Attachment-6-GPO Directive 670-52a.pdf

ORIGINATING OFFICE

Safety Branch

EFFECTIVE DATE

June 5, 2019

GPO Directive 670.52A June 5, 2019

Working with Lead

1. Purpose. To ensure a healthy work environment in GPO facilities.

2. Supersedes. This Directive replaces GPO Directive 670.52, Subject: Working with Lead, dated September 7, 2017.

3. Scope. This Directive is applicable to all work with lead within GPO facilities.

4. Definitions.

a. Abatement: Activity to reduce or eliminate lead hazards.

b. Cleaning: The removal of bulk debris from the work area, to include using a HEPA vacuum and wet cleaning agents to remove lead-contaminated dust and/or debris.

c. Containment: A process to protect workers and the environment by controlling exposures to the lead-contaminated dust and debris created during abatement.

d. Disposal (of hazardous waste): The placement of solid or liquid hazardous waste so that it cannot pollute the environment.

e. Encapsulation: Encapsulation is the application of a barrier between lead-based paint and the environment using a liquid-applied coating (with or without reinforcement materials) or an adhesively bonded covering material.

f. Enclosure: The use of rigid, durable construction materials that are mechanically fastened to the substrate to act as a barrier between the lead-based paint and the environment.

g. High-Efficiency Particulate Air (HEPA) Filters: A filter capable of removing particles of 0.3 microns or larger from air at 99.97 percent or greater efficiency.

h. Lead-based Paint (LBP): Any paint, varnish, shellac, or other surface coating that contains lead equal to or in excess of 1.0 mg/cm2 (EPA) / 0.7 mg/cm2 (MDE) as measured by an x-ray fluorescence analyzer or laboratory analysis, or greater than 0.5% by weight (5,000ppm) by laboratory analysis. Over 100 ppm of lead in paint is considered hazardous waste.

i. Permissible Exposure Limit: The employer shall assure that no employee is exposed to lead at concentrations greater than fifty micrograms per cubic meter of air (50 ug/m3) averaged over an 8-hour period.

670.52A 06/05/2019

5. Responsibilities.

a. The Safety Branch will:

(1) Conduct paint chip sampling of peeling paint and areas where activities including sanding, chipping, grinding, scraping, or demolition may disturb painted areas, prior to those activities occurring. Each paint chip sample collected must contain at least two grams or about the size of a quarter. If possible, the sample will contain all layers of paint.

(2) Periodically assess paint removal activities to ensure proper procedures are being followed. Any noted discrepancies will be followed up with the appropriate supervisor.

(3) Review construction activities for potential lead hazards.

(4) Evaluate lead risk based on the following standards:

(a) Dust Standards (Single Surface Dust Wipes)

Surface Dust- Lead Concentration must be equal or less than

Floors 200 μg/ft2 Interior window sills 250 μg/ft2

Window troughs 400 μg/ft2

(b) Air – 50 μg/m3 over an 8 hour period. Area and/or personal air monitoring is to be conducted

(c) Water – 15 parts per billion

(d) Lead-Based Paint (LBP) – Paint that has been tested and determined to contain

0.5% or 5,000ppm of lead

(5) The Safety Branch will assess the hazard in one of three categories (Low, Medium or High) based on the following:

(a) Categories

i. LOW – hazard can be avoided through occupant education (ex: peeling LBP on a wall)

ii. MEDIUM – hazard can’t be avoided (ex: peeling LBP on a ceiling throughout)

iii. HIGH – occupants have likely ingested or breathed contaminates in significant amounts over a short duration (ex: area and occupants have been exposed to lead fumes)

(b) Level of lead contamination on the surfaces, air or water

(c) Employee exposure

(d) Renovation activities

(e) Likelihood of lead dust migrating due to the following:

i. Foot traffic to and from the occupied spaces

ii. Lead-containing dust being blown to adjacent areas by air flow

iii. Proximity of employees to possible lead dust hazard

iv. Lead dust generated due to vibrations

(f) Visible paint chips will not be included in dust wipe samples as the paint chips will skew the results and do not reflect the level of lead in the dust. Paint chips should be removed first or the sampling area adjusted to an area nearby that doesn’t have visible chips present.

(g) Dust wipe samples with high lead from areas where employees are not exposed (ex: above ductwork/lights, above drop ceilings, in shafts) are not a hazard unless the area is disturbed. Unless sampled and found to be below the above standards, all work in these areas should be done considering the dust as lead-containing when significant amounts of dust is present. Workers in these areas will wear personal protective equipment (ex: respirators, Tyvek, and gloves) and take precautions to not contaminate a nearby employee area by putting up a plastic barrier or cleaning up the dust prior to work.

(6) Occupants of GPO facilities will respond to the hazard based on the Safety Branch assessment of the risk. See Attachment for a flowchart of this process.

(a) Low

i. Brief affected employees/tenants on the hazard

ii. Annotate the hazard with barrier tape or other methods

iii. Do not allow eating or drinking in the area

iv. Determine intermediate and permanent abatement strategies

(b) Medium

i. Remove employees from affected area

ii. Isolate the area from adjacent occupied areas

iii. Determine intermediate and permanent abatement strategies

iv. Conduct air sampling during work and reassess hazard after work completion using the above standards

(c) High

i. Remove employees from affected area

ii. Isolate the area from adjacent occupied areas

iii. Test blood levels of affected employees

iv. Determine intermittent and permanent abatement strategies.

v. Conduct air sampling during work and reassess hazard after work completion using the above standards

(7) Perform annual respirator fit testing and training of lead paint workers.

b. A commercial laboratory will perform lead paint analysis of paint chips and provide a written report to the Safety Branch. Items, other than LBP suspected to contain lead that may be referred to the Environmental Manager to determine if those items contain hazardous waste through a toxicity characteristic leaching procedure (TCLP) test.

c. The Medical branch will:

(1) Evaluate lead paint workers for respirator use in accordance with GPO Directive 670.2, Government Publishing Office Respiratory Protection Program.

(2) Annually test lead paint worker blood levels for lead and recommend any required follow-up actions.

d. The Paint Shop or assigned workers will:

(1) Receive and pass appropriate 29 C.F.R. § 1910.1025 training to conduct abatement before working with lead-based paint.

(2) Follow the Lead-based Paint Abatement Procedures in Paragraph 6 of this directive for paint chips containing above 5,000ppm of lead.

(3) For paint chips that contain over 100ppm and less than or equal to 5,000ppm of lead, follow only paragraph 6.s of this directive to dispose of the paint chips as hazardous waste. The chips are considered hazardous waste, but are not considered lead-based paint.

e. Facilities Management will:

(1) Notify the Safety Branch of any projects that may require lead testing of materials.

(2) Prior to the commencement of a construction project, establish and implement a written plan to include at least the following:

(a) A description of each activity in which lead is emitted; e.g., equipment used, material involved, controls in place, crew size, employee job responsibilities, operating procedures, and maintenance practices.

(b) A description of the specific means that will be employed to minimize worker lead exposure.

(c) Frequently inspect job sites, materials, and equipment to ensure safe worker lead abatement practices and engineering controls are being used.

(d) A description of arrangements made among contractors on multi-contractor sites with respect to informing affected employees of potential exposure to lead and with respect of responsibility of compliance.

f. All GPO occupants will notify their supervisor and the GPO Safety Branch of any areas of suspected lead-contaminated dust, debris, or building materials prior to disturbing those areas.

6. Lead-based Paint Abatement Procedures.

a. Greater emphasis is placed on interim controls, rather than total abatement. Lead-based paint should be maintained in an intact condition to avoid lead hazards. Any peeling, flaking, or chipping paint should be repaired as soon as possible.

b. Employees are required to be removed from the room or space in which actual corrective work is being conducted. Prevent unauthorized persons from entering the work area with signs, barrier tape, rope, and/or polyethylene sheeting. Employees shall not be permitted to enter the room/space/work area until cleanup has been completed.

c. Furnishings and personal belongings that must remain in the room or space are to be protected with duct-taped sealed polyethylene sheeting.

d. All floors in the work areas must be covered with polyethylene sheeting.

e. All ductwork, registers, cabinets, and drawers must be sealed with polyethylene sheeting.

f. The work area shall be sealed by means of containment from the rest of the facility, to include the facility HVAC system.

g. Cover all areas immediately adjacent to the work with 6-mil polyethylene sheeting to contain the wet debris and dust that may be dislodged during the corrective work. All joints and edges of the polyethylene sheeting shall be sealed with duct tape.

h. The surface to be corrected should be moistened (but not flushed) with water from a sprayer or atomizing spray bottle.

i. Ensure electricity to outlets, switches, and appliances in the immediate vicinity of the work are turned off before any water is introduced to surfaces.

j. Wear appropriate Personal Protective Equipment (PPE) when removing loose, peeling, or flaking paint or when work creates dust.

(1) Wear a half-face respirator in accordance with GPO Directive 670.2, Government Publishing Office Respiratory Protection Program.

(2) Wear disposable coveralls and gloves to prevent bringing paint chips and dust outside the area. Consider wearing disposable shoe covers and a painter’s hat to further reduce the chance of bringing paint chips and dust outside the area. Remove protective clothing before exiting the area. A large disposable tack pad on the floor will help clean shoe soles. If feasible, shower on-site. If unable to shower on-site, workers should shower and wash their hair immediately upon returning to their homes.

(3) Wear appropriate PPE to protect eyes and face.

k. Loose, peeling, or flaking paint shall be removed from surfaces with the objective of obtaining a smooth, cleanable surface. Select the appropriate scraping tool to not gouge the surface, but rigid enough to remove the rough, jagged edges or paint. The following methods of paint removal will not be permitted: open-flame burning, dry scraping, and machine sanding/grinding/cutting without HEPA attachments.

l. Do not dry sand or scrape. During wet scraping, the debris shall be collected frequently with a wet/dry vacuum to minimize tracking or spreading the removed material throughout the room or space.

m. Breaks should be taken away from the work area. Never smoke, drink, or eat in the work area. Whenever leaving the area, remove all PPE and wash hands and face thoroughly.

n. Wet-scraped surfaces should be cleaned with a damp sponge and permitted to dry in preparing for repainting or resealing, which shall be done in accordance with the coating/paint manufacturer’s instructions. Cleaning with a tri-sodium phosphate detergent followed by a clean water wash will degloss as well as clean the surface.

o. Wet-scraped, dry surfaces are to be sealed with paint or coating that yields a smooth surface.

p. At the conclusion of the corrective work, or at the end of the workday on multiday activities, debris should be misted with water and swept up and placed in double 6-mil plastic bags. The protective polyethylene sheeting shall be carefully removed, retaining any remaining dust or debris, and bagged in plastic. Polyethylene sheeting shall not be reused.

q. All retained liquid waste shall be poured through a filter cloth to remove paint chips and other debris prior to disposal. Filtered materials will be double bagged.

r. All waste materials generated by this activity including paint debris, HEPA vacuum contents, rags, mops, sponges, water, work clothes, polyethylene sheeting, and any objects in the room that became contaminated and cannot be decontaminated must be disposed of as Hazardous Waste. Place the bag of paint chips in a rigid container (ex:

open top drum, pail), label with a Hazardous Waste sticker and contact the lab at x30883 or x30004.

s. Following work and clean up, visually inspect the area to ensure all paint chips and dust have been removed.

7. Lead Ceramic Tile Procedures.

a. Many types of ceramic tiles used in commercial construction contain high concentrations of lead in their glaze. Workers conducting demolition and renovation of men’s and women’s restrooms, showers, and other areas where glazed ceramic tile is expected to be impacted during the course of construction must follow the Lead-based Paint Procedures listed in Paragraph 6 with the following additional guidance below.

b. Since wet procedures are less effective with tiles, use a HEPA negative air pressure machine to filter and exhaust the dust. Equip power tools used to chip, cut, grind, drill, and other construction activities that will impact ceramic tile with dust collection shrouds or other attachments so that the lead-containing dust generated is exhausted to a HEPA vacuum system. Use HEPA vacuums for cleanup operations.

c. If the Environmental Manager determines the tiles contain hazardous waste through a toxicity characteristic leaching procedure (TCLP) test, put all debris into sealed double 6-mil plastic bags or other rigid containers. Place bags of hazardous waste in a rigid container (ex: open top drum, pail), label with a Hazardous Waste sticker and contact the lab at x30883 or x30004.

8. Other Uses of Lead.

a. Lead has been used in GPO for a variety of other purposes, including lead weights and stamping equipment. Lead use should be minimized. Where feasible, the lead should be turned in for recycling. Items that must remain will be made safe through isolation, protective coating, or other protective measures. Measures shall be evaluated periodically to verify continued safety.

b. Do not bring lead into GPO facilities without approval of the Safety Branch and QCIM.

9. References.

a. 29 C.F.R. § 1910.1025, Lead, Subpart Z – Toxic and Hazardous Substances

b. 29 C.F.R. § 1926.6, Lead

10. Inquiries. Questions concerning the provisions of this Directive should be directed to the Safety Branch at 202-512-1036.

11. Effective Date. This Directive is effective upon issuance.

JOHN W. CRAWFORD

Acting Deputy Director

06/05/19 Attachment