1.0 PURPOSE
The purpose of this program is to set forth the requirements and safe operating procedures to identify and control lead hazards.
2.0 RESPONSIBILITY
It is the responsibility of the job superintendents and all workers follow good work practices that minimize their potential exposure to lead and to implement the requirements of this procedure.
3.0 REFERENCES
29 CFR 1910.1025
29 CFR 1926.62
29 CFR 1910.134
29 CFR 1910.1020
4.0 DEFINITIONS
4.1 Action Level – employee exposure without regard to the use of respirators, to an airborne concentration of lead of 30 micrograms per cubic meter of air (30 g/m3) per 8-hour period.
4.2 Affected Employees – employees who have been or potentially been exposed to lead.
4.3 Competent Person – an individual who can identify existing and predictable lead hazards in the surroundings or working conditions and who has the authorization to take prompt corrective measures to eliminate them.
4.4 Employee Exposure – that exposure which would occur if the employee were not using a respirator.
4.5 Lead – metallic lead, all inorganic lead compounds, and organic lead soaps. Excluded from this definition are all other organic lead compounds.
5.0 PROCEDURE
5.1 Facility Coordination
5.1.1 The Site Manager or Superintendent, and Competent Person shall coordinate with the facility owner to communicate the location of work areas that may impact facility operations or personnel.
5.1.2 The Competent Person shall assess the work area and adjacent activities for potential exposure to other employers or plant personnel.
5.1.3 Subcontractors and other employers who may be affected by the lead activities shall be notified of the activities and the hazards associated with the work.
5.1.4 The notification should include the location of controlled access areas by authorized personnel only.
5.1.5 The employer shall assure that no employee is exposed to lead at concentrations greater than fifty micrograms per cubic meter of air (50 ug/m(3)) averaged over 8-hours.
5.1.6 When working on multi-contractor worksites, all employees shall be protected from potential exposure to lead.
5.2 Lead Assessments
5.2.1 A lead assessment shall be conducted before working on a painted or coated surface.
5.2.2 The Lead Assessment Form (NCS Form 034) or an equivalent form shall be completed by the equipment owner responsible for the work being requested with the aid of the facility’s Safety Department if necessary. Completed forms are to be kept with the project.
5.2.3 Nitro Construction Services employees shall not be assigned to do work that may involve exposure to lead unless a lead assessment is complete and proper precautions are taken to protect the employees, i.e. appropriate PPE.
5.3 Regulated Areas
5.3.1 Regulated areas are controlled access areas to which only authorized personnel are permitted.
5.3.2 Regulated areas are generally the containment system, decontamination facility, waste storage areas, and the perimeter immediately adjacent to the listed areas.
5.3.3 Regulated areas shall be adequately demarcated and warning signs posted for lead activities that result in exposure at or above the Action Level.
5.3.4 Demarcation should be in the form of warning tape and/or physical barriers warning of the hazards within the area.
5.3.5 Warning signs shall be posted warning entrants of the lead hazards for each work area at each entry point. Warning signs shall include the following at a minimum:
WARNING
LEAD WORK AREA
POISON
NO EATING OR SMOKING
5.4 Exposure Monitoring
5.4.1 Full shift personal samples shall be representative of the monitored employee’s regular, daily exposure to lead and shall be the responsibility of the employer.
5.4.2 If the initial determination or subsequent monitoring reveals employee exposure to be at or above the action level but below the permissible exposure limit, the employer shall repeat monitoring at least every 6 months.
5.4.3 The employer shall continue monitoring at the required frequency until at least two consecutive measurements, taken at least 7 days apart, are below the action level at which time the employer may discontinue monitoring for that employee.
5.4.4 Employees must be notified in writing of air monitoring results within 15 working days after the receipt of the results.
5.4.5 If the results indicate the employee exposure exceeds the permissible exposure limit, without regard to respirators, the employer shall include in the written notice a statement that the permissible exposure limit was exceeded and detail corrective action(s) to be taken to reduce exposure to or below the permissible exposure limit.
5.5 Use of Certified Contractors for Lead Abatement Work
5.5.1 Certified lead abatement contractors will be used for all work with the potential to produce lead exposures.
5.5.2 Jobs or tasks that could potentially have such exposures include:
5.5.2.1 Demolition or salvage of structures where lead or material containing lead are present.
5.5.2.2 Removal or encapsulation of materials containing lead.
5.5.2.3 New construction, alteration, repair, or renovation of structures or surfaces that contain lead.
5.5.2.4 Installation of products containing lead.
5.5.2.5 Lead contamination/cleanup.
5.5.2.6 Transportation, disposal, storage of materials containing lead where construction activities are performed.
5.5.2.7 Grinding, welding, cutting, or blasting on lead-painted surfaces or surfaces that may contain lead or manual scrapping or sanding on lead-containing materials or surfaces that are painted with lead paint.
5.6 Engineering and work practice controls
5.6.1 Where any employee is exposed to lead above the permissible exposure limit (PEL) for more than 30 days per year, the employer shall implement engineering and work practice controls (including administrative controls) to reduce and maintain employee exposure to lead.
5.6.2 Any welding cutting or brazing work that involves lead-based coatings is to be performed under local exhaust ventilation.
5.6.3 Tasks where dust from lead-based paints or coatings are generated will be performed wet, where feasible.
5.6.4 Workers must wear Tyvek Suits, or equivalent, and full-face respirators with HEPA/P-100 (purple) cartridges, which will be provided at no cost to the employee.
5.6.4.1 Respirators are to be used during the period necessary to install or implement engineering or work practice controls, where engineering and work practice controls are insufficient and during emergencies.
5.6.5 Enclosures, usually with negative ventilation, may be required based on tasks and potential employee exposures or environmental impacts.
5.7 Hygiene Facilities
5.7.1 Hygiene facilities (e.g. wash station, showers) shall be available on all project sites where lead exposure is at or above the Action Level, before Exposure Assessment or when deemed necessary by the Competent Person and/or Safety Department.
5.7.2 Site locations where the construction of hygiene facilities proves infeasible shall be communicated to the Safety Department for review. Hygiene facilities should be positioned at locations on the project site to effectively clean and decontaminate personnel.
5.7.3 Hand and Face Washing Facilities
5.7.3.1 Hand and face washing facilities shall be positioned for use for all affected personnel.
5.7.3.2 Lead workers are required to wash their hands and face and thoroughly decontaminate their person before leaving the regulated area, where feasible.
5.7.3.3 A remote wash station may be set up with an approved travel path as designated by the Competent Person where it is not feasible to have the wash station adjacent to the regulated area.
5.7.3.4 Hand and face washing facilities should be equipped with clean potable water, soap and cleaning supplies, and clean dry towels.
5.7.3.5 The Competent Person must ensure that wastewater generated from the hand and face-washing facility is containerized, tested, and properly discharged per Section 11.0 of this procedure or as directed by the client.
5.7.4 Shower Facilities
5.7.4.1 Shower facilities should be available and used by lead workers when exposure is at or above the PEL.
5.7.4.2 Lead workers, exposed at or above the PEL, are required to take a shower after each day.
5.7.4.3 Contaminated work clothing and/or protective clothing shall be containerized for laundering.
5.7.4.4 Shower facilities shall be equipped with clean potable hot and cold water, soap and shampoo, and clean dry towels.
5.7.4.5 Shower facilities may not be feasible at all project locations. The Site Manager or Superintendent, and Competent Person shall contact the Safety Department to determine feasibility. Project locations where shower facilities are not feasible shall at a minimum have a hand and face washing facility for worker hygiene.
5.7.5 Contaminated work clothing and/or washable protective clothing should be laundered and dried each day. The Competent Person should ensure a sufficient supply of work clothing and protective clothing during the cleaning cycles.
5.8 Compliance Program
5.8.1 Before the commencement of the job, each employer (facility owner) shall establish and implement a written compliance program which shall include:
5.8.1.1 A description of each activity in which lead is emitted;
5.8.1.2 A description of the specific means that will be employed to achieve compliance;
5.8.1.3 A report of technology considered in meeting the permissible exposure limit;
5.8.1.4 Air monitoring data which documents the source of lead emissions;
5.8.1.5 A detailed schedule for implementation of the program, including copies of purchase orders for equipment, construction contracts, etc.;
5.8.1.6 A work practice program;
5.8.1.7 An administrative control schedule, if applicable;
5.8.1.8 A description of arrangements made among contractors on multi-contractor sites concerning informing affected employees of potential exposure to lead.
5.9 There are acute and chronic health effects as a result of exposure to lead as listed below:
5.9.1 Acute Effects include abdominal pain, constipation, limb pain, hypertension, vomiting, coma, respiratory arrest, death.
5.9.2 Chronic Effects include fatigue, weight loss, insomnia, decreased sexual function, shaking of arms, foot drop, wrist drop, the blue line on gums.
5.10 Lead can be found during the following activities in industries: abrasive blasting; welding, cutting and burning on steel coated with lead-based paint; lead burning; spray painting with lead-based paint; hand scraping of lead-based paint; heat gun removal of lead-based paint. This list is not all-inclusive. Conduct a lead assessment as detailed in Section 5.2 to verify the presence of lead.
6.0 TRAINING AND EDUCATION
6.1 All employees, subcontractors, owner personnel, and other persons that will be involved in the lead activities shall be trained based on the level of involvement, activities conducted, and exposure values before the time of job assignment (initial training) and annually thereafter. This training shall be documented.
6.2 Competent Person
6.2.1 A Competent Person shall supervise each project site that generates lead exposure at or above the Action Level. A Competent Person shall meet the following criteria to obtain the status of a Lead Competent Person:
6.2.1.1 Demonstrate competency and proficiency in the identification and control of lead hazards as determined by the Nitro Construction Services Corporate Safety Director.
6.2.1.2 Annual Refresher Training
6.2.2 The Competent Person may perform other duties such as Site Manager, Site Safety, Superintendent, or Quality Control provided that these duties do not impair his or her primary lead responsibilities.
6.3 Lead Worker Training
6.3.1 Each worker involved in the lead activities at any level that will result in exposure at or above the Action Level shall participate in the Lead Worker Training Program, which shall be documented. This program consists of model course materials that train lead workers on the proper procedures for lead activities.
6.3.2 The training program will include, at a minimum, the following items:
• Introduction to Lead
• Health Effects of Lead
• Activities that result in Lead Hazards
• Lead Hazard Control Measures
• Decontamination Procedures
• Respiratory Protection Device Training
• Medical Surveillance Program
• Site-Specific Compliance Plan
• Hazard Communication Program
• Contents of the Lead in Construction Standard
• Hazards of Chelation Therapy
• Employee Access to Information
• General Safety
7.0 Medical Surveillance
7.1 A Medical Surveillance Program shall be developed and initiated for all lead activities that result in worker exposure above the Action Level. This program will include testing workers for biological exposure indices to monitor internal exposure to lead. Workers are encouraged to participate in the program to monitor their internal exposure to lead, however, the program is voluntary.
7.2 Medical Clearance for Respiratory Protection Devices
7.2.1 All workers who in the course of their work activities are required to use respiratory protection devices shall be deemed medically capable of using the selected device or devices by a physician or licensed health care professional (PLHCP).
7.2.2 See Respiratory Protection procedure #029 for details.
7.3 Biological Monitoring
7.5.1 Biological monitoring shall be conducted on employees potentially exposed at or above the action level of 30 micrograms/cubic meter of lead by a physician or licensed health care professional (PLHCP). The extent and frequency will be based on exposure values and test data.
7.5.2 For each examination, Nitro Construction Services Corporate Safety Director will obtain a written opinion from the examining physician that contains the following:
7.5.2.1 Whether the employee has any detected medical condition that places him or her at an increased risk or health effects from exposure to lead.
7.5.2.2 Any special protective measures to be provided to the employee or limitations to be placed on the employee’s exposure to lead.
7.5.2.3 Whether the employee is medically qualified to wear a respirator and any limitations of use, especially concerning negative pressure respirators.
7.5.2.4 A statement that the employee has been informed by the physician the results of the medical examination, blood tests, urine tests, and any medical conditions that may result from lead exposure.
1.5.3 Nitro Construction Services Corporate Safety Director will provide a copy of the examination and test results and the physician’s opinion to the employee at the request of the employee.
1.5.4 Nitro Construction Services will retain medical records of examinations and tests for the employee’s length of employment plus 30 years
7.5.5 Medical Removal Protection
7.5.5.1 Workers that are removed from the lead work area due to an elevated blood lead level, medical examination, or physician opinion shall not be exposed to lead at or above the Action Level.
7.5.5.2 Workers should be moved to another position, work area, or project site that does not involve the removal or disturbance of lead at or above the Action Level. This includes painting or auxiliary activities within the lead work area resulting in exposure at or above the Action Level.
7.5.5.3 Workers that are removed from the lead work area as a result of an elevated blood lead level, medical examination, or physician opinion shall maintain and receive the same title and status to include the same wages and benefits.
8.0 Appendices:
NCS Form 034 Lead Assessment Form