Initial Exposure Assessment Exceptions

If an employer has conducted monitoring in the past twelve months under very similar circumstances, that monitoring can satisfy the initial exposure assessment requirement. The conditions under which the previous monitoring was done must closely match the current working conditions, including processes, types of material, control methods and work practices, and environmental conditions. The previous monitoring must also be sufficiently accurate.

Employers may also rely on objective data that states that certain processes or materials will not expose employees to lead above the action level. This objective data could come from materials manufacturers or previous academic studies, as long as it is sufficiently accurate and applies to the types of activities workers will be performing. Objective data cannot, however, be used to exempt the employer from providing protection for certain activities. These activities always require protection until active monitoring proves that employees are not exposed above the action level.

To learn more about Construction Lead Exposure visit our Cal/OSHA Construction Lead Exposure Online Training web page.