Lead in Construction Compliance Plan — 29 CFR 1926.62 Compliant
The written compliance plan required by OSHA 1926.62(e)(2) before any construction work where employees may be exposed to lead. Covers exposure determination, methods of compliance, medical surveillance with BLL triggers, hygiene facilities, and the Competent Person designation.
When this template is required
Required of every construction employer with employees who may be exposed to lead — including demolition, removal/encapsulation of lead materials, new construction or renovation involving lead-containing materials, transportation/disposal of lead materials, and lead abatement. PEL: 50 µg/m³ 8-hour TWA; Action Level: 30 µg/m³ 8-hour TWA. The written compliance program (1926.62(e)(2)) is required BEFORE work commences.
Why this template
Trigger task list — presumed exposure
1926.62(d)(2) identifies trigger tasks (abrasive blasting, welding, cutting, burning on lead-painted surfaces; lead burning; abrasive blasting/sanding of lead-painted surfaces; rivet busting) where the employer must presume the worker is exposed above the PEL until an exposure assessment documents actual exposure — objective data may not be used for this purpose (29 CFR 1926.62(d)(3)(iv)(B)). The plan includes the trigger task list and the procedural response.
Medical Removal Protection (MRP)
29 CFR 1926.62(k)(1)(i) requires removal when a periodic and a follow-up blood test both show a level at or above 50 µg/dL. 40 µg/dL is the return threshold, not a removal trigger. MRP provides up to 18 months of medical removal at full pay and benefits — a substantial cost that the program documents and tracks.
BLL trending log
Tracking BLL trends across the workforce identifies operational issues before they trigger MRP. The trending log captures all BLL results with date, employee, exposure context, and remediation actions.
Multi-employer site coordination
On multi-contractor sites, 1926.62(e)(2)(ii)(H) requires information exchange between host/controlling/exposing employers about potential lead exposure. The procedure documents the exchange.
What you receive
- Lead in Construction Compliance Plan (Word .docx) — written program per (d)-(n)
- Initial exposure determination procedure (PEL: 50 µg/m³; Action Level: 30 µg/m³)
- Air monitoring schedule (initial + periodic + change-triggered)
- Methods of compliance — engineering & work practice controls hierarchy
- Respiratory protection program crosswalk (with 1910.134)
- Medical surveillance protocol (examination by or under the supervision of a licensed physician, blood/biological tests as applicable)
- Lead work area designation and warning-sign procedure (29 CFR 1926.62(m)(1)(i) signage, with clothing, change area and hygiene controls)
- Housekeeping and hygiene procedures
- Employee training outline (annual refresher requirement)
- Recordkeeping requirements (exposure: 30 years; medical: employment + 30 years)
- Trigger task list — presumed-exposure operations under 1926.62(d)(2)
- Competent Person designation form
- Medical removal protection (MRP) procedure (removal on a periodic and follow-up test at or above 50 µg/dL; return on two consecutive tests below 40 µg/dL)
- Blood Lead Level (BLL) tracking and trending log
- Multi-employer worksite coordination procedure (1926.62(e)(2)(ii)(H))
How you get it
This document is written and reviewed against the standard it cites, and it is ready now. The download link is emailed as soon as your payment clears.
Revisions included — if something about your operation changes what the document should say, reply to the delivery email and we will amend it.
Who buys this
- Lead abatement and demolition contractors
- Bridge painting contractors (lead-based paint removal)
- Renovation contractors working on pre-1978 structures
- Welding and torch-cutting on lead-painted steel
- Industrial coating contractors
- Plumbing contractors working with lead pipe or solder
Frequently asked
What's the difference between this and the general industry lead plan?
29 CFR 1926.62 covers construction work where lead exposure may occur. 29 CFR 1910.1025 covers general industry (manufacturing) lead exposure. Both have the same PEL (50 µg/m³) and Action Level (30 µg/m³), but different exposure scenarios, methods of compliance, and trigger task definitions. Many contractors need 1926.62 (construction work) while their permanent facility operations would be under 1910.1025.
What's a 'trigger task' under 1926.62(d)(2)?
Specific construction tasks where the employer must PRESUME the worker is exposed above the PEL until air monitoring shows otherwise. Examples: manual demolition of structures with lead, manual scraping/sanding of lead-painted surfaces, heat gun applications, power tool cleaning with HEPA, lead burning, rivet busting, abrasive blasting, welding/cutting/burning on lead surfaces. Trigger tasks have presumed-protection requirements before exposure data is available.
When is Medical Removal Protection triggered?
1926.62(k) requires removal when: (1) A periodic test shows BLL ≥50 µg/dL — immediate removal; (2) The average of the last three BLLs (or all BLLs over past 6 months, whichever is more) is ≥50 µg/dL; (3) Removal upon employee's request if the employee is pregnant or planning pregnancy and BLL is elevated. Removal continues until BLL is below 40 µg/dL and the physician determines return is appropriate.
What records do I need to keep?
Per 1926.62(n): Exposure monitoring records — 30 years. Medical records (including BLL results) — duration of employment + 30 years. Medical removal records — duration of employment + 30 years. Training records — 1 year. Written compliance plan — for the duration of the work.
Does this satisfy California requirements?
California has its own lead in construction standard, T8 CCR §1532.1. California's standard is generally stricter than federal — lower BLL action thresholds (Cal/OSHA adopted lower removal triggers in 2024), more frequent monitoring, more extensive medical surveillance. The template provides the federal baseline; California work needs the §1532.1 overlay.