OSHA’s Proposed Rulemaking for Blood Lead Level Medical Removal

In 2022, OSHA  published an Advance Notice of Proposed Rulemaking (ANPRM) on blood lead level for medical removal in the federal register. This begins a period of public comment on a new rule. Under the lead standard a worker is required to be removed to a work area with a TWA for 8-hours of 30 micrograms per cubic meter when his/her blood level is at or above a certain criteria. The general industry lead standard 1910.1025 was issued in 1978 and the construction lead standard 1926.62 came out in 1993. Since that time, new medical research has shown that blood lead at current limits may not adequately protect workers. Current medical removal is at  (≥ 60 µg/dL (micrograms per deciliter) in general industry, ≥ 50 µg/dL in construction), and return-to-work status level (< 40 µg/dL). Some states including Michigan, Washington, and California have already lowered or are in the process of lowering their limits.

There are a large number of common symptoms of overexposure to lead. These may  include loss of appetite, metallic taste in the mouth, anxiety, constipation, nausea, pallor, excessive tiredness, weakness, insomnia, headache, nervous irritability, muscle and joint pain, fine tremors, numbness, dizziness, hyperactivity and colic. Chronic exposure may result in damage to blood-forming, nervous, urinary, and reproductive systems. Very high levels can cause brain damage and death. According to the Centers for Disease Control (CDC), exposure to lead during pregnancy can increase the risk of miscarriage, cause the baby to be born too early or too smallhurt the baby’s brain, kidneys, and nervous system, and cause the child to have learning or behavior problems.

The primary use of lead in the U.S. is for automotive lead-acid storage batteries. In general,  lead is found in ammunition, pipes, cable covering, building material, solder, radiation shielding, collapsible tubes, and fishing weights. Lead is also used in ceramic glazes and as a stabilizer in plastics.

In general industry, workers come in contact with lead in solder, plumbing fixtures, rechargeable batteries, lead bullets, leaded glass, brass, or bronze objects, and radiators. Lead exposure can occur not only in the production of these kinds of objects but also in their use (e.g., firing ranges), repair (e.g., radiator repair), and recycling (e.g., lead-acid battery recycling). Construction workers are exposed to lead during the removal, renovation, or demolition of structures painted with lead pigments. Workers may also be exposed during installation, maintenance, or demolition of lead pipes and fittings, lead linings in tanks and radiation protection, leaded glass, work involving soldering, and other work involving lead metal or lead alloys.

Adding or updating an OSHA standard is a cumbersome process and can take years to be enacted and enforced. Many federal work standards are over 50 years old and attempts to change them have only had limited success. OSHA should be applauded for its proposed rulemaking to change the blood lead level for medical removal. Hopefully, a more current standard will be developed and approved to better protect workers who are exposed to lead.

For more information on this topic and to discuss your company’s safety and industrial hygiene needs call OccuSafe at (214) 662-6005 or visit us at www.occusafeinc.comOccuSafe Industrial Hygiene & Safety, Inc. provides skills and expertise to recognize, evaluate and control hazards and injuries in the areas of industrial hygiene, occupational safety and health. OccuSafe services companies of all sizes in a range of industries.

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