Vancouver City Council |
FINAL REPORT ON
Submitted to:
City of Vancouver
453 West 12th Avenue
Vancouver, British Columbia
V5Y-1V4
DISTRIBUTION:
3 Copies - City of Vancouver
2 Copies - Golder Associates Ltd.March 16, 2004 03-1417-027
TABLE OF CONTENTS
SECTION PAGE
1.0 INTRODUCTION 1
2.0 CURRENT REGULATORY AND CONTRACT REQUIREMENTS 2
2.1 Summary of Section 3 of the City Of Vancouver Sewer and Watercourse By-Law No. 8093 2
2.2 Summary of Part 5, Section 5.57, of the British Columbia OHSR 3
2.3 Summary of Part C, Section 4, of the City of Vancouver's RFP PS02031 4TOXICITY ASSESSMENT 5
2.4 Citrus Paint Remover 5
2.5 Summary of the Toxicological Review for Citrus Paint Remover 7
2.6 Other Chemicals 73.0 BEST MANAGEMENT PRACTICES (BMPS) 9
3.1 Prevention in Areas Prone to Graffiti 9
3.2 Health and Safety During Graffiti Removal 9
3.3 Chemical Restrictions 10
3.4 Minimize Use of Water and Cleaning Agents 10
3.5 Use and Containment of Chemical Agents 10
3.6 Spills 11
3.7 Storing Chemicals 11
3.8 Compliance Monitoring 11
3.9 Comparing with other Municipalities 114.0 LIMITATIONS 14
5.0 CLOSURE 15TABLES
Table 1 Summary of Human Health and Environmental Data for Cleaning Products
Table 2 Review of Canadian Cities Graffiti Management and Environmental Protection Practices.
Table 3 Internet Sites of Cities Selected For ReviewAPPENDICES
Appendix I Graffiti Removal Best Management Practices for Specific Methods
1.0 Alkaline Compounds
2.0 Barrier Coatings
3.0 Bleaches
4.0 Mechanical or Abrasive Methods
5.0 Organic Solvents and Paint Removers
6.0 Poulticing
7.0 Pressure WashingAppendix II Toxicological Terminology
Golder Associates Ltd (Golder) was retained by the City of Vancouver ("the City") to carry out an environmental review of graffiti removal practices. The purpose of this review is to help the City minimize environmental impacts from graffiti removal and comply with relevant legislation, regulations and current best management practices.
The City contracts out graffiti removal from City buildings and other municipal infrastructure, such as light poles, bridges, retaining walls, and traffic signs. The City also distributes graffiti removal products to members of the public.
As outlined in the Golder's Proposal "Environmental Review of Graffiti Removal Practices in the City of Vancouver" (Proposal No. P32-1359) the specific objectives of the review include:
· An assessment of Canadian Building Restoration Products Inc. (CBR) Citrus Paint Remover and other graffiti removal chemical products with respect to toxicological properties, ecological information, handling procedures and storage, and disposal considerations; and
· Developing Best Management Practices (BMPs) in accordance with the City of Vancouver's current regulatory requirements with respect to chemical restrictions, containment of wastes including preventive mitigation measures, and compliance monitoring.
The City of Vancouver's current regulatory and contract requirements related to graffiti removal were used as the basis for developing BMPs and are summarized below. Also, the toxicity of Citrus Paint Remover, which the City currently distributes to the public for graffiti removal, and other chemicals used by the City and/or the contractor, were assessed, and the results of this analysis are presented. Best management practices are then recommended with consideration given to the toxicological properties.
References used in developing the BMPs incorporate graffiti removal practices from several major cities in North America including; San Francisco, Seattle, Calgary, Toronto and New York. We wish to acknowledge these cities for providing us with informative documentation.
2.0 CURRENT REGULATORY AND CONTRACT REQUIREMENTS
The City of Vancouver has adopted regulatory and contractual requirements from the following sources:
· City of Vancouver Sewer and Watercourse By-law (No. 8093);
· British Columbia Occupational Health and Safety Regulation (OHSR); and,
· City of Vancouver graffiti removal services request for proposal (RFP P202031).
A summary of these requirements are provided below.
2.1 Summary of Section 3 of the City Of Vancouver Sewer and Watercourse By-Law No. 8093
The relevant section of the City of Vancouver Sewer and Watercourse By-Law No. 8093 is Section 3, "Wastewater and Storm Water Discharge and Quality Standards".
With respect to graffiti removal practices, Section 3 of the Bylaw prohibits:
· Discharge, without express permission, into a sanitary sewer or combined sewer substances which have the following characteristics:
o Solids with particle sizes greater than 0.5 cm in any dimension, suspended solids content of more than 600 milligrams per litre, or garbage;
o Greases at a concentration of 150 milligrams per litre or which contains more than 15 milligrams per litre of substances derived from petroleum sources;
o Acidic or alkaline waste or waste water having a pH lower than 5.5 or higher than 10.5;
o Liquid or vapour having a temperature higher than 65ºC; and,
o Toxic substances.· Discharge, directly or indirectly, or cause to be discharged, into the storm drainage system or watercourse, water or waste having the following characteristics:
o Water or wastes with a total suspended solid content of more than 75 milligrams per litre;
o Water or wastes containing grease in a concentration more than 15 milligrams per litre;
o Acidic or alkaline waste, prior to discharge, having a pH lower than 6.0 or higher than 9.0;
o Chemical wastes;
o Liquids or vapours having a temperature higher than 40ºC; and,
o Deleterious substances as defined in Section 34(1) of the federal Fisheries Act.· Placement, or discharge, or cause to be placed or discharged, into the sewerage system, the storm drainage system, or watercourse any of the following:
o Explosive or flammable substances;
o Poisonous and infectious substances;
o Corrosive or noxious substances;
o Special wastes as defined by the British Columbia Waste Management Act;
o High temperature wastes;
o Truck wastes; and
o Obstructive wastes.In addition, the Bylaw requires that accidental discharges of prohibited substances into public or private sewerage system, storm drainage system or watercourse, be reported.
In accordance with Section 8 of the "Wastewater and Storm Water Discharge and Quality Standards" persons in violation of the provisions of this By-Law may be found guilty of an offence against this By-Law and liable to penalties. Penalty for offences against this By-Law may result in fines of not less than $200 or more than $10,000 for each offence.
2.2 Summary of Part 5, Section 5.57, of the British Columbia OHSR
Part 5 of the British Columbia OHSR refers to hazards associated with "Chemical and Biological Substances". Section 5.57 provides the classification system for chemicals or products that are identified as "Designated Substances". In accordance with the classification system indicated in Section 5.57 of the BC OHSR the City of Vancouver requires that graffiti removal contractors ensure chemicals or products utilized for the removal of graffiti are not listed in Table 5-4 "Exposure Limits for Chemical and Biological Substances" with the following ratings:
· American Conference of Governmental Industrial Hygenists (ACGIH)A1 or A2, or International Agency for Research on Cancer (IARC) 1, 2A or 2B (Carcinogens),
· Reproductive critical effects (Reproductive Toxins),
· Sensitization critical effect or SEN notation (Sensitizers), or
· L endnote (Exposure by all routes should be carefully controlled to levels as low as possible).
In addition to prohibiting the chemicals or products listed in Table 5-4 with the ratings mentioned above the City of Vancouver also prohibits the use of Methylene chloride, a probable carcinogen.
2.3 Summary of Part C, Section 4, of the City of Vancouver's RFP PS02031
In accordance with the City of Vancouver's RFP PS02031, Part C - Special Conditions, Section 4.0, "Product Methodology Safety and Environmental Protection", the graffiti removal contractor is required to:
· Use environmentally sensitive products and/or services;
· Comply with the City of Vancouver Sewer and Watercourse bylaw No. 8093 with particular emphasis placed on Section 3, Sub-sections 3.1-3.4;
· Supply the City of Vancouver, and have available at all times, current copies of Material Safety Data Sheets (MSDS) for each chemical or product that contains a controlled product listed in the Canadian Hazardous Products Act and / or the Canadian Controlled Product Regulations. Information contained within the MSDS must meet the requirements of the Canadian Controlled Products Regulations.
· Provide the worker's training records and written work procedures to the City of Vancouver upon request. The written work procedures must comply with the applicable statements on the MSDS and with the British Columbia Occupational Health and Safety Regulation.
A toxicity assessment was undertaken based on existing, available information for CBR Citrus Paint Remover and other chemicals that are used for graffiti removal. The attached Table 1 provides a summary of the available human health and environmental data for Citrus Paint Remover and other commonly used chemicals.
Depending on the source material used, graffiti may contain a number of chemicals. Graffiti can be from various types of paints, latex, spray paints, or metals based paints. It can also be generated from types of markers that contain solvents such as xylenes. The purpose of this report was not to conduct a toxicological review on each of the chemicals that may be found in the source, however, it is noted that these chemicals may also have some hazardous properties. Chemicals potentially found in graffiti may have the ability to impact aquatic life or contaminate soil. When selecting removal techniques it is important to consider the source material. The primary active ingredient in Graffiti WIPES (manufactured by Total Solutions), dimethyl glutarate has been reviewed and is summarized in Table 1.
There are two active ingredients in Citrus Paint Remover; D-limonene and N-methyl, 2-pyrrolidone. The following presents a brief toxicological summary and recommendations as to personal protection equipment. This information should be provided in conjunction with the MSDS which also contains information related to spills and fire.
D-limonene is a naturally occurring compound that is extracted from the rind of citrus fruits. It is lighter than water, is usually colourless and has an orange aroma. It is commonly used in environmentally friendly cleaning products as an alternative to conventional solvents or caustic agents (e.g., chlorinated solvents, methyl ethyl ketone, xylene, etc.). Limonene is also used as a flavour and fragrance additive in food, household cleaning products, and perfumes. It is one of the active ingredients currently found in ABR Citrus Paint Remover.
The World Health Organization (WHO) provides a comprehensive summary of the toxicity and environmental behaviour of D-limonene. Based on the results of animal testing, the toxicity of D-limonene through various routes of administration (e.g., oral, intravenous, etc.) is considered low. Furthermore, there is currently no evidence that D-limonene or its metabolites are genotoxic or mutagenic. Carcinogenic effects in humans are unlikely. Although laboratory tests involving rats demonstrated increases incidence of renal tumours, the effects were linked to a specific protein (alpha2µ-globulin) found in male rats. The results were not considered relevant to humans and D-limonene is not classified as a carcinogen by Canadian or U.S. agencies (e.g., Health Canada, National Toxicology Program, U.S. Environmental Protection Agency (EPA), etc.). D-limonene also does not appear to cause developmental or reproductive effects.
D-limonene is however considered a skin, eye, respiratory tract and gastrointestinal irritant based on both animal and/or human studies. Skin contact can cause redness, irritation, dermatitis and can aggravate existing skin conditions. Furthermore, ingestion of large quantities could lead to vomiting, headache and other medical problems.
D-limonene is moderately toxic to aquatic organisms such as invertebrates and fish.
D-limonene is, however, biodegradable and would not persist in the environment. Bioaccumulation would likely be limited. In order to minimize environmental impacts, any spills should be dealt with immediately.The main routes of human exposure to D-limonene in cleaning products would be through inhalation and skin/eye contact. In order to limit exposure, gloves (e.g., rubber, nitrile), adequate clothing and eye protection (goggles or face shield) is recommended while using this substance. The product should only be used in well-ventilated areas in order to prevent inhalation and since the compound is combustible. Respiratory protection (approved respirator) may be required for sensitive individuals (e.g., asthmatics) or due to poor ventilation.
N-methyl-2-pyrrolidone (NMP) is a volatile organic solvent that is currently used for extraction in the petrochemical industry, as a paint and graffiti remover and for stripping/cleaning applications in the microelectronics industry. It is also used to formulate pigments, inks, dyes, insecticides, herbicides and other products. It is increasingly being used as a substitute for chlorinated organic solvents. It is clear to slightly yellow liquid, with an amine like odour. It is one of the active ingredients currently found in ABR Citrus Paint Remover.
The acute toxicity of NMP through inhalation and oral administration is considered low. However, high doses can result in nausea, headaches, and gastrointestinal and respiratory discomfort (cough, sneezing, dryness of mouth/throat, etc.). NMP may cause skin and eye irritation (redness, dermatitis, itching, pain, blurred vision). The absorption of chemical through the skin and subsequent distribution through the body can be rapid. Based on the results of animal studies, NMP does not appear to cause cancer, and is not classified as a potential carcinogen by Canadian or U.S. agencies (e.g., Health Canada, National Toxicology Program, U.S. EPA). At high doses NMP has been linked to developmental effects including decreased offspring weights, delayed ossification and behavioural effects. However, typical doses received during the use of an NMP containing product would be considerably less than those associated with developmental or reproductive effects.
Available data indicate that NMP has low toxicity to fish, crustacean, algae and bacteria. NMP is readily biodegradable and would not persist in the environment. Bioaccumulation would also be minimal. In order to limit environmental impacts, any spills should be dealt with immediately.
The main routes of human exposure to NMP in cleaning products would be through inhalation and skin/eye contact. Since NMP is semi-volatile, care should be taken to ensure adequate ventilation to reduce exposure and prevent the build-up of combustible vapours. Furthermore, skin, eye and respiratory exposure should be minimized to prevent irritation of, and absorption through skin and mucous membranes. In order to limit exposure, gloves (e.g., rubber, nitrile), adequate clothing and eye protection (goggles or face shield) is recommended while using the substance. Respiratory protection (approved respirator) may be required for sensitive individuals (e.g., asthmatics) or due to inadequate ventilation.
2.5 Summary of the Toxicological Review for Citrus Paint Remover
In summary, based on the toxicological review conducted, the active ingredients are considered to be of relatively low toxicity. Personal protection measures are recommended to minimize exposure and to minimize low overall hazard. Some persons may be sensitive to these chemicals and should discontinue usage if sensitivity occurs. Personal protection measures including gloves and spray goggles should be used and persons should consider wearing long sleeves and pants or coveralls to further minimize exposure. The active ingredients in this product are found in household cleaning products.
Currently there are numerous graffiti removal products used by contractors or the general public. A literature review was conducted of sources including the US Environmental Protection Agency (EPA), Health Canada and the World Health Organization (WHO) to determine toxicological properties of some common chemicals used for graffiti removal. These products were evaluated as individual chemicals not as formulations, due to lack of product toxicity data. These chemicals have been evaluated assuming they have not been diluted, however, typical product formulations range from 1-5 % of the total volume of solution. For example, while amyl acetate has been classified as having a high dermal and oral toxicity, in a product formulation the chemical concentrations could be ten to one hundred times more dilute and therefore the chemical would be only moderately toxic. The classification for various pathways (i.e.oral route of exposure) was low moderate and high based on guidance from the Ministry of Water Land and Air Protection (MWLAP). Some chemicals do not have adequate studies conducted to determine toxicity and were listed as n/d. Outlined in Appendix II is a summary of toxicological terminology. The ranking system utilized the categories of low, medium and high risk as outlined on the MWLAP website and from information obtained from Material Safety Data Sheets.
(http://wlapwww.gov.bc.ca/epd/epdpa/ips/ghcc/ghcc4.html).
3.0 BEST MANAGEMENT PRACTICES (BMPS)
BMPs are proposed for adoption by the City of Vancouver for graffiti removal. It is intended that these general BMPs would be provided to contractors and members of the public to protect the health and safety of graffiti removal workers and the public, help minimize environmental impacts, and facilitate compliance with applicable legislation and regulations, including the City of Vancouver Sewer and Watercourse Bylaw. We anticipate that the City will use the BMPs provided here to develop a Bulletin or Bulletins for general distribution. BMPs related to specific graffiti removal methods are presented in Appendix I, Documents 1.0-7.0.
3.1 Prevention in Areas Prone to Graffiti
1. Undertake regular maintenance of areas prone to graffiti. Studies have shown that graffiti removed within 72 hours of its appearance have a minimized likelihood of re-occurring at that location (City of Calgary, 2002).
2. Use non-toxic coatings to facilitate graffiti removal in areas that are highly prone to graffiti. Use of coatings can prevent penetration of ink and spray paint into porous substances such as concrete and brick.
3.2 Health and Safety During Graffiti Removal
1. Determine the nature of any cleaning agents that are to be employed prior to undertaking graffiti removal and follow all recommended precautions, including use of personal protective equipment. Refer to, and maintain, the Material Safety Data Sheet (MSDS) for any chemicals that are to be used.
2. Where required erect signs, barriers and all other appropriate means to prevent exposure of any water and/or cleaning agents used in graffiti removal to the public (such as pedestrians, nearby residents, etc.).
3. If using CBR Citrus Paint Remover wear gloves, full clothing and eye protection, and ensure adequate ventilation to avoid build-up of combustible vapours. People with sensitivity to CBR or having respiratory ailments should not engage in use of CBR.
1. Never use chemicals that are restricted under the B.C. Occupational Health and Safety Regulation as being carcinogens, reproductive toxins or sensitizers.
2. Use the least toxic chemical product possible to remove graffiti. For information on toxicity, call the City of Vancouver Graffiti Coordinator at (604) 871-6300.
3. Never mix chemical agents or cleaning products.
3.4 Minimize Use of Water and Cleaning Agents
1. Use the least amount of water possible to remove graffiti. All water used in graffiti removal has the potential to carry ink, paint, other residue on the washed surface, and in some cases particles from the washed surface itself, into the stormwater system.
2. Use the least amount of any chemical products possible. It will be easier to properly apply, contain, clean-up and dispose of small amounts of chemicals.
3.5 Use and Containment of Chemical Agents
1. Ensure all containers are properly labeled in accordance with British Columbia Occupational Health and Safety Regulation. Keep them closed when not in use.
2. Never dump any chemical agent or cleaning product down open sewers. This includes wash water from cleaning paint brushes or rags.
3. Provide inlet protection such as filter cloth or tarpaulin to storm water catch basins and sewer drain covers.
4. Keep empty paint cans, allow them to dry, and take them to the paint recycling centre for disposal.
5. Keep any excess or leftover paint in the original container. Contractors working with large volumes of paint products may collect products into drums or other appropriate containers. Paint products should not be mixed. Waste paint should be disposed of by a chemical disposal contractor.
6. Brushes should be washed in an acceptable work environment preferably with containment of waste water or cleaners. Small volumes of rinse water can be treated at the sewage treatment plant. Do not pour brush wash water into an open sewer, it will be discharged to a watercourse and waterbody and may be hazardous to fish and other aquatic organisms. Solvents are a prohibited waste and shall not be discharged into the sewer or drainage systems.
7. Return leftover Citrus Paint Remover to City of Vancouver for reuse.
1. Contain and curb any spill so that it does not enter the stormwater system. Wipe up a small spill with a rag immediately. Report a large spill of a chemical agent (greater than 1L) to the City of Vancouver Environmental Protection Branch at (604) 873-7528. Clean up the spill (if it is safe to do so) once the spill is contained.
1. Keep stored containers cool and dry. Do not store containers near any source of heat or flame, or in damp or wet areas.
2. Store rags used to clean up chemicals in an appropriate container.
1. Contractors will provide work schedules and removal methods to the City of Vancouver prior to the commencement of works.
2. Monitoring of contractor compliance will be carried out by City officials without prior notice.
3. Questions concerning practices or bylaw violations should be directed to the City of Vancouver Environmental Protection Office.
3.9 Comparing with other Municipalities
At the request of the City of Vancouver Golder carried out a review of the graffiti management and environmental protection practices of 5 major Canadian cities. The purpose of the review was to gauge the City of Vancouver's graffiti management and environmental protection practices with that of other municipalities.
The 5 Canadian cities included as part of the review consisted of City of Victoria, District of North Vancouver, City of Calgary, City of Edmonton, and City of Toronto.
A summary of the review is presented in the attached Table 2 "Review of Canadian Cities Graffiti Management and Environmental Protection Practices". Each city was given a rating out of 10 for their graffiti management and environmental protection practices based on the following 5 factors:
1. Anti-Graffiti By-law(s);
2. Graffiti Management Program;
3. Community Involvement in Graffiti Removal;
4. Best Management Practices for Graffiti Removal; and
5. Environmental Protection By-Law(s).
The rationale for the selection of cities included in the review was to provide a comparison at the regional level, the provincial level and the national level with cities of similar populations. For each of the selected cities data was obtained through telephone conversations with city workers and internet searches of city websites. A list of the internet sites for the cities reviewed are presented below in Table 3.
Table 3. Internet Sites of Cities Selected For Review
City
Internet Site
City of Victoria
District of North Vancouver
City of Calgary
City of Edmonton
City of Toronto
Results
The results of the review indicates that the City of Vancouver provides a relatively high level of effort with respect to graffiti management and environmental protection practices compared to the other cities identified based on the above criteria. The City of Vancouver has established practices and protocols that specifically address graffiti, while the other municipalities that were considered in this review address environmental impacts from graffiti management only indirectly through bylaws that provide general environmental protection. Of the 5 measuring factors, the only category where improvement is recommended, was in the implementation of Environmental Protection By-Law(s). Although the City of Vancouver Sewer and Watercourse By-Law 8093 provides excellent protection to the environment and city drainage systems, the District of North Vancouver and the City of Toronto also provide a separate By-law for Environmental Protection.
This report was prepared for the exclusive use of the City of Vancouver. This report is intended to provide an assessment of current best management practices relating to graffiti removal and to provide a brief literature review for several chemicals that may be potentially used in graffiti removal. This chemical toxicity review was conducted at a screening level and was intended to provide a general summary of toxicological issues from secondary sources; it does not constitute a worldwide comprehensive literature review.
The report is based on data obtained from various information sources and Golder Associates Ltd. has relied in good faith on this data. We have assumed that the data provided by various sources are accurate and complete for the purpose of this assessment.
Golder Associates Ltd. makes no warranty, expressed on implied, and assumes no liability with respect to the use of the information contained in this report by the City of Vancouver or any third party. This report intends to provide Health and Safety information only; it is not a recommendation or endorsement of specific products or chemicals.
This assessment includes literature available from the US Environmental Protection Agency, Health Canada and the Risk information System at the time of report production. If information is discovered in other literature sources, Golder Associates Ltd. should be requested to re-evaluate the conclusions of this report, and to provide amendments as required.
5.0 CLOSUREWe trust that this report meets your requirements. Should you have questions or comments please contact the undersigned at 604-296-4200.
GOLDER ASSOCIATES LTD.
Reviewed by:
Darren Brown, B.Sc., B.I.T. Jay Hammond, M.Sc.
Environmental Scientist Manager Env. Assessment GroupReviewed by:
Cher Lacoste, M.Sc. Michael Z'graggen
Risk Assessor Senior Risk AssessorO:\ACTIVE\#2003-4\2003\1417\03-1417-027 GRAFFITI REMOVAL, CITY OF VANCOUVER\FINAL REPORT WITH APPENDICES\2 REP 1125 2003 FINAL GRAFFITI REMOVAL NDM.DOC
TABLES