Lead for Project Managers
Presented by Aurora Industrial Hygiene, Inc.
www.auroraih.com, info@auroraih.com
Overview
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Background
Health Effects
Definitions
Regulations
Procedures
Important Numbers
Useful Links
What is Lead
• Lead is an elemental
metal
• Forms 0.06% of the
earth’s crust
• Cannot be destroyed,
only smaller
• Should not be in our
bodies
Why was Lead Used
• Prevents Corrosion
• Kills mold and mildew
• Malleable
• Strong
• Blocks Radiation
• Blocks Sound
• Drying Agent
Problems
• It’s a chronic and
acute poison
• Contamination
Where is Lead Found?
• Quality Paint
Military uses
Bridges and
Steel Structures
Residences
Interior
Exterior
Banned in 1978
Schools in 1984
Lead is Found in Gasoline
• Used over a period of
50 years
• 93% reduction from
1978-1987
Lead Is Found In….
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Industrial Releases
Soil
Food
Drinking Water
Occupational Exposure
Heart and Blood System
•High blood
pressure
•Increased risk
of heart attack
and stroke
•Anemia
Caroti dartery
Innominateartery
Subcl avianartery
Hear t
Lung
Aorta
Pulmonaryartery
Alveolarcapill aries
Left atri um
Ri ght atri um
Left ventri cle
Right ventri cle
Brachial artery
Liver
Kidney
Hepati cartery
Renal artery
Large intestines
Capill ari es of
gastrointestinal tract
Small intestines
Iliacartery
Femoral artery
Ti bial artery
A RTE RIAL SYS TEM
Kidneys
• Filter the blood
• Not detectable
• Kidney failure
Central Nervous System
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Most affected
Permanent
Brain damage
Damage to
nerves
Bone Tissue
Cr a ni um
Ce r vic a l ve r t e br a e
M andi ble
Cla vi c le
Sc a pula
T hor a c i c ve r t e br a e
H umer us
R ib
Lumba r ve r t e br a e
P e l vis
Sa c r um
Ulna
Cocc yx
Ra dius
Ca r pa ls
Me ta c a r pa ls
P ha l a nge s
Fe mur
Fi bula
T i bia
T a lus
Ca l c a ne us
SKELETON, POSTERIOR VIEW
T a r s al s ,met a ta r s a ls &pha l a nge s
• Body Burden
• Released when the
body is under stress
• Pregnancy
• Menopause
• Serious Illness
Reproductive Systems
• Male System
– Impotency
– Lack of drive
– Damage to sperm
– Infertility
• Female System
– Infertility
– Birth defects
– Miscarriage
– Pregnancy
Children
• Proportion to body
weight and size
• Developmental effects
• More hand-to mouth
contact
• More absorption of
lead
Lead Bans/Phase-Out
• Late 20th Century
• Residential paint (1978)
• Solder and pipes for drinking water
• Solder in food cans
• Gasoline
Huge improvements in air quality in last 50 years but
DETERIORATING LEAD-BASED PAINT
still a major source of lead pollution today
Definitions
• Lead-based paint:
– New paint: greater than 0.06% (600 ppm) lead content.
– Existing paint: greater than 0.5% (5000 ppm) or 1 mg/cm2 lead
content.
– Some counties: 0.7 mg/cm2 lead content.
– City of SD: Lead-Safe Work Practices (LSWP) required at 0.1%
(1000 ppm) or 0.5 mg/cm2.
• Lead-containing paint: paint with any detectable lead.
• Presumed lead-based paint.
– State: Constructed prior to January 1, 1978.
– San Diego: Constructed prior to January 1, 1979 and ALL steel
structures, regardless of construction date.
• Lead hazards: deteriorating LBP or PLBP, contaminated dust,
contaminated soil, disturbance of LBP or PLBP w/o containment.
Applicable Regulations (a few)
• Title X, Lead-Based Paint Poisoning Prevention Act of
1992.
• HUD Guidelines for the Evaluation and Control of LeadBased Paint Hazards in Housing
• California-OSHA Lead in Construction
• California Title 17, Accreditation, Certification, Work
Practices for Lead-Based Paint and Lead Hazards
• CA SB 460
• San Diego Municipal Code, Lead Hazard Prevention and
Control Ordinance
• EPA Lead Renovation Repair and Painting Program
Regulations
Title X, Lead-Based Paint Poisoning Prevention Act of 1992.
• The regulation which started it all.
• Evaluation hazards
– Risk Assessment
– Inspection
• Reduce hazards
– Interim controls
– Remediation
Regulations
HUD Guidelines for Evaluation and Control of Lead-Based
Paint Hazards in Housing
• Step-by-step “how-to” manual
• Inspection, risk assessment, monitoring, worker protection,
waste management, interim controls, abatement, clearance,
maintenance
• Written as guidance document for housing
• Made mandatory for public and residential buildings by
California Title 17
Regulations
California OSHA Lead in Construction – 8 CCR 1532.1
• Applies to all lead exposure in construction, regardless of
type of building or lead content in paint
• Construction includes demolition, renovation, clean-up
• UCSD puts compliance responsibility onto contractors:
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Airborne exposure limits
Exposure assessment
Written compliance program
Respiratory protection and PPE
Medical surveillance
Recordkeeping
Regulations
California OSHA Lead in Construction – 8 CCR 1532.1
• Important for Protecting Workers AND Surrounding
Areas:
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Housekeeping: wet cleaning, HEPA vacuums, prompt clean-up
Hygiene facilities, change areas, showers
Regulated areas
Posting
Certified workers if abatement of public or residential OR
exposure over PEL
Regulations
Accreditation, Certification, and Work Practices for LeadBased Paint and Lead Hazards. Title 17 CCR 35001 36100
• Applies to all public and residential buildings
• Certification of training and training providers, workers,
supervisors, inspectors, project monitors
• Defines LPB, PLBP, lead hazards, lead-safe work practices
• Defines inspection, risk assessment, clearance
• Makes HUD Guidelines regulatory
Regulations
Lead Hazard Prevention and Control Ordinance, San Diego
Municipal Code, Division 10, 54.1001-54.1015 (2008)
• Applies to properties, premises, dwelling units, structures,
and steel structures
• Re-states many requirements of Title 17
• LEAD HAZARDS are dangerous to life and health and
owner must prevent or correct
• Requires LSWP at lower lead content than LBP
• Defines presumed LBP one year earlier than Title 17
• San Diego City enforcement team – drive-by citations
Regulations
EPA Lead Renovation Repair and Painting Program, (2008, effective
2010)
• Applies to residential houses, apartments, child-occupied facilities.
• Renovation = ANY activity that disturbs paint.
• Renovation firms must be EPA-certified
• Workers must be trained in LSWP
• Pre-renovation education required (pamphlet, signs)
• LSWP mandatory
• Recordkeeping
CAUTION: STATE-CERTIFIED LEAD WORKERS vs
CERTIFIED RENOVATION FIRMS
Procedures - Variables
• Requirements vary based on:
– Building age
– Building function (public, commercial,
residential, industrial)
– Lead content in paint
– Scope of construction/renovation
– State, County, City
Procedures - General
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Characterize
Handling/Management
Clearance
Disposal
Procedures – Characterize
• Pre-1979 buildings must be inspected prior to
renovation
• Inspection must be by certified inspectors
• Inspection must follow HUD Guidelines
procedures
• Laboratories must be accredited
• CDPH 8552 must be submitted to State and City
*Some exceptions if buildings not accessible to
public.
Procedures –
Handling/Management
• OSHA applies for any lead content
• LSWP required if over criteria
• Loose/flaky paint returned to intact state
(abatement)
• Renovation/demolition in a manner that adhered
paint must remain adhered
• Worksite preparation, containment, and clearance
vary based on use of building and lead content
Procedures - LSWP
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Notice to occupants
Regulated area
Temporary relocation
Containment (App. A, HUD Guidelines)
Specialized cleaning (HEPA-wet-HEPA)
Daily clean-up
Proper waste disposal
Clearance (visual or test dep. on building and lead content)
Prohibited: burning or torching; heat guns >1100F;
scraping, sanding, grinding, or blasting without
containment
Procedures – Interim Controls
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Abatement designed for less than 20 years
Trained workers
Containment
Notification
Follow HUD Guidelines Chapter 11
Clearance inspection depending on
conditions
Procedures - Abatement
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Abatement for 20 years or longer
Certified supervisors and workers
Abatement plan
Notification to CDPH and OSHA
HUD Guidelines, Chapter 12
Containment
Clearance inspection
Procedures - Clearance
• Certified Inspector/Risk Assessor or Project
Monitor
• Visual
• Dust
• Soil
• CDPH 8552 to City and State
Procedures - Disposal
• Segregate and test each waste stream
• Firmly adhered paint can be tested as a composite
in construction debris
• TTLC. Total Threshold Limit Concentration.
• STLC. Soluble Threshold Limit Concentration.
(also WET)
• TCLP. Toxicity Characteristic Leachate
Procedure.
Important Numbers
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Presumed LBP: Pre-1979
LBP – New Paint – 0.06%, 600 ppm
LBP – Existing Paint – 0.5%, 5000 ppm, 1 mg/cm2
LSWP Required – 0.1%, 1000 ppm, 0.5 mg/cm2
Lead in Air – PEL = 50 µg/m3; AL = 30 µg/m3
Contaminated Soil – 400 ppm play areas; 1000 ppm other
Contaminated Dust – 40 µg/ft2 interior floor;
250 µg/ft2 interior horizontal; 400 µg/ft2 exterior
• Waste
Useful Links
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CA DPH Childhood Lead Poisoning Prevention Branch (lots of useful
information and links):
http://www.cdph.ca.gov/programs/CLPPB/Pages/default.aspx
Ca DPH List of Certified Individuals:
http://www.cdph.ca.gov/programs/CLPPB/Pages/LRCCertList.aspx
EPA’s Resources Related to Lead in Paint, Dust, and Soil:
http://www.epa.gov/lead/
HUD Guidelines:
http://www.hud.gov/offices/lead/lbp/hudguidelines/index.cfm
Compliance Guide to EPA LRRP:
http://www.epa.gov/lead/pubs/sbcomplianceguide.pdf
LRRP: http://www.epa.gov/fedrgstr/EPA-TOX/2008/April/Day-22/t8141.htm
Cal-OSHA Lead in Construction Standard:
http://www.dir.ca.gov/Title8/1532_1.html