Purpose

 To provide guidance on the management of painted surfaces on campus, reduce the risk of exposure to lead, and ensure compliance with NC Occupational Safety and Health regulations.

Scope

 The requirements of this policy apply to all University employees. It also applies to contractors and their subcontractors who have been hired to work on campus.

Summary

 There are many buildings on campus that were built before 1977 when the Consumer Product Safety Commission started restricting the amount of lead in residential paint to 0.06% by weight or less. There are areas on campus that have surfaces covered with paint that contains 0.5% or more of lead by weight or in excess of 1.0 milligrams per square centimeter (mg/cm2), which is commonly referred to as lead-based paint. While lead-based paint is a hazard to small children, the Center for Disease Control knows of no cases where adults have been poisoned by simply inhabiting a building containing this material.

Lead-based paints can be managed in place as long as they are maintained. Older paint that is in good condition or that has been painted over with newer paint is not a concern. Moisture problems or water leaks can cause paint to fail and start peeling. Problem areas such as these, when identified, should be brought to the attention of both EHS and Facilities Services.

There are also areas on campus that have surfaces covered with paint that contain less than 0.5%, but more than 0.06% of lead. This paint does not meet the definition of lead- based paint, yet it contains lead in amounts that can cause an excessive occupational exposure to air-born lead dust if certain activities are performed on it. Manual scraping, sanding, or demolition of a structure covered with this paint can generate air-borne lead dust at levels that exceed the occupational Permissible Exposure Limit (PEL) for lead.

OSHA Requirements

OSHA requires employers to protect workers from lead exposure under its lead standards covering general industry (1910.1025), shipyards (1915.1025), and construction (1926.62). The lead standards establish a permissible exposure limit (PEL) of 50 μg/m3 of lead over an eight-hour time-weighted-average for all employees covered. The standards also set an action level of 30 μg/m3, at which an employer must begin specific compliance activities, including blood lead testing for exposed workers. The lead standards also include ancillary provisions such as medical surveillance, exposure monitoring, and hygiene facilities and practices that are critical in preventing lead exposure and elevated blood lead levels.

Procedure

 Any University structure built before 1978 must be presumed as having paint containing lead until proven otherwise. All paint containing lead must be properly maintained and repaired if damaged. Precautions must be taken to avoid disturbing painted surfaces during routine maintenance, repair, and renovation work.

Responsibilities

 Building Occupants

The mere presence of lead-based paint in a building does not create a hazard. The risk depends on where the paint is located, the condition it is in, the way the painted surface is treated, and the potential for human exposure. If you work in a building that was built before 1978 you should:

  1. Avoid any activity that would disturb painted
  2. Pay attention to the condition of painted surfaces in your
  3. Report any damaged or visibly deteriorating paint to your building liaison and ask them to submit a work request to have it repaired.

If you have questions or concerns about the condition or level of lead in the paint in your area, contact Environmental Health & Safety at env-health-occ-health@ncsu.edu or call  919-515–6862.

Building Liaisons and Facility Coordinators

If you are responsible for a building that was built before 1978 you should:

  1. Pay attention to the condition of painted surfaces in your
  2. Promptly submit work requests to repair any damaged or visibly deteriorating
  3. Instruct building occupants not to disturb painted
  4. Submit a Building Modification Form for any renovation, construction, or demolition project that will disturb painted surfaces.
  5. Never hire a contractor without first having Design & Construction Services review the project.
  6. Notify all contractors bidding on projects of any lead survey information. In the absence of survey information, instruct the contractor to presume lead is

Project Planners and Managers (outside contractors)

If you plan or manage projects that will disturb painted surfaces you should:

  1. Request from EH&S any past paint survey records of the
  2. Arrange for a paint survey if needed. Notify in writing all contractors
  3. Include this document in your contractor safety guidelines as well as construction documents involving lead.
  4. For projects that will disturb paint containing lead, request from the contractor a plan on how he will comply with the NC OSH Construction Lead Standard and prevent lead dust from leaving the work area.
  5. Verify that the work area has been thoroughly cleaned before releasing the

Maintenance, Renovation or Painting Staff

If you perform activities that may disturb painted surfaces you should:

  1. Attend the Lead Awareness class given by EH&S (EHPS OH400 available of Reporter).
  2. Read and understand the NC State University Management Plan for Occupational Exposure to Lead.
  3. Notify EH&S when planning a job that will disturb painted surfaces and arrange for air sampling if needed. Refer to the NC State University Management Plan for Occupational Exposure to Lead for more information on jobs that have the potential to generate lead dust.
  4. Evaluate each job for the proper use of personal protective equipment (PPE),work practices, and hygiene practices.

Clean Up and Waste Disposal

A thorough cleaning is very important after a project that disturbs paint that contains lead. All dust, paint chips, and debris must be cleaned up and sealed in plastic bags. Vacuuming with HEPA filtered shop-vacs and/or wet cleaning methods must be used.

All waste such as paint chips, paint stripper residue or debris, protective clothing, and plastic sheeting must be collected and disposed of as hazardous waste. Contact EH&S at env-health-haz-waste@ncsu.edu for information on disposal of lead related waste.

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