This document establishes the program for controlling occupational exposures to Lead as per 29 CFR , OSHA Construction Lead Standard.

Transcription

1 PAGE: 1 OF Purpose This document establishes the program for controlling occupational exposures to Lead as per 29 CFR , OSHA Construction Lead Standard. 2. Scope This program applies to all maintenance and construction work where PPG employees or contractors use, disturb or remove Lead Containing Material (LCM). 3. Responsibility It is the responsibility of PPG management to ensure adherence to this program. It is the responsibility of the Safety/Industrial Hygiene to oversee application and evaluation of this program It is the responsibility of the designated competent person(s) to carryout the provision of this program. It is the responsibility of engineering, maintenance supervision/planning to identify tasks triggering this program. It is the responsibility of the purchasing department to ensure contractors are qualified to perform lead work It is the responsibility of the contractor to ensure adherence to this program, 29 CFR and all applicable federal, state and local regulations relating to exposure, handling and/or disposition of lead. It is the responsibility of each individual involved in lead work as defined under this program to adhere to requirements set herein. 4. Procedure 4.1. Determination of Lead Containing Material (LCM) Prior to conducting trigger tasks (see appendix A) or other tasks that could disturb LCM, it must be determined if lead is present in the material in question. If historic records or other verifiable documents exist and indicate no lead is present then a qualitative screening (swipe) test shall be conducted (see Appendix B) If qualitative test is negative: the material is free of lead. If qualitative test is positive: no need for a quantitative test, the material is LCM, it must be treated as lead. If historic records or other verifiable documents exist and indicates that lead is present: the material is LCM, it must be treated as lead If historic records or other verifiable documents do not exist a quantitative test must be performed: If quantitative test is negative: the material is free of lead. If quantitative test is positive: the material is LCM, it must be treated as lead. At any time, one can consider a material as LCM and treat it as such without testing PPG conducted lead tasks a) If LCM work is to be performed by PPG personnel: Only PPG employees that are in the Lead program can do lead work. Only the Manager, Safety and Health can approve employees to be included in the Initial Lead Medical screening and the Lead Medical Surveillance. Competent Person/Supervisor shall: Notify Industrial hygiene department in advance of task.

2 PAGE: 2 OF 10 Determine (in conjunction with industrial hygiene department) if LCM is to be disturbed or the task is a listed lead exposure trigger task (see Appendix A). Determine the proper engineering controls, work practices and personal protective equipment necessary to conduct a safe lead exposure job and meet the requirements and objectives of written program. Verify that employees performing the trigger tasks have been trained. Verify that employees performing lead trigger tasks have had appropriate medical screening. The competent person or supervisor must complete most of Part A of the lead task documentation form (Appendix D) prior to commencement of work. This will serve as a checklist in setting up the job and provide necessary information to Industrial Hygiene. Upon completion of the job, Part B must be completed and a copy forwarded to the plant industrial hygienist without delays following completion of the job. Supervise all trigger tasks identified by this program and provide frequent and regular inspections of the job sites, materials and equipment to ensure conformance to and this written program. Identify all employees performing trigger tasks by name, PPG Identification number, date of task, nature of task and supervisor to the industrial hygienist in writing. This can be accomplished by submitting a copy of the completed lead task documentation form (Appendix D of Written Program). Document and maintain results of lead field tests, sampling, paint history, historical record searches or any other method used to determine the presence of lead prior to engaging in any of the listed trigger tasks or any other disturbance of LCM. Notify the plant industrial hygienist at least 48 hours in advance of trigger task activity so that employee s exposure assessment may be conducted. Notify the plant industrial hygienist of any changes in engineering controls, work practices, equipment or processes that may cause an increase or decrease in employee exposure potential so that exposure potential may be reviewed and exposure assessments conducted if necessary. Assure that lead contaminated clothing and equipment which is to be cleaned, laundered or disposed of is in a closed container and properly labeled with the wording: 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, or federal regulations.. Industrial Hygiene The industrial hygiene group will be responsible for arranging all personnel air monitoring, and evaluation and recordkeeping of air monitoring data, including review of the completed Lead Task Documentation Form. The industrial hygiene group will be responsible for forwarding a copy of the completed Lead Task Documentation Form to the Medical Department with appropriate recommendations on medical screening or surveillance. The industrial hygiene group shall inform in writing any person who cleans or launders protective clothing or equipment of the potentially harmful effects of exposure to lead. Make recommendations for initial employee lead medical screens and employee inclusion into the lead medical surveillance program Medical Department Shall be responsible for conducting and documenting initial medical screening and medical surveillance programs in conformance with 29 CFR and PPG policies and procedures. Maintaining current lists of employees receiving the initial screen Maintaining a list of employees on the medical surveillance program for lead Maintaining an employee exposure history so as to identify potential participants in the lead medical surveillance program.

3 PAGE: 3 OF 10 b) If LCM work is performed by a contractor, Purchasing Department Shall include a copy of 29 CFR with the bid package for work involving LCM. Verify that qualified contractors (projects or maintenance contractors) are qualified for LCM work. Qualified contractor shall: understand that the work which is the subject of the contract may involve the potential for lead exposure Demonstrate, by means of program and expertise that it is knowledgeable and capable of safely engaging in such work. Agree to fully comply with the lead standard contained in the federal Occupational Safety and Health Act, 29 CFR and all applicable federal, state and local laws, ordinances and regulations relating to exposure, handling and/or disposition of lead. Contractor shall provide all necessary equipment, medical monitoring, air sampling, protective equipment, training of personnel, administrative practices and work practices necessary to ensure compliance with the above mentioned standards, policies, laws, ordinances and regulations. Contractors doing work covered by this standard s scope shall keep a copy of 29 CFR on site. Prior to beginning any work, the contractor shall provide PPG with a copy of its written compliance plan as defined in 29 CFR Contractor remains solely responsible for the adequacy, completeness, and adherence to the written compliance plan Exposure Assessments a) It will be the responsibility of the Maintenance Supervisor, Supervisor or Competent Person to: Notify the plant industrial hygienist well in advance of any tasks that disturb LCM. Request air monitoring from the Industrial Hygiene department when any trigger task (see Appendix A) or other task that disturbs LCM is conducted. The industrial hygienist in conjunction with the competent person or supervisor will determine the need for and scope of personal/area air monitoring. document the number of shifts/days each employee is performing trigger tasks and complete the form provided in Appendix D and give the form to the industrial hygiene department in a timely manner b) The responsibility of the plant industrial hygienist department includes Determine all initial and follow-up personal air monitoring activities, strategies and documentation compliant with 29 CFR (d) and PPG policies Determine proper Respiratory protection 4.4. Engineering Controls a) Engineering and work practice controls, including administrative controls, shall be used to reduce and maintain employee exposures to lead below the permissible exposure limit (PEL) of 50ug/m 3 8 hour time weighted average (TWA) or its equivalent to the extent that such controls are feasible. Wherever all feasible engineering and work practices controls that can be instituted are not sufficient to reduce employee exposure to or below the PEL, they shall be used nonetheless and shall be supplemented by the use of respiratory protection. The PPG competent person/supervisor supervising the trigger task(s) shall be responsible for the determination of feasibility and type of controls. Examples of engineering controls may include containment systems, partial enclosures, chemical strippers, local exhaust ventilation, wetting agents and vacuum systems.

4 PAGE: 4 OF 10 b) Until adequate exposure assessment data is generated, proper respiratory protection must be used any time lead trigger tasks are conducted. Monitoring data used to perform a negative exposure assessment must have been generated within the past twelve months per CFR (d)(3)(iii) Warning Signs a) Warning signs shall be posted in each work area where exposure trigger tasks are performed. The signs shall read: "Warning Lead Work Area - Poison No Smoking or Eating." Unauthorized personnel shall not enter the work area without proper authorization and protection. The work area boundaries shall be clearly demarcated with caution tape or similar warning and signs Protective Equipment and Hygiene Practices a) Respiratory protection shall be selected and provided according to the Table in Appendix C, unless objective data is available to indicate otherwise. Respirators shall be used in accordance with Work Practices where employees are exposed to lead above the PEL or its equivalent without the regard for respiratory protection: a) Showers, clean change rooms and separate storage facilities for protective work clothing and equipment and clean clothing shall be provided. Protective clothing shall not be taken home. It will be PPG's responsibility to launder/dispose of the contaminated clothing. If disposed of, contaminated clothing shall be disposed of as hazardous waste. b) Clean clothing (i.e. cotton coveralls, Tyvek suits) shall be provided at least weekly for exposures up to 200ug/m3 8 hour time weighted average (TWA) or its equivalent, and daily where employee exposures are greater than 200ug/m3 8 hour TWA or its equivalent. The industrial hygienist shall make this determination. c) Gloves, shoes, face shields, goggles and any other protective equipment provided shall be cleaned, laundered or disposed of properly. d) Showering at the end of the work shift is mandatory. e) Blowing, shaking or other means which disperse lead into the air shall not be permitted as a method to remove lead from clothing. Vacuums with high efficiency particulate air filters (HEPA Vacs) are an acceptable means to remove gross contamination. f) Any person who cleans or launders the protective clothing shall be notified in writing of lead contamination and the potential harmful effects of lead exposure. g) Disposable coveralls and separate shoe covers may be used, if appropriate, to avoid the need for laundering. h) Disposable coveralls and shoe covers must be disposed of in accordance with applicable local, state or federal regulations for lead contaminated material. i) Contaminated clothing which is to be cleaned or laundered shall be placed in closed containers in the change rooms and 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 Or Federal Regulations. j) Protective clothing shall be removed at the end of the work shift and stored separately from clean clothes. It shall be stored in a closable container and labeled properly. k) Employees shall not be permitted to smoke, eat, or drink in the work area. Any contact with food, drink, smoking, cosmetics, etc. shall only be undertaken after contaminated clothing and equipment are removed or decontaminated and the hands and face are thoroughly washed Training

5 PAGE: 5 OF 10 a) All employees who perform trigger tasks or other tasks that disturb LCM for any one day in a calendar year shall receive initial training and annually thereafter if he/she continues to work with LCM. b) PPG shall designate representatives to be trained and maintain the qualification of competent person(s) as defined by local PPG Policy, 29 CFR and any applicable local, state and/or federal requirements. A sufficient number of competent persons shall be trained to allow conformance to the requirements of this program, which includes frequent and regular inspections of job sites, materials and equipment Medical Surveillance a) Initial medical screening consistent with 29 CFR (j)(1)(i) shall be done on all employees who perform lead trigger tasks on any day in any 12 month calendar. A list of such employees, task(s) performed and other necessary information shall be furnished by the supervisor or competent person to the industrial hygienist on the lead documentation form found in Appendix D. b) A medical surveillance program will be made available to all employees who perform trigger tasks for more than 30 days in any consecutive 12 month period. An employee performing a lead exposure trigger task on any shift for 30 shifts in a 12 month period would be included. The competent person(s) or direct supervisor shall be accountable for documenting exposure days for employees and providing the names and other information to the industrial hygienist so that employees eligible for the program can be identified in a timely manner. The form found in Appendix D should be used for lead documentation. The medical surveillance program shall be consistent with the requirements of 29 CFR (j) and the PPG Medical Manual. 5. Environmental Controls 5.1. When conducting lead exposure trigger tasks or other identifiable tasks where LCM may be released, all consideration shall be given to the impact of such work on the environment, including but not limited to, the air quality, soil quality, water quality and waste handling and disposal practices. All consideration shall be given to the proper design and use of containment and ventilation systems that protect the environment without endangering the health of workers. Questions regarding environmental concerns should be addressed to the plant environmental department.

6 PAGE: 6 OF 10 APPENDIX A List of Lead Trigger Exposure Tasks This is a list of Lead Trigger Exposure Tasks for LCM Containing any amount of lead or greater that may cause lead exposure levels above the Permissible Exposure Limit (PEL). Where Lead containing paint is present: Manual Demolition (removal of walls or building components by sledge hammer or similar tools) Manual Scraping and Sanding Heat Gun Applications Power Tool Cleaning (grinders, brushes, needle guns) Spray Painting with lead based paint Lead Burning Rivet Busting (removal of rivets where lead paint is present) Cleanup of Abrasives Abrasive Blasting Abrasive Blasting Enclosure Movement Welding Cutting (heating to melting temperature) Torch Burning on Steel Structures Lead Containing Mortar Repair ( used in high pressure acid tanks) NOTE: This is not an all inclusive list, if there are questions about a task not specifically mentioned, contact the Safety Department.

7 PAGE: 7 OF 10 APPENDIX B Testing Protocols This section contains instructions on using the Lead Check Kit for lead paint dust clearance and how to collect samples for laboratory analysis. Qualitative Testing Lead Check Test Kit 1. All personnel performing lead tests with lead test kits shall be properly instructed on the use and limitations of the kit. The competent person or supervisor supervising the task shall ascertain proficiency in testing competence. 2. All personnel using the test kit shall read and follow the manufacturer's instructions enclosed with the test kit. 3. With certain paints (i.e. lead chromate s frequently used in industrial and marine applications) lead is difficult to extract and it may take longer for positive test results to develop. Examine the test surface 30 to 60 minutes after the test has been performed before assuming a test result. 4. Negative tests using the lead check test kit may be confirmed by quantitative laboratory analysis 5. All positive test kit results shall cause this written program to be implemented. Quantitative Testing - Laboratory Analysis 1. Quantitative laboratory analysis may be used to 1.1. Determine if lead containing material is present and in what amount or 1.2. verify a lead test kit and quantify amount of lead present in the material. All materials testing positive with a lead test kit shall be considered as lead materials unless a quantitative analysis is performed to demonstrate lead otherwise. Lab analysis shall be done at the discretion of the competent person(s) and all lab reports shall be maintained as permanent record. 2. It is important that representative samples be taken for analysis. The samples should represent the range of thickness found on the structure as well as the number of coats. Typically, three to six samples is sufficient to characterize structures such as tanks. Judgment must be used to determine a sufficient number of representative samples, taking into account paint history, total area, visible colors and/or markings, etc. 3. When removing samples for laboratory analysis, it is essential that the total thickness of the paint film be removed cleanly to the substrate. The removal should be controlled to assure that the sample represents all of the coating within a well defined area. Haphazard scraping with a knife is unacceptable, because the finish coat may be removed over an area covering a few square inches, while a primer is removed from only a fraction of a square inch. As a result, the sample is diluted by the excessive amount of finish coat. 4. The sample at each test location can be comprised of scrapings or shavings of paint or of complete chips. The sample size should cover the area about the size of a fingernail (1/2 inch x 1/2 inch). Cut the square through the coating to the substrate while a clear plastic bag is held or taped beneath it. Cleanly detach the entire square. Exposed substrate can be scraped with a clean knife or chisel to remove any residual paint. 5. Be careful not to include rust or scale in the sample if at all possible. This will dilute the sample or even cause a laboratory void of the sample. 6. Seal each sample in a clean plastic bag or container that will not contaminate the sample. The sample should be identified with the following information at a minimum: ID of project site or material ID, date of sample, name of individual obtaining sample, location of the sample, and a signature. The lab will assign an ID number. Sample bags or containers should be sealed, taped shut and sent to the PPG lab with a request for total lead analysis (or other elements as deemed appropriate).

8 PAGE: 8 OF 10 Appendix C Respirator Protection for Lead Aerosols Airborne Concentration 50µg/m³- 500 µg/m 3 Required Respirator: HF Mask Air Purifying w/ HEPA Filters 500 µg/m³-100,000µg/m³* FF SCBA *100,000µg/m³ is the IDLH for Lead

9 PAGE: 9 OF 10 LEAD TASK DOCUMENTATION FORM APPENDIX D Date(s): Work Order #: Supervisor: IH Notified: Y N Task Unit/Location: Part A Task Activity (Where Lead is Present) Check one: Manual - Demolition/Scraping/Sanding Heat Gun Application Power Tool Cleaning Lead Burning Rivet Busting Other: % Lead in Material: Description of Activity: Cleanup Activities Abrasive Blasting Welding Cutting Torch Burning Equipment Used: Materials Involved: Engineering Controls: Respiratory Protection: Crew Size: Site Inspection(s) Date/Time Part B Employee PPG ID# Task Date

10 PAGE: 10 OF 10 APPENDIX E Definitions Action Level - means 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/m 3 ) calculated as an 8-hour time weighted average (TWA). Competent person - means one who is capable of identifying existing and predictable lead hazards in the surroundings or working conditions and who has authorization to take prompt corrective measures to eliminate them. Permissible Exposure Limit - The employer shall assure that no employee is exposed to lead at concentrations greater than fifty micrograms per cubic meter of air (50 g/m 3 ) averaged over an 8- hour period. Exposure assessment - Each employer who has a workplace or operation covered by this standard shall initially determine if any employee may be exposed to lead at or above the action level. Trigger tasks - A specific task or job that may cause an employee to be exposed to levels of lead above the Permissible Exposure Limit. Lead - means metallic lead, all inorganic lead compounds, and organic lead soaps. Excluded from this definition are all other organic lead compounds.