"Lead-Based Paint Identification and Removal"
The George Washington University Lead-Based Paint Identification and Removal Purpose: To establish general procedures for staff, students, faculty and contractors who encounter lead- based paint in campus buildings at The George Washington University. Statement: It is the policy of the University to protect the campus community from potential exposure to lead-based paint dust. This policy establishes general safety procedures for the identification, maintenance, accidental disturbance, and abatement of lead-based paint in accordance with the regulations issued by the Occupational Safety and Health Administration (OSHA) Lead In Construction Standard (40 CFR 1926.62), the Environmental Protection Agency (EPA) Lead: Requirements For Disclosure of Known Lead Based-Paint (24 CFR Part 35), and the District of Columbia Lead-based Paint Abatement And Control Act of 1996 DC Law 11-221. General Most houses and buildings built before 1950 have had lead-based paint applied to the interior or exterior surfaces. In most cases, lead paint of this era contained up to 40% lead by weight. Paints made between 1950 and 1978 usually contained smaller amounts of lead. Lead paint that is in poor condition is known to be a potential hazard to small children and pregnant women. In 1993, increasing concerns about exposure to lead paint during construction and renovation activities prompted OSHA to revise their Lead In Construction Standard to be more protective of workers engaged in such activities. The standard provides guidelines and work practices to minimize the generation and migration of lead-containing dust, establishes a permissible exposure limits for inhalation, and biological monitoring criteria. Procedures ?? Prior to building maintenance or renovation projects involving the disturbance of painted surfaces, particularly by means of scraping or sanding, the University’s Project Manager is responsible for arranging a survey to determine if lead-based paint is present in the work area, and if so, whether it will be impacted by the planned work. This can be accomplished by contacting the Risk Management Office at 994-3265. The Risk Management Office may also provide guidance and coordination for lead-based paint removal projects. Larger scale projects may require the University to hire an outside firm to coordinate and design the abatement plan. ?? The Project Manager is responsible for ensuring that all contractors and subcontractors are informed of the location of lead-containing paint in the work areas to which they are assigned, and that painted surfaces that may be impacted by the work are abated. ?? Under no circumstances shall University or contracted workers damage or disturb known or suspected lead-based paint unless they are a licensed abatement contractor or envi ronmental consultant, and have been specifically employed to perform sampling, removal or repair. ?? If left undisturbed, lead-based paint does not always need to be removed. In some cases, management in place may be advisable. The Risk Management Office will provide specific recommendations for each project that involves lead-based paint. ?? If the sole purpose of a renovation is to remove lead-based paint, it is considered a lead abatement project, and the District of Columbia requires notification of the project 10 days in 1 advance of the anticipated start date. The District also requires the use of a licensed firm to perform the abatement and the air monitoring of the project area during removal, inspection, and clearance testing prior to re-occupancy. In most cases, an outside contractor performs each of these functions. ?? If suspect lead-based paint is discovered during the course of renovation/demolition work, the Project Manager/Site Supervisor should suspend work that could disturb the material and contact the Risk Management Office for testing of the materials. Work must not resume until the material can be positively identified. ?? In the event that lead-based paint is accidentally impacted, Project Managers/Contractors should contact the Risk Management Office and take all reasonable precautions to protect University employees, students and visitors from exposure to lead dust, and possible building contamination. Emergency response measures may include: isolating the work area with plastic sheeting, employing wet methods, using a HEPA vacuum, and wearing a respirator. Exposure monitoring by means of air sampling may also be advised. ?? If lead paint was disturbed in areas occupied or frequently visited by children under six years old or pregnant women, clearance testing is advised. Risk Management should be contacted to perform wipe sampling of the areas. Sample results will be compared to the clearance requirements for lead abatement projects. ?? Contractors that disturb lead-containing paint must take the necessary precautions to protect their own employees, and are responsible for ensuring that their employees have had the appropriate level of training for the tasks being performed. ?? Lead paint chips usually contain enough lead to be considered a hazardous waste. If paint chips are generated, they must be collected and set aside for proper disposal by the Risk Management Office. Risk Management will coordinate any TCLP tests required of paint residues to determine if the material must be disposed of as hazardous waste. ?? Lead-based paint that has be characterized as hazardous waste must be disposed of in a secure landfill in a manner consistent with relevant state and federal regulations. Enforcement Departmental Directors and the Directors of Architecture, Engineering and Construction, Facilities Management, Special Projects, Property and Real Estate Management will be responsible for complying with this policy. Compliance includes the communication of the policy to all relevant members of their staff as well as all contractors under their control. Information and Questions If you have any questions on the Lead-Based Paint Identification and Removal Policy, please contact the Risk Management Office at (202) 994-3265. Create Date: 2002-02-11 Author: Risk Management 2