Lead Exposure Control Standard Document Number: Standard – Administrative LMS0061A Revision Date: 2016/04/25 Revision: 2 Review Cycle: 3 years Applies To: Regional Wood Buffalo Document Owner (Title): Director, Oil Sands Enviro & Reg Summary of Changes Rev No. Section Changed 1 Revision Made Old document transferred to new template. Doc drafted in March 2006 2 Regionalized Definition Added Lead Exposed Worker 4.10 Removed step to complete Transfer of Materials to Hazardous Waste Yard Authorization form, added contact numbers for FH, and OSIS 5.1 Added contact information for OSIS and FH 5.2 Removed step to complete the Transfer of Materials to Hazardous Waste Yard Authorization form, changed wording regarding use of MSDS. Scope This Standard provides information on how to recognize, evaluate and eliminate/control worker exposure to airborne lead concentrations. Purpose To prevent adverse health effects to workers from exposure to hazardous levels of airborne lead at Suncor Energy Inc., Regional Wood Buffalo. Compliance This standard applies to all Suncor Energy Inc., Regional Wood Buffalo employees, contractors, vendors and visitors and is part of the EHS management system. Roles and Responsibilities The following individuals and groups have the following roles and responsibilities: Document Owner • Ensures this document is reviewed according to the required revision cycle. • Ensures the document is updated to accommodate changes to Suncor, provincial, and federal regulation. • Ensures the document is updated to mitigate risks found as the result of an incident. Document Approver • Ensures this standard is necessary and that it aligns with management and company direction. Continued on next page WARNING - Uncontrolled when printed. The current revision of this document is available in LiveLink. Approved By: Sheila Chernys, Director, Oil Sands Enviro & Reg Page 1 of 17 Subject: Lead Exposure Control Standard Number: LMS0061A Rev: 2 Roles and Responsibilities Continued Line Management • Ensures implementation and adherence to this standard. • Ensures employee competency for lead handling work such as bulk sampling of suspected lead-containing materials and lead remediation work. • Ensures all concerned parties are aware of the area entry/work conditions and requirements for use, removal and disposal of lead containing materials. • Ensures adherence of this standard at the work front and ensures all collected information is shared with Suncor Industrial Hygiene. Planning Department • Ensures adherence of this standard in the planning stages of work orders where buildings are older than the year 2000. • Ensures lead in paint is identified during walkthroughs with supervision and coordination for P2 work. • Ensure task lists include checking for painted surfaces and are accordingly updated with changes to this standard. • Ensures FLOC documentation is updated with lead sampling results for P2 work when applicable. Frontline Supervision • Ensures that lead containing material has been identified and that workers with potential for exposure have been alerted to the possible hazards, and instructed on proper procedures. • Shall make available, and review appropriate MSDS information with employees concerning additional hazards and health warnings of the products they are expected to handle, (e.g. paint removal chemicals). • Ensures contractor removal procedures meet or exceed related site standards and legislated requirements. • Ensures site standards and legislated requirements are understood and adhered to. • Ensures frontline employees with potential for exposure have been fit tested for air purifying respirators and are trained in the proper use and limitations of such respirators as per LMS0052A Respiratory Protection Standard. Frontline Employee • Responsible for using personal protective equipment, engineering controls and adhering to administrative work practices as instructed. • Must notify Frontline Supervision of unusual conditions or changes in work practices that would make initial lead hazard assessments non-representative of actual lead exposures. • Must inform the Frontline Supervision and leave the work area immediately if problems develop with the respirator or in the event of an emergency. Continued on next page WARNING - Uncontrolled when printed. The current revision of this document is available in LiveLink. Approved By: Sheila Chernys, Director, Oil Sands Enviro & Reg Page 2 of 17 Subject: Lead Exposure Control Standard Number: LMS0061A Rev: 2 Roles and Responsibilities Continued Industrial Hygiene • The Manager, Industrial Hygiene is responsible for the annual evaluation, maintenance, updating and revision of this standard. • Shall conduct task-specific lead hazard evaluations, conduct airborne lead sampling when required, and assist the Frontline Supervision in identifying at-risk job tasks. • Shall advise the Health & Wellness Centre of groups requiring medical monitoring. • Shall maintain all documents relating to lead exposure including sampling data, reports and regulatory agency and other correspondences. Health and Wellness • Responsible for the medical surveillance program including the biological monitoring of at-risk employees. • The Health and Wellness Centre shall maintain all medical surveillance records. Lead Abatement Contractor • Meets and exceeds the requirements in this standard. • Responsible for the medical surveillance and training of their own employees. • Responsible for keeping records of medical surveillance and training. • Ensures their employees are aware of hazards of lead, proper abatement procedures, personal protective equipment, and cleanup and clearance procedures. References • International Agency for Research on Cancer (IARC) Volume 87 (2006) Inorganic and Organic Lead Compounds • Work Safe Alberta Occupational Health & Safety Bulletin CH071 - Lead at Worksite Chemical Hazards November 2013 • Alberta Occupational Health and Safety - Acts, Regulation, and Code – Handbook, Current as of October 1, 2013 • Ontario Ministry of Labour, Occupational Health and Safety Branch, Guideline Lead on Construction Projects, April 2011 • WorkSafe BC, Workers' Compensation Board of British Columbia, Lead-Containing Paints and Coatings: Preventing Exposure in the Construction Industry 2011 • LMS0052A Respiratory Protection Standard • RGP0005A Control of Hazardous Energy • LMS0019A Erection, Identification, and Removal of Flagging • RGS0009A Personal Protective Equipment WARNING - Uncontrolled when printed. The current revision of this document is available in LiveLink. Approved By: Sheila Chernys, Director, Oil Sands Enviro & Reg Page 3 of 17 Subject: Lead Exposure Control Standard Terms, Definitions and Acronyms Number: LMS0061A Rev: 2 The following terms, definitions and acronyms are used in this standard: ALARA As Low As Reasonably Achievable Barriers A barrier should follow requirements outlines in LMS0019A. Blood Lead Level Test Medical test to measure the concentration of lead in patient blood. Specimen requirements are whole blood. Blood Urea Nitrogen Medical test to measures the concentration of urea nitrogen in the blood. Urea nitrogen is a breakdown product of protein metabolism. CALA Canadian Association for Laboratory Accreditation Competency In relation to a person, means adequately qualified, suitably trained and with sufficient experience to safely perform work without supervision or with only a minimal degree of supervision. Containment An isolation system designed to effectively contain lead dust and debris within a designated work area where lead-containing materials are handled, removed, encapsulated, or enclosed. Enclosure A physical barrier made of materials such as gyproc (gypsum wallboard), plywood, metal, or polyethylene (poly) sheeting used to separate lead-containing materials from the habitable environment. They isolate an area but will allow some emissions to get outside of the enclosure. Full enclosures are the safest method of isolation. A full enclosure is a tight enclosure that allows minimal or no emissions to get out of the isolated area. Exposed Worker As per Alberta OHS, Part 1 Definitions, an "exposed worker" means a worker who may reasonable be expected to work in a restricted area at least 30 work days in a 12-month period. Hematocrit The volume percentage of erythrocytes (red blood cells) in whole blood. Hemoglobin The oxygen-carrying pigment of the blood, the principal protein in the erythrocyte (red blood cell) HEPA filter (P100) High Efficiency Particulate Air Defined in the Regulation as a high-efficiency particulate air filter that is at least 99.97% efficient in collecting an aerosol particle 0.3 micrometre in size. When used for respiratory protection, HEPA filters are now referred to as NIOSH 100 series filters or “100” filters for short. Continued on next page WARNING - Uncontrolled when printed. The current revision of this document is available in LiveLink. Approved By: Sheila Chernys, Director, Oil Sands Enviro & Reg Page 4 of 17 Subject: Lead Exposure Control Standard Number: LMS0061A Rev: 2 Terms, Definitions and Acronyms Continued Lead Exposed Worker A worker who may reasonably be expected to work in a worksite where there is a reasonable chance that airborne concentration of lead exceeds or may exceed the lead occupational exposure limit at least 30 work days in a 12-month period. Local Exhaust Ventilation Local exhaust ventilation is useful for removing lead dust during dust generating operations. Use local exhaust ventilation for welding, burning and high-temperature cutting of surfaces from which lead coatings have been removed (to control fumes from residual lead), and when using power tools to remove leadcontaining coatings. Negative Air Unit A cabinet, usually portable, that contains a fan and one or more HEPA filters. Negative air units are used to exhaust air from an enclosure, reducing the risk of contaminated air escaping into the workplace through a leak in the enclosure. Negative air unit efficiency should be tested at least annually using a suitable indicator chemical, such as dioctyl phthalate (DOP) or polyalphaolefin (PAO) aerosols. Occupational Exposure Limit (OEL) The concentration for a conventional 8-hour workday and a 40-hour work week, to which it is believed nearly all workers may be repeatedly exposed, day after day, for a working lifetime without adverse effect. Peripheral Smear Morphology Medical test that provides information about the number and shape of blood cells by visual inspection. Red Cell Indices Using the results of the red blood cell (RBC) count, hematocrit, and total hemoglobin tests, red cell indices (erythrocyte indices) provide important information about the size, hemoglobin concentration, and hemoglobin weight of the red blood cell. Restricted Area As per Alberta OHS, Part 1 Definitions, a restricted area means an area of a work site where there is a reasonable chance that the airborne concentration of asbestos, silica, coal dust or lead exceeds or may exceed the occupational exposure limit for one or more of the substances. Serum Creatinine Medical test to measure the amount of creatinine in the blood. WO Work Order WARNING - Uncontrolled when printed. The current revision of this document is available in LiveLink. Approved By: Sheila Chernys, Director, Oil Sands Enviro & Reg Page 5 of 17 Subject: Lead Exposure Control Standard Standard Health Effects Number: LMS0061A Rev: 2 1. Hazard/Risk Identification Note: The recognition, evaluation and control to mitigate potential effects from lead exposure must be identified and communicated before starting activities where lead is, may be present, or handled. Handling, storage and disposal of lead waste shall be performed in compliance with applicable regulations and in a manner that minimizes any impact to the environment. Item Description 1.1 At Suncor, lead may be present in various locations particularly in paints in buildings existing before 2000. 1.2 At Suncor, lead may be found in building materials, paint in floor, columns and tanks, tile, roofing materials, plumbing materials, lead sheets, anodes, solder materials, alloys, fittings, valves, etc. 1.3 Handling of lead-containing material can be a potential health risk and thus care must be taken to prevent exposures. There are two routes of entry that are of major concern: inhalation and ingestion. Breathing in lead dust, fume or vapour may occur during processing, when metal is being cut, heated, welded or soldered as well as when lead paint coatings are disturbed. Ingesting lead may occur when eating, drinking or smoking in areas where lead contamination exists as well as during hand to mouth transfer of lead during poor hygiene practices. Harmful effects can follow after high exposure over a short period of time (acute poisoning), or long-term exposure to lower doses (chronic poisoning). High exposure over a short period of time can result in a metallic taste in mouth, gastrointestinal symptoms, such as vomiting, abdominal cramps, constipation, and diarrhea. Lead can accumulate in soft tissues (e.g. liver, kidneys, lungs, brain, spleen, muscles and heart) and ultimately bones and teeth. Small amounts of lead exposure can accumulate over time which may result in health problems. Early signs of lead poisoning include tiredness, irritability, muscle and joint pain, headaches, stomach aches, and cramps. Severe chronic poisoning symptoms include blue line on the gums, wrist drop (inability to hold the hand extended), severe abdominal pain and pallor. Occupational Exposure Limit 1.4 Lead has been classified by the International Agency for Research on Cancer (IARC) as a 2A for inorganic lead and 3 for organic lead (probably and not classifiable as carcinogenic to humans, respectively). As a result of IARC's classification of lead, Suncor Industrial Hygiene recommends lead be treated as an ALARA substance where occupational exposures are as low as reasonably achievable. The 8 hour occupational exposure limit for airborne lead 3 is 0.05mg/m (or 0.006ppm) according to Alberta Occupational Health and Safety Code, Schedule 1 Table 2. This includes elemental, inorganic, and organic compounds with the exception of lead chromate and lead arsenate. WARNING - Uncontrolled when printed. The current revision of this document is available in LiveLink. Approved By: Sheila Chernys, Director, Oil Sands Enviro & Reg Page 6 of 17 Subject: Lead Exposure Control Standard Number: LMS0061A Rev: 2 2. Recognition Note: Lead is known to be present in building material (e.g. certain paint and floors in plants and tanks with paint older than 2000). Any suspected lead-containing material to be handled or removed shall be analyzed for lead and must be treated as lead-containing material until proven otherwise. Item Description 2.1 The material safety data sheet (MSDS) for new chemical materials submitted for approval to use on site will be evaluated for the presence of lead. Lead-containing materials, with the exception of lead-acid batteries, will not be permitted to be used on site. Leaded paints have previously been a concern; therefore, several non-leaded paints have been approved for use on site to replace lead paints formerly used. 2.2 Before starting work involving lead based paint on surfaces, likely during the planning phase, project frontline managers, coordinators or supervisors must ensure that any activities known or expected to generate airborne levels of lead have the surface(s) tested for lead paint content. 2.3 Where the identification of lead-containing material is unspecified, a competent person shall collect bulk samples. Refer to Appendix A for a detailed bulk sampling procedure. 2.4 All building material (e.g. paint on tanks, walls and floors) suspected to be lead-containing must be treated as lead-containing until proven otherwise. 2.5 Records collected must be shared with Industrial Hygiene who will assist with interpretation of results. 3. Evaluation Air and Bulk Sampling Item Description 3.1 Assessment for the presence of lead in building materials or during demolition / renovation and occupational air monitoring will be conducted according to the Surface and Bulk Sampling methods and Air Sampling methods respectively, as outlined in the Lead at the Worksite bulletin CH061 published by the Government of Alberta, Employment and Immigration, November 2013. The most reliable method for the positive identification of lead in surface samples is through bulk sampling. As a result, unless approved by Industrial Hygiene, bulk sampling will be identified as the primary route of identification of lead in surfaces or materials. The material will be considered lead positive at concentrations of 1000 mg/kg (1000 ppm) or higher. A draft bulk sampling procedure has been attached in Appendix A for reference. Continued on next page WARNING - Uncontrolled when printed. The current revision of this document is available in LiveLink. Approved By: Sheila Chernys, Director, Oil Sands Enviro & Reg Page 7 of 17 Subject: Lead Exposure Control Standard Number: LMS0061A Rev: 2 Continued Item Occupational Health- Medical Monitoring and Surveillance Description 3.2 Medical monitoring on Suncor employees for lead include blood lead level testing for lead exposed workers, who could reasonably be expected to have an elevated body burden of lead. 3.3 At Suncor, lead medical monitoring is available for identified lead exposed Suncor employees. • Lead exposed employees are informed of the availabilities of blood lead test. • Any contractors working with lead material should identify their lead exposed workers and implement a medical monitoring program for their workers. 3.4 Participation in the medical surveillance program for lead is voluntary for Suncor employees. Lead remediation contractors are required to meet or exceed this standard. Details of the Medical Surveillance Program can be found in Appendix B. Workers choosing not to participate in the health assessment must provide a written statement indicating their refusal to participate. 4. Control Measures The selection of the most appropriate control option(s) will be governed by the specific task and specific work area. Elimination and Substitution Engineering Controls Administrative Controls PPE Item Substitution 4.1 Description Substitute less hazardous materials or processes (for example, replace lead-containing paints with paints that do not contain lead). Continued on next page WARNING - Uncontrolled when printed. The current revision of this document is available in LiveLink. Approved By: Sheila Chernys, Director, Oil Sands Enviro & Reg Page 8 of 17 Subject: Lead Exposure Control Standard Number: LMS0061A Rev: 2 Continued Item Description Engineering Controls 4.2 Possible controls include using engineered ventilation controls, air filtration, set up of decontamination areas, and closure of emission points that allows control of the concentration to levels below the OEL. Administrative Controls 4.3 Possible controls include work scheduling (limiting the shift time for workers exposed to lead), good housekeeping procedures, proper use of washing facilities, and setting up a blood monitoring program. Training 4.4 Employees involved in handling or removing lead-containing or suspected lead-containing materials must receive training that includes and reviews the following: • Hazard identification/evaluation • Health effects of lead exposure • Appropriate written handling procedures • Appropriate engineering controls and work practices to reduce lead exposure • Use of PPE, the proper respirator and limitations of respirators • Personal hygiene required • Purpose and application of medical surveillance. Records 4.5 The exposure control plan should be written down, and records should be kept for each component of the plan by the employer. For example, records should be maintained for when the employer reviewed the standard and exposure control plan with the employees. Other documentation maintained by the employer should include the following: • • • • Personal Protective Equipment 4.6 Workplace inspections Health and safety meetings Accident investigations Health monitoring records PPE is considered the last line of defence and should be used only when other controls are not practicable, or in addition to other controls. Proper use, fit, and disposal of PPE must also be considered. • All respiratory PPE must conform to LMS0052A Suncor Respiratory Standard. • All regular PPE must conform to RGS0009A Suncor Personal Protective Equipment Standard. Safe Work Practices 4.7 A restricted work area must be established and access must be physically restricted by using properly tagged banner-guard tape forming a perimeter approximately 3 meters around the work/removal area. The tape is to be in place before work begins and should be labelled "DANGER - DO NOT ENTER". Continued on next page WARNING - Uncontrolled when printed. The current revision of this document is available in LiveLink. Approved By: Sheila Chernys, Director, Oil Sands Enviro & Reg Page 9 of 17 Subject: Lead Exposure Control Standard Number: LMS0061A Rev: 2 Safe Work Practices Continued Item 4.8 Description Lead containing material must be removed carefully. Where feasible: • • • • Decontamination and Personal Hygiene Practices restrict air flow from local or general ventilation minimize use of power tools to reduce the risk of airborne dust wet surface before scraping especially if no paint removal chemical is being used enclose any location requiring sandblasting or mechanical grinding. 4.9 Cover all areas immediately adjacent to and below the work with 6 mil polyethylene film to ensure workers retain wet debris and dust that will be created. In the case of removal from a wall, the polyethylene drop sheet should extend horizontally on the ground for a distance equal to one half the height of the surface to be treated. 4.10 Ensure workers place any waste material into 6 mil thick plastic bags, seal with fibre duct tape, and dispose by careful removal to the Suncor Hazardous Waste Yard. For lead waste generated at Oil Sands, contact Facilities Services (780-743-6555) to arrange for appropriate transfer of the waste to the Hazardous Waste Yard. For lead waste disposal at Firebag contact the RNAS Call Center (780-588-3526) to arrange for appropriate transfer of the waste to the Hazardous Waste Yard, for Mackay River contact the RNAS Waste Coordinator (780-588-1462), and for Fort Hills contact the Waste Management Coordinator (FHWasteManagement@suncor.com). 4.11 Exposed equipment surfaces must be cleaned to ensure removal of all visible material using a damp cloth or a 2 stage HEPA vacuum. For a project of more than 1 day, lead containing debris, paint chips and dust must be cleaned up on at least a daily basis. After removal of all visible material, the final cleaning will be by successive HEPA vacuuming and wet mopping with trisodium phosphate solution or mopping and hosing down to the API sewer system. 4.12 Move the sealed 6 mil plastic bags to a prearranged staging zone within the restricted area for removal, and wipe clean with a damp cloth. The cloth should then be placed in the bag and the bag should then be sealed. 4.13 Ensure banner-guard tape is removed immediately after clean-up/removal is complete and the area is safe. 4.14 Ensure that protective clothing visibly contaminated with lead containing material is HEPA vacuumed before it is removed. Protective clothing must be removed before leaving the restricted work area. Disposable coveralls should be used for removals where exposures above 0.05 mg/m3 (OEL) have been established. They will be discarded with the waste before leaving the work area. 4.15 Remove respirators only after ensuring the respirator is free of gross contamination. Clean the respirator with soap and water, wipe dry and place in appropriate storage. 4.16 Personal hygiene is important. Wash hands and face before all breaks and at the end of the day. Showering is preferable if available and is mandatory when exposures exceed 0.05 mg/m3 (OEL). Any reusable clothing must be laundered before reuse. WARNING - Uncontrolled when printed. The current revision of this document is available in LiveLink. Approved By: Sheila Chernys, Director, Oil Sands Enviro & Reg Page 10 of 17 Subject: Lead Exposure Control Standard Number: LMS0061A Rev: 2 5. Disposal and Waste Management Item Description 5.1 Any waste containing lead (including recycling of lead acid batteries) is typically considered Hazardous Waste. For Oil Sands, disposal of hazardous waste can be coordinated through FacilitiesServices at 780-743-6555. At Firebag contact the RNAS Call Center at 780-588-3526, at MacKay River contact the RNAS Waste Coordinator (780-588-1462), and at Fort Hills contact the Waste Management Coordinator (FHWasteManagement@suncor.com). 5.2 Have an MSDS for the lead containing product ready in order to transfer the lead waste to the hazardous waste yard. End of Standard WARNING - Uncontrolled when printed. The current revision of this document is available in LiveLink. Approved By: Sheila Chernys, Director, Oil Sands Enviro & Reg Page 11 of 17 Subject: Lead Exposure Control Standard Number: LMS0061A Rev: 2 APPENDIX A – Lead Bulk Sampling Procedure of Suspected Lead Containing Paint This document provides user with the guidelines and requirements for bulk sampling of suspected lead containing products and personal protective equipment required to perform the work safely. Areas with known lead-containing paints and products have been confirmed in Plant 31. Suspected lead-containing paints may be located in older plants and facilities such as in Upgrading 1 and certain plants in Extraction. Any paint potentially containing lead need to be bulk sampled to confirm if it is more than 1000mg/kg (1000ppm) lead. 1. Pre-Sampling Specifics: a. Paint Chip Sampling: i. Paint-chip samples may be collected by any worker, who has reviewed this procedure. Ensure the required PPE and precautions highlighted in this procedure are used. ii. Paint-chip samples should contain all layers of paint (not just peeled layers) and must always include the bottom layer. iii. Paint from 4 square inches (25 square centimetres) should provide a sufficient quantity for laboratory analysis. Smaller surface areas may be used, if the laboratory indicates that a smaller sample is acceptable. iv. In all cases, the surface area sampled must be recorded. Be as accurate as possible. b. Number of samples required: If the area is a uniform layer of paint or colouring without any patches or changes in visible thickness the following samples are suggested and up to the Industrial Hygienists discretion: i. If the total surface area is <10square feet, take 1 sample. ii. If the total surface area is between 10 square feet and 100 square feet, take 3 samples. iii. If the total surface area is >100 square feet, break the area down into sections less than 100 square feet and take 3 samples per area. If the area is non-uniform in paint layer, follow the above sampling strategy for each different patch of paint encountered. c. For non-paint bulk materials, please consult your Industrial Hygienist for a path forward. 2. Records:, The following information for bulk samples must be recorded and provided to the Industrial Hygienist by persons collecting bulk samples: a. Who performed the sampling b. Date &Time c. Sample Number d. Plant # and Floor # e. Paint condition and colour f. Sample location description (and drawing if possible). Use N/W/E/S as much as possible and reference vessel/equipment numbers when possible. WARNING - Uncontrolled when printed. The current revision of this document is available in LiveLink. Approved By: Sheila Chernys, Director, Oil Sands Enviro & Reg Page 12 of 17 Subject: Lead Exposure Control Standard Number: LMS0061A Rev: 2 Appendix A – Lead Bulk Sampling Procedure of Suspected Lead Containing Paint (Cont'd) 3. Materials Needed: a. Disposable gloves (nitrile recommended). b. Water bottle spray (to be used to keep the surface wet during sampling). c. Metal scraper. d. Drop sheets to collect any wet dust from the sampling. e. Sampling bags/containers: i. 6mil thick bags are adequate: http://www.uline.ca/BL_110/Uline-6-Mil-Poly-Bags ii. Glass/plastic vials with twist caps are also acceptable: https://www.acklandsgrainger.com/AGIPortalWeb/WebSource/ProductDisplay/globalProductDetailDisp lay.do?item_code=WWG21C006 f. Sample labels or black marker to CLEARLY identify sampling information on bags/containers. g. Duct tape. h. Signage indicating: “Do not grind, weld or drill- lead sampling in progress” 4. Sampling Procedure: a. Identify the total area of sampling, flag off if large area has been designated for sampling. Follow LMS0019A requirements, yellow flagging is sufficient at a distance of 5 meters from perimeter of work area. b. Assess the number of samples to be taken, contact your Industrial Hygienist if required. c. Prepare sampling bags/containers with sample numbers, date, time and location of sample. For location of sample, be as specific as possible. d. If the paint to be sampled seems friable (i.e. will easily lead to dust generating in the immediate area), place a drop sheet to collect dust that may fall from the sampling location. e. Paint Chip sampling: i. A metal scraper can be used to remove paint chips or paint from the sampling areas in question. ii. If the sampling area seems friable, water should be sprayed over the area to prevent dust becoming airborne. iii. Paint-chip samples should contain all layers of paint (not just peeled layers) and must always include the bottom layer. iv. Paint from 4 square inches (25 square centimetres) should provide a sufficient quantity for laboratory analysis. v. 4 square inches of paint can be any shape as long as the area is as close to 4 square inches as possible. vi. Samples containers must be sealed with tape. Ensure sample numbers and descriptions are not affected by seal tape and can still be read easily. f. Post sign where sample was taken “Do not grind, weld or drill- lead sampling in progress” WARNING - Uncontrolled when printed. The current revision of this document is available in LiveLink. Approved By: Sheila Chernys, Director, Oil Sands Enviro & Reg Page 13 of 17 Subject: Lead Exposure Control Standard Number: LMS0061A Rev: 2 Appendix A – Lead Bulk Sampling Procedure of Suspected Lead Containing Paint (Cont'd) 5. Personal Protective Equipment: The following protective equipment should be worn during paint chip sampling. a. steel-toed safety boots b. half-face respirator with HEPA (high efficiency particulate air) filter i. Ensure cartridges selected reflect the hazards of the area (some areas may require additional cartridges). c. disposable nitrile gloves d. eye protection e. hard hat (as required). 6. Bulk Sampling Lab Analysis a. Bulk samples can be analysed by CALA accredited labs through Industrial Hygiene, OR b. Bulk samples can be directly sent to CALA accredited labs for analysis by business areas. If this option is chosen, follow this process: i. Contact CALA accredited lab and designate a PO ii. Fill out a chain of custody for the samples and provide a copy to IH. iii. Designate your industrial hygienist on the list of who is to receive the report, pdf or excel is adequate through email. iv. Ensure urgency/priority of analysis is appropriately checked. If emergency sampling is required, the Lab must be contacted. v. Place samples and chain of custody in a box and mail to lab location. vi. Seal the box and designate “lab samples” on the top of the box. vii. An MSDS for the product may be required if shipping through the Suncor warehouse. 7. Bulk Sampling Result Interpretation All bulk sample result interpretation must go through the Industrial Hygienist or their designate. Results will be interpreted as per LMS0061A, or Industrial Hygienist rationale. All other requirements will be detailed in the safe work plan if lead abatement is required or in LMS0061A. WARNING - Uncontrolled when printed. The current revision of this document is available in LiveLink. Approved By: Sheila Chernys, Director, Oil Sands Enviro & Reg Page 14 of 17 Subject: Lead Exposure Control Standard Number: LMS0061A Rev: 2 Appendix B - Medical Surveillance Program Participation in the medical surveillance program for lead is voluntary. Workers choosing not to participate in the health assessment must provide a written statement indicating their refusal to participate. Initial Medical Assessment Workers with the potential to be exposed to lead in the workplace will have an initial health assessment conducted, which includes: • Medical history • Physical examination • Blood lead testing Results of the initial blood lead testing will be considered the baseline level to which all future blood lead levels will be compared. Periodic Medical Assessment 3 A periodic medical assessment will be conducted on workers exposed to lead in excess of 50 µg/m for more than 30 days per year. A blood lead test will be conducted for these workers, the frequency of which will be determined by the results. The frequency of testing is outlined in Table 1 Blood Lead Levels for Workers, of this Appendix. Pregnant workers or female workers of childbearing age who are considering becoming pregnant will need to meet more stringent criteria, as outlined in Table 2: Blood Lead levels for pregnant workers and female workers of childbearing age. 1. If blood lead levels are below 1.5 micromoles per litre (μmol/L), no further action is required. 2. If blood lead levels exceed 1.5 μmol/L, additional medical testing may be conducted and includes: • Occupational history • Physical exam and blood pressure evaluation • Complete blood count with differential (CBC and Diff.) for hematocrit, hemoglobin and red cell indices. This testing is completed as lead affects the ability to make red blood cells. • Routine urinalysis, blood urea nitrogen and serum creatinine. High levels of lead can affect kidney function. • Peripheral smear morphology is only completed if the blood tests show abnormal results. 3. If blood lead levels are 2.5 μmol/lL or greater, worker must be removed from exposure and monitored until blood level return to acceptable levels, less than 2.0 μmol/L. WARNING - Uncontrolled when printed. The current revision of this document is available in LiveLink. Approved By: Sheila Chernys, Director, Oil Sands Enviro & Reg Page 15 of 17 Subject: Lead Exposure Control Standard Number: LMS0061A Rev: 2 Appendix B - Medical Surveillance Program (Cont'd) Examination Records/Health Records for each worker must be maintained by the examining physician or designate and must include: • • • • • • • • • • • • • • • • • • Full name of the worker Date of Birth Gender Social Insurance Number Occupations or job titles Date occupations or job titles commenced and ended The kinds of operations or processes in which the worker was involved Concentrations of airborne benzene to which the worker was exposed if available Use of PPE such as respiratory equipment, chemical protective clothing (e.g. gloves) Date of visits to physician’s office Medical examination reports Date(s) of the medical examination Health Assessment and Medical Examination reports Occupational history Laboratory Reports Copies of referral letters Copies of completed Worker’s Compensation forms All relevant correspondence concerning health/medical issues and any information concerning the actions taken in response to abnormal clinical tests. Records – Retention and Release • The information obtained during the health assessment is confidential to the health professionals who conducted the assessment and to the worker assessed. The worker must provide written consent for release of information, including to the family doctor. • A worker’s health records shall be kept for whichever period is longer: • Forty (40) years from the time of the initial record, or • Twenty (20) years from the time of the last record. WARNING - Uncontrolled when printed. The current revision of this document is available in LiveLink. Approved By: Sheila Chernys, Director, Oil Sands Enviro & Reg Page 16 of 17 Subject: Lead Exposure Control Standard Number: LMS0061A Rev: 2 APPENDIX B - Medical Surveillance Program Table 1: Blood Lead Levels for Workers Blood Lead Level (mol/L) Frequency of Follow-up Required Actions <1.5 Annual blood testing for exposed workers • No action required 1.5-1.99 Blood testing every 6 months for lead exposed workers • Worker must be informed • Effectiveness of controls must be evaluated • Implement controls to reduce exposure • Worker must be informed • Effectiveness of controls must be evaluated • Implement controls to reduce exposure • Worker must be informed • Worker must be removed from lead-containing area until blood lead levels are less than 2.0 mol/L • Director of Medical Services, Alberta Employment and Immigration must be notified • Source of exposure must be identified and exposure potential removed for reduced • Effectiveness of controls must be evaluated • Implement controls to reduce exposure 2.0-2.4 2.5 or greater Blood Testing every 2 months Blood testing every month Table 2: Blood lead Levels for Pregnant Workers and Female Workers of Childbearing Age Blood Lead Level (mol/L) Frequency of Follow-up Required Actions <0.5 Annual blood testing • Blood lead levels must be kept below 0.5 mol/L 0.5 or greater To be determined by the treating physician based on blood lead level • Worker to be removed from further exposure to lead WARNING - Uncontrolled when printed. The current revision of this document is available in LiveLink. Approved By: Sheila Chernys, Director, Oil Sands Enviro & Reg Page 17 of 17 The following individuals have approved and signed this document. UserName: Sheila Chernys (schernys) Title: Dir OS Enviro & Reg Date: Tuesday, 26 April 2016, 07:40 AM Mountain Time Meaning: Approver 1 Signed ================================================