OSHA aims to tighten lead exposure levels throughout industrial sectors

With OSHA considering changes to its rulemaking related to lead exposure levels, the metal fabricating sector undoubtedly will be one of the industries affected. AntonVImages/iStock/Getty Images Plus

The Occupational Safety and Health Administration (OSHA) is considering lowering permissible levels of lead in the blood of employees in various industry sectors.

More than 1,000 firms that are potentially affected by this adjustment, and some of those businesses are part of the fabricated metal product manufacturing sector (North American Industrial Classification System 332000). OSHA reports that some companies in that sector likely have employees with blood lead levels (BLLs) greater than 5 micrograms per deciliter (μg/dL). Other metal manufacturing sectors with people likely experiencing similar levels of lead exposure include motor vehicle parts, electrical equipment and components, and architectural and structural metals.

Although OSHA issued an advance notice of proposed rulemaking, the first step in potentially making changes to a federal regulation, the agency’s original announcement proved controversial enough that it agreed to push back the comment deadline two months to Oct. 28.

OSHA’s lead standard for general industry, adopted in 1978, established a permissible exposure limit airborne concentration of 50 μg/m3 averaged over an eight-hour period. It was set at that level to keep BLLs below 40 μg/dL for the majority of workers occupationally exposed to lead. Many states have already dropped state lead exposure thresholds, putting pressure on OSHA to re-examine its 45-year-old standard. For example, Michigan changed the BLL at which an employee is required to be removed from lead exposure, previously 50 μg/dL, to 30 μg/dL.

California’s most recent discussion draft calls for workers to be removed from lead exposure when a single test result shows a BLL of 30 μg/dL, when the last two monthly BLL tests are greater than 20 μg/dL, or when the average of the results of all BLL tests conducted in the last six months is at or above 20 μg/dL of whole blood.

Added Controls Needed for Some Workplace Air Emissions

Like many Environmental Protection Agency (EPA) regulations, the agency’s boiler MACT (maximum achievable control technology) rulemaking has undergone legal twists and turns since it was first finalized in 2011.

The latest iteration, published in July, will be of concern certainly to the electroplating, polishing, and anodizing industry, mentioned in the rule as a key affected sector. Manufacturers of auto parts also are likely interested in these proposed changes.

In this rule, the EPA finalizes revisions to 34 different emission limits that it had previously promulgated in 2011 and amended in 2013. Of these 34 emission limits, 28 are more stringent and six are less stringent than the previously promulgated emission limits. These are limits for industrial boilers and process heaters in industrial and manufacturing settings that emit hazardous air pollutants such as hydrochloric acid, hydrogen fluoride, mercury, filterable particulate matter, and toxic metals.

Facilities have up to three years to comply with the revised emissions limits in this final rule. Before this date, facilities must continue to comply with the rule as it was finalized in 2015.

Boilers built after 2010 are affected. To meet the revised lower emission limits, companies will have to install wet scrubbers, electrostatic precipitators, fabric filters, or some combination of those technologies.