(1) Engineering and work practice controls. The employer shall
implement engineering and work practice controls, including administrative
controls, to reduce and maintain employee exposure to lead to
or below the permissible exposure limit to the extent that such
controls are feasible. Wherever all feasible engineering and work
practices controls that can be instituted are not sufficient to
reduce employee exposure to or below the permissible exposure
limit prescribed in WAC
296-155-17607, the employer shall nonetheless use them to
reduce employee exposure to the lowest feasible level and shall
supplement them by the use of respiratory protection that complies
with the requirements of WAC
296-155-17613.
(2) Compliance program.
(a) Prior to commencement of the job each employer shall establish
and implement a written compliance program to achieve compliance
with WAC
296-155-17607.
(b) Written plans for these compliance programs shall include
at least the following:
(i) A description of each activity in which lead is emitted;
e.g., equipment used, material involved, controls in place,
crew size, employee job responsibilities, operating procedures
and maintenance practices;
(ii) A description of the specific means that will be employed
to achieve compliance and, where engineering controls are
required engineering plans and studies used to determine methods
selected for controlling exposure to lead;
(iii) A report of the technology considered in meeting the
PEL;
(iv) Air monitoring data which documents the source of lead
emissions;
(v) A detailed schedule for implementation of the program,
including documentation such as copies of purchase orders
for equipment, construction contracts, etc.;
(vi) A work practice program which includes under requirements
in WAC
296-155-17615,
296-155-17617, and
296-155-17619, and incorporates other relevant work practices
such as those specified in subsection (5) of this section;
(vii) An administrative control schedule required by subsection
(4) of this section, if applicable;
(viii) Other relevant information.
(c) The compliance program shall provide for frequent and regular
inspections of job sites, materials, and equipment to be made
by a competent person.
(d) Written programs shall be submitted upon request to any
affected employee or authorized employee representatives, and
the director, and shall be available at the worksite for examination
and copying by the director.
(e) Written programs shall be revised and updated at least
every 6 months to reflect the current status of the program.
(3) Mechanical ventilation. When ventilation is used to control
lead exposure, the employer shall evaluate the mechanical performance
of the system in controlling exposure as necessary to maintain
its effectiveness.
(4) Administrative controls. If administrative controls are used
as a means of reducing employees TWA exposure to lead, the employer
shall establish and implement a job rotation schedule which includes:
(a) Name or identification number of each affected employee;
(b) Duration and exposure levels at each job or work station
where each affected employee is located; and
(c) Any other information which may be useful in assessing
the reliability of administrative controls to reduce exposure
to lead.
(5) The employer shall ensure that, to the extent relevant, employees
follow good work practices such as described in Appendix B, WAC
296-155-17652.
(1) General. For employees who use respirators required by WAC
296-155-176, the employer must provide each employee with
an appropriate respirator that complies with the requirements
of this section. Respirators must be used during:
(a) Periods when an employee's exposure to lead exceeds the
PEL.
(b) Work operations for which engineering controls and work-practices
are not sufficient to reduce employee exposures to or below
the PEL.
(c) Periods when an employee requests a respirator.
(d) Periods when respirators are required to provide interim
protection of employees while they perform the operations as
specified in WAC
296-155-17609(2).
(2) Respirator program.
(a) The employer must develop, implement, and maintain a respiratory
protection program as required by chapter
296-842 WAC, Respirators, which covers each employee required
by this chapter to use a respirator.
(b) If an employee has breathing difficulty during fit testing
or respirator use, the employer must provide the employee with
a medical examination as required by WAC
296-155-17621(3)(a)(ii) to determine whether or not the
employee can use a respirator while performing the required
duty.
(3) Respirator selection. The employer must:
(a) Select and provide for employees the appropriate respirators
according to this section and WAC 296-842-13005 in the respirator
rule.
(b) Provide employees with a powered air-purifying respirator
(PAPR) when an employee chooses to use a PAPR and its provides
adequate protection to the employee.
(c) Provide employees with full-facepiece respirators instead
of half-facepiece respirators for protecton against lead aerosols
that may cause eye or skin irritation at the use concentration.
(d) Provide HEPA filters or N-, R-, or P-100 filters for powered
air-purifying respirators (PAPRs) and negative-pressure air-purifying
respirators.
(1) Provision and use. Where an employee is exposed to lead
above the PEL without regard to the use of respirators, where
employees are exposed to lead compounds which may cause skin
or eye irritation (e.g., lead arsenate, lead azide), and as
protection for employees performing tasks as specified in WAC
296-155-17609(2), the employer shall provide at no cost
to the employee and assure that the employee uses appropriate
protective work clothing and equipment that prevents contamination
of the employee and the employee's garments such as, but not
limited to:
(a) Coveralls or similar full-body work clothing;
(b) Gloves, hats, and shoes or disposable shoe coverlets;
and
(c) Face shields, vented goggles, or other appropriate protective
equipment which complies with WAC
296-800-160.
(2) Cleaning and replacement.
(a) The employer shall provide the protective clothing required
in subsection (1) of this section in a clean and dry condition
at least weekly, and daily to employees whose exposure levels
without regard to a respirator are over 200 µg/m3
of lead as an 8-hour TWA.
(b) The employer shall provide for the cleaning, laundering,
and disposal of protective clothing and equipment required
by subsection (1) of this section.
(c) The employer shall repair or replace required protective
clothing and equipment as needed to maintain their effectiveness.
(d) The employer shall assure that all protective clothing
is removed at the completion of a work shift only in change
areas provided for that purpose as prescribed in WAC
296-155-17619(2).
(e) The employer shall assure that contaminated protective
clothing which is to be cleaned, laundered, or disposed of,
is placed in a closed container in the change area which prevents
dispersion of lead outside the container.
(f) The employer shall inform in writing any person who cleans
or launders protective clothing or equipment of the potentially
harmful effects of exposure to lead.
(g) The employer shall assure that the containers of contaminated
protective clothing and equipment required by subdivision
(e) of this subsection are labeled as follows:
Caution: Clothing contaminated with lead. Do not remove
dust by blowing or shaking. Dispose of lead contaminated wash
water in accordance with applicable local, state, or federal
regulations.
(h) The employer shall prohibit the removal of lead from
protective clothing or equipment by blowing, shaking, or any
other means which disperses lead into the air.
(1) All surfaces shall be maintained as free as practicable
of accumulations of lead.
(2) Clean-up of floors and other surfaces where lead accumulates
shall wherever possible, be cleaned by vacuuming or other methods
that minimize the likelihood of lead becoming airborne.
(3) Shoveling, dry or wet sweeping, and brushing may be used
only where vacuuming or other equally effective methods have
been tried and found not to be effective.
(4) Where vacuuming methods are selected, the vacuums shall
be equipped with HEPA filters and used and emptied in a manner
which minimizes the reentry of lead into the workplace.
(5) Compressed air shall not be used to remove lead from any
surface unless the compressed air is used in conjunction with
a ventilation system designed to capture the airborne dust created
by the compressed air.
(1) The employer shall assure that in areas where employees
are exposed to lead above the PEL without regard to the use
of respirators, food or beverage is not present or consumed,
tobacco products are not present or used, and cosmetics are
not applied.
(2) Change areas.
(a) The employer shall provide clean change areas for employees
whose airborne exposure to lead is above the PEL, and as protection
for employees performing tasks as specified in WAC
296-155-17609(2), without regard to the use of respirators.
(b) The employer shall assure that change areas are equipped
with separate storage facilities for protective work clothing
and equipment and for street clothes which prevent cross-contamination.
(c) The employer shall assure that employees do not leave
the workplace wearing any protective clothing or equipment
that is required to be worn during the work shift.
(3) Showers.
(a) The employer shall provide shower facilities, where feasible,
for use by employees whose airborne exposure to lead is above
the PEL.
(b) The employer shall assure, where shower facilities are
available, that employees shower at the end of the work shift
and shall provide an adequate supply of cleansing agents and
towels for use by affected employees.
(4) Eating facilities.
(a) The employer shall provide lunchroom facilities or eating
areas for employees whose airborne exposure to lead is above
the PEL, without regard to the use of respirators.
(b) The employer shall assure that lunchroom facilities or
eating areas are as free as practicable from lead contamination
and are readily accessible to employees.
(c) The employer shall assure that employees whose airborne
exposure to lead is above the PEL, without regard to the use
of a respirator, wash their hands and face prior to eating,
drinking, smoking or applying cosmetics.
(d) The employer shall assure that employees do not enter
lunchroom facilities or eating areas with protective work
clothing or equipment unless surface lead dust has been removed
by vacuuming, downdraft booth, or other cleaning method that
limits dispersion of lead dust.
(5) Hand washing facilities.
(a) The employer shall provide adequate handwashing facilities
for use by employees exposed to lead in accordance with WAC
296-155-140.
(b) Where showers are not provided the employer shall assure
that employees wash their hands and face at the end of the
work-shift.
(a) The employer shall make available initial medical surveillance
to employees occupationally exposed on any day to lead at
or above the action level. Initial medical surveillance consists
of biological monitoring in the form of blood sampling and
analysis for lead and zinc protoporphyrin levels.
(b) The employer shall institute a medical surveillance program
in accordance with subsections (2) and (3) of this section
for all employees who are or may be exposed by the employer
at or above the action level for more than 30 days in any
consecutive 12 months;
(c) The employer shall assure that all medical examinations
and procedures are performed by or under the supervision of
a licensed physician.
(d) The employer shall make available the required medical
surveillance including multiple physician review under subsection
(3)(c) without cost to employees and at a reasonable time
and place.
(2) Biological monitoring.
(a) Blood lead and ZPP level sampling and analysis. The employer
shall make available biological monitoring in the form of
blood sampling and analysis for lead and zinc protoporphyrin
levels to each employee covered by subsection (1)(a) and (b)
of this section on the following schedule:
(i) For each employee covered by subsection (1)(b) of this
section, at least every 2 months for the first 6 months
and every 6 months thereafter;
(ii) For each employee covered by subsection (1)(a) or
(b) of this section whose last blood sampling and analysis
indicated a blood lead level at or above 40 µg/dl, at least
every two months. This frequency shall continue until two
consecutive blood samples and analyses indicate a blood
lead level below 40 µg/dl; and
(iii) For each employee who is removed from exposure to
lead due to an elevated blood lead level at least monthly
during the removal period.
(b) Follow-up blood sampling tests. Whenever the results
of a blood lead level test indicate that an employee's blood
lead level exceeds the numerical criterion for medical removal
under WAC
296-155-17623 (1)(a), the employer shall provide a second
(follow-up) blood sampling test within two weeks after the
employer receives the results of the first blood sampling
test.
(c) Accuracy of blood lead level sampling and analysis. Blood
lead level sampling and analysis provided pursuant to this
WAC
296-155-176 shall have an accuracy (to a confidence level
of 95 percent) within plus or minus 15 percent or 6 µg/dl,
whichever is greater, and shall be conducted by a laboratory
approved by OSHA.
(d) Employee notification.
(i) Within five working days after the receipt of biological
monitoring results, the employer shall notify each employee
in writing of their blood lead level; and
(ii) The employer shall notify each employee whose blood
lead level exceeds 40 µg/dl that the standard requires temporary
medical removal with Medical Removal Protection benefits
when an employee's blood lead level exceeds the numerical
criterion for medical removal under WAC
296-155-17623(1)(a).
(3) Medical examinations and consultations.
(a) Frequency. The employer shall make available medical
examinations and consultations to each employee covered by
subsection (1)(b) of this section on the following schedule:
(i) At least annually for each employee for whom a blood
sampling test conducted at any time during the preceding
12 months indicated a blood lead level at or above 40 µg/dl;
(ii) As soon as possible, upon notification by an employee
either that the employee has developed signs or symptoms
commonly associated with lead intoxication, that the employee
desires medical advice concerning the effects of current
or past exposure to lead on the employee's ability to procreate
a healthy child, that the employee is pregnant, or that
the employee has demonstrated difficulty in breathing during
a respirator fitting test or during use; and
(iii) As medically appropriate for each employee either
removed from exposure to lead due to a risk of sustaining
material impairment to health, or otherwise limited pursuant
to a final medical determination.
(b) Content. The content of medical examinations made available
pursuant to subdivision (a)(ii) and (iii) of this subsection
shall be determined by an examining physician and, if requested
by an employee, shall include pregnancy testing or laboratory
evaluation of male fertility. Medical examinations made available
pursuant to subdivision (a)(i) of this subsection shall include
the following elements:
(i) A detailed work history and a medical history, with
particular attention to past lead exposure (occupational
and non-occupational), personal habits (smoking, hygiene),
and past gastrointestinal, hematologic, renal, cardiovascular,
reproductive and neurological problems;
(ii) A thorough physical examination, with particular attention
to teeth, gums, hematologic, gastrointestinal, renal, cardiovascular,
and neurological systems. Pulmonary status should be evaluated
if respiratory protection will be used;
(iii) A blood pressure measurement;
(iv) A blood sample and analysis which determines:
(A) Blood lead level;
(B) Hemoglobin and hematocrit determinations, red cell
indices, and examination of peripheral smear morphology;
(C) Zinc protoporphyrin;
(D) Blood urea nitrogen; and,
(E) Serum creatinine;
(v) A routine urinalysis with microscopic examination;
and
(vi) Any laboratory or other test relevant to lead exposure
which the examining physician deems necessary by sound medical
practice.
(c) Multiple physician review mechanism.
(i) If the employer selects the initial physician who conducts
any medical examination or consultation provided to an employee
by WAC
296-155-176, the employee may designate a second physician:
(A) To review any findings, determinations or recommendations
of the initial physician; and
(B) To conduct such examinations, consultations, and
laboratory tests as the second physician deems necessary
to facilitate this review.
(ii) The employer shall promptly notify an employee of
the right to seek a second medical opinion after each occasion
that an initial physician conducts a medical examination
or consultation pursuant to WAC
296-155-176. The employer may condition its participation
in, and payment for, the multiple physician review mechanism
upon the employee doing the following within fifteen days
after receipt of the foregoing notification, or receipt
of the initial physician's written opinion, whichever is
later:
(A) The employee informing the employer that they intend
to seek a second medical opinion; and
(B) The employee initiating steps to make an appointment
with a second physician.
(iii) If the findings, determinations or recommendations
of the second physician differ from those of the initial
physician, then the employer and the employee shall assure
that efforts are made for the two physicians to resolve
any disagreement.
(iv) If the two physicians have been unable to quickly
resolve their disagreement, then the employer and the employee
through their respective physicians shall designate a third
physician:
(A) To review any findings, determinations or recommendations
of the prior physicians; and
(B) To conduct such examinations, consultations, laboratory
tests and discussions with the prior physicians as the
third physician deems necessary to resolve the disagreement
of the prior physicians.
(v) The employer shall act consistent with the findings,
determinations and recommendations of the third physician,
unless the employer and the employee reach an agreement
which is otherwise consistent with the recommendations of
at least one of the three physicians.
(d) Information provided to examining and consulting physicians.
(i) The employer shall provide an initial physician conducting
a medical examination or consultation under WAC
296-155-176 with the following information:
(A) A copy of this regulation for lead including all
Appendices;
(B) A description of the affected employee's duties as
they relate to the employee's exposure;
(C) The employee's exposure level or anticipated exposure
level to lead and to any other toxic substance (if applicable);
(D) A description of any personal protective equipment
used or to be used;
(E) Prior blood lead determinations; and
(F) All prior written medical opinions concerning the
employee in the employer's possession or control.
(ii) The employer shall provide the foregoing information
to a second or third physician conducting a medical examination
or consultation under WAC
296-155-176 upon request either by the second or third
physician, or by the employee.
(e) Written medical opinions.
(i) The employer shall obtain and furnish the employee
with a copy of a written medical opinion from each examining
or consulting physician which contains only the following
information:
(A) The physician's opinion as to whether the employee
has any detected medical condition which would place the
employee at increased risk of material impairment of the
employee's health from exposure to lead;
(B) Any recommended special protective measures to be
provided to the employee, or limitations to be placed
upon the employee's exposure to lead;
(C) Any recommended limitation upon the employee's use
of respirators, including a determination of whether the
employee can wear a powered air purifying respirator if
a physician determines that the employee cannot wear a
negative pressure respirator; and
(D) The results of the blood lead determinations.
(ii) The employer shall instruct each examining and consulting
physician to:
(A) Not reveal either in the written opinion or orally,
or in any other means of communication with the employer,
findings, including laboratory results, or diagnoses unrelated
to an employee's occupational exposure to lead; and
(B) Advise the employee of any medical condition, occupational
or nonoccupational, which dictates further medical examination
or treatment.
(f) Alternate physician determination mechanisms. The employer
and an employee or authorized employee representative may
agree upon the use of any alternate physician determination
mechanism in lieu of the multiple physician review mechanism
provided by subdivision (c) of this subsection so long as
the alternate mechanism is as expeditious and protective as
the requirements contained in this section.
(4) Chelation.
(a) The employer shall assure that any person whom he retains,
employs, supervises or controls does not engage in prophylactic
chelation of any employee at any time.
(b) If therapeutic or diagnostic chelation is to be performed
by any person in subdivision (a) of this subsection, the employer
shall assure that it be done under the supervision of a licensed
physician in a clinical setting with thorough and appropriate
medical monitoring and that the employee is notified in writing
prior to its occurrence.
(1) Temporary medical removal and return of an employee.
(a) Temporary removal due to elevated blood lead level. The
employer shall remove an employee from work having an exposure
to lead at or above the action level on each occasion that
a periodic and a follow-up blood sampling test conducted pursuant
to WAC
296-155-176 indicate that the employee's blood lead level
is at or above 50 µg/dl; and
(b) Temporary removal due to a final medical determination.
(i) The employer shall remove an employee from work having
an exposure to lead at or above the action level on each
occasion that a final medical determination results in a
medical finding, determination, or opinion that the employee
has a detected medical condition which places the employee
at increased risk of material impairment to health from
exposure to lead.
(ii) For the purposes of WAC
296-155-176, the phrase “final medical determination”
means the written medical opinion on the employees' health
status by the examining physician or, where relevant, the
outcome of the multiple physician review mechanism or alternate
medical determination mechanism used pursuant to the medical
surveillance provisions of WAC
296-155-176.
(iii) Where a final medical determination results in any
recommended special protective measures for an employee,
or limitations on an employee's exposure to lead, the employer
shall implement and act consistent with the recommendation.
(c) Return of the employee to former job status.
(i) The employer shall return an employee to their former
job status:
(A) For an employee removed due to a blood lead level
at or above 50 µg/dl when two consecutive blood sampling
tests indicate that the employee's blood lead level is
at or below 40 µg/dl;
(B) For an employee removed due to a final medical determination,
when a subsequent final medical determination results
in a medical finding, determination, or opinion that the
employee no longer has a detected medical condition which
places the employee at increased risk of material impairment
to health from exposure to lead.
(ii) For the purposes of WAC
296-155-176, the requirement that an employer return
an employee to their former job status is not intended to
expand upon or restrict any rights an employee has or would
have had, absent temporary medical removal, to a specific
job classification or position under the terms of a collective
bargaining agreement.
(d) Removal of other employee special protective measure
or limitations. The employer shall remove any limitations
placed on an employee or end any special protective measures
provided to an employee pursuant to a final medical determination
when a subsequent final medical determination indicates that
the limitations or special protective measures are no longer
necessary.
(e) Employer options pending a final medical determination.
Where the multiple physician review mechanism, or alternate
medical determination mechanism used pursuant to the medical
surveillance provisions of WAC 296-155-176, has not yet resulted
in a final medical determination with respect to an employee,
the employer shall act as follows:
(i) Removal. The employer may remove the employee from
exposure to lead, provide special protective measures to
the employee, or place limitations upon the employee, consistent
with the medical findings, determinations, or recommendations
of any of the physicians who have reviewed the employee's
health status.
(ii) Return. The employer may return the employee to their
former job status, end any special protective measures provided
to the employee, and remove any limitations placed upon
the employee, consistent with the medical findings, determinations,
or recommendations of any of the physicians who have reviewed
the employee's health status, with two exceptions:
(A) If the initial removal, special protection, or limitation
of the employee resulted from a final medical determination
which differed from the findings, determinations, or recommendations
of the initial physician or;
(B) If the employee has been on removal status for the
preceding eighteen months due to an elevated blood lead
level, then the employer shall await a final medical determination.
(2) Medical removal protection benefits.
(a) Provision of medical removal protection benefits. The
employer shall provide an employee up to eighteen (18) months
of medical removal protection benefits on each occasion that
an employee is removed from exposure to lead or otherwise
limited pursuant to WAC
296-155-176.
(b) Definition of medical removal protection benefits. For
the purposes of WAC
296-155-176, the requirement that an employer provide
medical removal protection benefits means that,
as long as the job the employee was removed from continues,
the employer shall maintain the total normal earnings, seniority
and other employment rights and benefits of an employee, including
the employee's right to their former job status as though
the employee had not been medically removed from the employee's
job or otherwise medically limited.
(c) Follow-up medical surveillance during the period of employee
removal or limitation. During the period of time that an employee
is medically removed from their job or otherwise medically
limited, the employer may condition the provision of medical
removal protection benefits upon the employee's participation
in follow-up medical surveillance made available pursuant
to WAC
296-155-176.
(d) Workers' compensation claims. If a removed employee files
a claim for workers' compensation payments for a lead-related
disability, then the employer shall continue to provide medical
removal protection benefits pending disposition of the claim.
To the extent that an award is made to the employee for earnings
lost during the period of removal, the employer's medical
removal protection obligation shall be reduced by such amount.
The employer shall receive no credit for workers' compensation
payments received by the employee for treatment-related expenses.
(e) Other credits. The employer's obligation to provide medical
removal protection benefits to a removed employee shall be
reduced to the extent that the employee receives compensation
for earnings lost during the period of removal either from
a publicly or employer-funded compensation program, or receives
income from employment with another employer made possible
by virtue of the employee's removal.
(f) Voluntary removal or restriction of an employee. Where
an employer, although not required by
WAC 296-155-176 to do so, removes an employee from exposure
to lead or otherwise places limitations on an employee due
to the effects of lead exposure on the employee's medical
condition, the employer shall provide medical removal protection
benefits to the employee equal to that required by subdivisions
(a) and (b) of this subsection.
(a) The employer shall communicate information concerning
lead hazards according to the requirements of WISHA's hazard
communication standard for the construction industry, chapter
296-800 WAC, including but not limited to the requirements
concerning warning signs and labels, material safety data
sheets (MSDS), and employee information and training. In addition,
employers shall comply with the following requirements:
(b) The employer shall train each employee who is subject
to exposure to lead at or above the action level on any day
or who is subject to exposure to lead compounds which may
cause skin or eye irritation (e.g., lead arsenate, lead azide),
in accordance with the requirements of this chapter. The employer
shall institute a training program in accordance with subsection
(2) of this section and ensure employee participation.
(c) The employer shall provide the training program as initial
training prior to the time of job assignment or prior to the
start up date for this requirement, whichever comes last.
(d) The employer shall also provide the training program
at least annually for each employee who is subject to lead
exposure at or above the action level on any day.
(2) Training program. The employer shall assure that each employee
is trained in the following:
(a) The content of this standard and its appendices;
(b) The specific nature of the operations which could result
in exposure to lead above the action level;
(d) The purpose and a description of the medical surveillance
program, and the medical removal protection program including
information concerning the adverse health effects associated
with excessive exposure to lead (with particular attention
to the adverse reproductive effects on both males and females
and hazards to the fetus and additional precautions for employees
who are pregnant);
(e) The engineering controls and work practices associated
with the employee's job assignment including training of employees
to follow relevant good work practices described in Appendix
B, WAC
296-155-17652;
(f) The contents of any compliance plan in effect;
(g) Instructions to employees that chelating agents should
not routinely be used to remove lead from their bodies and
should not be used at all except under the direction of a
licensed physician; and
(a) The employer shall make readily available to all affected
employees a copy of this standard and its appendices.
(b) The employer shall provide, upon request, all materials
relating to the employee information and training program
to affected employees and their designated representatives,
and the director.
(a) The employer may use signs required by other statutes,
regulations or ordinances in addition to, or in combination
with, signs required by this section.
(b) The employer shall assure that no statement appears on
or near any sign required by this section which contradicts
or detracts from the meaning of the required sign.
(2) Signs.
(a) The employer shall post the following warning signs in
each work area where an employees exposure to lead is above
the PEL.
Warning
Lead
Work Area
Poison
No
Smoking Or Eating
(b) The employer shall assure that signs required by this
section are illuminated and cleaned as necessary so that the
legend is readily visible.
(a) The employer shall establish and maintain an accurate
record of all monitoring and other data used in conducting
employee exposure assessments as required in WAC
296-155-17609.
(b) Exposure monitoring records shall include:
(i) The date(s), number, duration, location and results
of each of the samples taken if any, including a description
of the sampling procedure used to determine representative
employee exposure where applicable;
(ii) A description of the sampling and analytical methods
used and evidence of their accuracy;
(iii) The type of respiratory protective devices worn,
if any;
(iv) Name, social security number, and job classification
of the employee monitored and of all other employees whose
exposure the measurement is intended to represent; and
(v) The environmental variables that could affect the measurement
of employee exposure.
(c) The employer shall maintain monitoring and other exposure
assessment records in accordance with the provisions of 296-802
WAC.
(2) Medical surveillance.
(a) The employer shall establish and maintain an accurate
record for each employee subject to medical surveillance as
required by WAC
296-155-17621.
(b) This record shall include:
(i) The name, Social Security number, and description of
the duties of the employee;
(ii) A copy of the physician's written opinions;
(iii) Results of any airborne exposure monitoring done
on or for that employee and provided to the physician; and
(iv) Any employee medical complaints related to exposure
to lead.
(c) The employer shall keep, or assure that the examining
physician keeps, the following medical records:
(i) A copy of the medical examination results including
medical and work history required by
WAC 296-155-17621;
(ii) A description of the laboratory procedures and a copy
of any standards or guidelines used to interpret the test
results or references to that information;
(iii) A copy of the results of biological monitoring.
(d) The employer shall maintain or assure that the physician
maintains medical records in accordance with the provisions
of 296-802
WAC.
(3) Medical removals.
(a) The employer shall establish and maintain an accurate
record for each employee removed from current exposure to
lead pursuant to WAC
296-155-17623.
(b) Each record shall include:
(i) The name and social security number of the employee;
(ii) The date of each occasion that the employee was removed
from current exposure to lead as well as the corresponding
date on which the employee was returned to their former
job status;
(iii) A brief explanation of how each removal was or is
being accomplished; and
(iv) A statement with respect to each removal indicating
whether or not the reason for the removal was an elevated
blood lead level.
(c) The employer shall maintain each medical removal record
for at least the duration of an employee's employment.
(4) Objective data for exemption from requirement for initial
monitoring.
(a) For purposes of WAC
296-155-176, objective data are information demonstrating
that a particular product or material containing lead or a
specific process, operation, or activity involving lead cannot
release dust or fumes in concentrations at or above the action
level under any expected conditions of use. Objective data
can be obtained from an industry-wide study or from laboratory
product test results from manufacturers of lead containing
products or materials. The data the employer uses from an
industry-wide survey must be obtained under workplace conditions
closely resembling the processes, types of material, control
methods, work practices and environmental conditions in the
employer's current operations.
(b) The employer shall maintain the record of the objective
data relied upon for at least 30 years.
(5) Availability. The employer shall make available upon request
all records required to be maintained by this section to affected
employees, former employees, and their designated representatives,
and to the director for examination and copying.
(6) Transfer of records.
(a) Whenever the employer ceases to do business, the successor
employer shall receive and retain all records required to
be maintained by this section.
(b) Whenever the employer ceases to do business and there
is no successor employer to receive and retain the records
required to be maintained by WAC
296-155-176 for the prescribed period, these records shall
be transmitted to the director.
(c) At the expiration of the retention period for the records
required to be maintained by WAC
296-155-176, the employer shall notify the director at
least 3 months prior to the disposal of such records and shall
transmit those records to the director if requested within
the period.
(d) The employer shall also comply with any additional requirements
involving transfer of records set forth in 296-802
WAC.
(1) Employee observation. The employer shall provide affected
employees or their designated representatives an opportunity
to observe any monitoring of employee exposure to lead conducted
pursuant to WAC
296-155-17609.
(2) Observation procedures.
(a) Whenever observation of the monitoring of employee exposure
to lead requires entry into an area where the use of respirators,
protective clothing or equipment is required, the employer
shall provide the observer with and assure the use of such
respirators, clothing and equipment, and shall require the
observer to comply with all other applicable safety and health
procedures.
(b) Without interfering with the monitoring, observers shall
be entitled to:
(i) Receive an explanation of the measurement procedures;
(ii) Observe all steps related to the monitoring of lead
performed at the place of exposure; and
(iii) Record the results obtained or receive copies of
the results when returned by the laboratory.
WAC
296-155-17650 Appendix A to WAC 296-155-176-Substance data
sheet for occupational exposure to lead.
The information contained in the appendices to WAC
296-155-176 is not intended by itself, to create any additional
obligations not otherwise imposed by this standard nor detract
from any existing obligation.
(1) Substance identification.
(a) Substance: Pure lead (Pb) is a heavy metal at room temperature
and pressure and is a basic chemical element. It can combine
with various other substances to form numerous lead compounds.
(b) Compounds covered by the standard: The word “lead”
when used in this standard means elemental lead, all
inorganic lead compounds and a class of organic lead compounds
called lead soaps. This standard does not apply to other organic
lead compounds.
(c) Uses: Exposure to lead occurs in several different occupations
in the construction industry, including demolition or salvage
of structures where lead or lead-containing materials are
present; removal or encapsulation of lead-containing materials,
new construction, alteration, repair, or renovation of structures
that contain lead or materials containing lead; installation
of products containing lead. In addition, there are construction
related activities where exposure to lead may occur, including
transportation, disposal, storage, or containment of lead
or materials containing lead on construction sites, and maintenance
operations associated with construction activities.
(d) Permissible exposure: The permissible exposure limit
(PEL) set by the standard is 50 micrograms of lead per cubic
meter of air (50µg/m3), averaged over an 8-hour
workday.
(e) Action level: The standard establishes an action level
of 30 micrograms of lead per cubic meter of air (30 µg/m3),
averaged over an 8-hour workday. The action level triggers
several ancillary provisions of the standard such as exposure
monitoring, medical surveillance, and training.
(2) Health hazard data.
(a) Ways in which lead enters your body. When absorbed into
your body in certain doses, lead is a toxic substance. The
object of the lead standard is to prevent absorption of harmful
quantities of lead. The standard is intended to protect you
not only from the immediate toxic effects of lead, but also
from the serious toxic effects that may not become apparent
until years of exposure have passed. Lead can be absorbed
into your body by inhalation (breathing) and ingestion (eating).
Lead (except for certain organic lead compounds not covered
by the standard, such as tetraethyl lead) is not absorbed
through your skin. When lead is scattered in the air as a
dust, fume respiratory tract. Inhalation of airborne lead
is generally the most important source of occupational lead
absorption. You can also absorb lead through your digestive
system if lead gets into your mouth and is swallowed. If you
handle food, cigarettes, chewing tobacco, or make-up which
have lead on them or handle them with hands contaminated with
lead, this will contribute to ingestion. A significant portion
of the lead that you inhale or ingest gets into your blood
stream. Once in your blood stream, lead is circulated throughout
your body and stored in various organs and body tissues. Some
of this lead is quickly filtered out of your body and excreted,
but some remains in the blood and other tissues. As exposure
to lead continues, the amount stored in your body will increase
if you are absorbing more lead than your body is excreting.
Even though you may not be aware of any immediate symptoms
of disease, this lead stored in your tissues can be slowly
causing irreversible damage, first to individual cells, then
to your organs and whole body systems.
(b) Effects of overexposure to lead.
(i) Short term (acute) overexposure. Lead is a potent,
systemic poison that serves no known useful function once
absorbed by your body. Taken in large enough doses, lead
can kill you in a matter of days. A condition affecting
the brain called acute encephalopathy may arise which develops
quickly to seizures, coma, and death from cardiorespiratory
arrest. A short term dose of lead can lead to acute encephalopathy.
Short term occupational exposures of this magnitude are
highly unusual, but not impossible. Similar forms of encephalopathy
may, however, arise from extended, chronic exposure to lower
doses of lead. There is no sharp dividing line between rapidly
developing acute effects of lead, and chronic effects which
take longer to acquire. Lead adversely affects numerous
body systems, and causes forms of health impairment and
disease which arise after periods of exposure as short as
days or as long as several years.
(ii) Long-term (chronic) overexposure. Chronic overexposure
to lead may result in severe damage to your blood-forming,
nervous, urinary and reproductive systems. Some common symptoms
of chronic overexposure include loss of appetite, metallic
taste in the mouth, anxiety, constipation, nausea, pallor,
excessive tiredness, weakness, insomnia, headache, nervous
irritability, muscle and joint pain or soreness, fine tremors,
numbness, dizziness, hyperactivity and colic. In lead colic
there may be severe abdominal pain. Damage to the central
nervous system in general and the brain (encephalopathy)
in particular is one of the most severe forms of lead poisoning.
The most severe, often fatal, form of encephalopathy may
be preceded by vomiting, a feeling of dullness progressing
to drowsiness and stupor, poor memory, restlessness, irritability,
tremor, and convulsions. It may arise suddenly with the
onset of seizures, followed by coma, and death. There is
a tendency for muscular weakness to develop at the same
time. This weakness may progress to paralysis often observed
as a characteristic “wrist drop” or “foot
drop” and is a manifestation of a disease to the nervous
system called peripheral neuropathy. Chronic overexposure
to lead also results in kidney disease with few, if any,
symptoms appearing until extensive and most likely permanent
kidney damage has occurred. Routine laboratory tests
reveal the presence of this kidney disease only about two-thirds
of kidney function is lost. When overt symptoms of
urinary dysfunction arise, it is often too late to correct
or prevent worsening conditions, and progression to kidney
dialysis or death is possible. Chronic overexposure
to lead impairs the reproductive systems of both men and
women. Overexposure to lead may result in decreased
sex drive, impotence and sterility in men. Lead can
alter the structure of sperm cells raising the risk of birth
defects. There is evidence of miscarriage and stillbirth
in women whose husbands were exposed to lead or who were
exposed to lead themselves. Lead exposure also may
result in decreased fertility, and abnormal menstrual cycles
in women. The course of pregnancy may be adversely
affected by exposure to lead since lead crosses the placental
barrier and poses risks to developing fetuses. Children
born of parent either one of whom were exposed to excess
lead levels are more likely to have birth defects, mental
retardation, behavioral disorders or die during the first
year of childhood. Overexposure to lead also disrupts
the blood-forming system resulting in decreased hemoglobin
(the substance in the blood that carries oxygen to the cells)
and ultimately anemia. Anemia is characterized by
weakness, pallor and fatigability as a result of decreased
oxygen carrying capacity in the blood.
(iii) Health protection goals of the standard. Prevention
of adverse health effects for most workers from exposure
to lead throughout a working lifetime requires that a worker's
blood lead level (BLL, also expressed as PbB) be maintained
at or below forty micrograms per deciliter of whole blood
(40 µg/dl). The blood lead levels of workers (both male
and female workers) who intend to have children should be
maintained below 30 µg/dl to minimize adverse reproductive
health effects to the parents and to the developing fetus.
The measurement of your blood lead level (BLL) is the most
useful indicator of the amount of lead absorbed by your
body.
Blood lead levels are most often reported in units of milligrams
(mg) or micrograms (µg) of lead (1 mg=1000 µg) per 100 grams
(100g), 100 milliliters (100 ml) or deciliter (dl) of blood.
These three units are essentially the same. Sometime BLLs
are expressed in the form of mg% or µg%. This is a shorthand
notation for 100g, 100 ml, or dl. (References to BLL measurements
in this standard are expressed in the form of µg/dl.)
BLL measurements show the amount of lead circulating in
your blood stream, but do not give any information about
the amount of lead stored in your various tissues. BLL measurements
merely show current absorption of lead, not the effect that
lead is having on your body or the effects that past lead
exposure may have already caused. Past research into lead-related
diseases, however, has focused heavily on associations between
BLLs and various diseases. As a result, your BLL is an important
indicator of the likelihood that you will gradually acquire
a lead-related health impairment or disease.
Once your blood lead level climbs above 40 µg/dl, your
risk of disease increases. There is a wide variability of
individual response to lead, thus it is difficult to say
that a particular BLL in a given person will cause a particular
effect. Studies have associated fatal encephalopathy with
BLLs as low as 150 µg/dl. Other studies have shown other
forms of diseases in some workers with BLLs well below 80
µg/dl. Your BLL is a crucial indicator of the risks to your
health, but one other factor is also extremely important.
This factor is the length of time you have had elevated
BLLs. The longer you have an elevated BLL, the greater
the risk that large quantities of lead are being gradually
stored in your organs and tissues (body burden). The
greater your overall body burden, the greater the chances
of substantial permanent damage. The best way to prevent
all forms of lead-related impairments and diseases-both
short-term and long-term is to maintain your BLL below 40
ug/dl. The provisions of the standard are designed
with this end in mind.
Your employer has prime responsibility to assure that the
provisions of the standard are complied with both by the
company and by individual workers. You, as a worker, however,
also have a responsibility to assist your employer in complying
with the standard. You can play a key role in protecting
your own health by learning about the lead hazards and their
control, learning what the standard requires, following
the standard where it governs your own actions, and seeing
that your employer complies with provisions governing employee
actions.
(iv) Reporting signs and symptoms of health problems. You
should immediately notify your employer if you develop signs
or symptoms associated with lead poisoning or if you desire
medical advice concerning the effects of current or past
exposure to lead or your ability to have a healthy child.
You should also notify your employer if you have difficulty
breathing during a respirator fit test or while wearing
a respirator. In each of these cases, your employer must
make available to you appropriate medical examinations or
consultations.
These must be provided at no cost to you and at a reasonable
time and place. The standard contains a procedure whereby
you can obtain a second opinion by a physician of your choice
if your employer selected the initial physician.
The standard sets a permissible exposure limit (PEL) of 50
micrograms of lead per cubic meter of air (50 µg/m3),
averaged over an 8-hour workday which is referred to as a time-weighted
average (TWA). This is the highest level of lead in air to which
you may be permissibly exposed over an 8-hour workday.
However, since this is an 8-hour average, short exposures above
the PEL are permitted so long as for each 8-hour work day your
average exposure does not exceed this level. This standard,
however, takes into account the fact that your daily exposure
to lead can extend beyond a typical 8-hour workday as the result
of overtime or other alterations in your work schedule. To deal
with this situation, the standard contains a formula which reduces
your permissible exposure when you are exposed more than 8 hours.
For example, if you are exposed to lead for 10 hours a day,
the maximum permitted average exposure would be 40µg/m3.
If lead is present in your workplace in any quantity, your
employer is required to make an initial determination of whether
any employee's exposure to lead exceeds the action level (30
µg/m3 averaged over an 8-hour day). Employee exposure
is that exposure which would occur if the employee were not
using a respirator. This initial determination requires your
employer to monitor workers' exposures unless the employee has
objective data which can demonstrate conclusively that no employee
will be exposed to lead in excess of the action level. Where
objective data is used in lieu of actual monitoring the employer
must establish and maintain an accurate record, documenting
its relevancy in assessing exposure levels for current job conditions.
If such objective data is available, the employer need proceed
no further on employee exposure assessment until such time that
conditions have changed and the determination is no longer valid.
Objective data may be compiled from various sources, e.g.,
insurance companies and trade associations and information from
suppliers or exposure data collected from similar operations.
Objective data may also comprise previously-collected sampling
data including area monitoring. If it cannot be determined through
using objective data that worker exposure is less than the action
level, your employer must conduct monitoring or must rely on
relevant previous personal sampling, if available. Where monitoring
is required for the initial determination, it may be limited
to a representative number of employees who are reasonably expected
to have the highest exposure levels. If your employer has conducted
appropriate air sampling for lead in the past 12 months, they
may use these results, provided they are applicable to the same
employee tasks and exposure conditions and meet the requirements
for accuracy as specified in the standard. As with objective
data, if such results are relied upon for the initial determination,
your employer must establish and maintain a record as to the
relevancy of such data to current job conditions.
If there have been any employee complaints of symptoms which
may be attributable to exposure to lead or if there is any other
information or observations which would indicate employee exposure
to lead, this must also be considered as part of the initial
determination. If this initial determination shows that a reasonable
possibility exists that any employee may be exposed, without
regard to respirator, over the action level, your employer must
set up an air monitoring program to determine the exposure level
representative of each employee exposed to lead at your workplace.
In carrying out this air monitoring program, your employer is
not required to monitor the exposure of every employee, but
they must monitor a representative number of employees and job
types. Enough sampling must be done to enable each employee's
exposure level to be reasonably represent full shift exposure.
In addition, these air samples must be taken under conditions
which represent each employee's regular, daily exposure to lead.
Sampling performed in the past 12 months may be used to determine
exposures above the action level if such sampling was conducted
during work activities essentially similar to present work conditions.
The standard lists certain tasks which may likely result in
exposures to lead in excess of the PEL and, in some cases, exposures
in excess of 50 times the PEL. If you are performing any of
these tasks, your employer must provide you with appropriate
respiratory protection, protective clothing and equipment, change
areas, hand washing facilities, biological monitoring, and training
until such time that an exposure assessment is conducted which
demonstrates that your exposure level is below the PEL.
If you are exposed to lead and air sampling is performed, your
employer is required to notify you in writing within 5 working
days of the air monitoring results which represent your exposure.
If the results indicate that your exposure exceeds the PEL (without
regard to your use of a respirator), then your employer must
also notify you of this in writing, and provide you with a description
of the corrective action that has been taken or will be taken
to reduce your exposure.
Your exposure must be rechecked by monitoring, at least every
six months if your exposure is at or over the action level but
below the PEL. Your employer may discontinue monitoring for
you if 2 consecutive measurements, taken at least 7 days apart,
are at or below the action level. Air monitoring must be repeated
every 3 months if you are exposed over the PEL. Your employer
must continue monitoring for you at this frequency until 2 consecutive
measurements, taken at least 7 days apart, are below the PEL
but above the action level, at which time your employer must
repeat monitoring of your exposure every six months and may
discontinue monitoring only after your exposure drops to or
below the action level. However, whenever there is a change
of equipment, process, control, or personnel or a new type of
job is added at your workplace which may result in new or additional
exposure to lead, your employer must perform additional monitoring.
Your employer is required to assure that no employee is exposed
to lead in excess of the PEL as an 8-hour TWA. The standard
for lead in construction requires employers to institute engineering
and work practice controls including administrative controls
to the extent feasible to reduce employee exposure to lead.
Where such controls are feasible but not adequate to reduce
exposures below the PEL they must be used nonetheless to reduce
exposures to the lowest level that can be accomplished by these
means and then supplemented with appropriate respiratory protection.
Your employer is required to develop and implement a written
compliance program prior to the commencement of any job where
employee exposures may reach the PEL as an 8-hour TWA. The standard
identifies the various elements that must be included in the
plan. For example, employers are required to include a description
of operations in which lead is emitted, detailing other relevant
information about the operation such as the type of equipment
used, the type of material involved, employee job responsibilities,
operating procedures and maintenance practices. In addition,
your employer's compliance plan must specify the means that
will be used to achieve compliance and, where engineering controls
are required, include any engineering plans or studies that
have been used to select the control methods. If administrative
controls involving job rotation are used to reduce employee
exposure to lead, the job rotation schedule must be included
in the compliance plan. The plan must also detail the type of
protective clothing and equipment, including respirator, housekeeping
and hygiene practices that will be used to protect you from
the adverse effects of exposure to lead.
The written compliance program must be made available, upon
request, to affected employees and their designated representatives,
and the director.
Finally, the plan must be reviewed and updated at least every
6 months to assure it reflects the current status in exposure
control.
Your employer is required to select respirator from the types
listed in Table I of the Respiratory Protection section of the
standard (see WAC
296-155-17613). Any respirator chosen must be certified
by the National Institute for Occupational Safety and Health
(NIOSH) under the provisions of 42 CFR part 84. This respirator
selection table will enable your employer to choose a type of
respirator that will give you a proper amount of protection
based on your airborne lead exposure. Your employer may select
a type of respirator that provides greater protection than that
required by the standard; that is, one recommended for a higher
concentration of lead than is present in your workplace. For
example, a powered air-purifying respirator (PAPR) is much more
protective than a typical negative pressure respirator, and
may also be more comfortable to wear. A PAPR has a filter, cartridge,
or canister to clean the air, and a power source which continuously
blows filtered air into your breathing zone. Your employer might
make a PAPR available to you to ease the burden of having to
wear a respirator for long periods of time. The standard provides
that you can obtain a PAPR upon request.
Your employer must also start a Respiratory Protection Program.
This program must include written procedures for the proper
selection, use, cleaning, storage, and maintenance of respirator.
Your employer must ensure that your respirator facepiece fits
properly. Proper fit of a respirator facepiece is critical to
your protection from airborne lead. Obtaining a proper fit on
each employee may require your employer to make available several
different types of respirator masks. To ensure that your respirator
fits properly and that facepiece leakage is minimal, your employer
must give you either a qualitative or quantitative fit test
as specified in WAC
296-842-15005.
If you are exposed to lead above the PEL as an 8-hour TWA,
without regard to your use of a respirator, or if you are exposed
to lead compounds such as lead arsenate or lead azide which
can cause skin and eye irritation, your employer must provide
you with protective work clothing and equipment appropriate
for the hazard. If work clothing is provided, it must be provided
in a clean and dry condition at least weekly, and daily if your
airborne exposure to lead is greater than 200 µg/m3.
Appropriate protective work clothing and equipment can include
coveralls or similar full-body work clothing, gloves, hats,
shoes or disposable shoe coverlets, and face shields or vented
goggles. Your employer is required to provide all such equipment
at no cost to you. In addition, your employer is responsible
for providing repairs and replacement as necessary, and also
is responsible for the cleaning, laundering or disposal of protective
clothing and equipment.
The standard requires that your employer assure that you follow
good work practices when you are working in areas where your
exposure to lead may exceed the PEL. With respect to protective
clothing and equipment, where appropriate, the following procedures
should be observed prior to beginning work:
Change into work clothing and shoe covers in the clean
section of the designated changing areas;
Use work garments of appropriate protective gear, including
respirator before entering the work area; and
Store any clothing not worn under protective clothing
in the designated changing area.
Workers should follow these procedures upon leaving the work
area:
HEPA vacuum heavily contaminated protective work clothing
while it is still being worn. At no time may lead be removed
from protective clothing by any means which result in uncontrolled
dispersal of lead into the air;
Remove shoe covers and leave them in the work area;
Remove protective clothing and gear in the dirty area
of the designated changing area. Remove protective coveralls
by carefully rolling down the garment to reduce exposure
to dust.
Remove respirator last; and
Wash hands and face.
Workers should follow these procedures upon finishing work
for the day (in addition to procedures described above):
Where applicable, place disposal coveralls and shoe covers
with the abatement waste;
Contaminated clothing which is to be cleaned, laundered
or disposed of must be placed in closed containers in the
change room.
Clean protective gear, including respirator, according
to standard procedures;
Wash hands and face again.
If showers are available, take a shower and wash hair. If shower
facilities are not available at the work site, shower immediately
at home and wash hair.
Your employer must establish a housekeeping program sufficient
to maintain all surfaces as free as practicable of accumulations
of lead dust. Vacuuming is the preferred method of meeting this
requirement, and the use of compressed air to clean floors and
other surfaces is generally prohibited unless removal with compressed
air is done in conjunction with ventilation systems designed
to contain dispersal of the lead dust. Dry or wet sweeping,
shoveling, or brushing may not be used except where vacuuming
or other equally effective methods have been tried and do not
work. Vacuums must be used equipped with a special filter called
a high-efficiency particulate air (HEPA) filter and emptied
in a manner which minimizes the reentry of lead into the workplace.
The standard requires that hand washing facilities be provided
where occupational exposure to lead occurs. In addition, change
areas, showers (where feasible), and lunchrooms or eating areas
are to be made available to workers exposed to lead above the
PEL. Your employer must assure that except in these facilities,
food and beverage is not present or consumed, tobacco products
are not present or used, and cosmetics are not applied, where
airborne exposures are above the PEL. Change rooms provided
by your employer must be equipped with separate storage facilities
for your protective clothing and equipment and street clothes
to avoid cross-contamination. After showering, no required protective
clothing or equipment worn during the shift may be worn home.
It is important that contaminated clothing or equipment be removed
in change areas and not be worn home or you will extend your
exposure and expose your family since lead from your clothing
can accumulate in your house, car, etc.
Lunchrooms or eating areas may not be entered with protective
clothing or equipment unless surface dust has been removed by
vacuuming, downdraft booth, or other cleaning method. Finally,
workers exposed above the PEL must wash both their hands and
faces prior to eating, drinking, smoking or applying cosmetics.
All of the facilities and hygiene practices just discussed
are essential to minimize additional sources of lead absorption
from inhalation or ingestion of lead that may accumulate on
you, your clothes, or your possessions. Strict compliance with
these provisions can virtually eliminate several sources of
lead exposure which significantly contribute to excessive lead
absorption.
The medical surveillance program is part of the standard's
comprehensive approach to the prevention of lead-related disease.
Its purpose is to supplement the main thrust of the standard
which is aimed at minimizing airborne concentrations of lead
and sources of ingestion. Only medical surveillance can determine
if the other provisions of the standard have affectively protected
you as an individual. Compliance with the standard's provision
will protect most workers from the adverse effects of lead exposure,
but may not be satisfactory to protect individual workers:
Who have high body burdens of lead acquired over past
years,
Who have additional uncontrolled sources of nonoccupational
lead exposure,
Who exhibit unusual variations in lead absorption rates,
or
Who have specific nonwork related medical conditions which
could be aggravated by lead exposure (e.g., renal disease,
anemia).
In addition, control systems may fail, or hygiene and respirator
programs may be inadequate. Periodic medical surveillance of
individual workers will help detect those failures. Medical
surveillance will also be important to protect your reproductive
ability-regardless of whether you are a man or woman.
All medical surveillance required by the standard must be performed
by or under the supervision of a licensed physician. The employer
must provide required medical surveillance without cost to employees
and at a reasonable time and place. The standard's medical surveillance
program has two parts-periodic biological monitoring and medical
examinations. Your employer's obligation to offer you medical
surveillance is triggered by the results of the air monitoring
program. Full medical surveillance must be made available to
all employees who are or may be exposed to lead in excess of
the action level for more than 30 days a year and whose blood
lead level exceeds 40 µg/dl. Initial medical surveillance consisting
of blood sampling and analysis for lead and zinc protoporphyrin
must be provided to all employees exposed at any time (1 day)
above the action level.
Biological monitoring under the standard must be provided at
least every 2 months for the first 6 months and every 6 months
thereafter until your blood lead level is below 40 µg/dl. A
zinc protoporphyrin (ZPP) test is a very useful blood test which
measures an adverse metabolic effect of lead on your body and
is therefore an indicator of lead toxicity.
If your BLL exceeds 40 µg/dl the monitoring frequency must
be increased from every 6 months to at least every 2 months
and not reduced until two consecutive BLLs indicate a blood
lead level below 40 µg/dl. Each time your BLL is determined
to be over 40 µg/dl, your employer must notify you of this in
writing within five working days of their receipt of the test
results. The employer must also inform you that the standard
requires temporary medical removal with economic protection
when your BLL exceeds 50 µg/dl. (See Discussion of medical removal
protection-WAC 296-155-17623.)
Anytime your BLL exceeds 50 µg/dl your employer must make available
to you within two weeks of receipt of these test results a second
follow-up BLL test to confirm your BLL. If the two tests both
exceed 50µg/dl, and you are temporarily removed, then your employer
must make successive BLL tests available to you on a monthly
basis during the period of your removal.
Medical examinations beyond the initial one must be made available
on an annual basis if your blood lead level exceeds 40 µg/dl
at any time during the preceding year and you are being exposed
above the airborne action level of 30 µg/m3 for
30 or more days per year. The initial examination will provide
information to establish a baseline to which subsequent data
can be compared.
An initial medical examination to consist of blood sampling
and analysis for lead and zinc protoporphyrin must also be made
available (prior to assignment) for each employee being assigned
for the first time to an area where the airborne concentration
of lead equals or exceeds the action level at any time. In addition,
a medical examination or consultation must be made available
as soon as possible if you notify your employer that you are
experiencing signs or symptoms commonly associated with lead
poisoning or that you have difficulty breathing while wearing
a respirator or during a respirator fit test. You must also
be provided a medical examination or consultation if you notify
your employer that you desire medical advice concerning the
effects of current or past exposure to lead on your ability
to procreate a healthy child.
Finally, appropriate follow-up medical examinations or consultations
may also be provided for employees who have been temporarily
removed from exposure under the medical removal protection provisions
of the standard. (See subsection (9), below.)
The standard specifies the minimum content of pre-assignment
and annual medical examinations. The content of other types
of medical examinations and consultations is left up to the
sound discretion of the examining physician. Preassignment and
annual medical examinations must include:
A detailed work history and medical history;
A thorough physical examination, including an evaluation
of your pulmonary status if you will be required to use
a respirator;
A blood pressure measurement; and
A series of laboratory tests designed to check your blood
chemistry and your kidney function.
In addition, at any time upon your request, a laboratory
evaluation of male fertility will be made (microscopic examination
of a sperm sample), or a pregnancy test will be given.
The standard does not require that you participate in any
of the medical procedures, tests, etc. which your employer
is required to make available to you. Medical surveillance
can, however, play a very important role in protecting your
health. You are strongly encouraged, therefore, to participate
in a meaningful fashion. The standard contains a multiple
physician review mechanism which will give you a chance
to have a physician of your choice directly participate
in the medical surveillance program. If you are dissatisfied
with an examination by a physician chosen by your employer,
you can select a second physician to conduct an independent
analysis. The two doctors would attempt to resolve any differences
of opinion, and select a third physician to resolve any
firm dispute. Generally your employer will choose the physician
who conducts medical surveillance under the lead standard-unless
you and your employer can agree on the choice of a physician
or physicians. Some companies and unions have agreed in
advance, for example, to use certain independent medical
laboratories or panels of physicians. Any of these arrangements
are acceptable so long as required medical surveillance
is made available to workers.
The standard requires your employer to provide certain
information to a physician to aid in their examination of
you. This information includes:
The standard and its appendices,
A description of your duties as they relate to occupational
lead exposure,
Your exposure level or anticipated exposure level,
A description of any personal protective equipment
you wear,
Prior blood lead level results, and
Prior written medical opinions concerning you that
the employer has.
After a medical examination or consultation the physician
must prepare a written report which must contain:
The physician's opinion as to whether you have any
medical condition which places you at increased risk
of material impairment to health from exposure to lead,
Any recommended special protective measures to be
provided to you,
Any blood lead level determinations, and
Any recommended limitation on your use of respirator.
This last element must include a determination of whether
you can wear a powered air purifying respirator (PAPR) if
you are found unable to wear a negative pressure respirator.
The medical surveillance program of the lead standard may
at some point in time serve to notify certain workers that
they have acquired a disease or other adverse medical condition
as a result of occupational lead exposure. If this is true,
these workers might have legal rights to compensation from
public agencies, their employers, firms that supply hazardous
products to their employers, or other persons. Some states
have laws, including worker compensation laws, that disallow
a worker who learns of a job-related health impairment to
sue, unless the worker sues within a short period of time
after learning of the impairment. (This period of time may
be a matter of months or years.) An attorney can be consulted
about these possibilities. It should be stressed that WISHA
is in no way trying to either encourage or discourage claims
or lawsuits. However, since results of the standard's medical
surveillance program can significantly affect the legal
remedies of a worker who has acquired a job-related disease
or impairment, it is proper for WISHA to make you aware
of this.
The medical surveillance section of the standard also contains
provisions dealing with chelation. Chelation is the use
of certain drugs (administered in pill form or injected
into the body) to reduce the amount of lead absorbed in
body tissues. Experience accumulated by the medical and
scientific communities has largely confirmed the effectiveness
of this type of therapy for the treatment of very severe
lead poisoning. On the other hand, it has also been established
that there can be a long list of extremely harmful side
effects associated with the use of chelating agents. The
medical community has balanced the advantages and disadvantages
resulting from the use of chelating agents in various circumstances
and has established when the use of these agents is acceptable.
The standard includes these accepted limitations due to
a history of abuse of chelation therapy by some lead companies.
The most widely used chelating agents are calcium disodium
EDTA, (Ca Na2 EDTA), Calcium Disodium Versenate (Versenate),
and d-penicillamine (penicillamine or Cupramine).
The standard prohibits “prophylactic chelation”
of any employee by any person the employer retains, supervises
or controls. “Prophylactic chelation” is the
routine use of chelating or similarly acting drugs to prevent
elevated blood levels in workers who are occupationally
exposed to lead, or the use of these drugs to routinely
lower blood lead levels to predesignated concentrations
believed to be “safe”. It should be emphasized
that where an employer takes a worker who has no symptoms
of lead poisoning and has chelation carried out by a physician
(either inside or outside of a hospital) solely to reduce
the worker's blood lead level, that will generally be considered
prophylactic chelation. The use of a hospital and a physician
does not mean that prophylactic chelation is not being performed.
Routine chelation to prevent increased or reduce current
blood lead levels is unacceptable whatever the setting.
The standard allows the use of “therapeutic”
or “diagnostic” chelation if administered under
the supervision of a licensed physician in a clinical setting
with thorough and appropriate medical monitoring. Therapeutic
chelation responds to severe lead poisoning where there
are marked symptoms. Diagnostic chelation involved giving
a patient a dose of the drug then collecting all urine excreted
for some period of time as an aid to the diagnosis of lead
poisoning.
In cases where the examining physician determines that
chelation is appropriate, you must be notified in writing
of this fact before such treatment. This will inform you
of a potentially harmful treatment, and allow you to obtain
a second opinion.
Excessive lead absorption subjects you to increased risk
of disease. Medical removal protection (MRP) is a means
of protecting you when, for whatever reasons, other methods,
such as engineering controls, work practices, and respirator,
have failed to provide the protection you need. MRP involves
the temporary removal of a worker from their regular job
to a place of significantly lower exposure without any loss
of earnings, seniority, or other employment rights or benefits.
The purpose of this program is to cease further lead absorption
and allow your body to naturally excrete lead which has
previously been absorbed. Temporary medical removal can
result from an elevated blood lead level, or a medical opinion.
For up to 18 months, or for as long as the job the employee
was removed from lasts, protection is provided as a result
of either form of removal. The vast majority of removed
workers, however, will return to their former jobs long
before this eighteen month period expires.
You may also be removed from exposure even if your blood
lead level is below 50 µg/dl if a final medical determination
indicates that you temporarily need reduced lead exposure
for medical reasons. If the physician who is implementing
your employers medical program makes a final written opinion
recommending your removal or other special protective measures,
your employer must implement the physician's recommendation.
If you are removed in this manner, you may only be returned
when the doctor indicates that it is safe for you to do
so.
The standard does not give specific instructions dealing
with what an employer must do with a removed worker. Your
job assignment upon removal is a matter for you, your employer
and your union (if any) to work out consistent with existing
procedures for job assignments. Each removal must be accomplished
in a manner consistent with existing collective bargaining
relationships. Your employer is given broad discretion to
implement temporary removals so long as no attempt is made
to override existing agreements. Similarly, a removed worker
is provided no right to veto an employer's choice which
satisfies the standard.
In most cases, employers will likely transfer removed employees
to other jobs with sufficiently low lead exposure. Alternatively,
a worker's hours may be reduced so that the time weighted
average exposure is reduced, or they may be temporarily
laid off if no other alternative is feasible.
In all of these situation, MRP benefits must be provided
during the period of removal-i.e., you continue to receive
the same earnings, seniority, and other rights and benefits
you would have had if you had not been removed. Earnings
includes more than just your base wage; it includes overtime,
shift differentials, incentives, and other compensation
you would have earned if you had not been removed. During
the period of removal you must also be provided with appropriate
follow-up medical surveillance. If you were removed because
your blood lead level was too high, you must be provided
with a monthly blood test. If a medical opinion caused your
removal, you must be provided medical tests or examinations
that the doctor believes to be appropriate. If you do not
participate in this follow up medical surveillance, you
may lose your eligibility for MRP benefits.
When you are medically eligible to return to your former
job, your employer must return you to your “former
job status.” This means that you are entitled to the
position, wages, benefits, etc., you would have had if you
had not been removed. If you would still be in your old
job if no removal had occurred that is where you go back.
If not, you are returned consistent with whatever job assignment
discretion your employer would have had if no removal had
occurred. MRP only seeks to maintain your rights, not expand
them or diminish them.
If you are removed under MRP and you are also eligible
for worker compensation or other compensation for lost wages,
your employer's MRP benefits obligation is reduced by the
amount that you actually receive from these other sources.
This is also true if you obtain other employment during
the time you are laid off with MRP benefits.
The standard also covers situations where an employer voluntarily
removes a worker from exposure to lead due to the effects
of lead on the employee's medical condition, even though
the standard does not require removal. In these situations
MRP benefits must still be provided as though the standard
required removal. Finally, it is important to note that
in all cases where removal is required, respirator cannot
be used as a substitute. Respirator may be used before removal
becomes necessary, but not as an alternative to a transfer
to a low exposure job, or to a lay-off with MRP benefits.
Your employer is required to provide an information and
training program for all employees exposed to lead above
the action level or who may suffer skin or eye irritation
from lead compounds such as lead arsenate or lead azide.
The program must train these employees regarding the specific
hazards associated with their work environment, protective
measures which can be taken, including the contents of any
compliance plan in effect, the danger of lead to their bodies
(including their reproductive systems), and their rights
under the standard. All employees must be trained prior
to initial assignment to areas where there is a possibility
of exposure over the action level.
This training program must also be provided at least annually
thereafter unless further exposure above the action level
will not occur.
Your employer is required to keep all records of exposure
monitoring for airborne lead. These records must include
the name and job classification of employees measured, details
of the sampling and analytical techniques, the results of
this sampling, and the type of respiratory protection being
worn by the person sampled. Such records are to be retained
for at least 30 years. Your employer is also required to
keep all records of biological monitoring and medical examination
results. These records must include the names of the employees,
the physician's written opinion, and a copy of the results
of the examination. Medical records must be preserved and
maintained for the duration of employment plus 30 years.
However, if the employee's duration of employment is less
than one year, the employer need not retain that employee's
medical records beyond the period of employment if they
are provided to the employee upon termination of employment.
Recordkeeping is also required if you are temporarily removed
from your job under the medical removal protection program.
This record must include your name and Social Security number,
the date of your removal and return, how the removal was
or is being accomplished, and whether or not the reason
for the removal was an elevated blood lead level. Your employer
is required to keep each medical removal record only for
as long as the duration of an employee's employment.
The standard requires that if you request to see or copy
environmental monitoring, blood lead level monitoring, or
medical removal records, they must be made available to
you or to a representative that you authorize. Your union
also has access to these records. Medical records other
than BLL's must also be provided upon request to you, to
your physician or to any other person whom you may specifically
designate. Your union does not have access to your personal
medical records unless you authorize their access.
When air monitoring for lead is performed at your workplace
as required by this standard, your employer must allow you
or someone you designate to act as an observer of the monitoring.
Observers are entitled to an explanation of the measurement
procedure, and to record the results obtained. Since results
will not normally be available at the time of the monitoring,
observers are entitled to record or receive the results
of the monitoring when returned by the laboratory. Your
employer is required to provide the observer with any personal
protective devices required to be worn by employees working
in the area that is being monitored. The employer must require
the observer to wear all such equipment and to comply with
all other applicable safety and health procedures.
(14) Startup date-WAC 296-155-17635.
Employer obligations under the standard begin as of that
date with full implementation of engineering controls as
soon as possible but no later than within 4 months, and
all other provisions completed as soon as possible, but
no later than within 2 months from the effective date.
(15) For additional information.
(a) A copy of the standard for lead in construction can be
obtained free of charge by calling or writing to the department
of labor and industries, Post Office Box 44620, Mailstop 44620,
Olympia, Washington 98504-4620: Telephone (360) 956-5527.
(b) Additional information about the standard, its enforcement,
and your employer's compliance can be obtained from the nearest
office listed in your telephone directory under the state
of Washington, department of labor and industries.
WAC
296-155-17654 Appendix C to WAC 296-155-176-Medical surveillance
guidelines.
(1) Introduction.
The primary purpose of the Washington Industrial Safety
and Health Act of 1973 is to assure, so far as possible,
safe and healthful working conditions for every working
man and woman. The occupational health standard for lead
in construction is designed to protect workers exposed to
inorganic lead including metallic lead, all inorganic lead
compounds and organic lead soaps.
Under this standard occupational exposure to inorganic
lead is to be limited to 50 µg/m3 (micrograms
per cubic meter) based on an 8 hour time-weighted average
(TWA). This permissible exposure limit (PEL) must be achieved
through a combination of engineering, work practice and
administrative controls to the extent feasible. Where these
controls are in place but are found not to reduce employee
exposures to or below the PEL, they must be used nonetheless,
and supplemented with respirators to meet the 50 µg/m3
exposure limit.
The standard also provides for a program of biological
monitoring for employees exposed to lead above the action
level at any time, and additional medical surveillance for
all employees exposed to levels of inorganic lead above
30 µg/m3 (TWA) for more than 30 days per year
and whose BLL exceeds 40 µg/dl.
The purpose of this document is to outline the medical
surveillance provisions of the standard for inorganic lead
in construction, and to provide further information to the
physician regarding the examination and evaluation of workers
exposed to inorganic lead.
Subsection (2) provides a detailed description of the monitoring
procedure including the required frequency of blood testing
for exposed workers, provisions for medical removal protection
(MRP), the recommended right of the employee to a second
medical opinion, and notification and recordkeeping requirements
of the employer. A discussion of the requirements for respirator
use and respirator monitoring and WISHA's position on prophylactic
chelation therapy are also included in this subsection.
Subsection (3) discusses the toxic effects and clinical
manifestations of lead poisoning and effects of lead intoxication
on enzymatic pathways in heme synthesis. The adverse effects
on both male and female reproductive capacity and on the
fetus are also discussed.
Subsection (4) outlines the recommended medical evaluation
of the worker exposed to inorganic lead, including details
of the medical history, physical examination, and recommended
laboratory tests, which are based on the toxic effects of
lead as discussed in subsection (3).
Subsection (5) provides detailed information concerning
the laboratory tests available for the monitoring of exposed
workers. Included also is a discussion of the relative value
of each test and the limitations and precautions which are
necessary in the interpretation of the laboratory results.
(2) Medical surveillance and monitoring requirements for
workers exposed to inorganic lead.
Under the standard for inorganic lead in the construction
industry, initial medical surveillance consisting of biological
monitoring to include blood lead and ZPP level determination
shall be provided to employees exposed to lead at or above
the action level on any one day. In addition, a program
of biological monitoring is to be made available to all
employees exposed above the action level at any time and
additional medical surveillance is to be made available
to all employees exposed to lead above 30 µg/m3
TWA for more than 30 days each year and whose BLL exceeds
40 µg/dl. This program consists of periodic blood sampling
and medical evaluation to be performed on a schedule which
is defined by previous laboratory results, worker complaints
or concerns, and the clinical assessment of the examining
physician.
Under this program, the blood lead level (BLL) of all employees
who are exposed to lead above 30 µg/m3 for more
than 30 days per year or whose blood lead is above 40 µg/dl
but exposed for no more than 30 days per year is to be determined
at least every two months for the first six months of exposure
and every six months thereafter. The frequency is increased
to every two months for employees whose last blood lead
level was 40 µg/dl or above. For employees who are removed
from exposure to lead due to an elevated blood lead, a new
blood lead level must be measured monthly. A zinc protoporphyrin
(ZPP) measurement is strongly recommended on each occasion
that a blood lead level measurement is made.
An annual medical examination and consultation performed
under the guidelines discussed in subsection (4) is to be
made available to each employee exposed above 30 µg/m3
for more than 30 days per year for whom a blood test conducted
at any time during the preceding 12 months indicated a blood
lead level at or above 40 µg/dl. Also, an examination is
to be given to all employees prior to their assignment to
an area in which airborne lead concentrations reach or exceed
the 30 µg/m3 for more than 30 days per year.
In addition, a medical examination must be provided as soon
as possible after notification by an employee that the employee
has developed signs or symptoms commonly associated with
lead intoxication, that the employee desires medical advice
regarding lead exposure and the ability to procreate a healthy
child, or that the employee has demonstrated difficulty
in breathing during a respirator fitting test or during
respirator use. An examination is also to be made available
to each employee removed from exposure to lead due to a
risk of sustaining material impairment to health, or otherwise
limited or specially protected pursuant to medical recommendations.
Results of biological monitoring or the recommendations
of an examining physician may necessitate removal of an
employee from further lead exposure pursuant to the standard's
medical removal protection (MRP) program. The object of
the MRP program is to provide temporary medical removal
to workers either with substantially elevated blood lead
levels or otherwise at risk of sustaining material health
impairment from continued substantial exposure to lead.
Under the standard's ultimate worker removal criteria,
a worker is to be removed from any work having an eight
hour TWA exposure to lead of 30 µg/m3 when their
blood lead level reaches 50 µg/dl and is confirmed by a
second follow-up blood lead level performed within two weeks
after the employer receives the results of the first blood
sampling test. Return of the employee to their job status
depends on a worker's blood lead level declining to 40 µg/dl.
As part of the standard, the employer is required to notify
in writing each employee whose blood lead level exceeds
40 µg/dl. In addition each such employee is to be informed
that the standard requires medical removal with MRP benefits,
discussed below, when an employee's blood lead level exceeds
the above defined limit.
In addition to the above blood lead level criterion, temporary
worker removal may also take place as a result of medical
determinations and recommendations. Written medical opinions
must be prepared after each examination pursuant to the
standard. If the examining physician includes a medical
finding, determination or opinion that the employee has
a medical condition which places the employee at increased
risk of material health impairment from exposure to lead,
then the employee must be removed from exposure to lead
at or above 30 µg/m3. Alternatively, if the examining
physician recommends special protective measures for an
employee (e.g., use of a powered air purifying respirator)
or recommends limitations on an employee's exposure to lead,
then the employer must implement these recommendations.
Recommendations may be more stringent than the specific
provisions of the standard. The examining physician, therefore,
is given broad flexibility to tailor special protective
procedures to the needs of individual employees. This flexibility
extends to the evaluation and management of pregnant workers
and male and female workers who are planning to raise children.
Based on the history, physical examination, and laboratory
studies, the physician might recommend special protective
measures or medical removal for an employee who is pregnant
or who is planning to conceive a child when, in the physician's
judgment, continued exposure to lead at the current job
would pose a significant risk. The return of the employee
to their former job status, or the removal of special protections
or limitations, depends upon the examining physician determining
that the employee is no longer at increased risk of material
impairment or that special measures are no longer needed.
During the period of any form of special protection or
removal, the employer must maintain the worker's earnings,
seniority, and other employment rights and benefits (as
though the worker had not been removed) for a period of
up to 18 months or for as long as the job the employee was
removed from lasts if less than 18 months. This economic
protection will maximize meaningful worker participation
in the medical surveillance program, and is appropriate
as part of the employer's overall obligation to provide
a safe and healthful workplace. The provisions of MRP benefits
during the employee's removal period may, however, be conditioned
upon participation in medical surveillance.
The lead standard provides for a multiple physician review
in cases where the employee wishes a second opinion concerning
potential lead poisoning or toxicity. If an employee wishes
a second opinion, they can make an appointment with a physician
of their choice. This second physician will review the findings,
recommendations or determinations of the first physician
and conduct any examinations, consultations or tests deemed
necessary in an attempt to make a final medical determination.
If the first and second physicians do not agree in their
assessment they must try to resolve their differences. If
they cannot reach an agreement then they must designate
a third physician to resolve the dispute.
The employer must provide examining and consulting physicians
with the following specific information: A copy of the lead
regulations and all appendices, a description of the employee's
duties as related to exposure, the exposure level or anticipated
level to lead and any other toxic substances (if applicable),
a description of personal protective equipment used, blood
lead levels, and all prior written medical opinions regarding
the employee in the employer's possession or control. The
employer must also obtain from the physician and provide
the employee with a written medical opinion containing blood
lead levels, the physician's opinion as to whether the employee
is at risk of material impairment to health, any recommended
protective measures for the employee if further exposure
is permitted, as well as any recommended limitations upon
an employee's use of respirators.
Employers must instruct each physician not to reveal to
the employer in writing or in any other way their findings,
laboratory results, or diagnoses which are felt to be unrelated
to occupational lead exposure. They must also instruct each
physician to advise the employee of any occupationally or
non-occupationally related medical condition requiring further
treatment or evaluation.
The standard provides for the use of respirators where
engineering and other primary controls are not effective.
However, the use of respirator protection shall not be used
in lieu of temporary medical removal due to elevated blood
lead levels or findings that an employee is at risk of material
health impairment. This is based on the numerous inadequacies
of respirators including skin rash where the facepiece makes
contact with the skin, unacceptable stress to breathing
in some workers with underlying cardiopulmonary impairment,
difficulty in providing adequate fit, the tendency for respirators
to create additional hazards by interfering with vision,
hearing, and mobility, and the difficulties of assuring
the maximum effectiveness of a complicated work practice
program involving respirators. Respirators do, however,
serve a useful function where engineering and work practice
controls are inadequate by providing supplementary, interim,
or short-term protection, provided they are properly selected
for the environment in which the employee will be working,
properly fitted to the employee, maintained and cleaned
periodically, and worn by the employee when required.
In its standard on occupational exposure to inorganic lead
in the construction industry, WISHA has prohibited prophylactic
chelation. Diagnostic and therapeutic chelation are permitted
only under the supervision of a licensed physician with
appropriate medical monitoring in an acceptable clinical
setting.
The decision to initiate chelation therapy must be made
on an individual basis and take into account the severity
of symptoms felt to be a result of lead toxicity along with
blood lead levels, ZPP levels, and other laboratory tests
as appropriate. EDTA and penicillamine which are the primary
chelating agents used in the therapy of occupational lead
poisoning have significant potential side effects and their
use must be justified on the basis of expected benefits
to the worker. Unless frank and severe symptoms are present,
therapeutic chelation is not recommended, given the opportunity
to remove a worker from exposure and allow the body to naturally
excrete accumulated lead. As a diagnostic aid, the chelation
mobilization test using CA-EDTA has limited applicability.
According to some investigators, the test can differentiate
between lead-induced and other nephropathies. The test may
also provide an estimation of the mobile fraction of the
total body lead burden.
Employers are required to assure that accurate records
are maintained on exposure assessment, including environmental
monitoring, medical surveillance, and medical removal for
each employee. Exposure assessment records must be kept
for at least 30 years. Medical surveillance records must
be kept for the duration of employment plus 30 years except
in cases where the employment was less than one year. If
duration of employment is less than one year, the employer
need not retain this record beyond the term of employment
if the record is provided to the employee upon termination
of employment. Medical removal records also must be maintained
for the duration of employment. All records required under
the standard must be made available upon request to the
director. Employers must also make environmental and biological
monitoring and medical removal records available to affected
employees and to former employees or their authorized employee
representatives. Employees or their specifically designated
representatives have access to their entire medical surveillance
records.
In addition, the standard requires that the employer inform
all workers exposed to lead at or above 30 µg/m3
of the provisions of the standard and all its appendices,
the purpose and description of medical surveillance and
provisions for medical removal protection if temporary removal
is required. An understanding of the potential health effects
of lead exposure by all exposed employees along with full
understanding of their rights under the lead standard is
essential for an effective monitoring program.
(3) Adverse health effects of inorganic lead.
Although the toxicity of lead has been known for 2,000
years, the knowledge of the complex relationship between
lead exposure and human response is still being refined.
Significant research into the toxic properties of lead continues
throughout the world, and it should be anticipated that
our understanding of thresholds of effects and margins of
safety will be improved in future years. The provisions
of the lead standard are founded on two prime medical judgments:
First, the prevention of adverse health effects from exposure
to lead throughout a working lifetime requires that worker
blood lead levels be maintained at or below 40 µg/dl and
second, the blood lead levels of workers, male or female,
who intend to parent in the near future should be maintained
below 30 µg/dl to minimize adverse reproductive health effects
to the parents and developing fetus. The adverse effects
of lead on reproduction are being actively researched and
WISHA encourages the physician to remain abreast of recent
developments in the area to best advise pregnant workers
or workers planning to conceive children.
The spectrum of health effects caused by lead exposure
can be subdivided into five developmental stages: Normal,
physiological changes of uncertain significance, pathophysiological
changes, overt symptoms (morbidity), and mortality. Within
this process there are no sharp distinctions, but rather
a continuum of effects. Boundaries between categories overlap
due to the wide variation of individual responses and exposures
in the working population. WISHA's development of the lead
standard focused on pathophysiological changes as well as
later stages of disease.
(a) Heme synthesis inhibition. The earliest demonstrated
effect of lead involves its ability to inhibit at least
two enzymes of the heme synthesis pathway at very low
blood levels. Inhibition of delta aminolevulinic acid
dehydrase (ALA-D) which catalyzes the conversion of delta-aminolevulinic
acid (ALA) to protoporphyrin is observed at a blood lead
level below 20 µg/dl. At a blood lead level of 40 µg/dl,
more than 20% of the population would have 70% inhibition
of ALA-D. There is an exponential increase in ALA excretion
at blood lead levels greater than 40 µg/dl.
Another enzyme, ferrochelatase, is also inhibited at
low blood lead levels. Inhibition of ferrochelatase leads
to increased free erythrocyte protoporphyrin (FEP) in
the blood which can then bind to zinc to yield zinc protoporphyrin.
At a blood lead level of 50 µg/dl or greater, nearly 100%
of the population will have an increase in FEP. There
is also an exponential relationship between blood lead
levels greater than 40 µg/dl and the associated ZPP level,
which has led to the development of the ZPP screening
test for lead exposure.
While the significance of these effects is subject to
debate, it is WISHA's position that these enzyme disturbances
are early stages of a disease process which may eventually
result in the clinical symptoms of lead poisoning. Whether
or not the effects do progress to the later stages of
clinical disease, disruption of these enzyme processes
over a working lifetime is considered to be a material
impairment of health.
One of the eventual results of lead-induced inhibition
of enzymes in the heme synthesis pathway is anemia which
can be asymptomatic if mild but associated with a wide
array of symptoms including dizziness, fatigue, and tachycardia
when more severe. Studies have indicated that lead levels
as low as 50 µg/dl can be associated with a definite decreased
hemoglobin, although most cases of lead-induced anemia,
as well as shortened red-cell survival times, occur at
lead levels exceeding 80 µg/dl. Inhibited hemoglobin synthesis
is more common in chronic cases whereas shortened erythrocyte
life span is more common in acute cases.
In lead-induced anemias, there is usually a reticulocytosis
along with the presence of basophilic stippling, and ringed
sideroblasts, although none of the above are pathognomonic
for lead-induced anemia.
(b) Neurological effects. Inorganic lead has been found
to have toxic effects on both the central and peripheral
nervous systems. The earliest stages of lead-induced central
nervous system effects first manifest themselves in the
form of behavioral disturbances and central nervous system
symptoms including irritability, restlessness, insomnia
and other sleep disturbances, fatigue, vertigo, headache,
poor memory, tremor, depression, and apathy. With more
severe exposure, symptoms can progress to drowsiness,
stupor, hallucinations, delirium, convulsions and coma.
The most severe and acute form of lead poisoning which
usually follows ingestion or inhalation of large amounts
of lead is acute encephalopathy which may arise precipitously
with the onset of intractable seizures, coma, cardiorespiratory
arrest, and death within 48 hours.
While there is disagreement about what exposure levels
are needed to produce the earliest symptoms, most experts
agree that symptoms definitely can occur at blood lead
levels of 60 µg/dl whole blood and therefore recommend
a 40 µg/dl maximum. The central nervous system effects
frequently are not reversible following discontinued exposure
or chelation therapy and when improvement does occur,
it is almost always only partial.
The peripheral neuropathy resulting from lead exposure
characteristically involves only motor function with minimal
sensory damage and has a marked predilection for the extensor
muscles of the most active extremity. The peripheral neuropathy
can occur with varying degrees of severity. The earliest
and mildest form which can be detected in workers with
blood lead levels as low as 50 µg/dl is manifested by
slowing of motor nerve conduction velocity often without
clinical symptoms. With progression of the neuropathy
there is development of painless extensor muscle weakness
usually involving the extensor muscles of the fingers
and hand in the most active upper extremity, followed
in severe cases by wrist drop or, much less commonly,
foot drop.
In addition to slowing of nerve conduction, electromyographical
studies in patients with blood lead levels greater than
50 µg/dl have demonstrated a decrease in the number of
acting motor unit potentials, an increase in the duration
of motor unit potentials, and spontaneous pathological
activity including fibrillations and fasciculations. Whether
these effects occur at levels of 40 µg/dl is undetermined.
While the peripheral neuropathies can occasionally be
reversed with therapy, again such recovery is not assured
particularly in the more severe neuropathies and often
improvement is only partial. The lack of reversibility
is felt to be due in part to segmental demyelination.
(c) Gastrointestinal. Lead may also affect the gastrointestinal
system producing abdominal colic or diffuse abdominal
pain, constipation, obstipation, diarrhea, anorexia, nausea
and vomiting. Lead colic rarely develops at blood lead
levels below 80 µg/dl.
(d) Renal. Renal toxicity represents one of the most
serious health effects of lead poisoning. In the early
stages of disease nuclear inclusion bodies can frequently
be identified in proximal renal tubular cells. Renal function
remains normal and the changes in this stage are probably
reversible. With more advanced disease there is progressive
interstitial fibrosis and impaired renal function. Eventually
extensive interstitial fibrosis ensues with sclerotic
glomeruli and dilated and atrophied proximal tubules;
all represent end stage kidney disease. Azotemia can be
progressive, eventually resulting in frank uremia necessitating
dialysis. There is occasionally associated hypertension
and hyperuricemia with or without gout.
Early kidney disease is difficult to detect. The urinalysis
is normal in early lead nephropathy and the blood urea
nitrogen and serum creatinine increase only when two-thirds
of kidney function is lost. Measurement of creatinine
clearance can often detect earlier disease as can other
methods of measurement of glomerular filtration rate.
An abnormal Ca-EDTA mobilization test has been used to
differentiate between lead-induced and other nephropathies,
but this procedure is not widely accepted. A form of Fanconi
syndrome with aminoaciduria, glycosuria, and hyperphosphaturia
indicating severe injury to the proximal renal tubules
is occasionally seen in children.
(e) Reproductive effects. Exposure to lead can have serious
effects on reproductive function in both males and females.
In male workers exposed to lead there can be a decrease
in sexual drive, impotence, decreased ability to produce
healthy sperm, and sterility. Malformed sperm (teratospermia),
decreased number of sperm (hypospermia), and sperm with
decreased motility (asthenospermia) can all occur. Teratospermia
has been noted at mean blood lead levels of 53 µg/dl and
hypospermia and asthenospermia at 41 µg/dl. Furthermore,
there appears to be a dose-response relationship for teratospermia
in lead exposed workers.
Women exposed to lead may experience menstrual disturbances
including dysmenorrhea, menorrhagia and amenorrhea. Following
exposure to lead, women have a higher frequency of sterility,
premature births, spontaneous miscarriages, and stillbirths.
Germ cells can be affected by lead and cause genetic
damage in the egg or sperm cells before conception and
result in failure to implant, miscarriage, stillbirth,
or birth defects.
Infants of mothers with lead poisoning have a higher
mortality during the first year and suffer from lowered
birth weights, slower growth, and nervous system disorders.
Lead can pass through the placental barrier and lead
levels in the mother's blood are comparable to concentrations
of lead in the umbilical cord at birth. Transplacental
passage becomes detectable at 12-14 weeks of gestation
and increases until birth.
There is little direct data on damage to the fetus from
exposure to lead but it is generally assumed that the
fetus and newborn would be at least as susceptible to
neurological damage as young children. Blood lead levels
of 50-60 µg/dl in children can cause significant neurobehavioral
impairments and there is evidence of hyperactivity at
blood levels as low as 25 µg/dl. Given the overall body
of literature concerning the adverse health effects of
lead in children, WISHA feels that the blood lead level
in children should be maintained below 30 µg/dl with a
population mean of 15 µg/dl. Blood lead levels in the
fetus and newborn likewise should not exceed 30 µg/dl.
Because of lead's ability to pass through the placental
barrier and also because of the demonstrated adverse effects
of lead on reproductive function in both the male and
female as well as the risk of genetic damage of lead on
both the ovum and sperm, WISHA recommends a 30 µg/dl maximum
permissible blood lead level in both males and females
who wish to bear children.
(f) Other toxic effects. Debate and research continue
on the effects of lead on the human body. Hypertension
has frequently been noted in occupationally exposed individuals
although it is difficult to assess whether this is due
to lead's adverse effects on the kidney or if some other
mechanism is involved. Vascular and electrocardiographic
changes have been detected but have not been well characterized.
Lead is thought to impair thyroid function and interfere
with the pituitary-adrenal axis, but again these effects
have not been well defined.
(4) Medical evaluation.
The most important principle in evaluating a worker for
any occupational disease including lead poisoning is a
high index of suspicion on the part of the examining physician.
As discussed in section (3), lead can affect numerous
organ systems and produce a wide array of signs and symptoms,
most of which are non-specific and subtle in nature at
least in the early stages of disease. Unless serious concern
for lead toxicity is present, many of the early clues
to diagnosis may easily be overlooked.
The crucial initial step in the medical evaluation is
recognizing that a worker's employment can result in exposure
to lead. The worker will frequently be able to define
exposures to lead and lead containing materials but often
will not volunteer this information unless specifically
asked. In other situations the worker may not know of
any exposures to lead but the suspicion might be raised
on the part of the physician because of the industry or
occupation of the worker. Potential occupational exposure
to lead and its compounds occur in many occupations in
the construction industry, including demolition and salvaging
operations, removal or encapsulation of materials containing
lead, construction, alteration, repair or renovation of
structures containing lead, transportation, disposal,
storage or containment of lead or lead-containing materials
on construction sites, and maintenance operations associated
with construction activities.
Once the possibility for lead exposure is raised, the
focus can then be directed toward eliciting information
from the medical history, physical exam, and finally from
laboratory data to evaluate the worker for potential lead
toxicity.
A complete and detailed work history is important in
the initial evaluation. A listing of all previous employment
with information on job description, exposure to fumes
or dust, known exposures to lead or other toxic substances,
a description of any personal protective equipment used,
and previous medical surveillance should all be included
in the worker's record. Where exposure to lead is suspected,
information concerning on-the-job personal hygiene, smoking
or eating habits in work areas, laundry procedures, and
use of any protective clothing or respiratory protection
equipment should be noted. A complete work history is
essential in the medical evaluation of a worker with suspected
lead toxicity, especially when long term effects such
as neurotoxicity and nephrotoxicity are considered.
The medical history is also of fundamental importance
and should include a listing of all past and current medical
conditions, current medications including proprietary
drug intake, previous surgeries and hospitalizations,
allergies, smoking history, alcohol consumption, and also
non-occupational lead exposures such as hobbies (hunting,
riflery). Also known childhood exposures should be elicited.
Any previous history of hematological, neurological, gastrointestinal,
renal, psychological, gynecological, genetic, or reproductive
problems should be specifically noted.
A careful and complete review of systems must be performed
to assess both recognized complaints and subtle or slowly
acquired symptoms which the worker might not appreciate
as being significant. The review of symptoms should include
the following:
General-weight loss, fatigue, decreased appetite.
Head, eyes, ears, nose, throat (HEENT)-headaches,
visual disturbances or decreased visual acuity, hearing
deficits or tinnitus, pigmentation of the oral mucosa,
or metallic taste in mouth.
Cardio-pulmonary-shortness of breath, cough, chest
pains, palpitations, or orthopnea.
Gastrointestinal-nausea, vomiting, heartburn, abdominal
pain, constipation or diarrhea.
Neurologic-irritability, insomnia, weakness (fatigue),
dizziness, loss of memory, confusion, hallucinations,
incoordination, ataxia, decreased strength in hands
or feet, disturbances in gait, difficulty in climbing
stairs, or seizures.
Reproductive (male and female and spouse where relevant)-history
of infertility, impotence, loss of libido, abnormal
menstrual periods, history of miscarriages, stillbirths,
or children with birth defects.
Musculo-skeletal-muscle and joint pains.
The physical examination should emphasize the neurological,
gastrointestinal, and cardiovascular systems. The worker's
weight and blood pressure should be recorded and the oral
mucosa checked for pigmentation characteristic of a possible
Burtonian or lead line on the gingiva. It should be noted,
however, that the lead line may not be present even in
severe lead poisoning if good oral hygiene is practiced.
The presence of pallor on skin examination may indicate
an anemia which, if severe, might also be associated with
a tachycardia. If an anemia is suspected, an active search
for blood loss should be undertaken including potential
blood loss through the gastrointestinal tract.
A complete neurological examination should include an
adequate mental status evaluation including a search for
behavioral and psychological disturbances, memory testing,
evaluation for irritability, insomnia, hallucinations,
and mental clouding. Gait and coordination should be examined
along with close observation for tremor. A detailed evaluation
of peripheral nerve function including careful sensory
and motor function testing is warranted. Strength testing
particularly of extensor muscle groups of all extremities
is of fundamental importance.
Cranial nerve evaluation should also be included in the
routine examination.
The abdominal examination should include auscultation
for bowel sounds and abdominal bruits and palpation for
organomegaly, masses, and diffuse abdominal tenderness.
Cardiovascular examination should evaluate possible early
signs of congestive heart failure. Pulmonary status should
be addressed particularly if respirator protection is
contemplated.
As part of the medical evaluation, the lead standard
requires the following laboratory studies:
Blood lead level.
Hemoglobin and hematocrit determinations, red cell
indices, and examination of the peripheral blood smear
to evaluate red blood cell morphology.
Blood urea nitrogen.
Serum creatinine.
Routine urinalysis with microscopic examination.
A zinc protoporphyrin level.
In addition to the above, the physician is authorized
to order any further laboratory or other tests which they
deem necessary in accordance with sound medical practice.
The evaluation must also include pregnancy testing or
laboratory evaluation of male fertility if requested by
the employee. Additional tests which are probably not
warranted on a routine basis but may be appropriate when
blood lead and ZPP levels are equivocal include delta
aminolevulinic acid and coproporphyrin concentrations
in the urine, and dark-field illumination for detection
of basophilic stippling in red blood cells.
If an anemia is detected further studies including a
careful examination of the peripheral smear, reticulocyte
count, stool for occult blood, serum iron, total iron
binding capacity, bilirubin, and, if appropriate, vitamin
B12 and folate may be of value in attempting to identify
the cause of the anemia.
If a peripheral neuropathy is suspected, nerve conduction
studies are warranted both for diagnosis and as a basis
to monitor any therapy.
If renal disease is questioned, a 24 hour urine collection
for creatinine clearance, protein, and electrolytes may
be indicated. Elevated uric acid levels may result from
lead-induced renal disease and a serum uric acid level
might be performed.
An electrocardiogram and chest x-ray may be obtained
as deemed appropriate.
Sophisticated and highly specialized testing should not
be done routinely and where indicated should be under
the direction of a specialist.
(5) Laboratory evaluation.
The blood lead level at present remains the single most
important test to monitor lead exposure and is the test
used in the medical surveillance program under the lead
standard to guide employee medical removal. The ZPP has
several advantages over the blood lead level. Because
of its relatively recent development and the lack of extensive
data concerning its interpretation, the ZPP currently
remains an ancillary test.
This section will discuss the blood lead level and ZPP
in detail and will outline their relative advantages and
disadvantages. Other blood tests currently available to
evaluate lead exposure will also be reviewed.
The blood lead level is a good index of current or recent
lead absorption when there is no anemia present and when
the worker has not taken any chelating agents. However,
blood lead levels along with urinary lead levels do not
necessarily indicate the total body burden of lead and
are not adequate measures of past exposure. One reason
for this is that lead has a high affinity for bone and
up to 90% of the body's total lead is deposited there.
A very important component of the total lead body burden
is lead in soft tissue (liver, kidney, and brain). This
fraction of the lead body burden, the biologically active
lead, is not entirely reflected by blood lead levels since
it is a function of the dynamics of lead absorption, distribution,
deposition in bone and excretion. Following discontinuation
of exposure to lead, the excess body burden is only slowly
mobilized from bone and other relatively stable body stores
and excreted. Consequently, a high blood lead level may
only represent recent heavy exposure to lead without a
significant total body excess and likewise a low blood
lead level does not exclude an elevated total body burden
of lead.
Also due to its correlation with recent exposures, the
blood lead level may vary considerably over short time
intervals.
To minimize laboratory error and erroneous results due
to contamination, blood specimens must be carefully collected
after thorough cleaning of the skin with appropriate methods
using lead-free blood containers and analyzed by a reliable
laboratory. Under the standard, samples must be analyzed
in laboratories which are approved by OSHA. Analysis is
to be made using atomic absorption spectrophotometry,
anodic stripping voltammetry or any method which meets
the accuracy requirements set forth by the standard.
The determination of lead in urine is generally considered
a less reliable monitoring technique than analysis of
whole blood primarily due to individual variability in
urinary excretion capacity as well as the technical difficulty
of obtaining accurate 24 hour urine collections. In addition,
workers with renal insufficiency, whether due to lead
or some other cause, may have decreased lead clearance
and consequently urine lead levels may underestimate the
true lead burden. Therefore, urine lead levels should
not be used as a routine test.
The zinc protoporphyrin test, unlike the blood lead determination,
measures an adverse metabolic effect of lead and as such
is a better indicator of lead toxicity than the level
of blood lead itself. The level of ZPP reflects lead absorption
over the preceding 3 to 4 months, and therefore is a better
indicator of lead body burden. The ZPP requires more time
than the blood lead to read significantly elevated levels;
the return to normal after discontinuing lead exposure
is also slower. Furthermore, the ZPP test is simpler,
faster, and less expensive to perform and no contamination
is possible. Many investigators believe it is the most
reliable means of monitoring chronic lead absorption.
Zinc protoporphyrin results from the inhibition of the
enzyme ferrochelatase which catalyzes the insertion of
an iron molecule into the protoporphyrin molecule, which
then becomes heme. If iron is not inserted into the molecule
then zinc, having a greater affinity for protoporphyrin,
takes the place of the iron, forming ZPP.
An elevation in the level of circulating ZPP may occur
at blood lead levels as low as 20-30 µg/dl in some workers.
Once the blood lead level has reached 40 µg/dl there is
more marked rise in the ZPP value from its normal range
of less than 100 µg/dl 100 ml. Increases in blood lead
levels beyond 40 µg/100 g are associated with exponential
increases in ZPP.
Whereas blood lead levels fluctuate over short time spans,
ZPP levels remain relatively stable. ZPP is measured directly
in red blood cells and is present for the cell's entire
120 day life-span. Therefore, the ZPP level in blood reflects
the average ZPP production over the previous 3-4 months
and consequently the average lead exposure during that
time interval.
It is recommended that a hematocrit be determined whenever
a confirmed ZPP of 50 µg/100 ml whole blood is obtained
to rule out a significant underlying anemia. If the ZPP
is in excess of 100 µg/100 ml and not associated with
abnormal elevations in blood lead levels, the laboratory
should be checked to be sure that blood leads were determined
using atomic absorption spectrophotometry anodic stripping
voltammetry, or any method which meets the accuracy requirements
set forth by the standard by an OSHA approved laboratory
which is experienced in lead level determinations. Repeat
periodic blood lead studies should be obtained in all
individuals with elevated ZPP levels to be certain that
an associated elevated blood lead level has not been missed
due to transient fluctuations in blood leads.
ZPP has a characteristic fluorescence spectrum with a
peak at 594 nm which is detectable with a hematofluorimeter.
The hematofluorimeter is accurate and portable and can
provide on-site, instantaneous results for workers who
can be frequently tested via a finger prick.
Careful attention must be given to calibration and quality
control procedures. Limited data on blood lead-ZPP correlations
and the ZPP levels which are associated with the adverse
health effects discussed in subsection (3) are the major
limitations of the test. Also it is difficult to correlate
ZPP levels with environmental exposure and there is some
variation of response with age and sex. Nevertheless,
the ZPP promises to be an important diagnostic test for
the early detection of lead toxicity and its value will
increase as more data is collected regarding its relationship
to other manifestations of lead poisoning.
Levels of delta-aminolevulinic acid (ALA) in the urine
are also used as a measure of lead exposure. Increasing
concentrations of ALA are believed to result from the
inhibition of the enzyme delta-aminolevulinic acid dehydrase
(ALA-D). Although the test is relatively easy to perform,
inexpensive, and rapid, the disadvantages include variability
in results, the necessity to collect a complete 24 hour
urine sample which has a specific gravity greater than
1.010, and also the fact that ALA decomposes in the presence
of light.
The pattern of porphyrin excretion in the urine can also
be helpful in identifying lead intoxication. With lead
poisoning, the urine concentrations of coproporphyrins
I and II, porphobilinogen and uroporphyrin I rise. The
most important increase, however, is that of coproporphyrin
III; levels may exceed 5,000 µg/l in the urine in lead
poisoned individuals, but its correlation with blood lead
levels and ZPP are not as good as those of ALA. Increases
in urinary porphyrins are not diagnostic of lead toxicity
and may be seen in porphyria, some liver diseases, and
in patients with high reticulocyte counts.
Summary. The Washington Industrial Safety and Health
Act's standard for inorganic lead in the construction
industry places significant emphasis on the medical surveillance
of all workers exposed to levels of inorganic lead above
30 µg/m3 TWA. The physician has a fundamental
role in this surveillance program, and in the operation
of the medical removal protection program.
Even with adequate worker education on the adverse health
effects of lead and appropriate training in work practices,
personal hygiene and other control measures, the physician
has a primary responsibility for evaluating potential
lead toxicity in the worker. It is only through a careful
and detailed medical and work history, a complete physical
examination and appropriate laboratory testing that an
accurate assessment can be made. Many of the adverse health
effects of lead toxicity are either irreversible or only
partially reversible and therefore early detection of
disease is very important.
This document outlines the medical monitoring program
as defined by the occupational safety and health standard
for inorganic lead. It reviews the adverse health effects
of lead poisoning and describes the important elements
of the history and physical examinations as they relate
to these adverse effects. Finally, the appropriate laboratory
testing for evaluating lead exposure and toxicity is presented.
It is hoped that this review and discussion will give
the physician a better understanding of the WISHA standard
with the ultimate goal of protecting the health and well-being
of the worker exposed to lead under their care.
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