Cadmium exposure in construction

Under 1926.1127(a) the cadmium standard applies to all construction work where employees may potentially be exposed to cadmium. Examples of covered activities include wrecking or demolition where cadmium is present, cutting or welding surfaces painted with cadmium paints, cadmium welding and brazing, installation or maintenance of cadmium-containing products, cleanup of cadmium contamination, and on-site storage or disposal of cadmium-containing materials as listed in 1926.1127(a).

• Use this list to screen a job before work starts: if the task appears on 1926.1127(a)(1)–(a)(9) then the standard applies.
• The employer must designate a competent person to make the applicability determination (see monitoring duties in 1926.1127(d)(1)(i)).

Under 1926.1127(b) the action level (AL) for cadmium is 2.5 µg/m3 as an 8‑hour time-weighted average, and it is the exposure threshold that triggers special monitoring and protective actions.

• Employers must begin the monitoring, medical surveillance, and other protections required by the standard when employee exposures are at or above the action level as described in 1926.1127(d).
• The action level is calculated as an 8‑hour TWA and is based on exposure without respirators per the definitions in 1926.1127(b).

Under 1926.1127(c) the permissible exposure limit (PEL) for cadmium is 5 µg/m3 as an 8‑hour TWA, and employers must ensure no employee is exposed above this level.

• If monitoring shows exposures above the PEL, employers must implement engineering and work-practice controls and, if necessary, respiratory protection to reduce exposures to at or below the PEL (1926.1127(c)).
• When exposures exceed the PEL, the employer must notify affected employees and describe corrective actions as required in 1926.1127(d)(5)(ii).

Under 1926.1127(b) a "competent person" is someone the employer designates who can identify cadmium hazards and the correct controls and who has the authority to take prompt corrective action.

• The competent person must meet the general definition in 1926.32(f) and the specific duties listed in the cadmium rule, such as determining whether cadmium is present, establishing regulated areas, assuring monitoring, PPE and hygiene facilities, training employees, and ensuring engineering controls are implemented (1926.1127(b)).
• Document the competent person’s qualifications and the basis for their determinations as part of your pre-work hazard assessment per 1926.1127(d)(1)(i).

Under 1926.1127(d)(1)(i) the employer must determine whether cadmium is present and whether employee exposures could reach the action level before work begins, and a competent person must make that determination.

• Use investigations and material testing, review plans, past reports and Safety Data Sheets (SDS), and consult property owners or agencies as part of the determination (1926.1127(d)(1)(i)).
• If the determination shows potential for exposures at or above the action level, identify employees who may be exposed at or above the action level as required by 1926.1127(d)(1)(ii).

Under 1926.1127(d)(2)(i)-(ii) the employer must conduct initial exposure monitoring as soon as practicable for each employee who may be exposed at or above the action level and must also monitor employees during tasks that may produce higher short-term exposures.

• Initial monitoring is required when the competent person’s pre‑work determination shows possible exposures at or above the action level (1926.1127(d)(2)(i)).
• If some tasks periodically produce higher cadmium concentrations, monitor employees while they perform those specific tasks per 1926.1127(d)(2)(ii).

Under 1926.1127(d)(2)(iii) an employer may rely on objective data demonstrating that exposures will not reach the action level under expected conditions instead of performing initial monitoring.

• Objective data must meet the definition in 1926.1127(n)(2) and convincingly show that exposure will be below the action level for the specific processes, materials, and conditions at the site (1926.1127(d)(2)(iii)).
• Keep written documentation of the objective data and the basis for relying on it in place of monitoring to demonstrate compliance.

Under 1926.1127(d)(1)(iii)-(iv) exposure determinations must be made from breathing-zone air samples that reflect each monitored employee’s full shift 8‑hour TWA, and representative sampling may be used when workers perform the same tasks with similar exposures.

• Collect personal breathing‑zone samples for full shifts on each shift and job classification as required in 1926.1127(d)(1)(iii)-(iv).
• When multiple employees perform identical tasks with similar exposure levels, sample the employee(s) expected to have the highest exposures to represent the group per 1926.1127(d)(1)(iv).

Under 1926.1127(d)(3)(i) periodic monitoring must be performed at a frequency and pattern needed to accurately reflect the employee’s typical exposure and to assure adequacy of controls whenever initial or periodic monitoring shows exposures at or above the action level.

• The monitoring frequency must account for variability in tasks, work practices, and environmental conditions on the job site (1926.1127(d)(3)(i)).
• If two consecutive samples (initial plus another at least seven days later) show exposures below the action level, monitoring may be discontinued for those employees per 1926.1127(d)(3)(ii).

Under 1926.1127(d)(4)-(5) the employer must institute monitoring whenever changes could increase exposures, and must notify affected employees of monitoring results within 5 working days of receiving them.

• Additional monitoring is required when changes in materials, equipment, personnel, work practices, or other conditions might raise exposures to the action level or above the PEL (1926.1127(d)(4)).
• Employers must notify each affected employee as soon as possible but no later than 5 working days after receipt of monitoring results, either individually in writing or by posting in a place accessible to employees (1926.1127(d)(5)(i)).
• If results exceed the PEL, the notice must state that fact and describe corrective actions being taken (1926.1127(d)(5)(ii)).

Under 1926.1127(d)(6) employers must ensure that exposure measurements are accurate, using appropriate sampling and analytical methods and following the accuracy requirements set out in the cadmium standard.

• Use validated air-sampling and analytical methods appropriate for measuring low µg/m3 concentrations of cadmium and follow laboratory QA/QC procedures as required by 1926.1127(d)(6).
• Where EPA/NIOSH/OSHA methods exist for cadmium sampling and analysis, follow those recognized procedures to meet accuracy requirements referenced in the standard.

Under 1926.1127(l) employers must provide medical examinations, periodic medical evaluations, and written medical determinations when required by the cadmium standard, and the final medical determination must be a written opinion from the examining physician.

• The standard requires baseline and periodic medical exams, biological monitoring (where applicable), and additional exams when an employee shows signs of cadmium-related health effects; see the medical provisions in 1926.1127(l).
• The physician’s final written medical determination and recommendations are defined under 1926.1127(l), including procedures for multiple physician review (1926.1127(l)(13)) and alternative physician determinations (1926.1127(l)(14)).

Under 1926.1127(b) "employee exposure" refers to the airborne concentration of cadmium to which the employee would be exposed if they were not wearing respiratory protective equipment.

• This definition means exposure measurements and comparisons to the action level and PEL must be based on unprotected exposure levels; respirator use can be a temporary control but you must evaluate and control the unprotected exposure as required by 1926.1127(b).
• Respirators are an element in the control hierarchy and their selection should be evaluated against measured unprotected exposures per the standard's control and respiratory provisions.

Under 1926.1127(b) a regulated area is an employer-demarcated space where employee airborne cadmium concentrations exceed, or can reasonably be expected to exceed, the PEL, and employers must establish such areas whenever exposures justify them.

• The competent person must set up regulated areas when monitoring or determinations indicate exposures over the PEL and must limit access to authorized persons only as required in 1926.1127(b).
• Regulated areas should be clearly posted and controlled to prevent unauthorized entry and to ensure workers inside receive required protections under the standard.

Under 1926.1127(d)(2)(iv) the employer must make a written record when a potentially exposed employee is determined not to be exposed at or above the action level; the record must include monitoring data, date of determination, and names of each employee.

• The written record should include the monitoring data developed under 1926.1127(d)(2)(i)-(iii) where applicable, the date of the determination, and the name of each employee represented (1926.1127(d)(2)(iv)).
• Keep these records available for employee access and for inspection as required by OSHA recordkeeping rules.

Under 1926.1127(a)(4) welding, cutting, or brazing cadmium, cadmium‑plated steel, or cadmium alloys can release cadmium fumes and airborne particles that may raise exposures above the action level or PEL, so employers must evaluate and control those operations accordingly.

• These hot‑work operations are specifically listed as covered activities in 1926.1127(a)(4), and employers should perform task-specific monitoring during the operations per 1926.1127(d)(2)(ii).
• Use engineering controls (local exhaust ventilation), work-practice controls, and appropriate respirators where necessary to reduce exposures below the PEL.

Under 1926.1127(a)(2)–(a)(3) employers must treat surfaces painted with cadmium-containing paints and structures containing cadmium as potential cadmium sources and determine exposure potential before disturbing them.

• Tasks like cutting, grinding, or welding on cadmium‑painted surfaces are specifically called out in 1926.1127(a)(2) and renovations of cadmium-containing structures in 1926.1127(a)(3).
• The competent person should test materials or consult SDSs and historical information as part of the pre‑work determination under 1926.1127(d)(1)(i).

Under 1926.1127(d)(3)(ii) an employer may discontinue monitoring for employees when two samples (initial or periodic plus another taken at least seven days later) both indicate exposures below the action level.

• The two confirmed results must show exposure below the action level and the second sample must be taken at least seven days after the first to qualify for discontinuation per 1926.1127(d)(3)(ii).
• Resume monitoring if conditions change or if the competent person suspects exposures may increase per 1926.1127(d)(4).

Under 1926.1127(d)(5)(ii) the employer must include a statement that the PEL has been exceeded and must describe the corrective actions being taken to reduce exposures to or below the PEL in the written notice to affected employees.

• Deliver the notice within 5 working days after receiving results per 1926.1127(d)(5)(i) and include the specific corrective measures and timetable in the notice as required by 1926.1127(d)(5)(ii).
• Keep documentation of the notice and corrective actions for compliance verification.

Under 1926.1127(n)(2) objective data are factual, process‑ or material‑specific information (such as validated testing results, historical monitoring from identical operations, or manufacturer data) that demonstrate employee exposures will not reach the action level under expected conditions.

• The data must be specific to the material, process, and conditions and sufficient to reasonably predict exposures below the action level as described in 1926.1127(n)(2).
• Keep written records of the objective data and the rationale for relying on it in place of monitoring to show compliance with 1926.1127(d)(2)(iii).

Under 1926.1127(a)(8) employers must treat cadmium contamination and emergency cleanup as covered activities and immediately evaluate exposures, establish controls, and designate a competent person to manage the response.

• Emergency cleanup that may release airborne cadmium requires prompt exposure monitoring, implementation of engineering controls, use of appropriate PPE (including respirators if needed), hygiene measures, and possible establishment of a regulated area per 1926.1127(a)(8) and the monitoring rules in 1926.1127(d).
• Document the emergency procedures and ensure affected employees receive training and medical surveillance where exposures meet applicable thresholds.

Under 1926.1127(d)(1)(i) the competent person should review relevant plans, past monitoring reports, Safety Data Sheets (SDS), material testing results, and consult the property owner or appropriate agencies to establish whether cadmium is present.

• The standard explicitly lists review of plans, past reports, SDSs, other records, and consultations as part of the investigation needed to determine cadmium presence (1926.1127(d)(1)(i)).
• If records are inconclusive, perform material testing or air monitoring to confirm presence and potential for exposures.

Under 1926.1127(b) and 1926.1127(l)(3) the "final medical determination" is the examining physician's written opinion about the employee's health status and fitness to work under the cadmium standard, and it must be prepared and signed by the physician conducting the required medical evaluations.

• The final medical determination is the written medical opinion produced by the physician under the medical provisions of 1926.1127(l)(3) and is defined in 1926.1127(b).
• If multiple physician review or an alternative physician determination process is used, the resulting final written finding from that process is the final medical determination per 1926.1127(l)(13)-(14).

Under 1926.1127(a)(9) transportation, disposal, storage, or containment of cadmium or cadmium-containing materials on the construction site is covered by the cadmium standard and requires evaluation of exposure potential and appropriate controls.

• Employers must assess exposure risks from these activities, monitor when exposures could reach the action level or PEL, and implement engineering controls, PPE, and hygiene measures as needed per 1926.1127(a)(9) and the monitoring provisions in 1926.1127(d).
• Ensure waste handling and storage areas are managed to prevent airborne releases and establish regulated areas if exposures can exceed the PEL.

An employer must establish a regulated area whenever an employee’s exposure to airborne cadmium is, or can reasonably be expected to be, in excess of the permissible exposure limit (PEL). This is required under 1926.1127(e)(1).

Regulated areas must be clearly demarcated in any manner that adequately establishes and alerts employees to the boundaries and protects people outside the area from airborne cadmium above the PEL. See 1926.1127(e)(2).

Access to a regulated area must be limited to authorized persons only. Employers must control entry so only authorized personnel enter areas where cadmium exposures can exceed the PEL, per 1926.1127(e)(3).

Yes — every person entering a regulated area must be supplied with and required to use a respirator selected in accordance with 1926.1127(g)(2). See the requirement at 1926.1127(e)(4).

Employers must implement engineering and work-practice controls to reduce and maintain employee exposures to cadmium at or below the PEL unless they can demonstrate such controls are not feasible. This hierarchy is set out in 1926.1127(f)(1)(i). Employers may not use employee rotation to meet the PEL (see 1926.1127(f)(1)(iv).

The employer may demonstrate that engineering controls to achieve the PEL are not required only when the employee is exposed only intermittently and is not exposed above the PEL on 30 or more days per year (in any consecutive 12-month period), per 1926.1127(f)(1)(ii).

If engineering and work-practice controls cannot reduce exposures to the PEL, the employer must still implement those controls to lower exposures as much as feasible and supplement them with respiratory protection that complies with paragraph (g) to achieve the PEL, per 1926.1127(f)(1)(iii).

High-speed abrasive disc saws and similar abrasive power equipment must not be used on cadmium or cadmium-containing materials when exposures are above the PEL unless they are equipped with appropriate engineering controls to minimize emissions, according to 1926.1127(f)(3)(i).

Materials containing cadmium must not be applied by spray methods if exposures are above the PEL unless employees are protected with supplied-air respirators with full facepiece (or hood/helmet/suit) operated in positive pressure mode and measures are taken to limit overspray and prevent contamination of adjacent areas, per 1926.1127(f)(3)(ii).

When ventilation is used, employers must make measurements (such as capture velocity, duct velocity, or static pressure) as necessary to demonstrate the system’s effectiveness and must develop procedures to minimize employee exposure during maintenance and filter changes, per 1926.1127(f)(4)(i) and 1926.1127(f)(4)(iv).

Employers must re-measure the ventilation system’s effectiveness within five working days of any production, process, or control change that might significantly increase cadmium exposure (1926.1127(f)(4)(ii)). If exhaust air is recirculated, the system must use a high efficiency filter and be monitored to assure effectiveness (1926.1127(f)(4)(iii)).

When employee exposure to cadmium exceeds the PEL and engineering/work-practice controls are required under paragraph (f)(1), the employer must establish and implement a written compliance program to reduce exposures to or below the PEL prior to the start of the job, per 1926.1127(f)(5)(i).

Written compliance programs must be reviewed and updated promptly to reflect significant changes in compliance status or achievable air cadmium levels, reviewed initially and after each change by a competent person, and provided on request to the Assistant Secretary, the Director, affected employees, and designated employee representatives per 1926.1127(f)(5)(ii)-(iv).

Respirators must be used during periods necessary to install or implement engineering and work-practice controls when exposures exceed the PEL, during maintenance and brief or intermittent operations where exposures exceed the PEL and controls are not feasible or required, in regulated areas, when an employee at/above the action level requests one, when controls are not required under the intermittent-exposure exception, and in emergencies, according to 1926.1127(g)(1).

The employer must implement a respiratory protection program in accordance with 1910.134(b) through (d) (except (d)(1)(iii)), and (f) through (m) that covers each employee required by this section to use a respirator, per 1926.1127(g)(2)(i).

If an employee exhibits breathing difficulty during fit testing or respirator use, the employer must provide a medical examination in accordance with paragraph (l)(6)(ii) to determine whether the employee can use a respirator; and no employee may use a respirator if the examining physician determines they cannot function normally while wearing it, per 1926.1127(g)(2)(ii)-(iii).

Employers must select and provide the appropriate respirators specified in paragraph (d)(3)(i)(A) of 29 CFR 1910.134, provide full facepiece respirators when employees experience eye irritation, and provide HEPA filters for powered and non-powered air-purifying respirators, per 1926.1127(g)(3)(i).

Yes — the employer must provide a powered air-purifying respirator instead of a negative-pressure respirator when an employee entitled to a respirator chooses to use a PAPR and it will provide adequate protection, per 1926.1127(g)(3)(ii).

The employer must develop and implement a written emergency plan that includes provisions for the use of appropriate respirators and personal protective equipment to deal with substantial releases of airborne cadmium, as required by 1926.1127(h).

Abrasive blasting on cadmium or cadmium-containing materials must be conducted in a manner that provides adequate protection to employees (for example, engineering controls, containment, and appropriate respiratory/PPE), per 1926.1127(f)(2)(i).

When ventilation is used to control cadmium exposures, measurements such as capture velocity, duct velocity, or static pressure should be made as necessary to demonstrate and maintain the system’s effectiveness, as required by 1926.1127(f)(4)(i).

If an employee is exposed to airborne cadmium above the PEL or experiences cadmium-related skin or eye irritation, the employer must provide, at no cost, appropriate protective work clothing and equipment (for example, coveralls, gloves, head coverings, boots, face shields or vented goggles meeting 1910.133) and ensure they are used; contaminated clothing must be removed only in provided change rooms and the employer is responsible for cleaning, laundering, repairing, replacing, and disposing of such clothing as needed to maintain effectiveness (weekly at minimum and immediately if ripped), per 1926.1127(i)(1)-(3).

Contaminated protective clothing may not be taken from the workplace except by authorized personnel for laundering/maintenance offsite; such clothing must be placed in sealed, impermeable bags or containers designed to prevent dust dispersion and containers removed from change rooms must bear labels as required by paragraph (m)(3)(ii). Employers must not remove cadmium from clothing by blowing or shaking, must maintain laundering/cleaning practices that prevent releasing airborne cadmium above the PEL, and must inform anyone who launders such clothing of the hazards and proper cleaning methods, per 1926.1127(i)(2)-(3).

No — the employer must assure that employees do not eat, drink, smoke, chew tobacco or gum, or apply cosmetics in regulated areas, and must prevent carrying or storing such products in those areas, as required by the hygiene and methods-of-compliance provisions of 1926.1127.

No — under 1926.1127(j)(4)(ii) employees are not allowed to enter lunchroom facilities with protective work clothing or equipment unless surface cadmium has first been removed by HEPA vacuuming or another method that removes cadmium dust without dispersing it.

• Employers must ensure lunchrooms are readily accessible, that eating surfaces are kept free of cadmium, and that no employee in a lunchroom is exposed to cadmium at or above 2.5 µg/m3, per 1926.1127(j)(4)(i).
• Acceptable cleaning before entry: HEPA-filter vacuuming or an equally effective non-dispersive method that actually removes cadmium dust (do not rely on brushing or blowing dust into the air).
• Practical employer steps: provide an area or procedure to HEPA-vacuum clothing/equipment before meal breaks; train employees not to enter lunchrooms with contaminated garments; post signage and supervise compliance.

See 1926.1127(j)(4)(ii) and 1926.1127(j)(4)(i) for the regulatory requirements.

Under 1926.1127(k), employers must keep surfaces as free as practicable of cadmium and, wherever possible, clean contaminated surfaces by vacuuming or other methods that minimize the likelihood of cadmium becoming airborne. HEPA-filtered vacuuming (or an equally effective filtration method) must be used when vacuuming.

• Preferred methods: HEPA-filtered vacuuming or other techniques that minimize airborne dust, and use/empty the equipment so cadmium does not reenter the workplace (1926.1127(k)(3)–(k)(4)).
• When sweeping or shoveling is allowed: Shoveling, dry or wet sweeping, and brushing may be used only after vacuuming or other low-dispersion methods have been tried and found not effective (1926.1127(k)(5)).
• Compressed air: Compressed air must not be used to remove cadmium from surfaces unless it is used together with a ventilation system designed to capture the dust cloud created (1926.1127(k)(6)).
• Disposal: Contaminated waste and PPE destined for disposal must be collected and sealed in impermeable bags/containers and labeled per 1926.1127(k)(7).

Practical steps: start with HEPA vacuuming, document attempts if you need an alternative, avoid dry sweeping unless justified, never use uncontained compressed air, and seal/label contaminated waste for disposal. See 1926.1127(k) for the full requirements.