SSPC-QP 4

May 1, 1997
Editorial Revisions November 1, 2004

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 structures. Simple rolled beam bridges may also be covered

by the requirements of this standard procedure.
1.1 This standard establishes a procedure for evaluating Evaluating Authority: A facility owner or authority des-
the qualifications of contractors whose work involves distur- ignated by the facility owner to review contractor submittals,
bance of hazardous coatings (e.g., containing lead or other conduct on-site evaluations and report results of the evaluation
hazardous metals) incidental to demolition or repair work on determining if the contractor is in compliance with the require-
complex or conventional structures. ments of this procedure.
Hazardous Coatings: Coating systems that contain
1.2 This standard establishes two qualification categories substances (e.g., lead or other hazardous metals) in suf-
for contractors disturbing and containing hazardous paint. The ficient concentrations to create an occupational hazard for
specifying agency shall designate the required qualification the worker exposed to or handling the coating waste, or an
category for the contractor based on the type and level of environmental hazard in the locale where disturbance of the
containment and ventilation required. coating is taking place.
Limited Amounts: Only the minimum amount of paint
1.3 This standard procedure also establishes minimum that should be removed from localized areas to meet regu-
requirements for worker health and safety programs and lations for: flame cutting of existing steel for the purpose of
environmental protection programs utilized by the contractor demolition; arc gouging to disconnect existing steel members;
who disturbs hazardous coatings incidental to demolition or welding of new steel members to existing members; welds for
repair work. the retrofitting of bearings, etc.
Qualification: The procedure by which written assurance
1.4 Contractors qualified under SSPC-QP 2 already meet is given that an applicant conforms to the prescribed set of
the requirements of this standard procedure. conditions or requirements of this standard procedure.
Subcontractor: For the purposes of this qualification
2. Description procedure, the term “subcontractor” is interchangeable with
the term “contractor” and is defined as the same.
2.1 DEFINITIONS
2.2 FUNCTIONS TO BE EVALUATED
Competent Person: One who is capable of identifying
existing and predictable hazards in the surroundings or work- 2.2.1 The qualification process rates four areas: 1) Man-
ing conditions that are unsanitary, hazardous, or dangerous agement of Hazardous Paint Removal; 2) Technical Capabili-
to employees, the public, and the environment, and who has ties; 3) Qualification of Personnel; and 4) Safety Health, and
authorization to take prompt corrective measures to eliminate Environmental Compliance. Specific requirements (evaluation
them. OSHA requires a competent person on-site during items) for each of these areas are presented in Section 4 of
exposure-producing operations. this standard procedure. For special requirements, additional
Complex Structure: Complex structures are those evaluation items may be included.
constructed of steel or concrete, such as metal producing
and rolling mills, bridges, and processing facilities, including 2.2.2 The evaluating authority shall develop specific
chemical and petrochemical processing plants, pulp and paper criteria, scoring, and evaluation schemes for determining the
mills, power plants and substations, and food and beverage qualifications of all contractors based on the evaluation items
plants and terminals. in Section 4. For special requirements, additional evaluation
Contractor: A firm that performs general construction items may be included.
(i.e., demolition and repair work) in the industrial and com-
mercial markets. 2.2.3 The criteria, scoring, and evaluation schemes
Conventional Structures: Structures such as light manu- constitute the “Evaluation Guidelines” used to determine a
facturing plants; miscellaneous and ornamental iron work; sign contractor’s qualifications, using the sequence of procedures
structures; storage tanks; low rise, truss, beam, and column in Section 5 of this standard procedure.

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May 1, 1997
Editorial Revisions November 1, 2004

2.3 QUALIFICATION CATEGORIES 40 CFR, Subchapter I “Solid Wastes” (parts 260-263

and 268)
2.3.1 This standard procedure establishes two qualification
categories for removing and containing hazardous (e.g., lead- 3.6 U.S. DEPARTMENT OF LABOR, OCCUPATIONAL
based) paint. These categories differ in the extent of contain- HEALTH & SAFETY ADMINISTRATION (OSHA):
ment and ventilation required, based on the amount of dust
and debris likely to be generated during repair and demolition. OSHA Guidelines on Workplace Safety and Health
Note: This standard procedure is primarily geared toward lead Program Management (Issued as 54 FR 3904,
paint removal work. However, if chromium or other hazardous January 26, 1989)
materials are present in the previously applied coating system, OSHA Instruction CPL 2-2.58, Inspection and Compli-
the contractor is expected to be familiar with OSHA and EPA ance Procedures for 29 CFR 1926.62, Lead Expo-
requirements for handling these materials. sure in Construction, Interim Final Rule

2.3.2 Category A: This category consists primarily of 4. Qualification Requirements

chemical stripping and power tool cleaning within contain-
ment in accordance with Class 1C or 1P of SSPC-Guide 6. The contractor shall meet the requirements of 4.1 through 4.4.
Contractors qualifying for Category A automatically qualify for
Category B. 4.1 MANAGEMENT OF HAZARDOUS PAINT RE-
MOVAL
2.3.3 Category B: This category consists primarily of
chemical stripping and power tool cleaning within containment 4.1.1 Contractor’s Company Policy: The company
in accordance with Class 2C, 3C, 2P or 3P of SSPC- Guide mission or policy statement shall state in writing that the con-
6. Qualification for Category B does not automatically include tractor is committed to the protection of workers and the public
qualification for Category A. from occupational and environmental hazards associated with
disturbance of lead-based or other hazardous paint during
3. Referenced Standards demolition or repair work. The contractor should take steps to
protect domestic and wild animals, fowl, and fish. The contrac-
3.1 The latest issue, revision, or amendment of these tor must also present the policy to all employees verbally to
standards and other references shall govern unless otherwise reinforce the spirit of the contractor’s mission and ensure that
noted. employees who cannot read English understand it.

3.3 If there is a conflict between the requirements of any 4.1.2 Authority and Responsibility of Competent
of the references and this procedure, the requirements of the Persons
procedure shall prevail.
a. Authority: The “competent person,” as defined in
3.4 SSPC STANDARDS: sections 2.1 and 4.3.1, shall have the complete support of
top management and the written authority to ensure that op-
Guide 6 Guide for Containing Debris erations are carried out in accordance with compliance plans
Generated During Paint Removal and governmental regulations, independent of production
Operations pressures. To ensure independence, competent persons shall
Guide 7 Guide for the Disposal of Lead- report directly to a manager not involved with production. The
Contaminated Surface Preparation competent person may have additional responsibilities and
Debris carry out other work assignments, but shall not routinely be a
QP 2 Standard Procedure for Evaluat- production member of the work crew.
ing the Qualifications of Painting b. Responsibility: The competent person shall be re-
Contractors to Remove Hazardous sponsible for overseeing hazardous paint removal operations.
Paint Responsibilities shall include:
1. Monitoring effectiveness and ensuring the contin-
3.5 U.S. GOVERNMENT CODE OF FEDERAL REGU- ued integrity of environmental controls.
LATIONS: 2. Monitoring worker exposure or overseeing monitor-
ing activities performed by others.
29 CFR, Part 1926 "Safety and Health Regulations for 3. Ensuring that a hazard communication program
Construction" and other applicable training has been conducted
40 CFR, Part 50 Appendix G, “NationalAmbient Air for the contractor’s personnel on site.
Quality Standard for Lead” 4. Ensuring that employees working in the exposure
area are wearing personal protective equipment

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May 1, 1997
Editorial Revisions November 1, 2004

and are trained in the use of such equipment and • Assessing quantity of emissions and worker expo-
in the use of exposure control methods, personal sure.
hygiene facilities, respiratory protection, and de-
contamination practices. 4.2.3 Requirements for Category B: The contractor shall
5. Ensuring that the engineering controls in use are in demonstrate competence in the following:
operating condition and functioning properly. • Protecting, storing, and labeling hazardous materials
6. Ensuring that fugitive emissions to air, water, or and waste (see Section 4.4.2).
soil are minimized and that handling of all waste • Operation, maintenance, and safety when using chemi-
streams is in compliance with applicable regula- cal stripping equipment and materials, power tools, or
tions and contract specifications. other paint removal equipment.
7. Ensuring that regulated areas are marked off and • Maintaining employee exposures below the appropriate
controlling access to them. OSHA Permissible Exposure Limit (PEL) first through
8. Maintaining project documentation, such as expo- use of engineering and work practice controls to the
sure assessment results, ventilation performance extent that such controls are feasible and secondarily
checks, respirator fit tests, personal monitoring through use of respiratory protection that complies with
results, results of site safety inspections, medical current OSHA regulations.
surveillance results, etc., in accordance with the • Coating removal using containment and ventilation that
programs required in Section 4.4. meet Class 2C, 3C, 2P, or 3P of SSPC-Guide 6.
• Assessing quantity of emissions and worker expo-
4.1.3 Information Resources: The contractor shall iden- sure.
tify a source for obtaining information on relevant regulations
pertaining to hazardous paint removal and industrial hygiene 4.2.4 Verifying Qualification Categories: Contractors
procedures. A reference file of information shall be maintained shall submit evidence of successfully meeting the specification
at the job site or be readily accessible. (See Section 4.2.5 for requirements of hazardous paint removal jobs, using environ-
types of references.) mental controls in accordance with the owner’s specifications.
Evidence shall include documentation of hazardous paint
4.2 TECHNICAL CAPABILITIES removal jobs in which the contractors are currently involved or
that they have completed in the last 24 months. Documentation
4.2.1 Qualification Categories: The contractor shall meet shall include the following.
the requirements for the qualification category specified (see a. Description of the jobs, including:
Section 2.3). The requirements for qualification categories A • Facility name, address, and principal contact.
and B are given in Sections 4.2.2 and 4.2.3. Note: In addition • Brief description of structure and work performed,
to the requirements given in Sections 4.2.2 and 4.2.3, the including dates on site.
contractor must also meet all the other requirements of this • Method used to disturb paint.
standard procedure. • Environmental controls used.
• Types of containment and ventilation used, if ap-
4.2.2 Requirements for Category A: The contractor shall plicable.
demonstrate competence in the following: • Portion of project specification dealing with safety,
• Protecting, storing, and labeling hazardous materials health, and environmental control.
and waste (see Section 4.6.1). • Name of competent person on site.
• Operation, maintenance, and safety when using water b. Verification of successful completion of the jobs de-
jetting, wet abrasive blast, dry abrasive blast, power scribed, including compliance with applicable federal,
tool cleaning or other coating removal equipment. state, and local regulations enforceable during the
• Coating removal using containment and ventilation project.
that meets the requirements of Class 1A or 2A, or
1W or 1P of SSPC-Guide 6. 4.2.5 Technical Library: The contractor shall have an
• Operation, maintenance, and safety when using up-to-date library of industrial and governmental resources on
abrasive or water recovery equipment. subjects related to hazardous paint removal, including:
• Maintaining employee exposures below the ap- a. Relevant federal, state, and local occupational safety
propriate OSHA Permissible Exposure Limit (PEL) and health standards, regulations, compliance direc-
first through use of engineering and work practice tives, and guidelines.
controls to the extent that such controls are feasible b. Ventilation standards and procedures, if applicable.
and secondarily through use of respiratory protection c. Relevant federal, state, and local environmental
that complies with current OSHA regulations. regulations regarding solid and hazardous waste and
• Coating removal using containment and ventilation on air, water, and soil quality.
that meet the requirements of Class 1C or 1P of d. Containment guidelines and technical data sheets
SSPC-Guide 6 (e.g., equipment operating manuals).

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May 1, 1997
Editorial Revisions November 1, 2004

e. Applicable paint removal methods. c. Procedures for handling hazardous materials and
f. Waste collection, handling, and disposal guide- waste.
lines. d. Contents of the contractor’s general and site-spe-
g. Industrial hygiene and safety practices. cific written compliance plans, as required in Sec-
tion 4.4.
4.3 PERSONNEL QUALIFICATIONS AND TRAINING
4.4 REQUIRED WORKER PROTECTION AND ENVI-
4.3.1. Competent Person Training and Experience: RONMENTAL COMPLIANCE PROGRAMS
Evidence or documentation shall be furnished that the com-
petent person has had at least 24 hours of training and has 4.4.1 Worker Protection Procedures and Record-
the experience described below in Section 4.3.1.b. NOTE: keeping Systems: The contractor shall have on site a written
Proposed Environmental Protection Agency (EPA) regula- worker protection plan based on the applicable requirements
tions may require more than 24 hours of training to comply of 29 CFR 1926.62 (Construction Industry) and OSHA and
with Title X. National Institute for Occupational Safety and Health (NIOSH)
a. Training of the competent person shall include: lead in construction guidelines and compliance directives. This
1. Relevant hazardous and solid waste handling program shall include, at a minimum:
procedures. a. Defined responsibilities for a safety coordinator,
2. Relevant portions of the following regulations who shall have training in industrial hygiene and
and standards: 1) National Ambient Air Qual- safety. This person may be on the contractor’s
ity Standards (NAAQS); 2) OSHA Construction staff, or the contractor may utilize the services of
Industry Standards; 3) EPA solid and hazardous an industrial hygiene or safety professional with
waste regulations; 4) EPA site clean-up and spill knowledge of hazardous paint removal operations.
response regulations; and 5) relevant state and Since the competent person is required to be on
local regulations. site to implement all compliance activities, it is not
3. Different removal methods, classes of contain- necessary for the safety coordinator to be on site
ment, and environmental controls consistent at all times. However, the safety coordinator should
with one or more of the qualification categories be available for consultation as needed.
specified in Section 4.2. b. Evidence that the written worker protection plan
4. All aspects of training specified in Section 4.3.2. has been reviewed and approved by an industrial
5. Relevant safety practices outlined in Section hygiene or safety professional.
4.4. c. Provisions for exposure monitoring.
6. Annual refresher training, at a minimum of eight d. Details of hazardous materials compliance plan,
hours per year. including provisions for:
b. Experience of the competent person shall include: 1. Protective clothing
1. Minimum of two years of related experience. • working clothes provided by employer
2. Experience in relevant safety practices. • laundry provided by employer
3. Experience in waste handling procedures rela- • changing work clothes prior to leaving the work
tive to projects described in Section 4.2. site
4. Experience in environmental monitoring relative 2. Housekeeping
to projects described in Section 4.2. • delineation of clean and contaminated areas
• delineation and usage of equipment storage
4.3.2 Production and Support Worker Training: areas
Evidence or documentation shall be furnished that produc- • periodic dust and waste clean up
tion and support personnel (i.e., those involved in hazardous 3. Hygiene
paint removal operations or related work) shall have had at • hand-washing facilities
least eight hours of training annually. Note: Proposed EPA • showers with separate clean and contaminated
regulations may require more than eight hours of training in areas for clothing storage and changing
the future; at a minimum, the training program shall include • separate worker break and eating areas
the following: 4. Medical surveillance
a. Contents of 29 CFR 1926.21, 1926.59, 1926.62, • pre- and post-job blood testing and physical•
and any EPA regulations in effect to comply with • periodic blood testing
Title X. • medical removal protection in accordance with
b. Awareness of the types of operations with lead OSHA
or other hazardous materials that could result in 5. Training
exposure exceeding the action levels. If no action • use of equipment
level exists, use half of the Permissible Exposure • use and maintenance of respirators
Limit (PEL) as the threshold.

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• safety, such as the use of scaffolding, eye risks associated with disturbance of hazardous paint,
and ear protection, and signs and in industrial hygiene.
6. Recordkeeping e. Other evidence of effectiveness of programs and
• OSHA 200 log qualifications outlined in Sections 4.1 through 4.4
• medical surveillance (e.g., OSHA 200 log and blood lead level monitoring
• exposure monitoring records).
• training f. Copies of safety and environmental compliance
e. Respiratory protection and medical surveillance programs.
program g. Copies of citations issued to the contractor for serious
f. Employee site-specific training or willful violations of federal, state, or local regula-
tions.
4.4.2 Environmental Compliance Plan: The contrac-
tor shall have a written plan to protect the environment from 6. Evaluation Sequence
hazardous materials located at the job site. This plan shall
include, at a minimum: 6.1 SUBMITTAL OF WRITTEN APPLICATION PACKAGE:
The initial step is to request an application form and instructions.
a. An environmental protection plan detailing how The request, along with an application fee, must be submitted
the contractor controls discharges to air, soil, and to the qualifying agency.
water.
b. A hazardous waste materials management and The application process involves gathering required
disposal plan. (See SSPC-Guide 7 and 40 CFR, information about the contractor or shop as described in the
Subchapter 1, “Solid Wastes” parts 260-263 and application form. This information and documentation will be
268.) submitted to the qualifying agency at the same time as the
formal application for qualification.
4.4.3 Monitoring Plan: The contractor shall have a written
procedure specifying monitoring criteria and a resulting ac- 6.2 REVIEW OF APPLICATION PACKAGE: The contrac-
tion plan for the competent person. The plan shall require the tor’s application package is reviewed by the qualifying agency
competent person to be on site at all times (unless otherwise using guidelines for evaluation that have been established by
authorized) during paint-disturbing operations. Instructions shall that agency. The evaluation items are based on Sections 4
require this person, independent of production pressures, to and 5 of this document.
stop non-conforming operations (i.e., work that deviates from
the safety and environmental compliance programs). This pro- 6.3 ON-SITE AUDIT OF CONTRACTOR: Subject to
cedure shall also provide for a qualified back-up person in the satisfactory evaluation of the application package referred
event that the competent person is absent from the job site. to Sections 4 and 5 and on a date mutually agreed upon by
the contractor and the qualifying agency (unless the audit is
4.4.4 Enforcement: The contractor shall document that unannounced), the qualifying agency’s auditor will visit the
procedures and policies are in effect to ensure that the worker contractor’s premises and complex structure job site or shop
safety and environmental plans are enforced. floor where thermal spray application is being performed to
investigate and rate the following areas directly and indirectly
5. Determining Qualifications affecting quality of work provided: Management Procedures;
Technical Capabilities; Quality Control; and Safety and Health.
5.1 CONTRACTOR SUBMITTALS: The contractor seek- The auditor will perform the following:
ing qualification shall submit to the evaluating authority written • Confirm data submitted with the application for quali-
documentation of the firm’s qualifications with respect to all fication.
items addressed in Section 4. These must include the follow- • Conduct interviews with key supervisory personnel
ing, at a minimum: and some subordinate employees.
a. Experience of contractor in operations that result in • Observe and rate the organization and operation,
disturbance of hazardous paint or related work. including management procedures, technical capabili-
b. Names of representatives of facility owners or prime ties, quality control, and safety and health programs
contractors for whom work was performed, and dates and procedures.
of work. • Examine and rate equipment and facilities.
c. Evidence that the contractor has designated specific The on-site audit will usually require from one to three
individuals as competent persons who are qualified to days to complete.
supervise hazardous paint removal or related work.
d. Specific training and certification of production and 6.4 EXIT INTERVIEW: Following the site audit, and be-
support personnel in the environmental and health fore the auditor leaves the site, an exit interview will be held.

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At the exit interview, the auditor will review observations and by the contractor and the qualifying agency. If the arbitration
the evaluation with the contractor, including discussions of panel does not find for the contractor, the contractor will be
deficiencies and omissions, if any. A written list of deficiencies responsible for payment of all fees and expenses. Any other
and omissions will be provided to the site supervisor, who will costs incurred by any party to the dispute will be borne by
be asked to confirm receipt of the list. Every attempt will be that party.
made by the auditor during the exit interview to fully explain
how the evaluation was conducted. 6.7 RECONFIRMATION OF QUALIFICATION:

6.5 EVALUATION OF APPLICATION AND DETERMINA- 6.7.1 Internal Audit: The contractor shall at his own ex-
TION OF STATUS: At the conclusion of the evaluation process, pense perform an annual internal audit, based on the require-
the auditor will report the findings to the qualifying agency, ments of Sections 4 and 5 above, following initial qualification.
which will make the final decision regarding applicant status The results of this internal audit will be forwarded to the qualifying
based on the following options: agency, with a copy retained on file by the contractor or shop,
and will be made available to the auditor upon request during
6.5.1 Qualify: The auditor has determined that the con- any announced or unannounced audits.
tractor has met or exceeded the requirements of Sections 4
and 5 above. The qualifying agency will make final determina- 6.7.2 Reconfirmation of Qualification - Owner Com-
tion of the contractor’s qualification status based on the audit ments: Owners for whom the contractor performs work will be
results and disciplinary or other evaluation criteria defined in given an opportunity to comment on the qualified contractor’s
the application materials. Upon review of all information, the performance by completing an owner comment form provided
qualifying agency will issue a certificate identifying the contrac- by the qualifying agency. Comments will be in the form of
tor by name and by location of the contractor’s home office. replies to specific questions asked of owners regarding per-
Subsequent annual reconfirmation is subject to the qualifying formance on specific jobs. All owner replies will be treated as
agency’s requirements. confidential.

6.5.2 Withhold Qualification: Based on audit results and 6.8 REVOCATION: Failure to satisfactorily complete the
other factors, the qualifying agency has determined that the annual internal audit or pass unannounced audit(s) or failure
contractor or shop has not met the requirements of Sections 4 to meet disciplinary or other evaluation criteria established by
and 5 above. If qualification is withheld, the qualifying agency the qualifying agency will be cause for suspension or revoca-
shall submit to the contractor or shop an itemization of deficien- tion of certification.
cies that resulted in the decision to withhold qualification. The
contractor or shop will be allowed 90 days after notification to 6.9 QUALIFICATION PERIOD: The qualifying agency
submit corrective actions, and request an audit to verify that shall determine the time period for which qualification shall
corrective actions have been implemented as stated by the be valid, and the requalification schedule during the qualifica-
contractor or shop. tion period.

6.6 METHOD OF APPEAL: If a contractor disputes the 6.10 QUALIFYING AGENCY FILES: The qualifying
qualifying agency’s decision, the contractor may appeal, utiliz- agency will maintain a list of certified thermal spray applica-
ing the following steps of recourse: tion contractors, as well as pertinent information submitted by
a. The contractor shall notify the qualifying agency within owners and users who have utilized the contractor’s services.
10 working days after notification of audit results, This information will assist in the validation process during the
identifying the specific reasons for the appeal. certification term.
b. The contractor may arrange with the qualifying agency All information gathered will be used only for purposes
to have a second independent auditor acceptable to intended. Information determined to be proprietary in nature
both parties brought in at the contractor’s expense to will be treated as confidential.
inspect and re-evaluate the contractor for compliance
with the standard’s requirements. 7. Disclaimer
In the event one of the foregoing step fails to resolve the
dispute, a mutually agreed-upon arbitration panel consisting 7.1 While every precaution is taken to ensure that all infor-
of three persons (one person chosen by the contractor, one by mation furnished in SSPC documents is as accurate, complete,
SSPC, and one agreed upon by both parties) with expertise and useful as possible, SSPC cannot assume responsibility
in thermal spray contracting operations or protective coating nor incur any obligation resulting from the use of any methods
operations will convene to hear evidence and make a final specified therein, or of the standard procedure itself.
decision. If the arbitration panel finds for the contractor, the
cost of all fees and expenses of the arbitration will be shared

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7.2 This procedure does not attempt to address all problems

concerning safety and health associated with its use. The user
of this procedure, as well as the user of all products or prac-
tices described herein, is responsible for instituting appropriate
health and safety practices and for ensuring compliance with
all governmental regulations.

Appendix A. Additional References

The references below are listed for information only and

do not constitute a part of this standard procedure.
ANSI/ASC Z9.4 — Ventilation and Safe Practice For
Exhaust Systems Abrasive Blasting Operations, American
National Standards Institute, 1430 Broadway, New York, NY
10018.
ANSI/AIHA Z88.2 - 1992 — Practices for Respiratory
Protection. American National Standards Institute.
Code of Federal Regulations: 40 CFR, Part 745, Lead;
Requirements for Lead-based Paint Activities: Proposed Rule
(found in Federal Register, Vol. 59, No. 170, September 2,
1994, pps. 45872-45921).
Industrial Ventilation Manual: A Recommended Practice
(most recent edition), American Conference of Governmental
Industrial Hygienists, 6500 Glenway, Building D-5, Cincinnati,
OH 45211.

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