Lead Compliance

The Seattle Public Schools Lead Compliance/Work Plan has been developed to comply with the Washington Industrial Safety and Health Act (WISHA) requirement for a written program. The Plan outlines engineering and work practice controls to reduce employee exposure to lead below the permissible exposure limit.

Word version and pdf version of the Lead Compliance/Work Plan is also available upon request.

Lead Compliance/Work Plan

Requirements for Projects that Involve Lead-Based Paint

Prepared by: Seattle Public Schools, Environmental Health and Safety

Introduction

The Seattle School District’s Lead Compliance/Work Plan has been developed to comply with the Washington Industrial Safety and Health Act (WISHA) requirement for a written program to achieve compliance with WAC 296-155-17607. The Plan outlines engineering and work practice controls implemented to reduce employee exposure to lead below the permissible exposure limit to the extent that such controls are feasible.

Site Location

This plan covers the safe removal, handling, and disposal procedures for exterior lead based paint (LBP) at: Provide Site Name and Address Here

Scope of Work

Provide a general description of work activities that are expected to disturb lead-based paint. Include a description of the location and type of building components involved.

Methods of Compliance

Competent Person

The District will designate a Competent Person, as defined by WAC 296-155-17605, for projects requiring this Lead Compliance/Work Plan. The Competent Person will be present on the job site throughout all phases of the project to ensure work is performed in accordance with the plan.

Exposure Assessment

The District will perform initial monitoring of employees who may be exposed to airborne concentrations of lead at or above the action level. Monitoring will be representative of a full shift for the job with the highest anticipated lead exposure.

The frequency of monitoring will be in accordance with WAC 296-155-17609(6). If the exposure assessment results indicate employee exposure to lead at or above

50ug/m³ the District will modify engineering controls and work practices as necessary to reduce exposure below the PEL. After modifications have been made the District will perform additional monitoring to determine the effectiveness of the modifications.

Medical Surveillance

Because District employees are not engaged in lead related activities for more than 30 days in any 12 months it is not expected that they would be exposed to lead at or above the action level for more than 30 days per year. Based on exposure assessments from similar projects and past biological monitoring, the District does not anticipate the need to institute a medical surveillance program.

However, the District will make available initial medical surveillance to employees who may be occupationally exposed to lead at or above the action level of 30μg/m³. Initial medical surveillance consists of biological monitoring in the form of blood sampling analysis for lead and zinc protoporphyrin levels. Additional samples may be required if sample results show significant lead exposure.

Medical Removal

An employee will be removed from the job if his/her blood lead level is 30μg/dl or greater. When an employee is removed, or otherwise limited, they will be assigned to a task that will not result in exposure to lead at or above the action level of 30μg/m³. The employee may return to his/her former assignment when a qualified physician determines that the employee is no longer at risk from exposure to lead or when the employee’s blood level is less than 25μg/dl.

Training

All employees who are potentially subject to exposure to lead at or above the action level on any day will be trained in accordance with WAC 296-155-17625. Training will include, but not be limited to the following:

• The content of the applicable standards and appendices;
• The site specific nature of the operations which could result in exposure to lead above the action level;
• The purpose, proper selection, fitting, use, and limitations of respirators;
• The purpose and a description of the medical surveillance program, and the medical removal program;
• The engineering controls and work practices associated with the employee’s assignment, including training of employees to follow relevant good work practices;
• The contents of this compliance program; Instruction of the use of chelating agents;
• The employee’s right of access to records.

Respirators

Employees entering the lead work area will wear 1/2 mask air purifying respirators with high efficiency filters. Respirators will be used according to the District’s Respiratory Protection Program.

Protective Clothing

Employees entering the lead work area will wear disposable full-body coveralls, gloves, and eye protection. Coveralls will include head and foot coverage.

Lead Work Area

The lead work area will be demarcated with caution tape at least 20 feet around the lead work activities. Warning signs of sufficient size to be clearly legible will be displayed at the lead work area. At a minimum, signs will include the following information:

“Warning” “Lead Work Area”

Where employee exposure to lead is above the PEL, signs will include the following information:

“WARNING” “Lead Work Area” “Poison”

“No Smoking or Eating”

Hygiene Practices

Hygiene practices will include, but are not limited to, the following:

• No eating, drinking, smoking, or applying cosmetics in the lead work area.
• Prior to exiting the lead work area employees will remove LBP debris from protective clothing with a HEPA vacuum.
• Immediately upon exiting the lead work area, protective clothing will be removed in a designated clean area and placed into a plastic bag or drum for disposal.
• Immediately upon leaving the clean area, each employee will wash and dry face, head, and hands and vacuum clothes, if necessary.
  • Additionally, where employee exposure to lead is above the PEL, hygiene practices will include the following:
    • Shower facilities, where feasible.
    • Clean change area equipped with separate storage facilities for protective clothing/equipment and for street clothes that prevents cross contamination.

Housekeeping Practices

Housekeeping practices will include, but are not limited to, the following:

• All surfaces will be maintained reasonably free of accumulations of lead. The lead work area will be inspected for visible LBP debris at the end of each shift.
• Cleaning of surfaces where lead accumulates will be accomplished by vacuuming or other methods that minimize the likelihood of lead becoming airborne.
• Where vacuuming methods are not effective, wet sweeping will be used to collect LBP debris.
• Where vacuuming methods area used, the vacuums will be equipped with HEPA filters.
• Compressed air will not be used to remove lead from any surface.

Work Practices

Method(s) of Removal

Areas with cracked, peeling, or loose paint surfaces, the surface will be scraped or sanded to dislodge any loose paint. Lead based paint will be removed by manual wet scraping and sanding methods only; mechanical methods will not be used.

Plastic sheeting will extend at least 6′ from the surface to be prepared. Debris generated from scraping will be collected using a HEPA vacuum or sweeping if the debris has been wetted. No scraping will occur in high wind conditions unless appropriate wind breaks are erected.

Storage and Disposal

Collected LBP debris will be stored in labeled lead waste containers and secured at the end of each shift. Lead waste containers will be kept separate from non-lead waste containers.

All lead waste will be disposed of in accordance with local, state, and federal requirements.