The Catholic University of America

Contractor Safety Guide

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Lead-Based Paint

 

Contractors must assume all painted surfaces in residential buildings constructed prior to March 1, 1978 contain lead. Any construction or renovation work in buildings constructed prior to March 1, 1978 must be done in accordance with 29 CFR 1926.62, the OSHA Lead in Construction Standard, and include appropriate exposure monitoring.   The CUA office of Environmental Health & Safety (EHS) may collect dust-wipe samples upon the completion of renovation/construction projects to determine residual levels of lead dust and ensure the use of proper lead-safe work practices and the effectiveness of final clean-up activities.  Generated waste which may be lead-contaminated shall be appropriately tested via a toxicity characteristic leaching procedure (TCLP) test to ensure proper disposal.
 
Select construction or renovation work disturbing lead-based paint in Nugent Hall, Curley Hall, or Curley Annex must also be performed in accordance with the applicable local DC requirements and the EPA’s Renovation, Repair and Painting (RRP) Rule, using EPA-certified firms with properly trained personnel and specific lead-safe work practices. Projects subject to the RRP Rule include:
 
·        Renovations/repairs involving the disturbance of greater than 6 square feet of lead-based paint per interior room;
·        Renovations/repairs involving the disturbance of greater than 20 square feet of lead-based paint per building exterior;
·        Any window replacement project involving lead-based paint.
 
For work covered by the RRP Rule, submit copies of applicable training and certification documents to EHS prior to the start of the project.

 

For situations requiring lead-based paint abatement:

Provide only trained/certified workers who will be equipped with necessary personal protective equipment and any other equipment needed to protect themselves and others from overexposure to lead. Contain the lead-contaminated waste to facilitate proper disposal.

 
Dispose of all waste materials generated in compliance with all applicable federal, state and local laws, regulations and codes.  Clearly and accurately identify the lead-containing waste.  PROVIDE ALL HAZARDOUS WASTE MANIFESTS TO THE PROJECT MANAGER FOR SIGNATURE, so that a CUA representative may sign as the generator.  Do not sign the manifest on the behalf of CUA as the generator.
 
Industrial hygiene services required as part of the work, such as ambient air monitoring and final clearance dust-wipe testing, must be conducted by or under the direction of a person certified as an industrial hygienist (CIH) by the American Board of Industrial Hygiene.  Final clearance dust wipe samples collected following abatement activity must be collected by a properly trained and certified risk assessor and must meet the appropriate District of Columbia criteria to permit re-occupancy: 40 micrograms per square foot (μg/ft²) for floors, 250 μg/ft² for interior window sills, and 400 μg/ft² for window troughs.  Industrial hygiene services will be provided by a consultant under contract with CUA. 
 
Analysis of lead in environmental samples including paint, soil, dust wipes and air, must be performed by a laboratory accredited by the AIHA ELLAP (Environmental Lead Laboratory Accreditation Program).
 
Submit notification to the District Department of the Environment at least seven (7) business days prior to the start of the project and obtain appropriate approvals and permits as necessary;

  • Provide two copies of the applicable notification, permits, approvals, etc., one each to the CUA/FPC project manager and to EHS;
  • Submit to EHS evidence of proper training, licenses and/or certifications for each employee scheduled to be on the job, including respirator training when respirators are to be worn;
  • Submit a detailed, job-specific work plan to EHS including a copy of the written respiratory protection program if applicable. Include work procedures, equipment/materials to be used, safety precautions to be taken, personal protective equipment to be worn, and how waste will be collected/stored/disposed. Where applicable, include air monitoring to be performed and MSDSs for all agents to be used.

 

REFERENCES

29 CFR 1926.62;

40 CFR 260-268, 745;

DCMR Title 20, Chapter 33; District of Columbia, Regulation of Lead-Based Paint Activities;

District of Columbia’s Lead–Hazard Prevention and Elimination Act of 2008, DC Law 17-381, DC Code Sec. 8-231.01 (et seq.) (2009 supp.)