Lead Hazard Control Summary
Applies to:
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.
Requirements
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.
Purpose
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.
Scope
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.
Health Effects
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.
Application
Construction and renovation activities may involve the disturbance or abatement of lead-based paint in occupied buildings. Abatement activities shall only be performed by licensed contractors with trained personnel, and in accordance with university requirements and regulatory authorities. Project managers and designated departmental safety representatives shall ensure proper disclosure of lead-based paint on university property to contractors working in the area. Where work occurs in occupied buildings, necessary steps shall be taken to ensure university personnel are not exposed to lead dust or fumes. For more information on the coordination of work activities involving contractors and subcontractors, refer to the Contractor Safety Program.
If a lead abatement project is performed, building occupants will be notified via VT Repair email notices. These notices explain the work that will be performed and the measures that will be taken to reduce the potential for exposure during the project. The person receiving the notice should share it with building occupants as appropriate. Additional notices/signage shall be posted at the work site per OSHA/EPA requirements.
Employees performing work tasks at the university may be in areas that have lead-based paint present or perform certain work tasks that involve lead-containing products, such as soldering, painting, welding, etc. To determine if lead-based paint is of concern in your area or for your scope of work, information is available per the Building Occupant Awareness program (see below). Information on various products that may be used during the course of your work is available on the material's Safety Data Sheet.
Occupants may review lead-related building survey records for their building (or work area) by contacting their designated departmental safety representative or Environmental, Health & Safety as follows:
- Dave Rettig for Division of Student Affairs buildings on campus.
- Robin Miller with Environmental Health & Safety.