Purpose and Scope
To formalize a department policy that ensures a safe and healthful working environment for employees involved in removing lead containing paint. It is of the utmost importance that de-leading be conducted as quickly, safely and correctly as possible. Procedures are to be followed when re-glazing windows, preparing surfaces for repainting and any situation that could result in the release of lead containing dust or fumes.
Policy
In order to eliminate potential occupational lead exposure which may occur as an airborne dust or fume hazard, employees working on surfaces containing lead based paint must comply with all of the established safety precautions contained in this Operating Procedure. Any employee observed violating any part of this procedure may be subject to departmental discipline.
Procedures
The following safety procedures and precautions have been developed in accordance with guidelines established by the Occupational Safety and Health Administration (OSHA) and the Ohio Department of Health.
1. Analyze the Paint: Test the surface upon which the work is to be performed through one of the following approved methods.
a. Use an approved lead test kit purchased by the department
b. Apply a ten percent solution of sodium sulfide to the area being tested (the solution will turn black if positive)
2. Analyze the Situation: Generally, the exposure to potential lead dust or fume is very minimal. Typical situations involve re-glazing a broken window or sanding down a small area or surface for repainting and much of this work is done outside of the building. If the job is of sufficient size, where exposure might be at or above the recommended exposure limits, the shop supervisor or manager shall make the determination as to whether the removal is necessary and what degree of precautionary measures should be implemented.
In the typical situation, where the exposure is very minimal (i.e., re-glazing a window or repainting a small area), the carpenter or painter is required to use a NIOSH approved disposable respirator, approved safety eyewear and if necessary, gloves. (See footnote 1. Respirator Training.)
Care should be taken to minimize the amount of dust and/or fumes generated. All dust and debris are to be cleaned up and disposed of via hard trash.
3. If the size of the job dictates the need for additional safety precautions, Large Job Paint Removal safety procedures shall be implemented. The shop supervisor or manager will make this determination. In addition, Physical Facilities management reserves the right to contract this type of job out to a contractor. However, the contractor must provide Physical Facilities management personnel with a copy of the firms written lead paint removal policy and must implement that policy in performing the removal.
4. All surfaces shall be repainted with a non-lead base paint.
5. Large Job Paint Removal Safety Procedures
a. Analyze a sufficient number of areas that can produce a representative sample of the presence of lead based paint.
b. Only workers who have been properly trained may be involved in lead paint removal.
c. Determine whether or not the area and/or surrounding areas should be evacuated until the job and subsequent clean-up has been completed.
d. Protective clothing and equipment shall be provided. This would include some type of disposable clothing, NIOSH approved respiratory protection, and ANSI approved eye protection and gloves. All safety equipment used on this job should be bagged and left at the work site each day until the job is completed.
e. Appropriate signage must be posted according to OSHA CFR 1910.1025.
f. Adequate ventilation is to be provided through open windows and/or exhaust fan (s).
g. No food, beverages or smoking shall be permitted in the work area.
h. Work on only one area at a time. If appropriate, seal the work area off from the rest of the area. If necessary, an appropriate floor covering should be used.
i. Every effort should be made to minimize the use of solvent "strippers", and the generation of dust from the sanding operations. The use of a blowtorch should be minimized.
j. All exposed surfaces and work surfaces are to be wet mopped or wet wiped, vacuumed with a HEPA-Vac and then wet mopped or wet wiped again, upon completion of the work or at the end of the work shift. This process should be repeated until the supervisor is satisfied that all lead containing residue has been picked up.
k. Upon leaving the work site, workers must wash their hands and face thoroughly before eating. Bathe and wash hair before interacting with family members.
l. Upon completion of the job, all dust, debris and disposable clothing is to be bagged and disposed of in accordance with applicable state and federal regulations.
Footnote: Respirator Training: In accordance with Miami University practice, any employee using a respirator should go through a respirator user's physical and the Respirator Training Program offered through the Environmental Health and Safety Office.
Filters will be NIOSH approved for dust and possible fumes.
Revision History