Lead for Project Managers

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Lead for Project Managers
Presented by Aurora Industrial Hygiene,
Inc. www.auroraih.com, info_at_auroraih.com
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Overview

• Background
• Health Effects
• Definitions
• Regulations
• Procedures
• Important Numbers
• Useful Links

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What is Lead

• Lead is an elemental metal
• Forms 0.06 of the earths crust
• Cannot be destroyed, only smaller
• Should not be in our bodies

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Why was Lead Used

• Prevents Corrosion
• Kills mold and mildew
• Malleable
• Strong
• Blocks Radiation
• Blocks Sound
• Drying Agent

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Problems

• Its a chronic and acute poison

• Contamination

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Where is Lead Found?

• Quality Paint

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Military uses
Bridges and Steel Structures
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Residences Interior Exterior Banned in
1978 Schools in 1984
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Lead is Found in Gasoline

• Used over a period of 50 years
• 93 reduction from 1978-1987

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Lead Is Found In.

• Industrial Releases
• Soil
• Food
• Drinking Water
• Occupational Exposure

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Heart and Blood System

• High blood pressure
• Increased risk of heart attack and stroke
• Anemia

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Kidneys

• Filter the blood
• Not detectable
• Kidney failure

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Central Nervous System

• Most affected
• Permanent
• Brain damage
• Damage to nerves

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Bone Tissue

• Body Burden
• Released when the body is under stress
• Pregnancy
• Menopause
• Serious Illness

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Reproductive Systems

• Male System
• Impotency
• Lack of drive
• Damage to sperm
• Infertility

• Female System
• Infertility
• Birth defects
• Miscarriage
• Pregnancy

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Children

• Proportion to body weight and size
• Developmental effects
• More hand-to mouth contact
• More absorption of lead

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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

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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.

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Applicable Regulations (a few)

• Title X, Lead-Based Paint Poisoning Prevention
  Act of 1992.
• HUD Guidelines for the Evaluation and Control of
  Lead-Based 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

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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

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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

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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
• Airborne exposure limits
• Exposure assessment
• Written compliance program
• Respiratory protection and PPE
• Medical surveillance
• Recordkeeping

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Regulations

• California OSHA Lead in Construction 8 CCR
  1532.1
• Important for Protecting Workers AND Surrounding
  Areas
• 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

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Regulations

• Accreditation, Certification, and Work Practices
  for Lead-Based 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

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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

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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

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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

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Procedures - General

• Characterize
• Handling/Management
• Clearance
• Disposal

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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.

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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

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Procedures - LSWP

• 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
  gt1100F scraping, sanding, grinding, or blasting
  without containment

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Procedures Interim Controls

• Abatement designed for less than 20 years
• Trained workers
• Containment
• Notification
• Follow HUD Guidelines Chapter 11
• Clearance inspection depending on conditions

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Procedures - Abatement

• Abatement for 20 years or longer
• Certified supervisors and workers
• Abatement plan
• Notification to CDPH and OSHA
• HUD Guidelines, Chapter 12
• Containment
• Clearance inspection

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Procedures - Clearance

• Certified Inspector/Risk Assessor or Project
  Monitor
• Visual
• Dust
• Soil
• CDPH 8552 to City and State

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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.

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Important Numbers

• 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

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Useful Links

• CA DPH Childhood Lead Poisoning Prevention Branch
  (lots of useful information and links)
  http//www.cdph.ca.gov/programs/CLPPB/Pages/defaul
  t.aspx
• Ca DPH List of Certified Individuals
  http//www.cdph.ca.gov/programs/CLPPB/Pages/LRCCer
  tList.aspx
• EPAs Resources Related to Lead in Paint, Dust,
  and Soil http//www.epa.gov/lead/
• HUD Guidelines http//www.hud.gov/offices/lead/l
  bp/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/Ap
  ril/Day-22/t8141.htm
• Cal-OSHA Lead in Construction Standard
  http//www.dir.ca.gov/Title8/1532_1.html