Lead Hazard Control

The Virginia licensed Lead Inspector or Risk Assessor shall prepare a written report titled "Asbestos and Lead Inspection Report" for the purpose of communicating the presence or absence of lead-containing materials in any renovation, demolition, or addition project. The following information is required, at a minimum, for the lead inspection portion of the report:

• Lead inspector or risk assessor's name and license (or certification) number
  • Note: License (or certification) must be current on the day of the inspection.
• Location of any new surveys conducted (building, room number, or other reference)
  • Note:  Per the Department of General Services' "Construction and Professional Services Manual,"locations must be marked on the drawings.
  • Note: If information is from historical data, indicate such in the report. Historical data may include information from the asbestos and lead database, CAD drawings, sample reports not included in the database, and abatement records.
• Location, type, and quantity of all lead-containing materials within the scope of work for the project
• Note the general condition of the material (ex. good, peeling, etc.)

Documentation regarding lead abatement projects shall be submitted to the university in accordance with the current "Hazardous Material Abatement Services" contract, which is held by the Division of Campus Planning, Infrastructure, and Facilities.

While many exposures to lead are non-occupational, there are some potential workplace exposures. The majority of overexposures occur in the manufacturing sector, in industries that make batteries, aircraft, plumbing fixtures, etc. Examples of potential non-construction, occupational exposures include:

• Disturbing lead-based paint on painted surfaces or structures without using wet methods or dust control; 
• Dust or paint chips from deteriorating lead-based paint in the work area if the debris is disturbed or not handled properly;
• Use of products containing lead (ex. solder, lead-acid batteries, plumbing, pottery glazes, paints, or ammunition);
  • Review the product Safety Data Sheet for suspect materials to determine if they contain lead.
• Welding, cutting, brazing, or soldering with lead, or on lead-based paint on a substrate;
• Foundry or metal-working (casting, grinding, polishing, buffing, smelting, and refining); or
• Use of lead-containing chemicals.

If lead is present in the workplace in any quantity and there is a potential for airborne, inhalable lead dust or fumes to be generated, an initial determination of whether or not the Action Level (AL) is exceeded for any employee must be made. Exposure monitoring for lead is conducted to determine if there is an employee exposure at or above 30 ug/m3, averaged over an 8-hour period. Employees selected to be included in monitoring are based upon information, observations, calculations, historical monitoring, or complaints of symptoms attributable to lead. 

Once monitoring has been completed by Environmental Health & Safety, employees will be notified in a timely manner of the results, and any necessary corrective actions to be taken to reduce or eliminate overexposure will be communicated to the department.

Initial Assessment

Initial monitoring to determine exposures may be limited to a representative sample of exposed employees who are reasonably believed to have the greatest airborne concentrations of lead exposure. 

• Where monitoring results show a possibility of exposure at or above the Action Level, monitoring will be conducted for each employee exposed to lead. 
• Where monitoring results indicate that employees are not exposed at or above the Action Level, results shall be documented, and future monitoring is not necessary unless there are changes in the production, process, controls, or new potential exposures to lead.
• Where initial monitoring indicates employee exposure above the Permissible Exposure Limit (50 ug/m3), controls shall be implemented to reduce or eliminate exposure, and monitoring shall be repeated quarterly.
  • Monitoring shall be repeated every six months where exposure is above the Action Level, but below the Permissible Exposure Limit (PEL). 
  • Subsequent monitoring shall be in accordance with OSHA requirements specified in 1910.1025.

Preventative measures to minimize or eliminate potential exposures to lead include:

• Reporting deteriorating paint in buildings to your facilities management contact for mitigation. 
• Using approved work practices to clean up any dust or debris. 
• Training individuals who may encounter lead-containing paint, or other lead materials, during their normal work activities so that precautions can be taken prior to exposures. 
• Involving EHS in the evaluation of activities that involve the heating or handling of lead materials, such as solder, coated metals, glazes, lead chemicals or products, etc.
• Developing standard work practices and procedures that will allow renovation, construction, or maintenance to be performed safely, and without exposing employees, building occupants, or members of the public to airborne or surface lead dust hazards. Procedures include:
  • Work Order Reviews
  • Standard Work Practices

Where any employee is exposed to lead above the Permissible Exposure Limit (PEL) for more than 30 days per year, engineering and administrative controls to reduce exposure to lead shall be implemented. Such controls include, but are not limited to:

• Medial surveillance
• Use of personal protective equipment, as necessary, including respiratory protection
• Local exhaust ventilation
• Dust control methods on power tools
• HEPA-filtered vacuums
• Wet methods for cleaning
• Avoiding the use of prohibited methods of cleaning, such as the use of compressed air or shoveling and dry sweeping
• Awareness level training
• Warning signs where exposure is above the PEL

No. It's still used in the manufacture of electrical storage batteries, ammunition, various chemicals, and fishing sinkers. It's also still used in industrial applications, such as in yellow road-marking paint, and red corrosion-resistant steel paint on bridges. Leaded solder is still used in circuit board manufacturing and other processes.

While the use of lead as additives in paint, gasoline, solder, and pipes has been reduced or eliminated in some cases, the old products or their remains can still be found in the environment.

Is training mandatory? If so, when? Yes. Persons who perform maintenance or renovation work, or who work with lead materials in the course of their duties must attend this training.

Class length: 1 hour.

Available online: Yes.

When is refresher training required? Annually.

Please see the online class schedule for more information.

If leaded solder cannot be replaced with lead-free solder, soldering in a fume hood or use of local exhaust ventilation (i.e. snorkels or table top fume extractors) must be used to divert fumes away from the breathing zone.

TCLP stands for Toxicity Characteristic Leaching Procedure, an EPA test used to characterize waste streams (for lead) as either hazardous or non-hazardous for the purpose of disposal.

A sample of the waste is sent to a third party lab and a report is issued indicating the results. The waste stream is then handled accordingly.

Lead was used in paint because it's a pigment that adds durability and corrosion control, and serves as a drying agent.

Lead-based paint is any paint, varnish, shellac, or other coating on surfaces that contain 1.0 mg/cm2 or more of lead, or 0.5 percent or more lead by weight. Note that from OSHA's perspective, if any level of lead is present in a material that will disturbed, then the work practices must comply with OSHA's lead standard.  

All facilities which may house children 6 years of age and younger, that were constructed prior to 1978, must have a lead materials and lead paint inspection, and risk assessment, conducted by a Virginia-licensed lead inspector and/or risk assessor prior to it being occupied.