Painting and Decorating (C-33) · Lesson 3 of 6

Lead on the Job: Cal/OSHA PEL, Action Level and Trigger Tasks

"Lead on the Job: Cal/OSHA PEL, Action Level and Trigger Tasks" is lesson 3 of 6 in the Painting and Decorating (C-33) Learning Hub. It opens with "Painting Is Named in the Scope" and works through 5 short steps, then a worked example you can check yourself against.

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Steps in this lesson

  1. Painting Is Named in the Scope
  2. Action Level 2, PEL 10
  3. Trigger Tasks: Assume High Until Measured
  4. Interim Protection and the 600 ppm Line
  5. Calculate the TWA, Then Set the Monitoring Schedule

The worked example in the course applies this lesson to a realistic job in 6 steps, starting with "Write the TWA formula".

What you'll be able to do

  • Explain the main idea of "Lead on the Job: Cal/OSHA PEL, Action Level and Trigger Tasks" in plain language you can use on the exam.
  • Apply this step with confidence: "Trigger Tasks: Assume High Until Measured".
  • Apply this step with confidence: "Interim Protection and the 600 ppm Line".
  • Apply this step with confidence: "Calculate the TWA, Then Set the Monitoring Schedule".
  • Test yourself on the worked example and the quick-check quiz inside the classroom.
Cal/OSHA Lead: Find the 8-Hour TWA8 CCR §1532.1 LIMITS (8-hr TWA)Action level: 2 µg/m³PEL: 10 µg/m³Level 1 tasks: above PEL, up to 100Level 2 tasks: above 100, up to 500Level 3 tasks: above 500MONITORING FREQUENCY (d)(6)2 up to (not incl.) 30: every 12 months30 to 50: every 6 monthsAbove 50: quarterlyNotify employees in 5 working daysCREW 1: SCRAPING3 h x 60 = 1805 h x 5 = 25(180 + 25) ÷ 8 = 25.6Above PEL 10Monitor every 12 monthsCREW 2: MANUAL SANDING4 h x 100 = 4004 h x 4 = 16(400 + 16) ÷ 8 = 52Above PEL 10 and above 50Monitor quarterlyBoth crews exceed the 10 µg/m³ PEL: controls and respirators requiredSource: 8 CCR §1532.1(b), (c)(1), (d)(2), (d)(6)CC
The diagram for this lesson, exactly as it appears in the Learning Hub.

The first steps of this lesson

Step 1: Painting Is Named in the Scope

8 CCR §1532.1(a) applies to all construction work where an employee may be occupationally exposed to lead, and it defines construction work as including "painting and decorating." It covers removal or encapsulation of lead-containing materials and renovation of structures or substrates that contain lead. "Altering or disturbing" means any process that may release lead dust, mist or fume, and the list includes scraping, sanding, abrading, spraying and grinding. This is the rule that protects the painter's own crew, separate from the EPA rule that protects occupants.

Step 2: Action Level 2, PEL 10

Under §1532.1(b) the action level is 2 micrograms of lead per cubic meter of air (2 µg/m³), and under §1532.1(c)(1) the permissible exposure limit (PEL) is 10 µg/m³, both as an 8-hour time-weighted average (TWA). (There is a separate 25 µg/m³ limit for abrasive blasting until January 1, 2030.) The TWA is the exposure averaged over 8 hours, so a few hours at a high level can push the average over the PEL even if the rest of the day is clean. Exposure is figured without counting the respirator (§1532.1(d)(1)(B)).

The remaining 3 steps, the worked example and the quiz are in the course. This is a preview. The full lesson, with the step-by-step explanations, a worked example and a quick-check quiz, is inside the classroom.

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