xLead Paint November 2012.pdf

Commanding Officer United States Coast Guard Health Safety and Work-Life Services Center

Rockmore-King Clinic, BLDG N46 PO Box 195002 Kodiak, AK 99615 Staff Symbol: (se-fo) Phone: (907) 487-5757 Fax: (907) 487-5360

30 November 2012

MEMORANDUM

From: H. Hurst, LCDR USCG HSWL SC (se-fo) det Kodiak

Reply to Attn of:

HSC Armando Martinez 907-487-5757 x133

To: CGC Alex Haley (WMEC 39)

Subj: LEAD PAINT SURVEY AND ANALYSIS

Ref: (a) Safety and Environmental Health Manual, COMDTINST M5100.47

1. On 01 November 2012, USCGC ALEX HALEY requested a survey of surface paint in various locations scheduled for maintenance (surface preparation and refinishing). In accordance with ref (a), HSC Martinez provided on-site evaluations of paint condition on specific locations identified by unit personnel. Given the estimated age of the existing finishes there is potential concern for lead (Pb) content in the paint.

2. In conclusion to quantitative assessments, my office has determined there was lead content present in the paint on six (6) of the 19 areas tested. Measurements collected using a portable XRF (X-ray fluorescence) Analyzer reveal the lead content in the paint ranges from 3.16 – 1.2 milligrams per centimeter squared (mg/cm

). The paint appeared intact and in fair condition with exception of the forward line locker deck where the paint has been mostly worn away. Refer to Enclosure (1) for complete details of survey results.

3. We look forward to providing continually improving safety and environmental health support to your unit. If there are any questions, or the need arises for additional support, please contact us 907-487-5757, ext. 138 (or) 133.

4. DON’T LET YOUR “GUARD” DOWN.

Enclosure: (1) Lead Paint Survey – CGC ALEX HALEY (WMEC 39)

Copy: HSWL SC (se) HSWL SC (se-fo) Det Kodiak

UNITED STATES COAST GUARD

HEALTH RISK ASSESSMENT REPORT

USCGC ALEX HALEY (WMEC-39)

Kodiak, Alaska

Lead Paint Evaluation

November 20, 2012

HSWL SC (se-fo) Detachment Kodiak Rockmore-King Clinic, BLDG N46

PO Box 195002 Kodiak, Alaska 99615

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TABLE OF CONTENTS

Table of Contents

Preface

Acknowledgments and Availability of Report

Introduction

Background

Weather Conditions

Methods

Evaluation Criteria

Results

Table I. Results of Surface Lead Content Photograph 1. Port Tow Bin, AFT Steering Photograph 2. 1-25-0-L Passageway Bulkhead, Starboard side Photograph 3. 1-25-0-L Passageway Bulkhead, Port side Photograph 4. Cover Plate, Damage Control Central Photograph 5. Paint Locker Water-Tight Door Photograph 6. Line Locker Water-Tight Door and Bulkhead 61 Photograph 7. Machine Shop Photograph 8. 1-17-1-L Passageway Bulkhead, Starboard side

Discussion

Conclusion

Recommendations

Study Limitations

References

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PREFACE

The Health, Safety, and Work-life Service Center (HSWL SC) Safety and Environmental Health Detachment Kodiak conducts field investigations of possible health hazards in the workplace in accordance with the US Coast Guard’s Safety and Environmental Health Manual, COMDTINST M5100.47.

Any mention of company names or products within this report does not constitute endorsement by Department of Homeland Security or the US Coast Guard.

ACKNOWLEDGMENTS AND AVAILABILITY OF REPORT

LCDR Harold Hurst and HSC Armando Martinez from HSWL SC (se-fo) Detachment Kodiak performed data collection and prepared this report. HSWL SC staff completed the peer review of this document.

A copy of this report has been sent to US Coast Guard Cutter Alex Haley Commanding Officer. To request a copy of the report, please call or send correspondence to the address provided below:

HSWL SC (se-fo) Detachment Kodiak Rockmore-King Clinic, BLDG N46

PO Box 195002

Kodiak, Alaska 99615

(907) 487-5757

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INTRODUCTION

On November 01, 2012, LCDR Harold Hurst and HSC Armando Martinez conducted a site visit to the US Coast Guard Cutter (CGC) ALEX HALEY to evaluate suspected presence of lead containing paint (LCP) on surfaces scheduled for maintenance by Coast Guard personnel. The Cutter Deck Division Officer requested an assessment of the potential to release lead dust from surface paints designated for abrasive removal prior to recoating.

BACKGROUND

The CGC ALEX HALEY is the only 282-foot Medium Endurance Cutter (WMEC-39) in the US Coast Guard fleet. The Cutter performs primary missions of Fisheries Law Enforcement and Search and Rescue (SAR) from its home port in Base Kodiak, Alaska. The former US Navy vessel was laid down in 1967 and was originally commissioned in 1971; the vessel was converted from a salvage ship to a Cutter and recommissioned by the Coast Guard in 1999. Many of the vessel building materials used at the time of production are now considered to be potentially hazardous to health.

The specific health concern of this investigation is personnel exposure to lead dust released from surface coatings during dock side maintenance. Exposure to lead occurs via inhalation of dust and fume, and ingestion through contact with lead-contaminated hands, food, water, and clothing. Absorbed lead accumulates in the body in the soft tissues and bones. Lead is stored in bones for decades, and may cause health effects long after exposure as it is slowly removed from the body.

Symptoms of lead poisoning include loss of appetite, excessive fatigue, irritability, constipation, abdominal pain, and tremors. Overexposure to lead may result in kidney damage, anemia, impotence, infertility and reduced libido. Lead exposure is associated with fetal damage in pregnant women and can lead to miscarriage or stillbirth. Even very low concentrations of lead are devastating to fetuses and young children due to potentially irreversible toxic effects on the developing brain and nervous system.

Many occupational lead exposures have been found responsible for cross-contamination of workers’ homes whereby exposing their families to lead dust.

Results from historical sampling performed on the CGC ALEX HALEY have revealed existing LCP on bulkheads, decks, and other infrastructure. In consideration of the vessel age and known existence of LCP, the Cutter Command policy is to require completion of a health risk assessment (HRA) prior to commencing surface maintenance operations where lead may be released. The surfaces analyzed for lead were identified for evaluation due to the existing paint would require abrasive removal whereby potentially exposing personnel to airborne dust.

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WEATHER CONDITIONS

Weather conditions on November 01, 2012 during the HRA were the following:

Temperature: 3.8oC (25oF) Barometric Pressure: 750 mm Hg (29.55 inches Hg) Relative Humidity: 79% Dew Point: 2.2oC (28oF) Wind Speed: <10 mph Wind Direction: T220 Visibility: 10 miles

METHODS

This assessment was conducted in two phases in order to evaluate the current condition of surfaces and the lead content of the existing coatings. First, a visual inspection and picture evidence was completed to document the condition of the surface paint in the areas specified by Cutter Deck Division personnel.

Following the visual inspection, surface paint was evaluated for presence of lead by quantitative measurements using a direct reading instrument. A lead paint analyzer was used (Thermo NITON Portable X-Ray Fluorescence (XRF) Analyzer; Model XLp 303A, Serial Number 22396) to measure lead concentration in milligrams of lead per square centimeter of surface area (mg/cm2). The application of XRF method allows for measurement of lead concentration directly by determining the absorption of radiation by lead particles. A calibration check was performed before taking measurements on different materials or coatings; calibration limits are accurate within + 0.06 mg/cm2. Equipment operation procedures were conducted in accordance with manufacturer instructions (Thermo Electron Corporation, 2006). The protocol used in selecting a sample site for a given component was based on a testing grid with equally approximated distances according to the size of the component analyzed, e.g. bulkheads were sampled at varying heights from the deck, equilaterally across the face of the bulkhead. Lead content was derived by calculating an average from all sites analyzed on a component.

EVALUATION CRITERIA

In accordance with COMDTINST M5100.47, Commands must ensure all Coast Guard personnel comply with Occupational Safety and Health Administration (OSHA) regulations, including military personnel performing operations and activities not uniquely military (e.g., industrial activities).

For compliance with regulatory lead exposure standards, OSHA does not define “lead paint” based on a minimal amount of lead content. Any detectable amount of lead in paint requires instituting personnel protective measures to comply with OSHA regulations. When paint is determined to contain lead, the Coast Guard and contractor personnel must be notified of its presence and must comply with lead safe work practice requirements, as defined in 29 Code of Federal Regulation (CFR) 1910.1025 (OSHA General Industry Lead Standard); and 29 CFR 1915.1025 (OSHA Shipyard Employment Standard for Lead). All lead containing waste must be disposed in compliance with federal, state, and local regulations.

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RESULTS

Visual Inspection

All the paint coatings identified for analysis were applied over metal substrate. Paint colors identified in Table (I) below are described with the top most, surface paint color listed first and the undercoat colors listed in order of visual prominence. The paint condition observed for all the surfaces evaluated was poor. Visual inspection of the painted surfaces found varying severity of damage to the paint coatings.

Damage to paint surfaces includes visual evidence of abrasion, chipping, and/or peeling as pictured in Photographs 1 - 8.

Direct Reading Data

In Table (I) below, the quantitative results of the XRF analysis are listed in order of decreasing lead content for the components tested in each of the nineteen (19) locations. The results are expressed as the calculated average lead content in milligrams lead per square centimeter of surface area (mg/cm2).

Components positive for lead content are displayed in Photographs 1 - 8; the approximate sampling areas targeted for testing on each component are illustrated in the photographs.

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Table I. Results of Surface Lead Content

LOCATION COMPONENT PAINT COLOR LEAD CONTENT

(mg/cm2)

1-25-0-L STB BULKHEAD WHITE 3.16

PAINT LOCKER WTD WHITE WITH RED,

GREEN 2.66

FWD LINE LOCKER FRAME 61 BULKHEAD

AROUND WTD

WHITE WITH RED,

GREEN 2.48

PORT TOW BIN RAILS BLACK WITH RED,

GREEN 2.23

FWD LINE LOCKER WTD WHITE 2.16

1-25-0-L PORT BULKHEAD WHITE 1.2

DC CENTRAL COVER PLATE ORANGE WITH GREEN,

BLUE 0.83

FWD LINE LOCKER FRAME 60 BULKHEAD

AROUND WTD

WHITE WITH RED,

GREEN 0.26

1-17-1-L

STB PASSAGEWAY BULKHEAD WHITE 0.23

MACHINE SHOP DECK RED WITH GREEN 0.19

AFT STB LINE LOCKER WALL RED 0

AFT PORT LINE LOCKER WALL RED 0

PORT TOW BIN WALL,

INTERIOR BLACK WITH RED 0

GYM DECK GRAY WITH GREEN 0

2-33-0-L STB BULKHEAD WHITE 0

AFFF DC SHOP BULKHEAD WHITE 0

1-25-0-L

FWD WATCHBOARD BULKHEAD WHITE 0

FWD FREEZER DECK RED 0

FWD LINE LOCKER DECK MULTIPLE 0

*NOTE: WTD – Water Tight Door; DC – Damage Control; FWD – Forward; STB – Starboard.

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Photograph 1. Port Tow Bin, AFT Steering

Exterior Rails: Black with red, green paint

Interior: Black with red paint

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Photograph 2. 1-25-0-L Passageway Bulkhead, Starboard side

Bulkhead: White paint

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Photograph 3. 1-25-0-L Passageway Bulkhead, Port side

Photograph 4. Cover Plate, Damage Control Central

Cover Plate: Orange with green, blue paint

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Photograph 5. Paint Locker Water-Tight Door

(View from inside the Line Locker)

Bulkhead: White paint

WTD: White with red, green paint

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Photograph 6. Line Locker Water-Tight Door and Bulkhead 61

Photograph 7. Machine Shop

Deck: Red with green paint

WTD: White paint

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Photograph 8. 1-17-1-L Passageway Bulkhead, Starboard side

DISCUSSION

While the results of the direct reading analysis indicates the specific areas listed in Table (I) have lead in the paint, all surface coatings onboard the CGC ALEX HALEY are suspect for lead content unless tested and shown to be completely free of lead. Many years of repainting for routine maintenance and spot resurfacing treatments has resulted in a myriad of different coatings, even on individual components. For example, lead containing paint was found to entirely cover the Forward Line Locker water tight door yet was sporadically detected on either side of the bulkhead radiating out for varying distances in a perimeter around the water tight door. The findings of this assessment also indicate any painted surface may contain lead in one or more layers of the paint matrix. Among the various paints on the line locker tow bin, it was the rails (with black topcoat and green, red undercoating) which was found to contain lead whereas the bin interior paint (black surface paint with red undercoat) was free of lead. In consideration of these variables in component coatings, the airborne release of lead dust can only be prevented by testing a specific surface prior to performing maintenance on the same surface.

Air sampling studies conducted by OSHA, National Institute of Occupational Safety and Health (NIOSH), and the US Navy have found an inverse relationship between the measured lead concentrations in paint and the resulting airborne lead concentrations during removal operations (Zedd et al., 1993). The studies revealed airborne lead concentrations may exceed permissible exposure limits (PEL) even when concentrations in paint are below the regulatory action level of 1.0 mg/cm2. These

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Lead Paint Evaluation Page 14 studies further noted airborne lead concentrations during paint removal were highly variable. Removal methods, individual work practices, environmental conditions, and the use of engineering controls were the most significant variables affecting worker exposure.

CONCLUSION

The CGC ALEX HALEY has many surface coatings which must be considered as lead containing paint.

Although some of the painted surfaces analyzed were found to contain relatively low concentrations of lead, any concentration detected may result in the generation of hazardous lead dust levels during surface maintenance operations. During maintenance on surfaces, personnel protective measures and other appropriate safe work practices should be implemented to ensure airborne levels of potential contaminates are controlled below permissible exposure levels.

RECOMMENDATIONS

Below are recommendations for reducing the possibility of exposure to lead dust released from surface coatings or paint:

1. Personnel who will be supervising or involved in the maintenance of surfaces onboard the CGC ALEX HALEY should be provided copies of this report and informed of the results. Command personnel should ensure report findings are documented in the Cutter Organization Manual and locations of LCP be inventoried for reference before performing future maintenance.

2. Disturbing LCP by Coast Guard personnel is not recommended since any amount of lead content may expose personnel to hazardous airborne concentrations. To ensure safety of personnel, removal of paint containing lead requires engineering controls and personal protection equipment; unless air monitoring has show airborne concentrations of lead do not exceed the PEL of 50 micrograms per cubic meter of air (μg/m3).

3. Treat all surface coatings as lead containing material until proven otherwise by results from analytical sampling.

4. The District Seventeen Safety and Environmental Health Officer (SEHO) should be consulted before Coast Guard members are permitted to disturb surface coatings onboard the CGC ALEX HALEY. The SEHO can assist with compiling a lead safe work plan, implementing human exposure and pollution prevention control measures (i.e. barriers, wet methods, personal protective equipment, etc.), training, and conducting air sampling to evaluate lead concentrations in breathing air.

5. Consult Base Kodiak Hazardous Waste Manager prior to the dock side removal and disposal of any materials which may be contaminated with lead.

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STUDY LIMITATIONS

The results of this study are only applicable to the specific location analyzed onboard the CGC ALEX HALEY and environmental conditions which existed at the time of sampling. Caution must be exercised should surfaces be disturbed which were not previously evaluated during this project.

Potential sources of systematic (bias) error during the performance of this HRA may include the following:

1. Unintentional preference for sample sites and/or analysis of select surfaces.

2. Inherent measurement errors associated with the NITON Portable XRF Analyzer.

Note: The findings and conclusions in this report cannot be used to designate work areas safe for non- Coast Guard, third-party contractors or any other entity hired to carry out work for the Coast Guard.

REFERENCES

1. Thermo Electron Corporation. (2006). NITON XLp 300 Series Analyzer: User’s Guide. Waltham, MA.

2. Occupational Safety and Health Administration. General Industry Lead Standard, 29 CFR 1910.1025.

3. Occupational Safety and Health Administration. Shipyard Employment Standard for Lead, 29 CFR

1915.1025.

4. US Coast Guard. (2006). Safety and Environmental Health Manual, COMDTINST M5100.47.

Washington, D.C.

5. Zedd, H., et al. (1993). Department of the Navy, Navy Environmental Health Center. Lead

Exposures during Shipboard Chipping and Grinding Paint-Removal Operations. American Industrial Hygiene Association Journal, 54 (7): 392 - 396.