FA9301-15-R-0005 _Attachment_2 _Appendix_E_EAFB_Lead_Management_Plan.pdf

EDWARDS AIR FORCE BASE

LEAD MANAGEMENT PLAN

March 2014

412th Civil Engineer Directorate

Environmental Management Division

Edwards Air Force Base, California

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EAFB Lead Management Plan Revision History

Date Name Description

21 March

Ron Czarnecki, Jeanette Van Norden, Michele LaComb, Bioenvironmental Engineering

Revise organizational structure to latest AF/Base changes; updated various responsibilities to match industry/base rules and regulations

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TABLE OF CONTENTS

Section No. Title Page No.

1.0 INTRODUCTION

2.0 PERSONNEL RESPONSIBILITIES

3.0 BASE ORGANIZATIONAL RESPONSIBILITIES FOR IMPLEMENTING

LEAD-PAINT PROGRAMS

4.0 EDWARDS AFB LEAD HAZARD MANAGEMENT TEAM RESPONSIBILITIES3

5.0 MEDICAL GROUP COMMANDER

5.1. Aerospace Medicine Responsibilities

5.2. Pediatrics/Family Practice Flight Commanders

6.0 PUBLIC HEALTH/PUBLIC HEALTH OFFICER

6.1. Public Health Responsibilities

7.0 412 AMDS/SGPB BIOENVIRONMENTAL ENGINEERING

7.1. The BE Responsibilities

8.0 CIVIL ENGINEERING

8.1 Civil Engineering Responsibilities

8.2 Lead-Based Paint/Hazard Program Officer

8.2.1 Edwards AFB LBPPO Responsibilities

8.3 Project Manager(s) Responsibilities

9.0 MILITARY FAMILY HOUSING

10.0 ENVIRONMENTAL MANAGEMENT

10.1 Environmental Management Responsibilities

11.0 FACILITY MANAGERS/BUILDING MANAGERS

11.1 Facility Managers Responsibilities

12.0 CONTRACTING

12.1 Contracting Officers Responsibilities

12.2 Contracting Office Responsibilities for Supplies and Services

13.0 REFERENCES

APPENDIX A UPDATE OF AIR FORCE MILITARY COMMAND GUIDANCE ON

LEAD-BASED PAINT IN FACILITIES .................................................................... A-1

APPENDIX B LIST OF DEFINITIONS AND TERMS ........................................................B-1

APPENDIX C LEAD EXPOSURE RISK ASSESSMENT QUESTIONNAIRE ................ C-1

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LIST OF ABBREVIATIONS, ACRONYMS, AND SYMBOLS

AFB Air Force Base

AFI Air Force Instruction

AFMC Air Force Materiel Command

AFRESS Air Force Reportable Event Surveillance System

AFRL Air Force Research Laboratory

BE Bioenvironmental Engineering

BLL Blood Lead Level

CAA Clean Air Act

Cal/OSHA California Occupational, Safety, And Health Administration

CCR California Code Of Regulations

CDC Center For Disease Control

CDPH California Department Of Public Health

CE Civil Engineering

CFR Code Of Federal Regulations

DOD Department Of Defense

DTSC Department Of Toxic Substance Control

EBLL Elevated Blood Lead Levels

ESOHC Environmental, Safety, And Occupational Health Council

FAS Functional Area Staff

HM Hazardous Material

HWMP Edwards Air Force Base Hazardous Waste Management Plan

EESOH-MIS Enterprise Environmental Safety And Occupational Health- Management Information System

HUD Housing And Urban Development

IAW In Accordance With

JA Judge Advocate

LBP Lead-Based Paint

LBPPO Lead-Based Paint Program Officer

LMP Lead Management Plan

LTI Lead Toxicity Investigations

M&R Maintenance And Repair

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LIST OF ABBREVIATIONS, ACRONYMS, AND SYMBOLS (Concluded)

MFH Military Family Housing

MWR Moral Welfare Recreation

O&M Operations And Maintenance

OSHA Occupational Safety And Health Administration

PEL Permissible Exposure Limit

PH Public Health ppm Parts Per Million

QAE Quality Assurance Evaluator

RACs Risk Assessment Codes

RCRA Resource Conservation And Recovery Act

SEL Substrate Equivalent Lead

SOW Statement of Work

T.O. Technical Order

TSCA Toxic Substances Control Act

TWA Time Weighted Average

U.S. United States

U.S.C. United States Code

U.S. EPA United States Environmental Protection Agency kg Kilogram mg/cm2 Milligram Per Square Centimeter µg/dL Micrograms Per Deciliter µg/ft2 Micrograms Per Square Foot µg/m3 Micrograms Per Cubic Meter Of Air

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1.0 INTRODUCTION

The Air Force Materiel Command’s (AFMC’s), Update of AFMC Guidance on Lead-Based

Paint (LBP) in Facilities (Our Memo, 16 Jun 93) (27 December 2000), (Appendix A) establishes requirements and assigns responsibility for lead hazard management at AFMC installations.

This document outlines the responsibilities of Edwards Air Force Base (AFB) 412th Civil Engineer Directorate (CE); Environmental Management Division (EM), Bioenvironmental Engineering (BE), facility managers, Air Force Test Center (AFTC) Contracting, and the 412th Medical Group Center Commander. The Air Force Policy and Guidance specifies actions that must be taken to protect facility occupants, workers, and the environment from exposure to lead hazards. Those steps include:

a. Identify, evaluate, control, and eliminate LBP hazards at housing, child-occupied facilities, or portions of a facility frequented by children under the age of 7.

b. Ensure a worker protection program is in place and followed.

c. Restrict the use of LBP.

d. Protect facility occupants during renovation activities.

e. Comply with United States Environmental Protection Agency (U.S. EPA) and California regulations applicable to lead.

f. Practice in-place management, but when feasible, remove LBP during renovations.

g. Responsible organizations will work together following this plan to ensure protection and/or elimination of hazards.

h. The Armstrong Laboratory Lead Exposure Hazard Management Guide and the Housing and Urban Development (HUD) Guidelines for the Evaluation and Control of Lead-Based Paint

Hazards in Housing (U.S. HUD, 1995) will be followed.

i. The requirements of the Air Force Office of Safety and Health; Occupational, Safety, and Health Administration (OSHA) (or California (Cal)/OSHA as applicable) will be complied with.

j. Each Edwards AFB organization will budget, program, and train employees as needed on LBP requirements using their applicable department appropriations. Examples are provided in the AFMC guidance.

This plan has been written to assist in implementing the previously mentioned steps into the Lead Management Program.

In order to track hazardous materials that contain lead, the Enterprise Environmental Safety and Occupational Health-Management Information System (EESOH-MIS) database is used. The EESOH-MIS database is maintained for all supplies being purchased that contain hazardous materials by the individual organizational hazardous material (HM) pharmacies throughout Edwards AFB. These individual organizations request the material safety data sheets (MSDSs) from the suppliers and load them into the EESOH-MIS. The MSDSs are then evaluated by Bioenvironmental Engineering (BE) to determine if this is a material allowed to be used on base.

Organizations will request lead-free products from suppliers. If there is a reason why lead-free products cannot be used, written justification (e.g., technical order (T.O.), and/or callout) must be included as part of the HM authorization request prepared by the requesting organization. It may

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Edwards AFB LMP 2 March 2014 not be possible to eliminate all sources of lead in procured HM (i.e., T.O. calls for a specific item that contains lead); however, lead-free substitutes must be used whenever feasible. The Self- Help store at Edwards AFB in Building 3500, will not release lead-containing materials for use in self-help activities.

The Lead Management Plan (LMP) will be reviewed and updated on an as needed basis, or at least reviewed annually for applicability and currency. Any required changes including regulatory and process changes will be implemented as they occur.

The Lead Hazard Management Team is responsible for ensuring the LMP as agreed upon by the group, is implemented. This plan will guide implementation of the Lead Management Program at Edwards AFB. This team has members from major organizations with lead-hazard responsibilities.

The personnel responsibilities noted in this document are clarifications of the AFMC guidance document and consensus of the responsible organizations as to how the guidance will be implemented.

2.0 PERSONNEL RESPONSIBILITIES

The success of this Edwards AFB LMP depends on the active involvement and understanding of all parties. This will range from 412th CE/EM, Facility Managers, Contracting, and Medical Group to the facility occupants. Per the guidance, and the LMP, the base must ensure that all lead-related activities are performed in compliance with relevant federal, state, and local laws. To achieve compliance, the Edwards AFB Civil Engineer will designate individuals to oversee facilities and infrastructure projects involving LBP. This designated individual will be known as the Lead-Based Paint Project Officer (LBPPO) and will be located in CE. The LBPPO will ensure that procedures are in place for worker protection requirements under OSHA for lead, and are incorporated in all projects.

Edwards AFB will also provide support staff, which includes consulting staff to assist the LBPPO in conducting their responsibilities.

Job responsibilities assigned to key organizations/jobs related to developing and implementing the LMP are specified in the following sections.

3.0 BASE ORGANIZATIONAL RESPONSIBILITIES FOR IMPLEMENTING

LEAD-PAINT PROGRAMS

This LMP will be implemented through the efforts of several key personnel/groups. The success of the LMP will depend on the ability of these personnel and organizations to effectively communicate with each other and coordinate their respective efforts in carrying out the Lead Management Program outlined in this document. The following sections identify the key base organizations and individuals instrumental in implementing the LMP at Edwards AFB, noting the major program activities each organization is involved in.

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4.0 EDWARDS AFB LEAD HAZARD MANAGEMENT TEAM RESPONSIBILITIES

The Lead Hazard Management Team is composed of CE/EM, BE, Facility Managers, Contracting, Medical Group, Aerospace Medicine Squadron Public Health (PH), Air Force Test Center Public Affairs, 412th Test Wing Force Support Squadron, and the HM Pharmacy. The primary organizations responsible for developing/updating the LMP are CE, BE, Environmental Management and Facility Managers of child-occupied structures, with CE being the principal organization.

The Lead Hazard Management Team is responsible for implementing and updating the LMP.

In order to accomplish the update of the LMP, the team will meet on an as needed basis to review ongoing management practices thus ensuring the LMP is being implemented correctly and all procedures and processes within the LMP are appropriate and current. Should it be determined that the procedures and processes are out of date or ineffective, the LMP will be revised to incorporate needed changes.

5.0 MEDICAL GROUP COMMANDER

The Medical Group Commander developed a blood-lead surveillance program using Center for Disease Control (CDC) Guidelines, Preventing Lead Poisoning in Young Children (Department of Defense Policy Letter on LBP, 1992); and Air Force Child Blood Lead

Screening Program, (1993). Other current guidance may be used.

It is also the Medical Group’s responsibility to ensure a system is in place to evaluate and followup with all children having a positive blood-lead level (BLL) test (BLL is equal to or greater than 10 micrograms per deciliter [g/dL]), and to appoint a team for the Lead Toxicity Investigation (LTI), which is normally the Aerospace Medicine Squadron Commander, Medical Group. An alternative team leader is the Chief of Pediatrics or Chief of Family Practice for Edwards AFB.

The Aerospace Medicine Commander oversees the LTIs and establishes and chairs the LTI team or Edwards AFB. Elevated BLLs are referred from pediatrics to PH.

5.1. Aerospace Medicine Responsibilities

The Aerospace Medicine responsibilities are as follows:

a. Initiate and supervise LTIs.

b. Present a written report to the Environmental, Safety, and Occupational Health Council (ESOHC) summarizing the LTI team’s findings and actions.

c. Provide risk communication as needed.

d. Attend the ESOHC meetings for lead issues on the agenda and participate on the Lead Hazard Management Team.

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5.2. Pediatrics/Family Practice Flight Commanders

Pediatrics/Family Practice personnel are responsible for lead-exposure education, exposure investigation/notification, coordination with local public-health authorities and lead-patient monitoring.

For children under the age of 7, who are considered high risk, will have venous blood tests based on the lead-screening questionnaire results.

Conduct follow up physician treatment for children with elevated blood lead levels (EBLL).

a. For cases of children with EBLL, coordinate with PH for potential local health authority notification purposes.

b. Implement the Pediatric Blood Lead Screening Program and Lead Exposure Questionnaire (Appendix C).

c. Administer the lead-exposure questionnaire and discuss any issues arising from answers during routine infant and toddler exams. If it is determined by the questionnaire results or by physical signs that there may be an exposure to lead hazards, then high-risk screening will be accomplished.

d. Conduct follow up physician treatment for children with EBLLs as per current CDC guidelines.

e. For children with BLLs between 10 and 14 µg/dL, institute individual case-management procedures as outlined for higher levels in the Medical Group Instruction 48-19.

f. For children with BLLs between 7 to 9 µg/dL, educate parents about the sources, effects, and prevention of lead poisoning.

g. In conjunction with Aerospace Medicine, ensure coordinated epidemiological evaluations of children with EBLL as per current CDC guidelines.

h. Participate in LTI and ensure appropriate clinical follow up of positive pediatric lead results, which would include obtaining a confirmatory venous BLL within 1 month. If still within the 10 to14 µg/dL range, repeat the BLL test within 3 months. Provide education and risk communication to decrease blood-lead exposure.

i. Participate in Lead Hazard Management Team.

6.0 PUBLIC HEALTH/PUBLIC HEALTH OFFICER

Public Health is responsible for lead-exposure education, exposure investigation and/or notification, coordination with local public health authorities, and lead-patient monitoring.

6.1. Public Health Responsibilities

The Public Health responsibilities are as follows:

a. Attend ESOHC meetings with lead issues on the agenda and participate on the Lead Hazard Subcommittee.

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b. Maintain a database of elevated blood-lead exposure records known as Air Force Reportable Event Surveillance System (AFRESS).

c. Pediatric: In accordance with (IAW) the 95th Medical Group Instruction 48-19, Pediatric Blood Lead Screening Program (November 2008), investigate all applicable child BLLs equal to or greater than 10 units per liter and report information in AFRESS.

(1) Coordinate with California Department of Public Health (CDPH) on lead exposure environmental assessments to be conducted in nongovernmental housing (i.e., off-base housing occupied by military and their dependents).

(2) Run laboratory reports on blood-lead testing through the Composite Health Care System. Present the status of its Lead-Screening Program to the ESOHB, through the LBPPO, with a written summary of results for monthly reporting.

(3) Monitor and ensure followup care of all patients with elevated BLLs.

(4) Statistically evaluate pediatric blood-lead screening test results that show a continued increase from average levels. Determine state and base lead-level averages to allow for interpretation of trends. This will be accomplished semiannually, unless there is a rise in elevations, and then the reporting frequency will be increased.

d. Occupational: Based on symptoms, providers will order blood-lead tests for patients they believe to have been occupationally exposed to lead and refer them to PH. An Air Force Form 190, Occupational Illness and Injury Report will be initiated. Bioenvironmental Engineering will evaluate the workplace and report findings. Public Health will summarize findings for the Aerospace Medical Squadron Occupational Health provider’s review and will make final recommendations. Public Health will update the information in the AFRESS. For further information reference most current applicable Air Force Instruction and AFI 48-101, Aerospace

Medicine Operations (19 Oct 2011).

(1) Run laboratory reports on blood-lead testing through the Composite Health Care System. Present the status of its Lead Screening Program to the ESOHB, through the LBPPO, with a written summary of results for monthly reporting.

(2) Monitor and ensure followup care of all patients with elevated BLLs.

e. Develop and provide educational materials addressing potential LBP hazards and lead-toxicity symptoms; this information will be provided to all occupants of Military Family Housing (MFH), Facility Managers, and Facility Managers of child-occupied structures.

(1) Educate newcomers at Desert Warrior Orientation Presentation. Publish yearly article in the Desert Eagle newspaper, educating base populace on lead prevention.

(2) Coordinate with obstetrics to provide educational materials to expectant parents of potential lead hazards and what they can do to reduce exposures.

7.0 412 AMDS/SGPB BIOENVIRONMENTAL ENGINEERING

BE assists commanders and supervisors with integrating Occupational and Environmental Health input into Risk Management based decision processes to protect Edwards AFB Department of Defense (DoD) civilian and military personnel from occupational and environmental health hazards related to lead. To ensure that this occurs, BE must be intricately

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Edwards AFB LMP 6 March 2014 involved in all matters related to lead and the LMP. Bioenvironmental Engineering will provide a representative for the Lead Hazard Management Team, which will meet on an as needed basis.

The responsibilities presented in this LMP are derived from federal (Code of Federal Regulations [CFR], OSHA, EPA), state (CDPH, Department of Toxic Substances Control [DTSC], and Cal/OSHA), and Air Force regulations/guidance. It is the responsibility of BE to ensure that all pertinent applicable regulations are followed; coordinate with EM on non-Air Force regulations. Any discrepancies between the LMP and federal, state, or Air Force regulations should be coordinated with the Lead Hazard Management Team. Since the BE is an integral part of both the Hazardous Material Management Plan (HMMP) team and the Lead Hazard Management team, BE will represent the HM Pharmacy and coordinate any issues between the two teams.

7.1. The BE Responsibilities

The BE responsibilities are as follows:

a. Lead-Abatement or Lead-Related Projects

(1) Review and comment on all lead-related work plans or health and safety plans through MAXIMO; send reply to LBPPO, Environmental Management, and Edwards AFB project managers.

(2) If clearance sampling is accomplished by contractor, review and approve clearance results prior to work area being released for reoccupancy.

(3) Bioenvironmental Engineering performs air sampling and personnel monitoring on DoD employees and military personnel, not contract employees, to quantify lead exposure in facilities during occupational health processes.

(4) Authorize/Unauthorize process/HAZMAT authorizations through EESOH-MIS for the use of HAZMAT containing lead to (1) support Air Force Missions; (2) to protect the safety and health of personnel on Edwards AFB by ensuring proper management of HAZMAT containing lead; (3) to minimize the EAFB use of HAZMAT containing lead consistent with mission requirements for EAFB.

(5) Perform Lead sampling in Drinking Water in accordance with the Lead and Copper Rule (LCR) adopted in 1991 by the Environmental Protection Agency (EPA) that requires Community Water Systems (CWS) and Non-Transient Non-Community Water Systems (NTWNCWS) to monitor for lead and copper.

(6) In the event lead-related work/abatement does not involve DoD military or civilian personnel (as described here-in) EM shall perform lead-related construction tasks assigned BE that are not performed by contactor. See Section 10.1 for EM responsibilities.

b. Lead Hazard Investigations

(1) If requested by building occupants, facility managers, or a member of the Lead Hazard Management team, BE shall conduct inspections and evaluations of facilities to investigate lead hazards. If necessary, CE, Environmental Management, and Facility Managers shall assist with Lead-Hazard Investigations.

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(2) Investigations may include some or all of the following:

i. Visual inspection,

ii. Wipe sampling,

iii. Bulk testing of painted surfaces,

iv. Soil and water testing, and

v. Air sampling for occupational health risk assessment.

c. Lead Toxicity Investigations

Bioenvironmental Engineering shall assist in all LTIs.

d. Occupational and Environmental Health Surveillance Program for DOD personnel and Edwards AFB facilities.

(1) BE manages/conducts the Edwards AFB occupational and environmental health surveillance program; this includes evaluating lead hazards.

(2) BE investigates health-hazard reports (190 investigations) and coordinates with installation ground-safety personnel.

(3) BE assigns Risk Assessment Codes to occupational and environmental health hazards and deficiencies in coordination with safety officials when required.

(4) BE shall assist in developing Respiratory Protection Programs for shops where hazardous and occupational lead exposures may occur as required.

e. Occupational Lead Exposures

(1) Bioenvironmental Engineering will evaluate government/military shops on an annual or biennial basis to determine whether any new lead hazards have been introduced into the workplace or any significant changes that may change previous documented exposures.

(2) When lead exposures are possible, BE will conduct monitoring IAW the OSHA’s Regulations (29 CFR 1910.1025, paragraph (d), Exposure Monitoring), and document initial and subsequent exposure determinations IAW AFI 48-145, Occupational and Environmental Health

Program, para 2.11.

f. Meetings

Bioenvironmental Engineering will attend ESOHC meetings when lead issues are on the agenda and participate on the Lead Hazard Management team.

g. Budget

Budgetary requirements for the following: Drinking Water testing and Wipe sampling, bulk testing of painted surfaces, soil, etc. for Elevated Blood Lead Levels IAW EPA and state requirements, air sampling for occupational health risk assessment and BE will procure the analytical laboratory support and analysis necessary for lead samples.

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8.0 CIVIL ENGINEERING

Civil Engineering has overall responsibility to operate and maintain facilities at their lowest life-cycle costs, and conducts these activities IAW applicable federal, state and local laws, regulations, and policies to support the Air Force mission (to include, but not limited to, all EPA, HUD, OSHA guidelines). The decision to repair, which includes replacement of facility components, renovate or demolish a building, is made by CE. Lead-containing materials are a facility component and as such, the maintenance repairs, which includes repair by replacement, or removal, is a CE responsibility. Civil Engineering’s responsibilities encompass identifying initial requirements, planning, programming, budgeting, operations and maintenance of lead-containing materials, and ensuring these elements are incorporated into projects. Tracking and documenting lead-containing material status shall be accomplished with records stored in a central file maintained by the Edwards AFB LBPPO.

Civil Engineering responsibilities associated with repair, construction, and demolition of Air Force real property and infrastructure includes designating in writing a LBPPO for Main Base and Air Force Research Laboratory (AFRL). This LBPPO, and/or their designee’s, will ensure that procedures are in place for worker protection requirements under OSHA, to make sure lead is incorporated in all projects.

Environmental Management is a division of the Civil Engineering Directorate. EM roles and responsibilities will be addressed separately herein.

8.1 Civil Engineering Responsibilities

The CE responsibilities are as follows:

a. Implements and updates a management plan for identifying, evaluating, and managing LBP, and procedures for identification and abatement of LBP hazards in housing and child-occupied facilities. The plan will be updated by the Lead Hazard Management team.

b. An Air Force Form 332, Base Civil Engineer Work Request, must be submitted in either hardcopy or via the LiveLink system, and shall be coordinated by the Edwards AFB LBPPO, prior to craftsmen, programmers, or program manager’s scoping the job requirements, to determine if lead-containing materials will be disturbed in conjunction with the work requested.

If it is determined by the Edwards AFB LPBBO that lead will be disturbed, an estimate for abatement or lead activities will be obtained through a qualified lead abatement contractor prior to any other work being performed. If the scope of work is determined to be under $15,000, abatement/removal will be handled through a qualified lead abatement contractor, with follow-on work performed by CE craftsmen. If the project is deemed to be over $15,000, all lead information will be provided to CE programmers, planners, and/or engineers to use in their contractual process. All lead abatement/removal (e.g., small scale, large scale, or emergency incidents) will be performed via a qualified lead abatement contractor. No in-house abatement services are available. Planners, designers, program managers, engineers, and workers must know where lead-containing materials may be encountered. Civil Engineering will review any project involving the following types of activities to evaluate appropriate mitigation measures for controlling potential lead exposure risks.

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(1) Demolition of painted buildings or structures, and renovation projects that include as applicable, partial demolition, installation of new windows or siding, and general remodeling.

(2) Maintenance activities that involve any cutting, drilling, or sanding of painted surfaces;

burning, welding, or cutting of any metal materials, whether painted, primed, or uncoated, can release very high levels of lead; lead fumes will potentially be generated when heated above 700 degrees Fahrenheit.

(3) All self-help program activities.

(4) Plumbing work requiring welding, soldering, or replacement of metal fixtures or demolition of painted surfaces.

(5) Soil excavation.

(6) Use of any new products that contain lead; anyone making purchases with a government purchase card is responsible for providing information to individuals who will be using lead-containing materials.

(7) All base projects should have a 332 Project Checklist which provides contractors performing work additional information, requirements and contact information that is specific to the project and/or standard Base procedures. These checklist items are mandatory.

c. Ensure that project planners and designers have clearly identified lead hazards, where they may exist, and what steps the contractors must take to protect base personnel and families to contractor in bid documents.

d. In the initial design phase of a project or scope of work development, the LBPPO should be consulted to determine potential areas of concern. If necessary, a predesign survey may need to be conducted. The survey may include a visual inspection and bulk sampling to assess lead hazards. If hazards are identified, the planners, designers, and workers will need to incorporate necessary abatement/removal procedures into their workplans or contract documents. All lead design, workplans, and/or removal plans shall be written by certified and/or trained individuals.

(1) Ensure all projects that impact lead at any detected concentration shall require a site specific lead abatement or removal work plan for all lead related activities to ensure all applicable lead rules and regulations are adhered to.

i. This work plan, if for construction type work, shall be prepared by a certified lead supervisor or project monitor, trained and licensed IAW CDPH Regulations Title 17 CCR Division 1, Chapter 8; Accreditation, Certification and Work Practices For Lead-Based Paint and Lead Hazards and at a minimum, the work plan shall include detailed information as required in an OSHA Lead Compliance Program as well as any project specific specification requirements.

ii. This work plan, if for nonconstruction type work, shall be prepared by an individual with a minimum of Lead Awareness Training per California OSHA 8 CCR 5198, Subsection l, Employee Information and Training; the training for construction work plan preparation is highly recommended. The work plan shall include detailed information as required in an OSHA Lead Compliance Program as well as any project specific base or project specification requirements.

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iii. This work plan shall be submitted through the contracting officer to LBPPO, BE and Environmental Management for review and approval prior to any work starting. Note:

Edwards AFB does not approve OSHA required Lead Compliance Programs.

iv. All projects that generate lead at hazardous levels in the waste stream will include Resource Conservation and Recovery Act (RCRA) of 1976, U.S. EPA and California DTSC regulatory requirements in the work plan. All waste stream sampling and testing is the responsibility of the contractor performing the work, unless otherwise indicated by the government.

(a) All hazardous waste disposal shall be IAW the Edwards AFB Hazardous Waste Management Plan (HWMP).

e. Civil Engineering personnel who conduct routine maintenance procedures should also be trained per applicable regulations and be able to recognize and report lead hazards that they may encounter to the LBPPO. Training should include how to conduct their work to minimize exposure, worker and occupant protection. Any cleanup or remediation of lead-based paint hazards will be conducted by qualified contract personnel. There is no in-house capability.

8.2 Lead-Based Paint/Hazard Program Officer

Civil Engineering oversees the majority of renovation, building, demolition, and maintenance activities at the Edwards AFB. Civil Engineering will appoint a LBPPO, who will be responsible for implementing and overseeing the LBP Management Plan. Civil Engineering, Environmental Management, and BE will advise and/or review proposed abatement work, lead-testing results, noncompliance situations, recommendations for modifications to the program, and equipment needed to maintain the program. The LBPPO shall successfully complete CDPH accredited supervisor/project monitor and inspection/assessment courses.

8.2.1 Edwards AFB LBPPO Responsibilities

The Edwards AFB LBPPO responsibilities are as follows:

a. Maintain and/or identify location of all records for the program, including lead surveys, laboratory results, inspections, abatement actions, and other lead-related information for Edwards AFB, AFRL, and child-occupied facilities. All historical housing data pertaining to lead will be properly archived and stored under electronic records management guidelines.

b. Identify and maintain listing of priority facilities (child-occupied facilities are defined as a building or a portion of a building, constructed prior to 1978 where children, less than 7 years of age, visit for 3 hours twice a week, 60 hours a year).

c. Assist project planners and designers in determining if proposed projects will disturb lead paint/hazards, how to deal with it, and review contract documents.

d. Coordinate completion of surveys of facilities prior to renovation, demolition, maintenance, and other CE activities that may disturb lead-containing materials.

e. Brief lead training and/or issues at monthly Facility Manager’s training. Incumbents shall have annual refresher training on their responsibilities under this LMP.

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f. Coordinate and monitor (provide quality assurance oversight) abatement and interim maintenance activities.

g. Maintain an inventory of training resources, and keep updated copies of applicable regulations on file or readily available electronically.

h. Provide technical advice and support in conducting lead-hazard assessments, LTI, facility clearance, and comprehensive survey activities.

i. Review and approve (based on applicable specifications, rules, regulations, and guidelines) contractor submittal, including training certifications, respirator fit-test records, and medical records in conjunction with abatement, renovations, and demolition plans.

8.3 Project Manager(s) Responsibilities

Many projects do not utilize the LBPPO as the primary Civil Engineering Project Manager (PM).

When this is the case an EAFB lead trained representative (LBPPO, EM and when government personnel are involved, BE) needs to be available to assist the PM in dealing with lead-related conditions. The PM has the following lead-related duties to help maintain this condition / requirement:

a. The Civil Engineering Project Manager(s) shall ensure the SOW for all lead-related projects have a qualified third party monitor/inspector as required herein in the Contracting section and the EAFB Lead in Paint Specifications; unless the PM has the proper training to do lead inspections.

b. The Project Manager (PM) should ensure there is a work site pre-inspection to ensure a pre-existing condition does not exist that may conflict with SOW, later inspections or final clearance. The pre-inspection should be attended by any/all responsible parties (contractors, CE PM, EM, LBPPO, etc.), the conditions are agreed upon and documented.

c. The PM shall report to LBPPO and/or EM lead responsible personnel where questions arise on lead-related projects, to ensure lead-related findings do not contaminate adjacent personnel/areas, become a legal liability to EAFB and to ensure potential issues are immediately addressed and properly documented in project records.

d. The PM shall ensure that all final clearance reports (visual or sampling) are forwarded to EM lead personnel for review and approval, prior to reoccupying the lead work site without personal protective equipment or releasing the contractor.

e. Project Managers should coordinate/consult with the LBPPO and EM for lead-related site inspections, and as needed.

9.0 MILITARY FAMILY HOUSING

The MFH has been privatized and is managed by Corvais Air Force Living and should be following all applicable Federal, State, local regulations pertaining to lead related activities.

All base housing is post lead based paint construction. Lead may still be identified in new materials and any amount of lead detected is regulated by OSHA when lead related construction activities are performed. Title 17, CCR, Division 1, Chapter 8 Accreditation, Certification, and

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Work Practices for Lead-Based Paint and Lead Hazards makes it illegal to create a lead hazard and also regulates lead related activities.

10.0 ENVIRONMENTAL MANAGEMENT

Environmental Management, in conjunction with CE and the Medical Group, has the responsibility for implementation of the LMP and to review and update as needed. EM is responsible for coordination of environmental regulatory compliance. EM acts as the point of contact between the Edwards AFB and federal, state, and local environmental regulatory agencies.

The BE interfaces with OSHA and Cal/OSHA. The environmental manager must work closely with CE, BE, and Judge Advocate to ensure lead activities are performed in compliance with laws and regulations. Fines and penalties for failure to comply with these rules are levied against the Air Force as part of the Toxic Substances Control Act of 1976.

10.1 Environmental Management Responsibilities

The Environmental Management responsibilities are as follows:

a. Acts as the installation point of contact for all federal, state, and local environmental regulatory agencies. The BE will take the lead on any OSHA or Cal/OSHA inspections.

b. Work with the LBPPO in determining if projects will generate construction debris that would become hazardous waste based on lead content through review of lead removal and wastestream sampling plans, and wastestream sampling results.

c. Review and comment or concur on all removal/abatement plans then submit the comment/concurrence to project manager, LBBPO, BE, contracting officer, as applicable.

d. Assist in LTI to determine if any reportable release or incident has occurred.

e. Assist the Medical Group, as necessary, in health-hazard evaluations. When the source of the EBLL is something other than paint–such as drinking water–the Environmental Management LBP program manager will notify the appropriate environmental officer at Environmental Management and BE.

f. Provide written summaries on an as requested basis to the LBPPO regarding lead-related activities that Environmental Management has been part of.

g. In the event lead-related work does not involve DoD military or civilian personnel (as overseen by BE) EM shall perform tasks assigned to BE that are not performed by contactor. See Section 7.1 a.

11.0 FACILITY MANAGERS/BUILDING MANAGERS

Facility Managers represent the first line of defense in protecting facility occupants and visitors from lead exposure; they ensure in-place management of lead paint, and expeditiously report any change in lead material condition to the appropriate organization. The organization commander appoints his/her facility manager.

11.1 Facility Managers Responsibilities

The Facility Managers responsibilities are as follows:

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a. Attend the CE monthly Facility Manager training session or an annual Facility Manager refresher training session to become familiar with the LMP and other lead-related issues.

b. Facility Managers will notify personnel, workers, and occupants in their buildings, through email or other appropriate means, when lead work will occur in their facility.

(1) Facility Managers will be cognizant of how maintenance and renovation activities may affect lead and the control methods that should be used. Most construction and maintenance activities that disturb lead will be planned and coordinated by CE and the LBPPO.

(2) During daily routines, the Facility Manager will have the opportunity to check on worker progress, ensure if any suspected painted surfaces are disturbed, and the LBPPO or BE is notified.

(3) Any unsafe activities that involve lead will be reported to the LBPPO immediately.

c. During routine inspections and operations of a particular building, the Facility Manager will:

(1) Inform the LBPPO of water leaks or other damage that could cause paint to be disturbed.

(2) Inform the LBPPO of peeling or flaking paint so that the LBPPO can evaluate and prioritize abatement/repair actions.

12.0 CONTRACTING

Contracting organizations and their contracting officers are responsible as an acquisition team member for ensuring the contractor is in compliance with the specifications for lead renovation and demolition projects.

12.1 Contracting Officers Responsibilities

The Contracting Officers responsibilities are as follows:

a. Contracting Office Personnel shall be knowledgeable of all sections of the Lead Management Plan; particularly the Civil Engineering Section for the Project Manager/LBPPO responsibilities.

b. Include standard contract language to inform all Edwards AFB contractors, that they may encounter lead-containing materials while conducting their work and that they must take precautions to protect their workers.

(1) If lead coatings (any detectable concentration) are involved in a project, ensure contract language requires all contractors/sub-contractors to be trained / qualified to work with lead per applicable federal, state and local (specification, management plans, etc.) rules and regulations.

c. Assume any and all hot-work will disturb lead until written documentation proves otherwise. All applicable rules and regulations shall apply.

d. Ensuring that within the statement of work, lead waste, such as construction debris, is properly tested by the contractor to determine if it needs to be treated as hazardous waste.

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Edwards AFB LMP 14 March 2014

e. Ensure that the specifications and contracts for services indicate that no lead materials will be used at Edwards AFB unless specified by a T.O. or other documentation, and have the contractor sign a document stating that no lead materials have been used. This expands the exclusion of LBP use on base facilities from public and commercial buildings to industrial and operational facilities.

The installation will not specify, purchase, use, or approve for use any paint or surface coating/coated material above the limits specified by the Consumer Product Safety Improvement

Act of 2008 (CPSIA).

f. Post contractor submittals via email simultaneously to program manager, BE, and Environmental Management for review and approval.

g. Set timeframe required for turnaround of review (contactors’ abatement, or removal plans, waste sampling, or disposal plans, medical surveillance and training programs, licenses, insurance bonds, qualifications, and fit-testing records); a minimum of 5 working days is required.

h. Award lead-related contracts to qualified lead contractors/consultants; ensure subcontractors abide by all applicable rules and regulations.

i. Enforce contract terms and conditions to stop any inappropriate work practices or breach-of-contract requirements, and notify the program manager, BE, and Environmental Management for corrective actions.

j. Ensure lead hazards/materials have been clearly identified to contractors in bid documentation.

k. All projects that generate lead at hazardous levels in the waste stream will include Resource Conservation and Recovery Act (RCRA) of 1976, U.S. EPA, California DTSC regulatory requirements in the work plan. All waste stream sampling and testing is the responsibility of the contractor performing the work, unless otherwise indicated by the government. All projects that generate lead at hazardous levels shall also comply with the Edwards AFB HWMP.

12.2 Contracting Office Responsibilities for Supplies and Services

Contracts for services have the potential to impact lead during routine and nonroutine activities; therefore, special precautions must be observed. Ensure all contracts and orders that may impact lead, whether they are for services or supplies, have had lead review, incorporate lead considerations into the statement of work, and other requirements.

a. Refuse: Ensure the statements of work includes the requirement that contractor personnel manning the Edwards AFB landfill have OSHA lead awareness training and are able to identify potential suspect lead-containing materials. If a material is suspected of containing LBP, the Edwards AFB LBPPO is to be contacted to perform sampling and abatement/removal if necessary. Suspect material will not be buried prior to sampling and analysis.

b. Equipment buys (automatic doors, chillers, generators, or any equipment that will change or disturb facility building components): Any installation or removal of equipment must be initiated with an Air Force Form 332 (either hardcopy or via a Web-based process such as or LiveLink) and must be coordinated by the Edwards AFB LBPPO to annotate any potential lead issues.

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c. Furniture buys: Any furniture purchase requiring installation, such as attachment to walls or floors, or requiring cable/wiring through floors, walls, or ceilings will be coordinated through the Edwards AFB LBPPO to determine whether any lead issues exist and what steps must be taken to prevent exposure to occupants and workers. See section 12.1e.

d. Government purchase card: Ensure special emphasis of lead issues is part of initial and any refresher training to organizations and their cardholders and management.

e. Projects that disturb lead or lead paint: Ensure all projects that impact lead shall require a site-specific lead abatement or removal workplan for all lead-related activities.

(1) The LMP, if for construction type work, shall be prepared by a certified lead supervisor or project monitor, trained and licensed IAW CDPH 17 CCR Division 1, Chapter 8.

At a minimum, the workplan shall include detailed information as required in an OSHA Lead Compliance Program as well as any project specific specification requirements.

(2) This workplan, if for nonconstruction type work, shall be prepared by an individual with a minimum of Cal/OSHA 8 CCR Section 5198, Subsection l. The workplan shall include detailed information as required in an OSHA Lead Compliance Program as well as any project-specific base or project-specification requirements.

(3) This workplan shall be submitted to LBPPO, BE, and Environmental Management for review and approval prior to any work starting. Note: Edwards AFB does not approve

OSHA required Lead Compliance Programs.

(4) All projects that generate lead at hazardous levels in the waste stream will include Resource Conservation and Recovery Act (RCRA) of 1976, U.S. EPA and California DTSC regulatory requirements in the work plan. All waste stream sampling and testing is the responsibility of the contractor performing the work, unless otherwise indicated by the government. All projects that generate lead at hazardous levels shall also comply with the Edwards AFB HWMP.

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Edwards AFB LMP 16 March 2014

13.0 REFERENCES

Air Force Forms 190, Occupational Illness and Injury Report.

332, Base Civil Engineer Work Request.

Air Force Information Management Tool 1219, Civil Engineering Housing Multi-Craft Job

Order.

Air Force Instruction (AFI) AFI 91-301, Air Force Occupational and Environmental Safety, Fire Protection and Health

(AFOSH) Program, 1 June 1996.

AFI 48-101, Aerospace Medicine Operations (11 July 1994 superseded), 19 August 2005.

AFI 48-119, Medical Service Environmental Quality, 25 July 1994.

AFI 32-7042, Waste Management (EAFB Hazardous Waste Management Plan)

Air Force Materiel Command (AFMC), 2000, Update of AFMC Guidance on Lead-Based Paint

(LBP) in Facilities (Our Memo, 16 Jun 93), 27 December.

95th Medical Group Instruction (MDGI) 48-19, Pediatric Blood Lead Screening Program, 4 November 2008.

Air Force Manual (AFMAN) AFMAN 85-3, Paints and Protective Coatings, June 1981.

AFMAN 48-155, Occupational and Environmental Health Exposure Controls, 1 October 2008.

Air Force Occupational Safety and Health (AFOSH) Standard 48-8, Controlling Exposures to

Hazardous Materials, 1 September 1997 (Superseded by Air Force Manual 48-155, Occupational and Environmental Health Exposure Controls, Aerospace Medicine, 1 October 2008).

Air Force Occupational Safety and Health (AFOSH) Standard 91-501, Air Force Consolidated

Occupational Safety Standard, 7 July 2004–Supplement 1, 9 June 2006.

Air Force Policy Directive 32-10, Installations and Facilities, 4 March 2010.

Armstrong Laboratory, Brooks AFB, Texas, Lead Exposure Hazard Management Guide, December 1993.

California Code of Regulations (CCR) Title 8 Division 1 Chapter 4, Subchapter 4, Section 1532.1, Cal/OSHA Construction Safety

Orders, Lead.

Title 8 Division 1 Chapter 4, Subchapter 7, Section 5198, Cal/OSHA General Industry Safety

Orders, Lead.

Title 8 Section 5198 (l), Employee Information and Training.

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March 2014 17 Edwards AFB LMP

Title 17 Division 1 Chapter 8; Accreditation, Certification and Work Practices for Lead-

Based Paint and Lead Hazards (administered by California Department of Public Health

{CDPH}).

Title 22 Division 4.5, Environmental Health Standards For The Management Of Hazardous

Waste.

Code of Federal Regulations (CFR) 24 CFR 35, Housing and Urban Development, Lead-Based Paint Poisoning Prevention in

Certain Residential Structures.

29 CFR 1910, U.S. Department of Labor, Occupational Safety and Health Administration (OSHA), General Industry Standards.

29 CFR 1926, U.S. Department of Labor, Occupational Safety and Health Administration (OSHA), Construction Industry Standards.

29 CFR 1926.62,…