Employer Responsibilities

What are employer responsibilities?

Develop and implement a worker protection program for workers exposed to lead above the PEL. Establish and implement a written compliance program for each job where employee exposure exceeds the PEL.

Conduct an initial employee exposure assessment (hazard assessment) to determine whether employees are exposed to lead at or above the AL. This includes a medical assessment of the employee. Employees must be notified of initial medical surveillance results, results of monitoring and written physicians’ opinions regarding the employees’ occupational exposure to lead.

Provide interim protection (such as a respirator) while the hazard assessment is conducted for employees working on certain tasks prone to high exposure.

Employers may be required to remove employees from work if blood tests indicate a high level of lead poisoning. Such employees may be entitled to Medical Removal Protection benefits. Employers must maintain employee medical and exposure records and all monitoring and other data used to conduct employee exposure assessments.

The above information on Employer Responsibilities was taken from the OSHA web page on Lead in Construction.

What must employers do to protect workers from lead?

Maintain all surfaces as free of lead as practicable. Note that compressed air is not allowed 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.

Provide and ensure that workers use washing facilities. Provide clean change areas and readily accessible eating areas. For job sites with exposures above the PEL, employers must ensure that workers do not wear contaminated clothing away from the job site; they must change into street clothes in a clean changing area. No eating, drinking, smoking or cosmetics are allowed on a job, and showers must be provided when the exposure is above the PEL. In addition, employees are required to wash their face and hands before engaging in any of the above activities.

Employers must issue employees protective clothing and equipment when exposure levels are above the PEL: full-body work clothing, gloves, hats and shoes or disposable shoe covers, goggles, helmets (if welding or abrasive blasting is involved) and respirators. Respirators are also required if requested by employees. A respiratory protection program is required when respirators are used.

Employers must inform employees about lead hazards and institute an employee information and training program. Training must begin before employees begin their first job assignment. Warning signs must be posted where employee exposure to lead is above the PEL (Warning, Lead Work Area, Poison, No Smoking or Eating).

The above information on Employee Protection was taken from the OSHA Fact Sheet, Protecting Workers from Lead Hazards and OSHA Lead Standard.

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