QP-2 Deleading Compliance Program

Prepared under the direction of a Certified Industrial Hygienist, the KTA Corporate Deleading Compliance Program addresses the protection of workers, management of releases of lead to air, soils and waters, and management of waste streams. The program provides policies and guidance in each of these three general areas, and is based upon existing Federal regulations. It contains the necessary forms, documents, checklists and other materials necessary to facilitate ease of implementation at individual project sites and to allow for tailoring to meet individual state and/or specific requirements. This plan is designed to meet the program requirements of the SSPC’s QP-2 Painting Contractor Certification Program

Worker Lead Protection: Developed in compliance with the requirements of 29 CFR 1926.26, the OSHA Construction Industry Lead Standard, this program includes a Medical Surveillance Program and a Respiratory Protection Program for lead exposure projects. The program is easily tailored using fill-in-the-blank forms to be project specific (as required by OSHA) and to include the following information at a minimum: a description of each activity in which lead is emitted; a description of the specific means used to control employee exposure to lead; a report of the technology considered in meeting the PEL; air monitoring data which documents the source of lead emissions; detailing schedule for implementing the program; a work practice program; an administrative control (job rotation) schedule; and a description of arrangements made among contractors on multi-contractor sites.
The Environmental Compliance Program includes a section on environmental compliance, which addresses the following items: criterion for establishing the need for PM-10 and/or TSP-lead high volume ambient air monitoring; procedures for instrument monitoring of ambient air and for visual assessment of emissions; quality assurance criteria for an ambient air monitoring program; and criterion for establishment of site-specific soil sampling protocols.
The Waste Management Program includes a Waste Management Plan, which addresses the following: sampling plans for collection and testing of waste streams; criteria for laboratory selection, analytical methods, sample identification and chain-of-custody requirements; site storage and handling procedures, as well as labeling requirements; general guidance on the selection of treatment and disposal options; and a preparedness, prevention and contingency plan or Emergency Response Plan governing the accidental release of lead contaminated debris.