854 Lead Safety in Construction

Controlling Hazards and Exposure

When a permissible exposure limit (PEL) is exceeded, employers must attempt to control the exposures that cause the PEL to be exceeded. Employers should use one or more of the control strategies in a "best-first" hierarchy. When all feasible exposure controls prove inadequate to lower lead exposure at or below the PEL, employers should nonetheless use one or more of these controls plus respiratory protection.

The Hierarchy of Controls (HOC)

Exposure to hazards can be effectively controlled through two basic HOC approaches: controlling the hazard, itself, and/or controlling the behavior that creates the exposure. To do that, employers should use the following Hierarchy of Controls strategies:

1. Elimination: This is the preferred strategy because it is most protective by completely eliminating exposure to a hazard. An example includes using lead-free abrasives.
2. Substitution: If you can't eliminate the hazard, you may be able to replace it with a less hazardous option. An example includes replacing materials that may create airborne lead with materials that more effectively mitigate lead exposure.

4. Warnings: This strategy influences behavior by raising employee hazard awareness. Examples include signs, barriers, and alarms that help employees become aware of lead hazards.
5. Work Practice Controls: The goal of work practice controls is to protect employees through the use of safe procedures. To do that, the employer can develop mandatory procedures and rules that reduce exposure to lead. For instance, good housekeeping and hygiene practices can help prevent lead ingestion.
6. Personal Protective Equipment (PPE): Each employee can be protected when exposure to lead hazards cannot be engineered completely out of normal operations or maintenance work, and when safe work practices and other controls cannot provide sufficient additional protection.

Interim Measures

Using a lower priority hazard control method over another higher priority control strategy may be appropriate for providing interim (temporary) protection until the hazard is abated permanently. If you can't eliminate the hazard entirely, the interim control measures will likely be a combination of control methods used together. OSHA believes that feasible interim measures are always available if higher-level control methods are not possible.

It's important to understand that HOC strategies work only as long as employees do not defeat the strategies through non-compliance. For more information on lead safety control measures in construction, see OSHA's Technical Manual, Section visibility: Chapter 3.

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