I-D-09.50SOSOPage 1 of 11
Rev # 2
SAFETY / SOSO / Current Issue:10/31/07Revision: 2
By: W. Wagner
Verified by:___
Date:______/ Lead-Based Material Handling Practices
Date Reviewed:
05/06/14 / I-D-09.50 Page 1 of 11 / Original Issue: 04/25/95
Originator: P. Daigle
STATEMENT OF PROCEDURE
This procedure outlines the health and safety requirements for the removal of lead-based paints and coatings, and the burning or cutting of metal alloys containing lead. Lead is a systemic, cumulative poison that can enter the body by inhalation of dust, fume or vapor, or by ingestion via eating, drinking or smoking on the job. Lead was once a common component in several metal alloys and paints. As the hazards of lead have become known, many of its uses have been discontinued. However, due to lead-based paint's resistance to rust and corrosion, and unique characteristics in metal alloys it is still used for many industrial applications.
Significant lead exposures can occur by removing paint from surfaces previously coated with lead-based paint and the cutting or burning of lead contaminated metal alloys such as during the repair and maintenance, renovation or demolition of tanks, vessels and steel structures. Operations that commonly generate lead dust and fume include:
a.Flame-torch cutting, welding or grinding of lead-based alloys or paint surfaces during dismantling and demolition work.
b.Abrasive blasting of lead-based paint structures.
c.Use of torches, heat guns or sanding of lead-based alloys or paint surfaces during renovation work.
OBJECTIVE
The recommendations contained in this procedure are intended to minimize exposures to lead in the workplace and meet the requirements mandated by OSHA Standards 1910.1025 and 1926.62.
Procedure recommendations shall be followed during the following type of activities:
1.Demolition or salvage of structures where materials containing lead are present.
2.Removal or encapsulation of materials containing lead.
3.New construction, alteration, repair or renovation of structures substrates that contain lead.
The procedure does not specifically address the installation of products containing lead, however, many of the work practices still apply. The purchase of lead containing products that may create exposures during their application or later removal should be substituted, if feasible, with a non-lead containing product. SOSO I-D-22.00, Hazardous Materials Screening Committee Guidelines, must be adhered to.
PRE-WORK LEAD IDENTIFICATION
Lead is found in many types of paints and coatings; unless the chemical content of the coating can be identified through documented engineering specifications or analysis of the paint, lead should be assumed to be present.
a.All coatings should be assumed to contain lead unless identified otherwise by documented engineering specifications or analysis of the paint.
b.Samples of the paint shall be collected by a designated, competent individual, trained in the hazards of lead and sampling protocol.
c.The competent individual will follow the Maintenance Procedure for Qualitative Lead Testing Practices number 25-8.
d.Once the material is identified to contain lead,samples shall be analyzed by methods that will provide reliable results down to 0.1% or less of lead concentration by weight. Two available methods are atomic absorption spectrophotometry (AAS) and X-ray fluorescence (XRF). A sample is considered lead-free if analysis indicates that the lead content is below 0.1% by weight.
e.When sample analysis is performed by a laboratory, the laboratory shall be accredited for lead (metals) analysis by the AAS method.
PREPARATION FOR WORK
Any job involving disturbing coatings or materials that have .1% lead content or above, requires a written compliance program. The compliance program must be submitted to the Green Lake Complex Safety Department for review prior to the job being performed.
EXPOSURE LIMITS
Exposures to lead shall be maintained below the OSHA Permissible Exposure Limit.
a.Permissible Exposure Limit (PEL): 50 g/m3 averaged over an eight hour period (TWA)
b.Action Limit (AL): 30 g/m3 averaged over an eight hour period
c.Maximum Lead in Blood (PbB): 40 g/dl
EXPOSURE CONTROLS
The most effective means of preventing lead exposures is to leave existing lead-based paint undisturbed either by surface preparation or application of new coatings over existing paint. If this is not feasible, then the following may be required to control exposures below the permissible exposure limit.
1.Engineering Controls
Engineering controls are the preferred method for controlling exposures to lead and shall be considered as the first means of controlling worker exposures. The following engineering controls, if feasible, shall be considered.
a.Increase the length of the cutting torch, thereby increasing distance to the source of the contamination.
b.When flame-torch cutting or welding on coated structures, the lead-based paint should be removed 6 inches from both sides of the cut or weld.
c.Use of a vacuum or wet vacuum blasting as opposed to open-air blasting.
d.Use of a rotary piening, needle scaling or angle sanders with vacuum recovery.
e.Use of chemical stripping systems.
f.Use of high pressure water blasting with vacuum recovery.
g.When feasible, avoid open air blasting. If blasting is permitted, controls such as a partial enclosure shall be used to reduce exposure outside the work area.
h.When working indoors, use local exhaust ventilation with the movable hood placed as near the source of lead emission as practical.
i.When welding or cutting in confined spaces, use adequate ventilation to prevent accumulation of toxic materials.
j.Mechanical ventilation used must not be of a type that removes the toxic materials to adjacent work areas. A HEPA filtered system is necessary to avoid contamination of other work areas. The performance of mechanical ventilation must be evaluated periodically to insure its effectiveness.
NOTE: All vacuum and ventilation systems must be equipped with high efficiency particulate air (HEPA) filters to minimize lead discharge.
2.Work Practice Controls
Good work practices are important in controlling exposures to lead. The following work practices shall be considered:
a. Regulated Area: For job tasks that may create exposures reasonably likely to exceed the PEL, the work area shall be restricted to authorized and properly equipped personnel.
b.For the removal of paints and coatings, a protective skirting, at least 6 mil in thickness, should be placed on the ground of the work area to prevent contamination and allow for easier clean-up. All loose debris should be removed from the ground after each day, at a minimum, if not after each task. The debris should be placed into properly labeled containers, and held for proper disposal.
c.Personal protective equipment shall not be removed in the lead work area.
d.Rags used in the work area shall be placed in properly labeled, closed containers at the end of each use.
e.Eating, drinking and smoking shall not be permitted in the work area.
f.Disposable clothing worn in the lead work area shall be removed in a designated change area before the worker leaves the area. Contaminated clothing should be placed in a properly labeled, closed container until it can be properly disposed. A HEPA vacuum should be used initially to remove gross contaminant. Respirators shall be worn during the vacuuming process.
g.Employees working in the lead work area shall be provided adequate facilities for washing and showering, and be required to do so.
h.No personal clothing, as the outer most layer, shall be worn into the work area.
i.No lead protective work clothing shall be worn out of the worksite, unless decontamination procedures have been followed.
j.Contaminated surfaces shall not be dry swept or blown with air. A HEPA vacuum shall be used during the decontamination process.
k.The maintenance coordinator shall insure compliance with the requirements of the lead compliance program. The inspection program shall include documentation of the inspection schedule, inspection findings and corrective action taken.
3.Personal Protective Equipment (PPE)
Personal protective equipment is to be used during any task that may create an exposure to lead. If a job task may expose personnel in excess of the permissible exposure limit, proper personal protective equipment shall be used. The following types of protective equipment shall be considered:
Respiratory Protection
When respiratory equipment is used, a written respiratory program shall be implemented in accordance to the OSHA Respiratory Standard 1910.134. Employees permitted to wear negative pressure respirators shall receive a qualitative or quantitative fit-test at time of initial fitting and at least once a year.
Respiratory protection shall be used in the following situations:
a.Exposure to lead exceeding the PEL.
b.Engineering controls and work practices are not sufficient to reduce exposures below the PEL.
c.An employee requests a respirator.
d.During initial exposure assessment for determination of potential exposure levels to lead.
The minimum required level of respiratory protection is as follows:
Airborne Concentrations of Lead Required Respirator
Not in excess of the 500 g/m3Half-face, air purifying
(10X PEL)respirator with HEPA filters
Not in excess of 1,250 g/m3Powered air purifying
(25 X PEL)respirator with HEPA filters, or hood or helmet supplied air operated in continous flow mode
Not in excess of 2,500 g/m3Full facepiece air purifying
(50 X PEL)respirator with HEPA filters
Not in excess of 50,000 g/m3Supplied air respirator
(1,000 X PEL)operated in positive pressure mode
Personal Protection
The following personal protective equipment is required to prevent lead exposure.
a.Full-body coveralls with hood: Full-body disposable coveralls or similar full body protection, shall be worn to avoid skin exposure and contamination of under layers of clothing. The outer most layer of protective clothing worn in lead work area shall be left at the work site for proper decontaminated or disposal.
b.Rubber boots or disposable shoe coverlets: Boots should be worn to reduce contamination of work or personal shoes. Boots should be taped to the coveralls to reduce chance of contamination. If shoe coverlets are worn, they shall be worn at all times in the work area and removed when leaving.
c.Gloves: Gloves are required to reduce hand contamination. Gloves should be taped at the wrist and be suitable for the work to be performed.
d.Safety glasses and/or faceshields: Appropriate eye and face protection must be worn during blasting, sweeping, chipping, cutting or welding tasks.
e.Hearing protection: Hearing protection is required when noise levels exceed 85 dBA averaged over eight hours. Tasks which are expected to exceed this level include piening, abrasive blasting, grinding, chipping, power wire brushing, and power sanding.
SIGNS AND LABELS
Contractors performing lead abatement projects at the Green Lake Complex are responsible for posting signs and labels specified below:
Signs: For job tasks that create exposures in excess of the PEL, the work area shall be restricted to authorized and properly equipped and trained personnel. The restricted work area shall be identified by rope, banner, tape or the equivalent. Signs shall be posted to warn employees of the hazard. Posted signs shall read:
WARNING!
LEAD WORK AREA
POISON
NO SMOKING OR EATING!
Labeling: Containers of contaminated protective clothing and equipment to be cleaned, laundered or disposed of shall be labeled as follows:
CAUTION: CLOTHING CONTAMINATED WITH LEAD.
DO NOT REMOVE DUST BY BLOWING OR SHAKING.
DISPOSE OF LEAD CONTAMINATED WASH WATER IN ACCORDANCE WITH
APPLICABLE LOCAL, STATE AND FEDERAL REGULATIONS.
Pending results of testing for hazardous waste status, containers for disposal may require a hazardous waste label in accordance to EPA Resource Conservation and Recovery Act (RCRA) requirements.
EXPOSURE ASSESSMENT
Contractors performing lead abatement projects at the Green Lake Complex are responsible for an Exposure Assessment Program. The Exposure Assessment Program shall be established to monitor and document employee exposures during tasks that may create an exposure to lead. An assessment of the exposures shall be conducted each time identified lead exposure tasks are performed unless:
a.Monitoring results collected in the past 12 months during similar work operations, workplace conditions, type of material, work practices control methods and environmental conditions are available that represent current exposures.
b.Objective data is available that demonstrate that a particular product or material containing lead cannot result in employee exposure to lead above the action limit.
The following elements shall be considered in the Exposure Assessment Program:
1.An initial assessment at the start of any task that has been identified that may create exposures to lead above the action limit.
2.Full shift personal exposure monitoring that is representative of the employee's regular, daily exposure to lead.
3.One personal sample for each job classification for each shift or for the shift with the highest exposure. If exposures are determined to be over the action limit, personal samples shall be collected for each employee in the regulated area exposed to lead.
4.A perimeter environmental (area) air sample shall be collected during the shifts with the highest lead emissions. The sample shall be taken downwind at the perimeter of the work area for determination of worst case.
5.Perimeter air monitoring shall be done unless the job is small-scale, short-duration such as removing a band of leaded paint from an I-beam or pipe, torch cutting an I-beam or pipe, or removing a small amount of paint to do a weld.
6.All air sampling will be performed and analyzed using NIOSH methods #7082, #7105 or equivalent. Samples will be analyzed by an AIHA accredited laboratory.
7.Exposure monitoring shall be performed by a competent person having, at a minimum, a course in basic industrial hygiene monitoring. The lead abatement contractor is responsible for having a competent person.
8.If the initial assessment determines exposures to be above the action limit but below the PEL, exposure monitoring shall be repeated, if applicable, every 6 months. If the initial assessment determines exposures to be above the PEL, exposure monitoring shall be repeated quarterly, if applicable.
9.Contractors, at a minimum, shall perform monitoring in accordance with the requirements of this section and the mandated monitoring requirements of all Federal, state and local regulations. Results of all monitoring will be provided to Green Lake Complex management.
10.Enclosures for lead abatement that meet the criteria for a confined space will be monitored as outlined in SOSO I-D-5.50, "Confined Space Entry". Prior to any lead abatement work the initial atmospheric testing for entry will be conducted by Green Lake Complex personnel. Once abatement has started, monitoring is to be done by contract personnel and the results communicated to Green Lake Complex Operations personnel.
TRAINING
All lead abatement contractors at the Green Lake Complex must meet the following requirements. All employees exposed to lead shall receive training in accordance to the OSHA Hazard Communication Standard. Personnel exposed to lead in excess of the action limit for any day during a year, shall participate in a lead training program. The training shall be given at the time of initial assignment and repeated annually.
The training program shall consist of the following:
a.The content of the OSHA Lead Standard 1926.62.
b.Specific operations which could result in exposure to lead above the action limit.
c.The purpose, proper selection, fitting, use and limitations of respirators.
d.Purpose and description of the medical surveillance program, and medical removal protection program. If applicable, the medical training should include discussion on use of chelating agents and blood lead levels.
e.Information concerning the adverse health effects associated with excessive exposure to lead.
f.Engineering controls and work practices associated with the job assignment.
g.The contents of any compliance plan in effect.
h.The importance of good personal hygiene and proper decontamination procedures.
i.The employee's right of access to monitoring and medical records.
j.All materials relating to employee information and training program, including a copy of the OSHA Lead Standard shall be made available upon request.
MEDICAL SURVEILLANCE
All workers exposed to lead, above the action limit for more than 30 days in any consecutive 12 months, shall be offered to be included in a medical surveillance program. The local physician shall be consulted on appropriate medical surveillance requirements and workers to be included using 29 CFR 1926.62 as a minimum guideline.
The Green Lake Complex will not provide medical services to contractor employees unless an alternative contractual agreement is specified. The contractor shall have a medical surveillance program in accordance with all federal, state and local regulations. The medical surveillance program shall be in writing and specify:
a.Employees identified to participate in the medical surveillance program.
b.Appropriate baseline blood tests for lead and zinc protoporphyrin.
c.The periodic blood tests and zinc protoporphyrin of affected employees.
d.A blood test and zinc protoporphyrin at the completion of the job.
e.Appropriate medical examination content in accordance to OSHA standards.
f.Appropriate frequency of examinations for affected employees.
Biological Monitoring
As part of the initial medical surveillance, any worker exposed to lead, above the action limit during any work day shall be offered biological monitoring in the form of blood sampling and analysis for lead and zinc protoporphyrin. The biological monitoring provisions of the Medical Surveillance Program shall include the following:
1.Workers exposed to lead, above the action limit for more than 30 days, shall be offered biological monitoring at least every 2 months for the first 6 months and every 6 months thereafter.
2.If an employee's blood lead level exceeds 40 g/dl the frequency of biological monitoring shall continue at least every two months until analysis of 2 consecutive samples are below 40 g/dl.
3.Employees temporarily removed from work due to elevated blood lead level shall be sampled monthly during the removal period.
4.Lead abatement contractors shall provide Green Lake Complex Management with the latest biological monitoring results for its employees at the start of the project. Results over six months old shall be repeated.
CONTRACTORS
In accordance with the Green Lake Complex Contractor Safety Program, contractor personnel are expected to conduct their assigned duties in a safe and proficient manner in compliance with all Federal, state and local safety and health regulations and the Green Lake Complex Safety Rules and procedures. The contractor shall assure that their employees and subcontractor employees are trained in the hazards of lead and the provisions of the OSHA lead Standard. Documentation of the training shall include: material covered, identity of the employee, date of the training, and means used to verify that the employee understood the training. All training records shall be made accessible to the Green Lake Complex.