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Lead Management

This program describes the methods and procedures to prevent or minimize CSUN employees’ exposure to lead during construction or renovation activities.

I.  Purpose/Scope

The purpose of this program is to prevent or minimize occupational and environmental exposures to lead resulting from construction or renovation activities on the Campus and to provide guidelines for compliance to California OSHA, Federal OSHA and the Environmental Protection Agency’s Renovation, Repair and Painting (RRP) programs / regulations on lead.

II.  Definitions

  • Abatement: any measure or set of measures designed to permanently eliminate lead-based paint hazards.
  • Lead Exposure Action Level (Action Level): (as defined in California Code of Regulations, Title 8 § 1532.1 Lead in Construction) employee exposure, without regard to the use of respirators, to an airborne concentration of lead of 30 micrograms per cubic meter of air (30μg/m3) calculated as an 8-hour time-weighted average (TWA).
  • Child Occupied Facilities: building or a portion of a building visited by the same child under the age of six (6) years for more than 60 hours per year consisting of at least two visits within a week whose weekly total exceeds 6 hours with at least one single visit > 3 hours.
  • Competent Person: a person who is capable of identifying existing and predictable lead hazards in the surroundings or working conditions that has authorization to take prompt corrective measures to eliminate these hazards.
  • Exposure Assessment: An initial determination of whether any employee's exposure to lead exceeds the action level.
  • Final Medical Determination: means the written medical opinion on the employees' health status by the examining physician.
  • Lead Containing Paint: (as defined in EPA’s RRP program) Coatings that contain greater than or equal to 0.5 % or 1.0 milligrams / square centimeter by weight of lead.
  • Lead Related Construction Work:  (as defined in Title 17) any construction, alteration, painting, demolition, salvage, renovation, repair, or maintenance of any residential or public building, including preparation and cleanup, that, by using or disturbing lead containing material or soil, may result in significant exposure of adults or children to lead.
  • Minor Repairs and Maintenance: projects that disturb no more than 6 square feet of interior surfaces or more than 20 square feet of exterior surfaces over a 30 day period, excluding certain activities utilizing high speed equipment such as grinding, sanding, blasting, etc.
  • Negative Initial Determination: (California Code of Regulations, Title 8 § 1532.1 Lead in Construction) employee exposure monitoring that demonstrates employees are not exposed to airborne concentrations of lead at or above the action level for a task or activity.
  • Permissible Exposure Limit: The highest level of lead in air to which an employee may be permissibly exposed over an 8-hour workday: (8 hr TWA = 50 μg/m3).
  • Renovation Activities: Removal, modification, repair or other activities that could disturb painted surfaces or painted components that contain lead.
  • Respiratory Protection: Devices that filter chemicals and gases or airborne particles from breathable air.  A second type of respirator protects users by providing clean, respirable air from another source. This type includes airline respirators and self-contained breathing apparatus (SCBA).
  • Target Housing:  Housing constructed before 1978 or 0-bedroom dwellings.
  • X-Ray Fluorescence (XRF) is the emission of characteristic "secondary" (or fluorescent) X-rays from a material. XRF may be used for elemental analysis (i.e. lead) and chemical analysis, particularly in the investigation of metals, glass, ceramics and building materials.

III.  Exemptions/Exclusions

  • EPA’s Renovation, Repair and Painting (RRP) program
    • Coatings that have been determined (by chemical analysis) to contain less than 0.5 % or 1.0 milligrams / square centimeter by weight of lead
    • Minor repair and maintenance is exempt from owner notification and certification. – projects that disturb no more than 6 square feet of interior surfaces or more than 20 square feet of exterior surfaces over a 30 day period, excluding certain activities utilizing high speed equipment such as grinding, sanding, blasting, etc.
  • California Code of Regulations, Title 8 § 1532.1 Lead in Construction
    • None

IV.  Responsibilities

  • Environmental Health and Safety
  • Provide compliance assistance, evaluation of exposure potential of abatement projects, and monitoring activities as needed
  • Maintain the Lead Management Program.
  • Ensure that all employees receive training appropriate for their roles in managing lead.
  • Provide Lead Awareness Training to employees who have the potential to disturb or damage lead containing materials.
  • Maintain records as required by this program.
    • Physical Plant Management (PPM)
    • Develop work procedures where there is a potential of disturbing lead containing materials.
    • Assist EH&S with identifying, locating and maintaining lead containing paints and coatings.
    • Assist EH&S in the collection of paint chip samples for analysis.
    • Ensure that all construction and maintenance work involving lead or lead-based materials managed by PPM is performed in accordance with current guidelines.
    • Ensure that recommended work procedures and safety practices will be followed before authorizing construction or maintenance work involving lead.
    • Notify EH&S prior to commencement of work involving lead based construction materials.
      • Facilities Planning, Design and Construction
      • Consult with EH&S on projects requiring removal or demolition of potential lead containing building materials.
        • Employees
        • Notify supervisor and/or EH&S prior to the start of work on suspected lead containing materials.
        • Wear personal protective equipment and clothing when required.
        • Follow approved lead-safe work and management practices.

V.  Training

  • California Code of Regulations, Title 8 § 1532.1 Lead in Construction - Lead training will be provided to employees who are subject to exposure to lead at or above the OSHA action level of 30 μg/m3.  This training will include at a minimum:
    • The content of the Cal-OSHA lead standard(s) and their appendices.
    • The specific nature of the operations, which could result in exposure to lead above the action level.
    • Respiratory protection awareness.
    • The purpose and description of a medical surveillance program.
    • Information concerning health effects associated with excessive exposure to lead.
    • Engineering controls and work practices associated with the employee’s job assignment.
    • The contents of any compliance plan and the location of regulated areas in effect.
  • EPA’s Renovation, Repair and Painting (RRP) program
    • Individuals or organizations that perform renovation, repair or remodeling activities on pre-1978 buildings must be trained and certified to follow the lead-safe work practices required by EPA's Renovation, Repair and Remodeling rule if the buildings meet the following requirements:
    • Child Occupied Facilities – building or a portion of a building visited by the same child under the age of six (6) years for more than 60 hours per year consisting of at least two visits within a week whose weekly total exceeds 6 hours with at least one single visit > 3 hours or
    • Target Housing – Housing constructed before 1978 or 0-bedroom dwellings

VI.  Forms Used

VII.  Procedures

The basics of lead-safe work practices:

-         Contain the work area.

-         Minimize dust.

-         Clean up thoroughly.

  • Lead Safe Work Practices
    • Lead based substrates should be removed intact when possible.
    • Any activities that have the potential to generate lead dust or promote the spread of lead debris should be minimized.
    • Use Personal Protective Equipment (PPE) such as:
    • Gloves
    • Eye protection
    • Protective coveralls may be required depending on activities.
    • Respiratory protection when lead containing materials are disturbed.
    • An exposure assessment will be performed to determine if any employee may be exposed at or above the action level for air borne lead.
      • During any new work process where lead work must necessarily be performed prior to completing the exposure assessment Lead-safe work practices will be utilized.
        • When lead based coatings must be removed by abrasive blasting, welding, or cutting, the lead containing materials must be removed at that location prior to performing the processes.
        • Typical accepted methods for removal of lead based paint are chemical stripping, manual scraping, manual demolition, manual sanding or heat gun.
        • Construction debris containing lead should be maintained intact as much as is feasible.
        • Vacuuming of lead debris is allowed only if the vacuum is equipped with a HEPA filter.
        • All debris must be collected and treated as hazardous waste until a waste determination can be made. When lead debris is generated by demolition outdoors it must be contained by use of wetting agents, plastic sheeting etc.  All dust and paint chips should be contained.
        • When lead dust may be generated inside a building all dust must be thoroughly controlled by isolating the dust from any ventilation system, controlling dust through the use of plastic sheet barriers and minimizing dust by the use of wetting agents when possible.
        • EPA covered Lead Renovation, Repair and Painting (RRP)
          • The University or Contractor must have a current EPA certification to conduct lead based paint activities and renovations.
          • Worker’s must be trained / certified to conduct Lead based paint activities.
          • Before beginning work, provide owners, tenants, and child-care facilities with a copy of EPA's lead hazard information pamphlet Renovate Right: Important Lead Hazard Information for Families, Child Care Providers, and School.

VIII.  Guidelines/Rules

    • Health effects of lead
      • People can get lead in their body if they:
      • Lead is more dangerous to children because:
      • If not detected early, children with high levels of lead in their bodies can suffer from:
        • Damage to the brain and nervous system
        • Behavior and learning problems, such as hyperactivity
        • Slowed growth
        • Hearing problems
        • Headaches
        • Lead is also harmful to adults. Adults can suffer from:
        • Various methods are available to maintain lead personal exposure levels below acceptable levels of OSHA PEL - 50 μg/m3  such as:
        • Administrative controls shall be utilized to reduce employee exposures.
          • Mechanical ventilation may be used as a method to control lead exposure. The ventilation will be evaluated for its effectiveness in reducing exposure. HEPA filtered systems are recommended.
          • Respiratory protection will be used to reduce employee exposure when alternative controls cannot be implemented.
          • Personal protective equipment shall be provided in addition to respiratory protection when the possibility of lead exposure may cause skin or eye irritation. 
          • The consumption of food, beverages or tobacco is prohibited in areas where lead exposures may occur.
          • Housekeeping practices should be utilized when the job is completed to ensure that all surfaces are lead free. Wherever possible, HEPA vacuums or other methods will be utilized to contain lead dust. Shoveling, dry or wet sweeping and brushing are not recommended.
          • Campus Lead Survey
            • Environmental Health and Safety will initiate a survey and develop a list (SP 2013.02) of buildings and components with lead containing materials. This list serves as a reference tool for evaluating projects that involve the disturbance of painted or coated surfaces.
    • People can get lead in their body if they:
      • Put their hands or other objects covered with lead dust in their mouths.
      • Eat paint chips or soil that contains lead.
      • Breathe in lead dust, especially during renovations that disturb painted surfaces.
    • Lead is more dangerous to children because:
      • Babies and young children often put their hands and other objects in their mouths. These objects can have lead dust on them.
      • Children's growing bodies absorb more lead.
      • Children's brains and nervous systems are more sensitive to the damaging effects of lead.
    • Lead is also harmful to adults. Adults can suffer from:
      • Reproductive problems (in both men and women)
      • High blood pressure and hypertension
      • Nerve disorders
      • Memory and concentration problems
      • Muscle and joint pain 

IX.  References

X.  Revision Record

REVISION

CHANGES

DATE

1.0

Creates the Lead Management Program

June 2010

1.1

Format and Program Review

January 2014

1.2

Reviewed

December 2018

Environmental Health and Safety
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