Exposure Limits

Limit	Concentration	Averaging Period
Permissible Exposure Limit (PEL)	50 ug/m3	8-hour TWA
Action Level (AL)	30 ug/m3	8-hour TWA

The PEL and action level apply to all construction work where employees may be exposed to lead, including demolition, renovation, abatement, and maintenance of structures containing lead-based materials.

When the Standard Applies

The lead in construction standard (29 CFR 1926.62) applies to all construction activities where employees may be exposed to lead, including:

Demolition or salvage of structures with lead-containing materials
Removal or encapsulation of lead-containing materials
New construction or renovation in areas with lead-containing materials
Installation or maintenance of lead-containing products
Lead abatement and cleanup
Transportation, disposal, or storage of lead-containing materials
Any construction activity that may release lead into the air

Exposure Assessment

Initial Determination

Employers must determine if any employee may be exposed to lead at or above the action level. This determination can be based on:

Historical exposure data from the employer’s own operations
Objective data from similar operations
Initial monitoring results

Monitoring Requirements

Condition	Requirement
Any employee possibly exposed at or above action level	Initial monitoring required
Initial results at or above action level	Monitoring every 6 months
Initial results at or above PEL	Monitoring every 2 months until 2 consecutive results below PEL
Two consecutive results below action level	May stop monitoring (resume if conditions change)

All monitoring must be personal breathing zone samples representative of the 8-hour TWA exposure. Results must be reported to affected employees within 5 working days of receipt.

Interim Protection

Until the employer performs an exposure assessment, employees performing any of the following tasks must be provided interim protection as if exposed above the PEL:

Manual demolition of structures with lead-based paint (such as dry wall demolition)
Manual scraping, sanding, or removal of lead-based paint
Use of heat guns on lead-based paint
Rivet busting, power tool cleaning, abrasive blasting, welding, cutting, or torch burning on lead-containing surfaces

These tasks are considered high-exposure activities where the PEL is likely to be exceeded.

Compliance Methods

Engineering and Work Practice Controls

When employee exposure exceeds the PEL, the employer must implement engineering and work practice controls to reduce exposure to or below the PEL. These may include:

Local exhaust ventilation
Wet methods
Containment
Substitution of materials
Work practice modifications

Respiratory Protection

Respiratory protection is required when:

Engineering and work practice controls do not reduce exposure below the PEL
During the time needed to implement controls
During tasks where controls are not feasible
In emergencies

The employer must implement a respiratory protection program meeting 29 CFR 1910.134.

Medical Surveillance

Medical surveillance is required for employees exposed at or above the action level for more than 30 days per year.

Initial and Periodic Examinations

Medical examinations must include:

Blood lead level (BLL) testing
Zinc protoporphyrin (ZPP) level
BUN and creatinine
Complete blood count with indices
A medical history focused on lead exposure

Blood Lead Level Monitoring

Condition	Requirement
Exposed at or above action level >30 days/year	BLL every 2 months for first 6 months, then every 6 months
BLL at or above 50 ug/dL	Medical removal required
Return to work after medical removal	BLL must be below 40 ug/dL on two consecutive tests

Medical Removal Protection

Employees whose BLL reaches 50 ug/dL must be medically removed from lead exposure. The employee must be maintained at their normal earnings, seniority, and benefits for up to 18 months while removed. The employee may return to lead work when their BLL drops below 40 ug/dL on two consecutive tests at least one month apart.

Hygiene and Housekeeping

Clean change areas must be provided when exposure exceeds the PEL
Showers must be available when exposure exceeds the PEL
Employees may not eat, drink, smoke, or apply cosmetics in areas where exposure exceeds the PEL
All surfaces must be kept as free of lead accumulation as practicable
Compressed air may not be used to clean surfaces or employee clothing unless combined with a ventilation system designed to capture the airborne dust

Training

Employers must provide training to all employees exposed at or above the action level or who may be exposed to lead compounds classified as skin hazards. Training must be provided at the time of initial assignment and at least annually thereafter. Training content must include the specific requirements of 29 CFR 1926.62, the health hazards of lead, and protective measures.

Recordkeeping

Record Type	Retention Period
Exposure monitoring records	30 years
Medical surveillance records	Duration of employment + 30 years
Medical removal records	Duration of employment + 30 years
Objective data (exposure assessment)	30 years

Resources

29 CFR 1926.62 - Full construction standard
OSHA Lead Standards - All sectors including construction
OSHA Lead Safety Fact Sheet
Lead Standards Quick Reference
Ohio Lead Program Overview