|
Lead Exposure in Construction Policy
I. PURPOSE. The purpose of this document
is to establish responsibilities, policies, and procedures
for construction activities that disturb lead containing
material.
II. APPLICABLE REGULATION. Lead Exposure
in Construction 29 CFR 1926.62 with Maryland Amendments.
III. ACTIVITIES COVERED BY THIS PROGRAM. This
program applies to all construction work where a UMB
employee may be occupationally exposed to lead. Construction
work is defined as work for construction, alteration
and/or repair, including painting and decorating. It
includes but is not limited to the following:
- Demolition
or salvage of structures where materials containing
lead are present.
- Removal
or encapsulation of materials containing lead.
- New
construction, alteration, repair or renovation of
structures, substrates, or portions thereof, that
contain lead, or materials containing lead.
- Installation
of products containing lead.
- Lead
contamination/emergency cleanup.
- Transportation,
disposal, or storage of lead containing materials
on the site or location at which construction activities
are performed.
- Maintenance
operations associated with the construction activities
described above.
IV. EXEMPTIONS. In 1978 the Consumer
Product Safety Commission (CPSC) established a maximum
lead content in paint of 0.06%. Based on this, construction
work that only disturbs paint in buildings built after
1980 will not be covered under this program.
V. INITIAL EXPOSURE ASSESSMENT. The
office of Environmental Health and Safety (EHS) shall
conduct an initial exposure assessment of construction
activities that represent UMB's highest employee exposures
to airborne lead. Within five (5) working days after
the completion of the exposure assessment, EHS will notify
each employee in writing of the results of their assessment.
If an employee is exposed above the permissible exposure
limit (PEL), a statement that the exposure was at or
above the PEL and a description of the corrective action(s)
to be taken to reduce the exposure level will be included
with the results. A written record of the initial assessment
shall be maintained at the Environmental Health and Safety
building.
Employees involved in construction activities
that may occupationally expose them to lead above the
PEL shall be provided with the following interim protection
during the exposure assessment.
- Appropriate
respiratory protection
- Appropriate
personal protective clothing and equipment
- Change
areas and hand-washing facilities
- Biological
monitoring
- Hazard
communication and respiratory training
- Training
on any operations that could result exposures above
the action level
It is the responsibility of the employees department
to provide the above interim protection.
VI. FREQUENCY OF EXPOSURE ASSESSMENT. If
the initial determination reveals that a certain construction
activity does not expose employees above the action level,
no additional exposure assessments will be required unless
the activity changes. If the initial determination or
subsequent determinations reveals an exposure at or above
the action level, EHS will continue to monitor in accordance
with the lead in construction standard.
VII. ACCESS TO INFORMATION. Affected
employees may receive a copy of the lead standard and
information on the Occupational Safety and Health Act
by contacting EHS at 706-3490.
VIII. LEAD WORK THAT IS BELOW THE ACTION
LEVEL. UMB employees that perform work that disturbs
lead containing material and are exposed below
the action level shall be provided with the following:
- Adequate
washing facilities. When running water is not available,
handy wipes may be used.
- Hazard
Communication training.
- To
prevent the ingestion of lead dust, employees
will be provided with and required to wear a paper
dust mask when disturbing lead-based paint. The dust
mask is only used to provide a barrier of protection
to prevent the ingestion of lead dust and is not
to be used in place of respiratory protection. The
double strapped mask shall be provided by their department.
IX. LEAD WORK THAT IS AT OR ABOVE THE ACTION
LEVEL.
UMB employees that perform work that exposes
them to airborne concentrations of lead at or above
the action level shall be provided with the following:
- Respirators
approved for protection against lead dust, fume,
and mist by the Mine Safety and Health Administration
(MSHA) and the National Institute for Occupational
Safety and Health (NIOSH). All employees that require
a respirator must be enrolled in the UMB respiratory
protection program.
- Protective
clothing and equipment that prevents contamination
of the employees' garments.
- Clean
change areas equipped with separate storage facilities
for protective work clothing, equipment, and street
clothing.
- Where
feasible, hand-washing and shower facilities.
- Medical
examination and blood lead level surveillance.
- Medical
removal protection in accordance with the lead in
construction standard.
- Lunchroom
facilities that are as free as practicable from lead
contamination.
- Initial
and annual training in accordance with the lead in
construction standard.
UMB supervisors directing work that exposes
UMB employees to airborne concentrations of lead at
or above the action level shall be responsible for
the following:
- Establish
and implement a written compliance program for any
maintenance activities that expose employees above
the action level. Supervisors should contact EHS
for assistance in developing their program. All written
compliance programs must be approved by EHS.
- A
supervisor directing work that has airborne lead
levels at or above the action level must complete
a forty (40) hour EPA-approved Lead Abatement Supervisor/Contractor
course.
- Ensure
that employees have received the appropriate training.
- Ensure
that engineering controls and safe work practices
are used to reduce lead exposure. Also, ensure that
sanding and scraping of lead paint and sweeping of
lead debris is done only after the material has been
wetted.
- Ensure
that food, beverages, and tobacco products are not
present or consumed and cosmetics are not applied
in the work area.
- Ensure
that employees wash their hands and face prior to
eating and do not enter the lunchroom with contaminated
clothing or equipment.
- Ensure
that the job site is clean and all surfaces are maintained
as free as practicable from accumulations of lead
dust. At the completion of the project, ensure that
the area is cleaned properly.
- Inform
building occupants of the nature and duration of
the work to be conducted.
- Post
the following warning signs in each work area were
employees are exposed above the PEL:
WARNING
LEAD WORK AREA
POISON
NO SMOKING OR EATING
- Ensure
that hazardous waste is disposed of in compliance
with Federal, State and local regulations.
- Ensure
that employees remove their protective clothing in
the appropriate area at the end of the work period.
Also, ensure that all contaminated protective clothing
which is to be cleaned, laundered, or disposed of
is placed in a closed and properly labeled container(s).
Notify in writing any person that cleans or launders
the protective clothing of the potentially harmful
effects of exposure to lead.
- When
respirators are required, ensure that employees are
trained in their use, have been fit tested, and wear
them properly.
- Ensure
that all safety and health regulations and procedures
are followed.
XI. CONTRACTORS. Contractors and subcontractors
that perform work covered under the Lead in Construction
Standard shall be responsible for ensuring that their
work is done in compliance with 29 CFR 1926.62 with MD
Amendments.
XII. PROHIBITED ACTIVITIES. Burning,
dry sanding, and dry scraping of lead paint is prohibited.
Footnotes
-
Osteoporosis. A
condition that is characterized by decrease in
bone mass with decreased density and enlargement
of bone spaces.
-
Permissible Exposure
Limit. An airborne concentration of lead
of fifty micrograms per cubic meter of air
(50 µg/m3) averaged over an 8-hour
period.
-
Action Level. An
airborne concentration of lead of thirty micrograms
per cubic meter of air (30 µg/m3)
averaged over an 8-hour period.
| Signed
by President David J.Ramsay, DM, D.PHIL |
7-1-97 |
President |
Date |
Next to Appendix
A - Lead Exposure in Construction Standard
Back to Introduction - Lead
Exposure in Construction Policy
|
home
> lead exposure toc
> lead exposure in construction policy
