Lead for Project Managers

Presented by Aurora Industrial Hygiene, Inc.www.auroraih.com, info@auroraih.com

Overview

• Background

• Health Effects

• Definitions

• Regulations

• Procedures

• Important Numbers

• Useful Links

What is Lead

• Lead is an elemental metal

• Forms 0.06% of the earth’s crust

• Cannot be destroyed, only smaller

• Should not be in our bodies

Why was Lead Used

• Prevents Corrosion

• Kills mold and mildew

• Malleable

• Strong

• Blocks Radiation

• Blocks Sound

• Drying Agent

Problems

• It’s a chronic and acute poison

• Contamination

Where is Lead Found?

• Quality Paint

Military uses

Bridges andSteel Structures

ResidencesInteriorExterior

Banned in 1978Schools in 1984

Lead is Found in Gasoline

• Used over a period of 50 years

• 93% reduction from 1978-1987

Lead Is Found In….

• Industrial Releases

• Soil

• Food

• Drinking Water

• Occupational Exposure

Heart and Blood System

Left atrium

Left ventricleRight atrium

Right ventricle

Heart

AortaPulmonary artery

Lung

Hepatic artery

Liver

Capillaries ofgastrointestinal tract

Large intestines

Small intestines

Innominate artery

Carotid artery

Subclavian artery

Brachial artery

Tibial artery

Femoral artery

Iliac artery

Kidney

Renal artery

ARTERIAL SYSTEM

Alveolar capillaries

•High blood pressure•Increased risk of heart attack and stroke•Anemia

Kidneys

• Filter the blood• Not detectable• Kidney failure

Central Nervous System

• Most affected• Permanent• Brain damage• Damage to nerves

Bone Tissue

• Body Burden• Released when the body is under stress• Pregnancy• Menopause• Serious Illness

Clavi cle

Humerus

Radius

UlnaSacrum

Femur

Fibula

Tibia

Pelvis

Mandible

Cranium

Coccyx

Scapula

Cervical ver tebrae

Lumbar ver tebrae

Thoraci c ver tebrae

Carpals

Metacarpals

Phalanges

Talus

CalcaneusTarsal s,metatar sals & phalanges

R ib

SKELETON, POSTERIOR VIEW

Reproductive Systems

• Male System

– Impotency

– Lack of drive

– Damage to sperm

– Infertility

• Female System

– Infertility

– Birth defects

– Miscarriage

– Pregnancy

Children

• Proportion to body weight and size

• Developmental effects• More hand-to mouth

contact• More absorption of

lead

Lead Bans/Phase-Out• Late 20th Century• Residential paint (1978)• Solder and pipes for drinking water• Solder in food cans• Gasoline

Huge improvements in air quality in last 50 years but DETERIORATING LEAD-BASED PAINT still a major source of lead pollution today

Definitions• Lead-based paint:

– New paint: greater than 0.06% (600 ppm) lead content.

– Existing paint: greater than 0.5% (5000 ppm) or 1 mg/cm2 lead content.

– Some counties: 0.7 mg/cm2 lead content.

– City of SD: Lead-Safe Work Practices (LSWP) required at 0.1% (1000 ppm) or 0.5 mg/cm2.

• Lead-containing paint: paint with any detectable lead.

• Presumed lead-based paint.

– State: Constructed prior to January 1, 1978.

– San Diego: Constructed prior to January 1, 1979 and ALL steel structures, regardless of construction date.

• Lead hazards: deteriorating LBP or PLBP, contaminated dust, contaminated soil, disturbance of LBP or PLBP w/o containment.

Applicable Regulations (a few)

• Title X, Lead-Based Paint Poisoning Prevention Act of 1992.

• HUD Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing

• California-OSHA Lead in Construction

• California Title 17, Accreditation, Certification, Work Practices for Lead-Based Paint and Lead Hazards

• CA SB 460

• San Diego Municipal Code, Lead Hazard Prevention and Control Ordinance

• EPA Lead Renovation Repair and Painting Program

Regulations

Title X, Lead-Based Paint Poisoning Prevention Act of 1992.

• The regulation which started it all.

• Evaluation hazards– Risk Assessment

– Inspection

• Reduce hazards– Interim controls

– Remediation

Regulations

HUD Guidelines for Evaluation and Control of Lead-Based Paint Hazards in Housing

• Step-by-step “how-to” manual

• Inspection, risk assessment, monitoring, worker protection, waste management, interim controls, abatement, clearance, maintenance

• Written as guidance document for housing

• Made mandatory for public and residential buildings by California Title 17

Regulations

California OSHA Lead in Construction – 8 CCR 1532.1

• Applies to all lead exposure in construction, regardless of type of building or lead content in paint

• Construction includes demolition, renovation, clean-up

• UCSD puts compliance responsibility onto contractors:– Airborne exposure limits

– Exposure assessment

– Written compliance program

– Respiratory protection and PPE

– Medical surveillance

– Recordkeeping

Regulations

California OSHA Lead in Construction – 8 CCR 1532.1

• Important for Protecting Workers AND Surrounding Areas:– Housekeeping: wet cleaning, HEPA vacuums, prompt clean-up

– Hygiene facilities, change areas, showers

– Regulated areas

– Posting

– Certified workers if abatement of public or residential OR exposure over PEL

Regulations

Accreditation, Certification, and Work Practices for Lead-Based Paint and Lead Hazards. Title 17 CCR 35001 - 36100

• Applies to all public and residential buildings

• Certification of training and training providers, workers, supervisors, inspectors, project monitors

• Defines LPB, PLBP, lead hazards, lead-safe work practices

• Defines inspection, risk assessment, clearance

• Makes HUD Guidelines regulatory

Regulations

Lead Hazard Prevention and Control Ordinance, San Diego Municipal Code, Division 10, 54.1001-54.1015 (2008)

• Applies to properties, premises, dwelling units, structures, and steel structures

• Re-states many requirements of Title 17

• LEAD HAZARDS are dangerous to life and health and owner must prevent or correct

• Requires LSWP at lower lead content than LBP

• Defines presumed LBP one year earlier than Title 17

• San Diego City enforcement team – drive-by citations

Regulations

EPA Lead Renovation Repair and Painting Program, (2008, effective 2010)

• Applies to residential houses, apartments, child-occupied facilities.

• Renovation = ANY activity that disturbs paint.

• Renovation firms must be EPA-certified

• Workers must be trained in LSWP

• Pre-renovation education required (pamphlet, signs)

• LSWP mandatory

• Recordkeeping

CAUTION: STATE-CERTIFIED LEAD WORKERS vs CERTIFIED RENOVATION FIRMS

Procedures - Variables

• Requirements vary based on:– Building age– Building function (public, commercial,

residential, industrial)– Lead content in paint– Scope of construction/renovation– State, County, City

Procedures - General

• Characterize

• Handling/Management

• Clearance

• Disposal

Procedures – Characterize

• Pre-1979 buildings must be inspected prior to renovation

• Inspection must be by certified inspectors• Inspection must follow HUD Guidelines procedures• Laboratories must be accredited• CDPH 8552 must be submitted to State and City

*Some exceptions if buildings not accessible to public.

Procedures – Handling/Management

• OSHA applies for any lead content• LSWP required if over criteria• Loose/flaky paint returned to intact state

(abatement)• Renovation/demolition in a manner that adhered

paint must remain adhered• Worksite preparation, containment, and clearance

vary based on use of building and lead content

Procedures - LSWP• Notice to occupants

• Regulated area

• Temporary relocation

• Containment (App. A, HUD Guidelines)

• Specialized cleaning (HEPA-wet-HEPA)

• Daily clean-up

• Proper waste disposal

• Clearance (visual or test dep. on building and lead content)

• Prohibited: burning or torching; heat guns >1100F; scraping, sanding, grinding, or blasting without containment

Procedures – Interim Controls

• Abatement designed for less than 20 years

• Trained workers

• Containment

• Notification

• Follow HUD Guidelines Chapter 11

• Clearance inspection depending on conditions

Procedures - Abatement

• Abatement for 20 years or longer

• Certified supervisors and workers

• Abatement plan

• Notification to CDPH and OSHA

• HUD Guidelines, Chapter 12

• Containment

• Clearance inspection

Procedures - Clearance

• Certified Inspector/Risk Assessor or Project Monitor

• Visual

• Dust

• Soil

• CDPH 8552 to City and State

Procedures - Disposal

• Segregate and test each waste stream• Firmly adhered paint can be tested as a composite

in construction debris• TTLC. Total Threshold Limit Concentration.• STLC. Soluble Threshold Limit Concentration.

(also WET)• TCLP. Toxicity Characteristic Leachate

Procedure.

Important Numbers

• Presumed LBP: Pre-1979

• LBP – New Paint – 0.06%, 600 ppm

• LBP – Existing Paint – 0.5%, 5000 ppm, 1 mg/cm2

• LSWP Required – 0.1%, 1000 ppm, 0.5 mg/cm2

• Lead in Air – PEL = 50 µg/m3; AL = 30 µg/m3

• Contaminated Soil – 400 ppm play areas; 1000 ppm other

• Contaminated Dust – 40 µg/ft2 interior floor; 250 µg/ft2 interior horizontal; 400 µg/ft2 exterior

• Waste

Useful Links

• CA DPH Childhood Lead Poisoning Prevention Branch (lots of useful information and links): http://www.cdph.ca.gov/programs/CLPPB/Pages/default.aspx

• Ca DPH List of Certified Individuals: http://www.cdph.ca.gov/programs/CLPPB/Pages/LRCCertList.aspx

• EPA’s Resources Related to Lead in Paint, Dust, and Soil: http://www.epa.gov/lead/

• HUD Guidelines: http://www.hud.gov/offices/lead/lbp/hudguidelines/index.cfm

• Compliance Guide to EPA LRRP: http://www.epa.gov/lead/pubs/sbcomplianceguide.pdf

• LRRP: http://www.epa.gov/fedrgstr/EPA-TOX/2008/April/Day-22/t8141.htm

• Cal-OSHA Lead in Construction Standard: http://www.dir.ca.gov/Title8/1532_1.html