Protection During the Initial Assessment

Until an assessment has been made by the employer, any activity that might expose workers to lead must be treated as though those activities result in exposure above the permissible exposure limit, and the employer must implement proper protection. Certain activities known as "trigger tasks" are not exempt from safety precautions (such as respirators and protective clothing) if the objective data mentioned previously is used as an initial assessment. The trigger tasks are divided into three categories - level 1, level 2, and level 3.

Until the initial assessment is complete, employees in any of these three categories must be provided with appropriate respiratory protection, personal protective clothing and equipment, changing areas, hand washing facilities, biological monitoring, and training, all of which will be discussed in a later section. Once the assessment is complete, employers will provide protection according to the level of exposure that the assessment found to be the case. All assessment results must be recorded, and employees must be notified of the results within five days of the assessment's completion.

Level 1 Trigger Tasks

If lead coatings or paint are present, any employees doing the following must be treated as though they are exposed to lead above the permissible exposure limit but below ten times the permissible exposure limit until proven otherwise:

• Demolishing structures such as drywall by hand
• Manual scraping or sanding
• Using a heat gun
• Cleaning power tools with dust collection systems
• Spray painting with lead paint

This also applies to other situations where the employer has reason to believe that workers may be exposed to lead above the permissible exposure limit. We refer to these as "level 1 trigger tasks."

Level 2 Trigger Tasks

If lead is present, any employees doing the following must be treated as though they are exposed to 500 micrograms per cubic meter until proven otherwise: burning lead; rivet busting; cleaning power tools without dust collection systems; doing cleanup activities where dry abrasives were used (such as sanding or blasting); or moving or removing the enclosures for abrasive blasting. We refer to these as "level 2 trigger tasks."

Level 3 Trigger Tasks

If lead is present, any employees doing the following must be treated as though they are exposed to 2,500 micrograms per cubic meter until proven otherwise: abrasive blasting, welding, cutting, and torch burning. We refer to these as "level 3 trigger tasks."

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