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elaws - employment laws assistance for workers and small businesses - OSHA Lead in Construction Advisor

ENGINEERING CONTROLS

What are some general types of engineering controls?

Engineering measures include:

  • local and general exhaust ventilation;

  • enclosure/encapsulation;

  • material substitution;

  • component replacement with new components;

  • process and equipment modification; and

  • isolation or automation.

What are examples of the recommended engineering control "local and general exhaust ventilation ?"

Power tools used for the removal of lead-based paint should be equipped with dust collection shrouds or other attachments exhausted through a high-efficiency particulate air (HEPA) vacuum system. Operations such as welding, cutting/burning and heating should be provided with local exhaust ventilation. Vacuums should be equipped with HEPA filters if they are used during clean-up activities.

For abrasive blasting operations where full containment exists, the containment structure should be designed to optimize the flow of ventilation air past the worker(s), so that the airborne concentration of lead is reduced and the visibility is increased. The affected area should be maintained under negative pressure to reduce the chances that lead dust will contaminate areas outside the enclosure. A containment structure must be equipped with an air-cleaning device to control emissions of particulate matter to the environment.

What are examples of the recommended engineering control "enclosure/encapsulation?"

Lead-based paint can be made inaccessible either by encapsulating it with a material that bonds to the surface, such as acrylic or epoxy coating or flexible wall coverings, or by enclosing it using systems such as gypsum wallboard, plywood paneling, and aluminum, vinyl or wood exterior siding.

Floors coated with lead-based paint can be covered using vinyl tile or linoleum flooring.

The building owner, or other responsible person, should oversee the custodial and maintenance staffs and contractors with regard to all activities that involve enclosed or encapsulated lead-based paint. This will minimize potential inadvertent release of lead during maintenance, renovation or demolition.

What are examples of the recommended engineering control "material substitution ?"

Zinc-containing primers covered by an epoxy intermediate coat and polyurethane topcoat are commonly used instead of lead-containing coatings.

What are examples of the recommended engineering control "component replacement with new components ? "

Lead-based painted building components (i.e., windows, doors and trim) can sometimes be replaced either with new lead-free components or with the same components after the lead- based paint has been removed off-site. Replacement is a permanent solution.

Brush/roller application of lead paints or other lead-containing coatings is a safer method than spraying. (Note: There is a ban on the use of lead-based paint in residential housing.) This method of application introduces little or no paint mist into the air where the mist can present a lead inhalation hazard.

Mobile hydraulic shears can be substituted for torch cutting under certain circumstances.

Surface preparation equipment, such as needle guns with multiple reciprocating needles completely enclosed within an adjustable shroud, can be substituted for abrasive blasting under certain operations. The shroud captures dust and debris at the cutting edge and can be equipped with a HEPA vacuum filtration system with a self-drumming feature. One such commercial unit can remove lead-based paint from flat steel and concrete surfaces, outside edges, inside corners and pipes.

Chemical strippers used primarily on the exterior of buildings, surfaces involving carvings or molding, or intricate iron works, can be used in place of hand scraping. Chemical removal generates less airborne lead dust.

These strippers, however, can be hazardous and the material safety data sheets (MODS) for the products used must be reviewed by the employer for information on worker exposure hazards from the chemical ingredients and protective measures recommended by the manufacturer.

Non-silica containing abrasive (e.g., steel or iron shot/grit) should be used where practical instead of sand in abrasive blasting operations. The crystalline silica portion of the dust presents a respiratory health hazard.

Blasting techniques that are less dusty than abrasive blasting and that can be effective under some conditions include: (1) hydro- or wet-blasting (using high pressure water with or without abrasive or surrounding the blast nozzle with a ring of water), and (2) vacuum blasting where a vacuum hood for material removal is positioned around the exterior of the blasting nozzle. Heat guns used to remove lead-based paints in residential housing units should be of the flameless electrical softener type. Heat guns should have electronically controlled temperature settings to allow usage below 700 degrees F. Heat guns should be equipped with various nozzles to cover all common applications and limit heated work area.

When using abrasive blasting with vacuum on exterior building surfaces, care should be taken that the configuration of the heads on the blasting nozzle match the configuration of the substrate so that the vacuum is effective in containing debris. Since HEPA vacuum cleaners can be used to clean surfaces other than just floors, operators should have attachments appropriate for use on unusual surfaces. The proper use of brushes of various sizes, crevice tools and angular tools, when needed, will enhance the quality of the HEPA-vacuuming process and help reduce the amount of lead dust released into the air.

What are examples of the recommended engineering control "isolation or automation?"

Although it is not feasible to completely enclose and ventilate some abrasive blasting operations, it is possible to isolate many operations to help reduce the potential for exposure to lead. Isolation, in this instance, consists of keeping employees not involved in the blasting operations as far as possible from the work area. By placing the employees at a greater distance from the source of lead exposure, their exposures will be reduced.

 

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