The interim final rule for lead exposures in construction (29 CFR 1926.62) requires the use of all feasible engineering controls to reduce employee exposures to the lowest feasible level. The question of what constitutes feasible has plagued the industrial painting industry since the rule was written. This paper investigates the issue and outlines criteria based upon the preamble to the rule, Occupational Safety and Health Administration (OSHA) technical manual and compliance directives, and a recent legal decision on the issue. This information was submitted to OSHA by SSPC: The Society of Protective Coatings in September, 1999 in a request for a formal letter of interpretation. OSHA's response, in March, 2001, is also referenced.

Subject
Abrasive blasting, Kinetic energy, Compliance, Industries, Containment, Contaminants, Lead, Particulates, Ventilation, Personnel, Engineering, Health, safety, and environment, Construction
© 2001 Association for Materials Protection and Performance (AMPP). All rights reserved. This work is protected by both domestic and international copyright laws. No part of this publication may be reproduced, stored in a retrieval system, or transmitted, in any form or by any means (electronic, mechanical, photocopying, recording, or otherwise) without the prior written permission of AMPP. Positions and opinions advanced in this work are those of the author(s) and not necessarily those of AMPP. Responsibility for the content of the work lies solely with the author(s).
2001
Association for Materials Protection and Performance (AMPP)
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