Did you know that OSHA continues to emphasize programs and inspection to address lead exposures in general industry and construction? Lead is a highly toxic poison that may affect several body systems after acute and chronic exposures. A national goal has been established that will eliminate exposures that result in blood lead concentration. To achieve this goal, expect OSHA to step-up inspections for lead over the coming months. During these inspections, the OSHA Compliance Officer (CSHO) may test for airborne lead, but also for surface contamination. The CSHO will likely ask to examine whether a lead program is in place, if airborne data has been gathered, what hygiene facilities exist, if engineering controls are used to limit exposure, PPE utilized, medical surveillance records, etc. While at your facility, the CSHO may also wish to see respirator fit testing records, your hazard communication program, training records, etc. If other metal contaminants are also generated (or suspected) during work activities, the CSHO can test for these as well. Such metals might include arsenic, manganese, chromium, cadmium, copper, and magnesium. Any operation where potential lead dust or fume is created will be targets of the NEP.
Industries where lead exposures are expected to exceed the permissible exposure limit include: