Lead-Containing Materials Procedures

Purpose

Adverse health effects may result from over exposure to lead. The purpose of these procedures is to educate departments and establish standards to protect workplace employees, building occupants, and the public from risks of lead exposure. 

Scope and Authority

The policies and procedures in this document are the minimum requirements for performing work with the potential to disturb lead or lead-containing materials.

Outside contractors shall be required to provide evidence they have a Lead Program that meets OSHA requirements prior to being allowed to perform work on campus that disturbs lead-containing materials.

EXCEPTION: If work is required to be done in a daycare, preschool or housing area with children age 6 or below present, contact the Environmental Health & Safety Office for additional requirements before beginning work.

Regulations and Policies

  • University of Iowa Operations Manual, Part III Human Resources, Division II Standards and Ethics, Chapter 16.4.d Policy on Ethics and Responsibilities for University of Iowa staff. 
  • Iowa Occupational Safety and Health Administration, 29 CFR 1910.1025 and 1926.52, pertaining to worker safety in industry and construction.  
  • Environmental Protection Agency, 40 CFR Parts 50 and 141, pertaining to ambient air and drinking water.
  • Environmental Protection Agency, 40 CFR Part 745, pertaining to paints, dusts, and soils in pre-1978 housing and child-occupied facilities.
  • Centers for Disease Control and Prevention pertaining to screening children and preventing exposures.

Definitions

Lead means metallic lead, all inorganic lead compounds, and organic lead soaps. Excluded from this definition are all other organic lead compounds.
 
Lead-based paint is paint that contains at least 1 mg/cm2 or 5000ug/g (0.5%) lead by weight.
 
Appendix B includes detailed listings of items and materials known or suspected to contain lead.

Responsibilities

  • EHS is responsible to establish University procedures to meet regulatory requirements.
  • Environmental Services or any other University or UIHC department that is managing contractors or conducting activities that may disturb lead-containing materials shall implement exposure control procedures.
  • Deans, Directors and Department Heads are responsible to provide oversight of department activities to ensure compliance with exposure control procedures. Day to day oversight may be assigned to a Department Lead Program Administrator.
  • Supervisors are responsible to implement procedures for employees.
  • Employees are responsible to comply with procedures and any further requirements set by the supervisor.

Procedures

General Requirements for Working with Lead or Lead-containing Materials

Government regulations limit the level of lead allowed in the air, in the water, and in waste materials being disposed.  Because of the complexity of lead regulations designed to prevent excessive lead
exposure to people and the environment, work that includes disturbing lead or lead containing materials requires special training and procedures.  

Analyze the Material for Presence of Lead

While there are general indicators of the presence of lead and simple over-the-counter lead test kits, these methods have not proven to be completely reliable indicators for the presence of lead and they do not provide the concentration of lead in the suspect material.  The only ways to confirm the presence or absence of lead is to either find the information on the MSDS for the suspect material, or to have an experienced laboratory analyze a sample of the material for the presence and concentration of lead.  Since the MSDS of most materials are rarely kept, laboratory analysis of samples of the suspect material is the preferred method of determining lead presence.  Proper lead testing can be obtained by contacting Environmental Services at 319-335-6190.   

Disturbing Lead-containing Materials

All work that results in the disturbance of lead-containing materials must be performed in accordance with the “Procedural Flow Chart for Disturbing Lead” found in Appendix A. There are seven sets of procedures to select from, based on the results of the exposure assessment and the nature of the work.
Educational information on exposure levels produced during common operations and tasks is found in Appendix B.

Disposal of Lead and Lead-containing Materials

  • A leach test (TCLP) must be performed by the Hygienic Lab to determine if the material may be disposed of as general waste or special waste.  Contact the Hygienic Lab (335-4500) for correct sample collection procedures for TCLP samples. Generally at least 5 ounces of material is needed to perform the test, but parameters may vary with the matrix.  
  • A container up to a drum in size will be used to collect any small amounts of lead-containing solid material for disposal of lead paint chips or other small amounts of lead-containing solid material.  In this manner, only one TCLP test needs to be conducted prior to the disposal of the waste since TCLP tests are expensive.
  • Contact EHS at 335-8501 for assistance in determining the method of waste disposal of the lead waste.

Training

Employees disturbing lead must complete the required lead training for the work they will be doing as described in OSHA regulations 29CFR 1910.1025 and/or 1926.26.  Because these training requirements are complex so personnel from other University departments or contractors that are trained and have experience working with lead containing materials will be used for work that disturbs lead containing materials whenever possible.

Assistance and Resources

  • Contact EHS for questions or assistance on occupational hazards or any lead work in areas where children age 6 or below are present.
  • Contact Environmental Services for questions or assistance related to pre-construction surveys for presence of lead-containing materials, and demolition or renovation contracts involving lead.
  • Appendix B contains educational information on recognizing and reducing lead hazards.  

Appendix

Lead-containing Materials Appendices