Definitions and Regulations
The Airport Authority has adopted best practices for working with lead on Airport Authority holdings.
Under the Canada Consumer Product Safety Act, the Surface Coating Materials Regulations define a lead-containing surface coating material as one that contains greater than 90 mg/kg lead in a dried sample.
Examples of LCM found on Airport Authority property include:
- Paints
- Coatings
- Primer on structural steel
- Ceramic tile glazing
Bulk Sampling Methods
WorkSafeBC-recommended sampling methods for LCM are NIOSH 7082, 7105, and 7300.
WorkSafeBC Occupational Exposure Limit
OHS Regulation Part 5 G5.48-1, Exposure Limits – Tables, shows the current 8-hour time weighted average (TWA) for airborne lead (elemental and inorganic compounds as Pb) to be 0.05 mg/m3.
Managing Lead
Upon receipt of the BRHEMP RFI, the BRHEMP administrator reviews the location, scope of work, and historical records to determine whether LCM or suspect LCM is present in the work area. At that time, one or more of the following actions are then taken:
- No sampling required: There is sufficient historical information on LCM within the work area.
- Additional sampling required: If there is insufficient historical information on whether LCM is present within the work area, and suspect materials will be disturbed based on the scope of work, the BRHEMP RFI initiator will be informed and required to engage an Airport Authority representative environmental consultant to conduct additional sampling.
- Removal of lead: High-risk work conducted on materials containing greater than or equal to 90 mg/kg lead require abatement by an Airport Authority pre-qualified abatement contractor. As lead is classified as a WorkSafeBC ALARA substance, the Airport Authority requires that surface coatings containing over 90 mg/kg of lead be removed whenever practicable, using procedures generating the lowest risk of airborne lead exposure (example: chemical stripping vs power sanding). Task-based Exposure Control Plans and written Safe Work Procedures should be developed as necessary. Additionally, WorkSafeBC mandates that all surface coatings, whether containing lead or not, be removed prior to hot work.
Risk Classification
Safe Work Practices for Handling Lead, issued by WorkSafeBC, defines low- to high-risk work activities as outlined below.
Activities Considered Low Risk
A work activity in which workers are exposed to lead but the airborne exposure is not likely to exceed the 8-hour exposure limit (0.05 mg/m3). These include:
-
- Applying lead-containing paint with a brush/roller
- Installing/removing sheet metal that contains lead
- Operating an excavator (within the cab) during building demolition
- Transporting sealed containers of lead waste
Activities Considered Low-Moderate Risk
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- Removing lead materials using power tools with dust collection systems and HEPA filters
- Manual scraping or sanding of lead-containing materials using non-powered hand tools
- Welding, burning, or cutting of surfaces from which lead-containing coatings have been removed
Activities Considered Moderate Risk
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- Removing lead-containing coatings with a chemical gel or paste by hand
- Removing lead-containing coatings with a heat gun
- Scraping or sanding lead-containing materials using non-powered hand tools (large projects)
- Manually demolishing lead-painted plaster walls or building components using a sledgehammer or similar tool
- Cleaning up and removing lead-containing dust and debris
Activities Considered Moderate-High Risk
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- Spraying on lead-containing coatings
- Using an electrical or pneumatic cutting device for dry removal of mortar that contains lead
- Removing lead-containing materials using power tools without an effective dust collection system equipped with a HEPA filter
- Removing or repairing ventilation systems used for controlling lead exposure
- Demolishing or cleaning up facilities where lead-containing products were manufactured
- Removing lead-containing surface coatings using a high-pressure waterjet
Activities Considered High Risk
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- Abrasive blasting of lead-containing surfaces (including wet, slurry, and dry abrasive blasting)
- Dry-ice blasting of lead-containing surfaces
- Using an air mist extraction system to remove lead dust
Airport Authority Minimum Control and Removal Expectations
Control Expectations
The table below outlines minimum control measures and recommended respiratory protection as described in Safe Work Practices for Handling Lead, issued by WorkSafeBC.
Removal Expectations
When surface coatings containing lead are removed, the following requirements must be met:
- The metal must be visually clean (all surface coatings removed).
- The surface must be cleaned to remove any dust and debris.
- The metal must pass a white glove test. This means that a white glove or white Kim Wipe comes out clean when wiped across the surface.
Pictures of the clean surface may be required when requested by the Airport Authority representative environmental consultant.
| Control Measures |
Recommended Respiratory Protection |
| Low Risk |
- Washing facilities must be provided, including wash basins, tempered (warm) water, soap, and disposable towels.
- Workers must not eat, drink, chew gum, smoke, or bite fingernails while in the work area.
- Workers must wash their hands before eating, drinking, smoking, or leaving the work area.
- Coffee and lunch breaks must be taken in a clean area separate from the work area.
- Disposable drop sheets should be used below all lead operations.
- Dust and waste must be cleaned up and placed in marked lead-waste containers that are dust-tight.
- The work area must be kept clean, and compressed air or dry sweeping must not be used to remove dust.
- Workers should remove all work clothes and shoes at the end of the workday and leave them at work.
|
Respirators should not be required if safe work procedures and proper housekeeping protocols are followed. |
| Low-Moderate Risk |
- Use barriers to prevent access to the work area by unprotected workers.
- Post signs at every entrance to the work area. Signs must include warnings of lead contamination and the requirement for respiratory protection.
- Workers must wear disposable coveralls and other PPE as needed.
- Use local exhaust ventilation equipped with HEPA filters when welding, burning, or cutting
- The work area must be kept clean, and workers must use cleaning methods that minimize the generation of dust, such as wet dusting, sweeping, or vacuuming using a vacuum with a HEPA filter on the exhaust.
|
- NIOSH-approved single-use N95, N99, or P100 respirator, or
- Half- or full-facepiece elastomeric respirator equipped with P100 HEPA cartridges, or
- Powered air-purifying respirator (PAPR) equipped with P100 HEPA cartridges.
|
| Moderate Risk |
- Construct partial or full containment around work areas where significant scraping, sanding, or demolition will take place.
- Where full containment is required, enclosures must be equipped with HEPA-filtered mechanical ventilation and kept under negative pressure.
- Where full containment is required, provide separate changing areas and a shower.
- When using a heat gun, keep the gun operating temperature as low as practicable.
|
- Half- or full-facepiece elastomeric respirator equipped with P100 HEPA cartridges, or
- Powered air-purifying respirator (PAPR) equipped with P100 HEPA cartridges.
- Combination cartridges (for example, HEPA and organic vapour) may be required when using chemicals.
The type of respirator chosen will depend on the amount of material removed and the duration of the work.
|
| Moderate-High Risk |
- Full containment enclosures should be constructed, equipped with HEPA-filtered mechanical ventilation, and kept under negative pressure.
- A decontamination facility should be constructed that has a dirty room for removing contaminated clothing, a shower room (with warm water), and a clean room for changing into street clothes.
- Incorporate wet methods into the operation wherever possible to reduce dust.
|
- Full-facepiece elastomeric respirator equipped with P100 HEPA cartridges, or
- Powered air-purifying respirator (PAPR) equipped with P100 HEPA cartridges.
- Full-facepiece supplied-air respirator operated in continuous-flow or pressure-demand mode.
The type of respirator chosen will depend on the amount of material removed and the duration of the work.
|
| High Risk |
- For dry abrasive blasting conducted outdoors, full containment enclosures equipped with HEPA-filtered mechanical ventilation must be constructed and kept under negative pressure.
- Full enclosures used for wet abrasive blasting must be designed to capture the resulting water and debris.
- Construct a decontamination facility that has a dirty room for removing contaminated clothing, a shower room (with warm water), and a clean room for changing into street clothes.
- Avoid using silica as an abrasive.
- Any ventilation or collection system that carries contaminated dust must be filtered before air is released to the atmosphere.
|
- Full-facepiece Type CE abrasive-blast supplied-air respirator operated in pressure-demand or positive-pressure mode, for abrasive blasting operations.
- Full-facepiece supplied-air respirator operated in pressure-demand or positive-pressure mode, when using an air mist extraction system.
|
Summary Roles and Responsibilities
Low/Low-Moderate Risk
| Required Parties |
Key Responsibilities |
Sampling Requirements |
Required Documentation |
| Airport Authority representative environmental consultant |
- Review contractor’s Safe Work Procedures and Exposure Control Plans as required.
- Perform QAQC as required.
|
- Conduct toxicity characteristic leaching procedure (TCLP) testing of waste as required.
|
- TCLP testing result memo as required.
|
| Prime Contractor |
- Go over the BRHEMP Conditional Report and all other subsequent sampling reports provided for the project with all workers. All workers must sign the BRHEMP Conditional Report before work commences.
- Have Exposure Control Plans and Safe Work Procedures in place.
- Ensure that appropriate controls are in place (LEV, HEPA vacuums, etc.).
- Dispose of hazardous waste at an approved facility.
- Retain third-party environmental consultant as necessary.
|
|
- Written Exposure Control Plans and Safe Work Procedures
- Waste manifest as required
|
| Airport Authority pre-qualified abatement contractor. |
|
|
|
| Third-party environmental consultant |
|
|
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*Involvement of a third-party environmental consultant and Airport Authority pre-qualified abatement contractor is at the discretion of the Prime Contractor.
Moderate/Moderate-High Risk
| Required Parties |
Key Responsibilities |
Sampling Requirements |
Required Documentation |
| Airport Authority representative environmental consultant |
- Review contractor’s Safe Work Procedures before work starts.
- Perform QAQC as required.
|
- Conduct toxicity characteristic leaching procedure (TCLP) testing of waste as required.
|
- TCLP testing result memo as required.
|
| Prime Contractor |
- Go over the BRHEMP Conditional Report and all other subsequent sampling reports provided for the project with all workers. All workers must sign the BRHEMP Conditional Report before work commences.
- Provide Exposure Control Plans and Safe Work Procedures to the Airport Authority representative environmental consultant.
- Ensure that appropriate controls are in place (LEV, HEPA vacuums, etc.).
- Follow any requirements of the Airport Authority representative environmental consultant.
- Dispose of hazardous waste at an approved facility.
- Retain third-party environmental consultant as necessary.
|
|
- Written Exposure Control Plans and Safe Work Procedures
- Waste manifest as required
|
| Airport Authority pre-qualified abatement contractor |
|
|
|
| Third-party environmental consultant |
|
|
|
*Involvement of a third-party environmental consultant and Airport Authority pre-qualified abatement contractor is at the discretion of the Prime Contractor.
High Risk
| Required Parties |
Key Responsibilities |
Sampling Requirements |
Required Documentation |
| Airport Authority representative environmental consultant |
- Create an abatement Scope of Work document.
- Review the Airport Authority pre-qualified abatement contractor’s Safe Work Procedures as necessary.
- Confirm approval of containment setup.
- Perform QAQC on the abatement work.
- Notify stakeholders and provide corrective actions if conditions of abatement are unacceptable.
- Create Weekly Summary Reports for contract owner.
|
- Conduct any additional sampling as necessary.
- Conduct TCLP testing of waste as required.
|
- Abatement Scope of Work document*
- Weekly Summary Reports
|
| Prime Contractor |
- Go over the BRHEMP Conditional Report and all other subsequent sampling reports provided for the project with all workers. All workers must sign the BRHEMP Conditional Report before work commences.
- Hire an Airport Authority pre-qualified abatement contractor
- Sign off on abatement Final Closure Document to confirm completion of Scope of Work.
- Retain third-party environmental consultant.
|
|
|
| Airport Authority pre-qualified abatement contractor |
- Provide the Airport Authority representative environmental consultant with all documentation as requested.
- Create Final Closure Document indicating materials have been removed. Upon completion of abatement, sign the document, provide prime contractor with document to sign, and provide Airport Authority representative environmental consultant with document.
- Dispose of hazardous waste at an approved facility and provide Airport Authority Health & Safety (and Airport Authority representative environmental consultant upon request), with Copy 2 & 6 of the Waste Manifest if applicable.
|
|
|
| Third-party environmental consultant |
- Inspect and approve the containment before starting work.
- Conduct compliance monitoring.
- Create and send all required monitoring and inspection reports to the Airport Authority representative environmental consultant.
|
- Conduct compliance monitoring
|
- Monitoring reports
- Daily inspection reports
- Final inspection report indicating materials have been removed.
- All reports must be sent to the Airport Authority representative environmental consultant within 24 hours
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*Depending on the size and complexity of the project, this could be a full Specification for Hazardous Materials Abatement document or a smaller document outlining scope and expectations.
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