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OSHA 1926.62AppA

Lead exposure substance data

Subpart D

20 Questions & Answers
10 Interpretations

Questions & Answers

Under 1926.62 App A, which lead compounds are covered by the construction lead standard?

The construction lead standard covers elemental lead, all inorganic lead compounds, and a class of organic lead compounds called lead soaps. The substance data sheet states that the word lead in the standard means elemental lead, all inorganic lead compounds, and lead soaps, and that the standard does not apply to other organic lead compounds (Substance Data Sheet, 1926.62 App A).

Under 1926.62 App A, what construction activities commonly create occupational lead exposure?

Construction activities that commonly create lead exposure include demolition or salvage of structures containing lead, removal or encapsulation of lead-containing materials, new construction, alteration, repair, renovation, installation of products that contain lead, and tasks involving transportation, disposal, storage, or containment of lead on-site. The substance data sheet lists these typical uses and construction-related activities where workers may be exposed to lead (Substance Data Sheet, 1926.62 App A).

Under 1926.62, what is the permissible exposure limit (PEL) for lead in construction?

The permissible exposure limit (PEL) for lead in construction is 50 micrograms per cubic meter of air (50 µg/m3) averaged over an 8-hour workday. The substance data sheet specifies this PEL and it is implemented through the construction lead standard (1926.62 PEL and Substance Data Sheet, 1926.62 App A).

Under 1926.62, what is the action level for lead and what does it trigger?

The action level for lead is 30 micrograms per cubic meter of air (30 µg/m3) averaged over an 8-hour workday, and it triggers requirements such as exposure monitoring, medical surveillance, and employee training. The substance data sheet explains the action level and that it initiates ancillary provisions of the standard (Substance Data Sheet, 1926.62 App A).

Under 1926.62 App A, how can lead enter a worker's body on a construction site?

Lead can enter a worker’s body primarily by inhalation of airborne lead (dusts and fumes) and by ingestion if lead-contaminated hands, food, cigarettes, or other items are put into the mouth. The substance data sheet identifies inhalation as generally the most important occupational route and also explains how ingestion from contaminated hands or personal items can contribute to exposure (Substance Data Sheet, 1926.62 App A).

Under 1926.62 App A, is lead absorbed through the skin?

Except for certain organic lead compounds not covered by the standard, lead is not absorbed through intact skin. The substance data sheet states that lead (except for some organic lead compounds such as tetraethyl lead, which are not covered by the construction standard) is not absorbed through the skin and that airborne lead is the principal occupational absorption route (Substance Data Sheet, 1926.62 App A).

Under 1926.62 App A, why are good hygiene and housekeeping important to prevent lead ingestion?

Good hygiene and housekeeping are essential because lead can be taken into the body by swallowing contaminated food, cigarettes, tobacco, or make-up handled with contaminated hands; preventing hand-to-mouth contact and removing lead dust reduces ingestion. The substance data sheet explains that handling food or personal items with lead-contaminated hands contributes to ingestion and that controlling dust and providing hygiene facilities helps prevent absorption (Substance Data Sheet, 1926.62 App A).

Under 1926.62 App A, what are the short-term (acute) health effects of high lead exposure?

High short-term (acute) exposure to lead can cause serious health effects including acute encephalopathy, seizures, coma, and death in extreme cases. The substance data sheet warns that although such acute occupational exposures are unusual, acute encephalopathy and other rapid, severe effects can occur with sufficiently large doses (Substance Data Sheet, 1926.62 App A).

Under 1926.62 App A, what are the long-term (chronic) health effects from lead exposure?

Long-term (chronic) lead exposure may cause severe damage to the blood-forming, nervous, urinary, and reproductive systems, and can lead to anemia, peripheral neuropathy (e.g., wrist or foot drop), kidney disease, reduced fertility, and risks to pregnancy and developing fetuses. The substance data sheet details common chronic symptoms (fatigue, headaches, gastrointestinal problems, nervousness, tremors) and explains serious outcomes such as kidney failure and reproductive harm (Substance Data Sheet, 1926.62 App A).

Under 1926.62 App A, what blood lead level (BLL) does OSHA say should be maintained to protect most workers?

To protect most workers over a working lifetime, blood lead levels should be maintained at or below 40 micrograms per deciliter (40 µg/dl), and workers who intend to have children should be kept below 30 µg/dl. The substance data sheet sets these health protection goals and explains the increased reproductive risk at higher BLLs (Substance Data Sheet, 1926.62 App A).

Under 1926.62 App A and related guidance, what does a blood lead level (BLL) measurement tell you and what are its limits?

A BLL measurement shows the current amount of lead circulating in the blood and is the most useful indicator of recent absorption, but it does not reveal how much lead is stored in body tissues or the full effects of past exposure. The substance data sheet explains that BLLs reflect current absorption (not tissue burden) and that both the magnitude and duration of elevated BLLs influence long-term risk (Substance Data Sheet, 1926.62 App A).

Under 1926.62 App A, what should a worker do if they develop symptoms of lead poisoning or have trouble breathing during a respirator fit test?

A worker should immediately notify their employer, and the employer must provide appropriate medical examinations or consultations at no cost and at a reasonable time and place. The substance data sheet instructs workers to report signs or symptoms associated with lead poisoning or difficulty breathing during respirator use so the employer can arrange medical evaluation and follow-up (Substance Data Sheet, 1926.62 App A).

Under 1926.62 App A, who has the primary responsibility for ensuring compliance with the lead standard on a construction site?

The employer has the primary responsibility to ensure compliance with the lead standard for both the company and individual workers, although employees also share responsibility by following controls and reporting concerns. The substance data sheet emphasizes that employers must meet standard requirements, while workers can help by learning lead hazards, following controls, and reporting symptoms (Substance Data Sheet, 1926.62 App A).

Under 1926.62 App A, why does the length of time with an elevated BLL matter?

The duration of elevated blood lead levels matters because the longer a worker has an elevated BLL, the greater the likelihood that lead is being stored in organs and tissues, increasing the risk of permanent damage. The substance data sheet explains that cumulative body burden and sustained elevations in BLL raise the chance of serious, long-term health effects (Substance Data Sheet, 1926.62 App A).

Under 1926.62 App A, how can employers and workers reduce the risk of lead ingestion on the job?

Employers and workers can reduce lead ingestion by keeping hands and work clothing clean, providing washing facilities and clean eating areas, prohibiting eating, smoking, and applying cosmetics in contaminated areas, and controlling lead dust through housekeeping and engineering controls. The substance data sheet highlights that ingestion commonly results from contaminated hands or personal items and that hygiene practices and dust control are key prevention measures (Substance Data Sheet, 1926.62 App A).

Under 1926.62 App A, does the lead construction standard apply to all organic lead compounds?

No; the lead construction standard does not apply to all organic lead compounds—only to a class called lead soaps. The substance data sheet states the standard covers elemental lead, all inorganic lead compounds, and lead soaps, and explicitly excludes other organic lead compounds (Substance Data Sheet, 1926.62 App A).

Under 1926.62 App A, are children of parents exposed to excess lead at workplace risk, and why?

Yes; children of parents exposed to excess lead are at increased risk for birth defects, developmental problems, behavioral disorders, and higher infant mortality, because lead exposure can affect reproductive cells and cross the placental barrier to harm developing fetuses. The substance data sheet describes these reproductive and developmental risks for children of exposed parents (Substance Data Sheet, 1926.62 App A).

Under 1926.62 App A, can a normal BLL rule out past lead accumulation in tissues?

No; a normal or current BLL does not rule out past accumulation of lead in body tissues because blood measurements reflect recent absorption and do not directly indicate the amount stored in organs and bones. The substance data sheet explains that BLLs indicate current absorption but not tissue burdens from past exposures (Substance Data Sheet, 1926.62 App A).

Under 1926.62 App A, what is the best single way to prevent lead-related impairment and disease?

The best single way to prevent lead-related impairments is to maintain a worker’s blood lead level at or below 40 µg/dl. The substance data sheet states that keeping BLLs below 40 µg/dl is the primary goal of the standard to avoid both short- and long-term lead-related health effects (Substance Data Sheet, 1926.62 App A).

Under 1926.62, what happens when workplace monitoring shows exposures at or above the action level?

When monitoring shows exposures at or above the 30 µg/m3 action level, the employer must implement provisions such as periodic exposure monitoring, medical surveillance, and training required by the lead standard. The substance data sheet notes that the action level triggers these ancillary provisions, which are detailed in the construction lead standard (Action level and related obligations, 1926.62 and 1926.62 App A).