LEAD COMPLIANCE Program

Lawrence Berkeley National Laboratory

Contents

[Page]{.underline}

I. Purpose 2

II\. Policy 2

III\. Applicable Regulations 2

IV\. Definitions 2

V. Hazards of Lead 3

VI\. Examples of Possible Lead Exposure Sources 4

VII\. Responsibilities 4

VIII\. Exposure Monitoring 6

IX\. Controlled Operations 7

X. Housekeeping 11

XI\. Lead Hammers 11

XII\. Medical Surveillance 11

XIII\. Personal Protective Equipment (PPE) 11

XIV\. Purchasing Lead-Containing Material 11

XV\. Storage and Use of Lead Bricks 12

XVI\. Training 12

XVII\. Waste Disposal 12

LEAD COMPLIANCE Program

I. Purpose

The purpose of this document is to outline the management of lead
containing materials at Lawrence Berkeley Laboratory. The information
presented in this document represents minimum safety requirements.

II\. Policy

To ensure that employee exposures to lead are minimized and that the
Laboratory is in compliance with Federal OSHA regulations, engineering,
work practice, and/or administrative controls shall be instituted to
reduce employee exposure to below the *OSHA* *Action Level*.

III\. Applicable Regulations

In addition to this document, the following regulations contain
applicable information.

> • 29 CFR 1910.1025 General Industry Lead Standard

Occupational Safety and Health Standards

• 29 CFR 1910.1450 Laboratory Standard

Occupational Safety and Health Standards

• 29 CFR 1926.62 Lead Construction Standard

Occupational Safety and Health Standards

• 29 CFR 1910.134 Respiratory Protection

Occupational Safety and Health Standards

IV\. Definitions

**Action Level**- An OSHA occupational exposure limit (without regard to
the use of respirators) for airborne contaminants. For lead it is 30
micrograms per cubic meter of air (30 µg/M3) for an 8-hour Time-Weighted
Average (TWA). Employees whose exposure is above the Action Level for
more than 30 days per year are required to be in a medical surveillance
program.

**Affected Employee-** Any employee whose exposure is at or above the
Action Level.

**ALARA**- As Low As Reasonably Achievable. LBL policy is to keep
employee chemical exposure as low as feasible.

**HEPA**- A High Efficiency Particulate Air Filter capable of filtering
0.3 micron particles with 99.97 percent efficiency.

**Lead**- Metallic lead, all inorganic lead compounds (e.g., laboratory
reagents, solder), and organic lead soaps. All other organic lead
compounds, such as tetraethyl lead, are excluded from this definition.

**Lead Paint**- Paint containing greater than 0.06 % (600 ppm) lead.

**Medical Surveillance**- Consists of medical examinations as well as
blood sampling for lead and zinc protoporphyrin, if applicable.
Performed by or under the supervision of a physician. The LBL EHS Health
Services Group is responsible for the Medical Surveillance Program.

**Permissible Exposure Limit (PEL)-** An OSHA occupational exposure
limit (without regard to the use of respirators) for airborne
contaminants. For lead it is 50 micrograms per cubic meter of air (50
µg/m3) for an 8-hour Time-Weighted Average (TWA). Exposure to airborne
lead above the PEL triggers requirements such as housekeeping,
engineering controls, showers, change and lunch rooms, area posting,
personal protective equipment, and respiratory protection.

**PPE-** Personal Protective Equipment. Safety equipment worn by
employees; may include safety glasses, respirators, coveralls etc.

V. Hazards of Lead

A. Ways in which lead enters the body

Lead can be absorbed into the body by inhalation (breathing) and
ingestion (eating). Lead (except for some organic compounds not covered
by this program) is not absorbed through the skin. Inhalation of lead is
considered the most important source of occupational exposure. When lead
is scattered in the air as a dust or fume particle, it can be inhaled
and absorbed into the blood stream through the lungs and upper
respiratory tract. Lead can also enter via the digestive system if it
enters the mouth and is swallowed. As an example, lead can be ingested
by handling cigarettes, food, etc., with lead contaminated hands.

B. Effects

1\. Short term (acute) overexposure. Large doses of lead may cause
seizures, coma, and death from cardio-respiratory arrest. Short term
occupational exposures leading to these effects are unusual but
possible.

2\. Long-term (chronic) overexposure may result in damage to the
blood-forming, nervous, urinary, and reproductive systems. Some common
symptoms of overexposure include loss of appetite, metallic taste in the
mouth, anxiety, constipation, nausea, pallor, insomnia, headache,
nervous irritability, muscle and joint pain, and tremors.

When lead gets into the body it is only partly eliminated. The majority
of the lead is stored in the bones and other tissues. As exposure to
lead continues, the amount stored in the body increases if more lead is
absorbed than is excreted. Consequently, continuous exposure to low
levels of lead can, over time, cause lead to accumulate in the body and
lead poisoning may result.

VI\. Examples of Possible Sources of Lead Exposure

• Lead-Containing Paint (banned 1977): Sanding, scraping, burning,
welding, ingestion.

Note: The paint on metal surfaces like structural steel generally
contains very high (20-40%) levels of lead.

• Drinking Water: Some water sources, lead solder in pipes (banned in
1986)

• Metallic Lead: Casting lead or brass, soldering, sawing, cutting, etc.

• Soil: Automobile exhaust, paint chips, fumes downwind of a smelter

• Miscellaneous: Pottery glazes, leaded crystal decanters, \"folk\"
medicine, tin cans (banned in USA), indoor shooting ranges, hobbies
(stained glass, fishing sinkers..)

At Lawrence Berkeley Laboratory the most likely sources of lead exposure
are activities involving lead-containing paints and metallic lead used
in the shielding of radioactive sources.

VII\. Responsibilities

A. Employees

1\. Follow lead safety procedures.

2\. Notify supervisor of tasks or procedures that may cause lead
exposure.

B. Facilities Division

1\. Inform the Industrial Hygiene Group of all upcoming work that may
involve the disturbance of lead-containing materials at the project
design phase, so that recommendations can be included in bid
specifications.

2\. Submit for approval to the Industrial Hygiene Group any proposed
procurement of lead-containing materials.

3.  Ensure that bid specifications disclose all hazardous lead materials
    that may be encountered by a contractor, and the party responsible
    for their mitigation.

C. Industrial Hygiene Group

1\. Conducts initial exposure assessments and workplace monitoring to
determine an employee's potential exposure to airborne lead.

2\. Recommends appropriate engineering and administrative controls to
ensure that airborne lead levels do not exceed the OSHA Action Level.

3\. Recommends appropriate personal protective equipment (PPE).

4\. Notifies supervisors and the EHS Health Services Group of personal
lead air monitoring results within three days of their receipt.

5\. Conducts training (EHS 329, 330) for employees who perform any tasks
in which there is a potential exposure to airborne lead at any level.

6\. Provides respirators and filters, and conducts annual respirator
fit-tests for employees who use respiratory protection to reduce lead
exposure.

7\. Performs annual checks of HEPA ventilation systems/vacuums used for
the control of airborne lead.

8\. Manages and updates the LBL Lead Compliance Program.

9\. Identifies for the Health Services Group, employees who should be
considered for the Medical Surveillance Program.

10\. Personal and area air sampling results collected by subcontractors,
shall be submitted to Facilities Project Managers, when applicable, for
collection, retention, and distribution to EHS Industrial Hygienists for
review. Copies of the results of samples collected by LBNL EHS
Industrial Hygienists will be forwarded to Facilities Project Managers,
when applicable, for collection and retention.

D. Health Services Group

1\. Maintains a medical surveillance program as described in 29 CFR
1910.1025.

2\. Maintains biological monitoring and medical removal records, as well
as making them available to affected employees and/or their authorized
representatives.

E. Supervisors

1\. Provide employees with personal air monitoring results within two
days of their receipt from the Industrial Hygiene Group.

2\. Ensure that employees receive appropriate training.

3\. Ensure that employees follow established safety procedures and that
engineering controls are properly functioning.

4\. Notify the Industrial Hygiene Group of employees who may have a
potential exposure to airborne lead, as well as operations or changes
that may produce or increase lead exposure to employees.

5\. Ensure that employees who perform work that may have a potential to
exceed the Action Level (Controlled Operation) are in a medical
surveillance program and have had a base-line blood lead sample prior to
starting work.

F. Waste Management Group

1\. Determines if lead-containing wastes should be classified as
\"hazardous waste\".

2\. Determines how lead-containing wastes are to be packaged.

3\. Selects an EPA approved disposal site.

4\. Manifests hazardous lead-containing waste to the disposal site.

5\. Maintains disposal records.

VIII\. Exposure Monitoring

The Industrial Hygiene Group has conducted site-wide personal exposure
monitoring to determine the lead exposure levels for employees who
perform tasks that involve working with lead or its compounds. This is
an ongoing program and new tasks involving work with lead will be
monitored as they occur.

1\. Tasks that have been monitored and found to be [below]{.underline}
the Action Level will be re-monitored periodically or whenever there is
a change in process, control, or changes in personnel that may change
the level of exposure to lead.

2\. Tasks that have been monitored and found to be [above]{.underline}
the Action Level shall be stopped immediately until engineering and/or
work practice controls (including administrative controls) are
implemented to reduce and maintain employee exposures to below the
Action Level.

3\. Results of airborne lead exposure monitoring shall be provided to
employees by their supervisor within two days of their receipt from the
Industrial Hygiene Group. The Industrial Hygiene Group will send the
written results to the supervisor and Health Services Group within three
working days of their receipt from the analytical laboratory.

IX\. Controlled Operations

The following operations have been identified as having the potential to
exceed the Action Level and shall not be performed without the
appropriate engineering and/or administrative controls. Though these
controls reduce employee exposure to below the Action Level, the
respiratory equipment requirements specified below are intended to
further minimize employee exposure, consistent with the ALARA concept.
Employees performing these tasks will not eat, drink, smoke etc., while
performing these tasks. They will also wash their hands before taking
breaks or otherwise leaving the area. Showering may be required, if the
PEL is exceeded.

**1**. **Welding/Lead Paint Removal - Site Wide**. Typically the work is
performed by paint or weld shop employees. Paint removal may be
performed to prepare surfaces for repainting, or prior to welding, hot
cutting, or brazing. Paint removal involves the reduction of visible
lead paint by sanding or grinding the surface. Welding, brazing, or
heating lead painted surfaces above 6000F is prohibited, unless the
paint has been removed to bare metal six inches from either side and
[behind]{.underline} the area that is to be welded, brazed, or heated.
The purpose of this is to prevent the generation of lead fumes from the
paint when the metal is heated. In certain instances (e.g., limited
access, extent of work), with the proper safety precautions, the
Industrial Hygiene group may waive the requirement to remove the paint
prior to welding/cutting.

[Engineering Controls:]{.underline}

1.  Local exhaust ventilation equipped with HEPA (or equivalent)
    filtration shall be used when performing this type of work.

> [Administrative Controls:]{.underline}
>
> 1\. Lead awareness training (EHS330)
>
> 2\. Work performed in designated area with warning signs.
>
> 3\. Written procedures.
>
> [Personal Protective Equipment:]{.underline}
>
> 1\. Full facepiece negative pressure respirator with HEPA**\***
> filters or continuous flow airline respirator for welding and paint
> removal in order to achieve an assigned protection factor of at least
> 50 times the PEL. The use of a lower level of respiratory protection
> is allowable if an initial exposure assessment or previous exposure
> air monitoring results warrant the down grade. This decision will be
> made by the Industrial Hygienist. Though the majority of visible paint
> is removed prior to welding, air sampling results have indicated that
> it is not possible to remove all of the paint, and there will be some
> lead-based paint present in cracks and other uneven surfaces of the
> metal to be welded.
>
> **\*** Note: In certain cases a full facepiece respirator with
> combination HEPA/Organic Vapor cartridges may be required for paint
> that may contain resins and polymers that can burn to form airborne
> organic compounds.
>
> 2\. Disposable coveralls (with head and foot covering).
>
> 3\. Safety shoes

**2**. **Cleaning of Lead Bricks. Site Wide.** Typically this work is
performed to remove the off-white powers (lead oxides, carbonates etc.)
that form on the outer surface of exposed lead bricks. These deposits
can readily flake off, contaminating the surfaces with which they come
into contact. In addition, lead containing powders can also become
airborne and pose an inhalation hazard. Cleaning is usually performed
prior to painting, taping or wrapping the bricks.

[Engineering Controls:]{.underline}

1\. Perform cleaning work on the specially designed HEPA mechanical
exhaust ventilation system table (when feasible). If using the table is
not feasible, other local exhaust ventilation equipped with HEPA
filtration shall be used.

[Administrative Controls:]{.underline}

1\. Lead awareness training (EHS 330)

2\. Work performed in designed area with warning signs

3\. Written procedures (Lead Compliance Plan) specific to the task

[Personal Protective Equipment:]{.underline}

1.  Full facepiece negative pressure respirator with HEPA filters is to
    be used in order to achieve an assigned protection factor of at
    least 50 times the PEL. The use of a lower level of respiratory
    protection is allowable if an initial exposure assessment or
    previous exposure air monitoring results warrant the down grade.
    This decision will be made by the Industrial Hygienist.

> 2\. Disposable coveralls (with head and foot covering).
>
> 3\. Safety shoes
>
> **3. Cutting, Machining of Lead Bricks/Sheets -- Site Wide.**
> Typically this work is performed when lead is used for shielding
> radioactive sources. Lead may be manipulated when experimental changes
> result in the requirement to reconfigure or increase the amount of
> shielding necessary to protect employees. Lead may be cut or machined
> when shielding of a specific and unique configuration is required. The
> Industrial Hygiene Group must be consulted prior to the machining or
> cutting of lead bricks/sheets.

[Engineering Controls:]{.underline}

1.  Local exhaust ventilation equipped with HEPA (or equivalent)
    filtration shall be used when cutting or machining lead. Portable
    HEPA filtered vacuums may be used for this purpose.

[Administrative Controls:]{.underline}

1\. Lead awareness training (EHS 330)

2\. Work performed in designed area with warning signs

3\. Written procedures (Lead Compliance Plan) specific to the task

[Personal Protective Equipment:]{.underline}

1.  Full facepiece negative pressure respirator with HEPA filters is to
    be used in order to achieve an assigned protection factor of at
    least 50 times the PEL. The use of a lower level of respiratory
    protection is allowable if an initial exposure assessment or
    previous exposure air monitoring results warrant the down grade.
    This decision will be made by the Industrial Hygienist.

> 2\. Disposable coveralls (with head and foot covering).
>
> 3\. Safety shoes
>
> **4. Manipulation of more than 5 unwrapped/painted lead bricks (or
> equivalent)- Site Wide.** Typically this work is performed when lead
> is used for shielding radioactive sources. Lead may be manipulated
> when experimental changes result in the requirement to reconfigure or
> increase the amount of shielding necessary to protect employees.
> Employee's potential airborne lead exposure is not expect to exceed
> the Action Level when less than 5 unwrapped/painted bricks are
> handled.

[Engineering Controls:]{.underline}

1.  Local exhaust ventilation equipped with HEPA (or equivalent)
    filtration shall be used when manipulating lead, if feasible.
    Portable HEPA filtered vacuums may be used to remove loose lead
    particles from the surface prior to handling to reduce potential
    airborne levels.

[Administrative Controls:]{.underline}

1\. Lead awareness training (EHS 330)

2\. Work performed in designed area with warning signs

3\. Written procedures (Lead Compliance Plan) specific to the task

[Personal Protective Equipment:]{.underline}

2.  Full facepiece negative pressure respirator with HEPA filters is to
    be used in order to achieve an assigned protection factor of at
    least 50 times the PEL. The use of a lower level of respiratory
    protection is allowable if an initial exposure assessment or
    previous exposure air monitoring results warrant the down grade.
    This decision will be made by the Industrial Hygienist.

> 2\. Disposable coveralls (with head and foot covering).
>
> 3\. Safety shoes

X. Housekeeping

Accumulations of lead shall be minimized to the extent practical in all
areas where lead is used. Work surfaces in areas where the sanding,
grinding, or cutting of lead containing materials is performed shall be
cleaned at least once per shift to prevent the accumulation of lead
dust. Dry sweeping or \"blowing down\" work surfaces and floors is
prohibited. Dedicated vacuums equipped with HEPA filters and labelled
\"Caution - contains lead\" should be used to clean work surfaces.
Vacuuming is the preferred method of cleaning. Wet sweeping, shoveling,
or wiping may not be used except where vacuuming has been tried and does
not work. Vacuums shall be used and emptied in a manner which minimizes
the re-entry of lead into the workplace.

XI\. Lead Hammers

Lawrence Berkeley Labs storehouse has discontinued the stocking of lead
hammers, substituting plastic \"deadblow\" hammers as equivalents.
Existing lead hammers should be placed in "Lead Only" scrap metal
hoppers (B77) for recycling. The purpose of this substitution is to
minimize the small amount of lead that is dispersed (by peening,
flaking) into the work environment by the use of lead hammers.

XII\. Medical Surveillance

All employees and contractors who have a potential exposure to
significant (i.e., \>30 g/m3) amounts of airborne lead shall have a
base-line blood lead sample taken by LBL Health Services prior to
starting this work. Personnel with a baseline blood lead level exceeding
25ug/100 ml shall not perform work that may expose them to airborne
lead.

XIII\. Personal Protective Equipment (PPE)

It is important to avoid the contamination of personal clothing, and to
ensure that lead contaminated materials do not leave the work area
unless they are sealed. Disposable coveralls, gloves, shoe covers etc.,
shall be used whenever it is possible to contaminate personal clothing
during lead work. After use they will be double bagged in 6-mil plastic
bags, identified as lead contaminated, and disposed of as hazardous
waste as per laboratory hazardous waste procedures.

XIV\. Purchasing Lead-Containing Materials

The Industrial Hygiene Group\'s Lead Program Manager shall be notified
of any procurement of materials that contain lead.

XV\. Storage and Use of Lead Bricks

Lead bricks not being used for shielding or in a controlled storage area
shall be painted, taped, or wrapped (when feasible). The purpose of this
is to minimize the amounts of lead compounds formed on the outer surface
of the lead (e.g., oxides, carbonates etc.) and subsequent exposure to
employees and the environment. Gloves and sufficient disposable clothing
are to be worn when handling lead to ensure that hands and personal
clothing are not contaminated. Refer to Section IX, Controlled
Operations, for more information.

Note: Pallets used in lead work shall be covered with a layer of
polyethylene, herculite, or similar impervious material before stacking,
storing, or transporting lead. Lead shall be stored off of the ground,
and covered with a tarp or plastic if exposed to the weather. Covers
shall be removed and disposed of as lead contaminated waste before the
pallets can be returned to general use.

XVI\. Training

1\. Employees who have a potential exposure to airborne lead at less
than the OSHA Action Level are required to take EHS 329- Lead Hazard
Communication.

2\. Employees who perform work in \"Controlled Operations\"(section IX)
or other tasks which could potentially result in exposures above the
OSHA Action Level are required to take EHS330. The information in
Appendix A and B of the OSHA Lead Standard, 29 CFR 1910.1025 is
discussed in this course.

Supervisors will identify the employees who work with or handle lead
(consult the JHQ) and the Industrial Hygiene Group will perform the
training.

XVII\. Waste Disposal

The Waste Management Group will determine whether lead containing wastes
should be classified as \"hazardous waste\". They will also provide
guidance for packaging and disposal, as well as approve all hazardous
waste manifests before waste leaves LBL.

Lead and its compounds are considered hazardous waste if the Soluble
Threshold Limit Concentration (STLC) exceeds 5.0 milligrams per liter
(mg/l) or the Total Threshold Limit Concentration (TTLC) exceeds 1,000
milligrams per kilogram (mg/kg).

It should be noted that the East Bay Municipal Utility District (EBMUD)
does not permit the discharge of water containing greater than 2 mg/l
lead into the sanitary sewer.