Attachment 5-Lead-based Paint Operations and Maintenance Plan (Exhibit 5).pdf

Lead-based Paint Operations and Maintenance Plan

U.S. Army, Fort Buchanan, Puerto Rico

U.S. Army Corps of Engineers

PD Environmental Branch, Jacksonville

Contract No. DACW17-00-D-0002

Delivery Order 0004

Updated Version

November 2019

LEAD-BASED PAINT OPERATIONS AND MAINTENANCE PLAN

FORT BUCHANAN, PUERTO RICO

Updated Version November 2019

PLAN REVIEWED AND APPROVAL

_________________________________________________________ Dated: _______________

MR. ANIBAL NEGRON

Chief Environmental Division

USAG Fort Buchanan PR 00934

Executive Summary

J. J. Sosa & Associates, Inc. was retained by the U.S. Army Corps of Engineers, Mobile District, to develop an operations and maintenance (O&M) Plan to address the management of all lead-based paint (LBP) remaining in Fort Buchanan structures. This O&M Plan was prepared by J.J. Sosa and Associates, Inc.

(JJSA). The management plan objectives involve defining the requirements to protect building occupants, workers performing LBP abatement activities, and maintenance personnel at Fort Buchanan.

Fort Buchanan is an Army installation located in San Juan, Puerto Rico, under the major command of U.S.

Army Reserve Support Command. Existing structures at the Fort Buchanan date back to the 1940s. Most of the facilities have been renovated or replaced over the years. More than 230 operational buildings and over

360 housing units for soldiers and their families stationed at Fort Buchanan currently exist at the installation.

Limited LBP survey data indicates that there is LBP present in the exterior of various operational buildings as well as in some family housing.

It is the desire of Fort Buchanan to prevent unnecessary exposure to LBP by employees, tenants, and other visitors to the facility. No employees, tenants, outside contractors, or visitors shall engage in any activity that will disturb LBP within the facility. Any activity that could disturb LBP must be approved by the Fort Buchanan LBP program manager (LPM). Disturbance of LBP will be conducted in accordance with the administrative procedures and work practices contained herein or by independent licensed LBP abatement contractors working pursuant to contract agreements.

The LPM for Fort Buchanan is Mr. Anibal Negron. The LPM will have responsibility for this LBP O&M Plan. The LBP management program will remain in force as long as LBP remain in the facilities at Fort Buchanan.

Contents

SECTION PAGE

Executive Summary in

Contents v

Lead-based Paint Operation and Maintenance Title Sheet ix

Assumptions, Limitations, and Conditions xi

List of Acronyms xiii

Introduction 1-1

Description of Lead-based Paint 1-1

Identifying Lead-based Paint 1-I.

Health Concerns 1-2

Overview of Applicable Federal and State Regulations 1-2

HUD Regulations and Guidance for Residential Housing 1-3

EPA Regulations and Guidance for LBP 1-4

OSHA Regulations for Worker Protection from LBP 1-6

Puerto Rico Environmental Quality Board Regulations 1-7

Program Description 2-1

Program Management Responsibilities 2-1

Lead Program Manager 2-1

Inspector 2-2

Antilles Consolidated School System Environmental Officer 2-2

Design Engineer 2-3

O&M Division Chief 2-3

Industrial Hygienist 2-3

Location of Lead-based Paint 2-3

Administrative Procedures 3-1

AP1-Worker Training, Exposure Assessment, and Medical Surveillance 3-2

Required Training 3-2

Training at Fort Buchanan 3-2

Assessing Exposure 3-3

Medical Surveillance Program 3-4

AP2-Notifications and Labeling 3-7

Worker Warning Signs 3-7

Employee Awareness Notification 3-7

Residential Disclosure Notification 3-7

AP3-Periodic Surveillance and Re-inspection 3-9

Periodic Surveillance 3-9

Re-inspection Program 3-9

AP4-Work Permit Program 3-10

AP5-Recordkeeping and Forms 3-13

Form 1. Verification of Employee Training Certification 3-15

Form 2. Record of LBP Awareness Training 3-16

Form 3. Sample Information Letter to Tenants/Occupants 3-17

Form 4. Periodic Surveillance Log 3-18

Form 5. Job Request Form for Maintenance Work 3-19

Form 6. Maintenance Work Authorization Form 3-20

Form 7. Work Evaluation Form 3-21

AP6-Selection of Personal Protective Equipment and Decontamination 3-22

Procedures

Protective Clothing and Equipment 3-22

Decontamination 3-22

Respiratory Protection 3-23

AP7-Waste Classification and Disposal Requirements 3-25

Hazardous Waste Determination 3-25

Hazardous Waste Containment, Shipping, and Disposal 3-20

AP8-Lead-based Paint Testing 3-27

Lead-based Paint Testing 3-27

Dust Wipe Sampling 3-28

Clearance Testing Following Lead-based Paint Work 3-30

Selecting Consultants and Laboratories 3-31

AP9-Recommended Housekeeping Procedures 3-32

Cleaning Floors 3-32

Cleaning Carpets and Rugs 3-32

Cleaning Walls and Other Surfaces 3-33

Specialized Work Practices 4-1

Selecting Work Practice 4-1

Determining Work Practice Levels 4-2

General Procedures for Level 1 4-2

General Procedures for Level 2 4-5

General Procedures for Level 3 4-6

WP-1 Removing Paint Chips and Debris 4-10

Description 4-10

Examples 4-10

Work Practice 4-10

WP-2 Cleaning Damaged or Deteriorated Surfaces 4-12

Description 4-12

Examples 4-12

Work Practice 4-12

WP-3 Removing Small Areas of Paint 4-14

Description 4-14

Examples 4-14

Work Practice 4-14

WP-4 Wet Sanding 4-16

Description 4-16

Examples 4-16

Work Practice 4-16

WP-5 Penetrating Lead-based Paint 4-17

Description 4-17

Examples 4-17

Work Practice 4-17

WP-6 Removing Components from Lead-painted Surfaces 4-20

Description 4-20

Examples 4-20

Work Practice 4-20

WP-7 Attaching to a Lead-painted Surface 4-22

Description 4-22

Examples 4-22

Work Practice 4-22

WP-8 Applying Coatings to Lead-painted Surfaces 4-24

Description 4-24

Examples 4-24

Work Practice 4-24

WP-9 Installing Materials Over Lead-painted Surfaces 4-26

Description 4-26

Examples 4-26

Work Practice 4-26

WP-10 Enclosing a Lead-painted Surface 4-28

Description 4-28

Examples 4-28

Work Practice 4-28

WP-11 Patching a Lead-painted Surface 4-30

Description 4-30

Examples 4-30

Work Practice 4-30

WP-12 Exposing Lead Paint-contaminated Cavities 4-33

Description 4-33

Examples 4-33

Work Practice 4-34

WP-13 Door and Window Maintenance 4-36

Description 4-36

Examples 4-36

Work Practice 4-36

WP-14 Changing Filters and Waste Bags In HEPA Vacuums 4-40

Description 4-40

Examples 4-40

Work Practice 4-40

WP-15 Cleaning or Removing Contaminated Carpet 4-42

Description 4-42

Examples 4-42

Work Practice 4-42

WP-16 Landscaping in Soil Containing Elevated Levels of Lead 4-44

Description 4-44

Examples 4-44

Work Practice 4-44

References 5-1

EPA Publications 5-1

HUD Publications 5-1

OSHA Publications 5-2

Military Publications 5-2

Commonwealth of Puerto Rico Publications 5-2

Exhibits

2-1 Lead Program Management Personnel

2-1

3-1 Work Permit Program Checklist 3-12

3-2 Respiratory Protection for Lead Aerosols 3-24

LIST OF APPENDICES

A Glossary

B Inventory of Lead-based Paints in Operational Buildings, Fort Buchanan, Puerto Rico

Assumptions, Limitations, and Conditions

O&M Program Assumptions The O&M Manual assumes that all elements of the O&M program listed below are considered and all applicable elements have been established and the programs in place. References to related information are included in Section 5.

Lead-based paint (LBP) program manager appointment and training

Building inspection and assessment

Copies of applicable regulations and guidance documents

Hazard communication program

Historical air monitoring data

Confined space entry program

Safety program for other hazards

All O&M related programs should be reviewed periodically and revised if necessary. Regulatory and guidance documents should also be reviewed periodically to ensure that they are current.

Limitations and Conditions This Plan was developed as reference for persons responsible for performing and/or directing approved O&M Work

Practices. Use of this Plan will assist in providing response actions required to manage LBP in-place. Use of the Plan does not guarantee that the quality of work will be equal to or better than if completed by a qualified independent contractor. JISA make no warranty or guarantee, expressed, or implied, with respect to work performed by Fort

Buchanan workers or contractors using the Plan. JJSA does not assume any liability for the use of any information, methods, or materials contained herein, or for damages arising from such use; neither JJSA assume any responsibility for any injury to individuals or property, or for any financial loss, sustained as a result of the use or application of this document.

Note that:

O&M activities involving LBP may involve health risks to those performing them or those performing unrelated work near the activities.

Experts from the building, scientific, and environmental communities have different views as to the proper management of LBP in-place. This document attempts to bring together information and viewpoints from several sources reflecting current knowledge and technology.

This O&M Plan shall be considered solely as a resource document representing the expert opinion of professionals in this field. This Plan does not represent the view, policies, or position of the U.S. Environmental Protection Agency

(EPA), the Occupational Safety and Health Administration (OSHA), or any other agency of the federal, state, or local governments.

The O&M Plan should serve as a guide to implement Fort Buchanan's LBP management program and instruct workers who execute the required tasks. The user bears all risks associated with reliance on these work practices and shall have the sole responsibility to evaluate the information contained herein and to make independent judgments on the use of the practices outlined in this O&M Plan.

List of Acronyms

AAS Atomic Absorption Spectroscopy

ALC apparent lead concentrations

AIHA American Industrial Hygiene Associates

AP Administrative Procedures

ASV Anodic Stripping Voltammetry

CFR Code of Federal Regulations

CLC corrected lead concentration

DENIX Defense Environmental Network Information Exchange

DOT Department of Transportation

DPW Directorate of Public Works

EPA U.S. Environmental Protection Agency

GFCI ground fault current interrupter

HEPA High Efficiency Particulate Air

HUD U.S. Department of Housing and Urban Development

ICP-AES Inductively Coupled Plasma — Atomic Emission Spectroscopy ICP inductively coupled plasma

JJSA J. J. Sosa and Associates, Inc.

LBP Lead-based Paint

LPM Lead Program Manager

MSDS material safety data sheets mg/L milligrams per liter mg/cm2 milligram per square centimeter g/dL micrograms per deciliter g/g micrograms per gram g/m3 micrograms per cubic meter

NOISH National Institute for Occupational Safety and Health

O&M Operations and Maintenance

OSHA Occupational Health and Safety Administration PEL Permissible Exposure Limit

PPE personal protective equipment ppm parts per million

PREQB Puerto Rico Environmental Quality Board

QA/QC quality assurance/quality control

RCRA Resource Conservation and Recovery Act

SEL substrate equivalent lead concentration

SOP standard operating procedure

TCLP toxicity characteristic leaching procedure

TSCA Toxic Substances Control Act

USARSO U.S. Army South

WP Work Practices

XRF X-ray fluorescence

Lead Based Paint Operations and Maintenance Plan Title Sheet

User Agency:

Facility Name:

Address:

City and Zip:

Date of O&M Plan:

Consultant:

Department of the Army Fort Buchanan

Directorate of Public Works

Building 34

South Gate Road

Fort Buchanan, Puerto Rico 00934-3400

Updated Version November 2019

J.J. Sosa and Associates, Inc.

5811 Memorial Highway, Suite 207

Tampa, Florida 33615

Phone: (813) 888-6525

Fax: (813) 881-1285

I hereby certify that this Operations and Maintenance (O&M) Plan was compiled in accordance with the Army Corps of Engineers, PD Branch's Scope of

Work and satisfies the intent to provide Fort Buchanan with a Lead-based Paint

Management Program, to the best of my ability and knowledge.

_________________________________________________________ Dated: _______________

MR. ANIBAL NEGRON

Chief Environmental Division

USAG Fort Buchanan PR 00934

SECTION 1

Introduction

This Operations and Maintenance (O&M) Plan is designed to establish a set of policies, procedures, and work practices that are intended to minimize occupant exposure to lead-based paint (LBP). Specifically, this plan was prepared to aid in safely maintaining the remaining LBP throughout Fort Buchanan. To assist the reader in implementing the LBP procedures and practices, Appendix A provides a glossary of many of the terms used in this Plan.

Description of Lead-based Paint Lead is a commonly used, soft, bluish metallic element found in its natural state worldwide. It is virtually indestructible and non-biodegradable, and has been used in paints, storage batteries, ceramics, leaded gasoline, construction materials (especially pipes), radiation protection gear, and ammunition. From the turn of the century to the mid-1960s, lead was used in many oil-based interior and exterior paints. As latex paints became more popular, the use of LBP decreased. Because of the health hazards associated with exposure to lead, the Consumer Product Safety Commission banned the use of LBP in 1978.

LBP is defined as any paint, varnish, stain, or other applied coating that has 1 milligram per centimeter squared (mg/cm2) or 0.5 percent by weight (5,000 micrograms per gram μg/g or 5,000 parts per million ppm by dry weight) or more of lead. However, even if concentrations below these levels are detected, disturbing the paint may create the potential for lead poisoning and may trigger regulatory requirements.

Identifying Lead-based Paint Painted surfaces can be tested to determine if LBP is present. If testing has not been performed, it should be assumed that surfaces painted before 1978 contain LBP. The guidance in the Plan should be used when working on these surfaces.

There are two primary methods for testing paint for lead: X-ray fluorescence detectors (XRF) and laboratory analysis of paint chips. A third method, using chemical kits for spot testing, has not been widely accepted as a reliable means of detecting low levels of lead in paint. However, these kits may improve in the future and become an easier, more cost effective, and more reliable way to test for lead.

The XRF detector is a hand-held probe that provides real-time reading of lead concentrations. When directed at the material in question, the XRF emits an x-ray beam that excites molecules in the material. As the excited molecules fall back to their original energy state, they emit a signal that is characteristic of particular compounds. The XRF device collects the signal characteristic of lead and indicates the concentration of lead in mg/cm2.

The second technique involves obtaining paint chips from materials surfaces and sending them to a laboratory for atomic absorption or inductively coupled plasma (ICP) atomic. The primary statutes and regulations addressing lead hazards consist of:

Residential LBP Hazard Reduction Act of 1992 (Public Law 102-550)

LBP hazards in Federally owned residential property and housing receiving federal assistance (24 Code of Federal Regulations [CFR] 35)

LBP Poisoning Prevention in Certain Residential Structures (40 CFR 745)

Management and Disposal of LBP Debris (40 CFR 745, Subpart P)

Hazardous Waste Toxicity Characteristic for Lead (40 CFR 261.24) General Industry Standards for Lead (29 CFR 1910.1025)

Construction Standards for Lead (29 CFR 1926.62)

Controlling LBP Abatement Activities in Puerto Rico (Rule 1501 to 1570)

HUD Regulations and Guidance for Residential Housing It was not until 1971 that Congress formally recognized lead poisoning as a significant threat to children and passed the LBP Poisoning Prevention Act directing HUD to initiate programs to screen children and begin controlling LBP hazards in residential housing. HUD continues to develop new information, regulations, and programs to eliminate LBP hazards in housing. Noteworthy developments in HUD's programs consist of:

The Residential LBP Hazard Reduction Act of 1992, which directed several federal agencies to establish a coordinated effort to reduce lead hazards

The Lead Hazards in Federally Owned Residential Properties regulation

HUD Guidelines for the Evaluation and Control of LBP Hazards in Housing

The following paragraphs present important features of the HUD statute, regulation, and guidance document.

Residential LBP Hazard Reduction Act (Title X)

Congress passed the Residential LBP Hazard Reduction Act in 1992 (Public Law 102-550), which formed

Title X of the Housing and Community and Development Act. Title X requires federal departments and agencies to address the threat of lead poisoning from LBP in residential real property. The following list highlights several sections of Title X:

Section 1003 requires a national strategy to eliminate LBP hazards in all housing.

Section 1012 establishes requirements for reducing lead hazards in housing receiving federal assistance.

Section 1013 requires inspection and abatement of LBP hazards in federally owned target housing and abatement for housing constructed prior to 1960 as well as inspections for housing constructed between

1960-1977.

Section 1017 requires development of guidelines for conducting work involving risk assessments, inspections, interim controls, and abatement of LBP hazards.

Section 1018 requires disclosure of certain information to persons selling or leasing housing that may contain LBP hazards and allows risk assessment or inspection for the presence of LBP hazards in the nation's housing. It also shifts the emphasis from only abatement to abatement and safe management of in-place LBP. Title IV requires EPA to develop regulations for:

Training and certification for LBP activities and work practices (Section 402)

Identification of dangerous levels of lead (Section 403)

Authorization of state programs (Section 404)

Development of a lead hazard information pamphlet (Section 406)

Control of LBP hazards at federal facilities (Section 408)

EPA has already published some regulations in response to this statute and has proposed others. Additional final regulations on lead hazards are anticipated.

LBP Disclosure Notification EPA and HUT) regulations (40 CFR 745, Subpart F and 24 CFR 35, Subpart A) require sellers and property managers of target housing (i.e., most pre-1978 housing) to disclose the presence of known LBP and or LBP hazards in the housing and provide available records or reports. The EPA, HUD, and the Consumer Product

Safety Commission jointly developed a pamphlet titled Protect Your Family from Lead in Your Home (April

1999) to inform families about how to reduce exposure to lead hazards in the home. This pamphlet is also available in Spanish. Distribution of this pamphlet is one method of disclosure along with warning statements included in contract agreements.

LBP Work Practices EPA's 40 CFR 745, Subpart L, "Work Practice Standards for Conducting LBP Activities" provides minimum requirements for conducting LBP inspections, risk assessments, and abatements to ensure such procedures are conducted safely, reliably, and effectively. As of March 1, 2000, individuals and firms offering professional services to perform LBP activities must be certified by successfully completing an EPA-accredited training program. Minimum work practices are defined in this rule for the following certified individuals:

Inspectors who examine homes for the presence of LBP

Risk assessors who evaluate homes for LBP hazards

Workers and supervisors who perform abatements to permanently eliminate LBP paint from homes

Project designers who plan abatement activities

Refresher training and periodic re-certification is also required for individuals engaged in LBP activities.

Hazardous Waste Determination for Lead Waste generated from LBP activities may require handling and treatment dictated by the hazardous waste regulations. To determine if LBP waste is hazardous waste or not, a representative sample of LBP waste should be sent to a laboratory for testing using the toxicity characteristic leaching procedure (TCLP). If an extract from the sample exceeds the regulatory limit for lead of 5 mg/L, then the waste must be managed as a characteristic. Vacuums used in housekeeping must be used and emptied in a manner that minimizes the re- entry of lead into the workplace. This standard also applies to maintenance activities involving making or keeping a structure, fixture, or foundation in proper condition in a routine, scheduled, or anticipated fashion.

Such maintenance may consist of minor surface preparation and repainting where there is insignificant damage, wear, or corrosion of existing lead-containing paint and coatings or substrates.

This standard establishes a permissible exposure limit (PEL) of no greater than

50 micrograms per cubic meter (ug/m3) of air averaged over 8 hours. An action level of

30 ug/m3 triggers provisions for exposure monitoring, medical surveillance, and training.

The topics addressed in this regulation consist of:

Exposure monitoring

Methods of compliance (e.g., engineering work practice controls and respiratory protection)

Respiratory protection (in accordance with OSHA regulations in 29 CFR 1910. 134)

Protective work clothing and equipment

Housekeeping

Hygiene facilities and practices

Medical surveillance

Employee information and training

Signs and recordkeeping

Construction Standard for Lead The general safety and health provisions of this OSHA standard (29 CFR 1926.62) apply to all construction work that could cause occupational exposures to lead. This work includes removal or encapsulation of materials containing lead through demolition, salvaging, alternations, new construction, repairs, or renovations. The construction standard for lead also addresses the topics listed above for the general industry standard.

Puerto Rico Environmental Quality Board Regulations The PREQB adopted the regulation for the Control of Lead-based Paint Abatement Activities, Chapter 1500, on May 27, 1999. These rules (1501-1570) established the requirements for certification and licensing of firms and individuals performing LBP functions including inspection, risk assessment, and abatement. The regulation establishes the educational requirements and training for individuals performing LBP work.

Training is to be received from schools certified by the PREQB. Firms providing consulting and/or abatement services must be licensed by PREQB as well.

SECTION 3

Administrative Procedures

This section presents the administrative elements of the LBP program. In contrast, Section 4 presents work practices and/or instructions for specific activities involving LBP. The following LBP Administrative

Procedures (AP) are presented in this section:

AP1 Worker Training, Exposure Assessment, and Medical Surveillance

AP2 Notifications and Labeling

AP3 Periodic Surveillance and Re-inspection

AP4 Work Permit Program

APS Recordkeeping and Forms

AP6 Selection of Personal Protective Equipment and Decontamination Procedures

AP7 Waste Classification and Disposal Requirements

AP8 Lead-based Paint Testing

AP9 Recommended Housekeeping Procedures

AP1-Worker Training, Exposure Assessment, and Medical Surveillance

Required Training The EPA published a final rule for the certification and training of LBP professionals on August 29, 1996.

The rule provided a phase-in period for the training program accreditation requirements, individual and firm certification, and work practice standards. After March 1, 2000, LBP training programs are to be accredited by

EPA, and individuals and firms are to be certified to perform certain LBP activities and use the work practice standards. The required training consists of the following minimum hours for the following individuals:

Inspector-24 hours with 8 hours devoted to hands-on training

Risk Assessor-16 hours with 4 hours for hands-on activities Supervisor-32 hours with 8 hours for hands-on activities Abatement worker-16 hours with 8 hours for hands-on activities

Project Designer-8 hours

Only trained and certified individuals are to conduct LBP inspections, lead hazard screening, sample collection, risk assessments, abatement activities, and post-abatement clearance and report preparation. These individuals shall be re-certified every year by attending an accredited refresher training course, usually an 8-hour class (PREQB Rule 1544). Form 1 in APS should be completed and filed to track employee LBP training certification.

Effective implementation of the LBP O&M Plan requires specific training of select personnel. The amount and content of training depends on the role and responsibilities of the individual. Fort Buchanan shall institute a training program for their employees engaged in LBP-related work. At a minimum, the LPM should attend an accredited class to become a certified LBP supervisor. By doing so, the LPM will be able to:

Coordinate completion of inspections to determine lead hazards

Provide awareness information to Fort Buchanan personnel and families

Evaluate potential exposure conditions

Implement this O&M Plan for identifying, evaluating, and prioritizing LBP activities Be familiar with proper cleaning and maintenance tasks

Understand applicable laws and regulations

Be aware of other crucial factors associated with the O&M program

In general, an awareness training session should be given to employees working in buildings known to contain lead. The awareness or basic training should include instruction in:

The hazards of lead

Warning signs, labels, and material safety data sheets

The requirements of the EPA, EQB, HUD, and OSHA standards

Form 2 in APS should be completed and filed to track employees attending the LBP awareness training. For employees whose job function may disturb lead and create potential exposure situations, a more in-depth training program is required along with an assessment of the lead exposure.

Assessing Exposure Construction activities with potential exposure to lead range from those such as abrasive blasting and welding, cutting, and burning to renovations and repairs to painting and decorating. As mentioned, the current OSHA standard sets a PEL or the maximum worker exposure limit. No employee may be exposed to lead at airborne concentrations greater than

50 μg/m3 averaged over an 8-hour period. If employees are exposed to lead more than

8 hours in any workday, the following formula must be used:

Employee exposure (in μg/m3) = 400 divided by hours worked in the day

In addition to the PEL, OSHA sets an action level, which is the level that an employer must begin certain compliance activities outlined in the regulations. The action level for lead is an airborne concentration of 30 ug/m3 calculated over 8 hours.

Certain lead-related construction tasks commonly produce exposures above the PEL. Until an employer performs an employee exposure assessment and determines the magnitude of the exposures actually occurring during the lead related activity, the employer must treat certain operations as if they are above the PEL. This means providing respiratory protection, protective work clothing and equipment, change areas, hand washing facilities, initial medical surveillance, and training as required by the standard.

The OSHA lead standard is unique in that it groups tasks that are presumed to be associated with employee exposures above the PEL into three lead-exposure ranges:

Employers must assume an exposure over 50 and up to 500 μg/m3 for the following tasks:

— Manual demolition of structures (e.g., dry wall)

— Dry manual scraping

— Dry manual sanding

— Using a heat gun where lead-containing coatings or paints are present

— Power tool cleaning with dust collection systems

— Spray painting with LBP

Employers must assume exposure over 500 and up to 2500 μg/m3 for the following tasks:

— Using lead-containing mortar

— Burning lead

— Rivet busting on lead paint

— Cleanup activities where dry expendable abrasives are used

— Abrasive blasting enclosure movement and removal

Employers must assume exposure over 2,500 μg/m3 for the following tasks:

— Abrasive blasting

— Cutting

— Welding

— Torch burning

The only difference in the provisions applying to these three categories of tasks is the degree of respiratory protection required.

Air monitoring is used to determine the actual lead exposures when construction disturbs LBP. Samples representative of a full work shift should be collected by a properly trained individual and analyzed by a laboratory. The results are compared to the PEL and action level for lead. Employees are to be notified in writing of the results of their air monitoring. If the initial determination proves employee exposure is below the action level, the records must be maintained and further exposure determination need not be repeated unless there is a change in equipment, processes, controls, or personnel.

If monitoring results are above the action level, the employer is required to continue air monitoring and implement engineering, work practice, and administrative controls to reduce employee exposure to the lowest level feasible. If these controls are not sufficient to reduce exposure below the PEL, they are to be supplemented with respiratory protection as discussed in 29 CFR 1926.62.

Additional training is required for employees exposed to lead at or above the action level on any day. The training should be provided annually and must address:

The hazards of lead

Warning signs, labels, and material safety data sheets

The requirements of the EPA, HUD, and OSHA standards The nature of tasks that could lead to exposures at or above the action level

The purpose, proper selection, fitting, use, and limitations of respirators

The purpose and description of the medical surveillance program The engineering and work practice controls associated with an employee's job assignment

The contents of the employer's written compliance program

The right of employees to access their exposure and medical records

Medical Surveillance Program Employers shall make initial medical surveillance available to any employee exposed at or above the action level on any day. This initial surveillance must include sampling for blood lead and zinc protoporphyrin levels. Employers must also provide biological monitoring for all employees performing lead-related tasks presumed to create employee exposures above the PEL. A medical surveillance program must be provided for employees exposed at or above the action level for more than 30 days in any consecutive 12-month period.

This program will include biological monitoring and medical examinations and consultations. Blood sampling and analysis for lead must be made available:

At least every 2 months for the first 6 months and every 6 months thereafter, for employees exposed at or above the action level for more than 30 days in any consecutive 12-month period.

At least every 2 months when blood lead level is at or above 40 micrograms per deciliter (μg/dL). and for employees exposed above the action level. Testing should continue at this rate until two consecutive blood sample results are below 40 μg/dL.

At least monthly during a period when an employee has been removed from work because of high blood lead levels.

If an employee's blood sample results exceed the criterion level for removal, another blood sampling test should be provided within 2 weeks.

Medical exams and consultations must be made available on the following schedule:

At least annually for an employee whose blood lead level was 40 μg/dL or greater in the last 12 months.

As soon as possible for any employee who has developed signs and symptoms commonly associated with lead poisoning or who desires medical advice concerning the effects of current or past exposure to lead on the ability to have a healthy child.

As soon as possible upon learning an employee is pregnant.

As soon as possible after an employee has shown difficulty in breathing during a respirator fit test or use.

As medically appropriate for each employee removed from lead exposure due to a risk of sustaining material impairment to health.

Employers must remove employees with lead exposure at or above the action level each time:

A periodic and follow tip blood sampling test indicates a blood lead level at or above 50 μg/dL; or

A final medical determination indicates a detected medical condition that increases health risks from lead exposure

A doctor may make a final medical determination to remove an employee from working with lead. The doctor is not to reveal any findings, lab results, or diagnosis unrelated to occupational exposure to lead to the employer. An employee exposed to lead at or above the action level must be removed from lead work, if the employee has a blood lead level at or above 50 μg/dL on two separate testings, two weeks apart. An employee can return to lead work when his or her blood lead level result is at or below 40 μg/dL on two consecutive testings or a doctor has made a medical determination that the employee can return to lead work. The employer must provide wages and benefits for any employee removed from lead work for up to 18 months, or as long as the job exists.

Under certain limited circumstances, doctors may administer special drugs called chelating agents to remove circulating blood lead. The use of chelating (binding) drugs as a prophylactic measure (i.e., to prevent a detectable rise in blood lead) is an unacceptable medical practice. Chelation may be used by a qualified physician only for diagnostic or therapeutic reasons (that is, to diagnose or treat the signs and symptoms of severe lead toxicity). Chelating drugs should not be used as a substitute for engineering controls, appropriate work practices, and proper personal protective equipment.

AP2—Notifications and Labeling

Worker Warning Signs The hazard communication standards (29 CFR 1910.1200 and 1926.59) apply to all employers in general industry and in the construction industry, respectively. The purpose of these regulations is to inform workers of health risks associated with exposure to hazardous chemicals in the workplace. The employer must inform employees about lead hazards according to the requirements of OSHA's Hazard Communication standard.

This includes, but is not limited to the requirements for warning signs and labels, material safety data sheets

(MSDSs), and employee information and training.

For example, the following warning sign must be posted in each work area where employee exposure to lead is above the PEL:

WARNING

LEADWORK AREA

POISON

NO SMOKING OR EATING

All signs must be well lit and kept clean so they are easily visible.

Employee Awareness Notification The LPM is responsible for informing employees and tenants of the presence of LBP and associated hazards in their buildings. In most instances, it is the owner or property manager's responsibility to communicate this information to the tenant. Form 3 in APS is a sample letter that may be used for this purpose. Occupants should understand the importance of not disturbing LBP and of reporting the presence of chipping, peeling, flaking or cracking paint or visible paint dust and debris.

When LBP abatement work is being planned, the employees working in and near the area of the abatement should be provided information about:

The specific work to be performed

The abatement work schedule

Precautions to be taken What will be visible during the work

That posted warning signs must be obeyed

Residential Disclosure Notification The regulations (24 CFR 35.13 and 40 CFR 745.113) have specific provisions for LBP in federally owned target housing that is transferred. Buyers and renters are to receive information on LBP and LBP hazards during sales and rentals of housing built before 1978. Specifically, they are to receive:

The EPA-approved pamphlet titled Protect Your Family from Lead in Your Home (EPA 747-K-99-001) available in English and Spanish.

A statement disclosing the presence or presumed presence of LBP or LBP hazards.

Copies of LBP inspections, risk assessments, or any records of LBP.

A "lead warning statement" in contract or lease agreements describing the possibility that the property may present a risk of childhood lead poisoning.

The transferee must sign a statement that he or she has read and understood the lead hazard information pamphlet. He or she must also sign a statement confirming receipt of available LBP records and reports pertaining to the housing.

AP3-Periodic Surveillance and Re-inspection Visual monitoring of LBP should be accomplished at set intervals. The purpose of this monitoring is to ensure that personnel discover any damaged or deteriorated LBP as soon as possible. This allows management to take the appropriate corrective actions. Both the custodial and maintenance staff should monitor the condition of their work areas. In the event of a problem, such as flaking or chipping in the paint, staff should contact their supervisor and the LPM as soon as possible.

Periodic Surveillance Periodic surveillance should be conducted at least every 6 months. The surveillance should include visual observations recorded on a periodic surveillance form (refer to APS, Form 4) that should be turned in to the

LPM. Individuals conducting LBP inspections must be properly trained at an EPA-accredited program. The

PREQB has an EPA-authorized certification program in place for various training facilities. When conducting periodic surveillance, it is important to note key information such as:

Building number

Building name

Location of the facility

Location of the specific area Number of the area (if applicable) Any changes to the condition of the area, e.g., type of work being conducted in the area

Any changes in the condition of the LBP

All of these details are significant, but the most important information is the location of the LBP and its condition.

Re-inspection Program A complete re-inspection of the facility should be accomplished at least every 3 years and completed by an

LBP Inspector/Risk Assessor. During a re-inspection, the majority of the information is the same as in the periodic surveillance. The primary difference when conducting a re-inspection is that in addition to noting the condition of the material, the inspector must also note the potential for disturbance and give a response action to the material. At the time of the re-inspection, the O&M Plan and LBP inventory should be updated to reflect any changes. The O&M Plan should accurately document response actions, condition of the LBP, and the use of the functional space in which the LBP exists. Any of these areas can be used to identify the possibility of a new hazard in the facility.

AP4—Work Permit Program This procedure is used as the basis for determining the proper response by the LPM to ensure that LBP is handled in a manner that minimizes the potential for exposure. A work permit program is implemented by the LPM to control and prevent disturbances of LBP during maintenance, renovation, and remodeling work.

The LPM requires that a Job Request Form for Maintenance Work (Form 5 in APS) be submitted prior to any work occurring that may impact building materials within the facility. The job request form should provide the LPM with the name of the person or persons who will be conducting the work, the time, location of, and type of job, as well as any information known about the presence of LBP. After the LPM has received the job request form, the LPM should:

Review the LBP inventory and relevant LBP Survey and Assessment Reports and any other pertinent records to determine if LBP is located within the intended work site.

Request that the Inspection Branch visit the intended work site and determine whether LBP that may be present is likely to be disturbed by the work.

If the LPM determines that LBP is not located within the work area, the LPM should complete the

Maintenance Work Authorization Form (Form 6 in APS) and submit it to the Chief of the O&M Division.

If LBP is found within the intended work area, and the LPM determines that the disturbance of the LBP is unlikely, the LPM should:

Complete the Maintenance Work Authorization Form and submit it to the Chief of the O&M Division.

The Authorization Form should inform the workers of the location of the LBP and provide the worker with Work Practices (see Section 4) which, if followed, will avoid or minimize the disturbance of the

LBP.

Instruct the Inspection Branch to conduct periodic visits to the work site to determine if the condition of the material or work practices have changed. The Work Evaluation Form (Form 7 in AP5) should be used to record this data.

If LBP is found within the intended work area, and the LPM determines that the work may impact the LBP, the LPM should complete the Maintenance Work Authorization Form and submit it to the Chief of the O&M Division. The Authorization Form should:

Recommend that the LBP be removed or encapsulated prior to the proposed work by an LBP Contractor, or

Recommend that work practices found within this Plan be used to minimize the disturbance.

Exhibit 3-1, the Work Permit Program checklist, may assist the LPM with following this procedure.

Whenever possible, all work disturbing LBP should be scheduled for a time when the work area will not be in use and can be closed off to anyone other than trained workers or other authorized personnel. If an area is always occupied, plans should be made to isolate the work area from building occupants using visual and/or physical barriers. If a special work area arrangement is required, it may be beneficial to provide a sketch to the workers showing how the area is to be set up. If respirators are to be used, it might be desirable to vacate the area to avoid concerns a worker in a respirator may prompt from unprotected workers/occupants.

EXHIBIT 3-1

Work Permit Program Checklist

Receive and review Form 5- Job Request Form for Maintenance Work

Work to be performed: (FILL OUT AS REQUIRED)

Review or request survey data to determine whether LBP is affected

Complete Form 6- Maintenance Work Authorization Form

Review historical air monitoring data for work practices to be used

Select Work Practice(s) for all LBP to be encountered

Select personnel protective equipment and decontamination requirements to be used, if needed

Select appropriate materials and review potential hazards (confined spaces, scaffold use, etc-)

Schedule work when area is not in use or develop a plan to isolate area (if necessary)

Federal, state, and local notifications filed (if applicable)

Notify personnel affected by work

Assign workers (or contractor) with appropriate level of training and verify currency of training, fit tests, and medical surveillance

Assign trained air monitoring person and determine air monitoring to be performed (if needed).

Record air monitoring requirements on Maintenance Work Authorization Form

Provide copies to workers/contractor of:

Maintenance Work Authorization Form

Work Practice checklist for proper work level

Work Practice(s):

Administrative Procedure(s):

Notifications

Schedule of work

As practical, review work practices during work for compliance with requirements

Complete Form 7— Work Evaluation Form

File all required records in proper files

Signature: Date:

AP—5 Recordkeeping and Forms The LPM is responsible for maintaining documentation related to all facets of the LBP O&M Plan. A well maintained and comprehensive recordkeeping program is a necessity for protecting residents and workers from exposure and demonstrating compliance with the regulations. This documentation will also be used to evaluate and modify the LBP management program and work practices.

It is recommended that the following records of O&M work be retained in permanent files:

Inspection and Assessment Reports

A copy of the O&M Program (initial program and all updated versions)

The Work Practices Used Respiratory Protection Program Job Request Forms for Maintenance Work

Maintenance Work Authorization Forms Work Evaluation Forms

Periodic Surveillance and Re-inspection Reports

For employers with employees engaged in LBP-related work, federal regulations require that the employer retain:

Exposure assessment data

Employee training records Medical records (for employees subject to a medical surveillance program) Cases of medical removals

Objective data for exemption from requirement of initial monitoring Waste manifesting and disposal records (if waste is a characteristic hazardous waste) Air monitoring data

Certification for outside contractors (individuals and firms)~ Copy of Notification Letter

Any analytical data collected within the facility (such as settled dust sampling)

OSHA requires that employers provide to each employee his/her record of exposure and medical surveillance under the Records Access Standard (29 CFR 1910.20) and the Hazard Communication Standards (29 CFR

1910.1200 and 1926.59). These regulations require that medical records must be maintained for 30 years past the end of employment. Air monitoring records must be maintained for 30 years. Training records must be maintained for 1 year past the end of employment. All records are to be available upon request to the OSHA

Administrator, the Director of the National Institute for Occupational Safety and Health (NIOSH), affected employees, and former employees or their designated representatives for examination and copying. If the employer goes out of business and there is no successor, records are to be transferred to the NIOSH Director.

Contact NIOSH prior to transferring any records for instructions and specific requirements.

EPA recommends that building owners make available all written elements of the O&M program to the building's O&M staff, as well as to tenants and building occupants, if applicable. Building owners are also encouraged to consult with their legal counsel concerning appropriate recordkeeping strategies as a standard part of their O&M programs.

The following example forms are provided in this procedure to assist the LPM with activity documentation:

Form 1—Verification of Employee Training Certification

Form 2—Record of LBP Awareness Training

Form 3—Sample Information Letter to Tenants/Occupants

Form 4—Periodic Surveillance Log

Form 5—Job Request Form for Maintenance Work

Form 6—Maintenance Work Authorization Form

Form 7—Work Evaluation Form

Form 1 Verification of Employee Training Certification

Employee Name:

Social Security #:

Position:

Training Provider:

Training Course Title:

Date of Course:

Length of Course (Hours):

Was this course? Initial: Update Training:

Does course have full approval of U.S. Environmental

Protection Agency and Puerto Rico Environmental Quality

Board? Yes

No

Does Employee Participate in Respirator Program? Yes No

Does Employee Participate in Medical Surveillance Program? Yes No

Attach Copy of Certificate Indicating Successful Completion of Training (including appropriate examination).

Signed:

(LBP Program Manager)

Date:

Form 2 Record of LBP Awareness Training

Fort Buchanan has implemented a program to help minimize exposure to LBP. Part of this program includes providing a

LBP awareness training session. This training session covers the following topics:

Information regarding LBP and its various uses and forms

Location of LBP in the facility

Health effects associated with LBP exposure

Recognition of damage, deterioration, and delamination of LBP

Housekeeping requirements relative to the General Industry Standard

Name and phone number for the LBP Program Manager

Question-and-answer period to discuss LBP in the building

Location of the LBP Survey Reports and O&M Plan

This is to verify the employees named below attended the LBP Awareness Training.

Employee Name/Title Social Security Number Date

Employee Name/Title Social Security Number Date

Employee Name/Title Social Security Number Date

Name of LBP Awareness Trainer:

Form 3 Sample Information Letter to Tenants/Occupants

MEMORANDUM FOR: Building Tenant Agencies/Occupants

FROM: Lead-based Paint Program Manager

SUBJECT: Notification of the Presence of Lead-based Paint

(Building Name)

As communicated to Building occupants in a memorandum dated, during scheduled renovation of within the building, lead-containing material was identified in The building was inspected for the presence of LBP by on . Upon receipt of the survey results, consultation was entered into with experts in the field of lead detection and control to develop a course of action specifically designed to protect the health and safety of building occupants and the environment. A lead-related Operations and Maintenance (O&M) program was established to provide an effective means for dealing with the lead paint. The objectives of the O&M plan are to:

Establish a program of work practices to maintain LBP in good condition.

Ensure the safe clean-up of area previously contaminated

Minimize disturbance and damage

Develop an in-house response team to effectively handle emergency situation

Through the establishment of a trained, in-house lead response team and use of experienced outside lead abatement consultants, the lead paint within this facility can be controlled in a manner that will be safe to the health of the building occupants. Of course, the help and cooperation of all tenant agencies and occupants will be needed.

This office will implement a policy of providing informational updates on any activity that will involve the intentional disturbance of lead-containing material during building operations, emergency response to lead releases, and precautions and procedures designed to ensure the health and safety of the building occupants. In addition, information can be gained by contacting the office at

Form 4 Periodic Surveillance Log Please complete the last column with your initials and the date when the six-month surveillance is performed.

Personnel Performing Surveillance

Observations Date Initials

(when completed)

Form 5 Job Request Form For Maintenance Work

Name:

Date:

Telephone No.

Job Request No.

Requested starting date: Anticipated finish date:

Address, building, and room number(s) (or description of area) where work is to be performed:

Description of work:

Description of any lead-containing material that might be affected, if known (include location, condition, paint color, and substrate):

Name and telephone number of requestor:

Name and telephone number of supervisor

Submit this application to:

(The LBP Program Manager)

NOTE: An application must be submitted for…