OSHA Targets Primary Metal Industries for Lead and PPE

OSHA Targets Primary Metal Industries for Lead and PPE
On May 19, 2011, OSHA began implementing a National Emphasis Program (NEP) to reduce or eliminate harmful worker exposure to both chemical and physical (heat and noise) health hazards encountered in the Primary Metal Industries (SIC Major Group 33). These industries include smelting and refining ferrous and non-ferrous metals, extracted from ore, pig and scrap, drawing, casting and alloying operations. OSHA contends that OSHA inspection history shows that Primary Metal Industry employees are exposed daily to serious health and safety hazards, including noise, heat, lead, silica, carbon monoxide, formaldehyde, metal dusts and fumes, and a variety of other chemicals. These industries were targeted because of all establishments that had at least one (1) employee with a blood lead level (in 2005) of 30 micrograms per 100 grams of whole blood (mcg/100g) or more, 26% of them (more than 1 in 4) were employed in the Primary Metal Industries. A blood lead level of 30 mcg/100g is the OSHA trigger point for removing an employee from lead exposure.

OSHA compliance officers will examine the employer’s hazard assessment (required under 29CFR1910.132(d)) and the type(s) of Personal Protective Equipment (PPE) selected for employee use as a result of the assessment. They will also examine MSD Sheets to verify that all hazardous chemicals brought into the establishment have a corresponding MSD Sheets and that the hazards identified have been properly addressed by the employer. If the employer has decided to require respiratory protection (respirators), the Compliance Officer will check to see that the employees have been medically qualified, trained, allowed to select an appropriate respirator and fit tested, and air testing (personnel sampling) to determine the proper respiratory protection in accordance with the Respiratory Protection standard (29CFR1910.134). Finally, since by definition, there are hazardous chemicals (lead, for example) present at the facility. The Compliance Officer will review the Hazard Communication program to ensure that it is in conformity with the requirements of 29CFR1910.1200 (Hazard Communication Standard).

Once the program and documentation evaluation is complete, the OSHA inspector will do air sampling to determine if any applicable OSHA exposure standards have been exceeded. This process may take several days, especially if the inspector finds “irregularities.” If the OSHA Compliance Officer finds areas of non-compliance, citation(s) will, in all likelihood, be issued.
Atlantic Environmental’s staff of experienced health and safety experts can identify areas of vulnerability in your health and safety program, and help you bring them into compliance.

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