Dispose of lead contaminated wash water in accordance with applicable local, state, or federal regulations. The employer did not assure that change areas were equipped with separate storage facilities for protective work clothing and equipment and for street clothes, which prevented cross contamination. The common denominator for these citations is missing just a few of the many details of the lead regulations. In each of the above cases, the painting company settled out of court by paying fines totaling thousands of dollars, with affirmative defenses entered for each citation. Employees are routinely exposed to a variety of lead sources and must be protected in an appropriate and legal manner from each.
Engineering controls refers to ventilation systems and containment structures.
This definition disappoints some since it does not include a detailed engineering description of minimum size dust collectors, maximum size containment structures, or specific air velocities. In no way does a minimum velocity alone assure either safe conditions for workers or compliance with OSHA regulations. At one bridge painting project in the middle Atlantic states, the contractor was incredulous when cited for the above violation because he was convinced that 100 feet per minute was a safe condition. The erroneous basis for this premise was his attendance at a trade show lecture on the subject of engineering controls. Since engineering controls are not the primary topic of this article, no further discussion can be made about this confusion.