Lead Hazard Control

The primary purpose of this program is to minimize the exposure of building occupants, maintenance workers, renovation, and custodial personnel to lead dust, lead fumes, and other sources of lead, and to comply with regulatory requirements for disclosure and abatement activities. 

Activities involving lead must comply with all local, state, and federal regulations, as applicable. Departments involved in lead-related activities, such as renovations or construction, shall designate a responsible person to coordinate program requirements at the university. 

Departments where faculty, staff, or students may be exposed to lead fumes from forging, soldering, welding, or heating lead-containing materials, or who otherwise handle lead-containing materials, are to notify Environmental Health & Safety so that the potential lead exposures can be evaluated. If concerns are identified, Environmental Health & Safety will provide guidance on appropriate control measures, including local exhaust ventilation, use of lead-free solder, and medical surveillance, if appropriate.

The purpose of the Lead Hazard Control Program is to minimize the exposure of building occupants, maintenance and custodial personnel during construction and renovation activities, as well as during routine work tasks that may increase the risk of exposure to lead dust or fumes. This program has been designed to comply with applicable state and federal regulations pertaining to lead. Agencies with regulations applicable to lead work on campus include: 

• Virginia Department of Labor and Industry (VDOLI);
• Virginia Department of General Services (DGS);
• Virginia Department of Professional and Occupational Regulation (DPOR);
• Occupational Safety and Health Administration (OSHA); and
• Environmental Protection Agency (EPA). 

Lead is a naturally occurring element found in small amounts in the environment - the air, soil, water, and in some homes. Children are particularly susceptible due to their developing bodies and the potential to touch contaminated objects, and/or putting contaminated objects in their mouths. Adults may be exposed by eating or drinking food or water containing lead, or from dishes or glasses that contain lead. Some activities/hobbies involve the use of lead, such as making stained glass, use of lead-containing ceramic glazes, indoor target practice, or bullet making. 

The Lead Hazard Control Program applies to all university-owned properties, employees, and the public. The program shall remain in effect until all lead-containing paint (LCP) has been removed from all university properties.

Leased properties shall include appropriate disclosures.

OSHA requires that personnel with potential exposure to lead dust be trained/informed of the health effects of lead exposure. Awareness level training is provided to housekeeping/custodial, trades, and maintenance staff. Other employees identified by Environmental Health & Safety, who work with, handle, heat, or otherwise disturb lead-containing materials, are to attend awareness training annually for the duration of that work activity.

Departments involved in work-related activities where lead-containing paints (LCP) and similar building materials containing lead may be disturbed during maintenance, custodial, renovation, or demolition activities shall:

• Designate a safety representative (DSR) specifically to address lead activities.
• Manage projects involving lead-containing paint/materials.
• Retain project documentation in such a manner that it is available upon request to Environmental Health & Safety, VOSH, or others as necessary.
• Update electronic information regarding the location of materials in campus facilities.
• Serve as administrator for university contracts for analytical, inspection, project monitoring, and abatement activities (with input from Environmental Health & Safety).
• Ensure that personnel who sample suspect LCP, conduct lead-related building inspections, perform clearance sampling after the lead abatement, and who perform hazard assessments are trained to lead inspector/risk assessor level. This training is provided by a third party.
• Personnel who develop response actions, or that make recommendations for removal procedures, must meet the minimum qualifications for lead project designer. This training is provided by a third party.

Renovation, alteration of building material (i.e. wall, ceiling, floor, insulation, etc.), or maintenance activities that may disturb LCP shall not occur unless it has been reviewed and approved by the departmental safety representative. Designated departmental safety representatives are responsible for the following:

• Serving as lead inspector for their department.
• Inspecting worksites and sampling suspect paint/materials for lead (if historical information isn't available).
• Maintaining records and communicating results to relative parties for upcoming projects (i.e. supervisors, project managers, contractors, etc.) on the Asbestos and Lead Inspection Report.
• Participating in quarterly meetings scheduled by Environmental Health & Safety.
• Any other duties and responsibilities as defined by Memorandums of Understanding as agreed upon between departments.

Departmental safety representatives who coordinate or perform lead-related activities include:

• For NI&S employees performing work tasks in various buildings on campus, contact Environmental, Health & Safety
• Dave Rettig (540-231-9397) for Division of Student Affairs (540-231-1111) buildings on campus.
• Robin Miller (540-231-2341) with Environmental Health & Safety.

Preventative maintenance and custodial staff should coordinate with their departmental safety representative to assure they are aware of the location of all suspect and known LCP in the buildings where they work. 

• Employees involved in work activities that may accidentally disturb LCP, or where employees work in areas contaminated by lead dust, or who use lead in the course of their work, shall receive awareness level training from Environmental Health & Safety annually. 
• Employees involved in de-leading or lead abatement activities shall maintain current the appropriate level of training/certification - lead supervisor or lead worker. 

If lead-related work activities are identified in academic or research units by Environmental Health & Safety, EHS will assist the department with performing an evaluation of lead exposures, and identification of appropriate hazard controls. As necessary, affected persons will be provided awareness training and access to medical services.

Environmental Health & Safety will provide technical support, accident investigation training, and oversight for this program; however, involvement by Environmental Health & Safety does not relieve the departments, supervisors, or contractors of their individual responsibilities. Environmental Health & Safety responsibilities for this program include:

• Developing, implementing, and administering the Lead Hazard Control Program, including delineation of responsibilities and standardized work procedures (SWP).
• Providing awareness level training to custodial and maintenance personnel annually, and maintaining centralized training records.
• Providing respiratory protection training and fit-testing to employees.
• Serving as a technical resource for program applications on campus.
• Conducting periodic audits and inspections to program requirements of those departments performing lead-related activities.
  
• Responding to potential personnel exposure incidents and campus complaints in conjunction with the responsible DSR and/or project manager.
• Retaining historical lead data/records and providing access to information to departments and building occupants.
• Providing medical surveillance services for all employees involved in lead-related work who are exposed in excess of the Action l Level for more than 30 days per year. Issue notification letters when exposures occur.
• Performing industrial hygiene air monitoring as needed to determine lead exposure levels when employees and students perform work where airborne lead dust or fumes may be generated.
  
• Assisting Real Estate Management with preparation of disclosures and other legal documents for leased properties.
• Scheduling quarterly meetings with DSRs to coordinate requirements of this program.

In accordance with 18VAC15-30-10, a Lead Contractor's License is required for firms that contract with another person, for compensation, to carry out lead abatement activities, or to perform any lead abatement activity, or work on a lead abatement project. Contractors must comply with all local, state, and federal safety requirements, and must assure that all employees performing work on Virginia Tech property have been trained as a Lead Worker, and are provided appropriate personal protective equipment. 

Contractor responsibilities for conducting lead work in Virginia are detailed in 18VAC15-20-510.

The Contractor Safety Program provides additional information for contractors on campus. 

Personnel who perform duties or tasks that may result in contact with lead paint or products, but who do not intentionally disturb lead-containing paint for the purposes of abatement or permanent removal, shall receive Lead Awareness training on an annual basis. Typical workgroups who fall under this category include: housekeeping and custodial staff, plumbers, welders, painters, roofers, electricians, telecommunications, mechanics, etc. Training shall be consistent with EPA requirements in 40 CFR 763.92(a)(1). This training is provided by Environmental Health & Safety. 

In addition to awareness level training, other related training may include:

• Respiratory Protection
• Personal Protective Equipment
• Hazard Communication Right-to-Know

Departments responsible for identifying lead-based paint for construction and renovation activities shall have a certified Lead Inspector perform sampling tasks, and provide pertinent information in an inspection survey/report. Training for a Lead Inspector must be conducted by an EPA/AHERA or DPOR board approved lead training program. Initial training is at least 24 hours, with at least eight hours devoted to hands-on training. This training must be taken through an outside provider. Additional training may be required when using:

• X-ray fluorescence spectrum analyzers
• Analytical X-ray equipment

Training for a Lead Risk Assessor must be conducted by an EPA/AHERA or DPOR board-approved lead training program. Initial training is at least 16 hours, with at least four hours devoted to hands-on training. This training must be taken through an outside provider.

This work involves direct, intentional removal or remediation of lead-containing materials (i.e. abatement). Such work activities will be performed by a certified lead abatement contractor in accordance with the Division of Campus Planning, Infrastructure, and Facilities' "Hazardous Material Abatement Services" contract. Training for a Lead Abatement Worker must be conducted by an EPA/AHERA or DPOR board-approved lead training program consisting of 16 hours of training (with 8 of those hours devoted to hands-on training). This training must be taken through an outside provider.

Abatement activities will be performed by a certified lead abatement contractor in accordance with the Division of Campus Planning, Infrastructure, and Facilities' "Hazardous Material Abatement Services" contract. Training for a lead abatement supervisor must be conducted by an EPA/AHERA or DPOR board-approved lead training program. Initial training is at least 32 hours, with eight hours devoted to hands-on training. This training must be taken through an outside provider.

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

Abatement: (in reference to lead) Any measure(s) designed to permanently eliminate lead-based paint hazards, including lead-contaminated dust or soil. Abatement includes, but is not limited to: the removal of paint, and dust, the permanent enclosure or encapsulation of lead-based paint, the replacement of painted surfaces or fixtures, or the removal or permanent covering of soil, when lead-based paint hazards are present in such paint, dust, or soil; and all preparation, cleanup, disposal, and post-abatement clearance testing activities associated with such measures.

Accessible surface: A surface that protrudes from the surrounding area to the extent that a child can chew the surface and is within three feet of the floor or ground (e.g. window sills, railing, and the edges of stair treads).

Accredited: Individuals have successfully completed a training program approved by the Virginia Board for Asbestos, Lead, and Home Inspectors to engage in asbestos abatement.

Action level: Employee exposure, without regard to the use of respirators, to an airborne concentration of lead of 30 micrograms per cubic meter calculated as an 8-hour time-weighted average (TWA).

Board: Refers to the Virginia Board for Asbestos, Lead, and Home Inspectors

CFR: Code of Federal Regulations

Child-occupied facility: A building, or portion of a building, constructed prior to 1978, visited regularly by the same child, sic years of age or under, on at least two different days, within any week, provided that each day's visit lasts at least three hours and the combined weekly visit lasts six hours, and the combined annual visits last at least 60 hours. Child-occupied facilities may include but are not limited to, day-care centers, preschools, and kindergarten classrooms.

Construction work: Work for construction, alteration and/or repair, painting and decorating, demolition or salvage, removal or encapsulation, installation of lead-containing products, transportation, disposal, storage, or containment of lead or lead-containing materials, maintenance operations associated with construction activities.

Deteriorated paint: Any interior or exterior paint that is peeling, chipping, chalking, flaking, cracking, or is otherwise separating from the substrate building component. 

DOLI: Department of Labor and Industry.

DOPR: Department of Professional and Occupational Regulation.

Dust clearance sampling: An on-site collection of dust or other debris that is present after the completion of a renovation to determine the presence of lead-based paint hazards and the provisions of a report explaining the results.

Employee exposure: That exposure to lead that would occur if the employee were not using respiratory protective equipment.

Encapsulation: The application of a substance that forms a barrier between lead-based paint and the environment using a liquid-applied coating (with or without reinforcement materials), or an adhesively bonded covering material.

Enclosure: The use of rigid, durable construction materials that are mechanically fastened to the substrate in order to act as a barrier between lead-based paint and the environment.

EPA: Environmental Protection Agency.

Friction surface: An interior or exterior surface that is subject to abrasion or friction (e.g. certain window, floor, and stair surfaces).

HEPA: High-Efficiency Particulate Air filtered equipment must be capable of trapping and retaining 99.97% of all particles larger than 0.3 microns.

Impact surface: An interior or exterior surface that is subject to damage from repeated impacts (e.g. certain parts of door frames).

Industrial hygienist: A professional qualified by education, training, and experience to recognize, evaluate, and develop control measures for occupational health hazards.

Lead: Metallic lead, all inorganic lead compounds, and organic lead soaps. Excluded from this OSHA definition are all other organic lead compounds.

Lead-based paint: Paint or other surface coatings that contain lead equal to or in excess of 1.0 milligrams per square centimeter (1.0 mg/cm2) or more than 0.5 percent by weight.

Lead-Based paint activity: Lead inspection, lead risk assessment, lead project design, and abatement of lead-based paint and lead-based paint hazards, including lead-containing dust and lead-contaminated soil.

Lead-based paint free: Target housing that has been found to be free of paint or other surface coatings that contain lead equal to, or in excess of, 1.0 milligram per square centimeter, or 0.5 percent by weight.

Lead-based paint hazard: Any condition that causes exposure to lead from lead-contaminated dust, lead-contaminated soil, or lead-contaminated paint that is deteriorated or present inaccessible surfaces, friction surfaces, or impact surfaces that would result in adverse human health effects as identified by EPA.

Lead-contaminated dust: Surface dust that contains an area or mass concentration of lead at or in excess of levels identified by the EPA.

Lead-contaminated soil: Bare soil that contains lead at or in excess of levels identified by the EPA.

Lead inspection: A surface-by-surface investigation to determine the presence of lead-based paint and the provisions of a report explaining the results of the investigation.

Lead inspector: An individual who has been licensed by the Board to conduct lead inspections and abatement clearance testing.

Lead project: Any lead-related activity which requires the contractor performing such activity to be licensed by the Board.

Lead risk assessor: An individual who has been licensed by the Board to conduct lead inspections, lead risk assessments, and abatement clearance testing.

Licensee: Any person, as defined by the Code of Virginia, who has been issued and holds a currently valid license as a lead abatement worker, lead abatement supervisor, lead inspector, lead risk assessor, lead project designer, or lead abatement contractor.

Medical surveillance: A periodic comprehensive review of a worker's health status.

NIOSH: National Institute for Occupational Safety and Health. Primary functions are to conduct research, issue technical information, and test and certify respirators.

OSHA: Occupational Safety and Health Administration, administered in Virginia by the Department of Labor and Industry (DLI).

Paint in poor condition: More than ten square feet of deteriorated paint on exterior components with large surface areas; or more than two square feet of deteriorated paint on interior components with large surface areas (e.g. walls, ceilings, floors, doors); or more than ten percent of the total surface area of the component has deteriorated on the interior or exterior components with small surface area (e.g. window sills, baseboards, soffits, trim).

PEL (Permissible Exposure Limit): The highest allowable level of exposure to lead in the air that an employee may be permissibly exposed over an eight-hour workday, without using respiratory protection, as stated by the Occupational Safety and Health Administration (OSHA). With regards to lead, the employer shall ensure that no employee is exposed to lead concentration in excess of 50 micrograms per cubic meter of air averaged over an 8-hour period.

Personal air samples: An air sample taken with a sampling pump directly attached to the worker with the collecting filter and cassette placed in the worker's breathing zone. These samples are required by the OSHA asbestos standards and the EPA Worker Protection Rule.

Personal protective equipment: Any material or device worn to protect a worker from exposure to, or contact with, any harmful material or force. PPE should be used only if engineering or administrative controls are insufficient to protect against a hazard.

Renovation: Altering, in any way, one or more facility components.

Residential dwelling: (1) Target housing that is a detached single-family dwelling, or (2) target housing that is a single-family dwelling unit in a structure that contains more than one separate residential dwelling unit, which is occupied, or intended to be occupied, in whole or in part, as the home or residence of one or more individuals.

Respiratory protection: A device worn to either purify the air or that provides clean air from another source to the wearer. All respirator users must be enrolled in Virginia Tech's Respiratory Protection Program and must have received appropriate training on respirator use, care, and maintenance.

Risk assessment: (1) An on-site investigation to determine the existence, nature, severity, and location of lead-based paint hazards, and (2) the provision of a report by the individual or firm conducting the assessment, explaining the results of the investigation and options for reducing lead-based hazards.

Target housing: Any housing constructed prior to 1978, except housing for the elderly or persons with disabilities (unless one or more children age 6 years or under resides, or is expected to reside in such housing for the elderly or persons with disabilities), or any zero-bedroom dwelling (e.g. barracks, dormitories, studio apartments, lofts).

TCLP - 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.

TWA - Time-weighted average: In air sampling, this refers to the average air concentration of contaminants during a particular sampling period (typically 8 hours).

XRF analyzer - X-ray fluorescence spectrometer: A handheld unit used to identify and analyze the elemental composition of materials for the presence and quantity of lead in paint layers, for example.

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.