Utility and Transportation Contractor February 2020

Page 82

NEWS

IV. Handwashing Facilities must be provided and available for use prior to eating, drinking, smoking, and toilet use. 1926.62(i)(5) V. Signage 1926.62(g)(2)(vii)(A) requires that “The employer shall ensure that the containers of contaminated protective clothing and equipment required by paragraph (g)(2)(v) of this section are labeled as follows:” DANGER: CLOTHING AND EQUIPMENT CONTAMINATED WITH LEAD. MAY DAMAGE FERTILITY OR THE UNBORN CHILD. CAUSES DAMAGE TO THE CENTRAL NERVOUS SYSTEM. DO NOT EAT, DRINK OR SMOKE WHEN HANDLING. DO NOT REMOVE DUST BY BLOWING OR SHAKING. DISPOSE OF LEAD CONTAMINATED WASH WATER IN ACCORDANCE WITH APPLICABLE LOCAL, STATE, OR FEDERAL REGULATIONS. If the Exposure Assessment results in sufficient evaluation that the tasks will not produce an airborne hazard above the Action Level of eight-hour average of 30 micrograms of lead in a cubic meter of breathing zone air, this may be used as a Negative Exposure Assessment for 12 months. If the Exposure Assessment results in employees being exposed for 30 days at the Action Level, medical surveillance is required. Exposure at or above the Permissible Exposure Level of 50 micrograms of lead in a cubic meter of breathing zone air triggers the full compliance under the regulation including engineering and work practice controls, respiratory protection, protective clothing and equipment decontamination, hygiene facilities and practices, specific lead work area designation and signs, and possibly temporary medical removal protection due to elevated blood lead. Since the U.S. EPA and the Centers for Disease Control and Prevention have established that there is no safe level of lead, precautions

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must be integrated into all aspects of the project operations to prevent lead contamination in the targeted affected household as well as preventing the occupational “take-home” lead exposure of the employee. Effective January 6 of 2020, the EPA finalized a rule to reduce the level of dust lead hazard assessment standards. These standards apply to most pre-1978 housing and child-occupied facilities (COF) such as day care centers and kindergarten facilities and was designed to identify dust-lead hazards from lead-based paints, however dust-lead hazards may be created during LSL replacement. Under the previously enforced rule, created in 2001, dust lead was considered a hazard when the level of lead in the dust reached or exceeded 40 micrograms per square foot on floors, 250 micrograms per square foot on interior window sills, and 400 micrograms per square foot in the window well. Hazardous dust lead may be generated from soils containing 400 parts per million in the soil of areas where children play and 1,200 parts per million for bare soil elsewhere on the property (some states or local jurisdictions may have lower standards). The 2020 EPA new lower standards identify a dust lead hazard for floors at or above 10 micrograms per square foot and at or above 100 micrograms per square foot for interior windowsills/wells and 40 micrograms per square foot on exterior porch areas. All contractors and utility workers should be mindful to wear clean protective foot coverings when entering the targeted affected households and to decontaminate thoroughly prior to entering their own homes. For more information on compliance with the OSHA and EPA Lead Standards, join us at the March 6th UTCA conference.


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