Document oDJr28RMvdw3n1mn09Qp783jE

March 9, 1979 To: S Official Members, L1A / LXA Environmental Health Committee ''LIA Litigation Sub-Committee on OSHA Lead Standard From: L. G. Piantanida SUBJECT: OSHA LEAD STANDARD SUMMARY Attached is a summary of the current requirements for the OSHA Lead Standard. It indicates how each section of the Standard is affected by the Court Stay and the revised compliance dates. Details of the Stay will be discussed at the forthcoming LIA Environmental - Health Committee meeting, March 22, in New Orleans. Lillian G. Piantanida Sc .c. ILZRO Lead Environmental Health Committee L1603482 N 3731 OSH* LEAD STANDARD SOMMAKT PBL (permissible exposure limit) * airborne lead concentration of 50 ug/e^, S-hr average AL (action level) - airborne laad concantradon of 30 ug/a^, S-hr average HD (effactlva data) - Kerch 1, 1979; data following afaleh lapleaanCatlon of provisions of the Standard mute bagIn, ualaaa effected by Court Stay SECTION (e) (d)(2-3) (d)(4) (a)(1) STATUS OF STAf EEOUIEEMENT EXPLANATION COMPLIANCE SCHEDULE stay danlad except re (f) - see be low no eaployee expo sure > PEL respirators can ba used to swat PEL, basad on Tabla II (f)(2)(l), including dust, slst, & fume reap), except as (f) is affected by stay As soon as possible(ASAP) stay denied Initial determi nation of PbA air monitoring of represente- ASAP but no tlve sample of employees ba- leter than 1laved to ba exposed to great- 30 days from ast PbA cone eo determine If ED axpoaad to PbA^AL or PEL saiat ba dona for each type of employee exposure w/t each op eration over a full ahlft (at laaat 7 bra) suit ba Bade v/t 30 days of ED & results obtained v/1 90 days of ED -oust notify employee In writing of reaults v/1 5 working daya of receiving results stay denied exposure (ftA) monitoring -If Initial determination la ASAP, but *AL coapleted no -aaiat ba representative for later than each employee exposed to FbA Va l 90 days froai ED -may use eaasurassents made v/1 the last year. Is aaapllng & analyt eachode equivalent to requirements of Standard -notify employees In writing of results v/1 3 working days of receiving thee If ftA ^ PEL, aust notify ea^lop ee of corrective action taken or to be taken to reduce PbA<PIL -esiat be coexisted no later chan 90 days from ED LI AO 3 46 3 stay granted aethods of coopllance -current standard of 200 ug/m^ ls in affect during the stay period. Instead of schedule in Table I -engineering controls Bust be used to Beet 200 ug/aP -requirements for add'1 ang'g control's and work practlcas to aeet interim & PEL limits are deferred pending outcome of challenge to Standard E D (for cow pllance with 200 ug/ar) N 3731.01 SECTICM (e)(2) (e)(3) (e)(4) (e)(5) (e)(6) (f)(2) (f)(3) (f)(4) (8) 2- STATUS OF STAY REQUIREMENT EXPLANATION COMPLIANCE SCHEDULE stay dented except re (f)-see below respiratory protectlon -to reduce exposure to or below SO ug/m3 -use of dust, fuse,6 mist reap permitted for cone of PbA $ 500 ug/mJ -qualitative fit testing re quired; quantatlve fit test? g postponed for 1 yr from ED see (f) below stay granted ex cept for (e)(3)(F) compliance pro gram -requirements for written compl prog to reduce PbA PEL or In terim level are stayed paragraph (F) is not stayed & requires work practices program Including Items in (g),(h),& (1) - see below 30 days from ED stay granted bypass of Interim level (100 ug/m3) current 200 ug/m3 standard is In effect until outcome of Court challenge la determined Not Applicable (NA) stay granted mechanical ventila tion effectiveness testing schedule is stayed -exhaust air may not be recircu lated Into the workplace NA stay granted administrative controls -If rotating employees, it Is _not necessary to Implement a Job rotation schedule as de scribed In the Standard NA stay denied except for (f)(2)(H) respiratory pro tection & selec tion -must provide i> assure use of respirators according to Table 11 -during stay, powered air-puri fying reap shall be supplied In lieu of reap specified In Table when such reap Is inad equate due to physical charac teristics of employee (2) (11) E Dif expos. 200 ug/m 150 days from ED If expos >PEL but < 200 ug/sp partial stay granted by OSHA fit testing of respirators -quantitative fit testing post poned for 1 yr from E D -qualitative fit testing is re quired during Interim period -examination If breathing diffi culty during fit test or resp usage 1 yr from E D ED stay denied respirator pro gram -change filter eletaents whenever Increase in breathing resistance noted ED stay denied protective work clothing & equip ment -for esployees with exposure ^ 30 days from PEL ED -coveralls/full-body work cloth ing-, gloves, hats, shoes, face shields, vented goggles -clean change provided at least weekly If PbA> PEL -clean change provided daily If PbA > 200 ug/m3 -cleaning, laundering, disposal. repair, & replacement at employer's expense L1A03 SECTION STATUS OF STAY (g)-cont' d REQUIREMENT (h) stay denied housekeeping (i)(l) stay denied hygiene prac tices UX2-5) Btay granted hygiene facili ties (J)(D (J>(2> stay denied medical surveil lance program (general) partial biological stay monitoring granted(see Requirements) 3 EXPLANATION COMPLIANCE SCHEDULE removal of lead from protective clothing or eqpt by bloving, shaking, etc., shall be pro hibited -all surfaces Maintained free as practicable of Pb accumu lations compressed air may not be used to remove accumulated Pb from floors & other surfaces vacuuming is preferred method; shoveling, dry or vet sweeping, brushing only when vae'g not effective -vacuums used & emptied in vsy to minimize reentry of Pb in to air 30 days from ED -presence or use of food, bev erage, tobacco products, and cosmetics are prohibited in work area where PbA E L ED stay is granted to the extent that these sections require the construction of new facil ities or substantial renovation of existing facilities NA otherwise, change rooms, storage facilities for prot cloth'g, showers, lunchroom provisions where PbA 7/? E L shall oantinue to be used where already in existence ED -medical exams by licensed MD for all employees exposed to PbA >A L for more Chan 30 days per year ASAP sfter ED -oust begin upon completion of initial air monitoring (see d 2-3) & completed w/i 90 days -priority given to employees st greatest risk, on basis of air Monitoring results or other relevant Indications (PbB, ten ure, etc) -ZPP Monitoring is not required during stay; PbB analysis is -frequency of PbB Monitoring: every 6 months for enployees exposed to PbA? A L (30 days/yr) every 2 mos if previous PbB <5-40 ug/lOOg; continued , until 2 consecutive PbBs <40 ug/lOOg Monthly during tine removed from exposure due to in creased PbB completed 180 days from E D IT0345 SECTION (J) (3) (J)(4) (k) STATUS OF STAY REQUIREMENT stay granted Cor (3)(il)(D) dSd (3) (Hi) medical exams & Multiple physician re* view stay denied chelation stay denied (except for references Co multiple physician review) medical removal protection (MRP) 4' EXPLANATION COMPLIANCE SCHEDULE -stay applies only to ZPP teac'g and Multiple physician review; other aed'l uas provisions not stayed -Bed' 1 exams for each employee E D exposed to PbAlsA L (30days/yr) annually if PbB^40 ug/lOOg prior to first*tiae assign ment in area w PbB ^A L ASAP after notification by eaployee of signs & aynptoms assoc1 d w Pb lotox, of difficulty in breach ing during resp fit test or resp use, & of desire for toed' 1 advice re effects of current or past expos on reproductive ability as medically appropriate after removal fmm exposure due to risk to health exam Co include: detailed work & stedlcal history (esp past expos to Pb, smoking & hygiene habits, & past GI, hematologic, renal, CV, reprod, or neurological problems); thorough physical exam; blood pressure; PbB, hemoglobin, hematocrit, red cell indices, peripheral smear morphology; BUN; serum creatinine; routine urinal; others deemed necessary by HD -information on Che Standard, on employee's exposure, protective eqpt used, prior PbBs 4 med11 opinions shall be provided to the examining KD -written mad'1 opinion provided to employee re rned'l condlt'n causing Increased health risk If exposed to Pb, recount'd special prot measures, limit'n to Pb expos or resp use, results of PbB analysis the employer shall assure that any person whom he retains, em ploys, supervises, or controls does not engage in prophylactic chelation of any employee at any cime ED 'MRP benefits Include earnings ED maintenance, seniority, 4 other rights as though employee had not been removed frae norm al exposure MRP may be made conditional based on employee's participa tion in follow-up med'l sur veillance ' if workers' comp is granted, MRP obilestloo may be reduced by that amount LIA03A56 5 SECTION STATUS OF STAY REQUIREVENT EXPLANATION COMPLIANCE SCHEDULE (k)-cont'd stay denied -temporary removal due to elevated PbB: 1st yr of Std If PbA i-100 ug/m3 and PbB >80ug/ lOOg 2nd yr of Std 3rd yr of Std & thereafter if PbA 50 ug/m3 and PbB^IOug/ lOOg if PbA i 30 ug/m3 and PbBJ560ug/100g 5th yr of Std & thereafter if PbA > 30 ug/m3 and average of last three PbBs^50 ug/lOOg, unless Che last PbB-C40 ug/lOOg 1st yr 2nd yr 3rd yr 5th yr -return Co former job status: if PbB vaa i 80 ug/lOOg when 2 consecutive PbBs^60 ug/lOOg if PbB vaa ^ 70 ug/lOOg when 2 consec PbBs $50 ug/lOOg if PbB vaslbbO ug/lOOg when 2 consec PbBs$40 ug/lOOg if average PbB^50ug/100g when 2 consec PbBs$40 ug/lOOg (1) stay denied training program -make contents of Appendices ASAP, but A&B known to employees in no later than workplace where potential 180 days from of PbA exposure at any level ED -Institute train'g prog for employees exposed to PbA^AL or for whom'posslb11 of skin or eye Irritation -provided prior to initial job assignment In area of PbAj^AL prog repeated annually for each esq>loyee prog to include: contents of Std & Appendices operations w potential expos > AL purpose, proper selection, fitting, use, (t limit`ns of respirators engineering concrols & work practices associated with job assignment -purpose & description of med'1 surveill & removal programs contents of company compliance program warning against prophylactic use of chelating agents (m) stay posting signs -requirement to post warning NA granted signs in srea where PbAVPEL is stsyed (n) stay denied recordkeeping -record of all monitoring re- ED quired by section (d)-see above -establish & maintain record of: med'1 surveill for each employee med'1 removals -all records available on request LIA03467 to 0SHA or inOSH SECTION STATUS OF STAY (n)-coat'd REQUIREMENT stay denied observation of monitoring 6- EXPLANATION COMPLIANT SCHEDULE -record* shall be kept for 40 yrs or duration of employment 20 yra, whichever Is longer -If employer ceases business, successor shall maintain re cords; otherwise they will" be transmitted to NIOSH at expiration of retention period for records, employer shall notify NIOSH 3 months prior to disposal and trans mit them to NIOSH If requested -affected employees provided opportunity to observe any monitoring of employee expo sure to Pb under section (d) -respirators or other protec tive clothing & eqpc shall be provided as necessary In the area of observation -observers entitled to explan ation of measurement proce dures, to observe all steps related to the monit'g at the place of exposure, & to record the results obtained ED LlA034f9