Chapter 37 – Lead Hazards and Controls

DRAFT

Contents

Approved by Joy Fleming
Revised 9/20

37.1 Policy
37.2 Scope
37.3 Applicability
37.4 Exceptions
37.5 Roles and Responsibilities
37.6 Definitions
37.7 Required Work Processes

• Work Process A. General Requirements
• Work Process B. Lead Hazard Assessment
• Work Process C. Training and Qualifications
• Work Process D. Authorizations, Permits, and Approved Work Plans
• Work Process E. Controlled Operations and Work Controls
• Work Process F. Waste Disposal
• Work Process G. Exposure and Surface Contamination Monitoring

37.8 Source Requirements
37.9 Implementing Documents
37.10 Appendices

• Appendix A. Lead Compliance Work Plan Templates
• Appendix B. Lead Work Permit
• Appendix C. Lead Warning Signs and Labels
• Appendix D. HEPA Vacuum Safe Work Procedure

Note:
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37.1 Policy

The Lead Program at Lawrence Berkeley National Laboratory (Berkeley Lab) is intended to minimize lead exposures and to ensure that any activities performed at the Laboratory involving lead or lead-containing materials comply with all applicable regulations. When implemented properly, this program provides Berkeley Lab employees, subcontractors, and affiliates with a safe and healthful work environment by instituting feasible engineering controls and work practices. In addition, administrative controls and respiratory protection will be used to further reduce exposures to lead concentrations not adequately controlled by engineering methods or work practices.

Proper lead management safeguards the health and safety of workers and building occupants, minimizes the impact to the environment, and ensures adherence to regulations concerning lead in the work environment. The purpose of the Lead Program is to outline the guidelines and work processes required to manage, handle, alter, and/or disturb any lead or lead-containing materials at Berkeley Lab.

37.2 Scope

Lead at Berkeley Lab is present in various forms and processes that pose potential employee exposure hazards. Deteriorating lead-based paint, dust from lead shielding, and research processes using lead are potential exposure sources. Employees may also be exposed to lead during construction, alteration, repair, renovation, painting, or decorating that involves any sanding, grinding, welding, removal, or disturbance of surface or building materials that contain or are coated with lead. Lead exposures may also occur with installation of products containing lead.

37.3 Applicability

This policy applies to all Berkeley Lab employees, subcontractors, affiliates and visitors. All applicable guidelines, requirements, and work processes established by the Lead Program must be followed when performing any lead work.

This policy encompasses general industry and construction work. General industry lead work includes handling lead shielding, building experimental equipment, soldering, and machining lead or lead alloys (including brass and pewter). Construction work includes maintenance, demolition, or remodeling of buildings with lead-containing materials, construction of new buildings, removal of lead paint from equipment or buildings, and the use of paint or other materials that contain lead.

The use and handling of lead and lead compounds in research laboratories is governed by the Berkeley Lab Chemical Hygiene and Safety Plan and criteria established in the California Code of Regulations Title 8, Section 5191, Occupational Exposure to Hazardous Chemicals in Laboratories. However, lead exposures in research laboratories must be maintained below Cal/OSHA’s permissible exposure limit (PEL).

37.4 Exceptions

None

37.5 Roles and Responsibilities

Role	Responsibility
Line management	Requests for industrial hygienist to evaluate work areas and activities for all workers who may be potentially exposed to lead above established limits Plans and supervises work in accordance with the Berkeley Lab Integrated Safety Management (ISM) Plan Ensures that all available and specified engineering controls, administrative controls, and personal protective equipment (PPE) are implemented before work begins, and ensures that they are used appropriately Verifies that workers have read the established, job-specific Negative Exposure Assessment or the applicable Lead Compliance Work Plan Verifies that workers are adequately and properly trained before starting work Schedules workers who have been exposed to levels above the Action Level for medical exams and enrollment into the Berkeley Lab Health Services Lead Medical Surveillance Program Ensures that individuals who may be potentially exposed to lead receive appropriate training Conducts job-specific lead training Provides an alternate work area and non-lead work activities for workers whom Health Services has removed from work involving lead exposure Notifies the assigned industrial hygienist at least 48 hours before lead work begins
Employees, subcontractors, affiliates, and visitors	Follow the requirements outlined in this document and other lead-work procedures for work involving lead Attend required lead training as specified in Work Process C, Training and Qualifications Report to line management any operation or unanticipated work activities that involve lead or lead-containing materials that were not addressed by ISM or pre-task planning Use engineering controls and PPE in accordance with instruction and training Notify Health Services if pregnant or actively trying to conceive a child, if working with lead or lead-containing materials
Industrial hygienist	When possible, establishes job-specific Negative Exposure Assessments for similar lead work activities Performs required air monitoring Notifies workers, supervisors, and Health Services of: Air-sample results within five days of receiving results from the analytical laboratory Any requirements for medical surveillance Assists in the design, implementation, and testing of engineering control systems Reviews job-specific Negative Exposure Assessments, bid specifications, and Lead Compliance Work Plans to ensure they incorporate adequate controls Recommends the most appropriate type of respirator for workers involved in lead work Refers employees to Respiratory Protection Program Manager for issuance of appropriate respirator and testing, and to Health Services for any required medical evaluations Assists supervisors in identifying potential lead-disturbing activities Performs bulk and surface wipe sampling as required, or as appropriate
Lead Program Manager	Develops and maintains the Lead Program Develops and provides the necessary classroom training, or assists in identifying an alternate source of training Assists industrial hygienists with establishing job-specific Negative Exposure Assessments Assists industrial hygienists with reviewing the Facilities Division’s bid specifications and Lead Compliance Work Plans to ensure adherence to the Lead Program
Health Services	Performs required respirator medical approvals and focused surveillance exams to include appropriate blood chemistry tests for employees exposed above the lead Action Level Determines when workers must be removed from lead work activities because of abnormalities detected during medical surveillance Determines when workers can return to lead work activities after being removed because of medical abnormalities Notifies workers of any medical findings, as required Notifies supervisors of any work restriction related to lead work Requests the Health and Safety Department to perform a work-site evaluation for any worker found to have an elevated blood lead level Coordinates exposure monitoring results with the Lead Program Manager
Facilities Division	Notifies the Lead Program Manager of purchases of lead-containing materials Prohibits Facilities personnel, supplemental labor personnel, and construction contractors from using construction products containing more than 0.06% lead, or any lead on drinking-water lines (this does not apply to electrical solder) Specifies in construction contracts if and where lead will be disturbed; alternatively, requires that subcontractors determine the presence of lead before disturbing materials that may contain it Develops and maintains a bid specification that implements the Berkeley Lab Lead Program in construction, renovation, and demolition contracts where lead material may be encountered
Procurement and Property Management	Notifies the Lead Program Manager, and obtains approval, prior to purchase of lead materials, in accordance with established protocols

37.6 Definitions

Term	Definition
Action Level (AL)	Employee exposure established by the federal Occupational Safety and Health Administration (OSHA) as airborne lead at an eight-hour time-weighted average concentration of 30 micrograms of lead per cubic meter (µ/m3) of air or 0.030 milligrams per cubic meter (mg/m3) of air, without regard to the use of respirators
Biological Exposure Index	Blood lead level established by American Conference of Governmental Industrial Hygienists as 30 micrograms of lead per 100 milliliters of blood (30 µg/100 ml) in the publication “TLVs and BEIs: Based on the Documentation of the Threshold Limit Values for Chemical Substances and Physical Agents & Biological Exposure Indices”
Biological monitoring	The analysis of blood, urine, or both to determine the level of lead contamination in the body. Blood-lead levels are expressed in micrograms of lead per deciliter (one-tenth of a liter) of blood, or µg/dL.
Engineering controls	Measures other than respiratory protection or administrative controls that are implemented at the work site to contain, control, and/or otherwise reduce exposure to lead-contaminated dust and debris usually in the occupational health setting. The measures include process and product substitution, isolation, and ventilation.
Exposure monitoring	The sampling and analysis of air both inside and outside the work area to determine the degree of worker and occupant exposure to lead or other airborne contaminants, often involving air sampling inside a worker’s breathing zone
High-efficiency particulate air (HEPA) filter	A filter capable of removing particles of 0.3 micron or larger from air at 99.97 percent or greater efficiency
HEPA vacuum	Vacuum that contains a high-efficiency particulate air (HEPA) filter that is able to remove at least 99.97% of monodispersed particles of 0.3 micrometer in diameter
Lead Compliance Work Plan	A document that describes the types of tasks, workers, protective measures, and tools and other materials that may be employed to control lead-containing hazards in order to comply with the OSHA Lead Exposure in Construction standard
Lead-containing	A coating or material that contains any detectable level of lead
Lead-contaminated surface	Any surface that contains an area or mass concentration of lead in excess of a regulatory limit established by OSHA or the Environmental Protection Agency (EPA) or in excess of a guideline established by an Environment, Health, and Safety (EHS) industrial hygienist or the Lead Program Manager
Lead paint abatement	A measure or set of measures designed to permanently eliminate lead-based paint hazards or lead-based paint. Abatement strategies include the removal of lead-based paint, removal of lead-contaminated dust, and removal of lead-contaminated soil or overlaying of soil with a durable covering such as asphalt. All these strategies require preparation; cleanup; waste disposal; post-abatement clearance testing; recordkeeping; and, if applicable, monitoring.
Negative Exposure Assessment (NEA)	A Negative Exposure Assessment (NEA) is a written statement within the past 12 months by an EHS industrial hygienist indicating that a specific lead-disturbing job (or a class of very similar lead-disturbing jobs) does not result in worker exposure above the Action Level. Work conducted pursuant to an NEA can proceed without subsequent review, provided that the controls specified in the NEA are implemented.
Permissible Exposure Limit (PEL)	The eight-hour time-weighted average concentration of airborne lead an employee exposure may not exceed without the use of respirators. The OSHA value is 50 µg/m3 of lead in air or 0.050 mg/m3 of lead in air.
Public building	A structure, or part of a structure, and its land, which are generally accessible to the public, including but not limited to schools, day-care centers, museums, airports, hospitals, stores, convention centers, government facilities, office buildings, and any other building that is not an industrial building or a residential building
Regulated Area	Work areas where airborne exposure to lead is above the PEL

37.7 Required Work Processes

Work Process A. General Requirements

1. Application and Installation of Lead-Containing Products. With the exception of lead solder in electrical work, materials containing more that 0.06% lead should not be used, specified, or allowed in the construction of a building or infrastructure. Requests for a special allowance require prior review by the EHS industrial hygienist and Facilities Project Management.
2. Proper Handling of Lead Shielding. Where it will not interfere with shielding properties, lead items used for shielding or weighting should be encapsulated in a suitable coating to protect the lead from corrosion and to reduce worker contact. Corroded lead materials may be particularly hazardous and should be encapsulated or replaced if feasible. Newly purchased shielding bricks should be encapsulated to prevent oxidation.
3. Personal Hygiene Practices. The precautions below apply to areas where lead is disturbed, and where the potential for exposure is greater than the PEL unless the work is covered by an NEA.
   1. Designate a separate location for eating, storing, and preparing food and beverages, and for using tobacco products and cosmetics to avoid the possibility of ingesting lead. No lead work shall be performed in these designated areas. Lunchrooms shall be kept under positive pressure by the provision of tempered, filtered air.
   2. Wash hands and face before eating, drinking, using tobacco products, or applying cosmetics. Workers should shower if exposed in excess of the PEL.
   3. Do not wear protective clothing into lunchrooms. Designate change rooms where workers can segregate street clothes from clothing used for work.
   4. Make shower facilities available. Showers located throughout the Laboratory may be used, only if other workers do not use these showers where they may be potentially contaminated with lead dust. Showers used by lead workers should be decontaminated before use by other workers. Portable shower units should be used for required decontamination activities.
   5. Promptly place lead-coated or lead-containing demolition or renovation debris (e.g., drywall) in plastic bags or other sealable containers. Do not allow them to accumulate in the workspace. These bags should be labeled in accordance with applicable Berkeley Lab environmental guidance. Refer to Work Process F, Waste Disposal, and consult your assigned Waste Management Representative/Generator Assistant to determine exact requirements.
4. Regulated Areas
   1. Signs with the wording below shall be posted at all possible entrances to Regulated Areas (i.e., locations where lead work other than lead work performed pursuant to an NEA is being conducted):
      
   2. These signs should be designed in accordance with OSHA or American National Standards Institute (ANSI) design criteria and color schemes. These signs must be well illuminated so they are easily visible to workers and visitors. Contact the Lead Program Manager (ext. 5406) for guidance. Refer to Appendix C for an example of the required sign.

Work Process B. Lead Hazard Assessment

Preconstruction Paint Sampling.

1. Lead is present in paint on the surfaces of many Berkeley Lab buildings. Thus, it is necessary to identify activities such as maintenance, renovation, remodeling, and demolition that will disturb lead-coated surfaces so that the appropriate controls can be implemented before work begins. It will be necessary to test the interior and exterior of most building surfaces before beginning activities that disturb potential lead-containing material or it may be assumed that the material disturbed includes lead.
2. Specifically, painted surfaces should be tested before beginning construction activities that involve disturbance of lead-containing surfaces/materials, including but not limited to:
   1. Scraping, abrasive blasting, or sanding
   2. Demolishing buildings
   3. Cutting, sawing, or otherwise penetrating a wall or other painted surfaces – except for installing a few screws into a wall
   4. Burning, torching, cutting, arc cutting, welding, or brazing
   5. Using a heat gun to remove paint
   6. Performing other activities that generate lead-containing dust
3. Testing should also be conducted on other potentially lead-containing construction materials if a lead aerosol may be generated, including but not limited to:
   1. Galvanized metal that is to be cut with a torch, burned, power sawn, or otherwise heated to the melting point of lead
   2. Brass, bronze, and pewter to be sanded or heated to the melting point of lead
   3. Solders to be sanded
4. Laboratories that analyze lead swipe or bulk samples must be accredited by the American Industrial Hygiene Association or another organization accredited by the EPA specifically to perform lead analysis. Bulk samples can be analyzed using atomic absorption or inductively coupled plasma emission spectroscopy (ICPES). Alternative techniques (e.g., laboratory or field X-ray fluorescence) may be approved by the EHS industrial hygienist.
5. Preconstruction testing is usually conducted by Berkeley Lab personnel who have either completed the State of California, Department of Public Health Accreditation Program for Lead Inspectors or Sampling Technicians, or who are certified by the American Board of Industrial Hygiene in industrial hygiene, or who work under the supervision of a Certified Industrial Hygienist (CIH) or an accredited inspector.
6. Berkeley Lab must either test all potentially lead-containing surfaces before releasing a construction proposal for work that may disrupt lead, or require the contractor to perform testing before disrupting any potentially lead-containing materials. Subcontractors who make lead determinations must be accredited by the State of California, Department of Public Health as a lead inspector, or a certified sampling technician.
7. In the case of designated public buildings, the preconstruction testing must be performed by a California accredited inspector/assessor or sampling technician. Additionally, the results of any materials tested in designated public buildings must be documented on California Department of Public Health (CDPH) Form 8551, and copies submitted to CDPH.

Work Process C. Training and Qualifications

There are several Berkeley Lab lead training requirements and programs based on the type(s) of tasks conducted. In addition to specific lead training, all workers who will generate hazardous waste must complete EHS0604, Hazardous Waste Generator Training, which is available online.

1. Non-routine Electrical Lead Soldering. Workers doing only light, non-routine soldering may take EHS0243, Soldering Awareness Training. If an employee has completed EHS0243, there is no requirement to also complete EHS0329, Lead Hazard Communication.
2. Laboratory Research Lead Work. Work in laboratories with lead or lead-containing compounds normally only requires completion of EHS0348, Chemical Hygiene and Safety. If extensive lead work may be performed (such as experiments with lead batteries or extensive handling of lead bricks or other shielding), additional training may be required. Please refer to the Berkeley Lab Chemical Hygiene and Safety Plan, your assigned industrial hygienist, or the Lead Program Manager for more information.
3. Negative Exposure Assessment Lead Work
   1. Workers who perform work under an established NEA (such as those in Work Process E, Controlled Operations and Work Controls) should take either:
      1. EHS0329, Lead Hazard Communication
      2. EHS0330, Lead Worker Training
   2. Workers who have successfully completed EHS0330 are not required to take EHS0329. EHS0330 has an annual retraining requirement.
4. Disturbing Lead-containing Materials or Abatement
   1. EHS0330 is required as a minimum. If more extensive training or certification is necessary based on risks of the activity, additional training may be required, such as:
      1. EHS0331, Lead-Construction Supervisor
      2. EHS0332, Lead-Construction Worker
      3. EHS0333, Lead-Construction Refresher
      4. CDPH Lead Supervisor for Public Buildings
      5. CDPH Worker for Public Buildings
   2. The courses listed above are not usually taught on site. Employees who have completed these courses and maintain currency are not required to take EHS0329 or EHS0330.
   3. Subcontractors disturbing lead-containing materials are required to obtain lead worker training, as a minimum. Remediation or abatement of lead-containing materials or paint by subcontractors requires training and certifications (lead supervisor and/or lead worker) in accordance with the CDPH. Proof of equivalent lead-work training or CDPH certifications must be provided and reviewed as part of the Construction Job Hazards Analysis (JHA) or Subcontractor Job Hazards Analysis (SJHA) approval process.
5. Evaluation and Sampling of Paint and/or Building Materials. The CDPH designates curricula and courses for lead inspectors/assessors and lead-sampling technicians. Workers who conduct surveys to determine the lead content in materials should completed these courses and have CDPH certifications, unless they are certified industrial hygienists or work directly under the supervision of a certified industrial hygienist or training lead inspector. For public buildings, CDPH certifications are required. Subcontractors who perform lead surveys must also meet these training and certification requirements.

Work Process D. Authorizations, Permits, and Approved Work Plans

1. Negative Exposure Assessments (NEAs). A Negative Exposure Assessment (NEA) is a statement written by an EHS industrial hygienist indicating that a specific lead-disturbing job (or a class of very similar lead-disturbing jobs) does not result in worker exposure above the Action Level. Work pursuant to an NEA can proceed without subsequent review, provided that the controls specified in the NEA are strictly followed. Examples of controlled lead work and activities covered by NEAs at Berkeley Lab are provided in Work Process E, Controlled Operations and Work Controls.
2. Lead Compliance Work Plans
   1. Lead Compliance Work Plans or other work procedures must be developed for any operation that will (or may) result in exposures above the PEL, unless the operation and its controls are fully described in the NEA. A separate Lead Compliance Work Plan is not required for jobs with an NEA. These Work Plans must specify the manner in which the work will be altered to reduce the exposure level to the PEL using both engineering and administrative controls. Examples of work requiring a Lead Compliance Work Plan:
      1. Lead paint removal prior to hot work
      2. Cleaning of lead bricks (or shielding)
      3. Cutting or machining of lead bricks or other lead shielding
      4. Handling more than five lead bricks or other lead shielding
      5. Installing enclosure booths in the Advanced Light Source (ALS) (or similar activities)
   2. Appendix A contains templates of Lead Compliance Work Plans (or similar documentation) that outline the specific requirements for lead work conducted by Berkeley Lab employees for work that may cause an exposure over the PEL. These Lead Compliance Work Plans must be reviewed at least every six months for construction-related work and annually for lead work not associated with building (if the plans are still in effect). General work requirements for all jobs are included in Work Process A, General Requirements. Lead Compliance Work Plans should be developed by the organization planning and conducting the work.
3. Generic Documentation for Small Jobs (Lead Work Permit). The Lead Work Permit form in Appendix B can be used to specify the controls for smaller routine jobs. The supervisor initiates the process and obtains the Berkeley Lab industrial hygienist’s approval signature prior to the start of work.
4. Lead-Work Pre-job Notification. Submit written notification to the nearest Division District Office in the manner prescribed in Title 8 CCR 1532.1 (p) if amount of lead-containing materials to be disturbed is greater than 100 square feet or 100 linear feet and contains greater than 0.5%, 5000 parts per million (weight by weight), or 1.0 mg/cm².

Work Process E. Controlled Operations and Work Controls

1. Lead Soldering. Monitoring data and available literature indicate that nonproduction benchtop lead soldering will not exceed the Action Level. Some fluxes and solder components may cause eye irritation or other health effects. Contact your division industrial hygienist for information about these products. Wash your hands after working with lead.
2. Moving Fewer Than Five Lead Bricks
   1. Monitoring data indicated that moving fewer than five lead bricks (or an equivalent amount of lead) in a day will not generated airborne levels that exceed the Action Level. The following Safe Work Procedures will assure that your hands, clothes, and the work area will not become contaminated with lead residue.
      1. Handle lead bricks carefully.
      2. Hold the lead bricks out from your body so they do not contact your clothing, or wear disposable coveralls or apron.
      3. Wear gloves and wash hands after work is finished.
      4. Place lead bricks on plastic for moving and transition, if feasible.
   2. If lead bricks are going to storage, contact the Lead Program Manager for more information.
   3. If lead bricks have visible powder on them, or otherwise are known to have high levels of removable surface contamination, contact your industrial hygienist or Lead Program Manager for cleaning information and requirements. Cleaning of lead bricks is not covered by an NEA and this operation must be evaluated and controlled.
3. HEPA Vacuum Safe Work Procedure
   1. HEPA vacuums must be labeled with the waste they collect. Dedicated vacuums for lead waste must be labeled: “Caution: Contains Lead” or similar language.
   2. Inspect the vacuum before use for testing dates, electric cord flaws, label, needed attachments, and function check.
   3. Maintain the vacuum and change the filters in a designated area with engineering controls to avoid exposure. Gloves and respiratory protection are required.
   4. Exposure monitoring is required for all maintenance work. Contact your division industrial hygienist.
4. Demolition or Remodeling of Lead-Containing Areas. This work requires collaboration with your division industrial hygienist. There are extensive additional requirements for this type of work, including significant space limitations and frequently other safety issues. This work is normally done by a subcontractor and will include submission and acceptance of a Lead Compliance Work Plan in accordance with OSHA 29 CFR 1926.62 and Berkeley Lab’s Master Specification 028300. Exposure monitoring is also usually required.
5. Lead Paint Abatement
   1. Lead-paint abatement refers to construction activities undertaken specifically to remediate an imminent or potential hazard to humans or the environment from lead paint. This may include the removal, enclosure, or encapsulation of paint. If lead-paint abatement activities are to be conducted in a public building, CDPH Form 8551 must be completed, a copy posted at the work site, and a copy submitted to CDPH.
   2. Lead-abatement work performed by Berkeley Lab personnel or supplemental labor workers should be evaluated by an EHS industrial hygienist for determination of appropriate controls. A Lead Compliance Work Plan is normally required for lead-abatement work.
   3. Indoor lead-abatement areas should be subjected to a final visual inspection and final surface sampling in accordance with Department of Housing and Urban Development (HUD) guidelines. For designated public buildings, these inspections are mandatory.
6. Subcontract Work
   1. Subcontracted lead-abatement work should be conducted by a contractor licensed by the CDPH and in accordance with HUD guidelines. Subcontracted work is normally conducted subject to the Berkeley Lab Master Specification, Section 028300, Lead Abatement. For designated public buildings, these are actual requirements.
   2. Lead work conducted by subcontractors (other than supplemental labor) requires, before the operation begins, submission of either an NEA pursuant to the OSHA standard’s basis of initial determination for exposure assessment that is satisfactory to the EHS industrial hygienist, or the subcontractor’s Lead Compliance Program, which must incorporate all the elements specified in the standard. Contractors also are required to work in accordance with Facilities specifications and the guidance given in this document if lead is disturbed.
7. Engineering and Administrative Controls. With lead work, as with other work that generates airborne hazards, ventilation is a preferred method of control, as opposed to relying exclusively on PPE. Whenever ventilation is used on an ongoing project, measurements that demonstrate the effectiveness of the system must be employed at least every three months. If administrative controls are implemented to control exposures, the Laboratory will implement a rotation program in accordance with the requirements of the OSHA lead standard.
8. Personal Protective Equipment. Personal Protective Equipment (PPE) such as coveralls, shoe covers, head covers, gloves, and respirators is required for operations that may generate airborne lead levels above the PEL (50 µg/m3) and operations for which there is not an NEA. Safety shoes may be required for some operations. Leather gloves (or equivalent) must be used when handling un-encapsulated lead bricks or shielding. Additional requirements may be applicable if the exposure is known or expected to exceed 200 µg/m3. When required, such equipment shall be specified in an NEA, Hazard Evaluation, or Lead Compliance Work Plan that is reviewed by the EHS industrial hygienist. More information on PPE can be found in Chapter 10 Personal Protective Equipment.
   1. Protective Garments. Workers are usually issued reusable work coveralls in lieu of disposable coveralls. These coveralls shall not be worn home. Cleaning of reusable coveralls is the responsibility of Berkeley Lab (or the subcontractor for subcontracted work) and clean coveralls are provided to workers at least weekly, or daily if exposure levels exceed 200 µg/m3. Reusable clothing must comply with the cleaning and replacement requirements in the standards, including having the following label:
      
   2. Respiratory Protection. The EHS industrial hygienist shall select respirators, except those for subcontractors other than labor only, in conformance with the Berkeley Lab Respiratory Protection Program and all requirements from the OSHA standards, including presumptive tasks that require certain protection levels prior to an employee exposure assessment (see 29 CFR 1926.62, Table 1, for specific information).
      1. No worker shall be required to wear a negative-pressure respirator for more than 4.4 hours a day when feasible engineering controls are in place.
      2. Fit-test of respirators, when required, must be conducted within 12 months prior to lead work.
      3. If requested by the worker, and sufficient for the exposure, a tight-fitting powered air-purifying respirator will be provided in lieu of a negative-pressure respirator.

Work Process F. Waste Disposal

1. Consult your assigned Waste Management representative/generator assistant to determine proper waste-disposal practices. Additional information is also available in PUB-3092, Guidelines for Generators to Meet HWHF Acceptance Requirements for Hazardous, Radioactive, and Mixed Wastes at Berkeley Lab.
2. All waste should be double-bagged and labeled for the appropriate Satellite Accumulation Area (SAA) or 90-day Waste Accumulation Area (WAA) if more than 55 gallons of waste will be generated.

Work Process G. Exposure and Surface Contamination Monitoring

1. Air Exposure Limits and Biological Exposure Indices. Exposures to airborne lead and biological monitoring are evaluated against, and controlled below, the following regulatory limits:
   1. Title 8 CCR 5198, Lead. This standard applies to elemental lead, all inorganic lead compounds, and lead soaps, in non-construction work environments. It does not apply to other organic lead compounds. The Cal/OSHA eight-hour time-weighted permissible exposure limit (PEL) for metallic lead, any inorganic lead compound, or lead soaps is 50 µg/m3 of air averaged over an eight-hour period. The Action Level is 30 µg/m3 of air averaged over an eight-hour period. Employees who will be potentially exposed above the Action Level for 30 days or more must be enrolled into a lead medical surveillance program offered by the subcontractor employer or Berkeley Lab Health Services.
      Anyone working with lead under 30 days per year may enroll upon request.
   2. Title 8 CCR 5155, Air Contaminants. The corresponding eight-hour time-weighted PEL for tetramethyl and tetraethyl lead is 75 µg/m3 of air. There is no PEL for other organic lead compounds.
   3. Title 8 California Code of Regulations (CCR) 1532.1, Lead. This is the Cal/OSHA standard that applies to elemental lead, inorganic lead compounds, and lead soaps in construction activities. It does not apply to other organic lead compounds. The PEL for metallic lead, any inorganic lead compound, or lead soaps is 50 µg/m3 of air averaged over an eight-hour period. The Action Level is 30 µg/m3 of air averaged over an eight-hour period. CCR 1532.1 is the Cal/OSHA equivalent of the federal OSHA construction standard 29 CFR 1926.62, Lead, and is essentially the same.
   4. American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Values, Air Contaminants. Exposure limits for tetraethyl lead (100 µg/m3) and tetramethyl lead (150 µg/m3). Note: Exposure to these chemicals should be limited to75 µg/m3, the applicable OSHA standard for general industry.
   5. ACGIH, Biological Exposure Index (BEI) for Lead, as established by the (ACGIH) Threshold Limit Values. The ACGIH BEI for lead in blood is 30 µg/100 ml.
2. Personal Monitoring Program
   1. Personal air sampling must be conducted to assess an individual’s (or group’s) exposure to airborne lead during work that disturbs lead-containing materials. Initial samples are required for all operations where exposure above the action level may occur. The frequency of subsequent sampling depends on the results of the initial samples. The process for initiating and collecting air samples is as follows:
      1. Work supervisors must notify the EHS industrial hygienist at least 48 hours in advance of planned lead operations so that air sampling can be arranged.
      2. The EHS industrial hygienist or a technician working under the guidance of an industrial hygienist shall do the following:
         1. Collect the initial personal air samples for uncharacterized operations that may generate airborne lead, and submit them to an accredited analytical laboratory for analysis.
         2. If the results of the representative samples are below the action level and collected within the past twelve months, no further sampling is required as long as the operation continues unchanged. If the results are above the Action Level but below the PEL, air sampling must be repeated every three months, and a written compliance plan detailing the steps to be taken to reduce the airborne lead levels must be developed and implemented.
         3. The results of air sampling conducted to measure exposure during operations at the Laboratory may be used to represent the level of exposure for similar operations, if the results were collected within the past twelve months. The decision to accept these results, however, is at the discretion of the EHS industrial hygienist.
   2. Air monitoring results will be communicated to employees within five days of the receipt of final analytical results from the analyzing lab. For more complete details on lead exposure assessment, contact your industrial hygienist or refer to the appropriate OSHA lead standard.
3. Surface Contamination Limits
   1. When lead-containing materials are disturbed, residual surface contamination may pose a hazard to people who subsequently occupy the area. Additionally, break areas should remain free of harmful levels of lead. In such cases, surface sampling is sometimes conducted, as determined by the industrial hygienist. Generally, the following wipe criteria would be applied:

< 200 µg/ft2 for change areas, storage facilities, and lunchrooms/eating area

2. Similarly, the following housekeeping level for established lead work areas may be used:

< 1800 µg/ft2 on work surfaces in a designated lead area

This latter value is a housekeeping level that defines whether a designated lead work area is in need of cleaning. It is derived from Lawrence Livermore National Laboratory wipe-sampling protocols.

3. For work and break areas at Berkeley Lab, a higher or lower limit may be acceptable at the discretion of the EHS Division industrial hygienist.
4. For designated public buildings, the requirements of Title 17 CCR, Div. 1, Chapter 8 also apply. This regulation establishes the following criteria for surface contamination:
   1. 40 micrograms per square foot (40 µg/ft2) for interior floor surfaces; or
   2. 250 micrograms per square foot (250 µg/ft2)  for interior horizontal surfaces; or
   3. 400 micrograms per square foot (400 µg/ft2)  for exterior floor and exterior horizontal surfaces

4. Surface Contamination Sampling
   1. Floors and other surfaces in work areas where significant lead is disturbed should be tested for residual lead contamination before workers re-occupy those areas. Specifically, this guidance applies when the work involves any of the activities listed in Appendix B; when the work is lead hazard abatement, or involves exposure above the action level; and when the work area is inside and will subsequently be re-occupied on a regular basis.
   2. These samples are usually obtained by making two S-shaped swipes with a pre-wetted wipe at a 90° angle; over a 1-ft2 horizontal area and submitted to an analytical laboratory for analysis. Details on this sampling method can be found in HUD “Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing.” Samples are generally collected by EHS staff.
   3. Clearance swipe samples, where required for work performed by subcontractors, shall be obtained and analyzed by the subcontractor in accordance with the HUD guidelines. However, Berkeley Lab reserves the right to request changes in the sampling and analysis procedure or to obtain parallel clearance samples.
   4. The analytical laboratory must be accredited by the American Industrial Hygiene Association or another organization accredited by the EPA specifically to perform lead analyses.

37.8 Source Requirements

• 8 CCR 5198, Lead
• 8 CCR 1532.1, Lead in Construction
• 17 CCR, Division 1, Chapter 8, 35001-36100, Accreditation, Certification and Work Practice for Lead-Based Paint and Lead Hazards
• 8 CCR 5191, Occupational Exposure to Hazards in Laboratories
• 8 CCR 5155, Air Contaminants

Other Driving Requirements

• U.S. Department of Housing and Urban Development (HUD), Guidelines for the Evaluation and Control of Lead Based Paint Hazards in Housing
• American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Values, Air Contaminants

37.9 Implementing Documents

Document Number	Title	Type
07.07.005.001	Chemical Safety Hazards and Controls	Program

37.10 Appendices

Appendix A. Lead Compliance Work Plan Templates

For each of these examples, a specific Safe Work Procedure must be developed with your division industrial hygienist, based on a template that uses the five core functions of Berkeley Lab’s ISM Plan, before the work begins. All these examples follow the ISM template.

1. Lead Paint Removal Prior to Hot Work. Welding, brazing, or heating lead-painted surfaces is not allowed unless the paint has been removed to bare metal 6 inches from either side and behind the area to be worked.
   1. Define the Work
      1. Who, what, where, when, why, and how
      2. Plan the job with any subcontractor.
   2. Evaluate the Hazards
      1. Arrange for air monitoring and evaluation. This job must be monitored.
      2. If this job is similar to previous work that was monitored, air monitoring may not be required.
   3. Design the Controls. Consider local exhaust, respiratory protection, disposable coveralls, engineering controls, lead collection, disposal methods, labels, signs, cordoned-off area, hand washing, and cleanup.
   4. Work within the Controls
      1. Ensure that all controls are in place and working.
      2. Follow the HEPA Vacuum Safe Work Procedure (Appendix D).
   5. Feedback and Continuous Improvement. Send a copy of the Safe Work Practice to the Lead Program Manager with any comments for improvement.
2. Cleaning of Lead Bricks (or Shielding)
   1. Define the Work
      1. Estimate the number of lead bricks, or describe the shielding.
      2. Identify the condition of the lead: Is it clean with a dark appearance, or covered with white powdery lead carbonate?
      3. Decide if the lead bricks will be used again, and at what location, or will need to be removed from the area.
         1. Specify who will do the work and in what location.
         2. Has a radiological survey been performed on the lead?
   2. Evaluate the Hazards. Provide the above information to your division industrial hygienist, and work with him/her in evaluating the hazards and designing the controls.
   3. Design the Controls
      1. Considerations:
         1. Use the HEPA-filtered mobile lead brick-cleaning cart. Cordon off the work area.
         2. Use respiratory protection, gloves, disposable suit, and safety shoes.
         3. Tape the cleaned lead bricks, if possible for your application, with Permacel tape (recommended strong and only 2.5 mils thick).
         4. Follow the HEPA Vacuum Safe Work Procedure (Appendix D). Clean the area and cart with HEPA vacuum and wet-wiping after work.
         5. Dispose of protective gear after use. (Double 6-mil plastic bags are recommended.) If the garments are reusable, they should be labeled: “Caution: Clothing contaminated with lead.
         6. Do not remove dust by blowing or shaking.
         7. Dispose of lead-contaminated wash water in accordance with applicable local, state, or federal regulations.
   4. Work within the Controls. Develop a plan to meet all requirements so that nothing is forgotten. Monitoring is required until this procedure eliminates it.
   5. Feedback and Continuous Improvement. Send a copy of the Safe Work Practice to the Lead Program Manager with any comments for improvement.
3. Cutting or Machining of Lead Bricks or Other Lead Shielding. A specific written Safe Work Procedure is required for this work. It must follow or improve on this template.
   1. Define the Work
      1. Define how much cutting, machining, or handwork must be done; the priority; and other needs.
      2. Specify the location and who will perform the work.
   2. Evaluate the Hazards
      1. Work with your division industrial hygienist to evaluate the hazards. Review previous work monitoring.
      2. Band saws must have all cracks sealed and procedures for use and maintenance.
      3. Review employee’s or subcontractor’s experience with this work.
   3. Design the Controls
      1. All work must be HEPA exhausted or performed with other engineering controls.
      2. Work in a designated area that controls access.
      3. Provide respiratory protection as prescribed by the assigned industrial hygienist. Consider using double gloves, disposable suit, and shoe covers over safety shoes.
      4. All containers that may contain lead should be labeled “Contains Lead.” Follow the HEPA Vacuum Safe Work Procedure (Appendix C).
      5. All waste should be double-bagged and labeled for the appropriate Satellite Accumulation Area (SAA) or 90-day Waste Accumulation Area (WAA) if more than 55 gallons of waste is generated.
      6. Will the use of the HEPA-filtered mobile lead brick-cleaning cart add to the safety of handling the stock?
      7. Tape lead bricks, if possible for your application, with Permacel tape (recommended strong and only 2.5 mils thick).
   4. Work within the Controls
      1. Follow the HEPA Vacuum Safe Work Procedure (Appendix D). Assure that all engineering controls are working.
      2. Peel gloves off backward into the waste bags; then remove respirator.
      3. Shower at the end of each shift if exposure is expected to be over the PEL; or as a minimum, wash hands and face.
      4. Clean the area, cart, and all machinery or equipment with a HEPA vacuum and wet-wiping after work.
      5. Dispose of protective gear after use (double 6-mil plastic bags are recommended) and place properly closed and labeled container in the SAA or WAA for pickup. If the garments are reusable, they should be labeled: “Caution: Clothing contaminated with lead.”
      6. Do not remove dust by blowing or shaking.
      7. Dispose of lead-contaminated wash water in accordance with applicable local, state, or federal regulations.
   5. Feedback and Continuous Improvement. Send a copy of the Safe Work Practice to the Lead Program Manager with comments for improvements.
4. Handling More Than Five Lead Bricks or Other Lead Shielding
   1. Define the Work. Establish the scope of the work. For example, specify the number of lead bricks to be handled, their condition, and proposed disposition. If handling lead sheeting, specify the quantity and whether (and how) it will be cut or modified. Indicate where the work will be done and who will perform the tasks.
   2. Evaluate the Hazards. Plan the job with your division industrial hygienist. Air monitoring is normally conducted for these activities.
   3. Design the Controls
      1. Cordon off the area (use the sign in Appendix C, if necessary).
      2. Respiratory protection, gloves, disposable suits, training, and safety shoes will normally be required.
      3. Handle lead bricks and material carefully. Clean the area with HEPA vacuum and wet-wiping after work, following the HEPA Vacuum Safe Work Procedure (Appendix D).
   4. Work within the Controls. Follow the HEPA Safe Work Procedure in Appendix D. Wash hands after work, shower, if possible (or if it is required).
   5. Feedback and Continuous Improvement. Send a copy of the Safe Work Practice to the Lead Program Manager with any comments for improvement.
5. Installing Enclosure Booths in the Advanced Light Source (ALS) (or similar activities). Monitoring data show that this work does not pose an exposure risk for lead, but more monitoring is required for continued analysis. De-installing always requires industrial hygienist evaluation.
   1. Define the Work. Document the scope of the work. Indicate the type and quantity of work and who will do it and the location.
   2. Evaluate the Hazards. Plan the job with your division industrial hygienist. This job will generally require air monitoring.
   3. Design the Controls
      1. Cordon off the area (use the sign from Appendix C).
      2. Consider respiratory protection, gloves, disposable suit, and safety shoes.
      3. Clean the area with a HEPA vacuum after work, following the HEPA Vacuum Safe Work Procedure (Appendix D).
   4. Work within the Controls. Follow the HEPA Safe Work Procedure in Appendix D.
   5. Feedback and Continuous Improvement. Send a copy of the Safe Work Practice to the Lead Program Manager with any comments for improvement.

Appendix B. Berkeley Lab Lead Work Permit

This permit is used to supplement the standard controls specified in the Berkeley Lab Lead Program Document and EHS0330, Lead Worker Training program.

Appendix C. Lead Warning Signs and Labels

Appendix D. HEPA Vacuum Safe Work Procedure

1. HEPA vacuums must be labeled with the waste they collect. Dedicated vacuums for lead waste must be labeled: “Caution Contains Lead” or other similar language.
2. Inspect the vacuum before use for testing dates, electric cord flaws, labels, needed attachments, and function check.
3. Maintain the vacuum and change the filters in a designated area with engineering controls to avoid exposure. Gloves and respiratory protection are required. Exposure monitoring is required for all maintenance work. Contact your division industrial hygienist.

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