Lead Hazard Control Responsibilities

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.