1. Working safely with paint containing lead and chromium (VI)
Toolbox
Working safely with paint containing lead and chromium (VI)
HSE- version March

2. Corrosion-resistant paint is common at Tata Steel
Introducing Tata Steel
Toolbox lead and chrome paint
Corrosion-resistant paint is common at Tata Steel
This paint can contain both lead and chromium (VI).
Because of the salty sea air in IJmuiden, the structural parts were previously painted with an anticorrosive paint, containing lead and chromate.
Corrosion-resistant paint occurs on metal constructions such as platforms, stairs, storage tanks, A-frames, wheel excavators, crane tracks etc.
Until the end of the 90's lead could be used as an anti-corrosion primer on steel constructions.
After that, the company switched to lead-free iron or welding alloys.
As of 2013 TS standard S is in force to ban Chrome (VI) containing paint systems.
Material analysis is needed to be sure
whether the paint contains lead or chromium (VI).
It is not possible to determine it by color.

3. Toolbox lead and chrome paint
Whether the paint contains lead or chromium (VI) is often not visible, so have it examined first.

4. Inhalation or ingestion of dust by machining steel construction:
Toolbox lead and chrome paint
Working on paint containing lead and/or chromium (VI) gives health risks
Inhalation or ingestion of dust by machining steel construction:
Examples: sanding, drilling, milling, blasting.
Inhalation of flue gases by heating the surface above 550 ˚C/ 1020 ˚F:
Examples: grinding, welding and burning.
Limit value for inhalation (8 hours average value)
Lead: 0.15 mg/m³
Chromium VI: 0,001 mg/m³ (= 1 µg/m³) Only for the Netherlands

5. How can lead and chromium (VI) be absorbed in the body (*)
Toolbox lead and chrome paint
How can lead and chromium (VI) be absorbed in the body (*)
Inhalation of air with dust
Ingestion
Through the skin
This applies to dissolved chromium (VI) compounds
In liquid, dissolved form, it can penetrate the skin.
Skin
Inhalation
Ingestion
(*) For more information (Netherlands only) (RIVM brochure “wat is chroom6”)

6. Dangers and health effects of lead substitution
Toolbox lead and chrome paint
Dangers and health effects of lead substitution
Insert your own text here (Arial 18p)
Hazards:
Suspected of damaging fertility: both male and female
May harm unborn child
May cause damage to organs
Very toxic to aquatic organisms
Health effects: at repeated prolonged exposure above the limit value
Lead poisoning, accumulation of lead in skeleton
Anemia
Weight loss, cramps
Insomnia
Continuous pressure on nerves
Kidney Damage
Severe muscle weakness and pain

7. Hazards and Health Effects of Chromium(VI)
Toolbox lead and chrome paint
Hazards and Health Effects of Chromium(VI)
Hazards:
Inhalation of chromium (VI) can also lead to direct health effects, such as coughing, sore throat and shortness of breath.
Ingestion may cause abdominal pain and nausea.
Health effects: by repeated prolonged exposure above the limit value
Chromium (VI) may cause cancer by repeated exposure.
The substance must be actually inhaled or swallowed.
If this happens, the substance must cross several natural barriers in the body before it causes damage. For example, particle size and concentration of the chromium compounds are important factors here
Prolonged exposure to chromium (VI) can lead to allergies
Allergies can be permanent and can cause the person to have a hypersensitivity reaction even in small quantities.

8. Sample Slide – three text boxes
Toolbox lead and chrome paint
Sample Slide – three text boxes
Step
Action
Sheet 1
Execute test protocol
If the paint system contains lead or chromium (VI), go to step 2, 3, 4 and 5.
If the paint system does not contain lead or chromium (VI), take standard control measures according to Ijmuiden QHSE 3.31 "respiratory protection in case of harmful fine dust
9,10,11,12,13, 14 2A
Examination if processing can be carried out without affecting the paint film
Link voor info
(NL only) 2B
Investigate whether paint layer can be removed using a less stressful processing method (no or moderate dust formation) 3
Determine the degree of dust formation with the selected processing method 15 4
Apply technical measures, in accordance with occupational hygiene strategy (see examples list of measures) 16 5
Apply the indicated management measure
17,18,19
Note: If test protocol cannot be performed, assume that the paint system contains lead or chromium (VI) and take additional control measures in accordance with this Toolbox.

9. Expiry schedule Test protocol (1)
Toolbox lead and chrome paint
Expiry schedule Test protocol (1)
NL only

10. Expiry schedule Test protocol (2)
Toolbox lead and chrome paint
Expiry schedule Test protocol (2)
NL only

11. Test protocol requirements (1)
Toolbox lead and chrome paint
Test protocol requirements (1)
The test is carried out under the responsibility of the client.
Execution according to work instruction (see link NL only ).
Document the test results of the lead and chrome test in the technical construction file (SAP PM on function code location. (Add photo of discoloration). Use the registration form (see link NL only ).
Test shall be performed by an employee, minimum level installation manager, fault service or team leader HTD (*). It is important that this person can adequately perform the tests, assess them and register the results in SAP. And when the assessment is not good, escalate to the right channels or act according to protocol.
(*) A third party may carry out the test.
if the above conditions are met and the test protocol is used.

12. Test protocol requirements (2) (NL only)
Toolbox lead and chrome paint
Test protocol requirements (2) (NL only)
Send the measurement results to for archiving.
If object is removed completely, registration in SAP and mail to KDT is not necessary.

13. Method of lead test (TK-08)
Toolbox lead and chrome paint
Method of lead test (TK-08)
Before starting operations on steel structures:
When lead is detected, chromium testing is no longer necessary, because the same control measures are in place.
At least 2 tests per paint system
Is one of both tests "positive". Paint layer is lead-containing

14. Method of use chromium (VI) test
Toolbox lead and chrome paint
Method of use chromium (VI) test
Tata Steel IJmuiden uses the standard test kit TK-11 from "MAT inspired".
Approved alternative test methods are:
3M CHROMATECHECK
Note: Performing tests on Chromium (VI) by SGS is no longer allowed.
Chromium (VI) detection using XRF Analyzer is not possible and is therefore not part of the test protocol.
Minimum of 2 tests per paint system
Is one of both tests "positive". Paint layer is chromium (VI) containing
Note the expiration date of test kit which is listed on pouch of cotton swabs sticks
These test kits are only suitable for testing on coatings,
NOT for testing dust samples.

15. Step 3: Determine the degree of dust formation (according to schedule)
Toolbox lead and chrome paint
Step 3: Determine the degree of dust formation (according to schedule)
Working on paint systems containing lead and/or chromium (VI)
Machining
Welding, flame cutting,
heating
Manual editing
Drilling, sawing
Blasting, sanding
mechanical rust removal/
bald grinding
Smoke formation/vapour formation
Moderate dust formation
Heavy dust formation

16. STEP 4: Apply technical measures (examples list)
Toolbox lead and chrome paint
STEP 4: Apply technical measures (examples list)
Starting point for measures
Tackle dust as much as possible directly at the source
Prevent dust from spreading to the environment
Examples
Using source-extraction equipment
Apply local extraction, vacuum cleaner with minimum HEPA 12 filter
Moistening or wetting the construction
Loose scraping of old paint layers instead of machine sanding/grinding
Replacing/cutting of installation parts instead of sandblasting
Wet or vacuum blasting instead of sandblasting
Cleaning construction parts before starting fire/welding
Loosening with a scrubbing saw or reciprocating saw
Loosen bolts instead of grinding and burning

17. STEP 5 Management measures to be taken (1)
Toolbox lead and chrome paint
STEP 5 Management measures to be taken (1)
Category
Activity
Technical measure
Breathing protection (***)
PPE
Meassures regarding surrounding area
Aftercare
0. No dust
Manual assembly/disassembly
Irrelevant
Standard closed work clothing, work gloves
1. Severe dust
Mechanical assembly/disassembly
"Use a vacuum cleaner with at least HEPA 12 filter as a point extraction (in case of visible dust formation).
"Half mask or snout with an FFP3 filtering filter
After completion of work on the immediate surroundings, vacuum with a vacuum cleaner with at least HEPA 12 filter (only the visible dust from the work).
"Afterwards, vacuum clean the clothes. Wipe tools, reusable PPE and shoes with a damp cloth. Dispose of gloves as chemical waste. Afterwards, wash hands, arms and face".
Driling in objects
Cutting objects
Wet grinding
Milling
Sawing with a scrubbing saw or a reciprocating saw (coarse tensing)
Mechanical sanding with integrated dust extraction
Heating
Direct suction dry blasting (Vacuum blasting) (****)
"Inner situation: Vacuum sand blaster minimum equipped with a HEPA 13 filter
Outdoor situation: HEPA filter not required. Positioning of the air outlet vacuum sand blaster, away from the work location. "

18. STEP 5 Management measures to be taken (2)
Toolbox lead and chrome paint
STEP 5 Management measures to be taken (2)
Category
Activity
Technical measure
Breathing protection (***)
PPE
Meassures regarding surrounding area
Aftercare
2. Heavy dust
Mechanical sanding without direct extraction
Inner situation:
Apply local point extraction with at least HEPA 13 filter directly to the source (suction nozzle distance as small as possible).
Outdoor situation:
Local point extraction if practically applicable
"Full face mask with an FFP3 filter or an airstream helmet with FFP3 "
Standard closed work clothes, disposable overalls, work gloves
Lay off workstation around 6 m or lay off workstation with screens/film (**) After completion of work on the immediate surroundings, vacuum with a vacuum cleaner with at least HEPA 12 filter (only the visible dust from the work).
Afterwards, vacuum clean the clothing. Wipe tools, reusable PPE and shoes with a damp cloth.
Disposable coveralls and gloves should be disposed of as chemical waste. Showering at the end of the work
Mechanical rust removal or bare grinding of larger areas (> 0.5 m2)
Cutting and mechanical de-rusting or bare grinding of small surfaces (< 0.5 m2)
Inner situation: Full face mask with an FFP3 filter or an airstream helmet with FFP3
Outdoor situation: Face shield with a half mask or a snout with an FFP3 filtering filter below
Dry blasting (****)
If technically feasible, select : Low dust blasting method e.g. wet blasting, torbo blasting or hydro-jet blasting
Blast helmet (independent breathing air supply)
Standard blasting suit and gloves,
Standard measures for dry blasting
Standard measures for dry blasting Showering at the end of the work

19. STEP 5 Management measures to be taken (3)
Toolbox lead and chrome paint
STEP 5 Management measures to be taken (3)
Category
Activity
Technical measure
Breathing protection (***)
PPE
Meassures regarding surrounding area
Aftercare
3. Heavy dust and vapour generation (*)
Welding
Inner situation:
Apply local point extraction with a minimum of HEPA 13 filter directly to the source (distance between the nozzle and the treated surface should be as wide as possible).
Outdoor situation:
Local point extraction if practically applicable
Welding shield /helmet with FFP3 filtering filter + ABE1 filter
Work clothing suitable for welding, cutting and grinding
Lay off the workstation around 6 m or lay off the workstation with screens/foil (**), or carry out work in a welding box. After completion of the work, vacuum the immediate surroundings with a vacuum cleaner with at least HEPA 12 filter (only the visible dust from the work);
Afterwards, vacuum clean the clothing. Wipe tools, reusable PPE and shoes with a damp cloth.
Put contaminated clothing in water-soluble bags and dispose of it (or have it disposed of) in accordance with the regular washing cycle. Showering at the end of the work
Heating / Cutting

20. Points of attention here are: - Work method to be applied
Toolbox lead and chrome paint
Tailor-made solution
If the said control measures are not applicable. Contact the local safety expert and/or occupational hygienist.
In consultation with the client and the executing party, look for a tailor-made solution.
Record tailor-made solutions in writing, possible options are: High Risk Work Permit (mandatory !), BOWR, WPI, SWP.
Points of attention here are:
- Work method to be applied
- Protection of the workplace and surroundings
- Access to the workplace
- Personal protection and hygiene
- Waste treatment
- Methods of monitoring
- Information for employees and the environment

21. Emissions to the environment (categories 2 and 3)
Toolbox lead and chrome paint
Emissions to the environment (categories 2 and 3)
Mark off the workstation 6 m around the object to be machined with a barrier tape. For jobs lasting more than one working day, cordon off with fences.
If this is not possible, the work area around the object to be machined can be fenced off with foil. Place screens as close as possible to the object to be machined. The foil ensures that the chrome (VI) containing substance remains within the deposition.
Afterwards, clean the screens with foil with a vacuum cleaner with at least HEPA 12 filter.
Remove the foil with a damp cloth and then dispose of it as chemical waste.
It is forbidden to clean equipment and clothing with compressed air.

22. Hygiene to prevent inhalation of dust after completion of activities
Toolbox lead and chrome paint
Hygiene to prevent inhalation of dust after completion of activities
Remove contaminated clothing slowly (stop breathing protection)
- For categories 1 and 3: vacuuming clothes before taking them off
- For category 2: disposable coveralls and gloves to be disposed of as chemical waste
- For category 3: Dispose of contaminated clothing in water-soluble bags and dispose of it (or have it disposed of) in accordance with the regular washing route.
Dispose of all disposable PPE and screen film as chemical waste (for NL :blue barrel).
Wash hands and face after work.
Showering after categories 2 and 3: heavy dusting work.

23. Apply the correct environmental measures
Toolbox lead and chrome paint
Apply the correct environmental measures
Collect all spills and dispose of as chemical waste in accordance with your local disposal department (for NL: SF/WMA instructions).
The mobile HEPA vacuum cleaner is equipped with special dust bags. These bags are easy to close so that they can be safely removed.
The HEPA filters of the extraction units may not be changed by the employees themselves. This should be done by a specialized company Dispose of used disposable overalls, screen foil, respiratory protection and gloves as chemical waste after finishing work.
Residue cards: PBMs/filters + dust Pb/Cr-containing paint ( )
available via: (
link is accessible via client (TS NL only)
Discharge of water containing lead and chromium (VI) is NOT permitted. Dispose of in accordance with instruction from your local disposal department (for NL: SF/WMA)

24. Registration in CARE (NL only)
Toolbox lead and chrome paint
Registration in CARE (NL only)
Lead is not a carcinogenic or mutagenic substance. There will be no registration in CARE in accordance with IJmuiden QHSE 2.16.
Chromium (VI) does fall under the category of carcinogenic substances. Registration will take place under the conditions that apply according to IJmuiden QHSE 2.16:
Tata Steel employees; temporary employees and secondees who work under the authority of Tata Steel.
The exposure has been higher than the background level.
An analysis has confirmed that the coating contains chromium (VI).
Employee is directly involved in carrying out activities involving dust formation.
Registration is possible via a special CARE registration form. This form can be completed per work unit/service unit (a list per WE/SU) and delivered to the HSE Front Office. HSE takes care of the further processing.

25. General information for IJmuiden
Toolbox lead and chrome paint
General information for IJmuiden
Information on applicable PPE:
the benefit of %20chromate).pptx
Order test kits and vacuum cleaners:
Contact the WE/SU designated contact person:
bestellen%20testkits%20chrome6.xlsx
For further questions please contact HSE Frontoffice
Tel. no.: 93030

26. Toolbox lead and chrome paint
Attendance list: Toolbox Working safely with paint containing lead and chrome (VI)Course ID: HSE-IJ-Overig-0013 (NL only)
Personnel number
Name
Initials
Trainer:
Date toolbox:
NOTE: Toolbox should be included in the People link training overview of the employee (star).
Send completed attendance sheet to ServicedeskHR, 2H14 or mail to