2.1 Regulatory Requirements
Regulations applicable to lead safety may vary depending on Federal, State, and local jurisdictions. For more specific information on the regulations for workplace lead, please contact the Plan Administrator or Microsoft OHS.
2.2 Prevention and Control
2.2.1 Site Lead Safety Plan
Each Microsoft location included in the scope of this program must develop a site-specific Lead Safety Plan (“Site Plan”). The Site Plan must be made available to all affected employees and external staff, or any regulatory agency personnel. The Site Plan must include the following:
Program purpose and scope.
Site-specific regulatory requirements.
Personnel roles and responsibilities. A Plan Administrator must be designated for each facility to oversee implementation of the Site Plan.
Definitions of terms critical to an understanding of the Site Plan.
General safety rules for working with lead or working in areas where lead is present.
Standard Operating Procedures (SOPs) for the use of lead and lead-containing materials.
A description of workplace controls including engineering and administrative controls.
PPE requirements.
Proper disposal methods for discarded lead-containing materials.
Incident investigations for all accidents, incidents, and near-misses that were directly or indirectly related to lead.
2.2.2 Hazard Identification and Risk Assessment
The Plan Administrator, in conjunction with Microsoft OHS, will assess the workplace to develop a current listing of the potential hazard areas, activities, or processes that involve the use lead or lead-containing materials. Lead may be found in paints, coatings, electronic devices, and materials used during welding and soldering. Hazards will be identified through exposure or risk assessments. Any area where lead hazards are identified will be communicated to affected employees and external staff by the Lab Manager, Project Manager or Contract Liaison. For more information, refer to the Microsoft Exposure Assessment Program, Lab Safety Manual, and the Microsoft Chemical Hygiene Plan.
2.2.3 Exposure Monitoring
Exposure monitoring and area sampling requires the development of sampling strategy which considers the following parameters:
Exposure monitoring or area sampling shall be conducted only by qualified personnel supervised by a Certified Industrial Hygienist (CIH). Exposure monitoring and area sampling will be conducted in a manner consistent with standard protocols established by such agencies as OSHA or NIOSH.
All sampling and monitoring analytical results will be communicated to both the Plan Administrator and Microsoft OHS. All results of sampling and monitoring must be communicated to the appropriate Lab, Project, or Facility Manager and all affected employees/external staff within 5 days of receipt of the results.
Based on the sampling results, appropriate exposure controls and safe work practices will be defined. Additional requirements related to the sampling or monitoring results may include:
Development of an exposure control plan
Determination of Lead Safety training
Providing proper signage and labeling in hazardous areas
Defining waste disposal plans.
Additional detailed information regarding employee monitoring is contained in the Microsoft Exposure Assessment Program.
No employee or external staff may be exposed to lead at concentrations greater than fifty micrograms per cubic meter of air (50 µg/m3) averaged over an eight-hour period.
If there is a documented overexposure, the Site Administrator shall implement engineering and administrative controls that reduce the exposure to levels and shall audit the Site Plan to ensure compliance with applicable regulations. Immediate notification of the overexposure will be made to Microsoft OHS, CELA and the appropriate Benefits Business Partner.
2.2.4 Workplace Controls
Where any employee could potentially be exposed to lead above the PEL described (in Section 2.3 exposure monitoring) for more than 30 days per year, the responsible Manager or Supervisor, will implement controls to reduce and maintain employee exposure to lead. Where any employee is exposed to lead above the PEL, for thirty days or less per year, the responsible manager or supervisor will implement engineering controls to reduce exposures to less than 200 µg/m3. Any combination of engineering, work practice (including administrative controls), and respiratory controls may be used to reduce and maintain employee exposure to lead at or below 50 µg/m3.
The following control strategies may be used singly or in combination for controlling exposure to lead:
If engineering and work practice controls are not sufficient to reduce employee exposure at or below the PEL, the responsible manager or supervisor will implement additional controls to reduce exposures to the lowest feasible level, including the use of respiratory protection.
Examples of appropriate workplace controls can be found in Appendix B.
2.2.5 Disposal Methods
Lead-containing materials must be properly disposed of consistent with Federal, State and local environmental requirements. Lead and lead-containing materials may not be disposed of as general or universal waste. For more information on proper disposal methods, contact Global OHS
OHS or the Plan Administrator and reference the Microsoft Lab Safety Manual.
2.2.6 PPE Requirements
For more detailed information regarding PPE selection refer to the Microsoft Personal Protective Equipment Program.
2.2.7 Respiratory Protection
If a work task causes exposure to airborne lead above the PEL, a respirator equipped with appropriate cartridges for environments contaminated with lead must be used. Respirator use requires prior approval and recommendations from Microsoft OHS. Employees and external staff shall refer to the Microsoft Respiratory Protection Program to determine respiratory protection requirements associated with the job or task performed.
2.2.8 Protective Work Clothing and Equipment
Appropriate protective work clothing and equipment will be provided at no cost to the employee if an employee is exposed to lead above the PEL. This may include, but is not limited to:
Coveralls or similar full-body work clothing.
Gloves, hats, and shoes or disposable shoe coverlets.
Face shields, vented goggles, or other appropriate protective equipment for the work being performed.
Protective clothing will be provided in a clean and dry condition to employees whose exposure levels without regard to a respirator are over 200 µg/m3 of lead as an eight-hour TWA. In addition, Microsoft shall inform in writing any person who cleans or launders protective clothing or equipment of the potentially harmful effects of exposure to lead. Individuals are not allowed to launder lead-contaminated clothing at their home. Lab Managers, Facility Managers, or Project Managers will prohibit blowing, shaking, or using other means for lead removal from protective clothing or equipment which could disperse lead into the air. Microsoft will notify external staff of any lead exposure that requires PPE.
2.2.9 Medical Surveillance
Microsoft OHS and CELA shall institute a medical surveillance program for all employees and external staff who are or may be exposed at or above the action level for more than 30 days per year. Microsoft OHS will ensure that all medical examinations and procedures are performed by or under the supervision of a licensed physician. If an employee has a concern about an exposure to lead, they should contact Microsoft OHS and their Business Benefits Partner.
2.2.10 Signage and Labeling
Detailed information regarding chemical signage and labeling can be found in the Microsoft Lab Safety Manual.
Each Microsoft location may use signs required by other statutes, regulations or ordinances in addition to, or in combination with, signs required by OSHA. The Plan Administrator will ensure signage complies with applicable regulatory standards for communication of warnings and lead hazards.
2.2.11 Lead Safety Training
Lab Managers, facility managers or Project managers must ensure that employees and external staff authorized to perform tasks where lead or lead-containing materials are used receive Lead Awareness training. Lead Awareness training shall be provided to each employee or external staff who is subject to exposure to lead. Managers/Supervisors must train authorized personnel at initial assignment and retrain annually, or if changes in procedures or work assignments occur. Microsoft OHS has defined training to meet regulatory requirements for working in environments where lead is present. To obtain training, contact Global OHS.
The training program must include the following information:
An overview of lead safety requirements and hands-on instruction of the applicable Site Plan.
Applicable federal, state or local regulations.
A summary of the lead safety program and how to access the written program.
The specific nature of the operations which could result in exposure to lead above the action level.
The purpose and a description of the medical surveillance program, and the medical removal protection program including information concerning the adverse health effects associated with excessive exposure to lead (with particular attention to the adverse reproductive effects on both males and females).
The engineering controls, administrative controls, and safe work practices associated with the employee's job assignment.
The contents of any compliance plan in effect.
Instructions to employees that chelating agents should not routinely be used to remove lead from their bodies and should not be used at all except under the direction of a licensed physician.
Details of the PPE requirements for lead work.
Procedures for responding to and reporting an incident.
The Site Plan must include additional information as required by federal, state, and local regulations if there is a potential exposure to airborne lead at any level.
2.2.12 Lead Safety Sample Documents
Appendix A contains a Sample Lead Safety Site Plan Outline to assist in the development of a site-specific lead safety program. Appendix B contains Examples of Workplace Controls.
