The Hierarchy of Controls
The most effective strategy is at the top.
As with all OSHA health standards, when the Permissible Exposure Limit (PEL) is exceeded, the hierarchy of controls requires employers to institute feasible engineering and work practice controls as the primary means to reduce and maintain employee exposures to levels at or below the PEL. When all feasible engineering and work practice controls have been implemented but have proven inadequate to meet the PEL, employers must nonetheless implement these controls and must supplement them with appropriate respiratory protection. The employer also must ensure that employees wear the respiratory protection provided when it is required.
- Elimination or substitution is the preferred choice (most protective) at the top of the hierarchy. Examples include using or replacing lead-free abrasives, solder, and paint.
- Engineering controls include isolating the exposure source or using other engineering methods, such as local exhaust ventilation, to minimize exposure to lead.
- Warnings such as signs, barrier tape, and alarms help employees become aware of lead hazards.
- Administrative controls usually involve logistic or workforce actions such as limiting the amount of time a worker performs work involving potential exposure to lead. Good housekeeping practices to prevent surface contamination and hygiene facilities and practice to protect workers from ingesting and taking home lead are also necessary to prevent exposure to lead.
- Personal Protective Equipment is used when exposure to lead hazards cannot be engineered completely out of normal operations or maintenance work, and when safe work practices and other forms of administrative controls cannot provide sufficient additional protection. PPE includes wearing the proper respiratory protection and clothing.
For more information on lead safety hazard control measures see OSHA's Evaluating Exposure and Controls webpage.
Replacing old windows is an example of substitution.
Choose materials and chemicals that do not contain lead for construction projects. Among the options are:
- Use zinc-containing primers covered by an epoxy intermediate coat and polyurethane topcoat instead of lead-containing coatings.
- Substitute mobile hydraulic shears for torch cutting under certain circumstances.
- Consider surface preparation equipment such as needle guns with multiple reciprocating needles completely enclosed within an adjustable shroud, instead of abrasive blasting under certain conditions. The shroud captures dust and debris at the cutting edge and can be equipped with a HEPA vacuum filtration with a self-drumming feature. One such commercial unit can remove lead-based paint from flat steel and concrete surfaces, outside edges, inside corners, and pipes.
- Choose chemical strippers in lieu of hand scraping with a heat gun for work on building exteriors, surfaces involving carvings or molding, or intricate iron work. Chemical removal generates less airborne lead dust. (Be aware, however, that these strippers themselves can be hazardous and that the employer must review the material safety data sheets (MSDSs) for these stripping agents to obtain information on their hazards.)
- Replace lead-based painted building components such as windows, doors, and trim with new components free of lead-containing paint. Another option is to remove the paint off site and then repaint the components with zinc-based paint before replacing them.
Painting within an enclosure.
Engineering measures include local and general exhaust ventilation, process and equipment modification, material substitution, component replacement, and isolation or automation. Click on the buttons below to see examples of engineering controls and a video on how to set up an lead abatement enclosure.
Exhaust Ventilation. Equip power tools used to remove lead-based paint with dust collection shrouds or other attachments so that paint is exhausted through a high-efficiency particulate air (HEPA) vacuum system. For operations such as welding, cutting/burning, or heating, use local exhaust ventilation. Use HEPA vacuums during cleanup operations.
Containment enclosures. For abrasive blasting operations, build a containment structure that is designed to optimize the flow of clean ventilation air past the workers' breathing zones. This will help reduce the exposure to airborne lead and increase visibility. Maintain the affected area under negative pressure to reduce the chances that lead dust will contaminate areas outside the enclosure. Equip the containment structure with an adequately sized dust collector to control emissions of particulate matter into the environment.
Enclosure or encapsulation. One way to reduce the lead inhalation or ingestion hazard posed by lead-based paint is to encapsulate it with a material that bonds to the surface, such as acrylic or epoxy coating or flexible wall coverings. Another option is to enclose it using systems such as gypsum wallboard, plywood paneling, and aluminum, vinyl, or wood exterior siding. Floors coated with lead-based paint can be covered using vinyl tile or linoleum.
Process or equipment modification. When applying lead paints or other lead-containing coatings, use a brush or roller rather than a sprayer. This application method introduces little or no paint mist into the air to present a lead inhalation hazard. Click on the button below for some examples.
- Use non-silica-containing abrasives such as steel or iron shot/grit sand instead of sand in abrasive blasting operations when practical. The free silica portion of the dust presents a respiratory health hazard.
- When appropriate for the conditions, choose blasting techniques that are less dusty than open-air abrasive blasting. These include hydro- or wet-blasting using high-pressure water with or without an abrasive or surrounding the blast nozzle with a ring of water, and vacuum blasting where a vacuum hood for material removal is positioned around the exterior of the blasting nozzle.
- When using a heat gun to remove lead-based paints in residential housing units, be sure it is of the flameless electrical softener type. Heat guns should have electronically controlled temperature settings to allow usage below 700 degrees F. Equip heat guns with various nozzles to cover all common applications and to limit the size of the heated work area.
- When using abrasive blasting with a vacuum hood on exterior building surfaces, ensure that the configuration of the heads on the blasting nozzle match the configuration of the substrate so that the vacuum is effective in containing debris.
- Ensure that HEPA vacuum cleaners have the appropriate attachments for use on unusual surfaces. Proper use of brushes of various sizes, crevice and angular tools, when needed, will enhance the quality of the HEPA-vacuuming process and help reduce the amount of lead dust released into the air.
Isolation. Although it is not feasible to enclose and ventilate some abrasive blasting operations completely, it is possible to isolate many operations to help reduce the potential for lead exposure. Isolation consists of keeping employees not involved in the blasting operations as far away from the work area as possible, reducing the risk of exposure.
Warnings do help to raise awareness about entering hazardous lead-containing areas, but they do not prevent entry. Warnings work only as long as employees comply with them. Generally, warnings include signs, alarms, and labels. Employers are required to post this warning sign where the PEL of lead is exceeded.
All signs must be well lit and kept clean so that they are easily visible. Statements that contradict or detract from the signs' meaning are prohibited. Signs required by other statutes, regulations, or ordinances, however, may be posted in addition to, or in combination with, this sign.
Administrative and Work Practice Controls
Lead is a cumulative and persistent toxic substance that poses a serious health risk. A rigorous housekeeping program and the observance of basic personal hygiene practices will minimize employee exposure to lead. In addition, these two elements of the worker protection program help prevent workers from taking lead- contaminated dust out of the worksite and into their homes where it can extend the workers' exposures and potentially affect their families' health.
Click on the button below to see examples of administrative and work practice controls.
Change areas. The employer must provide a clean change area for employees whose airborne exposure to lead is above the PEL.
- The area must be equipped with storage facilities for street clothes and a separate area with facilities for the removal and storage of lead-contaminated protective work clothing and equipment. This separation prevents cross-contamination of the employee’s street and work clothing.
- Employees must use a clean change area for taking off street clothes, suiting up in clean protective work clothing, donning respirators before beginning work, and dressing in street clothes after work. No lead-contaminated items should enter this area.
- Work clothing must not be worn away from the jobsite. Under no circumstances should lead-contaminated work clothes be laundered at home or taken from the worksite, except to be laundered professionally or for disposal following applicable federal, state, and local regulations.
Showers. When feasible, showers must be provided for use by employees whose airborne exposure to lead is above the permissible exposure limit so they can shower before leaving the worksite.
- Where showers are provided, employees must change out of their work clothes and shower before changing into their street clothes and leaving the worksite.
- If employees do not change into clean clothing before leaving the worksite, they may contaminate their homes and automobiles with lead dust, extending their exposure and exposing other members of their household to lead.
Washing facilities. In addition, employers must provide adequate washing facilities for their workers.
- These facilities must be close to the worksite and furnished with water, soap, and clean towels so employees can remove lead contamination from their skin.
- Contaminated water from washing facilities and showers must be disposed of in accordance with applicable local, state, or federal regulations.
Housekeeping practices. An effective housekeeping program involves a regular schedule to remove accumulations of lead dust and lead-containing debris.
- The schedule should be adapted to exposure conditions at a particular worksite. OSHA’s Lead Standard for Construction requires employers to maintain all surfaces as free of lead contamination as practicable.
- Vacuuming lead dust with HEPA-filtered equipment or wetting the dust with water before sweeping are effective control measures.
- Compressed air may not be used to remove lead from contaminated surfaces unless a ventilation system is in place to capture the dust generated by the compressed air.
- Put all lead-containing debris and contaminated items accumulated for disposal into sealed, impermeable bags or other closed impermeable containers.
- Label bags and containers as lead-containing waste. These measures provide additional help in controlling exposure.
End-of-day procedures. Employers must ensure that workers who are exposed to lead above the permissible exposure limit follow these procedures at the end of their workday:
- Place contaminated clothes, including work shoes and personal protective equipment to be cleaned, laundered, or disposed of, in a properly labeled closed container.
- Take a shower and wash their hair. Where showers are not provided, employees must wash their hands and face at the end of the workshift.
- Change into street clothes in clean change areas.
Personal Hygiene Practices. Emphasize workers' personal hygiene such as washing their hands and face after work and before eating to minimize their exposure to lead. Provide and ensure that workers use washing facilities. Provide clean change areas and readily accessible eating areas. If possible, provide a parking area where cars will not be contaminated with lead. These measures:
- Reduce workers' exposure to lead and the likelihood that they will ingest lead,
- Ensure that the exposure does not extend beyond the worksite,
- Reduce the movement of lead from the worksite, and
- Provide added protection to employees and their families.
Personal practices. The employer must ensure that employees use suitable personal hygiene practices to prevent exposure to lead.
- Do not enter lunchroom facilities or eating areas with protective work clothing or equipment unless surface lead dust has been removed. HEPA vacuuming and use of a downdraft booth are examples of cleaning methods that limit the dispersion of lead dust from contaminated work clothing.
- In all areas where employees are exposed to lead above the PEL, employees must observe the prohibition on the presence and consumption or use of food, beverages, tobacco products, and cosmetics. Employees whose airborne exposure to lead is above
- the PEL must wash their hands and face before eating, drinking, smoking, or applying cosmetics.
Protective Clothing and Equipment
Lead requires the use of effective PPE.
Employers must provide workers who are exposed to lead above the PEL or for whom the possibility of skin or eye irritation exists with clean, dry protective work clothing and equipment that are appropriate for the hazard. Employers must provide these items at no cost to employees. Appropriate protective work clothing and equipment used on construction sites includes:
- Coveralls or other full-body work clothing;
- Gloves, hats, and shoes or disposable shoe coverlets;
- Vented goggles or face shields with protective spectacles or goggles;
- Welding or abrasive blasting helmets; and
Clean work clothing must be issued daily for employees whose exposure levels to lead are above 200 µg/m3, weekly if exposures are above the PEL but at or below 200 µg/m3 or where the possibility of skin or eye irritation exists.
Remove contaminated clothing.
Handling Contaminated Protective Clothing
Properly handling protective equipment is an essential step in reducing the movement of lead contamination from the workplace into the worker’s home and provides added protection for employees and their families.
Workers must not be allowed to leave the worksite wearing lead-contaminated protective clothing or equipment.
Click on the buttons below to see examples of policies and practices related to the use of protective clothing and a video on using personal protective equipment.
- Disposable coveralls and separate shoe covers may be used, if appropriate, to avoid the need for laundering
- Workers must remove protective clothing in change rooms provided for that purpose.
- Employers must ensure that employees leave the respirator use area to wash their faces and respirator facepieces as necessary. Employers may require their employees to use HEPA vacuuming, damp wiping, or another suitable cleaning method before removing a respirator to clear loose particle contamination on the respirator and at the face-mask seal.
- Workers must place contaminated clothing that is to be cleaned, laundered, or disposed of by the employer in closed containers.
- Containers must be labeled with the warning: "Caution: Clothing contaminated with lead."
- Workers must not remove dust from protective clothing by blowing, brushing, or shaking.
- Workers must dispose of lead-contaminated wash water in accordance with applicable local, state, or federal regulations.
- Employers must inform workers in writing of the potential health hazard of lead exposure.
Preventing Heat Stress
Click to enlarge.
Workers wearing protective clothing, particularly in hot environments or within containment structures, can face a risk from heat stress if proper control measures are not used.
There are many factors that have a role in creating an occupational heat stress risk to workers. These factors include:
- environmental conditions (such as air temperature, humidity, sunlight, and air speed), especially on sequential days;
- presence of heat sources (e.g., hot tar ovens or furnaces) in the work area;
- level of physical activity, i.e., the workload leading to body heat production;
- use of clothing or protective gear that can reduce the body’s ability to lose excess heat; and
- individual/personal risk factors.
Click on the buttons below to see a list of ways to help prevent heat stress and watch a video by the NAHBTV on heat stress and how to prevent heat stroke and exhaustion.
- discuss the possibility of heat stress and its signs and symptoms with all workers;
- use appropriate work/rest regimens;
- provide heat stress monitoring that includes measuring employees' heart rates, body temperatures, and weight loss;
- choose lighter, less insulating protective clothing over heavier clothing, as long as it provides adequate protection; and
- drink electrolytes in a non-contaminated eating and drinking area close to the work area so employees can drink often throughout the day. Workers must wash their hands and face before drinking any fluid if their airborne exposure is above the PEL.
For more information on heat stress see Course 602, Heat and Cold Stress Safety and OSHA's Heat Stress Quick Card.
Education includes instruction, training, and evaluation.
Safety education is accomplished in three components: instruction, training, and evaluation to ensure employees have the necessary knowledge, skills, and abilities (KSAs) required to work safe on the job.
- Instruction. Employees must be instructed on OSHA regulations, company safety policies, programs, procedures, and how to avoid unsafe conditions.
- Training. They must be trained including instructor demonstration and an opportunity to practice.
- Evaluation. Their abilities on the job must be evaluated by a competent person, formally certified, and designated as qualified to use equipment and perform procedures.
Employers are held accountable by OSHA to develop a suitable safety training program. It's important to know that OSHA will ALWAYS inspect the safety training program during an OSHA inspection.
Click on the buttons below to see more specific training responsibilities and a video that might be used in a safety orientation or tool-box meeting..
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
Your employer must make readily available to all employees, including 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 by OSHA.
All new employees must be trained prior to initial assignment to areas where there is a possibility of exposure over the action level. This training program must also be provided at least annually thereafter.
For more information on OSHA training requirements see OSHA Pub 2254, Training Requirements in OSHA Standards, and OSHAcademy Course 703, Introduction to OSHA Training.
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