6.12 CONTROL OF
LEAD HAZARDS DURING CONSTRUCTION AND RENOVATION PROJECTS
Lead was a major ingredient in many types of paint until the late 1940s.
In the early 1950s, other pigment materials became more popular; however,
lead compounds were still used in some pigments and as drying agents.
Federal regulations lowered the permissible lead content in dry paint
film to 0.5% in 1973 and again in 1978 to 0.06%.
Because of the potential for widespread use at UNM, we must expect that
any building constructed earlier than 1980 will contain lead-bearing paints.
A.
SCOPE
This document describes appropriate methods for managing lead hazards associated with renovation or demolition projects. It is intended to be used by those involved with the planning processes of renovation and construction projects and those responsible for oversight during the construction phase. It can be expected that, because of the increasing regulatory activity in this area, these guidelines may require periodic modification. Renovation and construction project designers must contact the Department of Safety and Risk Services (SRS) to ensure adequate and up-to-date information is utilized during the planning process.
B.
REFERENCES
29 CFR 1910.1025, OSHA Lead Standard for General Industry
29 CFR 1926.62, OSHA Lead Standard for Construction
40 CFR Parts 260-272, EPA Hazardous Waste Regulations
24 CFR Part 35, Lead Disclosure
Development
C.
RESPONSIBILITIES
1.
Renovation and construction project planners and managers are accountable
for:
·
ensuring that all requirements of this policy are carried out as applicable to
their specific projects, and
·
coordinating efforts between the Physical Plant Department or the Office of
Capital Projects, the Safety and Risk Services Department (SRS) and the selected
contractor.
2.
The Safety and Risk Services Department
(SRS) is accountable for:
·
advising project planners and managers concerning the lead hazards that may
affect their projects;
·
Utilizing an INNOV-X systems alpha series X-Ray Fluorescence Spectrometer to
measure for potential lead-based paint on selected accessible painted surfaces;
·
hiring consultants to perform surveys to assess the presence and scope of
lead-containing materials, when necessary;
·
hiring abatement contractors to remove lead paint prior to construction or
renovation projects, when necessary;
·
taking bulk samples for laboratory analysis (EPA TCLP analyses) and/or
classifying materials as regulated hazardous waste or as non-regulated
construction debris, if applicable; and
·
acting as a liaison between
D.
IMPLEMENTATION
1.
Inspection
When a renovation or demolition project is identified by any UNM department,
i.e., Office of Capital Projects or Physical Plant Department, a written scope
of work and renovation plans are provided to SRS utilizing the Hazardous
Materials Inspection Request Form (see under “Important Forms” in the Industrial
Hygiene section of the SRS web site).
Once SRS is informed of a project that may involve lead-bearing paints
(LBP), SRS staff will perform or coordinate an inspection of the affected areas,
to provide information that is essential to the project planning process.
Specifically, inspection results will facilitate early decisions about expected
occupational exposures to lead-contaminated dust, the necessity for abatement of
LBP, control measures, and the potential for generation of regulated hazardous
lead-contaminated waste.
Because of the potential impact on the project, it is paramount that inspections
are conducted in such a manner to ensure that resultant information is useful.
Therefore, a sufficient number of measurements or samples must be
obtained (because of
such variables as paint film thickness,
inadequate mixing, number of coats, etc.) to assure accurate classification.
XRF (X-Ray Fluorescence) Sampling. The
SRS INNOV-X Systems alpha series X-Ray Fluorescence Spectrometer is calibrated
to provide results in parts per million of lead by weight. At least five (5)
measurements must be taken of each homogeneous building component with a similar
coating. For large area projects
involving multiple rooms, the following matrix shall be used:
Up to 25 rooms
1 sample of each component in each room
26 - 75 rooms
1 sample of each component in 50% of rooms
76 - 150 rooms
1 sample of each component in 35% of rooms
Bulk Sampling for LBP.
At least two (2) samples must be taken of each building component with similar
coating. If sampling by scraping
paint, the area scraped must be quantified.
The paint within this test area (6.25 square centimeters is recommended)
is scraped down to the substrate and submitted for analysis of lead content (in
ppm) by an accredited laboratory.
Sampling for the EPA’s Toxicity Characteristic Leachate Procedure (TCLP) test.
Representative composite samples of at least 125 grams will be taken of
the materials expected to become construction debris during any renovation
and/or demolition of buildings, and which were determined to exceed 5,000 ppm
during XRF and bulk sampling. These
composite samples are to be submitted for lead analysis by the EPA’s TCLP test
by an accredited laboratory.
2.
Project Planning
Once the inspection is complete, the Safety and Risk Services Department will
present a report of the measurements taken, coupled with specific
recommendations to the project planners within the Physical Plant Department or
Office of Capital Projects. Such
recommendations will address, but not necessarily be limited to the following
areas:
·
Necessity for abatement prior to general construction, renovation and/or
demolition.
·
Types of engineering and administrative controls necessary to protect employees
in potentially affected areas.
·
Management of lead-contaminated waste materials.
3.
Abatement
Abatement will be required whenever TCLP analytical results show lead levels in
the extract at or above 5.0 milligrams per liter by the EPA’s Toxicity
Characteristic Leachate Procedure (TCLP), as these materials are regulated by
the Environmental Protection Agency as hazardous wastes, and cannot be legally
disposed at regular landfills. All
work will be done by a contractor who has been prequalified by SRS, and who is
contractually obligated to comply with all applicable OSHA and EPA regulations.
4.
Notification
The University of New Mexico Project Manager will inform contractors of the
presence of LBP and other lead-containing materials that may affected by the
project. This may be done by
letter with the analytical results attached.
5.
EPA Regulated Lead-Bearing Hazardous Wastes
Construction wastes from lead abatement projects analytical results that show
lead levels at or above 5.0 milligrams per liter in the extract by the EPA’s
Toxicity Characteristic Leachate Procedure (TCLP) test,
are regulated as hazardous wastes under the Resource Conservation and
Recovery Act (RCRA). Because RCRA
regulations demand that UNM retain ownership and concomitant liability for the
wastes until destruction/disposal, it is essential that all such wastes be
managed through the SRS Hazardous Chemical Waste Program (Section 4.07 of the
SRS Manual). If appropriate, SRS
will obtain representative samples of waste materials generated prior to and
during renovation and demolition projects for analysis.
If analytical results show lead levels at or above 5.0 milligrams per
liter by the EPA’s Toxicity Characteristic Leachate Procedure (TCLP) test, all
such wastes will regulated as EPA hazardous waste.