COMPLETE_SOW_RC_MAY_2020.pdf

STATEMENT OF WORK

Industrial Hygiene Services for

National Guard Bureau Industrial Hygiene Region Northeast Army National Guard Facilities

May 2020

1 General.

1.1 Objective.

1.1.1 The purpose of this contract is to anticipate, recognize, and evaluate potential health hazards according to appropriate requirements (attachment 1) associated with processes performed at Army National Guard (ARNG) facilities and to provide sound recommendations for hazard control. The surveys will serve to establish a baseline of workplace conditions or update a previous baseline so that a worker’s history of exposures is provided for civilian and military employees.

1.1.2 Background: In accordance with (IAW) The Occupational Safety and Health (OSH) Act of 1970, Title 29 of the Code of Federal Regulation, Section 25, Part 1960, Title 29 CFR, paragraph (c) states that “all areas and operations of each workplace, including office operations, shall be inspected at least annually. More frequent inspections shall be conducted in all workplaces where there is an increased risk of accident, injury, or illness due to the nature of the work performed.” In addition, DODI 6055.1, paragraph E3.5.3.1, and AR 385–10 also require annual workplace inspections conducted by qualified safety and occupational health personnel. The industrial hygienist is included in the definition of “qualified safety and health personnel” from all three references cited.

1.1.3 The period of performance is 30 September 2020 through 29 September 2021.

1.1.4 The Contractor shall provide the necessary personnel, equipment, and materials required to conduct industrial hygiene surveys and to prepare a comprehensive report for the specified facilities.

1.2 Description of Facilities. Readiness Centers (RCs) or Armories. RCs and Armories provide space for units to support and train soldiers. They generally contain offices, classrooms, an assembly hall, and a kitchen. Some may contain an active, inactive (not converted), or converted indoor firing range and/or maintenance bay that are used during drill weekends. Include the presence of indoor firing ranges and their status in the description of processes.

ARNG-CSG-P

Statement of Work, Armories/Readiness Centers

1.3 Quotes and Contract Award.

1.3.1 Price will be for survey planning and coordination; field work; and report writing. Contractor will provide equipment (see 1.4).

1.3.2 Evaluation factors will be price, past performance and technical capability.

Determination for award is based on “best value” lowest price while technically acceptable, which includes the following factors in order of importance:

1.3.3 Experience. (Technically accurate, comprehensive, consistent) and past performance.

1.3.4 Price will include travel costs incorporating a plan to spend approximately 3 hours at each armory/readiness center.

1.4 Equipment. The ARNG Region Northeast Industrial Hygiene (IH) Office will NOT provide industrial hygiene equipment. Contractor is required to have on every survey the equipment listed in attachment 3. The equipment must have a current, valid calibration.

1.5 Scheduling and Coordination.

1.5.1 The contractor shall contact the ARNG Region Northeast IH Office to obtain the State Safety and Occupational Health (SOH) point of contact (POC) information. The contractor must contact the SOH POC prior to scheduling with the facility to make sure it is all right to do so, to determine if they will be going on the survey, and whether they want an in- and out-brief.

1.5.2 The contractor shall coordinate survey dates with the facilities’ POCs. The contractor shall provide survey dates to the SOH POC, the Region Northeast Industrial Hygienists, point of contact will be provided upon award of contract.

Contact the Region Northeast IH Office immediately if a facility was closed or combined with another one after the contract was awarded. In most cases, an alternate facility may be determined to replace the facility that was closed.

1.6 Payment.

1.6.1 The contract will be paid as final reports have been completed and accepted.

1.6.2 Final payment will not be made unless all reports are completed and accepted.

Media and Laboratory Analyses.

1.7.1 Sampling media will be paid for and provided by the ARNG Region Northeast IH Office.

1.7.2 The laboratories will provide chain of custody forms. The facility name and state must be written clearly on the chain of custody forms for lab analyses. The contractor will note on the chain of custody form to bill the ARNG Region Northeast IH Office directly for services.

1.8 Personnel Qualifications. Field work must be performed by an individual with a minimum of 2 years experience as an industrial hygienist. A certified Industrial Hygienist must be certified by American Board of Industrial Hygiene to approve all work performed by the industrial hygienists. They must be proficient in the anticipation, recognition, evaluation, and control of environmental factors or stresses from the workplace, which may cause sickness, impaired health and well-being, or significant discomfort among workers. Resumes will be submitted if requested to the NGB Region Northeast IH Office before being considered for work. The NGB Region Northeast IH Office reserves the right to request a change in industrial hygienist if there is a conflict with facility personnel, improper/unethical actions on site, or due to a lack of experience.

2 Descriptions of Tasks and Specifications

2.1 Sampling. Collect surface wipe samples throughout the facility following the ARNG Lead Sampling Guide (attachment 2).

2.2 Lighting. Measure lighting several areas of the facility. Report measurements in footcandles (fc).

2.3 Indoor Air Quality. Determine if there are any indoor air quality concerns through employee interviews. Measure carbon dioxide, carbon monoxide, temperature, and relative humidity and note outdoor levels.

2.4 Water Damage/Mold. Note the location and extent of water damage and/or visible mold. Discuss potential source of water incursion.

2.5 Paint Condition. Note condition and location of damaged paint. Example Finding: Peeling and chipping red paint was noted on all four walls of the drill hall. Example Recommendation: Alert the facilities management office (FMO) of the peeling and damaged paint so that if they have not already done so, they may make arrangements to have the paint tested for lead content and perform remediation if necessary.

2.6 Asbestos. Perform a visual inspection for suspected asbestos containing material (ACM). Note the condition, location, and approximate quantity of any ACM and/or suspect ACM. Example Finding: Broken and crumbling 9” X 9” floor tiles encompassing approximately 450 square feet, that are presumed to contain asbestos were noted in the break room and office 101. Example Recommendation: Alert the FMO of the damaged asbestos containing floor tiles so that they may make necessary arrangements for cleaning and remediation of potentially released asbestos fibers.

2.7 Interpretation of Results and Further Recommendations. Interpret results of measurements, sampling, and observations. Include a recommendation for every finding noted. Risk assessment codes shall be applied to each recommendation (attachment 4).

2.8 Photographs. Provide photographs, clearly labeled, when useful in describing deficiencies noted in the report.

3 Reporting Requirements.

3.1 Coordinate with the State POC to arrange for facility survey visits and once a final schedule is created, send a copy to the ARNG Region North IH Office.

3.2 If there is an urgent situation during the survey (such as damaged and/or friable suspected asbestos materials, etc.) that will be classified as a RAC 1 or 2, alert an onsite safety representative or facility supervisor immediately. Call or email the NGB Region North IH Office and SOH POC as soon as possible. Additionally, within one week provide a summary of the situation with findings, recommendations, and any corrective actions already taken (if any).

3.3 An electronic draft report and field notes for each facility is due to the Region Northeast Industrial Hygienists Cynthia Harrison at cynthia.s.harrison2.civ@mail.mil and Jayson Allan at jayson.r.allan.civ@mail.mil., four weeks after the survey date. Do not wait until all surveys are completed before sending reports. Final reports are due two weeks after receipt of comments from the ARNG Region Northeast IH Office. All comments that were made on the draft report must be implemented. If there are any issues or questions regarding the comments, contact the ARNG Region Northeast IH Office. The following should be included for the final report:

3.3.1 The date of the survey, address, and the POC of the facility.

3.3.2 Do not collect or include social security numbers or birth dates of employees on any documents or reports.

mailto:cynthia.s.harrison2.civ@mail.mil mailto:jayson.r.allan.civ@mail.mil

3.3.3 A table of contents for the report.

3.3.4 The survey specifications outlined in paragraph 2 of this SOW.

3.3.5 A conclusion. Maximum of 1-2 paragraphs.

3.3.6 The following information shall be included in the appendices along with the information identified in paragraph 2. When applicable, appendices shall be referenced in the report. For example, “refer to Appendix A for surface wipe sample results.”

3.3.7 References. The list provided is only an example. Only the references used in writing the report should be included in the reference section. Since publication dates may change, verify that the last published reference date is used.

3.3.8 Field notes shall be provided as separate documentation from the report so that the reviewer can compare notes to the report.

3.3.9 The entire report and supporting documents in electronic format as PDF files. Send draft/final reports and supporting documents to Cynthia.s.harrison2.civ@mail.mil and Jayson.r.allan.civ@mail.mil. Please name report files as state_facility_city_mm_yyyy (i.e. NJ_Readiness Center_Trenton_10_2020).

4. General Information.

4.1 Quality Control (QC): The contractor shall develop and maintain an effective QC Plan (QCP) to ensure services are performed in accordance with this PWS.

The contractor shall develop and implement procedures to identify, prevent, and ensure non-recurrence of defective services. The contractor’s QCP is the means by which it assures itself that its work complies with the requirements of the contract. As a minimum, the contractor shall develop QC procedures that address the areas identified in Technical Exhibit 1, Performance Requirements Summary. After acceptance of the QCP, the contractor shall obtain the Contracting Officer’s (KO) acceptance in writing of any proposed changes to its

QCP.

4.2 Quality Assurance (QA): The Government shall evaluate the contractor’s performance under this contract in accordance with the Quality Assurance Surveillance Plan (QASP). This plan is primarily focused on what the Government must do to ensure that the contractor has performed in accordance with the performance standards. It defines how the performance standards will be applied, the frequency of surveillance, and acceptable quality level.

mailto:Cynthia.s.harrison2.civ@mail.mil mailto:Jayson.r.allan.civ@mail.mil

4.3. Recognized Holidays: The following are recognized US holidays and the organizations observed days off. The holidays that fall on a Monday are observed on the Friday prior to the actual holiday. The contractor shall treat these days as a holiday in compliance with section 1.4.4 of this PWS.

4.3.1. New Year’s Day: January 1st

4.3.2.. Martin Luther King, Jr.’s Birthday

4.3.3. President’s Day

4.3.4. Memorial Day

4.3.5. Independence Day: July 4th

4.3.6. Labor Day

4.3.7. Columbus Day

4.3.8. Veteran’s Day: November 11th

4.3.9. Thanksgiving Day

4.3.10. Christmas Day

4.4 Unscheduled gate closures by the Security Police may occur at any time causing all personnel entering or exiting a closed installation to experience a delay. This cannot be predicted or prevented. Contractors are not compensated for unexpected closures or delays. Contractors are required to follow the guidelines of each installation visited. Violation of post guidelines may result in termination of access to and driving privileges on the installation. Vehicles operated by contractor personnel are subject to search pursuant to applicable regulations. Moving violations of any contractor motor vehicle may also result in the termination of the contractor employee’s installation driving privileges.

4.5 The contractor’s employees shall become familiar with and obey the regulations of the installation; including fire, traffic, safety and security regulations while on the installation. Contractor employees should only enter restricted areas when required to do so and only upon prior approval. All contractor employees shall carry proper identification with them at all times. The contractor shall ensure compliance with all regulations and orders of the installation which may affect performance.

4.6 COMSEC/IT Security. All communications with DOD organizations are subject to communications security (COMSEC) review. All telephone communications networks are continually subject to intercept by unfriendly intelligence organizations. DOD has authorized the military departments to conduct COMSEC monitoring and recording of telephone calls originating from, or terminating at, DOD organizations. Therefore, the contractor is advised that any time contractor place or receive a call they are subject to COMSEC procedures. The contractor shall ensure wide and frequent dissemination of this information to all employees dealing with DOD information. The contractor is not authorized use of the Government's computer network.

4.7 Protection of Personally Identifiable Information (PII). As applicable, the contractor shall protect all Personally Identifiable Information (PII) encountered in the performance of services in accordance with DFARS 224.103, DoDD 5400.11 and DoD 5400.11-R. If a PII breach results from the contractor’s violation of the aforementioned policies, the contractor is responsible for all notification costs, call-center support costs, and credit monitoring service costs for all individuals whose PII has been compromised.

4.8 CAC Requirements: The Common Access Card (CAC) is the

DOD Federal Personal Identity Verification (PIV) credential. The contractor is not authorized or required to have a CAC card in the performance of services.

4.9 AT Level 1 Awareness Training (AT): All contractor employees requiring access to Army Installations, facilities, and controlled access areas shall complete Level 1 AT prior to gaining access to any MDARNG facility. The contractor shall submit certificates of completion for the contractor and/or subcontractor conducting the training, to the COR, within 15 calendar days of the scheduled on-site training. Level 1 AT is available at http://jko.jten.mil.Administration

4.10 Identification of Contractor Employees: All contractors working in a situation where their contractor status is not obvious to third parties are required to identify themselves as such to avoid creating an impression that they are Government employees. The contractor shall ensure that all documents or reports produced by contractor personnel are suitably marked as contractor products or that contractor participation is appropriately disclosed. The contractor’s status as a “contractor” shall be predominantly displayed in all correspondence types (to include signature blocks on email) and dealings with Government or non- Government entities/Contractor personnel shall wear identification badges distinguishing themselves as such. The badges shall have the company name, employee name and the word “contractor” displayed. The contractor shall retrieve all identification media (including vehicle passes) from their employees who depart employment for any reason. All identification media (i.e., badges and http://jko.jten.mil.administration/ vehicles passes) shall be returned to the KO within 14 days of an employee’s departure.

4.11 Combating Trafficking in Persons: The United States Government has adopted a zero tolerance policy regarding trafficking in persons. Contractors and contractor employees shall not engage in any form of trafficking in persons in performance of the contract. This includes but is not limited to procuring commercial sex acts and the use of forced labor in the performance of the contract. The Contractor shall notify its employees of the United States Government’s zero tolerance policy. The necessary actions will be taken against contractor for violation of this policy. Such actions may include, but are not limited to, removal from the contract, revocation of contract, and termination of employment. The Contractor shall take the appropriate action, up to and including termination, against employees or subcontractors that violate the US Government policy as described at FAR 22.17.

4.12 Organizational Conflicts of Interest (OCI): The contractor and subcontractor personnel will not be performing services under this contract that may receive, have access to or participate in the development of proprietary or source selection information (e.g., cost or pricing information, budget information or analyses, specifications or work statements, etc.) or perform evaluation services which may create a current or subsequent OCIs, as defined in FAR Subpart 9.5.

5. Definition and Acronyms:

5.1 CONTRACTOR. A supplier or vendor awarded a contract to provide specific supplies or service to the government. The term used in this contract refers to the prime.

5.2 CONTRACTING OFFICER (KO). A person with authority to enter into, administer, and or terminate contracts, and make related determinations and findings on behalf of the government. Note: The only individual who can legally bind the government.

5.3 CONTRACTING OFFICER'S REPRESENTATIVE (COR). An employee of the U.S. Government designated by the KO to monitor contractor performance.

Such appointment shall be in writing and shall state the scope of authority and limitations. This individual has authority to provide technical direction to the Contractor as long as that direction is within the scope of the contract, does not constitute a change, and has no funding implications. This individual does NOT have authority to change the terms and conditions of the contract.

5.4 DEFECTIVE SERVICE. A service output that does not meet the standard of performance associated with the Performance Work Statement.

5.5 DELIVERABLE. Anything that can be physically delivered and includes survey notes or reports.

5.6 KEY PERSONNEL. Contractor personnel that are evaluated in a source selection process and that may be required to be used in the performance of a contract by the Key Personnel listed in the SOW. When key personnel are used as an evaluation factor in best value procurement, an offer can be rejected if it does not have a firm commitment from the persons that are listed in the proposal.

5.7 PHYSICAL SECURITY. Actions that prevent the loss or damage of Government property.

5.8 QUALITY ASSURANCE. The government procedures to verify that services being performed by the Contractor are performed according to acceptable standards.

5.9 QUALITY ASSURANCE SURVEILLANCE PLAN (QASP). An organized

written document specifying the surveillance methodology to be used for surveillance of contractor performance.

5.10 QUALITY CONTROL. All necessary measures taken by the Contractor to assure that the quality of an end product or service shall meet contract requirements.

5.11 SUBCONTRACTOR. One that enters into a contract with a prime contractor. The Government does not have privity of contract with the subcontractor.

5.12 WORK DAY. The number of hours per day the Contractor provides services in accordance with the contract.

5.13 WORK WEEK. Tuesday through Friday, unless specified otherwise.

5.2 ACRONYMS:

AEI

AFARS Army Federal Acquisition Regulation Supplement AR Army Regulation AT/OPSEC Antiterrorism/Operational Security CFR Code of Federal Regulations CONUS Continental United States (excludes Alaska and Hawaii) COR Contracting Officer Representative COTS Commercial-Off-the-Shelf DA Department of the Army DD250 Department of Defense Form 250 (Receiving Report)

DD254 Department of Defense Contract Security Classification Specification DFARS Defense Federal Acquisition Regulation Supplement DOD Department of Defense FAR Federal Acquisition Regulation GFP/M/E/S Government Furnished Property/Material/Equipment/Services IA Information Assurance IS Information System(s) KO Contracting Officer OCI Organizational Conflict of Interest ODC Other Direct Costs PII Personally Identifiable Information PIPO Phase In/Phase Out POC Point of Contact PRS Performance Requirements Summary QA Quality Assurance QAP Quality Assurance Program QASP Quality Assurance Surveillance Plan QC Quality Control QCP Quality Control Program SOW Statement of Work TE Technical Exhibit

6. Contractor Requirements

6.1 The contractor shall arrive on time to prepare and conduct the IH survey.

6.2 Personal appearance. The contractor and staff shall present a professional appearance wearing appropriate clothing for maintenance work locations and conduct themselves in a professional manner at all times. Shorts, skirts, and sleeveless garments do not protect skin adequately.

6.3 Contractor and staff will present with good personal hygiene and ensure clothing is clean and neat on their person.

6.4 Clothing will not be derogatory or offensive in nature or suggestive of sexual behavior or conduct unbecoming in the presence of employees.

6.5 The contractor shall abide by applicable laws and regulations governing the safety and health programs.

6.6 Complete disclosure. Complete disclosure of any past incidents involving the professional duties of staff which might have an impact on professional standing, such as charges (unless acquitted) involving either felonies or misdemeanors (other than minor traffic violations) is a necessary part of the competency process. This disclosure must also specifically include reports of any actions, claims, charges of malpractice ever brought against any of the staff or subcontractors (either individually or as a part of a group), as well as the outcome (or current status) of any such case. The ARNG IH representative will evaluate any such incident and determine whether it should be disqualifying.

6.7 If at any time during the contract period it is discovered that an employee is currently pending charges, or has previously been convicted of any of the aforementioned incidents, the contract may be terminated pending further investigation. Upon discovery the COR will consult with the contractor and will handle situations on a case by case basis.

6.8 Unacceptable skills. The ARNG IH Office reserves the right to assess the services provided and the staff providing the service at any time during the contract. Should there be a question on the skill or employee is found to be unsatisfactory or unfit for duty, they will be asked to cease performance of such services.

6.9 Misconduct/Disruption of Services. At any time during the performance of this contract, the COR may immediately request the removal of contractor staff whose actions or impaired state, results in the clear disruption to the work force.

6.10 Litigation. In the event of litigation/investigation of a claim of liability or malpractice the contractor shall cooperate fully with government authorities and designated officials in the investigation of the claim or preparation of litigation.

The contractor shall immediately notify the KO and COR of any claims and promptly furnish copies of all pertinent papers received; cooperate with the government in the processing, review, settlement, or defense of the suit, action or claim; and authorize government representatives to settle or defend the claims and to represent the healthcare provider in, or take charge of, any litigation involved in such action.

6.11 Confidentiality. The contractor shall abide by the agency requirements concerning the nature of limited privileged communication of information gathered to entities outside of the ARNG. The contractor shall not release any information regarding ARNG worksites, facilities or shops without first receiving written approval from the COR.

7. Conflict of Interest

7.1 The contractor shall not introduce any new services without prior approval of the COR. In disagreements or deviations from established protocols, COR will be the deciding authority.

7.2 The contractor shall not use services rendered pursuant to this agreement as part of a study, research grant, or publication without the prior written consent of the KO.

7.3 The contractor shall not bill the worksite or anyone else for services rendered. The only compensation the contractor is entitled to for performance of the contract is payment as specified by this contract. .

7.4 The contractor and staff shall not be an employee of the United States government if the employment would create a conflict of interest

7.5 Vehicle registration. The contractor shall comply with the local installation requirements for vehicle registration and operation on the military facility. Any vehicle operated by the contractor in performance of this service must have the minimum liability coverage required by the state in which the installation is located.

7.6 The agency has a strict policy against sexual harassment, sexual assault and discrimination of any kind. Contractor and employees must not engage in these acts will treat everyone with respect and without discrimination based on gender, race, sexual orientation, or religious beliefs.

8 Points of contact. Contact the NGB Region Northeast IH Office for further information. Technical POCs are Cynthia Harrison (Cynthia.s.harrison2.civ@mail.mil) and Jayson Allan (jayson.r.allan.civ@mail.mil)

Attachments

1. Regulations and Standards

2. ARNG Lead Sampling Guide

3. Required Industrial Hygiene Equipment and Supplies

4. Deriving Risk Assessment Codes for Health and Safety

Attachment 1

Regulations and Standards

1. Title 29, Code of Federal Regulations (CFR), Part 1910, Occupational Safety and Health Administration, current Ed. http://www.osha.gov/comp-links.html

2. Department of Defense Instruction (DODI) 6055.01, Department of Defense Occupational Safety and Health (OSH) Program, 14 October, 2014.

http://www.dtic.mil/whs/directives/corres/pdf/605501p.pdf

3. Army Regulation (AR) 11-34, The Army Respiratory Protection Program, 25 July 2013. http://armypubs.army.mil/epubs/pdf/r11_34.pdf

4. AR 40-5, Medical Services, Preventive Medicine, 25 May 2007.

http://armypubs.army.mil/epubs/pdf/R40_5.pdf

5. AR 385-10, The Army Safety Program, 27 November 2013.

http://armypubs.army.mil/epubs/pdf/r385_10.pdf

6. Department of the Army Pamphlet (DA PAM) 40-501, Medical Services, Army Hearing Program, 8 January 2015.

http://armypubs.army.mil/epubs/pdf/P40_501.pdf

7. DA PAM 40-11, Preventive Medicine, 22 July 2005, RAR issue date: 19 October 2009. http://armypubs.army.mil/epubs/pdf/p40_11.pdf

8. DA PAM 40-503, Medical Services, The Army Industrial Hygiene Program, 2 April 2013. http://armypubs.army.mil/epubs/pdf/P40_503.PDF

9. UFC 3-410-01FA, Heating, Ventilating, and Air Conditioning Systems, 1 July 2013, change 1, October 2014.

http://www.wbdg.org/ccb/DOD/UFC/ufc_3_410_01.pdf

10. Threshold Limit Values (TLVs) and Biological Exposure Indices (BEIs), American Conference of Governmental Industrial Hygienists (ACGIH), current Ed.

11. Industrial Ventilation – A Manual of Recommended Practice for Design, ACGIH, current Ed.

12. American National Standards Institute (ANSI)/International Safety Equipment Association (ISEA) Z358.1-2009, Emergency Eyewash and Shower Equipment.

http://www.osha.gov/comp-links.html http://www.dtic.mil/whs/directives/corres/pdf/605501p.pdf http://www.dtic.mil/whs/directives/corres/pdf/605501p.pdf http://armypubs.army.mil/epubs/pdf/r11_34.pdf http://armypubs.army.mil/epubs/pdf/r385_10.pdf http://armypubs.army.mil/epubs/pdf/P40_501.pdf http://armypubs.army.mil/epubs/pdf/p40_11.pdf http://armypubs.army.mil/epubs/pdf/P40_503.PDF http://www.wbdg.org/ccb/DOD/UFC/ufc_3_410_01.pdf

13. ANSI/American Society of Heating, Refrigerating and Air-Conditioning Engineers, Inc. (ASHRAE) 55-2013, Thermal Environmental Conditions for Human Occupancy.

14. ANSI/ASHRAE 62.1-2016, Ventilation for Acceptable Indoor Air Quality.

15. The Lighting Handbook, IESNA, current Ed.

16. American Society for Testing and Materials (ASTM) Standard E1728, Standard Practice for Collection of Settled Dust Samples Using Wipe Sampling Methods for Subsequent Lead Determination, ASTM International, West Conshohocken, Pennsylvania, www.astm.org, 2010.

17. Industrial Hygiene Sampling Guide for Surface Lead in Readiness Centers, Army National Guard (ARNG) Industrial Hygiene Program, 26 October 2015.

18. Memorandum for the Chiefs of Staff of all States, Puerto Rico, the US Virgin Islands, Guam, and the District of Columbia, National Guard Bureau, ARNG- CSG, subject: Possible Lead Dust Hazard in Army National Guard (ARNG) Readiness Centers, 23 September 2015.

19. Army National Guard Pamphlet (NG Pam) 420-15, Guidelines and Procedures for Rehabilitation and Conversion of Indoor Firing Ranges, 3 November 2006.

Attachment 2 ARNG Lead Sampling Guide

ARMY NATIONAL GUARD

INDUSTRIAL HYGIENE SAMPLING GUIDE FOR

SURFACE LEAD IN READINESS CENTERS

26 OCTOBER 2015

1. REFERENCES. See Appendix A.

2. PURPOSE. The purpose of this guide is to provide clear instruction for conducting annual lead surface wipe sampling at Army National Guard (ARNG) Readiness Centers (RCs) that contain active, nonfunctional, closed, or disposed indoor firing ranges (IFRs).

The annual surface sampling to assess possible lead surface levels in the RC does not take the place of the mandated comprehensive industrial hygiene survey; active IFR industrial hygiene evaluation; or assessment of inactive IFRs identified for rehabilitation and conversion.

3. AUTHORITY.

a. Workplace Hazard Assessment. The Department of the Army Pamphlet (DA- PAM) 40-503, paragraph 1-8b(3), mandates that facilities provide healthful work environments in accordance with the most stringent assessment standards (reference 1). The Occupational Health and Safety Administration (OSHA) through the Code of Federal Regulations (29 CFR 1910), have enforceable regulatory standards for workplace safety (reference 2).

b. Sampling Methodology. The American Society for Testing and Materials (ASTM) International is an international standards organization that develops and publishes voluntary consensus technical standards for a wide range of materials, products (such as lead wipes), systems, and services, including surface wipe testing for lead (reference 3).

c. Evaluation Criteria. The recently signed Memorandum for the Chiefs of Staff (COS) regarding possible lead in RCs (reference 4) sets forth the requirement to conduct surface wipe sampling annually and to set limitations on public and family member access to the RCs based on unacceptable sampling results. The memorandum requires surface levels less than forty micrograms per square foot (<40 μg/ft2) in areas that will accessed by the public or family members. Army National Guard Regulation (NGR) 385-15 paragraph 5-4 requires a housekeeping program sufficient to maintain all active IFR surfaces as free as practicable of accumulations of lead dust (reference 5). The Army National Guard Pamphlet (NG Pam) 420-15 paragraph 3-6(o) states that the lead surface goal in rehabilitated IFRs is <200 μg/ft2 prior to encapsulation (reference 6). The NG Pam 420-15 paragraph 3-6(p) also requires that annual testing continue after successful IFR surface cleaning, encapsulation, and enclosure (tile or linoleum) to verify that no lead migration from the substrate is occurring (reference 6).

SUBJECT: ARNG Industrial Hygiene Sampling Guide for Surface Lead in Readiness Centers, 26 October 2015

4. SAMPLING PLANNING AND INSTRUCTIONS.

a. Sampling Plan.

1) Identification of Personnel Qualified to Conduct Sampling. As responsible office for the execution of the surface wipe sampling program (reference 4), each ARNG Regional IH Office will make the final determination as to the qualification of personnel to conduct lead surface wipe sampling. All personnel performing the wipe sampling surveys must read this guidance and either demonstrate the skills necessary to perform the work or provide proof of certification in lead sampling prior to conducting the surveys.

2) Site Identification. Complete the Facility Information Spreadsheet provided with this document, ensuring the list of all RCs containing IFRs (regardless of status) in the state, district, or territory is complete. Identify the status of IFRs (active, nonfunctional, closed, or disposed) using the criteria outlined in the ARNG COS Memorandum (reference 4) in advance if possible.

3) Coordination and Travel Planning. Coordinate with the state, district, or territory representative in the Safety and/or Occupational Health Office to arrange dates and times to conduct sampling. Plan travel routes that allow multiple facilities to be visited in a day when feasible.

4) Team Member Designation. For quality control purposes and ease of performance, it is recommended that all sampling surveys be conducted by teams of at least two personnel. Because there is variability between each person’s technique and wiping pressure during sampling, a ‘sampler’ and ‘assistant’ should be designated in each team (reference 3). The ‘sampler’ will conduct all wiping within a state, district, or territory to maintain consistency in sampling results.

5) Sample Collection Plan. Thirty five (35) samples and three blanks will be collected from each RC with an active or nonfunctional (closed but not cleaned and converted) IFR. Twenty three (23) samples and two blanks will be collected from each RC with a closed (cleaned) or disposed IFR. Sampling will be conducted using the method outlined in the ASTM E 1728 (reference 3). Sample location and methods are discussed in paragraph 5c. Actual sample locations will be recorded on a floor plan of each facility.

b. Sampling Supplies. The ARNG Regional IH Offices will provide all sampling supplies to their designated sampling teams in the region and any deviation from the following listed materials must be approved.

Centers, 26 October 2015

1) Wipes. Use Environmental Express® Ghost Wipes™ with a valid expiration date or wipes meeting the criteria outlined in ASTM E1792 (reference 7).

2) Containers. Collected wipe samples will be stored and transported in individual plastic containers with secure, screw on lids. Wipes will not be placed directly into small re-sealable plastic bags because as the ASTM E1728 relates, laboratory recoverability is improved when using straight sided plastic containers (reference 3).

3) Bags. Plastic storage bags for collected wipe samples/plastic containers will be used to further protect samples.

4) Gloves. Disposable, one time use, powder free gloves are required for each sample (reference 3).

5) Templates. To achieve the desired laboratory detection limit of 40 μg/ft2, 30 centimeter (cm) by 30 cm pre-cut cardboard one time use templates must be used.

c. Surface Wipe Sampling Procedures.

1) Supply Request. Request supplies by e-mail no less than two weeks prior to the start of the surveys using the form in Appendix B. The provided supply packs will include administrative support items such as field data sheets, laboratory chain of custody and analysis request forms, pre-labeled shipping boxes, permanent markers, duct tape, gloves, and re-sealable bags.

2) Control, Storage, and Transportation of Sampling Supplies. Maintain wipes, templates, plastic tubes, and lids in closed, re-sealable bags until ready for use and keep clean and away from contamination. Maintain visual control of supplies at all times at facilities. Do not leave collected samples and supplies in vehicles overnight and avoid temperature extremes of heat or cold.

3) Damaged Supplies. Use only supplied wipes in undamaged packaging. If a wipe is found to be dried out or damaged, it must be discarded. If other supplies are found damaged or contaminated, do not use.

4) Surface Selection. Select floor surfaces that are “solid, hard, and non-porous” as much as possible. Choose locations near the edges of rooms where dust is most likely settled. Seek out locations under desks or cabinets where cleaning occurs less frequently. Table 1 (for RCs with active or nonfunctional IFRs) and Table 2 (for RCs with closed or disposed IFRs) list surface location, type, and collection quantity. If the locations listed in the table are not present at the RC, move on to the next location designation.

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Table 1. Sample Collection for RCs with Active or Nonfunctional IFRs.

Sample Collection Location Surface Type Quantity Samples

IFR1 Floor 3 IFR1 Wall 3 per wall IFR1 Ceiling/Elevated Location 3 Floor Area Outside of IFR Floor 1 Drill Hall Floor 2 Rooms specifically occupied/rented by the public (Boy/Girl Scouts etc.)

Floor 1 per room Table / Desk 1 per room

Family Readiness Office Floor 1 per office Table / Desk 1 per office

Break Room Floor 1 Table 1

Kitchen Floor 1 Counter / Prep Area 1

Other Occupied Offices or Rooms (to reach a total of 35 samples) Floor To be determined Blanks N/A 3

TOTAL 38

1 Samples Determined by NGR 385-15 and NG Pam 420-15 (references 5 and 6).

Table 2. Sample Collection for RCs with Closed or Disposed IFRs.

Sample Collection Location Surface Type Quantity Samples

Former IFR Floor 2 Former IFR Wall 1 per wall Floor Area Outside of former IFR Floor 1 Drill Hall Floor 2 Rooms specifically occupied/rented by the public (Boy/Girl Scouts etc.)

Floor 1 per room Table / Desk 1 per room

Family Readiness Office Floor 1 per office Table / Desk 1 per office

Break Room Floor 1 Table 1

Kitchen Floor 1 Counter / Prep Area 1

Other Occupied Offices or Rooms (to reach a total of 23 samples) Floor To be determined Blanks N/A 2

TOTAL 25

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5) Sampling Supplies. Use a new pair of gloves and a new, clean template for the collection of each sample (reference 3). No sampling supplies will be reused.

6) Template Placement. With clean hands and only touching the outer edges, the ‘assistant’ will place a clean template on the floor surface without disturbing existing dust. They will ensure the template has the ability to lay flat and secure the template to the floor surface by its outer edges with tape. Template location will be recorded on the facility floor plan. Without touching the wipe, the ‘assistant’ will tear open the top edge of the wipe packet and hold it ready for the ‘sampler’.

7) Sample Collection. The ‘sampler’ will don a pair of clean, powder free gloves;

remove the wipe from the open package, unfold it, and begin wiping in accordance with the method outlined in ASTM E 1728 and depicted in the following (reference 3).

a) “Using an open flat hand with the fingertips together, place the wipe on the surface to be sampled. Wipe the selected surface area, side to side, in an overlapping “S” pattern while applying moderate pressure to the fingertips. Wipe the surface so that the entire selected surface area is covered. Perform the wiping process using the fingers not the entire hand” (reference 3).

b) “Fold the wipe in half with the collected dust side folded inward, and repeat the preceding wiping procedure within the selected sampling area using an overlapping up and down “S” pattern” (reference 3).

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c) “Fold the wipe in half again with the collected dust side folded inward, and repeat the wiping procedure one more time, around the perimeter, concentrating on collecting settled dust from all corners and edges within the selected surface area” (reference 3).

d) While the ‘sampler’ is collecting the wipe sample, the ‘assistant’ will ready the collection tube and cap.

8) Documentation and Labeling. Use a permanent marker to mark the side of the collection tube with the sampling identification (ID). The following sampling ID naming convention will be followed:

State two letter abbreviation (space) First Four Letters of Town/City of Readiness Center Location (space) Sample Number (space)

Example: PA HARR 1, PA HARR 2, PA HARR 3, and so on.

9) Blanks. Prepare the number of blanks described in tables 1 and 2. While wearing a pair of clean gloves open a packet, remove the wipe, expose briefly to air and place into a plastic tube and label with sample ID criteria listed above.

10) Field Data Sheets. Fill out the provided field data sheets completely including signature and date. Use the example provided in Appendix C.

11) Sample Shipping. Fill out laboratory request for analysis of the selected laboratory and include a copy of the field data sheet with the analysis request and samples. Appendix D lists important details to include on the laboratory chain of custody. Keep a copy of the lab request and field data sheet. E-mail a copy of the lab request and field data sheet to the Regional ARNG IH Office.

d. Results Discussion. The Regional IH Office will receive sample results and will provide data in a ‘preliminary findings’ e-mail that will be followed by a formal published report summarizing results for the state, district, or territory.

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5. ADDITIONAL ASSISTANCE. The technical point of contacts are the ARNG Regional Industrial Hygienists listed below.

a. Midwest Region: AK, IA, IL, IN, KS, MI, MN, MO, OH, ND, NE, SD, WI

1) Scott Carpenter, (410) 939-5819, scott.c.carpenter.civ@mail.mil

2) Randy Fritz, (303) 210-8722, randy.c.fritz.civ@mail.mil

b. Northeast Region: CT, DC, DE, MA, MD, ME, NH, NJ, NY, PA, RI, VA, VT, WV

1) Cindy Harrison, (410) 942-0273, cynthia.s.harrison2.civ@mail.mil

c. Southeast Region: AL, AR, FL, GA, KY, LA, MS, NC, OK, PR, SC, TN, TX, VI

1) Ken Fuller, (404) 559-4174, mandan.k.fuller.civ@mail.mil

2) Etienne Rodriguez, (404) 559-4174, etienne.rodriguez.civ@mail.mil

d. Southwest Region: AZ, CA, CO, GU, HI, ID, MT, NM, NV, OR, UT, WA, WY

1) Ron Faull, (916) 854-1491, ronald.w.faull.mil@mail.mil

2 Encls KENNETH A. FORSYTHE, III

1. Facility Information Spreadsheet Chief, ARNG Industrial Hygiene

2. Wipe Sampling Field Data Sheet

FORSYTHE.KENNETH.A

USTIN.III.1244948533

Digitally signed by

FORSYTHE.KENNETH.AUSTIN.III.1244948533

DN: c=US, o=U.S. Government, ou=DoD, ou=PKI, ou=USA, cn=FORSYTHE.KENNETH.AUSTIN.III.1244948533 Date: 2015.10.26 17:21:48 -04'00'

Centers, 26 October 2015

APPENDIX A

REFERENCES

1. Department of the Army Pamphlet (DA-PAM) 40-503, The Army Industrial Hygiene Program, 2 April 2013.

2. Title 29 Code of Federal Regulations (CFR), Part 1910, 2015 Edition, Occupational Safety and Health Administration (OSHA).

3. American Society for Testing and Materials (ASTM) Standard E1728, 2010, "Standard Practice for Collection of Settled Dust Samples Using Wipe Sampling Methods for Subsequent Lead Determination," ASTM International, West Conshohocken, PA, www.astm.org.

4. Memorandum for the Chiefs of Staff of all States, Puerto Rico, the US Virgin Islands, Guam, and the District of Columbia. SUBJECT: Possible Lead Dust Hazard in Army National Guard (ARNG) Readiness Centers, 23 September 2015.

5. Army National Guard Regulation (NGR) 385-15, Policy and Responsibility for Inspection, Evaluation, and Operation of Army National Guard Indoor Firing Ranges, 3 November 2006.

6. Army National Guard Pamphlet (NG Pam) 420-15, Guidelines and Procedures for Rehabilitation and Conversion of Indoor Firing Ranges, 3 November 2006.

7. ASTM Standard E1792, 2011, “Standard Specification for Wipe Sampling Materials for Lead in Surface Dust,” ASTM International, West Conshohocken, PA, www.astm.org.

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APPENDIX C

SAMPLE FIELD DATA SHEET

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APPENDIX D

CHAIN OF CUSTODY/LABORATORY ANALYSIS REQUEST

Include:

The Regional IH Name and Contact Information

The State/District, Location, and Date of the Sampling

Select ‘Normal Business Hours’ and ‘Standard Turn Around Time’.

Check ‘Include COC/Field Data Sheets with Report’

Check ‘Lead (Pb) Analysis’ for ‘Dust in Wipes’

List Sample IDs and Wipe Area (30cm X 30cm = 900 cm2)

Include ‘Submitted By’ and ‘Signature’

Attachment 3 Required Industrial Hygiene Equipment

All Equipment on this list must be provided by the contractor for the survey and be under current calibration.

Equipment Capability Purpose Quantity

Indoor Air Quality Meter

Carbon Monoxide, Carbon Dioxide, Percent Relative

Humidity, Temperature

Measure indoor air quality parameters.

1 per survey location

Light Meter Footcandles Measure illumination

1 per survey location

B-1

Attachment 4

DERIVING RISK ASSESSMENT CODES (RACs) FOR CHRONIC HAZARDS Department of Defense Instruction 6055.01, Appendix to Enclosure 3

Department of Defense Occupational Safety and Health Program, 14 October 2014

1. DETERMINE THE HEALTH HAZARD SEVERITY CODE (HHSC). Use the following procedures to assess exposure and medical effects points and determine the health hazard severity category (HHSC). The HHSC reflects the magnitude of exposure to a single physical, chemical, or biological agent and the effects of chronic exposure.

a. Determine Exposure Points.

AER Possible?

Exposure Condition

95th percentile <10% of OEL

95th percentile between 10% of OEL and 50% of OEL

95th percentile between 50% of OEL and

OEL

95th percentile

>OEL

No 0 3 5 7 Yes 1 – 2 4 6 9

AER = Alternate exposure route, such as skin absorption, ingestion.

OEL = Occupational Exposure Limit, such as OSHA PEL or ACGIH® TLV®.

b. Determine Medical Effects Points.

Condition Points No medical effect, such as nuisance noise and nuisance odor 0 Temporary reversible illness requiring supportive treatment, such as eye irritation and sore throat 1 - 2

Temporary reversible illness with a variable but limited period of disability, such as metal fume fever 3 - 4

Permanent, non-severe illness or loss of capacity, such as permanent hearing loss 5 - 6

Permanent, severe, disabling, irreversible illness, such as asbestosis, lung cancer, or death 7 - 8

c. Determine the HHSC by totaling the points assessed.

Total Points (sum of Exposure Points [1a] and Medical Effects Points [1b]) HHSC

13 – 17 I

9 – 12 II

5 – 8 III

0 – 4 IV

B-2

APPENDIX B (CONTINUED)

2. DETERMINE THE EFFECT PROBABILITY CATEGORY (EPC). Use the following procedures to assess exposure frequency and duration to determine the effect probability category (EPC). The EPC is a function of the duration and frequency of exposure and the number of exposed personnel.

a. Determine Duration and Frequency of Exposure Points. Add exposure duration points and exposure frequency points, divide total by 2, then round UP.

Points

Exposure Duration >8 hours/day 6-8 hours/day 4-6 hours/day 2-4 hours/day 1-2 hours/day

30-60 minutes/ day

15-30 minutes/ day

0-15 minutes/ day 8 8 6 5 4 3 2 1

Points

Exposure Frequency

Daily 2-3 times/week Weekly 2-3 times/ month Monthly Quarterly or 2-3 times/year

Annual Less than

Annual 8 7 6 5 4 3 2 1

b. Determine Number of Exposed Personnel Points.

Number of Exposed Workers Points < 5 1 - 2

5 - 9 3 - 4 10 - 49 5 - 6

> 49 7 - 8

c. Determine the EPC by totaling the points assessed.

Total Points (sum of Exposure Duration and Frequency Points [2a] and Exposed

Personnel Points [2b])

EPC

13 – 17 A 9 – 12 B 5 – 8 C 0 – 4 D

B-3

APPENDIX B (CONTINUED)

3. Determine the RAC for Chronic Hazards.

HHSC EPC

A B C D

I 1 1 2 3

II 1 2 3 4

III 2 3 4 5

IV 3 4 5 5

4. RAC Descriptor.

RAC Descriptor 1 Critical 2 Serious 3 Moderate 4 Minor 5 Negligible

DERIVING RACs FOR SAFETY HAZARDS

1. Use the matrix and descriptive definitions below as a model to determine the RAC for safety hazards:

a. Determine Accident Probability.

b. Determine Hazard Severity.

Code Description A Likely to occur immediately B Probably will occur in time C Possible to occur in time D Unlikely to occur

Code Description I Death, permanent total disability or loss of facility or asset

II Permanent partial disability, temporary total disability in excess of 3 months or major property damage

III Lost-workday injury or compensable injury or minor property damage

IV

Minimal threat to personnel or property, first-aid, minor supportive medical treatment, but still a violation of a standard

2. Determine the RAC for health hazards by using the following matrix to measure safety severity and mishap probability factors.

HAZARD

SEVERITY

CODE

ACCIDENT PROBABILITY CODE

A B C D

I 1 1 2 3

II 1 2 3 4

III 2 3 4 5

IV 3 4 5 5

From Table 3 of Department of Defense Instruction 6055.1, Department of Defense Occupational Safety and Health Program, 19 August 1998 (reference 1).

3. RAC DESCRIPTOR

RAC DESCRIPTOR

1 CRITICAL

2 SERIOUS

3 MODERATE

4 MINOR

5 NEGLIGIBLE