UNIVERSITY OF SOUTH CAROLINA

ENVIRONMENTAL HEALTH AND SAFETY

OFFICE OF INDUSTRIAL HYGIENE

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INDUSTRIAL HYGIENE PROGRAM

SECTION 3: LEAD COMPLIANCE PROGRAM

Issued: November 1, 2005

Revised: November 2, 2006

A.  BACKGROUND

B.  PURPOSE AND SCOPE

C.  ORGANIZATION/OTHER ROLES AND RESPONSIBILITIES

D.  INDUSTRIAL HYGIENE RESPONSIBILITY

APPENDICES:

APPENDIX A: Departmental Lead Management Plans

1.  Facility Services Lead Management Plan (& review documentation)

2.  Housing Maintenance Lead Management Plan (& review documentation)

APPENDIX B: Forms and Templates

1.  Lead Work Audit Form

2. Lead Training Outline

APPENDIX C: Air Monitoring Results

APPENDIX D: Training Records

APPENDIX E: Annual Program Review Records

APPENDIX F: Lead Work Audit Records (separate binder)

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USC EHS Office of Industrial Hygiene Destroy Previous Revisions

(EHS-M-016) Industrial Hygiene Program – Section 3 Issue Date: 3/1/06

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A. BACKGROUND

Inorganic lead can be absorbed into the body by inhalation (breathing) and ingestion (eating). Lead (except for certain organic lead compounds, such as tetraethyl lead) is not absorbed through your skin. When lead is scattered in the air as a dust, fume, or mist it can be inhaled and absorbed through the lungs and upper respiratory tract. Inhalation of airborne lead is generally the most important source of occupational lead absorption. Lead can also absorb lead through the digestive system ingested.

Lead is a potent, systemic poison that can (depending on exposure) lead to a variety of acute (short-term) and chronic (long-term) health effects. Very high short-term exposures to lead can cause acute encephalopathy, which develops quickly to seizures, coma, and death from cardiorespiratory arrest. Chronic exposures to lead can result in severe damage to circulatory, nervous, urinary and reproductive systems. Damage to the central nervous system in general and the brain (encephalopathy) in particular is one of the most severe forms of lead poisoning.

The most common source of potential exposure to lead among USC employees is from the removal of lead-based paint. This work is regulated by OSHA under the Lead in Construction Standard (29 CFR 1926.62.

B. PURPOSE AND SCOPE

This document provides an overview of departmental roles and responsibilities regarding the effective management of lead containing materials at USC. It also establishes specific policies and procedures related to EHS’s role in lead issues at USC.

The office of Industrial Hygiene is responsible for the implementation and maintenance of this Lead Compliance Program.

The Industrial Hygienist:

1. Conducts annual reviews of Lead Management Plans for Facility Services and Housing Maintenance.

2. Provides consultative and technical assistance to campus organizations involved in activities related to lead.

3. Conducts regulatory audits of work regulated by the Lead in Construction Standard.

4. Conducts personal and area air monitoring to assess worker exposures and ambient concentrations of lead during work regulated by the OSHA Lead in Construction Standard.

5. Conducts training sessions for employees who engage in work activities where lead containing materials are disturbed.

6. Reviews this document annually.

C. ORGANIZATION/OTHER ROLES & RESPONSIBILITIES

Departmental Lead Management Plans have been developed and implemented for Facilities Planning and Operations and Housing Maintenance. Each department is responsible for following their respective Lead Management Plans. According to the Departmental plans, each department must comply with the following:

1.  Prior to disturbing any paint or painted building materials, determine if paint contains lead.

2.  Notify EHS prior to any construction or renovation work involving the disturbance of lead based materials.

3.  Consult with EHS on contracted projects requiring removal or demolition of potential lead containing building materials.

4.  Ensure that all construction and maintenance work involving lead or leadbased materials is performed in accordance with current regulatory requirements, and that the work practices outlined in Section 2.0 of the departmental lead management plan are followed.

5.  Ensure that all personnel who perform work regulated under 29 CFR 1926.62 are trained annually. EHS can provide this training.

D. INDUSTRIAL HYGIENE RESPONSIBILITY

The Office of Industrial Hygiene has the following responsibilities regarding the management of asbestos hazards at USC:

1. Conducts annual reviews of Facilities Planning and Operations’ and Housing Maintenance’s Lead Management Plans. In December of each year, the Industrial Hygienist will schedule and complete a review of Facilities Planning and Operations’ and Housing Maintenance’s Lead Management Plans. Following the review, a report of findings and recommendations will be forwarded to the department director. The form used for the reviews can be found in Appendix B of this document. Review reports and records can be found in Appendix A.

2. Provides consultative and technical assistance to campus organizations involved in activities related to lead. The Industrial Hygienist is available to provide consultative services to the University. This includes assisting Facilities Planning and Operations in developing lead-related work procedures, advising Facilities Planning and Operations and Housing Maintenance on regulatory compliance issues, and answering questions from faculty, staff and students. Upon request, the Industrial Hygienist is also available to attend meetings with contractors regarding specific projects.

3. Conducts audits of work regulated by the Lead in Construction Standard (29 CFR 1926.62). The Industrial Hygienist is responsible for conducting compliance audits of lead projects at the University. Also, all audit records and subsequent communication regarding that audit are maintained in Appendix E, a separate binder.

4.  Conducts personal and area air monitoring to assess worker exposures and ambient concentrations of lead during work regulated by the OSHA Lead in Construction Standard. Personal air sampling will be conducted as needed to establish Negative Exposure Assessments for each type of activity where lead is disturbed. Area samples will also be collected, as determined by the IH. Sampling records will be kept in Appendix C of this document.

5.  Conducts training sessions for employees who engage in work activities where lead containing materials are disturbed. The Industrial Hygienist will conduct training for Facilities Planning and Operations and Housing employees who, during the course of their job, disturb lead or lead containing materials. Training records are maintained in Appendix D of this document.

6.  Reviews this document annually. Beginning in 2006, each November, the IH will review this written program and evaluate its overall effectiveness.

Revision
No. / Date / Type of Revision / Revised By:
1 / 11/2/06 / Changed all instances of “Facility Services” to “Facilities Planning and Operations”
Removed “Departmental LMP Review Form” from Appendix B.
Moved lead work audit records to Appendix F.
Appendix E changed to: Annual Program Review Records / PKM

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USC EHS Office of Industrial Hygiene Destroy Previous Revisions

(EHS-M-016) Industrial Hygiene Program – Section 3 Issue Date: 3/1/06

Page 3 of 5