LEAD-BASED PAINT SAFETY PROGRAM

 

Purpose, Application, and Scope

Wichita State University (WSU) employees, student workers, faculty, staff, and outside contractors whose job requires them to disturb painted surfaces. Lead Based paint (LBP) was commonly used prior to 1978. All surfaces painted prior to 1978 should be assumed to contain lead unless otherwise tested. Working with LBP can lead to unsafe exposures to lead. The disruption of paints containing any detectable amounts of lead may result in exposure to airborne lead depending on the method of removal and other conditions in the workplace.

WSU, in its continuing effort to provide employees with safe, healthful working conditions, and to comply with the Occupational Safety and Health Act (OSHA) is implementing the following program for LBP safety to protect people working at WSU, by helping employees, student workers, faculty, staff, and outside contractors better understand the risks of working LBP and the procedures required to prevent exposure.

 

Definitions

Action Level (AL) --- The action level is set by OSHA at 30 μg/m2  over an 8-hour work day. OSHA requires that medical monitoring must be provides to personnel if they have been exposed above the AL for any single day in a calendar year. Medical monitoring is required for all personnel exposed at or above the AL for more than 30 days in any year. This monitoring can include BLL monitoring.

Blood Lead Level (BLL) --- The amount of lead in the blood, measured in μg lead per deciliter (μg/dL) of blood. Employees must be removed from any work which exposes them to lead if their BLL is at or above 50 μg/dL. WSU personnel will have ongoing BLL monitoring requirements if they exceed 40 μg/dL.

High Efficiency Particulate Air (HEPA) Filtration System --- A filtration system that has the capability of removing up to 99.97% of airborne impurities that are as small as 0.3 microns.

Lead Based Paint (LBP)--- Paint containing more than 0.5% or 1.0 mg/cm2 of lead, as determined by laboratory analysis or field detection with an X-Ray Fluorescence (XRF) detector. All pre-1978 painted surfaces are presumed to contain lead unless otherwise tested.

Lead Containing Paint (LCP) --- Paint containing any measurable amount of lead (typically set at greater than 0.06% lead).

Permissible Exposure Limit (PEL) --- The OSHA established maximum exposure limit for lead is 50 μg/m3 over an 8-hour work shift.

Personal Protective Equipment (PPE) --- Equipment worn to minimize exposure to hazards that may cause injury or illness.

X-Ray Fluorescence (XRF) Detector --- A non-destructive analytical technique used to determine the elemental composition of materials often used for the detection of lead in paint.

 

Roles and Responsibilities

EHS Department is responsible for the following:

  • Provide program oversite and consultation to WSU personnel regarding potential risks, exposure prevention, and training relating to potential LBP exposures
  • Provide support to departments to ensure that all affected personnel and their managers or supervisors receive the necessary training and medical monitoring as related to this program
  • Document, track, and/or conduct inspections on painted surfaces where applicable
  • Review and update the program as necessary

Manager/Supervisor is responsible for the following:

  • Determine if there is a potential for LBP exposure in their department and if necessary, work with EHS to implement the LBP Program
  • Identify personal who are at risk for LBP exposure
  • Ensure appropriate tools and PPE are available and used as required
  • Ensures that employees complete required training, and that training is documented

Employees are responsible for the following:

  • Observe the procedures and requirements outlined in the program
  • Completes required training
  • Wear proper PPE as required
  • Notifies the supervisor/manager of changes in the workplace that could cause an increase in exposure to LBP/LCP

Contractors are responsible for the following:

  • Perform all work in compliance with their company’s LBP/LCP program, which may be reviewed by WSU EHS
  • If the company does not have a program, they must comply with this program

 

Hazards Associated with LBP/PCP

The following hazards associated with LBP/LCP exposure can lead to personal injury or death:

  • Lead poisonings can damage the brain, liver, kidneys, and red blood cells
  • Lead can also damage the reproductive system and central nervous system
  • Children, because they are growing and developing their central nervous system, are particularly susceptible to the effects of lead exposures. Lead can be brought home from the jobsite to families when proper hygiene steps are not followed during LBP/LCP work

 

Engineering Controls

Engineering controls are design plans or changes to the working environment to prevent or reduce personnel exposure to potential hazards. The following example of engineering controls should be considered in area design to reduce the risk of exposure from work involving LBP/LCP

  • Using HEPA filtration systems when working on LBP/LCP
  • Utilizing a tool-specific shroud with a HEPA filtration system when working with LBP/LCP
  • Installing isolation barriers to prevent exposure to the public at large when working with LBP/LCP

 

Administrative Controls

Administrative controls are safe work practices and procedures designed to reduce the ricks associated with working with LBP/LCP. Examples of administrative controls include the following:

  • Train personnel who work with LBP
  • Routine inspections of LBP surfaces to ensure they are intact and in good condition
  • Immediate stabilization or removal of peeling or flaking LBP

Renovation Projects

All surfaces painted before 1978 will be presumed to contain Lead. Testing can be performed by a Certifies Lead Inspector.

  • Conduct the renovation work or paint over the existing surface as long as the existing painted surface is in good condition (not flaking or falling off the wall) and the workers are not planning to us “abrasive” work practices or surface preparation methods (ex. scrapping, sanding, etc.).
  • Retain a Certified Lead Inspector/Risk Assessor to test the paint prior to the renovation activities if the workers will be using abrasive work practices/surface preparation or if the existing painted surface is not in good condition

The Lead Inspector/Assessor should determine if the LBP must be removed, or if other control methods such as worker PPE are appropriate to prevent harmful exposures to renovation workers or the facility environment.

For certain minor “spot” renovations or repairs (less than 2 square feet), safe work practices such as personnel lead exposure awareness training, PPE and containment methods may be used in lieu of detailed risk assessment and abatement procedures by certified personnel.

Disposal of LBP

All LBP containing waste must be properly characterized and disposed of in accordance with local, state, and federal regulations. (40 CFR 261.3, 261.24, 262.40 (c)).  A representative sample of waste must be submitted to a laboratory for Toxic Characteristic Leaching Procedure (TCLP) testing. If the debris contains more than 5 ppm of lead by TCLP, the debris must be disposed of as characteristic hazardous waste.

 

Information and Training

WSU shall provide training for all personal whose work impacts LBP/LCP.  The training shall enable personnel to recognize hazards to lead exposure from painted surfaces and be trained by a competent person in the following area, as applicable:

  • The hazards of lead in the workplace, and where lead may be found
  • How lead enters the body and health effects related to over exposure
  • OSHA regulations and PEL/AL
  • Medical monitoring and medical removal programs
  • Safe work practices to limit lead exposure and the use of PPE

Retraining shall be provided for all affected personal annually, when new workplace hazards are identified, or there are changes in work practices, so that personnel maintains the understanding and knowledge acquired through compliance with this program.

 

Recordkeeping

The EHS Department will:

  • Provide Lead-Based Paint training and retraining and be responsible for maintaining records. Records will include names of the individuals trained, type of training, date of training, and name of trainer.

Annual Review

The Lead-Based Paint Safety Program will be reviewed by the EHS Department.  The review will include current training and any documents associated with this program.  When new tasks, procedures, and/or positions are added or modified/revised which affect this program, it will be updated to reflect these changes.