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Lead Based Paint Guidelines

The goal of these guidelines is to minimize any potential exposure and to comply with all applicable federal, state and city regulations pertaining to management of lead-based paint (LBP). The guidelines address the following issues such as inspection, worker certification, abatement, communication, housekeeping and recordkeeping. 

1. General Information:

In general, buildings or structures built before 1978 may contain lead based paint. Lead paint poses little or no risk as long as it is maintained in good condition. Even loose or damaged paint poses little or no risk to most adults as long as it is not ingested or inhaled.

2. Activities That Impact Lead Based Paint:

Two categories of activities that impact lead based paint are  “no risk” activities and “at risk” activities. “No risk” activities are defined as those that generate either no airborne lead or only low levels of lead dust in air (< 30μg/M3)*.

Examples include:

  • Painting Intact Lead based paint
  • Hand Scraping Lead based paint
  • Wet Sanding Lead based paint

“At risk” activities are defined as those that are likely to generate moderate to high levels of lead fume or dust in air (>30μg/M3)* and are of long or short duration of time.

Examples include:

  • Hand scraping lead based paint
  • Wet sanding lead based paint
  • Electric sanding lead based paint **
  • Grinding or burning lead based paint **
  • Using a heat gun on lead based paint**
  • Removing lead based paint with chemical strippers
  • Replacing windows with lead based paint
  • Demolishing lead based painted structures

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*  The action limit for airborne lead as defined by the OSHA Lead Standard. Concentration of > 30μg/M3 averaged over an (8) hour shift triggers requirements for employee exposure medical surveillance, monitoring and training.
** Abatement procedures are prohibited in daycare/kindergarten or residential settings (i.e. apartments and dorms) unless approved by EH&S.


3. General Requirements for “No Risk” and “At Risk” Activities:

A. Equipment and Supplies:

The following supplies are necessary for any work involving surface preparation of lead paint:

  • Polyethylene sheeting (6 mil)
  • Water spray bottle
  • HEPA vacuum
  • Waste containers
  • Utility knife
  • Scraper
  • Duct tape

B. Personal Protective Equipment:

The following personal protective equipment is required for “at risk” activities:

  • Disposable coverall
  • Air Purifying Respirator with HEPA filters

C. Work Practices – Interior Work:

Plastic sheeting (6 mil thickness) shall be used to protect the following areas:

  • Floor surfaces of  work area
  • Furnishings (e.g. desks, chairs, computers, etc.)
  • Ventilation diffusers, vents, grills

Scraping and sanding of LBP shall be conducted using a spray water bottle to pre-wet the affected surface and to mist the air.
Loose paint chip debris shall be HEPA vacuumed from the plastic sheeting before removal and disposal of the sheeting.
Final cleaning of affected work surfaces shall be accomplished by wet wiping and HEPA vacuuming. Clean water or a high phosphate solution (i.e. 5% tri-sodium phosphate) shall be used.

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D. Work Practices – Exterior Work:
Plastic sheeting shall be used to protect the following areas:

  • Shrubs, trees and ground cover beneath the work area
  • Sidewalks and other paved areas
  • Outside air intakes, window air conditioners and other vents

Plastic sheeting shall be secured to the building and extend out at least 8 feet.
Windows and doors shall be closed for the duration of the work.
A barricade shall be erected to control pedestrian traffic around the abatement work area.

E. Window Removal and Replacement:
Window surfaces shall be pre-cleaned with a HEPA vacuum prior to window replacement. Nearby interior surfaces and occupant belongings shall be protected with (6) mil plastic sheeting. Exterior surfaces shall be protected.

The following sequence of work shall be followed:

  • Unscrew and remove exterior stops
  • Remove top sash
  • Remove parting beads with pry or pliers
  • Remove bottom sash
  • Remove right and left side window trough casings with pry
  • Pry off head stop
  • Remove existing mullions
  • Remove exterior header
  • HEPA vacuum surrounding surfaces and window wells

The removal sequence for custom windows (e.g. stained glass, bow, plate glass) with components that are lead painted shall be determined on a case-by-case basis.

4. The following Specific Requirements must be adhered to by the abatement contractor:

  • The lead contractor must have an EPA certification.
  • The supervisor must complete (40) hour EPA lead supervisor compliance course.
  • The laborer must complete (30) hour EPA lead worker compliance course.
  • The supervisor and laborers must complete a lead worker OSHA compliance course
  • All workers must have a Blood Lead Level (BLL) prior to commencement of work.
  • Personal Air monitoring must be done by the lead abatement contractor for the crew.
  • Ambient Air testing must be done by the 3rd party environmental consulting firm.
  • Contractor must send the work schedule to EH&S prior to commencement of work.                                                
  • SDS for the Peel Away or Back to Nature must be forwarded to EH&S prior to commencement of work.
  • SDS for paint or primer must be forwarded to EH&S prior to commencement of work.
  • Proper Personal Protective Equipment (PPE) must be utilized by the laborer, such as respirator, gloves, hardhat, protective clothing, safety belt and safety harness, if applicable.
  • Fall Protection Plan
  • Site Safety Plan
  • Wash station or a Personal Decontamination Unit must be utilized.
  • Lead debris will be discarded in a fifty five gallon drum provided by EH&S.
  • Coordinate with EH&S to pickup and drop off fifty five gallon drum.
  • Setup a storage room for lead debris prior to commencement of work.
  • Storage rooms must have a lock and a caution sign on the door. Drums must be sealed and labeled.
  • Disposal arrangements in a roll-off container must be coordinated with EH&S.
  • Work procedures must be approved by the Lead Coordinator prior to the commencement of work.  
  • There must be containment of the lead abatement project with lead warning signs, tent, and caution tape.
  • The area must pass final clearance wipe testing and ambient air testing.
  • Final clearance wipe testing and ambient air testing lab results must be included in the final report.

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