Removal of Lead-Based Paint

Transcription

1 Safety Management System SP24-61 Process Authority: HS Manager Removal of Lead-Based Paint Approval: Chief Operating Officer Version Date:30/03/2015 Revision: B 1 Purpose To define the requirements for the removal and disposal of lead-based paint. 2 Scope Applicable to all Snowy Hydro employees and contractors undertaking work that requires the disturbance of paint film. 3 Process 3.1 Process flow chart (next page) THIS DOCUMENT IS UNCONTROLLED IN HARD COPY Page 1 of 5

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3 3.2 Planning Test for presence of lead in paint Use a semi quantitative lead paint test kit and follow the test procedure defined with the particular test kit. If the determined lead concentration exceeds the upper resolution limit of the test kit or indicates a > 1% (by dry weight) lead concentration then further testing must be completed by a NATA certified laboratory for lead testing. Refer to Appendix A Instructions on Paint Film sampling for guidance on preparing a sample. 3.3 Determination of Lead Risk Work status If lead is not detected or is confirmed at less than 1% (w/w) lead or lead compounds in paint film then the job is not classified as lead risk work and standard work methods apply. If lead-containing paint is confirmed at the defining level of greater than or equal to 1% (w/w) lead or lead compounds in paint film then the job must be assessed to determine if it is lead risk work. In assessing the job consideration is given to the following: past biological monitoring results of workers doing similar work past airborne lead levels during similar work the type of disturbance to be undertaken on the lead paint the likely duration and frequency of the work possible routes of exposure to lead paint dust any information about incidents, illnesses or diseases in relation to similar work undertaken in the workplace To assist in determining whether the job involving lead paint is lead risk work contact a Health and Safety Team member. If uncertainty exists as to whether the job is lead risk work then the job is taken to include lead risk work until it is determined otherwise. If the lead paint job is determined to not be lead risk work then standard control procedure SCP093 Minor disturbance of lead paint must be applied to manage any potential lead risks. If the job is assessed as lead risk work then the following steps apply: Note: Pregnant or breastfeeding employees are not to be involved in lead risk work and are to advise their manager of the fact as soon as practicable. 3.4 Notification of lead risk work The Regulator must be notified within 7 days prior to commencement of the lead risk work. Notification is to be provided by completing the appropriate Regulator notification form for lead Risk work (F24-61-A NSW Workcover Notification for Lead Risk Work or F24-61-B Vic Worksafe Notification for Lead Risk Work) and submit in accordance with instructions on the form. 3.5 Pre-start health monitoring All employees involved in lead risk work are to undertake a pre-start blood lead analysis under the supervision of a registered medical practitioner. Note: Results of lead testing must upon receipt be provided to the employee and a copy forwarded to the Health and Safety Team. THIS DOCUMENT IS UNCONTROLLED IN HARD COPY Page 3 of 5

4 3.6 Complete work method statement (WMS) Complete a work method statement for each project or maintenance activity. The work method statement must define the perimeters of the lead work area and identify controls to ensue that lead contamination is confined to the area in which the lead risk work is carried out. Prevention of exposure to lead must be controlled utilising the hierarchy of controls and as appropriate may require the use of two or more control measures including PPE to reduce exposure to as low a level as practicable. A Health and Safety Team member must be contacted to assist in the development of controls for lead risk work. No food, drinks, chewing gum, etc are to be taken into, used or consumed within the defined lead work area. Changing and washing facilities with sufficient soap or other cleaning agents must be available at the worksite to minimise ingestion of lead and the spread of lead contamination. If disposable protective over clothing is not used then separate change and laundering facilities are to be established. 3.7 Monitor controls Prior to the commencement of lead risk work and at planned intervals inspections must be conducted to ensure the identified control measures have been implemented and are effective. As a minimum air quality monitoring is to be provided when other personnel are conducting work of a nontransient nature in the immediate vicinity of the defined lead work area. For assistance in determining the requirement for air quality monitoring and provision of air quality monitoring services contact the Health and Safety Team. 3.8 Managing lead contaminated waste Lead based paint waste is classified by the EPA as a list 1 Controlled Waste (Hazardous) product. All collected waste is to be securely contained and returned to stores for disposal according to CGS procedure QP24-19 Storage Transport and Disposal of Hazardous Waste. 3.9 Completion cleaning and clearance Cleaning of areas that are potentially contaminated with lead containing dust must be conducted as frequently as is necessary to ensure removal of lead paint chips or dust deposits. Prior to releasing the removal area to service an inspection must be conducted to ensure that there is no lead dust remaining on equipment or structures in or near the paint removal area Health monitoring All employees involved in lead risk work are to undertake at least a second blood lead analysis under the supervision of a registered medical practitioner within one month of commencing the lead risk work. Note 1: Results of health monitoring must upon receipt be provided to the employee and a copy forwarded to the Health and Safety Team. Note 2: On receipt of health monitoring results the Health and Safety Team if required will notify the appropriate personnel of any additional health monitoring requirements and if necessary make notification to the Regulator if statutory blood lead limits have been exceeded. 4 Accountabilities Managers & Supervisors Ensure persons managing the removal of lead based paints do so in accordance with this procedure THIS DOCUMENT IS UNCONTROLLED IN HARD COPY Page 4 of 5

5 Contractors H&S Team Employees Must apply equivalent or higher level of lead based paint management required by this procedure Provide guidance in support of this procedure Audit compliance with the requirement of this procedure. Participate in consultation and undertake required controls 5 Records H&S records are to be managed according to CGS procedure SP24-56 Occupational Health and Safety Management including: For lead risk work the work method statement, testing and air quality monitoring results, chain of custody records, training records and EPA registered disposal certificates are to be electronically filed within the designated TRIM containers. Reports or results of health monitoring are to be retained for 30 years. 6 Associated Forms and Documents Annexure A: Instruction on paint film sampling F24-61-A NSW Workcover Notification for Lead Risk Work. F24-61-B Vic Worksafe Notification for Lead Risk Work THIS DOCUMENT IS UNCONTROLLED IN HARD COPY Page 5 of 5

6 Appendix A: Instructions on paint film sampling 1. The sample must be representative and whenever possible should be taken from several locations (preferably at 3 locations) of the paint film being disturbed. 2. The optimum sample size equates to a total sample size of approximately 5 x 5 centimeter square to ensure sufficient sample for a test kit screen and if required NATA laboratory analysis. Smaller sample sizes may be permissible but will need to be discussed with the testing laboratory to ensure sufficient sample weight for analysis. 3. The sample must include the full substrata at each location sampled. 4. The sample and if several locations of the same paint film have been taken are composited and placed in a sealed labeled plastic sample bag. 5. The labeled plastic bag containing the sample is double bagged ie placed into a second sealed plastic bag in preparation for test kit screening and/or NATA laboratory analysis. THIS DOCUMENT IS UNCONTROLLED IN HARD COPY Page 6 of 5