23 - LEAD SAFETY
Section Contents
PURPOSE AND SCOPE
Lead poses a major potential public health risk. In general populations, lead may be present in hazardous concentrations in food, water, and air. The most common source of lead is paint found in homes and buildings constructed prior to 1978. Other sources include industrial sources and plumbing materials.
Lead adversely affects numerous body systems and causes health effects that arise after periods of exposure as short as days (acute exposure) or as long as several years (chronic exposure). The frequency and severity of medical symptoms increases with the concentration of lead in the blood. Common symptoms of acute lead poisoning are loss of appetite, nausea, vomiting, stomach cramps, constipation, difficulty in sleeping, fatigue, moodiness, headache, joint or muscle aches, anemia, and decreased sexual drive. Long term (chronic) overexposure to lead may result in severe damage to the blood-forming, nervous, urinary, and reproductive systems.
Although adults are susceptible to lead exposure, it poses the greatest risk to children under the age of six because they are undergoing rapid neurological and physical development and pregnant women.
This program is designed to ensure that CUA employees follow the appropriate procedures to prevent building occupants, visitors, and contractors from exposure to hazardous levels of lead. It applies to all CUA employees and students involved with, or affected by, activities resulting in the disturbance of lead-containing materials.
DEFINITIONS
Lead-Based Paint Abatement - 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 Paint Activities - With respect to target housing, the term includes risk assessment, inspection and abatement. With respect to a public building - Identification of lead-based paint and materials containing lead-based paint, deleading and removal or lead activities where the specific purpose of the work is to abate lead-based paint or lead-based paint hazards.
Lead-Based Paint Hazard - A condition that causes exposure to lead from lead-contaminated dust, lead-contaminated soil, or lead-contaminated paint that is deteriorated or present in accessible surfaces, friction surfaces, or impact surfaces that would result in adverse human health effects.
Lead Hazard Evaluation - A quantitative determination of employee exposure to lead. Includes full shift personal air samples that are representative of the monitored employee’s regular, daily exposure to lead.
Lead Hot Work – Burning, cutting or torch burning of materials that have lead-containing coatings or paint.
OSHA Action Level (AL) for Lead - an exposure of 30 micrograms per cubic meter of air (ug/m3) as averaged over the course of an eight-hour workday.
OSHA Permissible Exposure Limit (PEL) for Lead - a time-weighted average exposure of 50 ug/m3 as measured over the course of an eight-hour workday.
Target Housing - Housing constructed prior to 1978. Any space in which the living area is not separated from the sleeping area is classified as a zero-bedroom dwelling and is not considered target housing.
ROLES AND RESPONSIBILITIES
Environmental Health and Safety (EHS) is responsible for:
- Maintaining the University’s Lead Management Program;
- Performing a lead hazard evaluation of at-risk employees as requested by supervisors and employees;
- Lead-based paint surveys of residential apartments, target housing and facilities occupied by children;
- Lead-based paint abatement project oversight;
- Consultation to ensure occupant safety during construction projects involving demolition, surface preparation of painted surfaces or paint removal in pre-1978 buildings; and
- Waste characterization and disposal.
Residence Life shall:
- Ensure families with children under the age of six (6) years old or pregnant women are assigned residential apartments in buildings constructed later than 1978;
- Disclose to occupants moving into target housing all lead-based paint data for the unit to be occupied; and
- Provide occupants of target housing with leases greater than 100 days with an EPA pamphlet entitled “Protect Your Family from Lead in Your Home.”
Facilities Planning & Construction (FPC) staff managing construction projects or lead hot work are responsible for:
- Notifying EHS of any construction or maintenance projects within target housing or child-occupied facilities that may involve disturbance of painted surfaces; and
- Notifying EHS of paint surface preparation and removal projects or other dust/fume generating construction or maintenance projects that could be reasonably anticipated to create dust/fumes that could impact occupied areas.
- Ensuring contractors performing construction activities disturbing paint in target housing are certified in lead safe work practices in accordance with the EPA Lead-Based Paint Renovation, Repair and Painting (RRP) program.
Facilities Maintenance & Operations (FMO) employees overseeing construction or lead hot work are responsible for:
- Notifying EHS of any construction or maintenance projects within target housing or child-occupied facilities that may involve disturbance of painted surfaces;
- Notifying EHS of paint surface preparation and removal projects or other dust/fume generating construction or maintenance projects that could be reasonably anticipated to create dust/fumes that could impact occupied areas;
- Maintaining all painted surfaces in pre-1978 residential buildings in an intact condition;
- Ensuring contractors performing work which impacts painted surfaces in target housing are EPA certified;
- Requesting lead hazard evaluations for employees conducting lead paint activities;
- Notifying EHS of unusual conditions or changes in work practices that would make initial lead hazard evaluations non-representative of actual lead exposure;
- Scheduling and ensuring employee attendance at EHS safety training;
- Enrolling employees exposed to lead above the OSHA action level into a medical surveillance program; and
- Enrolling employees exposed to lead above the OSHA permissible exposure limit into a respiratory protection program, including medical clearance, respiratory protection training and fit testing.
FMO employees who perform construction or lead hot work are responsible for:
- Participating in EHS safety training;
- Participating in medical surveillance program if necessary;
- Following proper procedures to prevent disturbance of lead- containing materials while performing assigned tasks;
- Using engineering controls, personal protective equipment and following administrative controls designed to minimize lead exposure; and
- Notifying supervisors of unusual conditions or changes in work practices that would make initial lead hazard assessments non- representative of actual lead exposures.
Laboratory personnel handling lead bricks or other lead-containing shielding devices are responsible for:
- Using engineering controls, personal protective equipment and following administrative controls designed to minimize lead exposure;
- Notifying supervisors of unusual conditions or changes in work practices that would make initial lead hazard assessments non- representative of actual lead exposures;
- Requesting lead hazard evaluations for employees conducting lead handling activities involving un-painted bricks for more than 30 minutes per day; and
- Notifying EHS of unusual conditions or changes in work practices that would make initial lead hazard evaluations non-representative of actual lead exposure.
PROCEDURES – CONSTRUCTION ACTIVITIES
FMO personnel shall assume detectable levels of lead at a minimum in target housing and all other facilities constructed prior to 1978 and shall use appropriate lead safe measures while performing work impacting painted surfaces in such facilities. Ensure any additional measures as required by the EPA Renovation, Repair and Painting Rule are observed for work in Nugent Hall, Curley Hall and Curley Annex. Testing to verify lead content prior to construction activities may be requested through EHS.
Lead safe measures must include, at a minimum:
- Containing the work area by sealing doors and HVAC vents with an appropriate plastic sheeting, covering the floor and unmovable furniture or other items with impermeable drop clothes, etc.;
- Place appropriate warning signs at the entrance to the work area;
- Use practices to minimize dust generation such as whole component removal, wet sanding/scraping, etc.;
- Clean thoroughly by wet wiping/mopping affected areas and HEPA vacuuming to ensure no dust, paint chips or other debris remains.
Restricted practices include use of:
- Power sanders or grinders without HEPA vacuum attachment;
- Open flame torches or high temperature heat guns (above 1100 degrees F);
- Paint strippers containing Methylene Chloride;
- Uncontained hydroblasting or uncontrolled abrasive blasting;
- Extensive dry scraping or sanding.
PROCEDURES – LABORATORY ACTIVITIES/HANDLING LEAD BRICKS
Training: Personnel handling lead bricks must receive basic lead awareness training from a department head or supervisor, which shall be documented and retained by the department. Training shall include information on lead hazards, personal protective equipment, proper storage practices and use.
Personal Protective Equipment: Use of proper personal protective equipment when handling lead bricks or other lead-containing shielding devices is mandatory. PPE at a minimum shall include disposable gloves. Proper hygiene shall be maintained by immediately washing hands after removal of gloves after material handling work is complete.
Storage Practices: Lead bricks shall be painted or otherwise coated/sealed whenever feasible. Use inventory tracking to facilitate proper lead storage and to keep lead inventories to a minimum. Store lead bricks in containers or keep them covered in specially designed areas. Routinely monitor lead inventories to check for lead dust contamination.
Proper Use: Ensure lead bricks are used only for their intended purpose as radiation shielding devices. Do not utilize them for alternate purposes, such as door stops. Personnel shall refrain from eating, drinking and chewing gum in lead handling and storage areas. Limit lead handling involving unpainted bricks to 30 minutes or less per day. Should personnel have need to exceed a 30 minute handling limit for unpainted bricks, contact EHS to initiate a lead hazard assessment.
Disposal: Lead bricks no longer needed, or lead scraps of any size, shall not be thrown out but retained for proper recycling and/or disposal. Contact EHS at extension 5865 if you have lead shielding devices requiring disposal.
LEAD IN DRINKING WATER
Lead is sometimes used in plumbing materials or in water service lines used to bring water from the main to the home. In 1974, Congress passed the Safe Drinking Water Act which requires the EPA to determine the level of various contaminants in drinking water and defines maximum levels for those contaminants.
A prohibition on lead in plumbing materials has been in effect since 1986. The lead ban, which was included in the 1986 Amendments of the Safe Drinking Water Act, states that only “lead free” pipe, solder, or flux may be used in the installation or repair of (1) public water systems, or (2) any plumbing in a residential or non-residential facility providing water for human consumption, which is connected to a public water system. But even “lead free” plumbing may contain traces of lead. The term “lead free” means that solders and flux may not contain more than 0.2 percent lead, and that pipes and pipe fittings may not contain more than 8.0 percent lead. Faucets and other end use devices must be tested and certified against the ANSI – NSF Standard 61 to be considered lead free.
EPA promulgated the Lead and Copper Rule in 1991 and revised the regulation in 2000 and 2007. This rule requires water systems to control the corrosivity of drinking water supply and collect tap samples from sites served by the system that are more likely to have plumbing materials containing lead. If more than 10% of tap water samples exceed the lead action level of 15 parts per billion, then water systems are required to take additional actions.
For all drinking water sources such as drinking fountains, bathroom and kitchen sinks, first flush pipes and then obtain drinking or cooking water from the cold tap only. Anytime the water in a particular faucet has not been used for six hours or longer, "flush" your cold-water pipes by running the water until it becomes as cold as it will get. This may take approximately one minute.
Report signs of corrosion such as pipe leaks or rust colored water to the Facilities Service Desk at (202) 319-5121 or http://cua-request.qbicsystems.info/#:1
RESOURCES AND REFERENCES
OSHA Lead in Construction Standard, 29 CFR 1926.62
EPA Renovation, Repair and Painting Rule
DC Water, Understanding Lead and Water