Introduction

There are many buildings on campus that were built before the Consumer Product Safety Commission started restricting the amount of lead in residential paint in 1977. There are areas on campus that have surfaces covered with paint that contain 0.5% or more of lead by weight, (Lead-based paint). While lead paint is a hazard for small children, the Center for Disease Control knows of no cases where adults have been poisoned by simply inhabiting a building containing lead paint.

Older paint that is in good condition or that has been painted over with newer paint is not a concern. If you work in an older building and see paint that is peeling, ask your building liaison to put in a work request to have it repaired. If you have concerns about lead paint in your work area contact Environmental Health and Safety.

Purpose

The purpose of this plan is to establish guidelines for compliance with the regulations for occupational exposure to lead and to assist in protecting University Community. This plan is to be used in conjunction with the State regulations covering exposure to lead and covers paint containing lead down to 0.06% by weight.

Scope

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

Applicable Regulations

  1. 29 CFR 62: NC OSH Lead Standard for the Construction Industry
  2. 29 CFR 1025: NC OSH Lead Standard for General Industry
  3. NC-EPA lead standards

These regulations are available for review by contacting Environmental Health and Safety.

Applicable References

  1. Office of State Personnel, Safety & Health Requirements for Lead https://epi.dph.ncdhhs.gov/lead/lhmp.html,
  2. National Institute of Building Sciences (NIBS), Lead Based Paint: Operations and Maintenance Work Practices (National Institute of Building Sciences (NIBS)

Definitions

  1. Action Level (AL) – airborne lead concentration of 30 mg/m3 calculated as an 8-hour time weighted average.
  2. Competent person – a person who is capable of identifying existing and predictable lead hazards in the surroundings or working conditions and who has authorization to take prompt corrective action to eliminate
  3. Lead – metallic lead, all inorganic lead compounds, and organic lead
  4. Lead Containing Paint – paint containing lead in a concentration above 600 ppm (0.06%).
  5. Lead Related Tasks – a task that has the potential of generating air-borne lead at hazardous levels.
  6. Permissible Exposure Limit (PEL) – airborne lead concentration of 50 mg/m3 averaged over an 8-hour period.

Responsibilities

The Environmental Health and Safety (EH&S) shall:

  1. Designate someone as the University’s Subject Matter Expert – the EHS Industrial Hygienist.
  2. Provide Lead Awareness training (EHPS OH400 on Reporter).
  3. Occasionally provide paint survey services
  4. Coordinate exposure
  5. Maintain exposure assessment
  6. Recommend safe work

Any University employee that performs Lead Related Tasks shall:

  1. Attend Lead Awareness training on Reporter.
  2. Participate in the University’s respiratory protection
  3. Contact EH&S for a paint survey before starting work involving Lead Related Tasks.
  4. Use work practices that keep dust as low as
  5. Follow good hygiene

Any University unit that hires outside contractors to work on campus shall:

  1. Submit a Facilities Modification Form during the planning
  2. Have Design and Construction Services review the
  3. Ensure area is surveyed for lead containing paint and the contractor is given this information.
  4. Ensure the contractor follows the construction lead standard and keeps dust contained in the work area.
  5. Ensure that any contractor or firm engaged in abatement activities are certified, regardless of the buildings they will be working on (residential, non-residential, child-care, etc.)

Lead Related Tasks

The following tasks have been specifically identified as having the potential to generate airborne lead at hazardous levels:

  1. Manual scraping
  2. Manual sanding
  3. Manual demolition of structures (e.g. dry wall)
  4. Heat gun applications
  5. Power tool cleaning
  6. Spray painting with lead containing paint
  7. Rivet busting
  8. Use of lead containing mortar
  9. Lead burning
  10. Abrasive blasting, clean up of dry expendable abrasives, and movement or removal of abrasive blasting enclosures.
  11. Welding, cutting, and torch burning

If any of these tasks are to be performed on a surface that is covered with lead containing paint, it is legally required to presume the air-born lead level will be above the Permissible Exposure Limit of 50 mg/m3. See Table 1, Presumed Exposures for Specific Tasks. Contact EH&S to arrange for air sampling to determine actual exposures.

Exposure Assessment

For any activity involving Lead Related Tasks the University must determine if any employee may be exposed to lead at or above the Action Level of 30 mg/m3. The employee’s exposure is considered to be that exposure which would occur if the employee were not using a respirator. Personal air samples must be collected that are representative of a full shift including at least one sample for each job classification in each work area. Contact EH&S for more information on this.

During the assessment of exposure, the employee is considered to be exposed at the levels listed in Table 1, and must be provided the protective measures listed in Table 2.

Should an exposure assessment show the possibility of any employee being exposed to air-borne concentrations of lead at or above the Action Level, air sampling shall continue and must be representative of the exposure of each employee who is exposed to lead. When a respirator is used to limit worker exposure the concentration of lead is determined by dividing the measured lead level by the protection factor of the respirator.

It may be possible to use objective data and previous air sampling to predict exposure in place air sampling. Contact EH&S to see if air-sampling data already exists for a similar task and paint lead level as the job you are planning.

Should an exposure assessment show that no employee is exposed to airborne concentrations of lead at or above the Action Level, a written record shall be made with the following information:

  1. Date of assessment;
  2. Location within the work site;
  3. Name and ID number of each employee monitored;
  4. Any information, observations, or calculations that would indicate employee exposure to lead;
  5. Any previous measurements of airborne lead; and
  6. Any employee complaints of symptoms that may be attributable to exposure to lead.

Respirator Protection

The University shall provide respirators to employees and respirators MUST be used during:

  1. Periods when an employee’s exposure to lead is above the PEL;
  2. Work operations for which engineering and work practice controls are not sufficient to reduce employee exposures to or below the PEL;
  3. Periods when an employee requests a respirator;
  4. Periods when respirators are required to provide interim protection before an negative exposure assessment has been made.

Prior approval by EH&S is required before employees can use a respirator. Contact EH&S for information on getting approved to wear a respirator. Anyone approved to wear a respirator is part of the University’s Respirator Protection Program and must attend annual training classes.

Contact EH&S with questions or concerns on selecting or wearing respirators.

Methods of Compliance

When it is possible for the PEL to be exceeded, engineering and work practice controls must be used to reduce the exposure to the lowest level possible.

Administrative controls, such as job rotation schedules, may also be used. Examples of engineering controls include:

  1. Power tools equipped with dust collection shrouds exhausted through a HEPA vacuum system.
  2. Local exhaust ventilation for operations such as welding, cutting, burning, and heat gun applications.
  3. Use of HEPA vacuums during clean-up
  4. Containment structures and
  5. Work procedures and equipment that reduce

If these controls are not adequate to reduce exposures below the PEL they must be used to reduce the exposure to the lowest level possible and then supplemented with appropriate respiratory protection.

For any job that may reach the PEL there must be a written compliance plan. This plan must include:

  1. A description of each activity in which lead is emitted;
  2. A description of the specific means that will be employed to achieve exposure below the PEL;
  3. The technology considered in meeting the PEL;
  4. Air monitoring data;
  5. A schedule for implementation;
  6. A work practice program;
  7. Administrative control schedule;
  8. Arrangements made with contractors
  9. And shall provide for frequent and regular inspections of job sites by a competent person.

Protective clothing and equipment

If an employee is exposed to lead above the PEL, or to lead compounds which can cause skin and eye irritation, the University shall provide protective work clothing and equipment appropriate for the hazard level. The employee must be trained in the proper fitting and use of the protective clothing and equipment and it must be assured the employee uses them to prevent contamination of himself and his personal clothing.

Protective work clothing includes, but is not limited to:

  1. Coveralls or similar full-body work clothing;
  2. Gloves, hats, and shoe covers; and
  3. Face shields, vented goggles, or other protective

Due to the hazards associated with handling and washing contaminated protective clothing, disposable protective clothing should be used whenever possible.

Housekeeping

The following housekeeping practices shall be observed:

  1. All surfaces shall be maintained as free as practicable of accumulations of
  2. Whenever possible the use of vacuums shall be used to clean up where lead accumulates.
  3. Shoveling, dry or wet sweeping, and brushing may only be used when vacuuming will not work.
  4. When vacuuming is used, the vacuum shall be equipped with High Efficiency Particulate Air (HEPA) filters and used and emptied in way that reduces the release of lead back into the workplace.
  5. Compressed air shall not be used to remove lead from any surface unless it is part of a dust collection system.

Collected lead dust and debris must be stored in a labeled container and handled as hazardous waste. Contact EH&S to arrange for a hazardous waste pick-up.

Hygiene facilities and practices

Hand washing facilities must be provided whenever there is occupational exposure to lead. When the exposure is above the PEL, change areas, showers (where feasible), and separate break or eating areas must also be provided.

In work areas that are above the PEL:

  1. No food or beverage may be preset or
  2. No tobacco products may be preset or
  3. Cosmetics may not be

Employees leaving a work area that is above the PEL must wash their hands and face prior to eating, drinking, smoking or applying cosmetics. Contaminated clothing or equipment must be removed in changes areas and not be taken home. The good work practices listed in Table 3 must be followed.

Medical surveillance

Initial medical surveillance shall be made available to employees exposed on any day to lead at or above the Action Level. Initial medical surveillance consists of biological monitoring in the form of blood sampling and analysis for lead and zinc protoporphyrin levels.

Employees who are exposed at or above the Action Level for more than 30 days shall be included in a Medical Surveillance Program that includes biological monitoring, medical examinations and consultations, and medical removal protection.

The decision for an individual to enter the medical surveillance program will be made on a case-by-case basis. Facilities Operations will have its painters and welders get a lead blood level check once a year.

Employee information and training

Any employee who may be exposed to airborne lead at any level must be given Hazard Communication training. Included is this training must be the requirements for warning signs and labels, Material Safety Data Sheets (MSDS), and employee information such as a copy of the lead standards and its appendices and any other training materials.

Employees exposed to levels at or above the Action Level or to lead compounds which may cause skin or eye irritation, must be given additional training that covers:

  1. The content of the NC OSH Construction Standard for Lead and their rights under this standard.
  2. The specific hazards associated with their work
  3. Protective measures that can be
  4. The contents of any compliance plan in
  5. The danger of lead to their bodies, including the reproductive

Employees must be trained prior to being assigned to work areas where there is a possibility of being exposed over the Action Level, and annually thereafter unless further exposure above the Action Level will not occur.

Signs

The following warning sign must be posted in work areas where the exposure to lead exceeds the PEL:

WARNING LEAD WORK AREA

POISON

NO SMOKING OR EATING

 This sign must be post at each entrance to the work area and maintained in a way that assures it is readily visible.

Recordkeeping

The following records will be maintained by EH&S:

  1. Exposure monitoring and assessments will be retained for 30
  2. Biological monitoring and medical examination results will be retained for the duration of employment plus 30 years.
  3. Medical removal records will be retained for the duration of

Table 1 Presumed Exposures for Specific Tasks

 

Presumed Exposure in mg/m3
50 – 500 500 – 2,500 > 2,500
Manual scraping Manual sanding Power tool cleaning with out dust collection

Clean-up of dry expendable abrasives

Movement & removal of abrasive blasting enclosures

Rivet busting

Use of lead-containing mortar

Lead burning

 Abrasive blasting
Manual demolition

Heat gun applications

 Welding, cutting, & torch burning
General clean-up  
Power tool cleaning with dust collection systems  
Spray painting  
Any other task where the PEL could be exceeded  

Table 2 Protective Measures

The following protective measures are required when there is a potential for exposure to air-borne lead at any level:

  1. Initial Hazard Communication training;
  2. Hand washing facilities

The following protective measures are required when an exposure assessment has not be completed:

  1. Appropriate respirator protection for the level of
  2. Appropriate personal protective clothing and equipment
  3. Change areas
  4. Hand washing facilities
  5. Biological monitoring
  6. Training

Additional protective measures required when exposure to air-born lead is known to exceed the Action Level

  1. Initial medical surveillance (blood analysis) when exposure is equal to or above the Action Level on any day.
  2. Medical surveillance program consisting of periodic biological monitoring and medical examinations and consultations when exposure equals or exceeds the Action Level for more than 30 days in 12 consecutive

Table 3 Good Work Practices

 The follow good work practices must be followed when working in areas where the lead exposure may exceed the PEL.

Prior to beginning work:

  1. Change into work clothing and shoe covers in the clean section of the designated changing areas;
  2. Use work garments of appropriate protective gear, including respirators before entering the work area; and
  3. Store any clothing not worn under protective clothing in the designated changing area.

Upon leaving the work area:

  1. HEPA vacuum heavily contaminated protective work clothing while it is still being worn. At no time may lead be removed from protective clothing by any means which result in uncontrolled dispersal of lead into the air;
  2. Remove shoe covers and leave them in the work area;
  3. Remove protective clothing and gear in the dirty area the designated changing Remove protective coveralls by carefully rolling down the garment to reduce exposure to dust.
  4. Remove respirators last; and
  5. Wash hands and

Upon finishing work for the day, (in addition to the items above):

  1. Where applicable, place disposable coveralls and shoe covers with the lead waste;
  2. Contaminated clothing which is to be cleaned, laundered, or disposed of must be placed in closed containers in the change room.
  3. Clean protective gear, including respirators, according to standard procedures;
  4. Wash hands and face If showers are available, take a shower and wash hair. If showers are not available at the work site, shower immediately at home and wash hair.