Need Feedback on OSHA’s Proposal to Revise Lead Exposure Standard
by Gary Jones, Vice President of Environmental, Health, and Safety Affairs Jul 5, 2022

On June 28, 2022, the Occupational Safety and Health Administration (OSHA) began the process of revising the standards for occupational exposure to lead. OSHA has not revised the lead standard since 1978 for general industry.

As a summary, OSHA’s lead standard establishes a permissible exposure limit (PEL) of 50 μg/m3 of lead over an eight-hour time-weighted-average for all employees covered. The standards also set an action level of 30 μg/m3, at which an employer must begin specific compliance activities, including blood lead testing for exposed workers. The lead standard includes additional provisions such as medical surveillance, exposure monitoring, and hygiene facilities and practices that are critical in preventing lead exposure and elevated blood lead levels.

OSHA’s blood lead level for medical removal is 60 micrograms per deciliter or more for general industry. The return-to-work blood lead level is less than 40 micrograms per deciliter. Recent medical research on workplace lead exposure shows adverse health effects can occur in adults at lower blood lead levels than recognized previously in the medical removal levels specified in OSHA’s lead standards.

OSHA is seeking input on many parts of the standard including:

  • Blood lead levels for medical removal and return to work
  • Medical surveillance provisions, including triggers and frequency of blood lead monitoring
  • Permissible exposure limits
  • Ancillary provisions for personal protective equipment, housekeeping, hygiene and training

Since OSHA has begun the regulatory process, we need to determine the extent of lead use that is currently occurring in the printing industry. Therefore, we have several questions that we need your feedback on:

  • Are you currently using lead type for any printing application, even if it is a small part of your business?
  • Are you currently melting lead to make lead type?
  • Are you using any inks that contain lead-based pigments, for example yellow or orange?
  • Are you using any substrate that contains lead, for example, some plastics, such as PVC, can have lead in it as a stabilizer?
  • Are you using any other product that contains lead and if so, what are the products?

We do need your feedback so we can better understand any ramifications associated with OSHA’s rulemaking and how we need to interact with OSHA on the rulemaking. Please feel free to contact Marci Kinter, mkinter@printing.org, Gary Jones, gjones@printing.org, or Adriane Harrison, aharrison@printing.org with the answers to the questions.  

PRINTING United Alliance seeks to keep the printing industry updated on workplace requirements related to OSHA compliance. Please let us know if you have any questions.
Environmental Health / Safety Regulations
Gary Jones Vice President of Environmental, Health, and Safety Affairs
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Gary A. Jones is the Vice President of Environmental, Health and Safety (EHS) Affairs at PRINTING United Alliance in Fairfax, VA. His primary responsibility is to monitor and analyze EHS regulatory activities at all domestic and some international government levels. He provides representation on behalf of the printing and specialty graphic imaging industry. Mr. Jones works closely with the federal and state-level Environmental Protection Agencies (EPA), Occupational Safety and Health Agency (OSHA), Department of Transportation (DOT), and other agencies. He also provides membership assistance on EHS compliance and sustainability programs through a variety of approaches including responding to inquiries, presentations, writing, and consulting services.

He holds a BS in biology from LaRoche College and an MS in chemistry from the University of Pittsburgh.

Speaking Topics:

  • Regulatory compliance and sustainability
  • Webinars on a wide variety of EHS related topics
  • Customized seminars and workshops, including: Compliance Today, Beyond Compliance Tomorrow, OSHA Compliance Essentials, and Hazardous Waste Boot Camp
  • Two-day workshops Environmental Compliance for Printers and OSHA Compliance for Printing

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