The employer must still follow all requirements of the standard and conduct an exposure assessment for the tasks involving lead. Our letter, however, goes on to say: OSHA wants to stress that this does not set 0.06% as a lower threshold for the concentration of lead in paint which would exempt the employer from the requirements of the standard. Chou states that for certain tasks involving such "lead free paint" (CPSC definition) that do not create large amounts of dust (such as power tool cleaning with dust collection systems, manual demolition of structures, manual scraping, and manual sanding), OSHA would allow the application of objective data to demonstrate that worker exposure levels to paint would be warranted. ![]() If the levels of lead to which employees are exposed are below the action level (which may occur when the levels of lead in paint are very low and work is being done in such a way as to not disturb the paint and, therefore, generate airborne concentrations of lead), then the further requirements of the standard would not apply. The results of the exposure assessment then determine whether the employer would need to apply the further protections of that rule. 62(n)(4)) to demonstrate that the Lead in Construction standard's action level (30 micrograms/cubic meter of air) is not exceeded. If an employer is working with paint which contains any amount of lead, including those with less than 0.06%, in such as way that would generate airborne levels to which employees may be exposed, it is the employer's duty to conduct exposure monitoring (or use objective or historical data as defined in. Accordingly, for all tasks governed by OSHA's Lead in Construction standard (.62) involving paints having any level of lead, employers must comply with the assessment measures and any applicable protections of that standard. Whereas, the CPSC's mission is to protect consumers from harmful consumer products, OSHA's role is to protect workers from health and safety hazards, including exposure to harmful levels of lead, whatever the source. OSHA's mission and that of the CPSC (as well as the Housing and Urban Development Agency and others who address lead in paint) are different. 62 states that "lead paint was banned after 1978 therefore, the standard has no impact on painting new residential units or repainting units build after l978." The Consumer Product Safety Commission (CPSC) considers paint containing less than 0.06% lead to be "lead free." OSHA does not, however, accept that categorization. Question: Is OSHA stating an exposure assessment would not be necessary when the related task is a trigger task (or other tasks) as outlined in 1926.62 and when the coatings are determined to be "lead free" (below the 0.06% threshold)? Based on your review and assessment of these two documents you raise the following question. 62, Lead in Construction, which you feel states that the Lead in Construction standard has no impact on activities involving paints manufactured after 1978. You state in your letter that you believe that this is contradictory to information presented in OSHA's report on the Regulatory Review of. Chou provides additional detail describing an employer's continuing obligation to conduct an exposure assessment for tasks involving lead. ![]() Hsin Chou, dated Mawhich states that OSHA does not set a 0.06 percent (%) threshold as a lower concentration of lead in paint which would exempt an employer from the requirements of the standard. Your letter references an existing letter of interpretation, to Mr. You specifically ask about the standard's requirement for an employer to conduct an exposure assessment for tasks involving lead-containing paint. In your letter, you requested an interpretation regarding OSHA's standard for Lead in Construction. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any questions not delineated within your original correspondence. ![]() Your letter was transferred to OSHA's Directorate of Enforcement Programs for response. This is in response to your correspondence of Apto the Occupational Safety and Health Administration (OSHA).
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