Environmental Health and Safety
Finance & Administration
University of Florida
UFEH&S-OHS-07-2-2003
OBJECTIVE
To ensure employee exposures to lead during construction work are in compliance with the levels specified in 29 CFR 1926.62.
AUTHORITY
29 CFR 1926.62
POLICY
Removal or disruption of lead based paint must be conducted pursuant to approved procedures and requirements of appropriate regulating agencies, and in full compliance with state and federal law.
The disruption of lead containing paints, soldering, and work with molten lead often causes exposure to airborne lead. Exposure of employees at or above the OSHA action level triggers special monitoring and training requirements.
Use of respiratory protection may be required for work that will disturb lead containing paint. Each division conducting activities that disturb lead containing paint shall implement the University respirator program.
Based on past monitoring, blood lead analysis, and other studies, it has been determined that the exposure of University employees performing "typical" maintenance tasks is below the action level. No monitoring or special personal protective equipment (PPE) use is required for employees engaged in typical maintenance work.
Typical refers to routine maintenance tasks, such as the scraping and sanding of lead paint, and pouring of lead seals, that require four hours or less to complete and are performed no more than once per week.
Atypical work includes spray applying a lead based product, using heat to remove a lead containing product, sand blasting, or a grinding and scraping job that last more than one or two days. Employees engaged in atypical work must be trained, monitored, use engineering controls, and wear PPE.
RESPONSIBILITIES
Environmental Health and Safety will provide consultative and technical assistance to campus organizations involved in the removal or disruption of lead based paint.
Environmental Health and Safety will provide limited analytical services for the determination of lead content in paint.
Environmental Health and Safety will serve as the University liaison with regulatory agencies and serve as the clearinghouse for the dissemination of regulatory and University requirements and new information to groups involved in lead based paint removal activities. Department heads are responsible for ensuring that their employees operate in compliance with this program.
Supervisors are responsible for evaluating all work activities as they relate to this policy, and taking necessary steps to ensure their employees work in compliance with this policy.
Project Managers
Managers for projects involving the actual or potential disruption or removal of painted surfaces in a building constructed prior to 1980 shall determine the lead content of the painted surfaces.
PROCEDURES
Where formal monitoring and controls are not required, supervisors should encourage employees to exercise good hygiene when working with materials suspected of containing lead Good hygiene includes: changing or brushing off clothes when work is completed; washing hands before eating; and not eating or smoking in the work area. Using wet techniques or hepa vacuums during scraping, grinding, and clean up of debris will also minimize lead exposure.
Call Environmental Health and Safety for assistance on atypical projects, or for further information.
For small projects (<8 samples) bring paint chip samples to EH&S for analysis. Include the name of the person collecting the samples, building number, sample location, and contact information with an email or facsimile number.