3c_CGTTP4.PDF

U.S. Coast Guard

Lead Hazard Awareness and Management Tactics, Techniques, and Procedures (TTP)

CGTTP 4-11.6A

February 2020

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Commander United States Coast Guard Force Readiness Command

Commandant (FC-Tptc) Attn: FORCECOM Training Division, Performance Technology Center 1 U.S. Coast Guard Training Center Yorktown, VA 23690-5000 Staff Symbol: FC-Tptc Phone: (757) 856-2356

07 February 2020

COAST GUARD TACTICS, TECHNIQUES, AND PROCEDURES, CGTTP 4-11.6A

Subj: LEAD HAZARD AWARENESS AND MANAGEMENT TACTICS, TECHNIQUES, AND PROCEDURES (TTP)

Ref: (a) Development System and Standards Tactics, Techniques, and Procedures (TTP), CGTTP 1-01 (series)

(b) Safety and Environmental Health Manual, COMDTINST M5100.47 (series)

(c) Lead, 29 CFR § 1910.1025

(d) Lead, 29 CFR § 1926.62

(e) Lead-Based Paint Poisoning Prevention in Certain Residential Structures, 40 CFR

Part 745

(f) Lead, 29 CFR § 1915.1025

(g) Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing, Office of Healthy Homes and Lead Hazard Control, U.S. Department of Housing and Urban Development (HUD), Second Edition, July 2012

(h) Coast Guard Occupational Medicine Manual, COMDTINST M6260.32 (series)

(i) Coast Guard Range Training Handbook Tactics, Techniques, and Procedures (TTP), CGTTP 3-30.3 (series)

(j) Ban of Lead-Containing Paint and Certain Consumer Products Bearing Lead-

Containing Paint, 16 CFR Part 1303

(k) Hazard Communication, 29 CFR § 1910.1200

(l) Risk Management (RM), COMDTINST 3500.3 (series)

(m) Coatings and Color Manual, COMDTINST M10360.3 (series)

(n) Lead Exposure in Construction; Interim Final Rule – Inspection and Compliance

Procedures, OSHA Instruction Compliance Directive (CPL) 02-02-058

(o) Welding, Cutting and Heating, 29 CFR Part 1915, Subpart D

(p) Industrial Hygiene Tactics, Techniques, and Procedures (TTP), CGTTP 4-11.7

(series)

(q) Respiratory Protection Program Tactics, Techniques, and Procedures (TTP), CGTTP 4-11.4 (series)

(r) Hearing Conservation Program Tactics, Techniques, and Procedures (TTP), CGTTP 4-11.11 (series)

Lead Hazard Awareness and Management TTP

(s) “Screening Young Children for Lead Poisoning: Guidance for State and Local Public Health Officials,” Centers for Disease Control and Prevention

(t) Child Development Services Manual, COMDTINST M1754.15 (series)

(u) Caring for Our Children: National Health and Safety Performance Standards;

Guidelines for Early Care and Education Programs, American Academy of Pediatrics, 4th Edition

1. PURPOSE. To provide Coast Guard personnel with Coast Guard tactics, techniques, and procedures (CGTTP) on avoiding lead exposure hazards. It also provides unit Assistant Safety Officer/Manager’s with guidance to develop implement and maintain a lead hazard control plan (LHCP) where lead exposure hazards have been identified.

2. ACTION. This CGTTP publication applies to all Coast Guard personnel. Internet release authorized.

3. CGTTP AFFECTED. This publication supersedes the Lead Hazard Awareness and Management Tactics, Techniques, And Procedures (TTP), CGTTP 4-11.6.

4. DISCUSSION. The Lead Hazard Awareness and Management TTP publication identifies specific known sources of potential lead exposure. It describes the consequences of exposure and provides TTP for avoiding exposure. It also structures a unit LHCP that identifies and tracks static (in-place) sources of lead (for example, paint and ballast ingots), and guides units to develop OSHA (Occupational Safety and Health Administration) compliant procedures whenever a work process has the potential to generate a lead exposure hazard, and procedures in the TTP publication are not sufficient to keep workers safe.

This TTP publication was authored and validated by accomplished performers and subject matter experts in the field. TTP publications adhere to a life-cycle maintenance periodicity unless triggered by other revision requirements.

5. DISCLAIMER. This TTP publication is not a substitute for applicable legal requirements, nor is it itself a rule. It is intended to provide guidance for Coast Guard personnel and is not intended to, nor does it, impose legally binding requirements on any party outside the Coast Guard.

6. CHANGES. This TTP publication contains major changes. Review of the entire document is advised due to substantial revisions. A high-level summary of changes is provided below.

1. The TTP publication was restructured to meet new standards implemented by the Safety and Environmental Health Division of the Health Safety and Work-Life Service Center (HSWL SC (se)).

2. Added guidance for lead in Coast Guard housing, including child development centers and unaccompanied personnel housing.

3. Updated training guidance.

4. Updated guidance for the Occupational Medical Surveillance and Evaluation Program

(OMSEP).

5. Added guidance for lead safe work practices, including decontamination procedures, testing of ventilation systems, and lead wipe sampling procedures.

6. Updated the unit Lead Hazard Control Plan template.

7. Created a Lead Hazard Awareness and Management TTP Library page on CGPortal as a repository of related material.

7. DISTRIBUTION. U.S. Coast Guard Force Readiness Command (FORCECOM) Training Division (FC-T) posts an electronic version of this TTP publication to the CGTTP Library on CGPortal. In CGPortal, navigate to the CGTTP Library by selecting Training & Education, then select the TACTICS, TECHNIQUES, AND PROCEDURES link. FC-T does not provide paper distribution of this publication.

8. USCG FORMS. None.

9. REQUEST FOR CHANGES. Field feedback regarding this TTP publication, or any other located in the CGTTP Library, may be provided via email to:

D05-SG-M-FORCECOM-TPTC-PRODUCTFEEDBACK@uscg.mil.

BRYAN J. BURKHALTER

Commander, U.S. Coast Guard Director, Performance Technology Center (FC-Tptc) By Direction of Chief, Force Readiness Command Training Division mailto:D05-SG-M-FORCECOM-TPTC-PRODUCTFEEDBACK@uscg.mil i

Table of Contents

Table of Figures .......................................................................................................................... ii

Table of Tables ............................................................................................................................ ii

Chapter 1: Introduction ........................................................................................................... 1-1

Section A: Introduction ............................................................................................................................. 1-2

Section B: Notes, Cautions, and Warnings ................................................................................................. 1-6

Chapter 2: Administration ....................................................................................................... 2-1

Section A: Program Elements .................................................................................................................... 2-2

Section B: Development and Implementation ........................................................................................... 2-7

Section C: Lead Hazard Control Plan Review ............................................................................................ 2-10

Section D: Training .................................................................................................................................. 2-11

Section E: Recordkeeping ........................................................................................................................ 2-14

Chapter 3: Tactics .................................................................................................................... 3-1

Section A: Introduction ............................................................................................................................. 3-2

Section B: Lead Hazard Identification ........................................................................................................ 3-7

Section C: Lead Hazard Assessment .......................................................................................................... 3-8

Section D: Hazard Mitigation ................................................................................................................... 3-12

Chapter 4: Coast Guard-Wide Techniques and Procedures ................................................ 4-1

Section A: Overview ................................................................................................................................. 4-2

Section B: Written Unit Lead Hazard Control Plan ..................................................................................... 4-3

Section C: Assessing Hazards .................................................................................................................... 4-5

Section D: Mitigating Hazards ................................................................................................................... 4-9

Chapter 5: Shore Techniques and Procedures ..................................................................... 5-1

Section A: Overview ................................................................................................................................. 5-2

Section B: Armories and Firing Ranges ...................................................................................................... 5-3

Section C: Housing and Child Development Centers (CDCs) ....................................................................... 5-6 ii

Appendix A: Glossary and Acronyms .................................................................................. A-1

Appendix B: Housing Lead Risk ........................................................................................... B-1

Appendix C: Personal Protective Equipment (PPE) Selection ........................................... C-1

Table of Figures Figure 4-1 Work flow for reducing lead dust exposure .................................................................................... 4-10

Figure_Apx B-1 CG housing lead risk flowchart ................................................................................................ B-1

Figure_Apx B-2 CG housing lead risk flowchart example .................................................................................. B-2

Table of Tables Table 3-1 Lead evaluation criteria .................................................................................................................... 3-9

Table 4-1 Assessment types and frequencies ................................................................................................... 4-5

Table_Apx C-1 Minimum respirators and PPE required for firing range maintenance tasks ............................... C-1

1-1 Chapter 1: Introduction

Chapter 1:

Introduction

Introduction This chapter overviews the contents of this Coast Guard tactics, techniques, and procedures (CGTTP) publication. It also defines the use of notes, cautions, and warnings in this TTP publication. See Appendix A:

Glossary and Acronyms for an explanation of terms and acronyms used in this TTP publication.

Per reference (a), Development System and Standards Tactics, Techniques, and Procedures (TTP), CGTTP 1-01 (series), “CGTTP is NOT policy and is not used to replace or fix policy gaps.”

In This Chapter This chapter contains the following sections:

Section Title Page

A Introduction 1-2

B Notes, Cautions, and Warnings 1-6

Chapter 1: Introduction 1-2

Section A: Introduction

A.1.

Background

Lead is a heavy, blue-gray colored, elemental metal found naturally in the earth. Historically, lead was used as a gasoline additive and in the production of batteries, paints, ammunition, metal solder, and pipes. Once released into the environment, lead does not break down and tends to accumulate in soil and on surfaces.

Lead exposure usually occurs through inhalation of lead fumes or dust, and ingestion of lead dust through hand-to-mouth contact. Exposure can occur on the job or at home. Childhood lead exposure typically happens through:

• Hand-to-mouth contact of household dust or soil containing lead from deteriorated lead based paint (LBP) applied before 1979.

• Ingesting lead in drinking water.

• Contact with “take-home lead” from parents’ clothing.

• High lead levels in pregnant and lactating mothers.

Lead can affect almost every organ and system in your body. In adults, it can lead to cardiovascular effects, decreased kidney function, and reproductive problems. In children and unborn babies, it can cause behavior and learning problems, and impede growth and development.

Good personal hygiene is the number one way to prevent lead ingestion and the transfer of lead to other areas.

This TTP publication provides United States Coast Guard (USCG) personnel with direction on lead hazard awareness for USCG communities.

Also, this TTP publication includes valuable information for units responsible for a lead hazard control program.

This guidance facilitates increased awareness and practical management techniques. Per reference (b), Safety and Environmental Health Manual, COMDTINST M5100.47 (series), the purpose of this publication is to establish and maintain a lead hazard control program when a hazard analysis has identified potential lead hazards. The Health, Safety and Work-Life Service Center, Safety and Environmental Health Division (HSWL SC (se)) developed this publication to:

• Inform units of lead exposure hazards.

• Communicate established safe work practices for known exposure risks.

• Provide guidance on regulatory compliance.

1-3 Chapter 1: Introduction

A.1.a.

Performance Objective(s)

The lead hazard control program’s performance objectives include effectively implementing the following program criteria:

• Medical evaluations.

• Training.

• Control measures and monitoring procedures.

• Records.

A.1.b. Policy The guidance in this publication complies with policy and regulations in:

• Reference (b), Safety and Environmental Health Manual, COMDTINST M5100.47 (series).

• Reference (c), Lead, 29 CFR § 1910.1025.

• Reference (d), Lead, 29 CFR § 1926.62.

• Reference (e), Lead-Based Paint Poisoning Prevention in Certain Residential Structures, 40 CFR Part 745.

• Reference (f), Lead, 29 CFR § 1915.1025.

Policies and regulations vary according to operational domain. Each operational community chapter provides a list of applicable policies and regulations specific to the operational domain.

A.2. Scope This publication provides a unit designated lead hazard control manager (LHCM) with guidance to develop, implement, maintain, and evaluate an effective lead hazard control program. In addition, per reference (b), this TTP publication outlines techniques, procedures, and resources necessary for development of a written lead hazard control plan (LHCP) at the unit-level.

A.2.a. Operational Community

The following operational community is discussed in this TTP publication:

• Chapter 5: Shore Techniques and Procedures. This includes armories and ranges as well as housing and child development centers.

A.3. Target Audience

This TTP publication provides guidance to all LHCMs, safety officers, assistant safety officers/managers, and training instructors. It applies to all Coast Guard units in government owned or leased facilities.

A.4. Exclusions and Assumptions

This TTP publication assumes the unit has identified the need for a lead hazard management program due to a hazard assessment or other condition listed in reference (b), SEHM. It also assumes the designated LHCM has qualified for the role as explained in reference (b).

Chapter 1: Introduction 1-4

This TTP publication excludes contractors. Contractors are required to provide their own training and lead hazard management program.

A.5. Disclaimer Statement

This TTP publication cannot cover every lead hazard scenario that might arise. Such cases might result in the need to deviate from guidance in this publication. You can deviate from the TTP as necessary to complete the task with greater safety, effectiveness, or efficiency. Do not take such deviations lightly. Temper any decision to deviate with maturity and a complete understanding of the mission, members’ capabilities, and equipment. Whenever possible, consult your unit chain of command before deviation. Report any need for changes to the TTP per the Request for Changes paragraph located in the letter of promulgation.

A.6. Economy of References

The title of the following reference has been abbreviated in this TTP publication from this point forward:

• Reference (b), Safety and Environmental Health Manual, COMDTINST M5100.47 (series), is listed as:

Reference (b), SEHM.

• Reference (g), Guidelines for the Evaluation and Control of Lead- Based Paint Hazards in Housing, Office of Healthy Homes and Lead Hazard Control, U.S. Department of Housing and Urban Development (HUD), Second Edition, July 2012, is listed as:

Reference (g), HUD Guidelines.

A.7. Registered Trademark Disclaimer

The use of registered trademarks in this TTP publication is not an endorsement of these products or companies by the United States Coast Guard (USCG), the Department of Homeland Security (DHS), or the Federal Government. This TTP publication has not been prepared, approved, or licensed by any entity that created or produced products referenced herein. Therefore, any use of third-party logos or trademarks is non-commercial in nature and constitutes a nominative fair use.

A.8. Best Practice

Throughout this TTP publication, the term “best practice” is defined as an innovative or modified practice that results in an improved or more effective response that could merit adoption by other units, platforms, or commands.

1-5 Chapter 1: Introduction

A.9. HSWL SC

(se) TTP Library Pages

HSWL SC (se) maintains resource pages on CGPortal for each of their TTPs. Each TTP library page contains current versions of associated templates, documents, links, tools, and references for a specific HSWL SC

(se) TTP publication. The Lead Hazard Awareness and Management TTP Library page on CGPortal is referenced throughout this TTP publication.

All of the HSWL SC (se) library pages can be accessed on the HSWL SC

(se) TTP CGPortal page.

NOTE:

Personnel preparing for deployment aboard a vessel are advised to download material from the associated TTP Library page for use when connectivity is limited. At a minimum, download the following documents:

Lead Hazard Awareness and Management TTP publication.

Lead Hazard Control Plan Template.

Lead Inventory Worksheet.

https://cg.portal.uscg.mil/units/hswlsc/SafeEvHealth/SitePages/Lead%20Hazard%20Awareness%20and%20Management%20TTP%20Library.aspx https://cg.portal.uscg.mil/units/hswlsc/SafeEvHealth/SitePages/Lead%20Hazard%20Awareness%20and%20Management%20TTP%20Library.aspx https://cg.portal.uscg.mil/units/hswlsc/SafeEvHealth/SitePages/TTPs.aspx

Chapter 1: Introduction 1-6

Section B: Notes, Cautions, and Warnings

NOTE: An emphasized statement, procedure, or technique.

CAUTION: A procedure, technique, or action that, if not followed, carries the risk of equipment damage.

WARNING: A procedure, technique, or action that, if not followed, carries the risk of personnel injury or death.

2-1 Chapter 2: Administration

Chapter 2:

Administration

Introduction This chapter discusses lead hazard control program elements and requirements. It also describes the training required to maintain lead hazard awareness and manage lead hazards.

In This Chapter This chapter contains the following sections:

Section Title Page

A Program Elements 2-1

B Development and Implementation 2-7

C Lead Hazard Control Plan Review 2-10

D Training 2-11

E Recordkeeping 2-14

Chapter 2: Administration 2-2

Section A: Program Elements

A.1. Overview Identification of lead hazards in the workplace is the first step in controlling lead exposure. After identifying the hazard, the LHCM develops, implements, and maintains a unit specific lead hazard control program. The unit program contains written plans to manage the lead hazard in a systematic and risk-prioritized manner.

A.2.

Requirements

Per reference (b), SEHM, all shore, afloat, and aviation units are required to develop and implement a written program using the guidance provided in this TTP publication. Important elements of a unit LHCP include:

• Designation letter of an LHCM.

• An inventory of lead exposure hazards (for example, LBP, lead ballast ingots).

• Task-specific, OSHA-compliant safe work practices for unit operations that generate lead exposure hazards.

• Required training.

• Occupational Medical Surveillance Evaluation Program (OMSEP) enrollments, if applicable.

• Engineering and administrative controls (See Chapter 3: Tactics, Section D: Hazard Mitigation).

• Periodic industrial hygiene surveillance.

• Records.

A.3. Roles and Responsibilities

Reference (b), provides the basis for roles and responsibilities in the unit’s lead hazard control program.

A.3.a. Sector Commanders/ Commanding Officers (COs)/Officers-in-Charge(OICs)

• Maintain resources to support unit LHCP, including:

Lead containing materials/hazards inventory.

Roster of personnel exposed/potentially exposed to lead above the action level (AL).

Records of lead waste disposal.

Completed training for personnel working in areas with potential for lead exposure at or above AL.

2-3 Chapter 2: Administration

Enrollment in OMSEP for personnel who meet requirements.

Implementation of appropriate and timely corrective measures to abate identified hazards.

• Are required to execute the unit’s LHCP, including:

LHCM designated in writing.

Control measures and monitoring procedures for processes using lead or lead containing materials.

Long term plans for the management of lead hazards.

• Are required to execute response actions for major and AL findings, such as:

Shore station maintenance records.

Interim control measures.

Long-term management plans.

Unit housing correction priority.

Unit’s engineering backlog.

• Are not permitted to authorize LBP removal for cosmetic reasons or excessive paint thickness for afloat units.

A.3.b. Base Commanders and Area Housing Authorities

• Maintain resources concerning USCG-owned housing, such as:

Completed Coast Guard Housing Environmental Risk Assessment (ERA) course for personnel who inspect and maintain USCG owned housing.

Inspections of USCG-owned housing for the condition of LBP.

Entries in the Housing Management Information System (HMIS) ERA database.

Abatement of major and AL findings within 1 year and 3 years, respectively.

• Are required to inform USCG housing residents and child development center (CDC) staff regarding:

Potential lead hazards.

Measures to control or abate the lead hazards.

Chapter 2: Administration 2-4

Efforts to identify, assess, and correct identified lead hazards.

• Are required to inform district SEHOs about deterioration of lead containing paint at unit.

NOTE: See Appendix B: Housing/CDC Lead Risk Levels/Findings for further guidance.

A.3.c. Local Housing Officers (LHOs)

• Are responsible for completion of the Coast Guard ERA Lead, Asbestos and Radon (LAR) Housing Inspector course (CG course # 501591) with recertification every 5 years.

• Are required to provide administrative support concerning LBP conditions, such as:

USCG controlled housing pre-inspection/annual housing inspection.

Coordination with area housing authority (AHA)/area housing officer (AHO) or owned housing maintenance coordinators (OHMC) about LBP deterioration.

Signed disclosure letter prior to the initial occupant’s acceptance of quarters.

A.3.d. Surface Forces Logistics Center (SILC)/ Civil Engineering Units (CEUs)

• Maintain verification concerning lead abatement for:

Environmental Protection Agency (EPA)/state-certification of lead abatement contractors.

Abatement of major and AL findings within 1 year and 3 years, respectively.

• Maintain resources for lead inspection prior to approval of housing leases.

• Are required to follow all applicable federal/state regulations and national consensus standards from project planning to disposal phase.

• Are required to notify their district safety and environmental health officer (SEHO) of all lead abatement project proposals, completions, and interim control efficacy.

2-5 Chapter 2: Administration

A.3.e. HSWL SC/

SEHO

• Provide administrative/technical support for unit lead hazard control program, including:

Lead sampling result interpretation, control implementation, and training.

Review of HMIS ERA database for completion of annual CG-owned housing inspections.

Investigations for elevated blood lead level (EBLL) upon EBLL notification via email or phone call.

• Coordinate support activities for USCG housing occupants with:

Unit and AHO to ensure pregnant women and small children in housing with major findings are offered the opportunity to participate in blood lead screenings.

Local health departments when EBLL investigations are initiated.

A.3.f. Lead Hazard Control Manager (LHCM)

• Responsible for providing direction to employees about:

Unit lead hazard control program and written plan.

Inspection of lead containing spaces where personnel work daily to ensure the integrity of containment/encapsulation methods.

Nature of the lead hazards.

Procedures to reduce lead exposure.

A.3.g.

Occupational Medical Surveillance and Evaluation Program

(OMSEP)

Coordinator

• Organize OMSEP activities for USCG personnel, such as:

Requesting enrollment of members.

Completion of examinations in a timely fashion.

Ensuring information on enrollees in the currently used medical readiness database (or other electronic tracking database) is updated.

• Are required to provide the examining medical officer/health care provider with required forms per the Coast Guard Occupational Medicine Manual, COMDTINST M6260.32 (series).

Chapter 2: Administration 2-6

A.3.h.

Supervisors

• Enforce work procedures and policies for employees, including:

Prevention of exposure to lead health hazards.

Required training when working with lead containing materials.

A.3.i. Employees • Follow safe work practices concerning lead hazards, including:

Prevention of exposure to lead hazards.

Completed unit instruction properly identifying lead hazards.

Properly labeled lead hazards per reference (b), SEHM.

Reporting changes to the LHCM, assistant safety officer (ASO) or supervisor if conditions of labeled hazardous material change.

A.4. Definitions • AL – The concentration or physical condition of lead materials can pose an increased human health risk. Findings at the action level require corrective actions to reduce the level to/or below the monitoring level.

• LBP – Paint or other surface coatings that contain lead equal to or in excess of 1.0 milligram per square centimeter, or more than 0.5 percent by weight.

• Lead Containing Paint – Any amount of lead in paint.

• Lead Inspection – A surface-by-surface investigation performed by a state-certified/licensed inspector or risk assessor. The inspection determines whether a coating/paint in a home or child-occupied facility is by EPA definition, LBP, and where it is located.

• Lead Risk Assessment – On-site investigation performed by a state-certified/licensed risk assessor. The assessment determines the presence, type, severity, and location of lead-based paint hazards (in paint, dust, and soil). It also suggests ways to control the hazards.

• Major Finding – The concentration or physical condition of lead materials poses an immediate health risk to occupants (especially sensitive populations) that requires immediate correction.

• Monitoring Level – The concentration or physical condition of lead materials does not pose a health risk to persons or require corrective actions. However, housing staff periodically monitors (at least annually) each lead material to ensure conditions have not changed.

• Presumed LBP – All paint is presumed to contain lead in structures built before 1979.

2-7 Chapter 2: Administration

Section B: Development and Implementation

B.1.

Development

The unit development of an LHCP begins with reviewing the requirements of the Coast Guard policy, reference (b), SEHM, and the applicable EPA and OSHA regulations. Reference (b), contains two chapters pertaining to lead hazards. Chapter 25: Environmental Health Program applies to Coast Guard owned housing, CDCs, and unaccompanied personnel housing (UPH). Chapter 27: Lead Hazard Control Program contains requirements for general industry, shipyards, and construction work.

B.1.a. Lead Hazard Control Manager Designation

The designation of the LHCM is done in writing in the LHCP, command memo, or as part of the unit collateral duty list. Typically, the LHCM is the ASO/Assistant Safety Manager (ASM).

B.1.b. Inventory The unit inventory of lead hazards contains information on lead materials found at the unit and on its assets (lead based paint, ballast ingots, aircraft weights for balancing, etc.) Use the Lead Inventory Worksheet provided on the Lead Hazard Awareness and Management TTP Library page on CGPortal or another means of recording inventory that captures the same information. Include the safety data sheet (SDS) of all lead containing materials (for example, lead solder, lead fittings, lead weights/ballast).

B.1.c. Written Plan

The unit written plan provides information on the lead hazard management program and includes or states where to find:

• Inventory of lead-containing materials.

• List of operations at unit with the potential to generate lead hazard.

• Current roster of personnel exposed to lead above the AL.

• Specific unit procedures to control lead hazards.

• Copies of all lead sampling lab analysis reports.

• Abatement or renovation project’s scope of work, sample results, and clearance results.

• SDS for all lead containing materials.

• Industrial hygiene health risk assessment reports.

• Ventilation survey results.

• Exposure monitoring plan.

• Waste disposal.

https://cg.portal.uscg.mil/units/hswlsc/SafeEvHealth/SitePages/Lead%20Hazard%20Awareness%20and%20Management%20TTP%20Library.aspx

Chapter 2: Administration 2-8

NOTE:

Contact your district SEHO to develop further EPA or OSHA compliant procedures for new operations with the potential to generate a lead exposure hazard.

B.2.

Implementation

After identifying the hazards and developing the written plans, these personnel implement the lead hazard control actions directed in the plans:

• Unit CO.

• Facilities engineers.

• ASO.

• LHCM.

• Personnel exposed to lead hazards.

B.2.a. Training Provide required training and document it in the Training Management Tool (TMT) and/or the unit training logs. Training requirements are detailed in Section D: Training of this chapter.

B.2.b. Medical Surveillance

Per the requirements specified in reference (h), Coast Guard Occupational Medicine Manual, COMDTINST M6260.32 (series), medical monitoring is performed to identify personnel with elevated lead exposures. At risk personnel include personnel performing these types of work activities:

• Aid to navigation (ATON)/lighthouse support.

• Law enforcement/armed security watch.

• Pistol/rifle team and small arms instructors.

• Welders.

Monitoring consists of blood lead level testing which allows medical personnel to identify at risk personnel and intervene to avoid related medical implications. Monitoring begins with an initial (baseline) blood level test. Personnel are monitored per the medical surveillance criteria in reference (h).

NOTE:

Personal air sampling data on CG cutters indicates lead exposures below the medical surveillance criteria. Therefore, afloat crew members do not need to be enrolled in the CG medical surveillance program. See Medical Documentation of Asbestos and Lead Exposures on Coast Guard Cutters Constructed Prior to 1991, HSWLSCTD 2018-006 for additional information.

2-9 Chapter 2: Administration

B.2.c.

Implementing Controls

Engineering and administrative controls are implemented to mitigate the hazard and maintain worker exposures below the OSHA permissible exposure limit (PEL). When occupational exposure limits (OEL) exist below the PEL, strive to mitigate the hazards below the most stringent OEL. See Chapter 3: Tactics, Section D: Hazard Mitigation.

B.2.d. Periodic Industrial Hygiene Surveillance

Periodic industrial hygiene surveys such as personal air monitoring and ventilation assessments are required per reference (b), SEHM, and OSHA.

These surveys validate the effectiveness of the controls in place.

Per reference (b), unit ventilation systems used to control lead exposures or emissions are tested to ensure the systems are performing adequately.

Qualified engineering or industrial hygiene personnel perform the testing.

The minimum frequency is at least every 3 months, but also within 5 days of any production, process, or control change that might result in a change in employee exposure. Where devices to measure fluid velocity (manometers, pitot tubes) are in place, industrial hygiene or engineering personnel only need to inspect the ventilation systems annually.

B.2.e. Maintain Records

Maintaining lead related records ensures key information is easily retrievable and communicated for consistency and continuity of the lead hazard management program. Records that enable the unit to demonstrate compliance with applicable policy and regulations, monitor exposure conditions, and provide records for potential litigation requests include:

• Training.

• Risk assessment.

• Medical.

• Waste disposal.

• Equipment maintenance.

See Section E: Recordkeeping in this chapter for additional information.

Chapter 2: Administration 2-10

Section C: Lead Hazard Control Plan Review

C.1. Evaluation Frequency

The unit LHCP annual evaluation ensures the unit plans and records are documented correctly.

As part of their program review, small arms firing range (SAFR) personnel conduct monthly safety checks of the SAFR. Use the checklist provided in reference (i), Coast Guard Range Training Handbook Tactics, Techniques, and Procedures (TTP), CGTTP 3-30.3 (series).

C.2. LHCP

Revisions

Outside of the annual review, the LHCM updates the plan if any of the following conditions or changes occur:

• Workplace conditions change.

• New LHCM.

• Contracted abatement project.

• Periodic industrial hygiene assessments completed.

• Personnel exposed.

The LHCM updates language in the written LHCP and presents a revised plan to the CO/OIC for concurrence and signature.

NOTE:

If there are no changes to the LHCP, document the completion of the review and the existing LHCP remains in effect. The unit instruction is valid until it is replaced or canceled.

2-11 Chapter 2: Administration

Section D: Training

D.1. Applicable Policy

Policy regarding lead hazard training is found in reference (b), SEHM.

D.2. Training Requirements

Per reference (b), employees must be trained if these conditions exist:

• Potential for lead exposure at or above the AL.

• Possibility of skin or eye irritation exists.

Per reference (b), employees must also be trained if they complete any one of the following tasks:

• Conduct minor repair work in Coast Guard housing with lead hazards present.

• Use engineering controls with installed manometers or pitot tubes.

• Inspect or assess lead based paint risk.

• Plan lead based paint program compliance activities.

• Inspect Coast Guard housing, including UPH and CDCs.

D.2.a. Lead Hazard Awareness

Units provide lead hazard awareness training prior to or at time of initial assignment and at least annually for members where:

• Potential exists for lead exposure at or above the AL.

• Possibility of skin or eye irritation exists.

• Minor repair work is conducted in Coast Guard housing with known or suspected lead hazard.

D.2.b.

Engineering Controls

Train employees who use engineering controls (for example, paint booths, downdraft tables, etc.) where manometers or pitot tubes are installed. As a best practice, train employees at initial assignment and at a minimum annually.

D.2.c. Lead Based Paint Inspector and Risk Assessors

Per reference (b), LBP inspectors and risk assessors are required to successfully complete special training. This training is an EPA accredited LBP inspector/risk assessor course (and/or appropriate state approved training course) for employees who, for the purpose of lead identification, conduct:

• Certified lead based paint inspections.

• Certified lead based risk assessments.

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This training is also highly recommended for employees who plan lead based paint program compliance activities. Per reference (e), Lead-Based Paint Poisoning Prevention in Certain Residential Structures, 40 CFR Part 745, certification must be maintained and recertification shall occur:

• Every 3 years if the individual completed a training course with a course test and hands-on assessment.

• Every 5 years if the individual completed a training course with a proficiency test.

D.2.d. Housing Inspectors

Coast Guard housing inspectors complete the ERA Lead, Asbestos and Radon Housing Inspector course (CG course #501591) and recertify every 5 years.

Newly assigned housing inspectors, maintenance personnel, AHAs, and LHOs are given the highest priority for ERA training. AHAs and LHOs are required to complete ERA training every 5 years after completion of initial training. LHOs are given priority over AHOs for initial and subsequent ERA training.

D.3. Training Objectives

The training objectives for the various types of training are listed in the following sub-sections.

D.3.a. Lead Hazard Awareness

Employees demonstrate proficiency of the following objectives:

• The specific nature of the operations during which exposure is possible.

• The adverse health effects of lead with particular attention to the reproductive effects upon both males and females.

• The purpose and description of the medical surveillance program, including the use of chelating agents and medical removal protection.

• The engineering controls and work practices to be applied and used in the employee’s job, including personal protective equipment (PPE) and personal hygiene measures.

• The purpose, proper selection, fit testing, use, and limitations of respirators.

• The contents of the unit’s LHCP.

D.3.b.

Engineering Controls

Employees demonstrate proficiency of the following objectives:

• Meaning and importance of the manometer or pitot tube measurements.

• Immediately contact the facility engineer if the measuring devices indicate a malfunction.

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D.3.c. Lead Based Paint Inspector and Risk Assessor

Employees demonstrate proficiency of the following objectives:

• Determine and locate presence of lead-based paint.

• Assess risk of lead based paint.

D.3.d. ERA Lead, Asbestos, and Radon Housing Inspector

Employees demonstrate proficiency of the following objectives:

• Identify through visual inspection, different levels of monitoring required for lead based paint.

• Read, understand, and use the environmental risk assessment report.

• Categorize housing units.

• Select appropriate disclosure requirements.

• Assemble appropriate report information.

• Educate residents on environmental dangers and safety precautions.

D.4. Training Resources

SkillPort provides online courses including:

• Lead Awareness in General Industry.

• Lead Awareness in Construction.

• Lead and Cadmium.

https://uscg.skillport.com/skillportfe/main.action#whatshappening

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Section E: Recordkeeping

E.1. Records Maintenance

Per reference (b), SEHM, the following records are required to be maintained either electronically or in a binder:

• Inventory of static lead exposure hazards.

• List of operations at the unit with the potential to generate lead hazard.

• Current roster of personnel exposed to lead above the AL.

• Copies of all lead sampling lab analysis reports.

• Abatement project’s scope of work, sample results, and clearance results.

• SDSs for all lead containing materials.

• Industrial hygiene health risk assessment reports.

• Ventilation survey results.

• Exposure monitoring plan.

• Waste disposal records.

E.2. Duration Maintain lead-related records per reference (c), Lead, 29 CFR 1910.25:

• Lead exposure monitoring – at least 40 years or the duration of employment plus 20 years, whichever is longer.

• Occupational medical surveillance – at least 40 years or the duration of employment plus 20 years, whichever is longer.

• Personnel training – duration of employment plus 1 year.

• Hazardous waste processing, management, and disposal – permanently.

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Chapter 3:

Tactics

Introduction This chapter describes tactics used to identify, assess, and mitigate lead exposure hazards.

NOTE:

This TTP publication contains up-to-date safe procedures for lead at the time of publication. As standards and practices change, newer guidance is developed. If there is a discrepancy between this publication and other guidance [for example, maintenance procedure cards (MPC) or HSWL SC (se) Safe Work Practices (SWP)], use the most current procedures that apply to your work environment.

In This Chapter This chapter contains the following sections:

Section Title Page

A Introduction 3-2

B Lead Hazard Identification 3-7

C Lead Hazard Assessment 3-8

D Hazard Mitigation 3-11

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Section A: Introduction

A.1. Overview:

Lead Hazards

Lead is a concern in various areas of the Coast Guard, from CG-controlled housing to cutters and firing ranges. Evaluations identified gaps in documentation records, condition inspections, and control implementation.

Assessment findings include:

• Substantial lead in surface dust, failing paint, and contaminated soil at several CG-controlled housing units.

• Concentrations of lead dust above OSHAs recommended levels on USCG cutters including icebreaker, buoy, and construction tenders (IBCT), medium endurance cutters (MEC), and long range enforcers

(LRE).

• Aid to navigation teams (ANTs) encountering lead dust hazards while performing maintenance at lighthouses.

Examples of hazard controls the USCG employs to decrease the risk of lead exposures include:

• Improving ventilation airflow at indoor small arms firing ranges.

• Confirming lead content before removing lead based paint.

• Following safe work practices onboard cutters with lead ingot ballast.

The Coast Guard continues to improve policy and this TTP publication in order to facilitate increased awareness and practical management techniques of lead hazards.

A.2. Common Lead Hazards

Common sources of lead exposure to Coast Guard personnel include:

• Paint removal and other disturbance of surfaces with coatings containing lead including:

Power sanding.

Sandblasting.

Needle-gunning.

Dry sweeping lead dust.

• Lead ingot ballast on Coast Guard cutters.

• Handling lead batteries.

• SAFR activities.

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• Soldering.

• Industrial activities such as plumbing and pipefitting.

• Welding on galvanized steel, with consumables, or on surfaces containing lead.

Many other possible exposure sources include:

• Shooting and maintaining personal firearms.

• Using molten lead to cast ammunition, make fishing weights, or other purposes.

• Making stained glass with lead solder.

• Handling lead glazes for making pottery.

• Using some platinum printing and screen-printing materials.

• Lead in drinking water.

A.2.a. Lead in Armories and Firing Ranges

Working at or visiting armories, firearms training facilities, and firing ranges is known to present a lead exposure risk. Several different components of ammunition can contain lead, such as the projectile and primer. When firing a weapon, the lead can vaporize into the air. A bullet traveling down the barrel creates heat and friction forces that eject lead particles in close proximity to the shooter which is an inhalation hazard.

Primer, which is responsible for creating propulsion of the bullet, also contains lead. Dust and fumes originating from the primer is released in close proximity to the shooter. Lead can also be released when a bullet strikes a backstop or other surface. Cleaning a firearm causes exposure to lead dust as well.

Lead dust is heavy and tends to settle out of the air quickly. Accumulations of lead dust at shooting ranges poses additional exposure risk, especially to personnel tasked with cleaning the facility.

A.2.b. Industrial Operations

Lead ingots are used within the bilge of cutters and aircraft ailerons and sometimes need to be removed prior to the completion of industrial operations. Some lead ingots have been enclosed and encapsulated, however, some remain exposed. Over time, friction can create lead dust and create the potential for inhalation exposures.

Lead dust and fumes are produced during sanding, grinding, needle-gunning, and abrasive blasting processes on surfaces containing lead or

LBP.

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Welding on metal that contains lead can produce fumes containing lead oxides. Personnel who perform soldering are also at risk of being exposed to lead fumes. Solder material used on common electronics can contain up to 40 percent lead.

WARNING:

LBP can emit toxic lead fumes if not properly removed prior to conducting hot work. Per reference (b), SEHM, units shall minimize hot work as a means to remove areas of LBP. Units performing hot work on lead materials must ensure personnel exposure does not exceed the PEL.

A.2.c. Housing and CDCs

Approximately three-quarters of the nation’s housing built before 1979 (approximately 64 million dwellings) contains some LBP. When properly maintained and managed, this paint poses little risk. However, in 2010, the Centers for Disease Control and Prevention estimated 535,000 cases of elevated blood lead levels in children ages 1-5, many of which are due to LBP hazards. When LBP is on exterior surfaces it can degrade and contaminate the soil as well.

Lead can enter drinking water when plumbing materials that contain lead corrode. This is especially true in systems where water has high acidity or low mineral content. The most common sources of lead in drinking water come from lead pipes, faucets, and fixtures. Lead solder used in a water system can also be a source of lead contamination.

Additional household items and hobbies can contribute to lead exposures, including toys, lead batteries, fishing weights, and leaded glass windows.

NOTE:

Per reference (j), Ban of Lead-Containing Paint and Certain Consumer Products Bearing Lead-Containing Paint, 16 CFR Part 1303, paint or any similar surface coatings for children's products, some furniture, and consumer use, must not contain a concentration of lead greater than 0.009 percent (90 parts per million).

A.2.d.

Construction (Not Housing or CDCs)

Coast Guard personnel can be exposed to LBP while performing routine maintenance at lighthouses, renovating facilities built before 1979, or from deteriorating lead containing material that becomes an airborne or dust hazard.

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Construction work is defined as work for construction, alteration, or repair.

Examples of construction work include:

• Painting and decorating.

• Installation of products.

• Demolition or salvage of structures.

• Removal or encapsulation of materials.

• New construction, alteration, repair, or renovation of structures, substrates, or portions thereof.

• Transportation, disposal, storage, or containment of materials on the site or location at which construction activities are performed.

• Maintenance operations associated with the construction activities listed above.

A.2.e. Aviation Lead weights control flight balancing in the elevator, aileron, and rudder of the HC-144A aircraft. During periodic depot level maintenance, employees check and adjust the balance as necessary. This can involve removal or installation of lead weights. Friction between the weights during aircraft movement creates lead dust. This dust can become airborne during disassembly of the aircraft part. In addition, machining (drilling) the lead to install or adjust a weight produces lead dust. Lead weight installation and placement is inconsistent. Therefore, absence of lead weights in a particular location does not necessarily indicate a total absence of lead.

Although the manufacturer might not identify lead as part of the brake assembly composition in the SDS, there is lead in C-130 aircraft brake assembly parts. Dust can accumulate on the brakes after many touch-and-go maneuvers and short-field tactical landings where the brakes are used heavily. Lead exposure is then possible when workers are handling these parts. Measured levels of lead dust on workbench surfaces indicates a significant amount of contamination that poses a skin contact and ingestion hazard. At this time, it is unknown if other airframes are affected.

A.3.

Adverse Health Effects

Lead’s presence in the body can lead to adverse health effects and can affect every human organ system. Lead exposure can be from lead dust or lead fumes. Upon exposure to lead, red blood cells distribute lead to the soft tissues and bones, where it can remain for years to decades. Over time, the bones slowly release and excrete lead as a continued internal exposure.

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Children, including unborn children, are particularly susceptible to adverse health effects and shows signs of toxicity at lower levels than adults due to their physiological differences. There is no known blood lead level for children without some level of risk for adverse neurological effects. Low levels of lead exposure can impair mental and physical growth, and cause learning and behavioral problems. Lead inhibits children from absorbing iron, zinc and calcium, which are essential to brain and nerve development.

Childhood lead poisoning can lead to the following health effects:

• Attention-related behavioral problems.

• Decreased cognitive performance.

• Developmental problems with their offspring.

• Anemia.

• Muscle weakness.

• Hypertension.

• Renal effects.

• Reproductive problems.

Lead exposure in adults produces many of the same health effects as in children, but at higher blood lead levels (BLL). Exposure to high levels of lead severely damages the brain and kidneys and can result in death.

Exposure to low and moderate levels of lead over time can cause:

• Decreased nervous system performance.

• Weakness in fingers, wrists, or ankles.

• Increased blood pressure.

• Impaired blood formation and anemia.

• Reproductive system impairment including:

Reduced…