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Reducing The Risks Of Working
With Lead
Working with lead has drastically changed within the
past 20 years due to an increased awareness of its danger
to employees, the public and the environment, as well
as increased regulatory enforcement of lead-related
laws from the Occupational Safety and Health Administration
(OSHA), the Environmental Protection Agency (EPA) and
other federal, state and local agencies. These changes
are readily apparent in the construction industry, where
working with lead can be a common occurrence, particularly
in painting, demolition, paint removal, bridge work
and other trades that regularly encounter lead. Working
with lead requires a certain level of planning, protection
and knowledge to prevent employee and public illness,
environmental impairment and costly regulatory fines.
Sources Of Exposure
The most common source of lead on work sites is from
lead-based paint (LBP). LBP can be found on any structure
but is most common on older structures where corrosion-resistance
is required. Lead can also be found in soils surrounding
those structures, around underground storage tanks that
may have leaked leaded gasoline, and along heavily traveled
roads that may have been contaminated by leaded gasoline
exhaust. Lead can also be found in tank linings, pipes,
at glass manufacturers and numerous other sources.
The manner in which lead activities are performed contributes
to airborne exposure. Dust-generating activities such
as abrasive blasting, sanding and crushing increase
the amount of lead-containing dust in the breathing
zones of employees. Heating by torch cutting, welding
or similar activities increases airborne lead concentrations
by generating lead fumes.
What About Contractual Liability?
At present, no federal law mandates that property
owners notify contractors of the presence of lead-based
paint. (In contrast, such a law exists for asbestos.)
Therefore, it must be determined in the contract negotiation
phase who will be responsible for identifying, remediating
and disposing of lead. Failure to coordinate this step
with clients or failure to include adequate protective
language in contracts can leave a contractor with considerable
unforeseen costs.
Before The Job Starts
Establishing an initial baseline exposure is important
in the event that future exposures are identified. Baseline
blood monitoring should be performed for employees who
may be exposed to determine the lead content in their
blood prior to working at the site. This is a crucial
step because an employer may be held responsible for
an employee's overexposure even though it may have been
caused by previous employment or a hobby.
Soil samples should also be collected around project
sites to determine the original quality of the soil.
This enables companies to determine if their acts on
a job site contributed to soil contamination. Adequate
baseline soil sampling can prevent costly remediation
costs linked to previous site activities.
Exposure Monitoring
An initial exposure assessment must be conducted as
early as possible. Personal sampling should be performed
for each job description and for any employee with a
distinct job duty with potential exposure. Employees
must be protected during this exposure assessment. Documentation
from previous projects may be used for the initial exposure
assessment, but conditions (amount of lead in paint,
ventilation, job tasks, weather) must be similar.
Upon receipt of monitoring results, employees must
be notified of the findings. If levels are below the
action level (AL) of 30 micrograms of lead per cubic
meter of air (mg/m3), no further action is required,
unless conditions change. If results are above the AL,
but below the permissible exposure limit (PEL) of 50
mg/m3, then medical surveillance, air sampling at least
every six months, additional training, and other requirements
must be met. If results are above the PEL, the contractor
must designate a competent person to oversee activities;
implement engineering, administrative and PPE controls;
post warning signs; develop a written control plan;
require respiratory protection; provide shower and laundry
facilities; and perform air monitoring every three months.
Written Lead Control Plan
A written plan describing how lead exposures will
be controlled is required if employee exposures are
above the PEL. This program must be in writing and must
include the following:
- A description of the work being performed (crew
size, responsibilities, operating procedures)
- A description of the engineering, administrative
and PPE controls;
- Air monitoring results;
- Work schedule; and
- Reviews and revisions at least every six months.
Contractors should also include a copy of their respiratory
protection program, medical surveillance documentation
and any other relevant information in the written control
plan.
Controls
If it is determined that lead levels exceed exposure
limits, engineering, administrative and personal protective
equipment (PPE) controls must be implemented, in that
order. Engineering controls consist of process changes
such as chemical stripping in lieu of abrasive blasting
to reduce airborne lead concentrations. Exhaust ventilation
and providing enclosures to prevent migration of lead
are also examples of engineering controls. Administrative
controls include employee rotation and removal of exposed
employees. PPE controls consist of respiratory protection,
coveralls and gloves. PPE must be selected based on
the type of hazard. Specific guidance can be found within
the lead standard.
Along with the aforementioned controls, personal hygiene
facilities such as hand washing facilities, showers
and laundering services must also be provided to prevent
employees from transporting lead to their residences
and exposing their children, who are much more susceptible
to the toxic effects of lead. Professional laundering
services should be notified in writing if the potential
for lead contamination exists in clothes being laundered.
Separate eating facilities must also be provided.
Waste
Contractors must ensure proper disposal of all lead-containing
materials. This includes the material itself (LBP-coated
metal, flashings, contaminated soil, abrasive grit),
as well as contaminated PPE, shower and hand washing
water, and rags used to decontaminate tools and equipment.
These wastes must be properly classified and taken to
appropriate disposal facilities. Clients or property
owners should sign hazardous waste manifests. Contractors
should not sign these documents as they may be held
liable for future environmental incidents related to
the waste.
When The Job Is Over
Upon completion of a lead project, exit blood testing
should be performed, along with exit soil sampling.
Blood-lead monitoring results must be kept for 30 years
after the employee's last work day. Construction companies
should also ensure lead-containing waste is accounted
for and any remediation reports are completed. Any surfaces
that could potentially be contaminated with lead must
be vacuumed, wiped down and tested. A final walkthrough
with the client should be performed to identify any
existing concerns.
XL Environmental • Risk Control Division •
520 Eagleview Boulevard, PO Box 636, Exton, PA 19341
• Phone: 800-327-1414 • Fax: 610-458-7285
• xlenvironmental.com
XL Environmental is a division of XL Specialty Insurance
Company.
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