Establishing a Compliance Program

If the results from initial monitoring prove employee lead exposure levels are above the PEL, employers must establish a written compliance training program.

A compliance program's goal is to reduce employee exposure to the PEL (or, better yet, below the PEL). It is a detailed program that includes the following:

• Air monitoring data showing the source(s) of lead emissions
• Plans for a competent person to frequently inspect job sites, materials, and equipment
• Information related to the worksite's technologies considered to meet the PEL
• A work practice program (which details the use of protective equipment and safety procedures)
• For multi-contractor sites, plans and actions to make all employees aware of potential lead exposure
• A detailed schedule for implementing the compliance program, including copies of documentation (such as purchase orders for equipment and construction contracts)
• An administrative control schedule to implement the program (if needed or applicable)
• A detailed description of each activity involving lead. This includes the equipment used, materials involved, the current controls in place, the crew size, each employee's job responsibilities, the standard operating procedures, and all maintenance practices.

Please note that the final bullet illustrates that a compliance program requires engineering plans and studies in order to determine the necessary engineering controls. You will learn about this in the next section.

Also note that employers must review and update written compliance programs at least every six months.

To learn more about Construction Lead Safety visit our Construction Lead Safety Online Training Certification web page.