12 Aug Lead Exposure – JSA

Lead Exposure Job Safety Analysis (JSA)

Job / Task

Work that may disturb lead-containing or presumed lead-containing materials, including demolition, renovation, cutting, grinding, sanding, scraping, torch work, welding, abrasive activities, surface preparation, cleanup, and handling of lead-contaminated debris.

Purpose

This Job Safety Analysis (JSA), also known as a Job Hazard Analysis (JHA), identifies hazards associated with occupational lead exposure and establishes controls to minimize inhalation and ingestion of lead dust, fumes, and contaminated materials. It also addresses exposure assessment, regulated areas, engineering and work-practice controls, respiratory protection, hygiene, housekeeping, medical surveillance, and training.

Personnel Qualifications

Employees performing work with potential lead exposure shall be trained for the task, hazards, and controls involved. Applicable exposure assessments and the lead compliance program shall be reviewed before work begins. Employees shall follow established engineering controls, hygiene requirements, PPE procedures, and regulated-area restrictions.

Employees shall:

• Recognize tasks and materials that may create lead dust or fumes.
• Understand that lead can enter the body through inhalation and ingestion.
• Follow exposure-control methods established for the task.
• Use required respiratory protection and PPE.
• Observe regulated-area and access restrictions.
• Follow required handwashing, showering, changing, and contamination-control practices.
• Never eat, drink, smoke, chew tobacco or gum, or apply cosmetics in lead-contaminated work areas.
• Use approved housekeeping methods that minimize airborne lead dust.
• Report failed controls, damaged PPE, unusual dust or fume conditions, and suspected exposures.
• Participate in required exposure monitoring, medical surveillance, and training.

Required PPE

PPE shall be selected according to the task, exposure assessment, and applicable lead requirements and may include:

• Safety glasses with side protection.
• Goggles or face shield where flying particles, sparks, or splash hazards exist.
• Protective work clothing or disposable coveralls that prevent contamination of employees’ clothing and skin.
• Gloves appropriate to the task and contamination hazard.
• Safety footwear; disposable or cleanable boot covers where needed to control contamination.
• Hard hat and high-visibility apparel where required by the work environment.
• Hearing protection where noise exposure requires it.
• NIOSH-approved respiratory protection when required, used in accordance with the respiratory-protection program.
• Additional task-specific PPE identified by the hazard assessment.

JSA – Job Steps, Hazards, and Controls

Step 1 – Evaluate the Material and Scope of Work

Potential Hazards

• Unrecognized lead-containing material.
• Lead dust or fume exposure.
• Incorrect controls.

Required Controls

• Determine whether materials contain or may contain lead before disturbance.
• Review available surveys, sampling results, specifications, labels, SDSs, or other reliable information.
• Identify the work methods that may generate dust or fumes.
• Determine applicable exposure-assessment and compliance requirements.
• Do not begin work until required controls have been established.

Step 2 – Review Exposure Assessment and Compliance Requirements

Potential Hazards

• Excessive exposure.
• Inadequate respiratory protection.
• Unprotected employees.

Required Controls

• Review available employee exposure data for the task.
• Where required, conduct initial or additional exposure monitoring.
• Apply required interim protections to covered construction tasks until exposure assessment demonstrates otherwise.
• Identify engineering controls, work practices, PPE, respiratory protection, hygiene, and medical-surveillance requirements.
• Communicate the required controls to affected employees before work begins.

Step 3 – Establish the Regulated or Controlled Work Area

Potential Hazards

• Exposure to other employees.
• Spread of contamination.

Required Controls

• Restrict access to employees authorized to enter the lead work area.
• Use barriers, signs, distance, enclosures, or other controls appropriate to the work.
• Post required warning signs where employee exposures exceed or may exceed applicable limits.
• Keep unprotected personnel away from dust- and fume-generating operations.
• Prevent contamination from migrating into clean or occupied areas.

Step 4 – Inspect Tools and Exposure Controls

Potential Hazards

• Control failure.
• Lead dust release.
• Tool hazards.

Required Controls

• Inspect tools, guards, local exhaust, HEPA vacuums, shrouds, hoses, ventilation, and wet-method equipment before use.
• Verify engineering controls are properly connected and functioning.
• Use HEPA-filtered collection equipment where required.
• Remove defective control equipment from service.
• Stop work if required controls fail.

Step 5 – Don Protective Clothing and PPE

Potential Hazards

• Skin and clothing contamination.
• Inhalation exposure.

Required Controls

• Wear required protective clothing before entering the contaminated work area.
• Use gloves, eye protection, footwear protection, and other PPE appropriate to the task.
• Inspect PPE before use.
• Keep clean clothing separate from contaminated clothing.
• Replace damaged or heavily contaminated PPE as necessary.

Step 6 – Don Respiratory Protection

Potential Hazards

• Lead inhalation.
• Improper respirator fit or selection.

Required Controls

• Use respiratory protection whenever required by the exposure assessment, applicable lead requirements, or compliance program.
• Use only NIOSH-approved respirators selected for the anticipated exposure.
• Employees required to wear respirators shall be medically evaluated, fit tested, and trained.
• Perform the required user seal check before entering the exposure area.
• Do not wear tight-fitting respirators when facial hair or other conditions interfere with the seal.

Step 7 – Perform Manual Surface Preparation

Potential Hazards

• Lead dust.
• Contaminated debris.
• Hand injuries.

Required Controls

• Use wet methods or HEPA-equipped tools where feasible and appropriate.
• Minimize aggressive dry scraping, sanding, or brushing that creates airborne dust.
• Collect debris as it is generated.
• Avoid unnecessary disturbance of lead-containing coatings.
• Maintain required PPE and respiratory protection.

Step 8 – Perform Power-Tool Work

Potential Hazards

• High lead-dust generation.
• Flying particles.
• Noise.

Required Controls

• Use tools equipped with effective local exhaust and HEPA dust collection where feasible.
• Maintain shrouds and collection devices at the point of dust generation.
• Use wet methods when appropriate and safe for the equipment.
• Keep guards installed and follow manufacturer instructions.
• Stop work if visible dust or control failure indicates ineffective capture.

Step 9 – Perform Cutting, Welding, Burning, or Torch Work

Potential Hazards

• Lead fumes.
• Fire and hot-work hazards.
• High airborne exposure.

Required Controls

• Determine whether lead-containing coatings or materials will be heated before beginning hot work.
• Remove coatings from the heat-affected area where feasible and appropriate using controlled methods.
• Use local exhaust ventilation or other effective engineering controls.
• Follow applicable hot-work controls and respiratory-protection requirements.
• Restrict access to personnel protected for the exposure.

Step 10 – Perform Demolition or Removal

Potential Hazards

• Lead dust.
• Falling debris.
• Contamination spread.

Required Controls

• Use methods that minimize breakage and airborne dust where feasible.
• Wet materials where appropriate to suppress dust.
• Use controlled removal methods and HEPA collection as applicable.
• Place debris into suitable containers or wrapping promptly.
• Keep contaminated debris within the controlled work area.

Step 11 – Maintain Engineering Controls

Potential Hazards

• Unexpected exposure.
• Dust or fume migration.

Required Controls

• Operate ventilation, HEPA collection, wet methods, or other required controls continuously during dust- or fume-generating work.
• Observe airflow, suction, water supply, and visible emissions.
• Stop work if required controls become ineffective.
• Repair or replace failed components before resuming work.
• Do not bypass or disable exposure controls.

Step 12 – Prevent Ingestion of Lead

Potential Hazards

• Lead ingestion.
• Contamination of food or personal items.

Required Controls

• Do not eat, drink, smoke, chew tobacco or gum, or apply cosmetics in contaminated areas.
• Do not store food, beverages, tobacco products, or cosmetics in contaminated work areas.
• Wash hands and face thoroughly before eating, drinking, smoking, or leaving the work area.
• Keep personal items out of contaminated areas.
• Use designated clean areas for breaks and meals.

Step 13 – Control Contaminated Clothing

Potential Hazards

• Take-home lead exposure.
• Cross-contamination.

Required Controls

• Do not wear contaminated protective clothing into clean areas.
• Remove protective clothing in designated changing areas where required.
• Do not clean lead-contaminated clothing by blowing, shaking, or other methods that disperse lead into the air.
• Place contaminated clothing in closed, properly identified containers for laundering or disposal.
• Do not take contaminated work clothing home for laundering.

Step 14 – Perform Housekeeping

Potential Hazards

• Re-suspension of lead dust.
• Secondary exposure.

Required Controls

• Keep surfaces as free as practicable from accumulated lead dust.
• Use HEPA vacuuming or other methods that minimize airborne dust.
• Use wet cleaning methods where appropriate.
• Do not use compressed air to remove lead from surfaces unless used with a ventilation system designed to capture the airborne dust.
• Avoid dry sweeping or brushing when it could increase employee exposure.

Step 15 – Handle Lead-Contaminated Debris

Potential Hazards

• Dust release.
• Skin contamination.
• Manual-handling injuries.

Required Controls

• Keep debris damp where appropriate to minimize dust.
• Place debris into durable, compatible bags, drums, containers, or wrapping.
• Avoid dropping or dumping debris in a manner that creates dust.
• Use mechanical assistance for heavy materials.
• Keep waste containers closed except when adding material.

Step 16 – Clean Tools and Equipment

Potential Hazards

• Residual lead contamination.
• Dust release.

Required Controls

• Clean tools using HEPA vacuuming, wet methods, or other approved techniques.
• Do not use compressed air unless specifically permitted with effective dust capture.
• Decontaminate reusable equipment before it leaves the controlled area when required.
• Collect residues and cleanup materials for proper handling.
• Keep contaminated tools separate from clean equipment until decontaminated.

Step 17 – Exit the Lead Work Area

Potential Hazards

• Contamination spread.
• Ingestion exposure.

Required Controls

• Follow the established decontamination sequence.
• HEPA vacuum or otherwise remove contamination from protective clothing before removal when appropriate.
• Remove contaminated PPE without dispersing dust.
• Wash hands and face thoroughly.
• Shower at the end of the work shift where required by the applicable exposure conditions and program.

Step 18 – Manage Lead-Contaminated Waste

Potential Hazards

• Dust release.
• Environmental contamination.
• Improper disposal.

Required Controls

• Keep lead-contaminated waste in closed containers or wrapping.
• Label or identify waste as required by applicable procedures.
• Prevent containers from tearing, leaking, or releasing dust.
• Store waste in designated areas pending characterization and disposal.
• Manage and dispose of waste according to applicable environmental and site requirements.

Step 19 – Conduct Exposure Monitoring

Potential Hazards

• Unrecognized overexposure.
• Incorrect control level.

Required Controls

• Perform personal air monitoring when required by the lead standard or exposure-assessment strategy.
• Use representative monitoring where permitted and appropriate.
• Inform affected employees of monitoring results as required.
• Reassess exposure when tasks, controls, materials, or conditions change in a way that may increase exposure.
• Use monitoring results to verify the adequacy of controls and respiratory protection.

Step 20 – Participate in Medical Surveillance

Potential Hazards

• Undetected occupational lead absorption.

Required Controls

• Employees meeting applicable exposure criteria shall participate in required medical surveillance.
• Blood lead and other medical testing shall be provided as required by the applicable lead standard.
• Follow medical removal protection requirements when triggered by applicable criteria.
• Employees shall receive required medical information and physician recommendations.
• Medical information shall be handled in accordance with applicable confidentiality requirements.

Step 21 – Respond to Suspected Lead Exposure or Control Failure

Potential Hazards

• Excessive exposure.
• Contamination spread.

Required Controls

• Stop work and move to a controlled or clean location as appropriate.
• Notify supervision when engineering controls, PPE, or respiratory protection fail.
• Correct failed controls before work resumes.
• Obtain medical evaluation when significant exposure is suspected or required.
• Reassess the task and exposure-control measures before restarting.

Step 22 – Complete Final Cleanup and Inspection

Potential Hazards

• Residual contamination.
• Exposure to subsequent occupants or workers.

Required Controls

• HEPA vacuum and wet-clean surfaces as appropriate.
• Remove remaining debris and contaminated materials without generating dust.
• Inspect the area for visible residues and contamination.
• Remove barriers or reopen the area only after required cleanup and clearance procedures are complete.
• Document deficiencies and corrective actions as required.

General Safe Work Requirements

• Potential lead-containing materials shall be identified and evaluated before disturbance.
• Employee exposure shall be assessed and controlled in accordance with applicable lead requirements.
• Engineering and work-practice controls shall be used to reduce exposure before relying solely on respiratory protection.
• Regulated or controlled areas shall be established where required, and access shall be limited to authorized personnel.
• Required respiratory protection shall be used under a compliant respiratory-protection program.
• Protective clothing and equipment shall be provided and used where employee contamination or exposure warrants it.
• Food, beverages, tobacco products, gum, and cosmetics are prohibited in lead-contaminated work areas.
• Employees shall wash hands and face before eating, drinking, smoking, or leaving contaminated work areas.
• Lead-contaminated clothing shall not be taken home for laundering.
• HEPA vacuuming and wet methods shall be used for housekeeping where appropriate; dust-generating cleanup methods shall be restricted.
• Compressed air shall not be used to remove lead contamination unless the airborne dust is effectively captured by ventilation.
• Lead-contaminated debris and waste shall be contained and handled to prevent dust release and environmental contamination.
• Exposure monitoring and medical surveillance shall be performed when required.
• Medical removal protection shall be implemented when required by applicable lead standards.
• Work shall stop whenever required exposure controls, PPE, respiratory protection, hygiene facilities, or contamination controls are inadequate.

Training

Employees with occupational lead exposure shall receive training appropriate to their tasks and exposure. Training shall address the health effects of lead; operations that may result in exposure; the purpose and requirements of the applicable lead standard; engineering and work-practice controls; respiratory protection; protective clothing and equipment; hygiene practices; exposure monitoring; medical surveillance and medical removal protection; warning signs; housekeeping; waste handling; and the contents of the applicable lead compliance program.

References

• OSHA 29 CFR 1926.62 – Lead in Construction.
• OSHA 29 CFR 1910.1025 – Lead, where applicable to general-industry operations.
• OSHA 29 CFR 1910.134 – Respiratory Protection, where applicable.
• OSHA 29 CFR 1926.95 – Criteria for Personal Protective Equipment.
• Applicable exposure assessments, written lead compliance program, Safety Data Sheets, manufacturer instructions, and site-specific procedures.