CoatingsPro Magazine

JAN 2019

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106 JANUARY 2019 COATINGSPROMAG.COM Industry Insight M ost people think of lead paint as a thing of the past; however, it continues to be present in old and new coatings systems, and we continue to learn how dangerous it is in any amount. e Occupational Safety and Health Administration (OSHA) Lead in Construction Standard 29 CFR 1926.62, issued May 4, 1993, is older than the coatings applicators, engineers, and other professionals entering today's workforce. Past: Pre-2010 e initial concern about lead was primarily over exposures to deterio- rating lead in residential and public buildings. Limits were placed on the amount of lead that could be added to residential paint formulations, and thresholds for lead in paint and dust related to housing abatement were established in the '80s and '90s via the U.S. Housing and Urban Development (HUD) and Environmental Protection Agency (EPA). In industrial painting, concern regarding lead and fugitive dust release during abrasive blast cleaning triggered some state and local regulations. Many owners turned to federal EPA regula- tions already in place for lead in the ambient air and in visible emissions, and for evaluation and disposal of lead-containing hazardous wastes to control lead paint removal on bridges, tanks, and other steel structures. e EPA placed additional limits on hazard- ous wastes containing lead, known as "Land Ban," preventing disposal in land without further treatment to universal treatment standards. e OSHA Lead Standard of 1993 affected nearly every abrasive blast cleaning project in the country. It spurred the use of dust collection (i.e., ventilation) as an engineering control and the development and use of "alternative" methods, such as vacuum- shrouded power tool cleaning and the use of water, to reduce exposures to lead to below the permissible exposure limit (PEL) of 50 mg/m3. The Present We continue to encounter lead in the removal of old coating systems; however, several factors have changed in the past 10 years related to lead. e EPA reduced the National Ambient Air Quality Standard for lead in the ambient air in 2008 by 90 percent from 1.5 mg/m3 to 0.15 mg/m3 as a 90-day average. Additionally, the EPA and other agencies have published several documents indicating that lead causes more health effects at a far lower blood lead level than previously thought. Currently, OSHA estimates that 804,000 workers in general indus- try and an additional 838,000 workers in construction are potentially exposed to lead. OSHA Lead Standards require workers to be removed from lead exposure when blood lead level (BLLs) are equal to or greater than 50 micrograms per deciliter (µg/dL) (construction industry) or 60 µg/ dL (general industry). Employees are allowed to return to work when the BLL is below 40 µg/dL.OSHA regulations have remained stagnant while evidence continues to indicate ongoing issues related to industrial lead paint removal. In 2015, the National Institute for Occupational Safety and Health (NIOSH) designated 5 µg/dL as the reference BLLs for adults. OSHA's own website suggests that we should voluntarily reduce BLLs to NIOSH- recommended levels and implement more rigorous medical removal criteria than currently required by law. e Consumer Product Safety Improvement Act of 2008 lowered the allowable concentration of lead in residential paint from 0.06 percent (600 ppm) to 0.009 percent (90 ppm). e EPA (in response to a court order) proposed reducing the lead dust levels from 40 mg/ft.2 for floors and 250 mg/ ft.2 for window sills to 10 mg/ft.2 and 100 mg/ft.2, respectively. Future: 2019 and Beyond OSHA regulations for lead will catch up with current science. Several states have proposed more conservative regulations than the current federal offerings, reducing both allowable BLLs and the airborne PEL for lead. e EPA is still under court order to reduce the regulatory level for lead in paint. W hile we wait, worker exposures and health effects continue to occur. CP Photo courtesy of the author By Alison B. Kaelin is the Principal of ABKaelin, LLC Lead Paint Is Not Only in the Past

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