Current Occupational Safety and Health Administration (OSHA) practices allow adjustments to the permissible exposure limit (PEL) for inorganic lead based on work schedules.
These adjustments can lead to significantly higher or lower allowable lead exposure compared to standard work schedules.
The existing procedure permits compliance solely through work schedule manipulation, without actual reduction in lead exposure.
Purpose of the Study:
To analyze the current OSHA practice for adjusting inorganic lead PELs for non-standard work schedules.
To evaluate the impact of work schedule adjustments on permissible lead exposure levels.
To propose a method for standardizing exposure calculations and eliminating variability.
Main Methods:
Analysis of existing OSHA guidelines and the OSHA Field Operations Manual.
Examination of the PEL adjustment procedure for inorganic lead.
Comparative assessment of exposure limits under different work schedules.
Main Results:
The PEL adjustment procedure can result in a wide range of allowable lead exposures, varying by up to sevenfold depending on the work schedule.
Work schedule manipulation alone can be used to achieve compliance with lead exposure standards.
Calculating exposure on a weekly basis, as per the OSHA Field Operations Manual, can eliminate this seven-fold range.
Conclusions:
Current OSHA practices for adjusting inorganic lead PELs for unusual work schedules are problematic and allow for significant variability in exposure.
The ability to achieve compliance solely by altering work schedules without reducing lead exposure is a critical flaw.
Implementing a weekly exposure calculation method would standardize compliance and reduce the potential for excessive exposure.