Policy: Lead-Based Paints Management
|Date: 06/30/05||Policy ID: SEC-008||Status: Final|
|Contact Office:||Environmental Health and Safety|
|Oversight Executive:||Vice President for Research|
|Applies To:||Academic Division and the Medical Center.|
|Table of Contents:|
|Reason for Policy:||To prevent harmful exposure to lead and to ensure compliance with all local, state and federal regulations, including OSHA 29 CFR 1926.62, OSHA 29 CFR 1910.1025, EPA 40 CFR 260-270, the Virginia Administrative Code and the Virginia Department of Professional and Occupational Regulation.|
|Policy Summary:||All Lead-Based Paints within University buildings must be properly managed.|
|Definition of Terms in Statement:||
LBP Inspection: Inspection of a building, portion of a building or other painted surfaces by a State Licensed LBP Inspector/Risk Assessor, which includes taking paint chip samples of suspected LBP for analysis by an accredited laboratory, or analyzing the painted surface on-site by use of an XRF meter, and a report summarizing the lead concentrations and locations of identified LBP.
LBP Risk Assessment: An assessment performed by a State Licensed LBP Inspector/Risk Assessor of the condition of LBP and the relative hazard potential resulting from its presence. This assessment includes a combination of visual inspection of painted surfaces, settled dust testing, soil testing and a report detailing the results and plans for proper in-place management to insure the safety of building residents, occupants, visitors and maintenance/custodial personnel, until such paints are properly removed.
LBP Abatement Activity: The total removal of LBP or LBP hazard from a UVA residential property by a State Licensed LBP Abatement Contractor with Licensed Abatement Workers and Supervisors using methods specified by a State Licensed LBP Abatement Project Designer.
LBP Abatement Activity Monitoring: Daily inspections of lead abatement activities, which include confirming integrity of work site enclosures, abatement equipment, worker credentials, regulatory and specifications compliance, and taking air and settled dust samples during and after abatement to insure a healthy environment for UVA housing residents.
LBP Management Activity: Any activity that involves the incidental disturbance of LBP, including repair, surface preparation or repainting of surfaces that contain LBP, or the removal/disturbance of building components containing LBP. This does not require State-Licensed Contractors, Workers or Supervisors, but does require OSHA and EPA compliance.
Project Manager: UVA representative who may be the Facilities Management Project Manager, Maintenance Superintendent, Cost Center Manager or other person who either oversees, plans, supervises or arranges for a maintenance, construction, renovations or demolition project within University facilities.
All LBP within University buildings must be properly managed. Any University building or architectural component built prior to 1978 may have high concentrations of lead in the paints. All such painted surfaces must be presumed to contain lead at regulated concentrations until properly tested and proven otherwise.
Environmental Health & Safety (EHS) maintains records of all past LBP inspections within University buildings and miscellaneous components, and all past residential LBP abatement activities. EHS provides lead awareness training to maintenance and renovations employees to inform them of the health hazards of LBP, proper procedures for safely working with materials containing LBP, use of personal protective equipment, engineering controls, and clean-up and disposal of LBP debris.
To prevent accidental disturbance of LBP, which could lead to air-borne or settled lead dust hazards, EHS performs inspections prior to maintenance, repainting, renovations or demolition projects to determine the concentrations of lead in paints. Disturbance of surfaces with regulated concentrations of LBP must either be avoided during the projects or properly controlled during these projects. If LBP hazards abatement is necessary, EHS designs and monitors these activities.
|Related Information:||Controlling Hazardous Air Contaminants and Respiratory Protection|
|Major Category:||Safety, Security and Environmental Quality|
|Category Cross Reference:|
|Next Scheduled Review:||06/30/14|
|Approved By, Date:||Policy Review Committee, 06/30/05|
|Revision History:||Updated 7/18/11.|
|Supersedes (previous policy):||Lead-based Paints Management XIV.N.1|