Lead-Based Paint

 Contractors must assume all painted surfaces in residential buildings constructed prior to March 1, 1978 contain lead. Any construction or renovation work in buildings constructed prior to March 1, 1978 must be done in accordance with 29 CFR 1926.62, the OSHA Lead in Construction Standard and include appropriate exposure monitoring.  The University office of Environmental Health & Safety (EHS) may collect dust wipe samples upon the completion of renovation/construction projects to determine residual levels of lead dust and ensure the use of proper lead-safe work practices.

Select construction or renovation work disturbing lead-based paint in Nugent Hall, Durley Hall or Curley Annex must also be performed in accordance with the EPA's Renovation, Repair and Painting (RRP) Rule, using EPA-certified firms with properly trained personnel and specific lead-safe work practices.  Projects subject to the RRP Rule include:

  • renovations/repairs involving the disturbance of greater than 6 square feet of led-based paint per interior room;
  • renovations/repairs involving the disturbance of greater than 20 square feet of lead-based paint per building exterior;
  • any window replacement project involving lead-based paint.

For work covered by the RRP Rule, submit copies of applicable training and certification documents to EHS prior to the start of the project.

Prior to starting lead-based paint abatement (removal, encapsulation, enclosure, etc.), do the following:

  • Submit notification to the District Department of Energy and Environment (DOEE) at least seven (7) business days prior to the start of the project and obtain appropriate approvals and permits as necessary;
  • Provide two (2) copies of applicable notifications, permits, approvals, etc., one each to the University project manager and to EHS;
  • Submit to EHS evidence of proper training, licenses and/or certifications for each employee scheduled to be on the job, including respirator training when respirators are to be worn;
  • Submit a detailed, job-specific work plan to EHS including a copy of the written respiratory protection program if applicable.  Include work procedures, equipment/materials to be used, safety precautions to be taken, personal protective equipment to be worn, and how waste will be collected/stored/disposed.  Where applicable, include air monitoring to be performed and Safety Data Sheets for all agents to be used.

Dispose of all waste materials generated in compliance with all applicable federal and local laws, regulations and codes.  Clearly and accurately identify the lead-containing waste.  Provide all hazardous waste manifests to the project manager for signature so that a University representative may sign as the generator.  Do not sign a manifest on behalf of the University.

Industrial hygiene services required as part of the work, such as ambient air monitoring and final clearance dust-wipe testing, must be conducted by or under the direction of a person certified as an Industrial Hygienist (CIH) by the American Board of Industrial Hygiene.  Final clearance dust wipe samples collected following abatement activity must be collected by a properly trained and certified risk assessor and must meet the appropriate District of Columbia criteria to permit re-occupancy.  Industrial hygiene services will be provided by a consultant under contract with the University.





29 CFR 1926.62;

40 CFR 260-268, 745;

DCMR Title 20, Chapter 8, Section 806, District of Columbia, Control of Lead;

District of Columbia's Lead-Hazard Prevention and Elimination Act of 2008, DC Law 17-381, DC Code Sec. 8-231.01 (et seq.) (2009 supp.)