OSHA requirements, lead equipment

Process safety management is the primary requirement that drives process plants and refineries to establish quality control programs for incoming materials and spare parts. OSHA 29 CFR 1910.119 has defined regulations for process safety critical equipment and systems that include such requirements. Other reasons for quality control programs may be equally important, for example when failure has a significant impact on capability to make product or leads to excessive maintenance costs. 

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. 

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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