Purpose and Scope
Bates College is required to maintain a written Lead Workplace Safety Program for employees who are exposed or potentially exposed to lead hazards in the workplace. This program covers the topics required by the OSHA standard for Lead in Construction, 29CFR Part 1926.62. This plan does not cover Lead in General Industry, which includes standards for industrial processes, not lead paint in construction.
This policy is to help ensure proper management of lead, primarily in the form of lead-based paint in buildings owned by Bates College, and applies to all Bates’ employees and outside contractors who work with or who are responsible for work with lead-based paint or suspected lead-containing materials in Bates buildings. The abatement, renovation, repair work and painting shall not inadvertently contaminate the building and create a lead exposure problem. The Bates EHS Director is responsible for maintaining and implementing this policy.
What is Lead?
Lead is a toxic metal that can lead to a number of serious health problems, especially in children. Most lead poisonings are caused by exposure to dust from old paint. More than half of Maine homes may have lead paint, and lead paint should be suspected to exist in any building built before 1978 which was when lead-based house paint was prohibited.
If lead exposure is found to be in excess of the PEL (Permissible Exposure Limit), a written compliance plan must be developed which documents:
- Lead-emitting activities, equipment, materials, controls, crew size, employee responsibilities, operating and maintenance procedures
- How compliance is achieved
- Reports on technology to meet the PEL
- Air monitoring data
- Implementation schedule
- Work practice program
- Administrative control schedule, and
- Methods to inform employees
Hazards of Lead
Pure lead (Pb) is a basic chemical element and is a heavy metal in normal conditions, but it can combine with various substances to form numerous compounds used commercially (i.e. crystal and batteries). Lead and it’s compounds are toxic, potentially being absorbed through inhalation and ingestion, such as breathing lead dust or eating paint chips. Food, tobacco, and/or make-up could become contaminated in a lead work area .
As lead exposure accumulates in the body, irreversible nervous system damage can occur. Lead is especially dangerous to children under the age of six and to women of childbearing age.
Acute Effects of Overexposure: Lead is a potent, systemic poison, and can kill in a matter of days if taken in large enough doses.
Chronic Effects of Overexposure: Long term overexposure may result in severe damage to blood-forming, nervous, urinary, and reproductive systems.
Bates College is required to protect employees with a Lead Workplace Safety Plan through implementation, maintenance, monitoring of the plan. Specific requirements include:
- Semi-annual Revisions and Updates
- Engineering and Administrative Controls
- Employee Training
- Medical Surveillance
- Respiratory Protection
- Lead Disposal
- Housekeeping, and
- Personal Protective Equipment (PPE)
Supervisors of the lead work will:
- Provide effective and continuous control of all lead operations
- Conduct routine inspections and monitoring
- Immediately inform Management or EHS of any deficiencies
- Immediately correct any deficiencies
- Ensure all affected employees are properly trained
- Provide immediate “spot” training to any employee who exhibits lack of knowledge or application of safety requirements
Employees involved with lead work are required to:
- Follow all operational and lead safety procedures
- Conduct operations in accordance with the required lead training
- Properly use, store, and dispose of issued and assigned PPE
- Maintain cleanliness and organization of change and shower areas
- Immediately report to a Supervisor or EHS any deficiency
- Seed immediate Supervisor guidance to resolve questions
In situations where employees might be exposed to lead, Bates College is required to monitor the lead levels that an employee would encounter in a typical day. A typical day is at least 7 continuous hours representing employees regular work routine for each job classification per shift per work area. Monitoring will be conducted by a trained and certified lead-safet consultant at all times.
If any Faculty, Staff, or Student observes lead in the workplace that could pose a hazard, Bates EHS should be contacted immediately for an assessment.
Lead in the Home
Lead in the home is governed in Maine by the Department of Human Services and the Department of Environmental Protection. Tenants of Bates College have a right to request information regarding lead in the specific property they reside in. If lead hazards are observed or conditions in a Bates owned property warrant concern, contact Bates EHS for an appointment or information regarding your residence.
Where is Lead Paint Found?
Many homes built before 1978 have lead-based paint. The federal government banned lead-based paint from housing in 1978, and some states stopped it’s use even earlier. Lead can be found in:
- Homes: in the city, country, or suburbs
- Apartments, single or multi-story homes, and both private and public housing
- Inside and outside of the house
- Soil: soil can pick up lead from exterior paint or even the past use of leaded cars
In general, the older your home, the more likely it has lead-based paint.
Checking Your Family
To reduce your child’s exposure to lead:
- Get your child checked
- Have your home tested, especially if older or in poor condition
- Fix any hazards
Blood tests are usually recommended for:
- Children before the age of 2
- Children or family members exposed to lead
- Children who should be tested under your state and local plan
Get your home and children tested if you think your home has high levels of lead.
- Lead-based Paint: usually not a hazard if it is in good condition, and it is not on an impact or friction surface, like a window or door.
- Deteriorating Lead-based Paint: if paint is peeling, chipping, chalking, cracking, or damaged, it is a hazard and needs immediate attention.
- Surfaces Accessed by Children: surfaces that children can chew or receive lots of wear-and-tear such as windows and sills, doors and frames, stairs, railings, banisters, and porches.
- Lead Dust: formed when lead-based paint is scraped, sanded, heated, or when painted surfaces rub together. Settled lead dust can re-enter the air when disturbed.
- Lead in Soil: a hazard when children play in bare soil or when people bring soil indoors on their shoes.
Lead from paint chips, which you can see, and lead dust, which you can’t always see, can both be serious hazards. The only way to find out if lead hazards exist is to test for them.
Checking Your Home
- Paint Inspection: tells you if your home has lead-based paint and it’s location.
- Risk Assessment: tells you if your home has any lead hazards and actions to take for abatement
Hire a trained and certified testing professional who will use a range of reliable methods when testing your home. Home test kits are available, but may not be as accurate and should not be relied upon for renovations to assure safety. Reliable methods include visual inspections, portable x-ray machines, and lab tests.
What You Can Do Now
Immediate steps to take if you suspect your house had lead in it:
- If you rent notify your landlord immediately.
- Clean up paint chips immediately.
- Clean horizontal surfaces weekly: window sills, floors, frames, etc.
- Thoroughly rinse sponges and mop heads after cleaning.
- Wash children’s hands often, especially before they eat and sleep.
- Wash toys and keep play areas clean.
- Keep children from chewing painted surfaces.
- Clean and/or remove your shoes before entering to reduce tracking soil into your home.
- Make sure children eat a nutritious, low-fat meals high in iron and calcium.
- Temporary: interim controls such as repairing damaged surfaces, repainting, and planting grass to cover bare soil are not permanent solutions and will need ongoing attention.
- Permanent: abatement methods include removing, sealing, or enclosing lead-based paint with special materials. Repainting a lead-based paint surface with regular paint is not permanent removal.
Removing lead improperly can increase the hazard to your family by spreading even more dust around the house. Certified contractors will employ qualified workers and follow strict safety rules as set by their state or by the federal government.
Remodeling or Renovating a Home
Precautions to take before you or a contractor begin remodeling anything that disturbs painted surfaces:
- Have the area tested for lead-based paint.
- Do not use a belt-sander, propane torch, high temperature heat gun, dry scraper or dry sandpaper to remove lead-based paint.
- Temporarily move your family.
If not conducted properly, certain types of renovations can release lead from paint and dust into the air.