eLCOSH : Guides for Managing Lead Control Programs in Construction

Guides for Managing Lead Control Programs in Construction

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Nancy Clark, Mark Goldberg, Katya Wanzer, Norman Zuckerman

Mount Sinai School of Medicine, Hunter College - Urban Public Health Program

Overview

Section 1: Planning

When to Plan
Who Does the Planning
What Plans Need to be Made
Blood Lead Monitoring Timetable

Section 2: Implementing

Managing the Screening

Section 3: Managing & Responding to Results

Managing the Results
Responding to Elevated Results

Section 4: Infosheets, Sample Forms, & Further Information

Overview

Blood Lead Monitoring (BLM) measures the quantity of lead a worker has absorbed into the blood stream.

Why perform Blood Lead Monitoring (BLM)?

It is required by OSHA
Required by some owner specifications
Elevated blood lead levels signal an increased health risk to workers
An increase in blood lead levels over time can be an indicator of a problem with engineering and work practice controls and/or respirator use.

Overview of the Tasks

1. Planning

2. Implementing

3. Managing and Responding to Results

— This Guide will elaborate on these tasks —

Planning

When to plan

Before workers begin lead disturbing tasks at the site

Who does the planning

Corporate safety office (where applicable) or management at the site begins the planning and chooses the Lead Program Manager (LPM).
- The LPM needs to be trained in lead hazards and their control Resources (G-1).

What plans need to be made

Identify workers performing lead disturbing tasks or who work in an area where these tasks are being or might be performed
Hire a medical service that provides BLM – See Infosheet 1: Questions to Ask When Hiring a Medical Service (B-11)
Establish a screening schedule
- beginning of work day
- same time of the month
- preferably not after holidays or weekends
Develop a procedure for BLM for new hires
Set up spreadsheet to keep records of BLM results - Use Sample Recordkeeping Form (B-17)
Plan for potential elevations in Blood Lead Levels – Read Section 3: Managing & Responding to Results
Establish monitoring timetable – refer to Blood Lead Monitoring Timetable below for more specific information

Blood Lead Monitoring Timetable

Test number	OSHA	*NYCDOT Specs**
1 (Baseline)	Within 48 hours of exposure	Prior to exposure
2-4	Every other month for the first 6 months if exposure level is above the airborne Action Level of 30 mcg/m³**	Every month
5 and thereafter	Every 6 months - or every two months for any individual(s) at or above 40 mcg/dl*** see Table 1: Blood Lead Level Triggers	Every month
At end of job or when worker leaves the job	Not required	Required

*New York City Department of Transportation - an example of local owner specifications.
**mcg/m3 = m i c r o g rams/cubic meter
***mcg/dl= micrograms/deciliter of blood

Implementing

Organizing BLM is an important activity. The goal is to help the medical service do the best possible job with the least disruption to the project. The following is an outline of the tasks of the LPM in implementing blood lead monitoring and a few pointers on how to do it.

Establish sanitary area for screening (if it is to be conducted on site and service has no mobile testing vehicle).
- Use the field office.
- Ensure that wash up stations are available (workers may need to clean up before blood can be drawn).
Organize BLM with supervisors, foreman and workers
- Figure out with medical service how many workers can efficiently be tested in a given time frame to ensure that the screening is executed with minimum disruption to medical team, workers and productivity.
- Give one person responsibility for organizing the flow of crews especially at complex work sites.
- Notify workers and foremen of BLM date and time as soon as possible prior to screening.
Provide necessary information to medical service before screening
- See Infosheet 2: Information to Provide the Medical Testing Service About the Project (B-13)

Managing & Responding To Results

After the results are received from the medical service, the LPM has responsibilities for reviewing and responding to results, informing workers and keeping records. The following is an overview of these activities.

Managing the Results

Review BLM results

Enter the results into a spreadsheet – use Sample Recordkeeping Form (B-17)
Compare results to trigger levels – See Table 1: Blood Lead Level Triggers (B-15)
Compare results to prior screenings. Look for trends within individuals and groups, for instance workers engaged in torch cutting activities.
Initiate response if necessary – see next page “Responding to Elevated Results”.

Provide results, in writing, to each employee within 5 days of receiving them

Use the Sample Blood Lead Monitoring Results Form (B-19)
Distribute during weekly toolbox talk or with paycheck
Maintain confidentiality when returning results to workers

Comply with legal notifications (e.g. Local/State Department of Transportation, Department of Health, Local/State Lead Registry)

Make sure that any information that can identify an individual (last name, SS#) be given only when legally necessary

Maintain records of the results

Employers must maintain employee's medical records for the length of their employment plus 30 years

Plan a safety meeting/toolbox talk to explain and discuss results. Ask medical service if they would attend safety meeting/toolbox talk to explain results.

Responding to Elevated Results

Elevated Blood Lead Levels indicate a problem with engineering and work practice controls or with respiratory protection. Consult the Guides for Managing Engineering & Work Practice Controls, Exposure Assessment and Respiratory Protection for further guidance on troubleshooting. The following points summarize the main steps to be taken:

Check out the control equipment to ensure that it is being used and functioning correctly.
Talk to the workers, ask them:
- if they are familiar with the controls
- if they think that controls are working properly
- if they have any suggestions for improving existing controls
- if they use the controls and, if not, why not
- what they do when the equipment isn’t working properly
Hold a safety meeting with managers and a toolbox talk with workers about the controls. It is possible that the controls are not suited to the particular application. If so, an investigation of other possible control options is in order.
Ensure that the types of respirators worn by the workers are sufficiently protective and are being used correctly.
Review hygiene facilities and housekeeping.

Section 3 Notes

Note: BLM results are usually measured in micrograms of lead per deciliter of blood (mcg/dl). The OSHA standard also requires that blood samples be analyzed for either zinc protoporhyrin (ZPP) or free erythrocyte protoporhyrin (FEP). There are no OSHA trigger levels for ZPP/FEP.
Graphing workers' results over a period of time helps them visualize their levels - See Sample Graph (B-21).
Although OSHA states that employers need not maintain records for employees working less than one year as long as they are given their medical records when they leave the company, it is advisable to keep them.

Infosheets, Sample Forms & Further Information

Infosheet 1: Questions to Ask When Hiring a Medical Service

Procedures are supervised by a physician familiar with provisions of the OSHA Lead in Construction Standard (preferred)
Capability of providing follow up medical evaluations (preferred)
Capability of performing blood tests on site (preferred)
Capability of providing service at nights or weekends (if necessary)
Service is well staffed and capable of completing the BLM on all of the workers in the allotted time (preferred)
Lab analysis performed in OSHA approved facility (required)
Results provided in a timely fashion
Results can be transmitted to you electronically
Capability of keeping records
Cost per person/what is the cost for testing only one or two workers

Infosheet 2: Information to Provide the Medical Testing Service About the Project

Start date for initial screening
Frequency of screenings
Duration of project
Approximate number of workers to be tested per screening
Location of screening, how to get there
Description of space where testing will be conducted, including provision for privacy, wash-up stations, size, electrical outlet availability
Site contact person and telephone number

Table 1: Blood Lead Level (BLL) Triggers

BLL Trigger (mcg/dl)	OSHA	*NYCDOT Specs**
> or equal to 25 mcg/dl for at least 2 workers	N/A	IH Intervention
Increase > or equal to 10 mcg/dl for any worker in consecutive screenings	N/A	IH Intervention
> or equal to 40 mcg/dl	Make medical exam available (at least annually). Inform worker of medical removal protection rights. Continue blood lead testing every 2 months until two consecutive test results below 40 mcg/dl.	Make medical exam available (at least annually). Inform worker of medical removal protection rights. Retrain worker.
> or equal to 50 mcg/dl (first test)	Not required	Retest within 2 weeks
> or equal to 50 mcg/dl (second test)	Medical removal	Medical removal

* An example of local specifications. Check requirements in your area.

Sample Recordkeeping Form

First Name	Last Name	D.O.B	Date	BLL (mcg/dl)	ZPP/FEP (mcg/dl)

SAMPLE BLOOD LEAD MONITORING RESULTS FORM

Employee name __________________________
Date of Test __________________________
BLL mcg/dl __________________________
ZPP/FEP mcg/dl __________________________
Medical Service __________________________

Blood lead results are usually given as micrograms of lead per deciliter of blood (mcg/dl). The blood lead level (BLL) reflects the amount of lead an individual has absorbed during the two weeks or so before the blood test was performed. It tells us very little about the lead absorption before that time. Average BLLs for adults in major urban areas are less than 10 mcg/dl.

FEP (sometimes called ZPP) shows us how much lead has been absorbed during the 90 - 120 or so days before the test, but tells us very little about exposure during the most recent two weeks. FEP levels below 35 are considered normal. The FEP level usually does not increase unless the blood lead level rises above 50 mcg/dl.

SAMPLE BLOOD LEAD MONITORING RESULTS GRAPH

graph

This type of graph can be generated from your record keeping spreadsheet.

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