Lead & LEAD AWARENESS
Origination Date: October 7, 2011 Revision Date:
Danny Trahan, Safety Director
June
2012
Manual Rev 4 Release Authorized by:
LEAD & LEAD AWARENESS
LEAD & LEAD AWARENESS
TABLE OF CONTENTS
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Copyright © 2012, P2S. All Rights Reserved.
P2S Health, Safety & Environmental
Page 1 of 14
Origination Date: October 7, 2011 Revision Date:
Danny Trahan, Safety Director
June
2012
Manual Rev 4 Release Authorized by:
LEAD & LEAD AWARENESS
Copyright © 2012, P2S. All Rights Reserved.
Page 2 of 14
P2S Health, Safety & Environmental
Origination Date: October 7, 2011 Revision Date:
Danny Trahan, Safety Director
June
2012
Manual Rev 4 Release Authorized by:
LEAD & LEAD AWARENESS
Purpose
This procedure provides minimum requirements for the protection of personnel engaged in operations where exposure to inorganic lead, lead compounds, or organic lead soaps above the action level can reasonably be expected.
Scope
This procedure defines what constitutes exposure to lead and medical, training, and record keeping requirements.
Application
This procedure applies globally to P2S and its subcontractors.
Definitions
Action Level
An airborne concentration of lead, without regard to the use of respirators, of thirty (30) micrograms per cubic meter of air (30 µg/m3) calculated as an eight (8)-hour time-weighted average (TWA).
Aerosols
Airborne dust, mists, fumes, or vapors.
Baseline
Medical condition of an employee prior to performing work where potential exposure may occur.
Biological Monitoring
Blood sampling and analyses for lead and zinc protoporphyrin levels performed by or under the supervision of a licensed physician. The accuracy of the analyses shall be plus or minus fifteen percent (±15%) or six (6) micrograms per deciliter 6 µg/dl, whichever is greater, with a confidence level of ninety-five percent (95%). A laboratory approved by the oversight agency shall conduct analyses. Blood levels at or above forty (40) µg/dl shall require immediate action to reduce employee exposure.
Chelation
A medical treatment in which a drug that is attracted to metals (such as lead) is infused into a patient’s vein. The drug binds to the metal in the blood, and both are excreted from the kidney as urine.
Copyright © 2012, P2S. All Rights Reserved.
P2S Health, Safety & Environmental
Page 3 of 14
Origination Date: October 7, 2011 Revision Date:
Danny Trahan, Safety Director
June
2012
Manual Rev 4 Release Authorized by:
LEAD & LEAD AWARENESS
Competent Person
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.
Exposure Assessment
Determination if any employee is exposed to lead at or above the action level.
Objective Data
Information demonstrating that a particular product or material containing lead or a specific process, operation or activity involving lead cannot release lead aerosols (dust, vapors, or fumes) in concentrations at or above the action level under any expected conditions. Examples include industry-wide studies or laboratory product test results.
PAPR
Powered Air Purifying Respirator
Personal Air Samples
Time weighted average samples collected for at least six (7) hours, within twelve (12”) inches (0.31 meters) of the employee's nose. Samples must meet the quality information requirements.
Quality Information
Information gathered following prudent industrial hygiene protocol. Air, bulk, and wipe sample results must be accurate to not less than plus or minus twenty-five percent (±25%) with a confidence level of ninety-five percent
(95%).
Relevant Information
Information gathered from industry-wide sources representing workplace conditions closely resembling the processes, types of materials, control methods, work practices, and environmental conditions in the operation.
PERMISSIBLE EXPOSURE LIMITS (PEL)
Fifty (50) micrograms per cubic meter (µg/m3) calculated as an eight (8)-hour TWA (time weighted average). If the employee works a shift longer than eight (8)-hours, permissible exposure is reduced according to the following formula:
Allowable Employee Exposure = 400
hours worked in the day
For proper exposure monitoring procedures, refer to OSHA 1926.62(d) or the appropriate citation for the country where the work is performed.
Copyright © 2012, P2S. All Rights Reserved.
Page 4 of 14
P2S Health, Safety & Environmental
Origination Date: October 7, 2011 Revision Date:
Danny Trahan, Safety Director
June
2012
Manual Rev 4 Release Authorized by:
LEAD & LEAD AWARENESS
Requirements
Initial Determination
Each project/site shall determine if any employee may reasonably be expected to be exposed to lead at or above the action level. The determination shall be conducted as if the employee(s) were not wearing a respirator.
Methodologies used to make this determination shall be documented in writing and kept in the project/site files.
The determination shall address the following topics at a minimum.
There must be a written request to the client asking for information on the location of lead-based paints and coatings, elemental lead components, and the use of lead or lead compounds in the client’s operation(s).
Test all painted or coated surfaces for the presence of lead where operations may create lead aerosols.
Examples of such operations include, but are not limited to, cutting, welding, abrasive blasting, sanding, and heating.
Employee Exposure Assessment (EEA)
If the Initial Determination indicates the presence of lead in areas where operations are to be performed, an EEA shall be conducted. The EEA shall consist of the following items.
Written record of the following: o each and every job classification on a project; o date the initial determination was made for each job classification and a listing of the objective data, if any, used in making the determination; o name and Personnel/ID Number of each employee in that job classification; and o the date, sample number(s), and result(s) of personal air samples collected on that employee.
Personal Air Samples – Time weighted average samples collected for at least seven (7) hours , within twelve
(12”) inches (0.31meters) of the employee’s nose. Samples must meet the quality information requirements.
Gathering objective data, observations, other information, or performing calculations, which would indicate employee exposure.
Obtaining copies of any previous measurements of airborne lead concentrations collected while performing similar operations under similar conditions.
Reviewing employee complaints of symptoms, which may be attributable to exposure to lead.
Reviewing available and feasible engineering and work practice controls, which may reduce employee exposures.
The EEA shall be conducted for each job classification performing tasks, or requiring proximity to operations, that may create lead aerosols.
Copyright © 2012, P2S. All Rights Reserved.
Page 5 of 14
P2S Health, Safety & Environmental
Origination Date: October 7, 2011 Revision Date:
Danny Trahan, Safety Director
June
2012
Manual Rev 4 Release Authorized by:
LEAD & LEAD AWARENESS
A record documenting the accuracy and relevancy of objective data used in assessing employee exposure shall be kept in the project files throughout the project and for thirty (30) years after project completion.
The information gathered during the EEA can be positive, inconclusive, or negative for the likelihood that an employee will be exposed to lead aerosols above the action level.
Positive EEA Results
If the EEA results indicate that job classifications are likely to be exposed to lead aerosols above the action level, appropriate controls, as specified in the Methods of Compliance section of this standard, shall be used to reduce potential employee exposures.
Inconclusive EEA Results
Information gathered during the EEA can be inconclusive either due to insufficient relevancy or quality. If the
EEA is inconclusive for job classifications performing any of the following tasks where lead is present:
manual demolition of structures;
manual scraping or sanding;
heat gun applications;
cleaning power tools equipped with dust collection systems; or
any other task that may generate aerosols.
The following shall be provided at NO COST for affected employees:
half face, air purifying, negative pressure respirators equipped with high efficiency particulate air (HEPA) filter cartridges. If the lead is causing eye or facial skin irritation, a full face piece respirator shall be required. If additional contaminants are involved in the tasks, appropriate compound filter cartridges shall be used;
appropriate coveralls or similar full-body work clothing;
appropriate gloves, hats, and shoes made of a non-permeable material or disposable shoe coverlets;
Note: Leather shoes cannot be decontaminated. If they are worn during these tasks without coverlets, they shall be disposed of along with the other lead-contaminated wastes.
clean change areas equipped with separate storage facilities for protective work clothing and for street clothing which prevent cross contamination;
hand washing facilities;
baseline biological monitoring; and
training in accordance with the training portion of this manual.
Note: Full face piece PAPRs shall be provided to employees, instead of half face respirators, upon request.
Copyright © 2012, P2S. All Rights Reserved.
P2S Health, Safety & Environmental
Page 6 of 14
Origination Date: October 7, 2011 Revision Date:
Danny Trahan, Safety Director
June
2012
Manual Rev 4 Release Authorized by:
LEAD & LEAD AWARENESS
If the EEA is inconclusive for job classifications performing any of the following tasks where lead is present:
using lead-containing mortar;
lead burning;
rivet busting;
cleaning power tools not equipped with dust collection systems;
cleanup activities where dry expendable abrasives were used; or
removal or moving of abrasive blasting enclosures.
All items previously described shall be provided for affected employees, except that minimum respiratory protection shall be either:
loose fitting hood or helmet powered air purifying respirator (PAPR) with HEPA filter cartridges; or
loose fitting hood or helmet supplied air respirator operated in continuous-flow mode.
If the EEA is inconclusive for job classifications performing any of the following tasks where lead is present:
abrasive blasting;
welding;
cutting or sawing; or
torch burning; then all items previously described shall be provided for affected employees, except that minimum respiratory protection shall be either:
full face piece, air-purifying respirator with HEPA filter cartridges;
PAPR with HEPA filter cartridges;
half face or full face piece supplied air respirator operated in a continuous-flow mode; or
full face piece, self-contained breathing apparatus (SCBA) operated in demand mode.
Respiratory protection shall be used until at least two (2) consecutive personal air samples, collected at least seven
(7) days apart by a competent person, are analyzed and found to be below the action level.
Collection of personal air samples shall be collected first on those employees reasonably believed to have the highest potential exposure. If these first air samples are found to be below the action level, further samples shall only be collected if there is no objective data to indicate that other tasks present lower exposure potential.
Negative EEA Results
Where objective data is available to indicate that a job classification cannot be exposed to airborne concentrations of lead at or above the action level, the data will be kept with the project files for thirty (30) years.
Employee Notification
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P2S Health, Safety & Environmental
Page 7 of 14
Origination Date: October 7, 2011 Revision Date:
Danny Trahan, Safety Director
June
2012
Manual Rev 4 Release Authorized by:
LEAD & LEAD AWARENESS
Within five (5) working days after completion of the EEA, the project shall notify each employee, in writing, of the results of the EEA for that employee's job classification.
Whenever personal air samples or biological monitoring samples are collected, the affected employee(s) shall be notified, in writing, within five (5) working days after receipt of the sample results.
Whenever area samples are collected, the results of the sample analyses shall be posted in a conspicuous area within five (5) working days after receipt of the analyses results.
Observation of Monitoring
The project shall make available to employees, or their designated representative, the opportunity to:
observe air monitoring conducted to comply with this standard;
receive an explanation of the monitoring procedures being followed; and
if requested in writing, receive a copy of the results obtained within five (5) working days of receipt.
If such observations require the observer to enter an area where respirators or other personal protective equipment
(PPE) is required, the project shall provide that PPE if, and only if, the observer is medically fit to wear the PPE and has complied with all other applicable safety and health procedures.
Management of Change
Whenever there has been a change of equipment, process, control, personnel, or a new task that may result in employee exposure at or above the action level, an EEA shall be conducted encompassing any new tasks and/or job classifications.
Methods of Compliance
Methods used to reduce potential employee exposure to lead shall be implemented in the following order of priority.
Engineering controls such as isolation, ventilation, or abatement.
Work practice controls, such as employee rotation or specific procedures. Wherever all feasible engineering and work practice controls that have been instituted are not sufficient to reduce employee exposure to or below the permissible exposure limit; then, in addition to these controls, respiratory protection shall be used. Respiratory protection alone shall not be an optional method for reducing potential employee exposures. Engineering controls and/or work practice controls must be implemented first.
Written Compliance Programs
Prior to the commencement of field activities, the project shall produce and implement a Written Compliance
Program that complies with this standard and OSHA 29 CFR 1926.62 (or the standard for the country where work
Copyright © 2012, P2S. All Rights Reserved.
P2S Health, Safety & Environmental
Page 8 of 14
Origination Date: October 7, 2011 Revision Date:
Danny Trahan, Safety Director
June
2012
Manual Rev 4 Release Authorized by:
LEAD & LEAD AWARENESS occurs). The Written Compliance Program shall be updated every six (6) months and shall be made available to all affected employees or their designated representative(s).
The Written Compliance Program shall, as a minimum, include:
procedures to be followed to conduct the initial determination;
procedures to be followed to conduct the EEA;
a description of each task which may produce lead aerosols including: o equipment used; o lead-containing materials impacted; o number of employees who may be exposed; o work practices to be used; and o employee responsibilities during task.
engineering controls to be used including objective data to justify their use;
a report of the technologies considered and discounted;
available air monitoring data;
detailed schedule for implementation of the Program including documentation such as purchase orders and contracts;
PPE, if necessary;
housekeeping procedures;
hygiene facilities and their usage;
relevant work practices;
administrative control schedule, if used to control employee exposure;
description of arrangements made to inform other contractors, if any, about potential lead exposure and contractor responsibilities;
project, materials, and equipment inspection schedules; and
the name of contractor's or project's/site’s competent person.
Medical Surveillance
Medical examinations shall be provided by the project/site to all employees who may be exposed above the action level for more than thirty (30) days in any twelve (12) month period.
The project/site shall promptly notify an employee of the right to seek a second medical opinion after each examination or consultation. Payment by the project for the second medical opinion is conditioned upon:
the employee informing Project Management in writing, of his/her intent to seek a second opinion; and
the employee initiating steps to make an appointment with the second physician.
Both of these actions must be completed within fifteen (15) days of receipt of the initial physician's written opinion or employee receipt of the previously mentioned notification, whichever is later.
All required medical surveillance programs must be performed by or under the supervision or direction of a licensed physician in a clinical setting with thorough and appropriate medical monitoring. The employee must be notified in writing prior to therapeutic or diagnostic chelation.
Copyright © 2012, P2S. All Rights Reserved.
P2S Health, Safety & Environmental
Page 9 of 14
Origination Date: October 7, 2011 Revision Date:
Danny Trahan, Safety Director
June
2012
Manual Rev 4 Release Authorized by:
LEAD & LEAD AWARENESS
Biological Monitoring
Biological monitoring shall be conducted for all employees who may be exposed to lead aerosols at or above the action level. Employees who may be exposed for less than thirty (30) days shall receive baseline biological monitoring only.
Employees who may be exposed for more than thirty (30) days shall be placed in a medical surveillance program.
The project/site shall communicate the availability of biological monitoring available every two (2) months for the first six (6) months and once every six (6) months thereafter until the employee no longer has a potential lead exposure.
Copyright © 2012, P2S. All Rights Reserved.
Page 10 of 14
P2S Health, Safety & Environmental
Origination Date: October 7, 2011 Revision Date:
Danny Trahan, Safety Director
June
2012
Manual Rev 4 Release Authorized by:
LEAD & LEAD AWARENESS
Employee Placement for Medical Reasons
Remove from work (which may present an exposure to lead aerosols) any employee whose:
periodic and follow-up blood sampling tests indicate blood lead levels are at or above 50 µg/dl, or;
medical examination or written physician's opinion indicates that the employee has a detected physical condition which places the employee at increased health risk to exposure.
Where a medical examination or written physician's opinion recommends special protective measures or limitations on an employee, the project/site shall implement appropriate additional engineering controls, work practices, or
PPE that meets the intent of the recommendation.
Return to Work Criteria
Where an employee was removed from work for high blood lead levels, the employee may return to his/her former job classification when two (2) blood-sampling tests indicate that the employee's blood lead level is below 40 µg/dl.
Where an employee was removed from work for a detected physical condition which places the employee at increased health risk to exposure, the employee may return to his/her former job classification when a subsequent medical examination and a written physician's opinion finds that the employee no longer has the condition.
Where a detected physical condition placed the employee at an increased health risk, the employee may return to his/her former job classification when a subsequent medical examination and a written physician's opinion finds that the special protective measures or limitations are no longer needed.
Training
P2S will provide refresher training annually for each employee who is subject to lead exposure at or above the action level on any day.
Prior to initial job assignment an employee shall train in the following:
the contents of the OSHA Lead in Construction standard (29 CFR 1926.62) and its appendices (if in U.S.; otherwise applicable in-country standard);
the specific nature of the operations which could result in exposure to lead above the action level;
the purpose, proper selection, fitting, use, limitations and health effects of respirators;
the purpose and a description of the medical surveillance program, the placement of employees for medical reasons, health effects of lead with particular attention given to the reproductive and teratogenic effects of lead exposure;
the engineering and work practice controls associated with each employee’s job classification;
relevant good work practices;
the contents of the written compliance program;
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P2S Health, Safety & Environmental
Page 11 of 14
Origination Date: October 7, 2011 Revision Date:
Danny Trahan, Safety Director
June
2012
Manual Rev 4 Release Authorized by:
LEAD & LEAD AWARENESS
instructions that chelating agents should not be used except under the direct supervision of a licensed physician; and
The employee's right to access records and documents including: o a copy of the Written Compliance Program; o the Lead in Construction standard; and o all other materials relating to the employee information and training program.
Signs
The project/site shall post signs, illuminated and cleaned as needed, stating the following in each work area where an employee exposure to lead aerosols may be above the PEL:
“WARNING LEAD WORK AREA - POISON - NO SMOKING OR EATING”
Recordkeeping
EEA
The project shall establish and maintain accurate records. The project shall make all records kept in accordance with this standard available to employees or their designated representative upon written request. These records shall be kept with the project files.
documentation stipulated in the EEA section of this standard;
records of all monitoring and other objective data used in conducting the EEA;
exposure monitoring records including: o date sample collected; o sample number; o sample duration; o sample location; o name of employee sampled; o Personnel/ID Number of employee; o job classification of employee; o names of all other employees the sample is intended to represent; o sampling procedure followed; o sample analysis results; o environmental variables that could affect interpretation of sample results such as temperature; o humidity and barometric pressure; o sampling equipment make, model and serial number; and o sampling equipment calibration records.
Medical Surveillance
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P2S Health, Safety & Environmental
Page 12 of 14
Origination Date: October 7, 2011 Revision Date:
Danny Trahan, Safety Director
June
2012
Manual Rev 4 Release Authorized by:
LEAD & LEAD AWARENESS
The project/site shall maintain the following records for each affected employee. These records shall be kept with the project files:
documentation stipulated in the medical surveillance section of this standard;
name, Personnel/ID Number, and job classification;
a copy of physician's written opinions, if any;
results of any air sampling results sent to the employee’s physician; and
any employee medical complaints or observed symptoms related to lead exposure.
The project shall also maintain or require the physician to maintain the following medical records:
a copy of the medical examination results including the employee's medical and work history;
a description of the laboratory procedures and a copy of any standards or guidelines used to interpret the test results or references to that information; and
a copy of the results of any biological monitoring.
Employee Placement for Medical Reasons
The project shall maintain the following records for each affected employee. These records shall be kept with the project files for thirty (30) years:
name and Personnel/ID Number of the affected employee;
the date of each placement change;
the date the employee was returned to former job classification;
a brief explanation of how each placement change was accomplished; and
a statement of whether or not each placement change was due to elevated blood lead levels.
REFERENCES
Document ID
000.653.1000
000.653.2000
Forms:
000.653.F0135
Non-P2S Documents:
29 CFR 1926.62(d)
Document Title
HSE General Requirements
Industrial Hygiene Program Requirements
Employee Exposure Assessment for Lead
Lead – Exposure Assessment
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P2S Health, Safety & Environmental
ATTACHMENTS
Origination Date: October 7, 2011 Revision Date:
Danny Trahan, Safety Director
June
2012
Manual Rev 4 Release Authorized by:
LEAD & LEAD AWARENESS
Attachment No.
Attachment 01
Attachment 02
Attachment 03
Attachment Title
Initial Determination for Employee Lead Exposure
Employee Exposure Assessment
Sample Form Letter
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P2S Health, Safety & Environmental
