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OSHA 1915.1025

Lead in shipyard employment

Subpart Z

22 Questions & Answers
10 Interpretations

Questions & Answers

Under 1915.1025, what is the permissible exposure limit (PEL) and the action level for airborne lead in shipyard employment?

The PEL for airborne lead is 50 micrograms per cubic meter of air as an 8‑hour time‑weighted average, and the action level is 30 micrograms per cubic meter as an 8‑hour time‑weighted average. These numeric limits are set by the lead standard for shipyard employment, which is identical to the general industry lead standard 1910.1025 and adopted at 1915.1025.

Under 1915.1025, when must an employer perform air monitoring for lead exposure?

Employers must perform initial monitoring to determine each employee’s exposure to lead when a workplace operation may reasonably result in exposures at or above the action level, and they must establish the frequency of periodic monitoring based on those results. The initial and follow‑up monitoring requirements are described in the lead standard 1910.1025 and adopted for shipyards at 1915.1025.

Under 1915.1025, what steps must an employer take if monitoring shows exposures above the PEL?

If monitoring shows airborne lead above the PEL, the employer must promptly use engineering and work practice controls to reduce exposures to or below the PEL, and where controls cannot reduce exposure fully, provide and require the use of appropriate respirators until controls do so. These control and respiratory protection obligations are set out in the lead standard 1910.1025 and incorporated at 1915.1025.

Under 1915.1025, when must an employer provide and require respirator use for lead exposures?

Employers must provide respirators and require their use when engineering and work practice controls are not feasible or are being implemented and do not reduce employee exposures to or below the PEL. Respirator selection and program requirements must follow the Respiratory Protection Standard, 1910.134, alongside the lead standard at 1910.1025 (applied in shipyards at 1915.1025).

Under 1915.1025, what medical surveillance is required for workers exposed to lead?

Employers must provide medical surveillance (including baseline and periodic blood lead and symptom evaluation) for employees who are exposed at or above the action level for 30 or more days per year. The medical surveillance program requirements are specified in the lead standard 1910.1025 and are applied to shipyard employment through 1915.1025.

Under 1915.1025, when must an employer remove an employee from lead exposure and what medical removal protections apply?

An employer must remove an employee from exposure when medical determinations under the lead standard require removal (for example, elevated blood lead levels or work‑related medical signs), and the employer must provide medical removal protection benefits while the employee is removed. The medical removal and associated protection requirements are found in 1910.1025 and apply to shipyards via 1915.1025.

Under 1915.1025, what hygiene facilities and practices must employers provide to protect workers from lead?

Employers must provide change areas, showers, and handwashing facilities (as appropriate), prohibit eating, drinking, smoking, applying cosmetics or storing food and drink in areas with lead contamination, and supply clean protective clothing and laundering or disposal for contaminated clothing. These hygiene and housekeeping requirements are detailed in the lead standard 1910.1025 and are required in shipyard employment under 1915.1025.

Under 1915.1025, what training must employers give employees exposed to lead?

Employers must provide initial training before assignment and annual refresher training that covers the health hazards of lead, workplace operations that could result in exposure, protective measures (including engineering controls and PPE), and medical surveillance and reporting procedures. Training requirements are part of the lead standard 1910.1025 and are applied to shipyards at 1915.1025.

Under 1915.1025, what housekeeping methods are prohibited for cleanup of lead dust and debris?

Dry sweeping, dry shoveling, and compressed air blowing of lead dust are generally prohibited unless engineering controls (like local exhaust) or HEPA‑equipped vacuums are used to prevent airborne dispersion; employers must use methods that minimize lead re‑entrainment. These housekeeping requirements are in the lead standard 1910.1025 and apply in shipyards via 1915.1025.

Under 1915.1025, what labels or signs must employers use where lead exposures occur?

Employers must post warning signs at regulated areas and label containers of lead and lead‑containing materials to communicate the hazard, and they must ensure that signs and labels contain required hazard information. These posting and labeling obligations are included in 1910.1025 and apply to shipyard employment under 1915.1025.

Under 1915.1025, how long must employers keep lead exposure monitoring and medical records?

Employers must retain exposure monitoring results and medical records for the periods specified by the lead standard—monitoring records must be kept for at least 30 years and medical records must be preserved in accordance with the standard’s retention rules—so employees can access their records. The recordkeeping timelines and access rules are specified in 1910.1025 and apply in shipyards through 1915.1025.

Under 1915.1025, are shipyard employers required to provide medical removal protection (MRP) pay during removal?

Yes; when employees are medically removed from lead‑exposure work under the standard, employers must provide medical removal protection benefits (which commonly include keeping pay and job benefits during the removal period) as specified by the lead standard. The medical removal protection provisions are in 1910.1025 and apply to shipyard employment at 1915.1025.

Under 1915.1025, how should employers control lead exposure during abrasive blasting or paint removal on ships?

Employers must use feasible engineering controls (such as local exhaust ventilation, containment, and dust suppression) to reduce exposure, and where those controls do not lower exposure to or below the PEL, provide respiratory protection and other PPE. Specific work practices for paint removal and abrasive blasting are covered by the lead standard 1910.1025 and apply in shipyards under 1915.1025.

Under 1915.1025, can employers allow food, drink, or tobacco use in areas where lead exposure occurs?

No. Employers must prohibit eating, drinking, smoking, chewing tobacco, and the use of cosmetics in areas where airborne lead concentrations exceed the PEL or where there is potential for skin or clothing contamination, and they must provide clean areas for these activities. These prohibitions are part of the lead standard 1910.1025 and are required in shipyard work by 1915.1025.

Under 1915.1025, what protective clothing and equipment must employers provide for lead work?

Employers must provide appropriate protective clothing (coveralls, gloves, etc.) and ensure they are removed before employees leave the work area; contaminated clothing must be laundered or disposed of by the employer. The protective clothing and hygiene provisions are described in 1910.1025 and apply in shipyards via 1915.1025.

Under 1915.1025, how must employers notify employees of their blood lead and zinc protoporphyrin (ZPP) test results?

Employers must promptly inform each employee of their individual blood lead and ZPP test results in writing within a specified time frame, and maintain confidentiality consistent with the standard. The notification and recordkeeping requirements for biological monitoring results are in 1910.1025 and apply to shipyard employment through 1915.1025.

Under 1915.1025, are contractors and host employers responsible for lead compliance when both work at the same shipyard site?

Both host employers and contractors have responsibilities: each employer must ensure its employees are protected and must coordinate with others to prevent lead exposures, including sharing hazard information and controls. Multi‑employer obligations are described in OSHA standards and applied in the lead standard 1910.1025, which is incorporated into shipyard rules at 1915.1025.

Under 1915.1025, is a medical removal required for pregnant workers exposed to lead?

If a medical professional determines a pregnant worker’s exposure poses a risk to her health or her fetus in accordance with the medical surveillance provisions, the employee must be removed from exposures that create that risk and receive medical removal protections as specified in the lead standard. The protections and pregnancy‑related considerations are in 1910.1025 and apply under 1915.1025.

Under 1915.1025, what steps should employers take before allowing employees to return to lead‑exposed jobs after medical removal?

Employers should follow the medical clearance and monitoring procedures specified by the standard—employees may return only when a physician or licensed healthcare professional determines it is safe and the employee meets the return‑to‑work criteria in the lead standard. The return criteria and medical removal program rules are in 1910.1025 and apply to shipyards via 1915.1025.

Under 1915.1025, how should employers decide if a particular task requires respiratory protection versus engineering controls?

Employers must first implement feasible engineering and work practice controls to reduce lead exposures; respirators are required only when those controls cannot reduce exposures to or below the PEL or while controls are being installed. Respirator selection and program requirements must comply with 1910.134. These requirements are part of the lead standard 1910.1025 and are applicable in shipyards at 1915.1025.

Under 1915.1025, are employers required to provide showers and change rooms for lead work in shipyards?

Yes; when required by the standard’s hygiene provisions (for example, when employees are exposed above certain levels or have contaminated clothing), employers must provide appropriate change rooms and showers or arrange access as specified in the lead standard. These hygiene facility requirements are in 1910.1025 and are applied to shipyard employment under 1915.1025.

Under 1915.1025, how should employers handle cleanup of lead paint debris removed from ships to prevent exposure spread?

Employers must contain and collect lead paint debris using methods that minimize dust generation (e.g., HEPA vacuuming, wet methods, local exhaust), transport debris in sealed containers, and prevent cross‑contamination of clean areas; these work practice and housekeeping requirements are set out in the lead standard 1910.1025 and apply to shipyards through 1915.1025.