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Lead for Project Managers. Presented by Aurora Industrial Hygiene, Inc. www.auroraih.com , info@auroraih.com. Overview. Background Health Effects Definitions Regulations Procedures Important Numbers Useful Links. What is Lead. Lead is an elemental metal
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Lead for Project Managers Presented by Aurora Industrial Hygiene, Inc. www.auroraih.com, info@auroraih.com
Overview • 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…. • Industrial Releases • Soil • Food • Drinking Water • Occupational Exposure
Heart and Blood System • High blood pressure • Increased risk of heart attack and stroke • Anemia
Kidneys • Filter the blood • Not detectable • Kidney failure
Central Nervous System • Most affected • Permanent • Brain damage • Damage to nerves
Bone Tissue • Body Burden • Released when the body is under stress • Pregnancy • Menopause • Serious Illness
Reproductive Systems • Female System • Infertility • Birth defects • Miscarriage • Pregnancy • Male System • Impotency • Lack of drive • Damage to sperm • Infertility
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 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
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: • 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: • 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 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
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 • 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 • 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 • Abatement designed for less than 20 years • Trained workers • Containment • Notification • Follow HUD Guidelines Chapter 11 • Clearance inspection depending on conditions
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
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 • 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 • 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