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Lead

Introduction

Workers have been poisoned by lead for thousands of years. Most lead over-exposures in the construction industry are found in the trades such as plumbing, welding and painting. In building construction, lead is frequently used for roofs, cornices, tank linings and electrical conduits. In plumbing, an alloy of lead/tin had been used extensively for soldering tin-plate and pipe joints. Use of lead solders in plumbing systems is now prohibited by law. Lead-based paint had also been used extensively for residential and commercial applications but has been banned for residential use by the Consumer Product Safety Commission. Lead-based paint may still be used on metal structures (bridges, railways, beams, etc.) to prevent corrosion, although substitute coatings are now available.

Significant lead exposures can arise during stripping or demolition of structures containing lead-based paint. Due to increases in highway work such as bridge repairs, residential remodeling and lead abatement, the potential for exposure to lead has become more common. The types of work with the greatest potential for lead exposure include iron work, demolition, painting, plumbing, electrical, lead-based paint abatement, heating/air conditioning and carpentry/renovation activities.

Applicable University Policy

UM Lead Management Plan

Applicable Regulations

• 29 CFR 1910.1025 - Lead (OSHA - General Industry)
• 29 CFR 1926.62 - Lead (OSHA - Construction)
• COMAR 26.02.07 - Procedures for Abating Lead Containing Substances from Buildings
• COMAR 26.16.01 - Accreditation and Training for Lead Paint Abatement Services
• COMAR 26.16.92 - Reduction of Lead Risk in Housing
• COMAR 26.13 - Disposal of Controlled Hazardous Substances
• EPA/RCRA - Title 40 CFR Parts 260-265 and 268
• EPA/TSCA - Lead: Household Waste Policy
• DOT - Title 29 CFR Parts 171, 172, 173, 178, and 179

Summary of Requirements

• Contractors performing lead abatement must be licensed by the Maryland Department of the Environment (MDE).
• Prior to the performance of any demolition or renovation activities, materials must be assessed for the presence of lead.
• Representative and periodic air monitoring must be conducted for all employees with airborne (fume, dust) lead exposure.
• Employees with 8-hour time-weighted average (TWA) exposures over 30 ug/m³ (Action Limit) for thirty days per year must be enrolled in a lead medical surveillance program.
• All employees with potential exposure to lead must receive training.
• Employees with lead exposure in excess of the Permissible Exposure Limit (PEL) of 50 ug/m³ as an 8-hour TWA must be provided appropriate protective clothing and respiratory protection.
• Engineering controls must be implemented, if feasible, to reduce lead exposures below the PEL.
• A written compliance plan must be implemented if airborne concentrations of lead exceed 50 ug/m³ as an 8-hour TWA.
• Surfaces must be maintained as free as possible from accumulation of lead dust.
• Signs must be posted outside areas where employees' lead exposures exceed the PEL.
• Certain work practices such as open flame burning, dry sanding and dry scraping of lead-containing substances are not permitted.
• Specific containment procedures are stipulated to control emissions from interior and exterior lead abatement sites.
• Surfaces in lead abatement sites must be cleaned.
• Lead-containing wastes must be handled, transported and disposed per DOT and EPA/MDE regulations.
• Specific surface lead dust testing must be performed in residential properties following lead abatement to verify adequate cleanup.

Training

• All employees with potential exposure to lead must receive basic awareness training.
• Individuals performing certain lead-related functions must receive MDE-accredited initial and annual training. These functions include:
• Lead Paint Abatement Worker
• Lead Paint Abatement Contractor
• Lead Paint Abatement Supervisor
• Lead Abatement (Residential) Project Designer
• Lead Paint Inspector
• Lead Paint Risk Assessor

Reporting

• A facility owner is required to notify residential occupants of all planned contractual lead abatement.
• Licensed contractors must notify EPA/MDE of all lead abatement projects.
• All owners of non-dormitory housing must notify residential occupants of lead hazards that may exist in the residence.

Written Program

A written compliance program must be developed for each lead abatement activity. It must be reviewed every six months and be available for on-site inspection. The following items are major components:

• regulatory information
• description of emission activities
• PEL compliance technologies
• air monitoring program
• work practices
• administrative control program
• personnel protection program
• medical surveillance/removal
• information and training
• signage
• recordkeeping

Inspections

• Building materials must be assessed for the presence of lead prior to all demolition and renovation operations.
• EPA/MDE may inspect lead abatement projects at any time to determine regulatory compliance and adequacy of work.

Recordkeeping

• Facilities shall maintain specific records relative to each lead abatement project.
• Exposure monitoring and medical surveillance records must be maintained per requirements of 29 CFR 1910.20.

University Resources

Written 5/98
Revised 3/04

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