Dust Study work practices

The American Textile Industry Involvement with cotton dust as a workplace hazard began over ten years ago with Industry studies to determine whether the Industry had such an Illness problem. Then followed major dust removal and ventlllatlon efforts. The Industry developed a work practices and medical surveillance program which was presented to OSHA. 

Objective data for exemption from requirement for initiai monitoring. (I) For purposes of this section, objective data are information demonstrating that a particular product or material containing lead or a specific process, operation, or activity involving lead cannot release dust or fumes in concentrations at or above the action level under any expected conditions of use. Objective data can be obtained from an industry-wide study or from laboratory product test results from manufacturers of lead containing products or materials. The data the employer uses from an industry-wide survey must be obtained under workplace conditions closely resembling the processes, types of material, control methods, work practices and environmental conditions in the employer s current operations. 

A major purpose of the Dust Study was to assess the proposed work practices. A statistically valid sample of housing at the national level is not needed to assess the work practices. If anything, the Dust Study is conservative with respect to the age of housing because it studied older houses and therefore is appropriate for assessing the effectiveness of the work practices. 

In particular, the Dust Study found that renovation activities involving power planing and high temperature heat gun resulted in higher post-job renovation dust lead levels than activities using other practices. The geometric mean post-work, precleaning... 

Based on the results of the Dust Study and in response to the voluminous persuasive public comments, this final rule prohibits or restricts the use of the following practices during renovation, repair, and painting activities that are subject to the work practice requirements of this rule ... 

The Dust Study, which is described elsewhere in the preamble, assessed the proposed work practices. As one component of the proposed work practices, the cleaning verification was evaluated in the Dust Study. It should be noted that the Dust Study was not designed specifically to evaluate the cleaning verification in isolation of the rest of the work practices. Unlike the earlier Disposable Cleaning Cloth Study that was intended to test the effectiveness of the use of the white glove test in isolation, the Dust Study was meant to evaluate the effectiveness of the proposed work practices, including cleaning verification. 

Cleaning verification, when used apart from the other work practices, is not as reliable a test for determining whether the hazard standard has been achieved as clearance testing. However, the Dust Study supports the validity of cleaning verification as an effective component of the work practices. The cleaning and feedback aspects of cleaning verification are important to its contribution to the effectiveness of the work practices. 

Based on a review of the Dust Study and the Disposable Cleaning Cloth Study, EPA concluded that if the practices prohibited in this final rule are avoided and the required work practices are followed, then cleaning verification is an effective component of the work practices. EPA believes that the suite of work practices as a whole are effective at addressing the lead-paint dust that is generated during renovation, repair, and painting preparation activities. 

The Environmental Protection Agency received comments prior to the 2007 reqnest for comments on the proposed work practices in light of the Dnst Stndy. Those pre-Dust Study comments are summarized in the following paragraphs. 

The proposed rule required the use of a HEPA vacuum as part of the work practice standards for renovation activities. One commenter stated that EPA did not have sufficient evidence showing that HEPA vacuums are significantly better at removing lead dust than non-HEPA vacuums. EPA has determined that the weight of the evidence provided by the studies it reviewed demonstrates that the HEPA vacuums consistently removed significant quantities of lead-based paint dust and reduced lead loadings to lower levels then did other vacuums. While there may be some vacuum cleaners that are as effective as HEPA vacuums, EPA has not been able to define quantitatively the specific attributes of those vacuums. That is, EPA is not able to identify what criteria should be used to identify vacuums that are equivalent to HEPA vacuums in performance. Thus, EPA does not believe that it can identify in the final rule what types of vacuums can be used as substitutes for HEPA vacuums. Therefore, EPA has not adopted this alternative. 

Fugitive emissions and fugitive dusts can be measured with a personal monitor or high-volume filter equipment when studying internal emission sources. Working methods and personal practices are, however, the most important factors that affect occupational lead exposure, and all personnel involved in lead operations must be trained adequately in lead abatement strategies and informed of the results of observations and monitoring, whether a cause for concern or not. 

Workers who mine and process mineral sands containing tin and associated trace metals can also be exposed to uranium and thorium dusts from the sands (252). In a United Nations-sponsored study of radiological exposures in the tin by-product industry in Southeast Asia, Hewson found that many of these exposures are above occupational exposure limits, but could easily be reduced by use of standard radiation protection practices involving ventilation and respiratory protection. Implementation of such practices may be difficult, however, because most of the estimated 2000 workers employed in this indnstry work in plants that employ fewer than 20 workers, with many plants employing fewer than 5 workers. 

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