Lead–Based Paint
Lead Regulations
29 CFR 1926.62, OSHA Construction Industry
Standard For Lead
Smithfield Foods, Inc. Policy
Most buildings and equipment built before 1978 are
likely to contain lead-based paints.
Purpose: The Lead regulations are intended to protect
workers from the harmful health effects of lead.
Lead-Free Paint
“Lead-Free Paint” – may contain up to 1% Lead
Any paint scheduled for use at a Smithfield Foods,
Inc. facility must be = or > the maximum TCLP
concentrations.
TCLP – Toxicity Characteristic Leaching Procedure
Paint debris not in compliance w/ TCLP must be treated
as a HAZARDOUS WASTE.
Paint in compliance with TCLP may be safely disposed in
a municipal solid waste (MSW) landfill.
Projects
Small Scale (Parts, storage cabinets, ect.)
Less than 100 sq feet
Short Duration
Do not need to test paint if item has undergone recorded
or regular paint removal. (ie. Scale part)
Large Scale
> 100 sq feet
Performed by approved contractor
Both need proper PPE as specified in
OSHA Construction Industry
Standard for Lead
Notification
Proper Notification must be given to employees
in or near lead-based paint work or exposure
area
Signs Around work area must include:
DANGER
LEAD WORK AREA
POISON
NO EATING OR DRINKING
Permissible Exposure Limit
PEL is 0.05 mg/cubic foot of air
averaged over an 8-hour period (TWA).
If the PEL is exceeded, respirators
must be used by employees in addition
to existing work practices and controls.
OSHA Construction Industry Standard for Lead
Applies to all construction work with possible
occupational exposure to lead
Lead-based paint removal, painting, transportation,
disposal, and storage
Minimize exposure
work practices, engineering controls, and PPE
Written compliance program before work begins
Guidance on respirators, PPE, decontamination,
medical monitoring, workplace monitoring, employee
notification, employee information, and training.
Training and Qualifications
Must use certified contractors for large scale
projects.
Check contractors’
Certification
Compliance History
Written Compliance Program for the specific
activity
Medical
Respirator and PPE fitness
Waste Disposal
Waste Includes –
Lead-Based Paint Debris
Filters
Contaminated Clothing
Packaging and other contaminated materials
TCLP –
Pass – Municipal Solid Landfill
Fail – Hazardous Waste
Waste must be properly labeled and put in
impermeable bags
Waste Shipment Records
Record Keeping
Facility Records:
Paint Records
Disposal manifests and records;
Contractor Files;
• Certifications;
• Dates of Removal (type and method);
Personnel Records;
• Certifications
• Exposures
• Medical (Respirator Clearance)