On August 6, 2015, OSHA, which regulates 35 heavy metals, took its most recent action regarding a heavy metal by proposing to drastically lower the eight-hour permissible exposure limit for beryllium from 2.0 micrograms per cubic meter to 0.2 micrograms per cubic meter. Beryllium can cause devastating lung disease. This regulatory action highlights the seriousness of heavy metal exposure, and the importance of ensuring that your organization is compliant and prepared for these occurrences. Below are three effective strategies to help prepare for employees’ exposures to heavy metals.
Strategy one: Know your at-risk employees and OSHA regulations
First, can you identify your employees who are at risk of heavy metal exposure? In order to effectively identify at-risk employees, you need to understand regulations and the job responsibilities in various functions across all of your sites.
OSHA estimates that 35,000 workers would be covered by its beryllium proposal. The agency also estimates that 300,000 workers are exposed to cadmium; 558,000 workers are exposed to hexavalent chromium; and 804,000 workers in general industry, and another 838,000 construction workers face lead exposures.
OSHA’s Website has a toxic metals topic page https://www.osha.gov/SLTC/metalsheavy/index.html, which is a good place to get an overview of the agency’s heavy metals regulations. There, you’ll find links to standards on aluminum, antimony, arsenic, beryllium, cadmium, copper, hexavalent chromium, iron, lead, manganese, mercury, molybdenum, nickel, selenium, silver, tin, vanadium, and zinc.
Let’s take a closer look at OSHA’s lead standard. Occupational exposure to lead is one of the most prevalent overexposures. Industries with high potential exposures include construction work, most smelter operations, radiator repair shops, and firing ranges. Employers are required to protect workers from inorganic lead exposure under OSHA lead standards covering general industry (1910.1025), shipyards (1915.1025), and construction (1926.62). The lead standards establish a permissible exposure limit (PEL) of 50 µg/m3 of lead over an eight-hour time-weighted average for all employees covered. The standards also set an action level of 30 µg/m3, at which an employer must begin specific compliance activities.
Strategy two: Determine PPE needs
Your second strategy is to determine specific compliance activities, particularly the required use of personal protective equipment (PPE) and medical surveillance. OSHA’s lead standard stipulates that when any employee is exposed to lead above the PEL for more than 30 days per year, engineering and work practice controls (including administrative controls) must be implemented, unless such controls are not feasible. In that case, controls should reduce exposures to the lowest feasible level and be supplemented by the use of respiratory protection. For employees exposed to lead above the PEL for 30 days or less per year, engineering controls are to be implemented to reduce exposures to 200 ug/m3, and then any combination of engineering, work practice (including administrative controls), and respiratory protection can be used to reduce and maintain employee exposure to lead to or below 50 ug/m3.
If engineering and work practice controls do not reduce employee exposure to or below the 50 ug/m3 PEL, employers must supplement controls by following the requirements of OSHA’s respiratory protection standard 1910.134. If an employee has breathing difficulty during fit testing or respirator use, employers must provide the employee with a medical examination to determine whether or not the employee can use a respirator while performing the required duty.
Employers must provide employees with full face piece respirators instead of half-mask respirators for protection against lead aerosols that cause eye or skin irritation at use concentrations. HEPA filters must be provided for powered and non-powered air-purifying respirators. A powered air-purifying respirator (PAPR) must be provided instead of a negative-pressure respirator when an employee chooses to use a PAPR and it provides adequate protection.
In addition to respiratory protection, if the possibility of skin or eye irritation exists, OSHA’s lead standard requires employers to provide coveralls or similar full-body clothing, gloves, hats, shoes or disposable shoe covers, face shields, vented goggles, and other appropriate PPE.
Employers must institute a medical surveillance program for all employees who are or may be exposed at or above the action level of the lead standard for more than 30 days per year. All medical examinations and procedures are to be performed by or under the supervision of a licensed physician. Biological monitoring includes blood lead and ZPP (zinc protoporphyrin) level sampling and analysis. The frequency of testing ranges from one to six months, depend on exposure levels, and follow-up testing depends on the level of risk exposure and test results.
OSHA’s standard states that blood lead level sampling must have an accuracy (to a confidence level of 95 percent) within plus or minus 15 percent or 6 ug/100 ml, whichever is greater, and must be conducted by a laboratory licensed by the Center for Disease Control, United States Department of Health, Education and Welfare (CDC), or which has received a satisfactory grade in blood lead proficiency testing from CDC in the prior 12 months.
Strategy three: Developing a medical surveillance program
A medical surveillance program actively monitors and tracks employee health over time. This tracking allows for full access to health records and test results and can be used to determine if any changes have occurred to the employee’s health. Monitoring changes over time offers insights into specific risks an employee is being exposed to while on the job, by comparing present day test results to previous results.
Managing a medical surveillance program can seem like a daunting task when considering the effort involved in the tracking, billing, scheduling, and monitoring of medical records and compliance regulations. However, utilizing a centralized model in which everything necessary for running a medical surveillance program is located in one location can greatly reduce administrative burden and increase regulatory compliance at the same time.
A centralized occupational health model provides two distinct benefits. The first is through medical oversight. Utilizing a network of credentialed clinics and in-house medical review officers ensures consistency and standardization across all processes and medical reviews. Secondly, administrative tasks are all centrally located and easy to access 24/7. The administrative benefits of the centralized model include: scheduling, consolidated billing with consistent pricing, electronic medical record management – decreasing turnaround time of important clearances, and ensuring data is accurate and secure.
Utilize all three of the above strategies to ensure that your organization and workforce are compliant and prepared for heavy metal exposures. Deciding which employees could be at risk, and determining their PPE and medical surveillance needs, limits the chances of an accidental exposure. Partnering with an occupational health specialist to manage a medical surveillance program will ensure proper monitoring of employee health over time to determine if an exposure has occurred.