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Safety and Health on Bridge Repair, Renovation and Demolition Projects

APPENDIX I

Table of Contents

Model Specifications
For the Protection of Workers
From Lead on Steel Structures

1996

The Center to Protect Workers' Rights (CPWR) is the research arm of the Building and Construction Trades Department, AFL-CIO.  CPWR is uniquely situated to serve workers, contractors, and the scientific community.  The first edition of this publication was developed by the Working Group for Model Specifications convened by CPWR in collaboration with the Occupational Health Foundation and the Steel Structures Painting Council in 1993. That meeting and the 1993 document were made possible by grant number U60/CCU306169 from the National Institute for Occupational Safety and Health (NIOSH).  This revised version of the Model Specifications was developed by a second Working Group meeting convened in 1995, following the implementation and evaluation of the 1993 Model Specs.  Its contents are solely the responsibility of the authors and do not necessarily represent the official views of NIOSH. It should be noted that this document is still in the process of revision.

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:

• goes beyond a single focus on lead to addresses some of the most serious hazards encountered on industrial lead abatement projects;
  
  
• establishes a system for communicating and coordinating among the numerous interests present on any construction site; and
  
  
• builds the necessary personnel and organizational structures to ensure that safety and health programs are effective in reducing injury and illness.

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:

• contractors are aware of the potential hazards associated with the rehabilitation, maintenance and demolition of lead painted structures;
  
  
• contractors are qualified to perform work safely; and
  
  
• contractors conduct work in such a manner that workers, their families, the environment and the community are protected from exposures to lead and that their employees are guaranteed their right to a safe and healthful workplace. 

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

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:

• identifies potential hazards;
  
  
• develops a written project safety and health plan for projects and for notifying authorities;
  
  
• designates personnel for development of the plan and coordination of the plan; and
  
  
• communicates the plan to the contractor and ensures they have adequate resources with which to execute it⁴.

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:

• more active involvement in contractor selection and oversight
• greater involvement in planning and communicating hazards associated with their structures.

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:

• Health and safety programs of previous lead projects
• Prior serious or willful OSHA citations
• Workers' compensation ratings
• Experience modification rating (EMR)
• OSHA 200 and 101 logs
• Environmental citations issued by the EPA, federal and state pollution control agencies, and other regulatory agencies

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.

D. Submittals

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.

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.

MODEL SPECIFICATIONS

I.  General Information

A. Introduction

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:

C. Definitions

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:

• five years experience working at the construction trades
• a minimum of 32 hours of lead abatement training for "superstructures"
• 30 hours of general safety and health training equivalent to the OSHA 500 Course
• 24 hours of Construction Safety and Health Specialist Training (to include air monitoring for lead)

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.

D. Submittals

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

1. General Introduction
2. Lead Health and Safety Organization and Responsibilities
   
3. Exposure Monitoring for Lead and Other Known Hazards
   
4. Engineering and Administrative Controls
   
5. Respiratory Protection
   
6. Protective Work Clothing and Equipment
   
7. Hygiene Facilities and Practices
   
8. Housekeeping
   
9. Medical Surveillance Program, including Medical Removal Protections and Appropriate Worker Notification Procedures
   
10. Decontamination Procedures
    
11. Employee Information and Training Procedures
    
12. Record Keeping

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.

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:

1. Fall hazards.  Falls account for 25% of occupational fatalities in construction¹⁰.  A Fall prevention plan must identify potential fall hazards and how they are to be addressed prior to the start of work. Plans must address fall arrest systems.  Where a fall arrest system is required, body harnesses should be used in lieu of body belts.  Identification of fall hazards shall be incorporated into periodic walkaround inspections as an integral part of the written plan.
   
   
2. Heat stress.  Temperatures in containment structures during warm weather can reach levels that present a serious hazard to workers.  Contractors shall implement a heat stress prevention program which follows the guidelines published by the American Conference of Governmental Industrial Hygienists¹¹.
   
   
3. Noise.  Noise induced hearing loss is suffered by construction workers in epidemic proportions.  Personal exposures in excess of the OSHA Permissible Exposure Limit of 90 dBA have been measured during use of abrasive blasting equipment.  Contractors shall incorporate a hearing conservation program into their general safety and health program.  Contractors shall consider equipment noise generation rates as an important factor in equipment selection and procurement.
   
   
4. Ergonomic hazards.  There is a considerable amount of information showing that construction workers suffer from a high rate of musculoskeletal disorders and that these injuries could be prevented by better design and organization of work.  Any plan for prevention of lead exposure must deal with the ergonomics of the job and the consequences of the controls which are specified.  In addition, ergonomic hazards associated with all aspects of the job should be identified and controlled.  The contractor’s safety and health program should include requirements aimed at reducing: i) manual handling of heavy loads (e.g. through use of hoists and dollies);  ii) awkward postures in combination of forceful exertions (e.g. through proper tool selection) and iii) vibration (e.g. use of vibration dampened tools).  Work practices (e.g. encouraging individuals to seek help before lifting heavy equipment and materials) and administrative controls (e.g. rest breaks and job rotation) should also be included in the safety and health program.
   
   
5. Heavy metals.  Airborne concentrations of cadmium, chromium and other heavy metals other than lead have been measured at levels in excess of current occupational exposure limits during abrasive blasting of bridges¹².  The principle source of metal exposure is likely to be in the paint being removed.  However, the use of slag abrasive may also be a source of metal hazards.  The contractors exposure assessment program should include characterization of the full range of metals which pose a potential hazard.  In addition, selection of abrasive media during the project planning phase should take into account the possibility of heavy metal exposure.  Manufacturer’s specifications on heavy metal concentrations should be verified with spot bulk sample checks if slag abrasives are used.

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:

1. Develop a written LHASP
2. Review adequacy of the LHASP on a regular basis and update accordingly with respect to changing site conditions.
3. Develop and oversee an exposure assessment strategy that includes personal air monitoring, wipe sampling and evaluation of the effectiveness of engineering and work practice controls.
4. Prepare monthly reports to be presented to the JSHC which summarize industrial hygiene activities including air and wipe sampling and biological monitoring
5. Develop and oversee the implementation of a respiratory protection program that complies with 29 CFR 1926.103
6. Review blood lead monitoring results as necessary with the physician in order to assess the efficacy of controls.  (Placement of workers with elevated BLLs should be based on collaboration of the JSHC, IH,  CSHS,  physician and contractor).
7. Develop detailed check lists to be used by the  CSHS in verifying compliance with the LHASP, periodically monitor the work site, and inform the contractor and JSHC of any deficiency noted as well as suggest corrective actions.
8. Evaluate the effectiveness of controls and other interventions.
9. Conduct monthly follow up training  with employees based on input of JSHC

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:

1. Implementing and monitoring compliance with the LHASP on a daily basis
2. Communicating with the JSHC and IH regarding implementation of the LHASP and areas needing improvement
3. Assisting IH in exposure assessment activities
4. Communicating results of IH monitoring to workers on a regular basis with the support of the IH as needed
5. Ensuring daily compliance with respiratory protection program
6. Utilizing developed check lists under the direction of the IH
7. Working with JSHC and IH in the implementation and evaluation of interventions and control technologies
8. Convening regular tool box talks to address identified problems and provide ongoing training on safety and health program elements
9. Maintaining a log of all personnel entering work areas with potential lead exposures.  The log shall include the name and social security number of the individual, the date, the time at which they enter and leave the area, the task/job being performed and exposure monitoring data, if any has been collected. 

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:

1. initial monitoring;
   
   
2. at least every two months for the first 6 months and every six months thereafter;
   
   
3. at least every two months for those workers whose last BLL was at or above 40 µg/dl until two consecutive blood samples indicate a BLL below 40 µg/dl, and
   
   
4. at least monthly for any worker who is removed from exposure to lead due to an elevated BLL .

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:

1. Baseline: upon hire or start of job- all workers (unless documentation of a blood lead test conducted by an OSHA approved laboratory within the past 2 weeks is presented).  A worker with a BLL greater than 40 ug/dl on an initial exam shall see an occupational physician to determine whether or not that worker should be assigned to leaded areas.
   
   
2. Second test: 2 to 4¹³ weeks later - all workers.
   
   
3. Third test: 2 weeks later - all workers whose second blood lead increased more than 10 ug/dl from baseline level.
   
   
4. Subsequent testing: monthly for 6 months if BLLs  are stable and job site operations or work procedures do not change.
   
   
5. If at the end of 6 months blood lead levels have remained below 25 µg/dl for three consecutive months and the job site operation and work practices do not change, biological monitoring may occur every 2 months.  If at any time a blood lead level of 25 µg/dl or greater is detected, biological monitoring will be conducted monthly until 3 consecutive tests are below 25 µg/dl.
   
   
6. Exit testing shall be required and consist of a blood lead test when a worker is terminated from the job.  All blood tests shall be provided at no expense to the worker at a reasonable time and location.  Employees shall receive full wages for all time involved in medical testing. Workers shall be notified of BLL results within 5 working days after being tested. 

In addition, the following provisions shall be implemented:

1. an increase of 10 µg/dl from one test to another shall trigger a work site evaluation by the CSHS and the IH to identify problem areas and implement appropriate control measures that effectively reduce BLLs to less than 25 µg/dl.
   
   
2. if at any time during testing, a blood lead level of 40 µg/dl or greater is detected, the employee shall be examined by the occupational health physician.  Such an employee shall have blood lead tests at a frequency of every two weeks until two consecutive tests indicate BLLs equal to or below 30 µg/dl.

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:

1. a detailed work and medical history, with particular attention to past lead exposure;
   
   
2. a thorough physical exam with particular attention to teeth, gums, hematologic, gastrointestinal, renal, cardiovascular, and neurological systems.  Pulmonary status should be evaluated if respiratory protection is to be used;
   
   
3. a blood pressure measurement;
   
   
4. a blood sample and analysis to determine: blood lead level, hemoglobin and hematocrit determinations, red cell indices, and examination of peripheral smear morphology; zinc protoporphyrin, blood urea nitrogen and serum creatinine;
   
   
5. a routine urinalysis with microscopic examinations;
   
   
6. any laboratory or other test relevant to lead exposure which the examining physician deems necessary by sound medical practice.

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).

II.  Products

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.

III.  Execution

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.

D.  Training

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:

• The content of the interim lead standard and its appendices;
• The sources and degree of lead exposure associated with specific tasks;
• The purpose, proper selection, fitting, use and limitations of respirators;
• The purpose and description of medical surveillance and medical removal protection including the health effects of lead;
• Engineering controls and work practices associated with the employee's job assignment including training on work practices that reduce lead exposure;
• The contents of the LHASP
• Instructions that chelating agents should never be used except under the direction of a licensed physician and never as a routine method of removing lead from the body;
• The right of employees and their designated representatives to exposure and medical records in a timely manner as specified in 29 CFR 1910.20.

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:

1. as a method of characterizing exposures for the purposes of devising effective control strategies for the prevention of elevated blood lead levels.
   
   
2. to characterize work tasks and areas to which workers with elevated blood lead levels can be assigned to reduce their exposure to airborne lead particulate.
   
   
3. to assess exposures during work tasks where increases in blood lead test results indicate a problem.
   
   
4. to assess any change in operations or procedures that may affect exposure levels.
   
   
5. to determine the effectiveness of engineering controls.
   
   
6. to assist in the selection of respiratory protection.

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:

1. Protection must be based on exposures between 50 µg/m³ and 500 µg/m³:
   
   
   1. where lead coatings or paint are present and the following tasks are occurring: manual demolition of structures, manual scraping, manual sanding, heat gun applications, power tool cleaning with dust collection systems
      
      
   2. when spray painting with lead paint.
      
      
2. Protection must be based on exposures greater than 500 µg/m³ when:
   
   
   1. using lead containing mortar
      
      
   2. lead burning
      
      
   3. where lead containing coatings or paint are present and the following tasks are being performed: rivet busting, power tool cleaning without dust collection systems, cleanup activities where dry expendable abrasive are used, abrasive blasting enclosure movement and removal.
      
      
3. Protection must be based on exposures greater than 2500 µg/m³ where lead containing coatings or paint are present and the following tasks are being performed:
   
   
   1. abrasive blasting
      
      
   2. welding
      
      
   3. cutting and torch burning

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.

V.  References

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:

Appendices

Appendix A: 1993 Working Group Participants

Appendix B: 1995 Working Group Participants

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.

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