Lead Management Presented by: Gary Chinn (815) 254 9554 President, Best Technology Systems
Gary Chinn, President Introduction I started in the Asbestos and lead remediation business in 1987 as a worker in the field. I have worked in every aspect of the Asbestos/Lead business from worker to supervisor to director of operations and now owner of Best Technology Systems (BTS). BTS started working in shooting ranges in 1999 and I have personally created all of our policies and procedures to protect my employee s working in lead contaminated shooting ranges.
OSHA 1910.1025 This regulation protects employees that work in a lead contaminated work environment such as a shooting range. This regulation governs LEAD in the general industry. "Lead" (Pb) means metallic lead. If entered into the body can cause poisoning, which could affect the blood, brain, nervous and digestive systems. Lead can only enter your body through ingestion or inhalation. Air sampling is the key to this regulation. Anyone working around lead dust must be monitored for exposure levels. Background
Action Level Background "Action level" means employee exposure, without regard to the use of respirators, to an airborne concentration of lead of 30 (ug) micrograms per cubic meter of air averaged over an 8 hour time weighted average (TWA). = 1 Gram = 1,000,000 Micrograms
Permissible Exposure Limit (PEL) Background PEL" means employee exposure, without regard to the use of respirators, to an airborne concentration of lead of 50 (ug) micrograms per cubic meter of air averaged over an 8 hour time weighted average (TWA).
Initial Determination Determination Initial determination. Each employer who owns a range or work operation covered by this standard needs to make a determination if any employee may be exposed to lead at or above the action level prior to any air monitoring. This initial determination will need to be broken down into two categories after calculating the exposure levels of the employees: 1. Negative initial determination (less than 30 ug.) in an 8 hr. TWA. 2. Positive initial determination (exposure to lead dust above 30 ug.) in an 8 hr. TWA a) 30 ug. 49 ug. In an 8 hr. TWA b) 50 ug. And above in an 8 hr. TWA
Negative Initial Determination Determination Negative initial determination and initial air monitoring. When an employee s exposure is below the action level, the employer shall make a written record of such determination. The record shall include at least the date of determination, location within the worksite, and the name and social security/employee number of each employee monitored. Air monitoring will not be needed again unless policies, procedures or personnel change.
Positive Initial Determination Between 30 50 ug Positive initial determination and initial air monitoring. When an employee exposure is at or above the action level, the employer shall conduct air monitoring for each employee in the workplace who is exposed to lead dust. If the employees exposure results are between 30 ug. and 50 ug., the record shall include at least the date of determination, location within the worksite, and the name and social security number/employee number of each employee and type of work conducted. Employees with air monitoring between 30 ug and 50 ug will need air monitoring conducted on them every 6 months unless policies, procedures or personnel change. Employees cannot be exposed to lead levels above the action level for more than 30 days per year. Determination
Positive Initial Determination 50 ug and above Determination If the employees exposure results are 50 ug and above, the record shall include at least the date of determination, location within the worksite, and the name and social security/employee number number of each employee and type of work conducted. Employees with air monitoring 50 ug and above will need air monitoring conducted on them every 3 months unless policies, procedures or personnel change. Entire regulation 1910.1025 is now in full effect.
Employee Notification Lead Exposure Within 5 working days after the receipt of monitoring results from the certified lab, the employer shall make the 8 hr. TWA calculation and notify each employee in writing of the results which represent that employee's exposure (negative or positive determination). Whenever the results indicate that the representative employee exposure, without regard to respirators, exceeds the permissible exposure limit, the employer shall include in the written notice a statement that the permissible exposure limit was exceeded and a description of the corrective action taken or to be taken to reduce exposure to or below the permissible exposure limit.
NEGATIVE INITIAL DETERMINATION (0ug 30ug) No more air sampling unless personnel or policies change. POSITIVE INITIAL DETERMINATION (30ug 50ug) Tyvek Suit, ½ Face respirator and fit test, booties, D Wipes, Physical with pulmonary function test, Air sampling (twice per year) POSITIVE INITIAL DETERMINATION (50ug & above) Full 1910.1025 Regulations are now in effect
OSHA Compliance for work areas greater than 50ug in an 8 hr. TWA
Engineering and Work Practice Controls Lead Exposure 1) 1) Ventilation System Must on while you are doing any range maintenance (including negative and positive initial determinations). 2) Employee Rotation
Respiratory Program Lead Exposure The employer must implement a respiratory protection program and provide respirators for employees. 1. ½ Face Respirator 2. PAPR Powered Air Purifying Respirator 3. Fit testing of respirators 4. Clean shaven 5. Clean respirator 2x per day
Protective Work Clothing and Equipment Equipment Employers will need to supply the following: Respirators Coveralls or similar full body disposable work clothing with hood and booties, gloves, and safety glasses.
Housekeeping Housekeeping Surfaces. All surfaces shall be maintained as free as practicable of accumulations of lead dust. Floors and other surfaces where lead accumulates may not be cleaned by the use of compressed air. Shoveling, dry or wet sweeping, and brushing may be used only where vacuuming or other equally effective methods have been tried and found not to be effective. HEPA vacuums must be used at all times to clean range floors (no brooms).
Hygiene Facilities and Practices Hygiene Wash hands (D Wipes and GoJo) to remove gross debris Showers mandatory when the lead levels exceed 50ug of lead. No eating food in contaminated areas. No smoking in contaminated areas.
Medical Surveillance Medical Medical surveillance can be broken down into two categories. 1. Physical/Pulmonary function (1 time per year). 2. Biological monitoring Blood leads/zpp (2 times per year) a) Under 40ug/dl two times per year b) Over 40 ug/dl every 2 months c) Three consecutive readings averaging 50ug or 60ug immediate removal from lead exposure.
Training Program Training Each employer who has a workplace in which there is a potential exposure to airborne lead at any level shall inform employees of the content of Appendices A and B of this regulation. The employer shall institute a training program for and assure the participation of all employees who are subject to exposure to lead at or above the action level or for whom the possibility of skin or eye irritation exists. The training program shall be repeated at least annually for each employee. All Employee records must be kept for a minimum of 40 years.
Range Maintenance Best Work Practices
Safety Regulate the work area with lead hazard signs on all range doors
Two Stage Decon/Shower Safety Change out of street clothes into disposable PPE Clean/inspect inspection Put on respirator Personal pump Back belt Begin work Towels
Hands Equipment Hair Lead Surfactant What techs use in the shower
Showering Options Training Set up wash station to remove lead contamination from hands and face (D Wipes, GoJo, Disposable towels). Remove respirator and disposable protective clothing Proceed to a building shower. Change back into street clothes.
Full Face PAPR Carbonic Filter PAPR Cord Gloves Back Belt P.P.E. TYVEK Suit Equipment
Equipment PAPR Battery Lead dust on cord Power Air Purifying Respirator Battery
Two Stage Decon/Shower Equipment Remove disposable clothing Shower Clean respirator Don street clothes All lead is left in the range. EXIT LCHW
This is Hazardous Waste! Ventilation LCHW must be manifested properly with the owner s EPA number!
Liability Exposure for Range Owners and Contractors Legal Issues Lack of proper Range Maintenance is a liability issue for the range owner. Neglecting manufacturers specifications with lack of proper bullet trap inspections can be a liability as well. Bullet traps need to be checked for gaps or missing hardware that would allow bullets or lead dust to exit the bullet traps. Neglecting ventilation filters and getting positive pressure in the range. This can overexpose the shooters and contaminate adjacent areas. Non compliant maintenance program in regard to 1910.1025 Neglecting employees cleaning the range can lead to elevated blood levels.
Liability Exposure for Range Owners and Contractors (cont.) Legal Issues Any company working in a lead contaminated range has to follow the law or that agency is at risk of a lawsuit and fines. Range operators own their hazardous waste from cradle to grave. This is why they need EPA numbers. They are responsible for it at all stages of handling and disposal. They need to hire companies/people that know the law and are documenting their process, results and manifesting the LCHW. Improper disposal of LCHW would draw large fines from the EPA. The largest fine would involve creating a hazardous waste landfill without a permit.
OSHA Violations/Fines Shooting range cleanup company fined more than $2 million for overexposing workers to lead. OSHA fined E.N. Range in Miami, Fla., $2,135,000 after the employer failed to protect workers who clean gun ranges from serious overexposure to lead. OSHA inspectors found that E.N. Range had not provided workers proper protective equipment, changing rooms or showering facilities. Air samples taken by OSHA inspectors found that these workers were exposed to lead levels as high as 10 to 19 times the permissible exposure limit. The company also provided workers with non FDA approved treatments for lead exposure without required medical supervision, misleading employees most of whom had limited knowledge of English into believing they were receiving appropriate medical treatment. OSHA issued E.N. Range more than 50 citations for disregarding workers' health and safety, including 28 citations for multiple egregious violations that include failing to provide workers with properly fitted respirators and control measures to limit workers' exposure to lead, and failing to ensure that workers were given required medical evaluations or blood lead level tests. See the news release for more information. Gun range in Lauderdale Lakes, Fla., cited by US Department of Labor s OSHA for health violations with $62,000 in penalties US Labor Department s OSHA fines Point Pleasant, W.Va., manufacturer nearly $70,000 for worker exposure to noise, other workplace hazards. Legal Issues
How involved do you want to be in range maintenance? Conclusion Range Maintenance In House 40% BTS Service 60%