SSPC-QP 4

May 1, 1997
Editorial Changes September 1, 2000

SSPC: The Society for Protective Coatings

QUALIFICATION PROCEDURE NO. 4
Standard Procedure for Evaluating the Qualifications of Contractors
Disturbing Hazardous Coatings During Demolition and Repair Work

1. Scope work; sign structures; storage tanks; low rise, truss, beam,
and column structures. Simple rolled beam bridges may
1.1 This standard establishes a procedure for evaluat- also be covered by the requirements of this standard proce-
ing the qualifications of contractors whose work involves dure.
disturbance of hazardous coatings (e.g., containing lead or Evaluating Authority: A facility owner or authority
other hazardous metals) incidental to demolition or repair designated by the facility owner to review contractor submit-
work on complex or conventional structures. tals, conduct on-site evaluations and report results of the
evaluation determining if the contractor is in compliance
1.2 This standard establishes two qualification catego- with the requirements of this procedure.
ries for contractors disturbing and containing hazardous Hazardous Coatings: Coating systems that contain
paint. The specifying agency shall designate the required substances (e.g., lead or other hazardous metals) in suffi-
qualification category for the contractor based on the type cient concentrations to create an occupational hazard for
and level of containment and ventilation required. the worker exposed to or handling the coating waste, or an
environmental hazard in the locale where disturbance of the
1.3 This standard procedure also establishes minimum coating is taking place.
requirements for worker health and safety programs and
Limited Amounts: Only the minimum amount of paint
environmental protection programs utilized by the contrac-
that should be removed from localized areas to meet regu-
tor who disturbs hazardous coatings incidental to demolition
lations for: flame cutting of existing steel for the purpose of
or repair work.
demolition; arc gouging to disconnect existing steel mem-
bers; welding of new steel members to existing members;
1.4 Contractors qualified under SSPC-QP 2 already
welds for the retrofitting of bearings, etc.
meet the requirements of this standard procedure.
Qualification: The procedure by which written assur-
ance is given that an applicant conforms to the prescribed
2. Description set of conditions or requirements of this standard proce-
dure.
2.1 DEFINITIONS
Subcontractor: For the purposes of this qualification
procedure, the term “subcontractor” is interchangeable with
Competent Person: One who is capable of identifying
the term “contractor” and is defined as the same.
existing and predictable hazards in the surroundings or
working conditions that are unsanitary, hazardous, or dan-
2.2 FUNCTIONS TO BE EVALUATED
gerous to employees, the public, and the environment, and
who has authorization to take prompt corrective measures
2.2.1 The qualification process rates four areas: 1)
to eliminate them. OSHA requires a competent person on-
Management of Hazardous Paint Removal; 2) Technical
site during exposure-producing operations.
Capabilities; 3) Qualification of Personnel; and 4) Safety
Complex Structure: Complex structures are those
Health, and Environmental Compliance. Specific require-
constructed of steel or concrete, such as metal producing
ments (evaluation items) for each of these areas are pre-
and rolling mills, bridges, and processing facilities, including
sented in Section 4 of this standard procedure. For special
chemical and petrochemical processing plants, pulp and
requirements, additional evaluation items may be included.
paper mills, power plants and substations, and food and
beverage plants and terminals.
Contractor: A firm that performs general construction 2.2.2 The evaluating authority shall develop specific
(i.e., demolition and repair work) in the industrial and com- criteria, scoring, and evaluation schemes for determining
mercial markets. the qualifications of all contractors based on the evaluation
Conventional Structures: Structures such as light items in Section 4. For special requirements, additional
manufacturing plants; miscellaneous and ornamental iron evaluation items may be included.

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COPYRIGHT The Society for Protective Coatings
Licensed by Information Handling Services
 SSPC-QP 4
May 1, 1997
Editorial Changes September 1, 2000

Remove Hazardous Paint

2.2.3 The criteria, scoring, and evaluation schemes 3.5 U.S. GOVERNMENT CODE OF FEDERAL REGU-
constitute the “Evaluation Guidelines” used to determine a LATIONS:
contractor’s qualifications, using the sequence of proce-
dures in Section 5 of this standard procedure. 29 CFR, Part 1926 Safety and Health Regulations for
Construction”
40 CFR, Part 50 Appendix G, “NationalAmbient Air
2.3 QUALIFICATION CATEGORIES
Quality Standard for Lead”
40 CFR, Subchapter I “Solid Wastes” (parts 260-263
2.3.1 This standard procedure establishes two qualifi-
and 268)
cation categories for removing and containing hazardous
(e.g., lead-based) paint. These categories differ in the
3.6 U.S. DEPARTMENT OF LABOR, OCCUPATIONAL
extent of containment and ventilation required, based on the
HEALTH & SAFETY ADMINISTRATION (OSHA):
amount of dust and debris likely to be generated during
repair and demolition. Note: This standard procedure is
OSHA Guidelines on Workplace Safety and Health
primarily geared toward lead paint removal work. However,
Program Management (Issued as 54 FR 3904,
if chromium or other hazardous materials are present in the
January 26, 1989)
previously applied coating system, the contractor is ex-
OSHA Instruction CPL 2-2.58, Inspection and Compli-
pected to be familiar with OSHA and EPA requirements for
ance Procedures for 29 CFR 1926.62, Lead Exposure
handling these materials.
in Construction, Interim Final Rule
2.3.2 Category A: This category consists primarily of
chemical stripping and power tool cleaning within contain- 4. Qualification Requirements
ment in accordance with Class 1C or 1P of SSPC-Guide 6.
The contractor shall meet the requirements of 4.1 through
Contractors qualifying for Category A automatically qualify
4.4.
for Category B.
4.1 MANAGEMENT OF HAZARDOUS PAINT RE-
2.3.3 Category B: This category consists primarily of
MOVAL
chemical stripping and power tool cleaning within contain-
ment in accordance with Class 2C, 3C, 2P or 3P of SSPC-
4.1.1 Contractor’s Company Policy: The company
Guide 6. Qualification for Category B does not automatically
mission or policy statement shall state in writing that the
include qualification for Category A.
contractor is committed to the protection of workers and the
public from occupational and environmental hazards asso-
3. References ciated with disturbance of lead-based or other hazardous
paint during demolition or repair work. The contractor should
3.1 The standards and references listed in Sections 3.4
take steps to protect domestic and wild animals, fowl, and
through 3.6 form a part of this standard procedure.
fish. The contractor must also present the policy to all
employees verbally to reinforce the spirit of the contractor’s
3.2 The latest issue, revision, or amendment of these
mission and ensure that employees who cannot read En-
standards and other references shall govern unless other-
glish understand it.
wise noted.

4.1.2 Authority and Responsibility of Competent

3.3 If there is a conflict between the requirements of any
Persons
of the references and this procedure, the requirements of
the procedure shall prevail.
a. Authority: The “competent person,” as defined in
sections 2.1 and 4.3.1, shall have the complete support of
3.4 SSPC STANDARDS:
top management and the written authority to ensure that
operations are carried out in accordance with compliance
Guide 6 Guide for Containing Debris Generated During
plans and governmental regulations, independent of pro-
Paint Removal Operations
duction pressures. To ensure independence, competent
persons shall report directly to a manager not involved with
Guide 7 Guide for the Disposal of Lead-Contaminated
production. The competent person may have additional
Surface Preparation Debris
responsibilities and carry out other work assignments, but
shall not routinely be a production member of the work crew.
QP 2 Standard Procedure for Evaluating the
b. Responsibility: The competent person shall be
Qualifications of Painting Contractors to
responsible for overseeing hazardous paint removal opera-

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COPYRIGHT The Society for Protective Coatings
Licensed by Information Handling Services
 SSPC-QP 4
May 1, 1997
Editorial Changes September 1, 2000

tions. Responsibilities shall include: that meets the requirements of Class 1A or 2A, or
1. Monitoring effectiveness and ensuring the contin- 1W or 1P of SSPC-Guide 6.
ued integrity of environmental controls. • Operation, maintenance, and safety when using
2. Monitoring worker exposure or overseeing monitor- abrasive or water recovery equipment.
ing activities performed by others. • Maintaining employee exposures below the appro-
3. Ensuring that a hazard communication program priate OSHA Permissible Exposure Limit (PEL)
and other applicable training has been conducted first through use of engineering and work practice
for the contractor’s personnel on site. controls to the extent that such controls are fea-
4. Ensuring that employees working in the exposure sible and secondarily through use of respiratory
area are wearing personal protective equipment protection that complies with current OSHA regula-
and are trained in the use of such equipment and in tions.
the use of exposure control methods, personal • Coating removal using containment and ventilation
hygiene facilities, respiratory protection, and that meet the requirements of Class 1C or 1P of
decontamination practices. SSPC-Guide 6
5. Ensuring that the engineering controls in use are in • Assessing quantity of emissions and worker expo-
operating condition and functioning properly. sure.
6. Ensuring that fugitive emissions to air, water, or soil
are minimized and that handling of all waste 4.2.3 Requirements for Category B: The contractor
streams is in compliance with applicable regulations shall demonstrate competence in the following:
and contract specifications. • Protecting, storing, and labeling hazardous materials
7. Ensuring that regulated areas are marked off and and waste (see Section 4.4.2).
controlling access to them. • Operation, maintenance, and safety when using chemi-
8. Maintaining project documentation, such as cal stripping equipment and materials, power tools, or
exposure assessment results, ventilation perfor- other paint removal equipment.
mance checks, respirator fit tests, personal • Maintaining employee exposures below the appropriate
monitoring results, results of site safety inspections, OSHA Permissible Exposure Limit (PEL) first through
medical surveillance results, etc., in accordance use of engineering and work practice controls to the
with the programs required in Section 4.4. extent that such controls are feasible and secondarily
through use of respiratory protection that complies with
4.1.3 Information Resources: The contractor shall current OSHA regulations.
identify a source for obtaining information on relevant regu- • Coating removal using containment and ventilation that
lations pertaining to hazardous paint removal and industrial meet Class 2C, 3C, 2P, or 3P of SSPC-Guide 6.
hygiene procedures. A reference file of information shall be • Assessing quantity of emissions and worker exposure.
maintained at the job site or be readily accessible. (See
Section 4.2.5 for types of references.) 4.2.4 Verifying Qualification Categories: Contrac-
tors shall submit evidence of successfully meeting the
4.2 TECHNICAL CAPABILITIES specification requirements of hazardous paint removal jobs,
using environmental controls in accordance with the owner’s
4.2.1 Qualification Categories: The contractor shall specifications. Evidence shall include documentation of
meet the requirements for the qualification category speci- hazardous paint removal jobs in which the contractors are
fied (see Section 2.3). The requirements for qualification currently involved or that they have completed in the last 24
categories A and B are given in Sections 4.2.2 and 4.2.3. months. Documentation shall include the following.
Note: In addition to the requirements given in Sections 4.2.2 a. Description of the jobs, including:
and 4.2.3, the contractor must also meet all the other • Facility name, address, and principal contact.
requirements of this standard procedure. • Brief description of structure and work performed,
including dates on site.
4.2.2 Requirements for Category A: The contractor • Method used to disturb paint.
shall demonstrate competence in the following: • Environmental controls used.
• Protecting, storing, and labeling hazardous materi- • Types of containment and ventilation used, if appli-
als and waste (see Section 4.6.1). cable.
• Operation, maintenance, and safety when using • Portion of project specification dealing with safety,
water jetting, wet abrasive blast, dry abrasive blast, health, and environmental control.
power tool cleaning or other coating removal equip- • Name of competent person on site.
ment. b. Verification of successful completion of the jobs
• Coating removal using containment and ventilation described, including compliance with applicable
federal, state, and local regulations enforceable
during the project.
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COPYRIGHT The Society for Protective Coatings
Licensed by Information Handling Services
 SSPC-QP 4
May 1, 1997
Editorial Changes September 1, 2000

4.2.5 Technical Library: The contractor shall have an least eight hours of training annually. Note: Proposed EPA
up-to-date library of industrial and governmental resources regulations may require more than eight hours of training in
on subjects related to hazardous paint removal, including: the future; at a minimum, the training program shall include
a. Relevant federal, state, and local occupational the following:
safety and health standards, regulations, compli- a. Contents of 29 CFR 1926.21, 1926.59, 1926.62,
ance directives, and guidelines. and any EPA regulations in effect to comply with
b. Ventilation standards and procedures, if applicable. Title X.
c. Relevant federal, state, and local environmental b. Awareness of the types of operations with lead or
regulations regarding solid and hazardous waste other hazardous materials that could result in
and on air, water, and soil quality. exposure exceeding the action levels. If no action
d. Containment guidelines and technical data sheets level exists, use half of the Permissible Exposure
(e.g., equipment operating manuals). Limit (PEL) as the threshold.
e. Applicable paint removal methods. c. Procedures for handling hazardous materials and
f. Waste collection, handling, and disposal guidelines. waste.
g. Industrial hygiene and safety practices. d. Contents of the contractor’s general and site-
specific written compliance plans, as required in
4.3 PERSONNEL QUALIFICATIONS AND TRAINING Section 4.4.

4.3.1. Competent Person Training and Experience: 4.4 REQUIRED WORKER PROTECTION AND ENVI-
Evidence or documentation shall be furnished that the RONMENTAL COMPLIANCE PROGRAMS
competent person has had at least 24 hours of training and
has the experience described below in Section 4.3.1.b. 4.4.1 Worker Protection Procedures and Record-
NOTE: Proposed Environmental Protection Agency (EPA) keeping Systems: The contractor shall have on site a
regulations may require more than 24 hours of training to written worker protection plan based on the applicable
comply with Title X. requirements of 29 CFR 1926.62 (Construction Industry)
a. Training of the competent person shall include: and OSHA and National Institute for Occupational Safety
1. Relevant hazardous and solid waste handling and Health (NIOSH) lead in construction guidelines and
procedures. compliance directives. This program shall include, at a
2. Relevant portions of the following regulations minimum:
and standards: 1) National Ambient Air Quality a. Defined responsibilities for a safety coordinator,
Standards (NAAQS); 2) OSHA Construction who shall have training in industrial hygiene and
Industry Standards; 3) EPA solid and hazardous safety. This person may be on the contractor’s
waste regulations; 4) EPA site clean-up and spill staff, or the contractor may utilize the services of an
response regulations; and 5) relevant state and industrial hygiene or safety professional with
local regulations. knowledge of hazardous paint removal operations.
3. Different removal methods, classes of contain- Since the competent person is required to be on
ment, and environmental controls consistent with site to implement all compliance activities, it is not
one or more of the qualification categories necessary for the safety coordinator to be on site at
specified in Section 4.2. all times. However, the safety coordinator should be
4. All aspects of training specified in Section 4.3.2. available for consultation as needed.
5. Relevant safety practices outlined in Section 4.4. b. Evidence that the written worker protection plan has
6. Annual refresher training, at a minimum of eight been reviewed and approved by an industrial
hours per year. hygiene or safety professional.
b. Experience of the competent person shall include: c. Provisions for exposure monitoring.
1. Minimum of two years of related experience. d. Details of hazardous materials compliance plan,
2. Experience in relevant safety practices. including provisions for:
3. Experience in waste handling procedures 1. Protective clothing
relative to projects described in Section 4.2. • working clothes provided by employer
4. Experience in environmental monitoring relative • laundry provided by employer
to projects described in Section 4.2. • changing work clothes prior to leaving the work
site
4.3.2 Production and Support Worker Training: Evi- 2. Housekeeping
dence or documentation shall be furnished that production • delineation of clean and contaminated areas
and support personnel (i.e., those involved in hazardous • delineation and usage of equipment storage
paint removal operations or related work) shall have had at areas

571
COPYRIGHT The Society for Protective Coatings
Licensed by Information Handling Services
 SSPC-QP 4
May 1, 1997
Editorial Changes September 1, 2000

• periodic dust and waste clean up

3. Hygiene 5. Determining Qualifications
• hand-washing facilities
• showers with separate clean and contami- 5.1 CONTRACTOR SUBMITTALS: The contractor
nated areas for clothing storage and chang- seeking qualification shall submit to the evaluating authority
ing written documentation of the firm’s qualifications with respect
• separate worker break and eating areas to all items addressed in Section 4. These must include the
following, at a minimum:
4. Medical surveillance a. Experience of contractor in operations that result in
• pre- and post-job blood testing and physical disturbance of hazardous paint or related work.
• periodic blood testing b. Names of representatives of facility owners or
• medical removal protection in accordance with prime contractors for whom work was performed,
OSHA and dates of work.
5. Training c. Evidence that the contractor has designated
• use of equipment specific individuals as competent persons who are
• use and maintenance of respirators qualified to supervise hazardous paint removal or
• safety, such as the use of scaffolding, eye and ear related work.
protection, and signs d. Specific training and certification of production and
6. Recordkeeping support personnel in the environmental and health
• OSHA 200 log risks associated with disturbance of hazardous
• medical surveillance paint, and in industrial hygiene.
• exposure monitoring e. Other evidence of effectiveness of programs and
• training qualifications outlined in Sections 4.1 through 4.4
e. Respiratory protection and medical surveillance (e.g., OSHA 200 log and blood lead level monitor-
program ing records).
f. Employee site-specific training f. Copies of safety and environmental compliance
programs.
4.4.2 Environmental Compliance Plan: The contrac- g. Copies of citations issued to the contractor for
tor shall have a written plan to protect the environment from serious or willful violations of federal, state, or local
hazardous materials located at the job site. This plan shall regulations.
include, at a minimum:
5.2 REVIEW WRITTEN MATERIAL SUBMITTED: The
a. An environmental protection plan detailing how the following steps shall be followed by the evaluating authority
contractor controls discharges to air, soil, and to determine the accuracy of written materials:
water.
b. A hazardous waste materials management and 5.2.1 Compare contractor submittals with criteria listed
disposal plan. (See SSPC-Guide 7 and 40 CFR, in Sections 4.1 through 4.4.
Subchapter 1, “Solid Wastes” parts 260-263 and
268.) 5.2.2 Identify any criteria for which additional informa-
tion is needed.
4.4.3 Monitoring Plan: The contractor shall have a
written procedure specifying monitoring criteria and a re- 5.2.3 Obtain, or direct contractor to obtain, additional
sulting action plan for the competent person. The plan shall information on items identified in Section 5.2.2. Such
require the competent person to be on site at all times information may be gathered by calling owner or prime
(unless otherwise authorized) during paint-disturbing op- contractor references, training organizations, or other knowl-
erations. Instructions shall require this person, independent edgeable services.
of production pressures, to stop non-conforming operations
(i.e., work that deviates from the safety and environmental 5.3 OPTIONAL ON-SITE EVALUATION: The evaluat-
compliance programs). This procedure shall also provide ing authority may choose the option of visiting the contractor’s
for a qualified back-up person in the event that the compe- permanent office, a job site representative of the contractor’s
tent person is absent from the job site. capabilities, or both, to verify information provided in the
submittal. The verification process may include examina-
4.4.4 Enforcement: The contractor shall document tion of field records and interviews with managers, supervi-
that procedures and policies are in effect to ensure that the sors, workers, and owner’s representatives about specific
worker safety and environmental plans are enforced.

572
COPYRIGHT The Society for Protective Coatings
Licensed by Information Handling Services
 SSPC-QP 4
May 1, 1997
Editorial Changes September 1, 2000

safety and technical procedures, training, and operations 6. Disclaimer

conducted by the applicant which resulted in disturbance of
hazardous paint during demolition or repair work. While every precaution is taken to ensure that all infor-
mation furnished in SSPC documents is as accurate, com-
5.4 COMPUTE FINAL RATING: Based on criteria plete, and useful as possible, SSPC cannot assume respon-
established in Section 4 and evaluations in Section 5.2 (and sibility nor incur any obligation resulting from the use of any
5.3 if this option is exercised), determine whether the con- methods specified therein, or of the standard procedure
tractor meets minimum ratings of the functions evaluated to itself.
achieve qualification.
Appendix A. Additional References
5.5 NOTIFY APPLICANT: Review the results of the
evaluation with the contractor, including discussion of omis- The references below are listed for information only and
sions. Inform the contractor whether the firm has met the do not constitute a part of this standard procedure.
authority’s qualification requirements. If the contractor has ANSI/ASC Z9.4 — Ventilation and Safe Practice For
not met requirements, advise of corrective actions and Exhaust Systems Abrasive Blasting Operations, American
establish time for implementation. National Standards Institute, 1430 Broadway, New York, NY
10018.
5.6 CONFIRMATION OF QUALIFICATION: Once quali- ANSI Z88.2 - 1992 — Practices for Respiratory Protec-
fied, the contractor meeting the requirements of this proce- tion. American National Standards Institute.
dure must be re-evaluated annually by the evaluating au- Code of Federal Regulations: 40 CFR, Part 745, Lead;
thority, depending upon criteria set up by the facility owner Requirements for Lead-based Paint Activities: Proposed
or evaluating authority. Rule (found in Federal Register, Vol. 59, No. 170, Septem-
ber 2, 1994, pps. 45872-45921).
5.7 REVOCATION: Failure to pass the aforementioned Industrial Ventilation Manual: A Recommended Prac-
periodic re-evaluation, submit required corrective actions tice (most recent edition), American Conference of Govern-
from a previous evaluation in a timely manner, or submis- mental Industrial Hygienists, 6500 Glenway, Building D-5,
sion of false or misleading information shall be cause for Cincinnati, OH 45211.
revocation of certificate of qualification.

573
COPYRIGHT The Society for Protective Coatings
Licensed by Information Handling Services