What Happens When You Don’t Protect Your Workers from Lead Exposure

A company in Waverly, Ohio, was recently fined over $56,000 for violations of the Occupational Safety and Health Administration’s (OSHA) lead standard concerning exposure monitoring and the use of personal protective equipment. Today we will review the permissible exposure limit (PEL) for lead, take a look at what happened in this particular case, and urge you to consider whether you need to worry about lead exposure at your facility.

Lead PEL

Employers must ensure that no employee is exposed to lead at concentrations greater than 50 micrograms per cubic meter (µg/m3) averaged over an 8-hour period. If an employee is exposed to lead for more than 8 hours in any workday, the PEL, as a time-weighted average for that day, must be reduced according to the following formula:
Maximum permissible limit (in µg/m3) = 400 / hours worked in the day

What Happened?

Echo Environmental Waverly LLC, an electronics recycling company, was fined $56,850 for serious and other-than-serious health violations. OSHA inspected the facility after receiving complaints alleging that workers were exposed to lead hazards at the facility in Waverly, Ohio.

The serious violations were:

  • Employees using tight-fitting face piece respirators were not provided fit testing before the initial assignment, nor was fit testing provided at least annually when workers were exposed to lead above the PEL.

OSHA Lead Standard Compliance Manual. MARCOM’s Regulatory Compliance Manuals help facilities to understand and comply with OSHA regulations. Learn More!

  • A furnace operator was exposed to lead at 120% of the PEL (over 60 µg/m3) for a 432-minute sampling period.
  • Where initial monitoring revealed that employee exposure to lead was above the PEL, monitoring was not repeated at least quarterly or continued until at least two consecutive measurements taken at least 7 days apart were below the PEL and at or above the action level.
  • A written compliance program to reduce lead exposure to or below the PEL was not established or implemented. In addition, measurements were not taken at least every 3 months to evaluate the performance of the ventilation system that was used to control lead exposure.
  • The furnace operator who was exposed to lead at 120% of the PEL for a 432-minute sampling period was not wearing the required protective full-body work clothing. The company did not ensure that contaminated clothing was placed in a closed container and did not have a closed container in the change rooms.
  • Food and beverages were allowed to be consumed in areas where lead was likely to be present. A lunchroom with positive pressure or filtered air was not provided for employees exposed to lead above the PEL. In addition, shower facilities were not provided.

OSHA Lead Standard Compliance Manual. The manuals review the regulations and their compliance requirements, as well as provide materials that are necessary to help meet those requirements. Learn More!

  • The facility did not have a medical surveillance program for lead, and biological monitoring was not available for blood sampling and analysis for lead and zinc protoporphyrin.
  • Employees exposed to lead at or above the action level were not provided with the required information for lead exposure and were not provided with a copy of OSHA’s lead standard. In addition, employees were not trained on the hazards of lead exposure under a Hazard Communication Program. In fact, the facility did not have a Hazard Communication Program at all.

The other-than-serious violations are:

  • Documentation of respirator physical evaluations and fit testing records for employees required to wear half-face respirators were not provided.
  • Medical monitoring results were not provided.
  • Safety data sheets were not available when OSHA inspectors requested them.

You May Likely Need to Worry About Lead Exposure

Exposure to lead occurs in many jobs. People who work in lead smelting and refining industries, brass/bronze foundries, electronics recycling facilities, rubber and plastics industries, battery manufacturing plants, alkyl lead manufacturing industries, pottery and ceramics industries, radiator repair shops, and other industries that use lead solder may be exposed. According to OSHA, lead exposure occurs in most industry sectors including construction, manufacturing, wholesale trade, transportation, remediation, and even recreation.

Tomorrow we will review some tips for training workers who may be exposed to lead in the workplace.