Lead-Safe Schools Guide

Transcription

1 Lead-Safe Schools Guide Lead-Safe Schools Project Labor Occupational Health Program University of California at Berkeley

2 Copyright 2000, Labor Occupational Health Program The Lead-Safe Schools Guide was developed under a grant to the Labor Occupational Health Program (LOHP) at the University of California, Berkeley by the Childhood Lead Poisoning Prevention Program, California Department of Health Services (DHS). The Lead-Safe Schools Project is a joint effort of U.C. Berkeley s Labor Occupational Health Program, the Childhood Lead Poisoning Prevention Branch of the California Department of Health Services, and the California Department of Education. Labor Occupational Health Program University of California 2223 Fulton Street Berkeley, CA Printed by Office of State Printing, Sacramento, CA.

3 Lead-Safe Schools Guide For Maintenance and Operations Departments

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5 Acknowledgments Writers Robin Dewey, MPH Gail Bateson, MS Michele González Arroyo, MPH Barbara A. Plog, MPH, CIH, CSP Leonor Dionne, MS Project Coordinator Michele González Arroyo, MPH Technical Coordinator Barbara A. Plog, MPH, CIH, CSP Editing, Design, and Production Gene Darling Kate Oliver Illustrator Mary Ann Zapalac Project Assistant Carmen Foghorn Donna Iverson LOHP Director Robin Baker, MPH iii

6 Contributors and Reviewers Organizations LOHP is indebted to the following organizations for their contributions to this Guide: California Department of Education (CDE) California School Employees Association (CSEA) Childhood Lead Poisoning Prevention Branch (CLPPB), California Department of Health Services Occupational Lead Poisoning Prevention Program (OLPPP), California Department of Health Services Technical Reviewer Stephen C. Davis, MPH, CIH, CSP Health Science Associates Emeryville, CA Individual Contributors and Reviewers Ellen Aasletten Planning Department, California Department of Education Doug Adams San Diego Unified School District Mark Allen Alameda County Lead Poisoning Prevention Program Lynn Anderson Department of Social Services, Community Care Licensing Division Amy Arcus Office of Environmental Health Hazard Assessment (OEHHA), DHS Don Benning Sacramento Unified School District Rachel Broadwin Office of Environmental Health Hazard Assessment (OEHHA), DHS Duwayne Brooks School Facilities Planning Division, California Department of Education Simone Brumis Occupational Lead Poisoning Prevention Program, DHS iv

7 Zin Cheung Education and Training Unit, Cal/OSHA Consultation Kimberly Comet North Coast Schools Insurance Group Susan Cummins Childhood Lead Poisoning Prevention Branch, DHS Lyn Dailey California Childcare Health Project George Datz California School Employees Association Jill Garellick Childhood Lead Poisoning Prevention Branch, DHS Bruce Gianini Asbestos Control, San Francisco Unified School District David Harrington Occupational Lead Poisoning Prevention Program, DHS Richard Henry Maintenance and Operations, Los Angeles Unified School District John Huls Maintenance and Operations, San Juan Unified School District Catherine Wilson Jones Self Insured Schools of California Larrie Lance Childhood Lead Poisoning Prevention Branch, DHS Don Lanier U.S. Environmental Protection Agency Eleanor Long Los Angeles Lead Poisoning Prevention Program Barbara Materna Occupational Lead Poisoning Prevention Program, DHS Scott McAllister Cal/OSHA, Department of Industrial Relations Jon Merkel U.S. Environmental Protection Agency Rhonda Bacot-Milan Hayward Unified School District Dana Polk Childhood Lead Poisoning Prevention Branch, DHS Gary Pons Los Angeles Unified School District Dan Scannell Childhood Lead Poisoning Prevention Branch, DHS M.A. Stevenson Public Utilities Commission, City and County of San Francisco Mona Thabit San Diego County Health Department Lead Program Mike Zurich California Association of School Business Officials v

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9 Contents Chapter 1 About This Guide... 1 Chapter 2 Health Effects of Lead... 9 Chapter 3 Elements of a Lead Program Chapter 4 Identify Lead in Schools Chapter 5 Analyze Maintenance Tasks Chapter 6 Provide Worker Protection Chapter 7 Use Safe Work Practices Chapter 8 Train Workers Chapter 9 Document and Evaluate the Program Forms Program Planning Form District Target Schools Form Building Inventory Form Paint & Soil Hazards Appendices A. California DHS Report Executive Summary B. Lead in Construction Standard Summary C. Hazard Communication Standard Summary D. Injury and Illness Prevention Program Summary E. Lead-Safe Schools Protection Act F. Title 17 Summary G. Contractor Requirements H. Guidelines for Volunteers I. Resources for More Information J. Glossary of Terms vii

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11 CHAPTER 1 ABOUT THIS GUIDE CHAPTER 1 About This Guide What Is a Lead-Safe Schools Program? It has been known for a long time that children get exposed to lead at home. Could they also get exposed at school? A study published by the California Department of Health Services (DHS) in 1998 found lead in most public elementary schools in the state. Nearly 96% of schools even some newer ones have detectable levels of lead in the paint. The study also found lead in the drinking water at some schools, and in the soil around older school buildings. (See Appendix A for a summary of the DHS study.) The results of the DHS study prompted a statewide effort to provide school districts with the information and training they need to address lead problems. The Lead-Safe Schools Project was begun in late This joint effort of several state agencies and the University of California at Berkeley will help school districts to initiate or strengthen their own lead-safe schools programs. Such programs set clear policies, procedures, and action plans for all lead work in schools. This Lead-Safe Schools Guide is a tool that California school districts can use to create a safer school environment. It focuses on custodial and maintenance work in schools. This type of work, if done unsafely, can expose both children and workers to significant amounts of lead. The Guide is intended primarily for staff in California public elementary schools and childcare facilities (such as daycare centers associated with schools and daycare programs for teen parents). The theme of this Guide is that, with proper resources and training, lead hazards can be managed and controlled safely as part of standard school 1

12 LEAD-SAFE SCHOOLS maintenance practices. Controlling lead hazards is usually a safer alternative than the complete removal of lead. The measures outlined here will go a long way toward making our schools safer. Systematic policies and procedures for lead work are also cost-effective. For example, school districts can wind up spending more than expected for renovation and maintenance work if it is done in an unsafe manner or with untrained personnel. Unsafe practices can create new problems that have to be corrected later at great expense, and can potentially result in costly legal difficulties for the school district as well. Consider this recent news story about a California school: Planning Could Have Saved School District $45,000 In 1998, a California school district planned a major renovation of one of their older elementary schools. Several contractors were brought in. Many of them were experienced in lead work. They and their employees had received lead training and were state-certified. In preparation for repainting, a school district maintenance crew water-blasted the outside of the school. There had been no testing of paint samples for lead. Paint chips fell to the ground, and were blown around by the wind. The contractors reported the water blasting to government agencies, which led to site inspections by Cal/OSHA and several other agencies. It was found that the paint chips did contain lead. The district was required to clean the entire school complex with special HEPA vacuum cleaners inside and out. They also had to notify all neighbors within a two-block radius of the school about their potential lead exposure. Unofficial estimates of the clean-up costs included: $15,000 in labor costs for the 10 days it took to vacuum around the school, $20,000 in lost wages to the contractors who couldn t work during the clean-up, and about $10,000 for air sampling and other testing. Could the school have avoided the new problems that were created? Unfortunately, situations like this come up again and again for schools. Adopting lead-safe policies and procedures and putting them in writing ensures that work involving lead will be handled safely and consistently. 2

13 CHAPTER 1 ABOUT THIS GUIDE This Guide gives advice on controlling lead hazards in paint, water, and soil while doing routine day-to-day maintenance and custodial work. It does not cover lead abatement, demolition, renovation, or activities involving complete paint removal, which should always be done by highly trained workers and supervisors who are state-certified in lead-related construction. However, it does provide specific guidelines on when and how to use statecertified lead workers and contractors. Why Worry About Lead? Lead is highly toxic to the human body. At one time, before its hazards were fully understood, lead was widely used throughout society in many industrial and consumer products. Today, it can still be found in some paints, solders, construction materials, pipes, plumbing fixtures, batteries, and even dishes and hobby supplies. Over time, lead from such products and from manufacturing processes has contaminated air, water, soil, and food. Although recent legislation has eliminated lead in gasoline and greatly reduced it in manufactured products, widespread contamination of the environment by lead continues to be a problem. Lead can cause serious health effects at any age, but it is especially dangerous for children eight and under. Lead poisoning is the most common environmental health problem affecting young children. It can permanently damage the brain and nervous system, slow growth, and cause learning and behavior problems. But lead poisoning is preventable. Lead hazards (such as deteriorating or damaged lead paint, contaminated soil, or contaminated water) can be controlled, both in the home and the school. For schools, this Lead-Safe Schools Guide is an important first step. Who Can Use This Guide? The Guide is primarily intended for California school district Maintenance and Operations (M&O) departments. These departments, known by various names in different school districts, typically include both custodial and maintenance personnel. School superintendents, principals, and other administrators also play a key role in creating lead-safe schools and can benefit from the Guide. In some cases, they may directly supervise custodial and maintenance workers. They also provide a link to all other members of the school community. 3

14 LEAD-SAFE SCHOOLS There is an increasingly aware population of parents, teachers, school staff, administrators, and school board members who are concerned about lead and other environmental matters. Informing and educating them can address unwarranted fears as well as help ensure safe work practices. In these times of limited resources, parents, teachers, and others may want to help by taking on volunteer maintenance projects. There are numerous stories about parents clubs repainting buildings or playground equipment without being aware of the potential lead hazards they may create. For example, consider this recent news story: Parent Attempt To Help School Backfires Staff from one small California school district vow they will never again allow parent volunteers to help with jobs that disturb lead paint. A father, believing he was helping the school, chipped off loose paint from an outdoor play structure at the school to prepare it for repainting. The paint contained lead. All of the sand near the structure had to be removed and replaced. The sand had not been protected from the falling lead paint chips as required by law. Proper disposal and replacement of the contaminated sand cost the school district $6,000. Administrators can use the material in this Guide to build awareness of the hazards involved in painting and other maintenance work. It should be noted that following lead-safe work practices will probably involve an investment of money for equipment and materials, and an investment of time. The entire school community needs to be aware that following recommended procedures for controlling lead may mean that maintenance jobs take longer. But the investment of time is worthwhile. The recommendations here can help schools protect children and staff from serious health damage. Why Follow These Recommendations? The recommendations in this Guide will help protect the health of children, workers, and families. It s also the law. California schools are required to use lead-safe practices under several laws and regulations (both state and federal). 4

15 CHAPTER 1 ABOUT THIS GUIDE These regulations include: Lead-Safe Schools Protection Act (LSSPA) of [California Education Code. Sections ] Requires California public elementary schools and childcare facilities to use state-certified construction personnel when abating lead hazards. Also forbids the use of lead-based paint, lead plumbing and solders, or other potential sources of lead contamination in new school construction and in school modernization or renovation projects. Accreditation, Certification, and Work Practices for Lead-Based Paint and Lead Hazards. [Title 17, California Code of Regulations, Section et. seq.] This is the key state regulation for lead work. Defines lead hazard as deteriorated lead-based paint, lead contaminated dust, lead contaminated soil, disturbing lead-based paint or presumed lead-based paint without containment, or any other nuisance which may result in persistent and quantifiable lead exposure. Requires accreditation of training providers by California DHS. Requires training in accredited programs and subsequent certification by DHS of workers who perform abatement and other high risk lead-related construction work such as any alteration, painting, demolition, salvage, renovation, repair, maintenance, preparation, and cleanup that may result in significant exposure of adults or children to lead. There are five categories of certification with different training and experience requirements: Lead Worker, Lead Supervisor, Lead Project Monitor, Lead Project Designer, and Lead Inspector/Assessor. Sets out requirements for all lead abatement work in public buildings and residential buildings. Defines lead abatement as any set of measures designed to reduce or eliminate lead hazards or lead-based paint in these buildings. (However, this does not include containment or cleaning.) Requires state-certified workers and supervisors for abatement work which is designed to reduce lead paint or other lead hazards for a minimum of 20 years. Requires other measures as well. For abatement designed to reduce lead paint hazards for less than 20 years, Title 17 has a list of requirements including specific work procedures that follow Chapter 11, Interim Controls, of the U.S. Housing and Urban Development (HUD) Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing, June Cal/OSHA Lead in Construction Standard. [Title 8, California Code of Regulations, Section ] Requires safe practices in all construction and maintenance work where an employee may be exposed to lead. California school employees are included. Activities covered include alteration, repair, and even painting of buildings. 5

16 LEAD-SAFE SCHOOLS 6 Sets requirements related to permissible level of worker exposure, exposure assessment, work practices, personal protective equipment including respirators, medical surveillance programs (including blood testing), housekeeping, hygiene facilities and practices, signs, and recordkeeping. Also defines a set of trigger tasks which are assumed to incur lead exposure over the legal limit and require respiratory and other protection until an actual exposure assessment is done. Also sets out requirements for medical removal protection, where an employee is removed from lead work and given alternate work, or paid leave and benefits, until medically released for return to lead work. Federal Lead Contamination Control Act of [Title 42, United States Code, Section 300j-21] An amendment to the federal Safe Drinking Water Act of It prohibits lead-lined water coolers in schools and childcare facilities, and requires the U.S. Environmental Protection Agency (EPA) to set up an information program to help local school districts identify and eliminate lead contamination in drinking water. Cal/OSHA Injury and Illness Prevention Program Standard. [Title 8, California Code of Regulations, Sections 1509 and 3203] Requires California employers to have a written program that outlines how they plan to assess hazards, correct them, and communicate information to workers. This Injury and Illness Prevention Program (IIPP) must cover hazards at each specific worksite, including lead. Cal/OSHA Hazard Communication Standard. [Title 8, California Code of Regulations, Section 5194] Requires California employers to inform workers about the hazards that may be present in the workplace, including lead. Requires employers to keep Material Safety Data Sheets (MSDSs) on hazardous substances and make them available to workers. Also, employers must provide training about work hazards, safe work practices, and protective measures. Federal Toxic Substances Control Act (TSCA) of [Title 15, United States Code, Section 2601 et seq.] Regulates all chemicals imported or produced in the U.S. Requires testing of commercial chemicals for toxic effects and regulates use and cleanup. Title IV of TSCA covers lead paint hazards. Enforced by EPA, sometimes in conjunction with other agencies such as U.S. Department of Housing and Urban Development (HUD). Enforced in California by Cal/EPA. Summaries of certain laws and regulations above appear in Appendices B F. For the full text of laws above, check the website For Cal/OSHA standards go to Click on Occupational Safety & Health and go to Title 8 Regulations. For EPA regulations and related information, go to

17 CHAPTER 2 HEALTH EFFECTS OF LEAD Failure to comply with these various requirements can raise legal and liability issues for a school district. But, much more importantly, following the law provides an opportunity to protect school children and employees from lead poisoning. We can hope that children are not exposed to lead at home, but we want to make sure they are not exposed at school. How Can the Lead-Safe Schools Project Help? The Lead-Safe Schools Project was set up to help California school districts minimize exposure of children and staff to lead in the school environment. It is a joint effort of the Labor Occupational Health Program at the University of California, Berkeley; the Childhood Lead Poisoning Prevention Branch of the California Department of Health Services; and the California Department of Education. The Project has developed recommendations for many aspects of a lead-safe schools program, including hazard surveys, custodial and maintenance work practices, training, recordkeeping, and other issues. These recommendations appear throughout this Guide and are consistent with legal requirements. In addition to the Guide, the Project also has a training curriculum and videotape to teach school custodians and maintenance staff about lead-safe work practices. Training on how to present these materials to staff will be offered to representatives from each California school district, beginning in the fall of The Lead-Safe Schools Project also has a technical hotline. School district staff can call with questions about material in this Guide and related issues. For more information about the Project, to reach the technical hotline, or to obtain a copy of the curriculum, call U.C. Berkeley s Labor Occupational Health Program at (510) The curriculum is also available from the Childhood Lead Poisoning Prevention Branch of the California Department of Health Services. Check the website 7

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19 CHAPTER 2 HEALTH EFFECTS OF LEAD CHAPTER 2 Health Effects of Lead Who Is at Risk from Lead Hazards? Lead can harm people of any age, but it is especially hazardous for children eight and under. Young children are at a higher risk because: They often put their hands and other objects into their mouths, and can easily swallow any lead dust that is present. Their growing bodies absorb more lead than older children and adults. For example, young children absorb up to 50% of the lead they swallow, while adults typically absorb only about 10%. A developing child s brain and nervous system are particularly sensitive to the effects of lead. The U.S. Centers for Disease Control and Prevention (CDC) found that approximately 900,000 U.S. children between 1 and 5 years old have abnormally high levels of lead in their blood. In California approximately 239,000 children have lead levels high enough to put them at risk of health damage, according to the Department of Health Services (DHS) study summarized in Appendix A. Lead can also be hazardous for adults. Workers who are exposed to high amounts of lead on the job can face serious health damage. Men and women who are planning to have children, and pregnant women, are especially at risk. 9

20 LEAD-SAFE SCHOOLS How Does Lead Get Into the Body? Lead can get into the body by breathing (inhaling) or swallowing (ingesting) dust, particles, or paint chips that contain lead. These may be on surfaces or in air, water, or soil. Note that lead dust can be invisible. It may be present in dangerous amounts even if it is not seen by the naked eye. Food, drink, and cigarettes can become contaminated if they are stored or consumed in an area with lead dust. Lead may also be found in vegetables grown in lead-contaminated soil. Once lead enters the body it gets into the bloodstream. It then circulates throughout the body. The body can eliminate some of it through the kidneys. But some lead is stored in the body, mostly in the bones where it can build up and stay for years. Many parts of the body can be damaged by lead. The more lead in the body, the more likely it is that damage will occur. How Can Children Be Exposed to Lead? Children are most often exposed to lead if they: Swallow lead dust that is on their hands or other surfaces. Swallow lead paint chips. Chew on surfaces with lead paint. Drink water that contains lead. Play in soil that is contaminated with lead. Breathe lead dust created when lead paint is disturbed. 10

21 CHAPTER 2 HEALTH EFFECTS OF LEAD How Can School Employees Be Exposed to Lead? Workers can be exposed to lead if they: Breathe lead dust or fumes created during possibly unsafe work activities, such as: UNSAFE! Sanding paint Scraping paint Grinding paint Carpentry Renovation work Welding Demolition work Soldering Cleanup work. Swallow lead dust that may be on hands, food, drink, or cigarettes. Drink water that contains lead. Are Workers Families at Risk? Yes. Workers can be a source of exposure to their families. They may take lead dust with them if they wear work clothes or shoes home. Lead dust can get into the car, furniture, and carpets. It may then be spread throughout the home, endangering everyone. 11

22 LEAD-SAFE SCHOOLS What Health Problems Can Lead Cause in Children? Lead is a poison that affects virtually every system in the body. Even exposure to low levels of lead can permanently affect children. The damage can occur soon after exposure, or many years later. Lead is particularly harmful to a young child s developing brain and nervous system. Lead exposure may result in: Learning disabilities Attention Deficit Disorder Decreased intelligence Speech and language problems Behavior problems. In addition, lead can: Slow physical growth Cause hearing problems Damage the kidneys. While low-level exposure is most common, exposure to high levels of lead can have devastating effects on children, including seizures, unconsciousness, and, in some cases, death. What Are the Early Signs of Lead Poisoning in Children? Many lead-poisoned children show no symptoms at all. The only sure way to know if a child has lead poisoning is to get a blood test. (There is more information on blood testing later in this chapter.) When symptoms do occur, they are often the same as those of common illnesses like a cold or the flu. Other early signs and symptoms of lead poisoning in children can include: Persistent tiredness or hyperactivity Irritability Loss of appetite Weight loss Reduced attention span Difficulty sleeping Constipation. 12

23 CHAPTER 2 HEALTH EFFECTS OF LEAD What Problems Can High Lead Levels Cause in Adults? Brain and Nervous System Permanent brain damage can occur. This may affect the ability to think and cause personality changes. Heart and Blood Kidneys Lead can cause anemia, which may make one feel weak and tired. Lead can also cause high blood pressure. Permanent damage can occur. Kidneys may be seriously damaged before any obvious symptoms appear, and before tests show anything abnormal. Digestive System Lead can cause nausea, constipation, diarrhea, cramps, lack of appetite, pain in the stomach or abdomen, and weight loss. Reproductive System Lead can damage the reproductive systems of both men and women. It may decrease sex drive, reduce the ability to have children, and increase the risk of miscarriage, stillbirth, and birth defects. Bones Lead can be stored in the bones for many years without causing symptoms. It is gradually released back into the bloodstream and can cause damage. Pregnancy, lactation, stress, and certain illnesses can increase this release. 13

24 LEAD-SAFE SCHOOLS Why Is Lead Hazardous for Pregnant Women? Pregnant women are especially sensitive to the damage lead can cause because: Lead can easily cross the placenta and harm the developing fetus. During pregnancy, any lead stored in the bones is more likely to be released into the blood. When pregnant women are exposed to high levels of lead their infants may: Weigh less at birth. Die more often in the first year of life. Have developmental problems. How Is Lead in the Body Measured? Blood Lead Level (BLL) and Zinc Protoporphyrin (ZPP) tests are used to measure how much lead has entered the body. Both of these blood tests can be done from the same blood sample. The results of the BLL and ZPP tests are reported in micrograms of lead per deciliter of blood (µg/dl). A microgram of lead is roughly the weight of one tiny piece of dollar bill, if the bill is torn into a million equal pieces. A deciliter of blood is about seven tablespoons. The BLL Test. Measures the amount of lead circulating in a person s blood. It gives an estimate of recent lead exposure, or of lead recently released from the bones. The BLL test cannot measure past lead exposure, the amount of lead stored in the body, or the effect lead is having on the body. The typical BLL for adults with no specific lead exposure is less than 3 µg/dl. 14

25 CHAPTER 2 HEALTH EFFECTS OF LEAD The ZPP Test. Measures a particular protein in the blood. It does not measure the amount of lead in the blood. The results estimate exposure to lead over the past three or four months. A rise in ZPP usually lags behind a rise in BLL by two to six weeks. Therefore a person with a normal ZPP but an elevated BLL has probably had very recent exposure to lead. The typical ZPP for adults with no specific lead exposure is 50 µg/dl or less. Is There Any BLL That Is Safe? No. There is no level that has been proven safe, either for children or for adults. Lead does not belong in our bodies at all. Most people, including children, are free of symptoms at BLL levels of 10 µg/dl or less. Both CDC and the California Department of Health Services consider any BLL above 10 µg/dl to be unsafe for children and for pregnant or nursing women. What Can Be Done About High Blood Lead Levels? Children. Action taken by health professionals depends on the child s specific BLL. It can include: An environmental investigation to determine possible sources of the child s lead exposure. Measures to reduce the lead hazards causing exposure. Family education about preventing future contact with lead. Medical treatment, such as chelation, if indicated. The home is usually the primary source of childhood lead poisoning. If a child has an elevated BLL, the home is the most likely suspect, but the school or childcare environment could also be involved. Adults. Many adults with high BLLs have been exposed to lead on the job. The best corrective action is to eliminate this job exposure. For example, the Cal/OSHA Lead in Construction standard says that workers whose BLLs are at or above 50 µg/dl (on two consecutive tests) as a result of their jobs must be removed from all lead exposure at or above the Action Level. Workers must also be removed from such exposure at any time if ordered by a doctor. They do not lose pay or benefits. This is called medical removal protection. The worker must be assigned to another job where exposure is lower than the Action Level, if one is available. For more on medical removal protection, see Chapter 6. 15

26 LEAD-SAFE SCHOOLS The Cal/OSHA standard (see Appendix B for a summary) also requires a number of other measures to monitor and lower workers lead exposure and BLLs. For workers whose BLLs are at or above 40 µg/dl, it provides for medical exams, medical treatment when necessary, and regular blood testing. For more information on medical monitoring requirements, see Chapter 6. Can Good Nutrition Help Prevent Lead Poisoning in Children? Yes. Good food can lessen the effects of exposure to lead. Although schools have limited control over children s diets, they should encourage students to eat well and should communicate with parents about good nutrition. Health professionals recommend that children: Eat at least three meals a day. Less lead is absorbed when children have food in their systems. Eat foods high in calcium, like dairy products. When a child does not have enough calcium in his or her body, the body mistakes lead for calcium. Eat foods high in iron, like meat, chicken, beans, and raisins. Most breads and cereals also have iron since they have been fortified. If children get enough iron, they won t absorb as much lead. Avoid fried and fatty foods. These foods allow the body to absorb lead faster. Wash their hands before they eat. Lead can be found in dust and soil in and around schools. While lead cannot be absorbed through the skin, it can be swallowed. What Is Chelation? Chelation therapy is the primary medical treatment for severe lead poisoning in both adults and children. It can be a painful and risky treatment. Chelating drugs attach themselves to lead in the body and are then filtered out through the kidneys into the urine. Some chelating drugs are injected and others can be taken orally. Chelation should only be done on a case by case basis, always under the care of a physician who is knowledgeable and experienced in the management of lead poisoning. 16

27 CHAPTER 2 HEALTH EFFECTS OF LEAD Cal/OSHA strictly forbids the practice called prophylactic chelation. This is when workers who are being exposed to lead on the job are routinely given chelating drugs to keep their lead levels down. This practice is dangerous as well as illegal. The best and safest therapy for lead poisoning is to stop the exposure to lead. 17

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29 CHAPTER 3 ELEMENTS OF A LEAD PROGRAM CHAPTER 3 Elements of a Lead Program Why Do You Need a Lead-Safe Schools Program? It is essential to develop a comprehensive written lead-safe schools program for your district. A clear set of policies and procedures addressing lead hazards can help you: Protect children and employees from lead poisoning. Respond to the concerns of parents, teachers, school board members, and others in the school community. Comply with the law. As explained in Chapter 1, several state and federal laws require school districts to control lead. Avoid unnecessary costs. By knowing how much lead is present and the extent of the lead hazards, a school district can determine the most cost effective way to deal with the problem. Remember that unsafe practices can create new problems that have to be corrected later at great expense. What s Needed To Develop a Program? Manager. Someone in your school district should be designated to oversee the lead-safe schools program. This program manager should be given sufficient authority and resources to do the job effectively. The manager should be a person familiar with the Maintenance and Operations department s existing policies and procedures, particularly those related to 19

30 LEAD-SAFE SCHOOLS health and safety. Knowledge of lead regulations is essential. It is recommended that the manager have training from a state-accredited lead training program and be DHS-certified at least at the Lead Supervisor level. Knowledge of Cal/OSHA regulations such as the Lead in Construction, Hazard Communication, and Injury and Illness Prevention Program standards is also important. The role of the program manager is to design, implement, and document your lead-safe schools program. The remainder of this Guide outlines the process step by step. Documentation. To keep track of your program s decisions, policies, and procedures, consider compiling a file or binder devoted to lead issues. Also use this file for the various types of documentation discussed in the sections below. Sample forms that can be used for some of this documentation appear in the Forms section at the end of the Guide. Ultimately this material can be developed into a formal written lead program. What Are the Elements of a Program? Lead should be dealt with the same way as any other health and safety problem: identify, evaluate and control the hazard, and then document what you did. The basic elements of a lead-safe schools program are: 1. Identify Lead in Schools. 2. Analyze Maintenance Tasks. 3. Provide Worker Protection. 4. Use Safe Work Practices. 5. Train Workers. 6. Document and Evaluate the Program. The elements are briefly described in this chapter, and are explained in more detail throughout the rest of this Guide. 20

31 CHAPTER 3 ELEMENTS OF A LEAD PROGRAM 1. Identify Lead in Schools. Collect and Review District Records. Existing records can give a first indication of which school sites are most likely to have lead hazards. Make a list of target schools those with children eight and under that were built before January 1, Then check the painting history, dates of plumbing work, and previous air, soil, and water sampling records if any. It is also useful to collect school site maps and photos if available. Survey Paint and Soil at Target Schools. Paint and soil should be visually inspected for lead hazards at all target schools. Visual inspections may be done by M&O personnel with at least general lead awareness training, but must always be supervised by the Lead-Safe Schools Program Manager or a state-certified Lead Inspector/Assessor. Repeat these surveys every few years or after any major damage. By law, a lead hazard is defined as deteriorated lead-based paint, lead contaminated dust, lead contaminated soil, disturbing lead-based paint or presumed lead-based paint without containment, or any other nuisance that may result in persistent and quantifiable lead exposure. Survey forms can be used to document what paint and soil problems were found. There are sample forms in the Forms section at the end of this Guide. Test Paint and Soil Where Appropriate. The only way to know for sure if there is lead in paint is to test it. However, Title 17 of the California Code of Regulations says that all paint at schools built before January 1, 1993 is presumed lead-based paint. An alternative to testing is to assume that paint contains lead and always use lead-safe work practices. Soil near buildings built before 1940 should be tested if it is accessible to children. If testing isn t feasible, and children use the area, cover the soil or deny access to the area. Test Water at All Schools. Drinking water should be tested for lead if records do not indicate previous testing. New tests should be done after plumbing renovations. During the site survey of paint and soil, ask school maintenance staff about sources of drinking water and any recent plumbing work. Set Priorities for Hazard Control. Determine how and when you plan to work on the most serious lead problems. Give them priority on the maintenance schedule where possible. Adjust your department workplan and policies accordingly. Also decide which lead control jobs can be done by district staff and which may require state-certified contractors. For more on identifying lead in schools, see Chapter 4. 21

32 LEAD-SAFE SCHOOLS Analyze Maintenance Tasks. Evaluate Tasks for High Risk and Lower Risk Exposure. Analyze maintenance tasks done throughout the school district and categorize them as either high risk or lower risk. These categories will help you select workers for each task, give them the right training, and put appropriate work practices in place. Both routine tasks and those specifically designed to reduce lead hazards should be reviewed this way. The district should evaluate pending maintenance requests to see if they could disturb lead paint. Current work practices might create lead hazards. Certain work may need to be postponed until your lead-safe schools program is in place. For more on analyzing maintenance tasks, see Chapter Provide Worker Protection. 4. Use Safe Work Practices. Choose Appropriate Protection for Workers. Required protective clothing and equipment varies according to a worker s expected lead exposure level. For lower risk tasks, only coveralls may be necessary. For high risk tasks, workers may have to wear respirators. The employer must supply whatever clothing and equipment are required. You need a system for purchasing, distributing, and maintaining this equipment, and you must train workers in how to use it. For more on protective equipment, see Chapter 6. Establish Procedures for Working Safely. Your written lead program should describe in detail the lead-safe work practices and procedures that must be followed for various types of maintenance work. Procedures should be spelled out for all aspects of the job initial personal air sampling, setup, doing the work, cleanup, disposing of waste, and quality assurance. It is critical to clean up properly after working and never to leave the work unattended. Depending on the level of lead exposure, you may also need policies on medical testing of workers. Obtain Necessary Supplies. You should have a system for purchase of necessary equipment and supplies before beginning any job that may disturb lead. These include caution tape, plastic sheeting, and warning signs. Sometimes special power tools are needed. Provide handwashing facilities, and lunch areas separate from work areas, for workers who may have lead exposure. For more on safe work practices, see Chapter 7.

33 CHAPTER 3 ELEMENTS OF A LEAD PROGRAM 5. Train Workers. Design and Conduct Worker Training. All workers, including custodians, should be given a basic awareness level of lead training if they work around lead. If district maintenance staff will do either routine maintenance work involving lead, or specific lead control work, you need a more advanced training program. Design appropriate training (or locate outside sources of training) and schedule staff to attend. Keep a record of dates when individuals were trained. Some workers may need to obtain DHSaccredited training and DHS Lead Worker certification. Require all contractors doing work that involves lead exposure to provide proof of DHS-accredited training and DHS certification for leadrelated construction. Evaluate Job Duties. New job duties may raise certain personnel issues. Some tasks once done by custodial or maintenance staff may now require special training. Whether current staff are retrained or other specially trained staff are used, it may be necessary to revise job descriptions. Educate Parents and Teachers. Alert and educate parents, teachers, and others about the hazards of lead. City and county lead poisoning prevention programs can be a source of educational materials and other resources. (See Appendix I.) Parent volunteers and other untrained individuals are not qualified to do any work involving possible lead exposure. Establish a policy that strictly prohibits such activity. For more on training, see Chapter Document and Evaluate the Program. Document Program Activities and Maintain Records. Develop a system to keep track of all the information your program generates and decisions you make. Some state and federal regulations have specific recordkeeping requirements. For example, air sampling and blood lead test results must be kept on file according to Cal/OSHA rules. Keep track of the outside resources your program uses. These may include labs, industrial hygiene services, abatement contractors, equipment suppliers, waste disposal facilities, and government agencies that can answer questions. Send a copy of your lead-safe schools program policies and procedures to appropriate people in your district, such as principals, school administrators, and managers in the Maintenance and Operations (M&O) department. 23

34 LEAD-SAFE SCHOOLS Regularly Evaluate and Improve Your Program. Programs improve only if you evaluate them periodically and determine what could be done better. For example, when tasks involving lead are done, periodically monitor how much exposure the workers have. High lead levels may point to a need for future improvement in work practices or training. There should be a system to obtain this kind of input regularly and document it. Talk to other school districts regularly to get ideas on what could be done differently to improve your program. Update your program as needed. For more on documenting and evaluating your program, see Chapter 9. Can You Afford a Lead Program? It s possible to make a program affordable. Following lead-safe work practices requires spending some money to purchase necessary equipment and supplies (for example, plastic sheeting, HEPA vacuums, power tools that can take HEPA attachments, and possibly air sampling equipment). For some school districts, particularly small districts, these costs may present a hardship. Sharing resources with surrounding districts can help small school districts save money. Maintenance departments in other districts may be able to share supplies and equipment as well as give you ideas for your own district. Many school districts are members of a Joint Powers Authority (JPA), established to share group insurance policies, transportation, and other services with nearby districts. JPAs might also be used to share equipment and other resources needed for lead-safe schools programs. In some cases, groups of nearby California school districts have purchased items jointly and stocked a special trailer which can go from school to school. The trailer carries tools, equipment, and disposable supplies like plastic sheeting and tape. Some trailers have equipment for both asbestos and lead jobs. Certain large districts in California also have their own trailers. How Can You Use the Program Planning Form? The sample Program Planning Form that begins on the next page can help organize your entire lead-safe schools program. This form, used in conjunction with other documentation, can guide you in developing your program. It covers all six elements discussed earlier in this chapter. For each element, it spells out what you need to do and what records you should keep. The completed form will also be useful later as documentation that each element of your program is in place. Keep the form on file and provide copies to appropriate school district managers. 24

35 CHAPTER 3 ELEMENTS OF A LEAD PROGRAM Program Planning Form Name of School District Date Program Manager A Program Manager has been appointed. Name Location Title Phone The Program Manager reports to: Name Location Title Phone The Program Manager has DHS lead certification. Level Renewal date 1. Identify Lead in Schools Target schools have been identified (pre-1993 buildings with children 8 and under). Total number of target schools in the district Attach the completed District Target Schools Form. Survey of target schools has been done. Date begun Date completed The survey was conducted by: Name Location Title Phone Attach a sheet with additional names if necessary. Also attach a completed Building Inventory Form Paint and Soil Hazards for each school building surveyed. 25

36 LEAD-SAFE SCHOOLS Program Planning Form page 2 Paint chip samples were collected for testing. (Optional.) Sampling locations and dates Samples collected by Name and phone of laboratory Attach test results and lab chain of custody forms. Soil samples were collected for testing. (Optional.) Attach test results and lab chain of custody forms. Drinking water has been tested at all schools. Name and phone of laboratory Attach test results and lab chain of custody forms. 2. Analyze Maintenance Tasks Personal air sampling has been conducted for each type of lead-related maintenance task. Attach sampling results, lab chain of custody forms, list of workers sampled, calibration information, calculations, etc. Workers have been notified of sampling results. Date notified How notified Typical maintenance tasks have been categorized as either lower risk or high risk based on sampling results and/or other data. Attach list of tasks. 26

37 CHAPTER 3 ELEMENTS OF A LEAD PROGRAM Program Planning Form page 3 3. Provide Worker Protection Personal protective equipment (PPE) necessary for lead work has been purchased (booties, goggles, gloves, respirators, etc.). Attach vendor contact information. Workers have been informed of the need for PPE and required personal hygiene measures. Date informed How informed If respirators will be used, a complete written Respiratory Protection Program is in place. Attach written Program. If high risk tasks will be performed, a Medical Surveillance Program is in place. Attach written Program or name, address, and phone of supervising physician. 4. Use Safe Work Practices Written policies and procedures on lead-safe work practices have been developed and distributed to workers. Attach written policies and procedures. Equipment and supplies necessary for lead work have been purchased (caution tape, plastic sheeting, sprayers, detergent, HEPA vacuums, etc.). Attach vendor contact information. Wipe sampling has been done on selected jobs to check quality of containment and cleanup. Attach sampling results and lab chain of custody forms. 27

38 LEAD-SAFE SCHOOLS Program Planning Form page 4 Policies and procedures on lead waste disposal have been developed. Attach written policies and procedures. 5. Train Workers A training policy has been developed, including training for both present workers and new hires. Attach written policy. Trainers or outside training facilities have been identified. Trainer(s) or facilities Address / phone Type of training offered Workers to be trained have been identified. Attach a sheet with the name of each worker, title, and level of training needed. Also attach dated sign-in sheets for trainings. 6. Document and Evaluate the Program Information on the Lead-Safe Schools Program has been sent to key administrators and M&O managers. The program has been explained to all M&O workers. A system for maintaining records has been developed. 28 A system for periodic evaluation of the program has been developed. A schedule of future actions has been prepared (follow-up lead surveys, worker re-training programs, etc.). Attach schedule.

39 CHAPTER 4 IDENTIFY LEAD IN SCHOOLS CHAPTER 4 Identify Lead in Schools What Is a Lead Inventory? The first element of a lead-safe schools program is to get an overall sense of the possible lead problems in your district. After identifying lead hazards, you will be able to set priorities and address the most serious issues first. This chapter will guide you through a lead inventory a process of identifying, evaluating, and prioritizing the lead hazards in all your schools district-wide. Where Is Lead Found in Schools? Most commonly, lead may be present in the paint, dust, soil, and water at school facilities. A recent California Department of Health Services (DHS) study of public elementary schools statewide, cited in Chapter 1, found many lead hazards. DHS discovered that nearly 96% of the schools surveyed have detectable levels of lead in the paint, 6% have lead in the nearby soil, and 18% have lead in the drinking water. Each of these sources is discussed in this chapter. (See Appendix A for a summary of the DHS study.) Lead hazards in paint, dust, and soil are related. The main source of soil contamination is lead paint. Paint on buildings and play structures can deteriorate or be disturbed, and chips, dust, or water runoff containing lead can get into the nearby soil. Therefore, it makes sense to look at paint and soil hazards together. On the other hand, lead contamination in water has different sources and must be considered separately. Don t overlook the hazards of lead in water. 29

40 LEAD-SAFE SCHOOLS Fortunately it is a fairly easy problem to identify and control. While paint and soil problems are more common at older schools, there can be lead in the water at any school. Both schools with new plumbing work and very old schools (pre-1930) can have significant problems of lead in water. This chapter first discusses how to identify, evaluate, and test for lead in paint and soil. It then provides similar information for water. Are There Other Sources of Lead in Schools? There may be other sources in some schools. Lead is sometimes found in art supplies, photography supplies, pottery glazes, science lab materials, and also in some vinyl miniblinds. School districts should evaluate whether there are ways to eliminate these sources of potential exposure. However, this Guide only addresses lead in paint, dust, soil, and water. Does Most Paint Contain Lead? Yes. Almost all commercial paint sold before 1993 contained some lead. As evidence of its hazards began to emerge, industry and government took steps to eliminate it. Lead in paint used to be a sign of quality. The higher the lead content, the better the paint. Lead was added to paint to make it last longer, dry faster, and stick better. Older schools and other buildings are more likely to have paint containing high levels of lead. This old lead paint is often covered with more recent layers of paint that may not contain lead. Until the mid-1950s, paint contained as much as 50% lead. In 1955, the paint industry adopted a voluntary standard limiting interior paints to 10,000 ppm (or one percent) lead. In 1978, the U.S. Consumer Product Safety Commission (CPSC) banned the manufacture of residential paint containing more than 600 ppm lead. (Note that most latex paint has never contained lead.) Non-residential paint, such as some industrial paints and marine paints used for boats, can still be lead-based. And although the CPSC ban occurred in 1978, supplies on hand extended the use of residential lead-based paint into the 1980s. In addition, schools may have received donations of older residential lead paint or industrial paint (for example, from businesses or parent groups). 30

41 CHAPTER 4 IDENTIFY LEAD IN SCHOOLS California s Lead-Safe Schools Protection Act, passed in 1992, banned leadbased paint and other sources of lead contamination from all new and renovated school facilities built on or after January 1, It is for this reason that Title 17 identifies all paint on schools built or renovated before January 1, 1993 as presumed lead-based paint. Exterior painted surfaces in newer schools tend to have about twice as much lead as interior surfaces. However, according to the DHS study, interior paint in schools built before 1960 had higher average lead levels than exterior wall paint. The paint on trim components such as window sashes, door jambs, and baseboards usually has significantly more lead than wall paint up to five times as much for trim on exterior walls, and twice as much for trim on interior walls. IMPORTANT! The year a school was built is the best indicator of whether or not lead paint will be found. According to the DHS study, schools built before 1960, and especially before 1940, are most likely to have a hazardous combination paint with a high lead content and paint in need of maintenance. If a school complex was built in stages, the oldest buildings in the complex are of greatest concern, especially if very young children spend time there. If old buildings house pre-schools, kindergartens, or cafeterias used by children eight and under, the lead hazards there should be given special attention. State Study Highlights Lead Paint The California DHS study revealed that: In schools built before 1980: 100% had detectable levels of lead in paint. 45% had some deteriorated lead paint. In schools built in 1980 or after: 45% had detectable levels of lead in paint. 3% had some deteriorated lead paint. 31

42 LEAD-SAFE SCHOOLS When Does Lead Paint Become a Hazard? If lead paint is in good condition and left intact, it is not likely to present a hazard. The problem can arise if the paint or underlying surface is in deteriorated condition, or if the paint is disturbed. The possibility that lead paint will become hazardous is increased by: Aging and deterioration of paint chipping, peeling, or cracking. Paint is also subject to chalking (formation of a fine powder on the paint surface that may contain high levels of lead). Weather effects on the exterior of buildings (sun or rain). Water damage or mildew inside buildings. Maintenance or repair activities that disturb paint. Children chewing on sills and other painted surfaces. Impact that disturbs paint, such as doors being slammed or walls hit. Friction that disturbs paint, such as windows opening and closing or doors scraping. In short, lead paint is a hazard when it is in poor condition or when it is disturbed It is a special concern when it is accessible to children. These are the school buildings we should be most concerned about. How Can Soil Get Contaminated With Lead? Soil can become contaminated when chips or dust from lead paint fall from nearby buildings or play structures. Lead often settles into nearby soil: When exterior lead paint is chipped during preparation for repainting. When exterior lead paint deteriorates over time from sun or rain. When lead dust is created by opening and closing painted windows or doors. When lead paint on playground structures chips or flakes. 32

43 CHAPTER 4 IDENTIFY LEAD IN SCHOOLS Lead may also be present in soil as a result of leaded gasoline emissions. Lead was a gasoline additive used to prevent engine knocking prior to the mid-1970s. Leaded gasoline has since been banned. Prior to the ban, an estimated 200,000 tons of lead were emitted in vehicle exhaust in the U.S. each year From the air it settled into soil throughout the country. As a result, in some urban areas, lead levels in soil are high enough to poison children. Industrial air emissions are another source of lead in soil. Over the years, lead from air emissions generated by industry has settled into the soil, particularly near lead smelters, battery plants, oil refineries, power plants, and waste facilities. Schools are more likely to have lead in soil from gasoline and from industrial sources if they are located near: Freeways, where auto exhaust has settled for years. Industrial areas (or former industrial areas), where industrial pollution has settled for years. In summary, lead can get into the soil near schools from paint chips or dust, from auto exhaust, and from industrial pollution. According to the DHS study, it is likely that a small but significant number of California s public elementary schools have a soil problem. In 6% of the elementary schools DHS found lead levels above the U.S. Environmental Protection Agency (EPA) limit of 400 parts lead per million parts of soil (ppm). (The EPA limit applies to bare soil where children play.) DHS found that contaminated soil is likely to be close to school buildings, and is most prevalent at schools built before However, if lead-safe work practices have not been followed over the years, newer schools may also have contaminated soil. 33

44 LEAD-SAFE SCHOOLS What Are the Steps in a Lead Inventory? To identify, evaluate, and prioritize the lead hazards in schools throughout your district, follow these five steps: 1. Collect and Review District Records. 2. Visually Survey Paint and Soil at Target Schools. 3. Test Paint and Soil Where Appropriate. 4. Test Water at All Schools. 5. Set Priorities for Hazard Control. Sample Lead Inventory Forms that can help in this process are provided in the Forms Section at the end of this Guide. Some of the individual forms are also displayed at relevant points throughout this chapter. You may decide to create your own forms to meet your school district s particular needs. Step 1. Collect and Review District Records. 34 Your lead-safe schools program manager should collect and review districtwide records showing the age and maintenance history of school buildings which house children eight and under. The object is to develop a list of target schools where a more detailed on-site survey of paint and soil hazards can be done. Even if your district is small and lead hazards are known, it is a good idea to collect and record this information. It is a useful way to document how the district identifies and prioritizes lead problems, and to make sure that the most serious problems are addressed first. Some districts may want to keep this information in a computerized system. First, identify the schools that house high risk children grades K-2 and younger children in pre-schools or childcare programs. Include high schools with teen parent programs that provide childcare. In other words, identify all school buildings with children eight and under. Don t forget privately operated before and after-school programs located on school grounds. Second, determine the date that each of these schools was built. Some schools were built in stages. Wings, or special purpose buildings such as gyms or libraries, may have been added on later. All buildings and additions constructed before January 1, 1993, by legal definition, have presumed lead-based paint unless tested and proven otherwise.

45 CHAPTER 4 IDENTIFY LEAD IN SCHOOLS Third, classify schools by the number of buildings or structures: Built before Built between 1960 and Built between 1980 and January 1, IMPORTANT! Target schools are those that have children eight and under and were built before January 1, The highest priority target schools are the oldest schools with the youngest children. Other information to collect for each school may include: Painting records. A map of school buildings and grounds. Construction and renovation records. Information on previous use of school grounds and the surrounding area, including land acquisition records. Previous surveys or lead test results of paint, soil, or water. This process should give you some idea whether any of the target schools are likely to have lead problems. 35

46 LEAD-SAFE SCHOOLS How Can You Use the District Target Schools Form? To organize the information you collect, it is useful to have a special form, other written system, or computer database. A sample District Target Schools Form is provided on the next page. It can give you a district-wide overview to help determine which target schools are most likely to have lead problems and should be surveyed first. There is a blank version of the form that you can copy in the Forms section at the end of this Guide. If you wish, you can modify the sample form to meet the needs of your district. Or you may want to develop your own form. On the sample form, use the first column to list all the schools you have identified as target schools. Use the second column to record the year each of those schools was built. Next make check marks ( ) indicating whether the school houses children in childcare and/or grades K 2. Where information is available, fill out the Possible Hazards columns for paint and soil hazards. (This section is optional.) Check the Paint column if you have any information indicating there may be deteriorated paint (prior test results, painting records, inspection records, requests for painting, etc.). Check the Soil column if the school is likely to have lead-contaminated soil, based on the age of the buildings or proximity to freeways or former or current industrial areas. Finally, give each target school a Priority ranking for a site survey. Base this on the age of the school and the number of check marks the school received on the form. This is just a guide to help you set priorities, so also draw upon your own knowledge in ranking each school. Consider using either a High / Medium / Low ranking or a numerical scale (1 5, with 1 being the top priority for inspection). Once the form is complete, you should have a good idea of which target schools to survey first. Develop a schedule for getting the surveys done. Set time-specific goals, such as surveying all target schools within 2 3 months, and so on. Record your projected dates on a master calendar, tracking system, or computer scheduling program. Also determine how long it would take the district to survey all elementary schools. Consider whether the district has the resources to survey middle schools and high schools as well. 36

47 CHAPTER 4 IDENTIFY LEAD IN SCHOOLS Lead-Safe Schools Program District Target Schools Form School District XYZ Unified Completed By John Smith Number of Schools in District 7 Title M&O Manager Use this form to develop a priority list of schools to survey for deteriorated paint and possible lead contamination of soil. Target Schools are those that have children eight and under and were built before List all your target schools at the left. Check Possible Hazards (Paint, Soil) columns if you have information that there may be a problem. Otherwise skip this section. In the Priority column, rank schools high, medium, or low. High priority target schools should be surveyed first. Target School Name Year Built Children Possible Hazards Priority Childcare K 2 Paint Soil School A 1945 High School B 1990 Low School C 1978 Medium Total Number of Target Schools 3 Date Completed 5/10/99 37

48 LEAD-SAFE SCHOOLS Step 2. Visually Survey Paint and Soil at Target Schools. The next step is to visit your target schools and survey them. You should use survey forms to collect and record information in a systematic way. Start with the oldest schools with the youngest children, which you ranked as high priority in Step 1. A survey consists of two elements a visual inspection and a written report with a summary of findings. Visual inspections may be done by M&O department personnel who have had at least general lead awareness training. They should always be done under the direction and supervision of the district s Lead-Safe Schools Program Manager or a state-certified Lead Inspector/Assessor. Since the focus of this Guide is on routine maintenance tasks and not lead abatement tasks, it does not describe how to do a formal risk assessment or lead inspection. These must be done by a certified Lead Inspector/Assessor. In some situations, school surveys may uncover problems that indicate the need for a risk assessment and/or a lead paint inspection. The purpose of your informal school surveys is to identify potential lead hazards, especially in classrooms, playgrounds, and other areas where the youngest children spend time. School surveys should include both visual inspections and conversations with school custodians, principals, and teachers. Following are some suggestions for your survey: Ask teachers what rooms and play areas are used by children eight and under. Note the condition of paint in these areas (including painted furniture and toys). Ask custodians how often carpets are cleaned, and by what method. Look for paint dust on sills and floors. Ask custodians and other maintenance staff to identify any moisture problems inside or outside the school leaks, mildew, etc. When surveying classrooms, open and close windows and doors a few times to see if this causes friction or impact that can disturb paint. HUD Guidelines suggest that the general building condition also be surveyed. If the building has not been well maintained, then the paint is also more likely to be in poor condition. Indicators of poor building maintenance include a roof that is missing parts, broken gutters or downspouts, walls with large cracks or holes, water stains on interior walls or ceilings, plaster walls that are deteriorating, and windows or doors that are broken or boarded up. 38

49 CHAPTER 4 IDENTIFY LEAD IN SCHOOLS Paint What Should You Look For? Assess the condition of painted surfaces on both the interior and exterior of buildings. Look for chipped, flaking, peeling, cracking, nicked, or chalking paint. Also look for paint dust. Pay special attention to: Interior Painted surfaces that have water damage. Paint that exposes a different color underneath. Paint chips or dust lying at the base of a wall, or on window troughs or sills. Painted surfaces that are subject to frequent impact or friction, such as windows, doors, and trim. Painted furniture and toys used by young children. Exterior Paint that is weathering from sun, wind, or rain exposure. Paint that exposes a different color underneath. Paint chips or dust lying at the base of a wall. Painted surfaces subject to frequent impact or friction. Soil What Should You Look For? Survey around the perimeter of buildings and throughout the school grounds for locations where lead may be present in soil. Consider the age of the school. The older the school, the more likely there will be lead in the soil. Also consider whether the school is near a freeway, industrial area, or former industrial area. And take into account that lead paint may have fallen to the ground during previous maintenance activities, contaminating the soil. Assume that soil is contaminated adjacent to buildings built before 1940, or test the soil. Note on your school map any exterior walls where paint is deteriorating and there is bare soil within five feet of the base of the wall. Make a note about the ground cover under all play structures and similar areas used by children eight and under. Note locations of gardens used by children. Ask the custodian or principal when sand in the sandbox was last replaced. Check with staff to learn more about the history of the school grounds, if possible. 39

50 LEAD-SAFE SCHOOLS 40 How Can You Use the Paint and Soil Hazards Form? When you do on-site surveys, start with the target schools you identified as high priority earlier. See the sample Building Inventory Form Paint and Soil Hazards on the next page, which can be used to record basic information about possible lead hazards at each school building you survey. There is a blank version of the form that you can copy in the Forms section at the end of this Guide. If you wish, you can modify the sample form to meet the needs of your district. Or you may want to develop your own form. When you survey a school, start by making a list (on a separate sheet of paper) of all buildings in the complex where children eight and under spend time. Also record the year each building was built, and make any notes you think would be useful (about general condition of the building, past problems, etc.). Your sheet may look like this: Building Year Built Notes Building # Building # Exterior paint chipping reported. Next, fill out a separate copy of the Building Inventory Form for each building. On the form, list each room and outdoor area you plan to survey. Be sure to include outdoor areas near the building if children spend time there. You may also want to use a school site map in conjunction with the form to mark the location of exterior walls with deteriorated paint and adjacent bare soil. In the Possible Hazard column, list all areas with lead-based paint, presumed lead-based paint, or soil that could be hazardous. Paint is considered a lead hazard when it is either deteriorated or disturbed in some way without containment. Paint Condition refers to whether the paint is cracking, chalking, flaking, chipping, peeling, non-intact, or otherwise separating from a surface. Describe the condition and the extent of the deterioration (whole wall, small area, entire bookcase, etc.). Use the column Nearby Surfaces To Check to list anything that could have become contaminated by paint chips, dust, or soil from the possible hazard. For example, list carpets, toys, books, etc. beneath deteriorating paint. If soil is listed, indicate the type of soil covering (bare, partially covered, covered with wood chips, etc.). In the next column, give each area a Priority ranking High, Medium, or Low. Base your ranking on the degree of hazard to children ages eight and under. Next, indicate what action is recommended in Response Needed. This column could later be reviewed and possibly amended by M&O supervisors or others. The Follow-up Action column allows you to track status.

51 CHAPTER 4 IDENTIFY LEAD IN SCHOOLS Building Inventory Form Paint and Soil Hazards School School A Building # 1 Date of Survey 5/11/99 Address 123 School St. Site Contact and Phone Mary Jones, _ Survey Completed By John Smith Title M&O Manager Room or Outdoor Area & Use of Space Possible Hazard Paint Condition Priority Nearby Surfaces to Check High/Medium/Low ( ) Response Needed Follow-up Action & Date Taken Room 2, Kindergarten Bookcase (blue) Poor peeling (undercoat exposed), presume leadbased paint High Repaint Removed for repainting 5/15/99 Schoolyard, Kindergarten play area Painted monkey bars Poor chipping, presume leadbased paint Uncovered sand beneath (probably contaminated) High Restrict area until repainted Scheduled for repainting summer 99 Same as above Sand beneath monkey bars High Replace sand To be replaced after monkey bars are painted Room 6, First grade Previous leak stained ceiling Good intact (no peeling yet) Low Teacher and custodian advised Scheduled for re-survey 11/15/99 ( ) PRIORITY: Rank high/medium/low depending on hazard and accessibility to children eight and under. Page of 41

52 LEAD-SAFE SCHOOLS Step 3. Test Paint and Soil Where Appropriate. Your district needs to determine when and how to test paint and soil for lead. In most cases, only a state-certified Lead Inspector/Assessor may take samples for testing. Testing paint is the only way to know the lead levels and the corresponding risks to children and school employees. On the other hand, testing can be expensive. However, the law (Title 17) defines all paint in school structures built before January 1, 1993 as presumed lead-based paint unless tested and shown otherwise. If you assume that paint contains lead and follow lead-safe work practices for routine, lower risk maintenance tasks all the time, no testing is needed. However, making this assumption for newer buildings (where lead is not so prevalent) may also be expensive. If you can show there is no lead, the job will be simpler and cost less because lead-safe precautions will not be required. Although samples to test paint, dust, or soil for lead must usually be taken by a state-certified Lead Inspector/Assessor, there are two exceptions to this rule. A person who is not certified may take paint chip samples related to a planned maintenance task if the purpose is to help comply with Cal/OSHA s worker protection regulations such as in selecting the proper controls (respirators, protective clothing, work practices, etc.). A non-certified person may also test dirt and debris for disposal purposes, to see whether it meets the legal definition of hazardous waste. For more on certification, see Chapter 8. Below are some approaches school districts have taken. Decide which approach makes sense for your district, and then document your decision. What Paint Should Be Tested? Many school districts take the approach that it is not always necessary to test paint for lead, if workers follow lead-safe work practices all the time. This approach can be safe and cost-effective for maintenance tasks that involve minor, lower risk work. See Chapter 5 for a discussion of high risk and lower risk lead tasks. This approach is recommended by DHS for older buildings. Many school districts find it can save them thousands of dollars in testing costs money perhaps better spent implementing lead-safe work practices. When deciding whether to use this approach, consider the age of the school and the size of the task. 42

53 CHAPTER 4 IDENTIFY LEAD IN SCHOOLS The year a building was constructed is the single best indicator of whether painted surfaces are likely to contain lead. Assuming that lead is present makes sense particularly for schools built before 1980, since the DHS study showed that 100% of them had some detectable lead in paint. Buildings fall into these categories: Built before 1980 Assume that these school buildings have some lead in paint. Schools built through 1950 generally have high levels of lead in paint. You may decide not to test, if you always use leadsafe work practices. Built between 1980 and January 1, 1993 These buildings may have lead paint even though most lead was banned in residential paint in For example, buildings may have been painted with old paint or industrial paint. Testing is often recommended. The DHS study mentioned earlier found that 45% of California schools built during this period have detectable levels of lead in paint. Built on or after January 1, 1993 According to DHS, these schools can be assumed not to have lead-based paint. Especially for buildings in the group, check any available records on the paint, such as Material Safety Data Sheets (MSDSs), to see if it contained lead. (However, MSDSs are not required to list lead as an ingredient if it is less than 1% of the paint.) Also check with the paint manufacturer. If you can t get a conclusive answer, testing makes sense. Testing may find there is no detectable lead and it is not necessary to use specially trained workers or special precautions for the job. Therefore, the testing may pay for itself. For abatement projects, and for major remodeling on renovation projects that will disturb painted surfaces, it is legally required that a risk assessment, paint inspection, or both be done. These must be performed by a certified Lead Inspector/Assessor and should take place during the initial planning stages of each project. Most districts also test for lead whenever they plan to contract out a major job. Districts need to know the location and level of lead present so they can properly evaluate the contractor s proposal, work practices, and compliance with the Cal/OSHA Lead in Construction standard. (See Chapter 8 for more information on using outside contractors.) How Is Paint Tested? There are several different ways to test paint for lead content. Each has its pros and cons. You need to weigh the costs and several other factors. 43

54 LEAD-SAFE SCHOOLS Three common testing methods are: Paint Chip Sampling. X-ray Fluorescence (XRF) Analysis. Wet Chemical Field Test. Paint Chip Sampling In this test, samples are taken from a painted surface by a certified Lead Inspector/Assessor and sent to a laboratory for analysis. The lab reports tell how much lead is in the paint. Paint chip sampling is usually done when only a few samples are needed. A sample is collected by scraping a 2 by 2 inch square area down to the underlying surface. Care must be taken not to include any underlying wood, plaster, concrete, etc. in the sample. The sample, usually containing several layers of paint, is sealed in a container, labeled with the sample location, and sent to a lab accredited by the National Lead Laboratory Accreditation Program (NLLAP). The results are usually expressed in parts of lead per million parts of paint (ppm) or as a percentage. Prices of the test vary from $5 to $25 per sample, depending on the number of samples sent and how quickly you need the results. Labs often provide instructions on where and how to take paint chip samples and may prefer that you use their containers. For a list of NLLAP-accredited labs in California, see the website For more on paint chip sampling methods, see Appendix 13.2 of the HUD Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing, June 1995 (Title X, Section 1017). XRF Analysis Another way to test painted surfaces is to hire a certified Lead Inspector/ Assessor to come to the site and use an X-Ray Fluorescence (XRF) Analyzer. This test gives an immediate reading of the lead level in the paint. The test doesn t disturb the painted surface. It is also cheaper than paint chip sampling for large numbers of samples. Because of these benefits, XRF Analyzers have been popular among school districts and lead contractors. 44

55 CHAPTER 4 IDENTIFY LEAD IN SCHOOLS Schools may still need to do paint chip sampling after XRF sampling if lead is present but at a low level. Remember that many current lead regulations cover paint with any detectable level of lead. Certified Inspector/Assessors typically charge several hundred dollars per day for XRF testing. Wet Chemical Field Test How Is Soil Tested? These tests are available in paint stores, are cheap, and give quick results. They are commonly referred to as lead sticks. However, both HUD and EPA recommend that you do not use these tests because the results can be unreliable. At best, the test only tells you if lead is present, not how much there is. Also, the test identifies lead only in the surface paint that is exposed not the undercoats, which are much more likely to contain lead because they are older. The hazard posed by lead in soil depends on: The amount of lead in the soil. Whether or not the soil is bare. Whether the soil is accessible to young children. According to the California DHS study mentioned earlier, almost all schools built before 1980 have some lead-contaminated soil, although only 6% exceed the EPA limit of 400 parts per million (ppm). Almost 30% of schools built before 1940 exceeded the limit. The best approach is for districts to assume that older schools, particularly those built before 1940, have lead-contaminated soil. In these schools, as a first step, either test the soil or fence off or cover bare soil within five feet of painted exterior walls of buildings. Next, address soil more than five feet from buildings (beginning with play areas). Soil that is covered or fenced off does not pose a hazard and therefore need not be tested. Schools built after 1940 are less likely to have lead in soil, but only testing can tell for sure. Soil testing must be done by a state-certified Lead Inspector/Assessor. Samples are sent to an NLLAP-accredited lab for analysis. Samples are usually taken along the building foundation, along the drip line, in sandboxes, or in any other area where there might be lead in the soil, such as below painted play structures. Composite samples are usually taken, where three to ten subsamples from different locations are combined into one sample for analysis. 45

56 LEAD-SAFE SCHOOLS Step 4. Test Water at All Schools. Lead-contaminated drinking water is a potential health risk to people of all ages, from infants to adults. Lead in water is impossible to detect by sight, smell, or taste, but students and school employees may drink it every day. According to the DHS study, 18% of surveyed California schools have lead levels in drinking water above the EPA limit of 15 parts per billion (ppb). EPA has found that children typically get up to 20% of their lead exposure from drinking water. Testing water and reducing lead levels is much easier than reducing lead paint hazards, yet it yields important health benefits. School districts should reduce lead in water to the lowest level possible. How Can Water Get Contaminated With Lead? Drinking water in schools can be contaminated when lead leaches from pipes, solder, or plumbing fixtures, or when the water supply itself is contaminated. Both old and new schools may have lead-contaminated water. Plumbing installed before 1930 is most likely to have lead pipes. However, newer plumbing may have leaded solder, which was in common use in California until it was banned in Leaded solder may still be used illegally by some plumbers. Faucets, valves, or fittings made of brass may also contain small amounts of lead, although many manufacturers today use lead free brass. More lead can leach into water from solder or brass fittings when the plumbing work is new, especially in the first five years after the work is done. The amount of lead in the water is likely to be higher if: The pipes are very old (especially pre-1930, when lead pipes were common). The plumbing has been illegally repaired with leaded solder within the last five years. Brass fixtures containing lead have been added within the last five years. The water source is soft or acidic (more corrosive). The water stands in the pipes for more than 24 hours. 46

57 CHAPTER 4 IDENTIFY LEAD IN SCHOOLS Water coolers were identified by the EPA in 1987 as another potential source of lead contamination. The Federal Lead Contamination and Control Act, passed in 1988, required that water coolers with lead-lined tanks be repaired or removed. It also banned the manufacture and sale of water coolers that are not lead free, and required that lead problems in schools drinking water be identified and corrected. Should Your District Test Drinking Water? Yes. Drinking water should be tested at all schools. The California Department of Education sent drinking water advisories to schools between 1987 and 1989, and EPA recommended testing in Schools with their own drinking water systems, such as wells, were required to test under a 1991 federal regulation. If water was tested at some time in the past, it may be necessary to test again if schools have had plumbing renovations since the test. A change as simple as a new faucet head can result in lead exposure over the EPA limit. New fixtures are not always lead free. For example, one California district found that a contractor had installed new faucets containing lead during a school modernization project. The district tested the water and found lead levels over 25 ppb, well above the EPA limit of 15 ppb. A site survey is not needed to identify lead hazards in water if the district has a good testing program. However, those conducting the lead-safe schools survey described earlier may want to ask school maintenance staff questions about sources of drinking water, any recent plumbing work, and any water problems encountered in the past. How Is Water Tested? The only way to find out if there is lead in drinking water is to have it tested. The EPA recommends that drinking water be tested after a weekend or in the morning before school starts (that is, when the water has not been running). For advice on sampling site selection, see Lead in School Drinking Water, January 1989, EPA Document number 570/ (To contact EPA, see Appendix I.) A person who takes drinking water samples does not need to be state-certified but should follow EPA test procedures as described in the National Primary Drinking Water Regulations (40 CFR Part , Control of Lead and Copper. ) Note the new federal limit of 15 ppb. For more information, check the website Click on Publications. The EPA s recommended method involves taking first draw samples and then possibly second draw samples. These are sent to a lab certified under 47

58 LEAD-SAFE SCHOOLS DHS s Environmental Laboratory Accreditation Program. The lab must have certification for metals in drinking water. For a list of labs, see the website If water samples taken on the first draw are over the EPA limit of 15 ppb at any water outlet (fountain, faucet, etc.), a second draw water sample should be taken after running the water for a period of time. Often the first draw samples are higher because the water has been sitting in the pipes, allowing more lead to leach out. If the second draw sample also exceeds 15 ppb, remove the water source from service until it is repaired. Supply an alternate source of water if necessary. Usually the next step is more sampling, and testing the water at different sites in the plumbing system to identify the lead source. If the second draw sample is under 15 ppb, consider a flushing program as described in Step 5. Step 5. Set Priorities for Hazard Control. School Maintenance and Operations (M&O) departments are primarily concerned with taking action and getting things done. However, it is important that managers take the time to reflect on what has been learned from their school lead surveys and testing results. To correct the problems found, you have to assess district resources and think through the implications of taking on new lead control jobs. As you set priorities, you should develop: 48 An M&O work plan that deals with the most serious lead problems first. A policy on which lead work to do in-house, and which work to contract out.

59 CHAPTER 4 IDENTIFY LEAD IN SCHOOLS A tracking system for all district lead work, including schedules, procedures, and forms. An action plan for lead in paint. An action plan for lead in soil. An action plan for lead in drinking water. After surveying schools for lead hazards and getting any necessary test results, managers will probably have discovered at least some potential lead hazards. This will make it necessary to revise current plans for maintenance work and shift the focus to resolving lead problems. Problems of deteriorating paint in areas with children eight and under will most likely head your list. It is also important to deal promptly with any severe problems in soil and water. What Can Be Done About Lead in Paint? You ll need to develop an action plan to address lead hazards in paint. Review your Building Inventory Form Paint and Soil Hazards, and decide what corrective action is most appropriate for each priority location. In each case, determine what work will be done, how it will be done, and who should do it. Most M&O departments will probably solve many problems by repainting. Remember that sealing painted surfaces so they will not create chips or dust is often safer, easier, and more cost-effective than complete removal of lead paint. If proper work practices are not used, the work you do to correct a hazard may pose a risk of increased lead exposure for your maintenance staff and school children. The work may disturb lead, putting more lead dust into the air and onto nearby surfaces. Taking these issues into account, some maintenance tasks intended to reduce lead problems are considered lower risk jobs and some are considered high risk jobs. See Chapter 5 for more information on lower risk and high risk maintenance jobs. Assess the district s ability to do lower risk, high risk, and full-scale lead abatement tasks in-house. Look at the number of workers available, their skill levels, how much lead training they have had, and whether they are lead certified. Also consider whether you have the right equipment, materials, and other resources available. There are extensive Cal/OSHA and Title 17 requirements for special work practices and worker protection when doing high risk or lead abatement tasks. These include wetting the work, using containment, using HEPA attachments on power tools, following other appropriate work methods, 49

60 LEAD-SAFE SCHOOLS doing air sampling, and providing medical tests for workers. See Chapters 5 7 for details. Does your district have the capability to put these required precautions in place? If not, some lead jobs may need to be done by contractors who are state-certified in lead-related construction. If you use a contractor, ask for proof of lead certification. Always have a detailed written contract that specifies the contractor s responsibilities and agreement to meet all Cal/ OSHA, DHS, Cal/EPA, and other legal requirements. Ask the contractor about their experience with lead, level of certification of the crew, lead liability insurance carried, and references for past lead work. (See Chapter 8 for more information on using outside contractors.) Another possible approach is to have a transition period, where the high risk jobs are contracted out until district staff can be trained and equipped to do them properly in-house. What Can Be Done About Lead in Soil? You also need an action plan to deal with lead in soil. Review your Building Inventory Form Paint and Soil Hazards, and decide what corrective action is most appropriate for each priority location. Districts should assume that bare soil within five feet of buildings built before 1940 is contaminated with lead above the legal limit (400 ppm). Such areas should either be fenced off to make them inaccessible to children, blanketed with ground cover, or both. This is the recommendation of the California Department of Health Services, based on the fact that soil testing is complex and requires specially certified personnel. If you assume that soil is contaminated outside older buildings (or if testing has found lead over 400 ppm in the soil), the school district should take measures to protect children. These include: Cover bare soil. Use dense planting or fencing to restrict children s access to these areas. Move play equipment out of these areas. Prohibit use of these areas for demonstration gardens, rainbow gardens, or any other educational activities. Post warning signs. 50

61 CHAPTER 4 IDENTIFY LEAD IN SCHOOLS If lead levels in soil are over 1,000 ppm, California DHS considers the soil hazardous for adults as well as children. As an interim measure, you can cover the soil as described above. You can permanently solve the problem by covering the soil with concrete or asphalt, or by complete removal of the contaminated soil. If you choose removal, the soil is considered to be hazardous waste as explained in Chapter 7, and you must use special waste disposal procedures. While removing soil, erect barriers to restrict access until the work is completed. For more complete information on soil cleanup, check the website What Can Be Done About Lead in Water? A flushing program can be instituted to reduce lead levels in drinking water temporarily. Flushing means running the water for a period of time to wash out as much lead as possible. Water outlets should be thoroughly flushed on a regular schedule if: The water is sampled and has a lead level over 15 ppb and The water is sampled again after full flushing and has a lead level under 15 ppb. EPA guidelines recommend that flushing be done daily each morning before school starts. Flushing should continue until a plan for permanently reducing lead to below 15 ppb has been put in place. Flushing is especially important after holidays and vacation periods. It should be done before students arrive back to school. If the second sample is also over 15 ppb, remove the fixture from service instead of flushing. Supply an alternate source of drinking water if needed. The California Department of Education issued a directive in 1988 that advised schools to have flushing programs. Regardless of testing results, flushing is advised in any of these situations: The school water system contains lead pipe (unlikely). The school has pipes with lead solder. The water is soft or acidic (corrosive). If you flush, continue to do so until a plan for permanently reducing lead has been put in place. Such a plan may include replacing pipes or plumbing fixtures, or obtaining water from a different source. For further advice, consult your local water district, or the DHS Division of Drinking Water and Environmental Management. (See Appendix I.) 51

62 LEAD-SAFE SCHOOLS How Often Should Schools Be Surveyed for Lead? Each target school should have an initial visual survey, primarily of paint. This site survey can also be used to survey the soil around the perimeter of buildings, and in outdoor lunch and play areas. After the target schools have been surveyed, schedule surveys for all of the other schools in the district. A school should be surveyed again if it suffers any major damage such as water, fire, vandalism, or earthquake. In addition, all schools should be surveyed periodically to detect newly deteriorating paint. Set up a survey schedule that fits into other M&O activities. Keep written records of these surveys. Districts are required to inspect schools for asbestos every three years by law, and many are beginning to inspect for mildew and mold. It makes sense to include a survey for lead hazards on the same site visit. 52

63 CHAPTER 5 ANALYZE MAINTENANCE TASKS CHAPTER 5 Analyze Maintenance Tasks When Is a Maintenance Task Hazardous? Another important element of a lead-safe schools program is evaluation of maintenance tasks. Look at work done throughout the school district and determine its potential to cause lead exposure. A systematic survey of the maintenance activities typically done in the district is desirable, although many districts review tasks on a case-by-case basis as they arise. School Maintenance and Operations (M&O) departments handle a wide variety of tasks. Given the typical age of California school buildings, many tasks will probably disturb lead paint. Cutting, drilling, sawing, sanding, or chipping into lead paint can release lead dust into the air and immediately expose workers. The dust then settles onto surfaces and becomes a possible source of lead exposure for children. Some maintenance activities produce a high level of risk, and some produce a lower level of risk. Before work begins on any job, it is important to analyze the specific tasks to be performed and assess their risk. Consider whether each task has the potential to create a high risk or lower risk of lead exposure for workers or children. This type of analysis is the only way to know what specific procedures should be followed and which workers on the staff (if any) have enough training. It can also help you find ways to minimize worker exposure while the work is being done, and prevent surface contamination that could expose children later. 53

64 LEAD-SAFE SCHOOLS Take these factors into account when deciding if a maintenance task involving lead paint creates a high risk or a lower risk: The amount of lead in the paint. The amount of dust likely to be generated by the task. The precautions that are taken to minimize dust and surface contamination. These factors are discussed in more detail below. How Much Lead Is in the Paint? Title 17 defines lead-based paint as paint or other surface coatings that have 5,000 or more parts of lead per million parts of paint (5,000 ppm). Consider any painted surface that has over 5,000 ppm to have a high level of lead. School buildings in California typically have at least this level of lead in the paint. The 1998 California Department of Health Services (DHS) study of the state s elementary schools found that: 93% of schools built before 1959 have paint with lead over 5,000 ppm. 70% of schools built between 1960 and 1979 have paint with lead over 5,000 ppm. Bear in mind that workers who may be exposed to any detectable level of lead in paint are protected by the Cal/OSHA Lead in Construction standard. Protective measures are required by the standard for all lead work (even lower risk tasks). A summary of the standard appears in Appendix B. Must Paint Be Tested for Lead? No. However, if you don t test the paint and your school building was constructed before January 1, 1993, you must assume that it contains lead and take all necessary precautions. You must follow the requirements of the Cal/OSHA Lead in Construction standard, just as if you knew for sure that there was lead in the paint. See Chapter 4 for more information on testing paint. 54

65 CHAPTER 5 ANALYZE MAINTENANCE TASKS How Dusty Is the Task? The amount of dust produced by a task is probably the most important factor in determining the risk. The Cal/OSHA Lead in Construction standard provides guidance on whether a task involves a high risk or a lower risk. To determine whether a particular task would expose workers to too much lead dust, the Cal/OSHA standard requires that personal air sampling be done when work begins. This sampling measures the amount of lead dust in a worker s breathing zone while work is in progress. The Cal/OSHA standard requires different work practices, protective measures, and training, depending on how high the dust level is found to be. What Does Cal/OSHA Require? If the initial personal air sampling finds that a worker is being exposed to less than 30 micrograms of lead per cubic meter of air (30 µg/m 3 ), only basic protective measures are required, primarily to prevent contamination of surfaces accessible to children. Measures include wetting surfaces, using plastic sheeting to contain lead dust and chips, cleaning up thoroughly after the job, and following good worker hygiene practices including mandatory hand and face washing. Another Cal/OSHA standard (Hazard Communication) also requires that workers receive training if they are exposed to any amount of a chemical, including lead. If the initial personal air sampling finds a worker s exposure to be 30 µg/m 3 or more, additional protective measures are required. These include more detailed training and additional personal air sampling to be sure the levels aren t rising higher. 30 µg/m 3 is called the Cal/OSHA Action Level for lead. Cal/OSHA also has a Permissible Exposure Limit (PEL) for lead. A PEL is the maximum amount of a substance allowed in the workplace air (averaged over an eight hour day). The Cal/OSHA PEL for lead is 50 µg/m 3. If a worker is being exposed to a lead level at or above the PEL, the task clearly involves a high risk. In this case, the Cal/OSHA standard requires very strict protective measures. These include more personal air sampling, respiratory protection, personal protective clothing and equipment, personal hygiene measures, and medical testing. See Chapter 6 for a more complete list. Furthermore, the standard requires that workers and supervisors on such jobs be trained by a provider accredited by the California Department of Health Services. Workers and supervisors must also be certified by the state. If a school maintenance worker is doing a task that generates a lot of lead dust, the PEL may be reached quickly. Therefore, even some maintenance 55

66 LEAD-SAFE SCHOOLS tasks that are done for short periods of time may present a high risk of exposure to workers. IMPORTANT! This Guide defines a high risk task as one likely to cause worker exposure above the PEL. However, lead work that does not cause exposure above the PEL can still be hazardous. For example, some tasks that pose a relatively low risk to workers can seriously contaminate surfaces accessible to children. Personal air sampling is not always required. Cal/OSHA allows exceptions if sampling was done on a similar job within the last 12 months, or if objective data shows that workers could not be exposed above the Action Level. See Chapter 6 for more information. Can Work Practices Affect Risk? 56 Yes. Many common school maintenance tasks that disturb lead can create either a high risk or lower risk of exposure, depending on how they are done. Following lead-safe work practices means finding ways to keep dust levels and contamination of surfaces to a minimum. The examples of common maintenance tasks below illustrate how work practices can affect the risk. Surface Preparation. Preparing a lead painted surface for repainting can be either a high risk or lower risk task, depending on how the job is done. For example, power sanding a painted wall will create high dust levels and therefore a high risk of lead exposure. This can be true even if the paint has only a small amount of lead (perhaps 600 ppm). For this reason, power sanding of lead painted surfaces is prohibited by HUD Guidelines and by Title 17, unless power tools with HEPA vacuum attachments are used. On the other hand, using wet scraping methods instead of sanding keeps dust levels down and lowers the risk. Removing Building Components. Sometimes building components need to be removed for repair or replacement. But if a window, for example, is pulled out without controlling where the paint dust and chips fall, significant lead contamination can occur. Instead, to control the dust and chips, seal the window from the inside, wet painted surfaces, and remove the window toward the outside. Wet dust and chips can be caught by plastic sheeting secured on the ground. After the job, the sheeting must be handled using proper procedures to avoid ground contamination, as explained in Chapter 7.

67 CHAPTER 5 ANALYZE MAINTENANCE TASKS Power Washing. Some school districts do power washing of buildings with a high pressure hose to clean them. If there is lead paint on the building and the water pressure is very high, this can be a hazardous task. It is difficult or impossible to contain the water runoff, which will probably have lead paint chips and debris. Significant environmental contamination can result. On the other hand, cleaning a wall with intact paint by low pressure power washing is much less hazardous. Paint will not be removed in the process because of the lower water pressure. The runoff will not be contaminated with lead paint chips or debris. Power washing is not the same as water blasting. Water blasting of buildings, sometimes done to remove paint, uses a much higher pressure. Water blasting without containment is prohibited by HUD Guidelines and by Title 17. Drilling, Chiseling, or Sawing. When workers drill, chisel, or saw painted surfaces, the task can generate either a lot of dust or a little dust, depending on the extent of the work and how it is done. Although these tasks may not generate enough dust to expose a worker above the PEL, they can contaminate surfaces accessible to children if they are done improperly. Wherever possible, minimize dust and paint chips by keeping the work surface wet, then clean up thoroughly. Remember to keep the accumulating dust and debris wet also. Repairing Radiators. Radiators in school heating systems often have deteriorating lead paint. When plumbers or other maintenance workers repair leaks or replace valves, paint chips can easily contaminate the surrounding area. The risk of contamination can be reduced by placing plastic sheeting on the floor around the radiator to catch debris. Keep debris wet. Certain tasks sometimes done by school M&O departments always pose a high risk of lead exposure above the PEL, even if they are done only for short periods of time. These tasks include dry scraping and dry sanding of lead-painted surfaces, sandblasting, welding, and torch burning. Cal/OSHA considers these trigger tasks because they automatically trigger special requirements of the Lead in Construction standard. For more information on trigger tasks, see Chapter 6. For more information on lead-safe work practices in general, see Chapter 7. 57

68 LEAD-SAFE SCHOOLS The story below illustrates how work practices in California school districts need significant change. Survey Examines School M&O Practices In 1997, DHS surveyed approximately 100 California school business officials about M&O work practices involving lead paint. The survey found that many districts will need to make major changes as they institute leadsafe schools programs. Potentially unsafe work activities are still prevalent in many M&O departments. For example: 59% of districts reported that they sometimes do abrasive blasting (sandblasting, water blasting, etc.). 84% sometimes use dry scraping or dry sanding during paint prep work. 60% sometimes do power sanding or grinding without HEPA attachments on the tools. What Is Lead Abatement? Abatement means any set of measures designed to reduce or eliminate lead hazards or lead-based paint in public or residential buildings. It does not include containment or cleaning. Title 17 spells out certain work practice and training requirements for abatement work which is designed to reduce hazards for at least 20 years, and other requirements for abatement work designed to last for less than 20 years. See Appendix F for a summary of Title 17. What Training Is Needed? 58 Only workers who have received a basic level of training in lead-safe work practices should perform any maintenance work that disturbs lead in paint, soil, or plumbing (even lower risk tasks). High risk lead tasks (and abatement) must be done by workers and supervisors who have received state-accredited training and have become state-certified in lead-related construction work. To become a state-certified Lead Worker, the employee must attend a 24- hour course accredited by the California Department of Health Services

69 CHAPTER 5 ANALYZE MAINTENANCE TASKS (DHS), and then apply to DHS for certification. Lead Supervisors must attend a 40-hour course and then apply to DHS for certification. If your school district decides to have high risk jobs done by district staff, they must be sent to an accredited course. For a list of accredited trainers in your area, contact the DHS Childhood Lead Program or check their website at An alternative is to have high risk and abatement tasks done by outside contractors who have the proper training and certification. The Childhood Lead Program website also has a list of lead-certified contractors. How Can Future Lead Problems Be Prevented? The M&O department should also identify what can be done to prevent future lead problems. For example, deteriorating paint can be avoided by early preventive maintenance repainting more often. Repainting a slightly deteriorated surface may not be a priority today, but work done now can save the school district time and money in the future. Here are some tips from experienced M&O managers: Paint often. Use high quality lead-free paint. Paint as soon as one section begins to deteriorate. Use a color scheme to track the age of paint. Getting a jump on maintenance tasks may seem unrealistic given most school district M&O budgets. Documenting the costs of repairing deteriorated surfaces, particularly when using expensive lead abatement contractors, can support your argument for additional resources to do preventive maintenance now. Parent groups can be allies in arguing for more resources, especially if school surveys indicate serious potential lead hazards that could harm children. Many districts have found that delaying maintenance work significantly increases repair costs. Prevention pays. 59

70 LEAD-SAFE SCHOOLS 60

71 CHAPTER 6 PROVIDE WORKER PROTECTION CHAPTER 6 Provide Worker Protection What Protection Do Workers Need? Another element of a lead-safe schools program is worker protection. Maintenance and Operations (M&O) employees who work around lead must be given necessary protective clothing and equipment, and other steps must be taken to reduce their lead exposure as much as possible. Wherever lead paint is disturbed during maintenance work, Cal/OSHA requires protective measures ranging from coveralls to respirators, depending on the nature of the task. Some protection is needed even if the risk is low. IMPORTANT! Cal/OSHA regulations make it the employer s responsibility to provide all necessary protective clothing and equipment, at no cost to the worker. Chapter 5 explained that Cal/OSHA s Lead in Construction standard applies whenever workers may be exposed to any detectable level of lead in paint. However, Cal/OSHA requires different protective measures and training, depending on how high the exposure is expected to be. Remember that: The Cal/OSHA Action Level is 30 micrograms of lead per cubic meter of air (30 µg/m 3 ), averaged over an 8-hour shift. Worker exposure at or above this level requires certain special precautions. The Cal/OSHA Permissible Exposure Limit (PEL) is 50 µg/m 3, averaged over an 8-hour shift. Worker exposure at or above this level requires even stricter precautions, and workers must be certified by the state. 61

72 LEAD-SAFE SCHOOLS This book defines a high risk maintenance task as one likely to cause lead exposure above the PEL. A summary of the Cal/OSHA Lead in Construction standard appears in Appendix B. The complete standard is available on Cal/OSHA s website at Click on Occupational Safety & Health. Go to Title 8 Regulations, where you can search for the standard (section ) by number. What Protection Is Required? According to Cal/OSHA, many precautions must be taken to protect maintenance employees who disturb lead paint in the course of their work. These precautions can include personal air sampling, respirators, protective clothing, mandatory personal hygiene measures, and medical testing. The chart below summarizes the protective measures that Cal/OSHA requires for proven lower risk and high risk lead tasks. These requirements are explained more completely in the remainder of this chapter. The measures shown as recommended are not necessarily legal requirements, but are generally accepted best practices. Protective Measures at a Glance A lower risk task is one shown by air sampling to be under 50 µg/m 3. A high risk task is 50 µg/m 3 or over. Personal air sampling when work begins Lower risk tasks Required. High risk tasks Required. Respirators Lower risk tasks Not necessary. High risk tasks Required. Protective clothing (gloves coveralls, safety glasses or goggles, and shoe coverings) Lower risk tasks Recommended. High risk tasks Required. 62

73 CHAPTER 6 PROVIDE WORKER PROTECTION Personal hygiene (wash face, hands, and forearms after task; no eating, drinking, or smoking) Lower risk tasks Required. High risk tasks Required. Showers Lower risk tasks Not necessary. High risk tasks Required if feasible; otherwise, washing hands and face is required. Medical testing Lower risk tasks Required at 30 µg/m 3 and above. High risk tasks Required. What Are Trigger Tasks? Some tasks almost always cause lead exposure above the PEL, even if they are done only for short periods of time. Cal/OSHA considers these trigger tasks under the Lead in Construction standard. Doing these tasks automatically triggers special requirements in the standard. You should assume that these tasks cause worker exposure above the PEL and follow all Cal/OSHA requirements for such exposure. For these tasks Cal/OSHA requires many very strict protective measures, and state certification of workers. The only exception is if personal air sampling shows that lead levels are below the PEL. For a complete list of trigger tasks, see the summary of Cal/OSHA s standard in Appendix B. For all trigger tasks, workers must wear an appropriate respirator. The type of respirator needed depends on how much lead is in the air. The Lead in Construction standard explains what respiratory protection is needed for each type of trigger task. There is more on respirators later in this chapter. Where lead coatings or paint are present, assume that the tasks below cause lead exposure above the PEL as shown. Assume exposure of µg/m 3 unless proven otherwise: Manual demolition of structures Manual dry scraping or sanding Heat gun application 63

74 LEAD-SAFE SCHOOLS Cleaning surfaces (sanding, grinding, etc.) with power tools that have dust collection systems. Assume exposure of µg/m 3 unless proven otherwise: Cleaning surfaces (sanding, grinding, etc.) with power tools that do not have dust collection systems (prohibited by HUD) Clean-up of dry expendable abrasives Moving or removing abrasive blasting enclosures. Assume exposure over 2500 µg/m 3 unless proven otherwise: Abrasive blasting Welding Cutting Torch burning (prohibited by HUD). IMPORTANT! Cal/OSHA does not consider wet manual scraping or sanding to be trigger tasks if the scope of the work is small in scale and duration, the work is wet continually, and the employer conducts personal air sampling to determine if there is exposure. What Is Personal Air Sampling? Personal air sampling is required at the beginning of most lead tasks. It measures the amount of lead dust and fumes in the air when employees are working. To test the air, the worker wears a small battery-powered air pump at the waist. This is connected by tubing to a filter cassette attached at the collar. During a full shift of work, the pump draws air from the worker s breathing zone (around the nose and mouth). The dust and fumes in this air are collected on the surface of the filter. The filter is then sent to a laboratory to measure the amount of lead it has collected. A calculation is done to estimate the average amount of airborne lead the worker was exposed to during the shift. This number is expressed in micrograms of lead per cubic meter of air (µg/m 3 ). If the level is below 30 µg/m 3, which is the Cal/OSHA Action Level for lead, no special precautions are required except mandatory hand and face washing and basic worker training. However, the work area 64

75 CHAPTER 6 PROVIDE WORKER PROTECTION should still be protected with plastic sheeting, and warning signs should be posted, as on any lead job. If the level is between the Action Level and the Cal/OSHA Permissible Exposure Limit (PEL) of 50 µg/m 3, some additional precautions are required. These include regular personal air sampling and initial blood lead tests for workers. If the level is above the Action Level for 30 or more days a year, then periodic blood tests are also required. If the level is above the PEL, stricter precautions must be taken to protect workers and the environment. Precautions required at various levels are described throughout this chapter. Is Sampling Always Required? The Cal/OSHA Lead in Construction standard requires that initial personal air sampling be done for every type of task where there is potential for lead exposure. The exceptions to this rule are: If personal air samples were taken within the last 12 months under very similar conditions (same type of task, same type of surface, similar lead paint concentration, same work methods, same environmental conditions, etc.) If you have data to show that a task involves low risk and could not produce exposure above the Action Level. Depending on the results of the initial sampling, it must be repeated as follows: If initial results are below the Action Level, repeat sampling for that type of job once a year. If initial results are between the Action Level and the PEL, repeat sampling every six months until two consecutive samples are below the Action Level. If initial results are above the PEL, repeat sampling every three months until two consecutive samples are below the PEL. IMPORTANT! If personal air sampling is not done, Cal/OSHA says you must assume that all tasks that disturb lead paint can expose a worker to lead above the PEL. Who Should Do Sampling? Personal air sampling requires some training to perform correctly. If you do it yourself you will have to obtain the equipment and be trained by a competent professional. 65

76 LEAD-SAFE SCHOOLS You can also hire an industrial hygienist as a consultant to do the sampling for you. Your school district s workers compensation insurance carrier or Joint Powers Authority (JPA) may also be able to provide this service. What Do Sampling Results Tell You? Personal air sampling is an important tool for finding out: If the job is causing too much lead dust in the air. Results can indicate whether you need to use safer work methods. After making changes, repeat the air sampling to see if your changes have been effective. If workers respiratory protection is adequate. Results can tell you whether workers need to wear respirators and what type they need. (Respirators are required above the PEL.) The higher the air sampling results, the more effective the respirators need to be. If your district is in compliance with the Cal/OSHA standard. The standard sets different requirements, depending on air sampling results. To stay in compliance, you must do air sampling. There are some limitations to personal air sampling: It doesn t measure total lead exposure. Personal air sampling measures the amount of lead in the air that a worker might inhale. It does not measure the amount of lead dust that a worker might swallow while eating, drinking, or smoking. Exposure levels can vary widely from day to day and from worker to worker. Exposure is affected by: The work task and work methods. The length of the shift. The worker s skill level, pace of the work, and tasks being done by other workers nearby. The lead content, thickness, and condition of the paint. Air movement. How well safety practices are followed. Must Workers Be Told Their Exposure Levels? Yes. Employers must notify workers in writing of personal air sampling results within five working days after obtaining them. The notification must be in a language the worker understands. 66

77 CHAPTER 6 PROVIDE WORKER PROTECTION When Do Workers Need Respirators? If personal air sampling finds lead levels above the PEL (50 µg/m 3 ), workers will need to wear respirators. Respirators must also be worn until initial air sampling has been completed for each task if there is reason to believe that exposure could be over the PEL (for example, when doing trigger tasks). In addition, respirators must be given to workers who request them, even if their exposure is below the PEL. HALF-MASK APR (up to 500 µg/m 3 ) FULL-FACE APR (up to 2500 µg/m 3 ) The type of respiratory protection needed depends on how high the lead levels are in the air. The goal of respiratory protection is to reduce a worker s exposure to a level below the PEL. The types of respirators described below are sometimes used on lead jobs. Note that simple dust masks are not acceptable for lead work. One common type of respirator is the air purifying respirator (APR). It uses a filter or cartridge to remove hazardous substances from the air the worker breathes. Different filters or cartridges are needed for different substances. These respirators are available in half-mask and full-face models. For lead tasks, workers need a HEPA (High Efficiency Particulate Air) cartridge, also called a P-100 cartridge. Cal/OSHA allows use of a half-mask APR for exposure up to 500 µg/m 3. It allows use of a full-face APR for exposure up to 2500 µg/m 3. For exposure above 2500 µg/m 3, a different type of respirator is needed. An air supplied respirator provides a separate source of clean air for the worker to breathe from a hose and tank. However, it is unlikely that school maintenance workers would require this type of respirator. If respirators are used, Cal/OSHA requires that a complete, written Respiratory Protection Program be put in place. The program must have guidelines for the proper selection, fitting, use, cleaning, storage, and maintenance of respirators. It must also cover medical qualification to wear respirators and employee training on use and limitations of respirators. Workers must be given respirators free of charge. All respirators must be NIOSH-approved. The Cal/OSHA standard on Respiratory Protection is available on Cal/ OSHA s website at Click on Occupational Safety & Health and search Title 8 Regulations for section FULL-FACE AIR SUPPLIED (above 2500 µg/m 3 ) If you need assistance in setting up your Respiratory Protection Program, check with your school district s workers compensation insurance carrier or Joint Powers Authority (JPA), who may be able to help. More information on Respiratory Protection Programs is also available from the OLPPP website at 67

78 LEAD-SAFE SCHOOLS What Protective Clothing Do Workers Need? Regardless of the level of exposure, it is a good practice for workers to wear protective clothing when working around lead. Although lead cannot enter the body through the skin, it can easily travel to the worker s home, or to other areas of the school, on clothes. Street clothes need to be protected. Protective clothing includes coveralls or disposable clothing worn only for the job. It may also include safety glasses or goggles for protection from dust. IMPORTANT! Remember that shoes track lead dust around as well. For this reason, disposable non-skid shoe coverings are recommended. What Personal Hygiene Measures Are Required? Whenever a worker does a lead maintenance task, regardless of the level of exposure, he or she must be required to wash face, hands, and forearms when leaving the work area. If necessary provide portable washing facilities. Nail brushes are recommended for thoroughly cleaning hands and fingernails. Washing should be required before breaks, lunch, and going home. Eating, drinking, and smoking must be prohibited in the work area. This reduces the risk that workers will accidentally swallow lead dust. What Medical Tests Do Workers Need? The Cal/OSHA Lead in Construction standard requires that some workers who are exposed to lead receive blood tests and other medical services. In this case, the employer must establish a comprehensive Medical Surveillance Program. A Medical Surveillance Program helps protect workers and prevent lead poisoning by: Identifying workers with high exposure Detecting the early stages of illness in workers Reducing sources of workplace lead exposure Educating workers on the effects of lead and how to avoid exposure. 68

79 CHAPTER 6 PROVIDE WORKER PROTECTION Who Should Be in a Medical Surveillance Program? According to Cal/OSHA, employers must set up a Medical Surveillance Program for workers who are exposed to lead in the air at or above the Action Level of 30 µg/m 3 for more than 30 days in any consecutive 12-month period. A Medical Surveillance Program must be supervised by a qualified physician in consultation with the employer. The physician should be familiar with the health effects of lead and Cal/OSHA medical surveillance requirements. Employers may use clinics and other health care facilities with which they have existing contracts for other services, provided that personnel have the required qualifications. To locate an occupational health clinic, check the website or the DHS OLPPP website at (Also see Appendix I.) Although school maintenance workers are unlikely to have exposure levels that require medical surveillance, a brief summary of the legal requirements appears below. What s Included in a Medical Surveillance Program? Medical surveillance must include: Blood Tests. As explained in Chapter 2, there are two tests currently used to monitor the amount and effect of lead exposure the Blood Lead Level (BLL) test and the Zinc Protoporphyrin (ZPP) test. Both can be done with the same blood sample. Results are reported in micrograms of lead per deciliter of blood (µg/dl). Blood testing is sometimes called biological monitoring. Cal/OSHA requires initial baseline BLL and ZPP tests when employees begin lead work. Workers who may be exposed at or above the Action Level for even one day must receive baseline blood tests. Baseline tests are also required for anyone before doing a Cal/ OSHA trigger task. Workers exposed at or above the Action Level for more than 30 days in any consecutive 12-month period must have further tests. They must be tested at least every 2 months for the first 6 months, and then every 6 months thereafter. The worker, employer, and physician must review BLL and ZPP test results to determine the degree of exposure and to decide if the worker needs special medical treatment or removal from further lead exposure. 69

80 LEAD-SAFE SCHOOLS Medical Exams. Cal/OSHA requires initial and periodic medical exams if a worker s BLL is at or above 40 µg/dl. Medical exams must also be offered to any worker who reports signs or symptoms of lead poisoning, who requests medical advice related to conception and pregnancy, or who has difficulty breathing while wearing a respirator. Medical Removal Protection (MRP). In some situations, workers must be temporarily removed from lead exposure. Cal/OSHA requires medical removal whenever a blood test indicates a BLL of 50 µg/dl or higher. A physician can also remove a worker with a BLL less than 50 µg/dl if the worker has symptoms of lead poisoning, is pregnant, or has certain other medical conditions. When medical removal is ordered, the worker may not be exposed to any lead at or above the Action Level. Whether and when to begin and end MRP is a medical decision that must be made by a physician. The worker must receive full pay and benefits during the temporary removal, but can be assigned to work in lead-free areas. Worker Notification. Cal/OSHA requires that workers be notified of their blood test results in writing within five working days after the employer receives them. They must also be given general information about lead that helps them understand the blood test results. The California Department of Health Services has literature available in English, Spanish, and Chinese that school districts can use to comply with this requirement. Check the OLPPP website at (Also see Appendix I.) Medical Records. All medical records must be kept confidential and maintained for at least the duration of employment plus 30 years. Workers have the right to see and copy their own medical records. 70

81 CHAPTER 6 PROVIDE WORKER PROTECTION CHAPTER 7 Use Safe Work Practices Are Special Work Practices Needed for Lead Tasks? Yes. Safe work practices are probably the most important element of a leadsafe schools program. Special work practices for lead tasks include restricting access to the work area, using plastic sheeting to contain lead dust and chips, wetting the work surface to keep dust down, using power tools with HEPA filters, cleaning up properly, and disposing of hazardous waste in a safe manner. Whenever lead paint is disturbed during maintenance work, following leadsafe work practices will help protect both workers and children. Take precautions even if the task presents a low level of risk. Remember that: Even low level exposure to lead can be hazardous, especially for children. Unsafe work practices can result in higher exposure than if intact paint had been left alone. Cal/OSHA s Lead in Construction standard requires different work practices for different types of tasks, depending on how high a worker s exposure is expected to be. As Chapter 5 explained: The Cal/OSHA Action Level is 30 micrograms of lead per cubic meter of air (30 µg/m 3 ). If a task may expose workers at or above this level, special work practices are required to keep exposure as low as possible. 71

82 LEAD-SAFE SCHOOLS The Cal/OSHA Permissible Exposure Limit (PEL) is 50 µg/m 3. If a task may expose a worker at or above this level, work practices which provide even greater protection are required. Workers must also be state certified as explained in Chapter 8. This Guide defines a high risk task as one likely to cause lead exposure above the PEL. This includes tasks defined by Cal/OSHA as trigger tasks, until air sampling is done to determine actual exposure level. A summary of the Cal/OSHA Lead in Construction standard appears in Appendix B. The complete standard is available on Cal/OSHA s website at Click on Occupational Safety & Health and search Title 8 Regulations for section Certain lead-safe work practices are also mandated by EPA, by DHS s Title 17, and by HUD. These are primarily designed to prevent lead work from contaminating surrounding areas. The section below summarizes the work practices that Cal/OSHA, EPA, DHS, or HUD require for lower risk and high risk lead tasks. These requirements are explained more completely later in this chapter. The measures shown as recommended are not necessarily legal requirements, but are generally accepted best practices. Lead-Safe Work Practices at a Glance A lower risk task is one shown by air sampling to be under 50 µg/m 3. A high risk task is 50 µg/m 3 or over. Containment Restrict access to work area Lower risk tasks Required. Higher risk tasks Required. Post warning signs Lower risk tasks Interior work: Recommended at entrance to room. Exterior work: Recommended on building and at work perimeter. High risk tasks Interior and exterior work: Required by Cal/OSHA at perimeter of the regulated area. 72

83 CHAPTER 7 USE SAFE WORK PRACTICES Use plastic sheeting around work area Lower risk tasks Interior: Poly sheeting (at least 4 mil thick) on floor, 5 feet from work area in all directions, taped to the wall. Exterior: Sheeting 10 feet from work area in all directions, secured with weights. Close nearby windows or cover with plastic. Control water runoff. High risk tasks Interior: two layers of sheeting on whole floor, taped to the wall. Have simple airlock at door or tape door shut. Exterior: Sheeting feet in all directions, taped to the building and secured with weights. Seal windows within 20 feet. May need vertical containment. Control water runoff. Protect items in work area Lower risk tasks Remove items within 5 feet, or cover and secure them. High risk tasks Interior: Remove items, or cover and secure them. Exterior: Remove toys and play equipment. Cover sandboxes and landscaping within 20 feet of work area. Shut down HVAC system Lower risk tasks Interior: Shut down heating, ventilation, and air conditioning (HVAC) vents within 5 feet of work area. Use proper lockout/tagout procedures if necessary. High risk tasks Interior: Shut down entire HVAC system and seal vents near work area with plastic. Provide alternate ventilation if needed. Use proper lockout/tagout procedures. Work Methods Work wet All tasks Use wet methods, except near electrical circuits or equipment. Use HEPA attachments on power tools (sanders, etc.) Lower risk tasks Not applicable. Using power tools on leadpainted surfaces is always high risk and is defined by Cal/OSHA as a trigger task. High risk tasks Required. 73

84 LEAD-SAFE SCHOOLS Cleanup and Disposal Clean work areas Lower risk tasks Clean indoor and outdoor work areas daily. Do not allow children or others to have access to work area after the work day if possible. Interior: Wet wash with lead-specific or other suitable detergent around work area (2 feet beyond area originally protected by plastic sheeting). Exterior: Remove all visible paint chips or debris. High risk tasks Clean indoor and outdoor work areas daily. Do not allow children or others to have access to work area until dust wipe samples have passed required clearance levels. Interior: Clean entire work area HEPA vacuum, then wet wash, then HEPA vacuum again. Exterior: Remove all visible paint chips or debris. Check safety of area after work is completed Lower risk tasks Visual examination. Dust wipe sampling recommended on 5% of tasks to check effectiveness of containment and work practices. High risk tasks Interior: For abatement only, clearance dust wipe sampling is required after all tasks. Exterior: Visual examination required, and clearance dust wipe samples on exterior floors and horizontal window surfaces. Dispose of waste safely Lower risk tasks Keep hazardous and non-hazardous waste separated. Depending on amount of hazardous waste and its lead content, may have to transport to a licensed collection facility. This is less likely for lower risk tasks although lead paint debris is hazardous. High risk tasks Keep hazardous and non-hazardous waste separated. Depending on amount of hazardous waste and its lead content, may have to transport to a licensed collection facility. 74

85 CHAPTER 7 USE SAFE WORK PRACTICES How Do You Set Up a Lead Maintenance Job? Plan all maintenance work involving lead carefully. Consider what materials and tools you will need, what protective clothing and equipment are required, what work methods you will use, and how you will clean up the area after work is done. Always use containment! Containment is a system, process, or barrier that is used to contain lead hazards inside a work area. It can range from warning signs, plastic sheeting, and special work procedures (for lower risk jobs) to full enclosure (for high risk or abatement jobs). This chapter describes the steps in a system of containment. Also, before work begins, pay special attention to the debris and other waste that will be generated. Since the safe disposal of hazardous waste is costly and time consuming, plan the work so that the amount of hazardous waste is kept to a minimum right from the start. Also keep hazardous and nonhazardous waste materials separated at all times. (There is more information on waste disposal later in this chapter.) After you have planned the work, follow these steps to set up the job: 1. Assemble Your Materials and Equipment Regardless of the level of risk, you will need certain essential materials and equipment. It may be helpful to have a special Maintenance and Operations lead cart or carrier to transport these items. The following materials should be available. Use items in the list below only once: Disposable nonskid shoe coverings to wear in the work area. Disposable gloves appropriate for the job. Plastic sheeting (at least 4-mil polyethylene). Non-destructive blue tape to secure the plastic sheeting (this will not damage painted surfaces). Damp rags to clean up dust and debris. Clean cloths and paper towels. Plastic bags for disposing of contaminated items. Hazardous waste labels for bags if needed. 75

86 LEAD-SAFE SCHOOLS Disposable string mop head to clean large areas. Detergent or other appropriate cleaning solution for lead. Towelettes for cleaning hands and face. The following materials can be reused if they have been properly cleaned since their last use: Signs and yellow caution tape. Spray bottle or commercial sprayer. Scraper and utility knife to remove loose paint. Dust pan for collecting wet debris into plastic bags. Mop handle. Safety glasses, goggles, or a face shield. For high risk lead tasks, you will also need: Properly selected and fitted respirator with correct filter (HEPA or P-100). Consult your Respiratory Protection Program manager. Disposable coveralls (recommended even for lower risk lead work). Vacuum cleaner with a HEPA filter (recommended for all lead work but especially for high risk tasks). 2. Restrict Access to the Work Area Only workers who are trained and directly involved in the lead maintenance task should be allowed near the work area. Make special efforts to keep children out. Always: Schedule the work when children won t come near the site. Put up warning signs. Put up yellow caution tape around the work area. If caution tape is not effective in keeping children out, erect temporary physical barriers. 76

87 CHAPTER 7 USE SAFE WORK PRACTICES 3. Use Plastic Sheeting to Contain Lead Dust and Paint Chips One of the most important ways to prevent lead contamination is always to use disposable plastic sheeting (or poly for polyethylene plastic) on the floor or ground around the work area. Use at least 4 mil sheeting. This catches dust and chips as they fall during the work. The plastic contains the lead dust inside the work area and makes it much easier to clean up afterwards. Containment like this should be used for every lead task, no matter how small. Before starting work, break the task down into steps. Assess what debris will result from each step and plan your containment accordingly. Lower Risk Tasks For good containment on indoor tasks, lay the poly so it extends at least five feet in all directions from the work area. Secure it to the wall with nondestructive (blue) tape or staples. Move or cover furniture and other nearby items that could be contaminated by lead dust or chips. Take special care to protect carpets. It is nearly impossible to remove lead dust from carpets once they become contaminated. If the work is to be done on the ceiling, the entire floor should be covered with plastic. Run the plastic a short way up onto the walls and seal it with tape. Be careful working in an area covered with plastic sheeting. You may slip, trip, or fall. Sheeting should be cut out around the ladder feet so that ladders have a firm footing. Tape the sheeting to the ladder feet to preserve good containment. For lower risk outdoor tasks, extend poly ten feet in all directions and secure it with weights. Also cover bushes, landscaping, and any other nearby objects with sheeting or scaffold netting (black mesh). Secure these covers. Cover and seal building windows with plastic sheeting and tape. For very low risk tasks you can simply close all nearby windows. If it s windy when outdoor lead work is scheduled, postpone the work until the wind will no longer blow paint chips around. If it starts to rain, stop work immediately and clean up. 77

88 LEAD-SAFE SCHOOLS High Risk Tasks Containment for a high risk task usually involves putting more plastic down. For indoor tasks, the whole floor of the room should be covered with two layers of poly. That way, the top layer can be removed at the end of the day without contaminating the floor. Put a new top layer down before beginning work the next day. Seal the poly to the wall with non-destructive (blue) tape. Doorways and windows should be sealed. If workers need to use doorways to enter and exit, construct an airlock flap using double sheets of plastic with slits on opposite sides. An airlock can be built by taping one sheet of poly, the size of the door frame, across the top and down the right side of the frame. Then tape a second sheet of poly, the same size, across the top and down the left side of the frame. You enter between the two sheets. For high risk outdoor tasks, extend poly at least ten feet in all directions and secure it. Extend the poly farther (up to 20 feet) if working at a height (for example, on the side of a building). You may need to build a vertical containment to control the dust on some outdoor projects. (Scaffolding hung with black mesh netting is often used.) Seal the windows within 20 feet of the work area. Water Runoff If you are using water during lead work, the water runoff may be contaminated by lead paint or chips. Contain the water by rolling the edges of the poly on all sides around 2x4 s or something similar, creating an area about two inches deep to hold water. This is called a berm. At the end of each work day collect the contaminated water with a special HEPA vacuum designed to pick up water, or with a mop. Dispose of the water as hazardous waste. Then roll up the poly, seal it with tape, and dispose of it properly. 4. Turn Off HVAC System or Seal Vents For lower risk indoor lead tasks, shut down heating, ventilation, and air conditioning (HVAC) vents within five feet. The air flow could blow dust around. For higher risk tasks, also seal the vents with plastic sheeting. This helps prevent the lead dust from spreading to other rooms. 78

89 CHAPTER 7 USE SAFE WORK PRACTICES For a very high risk task, shut down the entire HVAC system and seal vents with sheeting. Depending on your particular HVAC system, shutting down may involve turning off a switch with a key, or resetting computerized controls. Regardless of the type of system, take steps to ensure that no one can accidently restart it. Use proper lockout/tagout procedures. What Work Methods Should Be Used for Lead Tasks? Use safe work methods when doing any maintenance task involving lead. The safest methods keep lead dust to a minimum so children and workers won t be exposed. What Is Working Wet? Working wet is a key lead-safe method. Dust levels can be kept low by keeping the surface damp while working. Mist the area with a spray bottle or commercial sprayer. Mist continuously throughout the course of the work. Allow for the water to soak into the material. Keep lead debris and chips wet, or clean them up before they dry. Be careful not to use too much water, which could cause runoff and damage to the building. Remember you want the paint wet, but you do not want pools of water on the floor. IMPORTANT! Electricity and water are a deadly combination. The only time wet methods are not recommended is when working with electrical equipment or around electrical outlets. Never use water around outlets or electrical boxes, whether the power is on or off. Never use water around any live wires. Watch out for concealed wiring in walls or ceilings. What s the Safest Way To Scrape Paint? To remove small amounts of lead paint, first wet the surface with the sprayer, and then use a putty knife or scraper. Scrape the loose paint slowly. Sometimes edges will need to be smoothed or feathered for proper surface preparation. Carefully chip or wet-sand the edges until no loose paint remains on the surface. Wet-sanding consists of wetting the material continually with the sprayer while sanding. 79

90 LEAD-SAFE SCHOOLS When a small area of paint needs to be removed and the painted surface is undamaged, make a cut around the area to be removed with a utility knife. Wet the work surface and then scrape it, keeping it wet. For example, this method is effective when removing a cabinet or door hinge that has been painted over. Cutting around the hinge will reduce the chance of chipping the paint, and will also make removal of the hinge much easier. Scraping paint from larger areas may be a high risk task requiring special precautions. Are Special Vacuum Cleaners Needed for Lead Work? Yes. Always use a HEPA vacuum for lead work. This is an industrial strength vacuum cleaner with a HEPA filter. HEPA stands for High Efficiency Particulate Air. HEPA filters can catch lead dust, but regular shop vac filters cannot. A shop vac just blows the lead back out into the room. Most HEPA vacuums have three filters: a pre-filter, a main filter, and one or more HEPA filters. Debris is sucked through the hose into the vacuum bag. The air and dust pass through the prefilter, the main filter, and then the HEPA filter. The HEPA filter captures lead dust before the air is released back into the work area. 80

91 CHAPTER 7 USE SAFE WORK PRACTICES How Do You Use a HEPA Vacuum? 1. Lightly mist the area with water to keep dust levels down. If your HEPA vacuum is not a wet vacuum, do not vacuum up pools of water. Read the manufacturer s instructions for proper use. 2. Vacuum slowly. Remember that lead dust sticks to surfaces. If you go slowly the HEPA vacuum can pick up all or most of the lead dust. 3. HEPA vacuum, always in one direction only, from the top down, and from the farthest parts of the work area towards the center. Use special vacuum attachments for hard to reach places. If HEPA vacuuming a carpet, use a carpet beater attachment. 4. After use, clean the outside of the HEPA vacuum by wet wiping. How Do You Maintain a HEPA Vacuum? Check the vacuum regularly for damaged wires, worn gaskets and switches, torn vacuum bag (if present), and damaged or clogged filters. Check the prefilter often for dust and debris clogs. Change filters when necessary. Use only parts and filters that are the same make as the originals. Never use shop vacuum parts on a HEPA vacuum. Removing and replacing HEPA filters, prefilters, bags, and parts should be treated as high risk tasks. The HEPA filter especially will be full of lead dust. Work in an enclosed area away from people. Seal off the area. Spread a poly containment for at least 5 feet. Use two layers of poly taped and sealed on top of each other. Wear protective clothing and a respirator. Follow the manufacturer s instructions to remove the HEPA filter and place it in a disposal bag. If the vacuum cleaner bag is also removed, handle it gently and tape the opening closed to seal the bag s contents. Place it in a proper disposal container. Wet wipe the inside and outside of the HEPA vacuum and any attachments. Use a second HEPA vacuum, if available, to clean out the inside of the first vacuum before replacing parts, filters, and bags. Be sure the new filters and bags are seated and fit properly. Then clean up the site with a HEPA vacuum, wet wash and rinse. Dispose of hazardous waste properly. 81

92 LEAD-SAFE SCHOOLS Are Special Power Tools Needed for Lead Work? Yes. For example, power sanding or grinding paint can create very high levels of lead dust, exposing workers and spreading lead contamination. This is always considered a high risk trigger task. If you are going to use power tools, always control the dust using a HEPA vacuum attachment on the tool. The tool is attached by a hose to a HEPA vacuum cleaner, as shown at the right. The vacuum has a special filter system to capture fine lead dust and prevent it from being blown around. A HEPA attachment to a power tool captures the paint dust generated by the work before it gets into the air, and collects it in the vacuum bag and filter. Always follow manufacturers instructions for the safe operation and cleaning of HEPA tools. Electrical Safety Remember electrical safety when using electric power tools. You can prevent shocks if you: GFI Use grounded, double-insulated power tools. Use approved 3-prong grounded plug adapters where necessary. Use a Ground Fault Interrupter (GFI), a sensitive switch that can shut off power before you get a shock. Extension cords should have their own GFIs. Keep power tools in excellent condition, and inspect them before use. Don t use broken tools or tools with damaged cords. Store power tools securely to avoid damage. Use non-metal tools where possible. If you use a power tool on a ladder, use a non-metal ladder. Don t use power tools near water. 82

93 CHAPTER 7 USE SAFE WORK PRACTICES Can You Remove Lead Paint With Heat? Yes, but this practice can be very hazardous and requires strict precautions. When removing lead paint that is not already peeling, a heat gun may be used to peel the paint. The heat setting should not exceed 1000 o Fahrenheit or toxic fumes can be released. You must guard against the danger of fire as well. A fire extinguisher must be readily available. When using a heat gun, never blister paint more than necessary. After applying the heat, scrape carefully. Only skilled employees should use a heat gun on lead painted surfaces. Never use an open flame or torch. Remember that using a heat gun is a Cal/OSHA trigger task and only certified workers may do it. Watch out for electrical hazards as well as fire hazards. Can You Remove Lead Paint With Chemicals? Yes. Removing lead paint with chemical strippers is an acceptable method. But beware of serious burn, eye, and skin hazards from these chemicals. Never use methylene chloride strippers because they can cause cancer and other serious health damage. Strippers contain solvents or caustics. Caustic strippers turn paint into a goo that can be scraped off with hand tools. Don t let the goo dry out. Workers need to be protected from caustics with the appropriate gloves, aprons, gauntlets, chemical splash goggles, face shields, and possibly other protective clothing. These should be types which are impervious to the particular caustic being used. They will keep it off the skin. Caustics can cause serious skin and eye damage. There must be emergency eyewashes and safety showers readily accessible. Also restrict access to the work area. Chemical stripping produces waste. Any waste generated is considered hazardous waste and must be disposed of properly. Should the Surface Be Sealed After Paint Removal? Once paint prep work is finished, it is a good idea to put a coat of primer on the surface, especially if some old lead paint remains. The remaining old paint may peel if you don t seal the surface. This would release lead. Peeling can be caused by moisture and is hard to stop once it has begun. What If Carpet Is Contaminated With Lead Dust? The best policy is to prevent contamination of carpeting in the first place. Where possible, avoid using carpets. When carpet has been contaminated with lead dust, cleaning it to remove the dust can be extremely difficult and 83

94 LEAD-SAFE SCHOOLS sometimes impossible. In addition, large quantities of lead dust can accumulate under the carpeting. Dry vacuuming should be prohibited. Even with a HEPA vacuum, it can increase the risk of exposure by bringing the lead dust closer to the carpet surface. If a regular (non-hepa) vacuum is used, lead dust will also escape into the surrounding air out of the vacuum. When performed properly, cleaning carpets by wet methods can effectively remove some lead dust and debris. However, the question of contamination still remains. Use wet methods only to clean up small amounts of lead dust and debris in a small surface area. To wet clean a small section of carpet, move objects from the area. Then collect visible chips or debris by misting and using cloths wetted with a leadspecific cleaning solution. Next, thoroughly mist the area and clean using the solution with rags or sponges. Then rinse the area thoroughly with clean water. Dispose of waste according to hazardous waste regulations. If an area rug or small section of carpet is contaminated, consider simply disposing of it instead of cleaning. To remove small sections of contaminated carpet, move objects from the area. Collect any visible debris as described above. Mist the work area and cut the carpet. Carefully remove and place the pieces in disposal bags. Wet wipe and HEPA vacuum the debris remaining under the removed section. Dispose of waste appropriately. While cleaning or removing a small section of lightly contaminated carpet may be a lower risk task, removing and disposing of heavily contaminated carpeting (especially a large area) is considered high risk. To remove extremely contaminated carpet, high risk procedures must be in place. These include protective clothing, respirators, personal monitoring, personal hygiene, training, certification, and all other requirements of the Cal/OSHA Lead in Construction standard. Also follow all the procedures described in this chapter for posting warning signs, containment, isolating ventilation systems, work practices, and cleanup. Moisten or mist the entire carpet and any dust underneath. Continually mist the carpet as it is rolled or folded up inward on itself. Carefully wrap up the carpet in poly and seal it with duct tape. HEPA vacuum the area, wash it with a lead specific solution, and then rinse thoroughly with clean water. The carpet can also be cut into pieces before removal. Dispose of all waste appropriately. To determine if a particular carpet cleaning or removal task is lower risk or high risk, you may want to get the advice of a certified lead professional. 84

95 CHAPTER 7 USE SAFE WORK PRACTICES Why Are Proper Cleanup and Disposal Important on Lead Jobs? Proper cleanup is crucial after doing a maintenance task that involves lead. Unless cleanup is thorough and complete, large amounts of lead dust can remain, exposing children and other members of the school community. The dust is especially dangerous because it is nearly invisible. How Should Surfaces Be Cleaned After Lead Work? After lead paint has been removed from a surface, the surface will be coated with a residue of lead dust that is very difficult to remove. This lead dust can contaminate the entire area quickly if it is on surfaces that are subject to abrasion, such as windows. Unsafe cleanup methods for lead dust include: Dry sweeping. Using compressed air to blow dust off. Any method that scatters dust into the air. Safer and more effective cleanup methods include HEPA vacuuming and wet cleaning. HEPA vacuums were discussed earlier in this chapter. Wet cleaning methods also help to keep lead dust out of the air. Using wet cleaning methods alone is probably sufficient for lower risk work. If you add a detergent (or a special solution made for lead cleaning) to your water, wet cleaning works even better. The solution attracts and picks up lead particles. To do wet cleaning, you will need two buckets and a premixed lead-specific detergent solution. Leave one bucket empty and fill one with clean water. You can keep the detergent solution in its original container (spray or pour bottle), or in a third bucket. Wet a cloth with cleaning solution and wash all surfaces (including those that had been covered with plastic). Wring out the cloth into the empty bucket. Then wet the cloth with cleaning solution again and repeat the washing. Replace the cloth whenever it gets loaded with dust and debris. Next, dip a new cloth into the water bucket and rinse all the surfaces you just cleaned. This removes detergent solution that can leave a film. Then wring out the cloth into the empty bucket, dip it into the clean water again, and repeat the rinsing. Change the clean water periodically. 85

96 LEAD-SAFE SCHOOLS Trisodium phosphate (TSP) solutions, used widely in the past, cause eye irritation and environmental damage. Some states and all federal projects have banned the use of TSP. However, there are other types of solutions available, some designed specifically for lead. If any solution you use is an irritant, appropriate gloves, and goggles or a face shield, should be provided. There should also be emergency eyewashes and safety showers available. High risk tasks. To clean up after a high risk task, use both a HEPA vacuum and wet cleaning. First use the HEPA vacuum to clean all surfaces in the area. Do not use a regular household vacuum or shop vac. If no HEPA vacuum is available, use wet cleaning alone. After HEPA vacuuming once, wet wipe the area using the wet cleaning method described earlier. Finally, HEPA vacuum the work area again. Carefully wrap up any remaining debris in your plastic sheeting and seal it with tape for disposal. Tools and equipment you have used should also be wet wiped. Any personal protective equipment you have used should be HEPA vacuumed. Also wet wipe the HEPA vacuum itself. What Is Quality Control? Quality control means checking the work area after a lead task to see if you have properly cleaned it. It is important to inspect the area after cleaning up to be sure there is no visible dust or debris remaining. For small, low risk tasks, a visual inspection is probably all that is necessary. For high risk tasks, clearance wipe samples are recommended. (They are required for abatement tasks.) What Is a Clearance Wipe Sample? Wipe sampling is a way of measuring settled lead dust on a surface. After a high risk indoor task is completed and the area has been thoroughly cleaned, clearance wipe samples must be taken by someone who is state certified for this purpose. (There are some exceptions to the certification requirement as explained below.) The process involves carefully wiping a measured surface area with a baby wipe which is then sent to an accredited laboratory. It is called clearance wipe sampling because results must be below a certain level before the area is considered safe (or cleared ) for people to enter. Although not required, you may also want to perform wipe samples on about 5% of your lower risk jobs. This allows you to evaluate how effective your lead-safe work practices and containment are. You can modify work practices, containment, or cleanup methods if the wipe samples show levels that are too high. Wipe sampling for this purpose does not require state certification, although training is needed. 86

97 CHAPTER 7 USE SAFE WORK PRACTICES When wipe sample results come back from the laboratory, they must show levels less than those indicated in the list below for each type of surface or area. If they are equal to or higher than these levels, the area is considered lead contaminated and must be cleaned and tested again before occupancy. Clearance levels are given in micrograms of lead per square foot of area (µg/ft 2 ), or parts per million (ppm) for soil. Clearance Levels Interior floor surfaces 50 µg/ft 2 Interior horizontal window surfaces 250 µg/ft 2 Exterior horizontal window surfaces 800 µg/ft 2 Exterior floor surfaces 800 µg/ft 2 Soil in play areas Soil in other areas 400 ppm 1,000 ppm Title 17, Section How Should You Dispose of Waste From Lead Work? After cleaning up, you must dispose of the waste that was generated by the lead work. This waste may be either hazardous or non-hazardous, depending on how much lead is in it. If the waste is hazardous, there are strict rules governing how and where you can dispose of it. Waste is hazardous if it is ignitable, corrosive, toxic, or reactive. Lead waste is in the toxic category. If you use certain paint strippers on a lead job, then that waste may be in both the toxic and corrosive categories. A particular lead job may produce both hazardous and non-hazardous waste. Because a portion of your waste may not be hazardous, it is important to plan ahead to segregate all the various types of waste into waste streams before the job starts. Then you won t need to bear the unnecessary expense of special disposal for the non-hazardous portion of the waste. Waste materials should be physically separated by sorting them into categories of like materials as the job progresses. There are different methods for doing this. Cal/EPA has described a two-category system while HUD describes a more complex four-category system. The two-category system separates the waste stream as shown on the next page. Depending upon the quantity of the waste, it may be economical to dispose of all material in Category A as hazardous waste without testing it, and then test all the waste in Category B to make sure it is not hazardous. 87

98 LEAD-SAFE SCHOOLS Category A Waste Usually Found To Be Hazardous Paint chips and dust. Used HEPA vacuum bags or filters. Solvents, sludge, and waste from chemical stripping. Rags, mops, sponges, and other cleaning materials. Category B Waste That May Be Non-Hazardous Disposable work clothing. Poly (plastic) sheeting if properly cleaned after use (except when used to wrap paint chips). Respirator filters. Carpets, rugs, and padding. Solid building components with intact, unpeeling paint, such as doors, casements, moldings, and jambs. IMPORTANT! The only way to know for sure if waste is hazardous is to have it tested. Keep records of all testing and waste disposal. How Is Waste Tested? In California, a series of tests is used to determine if waste is hazardous. First you must take representative samples of various waste streams that are generated. (How many samples you take and their location is a controversial decision. Contact Cal/EPA for guidance.) The first test that is done is called a Total Threshold Limit Concentration (TTLC) test. If this test shows that the lead concentration for a waste stream is equal to or higher than 1,000 ppm, then that waste stream is hazardous and must be disposed of as hazardous waste. No further testing is needed. If the waste passes the TTLC test as non-hazardous, then another test must be performed. This is called the Waste Extraction Test (WET). This test measures the Soluble Threshold Limit Concentration (STLC). If any sample of your waste shows a STLC of 5 ppm or more, then you have hazardous waste (as defined in California). Contact your designated landfill to see if they require any other tests. Waste being transported outside California will also require further tests. 88

99 CHAPTER 7 USE SAFE WORK PRACTICES Hazardous waste is regulated by the California Environmental Protection Agency s Department of Toxic Substances Control. Regulations are complicated and under constant revision, so always check with the department first. (See Appendix I for contact information.) What If the Waste Is Hazardous? As the generator of the hazardous waste, a school district is legally required to follow certain procedures for proper disposal. How and where to dispose of hazardous waste depends on how much waste is generated each month at each school site. If less than 220 pounds of hazardous waste (of all kinds, not just lead waste) are generated per month per site, the district is considered to be a conditionally exempt small quantity generator. Such generators can transport up to 50 pounds or 5 gallons of waste at a time to a licensed collection facility without obtaining a permit. If more than 220 pounds but less than 2,200 pounds of hazardous waste are generated per month per site you become a small quantity generator. The district must contract with a certified hazardous waste hauler to transport and dispose of the hazardous waste. Certified haulers already have the necessary permits to deal with these larger quantities of waste. A large quantity generator produces over 2,200 pounds of hazardous waste per month. Regardless of the quantity you generate, hazardous waste should be transported and disposed of promptly. You may store up to 220 pounds of hazardous waste without obtaining a permit. If you store more than 220 pounds, then you have 90 days to dispose of it. The 90-day period begins on the first day any hazardous waste is stored. You must get a storage permit to keep hazardous waste more than 90 days. The best and safest policy is to dispose of hazardous waste immediately, avoiding accumulation. Keep hazardous waste separated from non-hazardous waste while you are doing the job and keep the amount of hazardous waste to a minimum if possible. For example, if you use two layers of poly on a high risk job, only the top layer may need to be considered hazardous waste. The bottom layer, if HEPA vacuumed and wet wiped, might be treated as non-hazardous waste. IMPORTANT! Safely disposing of large quantities of hazardous waste can be costly and time consuming. So take the time to plan the job carefully. There are complex waste disposal regulations for all the generator categories above. For more information about hazardous waste regulations, contact the California EPA Department of Toxic Substances Control office near you. 89

100 LEAD-SAFE SCHOOLS Check city and county ordinances for any additional requirements governing the disposal of hazardous waste. Cities and counties may also have assistance programs that can help. What About Waste Water From a Lead Job? Disposing of lead-contaminated water after a job is a difficult issue. Typical procedures to reduce the contamination or the volume of the waste water include filtering and letting the lead settle out in a holding tank. This is considered a treatment in California, and is subject to strict regulations. At the very least, Cal/EPA must be notified before you begin if you plan such a procedure. 90

101 CHAPTER 8 TRAIN WORKERS CHAPTER 8 Train Workers Who Should Be Trained? Training is a key element of a lead-safe schools program. Maintenance and Operations (M&O) workers need to understand lead health and safety issues and the specialized work practices they should follow. All employees who work around lead need some amount of training. Training is required by several California laws and regulations for everyone whose work may result in lead exposure. The amount and type of training required depends on the level of exposure the worker is likely to encounter. Decide what level of training and information is appropriate for: Custodians. Whether or not custodians in your district do maintenance tasks that could disturb lead, all custodians need a basic level of lead awareness training. Maintenance Workers and Supervisors. In most school districts, this is the group most at risk. These workers will need thorough training in lead-safe work practices, since some of their usual tasks may involve lead exposure. If maintenance workers and supervisors are involved in high risk lead jobs, they will require advanced training and state certification. Teachers, Administrators, and Parents. The whole school community should be made aware of lead and its hazards. Educating everyone about lead can help build acceptance of your lead-safe schools program. Emphasize that teachers and parents should never disturb lead paint. 91

102 LEAD-SAFE SCHOOLS The following sections describe the training required by law for various levels of work involving lead. Summaries of the California laws and regulations mentioned appear in Appendices B F. What Training Do School Custodians Need? Job tasks of school custodians vary widely in California. In some school districts custodians never do tasks that disturb lead paint, but in other districts their job descriptions do include such tasks. For example, some custodians may do basic maintenance work like minor repairs or painting. Your lead-safe schools program should determine the specific tasks that your custodians typically perform. This will help you decide who needs what level of training. Even those custodians who never do lead maintenance tasks need at least awareness level training. This basic introduction to lead health and safety issues is required by Cal/OSHA s Hazard Communication standard and Injury and Illness Prevention Program (IIPP) standard. Giving lead training to all custodians is important for another reason. In most California districts, custodians are assigned to a single school and know it well. Thus they can play an important role in identifying potential lead hazards in that school. They can report the hazards to the central M&O office, which can arrange for trained maintenance staff to handle them. Training for custodial staff should focus on preparing them for this important function as well as emphasizing the importance of leaving lead paint undisturbed. At a minimum, awareness level training for custodial staff should include: The health effects of lead exposure for children and adults. How to identify lead hazards in their school. How and where to report any lead hazards they find. How to avoid disturbing lead paint. Any custodian who does maintenance tasks that could disturb lead paint must receive the more advanced Maintenance and Operations level of training. 92

103 CHAPTER 8 TRAIN WORKERS What Training Do Maintenance Workers Need? M&O workers who may disturb lead paint during their work need more detailed training about lead-safe work practices. The primary goal of this level of training is to educate workers about how to minimize their own lead exposure, and how to reduce the chance of contaminating surfaces accessible to children. The training described in this section complies with the training requirements of Cal/OSHA s Lead in Construction standard. This Guide defines it as the M&O level of training. Although Cal/OSHA requires training on the topics shown here only when workers are exposed to lead above the Action Level (30 µg/m 3 ), it is desirable for all M&O workers who may be exposed to lead on the job to receive this training. Note that this M&O training is not sufficient for workers who do high risk lead tasks (exposure above the PEL of 50 µg/m 3 ). These workers need more advanced training and state certification, as explained later in this chapter. This M&O training is also required by the Cal/OSHA Hazard Communication standard and IIPP standard. At a minimum, the M&O level of training should include all topics covered in the awareness training, plus: The Cal/OSHA Lead in Construction standard and its appendices. Tasks that may cause high lead exposure. The purpose, proper selection, fitting, use, and limitations of respirators. Other appropriate personal protective equipment. The health effects of lead exposure, including reproductive effects. Medical surveillance program requirements. The dangers of chelation and why its routine use is prohibited. Engineering controls and lead-safe work practices relevant to the worker s job assignment. Any lead compliance plan currently in effect. Locations of any regulated areas. Workers right to see their own exposure and medical records. 93

104 LEAD-SAFE SCHOOLS What Training Is Available for M&O Departments? A training curriculum has been developed for school custodians and M&O staff by the Lead-Safe Schools Project at the Labor Occupational Health Program, U.C. Berkeley. Portions of the curriculum are appropriate for either the awareness or M&O levels of training just described. To obtain a copy, contact the Lead-Safe Schools Project or the Childhood Lead Poisoning Prevention Branch of the California Department of Health Services. Note that this curriculum does not cover topics required for state lead certification. The chart below summarizes how training needs depend on the level of workers potential exposure to lead. Awareness Level M&O Level Certified Level No Jobs That Disturb Lead YES no no Potential Exposure Under PEL YES YES no Measured Exposure Over PEL YES YES YES IMPORTANT! The only way to know exposure levels for sure is to do personal air sampling. What Training Is Needed for High Risk Tasks? Whenever a school M&O department does high risk lead tasks, the individuals involved must be certified by the state, whether they are school staff or outside contractors. There are five categories of certification, with different training and experience requirements: Lead Worker, Lead Supervisor, Lead Project Monitor, Lead Project Designer, and Lead Inspector/Assessor. For more information on certification requirements, check the website A high risk task is one that falls into either of these categories: It exposes workers to lead dust or fumes that have been measured, and found to be above the Cal/OSHA Permissible Exposure Limit (PEL) of 50 µg/m 3. It is lead abatement work that is designed to reduce a lead hazard for a minimum of 20 years. For more information see Chapter 6. 94

105 CHAPTER 8 TRAIN WORKERS Certified Lead Worker Training Workers who do high risk tasks must receive specialized training and be certified by the state as Lead Workers. Certification can be obtained only by attending a 24-hour Lead Worker course given by a training provider who is accredited by DHS. For an up-to-date list of accredited training providers, check the website Certified Lead Worker training must include issues such as (partial list): History of the use of lead and lead paint in buildings. Health effects of lead exposure for children and adults. Lead poisoning symptoms, diagnosis, and medical treatment. Respiratory protection programs, including types, selection, inspection, maintenance, storage, and fit testing of respirators. Selection and use of personal protective clothing. Sampling methods for lead in paint, dust, and soil. Containment and barrier systems in lead work. Administrative and engineering controls. Work practices. Waste characterization and disposal. Personal hygiene. Medical monitoring of workers. This training is required by the Cal/OSHA Lead in Construction standard, the Lead-Safe Schools Protection Act, and Title 17 of the California Code of Regulations. IMPORTANT! California public elementary schools and childcare facilities are required by the Lead-Safe Schools Protection Act to use only DHScertified Lead Workers and Lead Supervisors when abating lead hazards. Failure to use DHS-certified personnel for abatement can also result in a Cal/OSHA citation. 95

106 LEAD-SAFE SCHOOLS Certified Lead Supervisor Training Maintenance supervisors must also be certified if their staff do high risk lead tasks. This level of certification can be obtained only by attending a 40-hour Lead Supervisor course given by a training provider accredited by DHS and passing a state exam. One year of experience as a Certified Lead Worker, or two years of experience in lead-related construction, are also required. Supervisors duties typically include enforcing lead-safe work practices, scheduling and coordinating work, and arranging for proper disposal of lead waste. At a minimum, Certified Lead Supervisor training includes all the elements included in Certified Lead Worker training, plus: Exposure assessment, including paint chip collection and personal air sampling. Specific job tasks on lead-related construction projects. Supervision and project monitoring issues. Lead Project Monitor Training Lead Project Monitors oversee lead-related construction work to ensure compliance with job specifications and the law. They are usually employed only on large projects. Their duties typically include: Working with consultants, industrial hygienists, journeymen, engineers, and others to develop the project specifications. Checking personal air sampling results to assess workers exposure levels. Checking dust wipe samples to ensure adequacy of containment. Conducting clearance testing at the end of each project to see if any lead contamination remains. Checking work activities for compliance with federal, state, and local regulations. Certification as a Lead Project Monitor requires a 40-hour course and passing a state exam. There are also education and experience requirements. 96

107 CHAPTER 8 TRAIN WORKERS Lead Project Designer Training Lead Project Designers prepare specifications, detailed designs, and cost estimates for lead-related construction projects. They are usually employed only on large projects. Their duties typically include: Visiting the site and reviewing inspection reports to select the proper abatement, clearance, and lead waste disposal methods. Working with consultants, industrial hygienists, journeymen, engineers, and others to develop the project specifications. Preparing project cost estimates and suggesting strategies for reducing costs. To be certified as a Lead Project Designer, it is necessary to attend a 40-hour Construction Supervision and Project Monitoring course and a 16-hour Construction Project Design course. Project Designers must also meet certain education and experience requirements and pass a state exam. Lead Inspector/Assessor Training Lead Inspector/Assessors inspect buildings and other areas for lead. They also assess the extent of lead hazards. This level of certification is recommended for anyone responsible for design and implementation of a school district s lead-safe schools program. Duties typically include: Conducting visual inspections to examine the condition of painted surfaces and the location of lead hazards. Taking paint chip, dust, soil, or water samples for testing. Using an X-ray Fluorescence (XRF) machine to test painted surfaces for lead. Interpreting laboratory and XRF test results. Preparing reports on the extent of lead hazards and the risks of lead poisoning. Recommending cost effective ways to safely handle lead hazards. Taking clearance samples. Certification as a Lead Inspector/Assessor requires a 40-hour course and passing a state exam. There are also education and experience requirements. 97

108 LEAD-SAFE SCHOOLS What Can Certified Personnel Do on a Lead Project? The table below, provided by DHS, shows what job responsibilities are permitted depending on a person s level of certification. Abatement Work Abatement Planning Hazard Evaluations Clearance Inspections Certified Lead Worker YES no no no Certified Lead Supervisor YES YES no no Certified Lead Project Monitor no YES no YES Certified Lead Projector Designer no YES no no Certified Lead Inspector/Assessor no no YES YES The following definitions are provided for guidance. They are based on Title 17. Abatement: Any set of measures designed to reduce or eliminate lead hazards or lead-based paint in public and residential buildings. Does not include containment or cleaning. Abatement which is designed to reduce lead paint or other lead hazards for a minimum of twenty years requires statecertified supervisors and state-certified workers, among other requirements. Clearance Inspection: An on-site limited investigation (as described by HUD Guidelines) to determine if lead work has been completed as specified, and if the work area is safe to enter. Does not include sampling done to ensure Cal/OSHA compliance or for hazardous waste disposal purposes. Lead Hazard Evaluation: The on-site investigation, for compensation, of lead hazards or lead-based paint, such as a lead inspection, risk assessment, and clearance inspection, in public and residential buildings. Does not include activities intended to determine Cal/OSHA compliance or adequacy of containment. Lead Hazard: Deteriorated lead-based paint, lead contaminated dust, lead contaminated soil, disturbing lead-based paint or presumed lead-based paint without containment, or any other nuisance which may result in persistent and quantifiable lead exposure. 98

109 CHAPTER 8 TRAIN WORKERS Will Workers Job Duties Change? When you institute a lead-safe schools program, job duties of individual workers may change. Revising school maintenance procedures to deal with lead paint will probably change how tasks are done, who does them, and how much training workers need. For example: Some tasks may now need to be done by M&O employees with special training, or by outside contractors. Some M&O staff may need to obtain special training and/ or DHS certification to continue their usual tasks. Some M&O staff will need to be told what tasks they should no longer do, and why. Using lead-safe procedures for maintenance tasks will probably take more time for setup, doing the task, cleanup, and proper waste disposal. It may be necessary to revise written job descriptions to reflect these changes in duties. You may also need to increase maintenance staffing levels. Remember that rewriting job descriptions requires discussing and negotiating these changes with any unions that represent these employees. Also notify workers in writing of the policies and procedures they now have to follow for routine tasks. Reinforce this message through safety meetings and training sessions. If applicable, explain why past practices must be discontinued. In some cases, you may need to postpone certain tasks on the maintenance schedule until workers have obtained the appropriate training, and where needed, DHS certification. Or you may need to use outside leadcertified contractors for these tasks. Do You Need a Lead-Certified Contractor? If your M&O department needs to do work that is considered a high risk task, or abatement work designed to reduce a lead hazard for a minimum of 20 years, you must either have a DHS-certified crew and supervisor on staff or hire a DHS-certified contractor. Here are a few tips for selecting a contractor: Hire only licensed contractors. Ask for the contractor s license number. 99

110 LEAD-SAFE SCHOOLS Hire only contractors that are DHS-certified to perform lead-related construction work. Ask to see the certification cards of the contractor and the contractor s employees (both workers and supervisors). You may verify the certification by checking the website Ask about the contractor s program for controlling worker lead exposure. It should meet Cal/OSHA requirements and include appropriate respiratory protection, periodic testing of workers blood lead levels, and conscientious housekeeping and personal hygiene practices. Ask the contractor what special precautions will be taken to control exposure of children and contamination of school property. Have a written contract that clearly describes the work to be done, and that includes a specific description of the lead-safe procedures the contractor will follow. Specify clearance levels. Ask about the contractor s lead liability insurance. Hire a DHS-certified person to monitor the work. Specify hazardous waste disposal procedures to be followed and document them. For more on contractor requirements, see Appendix G. What Information Do Parents and Teachers Need? 100 Educating parents and other volunteers about the hazards of lead paint should be a part of every school district s lead program. Parent involvement in schools is very important to the success of our children s education. Parent groups work hard to raise money and often devote countless hours of volunteer labor that improves school facilities. In general, these efforts should be encouraged. As districts become increasingly strapped for resources, parents may step in and volunteer to help. For example, they have sometimes done painting or run computer cables to connect their school to the Internet. Bear in mind that these tasks can potentially create lead hazards. Many maintenance issues are too complicated for parents to tackle. School districts should make certain that these volunteer projects do not disturb painted surfaces. The school district could not only face liability for unsafe situations that they create, but may also have to pay high cleanup costs.

111 CHAPTER 8 TRAIN WORKERS Teachers and administrators may be approached by parents offering to do volunteer projects. It is important for school officials to be aware of the potential for lead problems and to communicate these concerns. There should be clear written policies on volunteer work and the entire school community should understand them. Policies should also cover any volunteer maintenance work done by teachers. IMPORTANT! All volunteer projects to improve school facilities should be reviewed and approved by the lead-safe schools program manager. Some school districts have policies that trained maintenance staff will prepare surfaces for repainting. They limit volunteer involvement to the painting itself: M&O Preps Parents Paint A group of parents told a school principal that they wanted to help students paint an ocean mural in one of the classrooms. The principal contacted the M&O department. The head of M&O worked with the parents and prepped the room for painting. He even used primer colors that blended with the proposed mural. He also made sure that the group would use only lead-free paint. The parents and students then painted the mural safely. Several California school districts have formally adopted this policy: volunteers may paint a classroom or other areas of a school, but only after it has been prepped by M&O. The Los Angeles school district, for example, now has a written policy to this effect. Parents can play an important role in voicing concerns about lead problems no one else has noticed. In one California school district, a parent noticed that the exterior of her child s school was being sandblasted. She asked whether the paint had been tested for lead. It turned out that the paint did contain high levels of lead. The sandblasting had to be stopped and the area cleaned up. For sample guidelines on working with parent volunteers, see Appendix H. 101

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113 CHAPTER 9 DOCUMENT & EVALUATE CHAPTER 9 Document & Evaluate the Program What Records Do You Need? Program Plan In managing your lead-safe schools program, it is essential to document what you do by keeping systematic written records. You should also evaluate the program regularly to measure progress and see what needs improving. Documentation and evaluation are as important as any other element of the program. Following are some suggestions for records you will probably need to keep on file. This is not a complete list. You may have additional types of records specific to your district s needs. As you develop your program, use the Program Planning Form discussed in Chapter 3 as a model. It can serve as documentation that each element of a lead-safe schools program has been put in place. It can also help identify and organize the records you need to maintain. When the form has been completed, keep it on file. It will be a useful summary of your entire program. The Program Planning Form follows the six basic elements that have been discussed throughout this Guide. For each element, you will need certain types of documentation. You can note on the Program Planning Form what records you will maintain for each element, and then organize the records themselves the same way. 103

114 LEAD-SAFE SCHOOLS 1. Identify Lead in Schools See the discussion in Chapter 4. Records may include: The completed District Target Schools Form, or your own equivalent form. A completed Building Inventory Form Paint and Soil Hazards for each school, or your own equivalent form. Results of any testing of paint, soil, or water. Records should include sampling locations, date collected, who collected the samples and that person s qualifications, and the testing laboratory s address, phone, and contact person. Work orders to correct identified problems. Show when the work was completed. 2. Analyze Maintenance Tasks See the discussion in Chapter 5. Records may include: Personal air sampling results for workers performing lead tasks. A list of typical M&O tasks and their lead exposure levels, based on sampling. A list of areas where full scale abatement work may be necessary, and what follow-up is planned. 3. Provide Worker Protection See the discussion in Chapter 6. Records may include: A list of personal protective equipment (PPE) available for lead tasks at various risk levels. Keep purchase orders and invoices. Documentation of your Respiratory Protection Program. A complete program, including a written plan, is required by Cal/OSHA if respirators are used. Documentation must be maintained including exposure levels, respirator and cartridge selection, workers respirator training, and respirator maintenance, and other records. Documentation of your Medical Surveillance Program. This program is required by Cal/OSHA if exposure is above the Action Level. Results of workers baseline blood tests, later blood tests, and other lead-related tests must be kept on file. Remember that they are confidential. 104

115 CHAPTER 9 DOCUMENT & EVALUATE 4. Use Safe Work Practices See the discussion in Chapter 7. Records may include: A set of written procedures for all common tasks involving lead. Include both lower risk and high risk tasks. Include information on how compliance will be enforced and who is responsible. Circulate these procedures to all maintenance staff and keep records of who has received them. A list of equipment and supplies available for lead work. Keep purchase orders and invoices. Results of wipe samples done to check safety of work areas after lead tasks are done. Results of testing of waste to determine if it is hazardous. Hazardous waste disposal manifests and landfill receipts. 5. Train Workers See the discussion in Chapter 8. Records may include: A list of workers who have been trained and at what level. For each worker, give name of trainer, date, and training agenda. Copies of any DHS lead certifications that workers have received, and required renewal dates. A list of outside lead contractors used by the district and copies of their DHS certifications. Also keep copies of the contracts. 6. Document and Evaluate the Program Use the sections provided on the Program Plan in Chapter 3 for periodic evaluations of your program. You may want to include wipe testing results and documentation of worker and management feedback you have received. See the discussion of evaluation later in this chapter. 105

116 LEAD-SAFE SCHOOLS Is Recordkeeping Required? Yes. You are required to maintain certain records to comply with the law. Recordkeeping is required by several Cal/OSHA standards, including the Lead in Construction, Respiratory Protection, Hazard Communication, and Injury and Illness Prevention standards. It is also required by EPA regulations, the state Lead-Safe Schools Protection Act, and the state Lead Accreditation and Certification Program (Title 17). For example, air sampling and blood lead test results must be kept on file according to the Cal/ OSHA Lead in Construction standard, and records of worker lead training and certification must be maintained to comply with Title 17. For recordkeeping requirements of the Cal/OSHA standards check the website Click on Occupational Safety & Health and go to Title 8 Regulations. Summaries of some Cal/OSHA standards also appear in Appendices B D of this Guide. For information on recordkeeping under other laws and regulations involving lead, check the website In some cases, recordkeeping requirements overlap. Records maintained to comply with one law or regulation may also help you comply with others. Check individual standards, laws, and regulations to determine how long records must be kept. Often specific retention periods are specified, ranging from less than a year to much longer. How and Where Should Records Be Kept? 106 You will need a system to keep track of all the information your program generates for example, policies, procedures, survey data, and test results. Determine what type of recordkeeping system makes sense for your district. It is best if original records are kept in a central location in the district, such as the lead-safe schools program manager s office. This permits management and staff at the district s headquarters to have easy access to them, and also puts them readily at hand in the event of a regulatory agency inspection. Duplicate copies of some records may also be kept at individual schools so administrators and maintenance staff there can refer to them. If the school district s Maintenance and Operations (M&O) department has its own central facility, copies may also be kept there. Some districts may choose to

117 CHAPTER 9 DOCUMENT & EVALUATE computerize their records and make them immediately available at all locations via a network. Also consider how you will record your information. For example, you may want to adopt standard forms to use for site surveys; tests of paint, soil, and water; personal air sampling results; worker training; work scheduled and completed; and waste disposal. A few sample forms are provided in this Guide, but you may want to create your own forms to meet the special needs of your district. In some cases, existing school district forms, such as M&O work orders, may have to be modified to provide information that your leadsafe schools program needs. How Should You Evaluate Your Program? Your lead-safe schools program will improve only if you periodically evaluate its progress. Try to determine what s working and what isn t, and see what can be done better. But evaluation takes place only if it is built into the program from the beginning. Develop systematic methods and a regular schedule for your evaluation activities. Evaluate the program on every level, from the local school to top administration. For example, on the local level, interview M&O staff to get feedback on how well lead-safe procedures are working: Are lead-safe work methods proving to be practical and workable? Are they causing any problems? Do they seem effective in controlling lead contamination? Do staff feel they have enough training, equipment, and time? Have there been any accidents or mishaps during lead work that resulted in contamination? Why did they happen? What could have been done differently? On the local or district level, involve existing health and safety committees in the evaluation by asking them to consider questions like those above. Also get worker feedback at safety trainings. Look at objective results as well. For example, perform wipe samples after some lead jobs to test the effectiveness of the containment. You may want to do such sampling to compare various work methods and see which are most effective. If lead levels begin to rise on wipe samples, evaluate the procedures used and make necessary changes. Re-training may also be needed. 107

118 LEAD-SAFE SCHOOLS The lead program manager should review the input received from all these sources and try to form an overall picture of how well the program is working. Identify problem areas and target them for improvement. Also share information with managers of similar programs in other districts. The ultimate question for the lead program manager to answer is how well the program is meeting its basic goals protection of children and workers from lead. 108

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121 FORMS Program Planning Form Name of School District Date Program Manager A Program Manager has been appointed. Name Location Title Phone The Program Manager reports to: Name Location Title Phone The Program Manager has DHS lead certification. Level Renewal date 1. Identify Lead in Schools Target schools have been identified (pre-1993 buildings with children 8 and under). Total number of target schools in the district Attach the completed District Target Schools Form. Survey of target schools has been done. Date begun Date completed The survey was conducted by: Name Location Title Phone Attach a sheet with additional names if necessary. Also attach a completed Building Inventory Form Paint and Soil Hazards for each school building surveyed. 111

122 LEAD-SAFE SCHOOLS Program Planning Form page 2 Paint chip samples were collected for testing. (Optional.) Sampling locations and dates Samples collected by Name and phone of laboratory Attach test results and lab chain of custody forms. Soil samples were collected for testing. (Optional.) Attach test results and lab chain of custody forms. Drinking water has been tested at all schools. Name and phone of laboratory Attach test results and lab chain of custody forms. 2. Analyze Maintenance Tasks Personal air sampling has been conducted for each type of lead-related maintenance task. Attach sampling results, lab chain of custody forms, list of workers sampled, calibration information, calculations, etc. Workers have been notified of sampling results. Date notified How notified Typical maintenance tasks have been categorized as either lower risk or high risk based on sampling results and/or other data. Attach list of tasks. 112

123 FORMS Program Planning Form page 3 3. Provide Worker Protection Personal protective equipment (PPE) necessary for lead work has been purchased (booties, goggles, gloves, respirators, etc.). Attach vendor contact information. Workers have been informed of the need for PPE and required personal hygiene measures. Date informed How informed If respirators will be used, a complete written Respiratory Protection Program is in place. Attach written Program. If high risk tasks will be performed, a Medical Surveillance Program is in place. Attach written Program or name, address, and phone of supervising physician. 4. Use Safe Work Practices Written policies and procedures on lead-safe work practices have been developed and distributed to workers. Attach written policies and procedures. Equipment and supplies necessary for lead work have been purchased (caution tape, plastic sheeting, sprayers, detergent, HEPA vacuums, etc.). Attach vendor contact information. Wipe sampling has been conducted on a few jobs to check quality of containment and cleanup. Attach sampling results. 113

124 LEAD-SAFE SCHOOLS Program Planning Form page 4 Policies and procedures on lead waste disposal have been developed. Attach written policies and procedures. 5. Train Workers A training policy has been developed, including training for both present workers and new hires. Attach written policy. Trainers or outside training facilities have been identified. Trainer(s) or facilities Address / phone Type of training offered Workers to be trained have been identified. Attach a sheet with the name of each worker, title, and level of training needed. Also attach dated sign-in sheets for trainings. 6. Document and Evaluate the Program Information on the Lead-Safe Schools Program has been sent to key administrators and M&O managers. The program has been explained to all M&O workers. A system for maintaining records has been developed. 114 A system for periodic evaluation of the program has been developed. A schedule of future actions has been prepared (follow-up lead surveys, worker re-training programs, etc.). Attach schedule.

125 FORMS Lead-Safe Schools Program District Target Schools Form School District Completed By Number of Schools in District Title Use this form to develop a priority list of schools to survey for deteriorated paint and possible lead contamination of soil. Target Schools are those that have children eight and under and were built before List all your target schools at the left. Check Possible Hazards (Paint, Soil) columns if you have information that there may be a problem. Otherwise skip this section. In the Priority column, rank schools high, medium, or low. High priority target schools should be surveyed first. Target School Name Year Built Children Possible Hazards Priority Childcare K 2 Paint Soil Total Number of Target Schools Date Completed 115

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127 FORMS Building Inventory Form Paint and Soil Hazards School Building Date of Survey Address Site Contact and Phone Survey Completed By Title Room or Outdoor Area & Use of Space Possible Hazard Paint Condition Priority Nearby Surfaces to Check High/Medium/Low ( ) Response Needed Follow-up Action & Date Taken ( ) PRIORITY: Rank high/medium/low depending on hazard and accessibility to children eight and under. Page of 117

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131 APPENDIX A DHS REPORT 1998 California Department of Health Services Childhood Lead Poisoning Prevention Branch A Report to the Legislature: Lead Hazards in California s Public Elementary Schools and Child Care Facilities Executive Summary Purpose of the Report In 1992, the California State Legislature approved the Lead-Safe Schools Protection Act (LSSPA) (Education Code, ) in response to concerns about the presence of lead hazards in schools. The Act required the California Department of Health Services (DHS) to conduct a study to determine the prevalence of lead and lead hazards in California s public elementary schools and childcare facilities, to report individual findings to participating schools, to make recommendations on the feasibility and necessity of conducting statewide lead testing in schools, to develop environmental lead testing methods and standards, to evaluate lead abatement technologies, and to work with the California Department of Education (CDE) to develop voluntary guidelines to minimize lead hazards in schools. Beginning in 1994, DHS conducted a study of the extent of lead contamination in paint, soil, and water in California schools. Data were collected from 200 randomly selected schools between 1995 and This report presents the findings of the study to the State Legislature and makes recommendations for ensuring that all California schools are lead-safe. Health Effects of Lead Lead is a highly toxic heavy metal that adversely affects virtually every organ system in the body. Fetuses and young children are particularly susceptible to the effects of lead. The U.S. Centers for Disease Control and Prevention (CDC) has found that lead poisoning remains the most common and societally devastating environmental disease of young children (CDC, 1997). Most children with lead poisoning have no overt symptoms, but can suffer permanent neurological deficits and behavioral problems, including attention deficit disorder and loss of IQ points. Childhood lead poisoning has a significant financial cost as lead poisoned children incur significant medical and special education costs and have reduced lifetime earning potential. 121

132 LEAD-SAFE SCHOOLS Sources of Lead There are numerous sources of lead in the environment, ranging from paint pigments to industrial and hobby materials. Three of the most common sources of lead are paint, soil, and water. Before 1950, lead was commonly added to paint to enhance durability. In 1955, the paint industry adopted a voluntary one percent limit on lead concentration in interior paint. In 1978, the Consumer Product Safety Commission (CPSC) banned the manufacture of most paints containing more than 0.06 percent lead. Any existing lead-based paint that is in poor condition is a potential hazard. Components coated with lead-based paint that abrade one another as they are moved, such as windows and doors, represent the highest potential source of exposure from lead paint. Soil can become contaminated from paint chips and lead-containing dust that falls from nearby structures. Lead is also present in soil as a result of gasoline emissions prior the 1980s when lead was phased out as a gasoline additive. Water can become lead-contaminated when lead leaches from plumbing and fixtures, or when the water supply is contaminated. Plumbing installed before 1930 is considered most likely to contain lead. However, newer plumbing is often connected with lead solder, the use of which was not prohibited until Children at highest risk for lead poisoning are younger than school age. Most children with elevated blood lead levels are exposed to multiple sources of lead at more than one location (CDC, 1997). When a child with high blood lead levels is identified, local public health and environmental health staff investigate possible sources of lead exposure. Nearly always, lead sources in the home environment are identified. Lead hazards at school have not been found to be the primary source of lead in any childhood lead poisoning case in the DHS lead poisoning surveillance system. Study Methods 122 The two goals of the study were (1) to estimate the extent to which lead is a contaminant of paint, soil, and water in California s public elementary schools, and (2) to describe operations and maintenance practices as they may contribute to (or protect against) the generation of lead hazards on public schools grounds. To address the first goal, DHS researchers conducted a survey of paint, soil, and water in a representative sample of 200 of California s public elementary schools and day care facilities. To address the second goal, researchers administered a questionnaire regarding maintenance and operations practices to public schools facilities managers. At each school, paint, soil, and drinking water samples were collected from the oldest building, which was assumed to be most likely to contain lead hazards. A maximum of four interior and seven exterior paint chip samples were collected. Researchers assessed the overall condition of the painted surface from which samples were taken. Wherever possible, paint chip samples were obtained from areas where the paint was visibly deteriorated, as these areas represent the highest potential hazard. A maximum of seven soil samples were taken at each school. Soil samples were collected from within five feet of painted walls or windows, within play areas, and from a location on the school grounds which was as far away from any buildings as possible in order to establish a

133 APPENDIX A DHS REPORT background level. Four drinking water samples were collected from each school: two from an inside outlet and two from an outside outlet. The first sample was taken immediately after the spigot was opened, and the second after the water was allowed to run for 30 seconds. A questionnaire was administered to 83 school facilities managers at a California Association of School Business Officials conference in Participation was voluntary and anonymous. The questionnaire was designed to survey awareness and use of lead-safe work practices, as well as knowledge of and attitudes about lead as an environmental contaminant. Summary of Findings 1. Paint The U.S. Environmental Protection Agency (USEPA) defines lead-based paint as 5000 parts lead per million parts paint (ppm). Given the findings of the study, it is estimated that 77.7 percent of California s public elementary schools and child care centers have been painted with lead-based paint. Lead in paint at schools was found at about the same frequency as has been found in California homes of similar age. Cal/OSHA defines lead-containing paint as paint with any detectable lead. This stringent definition is useful for protecting workers and others when disturbing lead-containing paint with activities like surface preparation for repainting, and where paint is deteriorating. Using this definition, it is likely that 95.8 percent of schools have some lead-containing paint. The study also shows that only 37.8 percent of the schools with some lead-containing paint also have some paint that is deteriorated. Within the representative sample of schools in the study, lead content of paint is significantly and inversely related to school age. Only one paint sample (taken from an interior door) above 5000 ppm was found at any school built after Exterior trim paint tended to have the highest average lead content, followed by (in descending order of lead content) interior trim, interior wall and exterior wall paint. 2. Soil According to study data, it is likely that six percent of California public elementary schools have bare soils with lead levels that exceed the USEPA reference value for bare soil in areas where children play (400 ppm). Soils that contain lead at or above that level are likely to be located close to school buildings and more likely to occur at schools built before It is not possible to determine from study data the source of the lead in the sampled soil. Characterizing soils at any particular school site will require a more detailed sampling protocol than this study could employ, and state-wide applications of study results are limited. 3. Drinking Water USEPA has set the action level for lead in drinking water at 15 parts lead per billion (ppb) parts water. The action recommended by USEPA is to remove the drinking water outlet from service immediately until the lead content falls below the action level. Study data indicate that an estimated 18.1 percent of California schools are likely to have lead in drinking water at or 123

134 LEAD-SAFE SCHOOLS above the federal action level. Lead exceeding this level was found at 10.5% of schools where the sampled outlet had been used within 24 hours of testing. These findings indicate that in some situations drinking water from school water outlets could contribute to children s lead exposure, and demonstrate a need for monitoring lead from drinking water outlets in schools. Water from outlets that have been left standing for 24 hours are generally more likely to contain higher lead levels than water from outlets that have recently been flushed. However, within the study, this flushing procedure did not always reduce lead content to below the action level. The age of the school was not a significant factor in the amount of lead in drinking water. 4. Maintenance and Operations Based on responses to the study questionnaire, it is evident that a majority of facilities managers believe that lead hazards in school pose a significant problem. However, only 11 percent of respondents reported that their school had any lead hazard control program in place. Few reported that facilities managers or their staffs had attended a DHS-accredited lead-related construction training course. Additionally, most of the respondents reported using unsafe work practices for managing lead-containing paint. Seventy-four percent of respondents thought that training in lead-safe work practices would be extremely useful for their district. Conclusions 1. Paint As in housing stock in California and across the nation, lead-containing paint is present in most California public elementary schools and child care facilities. With proper training, resources, and support, it can be managed safely as part of standard maintenance and operations practices. If lead-safe work practices are instituted and continued over time, they are safer, more efficient, and more cost effective than wholesale removal of lead-containing paint. Removing lead-containing paint incorrectly can actually increase the risk of exposure to children. Interim control measures (management in place), is the safest alternative. 2. Soil The lead content of bare soil may be elevated if the soil is close to pre-1940 s painted exterior walls. Simple steps such as limiting access to these areas or permanently covering them can eliminate potential exposure hazards to children. 3. Drinking Water Lead may be present in drinking water in up to one in five of California public elementary schools and child care facilities. A testing and replacement program will identify and eliminate this potential source of exposure. The USEPA standard of 15 ppb has a safety factor built into it. Thus it is very unlikely that a child who drinks tap water with the exceedances which were 124

135 APPENDIX A DHS REPORT found in this study would develop significantly elevated blood lead levels from this source alone. Many of California s public schools have already completed testing of school drinking water outlets. DHS Action Plan The findings of this study require immediate action, and DHS has begun to work with CDE to develop, implement, and support a four-year California Lead-Safe Schools Program to promote safe and cost-effective lead-safe work practices among Local Education Agencies (county and local school districts). The program will concentrate on lead-based paint maintenance practices that will decrease childhood exposures to lead. It will include the following key elements: 1) voluntary leadsafe work practice guidelines for schools, 2) identification of high risk tasks and occupational groups, 3) training programs aimed at reducing exposure risks to children and staff, 4) a timelimited technical assistance and support program, and 5) evaluation. Recommendations These recommendations are designed specifically to address the needs of public elementary schools and child care facilities that are located on public elementary school grounds. They incorporate existing lead-safe procedures considered by HUD and USEPA to be the best practices in the construction and maintenance industries. However, their utility is not limited: they may be applicable in other settings where young children are present on a regular basis. 1. Paint Prioritize deferred maintenance activities to classrooms that house the most vulnerable children. Deteriorated paint that contains lead presents the greatest opportunity for exposing young children to lead hazards. The most vulnerable children in public schools settings are those in pre-kindergarten through grade 2, and those with developmental disabilities. Targeting their classrooms is the surest way to reduce opportunities for exposure to lead, but only if the deferred maintenance activities are conducted when children are not present and if the work area is thoroughly cleaned afterwards. Assume that painted surfaces contain lead and use leadsafe work practices, unless the paint is tested. These practices include using sprayers to mist painted surfaces while sanding to reduce dust, using clean plastic sheeting, avoiding dry sanding and scraping that generates dust, and cleaning thoroughly after work is completed. Lead-safe work practices minimize the production of lead dust and paint chips and minimize contamination of the environment. Keep children, pregnant women, and school pets away from potentially contaminated work areas. 2. Soil Fence off or cover bare soil adjacent to painted exterior walls of buildings constructed prior to 1940 because these areas are likely to contain lead levels that exceed the USEPA recommendation of no more than 400 parts per million lead in bare soils in which children play 125

136 LEAD-SAFE SCHOOLS or garden. Unless they are tested for lead content, soils adjacent to painted exterior walls are not appropriate to use for children s demonstration gardens, rainbow gardens, or other educational activities. These areas should never be used as children s play areas. 3. Water Evaluate the lead content of school drinking water at the outlet following USEPA protocols at schools that have not already done so. The lead content of drinking water was not completely predicted by age of the school, the length of time the water had been standing in the pipes, or by using the USEPA flushing procedure. When lead content exceeds the USEPA action level of 15 parts per billion and USEPA-recommended remedial action does not reduce lead content to below 15 parts per billion, Local Education Agencies should make that outlet inoperable and supply alternative sources of drinking water until lead content is reduced to acceptable levels. 4. Work Practices and Personnel Use lead-safe work practices, and adopt and support the voluntary Lead-Safe Schools Program, once it is in place. This program will protect children and staff, and prevent costly and unnecessary over spending. Program activities should be fully integrated into daily practices so that they become a standard part of regular work activities. Use the expertise of DHS Certified Lead-Related Construction personnel. The Lead-Safe Schools Protection Act of 1992 requires that LEAs use DHS Certified Lead-Related Construction personnel for identifying and abating lead hazards. Always verify certification. Each Lead-Related Construction professional who is properly certified has received a photo identification card from the Department of Health Services. The identification card lists the categories in which the individual is certified, along with expiration dates. This DHS Lead- Related Construction identification card is the only proof of certification that public schools or the public at large should accept. Assure that workers are properly trained. Although existing training materials have not been modified to meet the specific needs of the public school environment, LEAs can use existing guidance and materials to assure that workers who may disturb lead in paint are identified, trained, and (if necessary) that they are DHS Lead-Related Construction Certified. 126

137 APPENDIX B CAL/OSHA LEAD Cal/OSHA Lead in Construction Standard Summary B Cal/OSHA s Lead in Construction standard is found in Title 8 of the California Code of Regulations, Construction Safety Orders, section Note that Cal/OSHA s standard has additional provisions not found in the federal OSHA Lead in Construction standard. Following is a summary of the relevant portions of Cal/OSHA s requirements as of August, For the complete standard, see the website Click on Occupational Safety & Health and go to Title 8 Regulations. (a) Scope This standard covers all construction work where an employee may be exposed to lead, including metallic lead, inorganic lead compounds, and organic lead soaps, but not organic lead compounds. (b) Definitions An airborne lead level of 30 µg/m 3 is called the Action Level (AL). Having airborne lead concentrations at or above the AL triggers certain health and safety measures described in this standard. (c) Permissible Exposure Limit (PEL) The 8-hour Permissible Exposure Limit (PEL) is 50 µg/m 3 of airborne lead. If the work day is longer than 8 hours, the PEL is 400/number of hours worked per day. The employer must ensure that no employee is exposed to lead at concentrations over the PEL. (d) Exposure Assessment Assessment must be performed in all workplaces where employees may be exposed to lead. (d)(2) Protection of Employees During Assessment of Exposure Three sets of specified tasks (often referred to as trigger tasks ) trigger basic protective measures where lead is present, until the employer performs an employee exposure assessment. (Exposure assessment is an initial determination via air monitoring, or previous monitoring of a very similar job within the last 12 months.) For all three sets of tasks, employers are required to provide the following basic protective measures until air monitoring indicates exposure levels are at or below the PEL: Appropriate respiratory protection (type of respirator is specified according to assumed airborne lead level and requirements of Table 1 on page 136). 127

138 LEAD-SAFE SCHOOLS Appropriate personal protective equipment clean work clothes such as coveralls at least weekly (daily if greater than 200 µg/m 3 lead in air); gloves, hats, shoes or disposable shoe coverlets, face shields, vented goggles or other appropriate equipment. Change areas with separate storage facilities for work and street clothes the employer shall assure that employees do not leave the workplace with work clothes or equipment. Hand washing facilities the employer shall assure that employees wash their hands and face at the end of each work shift. Biological monitoring consisting of initial or baseline blood sampling for lead and zinc protoporphyrin (ZPP). Training includes Hazard Communication, respirator and lead training. Lowest Exposure Trigger Tasks: Assume exposures greater than 50 and up to 500 µg/m 3 unless proven otherwise: where lead coatings or paint are present: manual demolition of structures manual scraping (dry) manual sanding (dry) heat gun applications power tool cleaning with dust collection system spray painting with lead any other task where the employer has reason to believe employees may be exposed over the PEL. Medium Exposure Trigger Tasks: Assume exposures greater than 500 and up to 2,500 µg/m 3 unless proven otherwise: use of lead-containing mortar lead burning where lead coatings or paint are present: rivet busting power tool cleaning without dust collection systems cleanup of dry expendable abrasives abrasive blasting enclosure movement and removal 128

139 APPENDIX B CAL/OSHA LEAD Highest Exposure Trigger Tasks: Assume exposures greater than 2,500 µg/m 3 unless proven otherwise: where lead coatings or paint are present: abrasive blasting welding cutting torch burning (d) Exposure Assessment (Air monitoring) When air monitoring is conducted, the employer shall collect full-shift personal samples representative of an employee s regular, daily exposure to lead. Monitoring should include at least one sample for each job classification in each work area either for each shift or for the shift with the highest exposure level. (For the initial determination, the employer may monitor only those employees expected to have the highest exposure levels.) (d)(3) Basis of Initial Determination The basis of initial determination, or initial assessment of employee exposure, will be employee exposure monitoring results and relevant considerations (e.g., observations, complaints) with the following two exceptions: Where the employer has previously monitored for lead exposures, and the data were obtained within the past 12 months during closely similar workplace operations and conditions, the employer may rely on the earlier results; or Where the employer has objective data, demonstrating that a particular product or material containing lead or specific process, operation or activity involving lead cannot result in an employee exposure to lead at or above the AL during processing, use or handling, the employer may rely upon such data instead of implementing initial monitoring. Objective data confirming that materials or surface coatings contain less than 0.06% (600 ppm) of lead may be used to demonstrate that employee exposure will not exceed the AL, as long as every unique surface or material has been sampled and analyzed. Note: Objective data are not permitted to be used for exposure assessment in connection with any of the trigger tasks listed under subsection (d)(2). (d)(6) Frequency of Exposure Assessment If the initial determination shows exposures less than the AL, no further assessment is needed until there has been a change of equipment, process, control, personnel or a new task has been initiated. 129

140 LEAD-SAFE SCHOOLS If the initial determination is at or above the AL but at or below the PEL, then monitoring shall be done at least every six months. If the initial determination is above the PEL, then monitoring shall be done quarterly. (d)(8) Employee Notification Within 5 working days after completion of the exposure assessment, the employer shall notify each employee in writing of the results which represent that employee s airborne lead exposure. (e) Methods of Compliance Exposures over the PEL shall be reduced through engineering, work practice and administrative controls, to the extent feasible. Respirators may be used to supplement other controls. Prior to the commencement of any job where exposures may reach the PEL, the employer shall establish and implement a written compliance program, describing the lead-emitting activities and the means by which exposures will be controlled. The compliance program shall provide for frequent, regular jobsite inspections by a person who is capable of identifying lead hazards and has authorization to take prompt corrective measures. Where mechanical ventilation is used, the employer shall evaluate the performance as necessary to maintain effectiveness. (f) Respiratory Protection Where respirators are used, they shall be selected on the basis of air monitoring results, with the minimum level of respirator as indicated in Table 1 on page 136. Until monitoring results are available, the appropriate respirator is determined according to the assumed exposure associated with the task being performed, as per subsection (d)(2). Where respirators are used, the employer shall institute a complete, written respiratory protection program in accordance with Cal/OSHA s Respiratory Protection standard, The program shall outline procedures for selection, use, training, cleaning and sanitizing, storage, inspection, and maintenance of respirators. The program shall be evaluated by regular inspections requires that any respirators used shall be certified by NIOSH. Also, employers shall perform quantitative or qualitative fit testing of respirators at the time of initial fitting, and at least annually thereafter, for employees wearing tight-fitting facepiece respirators. If an employee exhibits difficulty breathing with the respirator, the employer shall make available a medical examination to determine whether the employee can wear a respirator safely while performing the work. 130

141 APPENDIX B CAL/OSHA LEAD PAPRs (powered air-purifying respirators) must be provided to any employee who requests one, where a PAPR would provide adequate protection as per Table 1. (g) Protective Work Clothing and Equipment When an employee is exposed to lead above the PEL (without regard to whether a respirator is worn), or to lead compounds which may cause irritation, the employer shall provide and assure the employee uses appropriate protective work clothing, such as coveralls or other full-body work clothing, gloves, hats, shoes or shoe coverings, and face shields, goggles or other protective equipment as needed. Work clothing shall be provided at least weekly for employees exposed over the PEL, except daily for those exposed at levels higher than 200 µg/m 3. The employer shall provide for the cleaning or disposal of protective clothing and equipment. Clothing to be laundered must be placed in a closed container, labeled to indicate it contains lead, and the launderer must be notified of the potentially harmful effects of lead exposure. Cleaning of protective clothing or equipment by blowing, shaking or any other means that disperses lead into the air is prohibited. (h) Housekeeping All surfaces shall be maintained as free as practicable of accumulations of lead. Vacuums equipped with toxic dust-removing HEPA filters are the preferred method of cleaning surfaces where lead accumulates. Other types of vacuums may not be used. Shoveling, dry or wet sweeping, and brushing may be used only where HEPA vacuuming has been tried and found to be ineffective. Use of compressed air for cleaning is prohibited, unless there is a ventilation system to capture the dust created by the compressed air. (i) Hygiene Facilities, Practices and Regulated Areas The employer shall assure that all employees exposed to lead above the PEL wash their hands and face prior to eating, drinking, smoking or applying cosmetics. The employer shall provide, for ALL employees exposed to lead, adequate hand washing facilities, and assures (in the absence of shower facilities) that employees wash their hands and face at the end of the work shift. In areas where employees are exposed to lead above the PEL, the employer shall assure that food or beverages are not present or consumed, tobacco products are not present or used and cosmetics are not applied. 131

142 LEAD-SAFE SCHOOLS Employees exposed to lead above the PEL shall be provided with clean change areas with separate storage facilities for work and street clothing, to prevent cross-contamination. The employer shall assure that employees do not leave the workplace wearing any protective clothing or equipment that was worn during the work shift. Shower facilities, soap and towels shall be provided, where feasible, for employees exposed to lead above the PEL, and the employer shall assure that these employees shower at the end of the work shift. Employees exposed to lead above the PEL shall be provided with a clean lunchroom or eating area. The employer shall assure that the lunch area is kept free from lead accumulation and that employees do not enter the lunch area with protective work clothing or equipment that has not been cleaned by vacuuming or other method that limits dispersion of lead dust. Employers shall establish regulated areas, where feasible, wherever employees are exposed above the PEL or performing trigger tasks (subsection (d)(2)). Warning signs shall be posted (subsection (m)), and access shall be restricted to authorized persons. Appropriate protective equipment shall be provided to and worn by employees and other persons who enter the regulated area. (j) Medical Surveillance The employer shall assure that the lead medical program (including all medical examinations and procedures performed) is under the supervision of a licensed physician. The employee has the right to seek a second medical opinion regarding the lead medical evaluation, at the expense of the employer, and if necessary a third physician may be requested to resolve any disagreements between the first two. Prophylactic chelation, the routine use of chelating drugs to lower blood lead levels in persons occupationally exposed to lead, is prohibited. (j)(2) Biological Monitoring Initial blood sampling and analysis for blood lead levels (BLL) and zinc protoporphyrin (ZPP) are required for employees performing any of the specified trigger tasks, or for any employee exposed to an air lead level at or above the AL for at least 1 day. Employees who are or may be exposed at or above the AL for more than 30 days in any consecutive 12 months, must be enrolled in a medical surveillance program, including BLL and ZPP at least every 2 months for the first 6 months, and every 6 months thereafter. Any employee with a BLL at or above 40 µg/dl shall have a BLL and ZPP every two months until two consecutive samples are less than 40 µg/dl. 132

143 APPENDIX B CAL/OSHA LEAD Any employee with a BLL above 50 µg/dl shall receive a follow-up BLL within 2 weeks after the employer receives the results of the first test. For those employees temporarily removed from their jobs involving lead exposure (see subsection (k), Medical Removal Protection), a BLL and ZPP must be provided every month during the removal period. All analysis of blood samples shall be conducted by a laboratory approved by OSHA. The employer shall notify all employees, in writing, of their blood sampling results within 5 working days after receipt of the results. (j)(3) Medical Examinations and Consultations A medical exam shall be provided annually for all employees who had a BLL at or above 40 µg/dl during the preceding 12 months. A medical exam shall be provided to any employee who reports signs or symptoms related to lead poisoning, desires medical advice regarding the effects of lead exposure on the employee s ability to produce a healthy child, is pregnant, or has difficulty breathing while wearing a respirator. A medical exam shall be provided as medically appropriate to any employee removed from his/her usual job involving exposure to lead. A medical exam shall include: detailed work history, with particular attention to past lead exposure; history and physical exam, with particular attention to teeth, gums, hematologic, gastrointestinal, renal, cardiovascular, neurological systems, and pulmonary system if respirators are used; blood pressure measurement; blood sample and analysis including BLL, ZPP, hemoglobin and hematocrit determinations, red cell indices, examination of peripheral smear morphology, blood urea nitrogen, serum creatinine; urinalysis with microscopic examination; pregnancy or male fertility evaluation, if requested by the employee; any other test deemed necessary by the physician. (k) Medical Removal Protection (MRP) (k)(1) Temporary Medical Removal and Return The employer shall remove an employee from work involving exposure to lead at or above the AL on each occasion that a BLL and follow-up test is at or above 50 µg/dl. An employee who has been removed due to an elevated BLL can return to his/her former job after having two consecutive BLLs at or below 40 µg/dl. The employer shall remove an employee from work involving exposure to lead at or above the AL on each occasion that a final medical determination results in a medical 133

144 LEAD-SAFE SCHOOLS finding, determination, or opinion that the employee has a detected medical condition which places the employee at increased risk of material impairment to health from exposure to lead. An employee who has been removed due to a final medical determination can return to his/her former job when a subsequent medical determination indicates he/she no longer has a medical condition which places that employee at increased risk of health impairment from exposure to lead. (k)(2) Medical Removal Protection Benefits As long as the job the employee was removed from continues, the employer shall provide up to 18 months of MRP benefits on each occasion that an employee is removed from exposure to lead. MRP benefits means the normal earnings, seniority and other employment rights, and benefits, as though the employee had not been removed from the former job. (l) Employee Information, Training and Certification The employer shall provide information about lead hazards, according to the Hazard Communication Standard (Section 5194), to all employees exposed to lead. For all employees exposed to lead at or above the AL on any day, exposed to lead compounds that cause eye or skin irritation, or who perform any of the specified trigger tasks, the employer shall provide initial (pre-placement) training that includes: the content of this standard and appendices; the operations that may cause lead exposure at or above the AL; the purpose, proper selection, fitting, use and limitations of respirators; the purpose and description of the medical surveillance program, including the adverse health effects of lead exposure (especially on reproduction); the engineering controls and work practices relevant to the employee s job assignment; the contents of any compliance plan in effect; the location of regulated areas; the prohibition against routine use of chelation agents; the employee s right of access to records. For all employees exposed to lead at or above the AL on any day, the above training must be provided annually. (l)(3) Training and Certification for Residential and Public Buildings All employees and supervisors who are engaged in lead-related construction in residences or buildings generally accessible to the public, and shown to be exposed to lead at or above the PEL, shall be trained by state-accredited training providers and certified by the California Department of Health Services (CDHS). [Call LEAD for information about accredited training providers and CDHS certification.] 134

145 APPENDIX B CAL/OSHA LEAD (m)signs In regulated areas (work areas where employee exposure is above the PEL and/or trigger tasks are performed), the employer shall post a warning sign with the words: WARNING: LEAD WORK AREA POISON NO SMOKING OR EATING (n) Record Keeping The employer is required to maintain detailed records on exposure assessment, including any objective data used for exemption from air monitoring requirements, medical surveillance and medical removals. (o) Observation of Monitoring The employer shall provide affected employees or their designated representatives an opportunity to observe any monitoring of employee lead exposure. Observers shall be provided with and use protective equipment if required in the area, receive an explanation of the measurement procedures, observe all steps related to monitoring, and receive copies of the results. Glossary of Symbols, Units of Measure, and Abbreviations > symbol meaning greater than x ppm µg/dl µg/m 3 AL BLL HEPA symbol meaning times, as in 50 x PEL (50 times the PEL). parts per million The units used to specify the concentration of lead in a material such as a paint chip sample. 1% is equivalent to 10,000 ppm. micrograms per deciliter The units used to specify the amount of lead in a person s blood sample, i.e., the weight of lead in a deciliter of whole blood. micrograms per cubic meter The units used to specify the concentration of lead dust or fume in air. These units are used to express the results of personal air monitoring. Action Level A concentration of lead in air of 30 µg/m 3 averaged over an 8-hour shift. blood lead level A measurement of how much lead is in a person s blood. high efficiency particulate air A type of filter that efficiently captures very small particles and is used in respirators, vacuums, and ventilation systems for toxic dusts such as lead. 135

146 LEAD-SAFE SCHOOLS PAPR PEL ZPP powered air-purifying respirator A respirator equipped with a battery-powered blower which draws air through filters and into the facepiece. Permissible Exposure Limit A concentration of lead in air of 50 µg/m 3 averaged over an 8-hour shift. zinc protoporphyrin A blood test that can indicate an effect of lead on the bloodforming system. This test is required whenever a BLL is done, and is analyzed from the same blood sample. Table 1 Respiratory Protection for Lead Aerosols Airborne Lead Concentration Required Respirator Lowest exposure Not > 500 µg/m 3 (up to 10 x PEL) half-mask air purifying with high efficiency trigger tasks, or (P-100) filters, or half-mask supplied air in negative pressure mode Not > 1,250 µg/m 3 (up to 25 x PEL) loose-fitting or helmet PAPR* with high efficiency (P-100) filters, or supplied air in continuous-supply mode Medium exposure Not > 2,500 µg/m 3 (up to 50 x PEL) full facepiece air purifying with high trigger tasks, or efficiency (P-100) filters, or tight fitting powered air purifying respirator with high efficiency (P-100) filters, or full facepiece supplied air in demand mode, or half-mask supplied air in continuous-flow mode, or SCBA** in demand mode Highest exposure Not > 50,000 µg/m 3 (up to 1,000 x PEL) half-mask supplied air in positive-pressure mode trigger tasks, or Not > 100,000 µg/m 3 (up to 2,000 x PEL) full facepiece supplied air in positive-pressure mode > 100,000 µg/m 3 (> 2,000 x PEL) full-face SCBA in positive-pressure mode * PAPR = powered air-purifying respirator ** SCBA = self contained breathing apparatus Adapted from materials produced by the Occupational Lead Poisoning Prevention Program/California Department of Health Services 136

147 APPENDIX C CAL/OSHA HAZCOM Cal/OSHA Hazard Communication Standard Summary C Cal/OSHA s Hazard Communication (HAZCOM) standard is found in Title 8 of the California Code of Regulations, General Industry Safety Orders, section It provides workers with the right to information about hazardous chemicals and other hazardous materials used in the workplace. Each California employer must establish a written Hazard Communication Program which includes: A detailed list of all hazardous substances in the workplace. (Materials that contain lead, such as paints and coatings, are included.) A description of the labeling system used for hazardous substances. Labels must include the name of the hazardous substance, warnings about its health effects and other hazards, and the name and address of the manufacturer, importer, or other responsible party. Training about each hazardous substance an employee may be exposed to on the job. Such training must be provided at the time of initial assignment and whenever a new substance is introduced in the workplace. Training must include information on the health effects and other hazards of the substance, the methods used to detect its presence or release, and appropriate protective measures including appropriate work practices, emergency procedures, and personal protective equipment. MSDSs (Materials Safety Data Sheets) for all hazardous materials on site. These sheets are provided by the manufacturer and must be made readily accessible to every employee. MSDSs must include: the product name and ingredients physical and chemical characteristics fire, explosion, and reactivity hazards health hazards exposure limits precautions for safe handling and use control measures personal protective equipment emergency and first aid measures spill and leak procedures. If an MSDS does not exist for a material (like old paint), then the employer should take samples and have them analyzed by a laboratory, or assume that the substance is hazardous and act accordingly. Both employers and employees benefit from a written Hazard Communication Program in the workplace. Employers can use the information to design engineering controls, substitute less hazardous chemicals, and selects appropriate personal protective equipment for workers. 137

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149 APPENDIX D CAL/OSHA IIPP Cal/OSHA Injury and Illness Prevention Program Standard Summary D Cal/OSHA s Injury and Illness Prevention Program (IIPP) standard is found in Title 8 of the California Code of Regulations, sections 1509 and It requires every California employer to establish, implement, and maintain an effective Injury and Illness Prevention Program (IIPP) to promote health and safety in the workplace. An IIPP must be a written plan that includes all of the following elements: Management commitment and assignment of responsibilities. A person (or persons) with the authority and responsibility for carrying out the program must be identified and given management s full support. Safety communication system. Employers should communicate with employees about health and safety issues in a language they can understand, and in a manner that does not depend on literacy skills. Communication systems may include safety meetings, written materials, joint labor-management health and safety committees, and/or other communication methods. Hazard assessment and control. There must be specific procedures for identifying and evaluating hazards, including periodic inspections of the workplace. Employees should be encouraged to participate in inspections without fear of reprisal. Hazards should be corrected as soon as they are identified, or a target date for correction should be set. Accident investigation. There must be a process for investigating work-related injuries and illnesses. Written documentation should be maintained indicating why each accident or near miss occurred, and what actions can be taken to preclude recurrence. Safety planning, rules, and work procedures. There must be a means for ensuring that the safety rules and procedures established for the workplace are followed. Training. At a minimum, training and instruction should be provided to all employees when the IIPP is established, and thereafter to all new employees, to all employees with a new job assignment, and whenever new substances, processes, procedures, or equipment are introduced. The written IIPP must be available to employees. Records must be kept to document that there is an effective program in place. These records should include scheduled inspections, actions taken to correct problems, and types, dates, and providers of training. 139

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151 APPENDIX E LSSPA Lead-Safe Schools Protection Act The Lead-Safe Schools Protection Act is found in the California Education Code, sections Following is the complete text. E This article shall be known, and may be cited, as the Lead-Safe Schools Protection Act (a) The State Department of Health Services shall conduct a sample survey of schools in this state for the purpose of developing risk factors to predict lead contamination in public schools. The survey shall include schools that are representative of the state by geographical region and size of enrollment. The schools to be surveyed shall be selected on the basis of their ability to provide data necessary to make scientifically valid estimates of the nature and extent of lead hazards. Risk factors shall include, but are not limited to, location in relation to high-risk areas, age of the facility, likely use of lead paint in or around the facility, numbers of children enrolled under the age of six, and results of lead screening programs established pursuant to Chapter 5 (commencing with Section ) of Part 5 of Division 103 of the Health and Safety Code. (b) For purposes of this article, schools mean public elementary schools, public preschools, and public day care facilities. (c) For purposes of this article, public preschools and public day care facilities mean preschools and day care facilities, respectively, located on public school property The department shall do all of the following: (a) Design and implement a strategy for identifying the characteristics of high-risk schools and provide a basis for statewide estimates of the presence of lead in schools attended by young children. (b) Conduct a sample survey, as described in Section 32241, to determine the likely extent and distribution of lead exposure to children from paint on the school, soil in play areas at the school, drinking water at the tap, and other potential sources identified by the department for this purpose. To the maximum extent possible, limited sample testing shall be used to validate survey results. The department shall compile and summarize the results of that survey and report those results to the Legislature and the State Department of Education. (c) Within 60 days of the completion of testing a schoolsite, the department shall notify the principal of the school or director of the schoolsite of the survey results. Within 45 days of 141

152 LEAD-SAFE SCHOOLS receiving the survey results, the principal or director, as the case may be, shall notify the teachers and other school personnel and parents of the survey results. (d) Make recommendations to the Legislature and the State Department of Education, based on the survey results and consideration of appropriate federal and state standards, on the feasibility and necessity of conducting statewide lead testing and any additional action needed relating to lead contamination in the schools. (e) As deemed necessary and appropriate in view of the survey results, develop environmental lead testing methods and standards to ensure the scientific integrity of results, for use by schools and contractors designated by schools for that purpose. (f) Evaluate the most current cost-effective lead abatement technologies. (g) Work with the State Department of Education to develop voluntary guidelines for distribution to requesting schools to ensure that lead hazards are minimized in the course of school repair and maintenance programs and abatement procedures (a) When a school subject to this article has been determined to have significant risk factors for lead, the school shall be advised of this finding, and the school shall notify parents of the provisions of the Childhood Lead Poisoning Prevention Act of 1991 (pursuant to Chapter 5 (commencing with Section ) of Part 5 of Division 103 of the Health and Safety Code). Within 45 days of receiving this finding, the school principal or the director of the schoolsite shall notify the teachers, other personnel, and the parents of the finding. (b) Subsequent to the implementation by the state of a certification and training program for environmental lead testing and abatement, any school that undertakes any action to abate existing risk factors for lead shall utilize trained and state certified contractors, inspectors, and workers Lead-based paint, lead plumbing and solders, or other potential sources of lead contamination shall not be utilized in the construction of any new school facility or the modernization or renovation of any existing school facility Funding to implement this article shall be provided for the Child Health and Safety Fund created under Chapter 4.6 (commencing with Section 18285) of Part 6 of Division 9 of the Welfare and Institutions Code, upon appropriation by the Legislature pursuant to Section of the Welfare and Institutions Code. 142

153 APPENDIX F TITLE 17 Title 17, California Code of Regulations Summary F Title 17, Division 1, Chapter 8, Accreditation, Certification, and Work Practices for Lead-Based Paint And Lead Hazards, is the key regulation for lead work in California. This summary of its major provisions is based on the revision dated January 8, The regulation is jointly enforced by the Department of Health Services (DHS) and the Division of Occupational Safety and Health (Cal/OSHA). The regulation s basic requirements for training and certification are summarized in Chapter 8 of this Guide. This summary emphasizes work practice requirements. To read the complete text of the regulation, check the Department of Health Services Childhood Lead Poisoning Prevention Program s website at Article 1 Definitions This Article provides definitions for terms used throughout the regulation. Key terms include abatement, accreditation, clearance inspection, containment, deteriorated lead-based paint, leadcontaminated dust, lead-contaminated soil, lead hazard, lead hazard evaluation, and presumed leadbased paint. (See Appendix J, Glossary, for full definitions of these terms.) Article 2 Eligibility Requirements for Accreditation and Course Approval This Article describes the requirements for individuals, agencies, and organizations to become approved training providers. It gives the minimum qualifications for instructors and requirements for training equipment, trainee testing, and training records. Articles 3 10 Training Course Requirements These Articles describe the specific topics of instruction, number of contact hours, and required training methods for each type of course that training providers may offer. The courses described include: Core Instruction, Lead-Related Construction Inspection and Assessment, Lead-Related Construction Supervision and Project Monitoring, Lead-Related Construction Project Design, Lead-Related Construction Work, Lead-Related Construction Supplemental Supervision and Project Monitoring, Lead-Related Construction Certified Industrial Hygienist, and Continuing Education. 143

154 LEAD-SAFE SCHOOLS Article 11 Application Requirements and Procedures for Training Provider Accreditation, Renewal, or Course Approval This Article provides information about the forms and documents required for making application to the Department of Health Services for accreditation as a training provider, renewal of accreditation, and approval of specific courses. Article 12 Suspension or Revocation of Accreditation, Provisional Accreditation, or DHS Course Approval This Article describes the process for revoking a training provider s accreditation or course approval. Article 13 Eligibility Requirements and Application Procedures for Certification or Interim Certification This Article lists the minimum qualifications for becoming a certified Lead Worker, Lead Supervisor, Lead Project Monitor, Lead Project Designer, and Lead Inspector/Assessor. The application process is discussed as well as the educational level, specific training, experience, and tests that are required for each of these classifications. Article 14 Suspension or Revocation of Certification or Interim Certification This Article discusses the process involved in suspending the certification status of a certified individual. Article 15 Enforcement This Article describes the amount of money allocated to the Division of Occupational Safety and Health annually for costs of enforcing compliance with the training and certification requirements of Title

155 APPENDIX F TITLE 17 Article 16 Work Practice Standards This Article sets out the requirements that must be followed when evaluating and abating lead hazards in public and residential buildings (including schools). It incorporates the requirements set out in the Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing, U.S. Department of Housing and Urban Development, June 1995 (and as revised in 1997). These HUD Guidelines form the basis of work practice regulation for lead jobs in California Lead Hazard Evaluation for Public and Residential Buildings (a) Lead hazard evaluation for public and residential buildings shall: (1) Be conducted only by a certified lead inspector/assessor. The certified lead inspector/ assessor conducting a lead hazard evaluation shall not conduct abatement on the same structure. (2) Be conducted in a manner in which paint, dust, and soil samples are tested in accordance with the procedures described in the HUD Guidelines. (3) Be conducted in a manner in which paint, dust, and soil samples taken for laboratory analysis are analyzed by a laboratory that is recognized by the U.S. Environmental Protection Agency pursuant to United States Code, Title 15, Section 2685(b). (4) Be documented in a lead hazard evaluation report which shall include a completed Department of Health Services (DHS) Form 8552 (12/97) and the following attachments: a foundation diagram, site map, or sketch of the structure, indicating the specific locations of each lead hazard or presence of lead-based paint, and results of the visual inspection, if applicable; a summary of each testing method, device, and sampling procedure used; a description of testing and sampling locations; and the results of laboratory analysis on collected samples, if applicable, including the name, address, and telephone number of each laboratory. (b) The certified lead inspector/assessor conducting the lead hazard evaluation for a public or residential building shall retain the original completed copy of DHS Form 8552 (12/97) and attachments for a minimum of three years and distribute copies as follows: a copy of the completed DHS Form 8552 (12/97) and attachments to the person who ordered the lead hazard evaluation; a copy of the completed DHS Form 8552 (12/97) to DHS within thirty days of completion; and a copy of the attachments to DHS upon request. (c) In addition to the requirements specified in subsections (a) and (b): (1) A lead inspection shall be conducted in accordance with procedures described in the HUD Guidelines (as revised in 1997). 145

156 LEAD-SAFE SCHOOLS (2) A risk assessment shall be conducted in accordance with procedures described in the HUD Guidelines and shall include a written description of abatement options for each identified lead hazard, a suggested prioritization for addressing each lead hazard, and recommendations for a maintenance and monitoring schedule. (3) A clearance inspection shall be conducted by a certified lead inspector/assessor or a certified lead project monitor and in accordance with the procedures described in the HUD Guidelines Abatement for Public and Residential Buildings (a) Abatement for public and residential buildings which is designed to reduce lead paint or lead hazards for a minimum of twenty years shall be conducted: (1) Only by a certified lead supervisor or a certified lead worker. A certified lead supervisor shall be onsite during all work site preparation and during the post-abatement cleanup of work areas. At all other times when abatement is conducted, the certified lead supervisor shall be onsite or available by telephone, pager or answering service, and able to be present at the work area in no more than two hours. (2) According to the procedures specified in the HUD Guidelines. (3) Using containment and in a manner which does not result in contamination of non-work areas with lead-contaminated dust, lead-contaminated soil, or lead-based paint debris. (4) In accordance with an abatement plan prepared by a certified lead supervisor, certified lead project monitor, or certified lead project designer which shall: (A) Include the following information: 1. A detailed written description of the measures and management procedures, including containment, that will be utilized during abatement to prevent exposure to lead hazards; 2. A detailed written description of abatement, including methods of abatement and locations of rooms and components where abatement is planned; 3. A recommended schedule for re-inspection, based upon the type of abatement; 4. Instructions on how to maintain potential lead hazards in safe condition. (B) Be retained and made available to DHS upon request for a period of at least three years by the preparer. 146

157 APPENDIX F TITLE 17 (5) After notification is posted and delivered pursuant to subsection (c). The certified lead supervisor conducting abatement shall retain records of notification for at least three years. (6) In a manner in which after abatement is completed, a clearance inspection is conducted in accordance with Sections 36000(a) and (c)(3) of Title 17. (b) Abatement for public and residential buildings which is designed to reduce lead paint or lead hazards for less than twenty years shall be conducted: (1) According to procedures specified in the HUD Guidelines. (2) Using containment and in a manner which does not result in contamination of non-work areas with lead-contaminated dust, lead-contaminated soil, or lead-based paint debris. (3) In a manner to ensure that the work area has no lead contaminated dust following the completion of abatement. (4) In a manner to ensure that a clearance inspection is conducted following the completion of abatement, if abatement was conducted in response to an identified case of lead poisoning as defined in Section (b) of the California Health and Safety Code. (5) After notification is posted and delivered pursuant to subsection (c). (c) Prior to conducting abatement, the individual conducting abatement shall provide notification by completing an Abatement of Lead Hazards Notification, DHS 8551 (12/97), form and: (1) Posting at all entrances to the work area a copy of the completed form which shall not be removed until abatement has been completed and, for abatement conducted pursuant to subsection (a), a clearance inspection has been completed; and (2) Delivering a copy of the completed form to DHS. Except for abatement conducted in response to an identified case of lead poisoning as defined in Section (b) of the Health and Safety Code, the completed form shall be delivered to DHS at least five days prior to conducting abatement. (d) Any individual conducting abatement or disturbing lead-based paint without containment shall permit the Department, or enforcement agencies, as specified in the California Health and Safety Code Sections 17960, 17961, and 17965, to access work areas to determine compliance with the requirements of this section. 147

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159 APPENDIX G CONTRACTORS Contractor Requirements for High Risk Lead Tasks All high risk lead tasks performed on school district property must be done by trained and state-certified workers. This policy should apply both to the school district s own personnel and to outside contractors. G As explained earlier in this Guide, a high risk lead task is one that: Can expose workers to lead dust or fumes above the Cal/OSHA Permissible Exposure Limit (PEL) of 50 µg/m 3, or Is considered to be lead abatement work that is designed to reduce a lead hazard for a minimum of 20 years. If an outside contractor is hired to perform abatement work or other high risk lead tasks, the following elements should be incorporated into any written contract. A. License The Contractor shall have a valid California State Contractors License in the classification appropriate to the work. B. Worker Certification 1. All high risk lead tasks and lead abatement work shall be under the supervision of a Certified Lead Supervisor with a current DHS certificate. This individual shall have direct control of all tasks, ensure that work is conducted in a lead-safe manner without producing lead hazards, and be responsible for enforcing safe work practices that comply with Cal/OSHA and other state requirements. The Certified Lead Supervisor shall be on site during all preparation and cleanup of work areas. At all other times when lead-related activities are underway, the Certified Lead Supervisor shall be on site or available by telephone, pager, or answering service, and shall be able to reach the site in no more than two hours. 2. All high risk lead tasks, and abatement work designed to reduce a lead hazard for a minimum of 20 years, shall be carried out by Certified Lead Workers with current DHS certificates. 3. The School District Representative may require that the Contractor provide state-certified supervisors and workers for any task that disturbs or may disturb lead-based paint, presumed lead-based paint, or lead-contaminated soil, as defined by Title 17 of the California Code of Regulations, Division 1, Chapter 8. Certain tasks may not require state-certified supervisors and workers. In any event, the Contractor shall be responsible for ensuring worker safety and Cal/OSHA compliance. 149

160 LEAD-SAFE SCHOOLS C. Insurance In addition to any insurance requirements stated elsewhere in the Job Specifications or other contract documents, the Contractor shall provide the District with evidence of insurance coverage for lead hazard reduction work (pollution liability) as follows: 1. Combined single limit of $1,000,000 minimum for property damage per occurrence. 2. $500,000 minimum limit for bodily injury and $1,000,000 minimum limit for property damage per occurrence. D. Worker Protection Programs The Contractor shall maintain the following written programs as required by Cal/OSHA: 1. Injury and Illness Prevention Program (IIPP). 2. Hazard Communication Program (HAZCOM). 3. Respiratory Protection Program. 4. Site Safety and Health Plan. E. Hazardous Waste The Contractor shall ensure that hazardous waste is transported by a licensed hazardous waste transporter, except as allowed under small-quantity transportation rules. Hazardous waste shall be disposed of in accordance with all applicable state and federal regulations. F. Submittals The Contractor shall provide the following to the District: 1. List of Certified Lead Supervisors and Certified Lead Workers, and copies of certification cards. 2. List of Subcontractors (or state None ). 3. Certificates for General Liability Insurance and Lead Hazard Insurance, naming the District as an additional insured. 4. A schedule, if required by the Scope of Work or the School District Representative. Submit three days before starting work. Include specific dates for the beginning and ending of each phase of the work and dates for testing. The schedule shall be updated weekly. 150

161 APPENDIX G CONTRACTORS 5. A copy of the completed DHS Form 8551, Abatement of Lead Hazards Notification. The form must be provided prior to the start of any lead-related construction work. 6. A copy of all Hazardous Waste Disposal Manifests, when these are required by applicable regulation. 7. When required by the School District Representative, copies of the Contractor s written: a. Injury and Illness Prevention Program (IIPP). b. Hazard Communication Program (HAZCOM). c. Respiratory Protection Program. d. Site Safety and Health Plan. Adapted from Alameda County Lead Poisoning Prevention Program, Contractor Qualifications Residential Lead Abatement. 151

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163 APPENDIX H VOLUNTEERS Guidelines for Volunteers A letter similar to the model below can be provided to parents and community volunteers who wish to assist schools with painting and related projects. The letter is intended to inform volunteers about district guidelines regarding lead paint. H To: Parent and Community Volunteers The Lead-Safe Schools Protection Act of 1992 requires California public elementary schools and childcare facilities to use specially trained personnel when carrying out activities that disturb lead-based paint. Such activities include removal (scraping or sanding) of paint, or alteration of painted surfaces. Complying with the Act can help schools protect children and staff from serious health damage. Lead poisoning can affect a child s growth and mental development. Adults may experience kidney, nervous system, blood, and reproductive disorders. Lead can get into the body by breathing (inhaling) or swallowing (ingesting) lead dust, particles, or chips. These may be on surfaces or in air, water, or soil. The primary source of lead in schools is older paint. Lead hazards can be controlled by following lead-safe work practices. Therefore, volunteers will not be permitted to perform work that disturbs lead-based paint. However, they will be allowed to paint or re-paint surfaces that have been prepared by the district s trained Maintenance and Operations staff. All paint used must have the prior approval of the District s Maintenance and Operations department. District-approved paint is lead-free and meets or exceeds the Consumer Product Safety Commission s current standard. Note that industrial paints and marine paints can be hazardous and shall not be used. Please contact the District s Maintenance and Operations department if you have any questions. Sincerely, Maintenance and Operations Manager 153

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165 APPENDIX I RESOURCES Resources for More Information Federal Government Agencies Centers for Disease Control & Prevention (CDC) I CDC Headquarters 1600 Clifton Road NE Atlanta, GA (404) (Operator) (800) (Public Inquiry) (888) (Healthline) Web An agency of the Department of Health and Human Services whose mission is to promote health and quality of life by preventing and controlling disease, injury, and disability. CDC Childhood Lead Poisoning Prevention Program 4770 Buford Highway NE, MS F-42 Atlanta, GA (770) Web Develops programs and policies to prevent childhood lead poisoning, educates the public and health care providers, provides funding to state and local health departments, and supports research to determine the effectiveness of prevention efforts at the federal, state, and local levels. CDC National Center for Environmental Health (NCEH) 4770 Buford Highway NE, MS F-29 Atlanta, GA (888) Web Call to get information on childhood lead poisoning, related issues, and a list of publications. CDC Agency for Toxic Substances and Disease Registry (ATSDR) 1600 Clifton Road NE Atlanta, GA (888) Web 155

166 LEAD-SAFE SCHOOLS Provides information on health effects for those living or working near hazardous waste sites. Can provide information on lead poisoning and effects of other toxic substances. Department of Housing and Urban Development (HUD) HUD Office of Lead Hazard Control 451 7th Street SW, Room P-3206 Washington, D.C (202) (National Office) (415) (San Francisco Office) Web Advises all HUD program offices and field offices on lead poisoning prevention. Committed to providing lead-safe housing to the nation s children while preserving affordable housing. Environmental Protection Agency (EPA) EPA National Lead Information Center 8601 Georgia Avenue, Suite 503 Silver Spring, MD (800) 424-LEAD Web NLIC is funded by the EPA to maintain a Lead Educational Materials Database which they can search in response to a caller s needs. They provide information to help parents protect their children from poisoning in the home, and can furnish a list of state and local contacts. Written materials and recordings are available in English and Spanish. EPA Office of Pollution Prevention and Toxics Lead Programs Web Responds to inquiries about lead and lead-based paint. Has information and materials in English and Spanish. Also involved in regulating training and certification programs. EPA Safe Drinking Water Hotline (800) Web Provides educational materials, explanation of lab analysis results, and other information about contaminants in drinking water, including lead. 156

167 APPENDIX I RESOURCES Food and Drug Administration (FDA) FDA California Office 1431 Harbor Bay Parkway Alameda, CA (510) Web Regulates food, drugs, cosmetics, and medical devices. Also regulates, investigates, and samples dinnerware, pottery, etc. for metals content such as lead. California State Agencies Cal/OSHA (Division of Occupational Safety and Health) Cal/OSHA Compliance Headquarters 455 Golden Gate Ave., 10th Floor San Francisco, CA (415) Web Investigates worksite fatalities, serious injuries or illnesses, and complaints about workplace hazards. Also conducts scheduled inspections of high-risk workplaces. Cal/OSHA Compliance District Offices Anaheim... (714) Concord... (925) Fresno... (209) Foster City/San Mateo... (650) Los Angeles... (213) Oakland... (510) Pico Rivera... (562) Redding... (530) Sacramento... (916) San Bernardino... (909) San Diego... (858) San Francisco... (415) San Jose... (408) Santa Rosa... (707) Torrance... (310)

168 LEAD-SAFE SCHOOLS Van Nuys... (818) Ventura... (805) West Covina... (626) Cal/OSHA Consultation Service Headquarters 455 Golden Gate Avenue, 10th Floor San Francisco, CA (415) (800) Provides free services to employers, including on-site evaluation of health and safety conditions in the workplace, training, publications, and information. Cal/OSHA Consultation Service Area Offices Oakland... (510) Sacramento... (916) San Diego... (858) Van Nuys/San Fernando Valley.. (818) Department of Education California Department of Education School Facilities Planning Division 660 J Street #350 Sacramento, CA (916) Assists school districts and their communities in creating well-planned K-12 learning environments in safe, clean, and up-to-date schools. 158 Department of Health Services Childhood Lead Poisoning Prevention Branch (CLPPB) 1515 Clay Street, Suite 1801 Oakland, CA (510) (General Information) (800) (Hotline) Web Helps eliminate childhood lead poisoning by identifying and caring for lead burdened children, and preventing environmental exposures to lead.

169 APPENDIX I RESOURCES Division of Drinking Water and Environmental Management (DDWEM) Drinking Water Program PO Box Sacramento, CA (916) Web Assures protection of the public through the regulation and monitoring of public water systems. Occupational Lead Poisoning Prevention Program (OLPPP) 1515 Clay Street, Suite 1901 Oakland, CA (510) (Information) (510) (Free Publications) Web Provides information and services designed to prevent and control lead poisoning in California workplaces. Activities directed towards workers, unions, employers, industry groups, health professionals and the general public. Environmental Protection Agency (Cal/EPA) Cal/EPA Department of Toxic Substances Control 400 P Street, PO Box 806 Sacramento, CA (916) (General Information (916) (Hazardous Waste) Web Protects public health and the environment by regulating hazardous waste and enforcing pollution prevention laws. Cal/EPA Office of Environmental Health Hazard Assessment (OEHHA) 310 Capitol Mall #205 Sacramento, CA (916) Web Regulates lead exposure under California s Proposition

170 LEAD-SAFE SCHOOLS Local Government Agencies California Childhood Lead Poisoning Prevention Programs 160 City and County Offices Many city and county lead programs provide information on testing children for lead, general lead information, and lead poisoning prevention services. Alameda County... (510) Alpine County... (530) Amador County... (209) Berkeley (City)... (510) Butte County... (530) Calaveras County... (209) Colusa County... (530) Contra Costa County... (925) or (510) Del Norte County... (707) El Dorado County... (530) Fresno County... (559) Glenn County... (530) Humboldt County... (707) Imperial County... (760) Inyo County... (760) Kern County... (661) Kings County... (559) , ext 2619 Lake County... (707) Lassen County... (530) Long Beach (City)... (562) Los Angeles County... (213) Madera County... (559) Marin County... (415) Mariposa County... (209) Mendocino County... (707) Merced County... (209) Modoc County... (530) Mono County... (760) Monterey County... (831) Napa County... (707) Nevada County... (530) Orange County... (714) Pasadena (City)... (626) Placer County... (530)

171 APPENDIX I RESOURCES Plumas County... (530) Riverside County... (909) Sacramento County... (916) San Benito County... (831) San Bernardino County... (909) San Diego County... (619) San Francisco (City & County)... (415) San Joaquin County... (209) San Luis Obispo County... (805) San Mateo County... (650) Santa Barbara County... (805) Santa Clara County... (408) Santa Cruz County... (831) Shasta County... (530) Sierra County... (530) Siskiyou County... (530) Solano County... (707) Sonoma County... (707) Stanislaus County... (209) Sutter County... (530) Tehama County... (530) Trinity County... (530) Tulare County... (559) Tuolumne County... (209) Ventura County... (805) Yolo County... (530) or (916) Yuba County... (530) Regional and Statewide Organizations University Programs Labor Occupational Health Program (LOHP) Lead-Safe Schools Project University of California, Berkeley 2223 Fulton St., 4th Floor Berkeley, CA (510) Web socrates.berkeley.edu/~lohp Produces materials and presents training programs for school personnel on lead safety in California schools. LOHP also has information on many other workplace safety and health issues. 161

172 LEAD-SAFE SCHOOLS UCLA Labor Occupational Safety and Health Program 6350 B Public Policy Building PO Box Los Angeles, CA (310) Web Provides training, publications and technical assistance on occupational health and safety issues in Southern California. Other Programs California Child Care Health Program 1322 Webster Street, Suite 402 Oakland, CA (510) (General Information) (800) (Healthline) Web Links the childcare and health communities to promote quality childcare in California via legislation, advocacy, technical assistance, training, and materials development. Developed a lead poisoning training curriculum for childcare providers. Also administers childcare lead poisoning and anemia prevention projects in three counties Los Angeles, Humboldt, and Kern. California Communities Against Toxics PO Box 845 Rosamond, CA (661) A coalition of over 70 community-based toxics groups working on issues involving lead in air, paint, industrial waste, other hazardous waste, fertilizers, and sludge. Communities for a Better Environment (CBE) 500 Howard Street # West Olympic Boulevard #850 San Francisco, CA Los Angeles, CA (415) (213) Web A community-based state wide organization that promotes clean air and water, and advocates for toxic free communities 162

173 APPENDIX I RESOURCES Occupational and Environmental Health Clinics California Clinics Many doctors do not have experience in treating patients with lead poisoning or other workrelated health problems. To consult with experts in lead-related health effects and other occupational and environmental health problems, contact the following clinics. Drew University of Medicine and Science, Los Angeles... (800) University of California, Davis (Sacramento)... (530) University of California, Irvine... (949) University of California, Los Angeles... (310) University of California, San Diego... (619) University of California, San Francisco... (415) Nationwide Clinics Association of Occupational and Environmental Clinics 1010 Vermont Avenue NW, Suite 513 Washington, DC (202) Web giligan.mc.duke.edu/oem/aoec.htm Has a complete list of affiliated occupational and environmental health clinics nationwide. 163

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175 APPENDIX J GLOSSARY Glossary of Terms a Abatement. See Lead Abatement. J Accreditation. Under Title 17, refers to a training provider obtaining state approval to offer courses that workers must take to become lead-certified. Action Level (AL). According to Cal/OSHA s Lead in Construction standard, this is a concentration of 30 micrograms of lead per cubic meter of air (µg/m 3 ), averaged over an 8-hour workday. Employees exposed to lead at or above the Action Level but below the Permissible Exposure Level (PEL) must be trained annually in the hazards of lead and must be included in a Medical Surveillance Program. There are other required health and safety measures for these employees also. See Appendix B. Air Purifying Respirator (APR). A type of respirator that uses filters to reduce the amount of dust, fumes, or vapors that workers inhale. APRs require the wearer to draw air through the filters when inhaling. Air Quality Management District (AQMD). One of several regional agencies that issue and enforce local air pollution regulations in California. Air Resources Board (ARB). California s state agency that oversees enforcement of air pollution regulations. Air Sampling. See Personal Air Sampling. Air Supplied Respirator (ASR). A type of respirator that supplies clean air. This may be from an air compressor and hose or from a tank on the worker s back (SCBA). (See Self- Contained Breathing Apparatus.) b Biological Monitoring. Required by Cal/OSHA for workers exposed to lead. Includes tests for Blood Lead Level (BLL), which measures the amount of lead in the blood, and Zinc Protoporphyrin (ZPP), which measures damage to the blood-forming system. Blood Lead Level (BLL). A blood test that measures how much lead is in a person s blood. The BLL usually reflects lead exposure received over the prior two to three weeks, but also may be high if the person has a large amount of lead stored in the body. 165

176 LEAD-SAFE SCHOOLS Breathing Zone. The area around a worker s nose and mouth (within about a 1-foot radius). Personal air sampling to measure worker exposure to lead is done by placing a small filter within the breathing zone (around the collar), attached to a pump which operates while the person is working. c Cal/EPA. California Environmental Protection Agency, the state agency responsible for issuing and enforcing environmental regulations. These include regulations on air and water pollution and hazardous waste. Cal/OSHA. The Division of Occupational Safety and Health within the California Department of Industrial Relations. The state agency that issues and enforces regulations to protect worker health and safety. Cal/OSHA Consultation Service. A program of Cal/OSHA that provides free, voluntary assistance to employers to help evaluate and correct health and safety hazards in the workplace. California Department of Health Services (DHS). The state government public health department. Centers for Disease Control and Prevention (CDC). The federal public health agency that oversees the National Institute for Occupational Safety and Health (NIOSH). CDC also provides guidance on the management of childhood lead poisoning cases. Certification. Under Title 17, the process by which a worker obtains a state certificate to do lead work. Only certified workers and supervisors may do high risk lead jobs. There are five levels of certification, each with different training and experience requirements. Chelation. A medical treatment for severe lead poisoning. Can be dangerous. Prophylactic chelation of lead poisoned workers is prohibited by Cal/OSHA regulations. Childhood Lead Poisoning Prevention Branch (CLPPB). A program within DHS that does training and research designed to protect children from lead poisoning. Also accredits lead training programs and certifies contractors. Clearance Inspection. An on-site investigation to determine if lead work has been done as specified, and if the work area is safe to enter. Does not include sampling to ensure Cal/OSHA compliance or for hazardous waste disposal purposes. See Wipe Sampling. Containment. A system, process, or barrier that is used to keep lead hazards inside a work area. One common step is using poly (plastic sheeting). 166

177 APPENDIX J GLOSSARY d Department of Toxic Substances Control (DTSC). A program within the Cal/EPA that is responsible for issuing and enforcing hazardous waste regulations. Deteriorated Lead-Based Paint. Defined by Title 17 as lead-based paint or surface coating that is cracking, chalking, flaking, chipping, peeling, non-intact, failed, or otherwise separating from a component. DHS. See California Department of Health Services. e Engineering Controls. Changes that can be made in the work environment to reduce hazards on the job, such as ventilation or special ventilated tools. Cal /OSHA requires employers to use all possible engineering controls to reduce lead exposure that is higher than the PEL. EPA. Environmental Protection Agency, the federal agency responsible for protecting the public from the effects of toxic substances in the environment. f Fit Check. Also called a User Seal Check. Tests that should be done by individual workers every time they put a respirator on to make sure it seals to the face properly. There are several types of fit checks (positive and negative pressure) described in Cal/OSHA s Respiratory Protection standard. Fit Test. Testing that should be done every six months by the employer to ensure that respirators continue to fit properly. In qualitative fit tests, a chemical that is irritating or has an odor is introduced in the air around the respirator wearer s head. If the wearer detects the chemical through the respirator, the respirator does not fit well enough to protect the worker. A quantitative fit test can be done if the respirator is of a special type. These respirators have the ability to detect a chemical inside themselves (or detect a difference in dust levels between inside and outside). Procedures for fit testing are described in the Cal/OSHA Respiratory Protection standard. (Title 8, California Code of Regulations, Sections 1531 and 5144.) Fumes. Very tiny particles of lead generated when a material containing lead is heated to high temperatures. Fumes are very easily breathed deep into the lungs. 167

178 LEAD-SAFE SCHOOLS h Hazard Communication (HAZCOM). A Cal/OSHA standard that requires employers to provide information and regular training to workers about hazardous substances in their workplace. (Title 8, California Code of Regulations, Section 5194.) Hazardous Waste. Any waste that is defined as dangerous to people or the environment by federal or state laws. There are specific federal, state, and local regulations governing the proper storage and disposal of waste that has been defined as hazardous. HEPA. High efficiency particulate air filter, also called a high efficiency P-100 filter. A type of filter that efficiently captures very small particles. These filters may be used in respirators, special vacuum cleaners, tool attachments, and ventilation systems to capture toxic dusts or fumes such as lead. HUD. The U.S. Department of Housing and Urban Development, the federal agency responsible for federally financed housing. Assists in enforcing certain federal lead regulations. California s Title 17 incorporates many regulations found in HUD s Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing, June i l Injury and Illness Prevention Program (IIPP). A Cal/OSHA standard that requires every employer to have a health and safety program. The program must include identification, assessment, and control of hazards in the workplace as well as training. Employers must involve workers in maintaining a safe workplace. (Title 8, California Code of Regulations, Sections 1509 and 3203.) Lead Abatement. Defined by Title 17 as any set of measures designed to reduce or eliminate lead hazards or lead-based paint in public or residential buildings. Does not include containment or cleaning. Title 17 requires the use of certified workers and supervisors for abatement which is designed to reduce lead for a minimum of 20 years. Lead-Based Paint. Defined by Title 17 as paint or other surface coatings that contain an amount of lead equal to, or in excess of, one milligram per square centimeter (1 mg/cm 2 ); or more than half of one percent (0.5%) by weight. Lead-Contaminated Dust. Defined by Title 17 as any dust that contains an amount of lead equal to, or in excess of, 50 micrograms per square foot (50 µg/ft 2 ) for interior floor surfaces, 250 µg/ft 2 for interior horizontal window surfaces, and 800 µg/ft 2 for exterior floors and exterior horizontal window surfaces. 168

179 APPENDIX J GLOSSARY Lead Hazard. Defined by Title 17 as deteriorated lead-based paint, lead contaminated dust, lead contaminated soil, disturbing lead-based paint or presumed lead-based paint without containment, or any other nuisance which may result in persistent or quantifiable lead exposure. Lead Hazard Evaluation. Defined by Title 17 as the on-site investigation, for compensation, of lead-based paint or lead hazards, such as a lead inspection, risk assessment, and clearance inspection, for public and residential buildings. Does not include activities intended to determine adequacy of containment or compliance with regulatory requirements. Lead in Construction Standard. A Cal/OSHA standard that spells out protective measures that employers must use to protect workers exposed to lead during construction work. (Title 8, California Code of Regulations, Section ) Lead-Safe Schools Protection Act (LSSPA). Bans lead paint, plumbing, and other sources of lead exposure in new schools, and requires use of certified personnel for school lead abatement. (Sections of the California Education Code.) Lead Stick. See Sodium Rhodizonate. Lockout/Tagout. Defined procedures for shutting down systems or equipment capable of movement (such as a heating or ventilation systems) so they cannot be accidentally restarted. (Title 8, California Code of Regulations, Section 3314.) m Material Safety Data Sheet (MSDS). A factsheet provided by manufacturers or suppliers about the hazards of chemical products used in the workplace. According to Cal/OSHA s Hazard Communication standard, employers must make MSDSs available to workers on request. Medical Removal Protection (MRP). A requirement of Cal/OSHA s Lead in Construction standard. Employers must temporarily remove workers from lead exposure at or above the Action Level if they have a BLL of 50 µg/dl or higher on two consecutive tests, or when recommended by a doctor for health reasons. Workers on MRP may be given work in leadfree areas. They must be paid their usual wages as long as their original job exists, or for up to 18 months. Medical Supervisor. A physician in charge of an employer s Medical Surveillance Program. Medical Surveillance Program. A program of medical exams and blood testing that an employer must make available to exposed workers under the Lead in Construction standard. Methylene Chloride. A chemical sometimes used in paint strippers. Never use methylene chloride strippers because they can cause cancer and other serious health damage. 169

180 LEAD-SAFE SCHOOLS Mil. One thousandth (1/1,000) of an inch. Poly sheeting used for containment on lead jobs must be at least 4 mil. n NIOSH. The National Institute for Occupational Safety and Health. An agency within CDC that conducts research and education on worker health and safety. NLLAP. National Lead Laboratory Accreditation Program. o Occupational Lead Poisoning Prevention Program (OLPPP). A program within DHS that does training and research designed to protect workers from lead poisoning. OSHA. Occupational Safety and Health Administration, a federal agency in the U.S. Department of Labor that issues and enforces regulations to protect worker health and safety nationwide. Its state counterpart in California is Cal/OSHA, some of whose standards are stricter and supersede federal OSHA standards. p Paint Chip Sampling. Testing done by an accredited laboratory to measure the amount of lead in a paint chip sample that was removed from a surface. Permissible Exposure Limit (PEL). According to Cal/OSHA s Lead in Construction standard, this is the maximum amount of lead that workers may be exposed to over an 8- hour workday. The PEL is 50 micrograms of lead per cubic meter of air (µg/m 3 ). Personal Air Sampling. Tests done to measure the amount of lead in the air a worker breathes on the job. Sometimes called air monitoring. (See Breathing Zone.) Poly. Polyethylene plastic sheeting, used to protect surfaces during lead work. Must be at least 4 mil thick. Power Tool Cleaning. The use of power tools (such as grinders, sanders, brushes, and needle guns) to remove dirt or paint from surfaces. Powered Air Purifying Respirator (PAPR). A respirator equipped with a battery-powered blower which draws air through filters and into the face piece. Presumed Lead-Based Paint. Defined by Title 17 as any paint or surface coating affixed to a component in or on a structure (except on residences built on or after January 1, 1979, or on schools built on or after January 1, 1993). 170

181 APPENDIX J GLOSSARY r Resource Conservation and Recovery Act (RCRA). A federal law which regulates hazardous waste disposal. (Title 42, United States Code, Section 821 et seq.) Respirator. A device worn by a worker for protection against toxic substances in the air. There are several types. An air purifying respirator (APR) uses a filter to remove the substances. It may be half-mask or full-face. An air supplied respirator provides a separate source of clean air from a hose or tank. Respirators must be NIOSH-approved. (See Air Purifying Respirator and Air Supplied Respirator.) Respiratory Protection Program. A program required by Cal/OSHA. Employers must put measures in place to ensure the safe and effective use of respirators on the job, including training, testing, selection, and maintenance. A written program is one part of these requirements. (Title 8, California Code of Regulations, Sections 1531 and 5144.) s Self Contained Breathing Apparatus (SCBA). A type of Air Supplied Respirator. Supplies air to the face piece from a tank carried on the worker s back. Sodium Rhodizonate. A chemical that turns pink or red on contact with lead in certain amounts. It is used in color-indicating tests like lead sticks. Supplied Air Respirator (SAR). See Air Supplied Respirator. t Take-Home Lead. Lead that is brought home from the job on a worker s clothing, shoes, or body. Take-home lead can contaminate cars and homes, endangering household members, especially young children and pregnant women. Title 17. This is the key regulation for work with lead in California schools. It requires accreditation of training providers by DHS. Workers who perform high risk lead work or abatement work designed to reduce lead hazards for a minimum of 20 years must be trained in accredited programs and be certified by DHS. Title 17 also specifies work practices required for lead jobs. (Section et seq of the California Code of Regulations.) Total Threshold Limit Concentration (TTLC) Test. A test to measure the amount of lead in a waste sample, which is one step in determining whether the waste should be classified and disposed of as hazardous waste. Toxic Substances Control Act (TSCA). A 1976 federal law (Title 15, United States Code, Section 2601 et seq.) Title IV of TSCA covers lead paint hazards. 171

182 LEAD-SAFE SCHOOLS Trigger Task. Any of the specific lead tasks listed as high risk in Cal/OSHA s Lead in Construction standard. These tasks almost always expose workers to lead above the PEL and must be assumed above the PEL until personal air sampling has been done. Trisodium Phosphate (TSP). A detergent that was once widely used for many types of cleaning. It binds well to lead and was added to water for cleaning up lead dust. It can cause eye irritation and environmental damage, and has been banned by some states and all federal projects. Other cleaning agents are available. TWA. Time-weighted average, a way of expressing the amount of chemical exposure to a worker by averaging the exposure over a period of time. For example, an eight-hour TWA averages exposure over an eight-hour workday. u w User Seal Check. See Fit Check. Waste Extraction Test (WET). A test to measure the concentration of soluble lead in a waste sample, which is one step in determining whether the waste should be classified and disposed of as hazardous waste. Wipe Sampling. A test to measure how much lead is present on a surface. A surface of a specific size is wiped with a baby wipe, which is sent to a laboratory for analysis. Used after lead work to determine if thorough cleanup has been done. See Clearance. x z X-ray Fluorescence (XRF) Analyzer. An electronic instrument used to test for lead in paint. The testing is non-destructive, and the results are reported in milligrams per square centimeter (mg/cm 2 ). Zinc Protoporphyrin (ZPP). A blood test that reflects a person s lead exposure over the prior 3 to 4 months, showing how much the blood-forming system has been damaged. 172

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