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The KTA Corporate Deleading Compliance Program, developed
under the direction of a Certified Industrial Hygienist,
addresses the protection of workers, management of releases
of lead to air, soil and water, and management of waste
products and debris. The program establishes policies
governing each of the following general areas:
1) Worker Protection: the program includes a Corporate
Worker Lead Protection Program in compliance with 29 CFR
1926.26, OSHA Construction Industry Lead Standard. This
program includes a Medical Surveillance Program and a
Respiratory Protection Program for lead exposure projects.
The program is also easily tailored using fill-in-the-blank
forms to be project specific (as required by OSHA.).
2) Environmental Compliance: The program includes
criterion for establishing the need for PM-10 and/or TSP-
lead monitoring, duration of monitoring and site sampling
location; procedures for instrument monitoring of ambient
air and for visual assessment of emissions, quality
assurance criteria for ambient air monitoring program, and
criterion for establishment of site-specific soil sampling
protocols, sampling techniques, laboratory selection and
analytical methods, and site clearance reporting.
3) Waste Management: This section of the program includes
sampling plans for collection and testing of debris,
criteria for laboratory selection, analytical methods,
sample identification and chain-of-custody requirements,
site storage and handling procedures, as well as labeling
requirements, and general guidance on the selection of
treatment and disposal options. A preparedness, prevention
and contingency plan (PPCP) or Emergency Response Plan
(ERP) governing the accidental release of lead contaminated
debris is also included in this section.
The Corporate Deleading Compliance Program is based upon
existing Federal regulations. It is appended with 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.
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