OSHA requirements, lead construction

When it comes to working with hazardous materials, both OSHA and the EPA are actively involved in regulations. This chapter focuses on the OSHA requirements. It is unHkely that you will memorize them all, but you should become famiHar with the rules. The reading here is not particularly entertaining, but it is enlightening. At the very least, you need to learn your way around the facts so that you can stay out of trouble on a job site. The information that follows is based on OSHA s view of working with lead on construction sites. 

Chapter 4 OSHA Requirements for Lead Construction 49 TABLE 4.2 Required Action under the OSHA Standard by Exposure Level... 

The OSHA standard requires employers to provide initial and annual training to all anployees exposed to an airborne concentration of lead of 30 pg/m averaged over an 8 h period. In some old facilities, exposure can come from lead-based paint or lead-soldered pipe connections. Construction and renovation projects can release lead particles into the air. Hospital departments of nuclear medicine use lead molds in patient treatment. Organizations must confine lead to a specific area. Decontamination and shower facilities should be provided to keep lead from being tracked to other areas. Provide respiratory protection and protective clothing wherever there is known exposure potential. 

Various airborne contaminants in Appendix A of 1926.55 do not list PELs but instead send you to another portion of the construction regulations. These contaminants are called OSHA specific contaminants. Examples are Asbestos ( 1926.1101), alpha-Naphthylamine ( 1926.1104), and lead ( 1926.62). There are approximately 27 of these substances. These OSHA specific contaminants have their own PELs and specific requirements. 

A. No. OSHA s fall protection standard for construction generally requires fall protection when there is a fall distance of six feet or more. In a few, very specific situations (low-slope roof work, some leading-edge work, precast concrete erection, and residential construction), because of feasibility limitations, the standard permits the use of a warning line, in combination with other measures, instead of conventional fall protection (guardrail systems, personal fall arrest systems or safety net systems) to keep employees away from an edge. 

According to Appendix D, therefore, an equivalent to control lines should restrict access to the CDZ. OSHA directive CPL 02-01-034, Inspection policy and procedures for OSHA s steel erection standards for construction, further explains Section 1926.760(c)(3) requires that the boundaries of the CDZ be marked by the use of control lines or the equivalent. In a CDZ, the control line restricts access by visually warning employees of an unprotected area (66 FR 5247). Control lines can be made of rope, wire, tape, or other equivalent materials, but they must clearly designate the CDZ. Examples of other acceptable methods would be a perimeter wall, guardrail system, or even a restraint system rigged so that non-leading edge workers could not access the area. In contrast, a line painted on the floor would not be considered to be equivalent to control lines since it would be less visible than a control line. [Emphasis added]... 

Given that the HUD guidelines recommend the use of HEPA vacuums and the OSHA Lead in Construction standard requires that vacuums be equipped with HEPA filters where vacuums are used, EPA proposed requiring the use of HEPA vacuums in its proposed work practices. Nonetheless, EPA requested comment on whether the rule should allow the use of vacuums other than vacuums equipped with HEPA filters. Specifically, EPA requested comment on whether there are other vacuums that have the same efficiency at capturing the smaller lead particles as HEPA-equipped vacuums, along with any data that would support this performance equivalency and whether this performance specification is appropriate for leaded dust cleanup. 

OSHA continues to require the use of HEPA vacuums in work subject to the Lead in Construction standard. 

If the airborne exposure is to be determined for a particular job, the IH must be prepared to monitor quickly. The next day may be too late. Concentrations usually need to be high to find TWAs that exceed OSHA PELs. More often than not the construction worker is not conducting the same job for an 8 h period. Many tasks are usually required to accomplish a day s work, which also makes it difficult to evaluate a particular hazard. A worker welding, cutting, and burning all day on an outside project such as a painted bridge may have no exposure or wind up in the hospital undergoing chelation therapy with a blood lead level in the hundreds. Many variables affect the potential and real exposure levels such as work habits, weather, and type of paint on the steel as well as personal protective equipment used. 

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