ADMS Electronic Source Document HeaderADMS Services

Ames Procedural
Requirements

APR 8715.1

Effective Date: 9/19/2011
Expiration Date: 9/19/2016

COMPLIANCE IS MANDATORY

NASA Ames Health and Safety Manual

Chapter 35 - Lead Management Plan

Table Of Contents

Document Log

35.1 Responsibilities
35.2 Lead Dust Clearance Levels
35.3 Prohibited Lead-Related Work Activities
35.4 Warning Signs
35.5 Procedures for Special Lead Activities
35.6 Analytical Laboratories
35.7 Definitions

Appendix A: Definitions
Appendix B: Acronyms
Appendix C: Lead Removal Inspection Form

Document History Log

Status (Base/Rev./Cancel Document Revision Effective Date Description

35.1 Responsibilities

35.1.1 Occupational Safety, Health and Medical Services Division shall:

  1. Oversee development and implementation of the Ames Lead Management Plan;
  2. Provide CDPH-certified lead inspectors/assessors/project monitoring services for lead-related work activities as requested;
  3. Review and evaluate the impact of regulatory changes on the Center;
  4. As requested, provide a thorough review and evaluation of lead abatement plans, specifications, and abatement contractor submittals prior to abatement;
  5. Verify that personnel who perform lead abatement work on NASA property have appropriate training and credentials to perform their assignment;
  6. Approve the selection of accredited laboratories used to analyze lead bulk/air/soil/water samples;
  7. Determine the need for baseline air monitoring or wipe sampling in occupied buildings;
  8. Periodically inspect the abatement area and contractor/subcontractor for compliance with the Ames Lead Management Plan;
  9. Establish criteria for post-abatement clearance inspection and testing and approve re-occupancy of buildings/areas upon a successful clearance testing;
  10. Provide lead hazard awareness training to employees that work with lead-containing materials or supervise employees that work with lead-containing materials;
  11. Maintain a central location for all lead management documentation.

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35.1.2 Project Managers and Contracting Officer's Technical Representatives (COTRs) shall:

  1. Ensure that a survey to determine the presence, location, and quantity of lead-containing material(s) has been conducted prior to any work performance. All painted surfaces located on NASA property are presumed lead-based paint;
  2. A copy of the survey shall accompany the construction permit for review. All painted surfaces located on NASA property are assumed to contain lead, unless written information is provided stating that specific surface coatings do not contain lead;
  3. Ensure that lead-related construction work activities are conducted in accordance with the laws, regulations, and guidance set forth in the Ames Lead Management Plan;
  4. Ensure that Occupational Safety, Health and Medical Services is notified of construction before the 30-percent design review phase, or ten days prior to maintenance-related lead work;
  5. Coordinate with Occupational Safety, Health and Medical Services to ensure that CDPH-certified lead personnel monitor any lead-related work activity;
  6. Provide CDPH notifications for inspections and/or abatement, etc., as required by CDPH;
  7. Provide the CDPH-certified lead personnel with accurate drawings and relevant information depicting the locations that shall be affected by any demolition/renovation, or maintenance activities;
  8. Require CDPH certified lead personnel provide oversight on lead related work and ensure that the CDPH certification is provided;
  9. Ensure that all construction specification documents that relate to lead specify the material, quantity, type, and location(s) of any lead-containing material to be removed;
  10. Provide notification to all building occupants prior to all lead-related work being conducted in occupied buildings;
  11. Ensure that the following documents are provided by the abatement contractor/subcontractor before any notice to proceed is granted. These documents shall be reviewed by a CDPH-certified lead individual for regulatory/NASA policy compliance:
  1. Lead abatement written compliance program;
  2. Site-specific health and safety plan with lead removal activities;
  3. Any/all training plans required by the scope of work;
  4. Site drawings that depict contractors/subcontractors removal methods, containment location(s), and emergency evacuation routing;
  5. Contractors/subcontractors Hazard Communication Program, including copies of any/all Material Safety Data Sheets (MSDS) for materials to be utilized during performance of work;
  6. Contractors/subcontractors Respiratory Protection Program;
  7. A copy of all applicable certificates, licenses/permits;
  8. A copy of contractors/subcontractors lead abatement supervisor(s) and lead abatement workers CDPH-certification cards authorizing them to conduct lead-related work;
  9. A copy of each employees biological monitoring, medical evaluations, and respirator-fit test certifications;
  10. A copy of hazardous waste landfill licenses/permits;
  11. A copy of hazardous waste haulers licenses/permits;
  12. Ensure that only NASA Environmental Services Office personnel sign the hazardous waste manifest(s);
  13. Ensure that maintenance personnel do not enter a regulated area without proper Personal Protective Equipment (PPE) and appropriate training;
  14. Ensure that all original laboratory reports and negative air pressure manometer records are provided to the Ames Occupational Safety, Health and Medical Services;
  15. Ensure that any contractor/subcontractors who conduct lead-related work on NASA property receive a copy of the Ames Lead Management Plan and sign a letter of receipt. Ensure that this document is incorporated as part of the required bid documents for each bidder;
  16. Provide proof of medical surveillance and successful completion of a lead physical evaluation to NASA Occupational Safety, Health and Medical Services before any NASA employee engages in lead-related work;
  17. Ensure that copies of all lead-related work documents are available, upon request, to the NASA Occupational Safety, Health and Medical Services;
  18. Endure that a copy of the site-specific health and safety plan is submitted to Code QH for review.

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35.1.3 CDPH-Certified Lead Inspector/Assessor/Project Monitor shall:

  1. Monitor compliance to the Ames Lead Management Plan;
  2. Conduct or oversee bulk/air sampling as requested by the Ames Occupational Safety, Health, and Medical Services and present findings in a user-friendly format;
  3. Assist in pre-lead abatement projects concerning bids, specifications, and procedures;
  4. Review contractor/subcontractor submittals for compliance with the Ames Lead Management Plan;
  5. Act as NASA ARC primary health and safety contact for inspection and compliance concerning lead-related work activities;
  6. Conduct pre-& post-lead abatement inspections;
  7. Submit CDPH form 8552 for work in public access facilities. Industrial faciliies, warehouses, tanks and buildings not open to the public are exempt;
  8. Conduct daily inspections on lead abatement projects including cleanup operations, and document these inspections. Notify the project manager and contracting officer of any contractor/subcontractor deficiencies;
  9. Should any deficiency pose an imminent safety and health hazard, the CDPH-certified individual shall stop the project and immediately follow up with the project manager and contracting officer;
  10. Determine final clearance criteria (visual inspection, wipe and/or air/bulk sampling) in concurrence with the Ames Occupational Safety, Health and Medical Services;
  11. Conduct area air monitoring on lead abatement projects as requested by the project manager or Ames Occupational Safety, Health and Medical Services;
  12. Provide proof of certification to Code QH.

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35.1.4 General Contractors Involved in Lead-Related Work shall:

  1. Exercise supervisory authority over all work covered by this chapter. As supervisor of the entire project, the general contractor shall comply and require all subcontractors to comply with the Ames Lead Management Plan, and all regulatory requirements including but not limited to the Department of Occupational Safety and Health Administration (OSHA), California Department of Public Health (CDPH), Bay Area Air Quality Management District (BAAQMD), and the Environmental Protection Agency (EPA);
  2. The general contractor shall ensure that the site lead abatement plan is submitted and approved by CDPH Lead Certified personnel and that all subcontractors comply with the plan;
  3. The general contractor shall ensure that CDPH Lead Certified personnel monitor the lead abatement;
  4. Notify the NASA project manager immediately upon discovery of any previously unidentified lead-containing material or material suspected of containing lead that will be disturbed.

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35.1.5 Lead Abatement Contractors/Subcontractors shall:

  1. Adhere to the Ames Lead Management Plan, and all Federal, State, and local regulatory agency regulations/guidelines that pertain to lead. Any deviations from the Ames Lead Management Plan shall have the approval of the NASA ARC Occupational, Safety, Health and Medical Service and the NASA project manager;
  2. NASA Ames will not be responsible for contractors/subcontractors failure to read and understand this chapter/policy;
  3. It is the sole responsibility of the contractor/subcontractor to perform exposure assessments and determine appropriate hazard control measures for their employees;
  4. Contractors shall assume that all painted surfaces located on NASA property contain lead, unless a lead survey written report is provided stating that specific surface coatings do not contain lead;
  5. All lead-related work, unless directed by the Ames Occupational, Safety, Health and Medical Service, shall be conducted under the surveillance of CDPH-certified lead personnel and approved by the Ames Occupational, Safety, Health and Medical Service;
  6. On multi-employer worksites, a contractor who performs work that requires the establishment of a regulated area shall inform other employers on the site of the nature of the employers work with lead, of the existence of the requirements that pertain to regulated areas, and the measures taken to ensure that employees of the other employer are not exposed to lead;
  7. Lead hazards at the contractors/subcontractors worksite shall be abated by the contractor/subcontractor who created the hazard;
  8. Notify the NASA project manager immediately upon discovery of any previously unidentified lead-containing material;
  9. All Storage/Disposal/Transport of waste shall be in compliance with Environmental Services and applicable regulations;
  10. The following documents shall be delivered to the project manager and approved before any lead-related work is conducted:
  1. Lead abatement written compliance program;
  2. Site-specific health and safety plan with lead removal activities;
  3. Any/all training plans required by the scope of work;
  4. Site drawings that depict contractors/subcontractors removal methods, containment location(s), and emergency evacuation routing;
  5. Contractors/subcontractors Hazard Communication Program, including copies of any/all Material Safety Data Sheets for materials to be utilized during performance of work;
  6. Contractors/subcontractors Respiratory Protection Program;
  7. A copy of all applicable certificates, licenses/permits;
  8. A copy of contractors/subcontractors supervisor(s) and workers DHS certification to conduct lead-related work;
  9. A copy of each employees biological monitoring, medical evaluations, and respirator fit- test certifications;
  10. A copy of hazardous waste landfill licenses/permits;
  11. A copy of hazardous waste haulers licenses/permits;
  12. There shall be no deviations from the contractors/subcontractors approved health and safety plan without prior consent of the Occupational Safety, Health and Medical Services and the NASA project manager.
  13. All contractors/subcontractors shall be responsible for conducting personal monitoring needed to demonstrate regulatory compliance;
  14. Copies of this monitoring shall be delivered to the contracting officer or representative within 48 hours. NASA may conduct area air-monitoring/wipe sampling at its discretion.
  15. If contractors/subcontractors or NASA monitoring results exceed regulatory limits, engineering controls and/or work practices and/or respiratory protection shall be modified for compliance;
  16. NASA has set the following process for clearance of buildings or areas prior to re-occupancy. A CDPH-certified lead inspector/assessor/project manager shall evaluate the adequacy of the contractor’s decontamination of the affected area before it is released for occupancy. The clearance process includes a visual inspection and air and surface dust sampling when appropriate. If it is determined by the CDPH certified lead professional that lead dust wipes will be collected for clearance then the following criteria will be used: 400 ug/ft2 on interior surfaces and 40 ug/ft2 on surfaces with high potential for hand to mouth contact In child occupied facilities (the child care center), public and residential buildings, the current CA CDPH, US EPA, or HUD regulations, whichever applies will be followed;
  17. When soil is affected by a lead abatement project, the Environmental Services Office shall be consulted to determine appropriate clearance levels for soil;
  18. All work areas shall be kept clean at all times, and thoroughly cleaned before the end of each shift;
  19. A CDPH certified lead inspector/assessor or project monitor shall visually inspect all work areas prior to the removal of any barriers, and approve removal of barriers. NASA may conduct final clearance visual inspections and sampling at its discretion;
  20. Should any work area not pass visual inspection and/or air/wipe sampling, the contractor/subcontractor shall re-clean the entire work area until approval to remove barriers is granted. The contractor/subcontractor is responsible for cleaning up any lead contamination inside/outside the work area that results from the contractors/subcontractors actions to the satisfaction of the DHS-certified lead project monitor;
  21. Any deviation from contractors/subcontractors original approved work plan shall be submitted as a request to the contracting officer and approved before changes are implemented. The contracting officer should allow a minimum of 48 hours to deny/approve procedures;
  22. NASA shall not be responsible for any job-related delays due to contractors/subcontractors request to change work practices/methods.

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35.1.6 The NASA Ames Acquisition Office shall:

  1. Require all contracts associated with lead-related work to include a copy of this entire document and to abide by its contents.
  2. Require, as part of the bid documents, a signed letter from the contractor/subcontractor stating they have read and understand the Ames Lead Management Plan.

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35.1.7 The NASA ARC Health Unit shall:

  1. Provide medical evaluations to NASA ARC employees for lead exposure as required by OSHA.
  2. Schedule and recall NASA ARC employees for lead-related medical evaluations as required by OSHA.
  3. Counsel concerned employees about the health risk of lead exposure.

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35.2 Lead Dust Clearance Levels

  1. NASA has set the following process for clearance of buildings or areas prior to reuse/re-occupancy. A CDPH-certified lead inspector/assessor/project manager shall evaluate the adequacy of the contractor’s decontamination of the affected area before it is released for occupancy.
  2. The clearance process includes a visual inspection and air and/or surface dust sampling when appropriate. If it is determined by the CDPH certified lead professional that lead dust wipes shall be collected for clearance then the following criteria is to be used: sample results collected at the work area are less than 400 micrograms per square foot (<400 ug/ft2) on interior surfaces and less than 40 micrograms per square foot (<40 ug/ft2) on surfaces with high potential for hand-to-0mouth contact. In child occupied facilities (the child care center), public and residential buildings, the current CA DHS, US EPA, or HUD regulations, whichever applies will be followed.

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35.3 Prohibited Lead-Related Work Activities

The following work practices and engineering controls shall not be utilized for lead-related work regardless of quantity, type, or operation:

  1. Use of power abrating tools that are not equipped with High Efficiency Particulate Air (HEPA)-filtered exhaust air.
  2. Dry scraping, dry sweeping, dry shoveling, non-HEPA vacuuming or other similar uncontrolled dry cleanup or removal of lead-containing material.
  3. Employee rotation as a means to reduce employee exposure to lead.
  4. Lead releases in excess of regulated levels without appropriate control and QH approval of written lead plan.
  5. Torch cutting, or any application of heat above 1100 deg. F to a lead-containing surface.

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35.4 Warning Signs

The following warning must be posted in each work area where the PEL may be exceeded:

WARNING
LEAD WORK AREA
POISON
NO SMOKING OR EATING

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35.5 Procedures for Special Lead Activities

Special lead work activities include:

35.5.1 Emergency Demolition/Renovation Operations:

  1. Before any lead-related work is conducted pursuant to and classified as an emergency demolition/renovation project, the Ames Occupational Safety, Health and Medical Services shall be notified and acknowledge notification.

35.5.2 Drilling Holes:

  1. Drilling holes into walls, which are coated with lead-containing material, may be performed as described in this section. Impermeable drop cloths shall be placed under/around area(s) to be drilled.
  2. Wet methods or HEPAassisted tools shall be used during the operation.
  3. Upon project completion, the area shall be cleaned using wet methods and/or HEPA vacuums.
  4. Notification shall be provided to the Ames Occupational Safety, Health and Medical Services, and acknowledged by the Ames Occupational Safety, Health and Medical Services prior to any drilling operation that affects lead painted surfaces.
  5. All persons who conduct this work shall have, at minimum, two-hour lead awareness training.

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35.6 Analytical Laboratories

All laboratories utilizes to perform lead analysis and relied upon to supply NASA with results shall be American Industrial Hygiene Association (AIHA) accredited and a National Lead Laboratory Accreditation Program (NLLAP) participant.

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Appendix A: Definitions

Abatement: A measure or set of measures designed to permanently eliminate lead-based paint hazards or lead-based paint.

Action Level (AL): Employee exposure, without regard to the use of respirators, to an airborne concentration of lead of 30 micrograms per cubic meter of air calculated as an 8-hour time-weighted average (30ug/m3 TWA).

Biological Monitoring: Baseline and post abatement blood lead-level measurements. This shall be conducted under the supervision of a licensed

Certified Industrial Hygienist: An individual certified in the comprehensive practice of industrial hygiene by the American Board of Industrial Hygiene.

Certified Lead Inspector/Assessor: An individual who has successfully completed a DHSapproved training course for lead inspectors/assessors and possess current DHS lead certification.

Certified Lead Project Monitor: An individual who as successfully completed a CDPH approved training course for lead project monitor and possess a current CDPH lead certification.

Certified Supervisor: An individual who is capable of identifying lead hazards in the workplace and who has sufficient experience and authority to take prompt corrective measures to eliminate them. An individual who has successfully completed an EPA-approved training course for supervisors and possess current DHS lead certification.

Compliance Program: Prior to the start of each job, an employer shall establish a compliance program that ensures that employees will not be exposed to airborne lead above the permissible exposure level (PEL). The plan must be written and include the following:

  1. Description of specific means utilized to reduce employee exposures below the PEL
  2. Air-sampling data
  3. Description of the work practices, including hygiene, personal protection, and housekeeping procedures
  4. Description of arrangements regarding notifying other contractors

Construction Work: Construction work is defined as work for construction, alteration, and/or repair, including painting and decorating. It includes but is not limited to the following:

  1. Demolition or salvage of structures where lead or materials that contain lead are present.
  2. Removal or encapsulation of materials that contain lead.
  3. New construction, alteration, repair, or renovation of structures, substrates, or portions there of that contain lead, or materials that contain lead.
  4. Installation of products that contain lead.
  5. Lead contamination/emergency cleanup operations.
  6. Transportation, disposal, storage, or containment of lead or materials that contain lead on the site or location at which construction activities are performed.
  7. Maintenance operations associated with construction activities.
  8. Construction work does not include making or keeping a structure, fixture, or foundation in proper condition in a routine, scheduled, or anticipated fashion.

Critical Barriers: One or more layers of at least six-mil polyethylene sheeting sealed over all openings into a work area or any other similarly placed physical barrier sufficient to prevent airborne lead/dust in a work area from migrating to an adjacent area.

Decontamination Area (D-Con): An enclosed area adjacent and connected to the regulated area and consisting of an equipment room, shower area, and clean room, which is used for the decontamination of workers, materials, and equipment that are contaminated with lead.

Demolition: Any operation that involves the wrecking or taking out of any load-supporting structural members of a facility.

Demolition/Renovation Survey: A survey conducted by a CDPH-accredited lead inspector/risk assessor to check for the presence of lead-containing materials prior to any demolition/renovation activities.

CDPH: California Department of Public Health.

Emergency Demolition: Demolition carried out pursuant to an order of a State or local Government agency because the building is structurally unsound and in danger of imminent collapse.

Emergency Renovation: Renovation that is not planned but results from a sudden, unexpected event. This includes operations necessitated by equipment failures and renovations due to fire, water, or earthquake damage, or where an imminent danger to the public health may exist.

Employee Exposure: The exposure to airborne lead that would occur if the employee were not using respiratory protective equipment.

Encapsulation: An abatement method that utilizes a thick coating material such as sealers or special bridging/penetrating compounds to prevent lead dust from being released.

Enclosure: The use of a rigid, airtight, impermeable, permanent barrier constructed to surround lead-containing materials and prevent the release of lead dust into the air.

Exposure Assessment: The process of defining exposure profiles and judging the acceptability of workplace exposures accomplished by performing personal monitoring. This assessment shall be redone whenever there is a change in work conditions or practices.

High-Efficiency Particulate Air (HEPA) Filter: A high-efficiency particulate air filter capable of removing particles 0.3 micrometers in diameter with 99.97-percent efficiency.

Lead-Based Paint: Any paint or other coating that contains any lead equal to or greater than 1.0 mg/cm2 or half of 1% by weight.

Lead-Related Construction Work: Disturbance of lead containing material that may cause significant lead exposure to persons via construction, alteration, painting, demolition, salvage, renovation, repair, maintenance work preparation or cleaning.

Permissible Exposure Limit (PEL): The maximum amount of lead that an employee be exposed to lead at concentrations greater than 50 micrograms per cubic meter of air calculated as an 8-hour time-weighted average (50ug/m3 TWA).

Presumed Lead-Based Paint: Paint or coating on a structure constructed before January 1, 1978. Tested paints or coatings are exempt when below the concentration defined for Lead-Based Paint.

Project Manager: An individual assigned to a specified project with the ultimate decision-making authority and responsibility for the project.

Public Building: A structure, which is generally accessible to the public, including but not limited to, daycare centers, museums, and stores.

Removal: All operations where lead-containing materials are taken out or stripped from structures or substrates (this includes demolition operations).

Renovation: Any operation that involves altering a facility or one or more facility components in any way.

Site-Specific Health and Safety Plan: A non-generic Health and Safety Plan. This plan shall be submitted prior to the start of any lead-related construction work and include:

  1. All methods utilized for compliance with the NASA Lead Management Plan, and all Federal, State, and local governing regulatory agency regulations/guidelines that pertain to lead
  2. All safety precautions and training appropriate/necessary to complete the scope of work as related to the specific contract
  3. Drawings that depict contractors/subcontractors abatement strategies/methods and containment(s) and negative- air machine(s) locations.
  4. The NASA ARC project manger shall approve this plan before any lead-related work is conducted.

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Appendix B: Acronyms

COTR: Contracting Officers Technical Representative.

CDPH: California Department of Public Health

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Appendix C: Lead Removal Inspection Form

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