By: margaret chandler neville, rehs/ih, principal consultant haztek inc.
U
.S. EPA’s Lead and Copper Rule was first introduced in 1991 and at that time it was estimated that 10.2 million Lead Service Lines (LSLs) were actively utilized by water systems around the country. With the public consciousness raised to the concerns for identifying sources of lead in drinking water by the declaration of a public health emergency in 2015 in Flint, Michigan, water companies and communities have begun to replace LSLs in an effort to reduce the hazard of lead leaching into the drinking water. In 2018, American Water Works Association (AWWA) estimated that 6.1 million LSLs were still in use.
Paul Olson, senior manager of standards programs for AWWA, explained the development and release of the first edition of AWWA’s 2017 standards document, C810-17 Replacement and Flushing of Lead Service Lines, as follows: “AWWA’s new standard is intended to describe essential procedures for the replacement of lead service lines, including … [the] appropriate tools and techniques; flushing of service lines after replacement; instructions to inform customers affected by the replacement, including additional risk reduction measures; and verification of lead level management prior to return of service.” [1] This standard created a user guide for addressing procedures for the removal of the LSLs and informing utilities about their requirements under the Safe Drinking Water Act to communicate lead risks when there is an exceedance of the lead action level as defined in the Lead and Copper Rule and annually as part of their consumer confidence reports. For utilities participating in mandatory LSL replacement, specific communication outreach requirements must be met for the targeted affected households, and guidelines suggest proactive community education not only when lead service lines are repaired or replaced but also when routine maintenance work on water mains may disturb lead service lines. Specific worker protection lead education for employees of the utility or third party contracted workers is not addressed in this standard because both EPA and OSHA have established federal codes for work which may expose employees to Lead Containing Materials (LCM). OSHA’s Lead in Construction Standard; 29 CFR 1926.62, lists the following minimum requirements when any amount of lead may be present and possibly create an airborne lead dust/fume exposure. Such hazards may come from torch cutting or mechanical cutting or abrasion of lead containing materials. Typical trench-
NEWS
is your company in compliance with all lead federal & state codes during lead service line replacement contracts? less LSL replacement methods such as directional drilling or pneumatic or hydraulic ramming tools (boring tools) to pull in the new service line on a new route or cutting and leaving the existing lead service in place and replacing it using a new service line may also produce some level of dust lead hazard on both ends of the operation. Further, open LSL trenching and cutting removal methods also create a possibility for lead exposure through handling and cutting activities. I. Exposure Assessment and Interim Protection [1926.62(d)] Regardless of the amount of lead, each employer who has a workplace or operation covered by this standard shall initially determine if any employee may be exposed to lead at or above the Action Level (AL is the average of 30 micrograms of lead in a cubic meter of air, averaged over 8 hours) The employer must conduct initial exposure assessments of all workplaces and operations where lead or lead-containing materials are being used, disturbed, or removed. Average lead content of the standard LSLs is 90 – 99.99% Lead, 0 – 9% Antimony, and 0 – 2% Tin. The Interim Protection, in accordance with the requirements of 1926.62(d)(2)(v), would include pre-emptive Personal Protective Equipment (PPE) until negative exposure assessments have been established. Employer must implement mandatory employee protective measures prior to and during the exposure assessment of tasks presumed to generate lead exposures greater than the Permissible Exposure Limit (PEL is the average of 50 micrograms per cubic meter of air over 8-hours) II. Lead Hazard Communication Training 1926.62(l)(1)(i) and/or 1926.21 Lead Task Safety Training and Education is required prior to any employee working with any amount of Lead Containing Materials, regardless of whether the LCM is organic or inorganic in nature. III. Housekeeping and Hygiene -1926.62(h) Written standard operating procedures must be established for the tasks of decontamination of clothing, tools, etc. Section 1926.62(h)(1) states that "All surfaces shall be maintained as free as practicable of accumulations of lead." Section 1926.62(i)(2)(i) of this standard requires that "The employer shall provide clean change areas for employees whose airborne exposure to lead is above the permissible exposure level." Section 1926.62(i)(4)(ii) requires that "The employer shall assure that lunchroom facilities or eating areas are as free as practicable from lead contamination and are readily accessible to employees” and 1926.62(i)(4)(iv) requires that “The employer shall assure that employees do not enter lunchroom facilities or eating areas with protective work clothing or equipment unless surface lead dust has been removed by vacuuming, downdraft booth, or other cleaning method that limits dispersion of lead dust.”
Utility & Transportation Contractor | february| 2020 79
