Lead Based Paint Management

Overview

Lead-based Paint (LBP) hazards are regulated by the Environmental Protection Agency (EPA), Occupational Safety and Health Administration (OSHA), and Housing and Urban Development (HUD). The EPA and HUD defines LBPs as those with lead concentrations equal to or greater than 1 milligram per square centimeter (1.0 mg/cm) or 5,000 parts per million (ppm).

Leaded dust and paint chips caused by the disruption of painted surfaces can be harmful to adults, children, and the environment. Environmental Health and Safety can provide consultation, sampling, and further information upon request.

EH&S Lead Information Request

Requirements

  • Presume that buildings built before 1978 contain lead paint, unless there is information that it has been completely removed by a licensed contractor (29 CFR 1926.62).
  • Individuals and contractors performing renovation, repair, or painting on pre-1978 and/or child occupied facilities1 must be trained in lead-safe work practices as required by EPA’s Renovation, Repair, and Painting (RRP) Rule (40 CFR 745).
  • In pre-1978 child occupied facilities1, HUD requires notification, evaluation, and reduction of lead-based paint hazards under the Lead Safe Housing Rule (LSHR). If renovation, repair, or painting creates leaded dust, clearance testing must be performed (24 CFR 35).
  • If lead is known to be present and activities could result in an exposure, air/exposure monitoring may be required. An initial determination, indicating whether work will expose individuals to lead, may be done by working groups, contractors, or EH&S if necessary.

Regulated Activities

Examples of activities regulated by OSHA that must adhere to the above requirements: Disturbing paint on structures built before 1978, demolition and salvage work, removing or encapsulating materials containing lead, renovating structures that contain lead, installing products that contain lead, transporting, storing, disposing of, and the cleanup of products that contain lead.

Resources

EPA - Learn about Lead
Renovation, Repair, and Painting Program
HUD Guidelines for Lead-Based Paint
Lead in Construction

1.  Child occupied facilities are defined as a building, or portion of a building, constructed prior to 1978, visited regularly by the same child, under 6 years of age, on at least two (2) different days within any week (Sunday through Saturday period), provided that each day's visit lasts at least three (3) hours and the combined weekly visits last at least six (6) hours, and the combined annual visits last at least 60 hours.