Q: All of my workers have been through the lead paint classes and we are doing jobs and documenting. My question is, why is there nothing being said about eye protection? We recently purchased goggles for the workers so that any dust can be kept away from and out of their eyes. Are we correct in our thinking? --Ralph Pagnucco, owner, IHS Building Co., Gwinn, Mich.
A: Ralph, "Why is there nothing being said about eye protection?" is a great question. Because you have asked this question within the context of lead, I'll give you a regulatory response and a medical response to it. All of this will follow the first rule in safety glasses: Wear them!
Regulations: Any lead-safe work practices training that your workers have taken has been created by either the Environmental Protection Agency (EPA) or the Department of Housing and Urban Development (HUD). These agencies collaborated to create the Residential Lead-Based Paint Hazard Reduction Act of 1992--Title X. The goal of Title X is to "eliminate childhood lead poisoning by 2010." Remember that the EPA was created to protect the public, and HUD was created to manage publicly funded housing projects and protect the occupants.
Keeping the focus of these two agencies in mind, think about the goals of the training courses they created: to protect the public (EPA) or, in the case of HUD, to protect the occupants of funded housing projects. Thus, components to protect workers are sometimes missed or are assumed to be covered by the employer in the employer's obligation to follow worker-safety regulations as defined by OSHA (Occupational Health and Safety Administration). OSHA was part of the development of Title X and has regulations specific to the role of the employer to protect his or her workers from exposure to lead (CFR1926.62 Lead in Construction).
Now workers wearing safety glasses fall under the responsibility of OSHA, or for contractors operating within Michigan, Michigan OSHA (MIOSHA). So, reading the OSHA CFR1926.102 Eye and Face Protection, the regulation clearly states in section 1926.102(a)(1), "Employees shall be provided with eye and face protection equipment when machines or operations present potential eye or face injury from physical, chemical, or radiation agents." Dust created during a remodeling project falls under the "physical agents" part of this section.
Medical: According to Dr. Thomas J. Byrd, M.D., an ophthalmologist practicing in Wyandotte, Mich., "There is little chance of someone getting lead poisoning through the eye." Dr. Byrd further explains that the real concern is getting conjunctivitis or an infection due to a foreign particle being introduced to the eye. So, following the first rule of safety glasses will help ensure that your workers are protected from lead dust or other particles entering their eyes.
-- Brindley Byrd is a national speaker, author, and advocate who has served the construction industry for more than 12 years. He established the Responsible Remodeling core operating system for dust-safe work practices to protect the health of workers and customers. He has guided hundreds of professional remodelers through the regulations and work practices of managing remodeling air quality. Contact Brindley at email@example.com or visit www.qx2.net for more information.