Protecting Workers from Lead Exposure Would Have Saved This Employer from Additional Citations

At a municipal storage facility in Danville, Pennsylvania, a painting contractor was conducting abrasive blasting to remove paint from water tanks. An Occupational Safety and Health Administration (OSHA) inspection showed that the workers were overexposed to airborne lead—and to other airborne contaminants as well. If the employer had paid attention to its lead compliance, it would have saved itself these additional citations without any additional effort.

Find out how complying with the lead standards would have brought this employer into compliance with additional standards at the same time.

Beyond the Lead Standards

In addition to multiple citations under the lead standard, the painting contractor was cited under four other standards. If the contractor had been in compliance with the lead standard, it would have largely achieved compliance with these standards without any additional effort.

In addition to the lead standard, the employer violated:

  1. The airborne contaminants standard (29 CFR 1926.55). The construction standards require employers to protect workers from exposure to gases, vapors, fumes, dusts, and mists in excess of the permissible exposure limit (PEL) and to use engineering methods to control these exposures as much as is feasibly possible. In this case, workers’ total dust exposure as measured by OSHA exceeded the PEL for particulates not otherwise regulated (PNOR) by a factor of 30–40 times—a serious violation.


In addition, the painting contractor’s failure to use engineering controls to reduce airborne contaminants was cited separately for lead, PNOR, and other contaminants (see below). If the employer had complied with the lead standard, the ventilation required to reduce lead exposure levels likely would have also controlled exposures to PNOR.

  1. The respiratory protection standard (29 CFR 1910.134). When the employer set up the air compressor that was intended to provide clean breathing air to workers, it situated the compressor just 15 feet from the tank manhole where dust and contaminants were exiting the tank. The problem with this setup was that it allowed contaminated air to be drawn into the system and recirculated to the area where workers were.


The employer also allowed workers to wear tight-fitting respirator face pieces without shaving their facial hair, a practice that can interfere with the respirator seal and can allow contaminated air into the workers’ breathing zone.

The lead standard requires employers to have a compliant respiratory protection program; had the employer been in compliance with this program, it probably would have also been in compliance with the respiratory protection standard.

  1. The hexavalent chromium and cadmium standards. Lead and other heavy metals are often present in the same substrates or surface coatings; when you disturb one, you’ll also disturb the other. In this case, the exposures to hexavalent chromium and cadmium were lower than the lead exposures and were below the applicable PELs, and the violations (failing to perform an exposure determination and failing to inform workers about the potential hazardous exposures) were classified as other-than-serious. But the employer probably would not have been cited at all had it performed an exposure determination for lead and other heavy metals.


For more information on controlling airborne contaminants, check out the resources at®.

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