296-62-07517 Reserved. 296-62-07519 Thiram. 296-62-07521 Lead.
296-62-07523 Benzene. (This section has been moved to WAC
296-849 Benzene, effective March 1, 2005) 296-62-07531
Appendix D-Sampling and analytical methods for benzene monitoring
and measurement procedures 296-62-07540
Formaldehyde. 296-62-07542
Appendix A-Substance technical guidelines for formalin. 296-62-07544
Appendix B-Sampling strategy and analytical methods for formaldehyde. 296-62-07546
Appendix C-Medical surveillance-Formaldehyde. 296-62-07548
Appendix D-Nonmandatory medical disease questionnaire-Formaldehyde. 296-62-076
Methylenedianiline (MDA). 296-62-07601
Scope and application-MDA. 296-62-07603
Definitions-MDA. 296-62-07605
Permissible exposure limits (PEL)-MDA. 296-62-07607
Emergency situations-MDA. 296-62-07609
Exposure monitoring-MDA. 296-62-07611
Regulated areas-MDA. 296-62-07613
Methods of compliance-MDA. 296-62-07615
Respiratory protection-MDA. 296-62-07617
Protective work clothing and equipment-MDA. 296-62-07619
Hygiene facilities and practices-MDA. 296-62-07621
Communication of hazards to employees-MDA. 296-62-07623
Housekeeping-MDA. 296-62-07625
Medical surveillance-MDA. 296-62-07627
Medical removal-Temporary medical removal of an employee-MDA. 296-62-07629
Medical removal protection benefits-MDA. 296-62-07631
Recordkeeping-MDA. 296-62-07633
Observation of monitoring-MDA. 296-62-07637
Appendices-MDA. 296-62-07654
Appendix A to WAC 296-62-076-Substance data sheet for 4,4'-methylenedianiline. 296-62-07656
Appendix B to WAC 296-62-076-Substance technical guidelines for
MDA. 296-62-07658
Appendix C to WAC 296-62-076-Medical surveillance guidelines for
MDA. 296-62-07660
Appendix D to WAC 296-62-076-Sampling and analytical methods for
MDA monitoring and measurement procedures.
(1) Scope and application. This section applies to occupational
exposure to thiram (tetramethylthiuram disulfide), in addition
to those requirements listed in WAC 296-62-07515. Nothing in this
section shall preclude the application of other appropriate standards
and regulations to minimize worker exposure to thiram.
(2) Definitions. The following definitions are applicable to
this section:
(a) Clean - the absence of dirt or materials which may
be harmful to a worker's health.
(b) Large seedlings - those seedlings of such size,
either by length or breadth, that it is difficult to avoid contact
of the thiram treated plant with the mouth or face during planting
operations.
(3) General requirements.
(a) Workers should not be allowed to work more than five days
in any seven day period with or around the application of thiram
or thiram treated seedlings.
(b) Washing and worker hygiene.
(i) Workers shall wash their hands prior to eating or smoking
at the close of work.
(ii) Warm (at least 85°F, 29.4°C) wash water and single use
hand wiping materials shall be provided for washing.
(iii) The warm water and hand wiping materials shall be at
fixed work locations or at the planting unit.
(iv) Where warm water is not available within 15 minutes
travel time, nonalcoholic based waterless hand cleaner shall
be provided.
(v) Every planter or nursery worker shall be advised to bathe
or shower daily.
(vi) The inside of worker carrying vehicles shall be washed
or vacuumed and wiped down at least weekly during the period
of thiram use.
(c) Personal protective measures.
(i) Clothing shall be worn by workers to reduce skin contact
with thiram to the legs, arms and torso.
(ii) For those workers who have thiram skin irritations,
exposed areas of the body shall be protected by a suitable
barrier cream.
(iii) Clothing worn by workers shall be washed or changed
at least every other day.
(iv) Only impervious gloves may be worn by workers.
(v) Workers hands should be clean of thiram before placing
them into gloves.
(vi) Thiram applicators shall be provided with and use respiratory
protection in accordance with WAC 296-62-071, disposable coveralls
or rubber slickers or other impervious clothing, rubberized
boots, head covers and rubberized gloves.
(vii) Nursery workers, other than applicators, who are likely
to be exposed to thiram shall be provided with and use disposable
coveralls or rubber slickers or other impervious clothing,
impervious footwear and gloves, and head covers in accordance
with WAC 296-800-160, unless showers have been provided and
are used.
(viii) Eye protection according to WAC 296-800-160, shall
be provided and worn by workers who may be exposed to splashes
of thiram during spraying, plug bundling, belt line grading
and plugging or other operations.
(ix) Item (viii) of this subdivision need not be complied
with where pressurized emergency eye wash fountains are within
10 seconds travel time of the work location. (Approved respirator
- see WAC 296-62-071.)
(x) A dust mask shall be worn, when planting large seedlings,
to avoid mouth and face contact with the thiram treated plant
unless equally effective measures or planting practices have
been established.
(d) Food handling.
(i) Food snacks, beverages, smoking materials, or any other
item which is consumed shall not be stored or consumed in
the packing area of the nursery.
(ii) Worker carrying vehicles shall have a clean area for
carrying lunches.
(iii) The clean area of the vehicle shall be elevated from
the floor and not used to carry other than food or other consumable
items.
(iv) The carrying of lunches, food or other consumable items
in tree planting bags is prohibited.
(v) Care shall be taken to insure that worker exposure to
thiram spray, including downwind driftings, is minimized or
eliminated.
(vi) When bags that contained thiram or thiram treated seedlings
are burned, prevent worker exposure to the smoke.
(e) Thiram use and handling.
(i) Thiram treated seedlings shall be allowed to dry or stabilize
prior to packing.
(ii) Seedlings shall be kept moist during packing and whenever
possible during planting operations.
(iii) Floors, where thiram is used, shall not be dry swept
but instead vacuumed, washed or otherwise cleaned at least
daily.
(iv) Silica chips used to cover thiram treated seedling plugs
shall be removed at the nursery.
(f) Training.
(i) Each worker engaged in operations where exposure to thiram
may occur shall be provided training on the hazards of thiram,
as well as the necessary precautions for its safe use and
handling.
(ii) The training shall include instruction in:
(A) The nature of the health hazard(s) from exposure to
thiram including specifically the potential for alcohol
intolerance, drug interaction, and skin irritation;
(B) The specific nature of operations which could result
in exposure to thiram and the necessary protective steps;
(C) The purpose for, proper use, and limitations of protective
devices including respirators and clothing;
(D) The necessity for and requirements of good personal
hygiene; and
(E) A review of the thiram rules at the worker's first
training and indoctrination, and annually thereafter.
(4) Effective date. This standard shall become effective 30 days
after being filed with the code reviser.
(a) This section applies to all occupational exposure to lead,
except as provided in subdivision (1)(b).
(b) This section does not apply to the construction industry
or to agricultural operations covered by chapter 296-307 WAC.
(2) Definitions as applicable to this part.
(a) “Action level” - employee exposure,
without regard to the use of respirators, to an airborne concentration
of lead of thirty micrograms per cubic meter of air (30 µg/m3)
averaged over an eight-hour period.
(b) “Director” - the director of the department
of labor and industries.
(c) “Lead” - metallic lead, all inorganic
lead compounds, and organic lead soaps. Excluded from this definition
are all other organic lead compounds.
(3) General requirements.
(a) Employers will assess the hazards of lead in the work place
and provide information to the employees about the hazards of
the lead exposures to which they may be exposed.
(iv) Personnel protective equipment and housekeeping;
(v) Medical surveillance and examinations;
(vi) Training requirements;
(vii) Recordkeeping requirements.
(4) Permissible exposure limit (PEL).
(a) The employer shall assure that no employee is exposed to
lead at concentrations greater than fifty micrograms per cubic
meter of air (50 µg/m3) averaged over an eight-hour
period.
(b) If an employee is exposed to lead for more than eight hours
in any work day, the permissible exposure limit, as a time weighted
average (TWA) for that day, shall be reduced according to the
following formula:
Maximum permissible limit (in µg/m3) = 400 ÷ hours
worked in the day.
(c) When respirators are used to supplement engineering and
work practice controls to comply with the PEL and all the requirements
of subsection (7) have been met, employee exposure, for the
purpose of determining whether the employer has complied with
the PEL, may be considered to be at the level provided by the
protection factor of the respirator for those periods the respirator
is worn. Those periods may be averaged with exposure levels
during periods when respirators are not worn to determine the
employee's daily TWA exposure.
(5) Exposure monitoring.
(a) General.
(i) For the purposes of subsection (5), employee exposure
is that exposure which would occur if the employee were not
using a respirator.
(ii) With the exception of monitoring under subdivision (5)(c),
the employer shall collect full shift (for at least seven
continuous hours) personal samples including at least one
sample for each shift for each job classification in each
work area.
(iii) Full shift personal samples shall be representative
of the monitored employee's regular, daily exposure to lead.
(b) Initial determination. Each employer who has a workplace
or work operation covered by this standard shall determine if
any employee may be exposed to lead at or above the action level.
(c) Basis of initial determination.
(i) The employer shall monitor employee exposures and shall
base initial determinations on the employee exposure monitoring
results and any of the following, relevant considerations:
(A) Any information, observations, or calculations which
would indicate employee exposure to lead;
(B) Any previous measurements of airborne lead; and
(C) Any employee complaints of symptoms which may be attributable
to exposure to lead.
(ii) Monitoring for the initial determination may be limited
to a representative sample of the exposed employees who the
employer reasonably believes are exposed to the greatest airborne
concentrations of lead in the workplace.
(iii) Measurements of airborne lead made in the preceding
twelve months may be used to satisfy the requirement to monitor
under item (5)(c)(i) if the sampling and analytical methods
used meet the accuracy and confidence levels of subdivision
(5)(i) of this section.
(d) Positive initial determination and initial monitoring.
(i) Where a determination conducted under subdivision (5)(b)
and (5)(c) of this section shows the possibility of any employee
exposure at or above the action level, the employer shall
conduct monitoring which is representative of the exposure
for each employee in the workplace who is exposed to lead.
(ii) Measurements of airborne lead made in the preceding
twelve months may be used to satisfy this requirement if the
sampling and analytical methods used meet the accuracy and
confidence levels of subdivision (5)(i) of this section.
(e) Negative initial determination. Where a determination,
conducted under subdivisions (5)(b) and (5)(c) of this section
is made that no employee is exposed to airborne concentrations
of lead at or above the action level, the employer shall make
a written record of such determination. The record shall include
at least the information specified in subdivision (5)(c) of
this section and shall also include the date of determination,
location within the worksite, and the name and social security
number of each employee monitored.
(f) Frequency.
(i) If the initial monitoring reveals employee exposure to
be below the action level the measurements need not be repeated
except as otherwise provided in subdivision (5)(g) of this
section.
(ii) If the initial determination or subsequent monitoring
reveals employee exposure to be at or above the action level
but below the permissible exposure limit the employer shall
repeat monitoring in accordance with this subsection at least
every six months. The employer shall continue monitoring at
the required frequency until at least two consecutive measurements,
taken at least seven days apart, are below the action level
at which time the employer may discontinue monitoring for
that employee except as otherwise provided in subdivision
(5)(g) of this section.
(iii) If the initial monitoring reveals that employee exposure
is above the permissible exposure limit the employer shall
repeat monitoring quarterly. The employer shall continue monitoring
at the required frequency until at least two consecutive measurements,
taken at least seven days apart, are below the PEL but at
or above the action level at which time the employer shall
repeat monitoring for that employee at the frequency specified
in item (5)(f)(ii), except as otherwise provided in subdivision
(5)(g) of this section.
(g) Additional monitoring. Whenever there has been a production,
process, control or personnel change which may result in new
or additional exposure to lead, or whenever the employer has
any other reason to suspect a change which may result in new
or additional exposures to lead, additional monitoring in accordance
with this subsection shall be conducted.
(h) Employee notification.
(i) Within five working days after the receipt of monitoring
results, the employer shall notify each employee in writing
of the results which represent that employee's exposure.
(ii) Whenever the results indicate that the representative
employee exposure, without regard to respirators, exceeds
the permissible exposure limit, the employer shall include
in the written notice a statement that the permissible exposure
limit was exceeded and a description of the corrective action
taken or to be taken to reduce exposure to or below the permissible
exposure limit.
(i) Accuracy of measurement. The employer shall use a method
of monitoring and analysis which has an accuracy (to a confidence
level of ninety-five percent) of not less than plus or minus
twenty percent for airborne concentrations of lead equal to
or greater than 30 µg/m3.
(6) Methods of compliance.
(a) Engineering and work practice controls.
(i) Where any employee is exposed to lead above the permissible
exposure limit for more than thirty days per year, the employer
shall implement engineering and work practice controls (including
administrative controls) to reduce and maintain employee exposure
to lead in accordance with the implementation schedule in
Table I below, except to the extent that the employer can
demonstrate that such controls are not feasible. Wherever
the engineering and work practice controls which can be instituted
are not sufficient to reduce employee exposure to or below
the permissible exposure limit, the employer shall nonetheless
use them to reduce exposures to the lowest feasible level
and shall supplement them by the use of respiratory protection
which complies with the requirements of subsection (7) of
this section.
(ii) Where any employee is exposed to lead above the permissible
exposure limit, but for thirty days or less per year, the
employer shall implement engineering controls to reduce exposures
to 200 µg/m3, but thereafter may implement any
combination of engineering, work practice (including administrative
controls), and respiratory controls to reduce and maintain
employee exposure to lead to or below 50 µg/m3.
TABLE
1
Industry
Compliance
dates1 (50 mg/m3)
Lead chemicals,
secondary copper smelting
July 19,
1996
Nonferrous
foundries
July
19, 19962
Brass and
bronze ingot manufacture.
6 years3
1Calculated by counting from the date the stay on
implementation of subsection (6)(a) was lifted by the U.S. Court
of Appeals for the District of Columbia, the number of years specified
in the 1978 lead standard and subsequent amendments for compliance
with the PEL of 50 µg/m3 for exposure to airborne concentrations
of lead levels for the particular industry.
2 Large nonferrous foundries (20 or more employees)
are required to achieve the PEL of 50 µg/m3 by means
of engineering and work practice controls. Small nonferrous foundries
(fewer than 20 employees) are required to achieve an 8-hour TWA
of 75 µg/m3 by such controls.
3Expressed as the number of years from the date on
which the Court lifts the stay on the implementation of subsection
(6)(a) for this industry for employers to achieve a lead in air
concentration of 75 µg/m3. Compliance with subsection
(6) in this industry is determined by a compliance directive that
incorporates elements from the settlement agreement between OSHA
and representatives of the industry.
(b) Respiratory protection. Where engineering and work practice
controls do not reduce employee exposure to or below the 50
µg/m3 permissible exposure limit, the employer shall
supplement these controls with respirators in accordance with
subsection (7).
(c) Compliance program.
(i) Each employer shall establish and implement a written
compliance program to reduce exposures to or below the permissible
exposure limit, and interim levels if applicable, solely by
means of engineering and work practice controls in accordance
with the implementation schedule in subdivision (6)(a).
(ii) Written plans for these compliance programs shall include
at least the following:
(A) A description of each operation in which lead is emitted;
e.g., machinery used, material processed, controls in place,
crew size, employee job responsibilities, operating procedures
and maintenance practices;
(B) A description of the specific means that will be employed
to achieve compliance, including engineering plans and studies
used to determine methods selected for controlling exposure
to lead;
(C) A report of the technology considered in meeting the
permissible exposure limit;
(D) Air monitoring data which documents the source of lead
emissions;
(E) A detailed schedule for implementation of the program,
including documentation such as copies of purchase orders
for equipment, construction contracts, etc.;
(F) A work practice program which includes items required
under subsections (8), (9) and (10) of this regulation;
(G) An administrative control schedule required by subdivision
(6)(f), if applicable; and
(H) Other relevant information.
(iii) Written programs shall be submitted upon request to
the director, and shall be available at the worksite for examination
and copying by the director, any affected employee or authorized
employee representatives.
(iv) Written programs shall be revised and updated at least
every six months to reflect the current status of the program.
(d) Mechanical ventilation.
(i) When ventilation is used to control exposure, measurements
which demonstrate the effectiveness of the system in controlling
exposure, such as capture velocity, duct velocity, or static
pressure shall be made at least every three months. Measurements
of the system's effectiveness in controlling exposure shall
be made within five days of any change in production, process,
or control which might result in a change in employee exposure
to lead.
(ii) Recirculation of air. If air from exhaust ventilation
is recirculated into the workplace, the employer shall assure
that (A) the system has a high efficiency filter with reliable
back-up filter; and (B) controls to monitor the concentration
of lead in the return air and to bypass the recirculation
system automatically if it fails are installed, operating,
and maintained.
(e) Administrative controls. If administrative controls are
used as a means of reducing employees TWA exposure to lead,
the employer shall establish and implement a job rotation schedule
which includes:
(i) Name or identification number of each affected employee;
(ii) Duration and exposure levels at each job or work station
where each affected employee is located; and
(iii) Any other information which may be useful in assessing
the reliability of administrative controls to reduce exposure
to lead.
(7) Respiratory protection.
(a) General. For employees who use respirators required by
this section, the employer must provide respirators that comply
with the requirements of this subsection. Respirators must be
used during:
(i) Periods necessary to install or implement engineering
or work-practice controls;
(ii) Work operations for which engineering and work-practice
controls are not sufficient to reduce exposures to or below
the permissible exposure limit;
(iii) Periods when an employee requests a respirator.
(b) Respirator program.
(i) The employer must develop, implement and maintain a respiratory
protection program as required by Chapter
296-842 WAC, Respirators.
(ii) If an employee has difficulty breathing during fit testing
or respirator use, the employer must provide the employee
with a medical examination as required by subsection (11)(c)(ii)(C)
of this section to determine whether or not the employee can
use a respirator while performing the required duty.
(c) Respirator selection. The employer must:
(i) Select and provide to employees appropriate respirators
according to this section and WAC 296-842-13005, found in
the respirator rule.
(ii) Provide employees with a powered air-purifying respirator
(PAPR) instead of a negative-prerssure respirator selected
when an employee chooses to use a PAPR and it provides adequate
protection to the employee.
(iii) Provide employees with full-facepiece respirators instead
of half-facepiece respirators for protection against lead
aerosols that cause eye or skin irritation at the use concentration.
(v) Provide HEPA filters or N-, R-, or P-100 filters for
powered air-purifying respirators (PAPRs) and negative-pressure
air-purifying respirators.
(8) Protective work clothing and equipment.
(a) Provision and use. If an employee is exposed to lead above
the PEL, without regard to the use of respirators or where the
possibility of skin or eye irritation exists, the employer shall
provide at no cost to the employee and assure that the employee
uses appropriate protective work clothing and equipment such
as, but not limited to:
(i) Coveralls or similar full-body work clothing;
(ii) Gloves, hats, and shoes or disposable shoe coverlets;
and
(iii) Face shields, vented goggles, or other appropriate
protective equipment which complies with WAC 296-800-160.
(b) Cleaning and replacement.
(i) The employer shall provide the protective clothing required
in subdivision (8)(a) of this section in a clean and dry condition
at least weekly, and daily to employees whose exposure levels
without regard to a respirator are over 200 µg/m3
of lead as an eight-hour TWA.
(ii) The employer shall provide for the cleaning, laundering,
or disposal of protective clothing and equipment required
by subdivision (8)(a) of this section.
(iii) The employer shall repair or replace required protective
clothing and equipment as needed to maintain their effectiveness.
(iv) The employer shall assure that all protective clothing
is removed at the completion of a work shift only in change
rooms provided for that purpose as prescribed in subdivision
(10)(b) of this section.
(v) The employer shall assure that contaminated protective
clothing which is to be cleaned, laundered, or disposed of,
is placed in a closed container in the change-room which prevents
dispersion of lead outside the container.
(vi) The employer shall inform in writing any person who
cleans or launders protective clothing or equipment of the
potentially harmful effects of exposure to lead.
(vii) The employer shall assure that the containers of contaminated
protective clothing and equipment required by subdivision
(8)(b)(v) are labeled as follows:
CAUTION: CLOTHING CONTAMINATED WITH LEAD.
DO NOT REMOVE DUST
BY BLOWING OR SHAKING.
DISPOSE OF LEAD CONTAMINATED WASH WATER
IN ACCORDANCE WITH APPLICABLE
LOCAL, STATE, OR FEDERAL REGULATIONS.
(viii) The employer shall prohibit the removal of lead from
protective clothing or equipment by blowing, shaking, or any
other means which disperses lead into the air.
(9) Housekeeping.
(a) Surfaces. All surfaces shall be maintained as free as practicable
of accumulations of lead.
(b) Cleaning floors.
(i) Floors and other surfaces where lead accumulates may
not be cleaned by the use of compressed air.
(ii) Shoveling, dry or wet sweeping, and brushing may be
used only where vacuuming or other equally effective methods
have been tried and found not to be effective.
(c) Vacuuming. Where vacuuming methods are selected, the vacuums
shall be used and emptied in a manner which minimizes the reentry
of lead into the workplace.
(10) Hygiene facilities and practices.
(a) The employer shall assure that in areas where employees
are exposed to lead above the PEL, without regard to the use
of respirators, food or beverage is not present or consumed,
tobacco products are not present or used, and cosmetics are
not applied, except in change rooms, lunchrooms, and showers
required under subdivision (10)(b) through (10)(d) of this section.
(b) Change rooms.
(i) The employer shall provide clean change rooms for employees
who work in areas where their airborne exposure to lead is
above the PEL, without regard to the use of respirators.
(ii) The employer shall assure that change rooms are equipped
with separate storage facilities for protective work clothing
and equipment and for street clothes which prevent cross-contamination.
(c) Showers.
(i) The employer shall assure that employees who work in
areas where their airborne exposure to lead is above the PEL,
without regard to the use of respirators, shower at the end
of the work shift.
(ii) The employer shall provide shower facilities in accordance
with WAC 296-800-230.
(iii) The employer shall assure that employees who are required
to shower pursuant to item (10)(c)(i) do not leave the workplace
wearing any clothing or equipment worn during the work shift.
(d) Lunchrooms.
(i) The employer shall provide lunchroom facilities for employees
who work in areas where their airborne exposure to lead is
above the PEL, without regard to the use of respirators.
(ii) The employer shall assure that lunchroom facilities
have a temperature controlled, positive pressure, filtered
air supply, and are readily accessible to employees.
(iii) The employer shall assure that employees who work in
areas where their airborne exposure to lead is above the PEL
without regard to the use of a respirator wash their hands
and face prior to eating, drinking, smoking or applying cosmetics.
(iv) The employer shall assure that employees do not enter
lunchroom facilities with protective work clothing or equipment
unless surface lead dust has been removed by vacuuming, downdraft
booth, or other cleaning method.
(e) Lavatories. The employer shall provide an adequate number
of lavatory facilities which comply with WAC 296-800-230.
(11) Medical surveillance.
(a) General.
(i) The employer shall institute a medical surveillance program
for all employees who are or may be exposed above the action
level for more than thirty days per year.
(ii) The employer shall assure that all medical examinations
and procedures are performed by or under the supervision of
a licensed physician.
(iii) The employer shall provide the required medical surveillance
including multiple physician review under item (11)(c)(iii)
without cost to employees and at a reasonable time and place.
(b) Biological monitoring.
(i) Blood lead and ZPP level sampling and analysis. The employer
shall make available biological monitoring in the form of
blood sampling and analysis for lead and zinc protoporphyrin
levels to each employee covered under item (11)(a)(i) of this
section on the following schedule:
(A) At least every six months to each employee covered
under item (11)(a)(i) of this section;
(B) At least every two months for each employee whose last
blood sampling and analysis indicated a blood lead level
at or above 40 µg/100 g of whole blood. This frequency shall
continue until two consecutive blood samples and analyses
indicate a blood lead level below 40 µg/100 g of whole blood;
and
(C) At least monthly during the removal period of each
employee removed from exposure to lead due to an elevated
blood lead level.
(ii) Follow-up blood sampling tests. Whenever the results
of a blood lead level test indicate that an employee's blood
lead level exceeds the numerical criterion for medical removal
under item (12)(a)(i)(A), the employer shall provide a second
(follow-up) blood sampling test within two weeks after the
employer receives the results of the first blood sampling
test.
(iii) Accuracy of blood lead level sampling and analysis.
Blood lead level sampling and analysis provided pursuant the
this section shall have an accuracy (to a confidence level
of ninety-five percent) within plus or minus fifteen percent
or 6 µg/100 ml, whichever is greater, and shall be conducted
by a laboratory licensed by the Center for Disease Control
(CDC), United States Department of Health, Education and Welfare
or which has received a satisfactory grade in blood lead proficiency
testing from CDC in the prior twelve months.
(iv) Employee notification. Within five working days after
the receipt of biological monitoring results, the employer
shall notify in writing each employee whose blood lead level
exceeds 40 µg/100 g: (A) of that employee's blood lead level
and (B) that the standard requires temporary medical removal
with medical removal protection benefits when an employee's
blood lead level exceeds the numerical criterion for medical
removal under item (12)(a)(i) of this section.
(c) Medical examinations and consultations.
(i) Frequency. The employer shall make available medical
examinations and consultations to each employee covered under
item (11)(a)(i) of this section on the following schedule:
(A) At least annually for each employee for whom a blood
sampling test conducted at any time during the preceding
twelve months indicated a blood lead level at or above 40
µg/100 g;
(B) Prior to assignment for each employee being assigned
for the first time to an area in which airborne concentrations
of lead are at or above the action level;
(C) As soon as possible, upon notification by an employee
either that the employee has developed signs or symptoms
commonly associated with lead intoxication, that the employee
desires medical advice concerning the effects of current
or past exposure to lead on the employee's ability to procreate
a healthy child, or that the employee has demonstrated difficulty
in breathing during a respirator fitting test or during
use; and
(D) As medically appropriate for each employee either removed
from exposure to lead due to a risk of sustaining material
impairment to health, or otherwise limited pursuant to a
final medical determination.
(ii) Content. Medical examinations made available pursuant
to subitems (11)(c)(i)(A) through (B) of this section shall
include the following elements:
(A) A detailed work history and a medical history, with
particular attention to past lead exposure (occupational
and nonoccupational), personal habits (smoking, hygiene),
and past gastrointestinal, hematologic, renal, cardiovascular,
reproductive and neurological problems;
(B) A thorough physical examination, with particular attention
to teeth, gums, hematologic, gastrointestinal, renal, cardiovascular,
and neurological systems. Pulmonary status should be evaluated
if respiratory protection will be used;
(C) A blood pressure measurement;
(D) A blood sample and analysis which determines:
(I) Blood lead level;
(II) Hemoglobin and hematocrit determinations, red cell
indices, and examination of peripheral smear morphology;
(III) Zinc protoporphyrin;
(IV) Blood urea nitrogen; and
(V) Serum creatinine;
(E) A routine urinalysis with microscopic examination;
and
(F) Any laboratory or other test which the examining physician
deems necessary by sound medical practice.
The content of medical examinations made available pursuant
to subitems (11)(c)(i)(C) through (D) of this section shall
be determined by an examining physician and, if requested
by an employee, shall include pregnancy testing or laboratory
evaluation of male fertility.
(iii) Multiple physician review mechanism.
(A) If the employer selects the initial physician who conducts
any medical examination or consultation provided to an employee
under this section, the employee may designate a second
physician:
(I) To review any findings, determinations or recommendations
of the initial physician; and
(II) To conduct such examinations, consultations, and
laboratory tests as the second physician deems necessary
to facilitate this review.
(B) The employer shall promptly notify an employee of the
right to seek a second medical opinion after each occasion
that an initial physician conducts a medical examination
or consultation pursuant to this section. The employer may
condition its participation in, and payment for, the multiple
physician review mechanism upon the employee doing the following
within fifteen days after receipt of the foregoing notification,
or receipt of the initial physician's written opinion, whichever
is later:
(I) The employee informing the employer that he or she
intends to seek a second medical opinion, and
(II) The employee initiating steps to make an appointment
with a second physician.
(C) If the findings, determinations or recommendations
of the second physician differ from those of the initial
physician, then the employer and the employee shall assure
that efforts are made for the two physicians to resolve
any disagreement.
(D) If the two physicians have been unable to quickly resolve
their disagreement, then the employer and the employee through
their respective physicians shall designate a third physician:
(I) To review any findings, determinations or recommendations
of the prior physicians; and
(II) To conduct such examinations, consultations, laboratory
tests and discussions with the prior physicians as the
third physician deems necessary to resolve the disagreement
of the prior physicians.
(E) The employer shall act consistent with the findings,
determinations and recommendations of the third physician,
unless the employer and the employee reach an agreement
which is otherwise consistent with the recommendations of
at least one of the three physicians.
(iv) Information provided to examining and consulting physicians.
(A) The employer shall provide an initial physician conducting
a medical examination or consultation under this section
with the following information:
(I) A copy of this regulation for lead including all
appendices;
(II) A description of the affected employee's duties
as they relate to the employee's exposure;
(III) The employee's exposure level or anticipated exposure
level to lead and to any other toxic substance (if applicable);
(IV) A description of any personal protective equipment
used or to be used;
(V) Prior blood lead determinations; and
(VI) All prior written medical opinions concerning the
employee in the employer's possession or control.
(B) The employer shall provide the foregoing information
to a second or third physician conducting a medical examination
or consultation under this section upon request either by
the second or third physician, or by the employee.
(v) Written medical opinions.
(A) The employer shall obtain and furnish the employee
with a copy of a written medical opinion from each examining
or consulting physician which contains the following information:
(I) The physician's opinion as to whether the employee
has any detected medical condition which would place the
employee at increased risk of material impairment of the
employee's health from exposure to lead;
(II) Any recommended special protective measures to be
provided to the employee, or limitations to be placed
upon the employee's exposure to lead;
(III) Any recommended limitation upon the employee's
use of respirators, including a determination of whether
the employee can wear a powered air purifying respirator
if a physician determines that the employee cannot wear
a negative pressure respirator; and
(IV) The results of the blood lead determinations.
(B) The employer shall instruct each examining and consulting
physician to:
(I) Not reveal either in the written opinion, or in any
other means of communication with the employer, findings,
including laboratory results, or diagnoses unrelated to
an employee's occupational exposure to lead; and
(II) Advise the employee of any medical condition, occupational
or nonoccupational, which dictates further medical examination
or treatment.
(vi) Alternate physician determination mechanisms. The employer
and an employee or authorized employee representative may
agree upon the use of any expeditious alternate physician
determination mechanism in lieu of the multiple physician
review mechanism provided by this subsection so long as the
alternate mechanism otherwise satisfies the requirements contained
in this subsection.
(d) Chelation.
(i) The employer shall assure that any person whom he retains,
employs, supervises or controls does not engage in prophylactic
chelation of any employee at any time.
(ii) If therapeutic or diagnostic chelation is to be performed
by any person in item (11)(d)(i), the employer shall assure
that it be done under the supervision of a licensed physician
in a clinical setting with thorough and appropriate medical
monitoring and that the employee is notified in writing prior
to its occurrence.
(12) Medical removal protection.
(a) Temporary medical removal and return of an employee.
(i) Temporary removal due to elevated blood lead levels.
(A) The employer shall remove an employee from work having
an exposure to lead at or above the action level on each
occasion that a periodic and a follow-up blood sampling
test conducted pursuant to this section indicate that the
employee's blood lead level is at or above 60 µg/100 g of
whole blood; and
(B) The employer shall remove an employee from work having
an exposure to lead at or above the action level on each
occasion that the average of the last three blood sampling
tests conducted pursuant to this section (or the average
of all blood sampling tests conducted over the previous
six months, whichever is longer) indicates that the employee's
blood lead level is at or above 50 µg/100 g of whole blood;
provided, however, that an employee need not be removed
if the last blood sampling test indicates a blood lead level
at or below 40 µg/100 g of whole blood.
(ii) Temporary removal due to a final medical determination.
(A) The employer shall remove an employee from work having
an exposure to lead at or above the action level on each
occasion that a final medical determination results in a
medical finding, determination, or opinion that the employee
has a detected medical condition which places the employee
at increased risk of material impairment to health from
exposure to lead.
(B) For the purposes of this section, the phrase “final
medical determination” shall mean the outcome of the
multiple physician review mechanism or alternate medical
determination mechanism used pursuant to the medical surveillance
provisions of this section.
(C) Where a final medical determination results in any
recommended special protective measures for an employee,
or limitations on an employee's exposure to lead, the employer
shall implement and act consistent with the recommendation.
(iii) Return of the employee to former job status.
(A) The employer shall return an employee to his or her
former job status:
(I) For an employee removed due to a blood lead level
at or above 60 µg/100 g, or due to an average blood lead
level at or above 50 µg/100 g, when two consecutive blood
sampling tests indicate that the employee's blood lead
level is at or below 40 µg/100 g of whole blood;
(II) For an employee removed due to a final medical determination,
when a subsequent final medical determination results
in a medical finding, determination, or opinion that the
employee no longer has a detected medical condition which
places the employee at increased risk of material impairment
to health from exposure to lead.
(B) For the purposes of this section, the requirement that
an employer return an employee to his or her former job
status is not intended to expand upon or restrict any rights
an employee has or would have had, absent temporary medical
removal, to a specific job classification or position under
the terms of a collective bargaining agreement.
(iv) Removal of other employee special protective measure
or limitations. The employer shall remove any limitations
placed on an employee or end any special protective measures
provided to an employee pursuant to a final medical determination
when a subsequent final medical determination indicates that
the limitations or special protective measures are no longer
necessary.
(v) Employer options pending a final medical determination.
Where the multiple physician review mechanism, or alternate
medical determination mechanism used pursuant to the medical
surveillance provisions of this section, has not yet resulted
in a final medical determination with respect to an employee,
the employer shall act as follows:
(A) Removal. The employer may remove the employee from
exposure to lead, provide special protective measures to
the employee, or place limitations upon the employee, consistent
with the medical findings, determinations, or recommendations
of any of the physicians who have reviewed the employee's
health status.
(B) Return. The employer may return the employee to his
or her former job status, end any special protective measures
provided to the employee, and remove any limitations placed
upon the employee, consistent with the medical findings,
determinations, or recommendations of any of the physicians
who have reviewed the employee's health status, with two
exceptions. If:
(I) The initial removal, special protection, or limitation
of the employee resulted from a final medical determination
which differed from the findings, determinations, or recommendations
of the initial physician; or
(II) The employee has been on removal status for the
preceding eighteen months due to an elevated blood lead
level, then the employer shall await a final medical determination.
(b) Medical removal protection benefits.
(i) Provision of medical removal protection benefits. The
employer shall provide to an employee up to eighteen months
of medical removal protection benefits on each occasion that
an employee is removed from exposure to lead or otherwise
limited pursuant to this section.
(ii) Definition of medical removal protection benefits. For
the purposes of this section, the requirement that an employer
provide medical removal protection benefits means that the
employer shall maintain the earnings, seniority and other
employment rights and benefits of an employee as though the
employee had not been removed from normal exposure to lead
or otherwise limited.
(iii) Follow-up medical surveillance during the period of
employee removal or limitation. During the period of time
that an employee is removed from normal exposure to lead or
otherwise limited, the employer may condition the provision
of medical removal protection benefits upon the employee's
participation in follow-up medical surveillance made available
pursuant to this section.
(iv) Workers' compensation claims. If a removed employee
files a claim for workers' compensation payments for a lead-related
disability, then the employer shall continue to provide medical
removal protection benefits pending disposition of the claim.
To the extent that an award is made to the employee for earnings
lost during the period of removal, the employer's medical
removal protection obligation shall be reduced by such amount.
The employer shall receive no credit for workers' compensation
payments received by the employee for treatment related expenses.
(v) Other credits. The employer's obligation to provide medical
removal protection benefits to a removed employee shall be
reduced to the extent that the employee receives compensation
for earnings lost during the period of removal either from
a publicly or employer-funded compensation program, or receives
income from employment with another employer made possible
by virtue of the employee's removal.
(vi) Employees whose blood lead levels do not adequately
decline within eighteen months of removal. The employer shall
take the following measures with respect to any employee removed
from exposure to lead due to an elevated blood lead level
whose blood lead level has not declined within the past eighteen
months of removal so that the employee has been returned to
his or her former job status:
(A) The employer shall make available to the employee a
medical examination pursuant to this section to obtain a
final medical determination with respect to the employee;
(B) The employer shall assure that the final medical determination
obtained indicates whether or not the employee may be returned
to his or her former job status, and if not, what steps
should be taken to protect the employee's health;
(C) Where the final medical determination has not yet been
obtained, or once obtained indicates that the employee may
not yet be returned to his or her former job status, the
employer shall continue to provide medical removal protection
benefits to the employee until either the employee is returned
to former job status, or a final medical determination is
made that the employee is incapable of ever safely returning
to his or her former job status.
(D) Where the employer acts pursuant to a final medical
determination which permits the return of the employee to
his or her former job status despite what would otherwise
be an unacceptable blood lead level, later questions concerning
removing the employee again shall be decided by a final
medical determination. The employer need not automatically
remove such an employee pursuant to the blood lead level
removal criteria provided by this section.
(vii) Voluntary removal or restriction of an employee. Where
an employer, although not required by this section to do so,
removes an employee from exposure to lead or otherwise places
limitations on an employee due to the effects of lead exposure
on the employee's medical condition, the employer shall provide
medical removal protection benefits to the employee equal
to that required by item (12)(b)(i) of this section.
(13) Employee information and training.
(a) Training program.
(i) Each employer who has a workplace in which there is a
potential exposure to airborne lead at any level shall inform
employees of the content of Appendices A and B of this regulation.
(ii) The employer shall institute a training program for
and assure the participation of all employees who are subject
to exposure to lead at or above the action level or for whom
the possibility of skin or eye irritation exists.
(iii) The employer shall provide initial training by one
hundred eighty days from the effective date for those employees
covered by item (13)(a)(ii) on the standard's effective date
and prior to the time of initial job assignment for those
employees subsequently covered by this subsection.
(iv) The training program shall be repeated at least annually
for each employee.
(v) The employer shall assure that each employee is informed
of the following:
(A) The content of this standard and its appendices;
(B) The specific nature of the operations which could result
in exposure to lead above the action level;
(C) The purpose, proper use, limitations, and other training
requirements for respiratory protection as required by chapter
296-62 WAC, Part E;
(D) The purpose and a description of the medical surveillance
program, and the medical removal protection program including
information concerning the adverse health effects associated
with excessive exposure to lead (with particular attention
to the adverse reproductive effects on both males and females);
(E) The engineering controls and work practices associated
with the employee's job assignment;
(F) The contents of any compliance plan in effect; and
(G) Instructions to employees that chelating agents should
not routinely be used to remove lead from their bodies and
should not be used at all except under the direction of
a licensed physician.
(b) Access to information and training materials.
(i) The employer shall make readily available to all affected
employees a copy of this standard and its appendices.
(ii) The employer shall provide, upon request, all materials
relating to the employee information and training program
to the director.
(iii) In addition to the information required by item (13)(a)(v),
the employer shall include as part of the training program,
and shall distribute to employees, any materials pertaining
to the Occupational Safety and Health Act, the regulations
issued pursuant to the act, and this lead standard, which
are made available to the employer by the director.
(14) Signs.
(a) General.
(i) The employer may use signs required by other statutes,
regulations or ordinances in addition to, or in combination
with, signs required by this subsection.
(ii) The employer shall assure that no statement appears
on or near any sign required by this subsection which contradicts
or detracts from the meaning of the required sign.
(i) The employer shall post the following warning signs in
each work area where the PEL is exceeded:
WARNING
LEAD WORK AREA
POISON
NO SMOKING OR EATING
(ii) The employer shall assure that signs required by this
subsection are illuminated and cleaned as necessary so that
the legend is readily visible.
(15) Recordkeeping.
(a) Exposure monitoring.
(i) The employer shall establish and maintain an accurate
record of all monitoring required in subsection (5) of this
section.
(ii) This record shall include:
(A) The date(s), number, duration, location and results
of each of the samples taken, including a description of
the sampling procedure used to determine representative
employee exposure where applicable;
(B) A description of the sampling and analytical methods
used and evidence of their accuracy;
(C) The type of respiratory protective devices worn, if
any;
(D) Name, social security number, and job classification
of the employee monitored and of all other employees whose
exposure the measurement is intended to represent; and
(E) The environmental variables that could affect the measurement
of employee exposure.
(iii) The employer shall maintain these monitoring records
for at least forty years or for the duration of employment
plus twenty years, whichever is longer.
(b) Medical surveillance.
(i) The employer shall establish and maintain an accurate
record for each employee subject to medical surveillance as
required by subsection (11) of this section.
(ii) This record shall include:
(A) The name, social security number, and description of
the duties of the employee;
(B) A copy of the physician's written opinions;
(C) Results of any airborne exposure monitoring done for
that employee and the representative exposure levels supplied
to the physician; and
(D) Any employee medical complaints related to exposure
to lead.
(iii) The employer shall keep, or assure that the examining
physician keeps, the following medical records:
(A) A copy of the medical examination results including
medical and work history required under subsection (11)
of this section;
(B) A description of the laboratory procedures and a copy
of any standards or guidelines used to interpret the test
results or references to that information; and
(C) A copy of the results of biological monitoring.
(iv) The employer shall maintain or assure that the physician
maintains those medical records for at least forty years,
or for the duration of employment plus twenty years, whichever
is longer.
(c) Medical removals.
(i) The employer shall establish and maintain an accurate
record for each employee removed from current exposure to
lead pursuant to subsection (12) of this section.
(ii) Each record shall include:
(A) The name and social security number of the employee;
(B) The date on each occasion that the employee was removed
from current exposure to lead as well as the corresponding
date on which the employee was returned to his or her former
job status;
(C) A brief explanation of how each removal was or is being
accomplished; and
(D) A statement with respect to each removal indicating
whether or not the reason for the removal was an elevated
blood lead level.
(iii) The employer shall maintain each medical removal record
for at least the duration of an employee's employment.
(d) Availability.
(i) The employer shall make available upon request all records
required to be maintained by subsection (15) of this section
to the director for examination and copying.
(ii) Environmental monitoring, medical removal, and medical
records required by this subsection shall be provided upon
request to employees, designated representatives, and the
assistant director in accordance with WAC 296-62-05201 through
296-62-05209 and 296-62-05213 through 296-62-05217. Medical
removal records shall be provided in the same manner as environmental
monitoring records.
(iii) Upon request, the employer shall make an employee's
medical records required to be maintained by this section
available to the affected employee or former employee or to
a physician or other individual designated by such affected
employee or former employees for examination and copying.
(e) Transfer of records.
(i) Whenever the employer ceases to do business, the successor
employer shall receive and retain all records required to
be maintained by subsection (15) of this section.
(ii) Whenever the employer ceases to do business and there
is no successor employer to receive and retain the records
required to be maintained by this section for the prescribed
period, these records shall be transmitted to the director.
(iii) At the expiration of the retention period for the records
required to be maintained by this section, the employer shall
notify the director at least three months prior to the disposal
of such records and shall transmit those records to the director
if requested within the period.
(iv) The employer shall also comply with any additional requirements
involving transfer of records set forth in WAC 296-62-05215.
(16) Observation of monitoring.
(a) Employee observation. The employer shall provide affected
employees or their designated representatives an opportunity
to observe any monitoring of employee exposure to lead conducted
pursuant to subsection (5) of this section.
(b) Observation procedures.
(i) Whenever observation of the monitoring of employee exposure
to lead requires entry into an area where the use of respirators,
protective clothing or equipment is required, the employer
shall provide the observer with and assure the use of such
respirators, clothing and such equipment, and shall require
the observer to comply with all other applicable safety and
health procedures.
(ii) Without interfering with the monitoring, observers shall
be entitled to:
(A) Receive an explanation of the measurement procedures;
(B) Observe all steps related to the monitoring of lead
performed at the place of exposure; and
(C) Record the results obtained or receive copies of the
results when returned by the laboratory.
(17) Appendices. The information contained in the appendices
to this section is not intended by itself, to create any additional
obligations not otherwise imposed by this standard nor detract
from any existing obligation.
(a) Appendix A. Substance Data Sheet for Occupational Exposure
to Lead.
(i) Substance identification.
(A) Substance. Pure lead (Pb) is a heavy metal at room
temperature and pressure and is a basic chemical element.
It can combine with various other substances to form numerous
lead compounds.
(B) Compounds covered by the standard. The word “lead”
when used in this standard means elemental lead, all inorganic
lead compounds (except those which are not biologically
available due to either solubility or specific chemical
interaction), and a class of organic lead compounds called
lead soaps. This standard does not apply to other organic
lead compounds.
(C) Uses. Exposure to lead occurs in at least 120 different
occupations, including primary and secondary lead smelting,
lead storage battery manufacturing, lead pigment manufacturing
and use, solder manufacturing and use, shipbuilding and
ship repairing, auto manufacturing, and printing.
(D) Permissible exposure. The Permissible Exposure Limit
(PEL) set by the standard is 50 micrograms of lead per cubic
meter of air (50 µg/m3), averaged over an eight-hour
work day.
(E) Action level. The standard establishes an action level
of 30 micrograms per cubic meter of air (30 µg/m3)
time weighted average, based on an eight-hour work day.
The action level initiates several requirements of the standard,
such as exposure monitoring, medical surveillance, and training
and education.
(ii) Health hazard data.
(A) Ways in which lead enters your body.
(I) When absorbed into your body in certain doses lead
is a toxic substance. The object of the lead standard
is to prevent absorption of harmful quantities of lead.
The standard is intended to protect you not only from
the immediate toxic effects of lead, but also from the
serious toxic effects that may not become apparent until
years of exposure have passed.
(II) Lead can be absorbed into your body by inhalation
(breathing) and ingestion (eating). Lead (except for certain
organic lead compounds not covered by the standard, such
as tetraethyl lead) is not absorbed through your skin.
When lead is scattered in the air as a dust, fume or mist,
it can be inhaled and absorbed through your lungs and
upper respiratory tract. Inhalation of airborne lead is
generally the most important source of occupational lead
absorption. You can also absorb lead through your digestive
system if lead gets into your mouth and is swallowed.
If you handle food, cigarettes, chewing tobacco, or make-up
which have lead on them or handle them with hands contaminated
with lead, this will contribute to ingestion.
(III) A significant portion of the lead that you inhale
or ingest gets into your blood stream. Once in your blood
stream lead is circulated throughout your body and stored
in various organs and body tissues. Some of this lead
is quickly filtered out of your body and excreted, but
some remains in your blood and other tissue. As exposure
to lead continues, the amount stored in your body will
increase if you are absorbing more lead than your body
is excreting. Even though you may not be aware of any
immediate symptoms of disease, this lead stored in your
tissues can be slowly causing irreversible damage, first
to individual cells, then to your organs and whole body
systems.
(I) Short-term (acute) overexposure. Lead is a potent,
systemic poison that serves no known useful function once
absorbed by your body. Taken in large enough doses, lead
can kill you in a matter of days. A condition affecting
the brain called acute encephalopathy may arise which
develops quickly to seizures, coma, and death from cardiorespiratory
arrest. A short-term dose of lead can lead to acute encephalopathy.
Short-term occupational exposures of this magnitude are
highly unusual, but not impossible. Similar forms of encephalopathy
may, however arise from extended, chronic exposure to
lower doses of lead. There is no sharp dividing line between
rapidly developing acute effects of lead, and chronic
effects which take longer to acquire. Lead adversely affects
numerous body systems, and causes forms of health impairment
and disease which arise after periods of exposure as short
as days or as long as several years.
(II) Long-term (chronic) overexposure.
a) Chronic overexposure to lead may result in severe
damage to your blood-forming, nervous, urinary and reproductive
systems. Some common symptoms of chronic overexposure
include loss of appetite, metallic taste in the mouth,
anxiety, constipation, nausea, pallor, excessive tiredness,
weakness, insomnia, headache, nervous irritability,
muscle and joint pain or soreness, fine tremors, numbness,
dizziness, hyperactivity and colic. In lead colic there
may be severe abdominal pain.
b) Damage to the central nervous system in general
and the brain (encephalopathy) in particular is one
of the most severe forms of lead poisoning. The most
severe, often fatal, form of encephalopathy may be preceded
by vomiting, a feeling of dullness progressing to drowsiness
and stupor, poor memory, restlessness, irritability,
tremor, and convulsions. It may arise suddenly with
the onset of seizures, followed by coma, and death.
There is a tendency for muscular weakness to develop
at the same time. This weakness may progress to paralysis
often observed as a characteristic “wrist drop”
or “foot drop” and is a manifestation of
a disease to the nervous system called peripheral neuropathy.
c) Chronic overexposure to lead also results in kidney
disease with few, if any, symptoms appearing until extensive
and most likely permanent kidney damage has occurred.
Routine laboratory tests reveal the presence of this
kidney disease only after about two-thirds of kidney
function is lost. When overt symptoms of urinary dysfunction
arise, it is often too late to correct or prevent worsening
conditions, and progression of kidney dialysis or death
is possible.
d) Chronic overexposure to lead impairs the reproductive
systems of both men and women. Overexposure to lead
may result in decreased sex drive, impotence and sterility
in men. Lead can alter the structure of sperm cells
raising the risk of birth defects. There is evidence
of miscarriage and stillbirth in women whose husbands
were exposed to lead or who were exposed to lead themselves.
Lead exposure also may result in decreased fertility,
and abnormal menstrual cycles in women. The course of
pregnancy may be adversely affected by exposure to lead
since lead crosses the placental barrier and poses risks
to developing fetuses. Children born of parents either
one of whom were exposed to excess lead levels are more
likely to have birth defects, mental retardation, behavioral
disorders or die during the first year of childhood.
e) Overexposure to lead also disrupts the blood-forming
system resulting in decreased hemoglobin (the substance
in the blood that carries oxygen to the cells) and ultimately
anemia. Anemiais characterized by weakness, pallor and
fatigability as a result of decreased oxygen carrying
capacity in the blood.
(III) Health protection goals of the standard.
a) Prevention of adverse health effects for most workers
from exposure to lead throughout a working lifetime
requires that worker blood lead (PbB) levels be maintained
at or below forty micrograms per one hundred grams of
whole blood (40 µg/100g). The blood lead levels of workers
(both male and female workers) who intend to have children
should be maintained below 30 µg/100g to minimize adverse
reproductive health effects to the parents and to the
developing fetus.
b) The measurement of your blood lead level is the
most useful indicator of the amount of lead absorbed
by your body. Blood lead levels (PbB) are most often
reported in units of milligrams (mg) or micrograms (µg)
of lead (1 mg = 1000 µg) per 100 grams (100g), 100 milliters
(100 ml) or deciliter (dl) of blood. These three units
are essentially the same. Sometimes PbB's are expressed
in the form of mg% or µg%. This is a shorthand notation
for 100g, 100ml, or dl.
c) PbB measurements show the amount of lead circulating
in your blood stream, but do not give any information
about the amount of lead stored in your various tissues.
PbB measurements merely show current absorption of lead,
not the effect that lead is having on your body or the
effects that past lead exposure may have already caused.
Past research into lead-related diseases, however, has
focused heavily on associations between PbBs and various
diseases. As a result, your PbB is an important indicator
of the likelihood that you will gradually acquire a
lead-related health impairment or disease.
d) Once your blood lead level climbs above 40 µg/100g,
your risk of disease increases. There is a wide variability
of individual response to lead, thus it is difficult
to say that a particular PbB in a given person will
cause a particular effect. Studies have associated fatal
encephalopathy with PbBs as low as 150 µg/100g. Other
studies have shown other forms of disease in some workers
with PbBs well below 80 µg/100g. Your PbB is a crucial
indicator of the risks to your health, but one other
factor is extremely important. This factor is the length
of time you have had elevated PbBs. The longer you have
an elevated PbB, the greater the risk that large quantities
of lead are being gradually stored in your organs and
tissues (body burden). The greater your overall body
burden, the greater the chances of substantial permanent
damage.
e) The best way to prevent all forms of lead-related
impairments and diseases--both short-term and long-term--is
to maintain your PbB below 40 µg/100g. The provisions
of the standard are designed with this end in mind.
Your employer has prime responsibility to assure that
the provisions of the standard are complied with both
by the company and by individual workers.
You as a worker, however, also have a responsibility
to assist your employer in complying with the standard.
You can play a key role in protecting your own health
by learning about the lead hazards and their control,
learning what the standard requires, following the standard
where it governs your own action, and seeing that your
employer complies with the provisions governing his
actions.
(IV) Reporting signs and symptoms of health problems.
You should immediately notify your employer if you develop
signs or symptoms associated with lead poisoning or if
you desire medical advice concerning the effects of current
or past exposure to lead on your ability to have a healthy
child. You should also notify your employer if you have
difficulty breathing during a respirator fit test or while
wearing a respirator. In each of these cases your employer
must make available to you appropriate medical examinations
or consultations. These must be provided at no cost to
you and at a reasonable time and place.
(b) Appendix B. Employee Standard Summary. This appendix summarizes
key provisions of the standard that you as a worker should become
familiar with. The appendix discusses the entire standard.
(i) Permissible exposure limit (PEL). The standard sets a
permissible exposure limit (PEL) of fifty micrograms of lead
per cubic meter of air (50 µg/m3), averaged over
and eight-hour workday. This is the highest level of lead
in air to which you may be permissibly exposed over an eight-hour
workday. Since it is an eight-hour average it permits short
exposures above the PEL so long as for each eight-hour workday
your average exposure does not exceed the PEL.
(ii) Exposure monitoring.
(A) If lead is present in the work place where you work
in any quantity, your employer is required to make an initial
determination of whether the action level is exceeded for
any employee. The initial determination must include instrument
monitoring of the air for the presence of lead and must
cover the exposure of a representative number of employees
who are reasonably believed to have the highest exposure
levels. If your employer has conducted appropriate air sampling
for lead in the past year he may use these results. If there
have been any employee complaints of symptoms which may
be attributable to exposure to lead or if there is any other
information or observations which would indicate employee
exposure to lead, this must also be considered as part of
the initial determination. If this initial determination
shows that a reasonable possibility exists that any employee
may be exposed, without regard to respirators, over the
action level (30 µg/m3) your employer must set
up an air monitoring program to determine the exposure level
of every employee exposed to lead at your work place.
(B) In carrying out this air monitoring program, your employer
is not required to monitor the exposure of every employee,
but he or she must monitor a representative number of employees
and job types. Enough sampling must be done to enable each
employee's exposure level to be reasonably represented by
at least one full shift (at least seven hours) air sample.
In addition, these air samples must be taken under conditions
which represent each employee's regular, daily exposure
to lead.
(C) If you are exposed to lead and air sampling is performed,
your employer is required to quickly notify you in writing
of air monitoring results which represent your exposure.
If the results indicate your exposure exceeds the PEL (without
regard to your use of respirators), then your employer must
also notify you of this in writing, and provide you with
a description of the corrective action that will be taken
to reduce your exposure.
(D) Your exposure must be rechecked by monitoring every
six months if your exposure is over the action level but
below the PEL. Air monitoring must be repeated every three
months if you are exposed over the PEL. Your employer may
discontinue monitoring for you if two consecutive measurements,
taken at least two weeks apart, are below the action level.
However, whenever there is a production, process, control,
or personnel change at your work place which may result
in new or additional exposure to lead, or whenever there
is any other reason to suspect a change which may result
in new or additional exposure to lead, your employer must
perform additional monitoring.
(iii) Methods of compliance. Your employer is required to
assure that no employee is exposed to lead in excess of the
PEL. The standard establishes a priority of methods to be
used to meet the PEL.
(iv) Respiratory protection.
(A) Your employer is required to provide and assure your
use of respirators when your exposure to lead is not controlled
below the PEL by other means. The employer must pay the
cost of the respirator. Whenever you request one, your employer
is also required to provide you a respirator even if your
air exposure level does not exceed the PEL. You might desire
a respirator when, for example, you have received medical
advice that your lead absorption should be decreased. Or,
you may intend to have children in the near future, and
want to reduce the level of lead in your body to minimize
adverse reproductive effects. While respirators are the
least satisfactory means of controlling your exposure, they
are capable of providing significant protection if properly
chosen, fitted, worn, cleaned, maintained, and replaced
when they stop providing adequate protection.
(B) Your employer is required to select respirators from
the seven types listed in Table II of the respiratory protection
section of this standard (see subsection (7)(c) of this
section). Any respirator chosen must be certified by the
National Institute for Occupational Safety and Health (NIOSH)
under the provisions of 42 CFR part 84. This respirator
selection table will enable your employer to choose a type
of respirator which will give you a proper amount of protection
based on your airborne lead exposure. Your employer may
select a type of respirator that provides greater protection
than that required by the standard; that is, one recommended
for a higher concentration of lead than is present in your
work place. For example, a powered air purifying respirator
(PAPR) is much more protective than a typical negative-pressure
respirator, and may also be more comfortable to wear. A
PAPR has a filter, cartridge or canister to clean the air,
and a power source which continuously blows filtered air
into your breathing zone. Your employer might make a PAPR
available to you to ease the burden of having to wear a
respirator for long periods of time. The standard provides
that you can obtain a PAPR upon request.
(C) Your employer must also start a respiratory protection
program. This program must include written procedures for
the proper selection, use, cleaning, storage, and maintenance
of respirators.
(D) Your employer must assure that your respirator facepiece
fits properly. Proper fit of a respirator facepiece is critical
to your protection against air borne lead. Obtaining a proper
fit on each employee may require your employer to make available
several different types of respirator masks. To ensure that
your respirator fits properly and that facepiece leakage
is minimal, your employer must give you either a qualitative
or quantitative fit test as required in chapter 296-842
WAC.
(E) You must also receive from your employer proper training
in the use of respirators. Your employer is required to
teach you how to wear a respirator, to know why it is needed,
and to understand its limitations.
(F) The standard provides that if your respirator uses
filter elements, you must be given an opportunity to change
the filter elements whenever an increase in breathing resistance
is detected. You also must be permitted to periodically
leave your work area to wash your face and respirator facepiece
whenever necessary to prevent skin irritation. If you ever
have difficulty breathing during a fit test or while using
a respirator, your employer must make a medical examination
available to you to determine whether you can safely wear
a respirator. The result of this examination may be to give
you a positive pressure respirator (which reduces breathing
resistance) or to provide alternative means of protection.
(v) Protective work clothing and equipment. If you are exposed
to lead above the PEL, or if you are exposed to lead compounds
such as lead arsenate or lead azide which can cause skin and
eye irritation, your employer must provide you with protective
work clothing and equipment appropriate for the hazard. If
work clothing is provided, it must be provided in a clean
and dry condition at least weekly, and daily if your airborne
exposure to lead is greater than 200 µg/m3. Appropriate
protective work clothing and equipment can include coveralls
or similar full-body work clothing, gloves, hats, shoes or
disposable shoe coverlets, and face shields or vented goggles.
Your employer is required to provide all such equipment at
no cost to you. He or she is responsible for providing repairs
and replacement as necessary and also is responsible for the
cleaning, laundering or disposal of protective clothing and
equipment. Contaminated work clothing or equipment must be
removed in change rooms and not worn home or you will extend
your exposure and expose your family since lead from your
clothing can accumulate in your house, car, etc. Contaminated
clothing which is to be cleaned, laundered or disposed of
must be placed in closed containers in the change room. At
no time may lead be removed from protective clothing or equipment
by any means which disperses lead into the work room air.
(vi) Housekeeping. Your employer must establish a housekeeping
program sufficient to maintain all surfaces as free as practicable
of accumulations of lead dust. Vacuuming is the preferred
method of meeting this requirement, and the use of compressed
air to clean floors and other surfaces is absolutely prohibited.
Dry or wet sweeping, shoveling, or brushing may not be used
except where vacuuming or other equally effective methods
have been tried and do not work. Vacuums must be used and
emptied in a manner which minimizes the reentry of lead into
the work place.
(vii) Hygiene facilities and practices.
(A) The standard requires that change rooms, showers and
filtered air lunchrooms be constructed and made available
to workers exposed to lead above the PEL. When the PEL is
exceeded, the employer must assure that food and beverage
is not present or consumed, tobacco products are not present
or used, and cosmetics are not applied, except in these
facilities. Change rooms, showers and lunchrooms, must be
used by workers exposed in excess of the PEL. After showering
no clothing or equipment worn during the shift may be worn
home and this includes shoes and underwear. Your own clothing
worn during the shift should be carried home and cleaned
carefully so that it does not contaminate your home. Lunchrooms
may not be entered with protective clothing or equipment
unless surface dust has been removed by vacuuming, downdraft
booth or other cleaning methods. Finally, workers exposed
above the PEL must wash both their hands and faces prior
to eating, drinking, smoking or applying cosmetics.
(B) All of the facilities and hygiene practices just discussed
are essential to minimize additional sources of lead absorption
from inhalation or ingestion of lead that may accumulate
on you, your clothes or your possessions. Strict compliance
with these provisions can virtually eliminate several sources
of lead exposure which significantly contribute to excessive
lead absorption.
(viii) Medical surveillance.
(A) The medical surveillance program is part of the standard's
comprehensive approach to the prevention of lead-related
disease. Its purpose is to supplement the main thrust of
the standard which is aimed at minimizing airborne concentrations
of lead and sources of ingestion. Only medical surveillance
can determine if the other provisions of the standard have
effectively protected you as an individual. Compliance with
the standard's provision will protect most workers from
the adverse effects of lead exposure, but may not be satisfactory
to protect individual workers (I) who have high body burdens
of lead acquired over past years, (II) who have additional
uncontrolled sources of nonoccupational lead exposure, (III)
who exhibit unusual variations in lead absorption rates,
or (IV) who have specific nonwork related medical conditions
which could be aggravated by lead exposure (e.g., renal
disease, anemia). In addition, control systems may fail,
or hygiene and respirator programs may be inadequate. Periodic
medical surveillance of individual workers will help detect
those failures. Medical surveillance will also be important
to protect your reproductive ability - regardless of whether
you are a man or a woman.
(B) All medical surveillance required by the standard must
be performed by or under the supervision of a licensed physician.
The employer must provide required medical surveillance
without cost to employees and at a reasonable time and place.
The standard's medical surveillance program has two parts
- periodic biological monitoring, and medical examinations.
(C) Your employer's obligation to offer medical surveillance
is triggered by the results of the air monitoring program.
Medical surveillance must be made available to all employees
who are exposed in excess of the action level for more than
30 days a year. The initial phase of the medical surveillance
program, which included blood lead level tests and medical
examinations, must be completed for all covered employees
no later than 180 days from the effective date of this standard.
Priority within this first round of medical surveillance
must be given to employees whom the employer believes to
be at greatest risk from continued exposure (for example,
those with the longest prior exposure to lead, or those
with the highest current exposure). Thereafter, the employer
must periodically make medical surveillance - both biological
monitoring and medical examinations - available to all covered
employees.
(D) Biological monitoring under the standard consists of
blood lead level (PbB) and zinc protoporphyrin tests at
least every six months after the initial PbB test. A zinc
protoporphyrin (ZPP) test is a very useful blood test which
measures an effect of lead on your body. If a worker's PbB
exceeds 40 µg/100g, the monitoring frequency must be increased
from every six months to at least every two months and not
reduced until two consecutive PbBs indicate a blood lead
level below 40 µg/100g. Each time your PbB is determined
to be over 40µg/100g, your employer must notify you of this
in writing within five working days of the receipt of the
test results. The employer must also inform you that the
standard requires temporary medical removal with economic
protection when your PbB exceeds certain criteria (see Discussion
of Medical Removal Protection - subsection (12)). During
the first year of the standard, this removal criterion is
80 µg/100g. Anytime your PbB exceeds 80 µg/100g your employer
must make available to you a prompt follow-up PbB test to
ascertain your PbB. If the two tests both exceed 80 µg/100g
and you are temporarily removed, then your employer must
make successive PbB tests available to you on a monthly
basis during the period of your removal.
(E) Medical examinations beyond the initial one must be
made available on an annual basis if your blood lead levels
exceeds 40 µg/100g at any time during the preceding year.
The initial examination will provide information to establish
a baseline to which subsequent data can be compared. An
initial medical examination must also be made available
(prior to assignment) for each employee being assigned for
the first time to an area where the airborne concentration
of lead equals or exceeds the action level. In addition,
a medical examination or consultation must be made available
as soon as possible if you notify your employer that you
are experiencing signs or symptoms commonly associated with
lead poisoning or that you have difficulty breathing while
wearing a respirator or during a respirator fit test. You
must also be provided a medical examination or consultation
if you notify your employer that you desire medical advice
concerning the effects of current or past exposure to lead
on your ability to procreate a healthy child.
(F) Finally, appropriate follow-up medical examinations
or consultations may also be provided for employees who
have been temporarily removed from exposure under the medical
removal protection provisions of the standard (see item
(ix) below).
(G) The standard specifies the minimum content of preassignment
and annual medical examinations. The content of other types
of medical examinations and consultations is left up to
the sound discretion of the examining physician. Preassignment
and annual medical examinations must include (I) a detailed
work history and medical history, (II) a thorough physical
examination, and (III) a series of laboratory tests designed
to check your blood chemistry and your kidney function.
In addition, at any time upon your request, a laboratory
evaluation of male fertility will be made (microscopic examination
of a sperm sample), or a pregnancy test will be given.
(H) The standard does not require that you participate
in any of the medical procedures, tests, etc., which your
employer is required to make available to you. Medical surveillance
can, however, play a very important role in protecting your
health.
You are strongly encouraged, therefore, to participate
in a meaningful fashion. Generally, your employer will choose
the physician who conducts medical surveillance under the
lead standard - unless you and your employer can agree on
the choice of a physician or physicians. Some companies
and unions have agreed in advance, for example, to use certain
independent medical laboratories or panels of physicians.
Any of these arrangements are acceptable so long as required
medical surveillance is made available to workers.
(I) The standard requires your employer to provide certain
information to a physician to aid in his or her examination
of you. This information includes (I) the standard and its
appendices, (II) a description of your duties as they relate
to lead exposure, (III) your exposure level, (IV) a description
of personal protective equipment you wear, (V) prior blood
level results, and (VI) prior written medical opinions concerning
you that the employer has.
After a medical examination or consultation the physician
must prepare a written report which must contain (I) the
physician's opinion as to whether you have any medical conditions
which places you at increased risk of material impairment
to health from exposure to lead, (II) any recommended special
protective measures to be provided to you, (III) any blood
lead level determinations, and (IV) any recommended limitation
on your use of respirators. This last element must include
a determination of whether you can wear a powered air purifying
respirator (PAPR) if you are found unable to wear a negative
pressure respirator.
(J) The medical surveillance program of the lead standard
may at some point in time serve to notify certain workers
that they have acquired a disease or other adverse medical
condition as a result of occupational lead exposure. If
this is true these workers might have legal rights to compensation
from public agencies, their employers, firms that supply
hazardous products to their employers, or other persons.
Some states have laws, including worker compensation laws,
that disallow a worker to learn of a job-related health
impairment to sue, unless the worker sues within a short
period of time after learning of the impairment. (This period
of time may be a matter of months or years.) An attorney
can be consulted about these possibilities. It should be
stressed that WISHA is in no way trying to either encourage
or discourage claims or lawsuits. However, since results
of the standard's medical surveillance program can significantly
affect the legal remedies of a worker who has acquired a
job-related disease or impairment, it is proper for WISHA
to make you aware of this.
(K) The medical surveillance section of the standard also
contains provisions dealing with chelation. Chelation is
the use of certain drugs (administered in pill form or injected
into the body) to reduce the amount of lead absorbed in
body tissues. Experience accumulated by the medical and
scientific communities has largely confirmed the effectiveness
of this type of therapy for the treatment of very severe
lead poisoning. On the other hand it has also been established
that there can be a long list of extremely harmful side
effects associated with the use of chelating agents. The
medical community has balanced the advantages and disadvantages
resulting from the use of chelating agents in various circumstances
and has established when the use of these agents is acceptable.
The standard includes these accepted limitations due to
a history of abuse of chelation therapy by some lead companies.
The most widely used chelating agents are calcium disodium
EDTA, (Ca Na2EDTA), Calcium Disodium Versenate (Versenate),
and d-penicillamine (penicillamine or Cupramine).
(L) The standard prohibits “prophylactic chelation”
of any employee by any person the employer retains, supervises
or controls. “Prophylactic chelation” is the
routine use of chelating or similarly acting drugs to prevent
elevated blood levels in workers who are occupationally
exposed to lead, or the use of these drugs to routinely
lower blood lead levels to predesignated concentrations
believed to be safe. It should be emphasized that where
an employer takes a worker who has no symptoms of lead poisoning
and has chelation carried out by a physician (either inside
or outside of a hospital) solely to reduce the worker's
blood lead level, that will generally be considered prophylactic
chelation. The use of a hospital and a physician does not
mean that prophylactic chelation is not being performed.
Routine chelation to prevent increased or reduce current
blood lead levels is unacceptable whatever the setting.
(M) The standard allows the use of “therapeutic”
or “diagnostic” chelation if administered under
the supervision of a licensed physician in a clinical setting
with thorough and appropriate medical monitoring. Therapeutic
chelation responds to severe lead poisoning where there
are marked symptoms. Diagnostic chelation, involves giving
a patient a dose of the drug then collecting all urine excreted
for some period of time as an aid to the diagnosis of lead
poisoning.
(N) In cases where the examining physician determines that
chelation is appropriate, you must be notified in writing
of this fact before such treatment. This will inform you
of a potentially harmful treatment, and allow you to obtain
a second opinion.
(ix) Medical removal protection.
(A) Excessive lead absorption subjects you to increased
risk of disease. Medical removal protection (MRP) is a means
of protecting you when for whatever reasons, other methods,
such as engineering controls, work practices, and respirators,
have failed to provide the protection you need. MRP involves
the temporary removal of a worker from his or her regular
job to a place of significantly lower exposure without any
loss of earnings, seniority, or other employment rights
of benefits. The purpose of this program is to cease further
lead absorption and allow your body to naturally excrete
lead which has previously been absorbed. Temporary medical
removal can result from an elevated blood lead level, or
a medical opinion. Up to eighteen months of protection is
provided as a result of either form of removal. The vast
majority of removed workers, however, will return to their
former jobs long before this eighteen month period expires.
The standard contains special provisions to deal with the
extraordinary but possible case where a long-term worker's
blood lead level does not adequately decline during eighteen
months of removal.
(B) During the first year of the standard, if your blood
lead level is 80 µg/100g or above you must be removed from
any exposure where your air lead level without a respirator
would be 100 µg/m3 or above. If you are removed
from your normal job you may not be returned until your
blood lead level declines to at least 60 µg/100g. These
criteria for removal and return will change according to
the following schedule:
TABLE 1
Effective
Date
Removal
Blood Level (µg/100g)
Air
Lead (µg/m3)
Return
Blood Lead (µg/m3)
09/06/81
At or
above 70
50 or
above
At or
below 50
09/06/82
At or
above 60
30 or
above
At or
below 40
09/06/84
At or
above 50 averaged over six months
30 or
above
At or
below 40
(C) You may also be removed from exposure even if your
blood lead levels are below these criteria if a final medical
determination indicates that you temporarily need reduced
lead exposure for medical reasons. If the physician who
is implementing your employers medical program makes a final
written opinion recommending your removal or other special
protective measures, your employer must implement the physician's
recommendation. If you are removed in this manner, you may
only be returned when the physician indicates it is safe
for you to do so.
(D) The standard does not give specific instructions dealing
with what an employer must do with a removed worker. Your
job assignment upon removal is a matter for you, your employer
and your union (if any) to work out consistent with existing
procedures for job assignments. Each removal must be accomplished
in a manner consistent with existing collective bargaining
relationships. Your employer is given broad discretion to
implement temporary removals so long as no attempt is made
to override existing agreements. Similarly, a removed worker
is provided no right to veto an employer's choice which
satisfies the standard.
(E) In most cases, employers will likely transfer removed
employees to other jobs with sufficiently low lead exposure.
Alternatively, a worker's hours may be reduced so that the
time weighted average exposure is reduced, or he or she
may be temporarily laid off if no other alternative is feasible.
(F) In all of these situations, MRP benefits must be provided
during the period of removal - i.e., you continue to receive
the same earnings, seniority, and other rights and benefits
you would have had if you had not been removed. Earnings
include more that just your base wage; it includes overtime,
shift differentials, incentives, and other compensation
you would have earned if you had not been removed.
During the period of removal you must also be provided
with appropriate follow-up medical surveillance. If you
were removed because your blood lead level was too high,
you must be provided with a monthly blood test. If a medical
opinion caused your removal, you must be provided medical
tests or examinations that the physician believes to be
appropriate. If you do not participate in this follow-up
medical surveillance, you may lose your eligibility for
MRP benefits.
(G) When you are medically eligible to return to your former
job, your employer must return you to your “former
job status.” This means that you are entitled to the
position, wages, benefits, etc., you would have had if you
had not been removed. If you would still be in your old
job if no removal had occurred, that is where you go back.
If not, you are returned consistent with whatever job assignment
discretion your employer would have had if no removal had
occurred. MRP only seeks to maintain your rights, not expand
them or diminish them.
(H) If you are removed under MRP and you are also eligible
for worker compensation or other compensation for lost wages,
your employer's MRP benefits obligation is reduced by the
amount that you actually receive from these other sources.
This is also true if you obtain other employment during
the time you are laid off with MRP benefits.
(I) The standard also covers situations where an employer
voluntarily removes a worker from exposure to lead due to
the effects of lead on the employee's medical condition,
even though the standard does not require removal. In these
situations MRP benefits must still be provided as though
the standard required removal. Finally, it is important
to note that in all cases where removal is required, respirators
cannot be used as a substitute. Respirators may be used
before removal becomes necessary, but not as an alternative
to a transfer to a low exposure job, or to a lay-off with
MRP benefits.
(x) Employee information and training.
(A) Your employer is required to provide an information
and training program for all employees exposed to lead above
the action level or who may suffer skin or eye irritation
from lead. This program must inform these employees of the
specific hazards associated with their work environment,
protective measures which can be taken, the danger of lead
to their bodies (including their reproductive systems),
and their rights under the standard. In addition, your employer
must make readily available to all employees, included those
exposed below the action level, a copy of the standard and
its appendices and must distribute to all employees any
materials provided to the employer under the Washington
Industrial Safety and Health Act (WISHA).
(B) Your employer is required to complete this training
for all employees by March 4, 1981. After this date, all
new employees must be trained prior to initial assignment
to areas where there is possibility of exposure over the
action level. This training program must also be provided
at least annually thereafter.
(xi) Signs. The standard requires that the following warning
sign be posted in work areas where the exposure to lead exceeds
the PEL:
WARNING
LEAD WORK AREA
NO SMOKING OR EATING
(xii) Recordkeeping.
(A) Your employer is required to keep all records of exposure
monitoring for airborne lead. These records must include
the name and job classification of employees measured, details
of the sampling and analytic techniques, the results of
this sampling and the type of respiratory protection being
worn by the person sampled. Your employer is also required
to keep all records of biological monitoring and medical
examination results. These must include the names of the
employees, the physician's written opinion and a copy of
the results of the examination. All of the above kinds of
records must be kept for 40 years, or for at least 20 years
after your termination of employment, whichever is longer.
(B) Recordkeeping is also required if you are temporarily
removed from your job under the MRP program. This record
must include your name and social security number, the date
of your removal and return, how the removal was or is being
accomplished, and whether or not the reason for the removal
was an elevated blood lead level. Your employer is required
to keep each medical removal record only for as long as
the duration of an employee's employment.
(C) The standard requires that if you request to see or
copy environmental monitoring, blood lead level monitoring,
or medical removal records, they must be made available
to you or to a representative that you authorize. Your union
also has access to these records. Medical records other
than PbBs must also be provided to you upon request, to
your physician or to any other person whom you may specifically
designate. Your union does not have access to your personal
medical records unless you authorize their access.
(xiii) Observations of monitoring. When air monitoring for
lead is performed at your work place as required by this standard,
your employer must allow you or someone you designate to act
as an observer of the monitoring. Observers are entitled to
an explanation of the measurement procedure, and to record
the results obtained. Since results will not normally be available
at the time of the monitoring, observers are entitled to record
or receive the results of the monitoring when returned by
the laboratory. Your employer is required to provide the observer
with any personal protective devices required to be worn by
employees working in the areas that is being monitored. The
employer must require the observer to wear all such equipment
and to comply with all other applicable safety and health
procedures.
(xiv) Effective date. The standard's effective date is September
6, 1980, and the employer's obligation under the standard
begin to come into effect as of that date. The standard was
originally adopted as WAC 296-62-07349 and later recodified
to WAC 296-62-07521.
(c) Appendix C. Medical Surveillance Guidelines.
(i) Introduction.
(A) The primary purpose of the Washington Industrial Safety
and Health Act of 1973 is to assure, so far as possible,
safe and healthful working conditions for every working
man and woman. The occupational health standard for inorganic
lead* was promulgated to protect workers exposed to inorganic
lead including metallic lead, all inorganic lead compounds
and organic lead soaps.
*The term inorganic lead used throughout the medical surveillance
appendices is meant to be synonymous with the definition
of lead set forth in the standard.
(B) Under this final standard in effect as of September
6, 1980, occupational exposure to inorganic lead is to be
limited to 50 µg/m3 (micrograms per cubic meter)
based on an eight-hour time-weighted average (TWA). This
level of exposure eventually must be achieved through a
combination of engineering, work practice and other administrative
controls. Periods of time ranging from one to ten years
are provided for different industries to implement these
controls which are based on individual industry considerations.
Until these controls are in place, respirators must be used
to meet the 50 µg/m3 exposure limit.
(C) The standard also provides for a program of biological
monitoring and medical surveillance for all employees exposed
to levels of inorganic lead above the action level of 30
µg/m3 for more than thirty days per year.
(D) The purpose of this document is to outline the medical
surveillance provisions of the standard for inorganic lead,
and to provide further information to the physician regarding
the examination and evaluation of workers exposed to inorganic
lead.
(E) Item (ii) provides a detailed description of the monitoring
procedure including the required frequency of blood testing
for exposed workers, provisions for medical removal protection
(MRP), the recommended right of the employee to a second
medical opinion, and notification and recordkeeping requirements
of the employer.
A discussion of the requirements for respirator use and
respirator monitoring and WISHA's position on prophylactic
chelation therapy are also included in this section.
(F) Item (iii) discusses the toxic effects and clinical
manifestations of lead poisoning and effects of lead intoxication
on enzymatic pathways in heme synthesis. The adverse effects
on both male and female reproductive capacity and on the
fetus are also discussed.
(G) Item (iv) outlines the recommended medical evaluation
of the worker exposed to inorganic lead including details
of the medical history, physical examination, and recommended
laboratory tests, which are based on the toxic effects of
lead as discussed in item (ii).
(H) Item (v) provides detailed information concerning the
laboratory tests available for the monitoring of exposed
workers. Included also is a discussion of the relative value
of each test and the limitations and precautions which are
necessary in the interpretation of the laboratory results.
(I) Airborne levels to be achieved without reliance or
respirator protection through a combination of engineering
and work practice or other administrative controls are illustrated
in the following table:
Industry
Permissible
Lead Level/Compliance Date
200µg/m3
100µg/m3
50µg/m3
Primary
Lead Production.
1973
06/29/84
06/29/91
Secondary
Lead Production.
1973
06/29/84
06/29/91
Lead Acid
Battery Manufacturing.
1973
06/29/83
06/29/91
Automobile
Mfg,/ Solder, Grinding.
1973
N/A
03/08/97
Electronics,
Gray Iron Foundries, Ink Mfg., Paints and Coatings Mfg.,
Can Mfg., Wallpaper Mfg., and Printing.
1973
N/A
06/29/91
Lead chemical
Mfg., Nonferrous Foundries, Leaded Steel Mfg., Battery
Breaking in the Collection and Processing of Scrap (when
not a part of secondary lead smelter), Secondary Copper
Smelter, Brass and Bronze Ingot Production.
1973
N/A
N/A1*
All Other
Industries.
1973
N/A
09/08/92
* Feasibility of achieving the PEL by engineering and work practice
controls for these industries has yet to be resolved in court,
therefore no date has been scheduled.
(ii) Medical surveillance and monitoring requirements for
workers exposed to inorganic lead.
(A) Under the occupational health standard for inorganic
lead, a program of biological monitoring and medical surveillance
is to be made available to all employees exposed to lead
above the action level of 30 µg/m3 TWA for more
than thirty days each year. This program consists of periodic
blood sampling and medical evaluation to be performed on
a schedule which is defined by previous laboratory results,
worker complaints or concerns, and the clinical assessment
of the examining physician.
(B) Under this program, the blood lead level of all employees
who are exposed to lead above the action level of 30 µg/m3
is to be determined at least every six months. The frequency
is increased to every two months for employees whose last
blood lead level was between 40µg/100g whole blood and the
level requiring employee medical removal to be discussed
below. For employees who are removed from exposure to lead
due to an elevated blood lead, a new blood lead level must
be measured monthly. Zinc protoporphyrin (ZPP) measurement
is required on each occasion that a blood lead level measurement
is made.
(C) An annual medical examination and consultation performed
under the guidelines discussed in item (iv) is to be made
available to each employee for whom a blood test conducted
at any time during the preceding twelve months indicated
a blood lead level at or above 40µg/100g. Also, an examination
is to be given to all employees prior to their assignment
to an area in which airborne lead concentrations reach or
exceed the action level. In addition, a medical examination
must be provided as soon as possible after notification
by an employee that the employee has developed signs or
symptoms commonly associated with lead intoxication, that
the employee desires medical advice regarding lead exposure
and the ability to procreate a healthy child, or that the
employee has demonstrated difficulty in breathing during
a respirator fitting test or during respirator use. An examination
is also to be made available to each employee removed from
exposure to lead due to a risk of sustaining material impairment
to health, or otherwise limited or specially protected pursuant
to medical recommendations.
(D) Results of biological monitoring or the recommendations
of an examining physician may necessitate removal of an
employee from further lead exposure pursuant to the standard's
medical removal program (MRP). The object of the MRP program
is to provide temporary medical removals to workers either
with substantially elevated blood lead levels or otherwise
at risk of sustaining material health impairment from continued
substantial exposure to lead. The following guidelines which
are summarized in Table 10 were created under the standard
for the temporary removal of an exposed employee and his
or her subsequent return to work in an exposure area.
TABLE 10
EFFECTIVE DATE
Sept.
6, 1980
Sept.
6, 1981
Sept.
6, 1982
Sept.
6, 1983
Sept.
6, 1984
A. Blood lead level requiring
employee medical removal (level must be confirmed with
second follow-up blood lead level within two weeks of
first report).
>80 µg/100g.
>70 µg/100g.
>60 µg/100g.
>60 µg/100g.
>60 µg/100g or average
of last three blood samples or all blood samples over
previous 6 months (whichever is over a longer time period)
is 50 µg/100g or greater unless last sample is 40 µg/100g
or less.
B. Frequency which employees
exposed is action level of lead (30 µg/m8 TWA)
must have blood lead level checked. (ZPP is also required
in each occasion that a blood test is obtained):
1. Last blood lead level
less than 40 µg/100g.
Every 6 months
Every 6 months.
Every 6 months.
Every 6 months.
Every 6 months.
2. Last blood lead level
between 40 µg/100g and level requiring medical removal
(see A above).
Every 2 months.
Every 2 months.
Every 2 months.
Every 2 months.
Every 2 months.
3. Employees removed
from exposure to lead because of an elevated blood lead
level.
Every 1 month.
Every 1 month.
Every 1 month.
Every 1 month.
Every 1 month.
C. Permissible airborne
exposure limit for workers removed from work due to
an elevated blood lead level (without regard to respirator
protection.
100 µg/m3
8 hr TWA
50 µg/m3 8
hr TWA
30 µg/m3 8
hr TWA
30 µg/m3 8
hr TWA
30 µg/m3 8
hr TWA
D. Blood lead level confirmed
with a second blood analysis, at which employee may
return to work. Permissible exposure without regard
to respirator protection is listed by industry in Table
1
60 µg/100g
50 µg/100g
40 µg/100g
40 µg/100g
40 µg/100g
Note: Where medical opinion indicates that
an employee is at risk of material impairment from exposure to
lead, the physician can remove an employee from exposure exceeding
the action level (or less) or recommend special protective measures
as deemed appropriate and necessary. Medical monitoring during
the medical removal period can be more stringent than noted in
the table above if the physician so specifies. Return to work
or removal of limitations and special protections is permitted
when the physician indicates that the worker is no longer at risk
of material impairment.
(E) Under the standard's ultimate worker removal criteria,
a worker is to be removed from any work having any eight-hour
TWA exposure to lead of 30 µg/m3 or more whenever
either of the following circumstances apply. (I) a blood
lead level of 60 µg/100g or greater is obtained and confirmed
by a second follow-up blood lead level performed within
two weeks after the employer receives the results of the
first blood sample test, or (II) the average of the previous
three blood lead determinations or the average of all blood
lead determinations conducted during the previous six months,
whichever encompasses the longest time period, equals or
exceeds 50 µg/100g, unless the last blood sample indicates
a blood lead level at or below 40 µg/100g, in which case
the employee need not be removed. Medical removal is to
continue until two consecutive blood lead levels are 40
µg/100g or less.
(F) During the first two years that the ultimate removal
criteria are being phased in, the return criteria have been
set to assure that a worker's blood lead level has substantially
declined during the period of removal. From March 1, 1979,
to March 1, 1980, the blood lead level requiring employee
medial removal is 80 µg/100g. Workers found to have a confirmed
blood lead at this level or greater need only be removed
from work having a daily eight hour TWA exposure to lead
at or above 100 µg/m3. Workers so removed are
to be returned to work when their blood lead levels are
at or below 60 µg/100g of whole blood. From March 1, 1980,
to March 1, 1981, the blood lead level requiring medical
removal is 70 µg/100g. During this period workers need only
be removed from jobs having a daily eight hour TWA exposure
to lead at or above 50 µg/m3 and are to be returned
to work when a level of 50 µg/100g is achieved. Beginning
March 1, 1981, return depends on the worker's blood lead
level declining to 40 µg/100g of whole blood.
(G) As part of the standard, the employer is required to
notify in writing each employee whose whole blood lead level
exceeds 40 mg/100g. In addition, each such employee is to
be informed that the standard requires medical removal with
MRP benefits, discussed below, when an employee's blood
lead level exceeds the above defined limits.
(H) In addition to the above blood lead level criteria,
temporary worker removal may also take place as a result
of medical determinations and recommendations. Written medical
opinions must be prepared after each examination pursuant
to the standard. If the examining physician includes medical
finding, determination or opinion that the employee has
a medical condition which places the employee at increased
risk of material health impairment from exposure to lead,
then the employee must be removed from exposure to lead
at or above the action level. Alternatively, if the examining
physician recommends special protective measures for an
employee (e.g., use of a powered air purifying respirator)
or recommends limitations on an employee's exposure to lead,
then the employer must implement these recommendations.
Recommendations may be more stringent than the specific
provisions of the standard. The examining physician, therefore,
is given broad flexibility to tailor special protective
procedures to the needs of individual employees. This flexibility
extends to the evaluation and management of pregnant workers
and male and female workers who are planning to conceive
children. Based on the history, physical examination, and
laboratory studies, the physician might recommend special
protective measures or medical removal for an employee who
is pregnant or who is planning to conceive a child when,
in the physician's judgment, continued exposure to lead
at the current job would pose a significant risk. The return
of the employee to his or her former job status, or the
removal of special protections or limitations, depends upon
the examining physician determining that the employee is
no longer at increased risk of material impairment or that
the special measures are no longer needed.
(I) During the period of any form of special protection
or removal, the employer must maintain the worker's earnings,
seniority, and other employment rights and benefits (as
though the worker has not been removed) for a period of
up to eighteen months. This economic protection will maximize
meaningful worker participation in the medical surveillance
program, and is appropriate as part of the employer's overall
obligation to provide a safe and healthful work place. The
provisions of MRP benefits during the employee's removal
period may, however, be conditioned upon participation in
medical surveillance.
(J) On rare occasions, an employee's blood lead level may
not acceptably decline within eighteen months of removal.
This situation will arise only in unusual circumstances,
thus the standard relies on an individual medical examination
to determine how to protect such an employee. This medical
determination is to be based on both laboratory values,
including lead levels, zinc protoporphyrin levels, blood
counts, and other tests felt to be warranted, as well as
the physician's judgment that any symptoms or findings on
physical examination are a result of lead toxicity. The
medical determination may be that the employee is incapable
of ever safely returning to his or her former job status.
The medical determination may provide additional removal
time past eighteen months for some employees or specify
special protective measures to be implemented.
(K) The lead standard provides for a multiple physician
review in cases where the employee wishes a second opinion
concerning potential lead poisoning or toxicity. If an employee
wishes a second opinion, he or she can make an appointment
with a physician of his or her choice. This second physician
will review the findings, recommendations or determinations
of the first physician and conduct any examinations, consultations
or tests deemed necessary in an attempt to make a final
medical determination. If the first and second physicians
do not agree in their assessment they must try to resolve
their differences. If they cannot reach an agreement then
they must designate a third physician to resolve the dispute.
(L) The employer must provide examining and consulting
physicians with the following specific information: A copy
of the lead regulations and all appendices, a description
of the employee's duties as related to exposure, the exposure
level to lead and any other toxic substances (if applicable),
a description of personal protective equipment used, blood
lead levels, and all prior written medical opinions regarding
the employee in the employer's possession or control. The
employer must also obtain from the physician and provide
the employee with a written medical opinion containing blood
lead levels, the physician's opinion as to whether the employee
is at risk of material impairment to health, any recommended
protective measures for the employee if further exposure
is permitted, as well as any recommended limitations upon
an employee's use of respirators.
(M) Employers must instruct each physician not to reveal
to the employer in writing or in any other way his or her
findings, laboratory results, or diagnoses which are felt
to be unrelated to occupational lead exposure. They must
also instruct each physician to advise the employee of any
occupationally or nonoccupationally related medical condition
requiring further treatment or evaluation.
(N) The standard provides for the use of respirators when
engineering and other primary controls have not been fully
implemented. However, the use of respirator protection shall
not be used in lieu of temporary medical removal due to
elevated blood lead levels or findings that an employee
is at risk of material health impairment. This is based
on the numerous inadequacies of respirators including skin
rash where the facepiece makes contact with the skin, unacceptable
stress to breathing in some workers with underlying cardiopulmonary
impairment, difficulty in providing adequate fit, the tendency
for respirators to create additional hazards by interfering
with vision, hearing, and mobility, and the difficulties
of assuring the maximum effectiveness of a complicated work
practice program involving respirators. Respirators do,
however, serve a useful function where engineering and work
practice are inadequate by providing interim or short-term
protection, provided they are properly selected for the
environment in which the employee will be working, properly
fitted to the employee, maintained and cleaned periodically,
and worn by the employee when required.
(O) In its final standard on occupational exposure to inorganic
lead, WISHA has prohibited prophylactic chelation. Diagnostic
and therapeutic chelation are permitted only under the supervision
of a licensed physician with appropriate medical monitoring
in an acceptable clinical setting. The decision to initiate
chelation therapy must be made on an individual basis and
take into account the severity of symptoms felt to be a
result of lead toxicity along with blood lead levels, ZPP
levels and other laboratory tests as appropriate. EDTA and
penicillamine, which are the primary chelating agents used
in the therapy of occupational lead poisoning, have significant
potential side effects and their use must be justified on
the basis of expected benefits to the worker.
(P) Unless frank and severe symptoms are present, therapeutic
chelation is not recommended given the opportunity to remove
a worker from exposure and allow the body to naturally excrete
accumulated lead. As a diagnostic aid, the chelation mobilization
test using CA-EDTA has limited applicability. According
to some investigators, the tests can differentiate between
lead-induced and other nephropathies. The test may also
provide an estimation of the mobile fraction of the total
body lead burden.
(Q) Employers are required to assure that accurate records
are maintained on exposure monitoring, medical surveillance,
and medical removal for each employee. Exposure monitoring
and medical surveillance records must be kept for forty
years or the duration of employment plus twenty years, whichever
is longer, while medical removal records must be maintained
for the duration of employment. All records required under
the standard must be made available upon request to representatives
of the director of the department of labor and industries.
Employers must also make environmental and biological monitoring
and medical removal records available to affected employees
and to former employees or their authorized employee representatives.
Employees or their specifically designated representatives
have access to their entire medical surveillance records.
(R) In addition, the standard requires that the employer
inform all workers exposed to lead at or above the action
level of the provisions of the standard and all its appendices,
the purpose and description of medical surveillance and
provisions for medical removal protection if temporary removal
is required. An understanding of the potential health effects
of lead exposure by all exposed employees along with full
understanding of their rights under the lead standard is
essential for an effective monitoring program.
(iii) Adverse health effects of inorganic lead.
(A) Although the toxicity of lead has been known for 2,000
years, the knowledge of the complex relationship between
lead exposure and human response is still being refined.
Significant research into the toxic properties of lead continues
throughout the world, and it should be anticipated that
our understanding of thresholds of effects and margins of
safety will be improved in future years. The provisions
of the lead standard are founded on two prime medical judgments;
first, the prevention of adverse health effects from exposure
to lead throughout a working lifetime requires that worker
blood lead levels be maintained at or below 40 µg/100g,
and second, the blood lead levels of workers, male or female,
who intend to parent in the near future should be maintained
below 30 µg/100g to minimize adverse reproduction health
effects to the parent and developing fetus. The adverse
effects of lead on reproduction are being actively researched
and WISHA encourages the physician to remain abreast of
recent developments in the area to best advise pregnant
workers or workers planning to conceive children.
(B) The spectrum of health effects caused by lead exposure
can be sub-divided into five developmental states; normal,
physiological changes of uncertain significance, pathophysiological
changes, overt symptoms (morbidity), and mortality. Within
this process there are no sharp distinctions, but rather
a continuum of effects. Boundaries between categories overlap
due to the wide variation of individual responses and exposures
in the working population. WISHA's development of the lead
standard focused on pathophysiological changes as well as
later stages of disease.
(I) Heme synthesis inhibition.
a) The earliest demonstrated effect of lead involves
its ability to inhibit at least two enzymes of the heme
synthesis pathway at very low blood levels. Inhibition
of delta aminolevulinic acid dehydrase (ALA-D) which
catalyzes the conversion of delta-aminolevulinic acid
(ALA) to protoporphyrin is observed at a blood lead
level below 20µg/100g whole blood. At a blood lead level
of 40 µg/100g, more than twenty percent of the population
would have seventy percent inhibition of ALA-D. There
is an exponential increase in ALA excretion at blood
lead levels greater than 40 µg/100g.
b) Another enzyme, ferrochelatase, is also inhibited
at low blood lead levels. Inhibition of ferrochelatase
leads to increased free erythrocyte protoporphyrin (FEP)
in the blood which can then bind to zinc to yield zinc
protoporphyrin. At a blood lead level of 50µg/100g or
greater, nearly 100 percent of the population will have
an increase FEP. There is also an exponential relationship
between blood lead levels greater than 40 µg/100g and
the associated ZPP level, which has led to the development
of the ZPP screening test for lead exposure.
(c) While the significance of these effects is subject
to debate, it is WISHA's position that these enzyme
disturbances are early stages of a disease process which
may eventually result in the clinical symptoms of lead
poisoning. Whether or not the effects do progress to
the later stages of clinical disease, disruption of
these enzyme processes over a working lifetime is considered
to be a material impairment of health.
d) One of the eventual results of lead-induced inhibition
of enzymes in the heme synthesis pathway is anemia which
can be asymptomatic if mild but associated with a wide
array of symptoms including dizziness, fatigue, and
tachycardia when more severe. Studies have indicated
that lead levels as low as 50 µg/100g can be associated
with a definite decreased hemoglobin, although most
cases of lead-induced anemia, as well as shortened red-cell
survival times, occur at lead levels exceeding 80 µg/100g.
Inhibited hemoglobin synthesis is more common in chronic
cases whereas shortened erythrocyte life span is more
common in acute cases.
e) In lead-induced anemias, there is usually a reticulocytosis
along with the presence of basophilic stippling, and
ringed sideroblasts, although none of the above are
pathognomonic for lead-induced anemia.
(II) Neurological effects.
a) Inorganic lead had been found to have toxic effects
on both the central and peripheral nervous systems.
The earliest stage of lead-induced central nervous system
effects first manifest themselves in the form of behavioral
disturbances and central nervous system symptoms including
irritability, restlessness, insomnia and other sleep
disturbances, fatigue, vertigo, headache, poor memory,
tremor, depression, and apathy. With more severe exposure,
symptoms can progress to drowsiness, stupor, hallucinations,
delirium, convulsions and coma.
b) The most severe and acute form of lead poisoning
which usually follows ingestion or inhalation of large
amounts of lead is acute encephalopathy which may arise
precipitously with the onset of intractable seizures,
coma, cardiorespiratory arrest, and death within 48
hours.
c) While there is disagreement about what exposure
levels are needed to produce the earliest symptoms,
most experts agree that symptoms definitely can occur
at blood lead levels of 60 µg/100g whole blood and therefore
recommend a 40 µg/100g maximum. The central nervous
system effects frequently are not reversible following
discontinued exposure or chelation therapy and when
improvement does occur, it is almost always only partial.
d) The peripheral neuropathy resulting from lead exposure
characteristically involves only motor function with
minimal sensory damage and has a marked predilection
for the extensor muscles of the most active extremity.
The peripheral neuropathy can occur with varying degrees
of severity. The earliest and mildest form which can
be detected in workers with blood lead levels as low
as 50 µg/100g is manifested by slowing or motor nerve
conduction velocity often without clinical symptoms.
With progression of the neuropathy there is development
of painless extensor muscle weakness usually involving
the extensor muscles of the fingers and hand in the
most active upper extremity, followed in severe cases
by wrist drop, much less commonly, foot drop.
e) In addition to slowing of nerve conduction, electromyographical
studies in patients with blood lead levels greater than
50 µg/100g have demonstrated a decrease in the number
of acting motor unit potentials, an increase in the
duration of motor unit potentials, and spontaneous pathological
activity including fibrillations and fasciculation.
Whether these effects occur at levels of 40 µg/100g
is undetermined.
f) While the peripheral neuropathies can occasionally
be reversed with therapy, again such recovery is not
assured particularly in the more severe neuropathies
and often improvement is only partial. The lack of reversibility
is felt to be due in part to segmental demyelination.
(III) Gastrointestinal. Lead may also effect the gastrointestinal
system producing abdominal colic or diffuse abdominal
pain, constipation, obstipation, diarrhea, anorexia, nausea
and vomiting. Lead colic rarely develops at blood lead
levels below 80 µg/100g.
(IV) Renal.
a) Renal toxicity represents one of the most serious
health effects of lead poisoning. In the early stages
of disease nuclear inclusion bodies can frequently be
identified in proximal renal tubular cells. Renal functions
remain normal and the changes in this stage are probably
reversible. With more advanced disease there is progressive
interstitial fibrosis and impaired renal function. Eventually
extensive interstitial fibrosis ensues with sclerotic
glomeruli and dilated and atrophied proximal tubules;
all represent end stage kidney disease. Azotemia can
be progressive, eventually resulting in frank uremia
necessitating dialysis. There is occasionally associated
hypertension and hyperuricemia with or without gout.
b) Early kidney disease is difficult to detect. The
urinalysis is normal in early lead nephropathy and the
blood urea nitrogen and serum creatinine increase only
when two-thirds of kidney function is lost. Measurement
of creatinine clearance can often detect earlier disease
as can other methods of measurement of glomerular filtration
rate. An abnormal Ca-EDTA mobilization test has been
used to differentiate between lead-induced and other
nephropathies, but this procedure is not widely accepted.
A form of Fanconi syndrome with aminoaciduria, glycosuria,
and hyperphosphaturia indicating severe injury to the
proximal renal tubules is occasionally seen in children.
(V) Reproductive effects.
a) Exposure to lead can have serious effects on reproductive
function in both males and females. In male workers
exposed to lead there can be a decrease in sexual drive,
impotence, decreased ability to produce healthy sperm,
and sterility. Malformed sperm (teratospermia), decreased
number of sperm (hypospermia), and sperm with decreased
motility (asthenospermia) can occur. Teratospermia has
been noted at mean blood lead levels of 53 µg/100g and
hypospermia and asthenospermia at 41 µg/100g. Furthermore,
there appears to be a dose-response relationship for
teratospermia in lead exposed workers.
b) Women exposed to lead may experience menstrual disturbances
including dysmenorrhea, menorrhagia and amenorrhea.
Following exposure to lead, women have a higher frequency
of sterility, premature births, spontaneous miscarriages,
and stillbirths.
c) Germ cells can be affected by lead and cause genetic
damage in the egg or sperm cells before conception and
result in failure to implant, miscarriage, stillbirth,
or birth defects.
d) Infants of mothers with lead poisoning have a higher
mortality during the first year and suffer from lowered
birth weights, slower growth, and nervous system disorders.
e) Lead can pass through the placental barrier and
lead levels in the mother's blood are comparable to
concentrations of lead in the umbilical cord at birth.
Transplacental passage becomes detectable at 12-14 weeks
of gestation and increases until birth.
f) There is little direct data on damage to the fetus
from exposure to lead but it is generally assumed that
the fetus and newborn would be at least as susceptible
to neurological damage as young children. Blood lead
levels of 50-60 µg/100g in children can cause significant
neurobehavioral impairments, and there is evidence of
hyperactivity at blood levels as low as 25 µg/100g.
Given the overall body of literature concerning the
adverse health effects of lead in children, WISHA feels
that the blood lead level in children should be maintained
below 30 µg/100g with a population mean of 15 µg/100g.
Blood lead levels in the fetus and newborn likewise
should not exceed 30 µg/100g.
g) Because of lead's ability to pass through the placental
barrier and also because of the demonstrated adverse
effects of lead on reproductive function in both males
and females as well as the risk of genetic damage of
lead on both the ovum and sperm, WISHA recommends a
30 µg/100g maximum permissible blood lead level in both
males and females who wish to bear children.
(VI) Other toxic effects.
a) Debate and research continue on the effects of lead
on the human body. Hypertension has frequently been
noted in occupationally exposed individuals although
it is difficult to assess whether this is due to lead's
adverse effects on the kidneys or if some other mechanism
is involved.
b) Vascular and electrocardiographic changes have been
detected but have not been well characterized. Lead
is thought to impair thyroid function and interfere
with the pituitary-adrenal axis, but again these effects
have not been well defined.
(iv) Medical evaluation.
(A) The most important principle in evaluating a worker
for any occupational disease including lead poisoning is
a high index of suspicion on the part of the examining physician.
As discussed in Section (ii), lead can affect numerous organ
systems and produce a wide array of signs and symptoms,
most of which are nonspecific and subtle in nature at least
in the early stages of disease. Unless serious concern for
lead toxicity is present, many of the early clues to diagnosis
may easily be overlooked.
(B) The crucial initial step in the medical evaluation
is recognizing that a worker's employment can result in
exposure to lead. The worker will frequently be able to
define exposures to lead and lead-containing materials but
often will not volunteer this information unless specifically
asked. In other situations the worker may not know of any
exposures to lead but the suspicion might be raised on the
part of the physician because of the industry or occupation
of the worker. Potential occupational exposure to lead and
its compounds occur in at least 120 occupations, including
lead smelting, the manufacture of lead storage batteries,
the manufacture of lead pigments and products containing
pigments, solder manufacture, shipbuilding and ship repair,
auto manufacturing, construction, and painting.
(C) Once the possibility for lead exposure is raised, the
focus can then be directed toward eliciting information
from the medical history, physical exam, and finally from
laboratory data to evaluate the worker for potential lead
toxicity.
(D) A complete and detailed work history is important in
the initial evaluation. A listing of all previous employment
with information on work processes, exposure to fumes or
dust, known exposures to lead or other toxic substances,
respiratory protection used, and previous medical surveillance
should all be included in the worker's record. Where exposure
to lead is suspected, information concerning on-the-job
personal hygiene, smoking or eating habits in work areas,
laundry procedures, and use of any protective clothing or
respiratory protection equipment should be noted. A complete
work history is essential in the medical evaluation of a
worker with suspected lead toxicity, especially when long-term
effects such as neurotoxicity and nephrotoxicity are considered.
(E) The medical history is also of fundamental importance
and should include a listing of all past and current medical
conditions, current medications including proprietary drug
intake, previous surgeries and hospitalizations, allergies,
smoking history, alcohol consumption, and also nonoccupational
lead exposures such as hobbies (hunting, riflery). Also
known childhood exposures should be elicited. Any previous
history of hematological, neurological, gastrointestinal,
renal, psychological, gynecological, genetic, or reproductive
problems should be specifically noted.
(F) A careful and complete review of systems must be performed
to assess both recognized complaints and subtle or slowly
acquired symptoms which the worker might not appreciate
as being significant. The review of symptoms should include
the following:
General
Weight
Loss, Fatigue, Decreased Appetite.
Head, Eyes, Ears, Nose,
Throat (HEENT)
Headaches, visual disturbance
or decreased visual acuity, hearing deficits or tinnitus,
pigmentation of the oral mucosa, or metallic taste
in mouth.
Cardio-pulmonary
Shortness of breath,
cough, chest pains, palpitations, or orthopnea.
Gastrointestinal
Nausea, vomiting, heartburn,
abdominal pain, constipation or diarrhea.
Neurologic
Irritability, insomnia,
weakness (fatigue), dizziness, loss of memory, confusion,
hallucinations, incoordination, ataxia, decreased
strength in hands or feet, disturbance in gait, difficulty
in climbing stairs, or seizures.
Reproductive (male
or female and spouse where relevant)
History of infertility,
impotence, loss of libidio, abnormal menstrual periods,
history of miscarriages, stillbirths, or children
with birth defects.
Musculo-skeletal
Muscle and joint pains.
(G) The physical examination should emphasize the neurological,
gastrointestinal, and cardiovascular systems. The worker's
weight and blood pressure should be recorded and the oral
mucosa checked for pigmentation characteristic of a possible
Burtonian or lead line on the gingiva. It should be noted,
however, that the lead line may not be present even in severe
lead poisoning if good oral hygiene is practiced.
(H) The presence of pallor on skin examination may indicate
an anemia, which if severe might also be associated with
a tachycardia. If an anemia is suspected, an active search
for blood loss should be undertaken including potential
blood loss through the gastrointestinal tract.
(I) A complete neurological examination should include
an adequate mental status evaluation including a search
for behavioral and psychological disturbances, memory testing,
evaluation for irritability, insomnia, hallucinations, and
mental clouding. Gait and coordination should be examined
along with close observation for tremor. A detailed evaluation
of peripheral nerve function including careful sensory and
motor function testing is warranted. Strength testing particularly
of extensor muscle groups of all extremities is of fundamental
importance.
(J) Cranial nerve evaluation should also be included in
the routine examination.
(K) The abdominal examination should include auscultation
for bowel sounds and abnormal bruits and palpation for organomegaly,
masses, and diffuse abdominal tenderness.
(L) Cardiovascular examination should evaluate possible
early signs of congestive hear failure. Pulmonary status
should be addressed particularly if respirator protection
is contemplated.
(M) As part of the medical evaluation, the lead standard
requires the following laboratory studies.
(I) Blood lead level.
(II) Hemoglobin and hematocrit determinations, red cell
indices, and examination of the peripheral blood smear
to evaluate red blood cell morphology.
(III) Blood urea nitrogen.
(IV) Serum creatinine.
(V) Routine urinalysis with microscopic examination.
(VI) A zinc protoporphyrin level.
(N) In addition to the above, the physician is authorized
to order any further laboratory or other tests which he
or she deems necessary in accordance with sound medical
practice. The evaluation must also include pregnancy testing
or laboratory evaluation of male fertility if requested
by the employee.
(O) Additional tests which are probably not warranted on
a routine basis but may be appropriate when blood lead and
ZPP levels are equivocal include delta aminolevulinic acid
and coproporphyrin concentrations in the urine, and dark-field
illumination for detection of basophilic stippling in red
blood cells.
(P) If an anemia is detected further studies including
a careful examination of the peripheral smear, reticulocyte
count, stool for occult blood, serum iron, total iron binding
capacity, bilirubin, and, if appropriate vitamin B12 and
folate may be of value in attempting to identify the cause
of the anemia.
(Q) If a peripheral neuropathy is suspected, nerve conduction
studies are warranted both for diagnosis and as a basis
to monitor any therapy.
(R) If renal disease is questioned, a 24-hour urine collection
for creatinine clearance, protein, and electrolytes may
be indicated. Elevated uric acid levels may result from
lead-induced renal disease and a serum uric acid level might
be performed.
(S) An electrocardiogram and chest x-ray may be obtained
as deemed appropriate.
(T) Sophisticated and highly specialized testing should
not be done routinely and where indicated should be under
the direction of a specialist.
(v) Laboratory evaluation.
(A) The blood level at present remains the single most
important test to monitor lead exposure and is the test
used in the medical surveillance program under the lead
standard to guide employee medical removal. The ZPP has
several advantages over the blood lead level. Because of
its relatively recent development and the lack of extensive
data concerning its interpretation, the ZPP currently remains
an ancillary test.
(B) This section will discuss the blood lead level and
ZPP in detail and will outline their relative advantages
and disadvantages. Other blood tests currently available
to evaluate lead exposure will also be reviewed.
(C) The blood lead level is a good index of current or
recent lead absorption when there is no anemia present and
when the worker has not taken any chelating agents. However,
blood lead levels along with urinary lead levels do not
necessarily indicate the total body burden of lead and are
not adequate measures of past exposure. One reason for this
is that lead has a high affinity for bone and up to 90 percent
of the body's total lead is deposited there. A very important
component of the total lead body burden is lead in soft
tissue (liver, kidneys, and brain). This fraction of the
lead body burden, the biologically active lead, is not entirely
reflected by blood lead levels since it is a function of
the dynamics of lead absorption, distribution, deposition
in bone and excretion. Following discontinuation of exposure
to lead, the excess body burden is only slowly mobilized
from bone and other relatively stable stores and excreted.
Consequently, a high blood lead level may only represent
recent heavy exposure to lead without a significant total
body excess and likewise a low blood lead level does not
exclude an elevated total body burden of lead.
(D) Also due to its correlation with recent exposures,
the blood lead level may vary considerably over short time
intervals.
(E) To minimize laboratory error and erroneous results
due to contamination, blood specimens must be carefully
collected after thorough cleaning of the skin with appropriate
methods using lead-free containers and analyzed by a reliable
laboratory. Under the standard, samples must be analyzed
in laboratories which are approved by the Center for Disease
Control (CDC) or which have received satisfactory grades
in proficiency testing by the CDC in the previous year.
Analysis is to be made using atomic absorption spectrophotometry
anodic stripping; voltammetry or any method which meets
the accuracy requirements set forth by the standard.
(F) The determination of lead in urine is generally considered
a less reliable monitoring technique than analysis of whole
blood primarily due to individual variability in urinary
excretion capacity as well as the technical difficulty of
obtaining accurate 24 hour urine collections. In addition,
workers with renal insufficiency, whether due to lead or
some other cause, may have decreased lead clearance and
consequently urine lead levels may underestimate the true
lead burden. Therefore, urine lead levels should not be
used as a routine test.
(G) The zinc protoporphyrin test, unlike the blood lead
determination, measures an adverse metabolic effect of lead
and as such is a better indicator of lead toxicity than
the level of blood lead itself. The level of ZPP reflects
lead absorption over the preceding three to four months,
and therefore is a better indicator of lead body burden.
The ZPP requires more time than the blood lead to read significantly
elevated levels; the return to normal after discontinuing
lead exposure is also slower. Furthermore, the ZPP test
is simpler, faster, and less expensive to perform and no
contamination is possible. Many investigators believe it
is the most reliable means of monitoring chronic lead absorption.
(H) Zinc protoporphyrin results from the inhibition of
the enzyme ferrochelatase which catalyzes the insertion
of an iron molecule into the protoporphyrin molecule, which
then becomes heme. If iron is not inserted into the molecule
then zinc, having a greater affinity for protoporphyrin,
takes place in the iron, forming ZPP.
(I) An elevation in the level of circulating ZPP may occur
at blood lead levels as low as 20-30 µg/100g in some workers.
Once the blood lead level has reached 40 µg/100g there is
more marked rise in the ZPP value from its normal range
of less than 100 µg/100ml. Increases in blood lead levels
beyond 40 µg/100g are associated with exponential increases
in ZPP.
(J) Whereas blood lead levels fluctuate over short time
spans, ZPP levels remain relatively stable. ZPP is measured
directly in red blood cells and is present for the cell's
entire 120 day lifespan. Therefore, the ZPP level in blood
reflects the average ZPP production over the previous three
to four months and consequently the average lead exposure
during that time interval.
(K) It is recommended that a hematocrit be determined whenever
a confirmed ZPP of 50 µg/100ml whole blood is obtained to
rule out a significant underlying anemia. If the ZPP is
in excess of 100µg/100ml and not associated with abnormal
elevations in blood lead levels, the laboratory should be
checked to be sure the blood leads were determined using
atomic absorption spectrophotometry, anodic stripping voltammetry
or any method which meets the accuracy requirements set
forth by the standard, by a CDC approved laboratory which
is experienced in lead level determinations. Repeat periodic
blood lead studies should be obtained in all individuals
with elevated ZPP levels to be certain that an associated
elevated blood lead level has not been missed due to transient
fluctuations in blood leads.
(L) ZPP has characteristic fluorescence spectrum with a
peak at 594nm which is detectable with a hematofluorimeter.
The hematofluorimeter is accurate and portable and can provide
on-site, instantaneous results for workers who can be frequently
tested via a finger prick.
(M) However, careful attention must be given to calibration
and quality control procedures. Limited data on blood lead
- ZPP correlations and the ZPP levels which are associated
with the adverse health effects discussed in item (ii) are
the major limitations of the test. Also it is difficult
to correlate ZPP levels with environmental exposure and
there is some variation of response with age and sex. Nevertheless,
the ZPP promises to be an important diagnostic test for
the early detection of lead toxicity and its value will
increase as more data is collected regarding its relationship
to other manifestations of lead poisoning.
(N) Levels of delta-aminolevulinic acid (ALA) in the urine
are also used as a measure of lead exposure. Increasing
concentrations of ALA are believed to result from the inhibition
of the enzyme delta-aminolevulinic acid dehydrase (ALA-D).
Although the test is relatively easy to perform, inexpensive,
and rapid, the disadvantages include variability in results,
the necessity to collect a complete 24 hour urine sample
which has a specific gravity greater than 1.010, and also
the fact that ALA decomposes in the presence of light.
(O) The pattern of porphyrin excretion in the urine can
also be helpful in identifying lead intoxication. With lead
poisoning, the urine concentrations of coproporphyrins I
and II, porphobilinogen and uroporphyrin I rise. The most
important increase, however, is that of coproporphyrin III;
levels may exceed 5,000 µg/1 in the urine in lead poisoned
individuals, but its correlation with blood lead levels
and ZPP are not as good as those of ALA. Increases in urinary
porphyrins are not diagnostic of lead toxicity and may be
seen in porphyria, some liver diseases, and in patients
with high reticulocyte counts.
(vi) Summary.
(A) The WISHA standard for inorganic lead places significant
emphasis on the medical surveillance of all workers exposed
to levels of inorganic lead above the action level of 30
µg/m3 TWA. The physician has a fundamental role
in this surveillance program, and in the operation of the
medical removal protection program.
(B) Even with adequate worker education on the adverse
health effects of lead and appropriate training in work
practices, personal hygiene and other control measures,
the physician has a primary responsibility for evaluating
potential lead toxicity in the worker. It is only through
a careful and detailed medical and work history, a complete
physical examination and appropriate laboratory testing
that an accurate assessment can be made. Many of the adverse
health effects of lead toxicity are either irreversible
or only partially reversible and therefore early detection
of disease is very important.
(C) This document outlines the medical monitoring program
as defined by the occupational safety and health standard
for inorganic lead. It reviews the adverse health effects
of lead poisoning and describes the important elements of
the history and physical examinations as they relate to
these adverse effects.
(D) It is hoped that this review and discussion will give
the physician a better understanding of the WISHA standard
with the ultimate goal of protecting the health and well-being
of the worker exposed to lead under his or her care.
(d) Appendix D. Recommendations to employers concerning
high-risk tasks (nonmandatory).
The department advises employers that the following tasks have
a high risk for lead overexposure (this list is not complete;
other tasks also can result in lead over-exposure):
Any open flame operation involving lead-containing solder
in a manner producing molten solder, including the manufacture
or repair of motor vehicle radiators;
Sanding, cutting or grinding of lead-containing solder;
Breaking, recycling or manufacture of lead-containing
batteries;
Casting objects using lead, brass, or lead-containing
alloys;
Where lead-containing coatings or paints are present:
abrasive blasting
welding
cutting
torch burning
manual demolition of structures
manual scraping
manual sanding
heat gun applications
power tool cleaning
rivet busting
clean-up activities where dry expendable abrasives
are used
abrasive blasting enclosure movement and removal;
Spray-painting with lead-containing paint;
Using lead-containing mortar;
Lead burning;
Operation or cleaning of shooting facilities where
lead bullets are used;
Formulation or processing of lead-containing pigments
or paints;
Cutting, burning, or melting of lead-containing
materials.
The department recommends that annual blood lead testing be
offered to all employees potentially overexposed to lead, including
those performing the tasks listed above, regardless of air lead
levels. Research has shown that air lead levels often do not
accurately predict workers' lead overexposure. The blood lead
testing will provide the most information if performed during
a period of peak lead exposure.
Employers should be aware that the United States Public Health
Service has set a goal of eliminating occupational exposures
which result in whole blood lead levels of 25 µg/dl or greater.
This goal should guide whether employees' blood lead levels
indicate lead overexposure.
If blood lead levels are elevated in an employee performing
a task associated with lead overexposure, employers should assess
the maintenance and effectiveness of exposure controls, hygiene
facilities, respiratory protection program, the employee's work
practices and personal hygiene, and the employee's respirator
use, if any. If a deficiency exists in any of these areas, the
employer should correct the problem.
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