Purpose and Scope
To formalize a department policy that provides guidance for the protection of personnel engaged in lead management.
Policy
It is the policy of the Miami University’s Physical Facilities Department to provide the University community with a safe and healthful environment. This policy is designed to ensure that University employees follow the appropriate procedures to prevent building occupants, visitors, maintenance personnel and contractors from exposure to hazardous levels of lead.
The following safety procedures and precautions have been developed in accordance with standards established by the Occupational Safety and Health Administration (OSHA).
This Standard Operating Procedure is intended as a guideline for routine maintenance of building substrates, to include surface preparation for painting. It is not intended as a procedure for lead-based paint abatement.
Definitions
- Rental Property -- A house owned by Miami University, occupied by students with children or employees residing with their partners and/or children.
- Lead-Based Paint Abatement -- As defined by OSHA. "A set of measures designed to eliminate or reduce lead-based paint hazards in accordance with standards established by EPA. The term does not include renovation and remodeling activities by contractors whose primary intent is not to permanently eliminate or reduce lead-based paint hazards, but is instead to repair, restore or remodel a given structure or dwelling."
- Lead Hazard Evaluation -- A quantitative determination of employee exposure to lead. Includes full shift personal samples that are representative of the monitored employee's regular, daily exposure to lead.
- OSHA Action Level (AL) -- Under the US Department of Labor, Occupational Safety and Health Administration (OSHA) Lead in Construction Standard 29 CFR 1926.62 and Lead in General Industry Standard 29 CFR 1910.1025 is defined as an exposure of 30 ug/m3 as averaged over the course of an eight-hour workday.
- OSHA Permissible Exposure Limit (PEL) -- Under the US Department of Labor, Occupational Safety and Health Administration (OSHA) Lead in Construction Standard 29 CFR 1926.62 and Lead in General Industry Standard 29 CFR 1910.1025 is defined as a time-weighted average exposure of 50 ug/m3 as measured over the course of an eight-hour workday.
Responsibilities
The Physical Facilities Department’s Safety Coordinator is responsible for identifying at-risk job tasks, conducting task-specific lead hazard evaluations, sampling, evaluation of renovation activities, notification and lead education for occupants residing in rental properties undergoing renovations or maintenance where lead paint will be disturbed, training, and record keeping.
The Physical Facilities Department is responsible for notifying the Safety Coordinator of changes in job descriptions and/or work tasks that may result in rendering initial lead hazard assessments as being unrepresentative. Examples of this include a change in job responsibilities and a change in work methodology. Additionally, PFD is responsible for notifying the Safety Coordinator of any renovation or maintenance projects that may involve working with suspected lead-based paint surfaces.
Employees are responsible for participating in Hazard Communication training and participating in the medical surveillance program (if applicable). Employees are also responsible for using personal protective equipment, engineering controls and adhering to administrative work practices as instructed and notifying supervisors of unusual conditions or changes in work practices that would make initial lead hazard assessments as being non-representative of actual lead exposures.
Procedures
Bulk sampling of suspect lead-containing paint shall be performed on jobs having the potential to expose employees above the OSHA action level. This determination will be made by the Facilities Safety Coordinator on a job-by-job basis. Testing of painted surfaces will be performed by lab analysis of bulk paint chip samples by an AIHA accredited laboratory. Following paint testing, the Facilities Safety Coordinator will provide a written response and recommend case-specific procedures to be followed.
Only employees who have received training are qualified to remove lead-containing materials. The following guidelines shall be used as removal options:
- Use chemical strippers that do not contain methylene chloride to remove as much paint as possible.
- Use wet-sanding and scraping when use of chemical stripping is not practical or feasible.
- Using a wet cloth or rag, wipe all surfaces following chemical stripping or wet sanding/scraping.
- Use drop cloths to collect scrapings. For small projects (e.g., routine maintenance), dispose of all materials in normal trash.
- The following personal hygiene practices shall be followed during all removal of lead-containing pain
- Eating, drinking and the use of tobacco products are prohibited in the work area.
- All personnel shall wash hands and exposed skin thoroughly with soap and water before leaving the work site.
- Personal protective equipment, to include gloves, safety glasses or goggles, and respiratory protection shall be used. Ensure proper decontamination of all personal protective equipment.
The Facilities Safety Coordinator will perform lead hazard evaluation of all tasks having the potential to expose employees to levels of lead above the OSHA action level of 30 ug/m3, as an eight-hour time-weighted average. The assessments shall include air monitoring and observation of work practices and engineering controls typically used for each task.
Waste Disposal
For large projects (e.g., major renovation intended to remove a large amount of delaminating paint), contact the Facilities Safety Coordinator for waste disposal guidance and waste stream characterization of suspected lead-containing waste materials by laboratory analysis following EPA Toxicity Characteristic Leaching Procedure (TCLP) for lead (40 CFR 261.24).
Training
The Facilities Safety Coordinator will conduct annual training for all employees exposed to lead above the OSHA action level. Employees will be informed of proper removal procedures and trained on the importance of proper hygiene during tasks that may involve exposure to lead.
Revision History