Prepared for: Operations and Maintenance Department School District #27 Cariboo-Chilcotin Lead Exposure Control Plan Prepared by #210-2950 Douglas Street Victoria, British Columbia V8T 4N4 Version 1.0
TABLE OF CONTENTS 1. INTRODUCTION... 1 2. STATEMENT OF PURPOSE... 1 3. RESPONSIBILITES... 1 4. BACKGROUND... 2 A. What is Lead?... 2 B. Health Effects of Lead... 2 5. RISK IDENTIFICATION, ASSESSMENT AND CONTROL... 3 A. Risk Identification and Assessment... 3 B. Controls... 4 1. Elimination... 4 2. Engineering Controls... 4 3. Personal Protective Equipment... 5 6. HYGIENE FACILITIES AND DECONTAMINATION PROCEDURES... 6 A. General Housekeeping... 6 B. Shower and change facilities... 6 C. Eating facilities... 6 D. MODERATE RISK WORK AREAS- ALL... 7 7. EDUCATION AND TRAINING... 7 8. HEALTH MONITORING... 7 9. DOCUMENTATION... 8 10. SAFE WORK PROCEDURES... 8 A. MODERATE RISK WORK... 8 11. TEMPORARY WASTE STORAGE, HANDLING AND DISPOSAL... 9 Page ii
1. INTRODUCTION School District 47-Operations and Maintenance Department has developed the following exposure control plan (ECP) for Lead as per WorkSafeBC OHS Regulation section 5.54. The following topics are addressed in this ECP a statement of purpose and responsibilities; risk identification, assessment and controls; hygiene facilities and decontamination procedures; written work procedures, education and training; health monitoring, documentation. 2. STATEMENT OF PURPOSE The purpose of this Exposure Control Plan (ECP) is to: Identify, assess and control any potential health hazards caused by the presence of Lead, To reduce or eliminate the Lead-containing material hazards present in the work site, Protect workers from exposure to Lead hazards during the hygiene monitoring or bulk sampling process with the use of personal protective equipment (PPE), safe work procedures, and engineering controls. 3. RESPONSIBILITES School District 47-Operations and Maintenance Department is Responsible for: Ensuring that the materials (e.g. tools, equipment, PPE) and other resources (i.e. worker training materials) required to fully implement and maintain this exposure control plan (ECP) are readily available and used where and when they are required. Ensuring Supervisors and workers are educated and trained to an acceptable level of competency. Maintaining records of training, fit testing, crew talks, and inspections. Maintaining this ECP by reviewing it annually with the Health and Safety Committee. Consult the Occupational Health and Safety Coordinator on any changes to the ECP Selecting, implementing and documenting the appropriate site-specific control measures. Providing adequate instruction to workers on the hazards of working with Lead-containing materials and on the precautions specified in the job specific plan covering hazards at the location. Ensuring that the workers are using the proper air purifying respirators (APR) and have been trained in their use, care and maintenance. Ensuring that the workers are fit tested and that the results are recorded. Revised: June 20, 2012 Approved by: Len Crivea Page 1
Directing the work in a manner that ensures the risk to workers is minimized and adequately controlled. Communicate Lead risks to hired contractors to ensure a safe work environment. 4. BACKGROUND A. WHAT IS LEAD? Lead is a soft, inexpensive metal that has been used for over 6000 years. Despite its many uses, lead is a hazardous material. There are countless applications of lead in the workplace, and a few of the common ones are discussed below. Paint: lead-based paints make a coating which is thick, heavy and durable; ensuring that they will not be compromised with temperature, exposure or corrosion. Residential lead paint has been banned since the 1970 s. Fuels: lead is no longer used in automobile fuels but is still used in non-roadway vehicles as it increases the octane rating and overall effectiveness of the engine. Others: lead is used for soldering, in lead acid batteries, and radiation protection Other past or current uses of lead include: ammunition manufacturing, sweetener in cooking, and insecticides. Exposures to Lead: although lead is present in the everyday environment, certain tasks promote higher risks of lead exposure. Examples include: abrasive blasting, any constructive work with materials coated in lead-based paint, application of spray-on lead-based paint, power tool cleaning, use of lead-based mortar or repair of stained-glass windows. B. HEALTH EFFECTS OF LEAD Lead is a hazardous material. Exposure to lead can induce short-term symptoms as well as chronic, long-term conditions. Knowledge of the risks, precautions and safe-handling procedures that pertain to lead will work to reduce the following negative health effects. Short-term effects of high lead exposure may cause vomiting, diarrhea, or convulsions, and in severe cases; coma and/or death. Long-term effects of even small doses of lead may induce anaemia, nervous-system effects, appetite loss, abdominal pain, constipation, fatigue, insomnia, irritability, headaches, and kidney damage. Secondary Exposure is made possible by lead dusts tendency to travel home in hair, clothing or skin. Infants subject to secondary exposure are more prone to display serious health effects as lead has an elevated effect on a child s development as their growing bodies re adily absorb lead. Symptoms may include: behavioural problems, learning disabilities, mental retardation/brain damage, abdominal complaints, anaemia, size and hearing. Pregnant women exposed to high levels of lead exhibit higher rates of miscarriage and stillbirths. Page 2
5. RISK IDENTIFICATION, ASSESSMENT AND CONTROL A. RISK IDENTIFICATION AND ASSESSMENT Before work is conducted where the potential for worker exposure to lead exists, a full risk assessment will be conducted by the School District 47-Operations and Maintenance Department, or their designate. This may include a review of the building or vessel materials history, bulk sampling of material, testing using direct-read instrumentation (XRF Meter Qualified Personnel Only), and review of work to be conducted. The risk assessment will be conducted by a person who is knowledgeable in the hazards of lead and how it may have been used, as well as having a familiarity with the work to be conducted. The Risk Assessment Report details the specific locations and types of materials containing lead, description of the type(s) and locations of the work to be conducted, the methodologies employed in the survey including sampling techniques and analytical procedures, summary of conclusions and recommendations. The Occupational Health and Safety Regulation lists an personnel exposure limit (PEL) for lead in the air of 50 micrograms per cubic meter (ug/m 3 ) during an 8-hour period). This is a concentration to which nearly all workers could be exposed for eight hours a day, five days a week, without adverse health effects. Necessary control precautions to be utilized are based upon the Low/Moderate/High Risk Procedure system created for asbestos and described in WORKSAFE BC publication Safe Work Practices for Handling Asbestos. NOTE: Additional Hazards may be present including (but are not limited to): Buried utilities Slip/trip hazards Noise Overhead hazards Eye hazards Working at elevations New and young worker considerations Mobile equipment Shoring/excavation Heat Stress Traffic Biohazards Working Alone Electrical hazards Mechanical hazards Page 3
B. CONTROLS 1. ELIMINATION Wherever possible, replacement or substitution of lead-containing materials will be taken into consideration in order to reduce the potential exposure to workers, however School District 47- Operations and Maintenance Department is primarily involved with maintenance or removal of lead containing materials already present within or on buildings. 2. ENGINEERING CONTROLS Engineering controls will be employed where possible in order to control and reduce worker exposure to lead. The following may be considered: a) Enclosure of work processes Sometimes lead-containing materials cannot be avoided and are required for, or produced by, the production process. Totally enclosing a specific task or process that produces lead contamination will minimize or eliminate lead exposure for all workers. Partially enclosing or segregating a task or process may reduce lead exposure for some workers but not for all workers. b) Local Exhaust Ventilation Lead contamination from a process can be decreased at the source by installing local exhaust ventilation. This option can be used where the lead being released is fairly localized for example, in welding, brazing, and casting operations. These ventilation systems must be carefully designed to ensure that they: Effectively remove the lead dust or fume Do not alter or interfere with the work process Ventilation should draw lead fume or dust away from the work and the worker. Do not increase the lead exposure to other workers (for example, by exhausting the lead fume or dust to other work areas) Do not increase the lead exposure to the worker by pulling the lead fume past the worker s breathing area c) Process modification In some situations, it may be possible to consider modifying processes to reduce the amount of lead fume or dust generated. For example, wet working methods can reduce the amount of lead dust produced. Pressurized water should be used to remove lead-based paint instead of stripping the paint with a heat gun. However, there still may be significant levels of lead dust generated if the water pressure is too high. Another example is to cut lead or lead-containing metals by hand sawing or mechanical shearing instead of using oxy-fuel torches or arc-air gouging. Page 4
d) Work schedules The amount of time a worker is exposed to lead can be reduced through job rotation and varied work assignments. Such changes in work schedules will limit the amount of lead absorbed and allow the body time to naturally get rid of lead that has been absorbed. Also, work activities involving high lead levels can be scheduled in areas where and during times when fewer workers would be exposed. 3. PERSONAL PROTECTIVE EQUIPMENT a) Respirators When other control measures are not technically possible, are impracticable, or do not provide adequate protection, personal protective equipment such as respirators must be used. School District 47-Operations and Maintenance Department will provide the necessary equipment and worker training on the proper use of such equipment. Workers must use and maintain the personal protective equipment provided to minimize lead exposure. If respirators are required, they must be properly selected and fit-tested to ensure adequate protection from exposure to lead. Respirators must be regularly cleaned and properly stored to prevent lead contamination. Respirator filters must be inspected and replaced according to the manufacturer s instructions. Respirators shall be worn at all times during the following work activities. During bulk sampling Where lead dust may be present. Moderate or high risk lead abatement projects. Where other airborne hazards airborne particulate matter may be present in hazardous levels. Workers must have annual fit testing complete within the past year prior to donning the respirator. The standard respirators to be used are: N95 disposable respirators for low to low-moderate risk work Approved half-face respirator with NIOSH P100 filter cartridges Moderate risk work Workers shall not enter locations requiring escape-type respirators without proper instruction from the site personnel. b) Clothing The use of personal protective clothing is mandatory for all lead work. Impervious disposable coveralls (Tyvek type or equivalent) fitted with head covering and non-skid booties that are acceptable for the specific worksite conditions. Coverall must resist penetration by lead dust. Page 5
cover the body and fit snugly at the neck, wrists, and ankles. Nitrile or latex Disposable Gloves taped at the wrist Safety Glasses Immediately repair or replace damaged torn protective clothing or equipment. Other protective equipment in addition to those listed above will be worn or carried on your person as warranted by site conditions and noted possible hazards that have been identified on the work site. Examples may include: hard hats, flashlights, high visibility vests, safety shoes, escape WARNING: Where other hazards are may be present, DO NOT ENTER THE WORK AREA! Contact the project manager for specific instruction prior to entry into the potentially contaminated work area. OTHER TYPES OF PERSONAL PROTECTIVE EQUIPMENT MAY BE REQUIRED TO MITIGATE THESE OTHER HAZARDS. 6. HYGIENE FACILITIES AND DECONTAMINATION PROCEDURES A. GENERAL HOUSEKEEPING Work areas are to be kept clean and free of lead dust. Surfaces should be cleaned with water, wet mops, wet rags, and vacuums with high efficiency particulate air (HEPA) filters to prevent lead dust from contaminating work clothes and tools. Surfaces should not be wiped or swept when dry as this will raise lead dust into the air where it can be inhaled and cause further contamination to other surfaces. Rags, mops, and filters contaminated with lead must be handled and disposed of according to safe work procedures established by the employer. B. SHOWER AND CHANGE FA CILITIES When School District 47-Operations and Maintenance Department workers are involved in low to moderate risk lead abatement, adequate washing, showering, and change facilities will be provided. These facilities will be designed for lead-exposed workers so they can wash thoroughly before work breaks and shower at the end of each shift. There will be a separate area designated for clean clothing (work and personal) and another area for contaminated work clothes, with showering and washing facilities in between. In addition to sinks, wash areas should be supplied with nail brushes, individual paper towels or air dryers (not communal or reusable towels), and soap dispensers (not soap bars) An example of a shower/change facility is shown to the right. For large abatement projects where significant levels of dust may be generated, a three stage decontamination chamber may be required with a walk-through shower as is commonly used in high risk asbestos work, should be used. C. EATING FACILITIES A separate room completely isolated from the work area will be provided for storing food, drinking, and eating food. Workers should remove contaminated clothing before eating. The eating area should be near the washing and changing rooms so that workers do not have to pass Page 6
through the shop floor area after washing before a meal or coffee break. Eating, drinking, storing of food, and smoking must not be allowed in the work areas. D. MODERATE RISK WORK AREAS - ALL Upon leaving a MODERATE RISK work area, each worker shall follow these decontamination procedures. 1. All tools and surfaces which have been contaminated should be cleaned off prior to removal from the Work Zone. If tools cannot be decontaminated prior to removal, they must be double bagged in the Waste Bags and cleaned while wearing full PPE under moderate risk procedures at a later time. 2. Remove coveralls and booties and place into the Waste Bag. 3. Carefully remove gloves using a no-touch technique and dispose of into the Waste Bag. 4. Wipe down respirator, remove cartridges and place into the Waste Bag or place duct tape on cartridges and clean respirator as indicated below. 5. Wash hands and face with disposable wet cloth. 6. Thoroughly clean all PPE used with a disposable wet cloth. 7. Dispose of cloth in the Waste Bag. 8. Take down barrier and dispose of tape. 7. EDUCATION AND TRAINING School District 47-Operations and Maintenance Department employees who may be at risk of exposure to lead will be adequately instructed and trained in: This Exposure Control Plan The hazards of lead, Identifying lead containing materials at the worksite The written work procedures to be followed The correct use of personal protective equipment and implementation and operation of any required engineering controls and administrative controls, Personal hygiene and decontamination procedures, and The purpose and significance of any health monitoring. Procedures to be followed in case of an emergency involving lead. 8. HEALTH MONITORING A health monitoring program (including the collection and analysis of blood samples) will be implemented under the supervision of an occupational physician for projects more than one week in duration. The purpose of health monitoring is to protect workers from developing occupational disease by detecting biological indicators or adverse health effects at an early stage. Health monitoring must not be used as a substitute for environmental monitoring. Records of any health monitoring must be maintained. Individual workers have the right to know the results of their own health monitoring tests. Page 7
9. DOCUMENTATION The following documents will be kept on file for at least 10 years: Risk Assessments Exposure Control Plan and Safe Work Procedures Material Safety Data Sheets Respirator Fit Test Records Training Records Lead Inventory Notice of Projects (NOP's) Records of Corrective actions (if any) Air monitoring and inspection results 10. SAFE WORK PROCEDURES School District 47-Operations and Maintenance Department has developed and implemented safe work procedures for activities where workers are, or may be exposed to lead. Step-by-step safe work procedures on how to perform the work safely have or will be developed for each particular work process before work begins. A. MODERATE RISK WORK The following general procedures are required for moderate-risk work: These procedures are mandatory for any School District 47-Operations and Maintenance Department employee undertaking a moderate risk work activity. 1. Clearly mark the designated work area boundary by closing doors and windows, placing barricades, fences, or caution tape or similar structures around the work area. 2. Place signs around the work area warning people not to enter the work area unless authorized to do so, that airborne lead dust may be present and respiratory protection is required. 3. Turn off any ventilation fans that may be affected and seal and supply, return, or exhaust air ducts. 4. Wear respiratory protection and protective clothing specified in Part 5 of this ECP: 5. NEVER use compressed air to clean up or remove dust or materials from work surfaces or clothing. 6. Use polyethylene (poly) drop sheets to cover wet material that is on floor and seal windows, doorways, and other openings to prevent the spread of lead dust to other work areas. 7. Before starting any work that is likely to render lead dust airborne, clean all adjacent surfaces within the work area, clean up any dusts by damp-wiping or using a vacuum cleaner equipped with a HEPA-filtered exhaust. Page 8
8. During the work, clean up dust and waste (wetted if possible) using a CERTIFIED vacuum cleaner equipped with a HEPA-filtered exhaust, or by wet-wiping or mopping. 9. Immediately upon finishing the work, complete the following tasks: Glue out the drop sheets and barriers using a suitable gluing agent such as Towerthon or spray with amended water. Fold drop sheets to contain any remaining dust and place into a bag labelled Lead Waste. Dispose of all wastes as Lead Waste. 10. Before leaving the work area follow egress procedures specified in Part 6 of this ECP. 11. To prevent any interference with the work activity, do not allow containers of lead waste to accumulate in the work area. Remove containers from the work area at the end of each work shift, if not more often, and ensure that the containers remain under effective control if they are stored at the worksite before being disposed of. 12. Before removing lead waste containers from the work area, clean their external surfaces by wiping with a damp cloth or using a vacuum cleaner equipped with a HEPA filtered exhaust. Double bagging is a good practice. 13. After completing the work, provide the owner or employer occupying the area with documentation stating that it is safe for unprotected workers to re-enter the work area. 11. TEMPORARY WASTE STORAGE, HANDLING AND DISPOSAL All lead contaminated wastes will be assumed to be hazardous wastes and stored in a secure location until it has been determined through testing that it is safe for disposal as a non-hazardous material. Testing involves taking a representative sample of the waste material and sending it to lab for extraction by the Toxicity Characteristic Leaching Procedure and analysis. Wastes that produce levels of leachable lead in excess of the limits set out in the BC Hazardous Waste Regulation will be transported for disposal to an authorized facility by a licensed hazardous waste transporter in accordance with federal and provincial transportation requirements. A waste manifest must be completed by the abatement contractor and the waste hauler for each load of waste exceeding 5 kg. Copies of the waste manifest must be submitted to the Ministry of Environment as per instructions on the back of each manifest form and also copied to School District 47-Operations and Maintenance Department for recording and lead-related inventory adjustments. Page 9