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Questions and Potential Impacts Facing Industrial Painting
The reduction of the NAAQS for lead from 1.5 μg/m3 as a 90 day average to 0.15 μg/m3 may have immediate and long-term impacts on the painting industry. While it is difficult to predict the impact, there are several scenarios and questions to be considered.
Should We Keep Using the NAAQS for Lead?
The most immediate question is whether the painting industry at-large, technical organizations such as SSPC and facility owners should continue to use the NAAQS for Lead as a basis for evaluating containment and ventilation system performance?
The health information provided in the standard makes a compelling argument not only for the reduction of the limit to 0.15 μg/m3 but also that there is a higher than previously suspected risk for public health, welfare and the environment at lower ambient lead levels.
Historical monitoring information from a few projects in the painting industry suggests that in urban areas, the 0.15 μg/m3 limit could be exceeded by the background values. The data also indicates that our current containment and ventilation technology or implementation of such may not be sufficient to meet the 0.15 μg/m3 limit.
The industry (SSPC, facility owners and other stakeholders) may need to re-evaluate the need for higher levels of emission control to meet the 0.15 μg/m3 limit should it be invoked, and how this might be achieved. This could include new focus on improvements to containment materials, seals and maintenance, and possible reduction of the limits for visible emissions. From a ventilation standpoint it could include improvements in overall ventilation system design and performance, and improvements in dust collector efficiency.
Meeting the Revised NAAQS for Lead
Agencies and facility owners with a specification that invokes the NAAQS for lead should consider how they will address this issue for the upcoming 2009 painting season and beyond.
Owners may want to allow for subtraction of background values from project monitoring results. If TSP – Lead air monitoring continues to be used to demonstrate containment and ventilation system performance, the approach to monitoring and analysis will have to change.
To measure levels of lead at or below 0.15 μg/m3 using high-volume TSP monitors, the monitors will likely need to be run for a 24-hour duration in order to achieve air volumes necessary for the lower reporting limits. Sample analysis may need to be conducted using methods that will achieve lower detection limits of lead on the filter. This will likely increase the cost for monitoring overall.
Compliance with this lower limit will likely increase overall costs of paint removal projects due to necessary improvements in containment / ventilation, increased monitoring durations and the likelihood for more frequent down time due to exceedances.
Will OSHA revise the lead standard, such as reducing the Permissible Exposure Limit (PEL) or allowable Blood Lead Levels (BLL)? Will they require more frequent air or blood
monitoring? Should facility owners, contractors and labor organizations be more focused on worker exposures to lead given this new information on the potential impact of airborne lead?
What Happens When Areas are Considered “Non-Attainment?”
States that have non-attainment areas will have to revise their State Implementation Plans (SIP) to outline how they will come into attainment. This typically includes new or tougher regulations (such as requiring air pollution control equipment on previously unregulated lead emitting facilities), licensing programs, and other policies aimed at the types of facilities or operations performed in the non-attainment areas that are contributing to lead levels in ambient air. SIPs can even focus on a single source or a particular operation (e.g. abrasive blasting) within a non-attainment area. The preamble of the revised Standard acknowledges it may be necessary to implement controls on non-industrial sources (e.g. construction projects) in order to achieve attainment.
Summary
The revised NAAQS for Lead requires that our professional organizations like SSPC and PDCA consider their positions and our industry’s approach to meeting these regulatory changes.
Our professional organizations, such as SSPC will need to address the changes brought by this regulation into existing training and certification programs, reference documents, and standards. Owners and specification writers will need to consider on a short-term basis how to address contracts and specifications already in-place for 2009 as well as their long-term approach. We all must consider the risk of tort litigation (alleging harm) if these lower levels are exceeded near sources of lead emissions and whether or not we can control emissions at this level.
NATIONAL EMPHASIS PROGRAM – LEAD (CPL 03-00-009)
Background
Site Selection
Unlike the previous NEP, the revised NEP establishes Site-Specific Targeting guidelines. It includes a targeted list of industries with historical lead exposures, as well as companies identified through the NIOSH Adult Blood Lead Epidemiological Surveillance (ABLES) database. Over 40 states participate in the ABLES program. ABLES data from 2003-2004 projects that between 5.7 to 7.5 % of adults for every 100,000 have BLL’s above 25 μg/dL and 94% were due to occupational exposure. The NEP directs Area OSHA offices to work with state agencies which maintain blood lead registries to identify employers of workers where BLL have been reported by a laboratory to be above 25 μg/dL.
Complaints / Referrals
The NEP requires the investigation of every complaint where a potential for lead exposure exists. It also requires the investigation of all referrals (public or private) alleging employee blood lead levels at or greater than 25 μg/dL and/or involving take-home exposures (this would likely be triggered by an elevated BLL in a child resulting in an investigation of lead sources in the home). NOTE: The previous NEP established referrals levels at 40 μg/dL.
Inspection Procedures
Inspections are to include the items below:
The NEP indicates the likelihood for increased OSHA inspections on all types of projects in 2009. Based upon the stated Site Specific Targeting guidelines, DOT projects will likely be targeted as well as contractors with employees whose BLL’s are reported by a laboratory to be above 25 μg/dL. According to the NEP, over 40 states are actively participating in the ABLES program and are reporting BLL’s to OSHA. The NEP requires follow-up evaluations which may result in more serious, or willful violations.
With OSHA evaluating BLL’s at 25 μg/dL (15 μg/dL lower than the regulatory threshold) and the implications of some of the health effects data presented by EPA in their basis for the reduction of the NAAQS for Lead, does our industry once again need to improve our technology and implementation to better control public health and worker exposures to lead?
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