Asbestos Concerns

Bridge demolition and renovation projects must comply with EPA's Asbestos Demolition and Renovation Rule. Asbestos issues should be identified early in project development (prior to letting) to allow time to plan and execute abatement work in a manner that minimizes construction impacts and avoids project delays. To assure compliance, TxDOT must:

Refer to the guidance document "Asbestos Procedures for TxDOT Projects" for detailed guidance for addressing project asbestos issues, including inspections, notifications, and abatement. The guidance may be found on the internal TxDOT .

Lead Paint Concerns

Lead compounds are often present in the indutrial grade coatings (paints and primers) applied to structural steel components on bridges and overpasses. Maintenance and demolition activities on steel structures may involve torch cutting, welding, or abrasive blasting on beams and other steel components that are coated with lead-containing paint. OSHA has determined that these activities have an especially high potential for emitting harmful concentrations of lead fumes or particles when lead-containing paint is present.

TxDOT standard specifications direct the contractor to assume coatings on existing steel contain hazardous materials (i.e. lead compounds) unless otherwise shown on the plans. However, when the concentration of lead in paint is known to be less than U.S. Consumer Product Safety Commission threshold for regulation as lead-containing paint in consumer products and toys (90 mg/kg or ppm), mitigation may not be necessary. ENV can assist with testing and guidance for managing lead paint on structures.

Lead-containing paint on steel is a pre-existing hazard. Therefore, when the work requires disturbing these coatings in a manner that could result in exposure exceeding OSHA permissible limits, TxDOT may need to perform lead-hazard mitigation outside of the construction contract. A separate abatement contractor, retained through ENV or District contracting mechanisms, can be used to strip back lead-containing paint at discreet locations prior to torch-cutting, welding, or similar lead-disturbing activities.

Painted steel removal and disposal requirements are addressed under Section 6.10.1, "Painted Steel Requirements", in the 2024 TxDOT

Standard Specifications

. In addition, the guidance document "Management of Lead-Containing Paint in TxDOT Construction Maintenance Projects" includes detailed guidance for identifying and managing lead paint on TxDOT projects and can be found on the internal .

Note that for bridge painting projects using the

Standard Specification

, Item 446 "Cleaning and Painting Steel", mitigation of hazardous materials concerns is addressed in the standard specification. Therefore, a separate contract for hazardous materials/lead abatement should not be needed for most bridge cleaning and painting projects.

Additional Considerations for Asbestos and Lead-Containing Paint Abatement Projects

Asbestos and lead-containing paint abatement work can be costly and take weeks or months to complete, especially for larger structures and projects with multiple structures requiring abatement. When abatement is performed outside of the construction contract, the TxDOT district will be responsible for identifying a funding source to pay for the abatement.

Note that separate, frequent lane closures may be required to perform lead and asbestos abatement work on highway structures. In addition, some common asbestos-contaning materials, such as felt bearing pads and joint materials may not be accessible prior to demolition. For demolition projects involving lead-containing paint, it may be difficult for the department to predict a contractor's preferred cut points for stripping back paint from steel prior to the project. In many such cases, the abatement work can be considered "intrinsic" to the project, and districts should consider including the abatement work in the project PS&E to be performed under the supervision of the prime contractor, in accordance with the procedures described above.

Surplus Materials

The contractor will take ownership of surplus materials unless otherwise shown on the plans or directed. TxDOT will ensure that the contractor removes, transport, and dispose of materials in accordance with federal, state, and local environmental regulations. If requested by the Engineer, the contractor must provide an appropriate level of documentation to verify proper transport and disposal.