An Occupational Safety and Health Administration (OSHA) citation recently was given to a roofing contractor who was removing a lead-coated copper roof. OSHA claimed the roof removal generated lead-containing dust and the contractor used insufficient employee safeguards. The roofing company received five willful citations and $315,000 in fines for failure to conduct initial exposure monitoring; provide proper personal protective work clothing and equipment; conduct training for handling lead materials; provide respirators and train employees to use them; and institute a biological monitoring program. Two other serious citations totaling $8,000 were issued for failure to have a complete lead-compliance program or collect personal samples of lead exposure.
Copper coated with lead provides alternative color options and reduces staining from water runoff. Once exposed to weather, the lead-coated surface reacts with moisture and other atmospheric components to form various substances, giving the material a range of surface patinas.
However, there are concerns with lead materials, which require careful removal and installation.
The OSHA lead standard "applies to all construction work where an employee may be occupationally exposed to lead," including demolition, installation, alteration, cleanup, repair and maintenance. It requires you to make an initial exposure assessment to determine whether an employee is exposed to lead at an airborne concentration of 30 mcgs/m³ of air or greater as an eight-hour time-weighted average; OSHA refers to this as the "action level."
OSHA has set the permissible exposure limit (PEL) for lead at 50 mcgs/m³ of air as an eight-hour time-weighted average. Until employee exposure monitoring has been completed, you must treat workers as though lead exposure exceeds the PEL. You must provide:
According to the standard, respirator selection is a function of presumed exposure depending on the type of work being done in instances where an initial exposure assessment is absent or not complete or on the basis of an exposure monitoring result indicating a precise airborne lead concentration. The regulation sets out presumptive levels of lead according to various types of work.
Respirator options range from a half-mask, air-purifying respirator for exposures at or below 10 times the PEL to a full-facepiece, self-contained breathing apparatus for exposures at or below 50 times the PEL. Different respirators are approved by OSHA for manual demolitions involving lead-coated materials versus cutting or torching lead-coated materials. OSHA requires engineering and work practice controls, if feasible, as primary methods to reduce lead exposures below the PEL; respirators supplement those controls to ensure worker protection.
In addition to suitable respirator selection and use, OSHA requires full-coverage protective gear, gloves, hats, shoes, and face shields or goggles when lead exposures exceed the PEL. This also applies during the period when the exposure level initially is being assessed and work involving lead takes place.
You must provide a worker exposed to lead at an airborne concentration exceeding the action level on any day initial medical surveillance consisting of blood sampling and analysis for lead. The testing must be offered at no cost and at a reasonable time and place.
Information regarding lead hazards should be part of your hazard training. Additionally, any worker exposed to lead at or above the action level must be trained on the lead standard, operational exposures, respirators, engineering controls and work practices, lead compliance plan provisions, and worker rights to records and warnings.
Lead exposures in roofing often are not obvious. OSHA's construction lead standard contains requirements subject to varying interpretations, and inevitable legal challenges can be expected by employers cited under the standard. In light of recent events, you should be vigilant when workers remove or install materials containing lead.
Harry Dietz is NRCA's director of safety and regulatory compliance.