is your company in compliance with all lead federal & State codes

is your company in compliance with all lead federal & state codes during lead service line replacement contracts? By: margaret chandler neville, rehs/ih, principal consultant haztek inc.

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 oper ation. 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)] Re gardless 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 expo sure 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 pro tective measures prior to and during the exposure assessment of tasks presumed to generate lead exposures greater than the Per missible 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 pri or 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 op erating 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.” 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 pro cedures 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 require ments 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 tar geted 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 expo sure. Such hazards may come from torch cutting or mechanical cutting or abrasion of lead containing materials. Typical trench

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 la beled as follows:” DANGER: CLOTHING AND EQUIPMENT CONTAMINATED WITH LEAD. MAY DAMAGE FERTILITY OR THE UNBORN CHILD. CAUSES DAMAGE TO THE CENTRAL NERVOUS SYS TEM. DO NOT EAT, DRINK OR SMOKE WHEN HANDLING. DO NOT REMOVE DUST BY BLOWING OR SHAKING. DIS POSE 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 Assess ment 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 micro grams 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, spe cific 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 Preven tion have established that there is no safe level of lead, precautions 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 ap ply 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 gener ated from soils containing 400 parts per million in the soil of areas where children play and 1,200 parts per million for bare soil else where 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 affect ed 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.