Controlling Exposure
Shipyard work is traditionally hazardous, with an injury-accident rate more than twice that of construction and general industry. When the PEL for lead is exceeded, OSHA 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 supplement them with appropriate personal protective equipment and respiratory protection.
The Hierarchy of Controls
As with all OSHA health standards, when a Permissible Exposure Limit (PEL) is exceeded, the employer must create feasible controls to reduce and maintain employee exposures to levels at or below the PEL.
A prioritized "Hierarchy of Controls" (HOC) has been used to implement feasible and effective exposure controls to protect workers. We encourage the use of the HOC as described within the ANSI/ASSP Z10, Occupational Health and Safety Management Systems, to control hazards. The six strategies are discussed below.
- Elimination: This strategy is preferred because it completely eliminates a hazard. Examples include lead-free abrasives, solder, and paint.
- Substitution: If you can't eliminate the hazard, you can reduce the severity of the hazard by replacing it with a less hazardous option. For instance, a toxic chemical can be replaced with a less toxic chemical.
- 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.
- Work Practice Controls usually involve 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.
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.
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.
For more information on lead safety hazard control measures see OSHA's Evaluating Exposure and Controls webpage.
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2-1. Which strategy is a work practice control to mitigate exposure to lead?
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