Clarification - What Jobs Qualify for QP 2 Certification Auditing - July, 2003
For the purposes of QP 2 job site auditing, a valid hazardous paint removal job is defined as a project in which the contractor is removing a coating and air monitoring by a qualified independent laboratory shows that airborne exposure exceeds prescribed limits, that is, the Permissible Exposure Limit (PEL). For example, 50 micrograms per cubic meter of air, as a Time Weighted Average (TWA) over an eight hour period is the current OSHA PEL for lead. The PEL (micrograms per cubic meter of air) for other metals that might be found in paints being removed include: Arsenic = 10; Cadmium = 5; Hexavalent Chromium = 5.
Note: If the contractor chooses to do its own exposure monitoring, it must provide independent confirmation in writing from a qualified CIH or CSP familiar and experienced with industrial painting operations, that the monitoring protocal being used by the contractor on the job is being done in accordance with regulations and accepted practice with properly functioning and calibrated equipment. If project airborne exposures do not exceed the PEL, the contractor may still be eligible for QP 2 certification provided the contractor can:
- Demonstrate (i.e. provide documentation by independent,
- accredited/approved laboratories) during the QP 2 audit that it has
historically implemented its OSHA & Environmental compliance programs to the extent required by regulations but that none of its hazardous paint removal projects has required full implementation of its compliance plans; and
- Demonstrate during the QP 2 audit that it has the capability to fully implement its compliance programs at a moment's notice, if project and work process conditions dictate; and
- Agree in writing to notify SSPC as soon as it takes on a project where it must fully implement its compliance programs (i.e. on projects where the contractor cannot reduce the exposure below the OSHA PEL and/or where waste generated at the job site is tested and deemed hazardous).
Regardless of which scenario the contractor can present, the SSPC auditor must observe the contractor removing hazardous paint (based on independent laboratory tests of paint/materials being removed) at an active job site during the initial QP 2 audit.