eLCOSH : Guides for Managing Lead Control Programs in Construction

Guides for Managing Lead Control Programs in Construction

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Nancy Clark, Mark Goldberg, Katya Wanzer, Norman Zuckerman

Mount Sinai School of Medicine, Hunter College - Urban Public Health Program

Overview
Project Timetable

Section 1: Planning

Who is Responsible for Planning
What Plans Need to be Made
When to Plan
Lead Controls Selection Chart

Section 2: Writing a Site Specific Compliance Program
Section 3: Implementing

Managing the Control Plan
Making the Control Plan Work

Section 4: Evaluating
Section 5: Infosheets for Commonly Used Controls
Section 6: Checklists

Overview

Why institute an engineering and work practice control program?

Worker exposure can be reduced or eliminated by:
- engineering controls, such as a process change (e.g. mechanical dismantling of steel structures instead of torch cutting or using tools fitted with a vacuum attachment).
- work practice controls (e.g. removing paint before using an oxyacetylene torch).
- a combination of engineering and work practice controls.
The OSHA Lead in Construction Standard requires that:
- contractors use engineering and work practice controls to reduce exposure to the lowest practical level.
- all lead disturbing tasks and selected controls are documented in a written compliance program.
Owners may require a lead control program be included in project submittal documents.

Overview of the Tasks

1. Planning

2. Writing a site specific program
3. Implementing

4. Evaluating

a) Assess effectiveness of controls — This Guide will elaborate on these tasks —

Engineering and Work Practice Control Project Timetable

Owner issues bid documents with specifications for worker protection from lead.

Bid awarded; contract includes provisions for lead control plan. Contractor develops initial compliance program.

Project starts. Interim controls in place; contractor develops site-specific lead health & safety program; engineering and work practice controls in place.

Owner and contractor Lead Program Manager (LPM) review blood lead and air monitoring results. Lead Competent Person makes frequent and regular site inspections.

Contractor assesses effectiveness of controls and tries other strategies if necessary. Updates compliance program.

Project complete. LPM reviews effectiveness of controls. Owner modifies specifications for future projects, if necessary.

Planning

Planning the engineering and work practice control program is part and parcel of project planning. A timeline for the planning stage looks something like this:

Owner issues bid documents with specifications for worker protection from lead.

Bid awarded; contract includes provisions for lead control plan. Contractor develops initial OSHA compliance program.

Who is responsible for planning

Can be any of the following:
- Project planners
- Managers
- Company health and safety officer
- Lead Program Manager (LPM)
- Lead Competent Person
- Union superintendent

What plans need to be made

Assign a LPM/competent person to organize and run the program (usually assigned by central office or project manager)
Identify lead disturbing tasks
Select one or several control options for each task. See the Lead Control Selection Chart below
- On most rehabilitation projects a combination of controls may be necessary. For instance, abrasive blasting might be used for paint removal in areas where mechanical removal is not effective.
- When selecting controls consider site-specific factors and schedules. For instance: chemical strippers must be left to work for a specified amount of time before they are removed; some chemical strippers may not be effective in cold weather.
Prepare a Compliance Program.

When to plan

Selection of lead controls should be included in project design phase
OSHA requires that the compliance program be in place before lead disturbing activities begin

Lead Controls Selection Chart

Task	Control Options
Torch Cutting	Remove paint before torch cutting Substitute mechanical dissembling when feasible Use hydraulic/pneumatic shears or chop saw when applicable Distancing
Rivet Busting	Remove paint before rivet busting Encapsulate paint Clean surfaces and surrounding areas with HEPA vacuums
Surface Preparation	Remove paint Use vacuum shrouded tools Clean surfaces and surrounding areas with HEPA vacuums
Installation Activities	Clean surfaces and surrounding areas with HEPA vacuum Remove paint before using pneumatic tools which may spread the dust Use vacuum shrouded tools

Section 1 Notes

Instituting an engineering and work practice control program goes to the heart of how the work is done. Such a program must be integrated into day-to-day operations. For instance, if paint is to be removed from beams before they are torch cut, paint removal must be scheduled before torch cutting and be reflected in the project timeline.
The OSHA Lead Standard requires that a "competent person" make frequent and regular inspections of job sites, materials, and equipment. It makes sense that the LPM is the competent person.
OSHA defines a lead competent person as an individual that can identify lead hazards in the work place and has the authority to take corrective action.

Writing a Site Specific Compliance Program

The compliance program describes the engineering and work practice controls used at the site and includes records of compliance activities. The written program should include:

Introduction: Project description, scope and schedule of work, location.
Personnel: Project Manager, Lead Program Manager and/or Lead Competent Person, industrial hygienist.
Lead-emitting activities: Describe tasks, equipment, materials used, work crew.
Engineering and work practice controls: Describe type of control, equipment, use and maintenance procedures. Include rationale for selecting each control and alternative technologies considered.
Personal air monitoring results: Provide industrial hygiene reports and air sampling results for lead disturbing activities. Refer to the Guide for Managing Exposure Assessment
Schedule: Provide timetable for implementing compliance program.
Interim controls: Describe respiratory protection and other controls that will be used for each task. Refer to the Guide for Managing Respiratory Protection
Hygiene procedures: Describe protective clothing and equipment, housekeeping, clean areas, showers, and hand washing stations.
Worker rotation schedule: (if applicable).
Notification procedures: Informing other employers on site regarding potential exposure risks.

Attach the following programs and records:

Respirator Program: Provide written program and identify program administrator, include respirator selected for each task, records for training, fit testing, and medical clearance.
Training & Information: Training schedule, topics and records.
Medical Surveillance Program: Include blood lead monitoring schedule and results.
Medical Removal Procedures: Include lead-free work assignments, medical evaluations and return to work criteria.

Section 2 Notes

Information on controls is available from a variety of sources - see the Resources List
The written Compliance Program must be revised and updated periodically to reflect the current status of the program

Implementing

Managing the Control Plan

Each of the activities listed below requires periodic inspection of controls and site tours by the LPM. A timeline for control implementation looks something like this:

Project starts. Interim controls in place; contractor develops site-specific lead health & safety program; engineering and work practice controls in place.

Owner and contractor LPM review blood lead and air monitoring results. Lead competent person makes frequent and periodic site inspections.

Making the control plan work:

Check that control equipment and supplies are on site before lead disturbing tasks begin.
Train workers and supervisors on how to use control equipment.
Check that tasks such as paint removal have been performed on schedule and properly.
Inspect site frequently to ensure that controls are:
- present at the location where the tasks will be conducted on any given day
- in operating order
- being used when they should be
- being used properly (provide for additional training if necessary)
- effective (that is controlling dust emissions)

Section 5 contains brief descriptions of commonly used controls for steel-structure rehabilitation.

Section 6 contains Checklists that can be used by the LPM or Lead Competent Person when conducting daily inspections of the site, as required by OSHA.

Section 3 Notes

Selecting a control is the first step in protecting workers from lead - making it work is the second. A control program must be closely managed to be effective. For each control selected, the LPM should consider exposure factors, work procedures and should evaluate the effectiveness of the control. Weekly toolbox talks are a good time to review the use of new tools or controls.
Caution: Lead disturbing activities in an enclosed or confined space may greatly increase exposure.

Evaluating

Evaluating the control program is an ongoing activity as shown in the time line below.

Contractor assesses effectiveness of controls and tries other strategies if necessary. Updates compliance program.program.

Project complete. LPM reviews effectiveness of controls. Owner modifies specifications for future projects, if necessary.

There are 3 ways to evaluate whether the control program is working:

Site inspections of the controls – use Checklists in Section 6
Monitoring worker exposure to airborne lead dust or fume while a control is being used (see Guide for Managing Exposure Assessment).
Blood lead monitoring (see Guide for Managing Blood Lead Monitoring).

If the evaluation indicates a potential problem with a control check these possibilities:

Control is not appropriate for the job. Seek an alternate control.
Control is not functioning properly.
Workers are not using control properly.

Section 4 Notes

Upon completion of the project, it is advisable to prepare a final effectiveness report for future projects.

Infosheets Commonly Used Controls

Distancing

Distancing is a work practice control where the worker "distances" the point of lead emissions from his/her breathing zone: for example an ironworker standing upwind during torch cutting. Distancing is also achieved by using a long demolition torch (up to 6' in length) that positions the worker's breathing zone further away from the cut.

Work procedures:

Maintain body position upwind.
Use demolition (long) torch whenever possible.
Monitor this control very carefully and be sure that appropriate air-supplied respirators are used.

Potential Problems	Possible Solutions
Change in wind direction or work position may change exposure	Don adequate respiratory protection
May expose workers downwind of torch cutting	All workers in vicinity must use adequate respiratory protection Burners and those working in vicinity should be monitored for exposure

Alternative Demolition Options for Structural Steel Projects

Mechanical removal of steel is an alternative to torch cutting. Steel members are disassembled by reversing installation procedures - removing rivets and bolts first and then uninstalling steel beams. Also, chop saws, hydraulic shears, or metal cutters can be used.

Work procedures:

Remove or encapsulate paint in areas where steel will be cut or unbolted.
When cutting, stay in the center of cut lines that have been stripped or encapsulated with protective tape.
Saw cutting operations work best on flat surfaces with good access. Train personnel in proper operating and safety practices.

Potential Problems	Possible Solutions
Disassembly slower than torch cutting	Schedule should reflect time required for safe demolition activities
Chop saw, shears not effective on thicker metal	Chop saws good only for thinner gauge metal. For thicker metal, use hydraulic shears or torches if necessary
Ergonomic issues, e.g. work position with saw	Conduct toolbox talks to review proper use Avoid using tool in awkward positions
Safety issues: chop saw	Machine guarding, never use with guard blocked in open position. Use proper PPE (e.g. eye protection) Use only as per manufacturers instructions Ensure all workers are trained in proper use; provide periodic review during toolbox talks.

Paint Removal: Chemical Stripping

Stripper is applied to steel surface and left in place for 1-24 hours. Paint and stripper are scraped off and residues are wiped away. Some strippers require neutralization.

Work procedures:

Layout cut lines and areas to be treated at least 4" on all sides of the cut. Wider strips are even better.
Coordinate location and stripping of cut lines with demolition cut requirements.
Cut lines should match front and back side of steel.
Inspect work prior to demolition activities to ensure that cut lines are prepared
Train personnel in proper operating and safety practices

Potential Problems	Possible Solutions
Worker exposure to caustic chemicals	Train workers Use proper PPE Review MSDS before using Contact manufacturer if there are any questions (manufacturers contact information included in MSDS)
Scheduling	Initial schedule should reflect time required for safe application and removal May not be applicable in all circumstances e.g. weather, manpower

Paint Removal: Power Tools

Lead paint is removed with power tools equipped with dust collectors prior to other lead-emitting activities. Small lead particles are collected by a HEPA vacuum system as they are released by the tools.

Work procedures:

Layout cut lines and areas to be treated at least 4" on all sides of the cut. Wider strips are even better.
Select appropriate tool based on type of surface to be treated.
Follow manufacturer's instructions for the tools.
Keep tool shroud flush with the surface for effective results.
Coordinate paint removal with demolition cut locations and other requirements of ironwork.
Inspect work prior to demolition activities to ensure that paint is removed as specified.

Potential Problems	Possible Solutions
Workers may be exposed to elevated lead levels if HEPA tools not operated properly	Train workers Consult manufacturer or vendor for information and/or help with worker training classes
Incomplete removal of painted surfaces. Difficulty cleaning irregular surfaces	Consult manufacturer or vendor for information e.g. special attachments for corners and/or help with worker training classes Equipment must be maintained properly e.g. replace worn parts, seals, needles in needle gun etc May need to consider alternative paint removal technique. Additional training in using control; toolbox talk

Encapsulation

Rivet heads and steel members are treated with an elastomeric coating (plastic dip) prior to rivet busting. Duct tape has been used as an encapsulant for sawcutting. In either case, the coating or tape holds the paint together and reduces dust generation at point of impact.

Work procedures:

Coordinate encapsulation with demolition activities.
Application of encapsulant may be weather dependent.

Potential Problems	Possible Solutions
Encapsulation is not a control for torch cutting or welding. Heat from sawing or torch cutting may ignite encapsulant causing fire and/or release of toxic vapors	Use different controls for different operations
May become brittle and break into small respirable dust particles	Use different encapsulant Adopt alternate control technology

HEPA Vacuum

HEPA vacuum is used for:

Keeping work areas clear of debris and dust that can become airborne during work activities.

Potential Problems	Possible Solutions
Vacuum line clogs up and/or vacuuming ineffective	Use vacuum for smaller size debris and paint chips only, a shovel should be used for larger pieces that may clog the vacuum Maintain adequate vacuum capacity Operate vacuum according to manufacturer instructions, make sure HEPA vacuum capacity adequate for the intended operation Use prefilters to extend the service life of HEPA filters
Ergonomic problems, e.g. bending, squatting	Use wide mouthed and rigid pole attachments to reduce stooping and bending
Potential exposure hazard during vacuum bag disposal	Train personnel in proper operating and safety practices

Checklists

Suggestion on using checklists: since these lists are short, they can be made smaller and placed or pasted into small field notebooks. For instance, Checklist 1 could be miniaturized - see example at end of checklists. They can also be programmed onto a PDA (Personal Digital Assistant).

CHECKLIST 1. SITE INSPECTION (for all controls)

Controls are:	Y/N	Problem noted (describe)	Problem fixed (describe)
Available at work location
In operating order
Used when they should be
Used properly (workers trained in their use)
Effective in controlling dust emissions
Location and cleaning of cut lines coordinated with demolition requirements

CHECKLIST 2. CLEANING UP DEBRIS WITH HEPA VACUUM

	Y/N	Problem noted (describe)	Problem fixed (describe)
Vacuum is operated as per manufacturer's instructions
Large pieces of debris have been picked up with shovel prior to use of vacuum (so that vacuum doesn't get clogged).
Adequate vacuum capacity maintained
Prefilters in place
Wide mouthed attachments and rigid wands in use. Workers able to operate vacuum without stooping over
Collection bags in place, bags disposed of properly

CHECKLIST 3. Paint Removal Chemical Stripper/Shrouded Tool

	Y/N	Problem noted (describe)	Problem fixed (describe)
(For chemical stripping) workers applying and removing stripper use appropriate PPE
(For vacuum shrouded tools) shroud maintained close to surface
Shroud effective in controlling visible dust emissions
Area cleaned at least 4" on either side of the cut line
Cut lines matching front and back side of steel
After cleaning is lead paint visible on surface, how much?

MINIATURIZED CHECKLIST 1. SITE INSPECTION (for all controls)

Controls are:	Y/N	Problem noted (describe)	Problem fixed (describe)
Available at work location
In operating order
Used when they should be
Used properly (workers trained in their use)
Effective in controlling dust emissions
Location and cleaning of cut lines coordinated with demolition requirements

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