Printreg Archive
Lead type and printers responsibility under OSHA 1910.1025

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From: SSchuler (
Date: Tue Nov 23 1999 - 11:17:56 CST

A member printer questioned me yesterday regarding their OSHA
responsibilities for using lead type in their shop. I was unfamiliar with
the OSHA lead requirements so I made some calls and did a little research.
What I found are requirements that appear to be rarely followed in the
printing industry.

As I read 1910.1025, an employer who uses lead in the workplace must conduct
an initial monitoring of a representative sample of the employees who the
employer reasonably believes are exposed to the greatest airborne
concentrations of lead in the workplace. Appendix B to 1910.1025 also
confirms this by stating that "if lead is present in the workplace where
your work in any quantity, your employer is required to make an initial
determination of whether the action level is exceeded for any employee."
Appendix B continues to state that, "this initial determination must include
instrument monitoring of the air for the presence of lead and must cover the
exposure of a representative number of employees who are reasonably believed
to have the highest exposure levels."

1910.1025(I)(1)(i) states that "each employer who has a workplace in which
there is a potential exposure to airborne lead at any level shall inform
employees of the content of Appendices A and B of this regulation."

Are printers around the country complying with these requirements? I am not
aware of any printers around these parts who have ever conducted industrial
hygiene tests to record their airborne lead concentrations or conducted any
employee training regarding the hazards with working with lead. Granted,
lead type in the modern print shop may be very rare, but some shops still
work with lead type. Any experiences that others have on this regulation,
testing or employee training would be appreciated.

Scott Schuler
Environmental Director
Printing Industry of Minnesota, Inc.
2829 University Avenue SE, Suite 750
Minneapolis, MN 55414-3222
Fax: 612-379-6030

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