CA May Cut Lead Limits Again
California regulators say they are taking a closer look at 30-year-old standards concerning work-related exposure of lead.
They have called the current lead exposure limits in play outdated and harmful to human health.
The California Division of Occupational Safety and Health (Cal/OSHA) has issued draft discussion changes for both general industry and construction standards that would cut permissible exposure limits (PELs) by five times their current level and blood lead levels by up to six times.
The proposed revisions are for discussion only and are not a rulemaking proposal, Cal/OSHA noted.
The desire to update state's lead standards has generated years of discussion between the California Department of Public Health and Cal/OSHA. Current rules reflect toxicity information that is more than 30 years old, officials say.
"Current medical information clearly demonstrates harmful effects of chronic and low-level exposure to lead in adults, at levels well below those currently allowed by the standards," the CDPH noted in its recommendations for improving the state's standards.
Cal/OSHA held an advisory meeting at 9:30 a.m. PT Thursday (June 12) in Oakland, CA, to give stakeholders an opportunity to provide feedback on proposed revisions to the lead standards.
Changing the PEL
According to a summary of changes, the draft discussion proposes permissible exposure limit of 10 µg/m3 (currently 50 µg/m3) and an action level of 2 µg/m3 (currently 30 µg/m3) averaged over an eight-hour period.
These limits are necessary to maintain blood lead levels below 10 micrograms per deciliter of blood (µg/dL), the CDPH said.
The CDPH Occupational Lead Poisoning Prevention Program reviewed scientific information and made health-based recommendations to Cal/OSHA for revising its current General Industry Lead Standard and Lead in Construction Standard.
CDPH first recommended changes to Cal/OSHA in 2011 for construction standards and in 2010 for general industry standards; the changes included lowering the PEL to 0.5-2.1 µg/m3 over and eight-hour workday.
Public health agencies have recommended that BLLs be maintained below this level over a working lifetime to avoid reproductive problems and longterm damage to target organs.
However, current standards allow BLLs up to 50-60 µg/dL before workers have to be removed from significant lead exposure.
"We know this level is harmful to health," CDPH stated.
The draft discussion includes changes to BLL testing protocols and frequency. Employers would offer initial testing, followed by testing every two months for the first six months of employment, and then every six months after that. Currently, this is required only by the construction standard.
If an employee's BLL is 10 µg/dL or higher, it would trigger continued testing every two months—something currently required at a BLL of 40 µg/dL—and monthly testing would be required at levels of 20 µg/dL, which is currently required for those on medical removal protection.
Employers would be required to investigate any BLL at or above 10 µg/dL and correct any workplace factors that contributed to the elevated levels.
"Current medical information clearly demonstrates harmful effects of chronic and low-level exposure to lead in adults, at levels well below those currently allowed by the standards," the California Department of Public Health said.
Testing for zinc protoporphyrin would not be required unless the employee's BLL was 20 µg/dL or higher.
Currently, employees in general industry must be placed on medical removal protection if the average of their last three BLL tests is 50 µg/dL or higher; in construction, employees are removed if their last two BLLs average 50 µg/dL or more. The draft proposes placing workers on medical removal protection if their BLLs are above 20 µg/dL for two tests spaced one month apart, or a single BLL of 30 µg/dL or higher.
Focus on Reproductive Health
Under the draft proposal, employee training would highlight the vulnerability of reproductive health to low-level lead exposure and the importance of medical consultation. Protecting reproductive health would be listed as a factor to consider in any physician-recommended special protective measures.
The draft would require that food and beverages are kept out of work areas and hand washing facilities are available.
For the general industry, altering or disturbing lead for over eight hours during any 30-day period would trigger the same protections currently given to employees with exposure over the action level.
Employers would also be required to provide protective clothing, changing rooms, clean eating areas and signs to employees performing threshold work.