Hazard Assessment & Initial Monitoring

How do you know if a worksite is lead-free? If a worksite contains lead, how do you know its lead levels will not cause overexposure?

Employers must conduct hazard assessment (often called "initial employee exposure assessment" or "initial monitoring") to determine lead levels. This determines if they must take actions (like establishing compliance programs or supplying PPE) to prevent worker overexposure.

Hazard assessment includes compiling the following:

• Information, observations, or calculations showing employee lead exposures
• Any prior measurements of airborne lead (from previous monitoring)
• Any employee complaints of symptoms possibly related to lead exposure

Initial monitoring can be minimal (for example, using a select number of employees possibly exposed to the greatest amount of lead, then using this group as a representative sample). This process (called "representative exposure sampling") is allowed when many employees perform the same job and have exposure around the same lengths of time each day.

Employers must establish and maintain accurate previous exposure data records. (You will learn about this in detail later. For now, note that a hazard assessment through initial monitoring must take place to establish the levels of lead exposure in the workplace.)

Please note that in its "Lead in Construction" PDF, OSHA states that "Instead of performing initial monitoring, the employer may in some cases rely on objective data that demonstrate that a particular lead-containing material or product cannot result in employee exposure at or above the action level when it is processed, used, or handled."

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