4.17 – Lead

LEAD- CONTAINING PAINTS AND COATINGS

PURPOSE

The purpose of this practice is to bring awareness and to establish a procedure for the removal and disposal of lead-based paint.

This Policy is for Supervisors, and Workers who may come into contact with lead-containing paints and coatings on one of our projects.

It provides information about lead and assists us in developing suitable safe work procedures. If you are involved with lead-containing paint removal or other processes that could disturb lead-containing paints and coatings, you need to know how to work safely.

Workers who are most at risk of high lead exposure include those in workplaces where activities such as the following are carried out:

Demolition or renovation of bridges, dams, structures, and buildings where lead-containing paints or coatings were used
Lead abatement (removal of lead-containing paints and coatings)
Dismantling or movement of abrasive blasting (and other) enclosures
Welding, brazing, and soldering of products where lead is on or in the metal (such as on steel structures)
Cleaning of power tools without (and even with) dust collection systems
Cleaning of lead dust collection systems and filters
Application of lead-containing paints or coatings

What does ALARA mean?

ALARA means As Low As Reasonably Achievable. The ALARA principle applies to lead, which means that worker exposures to lead in paints and coatings must be kept as low as reasonably achievable. Although the WorkSafeBC Regulation specifies exposure limits for lead, as an employer Griffin Properties must further reduce or eliminate worker exposure if it can reasonably be done. Lead is an ALARA substance and is listed as a 2A and 2B carcinogen (probably and possibly, respectively, carcinogenic to humans) by the International Agency for Research on Cancer (IARC). Lead also has an “R” designation in the WorkSafeBC “Table of Exposure Limits for Chemical and Biological Substances,” meaning that the substance has an adverse reproductive effect. Where possible, if damaged or during renovations, lead-containing materials should be replaced with products that do not contain lead. Improvements in technology as well as new work practices and procedures will help decrease worker exposures and move closer to the ultimate goal of zero exposure.

Industry terms and definitions

CONTAINMENT –An isolation system designed to effectively contain lead dust and debris within a designated work area where lead-containing materials are handled, removed, encapsulated, or enclosed.

ENCLOSURE – A physical barrier made of materials such as gyproc (gypsum wallboard), plywood, metal, or polyethylene (poly) sheeting used to separate lead-containing materials from the habitable environment.

HAZARD IDENTIFICATION/ASSESSMENT – A comprehensive document that determines the conditions or changing set of circumstances in a workplace that present a potential for injury, illness, or property damage, including any activities that could produce harmful consequences.

HEPA FILTER – Defined in the Regulation as a high-efficiency particulate air filter that is at least 99.97% efficient in collecting an aerosol particle 0.3 micrometre in size. When used for respiratory protection, HEPA filters are now referred to as NIOSH 100 series filters, or “100” filters for short.

LEAD-CONTAINING SURFACE COATING MATERIALS – Defined by the federal Ministry of Health, under the Hazardous Products Act, as a paint or other similar material that dries to a solid film that contains over 90 mg/kg (0.009%) dry weight of lead.

NEGATIVE AIR UNIT – A cabinet, usually portable, that contains a fan and one or more HEPA filters. Negative air units are used to exhaust air from an enclosure, reducing the risk of contaminated air escaping into the workplace through a leak in the enclosure. Negative air unit efficiency should be tested at least annually using a suitable indicator chemical, such as dioctyl phthalate (DOP) or polyalphaolefin (PAO) aerosols.

NIOSH 100 SERIES FILTER – A high-efficiency particulate air (HEPA) filter used for respiratory protection. These HEPA filters, called “100” filters for short, are at least 99.97% efficient in collecting an aerosol particle 0.3 micrometre in size, and carry an N, R, or P designation that specifies where and for how long the filter can be used

NIOSH 100 series filter designations

Filter Designation	For use in…	Time-use limitations
N= No oil	Oil-free atmospheres only (atmospheres containing no oil mist)	May be reused only after considering: Cleanliness, filter damage, and increased breathing resistance
R= Oil- resistant	Oily atmospheres	A single shift only (or eight hours of continuous or intermittent use)
P= Oil- proof	Oily atmospheres	Check the manufacturer’s specified time-use limitations for each P-type filter

PRACTICABLE – Defined in the Regulation as “that which is reasonably capable of being done.”

QUALIFIED PERSON – An occupational health and safety professional with experience in the practice of occupational hygiene as it relates to lead management.

RESPIRATOR – A device worn to prevent the inhalation of hazardous airborne substances. There are two basic types of respirators: air-purifying and air-supplying. So-called “single-use” or “disposable” respirators are not acceptable for working with lead-containing materials.

RISK ASSESSMENT – A comprehensive document, developed to select appropriate workplace controls, that evaluates the probability and degree of possible illness, injury, or death in a hazardous situation.

WORKERS – Includes supervisors, managers, and workers.

Lead enters your body when you breathe it in (inhalation) or when you swallow it (ingestion). Lead can enter your body if you:

Breathe in lead dust or fume
Drink or eat food contaminated with lead
Eat or drink from contaminated cups, plates, or bowls
Bite your nails or smoke when your fingers are contaminated with lead
Smoke or chew gum where there is lead dust or fume

Lead gets into your body when you breathe in lead dust or fume or when you swallow lead.

Put objects contaminated with lead in your mouth (such as pens and pencils from the work area)
Once lead is in your bloodstream, it is carried throughout the body and stored in various body tissues, mostly in the bones. The body can get rid of lead naturally over time, but lead may build up or accumulate in your body if it enters your body faster than you can get rid of it.
Tiredness and weakness
Headaches
Lack of appetite
Metallic taste

Later signs and symptoms may include:

Abdominal aches or pains
Constipation
Muscle and joint aches and pains
Memory problems

Signs and symptoms of lead exposure may take a long time to develop.

Workers with similar exposures to lead may have different symptoms, which may also vary in severity. All workers need to prevent or minimize lead exposure.

Possible effects

Lead can affect the brain and nervous system, the reproductive system, the digestive system, the kidneys, and the body’s ability to make blood. Lead is also a suspected human carcinogen and has been shown to cause cancer in laboratory animals. Possible effects of lead absorption are:

Anemia
Nerve damage causing muscle weakness
Decrease in brain function
Kidney damage
High blood pressure
Reproductive effects in both men and women

Measuring lead in the body

The amount of lead present in a person’s body is measured using a blood test. The typical blood lead level for an adult is less than 0.1 micromoles per litre (μmol/L), or 2 micrograms per decilitre (μg/dL). Overt symptoms of lead poisoning in adults generally begin at blood levels between 3 and 6 μmol/L (60 to 120 μg/dL). If a worker’s blood lead level exceeds 1 μmol/L

(20 μg/dL), exposure should be minimized and protective measures improved.

Everyone in the workplace has health and safety responsibilities- including owners, employers, prime contractors, supervisors, and workers.

Owners

Owners have the following responsibilities:

Provide and maintain the land and premises that are being used as a workplace to ensure the health and safety of anyone at or near the workplace.
Provide the employer or prime contractor at the workplace with information known to the owner that is necessary to identify the hazards, including lead.
Comply with the relevant sections of the Regulation and the Workers Compensation Act (the Act), as well as any applicable orders.

Employers

Employers have the following responsibilities:

Ensure the health and safety of all workers at the worksite.
Identify workplace hazards and assess the risks of injury associated with those hazards.
Conduct a risk assessment for lead exposure, develop an exposure control plan, write safe work procedures, and implement controls.
Ensure that workers and supervisors are adequately instructed and trained.
Keep written records of training (detailing who, what, and when).
Establish and maintain an occupational health and safety program, including a written health and safety policy and a procedure for incident investigations.
Support supervisors, safety coordinators, and workers in their health and safety activities.
Take action immediately when a worker or supervisor tells you about a potentially hazardous situation.
Initiate immediate investigations into incidents.
Report exposure incidents to WorkSafeBC.
Provide adequate first aid facilities and services.
Provide and maintain personal protective equipment, clothing, and devices as required.
Ensure that your workers follow the requirements of the Regulation and the Act. Ensure that workers have access to these documents.

Prime contractors

Prime contractors have the following responsibilities:

Ensure the coordination of health and safety activities for employers, workers, and others at the workplace.
Do everything that is reasonably practicable to establish and maintain a system or process that will ensure compliance with the relevant sections of the Regulation and the Act.

Each employer at a multiple-employer workplace must give the prime contractor the name of the person the employer has designated to supervise his or her workers.

Supervisors

Supervisors have the following responsibilities:

Instruct workers in safe work procedures.
Ensure that workers are familiar with and follow the exposure control plan.
Train workers for all tasks assigned to them, and regularly check that they are doing their work safely.
Ensure that only authorized, adequately trained workers operate tools and equipment or use hazardous chemicals.
Ensure that workers follow safe work procedures for handling, storing, and maintaining equipment and materials.
Enforce health and safety requirements.
Correct unsafe acts and conditions immediately.
Identify workers with problems that could affect safety at the worksite, and follow up with interviews and referrals where necessary.
Create health and safety rules, and inspect the workplace regularly for hazards.

Workers

Workers have the following responsibilities:

Know and follow health and safety requirements that apply to your job.
If you don’t know how to do something safely, ask your supervisor for training before you begin work.
Participate in all required health and safety education and training.
Work safely, and encourage your co-workers to do the same.
Use all required personal protective equipment and clothing.
Correct any unsafe conditions or immediately report them to your supervisor.
Immediately report any injury to a first aid attendant or supervisor.
Inform your supervisor of any physical or mental impairments that may affect your ability to work safely.
Make suggestions to improve health and safety.

Consultants

Should be occupational health and safety professionals with experience in the practice of occupational hygiene as it relates to lead management. Must follow accepted occupational hygiene practices, including those related to:

a) The collection and identification of samples
b) Performance of risk assessments
c) Development of safe work procedures
d) Implementation of exposure control methods

Should provide documentation in a reasonable timeframe and clearly explain any results, conclusions, and recommendations to their clients.

Personal Protective Equipment

All workers entering an area containing a lead hazard should wear the appropriate personal protective equipment (PPE). PPE should be the last line of defence in a health and safety program. It may be used as a control if other controls are not practicable, or in addition to other controls. Before considering PPE, first try to eliminate or minimize the risks using other means. Follow these guidelines when using PPE to prevent exposure to lead:

Provide workers with appropriate respirators to remove contaminants from the air, and ensure that they use them according to their training.
Ensure that workers use protective clothing to prevent skin contact with lead contaminant

Protective work clothing

The use of disposable protective clothing is recommended. Workers should wear protective clothing that:

Is made of a material that resists penetration by lead dust
Covers the body and fits snugly at the neck, wrists, and ankles
Covers the head
Covers the feet
Can be immediately repaired or replaced if torn

When working around lead, workers often have to wear protective clothing in confined spaces where there is not a lot of air movement.

As a result, these workers may be at a higher risk of experiencing heat stress and resulting in heat related disorders

Respiratory protection

Employers must establish a respiratory protection standard for a specific job by selecting an appropriate respirator based on the anticipated work activity. Table 4 outlines appropriate respiratory protection choices based on risk level and work activity. The respiratory protection used should be based on the size of the work area, the amount of lead to be removed, and the duration of the work. More protection would be required if a greater amount of lead is potentially disturbed.

The respirator choices shown in Table 4 are determined by maximum use concentrations as detailed in section 8.34 of the Regulation. As the lead concentration approaches the maximum use concentration for the respirator being used, workers must switch to a respirator with a higher protection factor.

Lead Concentration	Air-purifying respirators	Air-supplying respirators
Up to 0.5 mg/m³	Single-use half-face respirator (e.g., N95/N99)	–
Up to 0.5 mg/m³	Half-facepiece respirator with P100 (HEPA) filters	–
Up to 1.25 mg/m³	Loose-fitting hood/facepiece, powered respirator with P100 (HEPTA) filters	–
Up to 2.5mg/m³	Full-facepiece respirator with P100 (HEPA) filters	–
Up to 50 mg/m³	Powered full-facepiece respirator (PAPR) with P100 (HEPA) filters	–
Up to 2.5mg/m³	–	Airline: demand (negative pressure) full-facepiece respirator
Up to 50 mg/m³	–	Airline: continuous-flow full-facepiece or helmet/hood respirator
Up to 50 mg/m³	–	Airline: pressure-demand (positive pressure) full-facepiece respirator
Up to 500 mg/m³	–	Self-contained breathing apparatus (SCBA): pressure-demand (positive pressure) respirator

Disposable N95 respirator

Half-face elastomeric respirator with HEPA cartridges

Full-face elastomeric respirator with HEPA cartridges

JOB PREPARATION

Worker Protection

INSTRUCTION – Before commencing work, instruct workers in respirator use and all aspects of procedures and protective measures. Post procedures on jobsite. All employees who are required to enter the work area are to be instructed in the potential health hazards associated with exposure to lead.
RESPIRATORS – The standard respirators for this practice will be dual cartridge half facemask complete with P100 HEPA cartridges. All personnel will be clean-shaven where the respirator seals to the face.
PROTECTIVE CLOTHING – Disposable, impermeable paper-type coveralls will be worn during the removal and encapsulation. Coveralls to be securely sealed with tape at ankles and wrists. Hard-hat, hearing protection work gloves and safety glasses or goggles and other common PPE are to be worn by any person entering the control area.

Each worker will:

Put on respirator with new filters and disposable impermeable paper-type coveralls complete with head and foot covering.
NOT eat, drink, smoke or chew tobacco or gum while in work area.
NOT remove their respirator in the work area
When leaving the work area, and after disposing of protective clothing, decontaminate their exposed skin by washing with soap and water.

Visitor Protection

Provide protective clothing and approved respirators for AUTHORIZED visitors.
Instruct AUTHORIZED visitors in use of protective clothing and respirators.
Instruct AUTHORIZED visitors in the potential health hazards related to lead and proper procedures of a controlled area.

Decontamination of Worker

A wash basin or bucket containing water, sponge and soap shall be present, just outside of work area for workers to decontaminate with just after removal of protective clothing.
At no time will the worker’s respirator be removed prior to removing the protective clothing, safety gear and decontaminating.

CLEAN-UP OF FLAKED PAINT CHIPS

A field Level Hazard Assessment or safe Work Plan must be completed and signed by each worker prior to starting this task.
Install yellow barrier tape a minimum distance of 15 feet from the work area.
PPE must be worn by all persons entering the control area, including: disposable coveralls, disposable head covers, disposable footwear covers, an approved half-face respirator with P100 filters, hard-hat, hearing protection, work gloves and safety glasses or goggles.
Inspect the area to install a drop-sheet. If the area to be covered by the drop-sheet has visible plaint flakes, HEPA vacuum the paint flakes and other suspected material.
Install a polyethylene drop-sheet to cover the immediate surface under the work area. This drop-sheet should be kept reasonably clean to prevent workers from tracking materials out of the work area.
HEPA vacuum remaining surface areas to remove all visual debris.
Wash all exposed skin upon exiting the contained area and prior to participating in any non-related activities, such as eating, smoking and washroom relief.
Wash or vacuum tools and equipment thoroughly prior to removing from work area.
Collect and dispose of materials (including drip-sheets) that are, or may be, contaminated according to the enclosed WASTE DISPOSAL section.
Upon completion of tool cleaning and waste disposal, remove and properly dispose of all PPE and disposable coverings.
Remove yellow barrier tape from the area and dispose.

BURNING (WELDING/CUTTING) ON LEAD BASED PAINT SURFACES OF LESS THAN 10 LINEAR FEET OR WITH LESS THAN 5% LEAD CONTENT

A field Level Hazard Assessment or Safe Work Plan must be completed and signed by each worker prior to starting this task.
Install yellow barrier tape a minimum distance of 15 feet from the work area.
PPE must be worn by all persons entering the control area, including: disposable coveralls, disposable head covers, disposable footwear covers, an approved half-face respirator with P100 filters, hard-hat, hearing protection, work gloves and safety glasses or goggles.
Inspect the area and HEPA vacuum surface areas to remove all visual debris.
Perform welding or cutting with a HEPA vacuum or vec-loader positioned to capture the fumes release by the welding or cutting operation
Wash all exposed skin upon exiting the contained area and prior to participating in any non-related activities, such as eating, smoking and washroom relief.
Wash or vacuum tools and equipment thoroughly prior to removing from work area.
Collect and dispose of materials (including drip-sheets) that are, or may be, contaminated according to the enclosed WASTE DISPOSAL section.
Upon completion of tool cleaning and waste disposal, remove and properly dispose of all PPE and disposable coverings.
Remove yellow barrier tape from the area and dispose.

BURNING (WELDING/CUTTING) ON LEAD BASED PAINT SURFACES OF MORE THAN 10 LINEAR FEET OR WITH MORE THAN 5% LEAD CONTENT

A field Level Hazard Assessment or Safe Work Plan must be completed and signed by each worker prior to starting this task.
Install yellow barrier tape a minimum distance of 15 feet from the work area.
PPE must be worn by all persons entering the control area, including: disposable coveralls, disposable head covers, disposable footwear covers, an approved full-face respirator or half-face respirator and mono goggles and full- face shield with P100 filters, hard-hat, hearing protection, work gloves and safety glasses or goggles.
Inspect the area and HEPA vacuum surface areas to remove all visual debris.
Install a polyethylene drop-sheet to cover the immediate surface under the work area. This drop-sheet should be kept reasonably clean to prevent workers from tracking material out of the work area.
Perform welding or cutting with a HEPA vacuum or vec-loader positioned to capture the fumes release by the welding or cutting operation
Wash all exposed skin upon exiting the contained area and prior to participating in any non-related activities, such as eating, smoking and washroom relief.
Wash or vacuum tools and equipment thoroughly prior to removing from work area.
Collect and dispose of materials (including drip-sheets) that are, or may be, contaminated according to the enclosed WASTE DISPOSAL section.
Upon completion of tool cleaning and waste disposal, remove and properly dispose of all PPE and disposable coverings.
Remove yellow barrier tape from the area and dispose.

BUFFING/GRINDING ON LEAD BASED PAINT SURFACES OF LESS THAN 10 LINEAR FEET OR WITH LESS THAN 5% LEAD CONTENT

If more than five spot-location jobs will be done on a site, the Safety specialist must be engaged to assess the control methods.
A field Level Hazard Assessment or Safe Work Plan must be completed and signed by each worker prior to starting this task.
Install yellow barrier tape a minimum distance of 15 feet from the work area.
PPE must be worn by all persons entering the control area, including: disposable coveralls, disposable head covers, disposable footwear covers, an approved full-face respirator or half-face respirator and mono goggles and full- face shield with P100 filters, hard-hat, hearing protection, work gloves and safety glasses or goggles.
Inspect the area and HEPA vacuum surface areas to remove all visual debris.
Install a polyethylene drop-sheet to cover the immediate surface under the work area. This drop-sheet should be kept reasonably clean to prevent workers from tracking material out of the work area.
Perform grinding or buffing with a HEPA vacuum or vec-loader positioned to capture the fumes release by the welding or cutting operation
Wash all exposed skin upon exiting the contained area and prior to participating in any non-related activities, such as eating, smoking and washroom relief.
Wash or vacuum tools and equipment thoroughly prior to removing from work area.
Collect and dispose of materials (including drip-sheets) that are, or may be, contaminated according to the enclosed WASTE DISPOSAL section.
Upon completion of tool cleaning and waste disposal, remove and properly dispose of all PPE and disposable coverings.

BUFFING/GRINDING ON LEAD BASED PAINT SURFACES OF MORE THAN 10 LINEAR FEET OR WITH LESS THAN 5% LEAD CONTENT- Open Work Method

The Safety specialist must be engaged to assess the control methods.
A field Level Hazard Assessment or Safe Work Plan must be completed and signed by each worker prior to starting this task.
Install yellow barrier tape a minimum distance of 15 feet from the work area.
PPE must be worn by all persons entering the control area, including: disposable coveralls, disposable head covers, disposable footwear covers, an approved full-face respirator or half-face respirator and mono goggles and full- face shield with P100 filters, hard-hat, hearing protection, work gloves and safety glasses or goggles.
Inspect the area and HEPA vacuum surface areas to remove all visual debris.
Install a polyethylene drop-sheet to cover the immediate surface under the work area. This drop-sheet should be kept reasonably clean to prevent workers from tracking material out of the work area.
Perform grinding or buffing with a HEPA vacuum or vec-loader positioned to capture the fumes release by the welding or cutting operation
Wash all exposed skin upon exiting the contained area and prior to participating in any non-related activities, such as eating, smoking and washroom relief.
Wash or vacuum tools and equipment thoroughly prior to removing from work area.
Collect and dispose of materials (including drip-sheets) that are, or may be, contaminated according to the enclosed WASTE DISPOSAL section.
Upon completion of tool cleaning and waste disposal, remove and properly dispose of all PPE and disposable coverings.
Remove yellow barrier tape from the area and dispose.

BUFFING/GRINDING ON LEAD BASED PAINT SURFACES OF MORE THAN 10 LINEAR FEET OR WITH LESS THAN 5% LEAD CONTENT- Enclosed Work Method

The Safety specialist must be engaged to assess the control methods.
A field Level Hazard Assessment or Safe Work Plan must be completed and signed by each worker prior to starting this task.
Install yellow barrier tape a minimum distance of 15 feet from the work area.
PPE must be worn by all persons entering the control area, including: disposable coveralls, disposable head covers, disposable footwear covers, an approved full-face respirator or half-face respirator and mono goggles and full- face shield with P100 filters, hard-hat, hearing protection, work gloves and safety glasses or goggles.
Inspect the area and HEPA vacuum surface areas to remove all visual debris.
Install a polyethylene drop-sheet to cover the immediate surface under the work area. This drop-sheet should be kept reasonably clean to prevent workers from tracking material out of the work area.
Encapsulate the area with CP240 (or equivalent) to contain residual material.
Tape off the enclosure.
The enclosure must have a negative-air unit attached to prevent escape of lead dust.
There must be a compartment created within the enclosure by the entrance or exit to provide for PPE removal and disposal. When possible, this compartment must have air-lock doors and will be referred to as the “Clean Room”.
Perform grinding or buffing with a HEPA vacuum or vec-loader positioned to capture the fumes release by the welding or cutting operation
Wet wipe exposed skin and respirator separately and leave the Clean Room prior to removing the respirator.
Wash all exposed skin upon exiting the contained area and prior to participating in any non-related activities, such as eating, smoking and washroom relief.
Wash or vacuum tools and equipment thoroughly prior to removing from work area.
Collect and dispose of materials (including drip-sheets) that are, or may be, contaminated according to the enclosed WASTE DISPOSAL section.
Upon completion of tool cleaning and waste disposal, remove and properly dispose of all PPE and disposable coverings.
Dismantle the enclosure and dispose and construction waste.
Remove yellow barrier tape from the area and dispose.

WASTE DISPOSAL

Material known or suspected to be contaminated with lead such as disposable clothing chemical strip waste residue, vacuum cleaner residue and bagged residue must be considered a Class One Hazardous Waste and disposed of in accordance with site or plant procedure.

Where Class One Hazardous Waste site procedure does not exist:

A log-book is to be kept on all Class One Waste Disposal. The log-book must contain: Name of waste generator dates of waste into container, name of waste, quantity of waste (Kg/L), container type, number of containers/ pieces, waste storage location, name of disposal carrier and date out.
Wastes are to be placed in adequate containers segregated and appropriately labeled. Waste type labels must be on 81/2” by 11” white paper with black lettering and laminated in clear plastic. The waste type labels must be securely fastened to the container in a way that the handing of the container will not disturb the label.
GHS and/or TDG product and hazard Worksite labels must also be attached in a way that the handling of the container will not disturb the label.
Waste containers must be located at collection areas determined by the site in accordance with the site procedure.
Containers must be in good condition and be non-leaking 18 gauge or better metal 45-gallon drums with removable and sealable lids, and red in color when possible. If corrosion may be a concern, steps must be taken to prevent the waste material from contacting the metal surface of the drum (i.e. 6mm or higher gauge polyethylene bags).
Class One wastes shall not be mixed together in the same collection drum but are to be segregated into separate containers per waste product.
A spill tray or placement within a dike must be provided at all collection areas.
“HAZARDOUS WASTE STORAGE AREA” signs must be posted at the storage area.
Access to the storage area access must be restricted to personnel instructed in safe handling procedures and to those required to be in the area for container deposit.
A minimum aisle space of 1.2m will be provided in the storage area.
Containers will be stored within a facility with appropriate sidewalls and roof to protect containers from weather. Containers may be stored outside in a properly covered area only if the containers are provided with secondary containment such as plastic inner liner or form of overpack.
Class One wastes must be sent to consolidation within 24 hours of filling. Shipper/Disposal Company must be approved by or in accordance with site procedure authorities.