Lead Content Unknown Checklist

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Labor Occupational Health Program

Summary Statement

Checklist of items to perform if it is known that there is lead on a job but the amount is unknown. Includes training, respirators, other PPE and hazard identification. Part of a collection. Click on the 'collection' button to access the other items.

These tailgate/toolbox talks were developed for use under California OSHA regulations. The complete set is available from the Labor Occupational Health Program at UC Berkeley. For ordering information, visit the website (www.lohp.org) The American Conference of Government Industrial Hygienists (ACGIH) has adapted these talks to apply to federal OSHA regulations. To contact ACGIH, visit its web site (www.acgih.org).

Date Prepared:_________________________ By:_______________________
Project Name/No.______________________ Location:__________________

  • Use this Checklist if the amount of lead exposure on the job is unknown. If it is known, use Checklist A.
  • Check the box if the statement is true.

  • Fill in the blanks where the Pencil Iconappears.


  • There is lead present on the job, but the amount of worker exposure is unknown because an exposure assessment has not yet been completed.

    If the amount is known, use Checklist A.

    Cal/OSHA requires that worker exposure be kept at or below 50 micrograms of lead per cubic meter of air (50 µg/m³), as an 8-hour average. This is called the 8-hour permissible exposure limit (PEL). [1532.1(c)]

    If you do not have data to adequately document the amount of lead exposure, you must treat employees as if they are exposed above the PEL. The precautions shown in this Checklist must be taken; the various protective measures depend upon the specific type of work being done. [1532.1(d)(2)(i)]


  • The company has a written Injury and Illness Prevention Program (IIPP) that meets all Cal/OSHA requirements. It includes identification of lead hazards on the site, regular inspections, accident investigation, and correction of hazardous conditions. [1509]


  • The company has a written Hazard Communication Program. [5194]
  • All employees have received basic Hazard Communication training. [5194]
  • Any employee who may be exposed to airborne lead at or above the action level on any given day has received initial training about lead prior to job assignment and receives annual training thereafter. [1532.1(l)(1)]
  • Copies of the Cal/OSHA lead standard are readily available to affected employees. [1532.1(l)(2)(i)]
  • Clear lead warning signs are posted in each work area where lead is above the PEL. [1532.1(m)(2)(i)]
  • For any new lead-containing products, containers are properly labeled. [5194(b)(1) and 5417(a)]
  • Material Safety Data Sheets (MSDSs) are available on the site for all new lead-containing products used. [5194]
  • Workers know where to find MSDSs and how to understand them. [5194]
  • Personnel working in adjoining areas of the job site, including subcontractors, are aware of the work and the hazards. [1509]
  • The company has a written lead compliance program. [1532.1(d)(2)(v)(F)]


  • If lead, lead paints, or lead coatings are involved but the amount of exposure is unknown, approved respiratory protection is provided by the company and used by workers performing the tasks shown below. [1532.1(d)(2)]

    • For spray painting, manual demolition, manual scraping, manual sanding, use of a heat gun, or cleaning a power tool while using a dust collection system, workers are provided with either: a half-mask air purifying respirator with a HEPA filter


    • a half-mask air supplied respirator operated in demand (negative pressure) mode.


  • For work using lead-containing mortar, burning lead, rivet busting, cleaning up with a dry expendable abrasive, moving and removing an abrasive blasting enclosure, or cleaning a power tool without using a dust collection system, workers are provided with either:

    • a powered air purifying respirator with a loose-fitting hood or helmet and a HEPA filter


    • an air supplied respirator with a hood or helmet, operated in continuous-flow mode.

  • For abrasive blasting, welding, cutting, or torch burning, workers are provided with a half-mask air supplied respirator operated in positive pressure mode.

The following respiratory protection measures are also in place:

  • Respirators are properly stored and maintained. [1531(d)]
  • Respirators, cartridges, and replacement parts have been approved by the Mine Safety and Health Administration (MSHA) or the National Institute for Occupational Safety and Health (NIOSH). [1531(b)]
  • Workers who wear respirators have been medically evaluated, fit-tested, and trained. For negative pressure respirators, fit-testing is repeated at least every 6 months. [1531(c) and (h), and 1532.1(f)(3)]
  • If respirators are used on the site, the company has a written Respiratory Protection Program. [1531(f) and 1532.1(f)(4)]
  • Powered air purifying respirators are provided to employees who request them if they are determined to provide adequate protection. [1532.1(f)(2)(ii)]
  • Only air supplied respirators, with grade D breathing air, are worn in low oxygen areas (less than 19.5% oxygen). [1531(a) and (e)]
Pencil Icon

Possible low oxygen area(s) on this site:


PROTECTIVE CLOTHING [1532.1(d)(2))v)(B)]

  • Protective clothing is provided to employees who may be exposed to lead above the PEL or any employees who are exposed to lead compounds that may cause skin irritation. (Examples: coveralls, gloves, hats, shoes or shoe coverlets, face shields, vented goggles.)
  • Impermeable gloves of the correct type are worn to prevent skin contact with lead. [1520] (To determine the appropriate glove, consult the MSDS for the product, or contact the glove supplier or manufacturer.)
  • Eye and face protection meets the requirements of American National Standards Institute (ANSI) Z 87.1 1979, American National Standard Practice for Occupational and Educational Eye and Face Protection. [1516]
  • Employees who may be exposed to lead above the PEL are provided clean, dry protective clothing at least weekly. [1532.1(g)(2)(i)] Contaminated clothing is removed in designated change areas and placed in properly closed and labeled containers. [1532.1(g)(2)(v) and (vii)]
  • Lead is not removed from clothing by blowing, shaking, or any other method that would create lead dust. [1532.1(g)(2)(viii)]
  • Persons laundering or cleaning lead contaminated clothing are informed in writing about the harmful effects of lead exposure. [1532.1(g)(2)(vi)]
  • Employees are provided with a clean change room. [1532.1(d)(2)(v)(C)]
  • Employees are provided hand washing facilities [1532.1(d)(2)(v)(D)]
  • Employees are provided initial medical surveillance. [1532.1(d)(2)(v)(E)]

Other Hazards Noted Action

Near Miss Reports: