UMB Policy on Lead Exposure in Construction
VI-17.14(A) | Administration | Approved
Responsible VP/AVP: Dawn M. Rhodes, DBA, MBA
Purpose
The Occupational Safety and Health Administration (OSHA) interim final standard for "Lead Exposure in Construction," 29 CFR 1926.62, became effective on June 3, 1993. This standard reduces the permitted level of exposure to lead for construction workers. The standard also includes requirements addressing exposure assessment, methods of compliance, respiratory protection, protective clothing and equipment, hygiene facilities and practices, employee information and training, signs, recordkeeping, and observation of monitoring.
Lead is a highly toxic heavy metal that can cause adverse health effects. These effects include peripheral and central nervous system dysfunction, deficiency in the oxygen-carrying material of the blood (anemia), mental retardation, and death. Lead has no beneficial biological effect.
Fetuses and young children are particularly susceptible to lead. Considerable data suggest a correlation between elevated blood lead and delays in early neurological and physical development, cognitive and behavior alterations, alterations in red blood cell metabolism and vitamin D synthesis, and kidney impairment.
Adults are also at risk. A positive association has been found in adult males between elevated blood lead and hypertension. Lead has also been associated with increased risk of cardiovascular disease. Since lead is stored in bone, it may be mobilized during periods of stress, during pregnancy, and among people suffering from osteoporosis.1 Lead exposure also may play a role in miscarriages and in damage to the male reproductive system.
In response to the health risks of working with lead and the University of Maryland Baltimore's (UMB) ongoing commitment to provide a safe and healthy working environment, the following policy has been adopted.
Policy Statement
I. PURPOSE
The purpose of this policy is to establish responsibilities, policies, and procedures for construction activities that disturb lead-containing material.
II. APPLICABLE REGULATION
Lead Exposure in Construction,29 CFR 1926.62, with Maryland Amendments.
III. ACTIVITIES COVERED BY THIS POLICY
This policy applies to all construction work where a UMB employee may be occupationally exposed to lead. Construction work is defined as work for construction, alteration, or repair, including painting and decorating. It includes but is not limited to the following:
- Demolition or salvage of structures where materials containing lead are present;
- Removal or encapsulation of materials containing lead;
- New construction, alteration, repair or renovation of structures, substrates, or portions thereof, that contain lead, or materials containing lead;
- Installation of products containing lead;
- Lead contamination/emergency cleanup;
- Transportation, disposal, or storage of lead containing materials on the site or location at which construction activities are performed;
- Maintenance operations associated with the construction activities described above.
IV. EXEMPTIONS
In 1978 the Consumer Product Safety Commission (CPSC) established a maximum lead content in paint of 0.06%. Based on this, construction work that only disturbs paint in buildings built after 1980 will not be covered under this policy.
V. INITIAL EXPOSURE ASSESSMENT
The Office of Environmental Health and Safety (EHS) shall conduct an initial exposure assessment of construction activities that represent UMB's highest employee exposures to airborne lead. Within five (5) working days after the completion of the exposure assessment, EHS will notify each employee in writing of the results of their assessment. If an employee is exposed above the permissible exposure limit (PEL),2 a statement that the exposure was at or above the PEL and a description of the corrective action(s) to be taken to reduce the exposure level will be included with the results. A written record of the initial assessment shall be maintained at the Office of Environmental Health and Safety.
Employees involved in construction activities that may occupationally expose them to lead above the PEL shall be provided with the following interim protection during the exposure assessment.
- Appropriate respiratory protection;
- Appropriate personal protective clothing and equipment;
- Change areas and hand-washing facilities;
- Biological monitoring;
- Hazard communication and respiratory training;
- Training on any operations that could result in exposures above the action level.3
It is the responsibility of the employee's department to provide the above interim protection.
VI. FREQUENCY OF EXPOSURE ASSESSMENT
If the initial determination reveals that a certain construction activity does not expose employees above the action level, no additional exposure assessments will be required unless the activity changes. If the initial determination or subsequent determination reveals an exposure at or above the action level, EHS will continue to monitor in accordance with the Lead Exposure in Construction standard.
VII. ACCESS TO INFORMATION
Affected employees may receive a copy of the lead standard and information on the Occupational Safety and Health Act by contacting EHS at 410-706-3490.
VIII. LEAD WORK THAT IS BELOW THE ACTION LEVEL
UMB employees who perform work that disturbs leadcontaining material and are exposed below the action level shall be provided with the following:
- Adequate washing facilities. When running water is not available, handy wipes may be used.
- Hazard Communication training.
- To prevent the ingestion of lead dust, employees will be provided with and required to wear a paper dust mask when disturbing lead-based paint. The dust mask is used only to provide a barrier of protection to prevent the ingestion of lead dust and is not to be used in place of respiratory protection. The double strapped mask shall be provided by the employee's department.
IX. LEAD WORK THAT IS AT OR ABOVE THE ACTION LEVEL
UMB employees who perform work that exposes them to airborne concentrations of lead at or above the action level shall be provided with the following:
- Respirators approved for protection against lead dust, fume, and mist by the Mine Safety and Health Administration (MSHA) and the National Institute for Occupational Safety and Health (NIOSH). All employees who require a respirator must be enrolled in the UMB respiratory protection program;
- Protective clothing and equipment that prevent contamination of the employee's garments;
- Clean change areas equipped with separate storage facilities for protective work clothing, equipment, and street clothing;
- Where feasible, hand-washing and shower facilities;
- Medical examination and blood lead level surveillance;
- Medical removal protection in accordance with the Lead Exposure in Construction standard;
- Lunchroom facilities that are as free as practicable from lead contamination.
- Initial and annual training in accordance with the lead in construction standard.
UMB supervisors directing work that exposes UMB employees to airborne concentrations of lead at or above the action level shall be responsible for the following:
- Establish and implement a written compliance program for any maintenance activities that expose employees above the action level. Supervisors should contact EHS for assistance in developing their program. All written compliance programs must be approved by EHS.
- A supervisor directing work that has airborne lead levels at or above the action level must complete a forty (40) hour EPA-approved Lead Abatement Supervisor/Contractor course.
- Ensure that employees have received the appropriate training.
- Ensure that engineering controls and safe work practices are used to reduce lead exposure. Also, ensure that sanding and scraping of lead paint and sweeping of lead debris is done only after the material has been wetted.
- Ensure that food, beverages, and tobacco products are not present or consumed and cosmetics are not applied in the work area.
- Ensure that employees wash their hands and face prior to eating and do not enter the lunchroom with contaminated clothing or equipment.
- Ensure that the job site is clean and all surfaces are maintained as free as practicable from accumulations of lead dust. At the completion of the project, ensure that the area is cleaned properly.
- Inform building occupants of the nature and duration of the work to be conducted.
- Post the following warning signs in each work area where employees are exposed above the PEL:
WARNING
LEAD WORK AREA
POISON
NO SMOKING OR EATING - Ensure that hazardous waste is disposed of in compliance with Federal, State, and local regulations.
- Ensure that employees remove their protective clothing in the appropriate area at the end of the work period. Also, ensure that all contaminated protective clothing which is to be cleaned, laundered, or disposed of is placed in a closed and properly labeled container(s). Notify in writing any person who cleans or launders the protective clothing of the potentially harmful effects of exposure to lead.
- When respirators are required, ensure that employees are trained in their use, have been fit tested, and wear them properly.
- Ensure that all safety and health regulations and procedures are followed. X. CONTRACTORS
Contractors and subcontractors who perform work covered under the Lead in Construction Standard shall be responsible for ensuring that their work is done in compliance with 29 CFR 1926.62 with Maryland Amendments.
XI. PROHIBITED ACTIVITIES
Burning, dry sanding, and dry scraping of lead paint are prohibited.
Definitions
- Osteoporosis:A condition that is characterized by decrease in bone mass with decreased density and enlargement of bone spaces.
- Permissible Exposure Limit: An airborne concentration of lead of fifty micrograms per cubic meter of air (50 æg/m3) averaged over an 8-hour period.
- Action Level: An airborne concentration of lead of thirty micrograms per cubic meter of air (30 æg/m3) averaged over an 8-hour period.