Safe Solutions

Lead exposure

Lead exposure is not as common in the roofing industry as it is in some other construction trades. During the Occupational Safety and Health Administration's (OSHA's) 2006 fiscal year, employees from 15 construction industry categories, including roofing, were assessed a total of $158,000 in penalties for violating OSHA's lead standard (29 CFR 1926.62). The roofing industry was one of the least affected by penalties during that year. However, recent actions by OSHA ensure lead will be a topic of safety training and compliance efforts.

A necessary review

A notice in the Sept. 27 issue of the Federal Register states that after a recent regulatory review, OSHA will retain the construction industry standard governing lead exposure but attempt to improve outreach materials to help explain the lead standard to workers. Additionally, OSHA plans to clarify the initial assessment requirements under 29 CFR 1926.62(d) in an effort to reduce costs and simplify compliance for small businesses. OSHA also plans to work with other federal agencies to develop a unified training curriculum regarding lead exposures in construction.

The review's purpose was to determine whether OSHA's lead standard could be revised to reduce the burden on employers without reducing worker protection. The impetus for the review was public comments and data addressing blood lead levels and exposure levels among construction workers that became available after the original standard was finalized.

Standard's requirements

OSHA's lead standard applies to all construction work where a worker may be "occupationally exposed to lead." In roofing, some common products or applications that may fall under the lead construction standard include lead flashing materials, lead-coated copper and lead soldering.

The standard places the burden on employers to determine whether workers are exposed to lead at or above an airborne concentration of 30 micrograms per cubic meter (µg/m3) of air as an eight-hour time-weighted average—this is called the "action level." Workers must be protected during the exposure assessment, and the protective measures that must be in place are determined by the nature of the work being performed.

The standard details certain types of work, and presumed exposures are set out that dictate that personal protective equipment (PPE) must be provided, as well as other required protective measures.

For example, before performing an exposure assessment, you must treat any exposed workers as though they were exposed to up to 10 times the permissible exposure limit (PEL) of lead if they were performing manual demolition of structures where lead-containing coatings or paint are present. The standard's PEL for lead is 50 µg/m3 as an eight-hour time-weighted average.

Worker protection mandated by the standard before completion of an employee exposure assessment includes:

  • Appropriate respirator selection
  • Appropriate PPE and clothing
  • Changing areas to prevent protective work clothing from contaminating street clothing
  • Hand-washing facilities
  • Blood sampling and analysis to determine lead levels in workers' blood
  • Training in OSHA's lead standard, hazard communication and respirator use and general safety training and education under 29 CFR 1926.21

Respirator selection must be accomplished, as with other airborne contaminants, based on the provisions set out in 29 CFR 1910.134. Protective clothing must include coveralls or similar full-body work clothing, gloves, hats, shoes, face shields and goggles.

Future awareness

The roofing industry will benefit from increased outreach and guidance materials from OSHA with respect to lead exposures, and interpretations from OSHA that clarify the initial assessment process also likely will assist in compliance. The construction lead standard, notwithstanding the OSHA review findings, is complicated, but you must be aware of your compliance obligations during removal and installation of many roof systems.

Harry Dietz is NRCA's director of risk management.



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