Health Hazard Evaluation Report 2016-0242-3315 Page 1

Evaluation of Exposure to Metals at an 

Electronics Recycling Facility

HHE Report No. 2016-0242-3315

May 2018

George R. Grimes, MD, MPH

Catherine C. Beaucham, MPH, CIH

Jessica G. Ramsey, MS, CPE
Page 2 Health Hazard Evaluation Report 2016-0242-3315

Contents

Highlights...............................................i

Abbreviations ..................................... iii

Introduction......................................... 1

Methods ............................................... 3

Results and Discussion........................ 4

Conclusions.......................................... 9

Recommendations............................... 9

Appendix A ........................................ 13

Appendix B ........................................ 14

References.......................................... 23

Acknowledgements........................... 29

The employer is required to post a copy of this report for 30 days at or near the 

workplace(s) of affected employees. The employer must take steps to ensure 

that the posted report is not altered, defaced, or covered by other material.

The cover photo is a close-up image of sorbent tubes, which are used by the HHE 

Program to measure airborne exposures. This photo is an artistic representation that may 

not be related to this Health Hazard Evaluation. Photo by NIOSH.
Health Hazard Evaluation Report 2016-0242-3315 Page i

We evaluated employee 

exposures to metals, including 

lead and cadmium, at an 

electronics recycling facility. 

Personal air concentrations 

of metals did not exceed 

any applicable occupational 

exposure limits. Blood lead 

and cadmium levels were 

below biological exposure 

indices. We found lead and 

cadmium on employees’ 

hands after they washed them. 

We recommended that the 

employer provide employees 

with a lead-removing product to 

wash their hands and to include 

all employees in a lead exposure 

prevention program.

Highlights of this Evaluation

The Health Hazard Evaluation Program received a request from an electronics recycling 

company. The managers were concerned about exposure to metals and flame retardants.

What We Did

● We evaluated the electronics recycler in February 2017 and July 2017.

● We collected surface, hand wipe, and air samples for metals including lead and cadmium.

● We collected blood samples for lead and cadmium.

● We observed employees during routine work activities.

What We Found

● We found lead and cadmium in the employees’ 

blood, but none of the employees’ blood samples 

were above reference levels.

● None of the air samples exceeded 

occupational limits.

● We found lead and cadmium on the employees’ 

hands after they had washed them.

● We observed employees eating and drinking 

in the processing area and smoking as they 

unloaded electronics equipment.

What the Employer Can Do

● Include all employees in a lead exposure 

prevention program.

● Provide employees with a lead-removing 

product to wash their hands.

● Prohibit the use of compressed air to 

clean electronics.

● Maintain a respiratory protection program in 

accordance with Washington’s Department of 

Occupational Safety and Health’s respiratory protection standard.

● Review and update the personal protective equipment hazard assessment, which is 

included as part of the accident prevention plan, to make sure that it includes all of the 

necessary personal protective equipment.

● Offer a smoking cessation program to employees.
Page ii Health Hazard Evaluation Report 2016-0242-3315

What Employees Can Do

● Wash your hands with a lead-removing product before eating, drinking, or smoking and 

before leaving work.

● Do not dry sweep. Use wet cleaning methods or vacuum instead. 

● Do not use compressed air to clean electronics.

● Do not eat, drink, or smoke in work areas.

● Stop smoking.
Health Hazard Evaluation Report 2016-0242-3315 Page iii

Abbreviations

μg/m3 Micrograms per cubic meter

μg/dL Micrograms per deciliter

μg/L Micrograms per liter

ABLES Adult Blood Lead Epidemiology and Surveillance

ACGIH® American Conference of Governmental Industrial Hygienists

Be Beryllium

BLL Blood lead levels

Cd Cadmium

CFR Code of Federal Regulations

Cr Chromium

Co Cobalt

Cu Copper

HEPA High-efficiency particulate air

ND Not detected

NIOSH National Institute for Occupational Safety and Health

OEL Occupational exposure limit

OSHA Occupational Safety and Health Administration

Pb Lead

PEL Permissible exposure limit

PPE Personal protective equipment

REL Recommended exposure limit

STEL Short-term exposure limit

TLV® Threshold limit value

TWA Time-weighted average
Page iv Health Hazard Evaluation Report 2016-0242-3315

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Health Hazard Evaluation Report 2016-0242-3315 Page 1

Introduction

The Health Hazard Evaluation Program received a request from managers at an electronics 

recycling company. The request concerned possible employee exposures to flame retardants 

and metals associated with electronics. We first visited the facility in February 2017. We 

held an opening meeting and toured the facility to observe operations, work practices, and 

working conditions. We returned in July 2017 to collect air, hand wipe, and blood samples 

for metals. The National Institute for Occupational Safety and Health (NIOSH) Industrywide 

Studies Branch evaluated employees’ exposure to flame retardants in July 2017 and will 

provide the results to the company and employee representatives in a separate report. We 

provided preliminary observations and recommendations to the employer and the employee 

representatives in February 2017 and July 2017.

Background

Electronic devices contain many hazardous components including flame retardants and heavy 

metals. Previous health hazard evaluations in electronics recycling facilities [NIOSH 2009, 2014] 

noted employee overexposures and potential take-home exposures to metals such as lead and 

cadmium. More detailed information about lead and other metals is available in Appendix B.

Common Elements in Electronic Scrap Recycling

Elements often found in electronic scrap waste streams vary because of the wide variety 

of electronic components that are recycled. Additionally, the concentration of elements 

may change over time, depending on the type and amount of electronics equipment being 

recycled. Elements commonly found in electronic scrap waste streams include the following:

● Beryllium (Be) – older printed circuit boards

● Cadmium (Cd) – nickel-cadmium batteries, printed circuit boards, pigments, plastic 

stabilizers, metal coatings, and coating on cathode ray tube glass

● Chromium (Cr) – data tapes, floppy disks

● Cobalt (Co) – batteries

● Copper (Cu) – wiring

● Lead (Pb) – cathode ray tube glass, batteries, solder, and older printed circuit boards

Process Description

The company opened in 2011 and has been in this location since June 2014. They lease 

the space and share the building with another company. The office area shares the heating, 

ventilation, and air-conditioning system with the other company, and the warehouse has two 

large bay doors that remain open throughout the day. They only do manual recycling and do 

not have a shredder. They do not recycle alkaline batteries, floppy disks, light bulbs, flatpanel displays, cathode ray tubes, or wood products. They accept electronics from companies 

as well as from the community. The company has 12 to 14 employees at this location. 
Page 2 Health Hazard Evaluation Report 2016-0242-3315

Employees often rotate to different jobs, as needed, to fulfill processing demands. The facility 

layout is located in Appendix A.

Driving and Receiving

Driving and receiving employees picked up electronics from businesses and homes. 

Electronic equipment was loaded onto a truck and then transported into the warehouse 

manually and with a dolly. The driver and one or two employees would assist in unloading 

the truck. The equipment was taken directly to sorting and inventory stations. 

Sorting and Inventory

Sorting and inventory employees evaluated and sorted electronics brought into the warehouse 

on the basis of whether the electronics were “end-of-life” or reusable. Electronics categorized 

as end-of-life were sent through the disassembly process. Reusable electronics were sent to 

the refurbishing and resale stations. Employees used a vacuum cleaner or compressed air to 

clean dusty electronic equipment.

Disassembly

Employees in the disassembly department received electronics from inventory stations. They 

used hand tools (electric drill or manual screwdriver, hammer) to disassemble the electronics. 

Employees removed the circuit boards and then sorted them on the basis of the value of the 

metals on the boards. They manually separated the plastic and metal components and placed 

them into bins to be shipped off site for processing.

Refurbishing

Employees tested the functionality of equipment, laptops, and batteries. If the central 

processing unit of the computer functioned, it was sent to the “wiping bench” where data was 

removed and software reloaded. Employees electronically and mechanically destroyed some 

hard drives. These hard drives were placed in a “degausser,” where an electromagnetic pulse 

was applied to the hard drive, then the hard drive was mechanically split. 

Resale and Shipping

Resale and shipping employees photographed the equipment, listed it on the internet for sale, 

and prepared it for shipping.

Office Employees

Office employees typically worked at a desk on a computer. Office employees were 

responsible for testing monitor screens and entered the processing area periodically to 

complete this task. One of the office employees was assigned to work on his computer at 

a workstation in the processing area. Processing employees regularly entered the office 

space because it was the most convenient route between the warehouse and the restroom 

facilities. We only collected samples on the employees who either worked in the warehouse 

or frequently entered the warehouse.
Health Hazard Evaluation Report 2016-0242-3315 Page 3

Methods

Our primary objective was to evaluate employee exposure to the most commonly found 

metals in electronic recycling streams. Our secondary objective was to determine if there was 

a potential for take-home contamination with metals.

Questionnaire and Consent

We obtained informed consent from all participants before beginning the evaluation. We 

asked all participants to fill out a questionnaire about their personal and work history 

(length of employment, job tasks, work history, current practices, use of personal protective 

equipment [PPE], and hygiene practices). 

Surface and Hand Wipe Samples

We collected and analyzed surface and hand wipe samples for metals according to 

NIOSH Method 9102, including lithium [NIOSH 2018]. We used premoistened SKC Inc. 

Ghostwipe® towelettes to wipe the surfaces using a 10 by 10 centimeter square disposable 

template to demarcate the surface sampling area. 

We collected hand wipe samples for metals from each participant at the end of shift on one 

day. We put on a new pair of nitrile gloves, then opened a glass vial, and asked the employee 

to take one Ghostwipe towelette from the vial, wipe both palms from wrist to finger tips 

for 30 seconds, and then place the wipe back into the same glass vial. We then asked the 

employee to take the second wipe and repeat the process for the back of both hands and place 

the wipe into the same glass vial. We sealed the vial with its lid and a parafilm wrap. We 

collected the postshift sample after the employees washed their hands before going home to 

determine the potential for take-home exposure. 

Air Samples

We collected one full-shift personal air sample per participant per day on two consecutive 

days. We collected personal and area air samples for metals and minerals, including lithium, 

on 37-millimeter cassettes and analyzed them according to NIOSH Method 7303 [NIOSH 

2018] with modification. The modification included using a digestible Solulcert® to collect 

particles on the inside of the cassette walls as recommended by NIOSH [2009].

Blood Samples for Cadmium and Lead

We collected approximately 10 milliliters of blood from each participant at the end of their 

shift at the end of their workweek to be analyzed for blood lead and cadmium levels. A 

trained technician drew blood from the vein following universal precautions for working with 

blood and blood products specified by the Centers for Disease Control and Prevention [Siegel 

et al. 2007] and the Occupational Safety and Health Administration (OSHA) [OSHA 2003]. 
Page 4 Health Hazard Evaluation Report 2016-0242-3315

Results and Discussion

Questionnaire

Eight of the 12 employees participated in this evaluation; one was female. The average 

age was 32 years (range: 19–47 years), and the median length of time in the facility was 

27 months (range: 2–66 months). All participants worked 40 hours per week. Some 

employees listed more than one usual job duty. Duties involved disassembly (5), refurbishing 

(3), sorting and inventory of electronics (5), sorting of batteries (3), storage (6), shipping 

(1), data destruction (4), loading and unloading of trucks (5), and office work (2). Most 

participants (6) performed more than one task regularly. Seven participants reported wearing 

their work clothing home, and six reported wearing their work shoes or boots home. All 

eight employees reported wearing gloves at work: one all the time, five most of the time, 

and two some of the time. All reported reusing their gloves. Employees most commonly 

reported wearing cloth gloves (4), followed by cut-resistant gloves (3), and nitrile and leather 

gloves (1 each). The only type of glove that we observed employees using was a cut-resistant 

glove. Four participants reported washing their hands more than five times per day, with the 

remainder washing their hands less frequently. One participant reported sometimes washing 

hands before eating at work, with the remainder reporting that they always washed their 

hands before eating at work. Six participants reported always washing their hands before 

leaving work, while two participants reported sometimes washing their hands before leaving 

work. Five employees reported that they currently smoked.

Surface and Hand Wipe Sampling

Although there are no occupational exposure limits (OELs) for surface and hand wipe 

samples, they can provide information about the effectiveness of housekeeping practices, 

the potential for exposure to contaminants by other routes such as the skin or mouth 

(e.g., from surface contamination on a table where people eat and drink), the potential for 

contamination of worker clothing and subsequent transport of the contaminant outside the 

work place, and the potential for activities unrelated to processing, such as sweeping, to 

generate airborne contaminants. 

Table 1 shows the surface wipe sample results for metals common in electronic scrap. The 

location with the highest concentration of lead, cobalt, and chromium was the refrigerator 

handle. The highest cadmium level was found on the women’s restroom door handle. The 

highest copper level was on the men’s restroom door handle. Although these levels were 

relatively low, they show migration of metal from processing areas to nonprocessing areas, 

most likely when employees with metal particles on their hands touch these surfaces. Similar 

or higher levels of metal on surfaces in nonprocessing areas suggests that these areas are not 

being cleaned sufficiently, and increase the risk of employees accidentally ingesting metal 

particles, either by direct hand-to-mouth or by ingesting a food with the contaminant on it.
Health Hazard Evaluation Report 2016-0242-3315 Page 5

Table 1. Metals detected in surface wipe samples, in micrograms per 100 square centimeters 

(unless otherwise noted)

Location Be Cd Cr Co Cu Pb

Nonprocessing areas

Women’s restroom door handle* ND 4 0.5 0.09 8 2

Men’s restroom door handle* ND 0.1 0.5 0.06 22 2

Women’s restroom floor ND 0.1 0.3 0.2 2 5

Men’s restroom floor ND 0.1 0.4 0.2 2 5

Microwave button* ND 0.03 0.3 ND ND 0.4

Floor in break area ND 0.2 0.2 0.1 1 2

Pop/soda machine ND 0.2 0.8 ND 20 2

Refrigerator handle* ND 1 3 0.6 18 14

Office desk ND ND ND ND ND 0.6

Processing areas

Door into office area ND 0.1 0.3 0.07 5 2

Disassembly drill handle* ND 1 0.9 0.07 10 8

Inventory scanner handle* ND 0.05 0.3 ND 1 0.3

Testing station desk ND ND 0.1 ND 1 ND

Employees desk ND 0.3 0.8 0.3 5 4

Refurbish area mouse* ND 0.3 0.2 0.06 2 0.4

Data destruction cart ND 0.3 0.2 ND ND 0.5

Resale desk ND 0.6 0.8 0.2 7 7

Rolling computer cart keyboard ND 0.2 1 0.3 5 4

Inside delivery vehicle

Steering wheel of delivery truck* ND 0.03 0.3 ND 4 1

Gearshift of delivery truck* ND 0.1 0.5 0.08 7 2

Limit of detection 

(micrograms per sample)

0.005 0.02 0.06 0.06 1 0.3

ND = Not detected 

*Estimated 100 square centimeters
Page 6 Health Hazard Evaluation Report 2016-0242-3315

Table 2 shows the hand wipe sample results for common metals found in electronic scrap. 

All employees had detectable levels of cadmium, chromium, and lead on their hands. Six 

of the eight employees had detectable cobalt, seven of the eight employees had copper, 

and one of the eight employees had detectable beryllium. We collected these samples after 

the employees had washed their hands and immediately before the employees went home 

for the evening. Therefore, employees could have transferred metals from their hands to 

their vehicles and homes. Research has shown that washing the hands with soap and water 

does not efficiently remove lead and other toxic metals from the skin [Filon et al. 2006]. In 

contrast, the use of lead removal products to clean the hands has been shown to substantially 

reduce lead [Esswein et al. 2011].

Table 2. Metals detected in hand wipe samples collected immediately before the employee left the 

workplace, levels in micrograms per sample

Task Be Cd Cr Co Cu Pb

Disassembly 0.007 0.04 0.2 ND 1 0.9

Disassembly ND 0.3 0.6 0.08 15 4

Sorting and inventory ND 2.0 5 1 40 36

Sorting and inventory ND 0.3 0.4 0.08 3 3

Shipping ND 0.02 0.2 ND ND 0.7

Office ND 0.7 1.0 0.3 5 5

Office ND 0.07 0.4 0.06 3 1

Driver ND 0.1 0.8 0.1 11 3

Limit of detection 

(micrograms per sample)

0.005 0.02 0.03 0.06 1 0.3

Air Samples

We collected 16 personal and 4 area air samples. One employee declined wearing the 

personal air sampling pump; however, we collected area air samples near the employee at the 

workstations and consider the results to be closely representative of the employee’s exposure. 

Personal air sample results for the most common metals found in electronic scrap are in 

Table 3. None of the personal exposure monitoring results exceeded applicable OELs; with 

the exception of chromium, they were well below the most protective OEL. The chromium 

concentration for one air sample was approaching half of the most protective OEL.
Health Hazard Evaluation Report 2016-0242-3315 Page 7

Table 3. Full-shift, personal air sampling results, in micrograms per cubic meter (μg/m3)

Task Be Cd Cr Co Cu Pb Sample 

duration

(minutes)

Day 1

Disassembly ND ND ND ND ND [0.27] 428

Disassembly ND [0.05] ND ND 2.3 [0.59] 393

Sorting and inventory ND ND ND ND [0.25] [0.28] 480

Sorting and inventory ND ND ND ND ND ND 433

Shipping ND ND ND ND 0.49 [0.39] 401

Office ND ND ND ND ND [0.25] 446

Office* ND ND ND ND ND ND 463

Driver ND ND ND ND ND ND 439

Monitors testing* ND ND ND ND ND ND 442

Day 2

Disassembly ND ND ND ND [0.32] ND 443

Disassembly ND [0.04] ND ND 0.98 [0.37] 405

Sorting and inventory ND ND ND ND [0.27] ND 443

Sorting and inventory ND ND ND ND ND ND 363

Shipping ND ND ND ND [0.43] [0.41] 383

Office ND ND ND ND ND ND 407

Office* ND ND 203 ND ND ND 422

Driver ND ND ND ND [0.18] ND 396

Monitors testing* ND ND ND ND ND ND 425

Most protective OEL 0.05 5 500 20 1000 50 —

OEL set by ACGIH ACGIH ACGIH ACGIH ACGIH NIOSH —

MDC 0.01 0.04 0.08 0.06 0.12 0.24 —

MQC 0.03 0.11 0.30 0.21 0.46 0.93 —

ACGIH = American Conference of Governmental Industrial Hygienists

MDC = Minimum detectable concentration 

MQC = Minimum quantifiable concentration

*Area samples close to employee workstations 

Note: Values in brackets are between the MDC and MQC; more uncertainty is associated with 

these concentrations. The MDC and MQC were calculated using an average sample volume of 

846 liters. 
Page 8 Health Hazard Evaluation Report 2016-0242-3315

Blood Samples

Eight employees had blood drawn for metals. Blood lead levels (BLLs) ranged from 

0.50 micrograms per deciliter (μg/dL) to 2.4 μg/dL. Blood cadmium levels were low, with six 

employees’ levels below the laboratory limit of detection of 0.5 micrograms per liter (μg/L). 

Blood cadmium levels for the two employees above the limit of detection were 

0.76 μg/L and 0.81 μg/L. 

Blood lead and cadmium levels were well below the OSHA acceptable level of 50 μg/dL for 

lead and 5 μg/L for cadmium. The NIOSH Adult Blood Lead Epidemiology and Surveillance 

system (ABLES) uses a surveillance case definition for a lead exposed worker that is 

considerably lower than OSHA’s acceptable level. The NIOSH ABLES considers a BLL 

elevated if it is 5 μg/dL or higher [CDC 2015]. No employee’s level exceeded this criterion. 

Smoking can increase blood lead and cadmium levels [Adams and Newcomb 2014; Mannino 

et al. 2005]. We found that the two employees with detectable levels of cadmium in their 

blood smoked, but we did not see a difference in BLLs between smokers and nonsmokers. 

This may be because of the small number of employees we tested. 

Workplace Observations and Record Review

The employer reported that they had a joint employee and employer safety committee, 

but it was unclear when the last committee meeting was held. We reviewed their accident 

prevention program, which included written documentation of a hazard assessment and the 

required PPE for specific job tasks. All employees were required to wear steel-toed shoes and 

gloves. All employees wore cut-resistant, palmar coated gloves. Employees reported that they 

reused gloves, but received a new pair every third day. We observed worn patches and holes 

in the work gloves. The company did not provide uniforms, and the employees laundered 

their work clothes at home. We observed steel-toed boots stored near employee food in the 

break area. Eye protection was required in the disassembly department, though we did not 

observe any employees wearing safety glasses while disassembling electronics. 

Employees reported that use of N95 filtering facepiece respirators was optional. However,

according to the accident prevention program and employee reports, N95 filtering facepiece

respirators were required to be worn during clean-up of mercury spills or breakage of leadcontaining electronics (i.e., cathode ray tube, leaded glass). In addition, the accident prevention

program stated that protective eyewear, gloves, and long sleeve clothing and pants were

required for these tasks. It must be noted that an N95 respirator, or other particulate respirator,

would not protect against mercury vapor exposures. For protection from exposure to mercury

vapor, a tight-fitting elastomeric respirator with mercury vapor cartridges would be needed. 

The company did not have a respiratory protection program, which is required when 

respirator use is mandatory. We observed respirators in the facility, including N95 filtering 

facepiece respirators and an elastomeric full facepiece respirator with particulate filters. 

Employees using respirators voluntarily had not received a copy of Table 2 of the 

Washington Administrative Code 296-842-11005 or Appendix D of the OSHA respiratory 

protection standard, 29 Code of Federal Regulations (CFR) 1910.134, as required by OSHA. 

We observed that the respirators were not always properly stored or kept clean. 
Health Hazard Evaluation Report 2016-0242-3315 Page 9

We reviewed records of industrial hygiene monitoring conducted in June 2015 by the 

Washington State Department of Labor and Industries, Division of Occupational Safety 

and Health. The personal air sampling showed no overexposures. Surface wipe samples 

for lead showed some workstations had lead levels of 120–430 micrograms per 100 

square centimeters. In response, company managers wrote a “Lead Recognition and 

Decontamination Procedure,” cleaned the surfaces with soap and water, and contracted 

a consultant to re-evaluate surface lead levels every 3 years. The “Lead Recognition and 

Decontamination Procedure” document identified more stringent PPE requirements than 

the accident prevention plan, noting that gloves, respirators, protective goggles, steel-toed 

boots, and protective clothing are required at all times in a facility with lead. The conflicting 

requirements between these documents could be confusing to employees. 

Employees reported using compressed air to clean dusty electronic equipment outside of the 

warehouse. Floors and other surfaces where lead or other heavy metals accumulate should 

not be cleaned with compressed air [29 CFR 1910.242]. The use of compressed air can cause 

lead and other metal particles to become airborne, making it easier to inhale. It may also 

contaminate nearby surfaces. We also observed employees using pedestal fans for personal 

cooling and brooms to sweep up at the end of the day. Fans and dry sweeping are also known 

to re-aersolize dust particles that may be contaminated with lead.

The company had no shower facilities, locker rooms, or dedicated break room. Some 

employees ate lunch at their workstations, outside, or in their cars. Taking contaminated 

clothing home could potentially bring lead and other hazardous metals to employees’ homes. 

In addition, we observed employees walking through the office area to get to the bathrooms 

and food storage areas instead of using the door with direct passage from the processing floor 

to the restrooms. This can cause hazardous materials to be tracked into nonprocessing areas. 

Although we did not specifically ask how frequently these areas were cleaned, we observed 

and collected wipe samples of dust built up on many of the horizontal surfaces in this area. 

Infrequent housekeeping can lead to the buildup of contaminated dusts. 

Conclusions

Employees at this recycling facility are exposed to metals, including lead and cadmium; 

however, exposures on the days we took air samples were well below OELs. Blood 

measurements for lead and cadmium were also below recommended levels. We identified 

a potential for take-home contamination with lead and other metals as indicated by the 

presence of metals on surface wipe samples in production and nonproduction areas where 

employees eat and drink. We also found metals on employees’ hands immediately before 

they left work at the end of the day. Take-home lead can contaminate cars and homes, and 

potentially expose family members. 

Recommendations

On the basis of our findings, we recommend the actions listed below. We encourage the 

electronics recycling facility to use an employer-employee health and safety committee or 

working group to discuss our recommendations and develop an action plan. Those involved 
Page 10 Health Hazard Evaluation Report 2016-0242-3315

in the work can best set priorities and assess the feasibility of our recommendations for the 

specific situation at the electronics recycling facility. 

Our recommendations are based on an approach known as the hierarchy of controls (Appendix 

B). This approach groups actions by their likely effectiveness in reducing or removing hazards. 

In most cases, the preferred approach is to eliminate hazardous materials or processes and 

install engineering controls to reduce exposure or shield employees. Until such controls are in 

place, or if they are not effective or feasible, administrative measures and PPE may be needed. 

Administrative Controls

The term administrative controls refers to employer-dictated work practices and policies 

to reduce or prevent hazardous exposures. Their effectiveness depends on employer 

commitment and employee acceptance. Regular monitoring and reinforcement are necessary 

to ensure that policies and procedures are followed consistently.

1. Include all employees in a lead exposure prevention program. Follow the medical 

surveillance program outlined in Appendix B in addition to all requirements of the 

OSHA lead standard. In the event that processes change, including a substantial increase 

or change in type of electronics recycled, more frequent BLL testing may be required. 

Provide employees with the results of their BLLs in writing after each blood draw.

2. Review and update the PPE hazard assessment, which is included as part of the 

accident prevention plan, to make sure that it includes all of the necessary PPE and 

types of PPE for specific job tasks. In addition, make sure that PPE recommendations 

included in the accident prevention and lead recognition and decontamination 

procedures are the same. 

3. Implement a formal policy and educate employees on handwashing in the workplace, 

including the use of lead-removing products to wash their hands. 

4. Implement a respiratory protection program if respirators are required for any 

task. The program at a minimum should meet the requirements of the Washington 

Administrative Code 296-842-11005. Ensure that employees required to wear 

respirators are medically cleared, fit-tested, clean-shaven, and adequately trained on 

respirator use and care before they use the respirators.

5. Ensure that employees whose only use of respirators is voluntary can safely wear 

the respirator. In addition, provide these employees with a copy of Appendix D 

of the OSHA respiratory protection standard (29 CFR 1910.1345) or Washington 

Administrative Code 296-842-11005. Ensure that respirators are stored properly so 

that they do not become contaminated.

6. Provide employees with a lead-removing product to wash their hands after removing 

gloves, and before eating, drinking, or smoking. Refer to “Information for Workers, 

How You Can Keep Yourself and Your Family Safe from Lead,” available at 

http://www.cdc.gov/niosh/topics/lead/safe.html for more information about 

commercially available lead-removal products. 
Health Hazard Evaluation Report 2016-0242-3315 Page 11

7. Clean all nonprocessing surfaces periodically to reduce the build-up of dust that 

contains lead, cadmium, and other metals. Consider using lead-removing wipes 

for this purpose. For carpeted areas or other porous surfaces, use a high-efficiency 

particulate air (HEPA) filtered vacuum cleaner. Prohibit dry sweeping of floors. 

Instead, use wet cleaning methods or a HEPA-filtered vacuum cleaner. 

8. Prohibit using compressed air to blow the dust out of electronics. Instead, use a HEPAfiltered vacuum cleaner.

9. Revitalize the employer-employee health and safety committee or working group to 

discuss workplace concerns and develop action plans for continued improvement of 

worker health and safety. 

10.Provide a location for food storage and consumption separate from work areas. Do 

not store contaminated PPE in the same location. Until a break room is provided, 

frequently clean the areas where employees take breaks.

11.Prohibit the consumption or storage of food and drinks at workstations.

12.Evaluate airborne exposures to metals whenever an increase in hazardous exposures 

is possible, such as introducing new operations, introduction of new hazards, and 

increased workloads. If employee exposures increase, additional protective measures 

may be needed.

13.Remove pedestal fans from the workbench, as they may aerosolize dust that contains 

heavy metals.

14.Write a formal policy for reusing or laundering cut resistant gloves. The policy should 

include information about the proper selection of gloves, when to use gloves, and how 

often gloves should be replaced.

15.Discourage workers from using the office space as a corridor to the bathroom or food 

preparation area. This may lead to tracking of metals into the office area. Use the door that 

leads directly from the processing areas into the hallway where the restrooms are located.

16.Increase the frequency of housekeeping in the nonprocessing areas to decrease the 

amount of lead and other hazardous materials.

17.Offer a smoking cessation program to employees. 
Page 12 Health Hazard Evaluation Report 2016-0242-3315

Personal Protective Equipment

PPE is the least effective means for controlling hazardous exposures. Proper use of 

PPE requires a comprehensive program and a high level of employee involvement and 

commitment. The right PPE must be chosen for each hazard. Supporting programs such as 

training, change-out schedules, and medical assessment may be needed. PPE should not 

be the sole method for controlling hazardous exposures. Rather, PPE should be used until 

effective engineering and administrative controls are in place.

1. Wear steel-toed boots, safety glasses with side shields, long sleeve shirts, pants, and 

cut-resistant gloves while performing general warehouse work. Specific tasks, such 

as cleaning up cathode ray tube or fluorescent bulb breakage, may require additional 

PPE. If fluorescent bulbs break, wear disposable nonlatex rubber or nitrile gloves 

to clean up the area. Use a commercial spill kit if available, or scoop glass and 

powder safely into a sealable container. Use tape to pick up any remaining pieces of 

glass. Disposable wet wipes or damp paper towels may then be used to clean up the 

remaining dust. More information on avoiding mercury exposure from fluorescent 

bulbs can be found at https://www.osha.gov/Publications/osha3536.pdf.

2. Provide clean gloves for daily use, or use clean inner gloves when reusing dirty gloves. 

Instruct employees to leave dirty gloves in the work area. Encourage employees to 

replace dirty gloves frequently to minimize contamination of surfaces with metals.
Health Hazard Evaluation Report 2016-0242-3315 Page 13

Appendix A. Facility Layout

Figure A1. Floor plan for the facility. Layout provided by the company.
Page 14 Health Hazard Evaluation Report 2016-0242-3315

Appendix B: Occupational Exposure Limits and 

Health Effects

NIOSH investigators refer to mandatory (legally enforceable) and recommended OELs for 

chemical, physical, and biological agents when evaluating workplace hazards. OELs have 

been developed by federal agencies and safety and health organizations to prevent adverse 

health effects from workplace exposures. Generally, OELs suggest levels of exposure that 

most employees may be exposed to for up to 10 hours per day, 40 hours per week, for a 

working lifetime, without experiencing adverse health effects. However, not all employees 

will be protected if their exposures are maintained below these levels. Some may have 

adverse health effects because of individual susceptibility, a pre-existing medical condition, 

or a hypersensitivity (allergy). In addition, some hazardous substances act in combination 

with other exposures, with the general environment, or with medications or personal habits of 

the employee to produce adverse health effects. Most OELs address airborne exposures, but 

some substances can be absorbed directly through the skin and mucous membranes.

Most OELs are expressed as a time-weighted average (TWA) exposure. A TWA refers to 

the average exposure during a normal 8- to 10-hour workday. Some chemical substances 

and physical agents have recommended short-term exposure limit (STEL) or ceiling values. 

Unless otherwise noted, the STEL is a 15-minute TWA exposure. It should not be exceeded 

at any time during a workday. The ceiling limit should not be exceeded at any time.

In the United States, OELs have been established by federal agencies, professional 

organizations, state and local governments, and other entities. Some OELs are legally 

enforceable limits; others are recommendations. 

● The U.S. Department of Labor OSHA permissible exposure limits (PELs) (29 CFR

1910 [general industry]; 29 CFR 1926 [construction industry]; and 29 CFR 1917

[maritime industry]) are legal limits. These limits are enforceable in workplaces

covered under the Occupational Safety and Health Act of 1970.

● NIOSH recommended exposure limits (RELs) are recommendations based on

a critical review of the scientific and technical information and the adequacy of

methods to identify and control the hazard. NIOSH RELs are published in the NIOSH

Pocket Guide to Chemical Hazards [NIOSH 2010]. NIOSH also recommends risk

management practices (e.g., engineering controls, safe work practices, employee

education/training, PPE, and exposure and medical monitoring) to minimize the risk of

exposure and adverse health effects.

● Another set of OELs commonly used and cited in the United States is the ACGIH

threshold limit values (TLVs). The TLVs are developed by committee members of this

professional organization from a review of the published, peer-reviewed literature.

TLVs are not consensus standards. They are considered voluntary exposure guidelines

for use by industrial hygienists and others trained in this discipline “to assist in the

control of health hazards” [ACGIH 2018]. 
Health Hazard Evaluation Report 2016-0242-3315 Page 15

Outside the United States, OELs have been established by various agencies and organizations 

and include legal and recommended limits. The Institut für Arbeitsschutz der Deutschen 

Gesetzlichen Unfallversicherung (Institute for Occupational Safety and Health of the German 

Social Accident Insurance) maintains a database of international OELs from European Union 

member states, Canada (Québec), Japan, Switzerland, and the United States. The database, 

available at http://www.dguv.de/ifa/GESTIS/GESTIS-Internationale-Grenzwerte-fürchemische-Substanzen-limit-values-for-chemical-agents/index-2.jsp, contains international 

limits for more than 2,000 hazardous substances and is updated periodically. 

OSHA requires an employer to furnish employees a place of employment free from 

recognized hazards that cause or are likely to cause death or serious physical harm 

[Occupational Safety and Health Act of 1970 (Public Law 91–596, sec. 5(a)(1))]. This is 

true in the absence of a specific OEL. It also is important to keep in mind that OELs may not 

reflect current health-based information.

When multiple OELs exist for a substance or agent, NIOSH investigators generally 

encourage employers to use the lowest OEL when making risk assessment and risk 

management decisions. NIOSH investigators also encourage use of the hierarchy of controls 

approach to eliminate or minimize workplace hazards. This includes, in order of preference, 

the use of (1) substitution or elimination of the hazardous agent, (2) engineering controls 

(e.g., local exhaust ventilation, process enclosure, dilution ventilation), (3) administrative 

controls (e.g., limiting time of exposure, employee training, work practice changes, medical 

surveillance), and (4) PPE (e.g., respiratory protection, gloves, eye protection, hearing 

protection). Control banding, a qualitative risk assessment and risk management tool, is a 

complementary approach to protecting employee health. Control banding focuses on how 

broad categories of risk should be managed. Information on control banding is available at 

http://www.cdc.gov/niosh/topics/ctrlbanding/. This approach can be applied in situations 

where OELs have not been established or can be used to supplement existing OELs.

Lead

Inorganic lead is a naturally occurring, soft metal that has been mined and used in industry 

since ancient times. It comes in many forms (e.g., lead acetate, lead chloride, lead chromate, 

lead nitrate, lead oxide, lead phosphate, and lead sulfate). Lead is considered toxic to all 

organ systems and serves no useful purpose in the body.

Occupational exposure to inorganic lead occurs via inhalation of lead-containing dust and 

fume and ingestion of lead particles from contact with lead-contaminated surfaces. Exposure 

may also occur through transfer of lead to the mouth from contaminated hands or cigarettes 

when careful attention to hygiene, particularly hand washing, is not practiced. In addition 

to the inhalation and ingestion routes of exposure, lead can be absorbed through the skin, 

particularly through damaged skin [Filon et al. 2006; Stauber et al. 1994; Sun et al. 2002]. 

Workplace settings with exposure to lead and lead compounds include smelting and refining, 

scrap metal recovery, automobile radiator repair, construction and demolition (including 

abrasive blasting), and firing ranges. Occupational exposures also occur among workers who 

apply or remove lead-based paint and among welders who burn or torch-cut metal structures. 
Page 16 Health Hazard Evaluation Report 2016-0242-3315

Blood Lead Levels

In most cases, an individual’s BLL is a good indication of recent exposure to lead because the

half-life of lead (the time interval it takes for the quantity in the body to be reduced by half its

initial value) is 1–2 months [CDC 2013a; Lauwerys and Hoet 2001; Moline and Landrigan 2005].

Most lead in the body is stored in the bones, with a half-life of years to decades. Measuring bone

lead, however, is primarily done only for research. Elevated zinc protoporphyrin levels have

also been used as an indicator of chronic lead intoxication; however, other factors, such as iron

deficiency, can cause an elevated zinc protoporphyrin level, so monitoring the BLL over time is

more specific for evaluating chronic occupational lead exposure.

BLLs in adults in the United States have declined consistently over time. The geometric 

mean BLL went from 1.75 μg/dL in 1999–2000 to 1.09 μg/dL in 2011–2012 [CDC 2015]. 

The NIOSH ABLES System uses a surveillance case definition for an elevated BLL in adults 

of 5 μg/dL of blood or higher [CDC 2015]. Very high BLLs are defined as BLLs ≥ 40 μg/dL. 

From 2002–2011, occupational exposures accounted for 91% of adults with very high BLLs 

(where exposure source was known) [CDC 2013b]. This underscores the need to increase 

efforts to prevent lead exposures in the workplace. 

Occupational Exposure Limits

In the United States, employers in general industry are required by law to follow the OSHA

lead standard (29 CFR 1910.1025). This standard was established in 1978 and has not yet been

updated to reflect the current scientific knowledge regarding the health effects of lead exposure.

Under this standard, the PEL for airborne exposure to lead is 50 μg/m3 of air for an 8-hour 

TWA. The standard requires lowering the PEL for shifts that exceed 8 hours, medical 

monitoring for employees exposed to airborne lead at or above the action level of 30 μg/m3

(8-hour TWA), medical removal of employees whose average BLL is 50 μg/dL or greater, 

and economic protection for medically removed workers. Medically removed workers cannot 

return to jobs involving lead exposure until their BLL is below 40 μg/dL. 

In the United States, other guidelines for lead exposure, which are not legally enforceable, 

are often followed. Similar to the OSHA lead standard, these guidelines were set years 

ago and have not yet been updated to reflect current scientific knowledge. NIOSH has an 

REL for lead of 50 μg/m3 averaged over an 8-hour work shift [NIOSH 2010]. ACGIH has 

a TLV for lead of 50 μg/m3 (8-hour TWA), with worker BLLs to be controlled to, or below, 

30 μg/dL. ACGIH designates lead as an animal carcinogen [ACGIH 2018]. In 2013, the 

California Department of Public Health recommended that Cal/OSHA lower the PEL for 

lead to 0.5 to 2.1 μg/m3 (8-hour TWA) to keep BLLs below the range of 5 to 10 μg/dL 

[Billingsley 2013].

Neither NIOSH nor OSHA has established surface contamination limits for lead in the 

workplace. The U.S. Environmental Protection Agency and the U.S. Department of Housing 

and Urban Development limit lead on surfaces in public buildings and child-occupied 

housing to less than 40 micrograms of lead per square foot [EPA 1998; HUD 2012]. OSHA 

requires in its substance-specific standard for lead that all surfaces be maintained as free as 
Health Hazard Evaluation Report 2016-0242-3315 Page 17

practicable of accumulations of lead [29 CFR 1910.1025(h)(1)]. An employer with workplace 

exposures to lead must implement regular and effective cleaning of surfaces in areas such 

as change areas, storage facilities, and lunchroom/eating areas to ensure they are as free as 

practicable from lead contamination [OSHA 2003]. 

Health Effects

The PEL, REL, and TLV may prevent overt symptoms of lead poisoning, but do not protect 

workers from lead’s contributions to conditions such as hypertension, renal dysfunction, 

reproductive, and cognitive effects [Brown-Williams et al. 2009; Institute of Medicine 2012; 

Schwartz and Hu 2007; Schwartz and Stewart 2007]. Generally, acute lead poisoning with 

symptoms has been documented in persons having BLLs above 70 μg/dL. These BLLs are 

rare today in the United States, largely as a result of workplace controls put in place to 

comply with current OELs. When present, acute lead poisoning can cause myriad adverse 

health effects including abdominal pain, hemolytic anemia, and neuropathy. Lead poisoning 

has, in very rare cases, progressed to encephalopathy and coma [Moline and 

Landrigan 2005]. 

People with chronic lead poisoning, which is more likely at current occupational exposure 

levels, may not have symptoms or they may have nonspecific symptoms that may not be 

recognized as being associated with lead exposure. These symptoms include headache, joint 

and muscle aches, weakness, fatigue, irritability, depression, constipation, anorexia, and 

abdominal discomfort [Moline and Landrigan 2005]. 

The National Toxicology Program recently released a monograph on the health effects of 

low-level lead exposure [National Toxicology Program 2012]. For adults, the National 

Toxicology Program concluded the following about the evidence regarding health effects of 

lead (Table B1).
Page 18 Health Hazard Evaluation Report 2016-0242-3315

Table B1. Evidence regarding health effects of lead in adults

Health area NTP 

conclusion

Principal health effects Blood lead 

evidence

Neurological Sufficient Increased incidence of essential tremor Yes, < 10 μg/dL

Limited Psychiatric effects, decreased hearing, 

decreased cognitive function, increased 

incidence of amyotrophic lateral sclerosis

Yes, < 10 μg/dL

Limited Increased incidence of essential tremor Yes, < 5 μg/dL

Immune Inadequate Unclear

Cardiovascular Sufficient Increased blood pressure and 

increased risk of hypertension

Yes, < 10 μg/dL

Limited Increased cardiovascular-related mortality 

and electrocardiography abnormalities

Yes, < 10 μg/dL

Renal Sufficient Decreased glomerular filtration rate Yes, < 5 μg/dL

Reproductive Sufficient Women: reduced fetal growth Yes, < 5 μg/dL

Sufficient Men: adverse changes in sperm parameters 

and increased time to pregnancy

Yes, ≥ 15–20 μg/dL

Limited Women: increase in spontaneous abortion 

and preterm birth

Yes, < 10 μg/dL

Limited Men: decreased fertility Yes, ≥ 10 μg/dL

Limited Men: spontaneous abortion Yes, ≥ 31 μg/dL

Inadequate Women and Men: stillbirth, 

endocrine effects, birth defects

Unclear

Various organizations have assessed the relationship between lead exposure and cancer. 

According to the Agency for Toxic Substances and Disease Registry [ATSDR 2007] and the 

National Toxicology Program [National Toxicology Program 2011], inorganic lead compounds 

are reasonably anticipated to cause cancer in humans. The International Agency for Research on 

Cancer classifies inorganic lead as probably carcinogenic to humans [IARC 2006a]. According 

to the American Cancer Society [ACS 2011], some studies show a relationship between lead 

exposure and lung cancer, but these results might be affected by exposure to cigarette smoking 

and arsenic. Some studies show a relationship between lead and stomach cancer, and these 

findings are less likely to be affected by the other exposures. The results of studies looking at 

other cancers, including brain, kidney, bladder, colon, and rectum, are mixed.

Medical Management

To prevent acute and chronic health effects, a panel of experts convened by the Association 

of Occupational and Environmental Clinics published guidelines for the management of 

adult lead exposure [Kosnett et al. 2007]. The panel recommended BLL testing for all leadexposed employees, regardless of the airborne lead concentration. These recommendations 

do not apply to pregnant women, who should avoid BLLs > 5 μg/dL. Removal from lead 

exposure should be considered if control measures over an extended period do not decrease 

BLLs to < 10 μg/dL or an employee has a medical condition that would increase the risk of 

adverse health effects from lead exposure. These guidelines were endorsed by the Council of 

State and Territorial Epidemiologists and the California Department of Public Health in 2009 
Health Hazard Evaluation Report 2016-0242-3315 Page 19

and the American College of Occupational and Environmental Medicine in 2010 [ACOEM 

2010; CDPH 2009; CSTE 2009]. The Council of State and Territorial Epidemiologists 

published updated guidelines in 2013 to reflect the new definition of an elevated BLL in 

adults of 5 μg/dL [CSTE 2015]. The California Department of Public Health recommended 

keeping BLLs below 5 to 10 μg/dL in 2013 [Billingsley 2013] and updated their medical 

management guidelines in 2014 [CDPH 2014]. In 2015, NIOSH designated 5 μg/dL of 

whole blood, in a venous blood sample, as the reference blood lead level for adults. An 

elevated BLL is defined as a BLL ≥ 5 μg/dL. In 2016, the American College of Occupational 

and Environmental Medicine released a position statement titled “Workplace Lead 

Exposure,” which reinforces the guidelines and recommendations from the expert panel 

guidelines and those from the California Department of Public Health, The American 

College of Occupational and Environmental Medicine, and the Council of State and 

Territorial Epidemiologists. Table B2 incorporates recommendations from the expert panel 

guidelines and those from the California Department of Public Health and the Council of 

State and Territorial Epidemiologists. 
Page 20 Health Hazard Evaluation Report 2016-0242-3315

Table B2. Health-based medical surveillance recommendations for lead-exposed employees

Category of exposure Recommendations

All lead exposed workers ● Baseline or preplacement medical history and physical 

examination, baseline BLL, and serum creatinine

BLL < 5 μg/dL ● BLL monthly for first 3 months placement, or upon change in 

task to higher exposure, then BLL every 6 months; if BLL 

increases ≥ 5 μg/dL, evaluate exposure and protective measures, 

and increase monitoring if indicated

BLL 5–9 μg/dL ● Discuss health risks

● Minimize exposure

● Consider removal for pregnancy and certain medical conditions

● BLL monthly for first 3 months placement or every 2 months for 

the first 6 months placement, or upon change in task to higher 

exposure, then BLL every 6 months; if BLL increases ≥ 5 μg/dL, 

evaluate exposure and protective measures, and increase 

monitoring if indicated

BLL 10–19 μg/dL ● Discuss health risks

● Decrease exposure

● Remove from exposure for pregnancy

● Consider removal for certain medical conditions or BLL > 10 μg/dL 

for extended period

● BLL every 3 months; evaluate exposure, engineering controls, and 

work practices; consider removal. 

● Revert to BLL every 6 months after 3 BLLs < 10 μg/dL

BLL 20–29 μg/dL ● Remove from exposure for pregnancy

● Remove from exposure if repeat BLL measured in 4 weeks 

remains ≥ 20 μg/dL

● Annual lead medical exam recommended

● Monthly BLL testing

● Consider return to work after 2 BLLs < 15 μg/dL a month apart, 

then monitor as above

BLL 30–49 μg/dL ● Remove from exposure

● Prompt medical evaluation

● Monthly BLL testing

● Consider return to work after 2 BLLs < 15 μg/dL a month apart, 

then monitor as above

BLL 50–79 μg/dL ● Remove from exposure

● Prompt medical evaluation

● Consider chelation with significant symptoms

BLL > 80 μg/dL ● Remove from exposure

● Urgent medical evaluation

● Chelation may be indicated

Adapted from Kosnett et al. 2007, CSTE 2013, 2015, and CDPH 2014
Health Hazard Evaluation Report 2016-0242-3315 Page 21

Take-home Contamination

Occupational exposures to lead can result in exposures to household members, including 

children, from take-home contamination. Take-home contamination occurs when lead dust is 

transferred from the workplace on employees’ skin, clothing, shoes, and other personal items 

to their vehicle and home [CDC 2009, 2012]. 

The Centers for Disease Control and Prevention considers a BLL in children of 5 μg/dL or 

higher as a reference level above which public health actions should be initiated, and states 

that no safe BLL in children has been identified [CDC 2013a].

The U.S. Congress passed the Workers’ Family Protection Act in 1992 (29 U.S.C. 671a). 

The Act required NIOSH to study take-home contamination from workplace chemicals and 

substances, including lead. NIOSH found that take-home exposure is a widespread problem 

[NIOSH 1995]. Workplace measures effective in preventing take-home exposures were (1) 

reducing exposure in the workplace, (2) changing clothes before going home and leaving 

soiled clothing at work for laundering, (3) storing street clothes in areas separate from work 

clothes, (4) showering before leaving work, and (5) prohibiting removal of toxic substances 

or contaminated items from the workplace. NIOSH noted that preventing take-home 

exposure is critical because decontaminating homes and vehicles is not always effective. 

Normal house cleaning and laundry methods are inadequate, and decontamination can expose 

the people doing the cleaning and laundry. 
Page 22 Health Hazard Evaluation Report 2016-0242-3315

Table B3. Chemical health effects

Chemicals Health effects IARC OEL (μg/m3

)

Beryllium ● Beryllium exposure may cause

dermatitis, lung inflammation,

and chronic beryllium disease in

humans [Proctor et al. 1991].

● Exposure to beryllium can lead

to sensitization.

● Exposure also slightly increases

the risk for lung cancer

[Schubauer-Berigan et al. 2010].

Group 1: 

carcinogenic 

to humans 

[IARC 2012]

OSHA PEL: 0.2

NIOSH REL: 0.5

ACGIH TLV: 0.05

Cadmium ● Long-term occupational

exposure to cadmium is

associated with increased

occurrence of lung cancer,

kidney damage, and chronic

obstructive lung disease

[WHO 1992].

Group 1: 

carcinogenic 

to humans 

[IARC 2012]

OSHA PEL: 5.0

NIOSH REL: Cancer

ACGIH TLV: 10 

(2 respirable fraction)

Chromium ● The toxic effects of chromium

exposure, including lung and

nasal cancer, are primarily

related to hexavalent chromium.

● Skin exposure to chromium dust

can cause skin irritation and skin

ulceration, and allergic contact

dermatitis.

Group 1: 

carcinogenic 

to humans 

[IARC 2012]

OSHA PEL: 1000

NIOSH REL: 500

ACGIH TLV: 500

Cobalt ● Exposure to elevated levels of

cobalt can cause gastrointestinal

irritation, nausea, and vomiting.

● Inhaled cobalt can lead to lung

damage.

● Skin exposure can cause irritant

and allergic contact dermatitis

[Vincoli 1997].

Group 2B: 

possibly 

carcinogenic 

to humans 

[IARC 2006b]

OSHA PEL: 100

NIOSH REL: 50

ACGIH TLV: 20

Copper ● Inhalation of copper fumes can

produce toxic effects on the

respiratory tract and may cause

metal fume fever.

● Copper salts may be absorbed

through the skin causing

systemic toxicity [IPCS 2017].

No evidence of 

carcinogenicity

OSHA PEL: 1,000

NIOSH REL: 1,000

ACGIH TLV: 1,000

IARC = International Agency for Research on Cancer

Beryllium, Cadmium, Chromium, Cobalt, and Copper

Below is a table summarizing the OELs for the other common metals found in electronic scrap 

recycling, as well as a discussion of the potential health effects from exposure to these elements.
Health Hazard Evaluation Report 2016-0242-3315 Page 23

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Health Hazard Evaluation Report 2016-0242-3315 Page 27

Keywords: North American Industry Classification System (NAICS) 423930 (Recyclable 

Material Merchant Wholesalers), Washington, Electronics Recycling, E-Scrap, E-Waste, 

Lead, Cadmium
Page 28 Health Hazard Evaluation Report 2016-0242-3315

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Health Hazard Evaluation Report 2016-0242-3315 Page 29

The Health Hazard Evaluation Program investigates possible health hazards in the workplace 

under the authority of the Occupational Safety and Health Act of 1970 (29 U.S.C. § 669(a)

(6)). The Health Hazard Evaluation Program also provides, upon request, technical assistance 

to federal, state, and local agencies to investigate occupational health hazards and to prevent 

occupational disease or injury. Regulations guiding the Program can be found in Title 42, Code 

of Federal Regulations, Part 85; Requests for Health Hazard Evaluations (42 CFR Part 85).

Disclaimer

The recommendations in this report are made on the basis of the findings at the workplace 

evaluated and may not be applicable to other workplaces.

Mention of any company or product in this report does not constitute endorsement by NIOSH.

Citations to Web sites external to NIOSH do not constitute NIOSH endorsement of the 

sponsoring organizations or their programs or products. NIOSH is not responsible for the 

content of these Web sites. All Web addresses referenced in this document were accessible as of 

the publication date.

Acknowledgments

Analytical Support: Maxxam Laboratories, Washington State Public Health Laboratory

Desktop Publisher: Shawna Watts 

Editor: Ellen Galloway 

Industrial Hygiene Field Assistance: Jonathan Slone

Logistics: Donnie Booher, Kevin Moore

Medical Field Assistance: Deborah Sammons, Shirley Robertson

Availability of Report

Copies of this report have been sent to the employer and employees at the facility. The state and 

local health department and the Occupational Safety and Health Administration Regional Office 

have also received a copy. This report is not copyrighted and may be freely reproduced. 

Recommended citation for this report:

NIOSH [2018]. Evaluation of exposure to metals at an electronics recycling facility. By 

Grimes GR, Beaucham CC, Ramsey JG. Cincinnati, OH: U.S. Department of Health 

and Human Services, Centers for Disease Control and Prevention, National Institute for 

Occupational Safety and Health, Health Hazard Evaluation Report 2016-0242-3315, 

https://www.cdc.gov/niosh/hhe/reports/pdfs/2016-0242-3315.pdf.
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