ 40 μg/dL (2 > 60 μg/dL); 7 had BLLs
ranging from 26 to 39 μg/dL. Five workers each had a child ranging in age from 8
months to 2 years with BLLs 14 to 26 μg/dL. In total, 22 individuals were
identified with significant lead exposure.
The work involved cutting and bailing lead-sheathed
cable. The company relied on initial air monitoring with low airborne lead
levels of 2 micrograms per cubic meter (μg/m³) and did not implement a lead
safety program. Repeat air-monitoring results were up to 240 μg/m³; all workers
cutting cable were exposed to air levels above the OSHA Permissible Exposure
Limit of 50 μg/m³.
While the toxic effects of lead exposures are well
recognized, and despite regulatory requirements, many employers in industries
with lead exposure do not provide routine blood lead testing for employees.
Sources:
-
http://www.cdph.ca.gov/programs/olppp/Documents/medgdln.pdf
-
http://www.cdph.ca.gov/programs/olppp/Documents/
family_lead_poisoning.pdf
-
http://www.cdph.ca.gov/programs/olppp/Documents/
-
adult_testing.pdf
http://www.atsdr.cdc.gov/csem/csem.asp?csem=7&po=8
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CONNECTICUT-OSHA ~
Training Update...
Hazard Communication
December 13, 2011, from 10:00 to noon
This OSHA standard requires four elements to be
covered in order to assure that employees are effectively protected from
chemical injury or illness. A written program, MSDS’s, Labeling and employee
information and training. This class will discuss these elements.
OSHA Recordkeeping December 14, 2011,
from 8:30 a.m. to noon At this
workshop, you will learn how to fill out the OSHA 300 Log of Work-Related
Injuries and Illnesses accurately and correctly.
Material Handling & Ergonomics January
10, 2012 from 10:00 a.m. to noon
Confronted with making ergonomic improvements to an existing manufacturing
process or office environment but have run out of ideas? Several manufacturing
case studies will be reviewed that have improved worker safety and health with
minimum cost. This session will help attendees develop a process for recognizing
and quantifying risks, creating cost-effective solutions, and documenting the
effectiveness of the results.
Workplace Violence February 7, 2012,
from 10:00 a.m. to noon This workshop
is designed to make you more aware of some of the issues related to the
workplace and to provide tools to help manage, defuse and prevent it.
Construction Site Safety February 15,
2012 2012, from 9:00 a.m. to noon
Construction managers, first line supervisors, and construction employees will
be provided with an overview of four areas of concern on the construction site.
Program contents include: fall protection, scaffolding and ladders, electrical
hazards, and trenching safety.
Breakfast Roundtable This
discussion group meets the third Tuesday of every month from 8:15 am to 9:45
am. Pre-registration is required. To be placed on the e-mail distribution
list, contact John Able at
able.john@dol.gov
Classes are free and held at 200 Folly Brook Boulevard, Wethersfield, CT in
Conference Room A/B. To register, contact John Able at
able.john@dol.gov
or Catherine Zinsser at zinsser.catherine@dol.gov.
Pre-registration is required. A Photo I.D. is required to allow entry into a
public building. For more training information, visit the CONN-OSHA web site
www.ctdol.state.ct.us/osha/osha.htm