U.S. Department of Transportation
Federal Highway Administration
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Washington, DC 20590
Federal Highway Administration Research and Technology
Coordinating, Developing, and Delivering Highway Transportation Innovations
|This report is an archived publication and may contain dated technical, contact, and link information|
Publication Number: FHWA-RD-98-180
Safety and Health on Bridge Repair, Renovation and Demolition Projects
Table of Contents
|CFR||Code of Federal Regulations|
|DOT||U.S. Department of Transportation|
|EPA||US Environmental Protection Agency|
|LHASP||Lead health and safety plan|
|NIOSH||National Institute for Occupational Safety and Health|
|OSHA||US Occupational Safety and Health Administration|
|PEL||Permissible exposure level|
|ug/dl||Microgram(s) per deciliter|
|ug/m³||Microgram(s) per cubic meter|
Introduction: A Comprehensive Approach
The deteriorating condition of the nation's infrastructure combined with the potential for high lead exposures associated with work on lead painted bridges point to an epidemic of lead poisoning unless comprehensive measures are employed to control worker exposures.
Work involving lead paint may pose serious health risks. Health risks associated with exposure to lead include impaired blood synthesis, nervous system disorders, gastrointestinal effects, malformation of sperm and offspring and kidney damage.
OSHA has estimated that over 5000 bridge repainting and rehabilitation projects involving lead exposure will occur each year (Federal Register). In addition, exposures greater than 400 times the current OSHA Permissible Exposure Limit (PEL) for construction have been documented during torch burning and abrasive blasting - activities common to bridge rehabilitation and demolition work.
Owners and contractors have a clear interest and responsibility in ensuring that work on lead painted structures does not endanger the health and well-being of workers, their families, the community and the environment.
Reliance on regulatory enforcement alone by agencies such as OSHA and EPA is an ineffective approach since 1) enforcement activities are scarce in relation to the volume of work underway, and 2) compliance approaches often identify problems after harmful exposures have already occurred. This document outlines a comprehensive, proactive approach to occupational lead poisoning prevention centered around the use of contract specifications.
As owners, state and federal transportation agencies, city and county governments, and turnpike commissions, play a critical role in how work on lead painted bridges and elevated highways is conducted. Development of specifications which require suitably protective work practices and controls, selection of a qualified contractor and enforcement of the terms of the specifications are the responsibilities of the owner. Execution of these activities with the intent of protecting workers from harmful exposures to lead ensures that work is carried out in a manner that doesn't jeopardize the health of workers or their families.
Specifications govern the terms of work in construction. They define how a job will be carried out and what activities will be compensated. Elevating worker protection to a detailed element of specifications for which owners are willing to pay for is the mechanism that is most likely to fully integrate safety and health into this type of work.
While these specifications may be applied to work on lead painted structures owned by municipalities, private industry or other government agencies, the primary purpose for their development is to assist state and federal transportation agencies involved in the rehabilitation, repainting and demolition of lead painted bridges and elevated highways. Although this document addresses the hazards associated with work on lead painted structures, contract specifications are a useful mechanism for protecting construction workers from a much broader spectrum of health and safety hazards.
These Model Specifications for the Protection of Workers from Lead on Steel Structures are intended to serve primarily as guidelines for language governing lead health and safety contractor requirements. In addition, some of the hazards commonly encountered during infrastructure repair, maintenance and demolition have also been addressed. The first version of this document was developed by a diverse group of public health experts, contractors, industry trade associations, government agencies and labor representatives in 1993. A roster of participants appears in Appendix A. Where applicable, the language of the OSHA Interim Lead in Construction Standard (29 CFR 1926.62) was incorporated. In addition, the recommendations of the Working Group, which may exceed the requirements of the standard, were included to assist agencies who are interested in providing more than the minimum requirements of protection to contract employees.
Following the development and widespread dissemination of the 1993 Model Specifications, the guidance language was revised with the interest of continuously improving their content. Under a cooperative agreement with the National Institute for Occupational Safety and Health (NIOSH), the Center to Protect Workers' Rights implemented the Model Specifications on a lead abatement project at NASA Lewis Research Center in Cleveland, OH. In addition, a survey of state transportation and health agencies and a review of "Best Practices" for effective safety and health programs were conducted. Based on the outcome of these efforts, a second Working Group meeting was convened in 1995 to make recommendations on how to improve the language developed in 1993. A roster of participants in the 1995 Working Group meeting appears in Appendix B. This revised document reflects the conclusions and recommendations resulting from that process.
The need for effective interventions aimed at preventing illness and injuries in construction is great. Representing only about 5-6% of the workforce but 16% of occupational fatalities, construction workers bear a disproportionate burden of deaths in the workplace¹. They also are disproportionately represented among
workers with blood lead levels greater that 40 ug/dl with 63% of workers in this category being construction workers². The number one recommendation resulting from the Second National Conference on Ergonomics, Safety and Health in Construction was that “the industry needs to develop a greater culture of safety to encompass owners, contractors at various tiers, workers and their unions”³.
This revised version of the Model Specifications has incorporated new language that:
The consensus of the 1995 Working Group responsible for updating the Model Specifications, was that "owners of public/private works are key to change in the construction industry". Specifications are an essential contractual tool that can be used towards the achievement of positive change in the industry. However, they are only one piece of the puzzle. As the controlling interest in construction projects, owners have enormous power to reverse the rate of illness, injuries and deaths by ensuring that:
Ensuring that all of these requirements are met involves integration of safety and health in each and every phase of construction, including project design and planning.
I. Pre-bid Phase
A. Job Planning
1) Owners should develop a written safety and health plan that identifies all recognized hazards and minimum requirements for controlling those hazards for each project prior to the selection of contractors.
2) Owners should designate a qualified safety and health planning coordinator to develop the plan and communicate and deliver the plan to the constructor.
It’s common to talk about the “life” of a structure in the context of maintenance and planning for continued safe use by the public. Information about a given structure over its “lifetime” rests with the owner. While a number of contractors may have worked on a structure over a period of several decades, the owner is the entity which is responsible for the structure and which provides continuity between projects. It is in the interest of the owner, the public, contractors and their employees to maintain a living file on such structures which documents the hazards associated with work on a particular structure and procedures, either planned are completed, for controlling those hazards. The information contained in the file should be communicated to prospective contract bidders to ensure that the means for controlling identified hazards are built into the project design.
The European Community has developed “minimum safety requirements for construction” which mandate specific owner responsibilities aimed at preventing injuries and illnesses once work begins on a structure. These directives as they have been applied in the United Kingdom simply establish a procedure whereby the owner:
Even in our country, the Occupational Safety and Health Administration has begun to recognize the important role that owners play in influencing contractor performance in 29 CFR 1926.64: Process Safety Management of Highly Hazardous Chemicals5. This standard requires that employers covered by the standard evaluate contractor safety performance before selection, communicate hazards to the contractor and periodically review contractor’s performance with respect to the “employers” plan in the event of a chemical release. The “employers” addressed by this standard are construction owner/clients much like highway agencies. Although this standard is aimed at the prevention of catastrophic events in the chemical processing industry, there is a clear parallel in that owners responsible for lead-painted structures can prevent contamination of the environment, surrounding communities and workers by having:
B. Mandatory Pre-bid Meetings
Pre-bid meetings provide an opportunity for owners to inform contractors of the potential for lead exposure and to discuss the worker, community and environmental protection measures, which must be employed, on these projects. If feasible, contractors should be required to visit the proposed work site.
Instead of holding a pre-bid meeting for each project, owners may prefer instead to conduct an annual general meeting that all potential contractors must attend. During this meeting, the requirements of a lead health and safety plan, owner expectations for contractor performance and enforcement mechanisms would be outlined.
C. Pre-qualification and Contractor Selection Requirements
As an example, use of the Steel Structures Painting Council (SSPC), Painting Contractors Certification Program (PCCP) certification QP 2(I) should be considered for pre-qualifying painting contractors. The PCCP QP 2(I) certification has been available to contractors since August of 19936.
Departments of transportation at the state and federal level (the DOT) should notify contractors of state and federal training certification regulations. Only contractors who can demonstrate their ability to comply with these regulations should be permitted to bid on work on lead-painted structures.
A contractor's past performance should be evaluated, including:
Contractors whose previous experience indicates poor performance in the area of safety and health should be considered non-responsive during the pre-bid stage for the next contract season.
The Interim Lead Standard requires that employers prepare a written lead compliance plan prior to the commencement of the job where employee exposure to lead is likely to exceed the PEL. Thus, contractors should be required to submit an outline of their Lead Health and Safety Plan (LHASP) as well as other documentation (e.g. worker/supervisor training certifications) in response to the specifications with the bid.
Alternatively, the owner could require that bidders complete a 1-2 page form that forces contractors to address how they will address each element of the LHASP. Information on the contractor's experience in executing a Lead Health and Safety Program could be collected through this medium. This approach will insure that each element of the program is included in the bid price and also assist DOT agencies in assessing contractor experience.
Only those contractors which have submitted a bid which can reasonably be expected to provide adequate protection to workers shall be considered for contract awards.
A health and safety professional, such as an industrial hygienist, is best equipped to critically review a LHASP. DOT agencies could best perform this function with in-house support and/or in concert with the assistance of state health agencies. For instance, some state DOT agencies have an industrial hygienist on staff to carry out this task. An alternative approach is to retain an on-call professional consultant to act in an "owner's representative" capacity. The DOT should ensure that consultants are independent from bidding contractors in order to prevent any potential conflict of interest from arising. One approach to assure that conflict of interest does not arise is for the DOT to contract directly with the consultant.
II. Pre-construction Phase
A. Verification and Approval of Contractor’s Lead Health and Safety Plan (LHASP)
At this point a pre-qualified contractor has been selected and a preliminary outline for the LHASP has been approved by the DOT. The DOT would now verify the mobilization of appropriate and adequate resources relevant to worker protection (e.g. ventilation equipment, personal protective equipment, etc).
The DOT should review the contractor's full written LHASP prior to the initiation of work. Qualifications of the on-site Construction Safety and Health Specialist, Industrial Hygienist and other personnel as well as documentation verifying pre-assignment training, medical surveillance and respiratory fit testing should be reviewed. Once the written LHASP and all other documentation required by the specifications have been approved by the DOT, the contractor would be authorized to move into the construction phase.
B. Notification of Project Startup to Appropriate Agencies
State and federal agencies responsible for worker protection can be an important resource of DOTs. Consultation programs are available which may be useful in project planning and to provide support throughout the duration of projects. In addition, they are the primary enforcement agency responsible for worker protection. Given the transient nature of construction, the large number of sites and limited OSHA staffing, Dots can greatly assist worker protection agencies by giving adequate advance notice of project start dates.
III. Construction Phase
While not a substitute for exposure monitoring, worker blood lead levels (BLLs) are one barometer of how effective a contractor's LHASP is in practice. Certified copies of all employee BLLs which do not contain the names or social security numbers of individual workers shall be forwarded to both the DOT and the state blood lead registry office in states where they exist no later than 5 days after receipt. State lead registries provide a useful means of tracking job sites with elevated BLLs. Interagency cooperation between state health and transportation agencies is necessary to insure that lead registries are effectively used in identifying problem job sites and intervening to prevent further exposure to workers. Specifically, in states where blood lead registries exist, state health departments should report those sites with elevated BLLs to the DOT. This additional source of BLL information to Dots can facilitate followup site visits aimed at identifying the problem. Interagency cooperation can extend further to involve the efforts of the DOL in enforcing worker safety laws or in providing consultation services to the contractor looking for constructive assistance.
Enforcement of the project specifications is the responsibility of the owner. Therefore, DOT personnel, or their authorized representatives, should serve as the front line inspectors of contractor compliance with the LHASP. Although Dots will need to train and maintain qualified staff, or retain outside professional support, coating or welding inspectors could be utilized for much of this work. For example, professional industrial hygienists (in-house or on a consulting basis) could develop site-specific enforcement checklists, which would be used by trained DOT inspectors.
13) A Project Committee should be established made up of co-chairs of the joint safety and health committee established by the contractor, the Construction Safety and Health Specialist and the owner’s Project Safety and Health Coordinator. The Committee should meet at least once per month.
14) Owners should use contract provisions to withhold payment or remove contractors from the job-site who fail to comply with the written safety and health program.
In order to ensure that the LHASP is being complied with, the following provision should be part of the construction contract:
If BLLs exceed 35 ug/dl7 for 2 or more workers, the contractor shall be required to submit a plan of corrective action within one week of receipt of results. If BLLs exceed 50 µg/dl8 for any worker, a percentage of the bid amount should be held on a monthly basis until controls have been upgraded to maintain BLLs below 50 µg/dl. In addition, the medical removal protection (MRP) provisions of the OSHA Interim Lead in Construction Standard requires that when a worker's periodic and follow-up blood lead test results in a BLL equal to or greater than 50 µg/dl that worker shall be removed from exposure without loss of pay for up to 18 months.
The costs of not protecting workers are painfully real but hard to measure. As such, it would be of value for owners to track payroll costs for contractor provision of Medical Removal Protection Benefits. In addition, it would be useful for state blood lead registries to tract the amount of Medical Removal Protection Benefits paid.
I. General Information
Work under this item shall consist of implementation of a Lead Health and Safety Plan. This special provision is applicable on any job where an employee may be occupationally exposed to lead. The intent of this special provision is to prevent employee absorption of harmful amounts of lead in any form by inhalation or ingestion and to prevent lead exposure to the families of workers through contaminated clothing, vehicles or other personal items, such as tools or lunch boxes. The contractor will be fully responsible for the protection of his or her employees and any subcontractor personnel from exposure to lead as well as other recognized safety and health hazards.
B. Applicable Documents
The contractor shall comply with the requirements of the Interim Final Rule for Lead Exposure in Construction (29 CFR 1926.62) of the US Occupational Safety and Health Administration (OSHA) and any other applicable federal or state laws. Additional Federal regulations which must be complied with include, but are not limited to9:
|29 CFR Part 1926.16
29 CFR Part 1926.59
29 CFR Part 1910.20
29 CFR Part 1910.134
29 CFR Part 1910.94
29 CFR Part 1926.20
29 CFR Part 1926.21
29 CFR Part 1926.28
29 CFR Part 1926.51
29 CFR Part 1926.55
29 CFR Part 1926.57
29 CFR Part 1926.103
29 CFR Part 1926.200
29 CFR Part 1926.353
29 CFR Part 1926.354
29 CFR Part 1926.32
29 CFR Part 1910.120
29 CFR Part 1910.141
|Rules of Construction
Access to Employee Exposure and Medical Records
General Safety and Health Provisions
Personal Protective Equipment
Gases, Vapors, Fumes, Dusts and Mists
Accident Prevention Signs and Tags
Ventilation and Protection in Welding, Cutting and Heating
Welding, Cutting and Heating in Way of Preservative Coatings
Hazardous Waste Operations & Emergency Response
Industrial Hygienist (IH). Industrial hygienists shall have the following qualifications: current certification by the American Board of Industrial Hygiene with field and sampling experience, preferably in the construction industry; or hold a Master's degree from an accredited college or university in the field of engineering, chemistry, physics, biological sciences, industrial hygiene, toxicology, the environmental sciences or a related field and have at least two years of full-time experience as an industrial hygienist, including field and sampling experience, preferably in the construction industry: or hold a Bachelor's degree in the field of engineering, chemistry, physics, biological sciences, industrial hygiene, toxicology, the environmental sciences or a related field and have at least three years of experience as an industrial hygienist, including field and sampling experience, preferably in the construction industry.
Construction Safety and Health Specialist (CSHS). Construction Safety and Health Specialist shall be capable of identifying hazardous or dangerous conditions. The individual shall have experience in the construction industry (preferably in highway and bridge rehabilitation), and formal training and experience in safety and health. Such formal training and experience shall include at a minimum:
In addition to meeting these requirements, personnel employed by the contractor responsible for safety and health should have qualifications consistent with federal and state regulations.
While the contractor may elect to train and authorize the CSHS to serve as the competent person as defined by 29 CFR Part 1926.32, these specifications do not require that the CSHS serve in this capacity.
1) Lead Health and Safety Plan
A Lead Health and Safety Plan (LHASP) must be submitted to the DOT prior to the initiation of work and should be specific to the job site. Filing of the plan will not constitute approval by the DOT. A copy of the Interim Lead Standard and other prevailing regulations should be submitted with this plan. Material Safety Data Sheets (MSDSs) for any chemical products to be used on the site should be submitted. The contractor's project supervisor shall be able to demonstrate that he or she has read and understands these documents. Training certifications for supervisors and employees should be submitted as well as SSPC Contractor Certifications, where applicable. A copy of the LHASP, applicable standards, MSDSs and Certifications must be on site at all times.
The LHASP must include, but is not limited to
The following documents may provide useful guidance for developing a LHASP. Their inclusion in these specifications is for reference only and not to be interpreted as a requirement.
Industrial Lead Paint Removal Handbook 2nd Edition. K. Trimber, (1991) SSPC 93-02. Steel Structures Painting Council, 4516 Henry St., Suite 301, Pittsburgh, PA 15213.
Minimum Criteria for Hazardous Waste Operations and Emergency Response Training Programs NIEHS (1991). National Clearing House for Worker Safety and Health Training for Hazardous Materials, Waste Operations, and Emergency Response. George Meany Center for Labor Studies, 10000 New Hampshire Avenue, Silver Spring, MD 20903. 301-431-5425.
The 100 Most Frequently Cited OSHA Construction Standards in 1991: A Guide for the Abatement of the Top 25 Associated Physical Hazards (1993). US Department of Labor, Occupational Safety and Health Administration. For sale by US Government Printing Office, Superintendent of Documents, Mail Stop SSOP, Washington, D.C. 20402-9328.
Preventing Lead Poisoning in Construction Workers (1992). National Institute for Occupational Safety and Health, 4676 Columbia Parkway, Cincinnati, OH 45226 (513) 533-8287.
Preventing Silicosis and Deaths from Sandblasting (1992). National Institute for Occupational Safety and Health, 4676 Columbia Parkway, Cincinnati, OH 45226. 513-533-8287.
Protecting Workers and their Communities from Lead Hazards: A Guide for Protective Work Practices and Effective Worker Training (1993). Society for Occupational and Environmental Health, 6728 Old McLean Village Drive, McLean, VA 22101.
Working with Lead in the Construction Industry OSHA 3142 (1993). US Department of Labor, Occupational Safety and Health Administration. Call OSHA Publications Office, 202-219-4667 or write to Publications Office, Room N3101, Department of Labor, 200 Constitution Ave. NW., Washington, DC 20210.
2) Comprehensive Safety and Health Program
Contractors shall incorporate lead hazard prevention program into a larger safety and health program aimed at preventing occupational exposure to all other hazards generated by this work. The contractor shall submit a written plan which addresses, at the minimum, the hazards described below prior to the start of work:
E. Quality Assurance
1. Joint Safety and Health Committee (JSHC). Meaningful employee participation and regular communication between labor and management are essential for effective safety and health programs. Joint Safety and Health Committees are necessary for a regular and systematic exchange of information between contractors and their employees. The general or prime contractor shall establish a site-based joint safety and health committee upon the onset of work. If there is no general or prime contractor on site, the owner shall establish a JSHC made up of individual contractors and their employees engaged in work on the site.
Each craft and each sub-contractor present on site will be represented on the JSHC, except in the case of projects less than one month in duration in which case the committee should consist of one labor and one management representative. On union sites, the labor representative should be a safety steward and assigned by the local Building and Construction Trades Council. On non-union sites the labor representative should be elected by the work force.
The JSHC shall be composed of at least 50% worker representatives and shall be co-chaired by both a management and labor representative. Those individuals serving as chairpersons of the Joint Safety and Health Committee shall have received training in Joint Safety and Health Committee Representative
Training. Chairpersons shall be given adequate preparation time to prepare for meetings (at least one hour). The JSHC shall meet at a regular frequency, at least once per month.
Committee Chairpersons and the Chief Safety and Health Representative or Steward shall have the power to remove workers from unsafe work conditions for which there is a reasonable cause to believe that an imminent danger exists.
A Workers' Trade Committee shall be established composed of one representative from each craft on site. On union jobs, such representatives should be designated as safety stewards. On nonunion jobs, the craft representative should be elected by members of their respective craft serving in a non-supervisory capacity. The Workers' Trade Committee shall meet at least once per month at least 48 hours prior to the JSHC.
Representatives serving on the Workers Trade Committee and the foremen for the subcontractor to which they are employed should conduct regular walk-throughs (at least once per week) for the purpose of: 1) communicating with the trades they represent and employ, respectively; and 2) to monitor site conditions.
The JS&HC will review reports made by safety and health personnel employed by the contractor and provide regular input into the implementation of the site safety and health program. The JSHC will provide direction to occupational safety and health personnel employed by the contractor. Recommendations of the committee must be acted on in a timely manner. The presence of a JSHC does not supercede nor negate the contractor's duty to provide a safe and healthful workplace.
2. Industrial Hygienist (IH). Contractors shall engage a qualified IH to:
While the CSHS may serve as the primary on-site monitor of the LHASP, the IH must be on site at least once a week during activities which have been associated with or can reasonably be expected to create lead exposures in excess of 30 µg/m³. The IH may be required to be on site more frequently at the start of the project or when site conditions or work practices change until exposure monitoring indicates that exposures are being effectively controlled. An increase greater than 10 ug/dl in worker BLLs will prompt more frequent site visits by the IH until corrective measures have successfully reduced BLLs.
The IH shall certify monthly in writing, within 5 days after the end of the month, to the DOT that the contractor has performed all of the listed requirements of the Lead Health and Safety Plan and any actions taken on any deficiencies found. The IH shall approve any changes to the LHASP. The DOT shall be immediately informed by the IH or CSHS of all major decisions regarding any changes to the LHASP.
The IH shall also evaluate potential exposure hazards related to the use of chemical products, including new paint coatings - and institute effective controls.
Construction Safety and Health Specialist (CSHS) The contractor shall designate a CSHS, not the project superintendent or foreman, to ensure that the LHASP is implemented on a daily basis and that all work conducted on site is in compliance with the LHASP. The Construction Safety and Health Specialist shall be designated as the Chief Safety & Health Steward on union jobs to enable performance of their job without fear of retribution. On nonunion jobs the CSHS will serve as the Chief Safety and Health Representative. The CSHS shall be provided with adequate duty-time. Determination of duty time will be dependent on the specific responsibilities of the CSHS, the nature of the site and site-specific hazards.
The CSHS will be responsible for:
4. Medical Surveillance. The contractor shall institute medical surveillance in accordance with the Interim Lead Standard. All medical procedures required by this program shall be provided by the contractor at no cost to the employee.
Medical surveillance does not replace exposure monitoring, rather it is a method of verifying that workers are not being adversely impacted by lead despite low airborne concentrations. The medical surveillance program must be overseen by a licensed physician. It is recommended that an occupational physician, board certified by the American Board of Preventive Medicine, oversee the medical surveillance program.
The employer shall notify each employee in writing of their biological monitoring results within 5 working days of receipt of such results. Employees with BLLs greater than 40 µg/dl shall be notified of their right to medical removal protection when their BLL exceeds the criterion defined in the Interim Lead Standard. The standard requires that biological monitoring occur at the following frequency:
Because of the high lead exposures associated with work activities performed during bridge rehabilitation and demolition, the schedule for blood monitoring required by the standard may be too infrequent to capture steep rises in BLL in a timely manner. In order to prevent this from occurring, the Working Group has recommended that the following schedule be followed:
In addition, the following provisions shall be implemented:
Contractors shall ensure that all physicians conducting blood monitoring shall have all samples analyzed by an OSHA approved lab that has demonstrated proficiency in blood lead analysis. A list of the approved labs can be obtained from OSHA.14
Certified copies of all blood lead level results shall be forwarded to the DOT no later than 5 days after receipt. In the interest of protecting the privacy of workers, individual names and social security numbers should not be included in the information sent to the DOT. Elevated BLL results shall be forwarded to the state blood lead registry office in states where they exist no later than 5 days after receipt.
The Interim Lead Standard requires that a medical exam be made available at least annually to any worker for whom a blood lead sample was found to be at or above 40 µg/dl during the preceding 12 months. According to the standard, such an exam must include:
Since health effects may occur at BLLs lower than 40 µg/dl and because workers may be employed by a number of contractors at different job sites, each of which will have varying levels of exposures and controls, it is recommended that contractors make the preceding tests available to employees before making job assignments to newly hired workers.
F. Site Conditions
The paint contained on this structure contains lead. Lead has been shown to have serious health effects on workers if caution and attention to details are not followed. Other hazards which may be associated with work on this structure include, but are not limited to, heat stress, noise, ergonomic hazards, heavy metals other than lead, and falls. (This section of the specifications should explicitly state the potential hazards associated with a specific project, thereby putting the prospective bidder on notice. Structure specific information on lead paint concentrations could be included in this section to provide contractors with a more definitive estimate of the potential hazard).
Abrasive blasting with abrasive containing crystalline silica can cause serious or fatal respiratory disease. The National Institute for Occupational Safety and Health (NIOSH) has recommended that the use of abrasive containing more than 1% crystalline silica be prohibited. NIOSH has also reported 99 cases of silicosis from exposure to silica during sandblasting. Fourteen of the 99 cases have already died, and the remaining 85 may die of silicosis or related complications15. Alternative technologies such as the use of recyclable steel grit or shot abrasives do exist. Given the severity of the hazard associated with silica-containing abrasive, the use of silica as an abrasive medium is prohibited.
The Consumer Product Safety Commission (CPSC) designates a concentration for paint application products of less than 0.06% lead by weight for consumer use16. The potential exposure hazards related to the use of chemical products, including new paint coatings, must be evaluated by the IH and effective controls must be instituted. This language should appear in all paint application specifications.
A. Engineering and Work Practice Controls
Engineering and work practice controls shall be the primary control methods to limit exposure to lead and other occupational hazards. Where feasible, preference shall be given to those paint removal and surface preparation methods which capture debris at the source. Lead based paint must be removed prior to welding or torch cutting of surfaces. 29 CFR Part 1926.354 requires that paint be removed at least 4 inches from the area of heat application in enclosed spaces. In the open air, employees shall be protected by a respirator. All power tools used for paint removal shall be equipped with vacuum shrouds which capture fine dust at the point and time of generation, and transport the dust to collection systems equipped with HEPA filters. such tools include needle guns, scrapers, and roto peeners. Extended handles should be used on cutting tools whenever possible to reduce exposure.
B. Respiratory Protection Program
The contractor shall implement a respiratory protection program in accordance with the provisions of 29 CFR 1910.134. The minimum respiratory protective equipment shall be selected based upon the task that a worker performs as specified in the Interim Lead Standard (29 CFR 1926.62(d)).
These requirements can be modified if, and only if, the IH can verify that exposures permit the use of other less protective respirators. Contractors must supply workers with respirators that are NIOSH and MSHA certified at no expense to the worker.
C. Hygiene Facilities and Practices
The IH shall establish a written personnel hygiene procedure available at the work site and in accordance with 29 CFR 1926.62 paragraphs (h) and (I) and other applicable standards. The Contractor shall provide at no cost to the employee:
1) Hygiene Facilities. The OSHA Interim Lead Standard requires that showers be provided where feasible. Where showers are provided, they must be equipped with hot and cold water. Such facilities must be readily available in the immediate work area. Hand washing facilities must also be provided in accordance with 29 CFR 1926.51. Hygiene facilities must conform to the requirements specified in 29 CFR 1910.141, the OSHA Sanitation Standard.
Because of the potential for taking lead home on clothing and personal belongings, the Working Group recommends that where exposures exceed 50 µg/m³ showers be mandated. Also, washing facilities shall be equipped with clean, hot and cold water, soap and disposable towels which the workers will use to wash their hands and faces before eating, drinking or smoking and after each work shift.
2) A clean area for eating, drinking and smoking. According to the Standard, smoking, eating and drinking in lead contaminated areas is to be prohibited.
3) A separate clean change room equipped with wash up facilities and separate lockers for work and street clothes. No street clothing shall be worn in contaminated areas.
4) Protective clothing and equipment with provisions for cleaning them. In accordance with 29 CFR Part 1926.62, clean work clothes must be provided at least weekly to all employees whose exposure levels are above the PEL and daily to those above 200 µg/m³ as an 8-hour TWA. To provide greater protection against the risk of taking home lead to children, the Working Group recommends that protective clothing be provided when exposures exceed 50 µg/m³. Protective clothing and equipment must be repaired or replaced as needed to maintain its effectiveness. Protective clothing and equipment must be removed at the completion of a work shift only in change areas provided for that purpose. Contaminated clothing is to be cleaned, laundered or disposed of and shall be placed in a closed labeled container. Persons responsible for handling contaminated clothing shall be informed of potential hazards. At no time shall lead be removed from protective clothing or equipment by any means that will put lead into the work area, such as brushing, shaking, blowing or using a regular vacuum cleaner. All protective clothing and equipment must remain on the work site, and thus cannot be worn home.
5) Workers shall be allowed sufficient pre-job preparation time to change into protective clothing and sufficient clean-up time as part of the work day.
All workers and foreman on site shall have been trained in General Construction Safety and Health, such training shall be at a minimum equivalent to the OSHA 10 hour construction course as well as lead specific. Lead specific training should at a minimum, satisfy existing federal and state regulations. Training on other specific hazards identified on the site shall also be provided.
The employer must have a written plan developed for conducting employee training of lead hazards in accordance with 29 CFR 1926.62(l). The training will cover, at a minimum:
Training content and duration must comply with EPA Standards, or state and local standards which are at least as protective as the EPA standards, . Documentation which verifies that training for workers and supervisors is current and valid must be on site at all times. Contractors must utilize workers and supervisors who have been trained in programs which have been accredited by the appropriate state or federal agency. Training must be presented in a language that is understandable to workers.
Training programs should comply with the training principles presented in the following documents: "Protecting Workers and their Communities from Lead Hazards: A Guide for Protective Work Practices and Effective Worker Training" (SOEH, 1993) and "Minimum Criteria for Hazardous Waste Operations and Emergency Response Training Programs" (NIEHS, 1991). SOEH recommends that industrial lead abatement training for workers be 32 hours in duration with 8 hours dedicated to hands-on training. Hands-on training should include activities involving trade specific operations (e.g. using shrouded needle-guns).
Initial training should be conducted in an area with seating for all workers, provisions for audio-visual aids and surfaces for writing. In addition to initial training, follow-up training will be conducted monthly by the IH or the CS&HS with the support of the IH. This training will consist of a review of the contents of the IH's monthly report.
E. Worker Exposure Assessment
1) Air monitoring. Personal air monitoring is one means of assessing worker exposure to lead dust and fume. In general, air monitoring at bridge rehabilitation and demolition sites is conducted in order to determine the range of lead concentrations to which workers are potentially exposed when performing different tasks and/or to measure the efficacy of controls in reducing airborne concentrations of lead.
The Interim Lead Standard requires that at a minimum this strategy include sampling one full shift for each job classification in each work area. Each shift must be sampled or the shift which is expected to have the highest exposure must be sampled. The standard also requires that samples be representative of the monitored worker's daily exposure. If exposures are less than the OSHA Action Level monitoring may cease. If exposures are greater than the Action Level but less than the PEL, monitoring is required to occur every 6 months. If exposures are greater than the PEL then monitoring must occur every 3 months.
Additional monitoring is also required when conditions change. The Standard further requires that workers must receive notification of results within 5 working days after completion of the assessment. When exposures are greater than the PEL, employers must provide written notice to workers as to how they plan to reduce exposures.
Because of the great variability in conditions which influence worker exposure in construction and because of the extremely high exposures associated with bridge projects, exposures may vary dramatically from week to week or even day to day. Therefore, the 1993 Working Group has determined that an effective strategy for accurate characterization of worker exposures is likely to require collecting multiple randomly collected samples over time for each job classification. This strategy should be in writing, and must accompany all reports containing air sampling results. Specific reasons for conducting air sampling include:
All air monitoring and analysis must be performed in accordance with NIOSH approved methods.
2) Wipe sampling. Because even small amounts of lead ingested from hand-to-mouth contact can contribute to total body burdens and because surface lead dust can easily become airborne, it is important to assess contamination of surfaces. Wipe sampling is one technique which may be used to assess potential contamination in areas which should be "clean"17. Such areas include change rooms and hygiene facilities. The contaminated area can be cleaned up by HEPA vacuuming followed by wet wiping. Wipe sampling may be required at the beginning of the job, and monthly thereafter, depending upon the blood lead results and the observations made by the IH. NIOSH method 0700 will provide a validated protocol for wipe sampling and will be available after January 1, 1994.
3) The OSHA Interim Standard requires that workers performing specific tasks be protected until exposure assessment is complete. These tasks and the presumed exposures which must be controlled for are as follows:
4) The contractor shall develop and implement an exposure assessment program for other identified hazards including noise, heat stress, solvents, total and respirable particulate and metal fumes associated with welding and thermal cutting.
IV. Basis of Payment
All elements of the contractor’s safety and health plan shall be paid for as cost plus or lump sum payment with an established minimum bid.
DHHS (1990). Healthy People 2000: National Health Promotion and Disease Objectives. Washington, DC: US Dept. of Health and Human Services, Public Health Service, DHHS Publication No. (PHS) 91-50212.
Federal Register (1993). Volume 58, Number 84, May 4, 1993.
USDOL (1991). OSHA List of laboratories approved for blood lead analysis.
VI. Additional Sources of Information
State, County and Municipal health agencies may be able to assist you in locating industrial hygienists and occupational physicians in your area. In addition, the following associations may be helpful in obtaining technical support:
American Conference of Governmental Industrial Hygienists
6500 Glenway Ave., Bldg. D-7, Cincinnati, OH 45211-4438
American Industrial Hygienists Association
2700 Prosperity Ave., Suite 250, Fairfax,VA 22031
(703) 849-8888, FAX 207-3561.
Association of Occupational and Environmental Clinics
1010 Vermont Ave., NW, #513, Washington, DC 20005
(202) 347-4976, FAX 347-4950.
American College of Occupational and Environmental Medicine
55 West Seegers Road, Arlington Heights, IL 60005
(708) 228-6850, FAX 228-1856.
Appendix A: 1993 Working Group Participants
Mr. Daniel P. Adley
Mr. Bernie Appleman
Mr. Peter Barlow, P.E.
Mr. William Bergfeld
Mr. Daniel M. Boody, President
Mr. Ted Brucker
Mr. L. Brian Castler
Mr. George Cesarini
Ms. Ellen Coe, R.N., M.P.H.
Mr. Steve Cooper
Mr. Michael Damiano
Mr. Denny Dobbin
Mr. Alan Echt, CIH
Ms. Barbara Gerwel, M.D.
Mr. Matt Gillen
Dr. Mark Goldberg
Ms. Janie Gordon
Mr. Joe Durst, Director
Mr. John P. Hausoul
Mr. George L. Hudspeth, Jr.
Mr. Bill Kojola
Mr. John Kolaya
Mr. Jerry Langone
Mr. Elihu Leifer
Dr. Stephen Levin, MD
Ms. Nora Leyland
Mr. Louis G. Lyras, President
Dr. Kathy Maurer, Project Director
Mr. R. Leroy Mickelsen
Mr. John Moran
Mr. Charles Most
Ms. Debbie Nagin
Ms. Ana Maria Osorio, M.D., M.P.H.
Mr. Anthony D. Pellegrino
Mr. Paul Perkins, Asst Chief
Mr. Richard Rabin
Dr. Knut Ringen
Mr. Brad Sant
Mr. Scott Schneider
Mr. David M. Serra
Mr. Paul J. Seligman, MD, MPH
Dr. Irene Smith, CRISP
Mr. Tom Smith
Mr. Pete Stafford
Ms. Pam Susi
Ms. Ellen Tohn
Mr. David J. Valiante
Dr. Laura Welch, MD
Ms. Teresa M. Willis
Appendix B: 1995 Working Group Participants
Mike Blotzer, MS, CIH, CSP
Lynda M. Ewers, PhD
Jack Finklea, M.D.
Bill Howe, PE
Tim St. Clair
Nidia Villalba, MD, IH, OHST
1Bureau of Labor Statistics, U.S. Dept. of Labor, National Census of Fatal Occupational Injuries, 1994, Washington, D.C., news release issued August 3, 1995.
2Commonwealth of Massachusetts, Dept. of Labor, Lead at Work: Elevated Blood Lead Levels in Massachusetts Workers, April 1991-April 1993. November 1994.
3Center to Protect Workers’ Rights: Building a Safety Culture. Report of the Second National Conference on Ergonomics, Safety and Health in Construction. CPWR Report G4-95; Washington, D.C. 1995.
4Presentation by Neil Murray, Head of Construction Policy Health and Safety Executive, Great Britain. Center to Protect Workers' Rights Second National Conference on Ergonomics, Safety and Health in Construction, June 18-21, 1995, Washington, D.C.
5U.S. Department of Labor, Occupational Safety and Health Administration: Title 29 Code of Federal Regulations, Part 1926.64: Process Safety Management of Highly Hazardous Chemicals.
6Steel Structures Painting Council Qualification Procedure No. 2(I): Standard Procedure for Evaluating the Qualifications of Painting Contractors to Remove Hazardous Paint. Steel Structures Painting Council. SSPC 92-14, Pittsburgh, PA, 1992.
7The Department of Health and Human Service has established 25 µg/dl as a specific goal above which workers' blood levels should not exceed (DHHS, 1990). The OSHA criteria for approving laboratories for blood lead analysis includes a requirement that individual BLLs sample analysis results be within 6 µg/dl of the all method mean if the mean is less than 40 µg/dl (USDOL, 1991). Therefore, a level of 35 µg/dl indicates that an increase in BLL above acceptable levels which is not a result of analytical error has clearly occurred.
8Penalty should be waived if the worker's entry BLL is greater than 35 µg/dl. If the worker has been employed at that site for more than two months the penalty may be levied regardless of entry BLL.
9On June 30, 1993, OSHA officially incorporated all applicable General Industry Standards (Part 1910) into the Construction Industry Standards (Part 1926). OSHA revised Part 1926 by adding the applicable Part 1910 Standards to part 1926. These changes are due to appear in the revision of the Code of Federal Regulations scheduled for publication in October, 1993. Copies of Federal regulations can be obtained from the Superintendent of Documents, US Government Printing Office, Washington, DC 20402.
10Robinson, C.F.; Halperin, W.E.; Alterman, T; Braddee, R.W.; Burnett, C.A.; Fosbroke, D.E.; Kisner, S.M.; Lalich, N.R.; Roscoe, R.J.; Seligman, P.F.; Sestito, J.P.; Stern, F.B. and Stout, N.A. Mortality patterns among construction workers in the United States. Occupational Medicine: State of the Art Reviews; Vol 10, No. 2, April 1995. Philadelphia, Hanley and Belfus, Inc.
11ACGIH (1994) 1994-1995 Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices. American Conference of Governmental Industrial Hygienist, Cincinnati, OH.
12Conroy, L.M.; Lindsay, R.M.M.; And Sullivan, P.M. Lead, chromium and cadmium emission factors during abrasive blasting operations by bridge painters. Am.Ind. Hyg. Assoc. J. (56), March 1995.
13Projects vary in the likelihood and degree of lead exposures, level of control and resulting risk to workers. The second blood lead test should never occur more than one month from the baseline measurement. Where activities are such that high exposures may occur or exposures are highly variable, a second test should occur within two weeks of the baseline. Examples of high exposure tasks include welding, burning, rivet busting and abrasive blasting. Exposures would also be expected to increase as the degree of enclosure increases.
14To obtain a current list of the approved labs contact: Bill Babcock, OSHA Technical Center, P.O. Box 65200, Salt Lake City, Utah, 84165-0200. (801) 487-0267.
15DHHS. (1992) Preventing silicosis and deaths from sandblasting. National Institute for Occupational Safety and Health.Publication No. 92-102.
16There is not set standard for industrial use of lead based paint at this time. However, both ASTM and legislative activities are underway which will establish definitions for industrial lead paint products. The Federal Highway Authority has prohibited the use of lead paint on Federal aid projects authorized after June 1, 1993.
17While there are currently no Federal standards for lead in surface dust, the Department of Housing and Urban Development (HUD) sets a clearance level of 200 µg/ft² for floors. The new OSHA Compliance Directive for Lead (due out in October of 1993) is expected to provide more definitive criteria for evaluating effective decontamination of hygiene facilities.