Lead Policy

Policy

The University of Chicago shall ensure that all work involving lead based paint be conducted in accordance with this policy to maintain employee or occupant exposures below established permissible exposure limits.

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Authority and Responsibility

The implementation of this program shall be the responsibility of the various departments to which it applies, particularly Facilities Operations, Facilities Services Capital Project Delivery and outside contractors.

Environmental Health and Safety is responsible for:

  • Responding to requests or employee inquiries within 48 hours;
  • Performing inspections of job sites, materials and equipment for quality control as necessary;
  • Coordinating exposure air monitoring for University employees, if necessary;
  • Conducting Lead Awareness training University of Chicago employees; and
  • Procuring the services of an EPA-RRP Certified firm or IDPH licensed lead abatement contractor.

Facilities Services Capital Project Delivery and Supervisors are responsible for:

  • Contacting Environmental Health and Safety for evaluation of project activities in pre-1978 buildings that may disturb any painted surface;
  • Disclosing the presence of lead to any outside contractors conducting work activities which will involve the disturbance of lead based paint surfaces in pre-1978 buildings;
  • Distributing the lead compliance program to contractors and referencing the pertinent sections or writing the pertinent section of the policy into job specifications;and
  • Bringing any safety related concerns pertaining to unsafe working practices (i.e., chemical stripping, burning, dry sanding) or procedures conducted on painted surfaces to the attention of Environmental Health and Safety.

Contractors and sub-contractors are responsible for complying with the Occupational Safety and Health Administration’s (OSHA) Construction Lead Standard 29 CFR 1926.62 and the appropriate sections of this policy.

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Activities Which Emit Lead

Employees performing maintenance activities not associated with construction work are covered by the general industry standard for lead, 29 CFR 1910.1025. Maintenance activities covered by the general industry standard are those which involve making or keeping a structure, fixture or foundation in proper condition in a routine, scheduled, or anticipated fashion.

Renovations are considered construction-related activities and this work is covered in the Construction Industry Lead Standard, 29 CFR 1926.62.

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Residential and Child Occupied Facilities

Environmental Protection Agency (EPA) Renovation, Repair and Painting (RRP) Rule

The EPA Renovation, Repair and Painting (RRP) rule applies to all pre-1978 residential buildings and child-occupied facilities (areas in residential, public and commercial buildings constructed pre-1978) if work activities will disturb interior painted surfaces >6 square feet in a single room, >20 square feet of any exterior painted surfaces or window renovation or replacement projects of any size.

Child-Occupied Facility is defined as (according to the EPA Regulations):

  • Six years of age or under, on at least two different days within any week, provide that each day's visit last at least three hours;
  • Building or portion of building visited by the same child;
  • The combined weekly visit last at least six hours and the combined annual visits last at least 60 hours; and
  • Includes common areas (e.g., rec-rooms, lounges,kitchens, bathrooms)

Portions of buildings a child will not be able to access (e.g., other apartments, offices, storage areas) or areas only meant for "pass-through" use (e.g., corridors and stairways) are exempt from the rule.

The EPA enacted the RRP Rule that requires individuals to receive certain information before renovating > 6 ft2 or more of painted surfaces in a room for interior projects or > 20 ft2  of painted surfaces for exterior projects in housing, child care facilities and schools built before 1978.  Additionally, the law requires that certain work practices designed to prevent lead contamination must be followed.  Those trained by EPA certified trainers are EPA Certified Renovators; employees trained by Certified Renovators are considered non-certified workers and must be supervised during the set-up and cleaning phases of all painting renovations.

The following warning sign shall be posted in each work area where the RRP Rule applies:

CAUTION
RENOVATION WORK
DO NOT ENTER WORK AREA UNLESS AUTHORIZED
NO SMOKING, EATING OR DRINKING

Signs must remain in place and be readable through completion of the renovation and the post renovation cleaning verification.

A warning sign must be posted:

  • At each entry to work area;
  • At each main and secondary entryway to a building from which occupants have been relocated too; or
  • For exterior work where it is easily read 20 feet from the edge of the worksite

If bulk sample results indicate the presence of lead in any building material in a residential or child occupied facility, a state-certified lead abatement contractor shall conduct all work with arrangements made by a representative from Environmental Health and Safety to ensure appropriate procedures are conducted.

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Classification of Work and Work Procedures for Lead Based Paint

Lead work and procedures shall be classified as follows:

Class A work involves:

  • Manual demolition of structures (e.g., removing a wall)   
  • Manual Scraping (includes chemical stripping) or sanding
  • Utilizing a heat gun on painted surfaces
  • Power tool cleaning with dust collection systems
  • Spray painting with lead-based paint

Class B work involves:

  • Using lead-based mortar
  • Burning lead
  • Rivet busting
  • Power tool cleaning without duct collection systems
  • Cleanup activities where dry expendable abrasives are used
  • Moving or tearing down the enclosure used for abrasive blasting

Class C work involves:

  • Abrasive blasting
  • Welding and cutting
  • Torch burning 

Note: All Class 3 work shall be conducted by a state-certified lead abatement contractor with arrangements made by a representative from Environmental Health and Safety to ensure appropriate procedures are conducted. A Lead Paint Disclosure shall be sent to building occupants for all Class 3 work. The Lead Paint Disclosure are identified in Lead Based Paint Disclosure;

Window replacement work activities and work procedures can be identified in Window Removal Procedures;
Welding operation activities and work procedures can be identified in Welding Exterior Surfaces.

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Unknown Presence of Lead

All work conducted on painted surfaces in pre-1978 buildings where the presence of lead is unknown shall be conducted in accordance with the aforementioned procedures.

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Medical Surveillance

Prior to each job where employee exposure exceeds the Action Level of 30 μg/m3 as an 8-hour TWA, 30 calendar days per year, the employer shall establish medical surveillance requirements based on the OSHA lead standard, 29 CFR 1910.1030. Medical surveillance includes an initial surveillance, on-going surveillance (e.g., biological monitoring, six-part medical exam, medical exam and consultation) medical treatment and medical removal. The medical surveillance requirements are identified in Medical Surveillance Program.

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Compliance Program

Where any employee is exposed to lead above the Permissible Exposure Limit (PEL) of 50 mg/m3 for more than 30 days per year, the employer shall establish and implement a written compliance program, identified in Compliance Program, to reduce employee exposure to the PEL or below.

The University of Chicago shall implement engineering and/or work practice controls including administrative controls to reduce and maintain employee exposure to lead at or below the PEL to the extent that such controls are feasible. Whenever all feasible engineering and work practices controls that can be instituted are not sufficient to reduce employee exposure at or below the PEL, the University of Chicago shall use them nonetheless to reduce employee exposure to the lowest feasible level and shall supplement them by the use of respiratory protection. Refer to the Respiratory Protection Program.

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Training, Recordkeeping and Signage

Training

All University of Chicago employees whose job classification airborne lead concentrations above the action level shall be trained by representatives from Environmental Health and Safety in the following:

  • The content of the standard and its appendices;
  • The specific nature of the operations that could result in exposure to lead above the Action Level;
  • The purpose, proper selection, fitting, use and limitations of respirators;
  • The purpose and a description of the medical surveillance program and the medical removal protection program;
  • The engineering controls and work practices associated with the employee’s job assignments;
  • The contents of the compliance program in effect;
  • Instructions to employees that special drugs (e.g., chelating agents) shall not be used routinely to remove lead from their bodies and when necessary used only under medical supervision; and
  • The right to access employee records.

All contractors shall also be responsible for meeting these OSHA training requirements.

Recordkeeping

Environmental Health and Safety shall establish and maintain accurate records of the following:

  • All monitoring and other data used in conducting employee exposure assessments;
  • Training records;
  • Each employee subject to medical surveillance; and
  • Medical removal records.

All records including exposure monitoring, medical removal and medical records are available upon request to affected employees, former employees and their designated representatives and shall be maintained for at least thirty years.

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Signage

The following warning signs shall be posted in each work area where an employee’s exposure to lead is above the PEL (typically Class 3 work activities of which signage shall be provided by the licensed abatement contractor).

WARNING
LEAD WORK AREA
POISON NO SMOKING OR EATING

These signs shall be illuminated and cleaned as necessary so that the legend is readily visible. Signs that contradict or detract from the meaning of the sign are prohibited.

Reviewed: August 30, 2015

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