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Lead: the four details of the standard that cost money

This page explains what the rules and common practice call for. Every site is different, and what a survey or a filing needs at your facility is something we work out with you after we see it.

Lead is the OSHA standard most likely to trip a plant up on the details. The limits are not unusual, but almost every working detail differs a little from the standards people are used to.

Four of those details cost money if you get them wrong.

Exposure limits

Value Paragraph
Permissible exposure limit (PEL) 50 micrograms per cubic meter of air (µg/m³), 8-hour time-weighted average (TWA) (c)(1)
Action level 30 µg/m³, 8-hour TWA, whether or not workers wear respirators (b)
Longer shifts The PEL goes down. Highest allowed level (µg/m³) = 400 ÷ hours worked in the day (c)(2)

That third row is the first thing people miss. If you run 10-hour shifts, your PEL is not 50 µg/m³ but 40, and on a 12-hour shift it is 33.

Some surveys compare an 8-hour TWA with a flat 50 and never record the shift length. For a plant on longer shifts, that survey has not answered the question.

You do not have to work this out alone.Ron Fleming has done this work himself since 1993. We come to your plant, sample the air, and tell you what you need and what you do not. See if we are the right fit. No cost.·More about air monitoring surveys

Full shift means at least seven continuous hours

The lead standard is unusually specific about this. It requires full-shift personal samples, at least 7 continuous hours long, with at least one sample for each shift, for each job classification, in each work area.

Most standards do not spell it out this closely. The requirement rules out the shortcut of sampling for a couple of hours and estimating the rest, and it means the sampling plan has to cover every job classification in every work area. A handful of typical workers from across the plant is not enough.

What your results require you to do

Result What the standard requires Paragraph
Below the action level No repeat monitoring needed, unless something changes (d)(6)(i)
At or above the action level, below the PEL Monitor at least every 6 months, until two consecutive measurements, taken at least 7 days apart, are below the action level (d)(6)(ii)
Above the PEL Monitor quarterly, until two consecutive measurements, at least 7 days apart, are below the PEL but at or above the action level. Then go back to the 6-month schedule (d)(6)(iii)
A change in production, process, control or personnel Additional monitoring (d)(7)
Employee notification Within 15 working days of receiving the results, in writing or by posting them. If a result is above the PEL, the notice must say so and describe the corrective action you are taking (d)(8)

Lead has no objective data option

The silica, hexavalent chromium, beryllium and formaldehyde standards all have a performance option or an objective data option, which can stand in for sampling when you assess exposure. The lead standard has no such option. The term “objective data” does not appear in its exposure monitoring section at all.

What lead has is historical monitoring data with a hard cutoff. Two provisions of the standard let you rely on airborne lead measurements made in the previous 12 months. Data older than 12 months does not qualify, however well it represents your operations.

Both provisions also apply only to your initial determination and your initial monitoring. The provision that covers periodic monitoring allows no substitute at all, so if someone has told you objective data covers your ongoing lead program, that is not correct.

The retention requirement that breaks most recordkeeping policies

Most exposure records fall under OSHA's standard on exposure and medical records, which says to keep them at least 30 years. But read how that provision opens. The 30-year period applies “unless a specific occupational safety and health standard provides a different period of time.”

The lead standard provides a different period. It requires you to keep lead exposure monitoring records at least 40 years, or for the duration of employment plus 20 years, whichever is longer.

If you keep all exposure records under one blanket 30-year policy, your lead records do not meet the standard. Almost no summary table on the internet will have told you so, because nearly all of them apply the 30-year default across the board.

→ See how often monitoring is required, by substance

Where we find lead exposures

One useful exception: EPA keeps a list of chemicals of special concern, and that list treats lead differently when the lead is contained in a stainless steel, brass or bronze alloy. That matters to a lot of machining shops for the Toxics Release Inventory (TRI), EPA's annual toxic chemical release report. It does not change the OSHA exposure question.

How we sample for it

Sampling media 0.8 µm mixed cellulose ester filter, 37 mm cassette
Analytical methods NIOSH 7300 / 7303 (ICP) · NIOSH 7082 (flame AAS) · OSHA ID-121
Sample type Personal sample in the worker's breathing zone, for the full shift. At least 7 continuous hours
Also consider Surface lead dust, which matters for housekeeping and for the workers' hygiene areas. That is a separate question from airborne lead. Surface wipe sampling is outside the four fields we work in

Plan a lead air monitoring survey

Ron Fleming has done this work himself since 1993. You talk directly to the person who does the job. No account managers. No call center. Our prices are well below the competition. Tell us what is going on and we will send a written scope of work and a price, at no cost.

Talk with us. No cost.

References

The regulations and standards behind this page, with links to the official text, so you can check the source yourself.

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