DJ CONSULTING
SOUTHWESTERN ELECTRICAL CO., INC.
August 2015
TO: ALL EMPLOYEES
SUBJECT: LEAD/CADMIUM METAL EXPOSURE POLICY
PURPOSE:
The purpose of this policy is to identify the dangers of Lead and Cadmium while performing a job where you could be exposed to these. All safety precautions will be obeyed to prevent an overexposure. SOUTHWESTERN ELECTRICAL CO., INC. does not do Lead Abatement. This policy will be used in the event that an employee is exposed to lead above the PEL.
LEAD
SUBSTANCE DATA SHEET FOR OCCUPATIONAL EXPOSURE TO LEAD
Substance Identification
1. Substance: Pure lead (pb) is a heavy metal at room temperature and pressure and is a basic chemical element. It can combine with various other substances to form numerous lead compounds.
2. Compounds: The word "lead" when used in this program means elemental lead, all inorganic lead compounds and class of organic lead compounds called lead soaps.
3. Uses: Exposure to lead occurs in at least 120 different occupations, including primary and secondary lead smelting, lead storage, battery manufacturing, lead pigment manufacturing and use, solder manufacturing and use, and removal of lead based paint.
4. Permissible Exposure: The permissible Exposure Limit (PEL) set by the OSHA standard is 50 micrograms of lead per cubic meter of air (50 ug/m3), averaged over an 8 hour workday.
5. Action Level: The established action level of 30 micrograms per cubic meter of air (30 ug/m3), time-weighted average, based on an 8 hour workday.
HEALTH HAZARD DATA
WAYS IN WHICH LEAD CAN ENTER YOUR BODY.
1. When absorbed into your body in certain doses, lead is a toxic substance. The objective of the OSHA lead standard is to prevent absorption of harmful quantities of lead. The OSHA standard is intended to protect you not only from the immediate toxic effects of lead but also from the serious toxic affects the may not become apparent until years of exposure have passed.
2. Lead can be absorbed into your body by inhalation (breathing) or by ingestion (eating). Lead (except for certain organic lead compounds not covered by OSHA standard, such as tetraethyl lead) is not absorbed through the skin. When lead is scattered in the air as a dust, fume or mist, it can be inhaled and absorbed through your lungs and upper respiratory tract. Inhalation of airborne lead is generally the primary source of occupational lead absorption. You can also absorb lead through your digestion system if lead gets into your mouth and is swallowed. If you handle food, cigarettes, chewing tobacco or make up which have lead on them or handle them with hands contaminated with lead, this will contribute to ingestion.
3. A significant portion of the lead that you inhale or ingest gets into your blood stream. Once in your blood system, lead is circulated throughout your body and stored in various organs and body tissues. Some of this lead is quickly filtered out of your body excreted, but some remains in the blood and other tissues. As exposure to lead continues, the amount stored in your body will increase if you are absorbing more lead than your body is excreting. Even though you may not be aware of any immediate symptoms of disease, this lead stored in your tissues can be slowly causing irreversible damage, first to individual cells, then to your organs and whole body systems.
EFFECTS IF OVEREXPOSURE TO LEAD
1. Short-term (acute) overexposure. Lead is a potent, systemic poison that serves no known useful function once absorbed by your body. Taken in large enough doses, lead can kill you in a matter of days. A condition affecting the brain called acute encephalopathy may arise which develops quickly to seizures, coma, and death from cardiorespiratory arrest. A short-term dose of lead can lead to acute encephalopathy. Short-term occupational exposures of this magnitude are highly unusual, but not impossible. Similar forms of encephalopathy may, however, arise from extended, chronic exposure to lower doses of lead. There is no sharp dividing line between rapidly developing acute effects of lead and chronic effects which take longer to acquire. Lead adversely affects numerous bodies systems and causes forms of health impairment and disease which arise after periods of exposure as short as days or as long as several years.
2. Long-term (chronic) overexposure. Chronic overexposure to lead may result in severe damage to your blood-forming, nervous, urinary and reproductive systems. Some common symptoms of chronic overexposure include loss of appetite, metallic taste in the mouth, anxiety, constipation, nausea, pallor, excessive tiredness, weakness, insomnia, headache, nervous irritability, muscle and joint pain or soreness, fine tremors, numbness, dizziness, hyperactivity and colic. In lead colic there may be severe abdominal pain.
3. Damage to the central nervous system in general and the brain (encephalopathy) in particular is one of the most severe forms of lead poisoning. The most severe, often fatal, form of encephalopathy may be preceded by vomiting, a feeling of dullness progressing to drowsiness and stupor, poor memory, restlessness, irritability, tremor, and convulsions. It may arise suddenly with the onset of seizures, followed by coma, and death. There is a tendency for muscular weakness to develop at the same time. This weakness may progress to paralysis often observed as a characteristic "wrist-drop" or "foot-drop" and is manifestation of a disease to the nervous system called peripheral neuropathy.
4. Chronic overexposure to lead also results in kidney disease with few, if any, symptoms appearing until extensive and most likely permanent kidney damage has occurred. Routine laboratory tests reveal the presence of this kidney disease only after about two-thirds of kidney function is lost. When overt symptoms of urinary dysfunction arise, it is often too late to correct or prevent worsening conditions, and progression to kidney dialysis or death is possible.
5. Chronic overexposure to lead impairs the reproductive systems of both male and female. Overexposure to lead may result in decreased sex drive, impotence and sterility in men. Lead can alter the structure of sperm cells raising the risk of birth defects. There is evidence of miscarriage and still birth in women whose husbands were exposed to lead or who were exposed to lead themselves. Lead exposure may also result in decreased fertility and abnormal menstrual cycles in women.
The course of pregnancy may be adversely affected by exposure to lead since lead crosses the placental barrier and poses risks to developing fetuses. Children born of parents either one of whom were exposed to excess lead levels are more likely to have birth defects, mental retardation, or behavioral disorders or to die during the first year of childhood.
6. Overexposure to lead also disrupts thee blood-forming systems resulting in decreased hemoglobin (the substance in the blood that carries oxygen to the cells) and ultimately anemia. Anemia is characterized by weakness, pallor and fatigue as a result of decreased oxygen-carrying capacity in the blood.
HEALTH PROTECTION GOALS OF OUR COMPANY.
1. Prevention of adverse health effects for workers from exposure to lead throughout a working lifetime requires that worker blood lead levels (PbB) be maintained at or below forty micrograms per one hundred grams of whole blood (40 ug/100g). The blood lead levels of workers (both male and female workers) who intend to have children should be maintained below 30 ug/100g to minimize adverse reproductive health effects to the parents and the developing fetus.
2. The measurement of blood lead levels is the most useful indicator of the amount of lead being absorbed by your body. Blood lead levels (PbB) are most often reported in units of milligrams or micrograms of lead (1 milligram = 1000 micrograms per 100 grams (100g), 100 milliliters (100ml) or deciliter (dl) of blood. These three units are essentially the same. Sometime PbB's are expressed in the form of milligrams % or micrograms %. This is a shorthand notation for 100g, l00ml, or dl.
3. PbB measurements show the amount of lead circulating in the blood stream but do give any information about the amount of lead stored in various tissues. PbB measurements merely show current absorption of lead, not the effect that lead is having on your body or the effects that past lead exposure may have already caused. Research into lead-related diseases, however, has focused heavily on associations between PbBs and various diseases.
As a result, the relative level of PbB is an important indicator of the probability of acquiring a lead-related health impairment or disease.
4. Once the blood lead level climbs above 40 ug/100g, the risk of disease increases. There is a wide variability of individual response to lead thus it is difficult to say that a particular PbB in a given person will cause a particular effect. Studies have associated fatal encephalopathy with PbBs as low as 150 ug/100g. The provisions of the OSHA standard were designed with this in mind. SOUTHWESTERN ELECTRICAL CO., INC. has the prime responsibility to assure that the provisions of the OSHA standard are complied with both by the company and the employee. You as an employee, under the OSHA standard, also have a responsibility to assist SOUTHWESTERN ELECTRICAL CO., INC., in complying with the OSHA standard. You can play a key role in protecting your own health by learning about lead hazards and their control, learning what the OSHA standard requires, following the OSHA standard where it governs your own actions, just as the company complies with the OSHA standard where it governs your own actions, just as SOUTHWESTERN ELECTRICAL CO., INC. complies with the OSHA provisions governing their actions.
REPORTING SIGNS AND SYMPTOMS OF HEALTH PROBLEMS.
1. You should immediately notify SOUTHWESTERN ELECTRICAL CO., INC. management if you develop signs or symptoms associated with lead poisoning or if you desire medical advice concerning the effects of current or past exposure to lead on your ability to have a healthy child.
2. You should also notify SOUTHWESTERN ELECTRICAL CO., INC. if you have difficulty breathing during the respiratory fit test or while wearing a respirator. In each of these cases, SOUTHWESTERN ELECTRICAL CO., INC. will make available to you appropriate medical examinations or consultations.
Permissible Exposure Limit (PEL)
1. The OSHA standard sets a permissible exposure limit (PEL) of fifty micrograms of lead per cubic meter of air (50 ug/m3), averaged over an 8-hour workday. This is the highest level of lead in the air to which you may be permissibly exposed over an 8-hour workday. Since it is an 8-hour average, it permits short exposure above the PEL so long as for each 8-hour workday your exposure does not exceed the PEL.
2. A description of specific means that will be employed to achieve compliance and where engineering controls are required engineering plans and studies used to determine methods selected for controlling exposure to lead.
3. Report of technology considered in meeting the PEL will be listed.
Exposure Monitoring
1. If lead is present in any quantity in our workplace SOUTHWESTERN ELECTRICAL CO., INC. will require and make an initial determination of whether the action level is exceeded for our employees. This initial determination will include instrument monitoring of the air for the presence of lead and will cover the exposure of a representative number of employees who are reasonably believed to have the highest exposure levels. We will conduct the appropriate air sampling for lead levels in our workplace or jobsite.
2. If the air sampling determines that our employees have been exposed to lead, (which would occur if the employee(s) were not using a respirator) we will notify the employee(s) in writing of the air sampling results within five (5) working days.
3. If employee exposure is revealed to be at or above the action level but below the permissible exposure limit Southwestern Electrical Co,. Inc. will repeat air monitoring at least every 6 months. This air monitoring will continue until at least 2 consecutive measurements, taken at least 7 days apart, are below the action level.
Note: SOUTHWESTERN ELECTRICAL CO., INC. will require their clients to inform them if there is lead above the PEL on any job site. When the lead level is above the PEL SOUTHWESTERN ELECTRICAL CO., INC. will conduct industrial hygiene monitoring to determine the airborne concentrations of lead associated with our service. This monitoring will document the source of lead emissions.
COMPLIANCE
1. Where any employee is exposed to lead above the permissible exposure limit for more than 30 days per year, SOUTHWESTERN ELECTRICAL CO., INC. shall implement engineering and work practice controls (including administrative controls – this can be reducing the time an employee is in the work area and wearing a respirator) to reduce and maintain employee exposure to lead. Whenever the engineering and work practice controls are not sufficient to reduce employee exposure to or below the permissible exposure limit, SOUTHWESTERN ELECTRICAL CO., INC. shall nonetheless use them to reduce exposure to the lowest feasible level and shall supplement them by the use of respiratory protection.
Respiratory Protection:
1. Under the OSHA standard SOUTHWESTERN ELECTRICAL CO., INC. is required to provide and assure that our employees use respirators when exposure to lead is not controlled below the PEL by other means. SOUTHWESTERN ELECTRICAL CO., INC., will provide respirators to employees at no cost. Respirators shall be used in the following circumstances:
a. Whenever an employee's exposure to lead exceeds the PEL;
b. In work situations in which engineering controls and work practices are not sufficient to reduce exposures to or below the PEL;
c. Whenever an employee requests a respirator; and
d. An interim protection for employees performing:
(a) Abrasive Blasting
(b) Welding
(c) Cutting, and
(d) Torch Burning
2. Respirator Selection:
a. Where respirators are used SOUTHWESTERN ELECTRICAL CO., INC. will select the appropriate respirator or combination of respirators from the attached table; (see attachment III).
b. SOUTHWESTERN ELECTRICAL CO., INC. will provide a powered, air-purifying respirator in lieu of the respirator specified in Table I (attachment III) whenever:
(1) An employee chooses to use this type of respirator; and
(2) This respirator will provide adequate protection to the employee.
3. SOUTHWESTERN ELECTRICAL CO., INC. will select respirators from among those approved for protection against lead dust, fume, and mist by the Mine Safety and Health Administration (MSHA) and the National Institute for Occupational Safety and Health (NIOSH) under the provisions of 30 CFR part 11.
Respirator Program:
SOUTHWESTERN ELECTRICAL CO., INC. has instituted a respirator program in accordance to 29 CFR 1910.134 (b), (d), (e) and (f).
1. An air purifying respirator is any respirator which has a filter, cartridge or canister which cleans the work room air as you breath it. The typical air purifying respirator is a negative pressure respirator because it requires force of your inhalation to draw air through the filtering element. It is less protective than a powered air purifying respirator (PAPR) which also has a filter, cartridge or canister to clean the air, but a power source SOUTHWESTERN ELECTRICAL CO., INC., might make a PAPR available to you to ease the burden of having to wear a negative pressure air purifying respirator for long periods of time. The OSHA standard provides the employee can obtain a PAPR upon request.
2. Supplied-air respirators are also available which as the name implies, are respirators to which breathing quality air is supplied from a source such as an air compressor, blower or compressed air cylinder. The three types of supplied-air respirators that are available are; demand, pressure demand, and continuous flow. The demand-type requires the force of inhalation to open a diaphragm valve thus admitting air from the supply source. As any leakage around the facepiece will permit the entrance of contaminated air, the demand-type only provides protection generally equivalent to that of the typical negative pressure air purifying respirator of the same facepiece type. Greater protection is provided by either the pressure-demand or continuous-flow types as positive air pressure exists within the respirator at all times.
3. The OSHA standard requires that SOUTHWESTERN ELECTRICAL CO., INC. must assure that your respirator facepiece fits properly. Proper fit of a respirator facepiece is critical and no single face iece fits all facial configurations equally well. Obtaining a proper fit thus may require that the company makes available two or three different mask types in order that facepiece leakage is minimized for each employee. In order to assure that your respirator fits properly and that face piece leakage is minimized, SOUTHWESTERN ELECTRICAL CO., INC. must give you a (quantitative fit test" on a semiannual basis if you use a negative pressure respirator having any face piece other than the half-mask type.
4. Under OSHA standard SOUTHWESTERN ELECTRICAL CO., INC. must also provide you with a medical examination to determine that you are medically qualified to wear a respirator prior to the issuance of a respirator. The results of this examination may be to give you a positive pressure respirator (which reduces breathing resistance) or to provide alternative means of protection.
Protective Work Clothing and Equipment.
1. Employees exposed to lead above the PEL, or if employees are exposed to lead compounds
such as lead arsenate or lead oxide which can cause skin and eye irritation, SOUTHWESTERN ELECTRICAL CO., INC. will provide the employee protective work clothing and equipment appropriate for the hazard. Work clothing will be given to employee(s) in a clean and dry condition at least weekly, and daily if their exposure to airborne lead is greater than 150 ug/m3. appropriate protective work clothing and equipment may include coveralls or similar full-body work clothing, gloves, hats, overshoes or disposable shoe coverlets, face shields or vented goggles. Protective Clothing shall be in clean and dry condition at least weekly. Protective clothing shall be cleaned, laundered, properly disposed and repaired or replaced as necessary. PPE will be provided and maintained to the employee at no cost to the employee.
Housekeeping
1. SOUTHWESTERN ELECTRICAL CO., INC. has established a housekeeping program.
Hygiene Facilities and Practices
When the PEL is exceeded we will assure that food and beverage is not present or consumed, tobacco products will not be present or used, and cosmetics are not applied, except in the change rooms. Change rooms, showers, and lunchroom, if available, must be used by our workers exposed to lead in excess of the PEL. After showering, no clothing or equipment worn during the shift may be worn home.
Medical Surveillance
1. The medical surveillance program is part of the OSHA standard's comprehensive approach to the prevention of lead-related disease. Its purpose is to supplement the main thrust of the OSHA standard which is aimed at minimizing airborne concentration of lead and sources of ingestion.
2. Compliance with the OSHA standard's provision will protect most workers from the adverse effects of lead exposure, but may not be satisfactory to protect individual workers
(1) who have high body burdens of lead acquired over past years,
(2) who have additional uncontrolled sources of non-occupational lead exposure,
(3) who exhibit unusual variations in lead absorption rates, or (4) who have specific (e.g., renal disease, anemia). In addition, control systems may fail, or hygiene and respirator programs may be inadequate.
3. Periodic medical surveillance of individual workers will detect those failures. Medical surveillance will also be important to protect your reproductive ability regardless of whether you are a man or woman.
4. All medical surveillance will be performed by or under the supervision of a licensed physician.
5. Medical surveillance will be made available to all employees who are exposed in the excess of the action level (without regard to the use of respirators) for more than 30 days a year.
6. An initial medical examination will also be made available (prior to assignment) for each employee being assigned for the first time to an area where concentration of airborne lead equals or exceeds the action level. In addition, a medical examination or consultation will be made available as soon as possible if you notify the company that you are experiencing signs or symptoms commonly associated with lead poisoning or that you have difficulty breathing while wearing a respirator or during a respirator fit test.
7. Blood lead and ZPP level sampling and analysis will be made available to covered employees, and at least every 6 months thereafter. At least every 2 months for each employee whose last blood sampling and analysis indicated a blood lead level at or above the 40 ug/100 g of whole blood. This frequency shall continue until two consecutive blood samples and analyses indicate a blood level below the 40 ug/100 g of whole blood. The sampling will be monthly during the removal period of each employee from exposure to lead due to an elevated blood lead level. Follow-up blood sampling tests, whenever the results of blood lead level test indicate that an employee’s blood level lead exceeds the numerical criterion for medical removal under the OSHA 1910.1025 (k)(1)(i)(A). The employer shall provide a second (follow-up) blood sampling test within two weeks after the employee receives the results of the first blood sampling test.
8. Employee notification. Within five (5) working days after the receipt of biological monitoring results, the employer shall notify in writing each employee whose blood lead level exceeds 40 ug/100g: of that employee’s blood lead level and that the standard requires temporary medical removal with Medical Removal Protection benefits when an employee’s blood lead level exceeds the numerical criterion for medical removal. See Attachment I
9. All medical expense will be at no cost to the employee.
TRAINING
A. In addition to the lead standard employees must receive training. SOUTHWESTERN ELECTRICAL CO., INC. employees will receive training on the following subjects:
a) Personal Protective Equipment
b) Respiratory Protection
c) Hazard Communications
d) Housekeeping
e) First Aid
f) Confined Space Entry
g) Electrical Safety
h) General Safety and Health
i) Appendices A & B of 29 CFR OSHA 1910.1025
B. SOUTHWESTERN ELECTRICAL CO., INC. will communicate information concerning lead hazards according to the requirements of OSHA's Hazard Communication Standard including but not limited to the requirements concerning warning signs and labels, material safety data sheets (MSDS).
C. All employees will be trained on the Medical Surveillance program and the Medical Removal program. This training will cover the benefits provided by the Medical Removal program. The training will also cover the adverse effects on the reproductive system.
D. Lead Safety Training will include specific nature of operations which could result in exposure to lead above the action level.
E. Training will include the purpose, proper selection, fitting, use and limitations of respirators.
F. Training will include the engineering controls and work practices associated with the employee’s job assignment including training of employees to follow relevant good work practice.
G. Training will include the contents of any compliance plan in effect.
H. Training will include the instructions to employees that chelating agents should not be routinely used to remove lead from their bodies and should not be used except under the direction of a licensed physician.
I. All affected employees are required to attend training prior to initial assignment and annually thereafter.
Access to information and training material. (Relevant Material)
a) SOUTHWESTERN ELECTRICAL CO., INC. will make readily available to all affected employees a copy of this standard and it appendices.
b) SOUTHWESTERN ELECTRICAL CO., INC. will provide, upon request, all materials relating to the employee information and training program to affected employees and their designated representatives, and to the Assistant Secretary and the Director.
SIGNS
SOUTHWESTERN ELECTRICAL CO., INC. employees will not enter this area when this sign is posted.
WARNING
LEAD WORK AREA
POISON
NO SMOKING OR EATING
SOUTHWESTERN ELECTRICAL CO., INC. will insure that no statement appears on or near any Lead Warning sign that contradicts Or detracts from the meaning of the required sign. SOUTHWESTERN ELECTRICAL CO., INC. will insure that the signs required are Illuminated and cleaned as necessary so that the sign is readily visible.
WRITTEN COMPLIANCE PROGRAM
SOUTHWESTERN ELECTRICAL CO., INC. will develop a written plan for each location where the lead level is above the PEL. The written plan will include the following:
* Description of each operation in which lead is emitted, e.g. machinery used, material processed, controls in place, crew size, employee job responsibilities, operating procedures, and maintenance practices;
* Specific means that SOUTHWESTERN ELECTRICAL CO., INC., INC will employed to achieve compliance, including engineering plans and studies used to determine methods selected for controlling exposure to lead;
* A report of technology considered in meeting the permissible exposure limit;
* Air monitoring data which documents the source of lead emissions;
* A detailed schedule for implementation of the program, including documentation such as copies of purchase orders for equipment, construction contracts, etc;
* A work practice program
* An administrative control schedule if applicable.
The Written programs shall be submitted upon request to the Assistant Secretary and the Director, and Shall be available at the worksite for the examination and copying by the Assistant Secretary, Director, any affected employee or authorized employee representatives.
Job site will be inspected frequent and regular by a competent person
Relevant information will be incorporated into the Written Program.
The Written programs shall be revised and updated at least every 6 months to reflect the current status of the program.
See attachment V.
Recordkeeping
SOUTHWESTERN ELECTRICAL CO., INC. will establish and maintain an accurate record of all monitoring and other data used in conducting employee exposure assessments as required.
Exposure monitoring records shall include the following:
a) Date(s), number, duration, location and results of each of the samples taken in any, including a description of the sampling procedure used to determine representative employee exposure where applicable.
b) A description of the sampling and analytical methods used and evidence of their accuracy.
c) The type of respiratory protective devices worn, if any.
d) Name, social security number and job classification of the employee monitored and of all other employees whose exposure the measurement is intended to represent.
SOUTHWESTERN ELECTRICAL CO., INC. will inform all contractors on a Multi Contractor job site if they are involved in a job where the lead is above the PEL. The job site supervisor will be responsible for notifying all other contractors that are working in the area.
CADMIUM:
I. Substance Identification
A. Substance: Cadmium
B. 8-hour, Time-weighted-average, Permissible Exposure Limit (TWA PEL):
1. TWA PEL: Five micrograms of cadmium per cubic meter of air 5ug/m3, time-weighted average (TWA) for an 8-hour workday. Action Level of 2.5 micrograms (ug) per cubic meterof air (m3).
C. Appearance: Cadmium metal - soft, blue-white malleable, lustrous metal or grayish-white powder. Some cadmium compounds may also appear as brown, yellow, or red powdery substance.
II. Health Hazard Data
A. Routes of Exposure.
Cadmium can cause local skin or eye irritation. Cadmium can affect your health if you inhale it or if you swallow it.
B. Effects of Overexposure.
1. Short-term (acute) exposure: Cadmium is more dangerous by inhalation than by ingestion. High exposure to cadmium that may be immediately dangerous to life or health occur in jobs where workers handle large quantities of cadmium dust or fumes; heat cadmium-containing compounds or cadmium-coated surfaces; weld with cadmium solders or cut cadmium-containing material such as bolts.
2. Severs exposure may occur before symptoms appear. Early symptoms may include mild irritation of the upper respiratory tract, a sensation of constriction of the throat, a metallic taste and/or a cough. A period of 1-10 hours may precede the onset of rapidly progressing shortness of breath, chest pain, and flu-like symptoms with weakness, fever, headache, chills, sweating and muscular pain. Acute pulmonary edema usually develops within 24 hours and reaches a maximum by three days. If death from asphyxia does not occur, symptoms may resolve within a week.
3. Long-term (chronic) exposure. Repeated or long-term exposure to cadmium, even at relatively low concentrations, may result in kidney damage and an increased risk of cancer of the lung and prostrate.
C. Emergency First Aid Procedures.
1. Eye exposure: Direct contact may cause redness or pain. Wash eyes immediately with large amounts of water, lifting the upper and lower eyelids. Get medical attention immediately.
2. Skin exposure: Direct contact may result in irritation. Remove contaminated clothing and shoes immediately. Wash affected area with soap or mild detergent and large amounts of water. Get medical attention immediately.
3. Ingestion: Ingestion may result in vomiting, abdominal pain, nausea, diarrhea, headache and sore throat. Treatment for symptoms must be administered by medical personnel. Under no circumstances should the employer allow any person whom he retains, employs, supervise or controls to engage in therapeutic chelation. Such treatment is likely to translocate cadmium from pulmonary or other tissue to renal tissue. Get medical attention immediately.
4. Inhalation: If large amounts of cadmium are inhaled, the exposed person must be moved to fresh air at once. If breathing has stopped, perform cardiopulmonary resuscitation. Administer oxygen if available. Keep the affected person warm and at rest. Get medical attention immediately.
5. Rescue: Move the affected person from the hazardous exposure. If the exposed person has been overcome, attempt rescue only after notifying at least one other person of the emergency and putting into effect established emergency procedures. Do not become a casualty yourself. Understand your emergency rescue procedures and know the location of emergency equipment before the need arises.
III. Employee Information
A. Protective Clothing and Equipment.
1. Respirators: You may be required to wear a respirator for non- routine activities; in emergencies; while your employer is in the process of reducing cadmium exposures through engineering controls; and where engineering controls are not feasible. If respirators are worn in the future, they must have a joint Mine Safety and Health Administration (MSHA) and National Institute for Occupational Safety and Health (NIOSH) label of approval. Cadmium does not have a detectable odor except at levels well above the permissible exposure limits. If you can smell cadmium while wearing a respirator, proceed immediately to fresh air. If you experience difficulty breathing while wearing a respirator, tell your employer (supervisor).
2. Protective Clothing: You may be required to wear impermeable clothing, gloves, foot gear, a face shield or other appropriate protective clothing to prevent skin contact with cadmium. Where protective clothing is required, SOUTHWESTERN ELECTRICAL CO., INC. must provide clean garments to you as necessary to assure that the clothing protects you adequately. SOUTHWESTERN ELECTRICAL CO., INC. will replace or repair protective clothing that has become torn or otherwise damaged.
3. Eye Protection: You may be required to wear splash-proof or dust resistant goggles to prevent eye contact with cadmium.
B. SOUTHWESTERN ELECTRICAL CO., INC. Requirements:
I. TRAINING
SOUTHWESTERN ELECTRICAL CO., INC. will train all employees who are potentially exposed to cadmium. To assure all ‘all employees are trained, a roster of all potentially exposed employees will be maintained. and reviewed on a regular schedule. Training will be conducted prior to initial assignment and annually thereafter.
Training programs will be understandable to the employee and will cover the following:
* The health hazards of cadmium exposure.
* The information in Appendix A of 29CFR OSHA 1910.1027
* The quantity, location, manner of use, release, and storage of cadmium in the workplace and specific nature of operations that could result in exposure to cadmium, especially exposures above the PEL:
* The engineering controls and work practices
* The measures employees can take to protect themselves from exposure, this includes modification of such habits as smoking and personal hygiene, work practices, emergency procedures, and provision of Personal Protective Equipment(PPE).
* The purpose of proper respirator protection, use, fitting and limitations of all PPE
* The purpose of Medical Surveillance Program.
* The employee’s rights to access records.
* SOUTHWESTERN ELECTRICAL CO., INC. will provide a copy of this policy and attachments without cost to all affected employees.
* SOUTHWESTERN ELECTRICAL CO., INC. will provide to the Assistant Secretary or the Director, upon request, all materials relating to the employee information and training programs.
SOUTHWESTERN ELECTRICAL CO., INC. will certify that the training has been conducted by preparing a record that indicates
(1) Identity of employee trained
(2) The signature of the person who conducted the training
(3) The date of the training and maintained on file for one (1) year beyond the date of training.
II WRITTEN COMPLIANCE PROGRAM
OSHA has established the PEL for cadmium action level at 2.5 ug/m3 as an 8-hour time weighted average (TWA). When any employee is exposed to cadmium, above the action level, a written compliance program will be implemented to reduce the level below the PEL or where applicalble the Separate Engineering Control Airborne Limits (SECALs). The written compliance program will include the following:
* Engineering and work practice controls
* Respiratory protection required
* Description of each operation in which cadmium is emitted, machinery used, materials processed
* Crew Size
* Employee job responsibilities
* Report of technology considered to meet PEL
* Air monitoring data that document the source of cadmium
* Detail schedule of implementation of the program, including documentation such as copies of purchase orders for equipment
* Work practice programs
* A written plan for emergency situations
* Other relevant information
The Written Program shall be reviewed and updated at least annually, or more often if necessary.
The Written Program shall be provided upon request for examination and copying to affected employees, Designated employee representatives as well as the Assistant Secretary, and Director.
SOUTHWESTERN ELECTRICAL CO., INC. will minimize the number of employees in the work area, when air from exhaust ventilation system is recalculated into the workplace, during the time the filters are maintained (changed or cleaned).
III RESPIRATORY PROTECTION
SOUTHWESTERN ELECTRICAL CO., INC. must supply the appropriate respirator (Table 2- Respirators Protection for Cadmium). See attachment IV.
SOUTHWESTERN ELECTRICAL CO., INC. will provide an employee with a powered air-purifying respirator instead of a negative-pressure respirator when an employee who is entitled to a respirator chooses to use this type of respirator and such respirator provides adequate protection to the employee. Refer to SOUTHWESTERN ELECTRICAL CO., INC. Respirator Protection Program that meets 29 CFR OSHA 1910.134 requirements.
EMERGENCY SITUATIONS
SOUTHWESTERN ELECTRICAL CO., INC. will develop and implement a written plan for dealing with emergency situations involving substantial releases of airborne cadmium. The plan shall include provisions for the use of appropriate respirators and Personal Protective Equipment (PPE). All none essential employees needed to correct the situation will be restricted from the area and all normal operations will be suspended until the emergency is abated.
MEDICAL SURVEILLANCE
SOUTHWESTERN ELECTRICAL CO., INC. is required to provide a medical surveillance for all employees who are or may be exposed to cadmium at or above the action level unless SOUTHWESTERN ELECTRICAL CO., INC. demonstrates that the employee is not, and will not be, exposed at or above the action level on 30 or more days per year.
Previously exposed - SOUTHWESTERN ELECTRICAL CO., INC. shall also institute a medical surveillance program for all employees who prior to the effective date of the Cadmium Standard (29 CFR OSHA 1910.1027).(Sept. 14, 1992) might previously have been exposed to cadmium at or above the action level by SOUTHWESTERN ELECTRICAL CO., INC.. INC. unless SOUTHWESTERN ELECTRICAL CO., INC. demonstrates that the employee did not prior to the effective date work for SOUTHWESTERN ELECTRICAL CO., INC. in jobs with exposure to cadmium for an aggregated total of more than 60 days.
SOUTHWESTERN ELECTRICAL CO., INC. will provide limited medical examination as specified in 29 CFR OSHA 1910.1027 (I) (6)
SOUTHWESTERN ELECTRICAL CO., INC. will assure that all medical examinations and procedures required are performed by or under the supervision of a licensed physician, who has read and is familiar with the health effects of cadmium and Appendix A of 1910.1027.
SOUTHWESTERN ELECTRICAL CO., INC. will assure that the collecting and handling of biological samples of cadmium will be in accordance with 29 CFR OSHA 1910.1027 (I)(1)(iv).
Employee notification: Within five (5) working days after the receipt of biological monitoring results, the employer shall notify in writing each employee whose cadmium level exceeds the Standard. See Attachment II. Access to Records: All medical records are kept strictly confidential. You or your representative are entitled to see the records of measurements of your exposure to cadmium. Your medical examination records can be furnished to your personal physician or designated representative upon request by you to your employer.
Observation of Monitoring: SOUTHWESTERN ELECTRICAL CO., INC. is required to perform measurements that are representative of your exposure to cadmium and you or your designated representative are entitled to observe the monitoring procedure. You are entitled to observe the steps taken in the measurement procedure, and to record the results obtained. When the monitoring procedure is taking place in an area where respirators or personal protective equipment are required to be worn, you or your representative must also be provided with, and must wear the protective clothing and equipment.
Employee Requirements: - You will not be able to smoke, eat, drink, chew gum or tobacco, or apply cosmetics while working with cadmium in regulated areas. You will also not be able to carry or store tobacco products, gum, food, drinks or cosmetics in regulated areas because these products easily become contaminated with cadmium from the workplace and can therefore create another source of unnecessary cadmium exposure.
Some workers will have to change out of work clothes and shower at the end of day, as part of their workday, in order to wash cadmium from skin and hair. Handwashing and cadmium-free eating facilities shall be provided by SOUTHWESTERN ELECTRICAL CO., INC. and proper hygiene should always be performed before eating. It is also recommended that you do not smoke or use tobacco products, because among other things, they naturally contain cadmium. For further information, read the labeling on such products.
Richard Drake: President Aaron Drake: Vice President
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ATTACHMENT 1
DATE:__________
FROM: ______________________________
SUBJECT: ELEVATED BLOOD LEAD LEVEL
Dear
This letter is to inform you that your Blood Lead Level tested on ______________ was
________________ which exceeds the Action Level of 40 ug/dl; therefore the following actions are to be taken immediately. Your blood lead level has not exceeded the level at which temporary medical removal would be required by OSHA. (1910.1025(k)(1)(i)
1. You will be removed from the ____________________ work area immediately; this means you are restricted to the type of work you can perform until your blood lead level returns to normal. This current restriction is by Southwestern Electrical Co., Inc. not OSHA.
2. You will immediately cease all personal activities which could increase your lead exposure; this includes such things as hunting (bullets contain lead), and any activity that could increase your exposure to lead.
3. You will be counseled by Aaron Drake, the Safety Director, and/or the project manager on both personal and company health and safety policies which have been established for your protection. We strongly recommend you again review all appropriate materials which have been made available to you, including our Employee Safety Manual, Written Hazard Communication Program and Material Safety Data Sheets.
4. An appointment with the company physician will be made for you immediately for evaluation and treatment. ________________________ will furnish you the appropriate medical forms and there will be no cost to you for this medical examination; however you are responsible for keeping your own appointments. You will be allowed to return to normal duty once your blood lead level drops back below the Action Level for two consecutive samples. Copies of your BLL tests will be provided to you upon request.
Sincerely,
ATTACHMENT II
DATE:__________
FROM: ______________________________
SUBJECT: ELEVATED CADMIUM LEVEL
Dear
This letter is to inform you that your Cadmium Level tested on ______________ was ________________ which exceeds the Action Level; therefore the following actions are to be taken immediately.
1. You will be removed from the cadmium work area immediately; this means you are restricted to the type of work you can perform until your cadmium level returns to normal.
2. You will immediately cease all personal activities which could increase your cadmium exposure; any activity that could increase your exposure to cadmium.
3. You will be counseled by _____________________________, the Safety Director and/or manager on both personal and company health and safety policies which have been established for your protection. We strongly recommend you again review all appropriate materials which have been made available to you, including our Employee Safety Manual, Written Hazard Communication Program, Material Safety Data Sheets.
4. An appointment with the company physician will be made for you immediately for evaluation and treatment. ________________________ will furnish you the appropriate medical forms and there will be no cost to you for this medical examination; however you are responsible for keeping your own appointments. You will be allowed to return to normal duty once your cadmium level drops back below the Action Level for two consecutive samples. Copies of your cadmium tests will be provided to you upon request.
Sincerely,
ATTACHMENT III
TABLE 1
|AIRBORNE | |
|CONCENTRATION OF |REQUIRED RESPIRATORS |
|LEAD OR CONDITION OF USE | |
| | |
|Not in excess of 0.5 |Half-mask, air-purifying respirator equipped |
|Mg/m3 (10X PEL) | |
| |With high efficiency filters 2.3 |
| | |
|Not in excess of 2.5 |Full facepiece, air-purifying respirator |
|Mg/m3 (50X PEL) |with high efficiency filters 3 |
| | |
|Not in excess of 50 |(1)Any powered, air-purifying |
|Mg/m3 (1000XPEL) |respirator with high efficiency |
| |filters 3 or Respirator |
| |(2)Half-mask supplied-air respirator |
| |operated in positive-pressure mode 1 |
| | |
|Not in Excess of 100 |Supplied-air respirator with full |
|Mg/m3 (2000XPEL) |Face piece hood, helmet, or suit operated |
| |in positive pressure mode |
| | |
|Greater than 100 |Full face piece, self-contained breathing |
|Mg/m3, unknown |apparatus operated in positive- pressure Mode |
|Concentration or |fire fighting |
| | |
1. Respirators specified for high concentrations can be used at lower concentration of lead.
2. Full face piece is required if the lead aerosols caused eye or skin irritation at the use concentrations.
3. A high efficiency particulate filter means 99.97 percent efficient against 0.3 micron size particles
(II) The employer shall provide a powered, air-purifying respirator in lieu of respirator specified in the above table whenever:
(a) An employee chooses to use this type of respirator; and
(b) This respirator will provide adequate protection to the employee.
ATTACHMENT IV
TABLE 2 – RESPIRATORY PROTECTION FOR CADMIUM
Airborne concentrations or condition of use (*) Required respirator type (b)
|10X or less |A half mask, air-purifying equipped with a HEPA filter(j) |
|25X or less |A powered air-purifying respirator (PAPR) with loose fitting hood or helmet equipped with a HEPA |
| |filter, or a supplied-air respirator with a loose fitting hood or helmet face piece operated in |
| |the continuous flow mode. A full face piece air-purifying respirator equipped with a HEPA |
| |filter, or a powered air-purifying respirator with a tight-fitting half mask operated in the |
| |continuos flow mode. |
|50X or less |A full face piece air-purifying respirator equipped with a HEPA filter, or a powered |
| |air-purifying respirator with a tight-fitting half mask operated in the continuos flow mode |
|250X or less |A powered air-purifying respirator with a tight fitting full facepiece equipped with a HEPA |
| |filter, or a supplied – air respirator with a tight fitting face piece operated in the continuous|
| |flow mode. |
|1000X or less |A supplied air respirator with half mask or full facepiece operated in the pressure demand or |
| |other positive pressure mode. |
|>1000X or unknown concentrations |A self-contained breathing apparatus with a full facepiece operated in the pressure demand or |
| |other positive pressure mode, or a supplied- air respirator with full facepiece operated in the |
| |pressure demand or other positive pressure mode, and equipped with an auxiliary escape type self|
| |contained breathing apparatus operated in the pressure demand. |
|Fire fighting |A self contained breathing apparatus with full facepiece operated in the pressure demand or other|
| |positive mode. |
*Concentrations expressed as multiple of the PEL
(b) Respirators assigned for higher environmental concentrations may be used at lower exposure levels. Quantitative fit test is required for all tight fitting air purifying respirators where airborne concentrations exceeds TWA PEL (10 X 5 ug/m(3) = 50 ug/m(3). A full facepiece respirator is required when eye irritation is experienced.
HEPA means High-efficiency Particulate Air.
Fit Testing, qualitative or quantitative is required.
SOURCE Respiratory Decision Logic, NIOSH, 1987.
ATTACHMENT V
WRITTEN COMPLIANCE PROGRAM FOR LEAD
The following compliance form will be completed prior to working in any area where the lead levels are above the PEL:
|Description of Operations: (where lead is emitted) |
| |
| |
| |
|List Machinery used: |
| |
| |
|Material being process: |
| |
| |
| |
|Controls in place: (list all engineering controls, mechanical, administrative controls, studies, to determine the methods selected to controlling exposure to |
|lead) |
| |
| |
| |
|Crew Size: |(Number of employees on job site) Use only minimum required number of employees. |
| |
| |
|Operating Procedures: (outline the steps of the job and cover all PPE required, you can use the JSA form to help address all steps in the operations). (attach |
|additional pages as required) |
| |
| |
| |
| |
| |
|Maintenance: (list the required maintenance of any equipment that will be used during the job) |
| |
| |
|Material Safe Data Sheets/other Technology considered: Have on site the MSDS and any other technology that would be helpful to meet the requirements. |
|Is MSDS on site |Yes |No |
|Other information |Yes |No |
|Air Monitoring date posted at job site (Monitoring to document the source of |Yes |No |
|lead) | | |
| | | |
|Detail schedule of work to be performed. | | |
|1. Start Date |Time | |
|2. List each employee job responsibility | | |
|Name |Job responsibility |
| | |
|Name |Job responsibility |
| | |
|Name |Job responsibility |
| | |
|Name |Job responsibility |
| | |
|Name |Job responsibility |
| | |
|Name |Job responsibility |
| | |
|(Use additional pages as required) | |
| | |
|What equipment was purchased for this project? |
| |
| |
|(Attach PO, Contracts or other documents to ensure the equipment is on hand) |
| |
|Administrative Control Schedule if applicable |
|(this would be items like how long each employee will work while wearing a respirator or doing other task that would require rotating the employees). |
| |
| |
|Relevant information: |
| |
| |
|Up Date: |
| |
| |
The Written Compliance Program will be revised/reviewed at least every 6 months
If there is a need to change, if no work is performed in an area where the lead level is above the PEL – a negative report will not be required.
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