Page History

Title:

Lead Hazards and Controls

Publication date:

8/18/2020

Effective date:

8/18/2020

Title:

Lead Hazards and Controls

Publication date:

8/18/2020

Effective date:

8/18/2020

Role

Responsibility

Line management

• Requests for industrial hygienist to evaluate work areas and activities for all workers who may be potentially exposed to lead above established limits.
• Plans and supervises work in accordance with the Berkeley Lab Integrated Environment, Safety & Health Management Plan.
• Ensures that all available and specified engineering controls, administrative controls, and personal protective equipment (PPE) are implemented before work begins and ensures that they are used appropriately.
• Verifies that workers have read the established job-specific Negative Exposure Assessment or the applicable Lead Compliance Work Plan.
• Verifies that workers are adequately and properly trained before starting work.
• Schedules workers who have been exposed to levels above the Action Level for medical exams and enrollment into the Berkeley Lab Health Services Lead Medical Surveillance Program.
• Ensures that individuals who may be potentially exposed to lead receive appropriate training.
• Conducts job-specific lead training.
• Provides an alternate work area and non-lead work activities for workers whom Health Services has removed from work involving lead exposure.
• Notifies the assigned industrial hygienist at least 48 hours before lead work begins.

Employees, subcontractors, affiliates, and visitors

• Follow the requirements outlined in this document and other lead-work procedures for work involving lead.
• Attend required lead training as specified in Work Process C, Training and Qualifications.
• Report to line management any operation or unanticipated work activities that involve lead or lead-containing materials that were not addressed by Integrated Safety Management or pre-task planning.
• Use engineering controls and PPE in accordance with instruction and training.
• Notify Health Services if pregnant or actively trying to conceive a child, if working with lead or lead-containing materials.

Industrial hygienist

• When possible, establishes job-specific Negative Exposure Assessments for similar lead-work activities.
• Performs required air monitoring.
• Notifies workers, supervisors, and Health Services of:
  
  • Air-sample results within five days of receiving results from the analytical laboratory.
  • Any requirements for medical surveillance.
• Assists in the design, implementation, and testing of engineering control systems.
• Reviews job-specific Negative Exposure Assessments, bid specifications, and Lead Compliance Work Plans to ensure they incorporate adequate controls.
• Recommends the most appropriate type of respirator for workers involved in lead work.
• Refers employees to the Respiratory Protection Program Manager for issuance of appropriate respirator and testing, and to Health Services for any required medical evaluations.
• Assists supervisors in identifying potential lead-disturbing activities.
• Performs bulk and surface wipe sampling as required or as appropriate.

Lead Program Manager

• Develops and maintains the Lead Program.
• Develops and provides the necessary classroom training or assists in identifying an alternate source of training.
• Assists industrial hygienists with establishing job-specific Negative Exposure Assessments.
• Assists industrial hygienists with reviewing facilities bid specifications and Lead Compliance Work Plans to ensure adherence to the Lead Program.

Health Services

• Performs required respirator medical approvals and focused surveillance exams to include appropriate blood chemistry tests for employees exposed above the lead Action Level.
• Determines when workers must be removed from lead-work activities because of abnormalities detected during medical surveillance.
• Determines when workers can return to lead-work activities after being removed because of medical abnormalities.
• Notifies workers of any medical findings, as required
• Notifies supervisors of any work restriction related to lead work.
• Requests the Industrial Hygiene Group perform a work-site evaluation for any worker found to have an elevated blood lead level.
• Coordinates exposure monitoring results with the Lead Program Manager.

Facilities Division

• Notifies the Lead Program Manager of purchases of lead-containing materials.
• Prohibits Facilities personnel, supplemental labor personnel, and construction contractors from using construction products containing more than 0.06% lead, or any lead on drinking-water lines.
  
  • This does not apply to electrical solder.
• Specifies in construction contracts if and where lead will be disturbed; alternatively, requires that subcontractors determine the presence of lead before disturbing materials that may contain it.
• Develops and maintains a bid specification that implements the Berkeley Lab Lead Program in construction, renovation, and demolition contracts where lead material may be encountered.

Procurement and Property Management

Notifies the Lead Program Manager, and obtains approval, prior to purchase of lead materials in accordance with established protocols.

Term

Definition

Action Level (AL)

Employee exposure established by the federal Occupational Safety and Health Administration (OSHA) as airborne lead at an eight-hour time-weighted average concentration of 30 micrograms of lead per cubic meter (µ/m³) of air or 0.030 milligrams per cubic meter (mg/m³) of air, without regard to the use of respirators

Engineering controls

Measures other than respiratory protection or administrative controls that are implemented at the work site to contain, control, and/or otherwise reduce exposure to lead-contaminated dust and debris usually in the occupational health setting. The measures include process and product substitution, isolation, and ventilation.

Exposure monitoring

The sampling and analysis of air both inside and outside the work area to determine the degree of worker and occupant exposure to lead or other airborne contaminants, often involving air sampling inside a worker's breathing zone

Lead Compliance Work Plan

A document that describes the types of tasks, workers, protective measures, and tools and other materials that may be employed to control lead-containing hazards in order to comply with the OSHA Lead Exposure in Construction standard

Lead containing

A coating or material that contains any detectable level of lead

Lead-contaminated surface

Any surface that contains an area or mass concentration of lead in excess of a regulatory limit established by OSHA or the Environmental Protection Agency (EPA) or in excess of a guideline established by an Environment, Health, Safety, and Security (EHS) industrial hygienist or the Lead Program Manager

Lead paint abatement

A measure or set of measures designed to permanently eliminate lead-based paint hazards or lead-based paint. Abatement strategies include the removal of lead-based paint, removal of lead-contaminated dust, and removal of lead-contaminated soil or overlaying of soil with a durable covering such as asphalt. All these strategies require preparation; cleanup; waste disposal; post-abatement clearance testing; recordkeeping; and, if applicable, monitoring.

Negative Exposure Assessment (NEA)

A Negative Exposure Assessment (NEA) is a written statement within the past 12 months by an EHS industrial hygienist indicating that a specific lead-disturbing job (or a class of very similar lead-disturbing jobs) does not result in worker exposure above the Action Level. Work conducted pursuant to an NEA can proceed without subsequent review, provided that the controls specified in the NEA are implemented.

Permissible Exposure Limit (PEL)

The eight-hour time-weighted average concentration of airborne lead an employee exposure may not exceed without the use of respirators. The OSHA value is 50 µg/m³ of lead in air or 0.050 mg/m³ of lead in air.

Public building

A structure, or part of a structure, and its land, which are generally accessible to the public, including but not limited to schools, day-care centers, museums, airports, hospitals, stores, convention centers, government facilities, office buildings, and any other building that is not an industrial building or a residential building

Regulated Area

Work areas where airborne exposure to lead is above the PEL

Document Number

Title

Type

07.07.019.001

Lead Hazards and Controls

Program

07.07.019.002

Work Process A, General Requirements

Process

07.07.019.003

Work Process B, Lead Hazard Assessment

Process

07.07.019.004

Work Process C, Training and Qualifications

Process

07.07.019.005

Work Process D, Authorizations, Permits, and Approved Work Plans

Process

07.07.019.006

Work Process E, Controlled Operations and Work Controls

Process

07.07.019.007

Work Process F, Waste Disposal

Process

07.07.019.008

Work Process G, Exposure and Surface Contamination Monitoring

Process

07.07.013.001

Exposure Assessment

Program

07.07.005.001

Chemical Safety Hazards and Controls

Program

Date

Revision

By Whom

Revision Description

Section(s) Affected

Change Type

1/2/2012

0

J. Heim

Re-write for wiki (brief)

All

Minor

5/28/2013

1

J. Fleming

Re-write for wiki (brief)

All

Minor

8/15/2020

1.1

J. Fleming

Reference update to Cal/OSHA to reflect 10 CFR 851 variance

Source documents

Minor

Title:

Lead Hazards and Controls

Document number

07.07.019.000

Revision number

1.1

Publication date:

8/18/2020

Effective date:

8/18/2020

Next review date:

8/18/2025

Policy Area:

Industrial Hygiene and Safety

RPM Section (home)

ESH

RPM Section (cross-reference)

none

Functional Division

EHS

Prior reference information (optional)

ES&H Manual Section 4.11 moved to Chapter 37

Document Number

Title

Type

07.07.019.001

Lead Hazards and Controls

Program

07.07.019.002

Work Process A, General Requirements

Process

07.07.019.003

Work Process B, Lead Hazard Assessment

Process

07.07.019.004

Work Process C, Training and Qualifications

Process

07.07.019.005

Work Process D, Authorizations, Permits, and Approved Work Plans

Process

07.07.019.006

Work Process E, Controlled Operations and Work Controls

Process

07.07.019.007

Work Process F, Waste Disposal

Process

07.07.019.008

Work Process G, Exposure and Surface Contamination Monitoring

Process

07.07.013.001

Exposure Assessment

Program

07.07.005.001

Chemical Safety Hazards and Controls

Program