Implementing Lead-Safe Work Practices for Steel
Structures
Transportation Agency Policies in Twelve States |
|
Pierre Erville
The Alliance to End Childhood Lead Poisoning
CPWR – Center for Construction Research and Training
Background
Discussion
of Survey Results
Obstacles
and Opportunities
Policy
Recommendations
Tables
1. Key survey findings Number of steel bridges
in each surveyed state, with states ranked by total number
Annex
A. State Summaries
California
Connecticut
Georgia
Louisiana
Maryland
Massachusetts
Michigan
New Jersey
New York
Ohio
Texas
Washington
Annex
B. Questionnaire Sent to State Transportation Agencies
Annex
C. Participating State Transportation Agencies
Maintenance of a vital infrastructure
has long been essential to our well-being as a nation. However, 40 years
after the construction of much of the nation's highways, the increased demand
for their restoration is paralleled only by the increased cost for such
work. State transportation agencies are increasingly being called on to
do more with less. Staff of 12 transportation agencies shared their valuable
time with us to help answer the questions in our survey. We hope their responses
will help us in developing strategies for restoring and maintaining safe
and viable highway structures, while assuring good working conditions and
a safe and healthful environment for the construction workers essential
to that task.
Those we would like
to thank include the following state Department of Transportation officials:
Pete Whitfield, California; Brian Castler, Connecticut; Don Wishon, Georgia;
Wayne Aymond and Francisco Gudiel, Louisiana; Paul Perkins, Bill Ransley,
Earle Freedman, and Tony Fusco, Maryland; Mike Fitzgerald, Massachusetts;
Sudhakar Kulkarni, Sonny Jadun, Ken Whelton, and Glenn Bukoski, Michigan;
Tony Pelligrino, Denny Diehl, Ralph Baliunas, and Robert McGlocklin, New
Jersey; Bill Howe and Paul Wells, New York; Jim Barnhart, Ohio; Clark
Titus, Texas; and Myint Lwin and Bob George, Washington State.
This report consists
of a summary and analysis of results of a survey of 12 state Departments
of Transportation (DOTs)1. The 12 states whose Dots were surveyed
are California, Connecticut, Georgia, Louisiana, Maryland, Massachusetts,
Michigan, New Jersey, New York, Ohio, Texas, and Washington.
The survey instrument
was developed by staff from the Alliance To End Childhood Lead Poisoning,
CPWR – Center for Construction Research and Training, the Mt. Sinai School of Medicine,
and the New York State Department of Health, as well as other members
of a working group that developed Model Specifications for the Protection
of Workers from Lead on Steel Structures. 2The purpose
of the survey was to establish each DOT's level of sophistication on lead-related
issues regarding worker and environmental protection and, more specifically,
to determine particular state characteristics, such as the annual budget
for bridge maintenance, repair, and demolition and the anticipated percentage
of such structures estimated to contain lead (see annex
A).
Departments of Transportation
in four of the states surveyed did not return completed questionnaires.
Instead, staff from agencies in Michigan, New Jersey, and Texas provided
some responses to most survey questions by telephone. Louisiana sent a
copy of the state specifications (see table 1 and
annex B).
1 Throughtout
this report, "DOT" refers only to state Departments of Transportation.
2Published
by CPWR – Center for Construction Research and Training, 1993.
Although this section
includes a policy analysis based on the survey data collected pursuant to
this project, it must be emphasized that the analysis is perforce limited
in scope and reliability by three factors.
First, the survey
instrument was not comprehensive enough to elicit all pertinent information
needed to draw useful conclusions. The parties involved in planning this
project agreed that the survey instruments should be relatively short
forms, to get as much pertinent information as possible without forcing
respondents to spend too much time responding to the questions. It was
felt that this would maximize our chances of getting respondents to fill
out and return the forms in a timely manner. As it turned out, in most
cases several phone calls were required to get Dots to return the completed
forms, and four Dots failed altogether to do so. Therefore, the assumption
that a short form would result in a higher percentage of returned questionnaires
was probably correct. However, the down side of this approach is that
less information was obtained than would be optimally desirable.
Second, relatively
little follow-up with respondents was planned or possible. Overall, DOT
respondents were less than anxious to cooperate with us on these questions.
This was not a surprise, as all parties involved in the planning of this
project anticipated that many Dots would be reluctant to share and discuss
weaknesses in their individual programs with us. As a result of this anticipated
reaction, telephone follow-up calls were generally limited to confirming
written responses and obtaining supplementary information and materials
whenever possible from cooperative DOT personnel.
Table 1. Key survey findings
State |
Budget
($ millions) |
Lead H&S
Specs? |
Structures
coated w/ lead-based paint |
Duration
of jobs (months) |
Extra training
required?a |
Stricter
worker-action levels?a |
Blood-lead
levels to DOT |
CA |
$39.945 |
No |
70% steel |
70%:<2 25%:2-12
5%:>12 |
No |
No |
No |
CT |
$63. - $114. |
Yes |
90%+ steel |
75%:2-12 15%:>12
1<%:<2 |
Yes |
Yes |
Yes |
GA |
$46. |
No |
85% steel 5%
concrete |
70%:<2 20%:2-12
10%:>12 |
No |
No |
Yes |
LA |
No Data |
No |
No data |
No data |
No |
No |
No |
MD |
$15. - $20. |
Yes |
99% steel and
concrete |
80% <2 18%
2-12 2% >12 |
Yes |
No |
No |
MA |
$27.+ |
Yes |
98% steel |
5% <2 65%
2-12 30% >12 |
No |
Yes |
Yes |
|
MI |
Est. $114. |
No |
50% steel |
(See note) |
No |
No |
No |
NJ |
$134. - $150.
|
Yes |
About 88% |
Avg. 1 yr |
No |
No |
Yes |
NY |
Est. $130.
|
Yes |
Most |
20% <2 60%
2-12 20% >12 |
No |
Yes |
Yes |
OH |
$21. |
No |
(See note) |
97% 2-12 3%
>12 |
No |
No |
No |
TX |
Up to $47.
|
No |
5% steel |
90% >2 10%
2-12 |
No |
No |
No |
WA |
$28.4 |
No |
95% steel 25% |
>2 65% 2-12
10% >12 |
No |
No |
No |
-
a. At issue
is whether DOT contract requirements exceed state and/or federal
standards.
- Note: In
Ohio, reportedly 80% of all steel structures and 20% of all concrete
structures slated for maintenance and repair are coated with lead-based
paint, as are 50% of all steel structures and 50% of all concrete
structures slated for demolition. Ohio contacts provided a July
1994 estimate of 2,530-3,089 bridges coated with lead-based paint.
Michigan contacts stated that 100% of all maintenance jobs take
less than 2 months to complete, 70% of all other jobs last between
2 and 12 months, and the remaining 30% last more than 12 months.
|
Third, survey responses
varied considerably in terms of the quality and the overall reliability
of the responses. It seems clear that much depended on who was filling out
the survey form or talking to us by telephone. In one case, contradictory
answers were provided by the individuals we interviewed and the survey form
was never returned to us.
In spite of the
above limitations, the survey results permit general observations, analysis,
and policy recommendations. Following are the key observations.
First, it seems
clear that of the bridges in the country likely to need maintenance, repair,
or demolition in the near future, most probably contain some lead-based
paint. Of the states surveyed, only Michigan and Texas claim their bridge
inventory is relatively free of lead, with these states reporting that
lead-based paint is on 50% and 5% of their bridges, respectively.3
Such assertions should be verified given that trends in other states indicate
that 70 to 99% of steel structures are coated with lead-based paints.
The overall pattern indicates an overwhelming likelihood that workers
involved in bridge maintenance, repair, and demolition are likely to encounter
lead-based paint in the course of their activities.
Second, lead health
and safety specifications were enhanced beyond federal and state law only
in northeastern and mid-Atlantic states.4 It seems to be no
coincidence that these are the regions of the country where lead poisoning
has been most widely acknowledged to be a problem. This suggests that
this geographic disparity is at least partly attributable to public awareness
of the hazards associated with lead exposure.
Third, in several
states,5 most jobs reportedly take less than two months to
complete. It is possible that a high frequency of short-duration jobs
reflects a greater volume of regular maintenance. Greater attention to
maintenance is desirable to the extent that it extends bridge life and
delays the need for more costly rehabilitation or demolition, which can
include extensive abrasive blasting and torch cutting. (Abrasive blasting
and torch cutting potentially produce the highest lead exposures.) It
is also possible, however, that the quick nature of the short-duration
jobs might result in greater attention to productivity and less attention
to safe work practices. This suggests that safety practices in those states
merit particularly close scrutiny.
Conversely, it can
be expected that in states where a significant percentage of the work
requires a year or so to complete, work practices are likely to be more
evolved and greater consideration is more likely to be given to health
and safety. 6Given that the states in this category have some
of the most health-protective requirements of the 12 surveyed, this assumption
seems to be borne out.
Fourth, DOT budgets
for maintenance, repair, and demolition of bridges varied considerably,
from a low of $15 million to $20 million in Maryland to a high of up to
$150 million in New Jersey. It is difficult to account for such variability.
On an optimistic note, greater budgets may reflect that work is being done
in a way that incorporates health and safety measures that add cost to projects.
Conversely, the availability of relatively large sums of money might conceivably
permit the state to rush to delead bridges before such work becomes more
expensive to undertake in light of heightened standards and more stringent
enforcement of safe work practices. Or, more simply, increased budgets may
reflect increased lead-painted bridge stock in a given state. The number
of steel bridges in each surveyed state is given in table 2.
Table 2. Number of steel bridges in each surveyed state, with states
ranked by total number
State |
Less than
60 feet |
Longer
than 60 feet |
Total
|
Ohio |
3,938 |
6,744 |
10,682 |
New York |
721 |
3,694 |
4,415 |
Michigan |
1,287 |
3,103 |
4,390 |
Georgia |
427 |
3,061 |
3,488 |
Texas |
135 |
3,156 |
3,291 |
Massachusetts |
409 |
1,771 |
2,180 |
Maryland |
520 |
1,605 |
2,125 |
New Jersey |
397 |
1,385 |
1,782 |
California |
181 |
1,236 |
1,417 |
Connecticut |
183 |
1,026 |
1,209 |
Washington |
257 |
646 |
903 |
Louisiana |
70 |
388 |
458 |
Source:
Coatings and Corrosion Costs of Highway Structural Steel. Federal
Highway Administration Report FHWA-RD-79-121; March 1980. |
Obstacles and Opportunities
The survey results point up
several obstacles to enhanced lead-related work practices and policies.
However, opportunities clearly exist to address the obstacles.
First and foremost,
a thorough understanding is needed of the potential risks involved in
this hazardous work. Those states that have documented significant lead
poisoning prevalence rates (including Connecticut, Maryland, Massachusetts,
New Jersey, and New York) have attempted to address the underlying causes
of worker exposures with enhanced specifications and other requirements
and innovations intended to reduce the risk of harmful lead exposures.
(It should be emphasized that each of these states has an occupational
blood-lead registry program, which is necessary to assess the magnitude
of occupational lead poisoning.) 7One obstacle blocking progress
elsewhere seems to be the relative lack of knowledge in most other states
in the country about this issue. The corresponding opportunity is to improve
awareness in those states through education and the establishment and
use of blood-lead surveillance systems. More focus on the lead issue needs
to occur through local unions, health departments, other appropriate organizations
(such as the Steel Structures Painting Council and the American Association
of State and Highway Transportation Officers [AASHTO]), and outreach efforts.
7 See
Occupational Blood-Lead Surveillance: Health Programs in Twelve States,
Washington, D.C.: CPWR – Center for Construction Research and Training, 1996.
Second, the cost issue
needs to be brought into sharper focus. Although several states surveyed
complained that costs had escalated due to worker and environmental protection
concerns, no mention was made about corresponding savings in terms of adverse
health effects avoided, the costs of medical treatment avoided, enhanced
worker productivity, and/or environmental remediation costs avoided, among
others. A thorough cost-effectiveness analysis reflecting such factors could
go a long way toward making such standard complaints about increased costs
of doing business look rather simplistic, and might also provide persuasive
arguments for policy makers interested in reducing overall state costs,
let alone simply protecting worker health and the environment generally.
Third, it seems
that not enough experimentation is occurring with some of the innovative
technologies that are thought to reduce worker exposure to lead. In most
cases, this problem refers back to the prior two obstacles cited --first,
that some of these states do not believe they have a lead poisoning concern
worth addressing (nor the data to prove otherwise) and, second, that many
of these states believe that switching to or experimenting with technologies
designed to reduce worker exposure will unnecessarily increase costs.
Thus, it appears that this third identified obstacle to progress in implementing
enhanced work practices and lead-related specifications is a function
of, or certainly related to, the first two.
A fourth obstacle
to progress identified through this survey is the predominant lack of
an appropriately trained state staff person to advise a DOT on health
and safety issues. Most Dots surveyed have an engineer on staff who serves
as "health and safety expert." This is in most cases insufficient to ensure
that health and safety concerns are being properly addressed. The lack
of appropriate formal training also makes it unlikely that such staff
can address health and safety problems in a truly preventive manner. It
is much more likely that such problems are reacted to, rather than anticipated
and prevented. This significant obstacle can be overcome by stressing
the importance of Dots hiring a professional industrial hygienist -- if
not as permanent staff, at least on an ongoing consulting basis. The presence
of such an individual would likely constitute more of a positive influence
on relevant DOT policy matters than would outreach efforts coming from
outside the DOT and potentially perceived by the DOT as far-fetched if
not hysterical. In addition, such a staff person is needed to review contractor
health and safety programs for lead before work proceeds.
Several policy recommendations
follow from the survey findings. Two apply at the state and federal levels.
- Supplement state
and federal law with additional specification requirements. The U.S.
Department of Transportation should require comprehensive measures to
protect workers and the environment against hazardous lead exposures.
In the interim, states should follow the examples of such Dots as those
in Connecticut and New York. In particular, state Dots should seriously
consider lowering their thresholds for medical removal and intervention,
as well as mandating appropriate worker training. The thresholds should
be set based on state-specific data on worker safety and health.
- In light of the
rapid development of new technologies for industrial lead abatement,
state agencies can play an important role in evaluating such technologies
and communicating their findings at meetings of professional, trade,
and industry forums. Federal agencies can assist in the identification
and evaluation of efficient technologies through investment in clean-technology
research and development.
The remaining policy recommendations apply to the state level.
- Include specific
health and safety costs in the contract specifications. This is already
being done by New York and has the effect of leveling the playing field
so that all contractors must provide the same minimal level of worker
protection.
- Require the lead
health and safety specifications to be highlighted. These important
specifications should be prominently featured in the overall contract
requirements. For instance, this would require the Ohio DOT to reorganize
its specifications so that the lead health and safety specifications
are given more prominence in the contract document.
- Require appropriate
worker training and contractor certification. While Title X may soon
require such training and certification, the US Department of Transportation
should institute these requirements immediately. In lieu of such federal
leadership, individual state Dots could do so. In addition to minimizing
the risk of adverse health exposures, such requirements could avoid
future problems, including a potential lack of qualified contractors
and workers once the federal mandates take effect.
- Hire a professional
industrial hygienist as part of permanent DOT staff in each state. As
discussed above, this could be the key to overcoming many of the current
obstacles to real progress in the area of worker protection from lead
exposures.
- Dots should require
that contractors use the support of professional industrial hygienists
in the development and oversight of lead health and safety programs.
Such a program should be monitored daily by an industrial hygienist
or by qualified personnel supervised by an industrial hygienist. A professional
industrial hygienist should visit each site weekly to ensure that its
lead health and safety program is up-to-date with current work activities.
- Require contractors
to use dust-minimizing technology. Uncontrolled abrasive blasting is
a dust-generating technology that should be phased out altogether. Instead,
local exhaust, vacuum-equipped, or similar technology should be more
widely encouraged as a dust-minimizing methodology. Nonabrasive methods
should also be more commonly explored, as should overcoating and other
newer methods. Consistent with recommendations made by NIOSH, silica
as a blasting abrasive should be strictly prohibited.
- Require contractors
to report blood-lead levels to Dots A lack of adequate DOT knowledge
about whether and how well workers are protected from lead exposures
at DOT sites is a critical flaw that must be addressed. By receiving
mandatory and frequent blood-lead level reports, Dots can help ensure
that safe practices are followed that do not result in elevated blood-lead
levels for workers and that contractors are instituting the controls
that state agencies are paying for. Additionally, Dots would then be
better able to track individual work sites and identify contractors
whose practices result in undesirable blood-lead levels. These contractors
would then presumably be under pressure to improve, or be eliminated
from consideration for future DOT jobs.
- Require pre-bid
conferencing. The US Department of Transportation should consider reinstating
the policy requiring pre-bid conferencing as a prerequisite to awarding
contracts for bridge work. In the absence of such a federally mandated
policy, Dots should nevertheless require attendance for all bridge and
steel structure contractors at pre-bid conferences to review project-specific
lead hazards and to discuss minimum control requirements.
- Require contractors
to have on hand and understand essential documents, including applicable
state and federal standards. A list of such materials is included in
Model Specifications for the Protection of Workers from Lead on Steel
Structures (CPWR – Center for Construction Research and Training, 1993). As Massachusetts
has done in its specifications, Dots may insert a clause in their specifications
requiring contractors to obtain copies of certain materials and to be
familiar with their contents. Dots should consider putting the model
specifications on such a list.
- Focus enforcement
efforts through better DOT staff training. Enhanced enforcement efforts
are likely to be one of the keys to better performance. Dots should
ensure that their staff are appropriately trained to critically evaluate
contractor performance on their lead health and safety programs. In
particular, enforcement efforts should target contractors whose records
indicate problems with worker protection and the effective implementation
of safe work practices.
- Establish better
ties within and among the states. Clearly, some Dots have evolved toward
safer work practices and more carefully crafted job specifications than
others. Better communication between Dots, through AASHTO for instance,
may well help set those now lagging behind on a course toward enhanced
lead-related job specifications. In addition, state health and labor
agencies can be important allies in these efforts, and vice versa. Interagency
collaboration, as demonstrated in Connecticut and New Jersey, maximizes
a state's ability to effectively enforce regulations and prevent lead
poisoning of workers and lead contamination of the community cost-effectively.
This section reports individual
state DOT responses to key survey questions. Where appropriate, the summary
quotes directly from the completed survey response. However, in many places
the summary paraphrases the actual response for purposes of clarity or brevity.
In several instances, no response was given to particular questions, or
if a response was given, it was ambiguous and/or the respondent was tentative.
In those cases, attempts at follow-up were made. However, in some instances
such follow-up yielded no clarification. In such cases, this section leaves
the question unanswered, marked with a dash (—).
Key questions were
determined by focusing on criteria designed to elicit information pertaining
to: the size of the DOT budget for potentially lead-related work; the
anticipated likelihood of encountering lead during the course of bridge
work; the typical duration of such work; the existence of lead health
and safety specifications that go beyond what is required under state
and federal law; the level of lead-related expertise applied by the DOT
in overseeing such work; whether Dots routinely receive reports of workers'
blood-lead levels; and an assessment of technologies being used or experimented
with to achieve greater worker and/or environmental protection (see
table 1).
- Estimated annual
budget: $39,945,000
- Percentage of
bridges and other elevated highway structures estimated to be coated
with lead-based paint: 70% of steel bridges
- Estimated duration
of projected work: 70% less than 2 months; 25 % bet. 2 and 12 months;
5% more than 12 months.
- Lead health and
safety specifications: None beyond OSHA
- DOT staff focused
on lead health and safety program: "District Safety Office and Headquarters
Safety Office review procedures, develop safety programs and procedures,
and advise field personnel."
- Training requirements
in addition to OSHA/EPA: None
- Blood-lead levels
reported to DOT: No
- Action levels
stricter than OSHA's: No
- Technologies
being evaluated and/or used to reduce worker exposure: Water blasting
with and without abrasives; hand tool cleaning; power tool cleaning;
shrouded tools; vacuum blasting; sand and water slurry blasting (torbo
system); copper slab with 15% Blastox abrasives.
- Difficulties
encountered with above technologies: "Low production rates, Increased
costs."
- Cost impact of
above technologies: "Unknown at this time."
- Technologies
being evaluated and/or used to reduce environmental exposure: Same
as those that reduce worker exposure.
- Effects of above
technologies on worker exposure: "Blastox: slight reduction in exposure
reported by vendor — not yet tested by [CALDOT]. Torbo: demonstration
looked very promising. Exposure levels for 15% lead paint at 10µg/m3."
- Cost impact of
above technologies: "No information except: Blastox mixed with copper
slag may be used in the kilning of Portland cement. Since this is considered
recycling, there is no long term liability. Torbo: significant increase
in production rates over most other cleaning methods (except open dry
blasting)."
- Additional remarks:
None
- Estimated annual
budget: Between $63 million and $114 million
- Percentage of
bridges and other elevated highway structures estimated to be coated
with lead-based paint: 90+% of steel structures
- Estimated duration
of projected work: 75% between 2 and 12 months; 15% more than 12
months; 10% less than 2 months.
- Lead health and
safety specifications: Required lump-sum fee to prepare and furnish:
written Lead Health Protection Program procedures; written record of
all employees participating in such program; procedure for instituting
medical surveillance including method and personnel involved; procedure
for employee notification; procedure for employee exposure assessment
with OSHA and CRISP guidelines; selection and justification of appropriate
respiratory equipment and protective clothing; procedure for conducting
employee training; written hazard communication procedures; written
personal hygiene procedures; monthly certification; monthly compliance
report; summary or annual reports. Also, weekly inspections
and certification that respirators are being cleaned properly; use of
CRISP forms to collect and report data to DOT; agreement to follow as
a minimum the testing guidelines provided by CRISP. (CRISP is Connecticut
Road Industry Surveillance Project.)
- DOT staff focused
on lead health and safety program: Office of Construction and District
offices oversee lead health and safety program development and execution.
Contractor must provide certified industrial hygienist.
- Training requirements
in addition to OSHA/EPA: Certified industrial hygienist must develop
and conduct job-specific training using CRISP/DOT guidelines.
- Blood-lead levels
reported to DOT: Site certified industrial hygienist provides blood-lead
levels to DOT.
- Action levels
stricter than OSHA's: Medical removal is triggered at 30 micrograms
per deciliter (µg/dl), with intervention at 20 µg/dl.
- Technologies
being evaluated and/or used to reduce worker exposure: Class 1 and
3 SSPC Guide 61 containment system (SSPC is Steel Structures Painting
Council.)
- Difficulties
encountered with above technologies: Not enough data
- Cost impact of
above technologies: Cost is minimal
- Technologies
being evaluated and/or used to reduce environmental exposure: "None
at this time."
- Effects of above
technologies on worker exposure: --
- Cost impact of
above technologies: --
- Additional remarks:
Attachments (to the returned survey form) included "State and Federal
Local Bridge Program" for Fiscal Year 1996. Also, CRISP is in danger
of being eliminated due to lack of funding. From July 1, 1995 to June
30, 1996, CRISP will continue to function albeit with a skeleton crew.
Currently no funding source has been found to maintain CRISP beyond
June 1996.
- Estimated annual
budget: $46 million
- Percentage of
bridges and other elevated highway structures estimated to be coated
with lead-based paint: 85% of steel structures and 5% of concrete
structures
- Estimated duration
of projected work: 70% less than 2 months; 20% between 2 and 12 months;
10% more than 12 months.
- Lead health and
safety specifications: Nothing beyond Federal requirements
- DOT staff focused
on lead health and safety program: None
- Training requirements
in addition to OSHA/EPA: Requires certification from contractor stating
that supervisors have had training
- Blood-lead levels
reported to DOT: Contractor reports blood-lead levels to DOT
- Action levels
stricter than OSHA's: None
- Technologies
being evaluated and/or used to reduce worker exposure: "SSPC. CL
3 that includes negative air and filtration equipment."
- Difficulties encountered
with above technologies: None
- Cost impact of
above technologies: --400% increase in cost when we required SSPC.
CL 3 containment.--
- Technologies
being evaluated and/or used to reduce environmental exposure: "SSPC
CL 3 that includes negative air and filtration equipment."
- Effects of above
technologies on worker exposure: Reduces dust in work area.
- Cost impact of
above technologies: 400% increase in cost when we required SSPC CL
3 containment.
- Additional remarks:
None
In addition to requiring compliance
with "all applicable Federal, State and Local laws and regulations and worker
protection and environmental protection requirements, -- the specifications
call for the following two supplementary elements:
- Contractor must
submit a written compliance plan to DOT for review 3 weeks prior to
beginning work.
- All personnel
hired for work on each lead-related project must have at least 2 years'
experience at their respective trades.
- Estimated annual
budget: $15 million -$20 million ü Percentage of bridges and
other elevated highway structures estimated to be coated with lead-based
paint: 99% of steel and concrete structures
- Estimated duration
of projected work: 80% less than 2 months; 18% between 2 and 12 months;
2% more than 12 months.
- Lead health and
safety specifications: Requires contractor to have a certified industrial
hygienist, who must "monitor worker exposure and ambient air before
and during cleaning operation at each bridge."
- DOT staff focused
on lead health and safety program: Certified Industrial Hygienist
representing DOT checks on field conditions and on the contractor's
certified industrial hygienist
- Training requirements
in addition to OSHA/EPA: Requires SSPC "QP-1" certification
- Blood-lead levels
reported to DOT: No
- Action levels
stricter than OSHA's: DOT's inspectors and project engineers are
removed from site if their blood-lead levels reach 20 µg/dl
- Technologies
being evaluated and/or used to reduce worker exposure: Containment
ventilation per SSPC Guide 61; vacuum power tools on small repair contracts.
- Difficulties
encountered with above technologies: High cost and the fact that
air-fed hoods and respirator and protection clothing are difficult to
work in.
- Cost impact of
above technologies: --Costs for cleaning and painting have risen
from $1-$2/square foot to $9-$13/sq ft.--
- Technologies being
evaluated and/or used to reduce environmental exposure: Vacuum power
tools
- Effects of above
technologies on worker exposure: "Worker safety has not been a problem."
- Cost impact of
above technologies: --Unknown.--
- Additional remarks:
DOT attached (to the completed survey form) copies of DOT's cleaning
and painting specifications and their lead and abrasive blasting protection
requirements.
- Estimated annual
budget: At least $27 million
- Percentage of
bridges and other elevated highway structures estimated to be coated
with lead-based paint: 98% of steel structures
- Estimated duration
of projected work: 65% between 2 and 12 months; 30% more than 12
months; 5% less than 2 months.
- Lead health and
safety specifications: Contractors are required to be familiar with
"various bulletins, guidelines and publications listed" in the specifications,
including two by SSPC, one by OSHA, and one by NIOSH. Contractors are
also required to submit all employees to monthly blood lead tests regardless
of blood lead levels. Medical removal at 40 µg/dl, with reinstatement
at two consecutive readings of 30 µg/dl. A CIH is required to prepare
and administer the Health and Safety Program for lead. -- A decontamination
/changing facility must be provided and used along with hot water washing
and respirator cleaning facilities.-- (CIH is certified industrial
hygienist.)
- DOT staff focused
on lead health and safety program: None
- Training requirements
in addition to OSHA/EPA: None
- Blood-lead levels
reported to DOT: Contractors required to report blood-lead levels
to DOT and DOH
- Action levels
stricter than OSHA's: Medical removal "at contractor's expense" if
blood-lead level reaches 40 µg/dl, with reinstatement when two consecutive
tests confirm levels at or below 30 µg/dl.
- Technologies
being evaluated and/or used to reduce worker exposure: Wet abrasive
blasting; chemical stripping; vacuum-assisted power tools.
- Difficulties
encountered with above technologies: Containment and disposal of
water run-off
- Cost impact of
above technologies: Wet abrasive blasting $3/square foot more cost-effective
than dry abrasive blasting
- Technologies
being evaluated and/or used to reduce environmental exposure: "None"
- Effects of above
technologies on worker exposure: --
- Cost impact of
above technologies: --
- Additional remarks:
Current specifications for cleaning and painting steel bridges are
attached.
- Estimated annual
budget: Approximately $114 million
- Percentage of
bridges and other elevated highway structures estimated to be coated
with lead-based paint: 50% of steel structures
- Estimated duration
of projected work: Less than 2 months for all maintenance jobs; for
all other jobs, 70% between 2 and 12 months and 30% more than 12 months.
- Lead health and
safety specifications:--
- DOT staff focused
on lead health and safety program: None (--Project manager--)
- Training requirements
in addition to OSHA/EPA: None
- Blood-lead levels
reported to DOT: No
- Action levels
stricter than OSHA's: No
- Technologies
being evaluated and/or used to reduce worker exposure: Vacuum blasting
- Difficulties
encountered with above technologies: --Workers don't like it. It
makes work too slow.---
- Cost impact of
above technologies: --Cost is not a concern.--
- Technologies
being evaluated and/or used to reduce environmental exposure: Ontario
Transportation Ministry's --Auto Blast-- made by Steinman Engineering
- Effects of above
technologies on worker exposure: No worker protection needed.
- Cost impact of
above technologies: Reduces costs by half and enables quicker work.
- Additional remarks:
None
- Estimated annual
budget: $134 million - $150 million
- Percentage of
bridges and other elevated highway structures estimated to be coated
with lead-based paint: About 88%
- Estimated duration
of projected work: Average about 1 year
- Lead health and
safety specifications: Require certified industrial hygienist on
site. Also require monthly blood-lead sampling and zinc protoporphyrin
counts. Also require post-employment or at least yearly physical exams
for all employees who had blood-lead level in excess of 40 µg/dl at
any time during their employment.
- DOT staff focused
on lead health and safety program: Certified industrial hygienist
or professional engineer with occupational health background
- Training requirements
in addition to OSHA/EPA: None
- Blood-lead levels
reported to DOT: Contractor required to report to DOT.
- Action levels
stricter than OSHA's: --
- Technologies
being evaluated and/or used to reduce worker exposure:--
- Difficulties
encountered with above technologies: --
- Cost impact of
above technologies: --Cost of work has probably gone up five times
in the last five or six years.--
- Technologies
being evaluated and/or used to reduce environmental exposure: --
- Effects of above
technologies on worker exposure: --
- Cost impact of
above technologies: --
- Additional remarks:
None
- Estimated annual
budget: Approximately $130 million
- Percentage of
bridges and other elevated highway structures estimated to be coated
with lead-based paint: Most
- Estimated duration
of projected work: 60% between 2-12 months; 20% less than 2 months;
20% more than 12 months
- Lead health and
safety specifications: Provides contract bid items to allow direct
payment to contractors for: 1) Development and implementation of a Lead
Health and Safety Program - paid on a lump sum basis prorated over the
course of the job; 2) Development of a Lead Exposure Control Plan, paid
on a lump sum basis on receipt; 3) Medical testing and exposure monitoring
sample analysis, paid as cost plus 5% for overhead and profit; 4) Decontamination
facilities, paid on a weekly basis. Also require qualified industrial
hygienist to provide oversight of all aspects of contractors' lead health
and safety program.
- DOT staff focused
on lead health and safety program: Regional Construction Safety Coordinators
are responsible for implementing NYDOT lead Health and Safety program
on individual projects and for monitoring contractors' programs. Central
Office Construction Division staff make Quality Assurance visits to
selected projects.
- Training requirements
in addition to OSHA/EPA: Contractors required to provide documentation
that OSHA training was completed.
- Blood-lead levels
reported to DOT: Contractors required to submit all medical monitoring
data.
- Action levels
stricter than OSHA's: Intervention by an industrial hygienist if
an increase of 10 µg/dl or more is observed between consecutive tests
for any individual worker.
- Technologies
being evaluated and/or used to reduce worker exposure: Alternative
paint-removal techniques required; special ventilation and filtration
requirements for containment systems; vacuum blasting; power tool cleaning
to bare metal with vacuum attachment; chemical stripping; wet abrasive
blasting.
- Difficulties
encountered with above technologies: Vacuum blasting: irregular surfaces,
rivet heads, and sharp-angled steel members present problems in acquiring
a perfect seal at the vacuum head; vacuum blast method is very slow
and the equipment is unwieldy to use. Power tool (vacuum shrouded) cleaning:
needle gun could not prepare the surface to Commercial Blast Cleaning
standards (SSPC-SP6). Chemical stripping: rust and mill scale were not
effectively removed, an alkaline residue was present on the surface
which would have to be neutralized if paint were to be applied. Steel
surfaces prepared by chemical removal methods do not meet Commercial
Blast Cleaning standards (SSPC-SP6) and would not be acceptable for
painting without further cleaning. Chemical removal methods do not impart
a surface profile for proper coating adhesion. Wet abrasive blasting
poses such problems as worker safety endangerment due to slippery footing
created by sludge, containment requirements for reduced dusting conditions
and for the collection of water, and the need for chemical rust inhibitors.
- Cost impact of
above technologies: Costs could be expected to be somewhat higher
than those for open abrasive blasting using expendable abrasives. Low
dusting abrasives bear a higher cost than those that pulverize upon
impact (like Black Beauty).
- Technologies
being evaluated and/or used to reduce environmental exposure: Class
A and localized containment systems, as well as alternative paint removal
techniques expected to reduce both worker and environmental lead exposure.
- Effects of above
technologies on worker exposure: Reduced worker exposure in Class
A containment structures, thanks to ventilation and filtration; no worker
exposure outside containment structures.
- Cost impact of
above technologies: Class A containment increases painting costs
210 to 270%.
- Additional remarks:
None
- Estimated annual
budget: $21 million
- Percentage of
bridges and other elevated highway structures estimated to be coated
with lead-based paint: 80% of all steel structures and 20% of all
concrete structures slated for maintenance and repair; 50% of all steel
structures and 50% of all concrete structures slated for demolition.
- Estimated duration
of projected work: 97% between 2 and 12 months; 3% more than 12 months.
- Lead health and
safety specifications: None beyond OSHA
- DOT staff focused
on lead health and safety program: None
- Training requirements
in addition to OSHA/EPA: None
- Blood-lead levels
reported to DOT: None
- Action levels
stricter than OSHA's: None
- Technologies
being evaluated and/or used to reduce worker exposure: Vacuum blasting,
dry ice, chemical strippers.
- Difficulties
encountered with above technologies: Vacuum blasting was extremely
slow and impossible on flange edges, cross frame angles, bolt heads
and tight corners. Dry ice was extremely low and not productive. Chemical
strippers still require sandblasting to provide anchor pattern.
- Cost impact of
above technologies: More than doubles the cost of performing the
work.
- Technologies
being evaluated and/or used to reduce environmental exposure: Nothing
at this time.
- Effects of above
technologies on worker exposure: --
- Cost impact of
above technologies: --
- Additional remarks:
As of July 29, 1994, Ohio DOT's bridge inventory lists 2530 bridges
with lead-based paint, plus an additional 559 that could possibly contain
lead-based paint. Attached DOT memo dated August 3, 1994 estimates that
"at our current pace, we could have all lead removed in approximately
9 years. Based on today's average cost of $205,000 to paint a bridge,
our total cost to paint all remaining lead coated bridges would be $518,650,000,
of which approximately one half would be borne by FHWA.
- Estimated annual
budget: $47 million at most
- Percentage of
bridges and other elevated highway structures estimated to be coated
with lead-based paint: 5% of steel structures and no concrete structures
are lead-coated
- Estimated duration
of projected work: 90% less than 2 months; 10% between 2 and 12 months.
- Lead health and
safety specifications: Nothing beyond Federal requirements
- DOT staff focused
on lead health and safety program: None
- Training requirements
in addition to OSHA/EPA: None
- Blood-lead levels
reported to DOT: "Only on case-by-case basis."
- Action levels
stricter than OSHA's: None
- Technologies
being evaluated and/or used to reduce worker exposure: acuum blasting
and "grinder enclosed shrouded tools."
- Difficulties
encountered with above technologies: "No data"
- Cost impact of
above technologies: "No data"
- Technologies
being evaluated and/or used to reduce environmental exposure: "Total
containment"
- Effects of above
technologies on worker exposure: "No data"
- Cost impact of
above technologies: Doubled cost of projects
- Additional remarks:
None
- Estimated annual
budget: $28.4 million
- Percentage of
bridges and other elevated highway structures estimated to be coated
with lead-based paint: 95% of all steel structures
- Estimated duration
of projected work: 65% between 2 and 12 months; 25% less than 2 months;
10% more than 12 months.
- Lead health and
safety specifications: Nothing beyond Federal requirements
- DOT staff focused
on lead health and safety program: No
- Training requirements
in addition to OSHA/EPA: None
- Blood-lead levels
reported to DOT: No
- Action levels
stricter than OSHA's: Medical removal of DOT staff at 30 µg/dl, with
return at 25 µg/dl.
- Technologies
being evaluated and/or used to reduce worker exposure: Shrouded tools;
vacuum blasting; encapsulation products.
- Difficulties
encountered with above technologies: None
- Cost impact of
above technologies: --
- Technologies
being evaluated and/or used to reduce environmental exposure: Vacuum
blasting; vacuum tools; Blastox.
- Effects of above
technologies on worker exposure: Reduced worker exposure to lead
dust; disuse of full containment reduces risk of injury and death by
falling while rigging.
- Cost impact of
above technologies: Under development.
- Additional remarks:
"Our main problem with implementing any environmental or health safety
program is that the rules are continually changing, it seems that we
are always in a state of flux. For example: we were told that zinc would
not be regulated by the EPA; now, after zinc has been adopted as a primer
constituent in lieu of lead the Journal of Protective Coatings &
Linings states that zinc will probably be regulated as a hazardous
material. This hit and miss method of regulation needs to be reformed.
Your
name and title:
Phone Number:
Fax Number:
National
Survey
A.
Condition of Infrastructure and Projected Workload
(The
questions in this section are intended to gather information and demolition
work involving the disturbance of lead-based paint on bridges and other
elevated highway structures. If you cannot give a precise answer to
any of these questions, please respond with your best estimate.)
1.Please
state your agency's projected annual budget for work involving:
- a. maintenance
of bridges and other elevated highway structures: $
- b. repair
of those structures: $
- % repair
work
- % painting/re-coating
- c. demolition
of those structures:
2.
Please estimate the respective anticipated Federal contributions and
State contributions for each of a, b, and c above.
- a. % Federal
$ $ % State $ $
- b.
- % Federal
$ $ % State $ $
- % Federal
$ $ % State $ $
- c. % Federal
$ $ % State $ $
3.
Please estimate the percentage of those structures that are steel structures
versus the percentage that are concrete:
- a. % steel
structures
- b.% concrete
structures
4.
Please estimate the percentage of those structures that you anticipate
are coated with lead-based paint:
- a.
- % of maintenance
work on steel structures
- % of
maintenance work on concrete structures
-
-
b.
- % of repair
work on steel structures
- % of
repair work on concrete structures
-
c.
- % of demolition
work on steel structures
- % of
demolition work on concrete structures
5.
Please estimate the anticipated duration of projected work:
- a. % of jobs
less than 2 months duration
- b. % of jobs
between 2 and 12 months duration
- c. % of jobs
greater than 1 year's duration.
B.
Environmental & Occupational Lead Exposure Prevention
(Please
provide details about current or planned programmatic initiatives to
protect workers and the environment from hazardous exposures to lead.)
1.
Does your state DOT have written contract specifications related to
lead health and safety for workers? If so, could you please send us
a copy?
- a. When were
these specifications written?
- b. Have they
been modified since the 1993 OSHA lead in construction standard
were issued? If so, how were they modified?
2.
Does your state DOT have written contract specifications related to
the prevention of environmental exposures to lead? If so, could you
please send us a copy?
- a. When were
these specifications written?
- b. What prompted
their development?
3.
Does your state DOT have specific staff whose duties include development
and/or execution of a worker lead health and safety program? If so,
please indicate their involvement.
- a. At the
contract bid review level?
- b. At the
lead health and safety program development level?
- c. At the
lead health and safety program execution level?
And
please indicate what if any professional qualifications are required
for this staff position:
4.
Does your state DOT impose specific worker and supervisor training requirements
for contractors with respect to lead? If so, what are they, who is responsible
for conducting the training, and how do you verify that training requirements
have been met?
5.
Does your state DOT receive blood lead level reports on workers employed
by contractors on DOT sites? If so, are these reports submitted by your
state's health department or by the individual contractor?
- a. Has your
agency established any threshold blood lead level, or any specific
increase in individual blood lead levels over time, either of which
is stricter than what OSHA requires? If so, what action is triggered
when?
C.
Technologies Designed for Prevention of Occupational and/or Environmental
Exposures
1.
What technologies are being evaluated and/or used to reduce worker
exposure to lead in your state DOT's maintenance, repair, and/or demolition
efforts on bridges and other elevated highway structures? (e.g. shrouded
tools)
- a. How are
these technologies being evaluated to determine their effectiveness
in reducing lead exposures?
- b. What if
any difficulties have you encountered with these technologies?
- c. For each
technology evaluated, please estimate the cost impact of utilizing
the technology:
2.
What technologies are being evaluated and/or used to reduce environmental
exposure to lead in your state DOT's maintenance, repair and/or demolition
efforts on bridges and other elevated highway structures?
- a. What effects
have each of these technologies had on worker protection or exposure?
- b. For each
technology evaluated, please estimate the cost impact of utilizing
the technology:
Finally,
do you know of any studies evaluating the condition of your state's
transportation infrastructure, particularly relating to bridges and
other elevated highway structures? If so, would you be so kind as to
send us a copy of their conclusions and/or executive summaries?
California Department of Transportation
1120 N Street
Sacramento, CA 95814
Phone: 916-654-5266
Mailing Address: P.O. Box 942873
Sacramento, CA 94273-0001
Connecticut Department
of Transportation
2800 Berlin Turnpike
Newington, Connecticut 06111
860-594-3000
Georgia Department
of Transportation
2 Capitol Square
Atlanta, Georgia 30334
404-656-5260
Louisiana Department
of Transportation
and Development
PO Box 94245, Capitol Station
Baton Rouge, LA 70804-9245
504-379-1200
Maryland Department
of Transportation
State Highway Administration
707 North Calvert Street
Baltimore, Maryland 21202
410-333-1122
Mailing Address: PO Box 717
Baltimore, Maryland 21203-0717
Massachusetts Highway
Department Transportation Building
Room 3510
10 Park Plaza
Boston, Massachusetts 02116-3973
617-973-7000
Michigan Department
of Transportation
425 West Ottawa
PO Box 30050
Lansing, MI 48909
517-373-2090
New Jersey Department
of Transportation
1035 Parkway Avenue
Trenton, New Jersey 08625
609-530-2001
New York State Department
of Transportation
1220 Washington Ave.
State Campus, Bldg. 5
Albany, New York 12232
518-457-4422
Ohio Department
of Transportation
25 South Front Street
Columbus, Ohio 43215
614-466-2335
Texas Department
of Transportation
Dewitt C. Greer Bldg.
11th and Brazos Streets
Austin, TX 78701-2483
516-463-8585
Washington State
Department of Transportation
Highway Administration Building
Maple Park Drive
Olympia, Washington 98504
360-705-7054
This document appears in the eLCOSH website with the permission of the author
and/or copyright holder and may not be reproduced without their consent.
eLCOSH is an information clearinghouse. eLCOSH and its sponsors are not
responsible for the accuracy of information provided on this web site, nor
for its use or misuse.
July 1995
This report was produced under contract for CPWR – Center for Construction Research and Training by the Alliance to End Childhood Lead Poisoning. The contract, totaling
$25,000, was supported by grant number U02/CCU310982 from the National Institute
for Occupational Safety and Health (NIOSH). The report's contents are solely
the responsibility of the author and do not necessarily represent the official
views of NIOSH.
Readers of this
report may also want to consult a companion document by Mark Goldberg
and others, Occupational Blood Lead Surveillance of Construction Workers:
Health Programs in Twelve States (report OSH2-96).
©Copyright
1996, CPWR – Center for Construction Research and Training. All rights reserved. For
permission to reproduce this document or for bulk copies, please write
to CPWR, 8484 Georgia Ave, Suite 1000, Silver Spring, MD 20910 (report
OSH1-96).
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