Lead Program

PURPOSE

The purpose of this program is to ensure a safe and healthy environment within SkyVine ITAD for all personnel working with or near sources of lead. This program is intended to meet the requirements of OSHA’s Lead Regulation - 29 CFR 1910.1025.

PROGRAM SCOPE

This document is meant to define a structure for issues surrounding the use of lead in SkyVine ITAD’s operations, and as such may only provide general information in certain subjects. Refer to OSHA 29 CFR 1910.1025 for full text.

Lead is the chemical substance Pb, (elemental lead). 29 CFR 1910.1025 does not apply to organic lead compounds, with the exception of organic lead soap. The health hazards associated with overexposure to lead are well known. Due to these potentially harmful health effects, monitoring and control of lead is of utmost importance at SkyVine ITAD.

RESPONSIBILITIES

The QEH&S Manager has the responsibility to ensure conformance with this program.

EXPOSURE DETERMINATION/MONITORING

Air Monitoring

The current OSHA Permissible Exposure Limit (PEL) for lead is 50 micrograms per cubic meter of air (ug/m³) over an eight-hour period (TWA, or time-weighted average). The “action limit” is defined as 30 ug/m³ as a TWA.

For the purpose of initial exposure determination, job classifications will be established for each work area where lead is used, and air samples will be taken from a representative sample of employees for each job classification. This sampling will be for a full shift (minimum of seven hours). In addition, monitoring will also take place any time there is a significant change in factors that may affect exposure (ex. Changes in equipment, processes, control measures, etc.) or signs or symptoms are reported by employees.

If monitoring results indicate an exposure at or above the action limit (30 ug/m³), monitoring will be repeated for a representative sample of employees in that area at least every six months. Monitoring may be discontinued if two consecutive sampling episodes (at least seven days apart) reveal levels below the action level, provided that the accuracy of the monitoring is ±25% and at a 95% confidence level @ (30 ug/m³). Additional monitoring will be conducted if at any time changes in the production, processes or personnel make it likely that exposures will be significantly different from those previously assessed.

Employees will be notified within five days of receipt of laboratory results. If the PEL is exceeded, a written plan for reducing levels will also be provided to the employee. Employees or their designated representative also have the right to observe air monitoring, including an explanation of the procedures used.

If the results of monitoring have shown airborne levels of lead to exceed the PEL, all entrances must be posted with signs reading:

WARNING

LEAD WORK AREA

POISON

NO SMOKING OR EATING

Medical Surveillance

SkyVine ITAD will provide medical examinations and consultations to its employees on initial assignment and at least every six months thereafter, as specified in OSHA CFR 1910.102 (See Appendix for text of rules). Medical examinations and consultations will be provided in the following circumstances:

1. An employee is or may be exposed at or above the action limit for 30 days per year

SkyVine ITAD will provide medical examinations and consultations to its employees as soon as possible in the following circumstances:

1. An employee is experiencing the signs and symptoms of overexposure to lead, and/or;

2. An employee desires medical advice regarding current or past exposures to lead,

as it relates to reproductive or developmental hazards.

SkyVine ITAD will provide medical examinations and consultations to its employees as “medically appropriate” under the following circumstances:

1. An employee is removed from their work due to risk of material health impairment from lead exposure.

If documented blood lead levels are greater than or equal to 40 ug/100g whole blood, medical examinations and consultations will be provided at least once every two months, until two consecutive blood lead levels are found to be less than 40 ug/100g whole blood.

Management will be responsible for ensuring that the examining physician is licensed, and for providing the physician with a copy of 29 CFR 1910.1025 and all appendices. SkyVine ITAD will also provide the physician with exposure conditions and measured levels of lead, personal protective equipment used and any previous medical information available. The content of the required evaluation is contained in 29 CFR 1910.1025.

Information to be provided to SkyVine ITAD by the Physician includes a written opinion regarding whether the employee is at risk of material health impairment dues to lead exposure; any special protective measures; any recommended limitations on the employees or on the use of protective equipment (including power purified respirators); and a statement that the employee has been informed by the physician of the results of the medical exam and of any medical conditions related to lead exposure that require further explanation or treatment. A written opinion must not reveal specific findings or diagnoses unrelated to exposure to lead, and a copy of the opinion must be provided to the employee within 15 days of its receipt.

An employee must be removed from the work area if documented exposures are at or above the action limit, and one (whichever time frame is longer) of the following two conditions is met:

1. The average of the last three blood levels equals or exceeds 50 ug/100g whole blood;

2. The average of all blood lead levels from the previous six months equals or exceeds 50 ug/100g whole blood.

The removal provision will apply unless the most recent blood lead level is less than 40 ug/100g whole blood. A medical examination will take place after any medical removal provision is enacted. The employee must also be informed that medical examinations and consultations will be made available at least once per year if any blood levels equal or greater than 40 ug/100g whole blood were found in the previous 12 months.

SkyVine ITAD may return the employee to their previous job status under the following conditions:

1. If removal was due to a blood lead level ≥80 ug/100g whole blood, followed by two consecutive blood lead levels ≤ 60 ug/100g whole blood, or;

2. If removal was due to a blood lead level ≥70 ug/100g whole blood, followed by two consecutive blood lead levels ≤ 50 ug/100g whole blood, or;

3. If removal was due to a blood lead level ≥60 ug/100g whole blood, or an average blood lead level ≥ 50 ug/100g followed by two consecutive blood lead levels ≤ 40 ug/100g whole blood, or;

4. A subsequent medical finding that the employee is no longer at a material risk of health impairment due to lead exposure.

SkyVine ITAD may also remove any special protective measures or other limitations at this time.

If the employee cannot be returned to the work area, employee earnings, seniority and benefits must be maintained for an 18-month period or until it is determined that the employee can be returned to the area. Compensation during the period may be reduced by the amount the employee obtains from worker’s compensation benefits (except for treatment-related expenses), another compensation program, or income derived from another employer that is made possible by the removal of the employee. SkyVine ITAD may elect to provide these only if the employee agrees to follow-up medical surveillance during this period. These provisions also apply if SkyVine ITAD voluntarily elects to remove or restrict the employee from working in the lead area.

In addition, the employee must be promptly notified that they have the right to a second medical opinion, provided that do so within 15 days of receipt of the original medical exam results. If the second opinion is contradictory to the first, a third opinion is obtained from an appropriate specialist to resolve the dispute. If this determination results in the medical opinion that the employee is at a material risk of health impairment due to lead exposure, the employee will temporarily be removed from work. If this information is not immediately available, SkyVine ITAD has the option to;

1. Temporarily remove the employee, or

2. Provide special protective measured or enact limitations, consistent with physician recommendations, or

3. Return the employee to their former job, unless the employee was removed for the previous 18 months for an elevated blood lead level, or initial removal resulted from a previous third opinion. In this case, SkyVine ITAD will await a “final medical determination”.

If the removed employee’s blood lead level does not decline after 18 months, SkyVine ITAD will make a medical examination available to the employee to obtain a “final medical determination” (including an opinion regarding whether or not an employee may return to the job). If the “final medical determination” still indicates that they cannot return, SkyVine ITAD will continue to provide earnings and benefits until the employee is either returned to the job or a “final medical determination” indicates that they can return safely to the job. If the employee is returned to work as a result of a “final medical determination” but still has an elevated blood lead level, other blood lead removal criteria need not apply.

Any laboratory performing analysis for blood lead levels must be licensed and/or rated proficient by the Centers for Disease Control (CDC). The accuracy of methods used must be at least ± 15% of 6 ug/100ml (at a confidence level of 95%), whichever is more stringent.

Prophylactic chelation therapy of any employee is strictly prohibited. If chelation therapy is deemed medically necessary, it must be performed by a licensed physician in a clinical setting. The physician ensures that thorough medical monitoring is conducted during and after chelation therapy. Chelation therapy will only be performed with prior written notification to the employee.

METHOD OF COMPLIANCE

Controls

Compliance with the OSHA lead standard may be achieved through a combination of engineering, administrative and work practices as control methods. SkyVine ITAD’s primary goal is to control exposures to below the PEL’s. If these controls are implemented and the PEL is still exceeded more than 30 days per year, supplementation with the use of respirators may be necessary, especially if additional controls are not feasible.

Compliance Program

Local ventilation will be employed as the primary exposure control.

Respirators, if deemed necessary, (see Respiratory Protection Program) will be used as a supplement to local ventilation.

Measures will be taken to ensure that mechanical ventilation controls are evaluated for effectiveness on a regular basis; this includes a review of ventilation effectiveness within five days of any significant process changes.

This program will be formally evaluated at least annually.

General Hygiene

Housekeeping; all surfaces are kept as clean as practical. Cleaning methods in lunchrooms are restricted to HEPA-equipped vacuum or wet wiping only. No compressed air, sweeping, brushing or other dry clean-up methods will be permitted.

Personal Hygiene

Employees who work in areas where their airborne exposure to lead is above the PEL wash their hands and face prior to eating, drinking, smoking or applying cosmetics,

Facilities

SkyVine ITAD assures that change rooms are equipped with separate storage facilities for protective work clothing and equipment and for street clothes which prevent cross-contamination.

SkyVine ITAD assures that employees who work in areas where their airborne exposure to lead is above the PEL, without regard to the use of respirators,

1. be provided clean change rooms and lavatories,

2. shower at the end of the work shift,

3. do not leave the workplace wearing any clothing or equipment worn during the work shift,

4. have access to lunchroom facilities which are temperature controlled, positive pressure, filtered air supply, and are readily accessible to employees

5. employees do not enter lunchroom facilities with protective work clothing or equipment unless surface lead dust has been removed by vacuuming, downdraft booth, or other cleaning method,

Personal Protective Equipment

When monitoring results mandate the use of respirators, respirators will be issued to employees, and has a protection factor sufficient to reduce expected levels to below the PEL’s. This includes usage during periods prior to implementation of engineering or other controls and during periodic maintenance activities.

Only NIOSH or MSHA approved respirators may be used and must conform to SkyVine ITAD’s Respiratory Protection Program. Negative pressure, air-purifying respirators must have lead-specific cartridges (HEPA’s) and these must be changed out any time an increase in breathing resistance is detected. A half-mask APR may be used in exposures up to 0.5 mg/m³. All other provisions of SkyVine ITAD’s Respiratory Protection Program will apply to respirators used for lead exposure.

SkyVine ITAD will provide protective clothing, goggles, gloves, hats, shoes and any other necessary equipment to prevent overexposure to lead. Clean protective clothing will be provided daily if exposures are > 200 ug/m³ and at least weekly if exposures are > 50 ug/m³. SkyVine ITAD will also provide for cleaning and repair of protective clothing. Clothing contaminated with lead that will be cleaned or disposed of must be labeled;

CAUTION: CLOTHING CONTAMINATED WITH LEAD. DO NOT REMOVE DUST BY BLOWING OR SHAKING. DISPOSE OF LEAD CONTAMINATED WASH WATER IN ACCORDANCE WITH APPLICABLE LOCAL, STATE, OR FEDERAL REGULATIONS.

Personnel required to handle contaminated clothing and/or equipment will be provided with information regarding safe handling procedures in writing.

TRAINING

Training will be conducted for all SkyVine ITAD employees potentially exposed to levels at or above the action level, or for whom the possibility of skin or eye irritation exists, including informing employees of the content of OSHA 29 CFR 1910.1025.

Training will be provided upon initial assignment, upon significant process or product changes, at least annually and includes the following topics;

• The content of OSHA 29 CFR 1910.1025 Lead Protection and its appendices,

• The specific nature of the SkyVine ITAD operations which could result in exposure to lead above the action level,

• The purpose, proper selection, fitting, use, and limitations of respirators,

• The purpose and a description of the medical surveillance program, and the medical removal protection program including information concerning the adverse health effects associated with excessive exposure to lead (with particular attention to the adverse reproductive effects on both males and females),

• The engineering controls and work practices associated with the employee's job assignment,

• The contents of any compliance plan in effect; and

• Instructions to employees that chelating agents should not routinely be used to remove lead from their bodies and should not be used at all except under the direction of a licensed physician

All provisions of SkyVine ITAD’s Hazard Communication Program will apply to this training.

RECORD RETENTION

SkyVine ITAD retains monitoring records for at least 30 years or for the duration of employment plus 20 years, whichever is longer, for the following records;

1. Exposure measurements, including operation, date of sampling, methods (including accuracy), PPE in use, social security number of employees sampled and all other relevant sampling data

2. Medical surveillance records, including Name, social security number, and job classification of the employee monitored and of all other employees whose exposure the measurement is intended to represent, complaint records, all medical examination results, air monitoring results, medical laboratory standard references, and biomonitoring results

3. Medical removal record, including the name, social security number, date of removal, date of reinstatement, reason for removal and how reinstatement was accomplished, statement with respect to each removal indicating whether or not the reason for the removal was an elevated blood lead level

A copy of all these records are made available to the SkyVine ITAD employee or their legal representative on request. If SkyVine ITAD ceases to do business or is acquired, successors to SkyVine ITAD will be required to maintain these records, and the OSHA directors are informed of the transfer. If SkyVine ITAD intends to dispose of any records, the OSHA director must be informed three months prior to disposal.