Alert to Pennsylvania foundries – OSHA lead program emphasis
The Non-Ferrous Founders' Society has recently become aware of several referrals from clinical laboratories to the State of Pennsylvania for instances where a foundry employee’s blood lead levels exceeded 25 micrograms per deciliter (μg/dL), as required by Pennsylvania Law (28 Pa. Code § 27.34). This has resulted in at least two separate foundry inspections by PA-OSHA in response to these notifications in the past month.
These OSHA inspections have resulted in requests for a tremendous amount of information for review from the foundries, including:
- Written Hazard Communication Programs
- Hazard Communication Training Records
- Written Respiratory Protection Program
- List of the different types of respirators required and worn voluntarily worn
- Copies of the most recent fit testing records for respirators
- Written lead compliance program
- Lead Program Training Records
- Lead Air Sampling Records for the past year
- Medical Removal Records
- Medical Surveillance Records for the past year
- Copies of the Physicians professional determination of approval to wear respirators for each employee
If your foundry is located in the State of Pennsylvania and you have anyone in your foundry with a blood lead level at or above 25 (μg/dL), you should anticipate referral to OSHA and a possible in-plant inspection with a request for the record sets and data identified above. Please review your written programs and record sets to ensure that they are up to date and complete!
If you have anyone in your plant who is at or above 40 (μg/dL) blood lead levels, you should take measure immediately to reduce these levels.
Please contact NFFS if you would like assistance in taking measures reduce your employees' blood lead levels.