OSH Tab 11 Lead Updated 09 12 2017 1282A720Q0058 Columbia Basin Job Corps Center Multiple Building HVAC Replacement.pdf

COLUMBIA BASIN

JOB CORPS

CIVILIAN

CONSERVATION

CENTER

STANDARD

OPERATING

PROCEDURE

SOP No.

520.11

Date

3/8/19

Revision

CD Approval: K. W. Lester

Safety Officer Approval:

W. Johnston

Supplement To:

PRH 5.20,R11,

Safety and Health Guide VII A, 1.0, 29 CFR 1910.1025

29 CFR 1926.62

Subject/Title: OSH Plan, Appendix 11: Lead Exposure Plan

Note: This plan shall be assessed periodically to determine its effectiveness. Revisions shall be made to modify or improve the procedures as necessary.

Introduction Lead is a heavy metal found in paints, inks, batteries, alloys such as bronze and brass, solder, pottery glazes, fuel additives, ammunition, etc. Lead is a common contaminant in soil, air, water, and dust. Employees may be exposed to lead during maintenance and construction activities. Lead in house paint was banned in 1978. Lead is still used in industrial paints to prevent corrosion.

Lead has both acute and chronic health effects. Large doses may cause irreversible brain damage, seizures, coma, and death. Chronic, low dose exposures damage the nervous system, blood-forming system (anemia), kidneys, and reproductive system.

Symptoms include loss of appetite, constipation, nausea, fatigue, insomnia, headache, muscle and joint soreness, etc. Lead may also cause miscarriages and sterility.

Sources of Lead The most likely source of lead exposure on Center is from lead based paint. Appendix A summarizes the locations on Center where there is lead based paint. In addition, lead could be encountered during certain trade activities. These include:

Construction activities such as sanding, chipping, or abrasive blasting on painted surfaces; and

Welding, torch cutting, or grinding on painted surfaces.

Center Policy Primary responsibility for coordination and enforcement of this plan is assigned to the Center Safety Officer. The Safety Officer is designated as the “Competent Person”, capable of identifying existing and predictable lead hazards and having the authority to take prompt corrective measures. Center Staff and Trainees are responsible for attending lead awareness training and informing the Safety Officer of situations and locations where lead may be a concern.

The Center Safety Officer will maintain a lead inventory (Appendix A). This inventory will be updated whenever there is a change in lead containing materials on Center.

The Center Safety Officer will review Safety Data Sheets for chemicals prior to purchase. Lead containing products will not be purchased unless there are no other alternatives. The Center Safety Officer will be consulted prior to acquisition of heavy equipment which may have exterior paint containing heavy metals.

The Center will hire certified lead abatement contractors for any construction or maintenance work that could involve lead.

Trainees and staff will not chip, abrade, sand, abrasive blast, torch cut, or weld on painted surfaces unless they are known to be lead free. The Center Safety Officer, or designee, will have the requisite training to perform lead testing on painting surfaces and will assist Staff and Trainees with making this determination.

The Center Safety Officer will coordinate with the BCL and trade instructors to evaluate potential lead hazards during the planning stages of WBL and CTST projects.

Lead Testing Lead testing will be accomplished through use of a XRF Analyzer, collecting representative samples of paint chips which are analyzed at an accredited laboratory, or use of an EPA Recognized Lead Test Kit (e.g. 3M LeadCheck™).

Training Trainees and staff with potential exposure to lead will receive Lead Awareness training annually. The training will cover the location of the lead and how exposure could occur, health effects of lead exposure, and hazard reporting.

The Safety Officer, or designated competent person, will receive EPA Lead Inspector or Certified Renovator training which includes specific training on sampling for lead.

Contractors The Center Director and Safety Officer will coordinate with the FS JCNO Program Engineer or Architect, to ensure that lead abatement activities on Center are performed by a certified lead abatement contractor. The contractor will have responsibility for conducting lead testing, industrial hygiene monitoring, implementing engineering and work practice controls, legal disposal of contaminated materials, etc. The contractor will comply with OSHA and EPA regulations and will provide a copy of their written lead compliance program to the Center.

Appendix A

Lead Inventory Location (be specific) Warning Posted (Sign/Sticker)

2401 Yellow painted safety strip on pavement

NONE

2402 Brown wood exterior wall trim on corners of building.

NONE

2403 Edge of entry concrete roof, green NONE

1901 Blue steel support columns for cover over freight area.

NONE

3601 Tan metal doors NONE

3601 Green metal doors NONE

3601 Green metal door frames NONE

3604 Tan metal roll-up doors NONE

3604 Tan metal roll-up door frames NONE

3606 Yellow metal doors NONE

3606 Tan metal door frames NONE

3606 Tan metal windows NONE