WrenchQuarry Editorial Team · Published · 13 min read
Set up washing, changing, storage and cleanup facilities before a crew works in an older building where lead dust may reach workers.
Read these out at the start of the shift, in your own words if you like:
Older buildings can have lead paint. Sanding, scraping, cutting, drilling and tearing out old walls can throw fine lead dust into the air. That dust settles on hands, faces, work clothes, tools and truck seats, and it can reach food and drinks. Oregon's state lead page puts it plainly: "Lead dust can also get on your hands and face or in your food, and drinks."
The rules care about more than the air. They also care about where workers wash, change, eat and store their clothes. Clean air readings do not stop dust from landing on clothes and hands, so set these up on every older-building job, not only the ones where someone has measured a problem.
Everyone on the crew should follow the setup, including drivers, helpers and anyone who only walks through the site. Keep visitors out of the dust zone, and tell them where the clean zone is.
This post lists eight things to have ready before the crew and truck leave. Hand the list to whoever runs the crew on site.
The federal construction lead rule, 29 CFR 1926.62, caps how much lead workers can breathe. It says no worker may be exposed to lead above fifty micrograms in a cubic meter of air. A microgram is one millionth of a gram. A cubic meter is a box of air one meter long, one meter wide and one meter high.
California's version, Title 8, Section 1532.1, is much tighter. It says no employee is exposed to an airborne concentration of lead greater than 10 micrograms in a cubic meter of air. That is one fifth of the federal number.
Oregon's state lead page, linked above, says its construction lead rule covers the key requirements of the federal rule. For a job in Oregon, ask your safety lead to confirm the state rule before you pick a setup.
Two things to keep in mind. First, these are the rules, not a measurement of your job. Only air testing on that job shows where the crew stands. Second, until someone has measured the air on a particular job, set up all eight items.
Get these answers from the job contact before the crew leaves the yard. Each answer changes the setup. For older-home visits, see Lead pamphlet checks before an older-home visit: 4 steps.
Write the answers on the dispatch sheet. If nobody can answer the air question, plan for the full setup, as this post says.
Mark the job in two zones and one path before anyone starts work. The dust zone is where the cutting, sanding or tearing out happens. The clean zone is where workers wash, change, store clothes and eat. Between them, make a path that workers walk one way, from dust to clean, and never back.
Put the clean zone upwind of the dust (the side the wind blows from) if you can, or at least on the side with the least dust. Keep it away from piles of debris and out of the path of the saws. A closed van or a room that is not being worked on makes a good clean zone. Rope or tape off the dust zone, and post the sign described in item 5 at its edge.
If the site has more than one area being worked, set up a dust zone for each, with one clean zone shared by the crew.
Tell the building owner or site contact where the clean zone is, so nobody stores tools or boxes in it. At the end of each shift, the crew walks the path out: they clean off the dust, wash, change, bag their work clothes, and only then eat, drink or drive.
Illustrative example: A crew of four is sent to a job in an older building. Before dispatch, the dispatcher counts eight storage spots, two for each worker, and checks the water and soap on the truck. At the end of each shift, the crew walks the path from dust to clean, and the dusty bags stay on the truck. The laundry day is the same day each week, so a spare set is always ready.
California's rule says that for all employees exposed to lead, the employer shall provide an adequate number of washing facilities, or lavatories. In plain words, every worker exposed to lead needs enough places to wash.
On the truck: a water jug with a tap, or a small portable hand-wash tank, liquid soap, paper towels, a bucket to catch the wash water, and a bag for used towels.
Set it up at the edge of the clean zone, so workers wash before they eat, drink, touch their face or get into a vehicle. Tell the crew to wash hands and face before every break and again at the end of the shift. Restock the soap and water before the truck leaves the yard, because a wash station with no soap is one nobody uses.
As dispatcher, your job is to see the water and soap on the truck before the crew rolls. If either is missing, the crew should not start the dusty part of the job until it is fixed.
The federal rule calls for clean change areas for employees whose airborne exposure to lead is above the limit. California's rule says the employer shall provide the same thing, in its own words.
In plain words, a change area is a clean place to take off work clothes, away from the dust, before a worker goes to lunch, to their car or home. Because nobody knows a worker's exposure level without testing the air, set up a change area for every crew on a lead job.
What counts as a change area on a job site: a closed van, a room the work is not happening in, or a corner walled off with plastic sheeting over a clean floor covering. Keep it clean: no tools, no debris and no dusty boxes inside.
The routine for workers is simple: come in from the dust side in work clothes, change, and leave the area in street clothes. Nobody walks back through the change area in dusty gear. Put a folding chair, a hook or a shelf inside so workers have somewhere to sit and set things down without touching the floor.
California's rule calls for storage facilities for protective work clothing and equipment, and for street clothes. In plain words, keep work gear and street clothes apart, so dust from one does not end up on the other.
Set up two spots for each worker: two hooks, two bins or two bags. Label one "work" and the other "street." Work gear goes into its own spot at the end of the shift, and street clothes stay in the other spot, on the clean side of the path.
On a small truck, a plastic tote with a lid works well for each spot. Count the spots against the crew size before you dispatch. A crew of four needs eight spots: two for each person.
The federal rule calls for shower facilities, where feasible, for workers whose airborne exposure to lead is above the limit. In plain words, that means a shower wherever it can reasonably be done.
Before you dispatch, find the nearest shower the crew can use: the company yard, a home base, or a gym that agrees to let the crew in. Write its address on the dispatch sheet. If the job is far from any shower, say so on the sheet, so the crew knows to wash more carefully at the wash station before leaving.
Build washing time into the end of the shift, and include hair, neck, arms and face, not just hands. Lead dust that is left on the skin can be carried to the next place a worker touches.
If a worker says the shower is too far to use, ask the site lead what the crew does instead, and write the answer down.
California's rule says food or beverage is not present or consumed, and tobacco products are not present or used, in the lead areas it covers. The federal rule includes a warning sign that reads: "DO NOT EAT, DRINK OR SMOKE IN THIS AREA."
Print the sign or a laminated card, and tape it at the edge of the dust zone where every worker walks in. Keep the cooler, the coffee and the lunch spot in the clean zone, not in the dust zone. Phones and water bottles go in the clean zone too, because hands carry dust to anything they touch.
The crew rule is short: no eating, drinking or smoking in the dust zone. Snacks and drinks happen only in the clean zone, and only after hands and face are washed. Bring one extra cooler, so nobody walks back into the dust for water.
The federal rule talks about protective clothing being in a clean and dry condition at least weekly. In plain words, if your company supplies the work clothes, plan on a clean set every week.
Plan a spare set for each worker, so the dirty set can go to the laundry while the clean set is in use. Put the laundry day on the calendar, the same day each week, and name the person who drives the bags to the laundry.
Dusty clothes travel in the sealed bags described in item 8, never loose on the seat. Do not wash dusty work clothes with family laundry, and do not let a worker take them home for the weekend.
Write the swap date on the dispatch sheet for every week of the job, so a missed swap is visible to you.
The federal rule says floors and other surfaces where lead builds up must be cleaned by vacuuming, wherever that is possible. It also says shoveling, dry or wet sweeping, and brushing may be used only in limited cases. In plain words, vacuuming comes first, and sweeping is the exception.
On the truck, carry a vacuum made for fine dust. Check the box for a fine-dust rating and follow the maker's instructions. Do not substitute a household or shop vacuum for the fine-dust vacuum.
Put a note on the dispatch sheet: no dry sweeping, vacuum first. Keep spare bags or filters on the truck so the vacuum can keep working through the whole job.
Vacuum the surfaces where dust settles, such as window sills, ledges and the floor under the work, before the crew packs up.
California's rule says employees do not enter personal vehicles or leave the workplace with any protective clothing or equipment. In plain words, dusty work clothes and gear stay at the job, not in a personal car and not in someone's house.
Set up one sealed bag or bin on the truck for each worker. At the end of the shift, workers put dusty clothes and gear into the bag in the clean zone, before they get into their own car. The bag stays on the truck until it goes to the laundry or to disposal, following your company's procedure.
Tell crews that lead on work clothes can reach people at home, and that is why the clothes stay at the job. Make it a standing rule, not a suggestion, and check it at the end of each shift.
Dust rides along in the truck. At the end of each day, vacuum the floor mats and seats with the fine-dust vacuum, and wipe the dashboard, door handles and steering wheel with a damp cloth. Put the used cloth in the sealed bag, so the dust is not blown back into the cab. Keep work gear in the bins, not on the seats.
Before the truck leaves the yard, check each line:
For the handoff itself, see Field Service Work Order Checklist for Dispatch Handoffs.
Walk the site once in the middle of the shift and look for these signs. Each one means the setup has a gap.
When you see a sign, stop the dusty work, fix the gap, and tell the crew why. A quick fix on site is far better than dust carried home.
Today, walk to the truck and check it against the dispatch sheet list above. Write down any missing water, soap, vacuum or bag, and fix it before the next dusty job starts.
Yes. Set up all eight items until someone has measured the air on that job.
The dust zone is where cutting, sanding or tearing out happens.
Check the California rule, Title 8, Section 1532.1, because its limit is much tighter than the federal one.
Check the rule for the state where the job is. As the California numbers show, a state rule can be stricter than the federal one.
This list is planning help for dispatch. It is not legal advice, and it does not replace your company's safety program or your site safety lead. Let the site lead decide what each job needs, and when in doubt, pause the dusty work and ask.