Lead Compliance Program
Exposure assessment, engineering controls, hygiene, medical surveillance, EBLL procedures.
What this document is
This document is a written Lead Compliance Program that satisfies OSHA requirements for contractors who disturb or work with lead-containing materials. It provides procedures for exposure assessment, engineering controls, hygiene practices, medical surveillance, and elevated blood lead level response.
The regulation that requires it
The key federal standards are 29 CFR 1926.62 for construction and 29 CFR 1910.1025 for general industry. These rules require employers to assess employee exposure to lead, implement engineering and work practice controls, provide hygiene facilities, conduct medical surveillance, and maintain records when employees may be exposed at or above the action level. In California the parallel requirements appear in Title 8 CCR Section 1532.1 for construction and Section 5198 for general industry.
Who needs it
General contractors, specialty trades, demolition crews, painters, plumbers, and anyone disturbing painted surfaces or lead-containing materials on construction sites need this program. It applies to all U.S. employers covered by federal OSHA and is especially important for California contractors who must also satisfy Cal/OSHA enforcement of Title 8 standards.
What happens without it
OSHA and Cal/OSHA inspectors routinely check lead work on renovation and demolition sites. A serious violation currently carries a maximum penalty of $16,131 while a willful or repeated violation can reach $161,323 per violation. Multi-employer work sites increase citation risk because the controlling contractor can be cited for subcontractors' failures to follow lead-safe procedures.
What's included in the generated document
- Scope and responsibilities
- Exposure assessment and monitoring procedures
- Engineering controls and work practices
- Hygiene facilities and decontamination
- Medical surveillance and elevated blood lead level procedures
How to implement it at your company
- Talk to Guy first. Describe your operation, trade, and location — Guy draws from 300,000+ verified OSHA and state regulatory citations to build a compliance plan specific to your company. Your answers shape every section of the document you receive. Takes about 10 minutes.
- Review the document and edit the company-specific information in the highlighted fields.
- Designate a competent person to oversee lead-related activities and train supervisors on the procedures.
- Distribute the program to all employees who may encounter lead and document their training.
- Integrate the exposure assessment and medical surveillance schedules into your existing safety program.
- Keep the written program on site and available for inspection along with monitoring records and medical surveillance results.