A construction project involves removal of lead-based paint from a bridge built in 1960. The 8-hour TWA exposure measurement shows 40 μg/m³. What action is required under Cal/OSHA?
Correct Answer
A) Provide medical surveillance and implement controls
At 40 μg/m³, the exposure exceeds the action level (30 μg/m³) but is below the PEL (50 μg/m³), requiring medical surveillance and exposure control implementation.
Why This Is the Correct Answer
Under Cal/OSHA Section 1532.1, the Action Level (AL) for lead is 30 μg/m³ and the Permissible Exposure Limit (PEL) is 50 μg/m³. At 40 μg/m³, the exposure exceeds the AL but is below the PEL. This triggers requirements for medical surveillance and implementation of engineering/administrative controls to reduce exposure.
Why the Other Options Are Wrong
Option B: No special action required
No action required is incorrect. Even at 40 μg/m³ — below the PEL — the Action Level of 30 μg/m³ has been exceeded, triggering mandatory medical surveillance and exposure control requirements.
Option C: Implement exposure control measures
Implementing exposure control measures alone is insufficient at this level. Once the Action Level is exceeded, medical surveillance is also required — not just engineering controls.
Option D: Stop work immediately
Stopping work immediately would be appropriate if the PEL of 50 μg/m³ were exceeded without adequate controls in place. At 40 μg/m³ (below the PEL), work may continue with appropriate controls and medical monitoring.
Memory Technique
Lead ladder: 30 AL → both surveillance AND controls kick in. 50 PEL → full compliance mandatory. Think of 30 as the 'alert' and 50 as the 'alarm.' At 40, you're between the two — alert mode: monitor people AND control exposure.
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