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Lead-Safe Schools ProjectLabor Occupational Health ProgramUniversity of California at Berkeley

Lead-SafeSchools Guide

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 PreventionProgram, 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, andthe California Department of Education.

Labor Occupational Health ProgramUniversity of California2223 Fulton StreetBerkeley, CA 94720-5120

Printed by Office of State Printing, Sacramento, CA.

Lead-SafeSchools Guide

For Maintenance and Operations

Departments

iii

Acknowledgments

Writers

Robin Dewey, MPHGail Bateson, MSMichele González Arroyo, MPHBarbara A. Plog, MPH, CIH, CSPLeonor Dionne, MS

Project Coordinator

Michele González Arroyo, MPH

Technical Coordinator

Barbara A. Plog, MPH, CIH, CSP

Editing, Design, and Production

Gene DarlingKate Oliver

Illustrator

Mary Ann Zapalac

Project Assistant

Carmen FoghornDonna Iverson

LOHP Director

Robin Baker, MPH

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Contributors and Reviewers

Organizations

LOHP is indebted to the following organizations for their contributionsto 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, CSPHealth Science AssociatesEmeryville, CA

Individual Contributors and Reviewers

Ellen AaslettenPlanning Department, California Department of Education

Doug AdamsSan Diego Unified School District

Mark AllenAlameda County Lead Poisoning Prevention Program

Lynn AndersonDepartment of Social Services, Community Care Licensing Division

Amy ArcusOffice of Environmental Health Hazard Assessment (OEHHA), DHS

Don BenningSacramento Unified School District

Rachel BroadwinOffice of Environmental Health Hazard Assessment (OEHHA), DHS

Duwayne BrooksSchool Facilities Planning Division, California Department of Education

Simone BrumisOccupational Lead Poisoning Prevention Program, DHS

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Zin CheungEducation and Training Unit, Cal/OSHA Consultation

Kimberly CometNorth Coast Schools Insurance Group

Susan CumminsChildhood Lead Poisoning Prevention Branch, DHS

Lyn DaileyCalifornia Childcare Health Project

George DatzCalifornia School Employees Association

Jill GarellickChildhood Lead Poisoning Prevention Branch, DHS

Bruce GianiniAsbestos Control, San Francisco Unified School District

David HarringtonOccupational Lead Poisoning Prevention Program, DHS

Richard HenryMaintenance and Operations, Los Angeles Unified School District

John HulsMaintenance and Operations, San Juan Unified School District

Catherine Wilson JonesSelf Insured Schools of California

Larrie LanceChildhood Lead Poisoning Prevention Branch, DHS

Don LanierU.S. Environmental Protection Agency

Eleanor LongLos Angeles Lead Poisoning Prevention Program

Barbara MaternaOccupational Lead Poisoning Prevention Program, DHS

Scott McAllisterCal/OSHA, Department of Industrial Relations

Jon MerkelU.S. Environmental Protection Agency

Rhonda Bacot-MilanHayward Unified School District

Dana PolkChildhood Lead Poisoning Prevention Branch, DHS

Gary PonsLos Angeles Unified School District

Dan ScannellChildhood Lead Poisoning Prevention Branch, DHS

M.A. StevensonPublic Utilities Commission, City and County of San Francisco

Mona ThabitSan Diego County Health Department Lead Program

Mike ZurichCalifornia Association of School Business Officials

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Contents

Chapter 1 About This Guide .................................................................... 1

Chapter 2 Health Effects of Lead ............................................................ 9

Chapter 3 Elements of a Lead Program ................................................. 19

Chapter 4 Identify Lead in Schools ....................................................... 29

Chapter 5 Analyze Maintenance Tasks .................................................. 53

Chapter 6 Provide Worker Protection .................................................... 61

Chapter 7 Use Safe Work Practices ....................................................... 71

Chapter 8 Train Workers ........................................................................ 91

Chapter 9 Document and Evaluate the Program ................................. 103

Forms ......................................................................................................... 109

Program Planning Form .................................................................. 111

District Target Schools Form .......................................................... 115

Building Inventory Form—Paint & Soil Hazards .......................... 117

Appendices ................................................................................................ 119

A. California DHS Report—Executive Summary ......................... 121

B. Lead in Construction Standard—Summary .............................. 127

C. Hazard Communication Standard—Summary ......................... 137

D. Injury and Illness Prevention Program—Summary ................. 139

E. Lead-Safe Schools Protection Act ............................................ 141

F. Title 17—Summary ................................................................... 143

G. Contractor Requirements .......................................................... 149

H. Guidelines for Volunteers .......................................................... 153

I. Resources for More Information .............................................. 155

J. Glossary of Terms ..................................................................... 165

C H A P T E R 1 — A B O U T T H I S G U I D E

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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 CaliforniaDepartment of Health Services (DHS) in 1998 found lead in most publicelementary schools in the state. Nearly 96% of schools—even some newerones—have detectable levels of lead in the paint. The study also found leadin the drinking water at some schools, and in the soil around older schoolbuildings. (See Appendix A for a summary of the DHS study.)

The results of the DHS study prompted a statewide effort to provide schooldistricts with the information and training they need to address leadproblems. The Lead-Safe Schools Project was begun in late 1998. This jointeffort of several state agencies and the University of California at Berkeleywill help school districts to initiate or strengthen their own lead-safe schoolsprograms. Such programs set clear policies, procedures, and action plans forall lead work in schools.

This Lead-Safe Schools Guide is a tool that California school districts canuse to create a safer school environment. It focuses on custodial andmaintenance work in schools. This type of work, if done unsafely, can exposeboth children and workers to significant amounts of lead. The Guide isintended primarily for staff in California public elementary schools andchildcare facilities (such as daycare centers associated with schools anddaycare programs for teen parents).

The theme of this Guide is that, with proper resources and training, leadhazards can be managed and controlled safely as part of standard school

◆1

About This Guide

CHAPTER

L E A D - S A F E S C H O O L S

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maintenance practices. Controlling lead hazards is usually a safer alternativethan the complete removal of lead. The measures outlined here will go a longway toward making our schools safer.

Systematic policies and procedures for lead work are also cost-effective. Forexample, school districts can wind up spending more than expected forrenovation and maintenance work if it is done in an unsafe manner or withuntrained personnel. Unsafe practices can create new problems that have tobe corrected later at great expense, and can potentially result in costly legaldifficulties 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 majorrenovation of one of their older elementary schools.Several contractors were brought in. Many of them wereexperienced in lead work. They and their employees hadreceived lead training and were state-certified.

In preparation for repainting, a school district maintenancecrew water-blasted the outside of the school. There hadbeen no testing of paint samples for lead. Paint chips fellto the ground, and were blown around by the wind.

The contractors reported the water blasting togovernment agencies, which led to site inspections byCal/OSHA and several other agencies. It was found thatthe paint chips did contain lead. The district was requiredto clean the entire school complex with special HEPAvacuum cleaners inside and out. They also had to notifyall neighbors within a two-block radius of the schoolabout their potential lead exposure.

Unofficial estimates of the clean-up costs included:$15,000 in labor costs for the 10 days it took to vacuumaround the school, $20,000 in lost wages to thecontractors who couldn’t work during the clean-up, andabout $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 writingensures that work involving lead will be handled safely and consistently.


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This Guide gives advice on controlling lead hazards in paint, water, and soilwhile doing routine day-to-day maintenance and custodial work. It does notcover lead abatement, demolition, renovation, or activities involvingcomplete paint removal, which should always be done by highly trainedworkers and supervisors who are state-certified in lead-related construction.However, it does provide specific guidelines on when and how to use state-certified lead workers and contractors.

Why Worry About Lead?

Lead is highly toxic to the human body. At one time, before its hazards werefully understood, lead was widely used throughout society in many industrialand consumer products. Today, it can still be found in some paints, solders,construction materials, pipes, plumbing fixtures, batteries, and even dishesand hobby supplies.

Over time, lead from such products and from manufacturing processes hascontaminated air, water, soil, and food. Although recent legislation haseliminated lead in gasoline and greatly reduced it in manufactured products,widespread contamination of the environment by lead continues to be aproblem.

Lead can cause serious health effects at any age, but it is especiallydangerous for children eight and under. Lead poisoning is the most commonenvironmental health problem affecting young children. It can permanentlydamage the brain and nervous system, slow growth, and cause learning andbehavior problems.

But lead poisoning is preventable. Lead hazards (such as deteriorating ordamaged lead paint, contaminated soil, or contaminated water) can becontrolled, both in the home and the school. For schools, this Lead-SafeSchools Guide is an important first step.

Who Can Use This Guide?

The Guide is primarily intended for California school district Maintenanceand Operations (M&O) departments. These departments, known by variousnames in different school districts, typically include both custodial andmaintenance personnel.

School superintendents, principals, and other administrators also play a keyrole in creating lead-safe schools and can benefit from the Guide. In somecases, they may directly supervise custodial and maintenance workers. Theyalso provide a link to all other members of the school community.


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There is an increasingly aware population of parents, teachers, school staff,administrators, and school board members who are concerned about lead andother environmental matters. Informing and educating them can addressunwarranted fears as well as help ensure safe work practices.

In these times of limited resources, parents, teachers, and others may want tohelp by taking on volunteer maintenance projects. There are numerousstories about parents’ clubs repainting buildings or playground equipmentwithout being aware of the potential lead hazards they may create. Forexample, consider this recent news story:

Parent Attempt To Help School Backfires

Staff from one small California school district vowthey will never again allow parent volunteers to help withjobs that disturb lead paint. A father, believing he washelping the school, chipped off loose paint from anoutdoor play structure at the school to prepare it forrepainting. The paint contained lead. All of the sand nearthe structure had to be removed and replaced. The sandhad not been protected from the falling lead paint chipsas required by law. Proper disposal and replacement ofthe contaminated sand cost the school district $6,000.

Administrators can use the material in this Guide to build awareness of thehazards involved in painting and other maintenance work.

It should be noted that following lead-safe work practices will probablyinvolve an investment of money for equipment and materials, and aninvestment of time. The entire school community needs to be aware thatfollowing recommended procedures for controlling lead may mean thatmaintenance jobs take longer. But the investment of time is worthwhile. Therecommendations here can help schools protect children and staff fromserious 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 uselead-safe practices under several laws and regulations (both state and federal).


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These regulations include:

Lead-Safe Schools Protection Act (LSSPA) of 1992. [California Education

Code. Sections 32240–32245] Requires California public elementary schoolsand childcare facilities to use state-certified construction personnel whenabating lead hazards. Also forbids the use of lead-based paint, lead plumbingand solders, or other potential sources of lead contamination in new schoolconstruction and in school modernization or renovation projects.

Accreditation, Certification, and Work Practices for Lead-BasedPaint and Lead Hazards. [Title 17, California Code of Regulations, Section

35001 et. seq.] This is the key state regulation for lead work. Defines “leadhazard” as deteriorated lead-based paint, lead contaminated dust, leadcontaminated soil, disturbing lead-based paint or presumed lead-basedpaint without containment, or any other nuisance which may result inpersistent and quantifiable lead exposure.

Requires accreditation of training providers by California DHS. Requirestraining in accredited programs and subsequent certification by DHS ofworkers who perform abatement and other high risk lead-relatedconstruction work such as any alteration, painting, demolition, salvage,renovation, repair, maintenance, preparation, and cleanup that may resultin significant exposure of adults or children to lead. There are fivecategories of certification with different training and experiencerequirements: Lead Worker, Lead Supervisor, Lead Project Monitor, LeadProject Designer, and Lead Inspector/Assessor.

Sets out requirements for all lead abatement work in public buildings andresidential buildings. Defines “lead abatement” as any set of measuresdesigned to reduce or eliminate lead hazards or lead-based paint in thesebuildings. (However, this does not include containment or cleaning.)Requires state-certified workers and supervisors for abatement workwhich is designed to reduce lead paint or other lead hazards for aminimum of 20 years. Requires other measures as well.

For abatement designed to reduce lead paint hazards for less than 20years, Title 17 has a list of requirements including specific workprocedures that follow Chapter 11, Interim Controls, of the U.S. Housingand Urban Development (HUD) Guidelines for the Evaluation andControl of Lead-Based Paint Hazards in Housing, June 1995.

Cal/OSHA Lead in Construction Standard. [Title 8, California Code of

Regulations, Section 1532.1] Requires safe practices in all construction andmaintenance work where an employee may be exposed to lead. Californiaschool employees are included. Activities covered include alteration,repair, and even painting of buildings.


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Sets requirements related to permissible level of worker exposure,exposure assessment, work practices, personal protective equipmentincluding respirators, medical surveillance programs (including bloodtesting), housekeeping, hygiene facilities and practices, signs, andrecordkeeping.

Also defines a set of “trigger tasks” which are assumed to incur leadexposure over the legal limit and require respiratory and other protectionuntil an actual exposure assessment is done. Also sets out requirementsfor “medical removal protection,” where an employee is removed fromlead work and given alternate work, or paid leave and benefits, untilmedically released for return to lead work.

Federal Lead Contamination Control Act of 1988. [Title 42, United

States Code, Section 300j-21] An amendment to the federal Safe DrinkingWater Act of 1974. It prohibits lead-lined water coolers in schools andchildcare facilities, and requires the U.S. Environmental ProtectionAgency (EPA) to set up an information program to help local schooldistricts 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 Californiaemployers to have a written program that outlines how they plan toassess hazards, correct them, and communicate information to workers.This Injury and Illness Prevention Program (IIPP) must cover hazards ateach specific worksite, including lead.

Cal/OSHA Hazard Communication Standard. [Title 8, California

Code of Regulations, Section 5194] Requires California employers to informworkers 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 workpractices, and protective measures.

Federal Toxic Substances Control Act (TSCA) of 1976. [Title 15,

United States Code, Section 2601 et seq.] Regulates all chemicals imported orproduced in the U.S. Requires testing of commercial chemicals for toxiceffects and regulates use and cleanup. Title IV of TSCA covers lead painthazards. Enforced by EPA, sometimes in conjunction with other agenciessuch 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 www.childlead.com. ForCal/OSHA standards go to www.dir.ca.gov. Click on “Occupational Safety &Health” and go to Title 8 Regulations. For EPA regulations and relatedinformation, go to www.epa.gov/lead.

C H A P T E R 2 — H E A L T H E F F E C T S O F L E A D

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Failure to comply with these various requirements can raise legal andliability issues for a school district. But, much more importantly, followingthe law provides an opportunity to protect school children and employeesfrom lead poisoning. We can hope that children are not exposed to lead athome, 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 districtsminimize exposure of children and staff to lead in the school environment. Itis a joint effort of the Labor Occupational Health Program at the Universityof California, Berkeley; the Childhood Lead Poisoning Prevention Branch ofthe California Department of Health Services; and the California Departmentof Education. The Project has developed recommendations for many aspectsof a lead-safe schools program, including hazard surveys, custodial andmaintenance work practices, training, recordkeeping, and other issues. Theserecommendations appear throughout this Guide and are consistent with legalrequirements.

In addition to the Guide, the Project also has a training curriculum andvideotape to teach school custodians and maintenance staff about lead-safework practices. Training on how to present these materials to staff will beoffered to representatives from each California school district, beginning inthe fall of 1999.

The Lead-Safe Schools Project also has a technical hotline. School districtstaff can call with questions about material in this Guide and related issues.For more information about the Project, to reach the technical hotline, or toobtain a copy of the curriculum, call U.C. Berkeley’s Labor OccupationalHealth Program at (510) 642-5507. The curriculum is also available from theChildhood Lead Poisoning Prevention Branch of the California Departmentof Health Services. Check the website www.childlead.com.


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Who Is at Risk from Lead Hazards?

Lead can harm people of any age, but it is especially hazardous for childreneight and under. Young children are at a higher risk because:

◆ They often put their hands and other objects into their mouths, andcan easily swallow any lead dust that is present.

◆ Their growing bodies absorb more lead than older children andadults. For example, young children absorb up to 50% of the leadthey swallow, while adults typically absorb only about 10%.

◆ A developing child’s brain and nervous system are particularlysensitive to the effects of lead.

The U.S. Centers for Disease Control and Prevention (CDC) found thatapproximately 900,000 U.S. children between 1 and 5 years old haveabnormally high levels of lead in their blood. In California approximately239,000 children have lead levels high enough to put them at risk of healthdamage, according to the Department of Health Services (DHS) studysummarized in Appendix A.

Lead can also be hazardous for adults. Workers who are exposed to highamounts of lead on the job can face serious health damage. Men and womenwho are planning to have children, and pregnant women, are especially atrisk.

◆2Health Effects of Lead

CHAPTER


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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 orin air, water, or soil. Note that lead dust can be invisible. It may be present indangerous amounts even if it is not seen by the naked eye.

Food, drink, and cigarettes can become contaminated if they are stored orconsumed in an area with lead dust. Lead may also be found in vegetablesgrown in lead-contaminated soil.

Once lead enters the body it gets into the bloodstream. It then circulatesthroughout 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 upand stay for years. Many parts of the body can be damaged by lead. The morelead 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.


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How Can School Employees Be Exposed to Lead?

Workers can be exposed to lead if they:

◆ Breathe lead dust or fumes created duringpossibly unsafe work activities, such as:

• 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 takelead dust with them if they wear work clothes or shoes home. Lead dust canget into the car, furniture, and carpets. It may then be spread throughout thehome, endangering everyone.

UNSAFE!


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What Health Problems Can Lead Cause in Children?

Lead is a poison that affects virtually every system in the body. Evenexposure to low levels of lead can permanently affect children. The damagecan occur soon after exposure, or many years later.

Lead is particularly harmful to a young child’s developing brain and nervoussystem. 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 leadcan 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 toknow if a child has lead poisoning is to get a blood test. (There is moreinformation on blood testing later in this chapter.)

When symptoms do occur, they are often the same as those of commonillnesses like a cold or the flu. Other early signs and symptoms of leadpoisoning in children can include:

• Persistent tiredness or hyperactivity

• Irritability

• Loss of appetite

• Weight loss

• Reduced attention span

• Difficulty sleeping

• Constipation.


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Brain and Nervous System

Permanent brain damage canoccur. This may affect the abilityto think and cause personalitychanges.

Heart and Blood

Lead can cause anemia, whichmay make one feel weak andtired. Lead can also cause highblood pressure.Kidneys

Permanent damage can occur.Kidneys may be seriouslydamaged before any obvioussymptoms appear, and beforetests show anything abnormal.

Bones

Lead can be stored in the bonesfor many years without causingsymptoms. It is gradually releasedback into the bloodstream andcan cause damage. Pregnancy,lactation, stress, and certainillnesses can increase thisrelease.

Digestive System

Lead can cause nausea,constipation, diarrhea, cramps,lack of appetite, pain in thestomach or abdomen, andweight loss.

Reproductive System

Lead can damage the reproductivesystems of both men and women. Itmay decrease sex drive, reduce theability to have children, andincrease the risk of miscarriage,stillbirth, and birth defects.

What Problems Can High Lead Levels Cause in Adults?


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Why Is Lead Hazardous for Pregnant Women?

Pregnant women are especially sensitive to the damage leadcan cause because:

◆ Lead can easily cross the placenta and harm thedeveloping fetus.

◆ During pregnancy, any lead stored in the bones is morelikely to be released into the blood.

When pregnant women are exposed to high levels of lead theirinfants 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 tomeasure how much lead has entered the body. Both of these blood tests canbe done from the same blood sample.

The results of the BLL and ZPP tests are reported inmicrograms of lead per deciliter of blood (µg/dl).

◆ A microgram of lead is roughly the weight ofone tiny piece of dollar bill, if the bill is torninto a million equal pieces.

◆ A deciliter of blood is about seven tablespoons.

The BLL Test. Measures the amount of lead circulatingin a person’s blood. It gives an estimate of recent leadexposure, or of lead recently released from the bones.The BLL test cannot measure past lead exposure, theamount of lead stored in the body, or the effect lead ishaving on the body. The typical BLL for adults with nospecific lead exposure is less than 3 µg/dl.


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The ZPP Test. Measures a particular protein in the blood. It does notmeasure the amount of lead in the blood. The results estimate exposure tolead 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 hadvery recent exposure to lead. The typical ZPP for adults with no specific leadexposure 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 foradults. Lead does not belong in our bodies at all. Most people, includingchildren, are free of symptoms at BLL levels of 10 µg/dl or less. Both CDCand the California Department of Health Services consider any BLL above10 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’sspecific BLL. It can include:

◆ An environmental investigation to determine possible sources of thechild’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 achild has an elevated BLL, the home is the most likely suspect, but theschool 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, theCal/OSHA Lead in Construction standard says that workers whose BLLs areat or above 50 µg/dl (on two consecutive tests) as a result of their jobs mustbe removed from all lead exposure at or above the Action Level. Workersmust 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 theAction Level, if one is available. For more on medical removal protection,see Chapter 6.


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The Cal/OSHA standard (see Appendix B for a summary) also requires anumber of other measures to monitor and lower workers’ lead exposure andBLLs. For workers whose BLLs are at or above 40 µg/dl, it provides formedical 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 schoolshave limited control over children’s diets, they should encourage students toeat 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 childrenhave food in their systems.

• Eat foods high in calcium, like dairy products. When a child does nothave enough calcium in his or her body, the body mistakes lead forcalcium.

• Eat foods high in iron, like meat, chicken, beans, and raisins. Mostbreads and cereals also have iron since they have been fortified. Ifchildren get enough iron, they won’t absorb as much lead.

• Avoid fried and fatty foods. These foods allow the body to absorblead faster.

• Wash their hands before they eat. Lead can be found in dust and soilin and around schools. While lead cannot be absorbed through theskin, it can be swallowed.

What Is Chelation?

Chelation therapy is the primary medical treatment for severe lead poisoningin both adults and children. It can be a painful and risky treatment. Chelatingdrugs attach themselves to lead in the body and are then filtered out throughthe kidneys into the urine. Some chelating drugs are injected and others canbe taken orally. Chelation should only be done on a case by case basis,always under the care of a physician who is knowledgeable and experiencedin the management of lead poisoning.


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Cal/OSHA strictly forbids the practice called prophylactic chelation. This iswhen workers who are being exposed to lead on the job are routinely givenchelating drugs to keep their lead levels down. This practice is dangerous aswell as illegal. The best and safest therapy for lead poisoning is to stop theexposure to lead.


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C H A P T E R 3 — E L E M E N T S O F A L E A D P R O G R A M

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Why Do You Need a Lead-Safe Schools Program?

It is essential to develop a comprehensive written lead-safe schools programfor your district. A clear set of policies and procedures addressing leadhazards 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 andfederal laws require school districts to control lead.

◆ Avoid unnecessary costs. By knowing how much lead is present andthe extent of the lead hazards, a school district can determine themost cost effective way to deal with the problem. Remember thatunsafe practices can create new problems that have to be correctedlater at great expense.

What’s Needed To Develop a Program?

Manager. Someone in your school district should be designated to overseethe lead-safe schools program. This program manager should be givensufficient authority and resources to do the job effectively. The managershould be a person familiar with the Maintenance and Operationsdepartment’s existing policies and procedures, particularly those related to

◆3Elements of a Lead Program

CHAPTER


20

health and safety. Knowledge of lead regulations is essential. It isrecommended that the manager have training from a state-accredited leadtraining 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 Programstandards is also important.

The role of the program manager is to design, implement, and documentyour lead-safe schools program. The remainder of this Guide outlines theprocess step by step.

Documentation. To keep track of your program’s decisions, policies, andprocedures, consider compiling a file or binder devoted to lead issues. Alsouse this file for the various types of documentation discussed in the sectionsbelow. Sample forms that can be used for some of this documentation appearin the Forms section at the end of the Guide. Ultimately this material can bedeveloped 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 safetyproblem: identify, evaluate and control the hazard, and then document whatyou 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 moredetail throughout the rest of this Guide.


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1. Identify Lead in Schools.

Collect and Review District Records. Existing records can givea first indication of which school sites are most likely to havelead hazards. Make a list of target schools—those with childreneight and under that were built before January 1, 1993. Thencheck the painting history, dates of plumbing work, and previousair, soil, and water sampling records if any. It is also useful tocollect school site maps and photos if available.

Survey Paint and Soil at Target Schools. Paint and soil should be visuallyinspected for lead hazards at all target schools. Visual inspections may bedone by M&O personnel with at least general lead awareness training, butmust always be supervised by the Lead-Safe Schools Program Manager or astate-certified Lead Inspector/Assessor. Repeat these surveys every few yearsor after any major damage.

By law, a “lead hazard” is defined as deteriorated lead-based paint, leadcontaminated dust, lead contaminated soil, disturbing lead-based paint orpresumed lead-based paint without containment, or any other nuisance thatmay result in persistent and quantifiable lead exposure.

Survey forms can be used to document what paint and soil problems werefound. 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 ifthere is lead in paint is to test it. However, Title 17 of the California Code ofRegulations says that all paint at schools built before January 1, 1993 is“presumed lead-based paint.” An alternative to testing is to assume that paintcontains lead and always use lead-safe work practices.

Soil near buildings built before 1940 should be tested if it is accessible tochildren. If testing isn’t feasible, and children use the area, cover the soil ordeny access to the area.

Test Water at All Schools. Drinking water should be tested for lead ifrecords do not indicate previous testing. New tests should be done afterplumbing renovations.

During the site survey of paint and soil, ask school maintenance staff aboutsources of drinking water and any recent plumbing work.

Set Priorities for Hazard Control. Determine how and when you plan towork on the most serious lead problems. Give them priority on themaintenance schedule where possible. Adjust your department workplan andpolicies accordingly. Also decide which lead control jobs can be done bydistrict staff and which may require state-certified contractors. For more onidentifying lead in schools, see Chapter 4.


22

2. Analyze Maintenance Tasks.

Evaluate Tasks for High Risk and Lower Risk Exposure.Analyze maintenance tasks done throughout the school districtand categorize them as either high risk or lower risk. Thesecategories will help you select workers for each task, give themthe right training, and put appropriate work practices in place.Both routine tasks and those specifically designed to reduce leadhazards should be reviewed this way.

The district should evaluate pending maintenance requests to see if theycould disturb lead paint. Current work practices might create lead hazards.Certain work may need to be postponed until your lead-safe schools programis in place. For more on analyzing maintenance tasks, see Chapter 5.

3. Provide Worker Protection.

Choose Appropriate Protection for Workers. Requiredprotective clothing and equipment varies according to a worker’sexpected lead exposure level. For lower risk tasks, only coverallsmay be necessary. For high risk tasks, workers may have to wearrespirators. The employer must supply whatever clothing andequipment are required. You need a system for purchasing,distributing, and maintaining this equipment, and you must trainworkers in how to use it. For more on protective equipment, seeChapter 6.

4. Use Safe Work Practices.

Establish Procedures for Working Safely. Your written leadprogram should describe in detail the lead-safe work practices andprocedures that must be followed for various types ofmaintenance work. Procedures should be spelled out for allaspects of the job—initial personal air sampling, setup, doing thework, cleanup, disposing of waste, and quality assurance. It iscritical to clean up properly after working and never to leave thework unattended. Depending on the level of lead exposure, youmay also need policies on medical testing of workers.

Obtain Necessary Supplies. You should have a system forpurchase of necessary equipment and supplies before beginningany job that may disturb lead. These include “caution” tape,plastic sheeting, and warning signs. Sometimes special powertools are needed. Provide handwashing facilities, and lunch areasseparate from work areas, for workers who may have leadexposure. For more on safe work practices, see Chapter 7.


23

5. Train Workers.

Design and Conduct Worker Training. All workers, includingcustodians, should be given a basic “awareness” level of leadtraining if they work around lead. If district maintenance staffwill do either routine maintenance work involving lead, orspecific lead control work, you need a more advanced trainingprogram. Design appropriate training (or locate outside sources oftraining) and schedule staff to attend. Keep a record of dates whenindividuals were trained. Some workers may need to obtain DHS-accredited training and DHS Lead Worker certification. Requireall contractors doing work that involves lead exposure to provideproof of DHS-accredited training and DHS certification for lead-related construction.

Evaluate Job Duties. New job duties may raise certain personnel issues.Some tasks once done by custodial or maintenance staff may now requirespecial training. Whether current staff are retrained or other specially trainedstaff are used, it may be necessary to revise job descriptions.

Educate Parents and Teachers. Alert and educate parents, teachers, andothers about the hazards of lead. City and county lead poisoning preventionprograms can be a source of educational materials and other resources. (SeeAppendix I.)

Parent volunteers and other untrained individuals are not qualified to do anywork involving possible lead exposure. Establish a policy that strictlyprohibits such activity. For more on training, see Chapter 8.

6. Document and Evaluate the Program.

Document Program Activities and Maintain Records. Developa system to keep track of all the information your programgenerates and decisions you make. Some state and federalregulations have specific recordkeeping requirements. Forexample, air sampling and blood lead test results must be kept onfile according to Cal/OSHA rules.

Keep track of the outside resources your program uses. These may includelabs, 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 toappropriate people in your district, such as principals, school administrators,and managers in the Maintenance and Operations (M&O) department.


24

Regularly Evaluate and Improve Your Program. Programs improve only ifyou evaluate them periodically and determine what could be done better. Forexample, when tasks involving lead are done, periodically monitor how muchexposure the workers have. High lead levels may point to a need for futureimprovement in work practices or training. There should be a system toobtain this kind of input regularly and document it.

Talk to other school districts regularly to get ideas on what could be donedifferently to improve your program. Update your program as needed. Formore 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 workpractices requires spending some money to purchase necessary equipmentand supplies (for example, plastic sheeting, HEPA vacuums, power tools thatcan take HEPA attachments, and possibly air sampling equipment). For someschool districts, particularly small districts, these costs may present ahardship. Sharing resources with surrounding districts can help small schooldistricts save money. Maintenance departments in other districts may be ableto 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 otherservices with nearby districts. JPAs might also be used to share equipmentand other resources needed for lead-safe schools programs.

In some cases, groups of nearby California school districts have purchaseditems jointly and stocked a special trailer which can go from school toschool. The trailer carries tools, equipment, and disposable supplies likeplastic sheeting and tape. Some trailers have equipment for both asbestos andlead 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 helporganize your entire lead-safe schools program. This form, used inconjunction with other documentation, can guide you in developing yourprogram. It covers all six elements discussed earlier in this chapter. For eachelement, 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 eachelement of your program is in place. Keep the form on file and providecopies to appropriate school district managers.


25

Program Planning Form

Name of School District ___________________________________ Date ______________________

Program Manager

� A Program Manager has been appointed.

Name ___________________________________ Title _______________________________

Location _________________________________ Phone ______________________________

� The Program Manager reports to:

Name ___________________________________ Title _______________________________

Location _________________________________ 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 ___________________________________ Title _______________________________

Location _________________________________ Phone ______________________________

Attach a sheet with additional names if necessary. Also attach a completed BuildingInventory Form—Paint and Soil Hazards for each school building surveyed.


26

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.)


� Drinking water has been tested at all schools.



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 onsampling results and/or other data.

Attach list of tasks.


27


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 anddistributed to workers.

Attach written policies and procedures.

� Equipment and supplies necessary for lead work have been purchased (caution tape, plasticsheeting, sprayers, detergent, HEPA vacuums, etc.).


� Wipe sampling has been done on selected jobs to check quality of containment and cleanup.

Attach sampling results and lab “chain of custody” forms.


28


� Policies and procedures on lead waste disposal have been developed.


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. Alsoattach 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&Omanagers.

� The program has been explained to all M&O workers.

� A system for maintaining records has been developed.

� 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-trainingprograms, etc.).

Attach schedule.

C H A P T E R 4 — I D E N T I F Y L E A D I N S C H O O L S

29

What Is a Lead Inventory?

The first element of a lead-safe schools program is to get an overall sense ofthe 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 ofidentifying, evaluating, and prioritizing the lead hazards in all your schoolsdistrict-wide.

Where Is Lead Found in Schools?

Most commonly, lead may be present in the paint, dust, soil, and water atschool facilities. A recent California Department of Health Services (DHS)study of public elementary schools statewide, cited in Chapter 1, found manylead hazards. DHS discovered that nearly 96% of the schools surveyed havedetectable levels of lead in the paint, 6% have lead in the nearby soil, and18% have lead in the drinking water. Each of these sources is discussed inthis chapter. (See Appendix A for a summary of the DHS study.)

Lead hazards in paint, dust, and soil are related. The main source of soilcontamination is lead paint. Paint on buildings and play structures candeteriorate or be disturbed, and chips, dust, or water runoff containing leadcan get into the nearby soil. Therefore, it makes sense to look at paint andsoil hazards together.

On the other hand, lead contamination in water has different sources andmust be considered separately. Don’t overlook the hazards of lead in water.

◆4Identify Lead in Schools

CHAPTER


30

Fortunately it is a fairly easy problem to identify and control. While paintand soil problems are more common at older schools, there can be lead in thewater at any school. Both schools with new plumbing work and very oldschools (pre-1930) can have significant problems of lead in water.

This chapter first discusses how to identify, evaluate, and test for lead inpaint 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 artsupplies, photography supplies, pottery glazes, science lab materials, andalso in some vinyl miniblinds. School districts should evaluate whether thereare ways to eliminate these sources of potential exposure. However, thisGuide only addresses lead in paint, dust, soil, and water.

Does Most Paint Contain Lead?

Yes. Almost all commercial paint sold before 1993 containedsome lead. As evidence of its hazards began to emerge, industryand government took steps to eliminate it.

Lead in paint used to be a sign of quality. The higher the leadcontent, the better the paint. Lead was added to paint to make itlast longer, dry faster, and stick better. Older schools and otherbuildings are more likely to have paint containing high levels oflead. This old lead paint is often covered with more recent layersof paint that may not contain lead.

Until the mid-1950s, paint contained as much as 50% lead. In1955, the paint industry adopted a voluntary standard limitinginterior paints to 10,000 ppm (or one percent) lead. In 1978, theU.S. Consumer Product Safety Commission (CPSC) banned themanufacture of residential paint containing more than 600 ppmlead. (Note that most latex paint has never contained lead.)

Non-residential paint, such as some industrial paints andmarine paints used for boats, can still be lead-based. Andalthough the CPSC ban occurred in 1978, supplies on handextended the use of residential lead-based paint into the1980s. In addition, schools may have received donationsof older residential lead paint or industrial paint (forexample, from businesses or parent groups).


31

California’s Lead-Safe Schools Protection Act, passed in 1992, banned lead-based paint and other sources of lead contamination from all new andrenovated school facilities built on or after January 1, 1993. It is for thisreason that Title 17 identifies all paint on schools built or renovated beforeJanuary 1, 1993 as “presumed lead-based paint.”

Exterior painted surfaces in newer schools tend to have about twice as muchlead as interior surfaces. However, according to the DHS study, interior paintin schools built before 1960 had higher average lead levels than exterior wallpaint. The paint on trim components such as window sashes, door jambs, andbaseboards usually has significantly more lead than wall paint—up to fivetimes as much for trim on exterior walls, and twice as much for trim oninterior walls.

IMPORTANT! The year a school was built is the best indicator of whether ornot lead paint will be found.

According to the DHS study, schools built before 1960, and especially before1940, are most likely to have a hazardous combination—paint with a highlead content and paint in need of maintenance.

If a school complex was built in stages, the oldest buildings in the complexare of greatest concern, especially if very young children spend time there. Ifold buildings house pre-schools, kindergartens, or cafeterias used by childreneight 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.


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When Does Lead Paint Become a Hazard?

If lead paint is in good condition and left intact, it is not likely to present ahazard. The problem can arise if the paint or underlying surface is indeteriorated 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 thepaint 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 ordoors scraping.

In short, lead paint is a hazard when it is in poor condition or when it isdisturbed It is a special concern when it is accessible to children. These arethe 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 fromnearby 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 windowsor doors.

◆ When lead paint on playground structures chips or flakes.


33

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 themid-1970s. Leaded gasoline has since been banned. Prior to the ban, anestimated 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 fromindustrial sources if they are located near:

◆ Freeways, where auto exhaust has settled for years.

◆ Industrial areas (or former industrial areas), where industrialpollution 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 DHSstudy, it is likely that a small but significant number of California’s publicelementary schools have a soil problem. In 6% of the elementary schoolsDHS found lead levels above the U.S. Environmental Protection Agency(EPA) limit of 400 parts lead per million parts of soil (ppm). (The EPA limitapplies 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 1940. However, if lead-safework practices have not been followed over the years, newer schools mayalso have contaminated soil.


34

What Are the Steps in a Lead Inventory?

To identify, evaluate, and prioritize the lead hazards in schools throughoutyour 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 inthe Forms Section at the end of this Guide. Some of the individual forms arealso displayed at relevant points throughout this chapter. You may decide tocreate your own forms to meet your school district’s particular needs.

Step 1. Collect and Review District Records.

Your lead-safe schools program manager should collect and review district-wide records showing the age and maintenance history of school buildingswhich house children eight and under. The object is to develop a list oftarget schools where a more detailed on-site survey of paint and soil hazardscan be done.

Even if your district is small and lead hazards are known, it is a good idea tocollect and record this information. It is a useful way to document how thedistrict identifies and prioritizes lead problems, and to make sure that themost serious problems are addressed first. Some districts may want to keepthis information in a computerized system.

First, identify the schools that house high risk children—grades K-2 andyounger children in pre-schools or childcare programs. Include high schoolswith teen parent programs that provide childcare. In other words, identify allschool buildings with children eight and under. Don’t forget privatelyoperated before and after-school programs located on school grounds.

Second, determine the date that each of these schools was built. Someschools were built in stages. Wings, or special purpose buildings such asgyms or libraries, may have been added on later. All buildings and additionsconstructed before January 1, 1993, by legal definition, have “presumedlead-based paint” unless tested and proven otherwise.


35

Third, classify schools by the number of buildings or structures:

◆ Built before 1960.

◆ Built between 1960 and 1979.

◆ Built between 1980 and January 1, 1993.

IMPORTANT! Target schools are those that have children eight and under andwere built before January 1, 1993. The highest priority target schools arethe 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 thesurrounding 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 arelikely to have lead problems.


36

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 TargetSchools Form is provided on the next page. It can give you a district-wideoverview to help determine which target schools are most likely to have leadproblems and should be surveyed first.

There is a blank version of the form that you can copy in the Forms sectionat the end of this Guide. If you wish, you can modify the sample form tomeet 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 haveidentified as target schools. Use the second column to record the year each ofthose schools was built. Next make check marks (✓) indicating whether theschool houses children in childcare and/or grades K–2.

Where information is available, fill out the Possible Hazards columns forpaint and soil hazards. (This section is optional.) Check the Paint column ifyou have any information indicating there may be deteriorated paint (priortest 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 orcurrent industrial areas.

Finally, give each target school a Priority ranking for a site survey. Base thison the age of the school and the number of check marks the school receivedon the form. This is just a guide to help you set priorities, so also draw uponyour own knowledge in ranking each school. Consider using either a “High /Medium / Low” ranking or a numerical scale (1–5, with 1 being the toppriority for inspection).

Once the form is complete, you should have a good idea of which targetschools to survey first. Develop a schedule for getting the surveys done. Settime-specific goals, such as surveying all target schools within 2–3 months,and so on. Record your projected dates on a master calendar, trackingsystem, or computer scheduling program.

Also determine how long it would take the district to survey all elementaryschools. Consider whether the district has the resources to survey middleschools and high schools as well.


37

Lead-Safe Schools Program

District Target Schools Form

School District ____XYZ Unified___________ Number of Schools in District ____7________

Completed By_____John Smith____________ Title ___M&O Manager__________________

Use this form to develop a priority list of schools to survey for deteriorated paint andpossible lead contamination of soil.

◆ Target Schools are those that have children eight and under and were built before1993. List all your target schools at the left.

◆ Check Possible Hazards (Paint, Soil) columns if you have information that theremay be a problem. Otherwise skip this section.

◆ In the Priority column, rank schools high, medium, or low. High priority targetschools should be surveyed first.

Total Number of Target Schools ______3________ Date Completed __5/10/99_____

Target School Name Children

Childcare K – 2

Possible Hazards

Paint Soil

PriorityYear Built

School A

School B

School C

1945

1990

1978

✔ ✔ ✔ ✔

✔

✔ ✔

High

Medium

Low


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Step 2. Visually Survey Paint and Soil at Target Schools.

The next step is to visit your target schools and survey them. You should usesurvey forms to collect and record information in a systematic way. Startwith the oldest schools with the youngest children, which you ranked as highpriority in Step 1.

A survey consists of two elements—a visual inspection and a written reportwith a summary of findings. Visual inspections may be done by M&Odepartment personnel who have had at least general lead awareness training.They should always be done under the direction and supervision of thedistrict’s Lead-Safe Schools Program Manager or a state-certified LeadInspector/Assessor.

Since the focus of this Guide is on routine maintenance tasks and not leadabatement tasks, it does not describe how to do a formal risk assessment orlead inspection. These must be done by a certified Lead Inspector/Assessor.In some situations, school surveys may uncover problems that indicate theneed for a risk assessment and/or a lead paint inspection.

The purpose of your informal school surveys is to identify potential leadhazards, especially in classrooms, playgrounds, and other areas where theyoungest children spend time. School surveys should include both visualinspections and conversations with school custodians, principals, andteachers.

Following are some suggestions for your survey:

◆ Ask teachers what rooms and play areas are used by children eightand under. Note the condition of paint in these areas (includingpainted furniture and toys). Ask custodians how often carpets arecleaned, and by what method. Look for paint dust on sills and floors.

◆ Ask custodians and other maintenance staff to identify any moistureproblems inside or outside the school—leaks, mildew, etc.

◆ When surveying classrooms, open and close windows and doors a fewtimes to see if this causes friction or impact that can disturb paint.

HUD Guidelines suggest that the general building condition also besurveyed. If the building has not been well maintained, then the paint is alsomore 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 stainson interior walls or ceilings, plaster walls that are deteriorating, and windowsor doors that are broken or boarded up.


39

Paint—What Should You Look For?

Assess the condition of painted surfaces on both the interior and exterior ofbuildings. Look for chipped, flaking, peeling, cracking, nicked, or chalkingpaint. 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 onwindow troughs or sills.

◆ Painted surfaces that are subject to frequent impactor 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 groundsfor locations where lead may be present in soil. Consider the age of theschool. 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 formerindustrial area. And take into account that lead paint may have fallen to theground during previous maintenance activities, contaminating the soil.

Assume that soil is contaminated adjacent to buildings built before 1940, ortest the soil. Note on your school map any exterior walls where paint isdeteriorating 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 similarareas used by children eight and under. Note locations of gardens used bychildren. Ask the custodian or principal when sand in the sandbox was lastreplaced. Check with staff to learn more about the history of the schoolgrounds, if possible.


40

How Can You Use the Paint and Soil Hazards Form?

When you do on-site surveys, start with the target schools you identified ashigh priority earlier. See the sample Building Inventory Form—Paint andSoil Hazards on the next page, which can be used to record basicinformation 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 sectionat the end of this Guide. If you wish, you can modify the sample form tomeet 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 ofpaper) of all buildings in the complex where children eight and under spendtime. Also record the year each building was built, and make any notes youthink would be useful (about general condition of the building, pastproblems, etc.). Your sheet may look like this:

Building Year Built NotesBuilding # 1 1955Building # 2 1960 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 toinclude outdoor areas near the building if children spend time there. You mayalso want to use a school site map in conjunction with the form to mark thelocation of exterior walls with deteriorated paint and adjacent bare soil.

In the Possible Hazard column, list all areas with lead-based paint, presumedlead-based paint, or soil that could be hazardous. Paint is considered a leadhazard when it is either deteriorated or disturbed in some way withoutcontainment.

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, smallarea, entire bookcase, etc.).

Use the column Nearby Surfaces To Check to list anything that could havebecome contaminated by paint chips, dust, or soil from the possible hazard.For example, list carpets, toys, books, etc. beneath deteriorating paint. If soilis listed, indicate the type of soil covering (bare, partially covered, coveredwith wood chips, etc.).

In the next column, give each area a Priority ranking—High, Medium, orLow. Base your ranking on the degree of hazard to children ages eight andunder. Next, indicate what action is recommended in Response Needed. Thiscolumn could later be reviewed and possibly amended by M&O supervisorsor others. The Follow-up Action column allows you to track status.


41

Building Inventory Form—

Paint and Soil Hazards

(✽✽ ✽✽✽)

PR

IOR

ITY

: Rank high/m

edium/low

depending on hazard and accessibility to children eight and under.P

age _____ o

f _____

School ____School A_______ B

uilding _____# 1_______________D

ate of Survey ____5/11/99______________________________

Address ____123 School St._________________________________

Site Contact and Phone ____M

ary Jones, _555-4444__________

Survey Com

pleted By ____John Sm

ith________________________T

itle ____M&

O M

anager________________________________

Schoolyard,K

indergartenplay area

Painted monkey

barsPoor—

chipping,presum

e lead-based paint

Uncovered sand

beneath (probablycontam

inated)

High

Restrict area

until repaintedScheduled forrepaintingsum

mer ‘99

Same as above

Sand beneathm

onkey barsH

ighR

eplace sandTo be replacedafter m

onkeybars are painted

Room

6,F

irst gradeP

revious leakstained ceiling

Good—

intact(no peeling yet)

LowTeacher andcustodianadvised

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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 takesamples for testing.

Testing paint is the only way to know the lead levels and the correspondingrisks to children and school employees. On the other hand, testing can beexpensive.

However, the law (Title 17) defines all paint in school structures built beforeJanuary 1, 1993 as “presumed lead-based paint” unless tested and shownotherwise. If you assume that paint contains lead and follow lead-safe workpractices for routine, lower risk maintenance tasks all the time, no testing isneeded. However, making this assumption for newer buildings (where lead isnot so prevalent) may also be expensive. If you can show there is no lead, thejob will be simpler and cost less because lead-safe precautions will not berequired.

Although samples to test paint, dust, or soil for lead must usually be taken bya state-certified Lead Inspector/Assessor, there are two exceptions to thisrule. A person who is not certified may take paint chip samples related to aplanned maintenance task if the purpose is to help comply with Cal/OSHA’sworker protection regulations such as in selecting the proper controls(respirators, protective clothing, work practices, etc.). A non-certified personmay also test dirt and debris for disposal purposes, to see whether it meetsthe legal definition of hazardous waste. For more on certification, seeChapter 8.

Below are some approaches school districts have taken. Decide whichapproach 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 testpaint for lead, if workers follow lead-safe work practices all the time. Thisapproach can be safe and cost-effective for maintenance tasks that involveminor, lower risk work. See Chapter 5 for a discussion of high risk and lowerrisk lead tasks.

This approach is recommended by DHS for older buildings. Many schooldistricts find it can save them thousands of dollars in testing costs—moneyperhaps better spent implementing lead-safe work practices. When decidingwhether to use this approach, consider the age of the school and the size ofthe task.


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The year a building was constructed is the single best indicator of whetherpainted surfaces are likely to contain lead. Assuming that lead is presentmakes sense particularly for schools built before 1980, since the DHS studyshowed that 100% of them had some detectable lead in paint.

Buildings fall into these categories:

◆ Built before 1980—Assume that these school buildings have somelead in paint. Schools built through 1950 generally have high levelsof lead in paint. You may decide not to test, if you always use lead-safe work practices.

◆ Built between 1980 and January 1, 1993—These buildings may havelead paint even though most lead was banned in residential paint in1978. For example, buildings may have been painted with old paint orindustrial paint. Testing is often recommended. The DHS studymentioned earlier found that 45% of California schools built duringthis period have detectable levels of lead in paint.

◆ Built on or after January 1, 1993—According to DHS, these schoolscan be assumed not to have lead-based paint.

Especially for buildings in the 1980–1992 group, check any available recordson the paint, such as Material Safety Data Sheets (MSDSs), to see if itcontained lead. (However, MSDSs are not required to list lead as aningredient if it is less than 1% of the paint.) Also check with the paintmanufacturer. 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 usespecially trained workers or special precautions for the job. Therefore, thetesting may pay for itself.

For abatement projects, and for major remodeling on renovation projects thatwill disturb painted surfaces, it is legally required that a risk assessment,paint inspection, or both be done. These must be performed by a certifiedLead Inspector/Assessor and should take place during the initial planningstages of each project.

Most districts also test for lead whenever they plan to contract out a majorjob. Districts need to know the location and level of lead present so they canproperly evaluate the contractor’s proposal, work practices, and compliancewith the Cal/OSHA Lead in Construction standard. (See Chapter 8 for moreinformation 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.


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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 LeadInspector/Assessor and sent to a laboratory for analysis. The lab reportstell how much lead is in the paint. Paint chip sampling is usually donewhen only a few samples are needed.

A sample is collected by scraping a 2 by 2 inchsquare area down to the underlying surface. Caremust be taken not to include any underlying wood,plaster, concrete, etc. in the sample. The sample,usually containing several layers of paint, is sealedin a container, labeled with the sample location,and sent to a lab accredited by the National LeadLaboratory Accreditation Program (NLLAP). Theresults are usually expressed in parts of lead permillion 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 howquickly you need the results.

Labs often provide instructions on where and how to take paint chipsamples and may prefer that you use their containers. For a list ofNLLAP-accredited labs in California, see the website www.childlead.com.For more on paint chip sampling methods, see Appendix 13.2 of the HUDGuidelines for the Evaluation and Control of Lead-Based Paint Hazardsin 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 thepaint. The test doesn’t disturb the painted surface. It is also cheaper thanpaint chip sampling for large numbers of samples. Because of thesebenefits, XRF Analyzers have been popular among school districts andlead contractors.


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Schools may still need to do paint chip sampling after XRF sampling iflead is present but at a low level. Remember that many current leadregulations cover paint with any detectable level of lead.

Certified Inspector/Assessors typically charge several hundred dollarsper day for XRF testing.

Wet Chemical Field Test

These tests are available in paint stores, are cheap, and give quick results.They are commonly referred to as lead sticks. However, both HUD andEPA recommend that you do not use these tests because the results canbe unreliable. At best, the test only tells you if lead is present, not howmuch there is. Also, the test identifies lead only in the surface paint thatis exposed—not the undercoats, which are much more likely to containlead because they are older.

How Is Soil Tested?

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 schoolsbuilt before 1980 have some lead-contaminated soil, although only 6%exceed the EPA limit of 400 parts per million (ppm). Almost 30% of schoolsbuilt before 1940 exceeded the limit.

The best approach is for districts to assume that older schools, particularlythose built before 1940, have lead-contaminated soil. In these schools, as afirst step, either test the soil or fence off or cover bare soil within five feet ofpainted exterior walls of buildings. Next, address soil more than five feetfrom buildings (beginning with play areas). Soil that is covered or fenced offdoes not pose a hazard and therefore need not be tested. Schools built after1940 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 areusually taken along the building foundation, along the drip line, insandboxes, or in any other area where there might be lead in the soil, such asbelow painted play structures. Composite samples are usually taken, wherethree to ten subsamples from different locations are combined into onesample for analysis.


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Step 4. Test Water at All Schools.

Lead-contaminated drinking water is a potential health risk to people of allages, 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 leadlevels 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 exposurefrom drinking water.

Testing water and reducing lead levels is much easier than reducing leadpaint hazards, yet it yields important health benefits. School districts shouldreduce 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 frompipes, solder, or plumbing fixtures, or when the water supply itself iscontaminated. 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 inCalifornia until it was banned in 1988. Leaded solder may still be usedillegally by some plumbers. Faucets, valves, or fittings made of brass mayalso contain small amounts of lead, although many manufacturers today uselead free brass.

More lead can leach into water from solder or brass fittings when theplumbing 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 werecommon).

◆ The plumbing has been illegally repaired with leaded solder withinthe last five years.

◆ Brass fixtures containing lead have been added within the last fiveyears.

◆ The water source is soft or acidic (more corrosive).

◆ The water stands in the pipes for more than 24 hours.


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Water coolers were identified by the EPA in 1987 as another potential sourceof lead contamination. The Federal Lead Contamination and Control Act,passed in 1988, required that water coolers with lead-lined tanks be repairedor removed. It also banned the manufacture and sale of water coolers that arenot lead free, and required that lead problems in schools’ drinking water beidentified and corrected.

Should Your District Test Drinking Water?

Yes. Drinking water should be tested at all schools. The CaliforniaDepartment of Education sent drinking water advisories to schools between1987 and 1989, and EPA recommended testing in 1989. Schools with theirown drinking water systems, such as wells, were required to test under a1991 federal regulation.

If water was tested at some time in the past, it may be necessary to test againif schools have had plumbing renovations since the test. A change as simpleas a new faucet head can result in lead exposure over the EPA limit. Newfixtures are not always lead free. For example, one California district foundthat a contractor had installed new faucets containing lead during a schoolmodernization project. The district tested the water and found lead levelsover 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 hasa good testing program. However, those conducting the lead-safe schoolssurvey described earlier may want to ask school maintenance staff questionsabout sources of drinking water, any recent plumbing work, and any waterproblems 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 themorning 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 570/9-89-001. (To contact EPA, seeAppendix I.)

A person who takes drinking water samples does not need to be state-certifiedbut should follow EPA test procedures as described in the National PrimaryDrinking Water Regulations (40 CFR Part 141.80, “Control of Lead andCopper.”) Note the new federal limit of 15 ppb. For more information, checkthe website www.epa.gov/safewater. Click on “Publications.”

The EPA’s recommended method involves taking “first draw” samples andthen possibly “second draw” samples. These are sent to a lab certified under


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DHS’s Environmental Laboratory Accreditation Program. The lab must havecertification for metals in drinking water. For a list of labs, see the websitewww.dhs.ca.gov/ps/ls/elap/elapindex.htm.

If water samples taken on the first draw are over the EPA limit of 15 ppb atany water outlet (fountain, faucet, etc.), a second draw water sample shouldbe taken after running the water for a period of time. Often the first drawsamples are higher because the water has been sitting in the pipes, allowingmore 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 alternatesource of water if necessary.

Usually the next step is more sampling, and testing the water at differentsites in the plumbing system to identify the lead source.

If the second draw sample is under 15 ppb, consider a flushing program asdescribed in Step 5.

Step 5. Set Priorities for Hazard Control.

School Maintenance and Operations (M&O) departments are primarilyconcerned with taking action and getting things done. However, it isimportant that managers take the time to reflect on what has been learnedfrom their school lead surveys and testing results. To correct the problemsfound, you have to assess district resources and think through theimplications of taking on new lead control jobs.

As you set priorities, you should develop:

◆ An M&O work plan that deals with the most serious lead problemsfirst.

◆ A policy on which lead work to do in-house, and which work tocontract out.


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◆ 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 testresults, managers will probably have discovered at least some potential leadhazards. This will make it necessary to revise current plans for maintenancework and shift the focus to resolving lead problems. Problems of deterioratingpaint in areas with children eight and under will most likely head your list. Itis also important to deal promptly with any severe problems in soil andwater.

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, anddecide 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 whoshould do it. Most M&O departments will probably solve many problems byrepainting. Remember that sealing painted surfaces so they will not createchips or dust is often safer, easier, and more cost-effective than completeremoval of lead paint.

If proper work practices are not used, the work you do to correct a hazardmay pose a risk of increased lead exposure for your maintenance staff andschool children. The work may disturb lead, putting more lead dust into theair and onto nearby surfaces. Taking these issues into account, somemaintenance tasks intended to reduce lead problems are considered lowerrisk jobs and some are considered high risk jobs. See Chapter 5 for moreinformation on lower risk and high risk maintenance jobs.

Assess the district’s ability to do lower risk, high risk, and full-scale leadabatement tasks in-house. Look at the number of workers available, theirskill levels, how much lead training they have had, and whether they are leadcertified. Also consider whether you have the right equipment, materials, andother resources available.

There are extensive Cal/OSHA and Title 17 requirements for special workpractices and worker protection when doing high risk or lead abatementtasks. These include wetting the work, using containment, using HEPAattachments on power tools, following other appropriate work methods,


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doing air sampling, and providing medical tests for workers. See Chapters5–7 for details.

Does your district have the capability to put these required precautions inplace? If not, some lead jobs may need to be done by contractors who arestate-certified in lead-related construction. If you use a contractor, ask forproof of lead certification. Always have a detailed written contract thatspecifies 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 ofthe 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 riskjobs are contracted out until district staff can be trained and equipped to dothem 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 BuildingInventory Form—Paint and Soil Hazards, and decide what correctiveaction is most appropriate for each priority location.

Districts should assume that bare soil within five feet of buildings builtbefore 1940 is contaminated with lead above the legal limit (400 ppm). Suchareas should either be fenced off to make them inaccessible to children,blanketed with ground cover, or both. This is the recommendation of theCalifornia Department of Health Services, based on the fact that soil testingis complex and requires specially certified personnel.

If you assume that soil is contaminated outside older buildings (or if testinghas found lead over 400 ppm in the soil), the school district should takemeasures to protect children. These include:

◆ Cover bare soil.

◆ Use dense planting or fencing to restrict children’s access to theseareas.

◆ Move play equipment out of these areas.

◆ Prohibit use of these areas for demonstration gardens, rainbowgardens, or any other educational activities.

◆ Post warning signs.


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If lead levels in soil are over 1,000 ppm, California DHS considers the soilhazardous for adults as well as children. As an interim measure, you cancover the soil as described above. You can permanently solve the problem bycovering the soil with concrete or asphalt, or by complete removal of thecontaminated soil. If you choose removal, the soil is considered to behazardous waste as explained in Chapter 7, and you must use special wastedisposal procedures. While removing soil, erect barriers to restrict accessuntil the work is completed. For more complete information on soil cleanup,check the website www.epa.gov/lead/leadhaz.htm.

What Can Be Done About Lead in Water?

A flushing program can be instituted to reduce lead levels in drinking watertemporarily. Flushing means running the water for a period of time to washout as much lead as possible. Water outlets should be thoroughly flushed on aregular 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 levelunder 15 ppb.

EPA guidelines recommend that flushing be done daily—each morningbefore school starts. Flushing should continue until a plan for permanentlyreducing lead to below 15 ppb has been put in place. Flushing is especiallyimportant after holidays and vacation periods. It should be done beforestudents arrive back to school.

If the second sample is also over 15 ppb, remove the fixture from serviceinstead of flushing. Supply an alternate source of drinking water if needed.

The California Department of Education issued a directive in 1988 thatadvised 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 hasbeen put in place. Such a plan may include replacing pipes or plumbingfixtures, or obtaining water from a different source.

For further advice, consult your local water district, or the DHS Division ofDrinking Water and Environmental Management. (See Appendix I.)


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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 ofbuildings, and in outdoor lunch and play areas. After the target schools havebeen 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 aswater, fire, vandalism, or earthquake. In addition, all schools should besurveyed periodically to detect newly deteriorating paint. Set up a surveyschedule that fits into other M&O activities. Keep written records of thesesurveys.

Districts are required to inspect schools for asbestos every three years bylaw, and many are beginning to inspect for mildew and mold. It makes senseto include a survey for lead hazards on the same site visit.

C H A P T E R 5 — A N A L Y Z E M A I N T E N A N C E T A S K S

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◆5Analyze Maintenance Tasks

CHAPTER

When Is a Maintenance Task Hazardous?

Another important element of a lead-safe schools program is evaluation ofmaintenance tasks. Look at work done throughout the school district anddetermine its potential to cause lead exposure. A systematic survey of themaintenance activities typically done in the district is desirable, althoughmany districts review tasks on a case-by-case basis as they arise.

School Maintenance and Operations (M&O) departments handle a widevariety of tasks. Given the typical age of California school buildings, manytasks will probably disturb lead paint. Cutting, drilling, sawing, sanding, orchipping into lead paint can release lead dust into the air and immediatelyexpose workers. The dust then settles onto surfaces and becomes a possiblesource of lead exposure for children.

Some maintenance activities produce a high level of risk, and some producea lower level of risk. Before work begins on any job, it is important toanalyze the specific tasks to be performed and assess their risk. Considerwhether each task has the potential to create a high risk or lower risk of leadexposure for workers or children.

This type of analysis is the only way to know what specific proceduresshould be followed and which workers on the staff (if any) have enoughtraining. It can also help you find ways to minimize worker exposure whilethe work is being done, and prevent surface contamination that could exposechildren later.


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Take these factors into account when deciding if a maintenance taskinvolving 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 surfacecontamination.

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 have5,000 or more parts of lead per million parts of paint (5,000 ppm). Considerany 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 thepaint. The 1998 California Department of Health Services (DHS) study of thestate’s elementary schools found that:

◆ 93% of schools built before 1959 have paint with lead over5,000 ppm.

◆ 70% of schools built between 1960 and 1979 have paint with leadover 5,000 ppm.

Bear in mind that workers who may be exposed to any detectable level oflead in paint are protected by the Cal/OSHA Lead in Construction standard.Protective measures are required by the standard for all lead work (evenlower 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 wasconstructed before January 1, 1993, you must assume that it contains leadand take all necessary precautions. You must follow the requirements of theCal/OSHA Lead in Construction standard, just as if you knew for sure thatthere was lead in the paint. See Chapter 4 for more information on testingpaint.


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How Dusty Is the Task?

The amount of dust produced by a task is probably the most important factorin determining the risk. The Cal/OSHA Lead in Construction standardprovides guidance on whether a task involves a high risk or a lower risk.

To determine whether a particular task would expose workers to too muchlead dust, the Cal/OSHA standard requires that personal air sampling be donewhen work begins. This sampling measures the amount of lead dust in aworker’s breathing zone while work is in progress.

The Cal/OSHA standard requires different work practices, protectivemeasures, 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 toless than 30 micrograms of lead per cubic meter of air (30 µg/m3), only basicprotective measures are required, primarily to prevent contamination ofsurfaces accessible to children. Measures include wetting surfaces, usingplastic sheeting to contain lead dust and chips, cleaning up thoroughly afterthe job, and following good worker hygiene practices including mandatoryhand and face washing. Another Cal/OSHA standard (HazardCommunication) also requires that workers receive training if they areexposed to any amount of a chemical, including lead.

If the initial personal air sampling finds a worker’s exposure to be 30 µg/m3

or more, additional protective measures are required. These include moredetailed training and additional personal air sampling to be sure the levelsaren’t rising higher. 30 µg/m3 is called the Cal/OSHA Action Level for lead.

Cal/OSHA also has a Permissible Exposure Limit (PEL) for lead. A PEL isthe maximum amount of a substance allowed in the workplace air (averagedover an eight hour day). The Cal/OSHA PEL for lead is 50 µg/m3.

If a worker is being exposed to a lead level at or above the PEL, the taskclearly involves a high risk. In this case, the Cal/OSHA standard requiresvery strict protective measures. These include more personal air sampling,respiratory protection, personal protective clothing and equipment, personalhygiene measures, and medical testing. See Chapter 6 for a more completelist. Furthermore, the standard requires that workers and supervisors on suchjobs be trained by a provider accredited by the California Department ofHealth 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 leaddust, the PEL may be reached quickly. Therefore, even some maintenance


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tasks that are done for short periods of time may present a high risk ofexposure to workers.

IMPORTANT! This Guide defines a high risk task as one likely to causeworker exposure above the PEL. However, lead work that does not causeexposure above the PEL can still be hazardous. For example, some tasksthat pose a relatively low risk to workers can seriously contaminatesurfaces accessible to children.

Personal air sampling is not always required. Cal/OSHA allows exceptions ifsampling was done on a similar job within the last 12 months, or if“objective data” shows that workers could not be exposed above the ActionLevel. See Chapter 6 for more information.

Can Work Practices Affect Risk?

Yes. Many common school maintenance tasks that disturb lead can createeither 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 levelsand contamination of surfaces to a minimum. The examples of commonmaintenance tasks below illustrate how work practices can affect the risk.

Surface Preparation. Preparing a lead painted surface forrepainting can be either a high risk or lower risk task,depending on how the job is done. For example, powersanding a painted wall will create high dust levels andtherefore a high risk of lead exposure. This can be trueeven if the paint has only a small amount of lead (perhaps600 ppm). For this reason, power sanding of lead paintedsurfaces is prohibited by HUD Guidelines and by Title 17,unless power tools with HEPA vacuum attachments areused. On the other hand, using wet scraping methodsinstead of sanding keeps dust levels down and lowers therisk.

Removing Building Components. Sometimes buildingcomponents need to be removed for repair or replacement.But if a window, for example, is pulled out withoutcontrolling where the paint dust and chips fall, significantlead contamination can occur. Instead, to control the dustand chips, seal the window from the inside, wet paintedsurfaces, and remove the window toward the outside. Wetdust and chips can be caught by plastic sheeting securedon the ground. After the job, the sheeting must be handledusing proper procedures to avoid ground contamination, asexplained in Chapter 7.


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Power Washing. Some school districts do power washing of buildingswith a high pressure hose to clean them. If there is lead paint on thebuilding and the water pressure is very high, this can be a hazardoustask. It is difficult or impossible to contain the water runoff, whichwill probably have lead paint chips and debris. Significantenvironmental contamination can result.

On the other hand, cleaning a wall with intact paint by lowpressure power washing is much less hazardous. Paintwill not be removed in the process because of the lowerwater pressure. The runoff will not be contaminated withlead paint chips or debris.

Power washing is not the same as water blasting. Waterblasting of buildings, sometimes done to remove paint,uses a much higher pressure. Water blasting withoutcontainment is prohibited by HUD Guidelines and byTitle 17.

Drilling, Chiseling, or Sawing. When workers drill, chisel, or sawpainted surfaces, the task can generate either a lot of dust or a littledust, depending on the extent of the work and how it is done.Although these tasks may not generate enough dust to expose aworker above the PEL, they can contaminate surfaces accessible tochildren if they are done improperly. Wherever possible, minimizedust and paint chips by keeping the work surface wet, then clean upthoroughly. Remember to keep the accumulating dust and debris wetalso.

Repairing Radiators. Radiators in school heating systemsoften have deteriorating lead paint. When plumbers orother maintenance workers repair leaks or replace valves,paint chips can easily contaminate the surrounding area.The risk of contamination can be reduced by placingplastic sheeting on the floor around the radiator to catchdebris. Keep debris wet.

Certain tasks sometimes done by school M&O departments alwayspose a high risk of lead exposure above the PEL, even if they are doneonly for short periods of time. These tasks include dry scraping anddry sanding of lead-painted surfaces, sandblasting, welding, and torchburning. Cal/OSHA considers these “trigger tasks” because theyautomatically “trigger” special requirements of the Lead inConstruction standard. For more information on trigger tasks, seeChapter 6. For more information on lead-safe work practices ingeneral, see Chapter 7.


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The story below illustrates how work practices in California school districtsneed significant change.

Survey Examines School M&O Practices

In 1997, DHS surveyed approximately 100 Californiaschool business officials about M&O work practicesinvolving lead paint. The survey found that many districtswill need to make major changes as they institute lead-safe schools programs. Potentially unsafe work activitiesare still prevalent in many M&O departments.

For example:

◆ 59% of districts reported that they sometimes doabrasive blasting (sandblasting, water blasting, etc.).

◆ 84% sometimes use dry scraping or dry sandingduring paint prep work.

◆ 60% sometimes do power sanding or grinding withoutHEPA attachments on the tools.

What Is Lead Abatement?

Abatement means any set of measures designed to reduce or eliminate leadhazards or lead-based paint in public or residential buildings. It does notinclude containment or cleaning. Title 17 spells out certain work practice andtraining requirements for abatement work which is designed to reducehazards for at least 20 years, and other requirements for abatement workdesigned to last for less than 20 years. See Appendix F for a summary ofTitle 17.

What Training Is Needed?

Only workers who have received a basic level of training in lead-safe workpractices should perform any maintenance work that disturbs lead in paint,soil, or plumbing (even lower risk tasks). High risk lead tasks (andabatement) must be done by workers and supervisors who have receivedstate-accredited training and have become state-certified in lead-relatedconstruction work.

To become a state-certified Lead Worker, the employee must attend a 24-hour course accredited by the California Department of Health Services


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(DHS), and then apply to DHS for certification. Lead Supervisors mustattend a 40-hour course and then apply to DHS for certification. If yourschool district decides to have high risk jobs done by district staff, they mustbe sent to an accredited course. For a list of accredited trainers in your area,contact the DHS Childhood Lead Program or check their website atwww.childlead.com. An alternative is to have high risk and abatement tasksdone by outside contractors who have the proper training and certification.The Childhood Lead Program website also has a list of lead-certifiedcontractors.

How Can Future Lead Problems Be Prevented?

The M&O department should also identify what can be done to preventfuture lead problems. For example, deteriorating paint can be avoided byearly preventive maintenance—repainting more often. Repainting a slightlydeteriorated surface may not be a priority today, but work done now can savethe school district time and money in the future. Here are some tips fromexperienced 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 mostschool district M&O budgets. Documenting the costs of repairingdeteriorated surfaces, particularly when using expensive lead abatementcontractors, can support your argument for additional resources to dopreventive maintenance now.

Parent groups can be allies in arguing for more resources, especially ifschool surveys indicate serious potential lead hazards that could harm children.

Many districts have found that delaying maintenance work significantlyincreases repair costs. Prevention pays.


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C H A P T E R 6 — P R O V I D E W O R K E R P R O T E C T I O N

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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 mustbe given necessary protective clothing and equipment, and other steps mustbe taken to reduce their lead exposure as much as possible.

Wherever lead paint is disturbed during maintenance work, Cal/OSHArequires protective measures ranging from coveralls to respirators, dependingon the nature of the task. Some protection is needed even if the risk is low.

IMPORTANT! Cal/OSHA regulations make it the employer’s responsibilityto provide all necessary protective clothing and equipment, at no cost tothe worker.

Chapter 5 explained that Cal/OSHA’s Lead in Construction standard applieswhenever 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 cubicmeter of air (30 µg/m3), averaged over an 8-hour shift. Workerexposure at or above this level requires certain special precautions.

◆ The Cal/OSHA Permissible Exposure Limit (PEL) is 50 µg/m3,averaged over an 8-hour shift. Worker exposure at or above this levelrequires even stricter precautions, and workers must be certified bythe state.

◆6Provide Worker Protection

CHAPTER


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◆ This book defines a high risk maintenance task as one likely to causelead exposure above the PEL.

A summary of the Cal/OSHA Lead in Construction standard appears inAppendix B. The complete standard is available on Cal/OSHA’s website atwww.dir.ca.gov. Click on “Occupational Safety & Health.” Go to Title 8Regulations, where you can search for the standard (section 1532.1) bynumber.

What Protection Is Required?

According to Cal/OSHA, many precautions must be taken to protectmaintenance employees who disturb lead paint in the course of their work.These precautions can include personal air sampling, respirators, protectiveclothing, mandatory personal hygiene measures, and medical testing.

The chart below summarizes the protective measures that Cal/OSHArequires for proven lower risk and high risk lead tasks. These requirementsare explained more completely in the remainder of this chapter. Themeasures 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/m3. A highrisk task is 50 µg/m3 or over.

◆ Personal air sampling when work begins

Lower risk tasks—Required.

High risk tasks—Required.

◆ Respirators

Lower risk tasks—Not necessary.


◆ Protective clothing (gloves coveralls, safety glasses or goggles, andshoe coverings)

Lower risk tasks—Recommended.



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◆ Personal hygiene (wash face, hands, and forearms after task; noeating, drinking, or smoking)



◆ Showers

Lower risk tasks—Not necessary.

High risk tasks—Required if feasible; otherwise, washing handsand face is required.

◆ Medical testing

Lower risk tasks—Required at 30 µg/m3 and above.


What Are “Trigger” Tasks?

Some tasks almost always cause lead exposure above the PEL, even if theyare done only for short periods of time. Cal/OSHA considers these triggertasks under the Lead in Construction standard. Doing these tasksautomatically “triggers” special requirements in the standard. You shouldassume that these tasks cause worker exposure above the PEL and follow allCal/OSHA requirements for such exposure.

For these tasks Cal/OSHA requires many very strict protective measures, andstate certification of workers. The only exception is if personal air samplingshows 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 typeof respirator needed depends on how much lead is in the air. The Lead inConstruction standard explains what respiratory protection is needed for eachtype of trigger task. There is more on respirators later in this chapter.

Where lead coatings or paint are present, assume that the tasks below causelead exposure above the PEL as shown.

Assume exposure of 50–500 µg/m3 unless proven otherwise:

◆ Manual demolition of structures

◆ Manual dry scraping or sanding

◆ Heat gun application


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◆ Cleaning surfaces (sanding, grinding, etc.) with power tools that havedust collection systems.

Assume exposure of 500–2500 µg/m3 unless proven otherwise:

◆ Cleaning surfaces (sanding, grinding, etc.) with power tools that donot have dust collection systems (prohibited by HUD)

◆ Clean-up of dry expendable abrasives

◆ Moving or removing abrasive blasting enclosures.

Assume exposure over 2500 µg/m3 unless proven otherwise:

◆ Abrasive blasting

◆ Welding

◆ Cutting

◆ Torch burning (prohibited by HUD).

IMPORTANT! Cal/OSHA does not consider wet manual scraping or sandingto 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 airsampling 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 whenemployees are working.

To test the air, the worker wears a small battery-powered air pump atthe waist. This is connected by tubing to a filter cassette attached atthe collar. During a full shift of work, the pump draws air from theworker’s breathing zone (around the nose and mouth). The dust andfumes 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 ithas collected. A calculation is done to estimate the average amount ofairborne lead the worker was exposed to during the shift. This numberis expressed in micrograms of lead per cubic meter of air (µg/m3).

If the level is below 30 µg/m3, which is the Cal/OSHA Action Levelfor lead, no special precautions are required except mandatory handand face washing and basic worker training. However, the work area


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should still be protected with plastic sheeting, and warning signs should beposted, as on any lead job. If the level is between the Action Level and theCal/OSHA Permissible Exposure Limit (PEL) of 50 µg/m3, some additionalprecautions are required. These include regular personal air sampling andinitial blood lead tests for workers. If the level is above the Action Level for30 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 protectworkers and the environment. Precautions required at various levels aredescribed throughout this chapter.

Is Sampling Always Required?

The Cal/OSHA Lead in Construction standard requires that initial personalair sampling be done for every type of task where there is potential for leadexposure. The exceptions to this rule are:

◆ If personal air samples were taken within the last 12 months undervery similar conditions (same type of task, same type of surface,similar lead paint concentration, same work methods, sameenvironmental conditions, etc.)

◆ If you have data to show that a task involves low risk and could notproduce exposure above the Action Level.

Depending on the results of the initial sampling, it must be repeated asfollows:

◆ If initial results are below the Action Level, repeat sampling for thattype of job once a year.

◆ If initial results are between the Action Level and the PEL, repeatsampling every six months until two consecutive samples are belowthe Action Level.

◆ If initial results are above the PEL, repeat sampling every threemonths until two consecutive samples are below the PEL.

IMPORTANT! If personal air sampling is not done, Cal/OSHA says you mustassume that all tasks that disturb lead paint can expose a worker to leadabove the PEL.

Who Should Do Sampling?

Personal air sampling requires some training to perform correctly. If you doit yourself you will have to obtain the equipment and be trained by acompetent professional.


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You can also hire an industrial hygienist as a consultant to do the samplingfor you. Your school district’s workers’ compensation insurance carrier orJoint 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 indicatewhether 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 youwhether workers need to wear respirators and what type they need.(Respirators are required above the PEL.) The higher the air samplingresults, the more effective the respirators need to be.

◆ If your district is in compliance with the Cal/OSHA standard. Thestandard sets different requirements, depending on air samplingresults. 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 samplingmeasures the amount of lead in the air that a worker might inhale. Itdoes not measure the amount of lead dust that a worker mightswallow while eating, drinking, or smoking.

◆ Exposure levels can vary widely from day to day and from worker toworker. 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 beingdone 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 samplingresults within five working days after obtaining them. The notification mustbe in a language the worker understands.


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When Do Workers Need Respirators?

If personal air sampling finds lead levels above the PEL (50 µg/m3),workers will need to wear respirators. Respirators must also be wornuntil initial air sampling has been completed for each task if there isreason to believe that exposure could be over the PEL (for example, whendoing trigger tasks). In addition, respirators must be given to workerswho request them, even if their exposure is below the PEL.

The type of respiratory protection needed depends on how high the leadlevels are in the air. The goal of respiratory protection is to reduce aworker’s exposure to a level below the PEL. The types of respiratorsdescribed below are sometimes used on lead jobs. Note that simple dustmasks are not acceptable for lead work.

One common type of respirator is the air purifying respirator (APR). Ituses a filter or cartridge to remove hazardous substances from the air theworker breathes. Different filters or cartridges are needed for differentsubstances. These respirators are available in half-mask and full-facemodels. For lead tasks, workers need a “HEPA” (High EfficiencyParticulate Air) cartridge, also called a “P-100” cartridge.

Cal/OSHA allows use of a half-mask APR for exposure up to 500 µg/m3.It allows use of a full-face APR for exposure up to 2500 µg/m3. Forexposure above 2500 µg/m3, a different type of respirator is needed. Anair supplied respirator provides a separate source of clean air for theworker to breathe from a hose and tank. However, it is unlikely thatschool maintenance workers would require this type of respirator.

If respirators are used, Cal/OSHA requires that a complete, writtenRespiratory Protection Program be put in place. The program must haveguidelines for the proper selection, fitting, use, cleaning, storage, andmaintenance of respirators. It must also cover medical qualification towear respirators and employee training on use and limitations ofrespirators. Workers must be given respirators free of charge. Allrespirators must be NIOSH-approved.

The Cal/OSHA standard on Respiratory Protection is available on Cal/OSHA’s website at www.dir.ca.gov. Click on “Occupational Safety &Health” and search Title 8 Regulations for section 5144.

If you need assistance in setting up your Respiratory Protection Program,check with your school district’s workers’ compensation insurancecarrier or Joint Powers Authority (JPA), who may be able to help. Moreinformation on Respiratory Protection Programs is also available fromthe OLPPP website at www.ohb.org/olppp.htm.

HALF-MASK APR(up to 500 µg/m3)

FULL-FACE APR(up to 2500 µg/m3)

FULL-FACEAIR SUPPLIED

(above 2500 µg/m3)


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What Protective Clothing Do Workers Need?

Regardless of the level of exposure, it is a good practice for workers to wearprotective clothing when working around lead. Although lead cannot enterthe body through the skin, it can easily travel to the worker’s home, or toother areas of the school, on clothes. Street clothes need to be protected.

Protective clothing includes coveralls or disposable clothing worn only forthe job. It may also include safety glasses or goggles for protection fromdust.

IMPORTANT! Remember that shoes track lead dust around as well. For thisreason, 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 ofexposure, he or she must be required to wash face, hands, and forearms whenleaving the work area. If necessary provide portable washing facilities. Nailbrushes 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 therisk that workers will accidentally swallow lead dust.

What Medical Tests Do Workers Need?

The Cal/OSHA Lead in Construction standard requires that some workerswho are exposed to lead receive blood tests and other medical services. Inthis case, the employer must establish a comprehensive MedicalSurveillance Program.

A Medical Surveillance Program helps protect workers and prevent leadpoisoning 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.


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Who Should Be in a Medical Surveillance Program?

According to Cal/OSHA, employers must set up a Medical SurveillanceProgram for workers who are exposed to lead in the air at or above theAction Level of 30 µg/m3 for more than 30 days in any consecutive 12-monthperiod.

A Medical Surveillance Program must be supervised by a qualified physicianin consultation with the employer. The physician should be familiar with thehealth effects of lead and Cal/OSHA medical surveillance requirements.Employers may use clinics and other health care facilities with which theyhave existing contracts for other services, provided that personnel have therequired qualifications. To locate an occupational health clinic, check thewebsite http://occ-env-med.mc.duke.edu/oem/aoec.htm or the DHS OLPPPwebsite at www.ohb.org/olppp.htm. (Also see Appendix I.)

Although school maintenance workers are unlikely to have exposure levelsthat require medical surveillance, a brief summary of the legal requirementsappears 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 tomonitor the amount and effect of lead exposure—the Blood Lead Level(BLL) test and the Zinc Protoporphyrin (ZPP) test. Both can be done with thesame blood sample. Results are reported in micrograms of lead per deciliterof blood (µg/dl). Blood testing is sometimes called “biological monitoring.”

Cal/OSHA requires initial “baseline” BLL and ZPPtests when employees begin lead work. Workers whomay be exposed at or above the Action Level for evenone day must receive baseline blood tests. Baselinetests are also required for anyone before doing a Cal/OSHA “trigger task.” Workers exposed at or above theAction Level for more than 30 days in any consecutive12-month period must have further tests. They must betested at least every 2 months for the first 6 months,and then every 6 months thereafter.

The worker, employer, and physician must review BLLand ZPP test results to determine the degree ofexposure and to decide if the worker needs specialmedical treatment or removal from further leadexposure.


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Medical Exams. Cal/OSHA requires initial and periodic medical exams if aworker’s BLL is at or above 40 µg/dl. Medical exams must also be offered toany worker who reports signs or symptoms of lead poisoning, who requestsmedical advice related to conception and pregnancy, or who has difficultybreathing while wearing a respirator.

Medical Removal Protection (MRP). In some situations, workers must betemporarily removed from lead exposure. Cal/OSHA requires medicalremoval whenever a blood test indicates a BLL of 50 µg/dl or higher. Aphysician can also remove a worker with a BLL less than 50 µg/dl if theworker has symptoms of lead poisoning, is pregnant, or has certain othermedical conditions. When medical removal is ordered, the worker may notbe exposed to any lead at or above the Action Level. Whether and when tobegin 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 theirblood test results in writing within five working days after the employerreceives them. They must also be given general information about lead thathelps them understand the blood test results. The California Department ofHealth Services has literature available in English, Spanish, and Chinese thatschool districts can use to comply with this requirement. Check the OLPPPwebsite at www.ohb.org/olppp.htm. (Also see Appendix I.)

Medical Records. All medical records must be kept confidential andmaintained for at least the duration of employment plus 30 years. Workershave the right to see and copy their own medical records.


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Are Special Work Practices Needed for Lead Tasks?

Yes. Safe work practices are probably the most important element of a lead-safe schools program. Special work practices for lead tasks includerestricting access to the work area, using plastic sheeting to contain lead dustand chips, wetting the work surface to keep dust down, using power toolswith HEPA filters, cleaning up properly, and disposing of hazardous waste ina safe manner.

Whenever lead paint is disturbed during maintenance work, following lead-safe work practices will help protect both workers and children. Takeprecautions even if the task presents a low level of risk. Remember that:

◆ Even low level exposure to lead can be hazardous, especially forchildren.

◆ Unsafe work practices can result in higher exposure than if intactpaint had been left alone.

Cal/OSHA’s Lead in Construction standard requires different work practicesfor different types of tasks, depending on how high a worker’s exposure isexpected to be. As Chapter 5 explained:

◆ The Cal/OSHA Action Level is 30 micrograms of lead per cubicmeter of air (30 µg/m3). If a task may expose workers at or above thislevel, special work practices are required to keep exposure as low aspossible.

◆7

Use Safe Work Practices

CHAPTER


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◆ The Cal/OSHA Permissible Exposure Limit (PEL) is 50 µg/m3. If atask may expose a worker at or above this level, work practices whichprovide even greater protection are required. Workers must also bestate certified as explained in Chapter 8.

◆ This Guide defines a high risk task as one likely to cause leadexposure above the PEL. This includes tasks defined by Cal/OSHA as“trigger tasks,” until air sampling is done to determine actualexposure level.

A summary of the Cal/OSHA Lead in Construction standard appears inAppendix B. The complete standard is available on Cal/OSHA’s website atwww.dir.ca.gov. Click on “Occupational Safety & Health” and search Title 8Regulations for section 1532.1.

Certain lead-safe work practices are also mandated by EPA, by DHS’s Title17, and by HUD. These are primarily designed to prevent lead work fromcontaminating 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. Theserequirements are explained more completely later in this chapter. Themeasures 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/m3. A highrisk task is 50 µg/m3 or over.

Containment

◆ Restrict access to work area


Higher risk tasks—Required.

◆ Post warning signs

Lower risk tasks—Interior work: Recommended at entrance toroom. Exterior work: Recommended on building and at workperimeter.

High risk tasks—Interior and exterior work: Required byCal/OSHA at perimeter of the regulated area.

C H A P T E R 7 — U S E S A F E W O R K P R A C T I C E S

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◆ 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 tothe wall. Exterior: Sheeting 10 feet from work area in alldirections, secured with weights. Close nearby windows orcover with plastic. Control water runoff.

High risk tasks—Interior: two layers of sheeting on wholefloor, taped to the wall. Have simple airlock at door ortape door shut. Exterior: Sheeting 10–20 feet in alldirections, taped to the building and secured with weights.Seal windows within 20 feet. May need verticalcontainment. Control water runoff.

◆ Protect items in work area

Lower risk tasks—Remove items within 5 feet, or cover andsecure them.

High risk tasks—Interior: Remove items, or cover andsecure 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, andair conditioning (HVAC) vents within 5 feet of work area. Useproper lockout/tagout procedures if necessary.

High risk tasks—Interior: Shut down entire HVAC system andseal vents near work area with plastic. Provide alternateventilation if needed. Use proper lockout/tagout procedures.

Work Methods

◆ Work wet

All tasks—Use wet methods, except near electrical circuitsor equipment.

◆ Use HEPA attachments on power tools (sanders, etc.)

Lower risk tasks—Not applicable. Using power tools on lead-painted surfaces is always high risk and is defined byCal/OSHA as a “trigger” task.



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Cleanup and Disposal

◆ Clean work areas

Lower risk tasks—Clean indoor and outdoor work areas daily. Donot allow children or others to have access to work area afterthe work day if possible. Interior: Wet wash with lead-specificor other suitable detergent around work area (2 feet beyondarea originally protected by plastic sheeting). Exterior:Remove all visible paint chips or debris.

High risk tasks—Clean indoor and outdoor work areas daily. Donot allow children or others to have access to work area untildust wipe samples have passed required clearance levels.Interior: Clean entire work area—HEPA vacuum, then wetwash, then HEPA vacuum again. Exterior: Remove all visiblepaint chips or debris.

◆ Check safety of area after work is completed

Lower risk tasks—Visual examination. Dust wipe samplingrecommended on 5% of tasks to check effectiveness ofcontainment and work practices.

High risk tasks—Interior: For abatement only, clearance dust wipesampling is required after all tasks. Exterior: Visualexamination required, and clearance dust wipe samples onexterior floors and horizontal window surfaces.

◆ Dispose of waste safely

Lower risk tasks—Keep hazardous and non-hazardous wasteseparated. Depending on amount of hazardous waste and itslead content, may have to transport to a licensed collectionfacility. This is less likely for lower risk tasks although leadpaint debris is hazardous.

High risk tasks—Keep hazardous and non-hazardous wasteseparated. Depending on amount of hazardous waste and itslead content, may have to transport to a licensed collectionfacility.


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How Do You Set Up a Lead Maintenance Job?

Plan all maintenance work involving lead carefully. Consider what materialsand 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 afterwork is done.

Always use containment! Containment is a system, process, or barrier thatis used to contain lead hazards inside a work area. It can range from warningsigns, plastic sheeting, and special work procedures (for lower risk jobs) tofull enclosure (for high risk or abatement jobs). This chapter describes thesteps in a system of containment.

Also, before work begins, pay special attention to the debris and other wastethat will be generated. Since the safe disposal of hazardous waste is costlyand time consuming, plan the work so that the amount of hazardous waste iskept to a minimum right from the start. Also keep hazardous and non-hazardous waste materials separated at all times. (There is more informationon 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 materialsand equipment. It may be helpful to have a special Maintenance andOperations lead cart or carrier to transport these items.

The following materials should be available. Use items in the list belowonly 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 willnot 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.


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• 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 cleanedsince 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 orP-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 leadwork but especially for high risk tasks).

2. Restrict Access to the Work Area

Only workers who are trained and directly involved in the leadmaintenance task should be allowed near the work area. Make specialefforts 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, erecttemporary physical barriers.


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3. Use Plastic Sheeting to Contain Lead Dust and Paint Chips

One of the most important ways to prevent lead contamination is alwaysto use disposable plastic sheeting (or “poly” for polyethylene plastic) onthe 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 plasticcontains the lead dust inside the work area and makes it much easier toclean up afterwards. Containment like this should be used for every leadtask, no matter how small.

Before starting work, break the task down into steps. Assess what debriswill result from each step and plan your containment accordingly.

Lower Risk Tasks

• For good containment on indoor tasks, lay the polyso it extends at least five feet in all directions fromthe work area. Secure it to the wall with non-destructive (blue) tape or staples.

• Move or cover furniture and other nearby itemsthat could be contaminated by lead dust or chips.

• Take special care to protect carpets. It is nearlyimpossible to remove lead dust from carpets oncethey become contaminated.

• If the work is to be done on the ceiling, the entirefloor should be covered with plastic. Run theplastic a short way up onto the walls and seal itwith tape.

Be careful working in an area covered with plastic sheeting. You mayslip, trip, or fall. Sheeting should be cut out around the ladder feet so thatladders have a firm footing. Tape the sheeting to the ladder feet topreserve good containment.

For lower risk outdoor tasks, extend poly ten feet in all directions andsecure it with weights. Also cover bushes, landscaping, and any othernearby objects with sheeting or scaffold netting (black mesh). Securethese covers. Cover and seal building windows with plastic sheeting andtape. For very low risk tasks you can simply close all nearby windows.

If it’s windy when outdoor lead work is scheduled, postpone the workuntil the wind will no longer blow paint chips around. If it starts to rain,stop work immediately and clean up.


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High Risk Tasks

Containment for a high risk task usually involvesputting more plastic down. For indoor tasks, thewhole floor of the room should be covered withtwo layers of poly. That way, the top layer can beremoved at the end of the day withoutcontaminating the floor. Put a new top layer downbefore beginning work the next day. Seal the polyto the wall with non-destructive (blue) tape.

Doorways and windows should be sealed. Ifworkers need to use doorways to enter and exit,construct an airlock flap using double sheets ofplastic with slits on opposite sides. An airlock canbe built by taping one sheet of poly, the size of thedoor frame, across the top and down the right sideof the frame. Then tape a second sheet of poly, thesame size, across the top and down the left side ofthe frame. You enter between the two sheets.

For high risk outdoor tasks, extend poly at least ten feet in all directionsand secure it. Extend the poly farther (up to 20 feet) if working at aheight (for example, on the side of a building). You may need to build avertical containment to control the dust on some outdoor projects.(Scaffolding hung with black mesh netting is often used.) Seal thewindows within 20 feet of the work area.

Water Runoff

If you are using water during lead work, the water runoff may becontaminated by lead paint or chips. Contain the water by rolling theedges of the poly on all sides around 2x4’s or something similar, creatingan area about two inches deep to hold water. This is called a “berm.” Atthe end of each work day collect the contaminated water with a specialHEPA vacuum designed to pick up water, or with a mop. Dispose of thewater as hazardous waste. Then roll up the poly, seal it with tape, anddispose of it properly.

4. Turn Off HVAC System or Seal Vents

For lower risk indoor lead tasks, shut down heating, ventilation, and airconditioning (HVAC) vents within five feet. The air flow could blow dustaround.

For higher risk tasks, also seal the vents with plastic sheeting. This helpsprevent the lead dust from spreading to other rooms.


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For a very high risk task, shut down the entire HVAC system and sealvents with sheeting. Depending on your particular HVAC system, shuttingdown may involve turning off a switch with a key, or resettingcomputerized controls. Regardless of the type of system, take steps toensure that no one can accidently restart it. Use proper lockout/tagoutprocedures.

What Work Methods Should Be Used for Lead Tasks?

Use safe work methods when doing any maintenance task involving lead. Thesafest methods keep lead dust to a minimum so children and workers won’tbe exposed.

What Is “Working Wet”?

Working wet is a key lead-safe method. Dust levelscan be kept low by keeping the surface damp whileworking. Mist the area with a spray bottle orcommercial sprayer. Mist continuously throughoutthe course of the work. Allow for the water to soakinto the material. Keep lead debris and chips wet,or clean them up before they dry. Be careful not touse too much water, which could cause runoff anddamage to the building. Remember you want thepaint wet, but you do not want pools of water onthe floor.

IMPORTANT! Electricity and water are a deadlycombination.

The only time wet methods are not recommended is when working withelectrical equipment or around electrical outlets. Never use water aroundoutlets or electrical boxes, whether the power is on or off. Never use wateraround 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 surfacepreparation. Carefully chip or wet-sand the edges until no loose paintremains on the surface. Wet-sanding consists of wetting the materialcontinually with the sprayer while sanding.


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When a small area of paint needs to be removed and the painted surface isundamaged, 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, thismethod is effective when removing a cabinet or door hinge that has beenpainted over. Cutting around the hinge will reduce the chance of chipping thepaint, and will also make removal of the hinge much easier.

Scraping paint from larger areas may be a high risk task requiring specialprecautions.

Are Special Vacuum Cleaners Needed for Lead Work?

Yes. Always use a HEPA vacuum for lead work. This is an industrialstrength vacuum cleaner with a HEPA filter. HEPA stands for HighEfficiency Particulate Air. HEPA filters can catch lead dust, but regular shopvac 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 ormore 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 HEPAfilter. The HEPA filter captures lead dust before the air is released back intothe work area.


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How Do You Use a HEPA Vacuum?

1. Lightly mist the area with water to keep dust levels down. Ifyour HEPA vacuum is not a wet vacuum, do not vacuum up poolsof water. Read the manufacturer’s instructions for proper use.

2. Vacuum slowly. Remember that lead dust sticks to surfaces. Ifyou go slowly the HEPA vacuum can pick up all or most of thelead 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 HEPAvacuuming 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 theprefilter often for dust and debris clogs. Change filters when necessary. Useonly parts and filters that are the same make as the originals. Never use shopvacuum parts on a HEPA vacuum.

Removing and replacing HEPA filters, prefilters, bags, and parts should betreated 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 polycontainment for at least 5 feet. Use two layers of poly taped and sealed ontop of each other. Wear protective clothing and a respirator. Follow themanufacturer’s instructions to remove the HEPA filter and place it in adisposal bag. If the vacuum cleaner bag is also removed, handle it gently andtape the opening closed to seal the bag’s contents. Place it in a properdisposal 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 firstvacuum before replacing parts, filters, and bags. Be sure the new filters andbags are seated and fit properly. Then clean up the site with a HEPA vacuum,wet wash and rinse. Dispose of hazardous waste properly.


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Are Special Power Tools Needed for Lead Work?

Yes. For example, power sanding or grindingpaint can create very high levels of leaddust, exposing workers and spreading leadcontamination. This is always considered ahigh risk “trigger” task. If you are going touse power tools, always control the dustusing a HEPA vacuum attachment on thetool. The tool is attached by a hose to aHEPA vacuum cleaner, as shown at theright. The vacuum has a special filtersystem to capture fine lead dust andprevent it from being blown around.

A HEPA attachment to a power toolcaptures the paint dust generated by thework before it gets into the air, and collectsit in the vacuum bag and filter. Alwaysfollow manufacturers’ instructions for thesafe operation and cleaning of HEPA tools.

Electrical Safety

Remember electrical safety when using electric power tools. You can preventshocks if you:

◆ 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 shutoff power before you get a shock. Extension cords should have theirown 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 aladder, use a non-metal ladder.

◆ Don’t use power tools near water.

GFI


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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 beused to peel the paint. The heat setting should not exceed 1000o Fahrenheit ortoxic fumes can be released. You must guard against the danger of fire aswell. A fire extinguisher must be readily available.

When using a heat gun, never blister paint more than necessary. Afterapplying the heat, scrape carefully. Only skilled employees should use a heatgun on lead painted surfaces. Never use an open flame or torch. Rememberthat using a heat gun is a Cal/OSHA “trigger task” and only certified workersmay 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 andother 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 otherprotective clothing. These should be types which are impervious to theparticular caustic being used. They will keep it off the skin. Caustics cancause serious skin and eye damage. There must be emergency eyewashes andsafety showers readily accessible. Also restrict access to the work area.

Chemical stripping produces waste. Any waste generated is consideredhazardous 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 onthe surface, especially if some old lead paint remains. The remaining oldpaint may peel if you don’t seal the surface. This would release lead. Peelingcan 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 contaminatedwith lead dust, cleaning it to remove the dust can be extremely difficult and


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sometimes impossible. In addition, large quantities of lead dust canaccumulate under the carpeting.

Dry vacuuming should be prohibited. Even with a HEPA vacuum, it canincrease the risk of exposure by bringing the lead dust closer to the carpetsurface. If a regular (non-HEPA) vacuum is used, lead dust will also escapeinto the surrounding air out of the vacuum.

When performed properly, cleaning carpets by wet methods can effectivelyremove some lead dust and debris. However, the question of contaminationstill remains. Use wet methods only to clean up small amounts of lead dustand debris in a small surface area.

To wet clean a small section of carpet, move objects from the area. Thencollect visible chips or debris by misting and using cloths wetted with a lead-specific cleaning solution. Next, thoroughly mist the area and clean using thesolution with rags or sponges. Then rinse the area thoroughly with cleanwater. Dispose of waste according to hazardous waste regulations.

If an area rug or small section of carpet is contaminated, consider simplydisposing of it instead of cleaning. To remove small sections of contaminatedcarpet, move objects from the area. Collect any visible debris as describedabove. Mist the work area and cut the carpet. Carefully remove and place thepieces in disposal bags. Wet wipe and HEPA vacuum the debris remainingunder the removed section. Dispose of waste appropriately.

While cleaning or removing a small section of lightly contaminated carpetmay be a lower risk task, removing and disposing of heavily contaminatedcarpeting (especially a large area) is considered high risk.

To remove extremely contaminated carpet, high risk procedures must be inplace. These include protective clothing, respirators, personal monitoring,personal hygiene, training, certification, and all other requirements of theCal/OSHA Lead in Construction standard. Also follow all the proceduresdescribed in this chapter for posting warning signs, containment, isolatingventilation systems, work practices, and cleanup. Moisten or mist the entirecarpet and any dust underneath. Continually mist the carpet as it is rolled orfolded up inward on itself. Carefully wrap up the carpet in poly and seal itwith 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 intopieces before removal. Dispose of all waste appropriately.

To determine if a particular carpet cleaning or removal task is lower risk orhigh risk, you may want to get the advice of a certified lead professional.


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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 canremain, exposing children and other members of the school community. Thedust 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 coatedwith a residue of lead dust that is very difficult to remove. This lead dust cancontaminate the entire area quickly if it is on surfaces that are subject toabrasion, 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 wetcleaning. HEPA vacuums were discussed earlier in this chapter.

Wet cleaning methods also help to keep lead dust out of the air. Using wetcleaning methods alone is probably sufficient for lower risk work. If you adda detergent (or a special solution made for lead cleaning) to your water, wetcleaning works even better. The solution attracts and picks up lead particles.

To do wet cleaning, you will need two buckets and a premixedlead-specific detergent solution. Leave one bucket empty andfill one with clean water. You can keep the detergent solutionin its original container (spray or pour bottle), or in a thirdbucket.

Wet a cloth with cleaning solution and wash all surfaces(including those that had been covered with plastic). Wringout the cloth into the empty bucket. Then wet the cloth withcleaning solution again and repeat the washing. Replace thecloth whenever it gets loaded with dust and debris.

Next, dip a new cloth into the water bucket and rinse all thesurfaces you just cleaned. This removes detergent solutionthat can leave a film. Then wring out the cloth into the emptybucket, dip it into the clean water again, and repeat therinsing. Change the clean water periodically.


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Trisodium phosphate (TSP) solutions, used widely in the past, cause eyeirritation and environmental damage. Some states and all federal projectshave banned the use of TSP. However, there are other types of solutionsavailable, some designed specifically for lead. If any solution you use is anirritant, 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 vacuumand wet cleaning. First use the HEPA vacuum to clean all surfaces in thearea. Do not use a regular household vacuum or shop vac. If no HEPAvacuum is available, use wet cleaning alone.

After HEPA vacuuming once, wet wipe the area using the wet cleaningmethod described earlier. Finally, HEPA vacuum the work area again.Carefully wrap up any remaining debris in your plastic sheeting and seal itwith tape for disposal. Tools and equipment you have used should also be wetwiped. Any personal protective equipment you have used should be HEPAvacuumed. 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 youhave properly cleaned it. It is important to inspect the area after cleaning upto be sure there is no visible dust or debris remaining. For small, low risktasks, a visual inspection is probably all that is necessary. For high risk tasks,clearance wipe samples are recommended. (They are required for abatementtasks.)

What Is a Clearance Wipe Sample?

Wipe sampling is a way of measuring settled lead dust on a surface. After ahigh risk indoor task is completed and the area has been thoroughly cleaned,“clearance” wipe samples must be taken by someone who is state certifiedfor this purpose. (There are some exceptions to the certification requirementas explained below.) The process involves carefully wiping a measuredsurface area with a baby wipe which is then sent to an accredited laboratory.It is called “clearance” wipe sampling because results must be below acertain level before the area is considered safe (or “cleared”) for people toenter.

Although not required, you may also want to perform wipe samples on about5% of your lower risk jobs. This allows you to evaluate how effective yourlead-safe work practices and containment are. You can modify work practices,containment, or cleanup methods if the wipe samples show levels that are toohigh. Wipe sampling for this purpose does not require state certification,although training is needed.


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When wipe sample results come back from the laboratory, they must showlevels less than those indicated in the list below for each type of surface orarea. If they are equal to or higher than these levels, the area is consideredlead contaminated and must be cleaned and tested again before occupancy.Clearance levels are given in micrograms of lead per square foot of area(µg/ft2), or parts per million (ppm) for soil.

Clearance Levels

Interior floor surfaces 50 µg/ft2

Interior horizontal window surfaces 250 µg/ft2

Exterior horizontal window surfaces 800 µg/ft2

Exterior floor surfaces 800 µg/ft2

Soil in play areas 400 ppm

Soil in other areas 1,000 ppm

—Title 17, Section 35035

How Should You Dispose of Waste From Lead Work?

After cleaning up, you must dispose of the waste that was generated by thelead work. This waste may be either hazardous or non-hazardous, dependingon how much lead is in it. If the waste is hazardous, there are strict rulesgoverning how and where you can dispose of it.

Waste is hazardous if it is ignitable, corrosive, toxic, or reactive. Lead wasteis in the toxic category. If you use certain paint strippers on a lead job, thenthat 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 toplan 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 ofspecial disposal for the non-hazardous portion of the waste.

Waste materials should be physically separated by sorting them intocategories of “like materials” as the job progresses. There are differentmethods for doing this. Cal/EPA has described a two-category system whileHUD describes a more complex four-category system.

The two-category system separates the waste stream as shown on the nextpage. Depending upon the quantity of the waste, it may be economical todispose 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.


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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 whenused to wrap paint chips).

◆ Respirator filters.

◆ Carpets, rugs, and padding.

◆ Solid building components with intact, unpeeling paint, such asdoors, casements, moldings, and jambs.

IMPORTANT! The only way to know for sure if waste is hazardous is to haveit 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 aregenerated. (How many samples you take and their location is a controversialdecision. 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 streamis equal to or higher than 1,000 ppm, then that waste stream is hazardous andmust 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 beperformed. This is called the Waste Extraction Test (WET). This testmeasures the Soluble Threshold Limit Concentration (STLC). If any sampleof your waste shows a STLC of 5 ppm or more, then you have hazardouswaste (as defined in California).

Contact your designated landfill to see if they require any other tests. Wastebeing transported outside California will also require further tests.


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Hazardous waste is regulated by the California Environmental ProtectionAgency’s Department of Toxic Substances Control. Regulations arecomplicated and under constant revision, so always check with thedepartment 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 requiredto follow certain procedures for proper disposal. How and where to disposeof hazardous waste depends on how much waste is generated each month ateach 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 cantransport up to 50 pounds or 5 gallons of waste at a time to a licensedcollection facility without obtaining a permit.

If more than 220 pounds but less than 2,200 pounds of hazardous waste aregenerated per month per site you become a “small quantity generator.” Thedistrict must contract with a certified hazardous waste hauler to transport anddispose of the hazardous waste. Certified haulers already have the necessarypermits to deal with these larger quantities of waste.

A “large quantity generator” produces over 2,200 pounds of hazardous wasteper month.

Regardless of the quantity you generate, hazardous waste should betransported and disposed of promptly. You may store up to 220 pounds ofhazardous waste without obtaining a permit. If you store more than 220pounds, then you have 90 days to dispose of it. The 90-day period begins onthe first day any hazardous waste is stored. You must get a storage permit tokeep hazardous waste more than 90 days. The best and safest policy is todispose of hazardous waste immediately, avoiding accumulation.

Keep hazardous waste separated from non-hazardous waste while you aredoing the job and keep the amount of hazardous waste to a minimum ifpossible. For example, if you use two layers of poly on a high risk job, onlythe 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 becostly and time consuming. So take the time to plan the job carefully.

There are complex waste disposal regulations for all the generator categoriesabove. For more information about hazardous waste regulations, contact theCalifornia EPA Department of Toxic Substances Control office near you.


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Check city and county ordinances for any additional requirements governingthe disposal of hazardous waste. Cities and counties may also have assistanceprograms that can help.

What About Waste Water From a Lead Job?

Disposing of lead-contaminated water after a job is a difficult issue. Typicalprocedures to reduce the contamination or the volume of the waste waterinclude filtering and letting the lead settle out in a holding tank. This isconsidered a “treatment” in California, and is subject to strict regulations. Atthe very least, Cal/EPA must be notified before you begin if you plan such aprocedure.

C H A P T E R 8 — T R A I N W O R K E R S

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◆8Train Workers

CHAPTER

Who Should Be Trained?

Training is a key element of a lead-safe schools program. Maintenance andOperations (M&O) workers need to understand lead health and safety issuesand the specialized work practices they should follow. All employees whowork around lead need some amount of training.

Training is required by several California laws and regulations for everyonewhose work may result in lead exposure. The amount and type of trainingrequired 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 maintenancetasks 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 trainingin lead-safe work practices, since some of their usual tasks may involvelead exposure. If maintenance workers and supervisors are involved inhigh risk lead jobs, they will require advanced training and statecertification.

Teachers, Administrators, and Parents. The whole school communityshould be made aware of lead and its hazards. Educating everyone aboutlead can help build acceptance of your lead-safe schools program.Emphasize that teachers and parents should never disturb lead paint.


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The following sections describe the training required by law for variouslevels of work involving lead. Summaries of the California laws andregulations mentioned appear in Appendices B–F.

What Training Do School Custodians Need?

Job tasks of school custodians vary widely inCalifornia. In some school districts custodiansnever do tasks that disturb lead paint, but in otherdistricts their job descriptions do include suchtasks. For example, some custodians may do basicmaintenance work like minor repairs or painting.

Your lead-safe schools program should determinethe specific tasks that your custodians typicallyperform. This will help you decide who needs whatlevel of training. Even those custodians who neverdo lead maintenance tasks need at least “awareness”level training. This basic introduction to leadhealth and safety issues is required by Cal/OSHA’sHazard Communication standard and Injury andIllness Prevention Program (IIPP) standard.

Giving lead training to all custodians is important for another reason. In mostCalifornia districts, custodians are assigned to a single school and know itwell. Thus they can play an important role in identifying potential leadhazards 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 forcustodial staff should focus on preparing them for this important function aswell 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 mustreceive the more advanced Maintenance and Operations level of training.


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What Training Do Maintenance Workers Need?

M&O workers who may disturb lead paint during their work need moredetailed training about lead-safe work practices. The primary goal of thislevel of training is to educate workers about how to minimize their own leadexposure, and how to reduce the chance of contaminating surfaces accessibleto children.

The training described in this section complies with the trainingrequirements of Cal/OSHA’s Lead in Construction standard. This Guidedefines it as the “M&O level of training.” Although Cal/OSHA requirestraining on the topics shown here only when workers are exposed to leadabove the Action Level (30 µg/m3), it is desirable for all M&O workers whomay be exposed to lead on the job to receive this training. Note that thisM&O training is not sufficient for workers who do high risk lead tasks(exposure above the PEL of 50 µg/m3). These workers need more advancedtraining and state certification, as explained later in this chapter.

This M&O training is also required by the Cal/OSHA HazardCommunication standard and IIPP standard.

At a minimum, the M&O level of training should include all topics coveredin 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 ofrespirators.

◆ 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 theworker’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.


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What Training Is Available for M&O Departments?

A training curriculum has been developed for school custodians and M&Ostaff by the Lead-Safe Schools Project at the Labor Occupational HealthProgram, U.C. Berkeley. Portions of the curriculum are appropriate for eitherthe “awareness” or “M&O” levels of training just described. To obtain acopy, contact the Lead-Safe Schools Project or the Childhood Lead PoisoningPrevention Branch of the California Department of Health Services.

Note that this curriculum does not cover topics required for state leadcertification. The chart below summarizes how training needs depend on thelevel of workers’ potential exposure to lead.

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 dopersonal air sampling.

What Training Is Needed for High Risk Tasks?

Whenever a school M&O department does high risk lead tasks, theindividuals involved must be certified by the state, whether they are schoolstaff or outside contractors. There are five categories of certification, withdifferent training and experience requirements: Lead Worker, LeadSupervisor, Lead Project Monitor, Lead Project Designer, and LeadInspector/Assessor. For more information on certification requirements,check the website www.childlead.com.

A high risk task is one that falls into either of these categories:

◆ It exposes workers to lead dust or fumes that have beenmeasured, and found to be above the Cal/OSHAPermissible Exposure Limit (PEL) of 50 µg/m3.

◆ It is lead abatement work that is designed to reduce a leadhazard for a minimum of 20 years. For more informationsee Chapter 6.

Awareness Level

M&O Level

Certified Level


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Certified Lead Worker Training

Workers who do high risk tasks must receive specialized training and becertified by the state as Lead Workers.

Certification can be obtained only by attending a 24-hour Lead Worker coursegiven by a training provider who is accredited by DHS. For an up-to-date listof accredited training providers, check the website www.childlead.com.

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, theLead-Safe Schools Protection Act, and Title 17 of the California Code ofRegulations.

IMPORTANT! California public elementary schools and childcare facilitiesare required by the Lead-Safe Schools Protection Act to use only DHS-certified Lead Workers and Lead Supervisors when abating lead hazards.Failure to use DHS-certified personnel for abatement can also result in aCal/OSHA citation.


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Certified Lead Supervisor Training

Maintenance supervisors must also be certified if their staff do high risk leadtasks. This level of certification can be obtained only by attending a 40-hourLead Supervisor course given by a training provider accredited by DHS andpassing a state exam. One year of experience as a Certified Lead Worker, ortwo 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 leadwaste.

At a minimum, Certified Lead Supervisor training includes all the elementsincluded in Certified Lead Worker training, plus:

◆ Exposure assessment, including paint chip collection and personal airsampling.

◆ 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 ensurecompliance with job specifications and the law. They are usually employedonly 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’ exposurelevels.

◆ Checking dust wipe samples to ensure adequacy of containment.

◆ Conducting clearance testing at the end of each project to see if anylead contamination remains.

◆ Checking work activities for compliance with federal, state, and localregulations.

Certification as a Lead Project Monitor requires a 40-hour course andpassing a state exam. There are also education and experience requirements.


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Lead Project Designer Training

Lead Project Designers prepare specifications, detailed designs, and costestimates for lead-related construction projects. They are usually employedonly on large projects. Their duties typically include:

◆ Visiting the site and reviewing inspection reports to select the properabatement, 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 forreducing costs.

To be certified as a Lead Project Designer, it is necessary to attend a 40-hourConstruction Supervision and Project Monitoring course and a 16-hourConstruction Project Design course. Project Designers must also meetcertain education and experience requirements and pass a state exam.

Lead Inspector/Assessor Training

Lead Inspector/Assessors inspect buildings and other areas for lead. Theyalso assess the extent of lead hazards. This level of certification isrecommended for anyone responsible for design and implementation of aschool district’s lead-safe schools program. Duties typically include:

◆ Conducting visual inspections to examine the condition of paintedsurfaces 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 surfacesfor lead.

◆ Interpreting laboratory and XRF test results.

◆ Preparing reports on the extent of lead hazards and the risks of leadpoisoning.

◆ Recommending cost effective ways to safely handle lead hazards.

◆ Taking clearance samples.

Certification as a Lead Inspector/Assessor requires a 40-hour course andpassing a state exam. There are also education and experience requirements.


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What Can Certified Personnel Do on a Lead Project?

The table below, provided by DHS, shows what job responsibilities arepermitted depending on a person’s level of certification.

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 onTitle 17.

Abatement: Any set of measures designed to reduce or eliminate leadhazards or lead-based paint in public and residential buildings. Does notinclude containment or cleaning. Abatement which is designed to reduce leadpaint or other lead hazards for a minimum of twenty years requires state-certified supervisors and state-certified workers, among other requirements.

Clearance Inspection: An on-site limited investigation (as described byHUD 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 toensure Cal/OSHA compliance or for hazardous waste disposal purposes.

Lead Hazard Evaluation: The on-site investigation, for compensation, oflead hazards or lead-based paint, such as a lead inspection, risk assessment,and clearance inspection, in public and residential buildings. Does notinclude activities intended to determine Cal/OSHA compliance or adequacyof containment.

Lead Hazard: Deteriorated lead-based paint, lead contaminated dust, leadcontaminated soil, disturbing lead-based paint or presumed lead-based paintwithout containment, or any other nuisance which may result in persistentand quantifiable lead exposure.

Abatement Work

Abatement Planning

Hazard Evaluatio

ns

Clearance Inspectio

ns


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Will Workers’ Job Duties Change?

When you institute a lead-safe schools program, job duties ofindividual workers may change. Revising school maintenanceprocedures to deal with lead paint will probably change how tasksare done, who does them, and how much training workers need.

For example:

◆ Some tasks may now need to be done by M&O employeeswith 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 theyshould no longer do, and why.

◆ Using lead-safe procedures for maintenance tasks willprobably take more time for setup, doing the task, cleanup,and proper waste disposal.

It may be necessary to revise written job descriptions to reflectthese changes in duties. You may also need to increasemaintenance staffing levels. Remember that rewriting jobdescriptions requires discussing and negotiating these changeswith any unions that represent these employees.

Also notify workers in writing of the policies and procedures they now haveto follow for routine tasks. Reinforce this message through safety meetingsand training sessions. If applicable, explain why past practices must bediscontinued. In some cases, you may need to postpone certain tasks on themaintenance schedule until workers have obtained the appropriate training,and where needed, DHS certification. Or you may need to use outside lead-certified 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 risktask, or abatement work designed to reduce a lead hazard for a minimum of20 years, you must either have a DHS-certified crew and supervisor on staffor hire a DHS-certified contractor. Here are a few tips for selecting acontractor:

◆ Hire only licensed contractors. Ask for the contractor’s licensenumber.


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◆ Hire only contractors that are DHS-certified to perform lead-relatedconstruction work. Ask to see the certification cards of the contractorand the contractor’s employees (both workers and supervisors). Youmay verify the certification by checking the websitewww.childlead.com.

◆ Ask about the contractor’s program for controlling worker leadexposure. It should meet Cal/OSHA requirements and includeappropriate respiratory protection, periodic testing of workers’ bloodlead levels, and conscientious housekeeping and personal hygienepractices.

◆ Ask the contractor what special precautions will be taken to controlexposure 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 proceduresthe 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 anddocument them.

For more on contractor requirements, see Appendix G.

What Information Do Parents and Teachers Need?

Educating parents and other volunteers about the hazards of lead paint shouldbe a part of every school district’s lead program. Parent involvement inschools is very important to the success of our children’s education. Parentgroups work hard to raise money and often devote countless hours ofvolunteer labor that improves school facilities.

In general, these efforts should be encouraged. As districts becomeincreasingly strapped for resources, parents may step in and volunteer tohelp. For example, they have sometimes done painting or run computercables to connect their school to the Internet.

Bear in mind that these tasks can potentially create lead hazards. Manymaintenance issues are too complicated for parents to tackle. School districtsshould make certain that these volunteer projects do not disturb paintedsurfaces. The school district could not only face liability for unsafesituations that they create, but may also have to pay high cleanup costs.


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Teachers and administrators may be approached by parents offering to dovolunteer projects. It is important for school officials to be aware of thepotential for lead problems and to communicate these concerns. Thereshould be clear written policies on volunteer work and the entire schoolcommunity should understand them. Policies should also cover any volunteermaintenance work done by teachers.

IMPORTANT! All volunteer projects to improve school facilities should bereviewed and approved by the lead-safe schools program manager.

Some school districts have policies that trained maintenance staff willprepare surfaces for repainting. They limit volunteer involvement to thepainting itself:

M&O Preps—Parents Paint

A group of parents told a school principal that theywanted to help students paint an ocean mural in one ofthe classrooms. The principal contacted the M&Odepartment. The head of M&O worked with the parentsand prepped the room for painting. He even used primercolors that blended with the proposed mural. He alsomade 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 adoptedthis policy: volunteers may paint a classroom or otherareas of a school, but only after it has been prepped byM&O. The Los Angeles school district, for example, nowhas a written policy to this effect.

Parents can play an important role in voicing concerns about lead problemsno one else has noticed. In one California school district, a parent noticedthat the exterior of her child’s school was being sandblasted. She askedwhether the paint had been tested for lead. It turned out that the paint didcontain high levels of lead. The sandblasting had to be stopped and the areacleaned up.

For sample guidelines on working with parent volunteers, see Appendix H.


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C H A P T E R 9 — D O C U M E N T & E V A L U A T E

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◆9Document & Evaluate the Program

CHAPTER

What Records Do You Need?

In managing your lead-safe schools program, it is essential to documentwhat you do by keeping systematic written records. You should also evaluatethe program regularly to measure progress and see what needs improving.Documentation and evaluation are as important as any other element of theprogram.

Following are some suggestions for records you will probably need to keepon file. This is not a complete list. You may have additional types of recordsspecific to your district’s needs.

Program Plan

As you develop your program, use the Program Planning Form discussed inChapter 3 as a model. It can serve as documentation that each element of alead-safe schools program has been put in place. It can also help identify andorganize the records you need to maintain. When the form has beencompleted, keep it on file. It will be a useful summary of your entireprogram.

The Program Planning Form follows the six basic elements that have beendiscussed throughout this Guide. For each element, you will need certaintypes of documentation. You can note on the Program Planning Form whatrecords you will maintain for each element, and then organize the recordsthemselves the same way.


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See the discussion in Chapter 4. Records may include:

◆ The completed District Target Schools Form, or your ownequivalent form.

◆ A completed Building Inventory Form—Paint and Soil Hazardsfor each school, or your own equivalent form.

◆ Results of any testing of paint, soil, or water. Records should includesampling locations, date collected, who collected the samples andthat person’s qualifications, and the testing laboratory’s address,phone, and contact person.

◆ Work orders to correct identified problems. Show when the work wascompleted.



◆ Personal air sampling results for workers performing lead tasks.

◆ A list of typical M&O tasks and their lead exposure levels, based onsampling.

◆ A list of areas where full scale abatement work may be necessary, andwhat follow-up is planned.



◆ A list of personal protective equipment (PPE) available forlead tasks at various risk levels. Keep purchase orders and invoices.

◆ Documentation of your Respiratory Protection Program. A completeprogram, including a written plan, is required by Cal/OSHA ifrespirators are used. Documentation must be maintained includingexposure levels, respirator and cartridge selection, workers’ respiratortraining, and respirator maintenance, and other records.

◆ Documentation of your Medical Surveillance Program. This programis required by Cal/OSHA if exposure is above the Action Level.Results of workers’ “baseline” blood tests, later blood tests, and otherlead-related tests must be kept on file. Remember that they areconfidential.


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◆ A set of written procedures for all common tasks involving lead.Include both lower risk and high risk tasks. Include information onhow compliance will be enforced and who is responsible. Circulatethese procedures to all maintenance staff and keep records of who hasreceived them.

◆ A list of equipment and supplies available for lead work. Keeppurchase orders and invoices.

◆ Results of wipe samples done to check safety of work areas after leadtasks are done.

◆ Results of testing of waste to determine if it is hazardous.

◆ Hazardous waste disposal manifests and landfill receipts.

5. Train Workers


◆ A list of workers who have been trained and at what level. For eachworker, give name of trainer, date, and training agenda.

◆ Copies of any DHS lead certifications that workers have received, andrequired renewal dates.

◆ A list of outside lead contractors used by the district and copies oftheir DHS certifications. Also keep copies of the contracts.


Use the sections provided on the Program Plan in Chapter 3 for periodicevaluations of your program. You may want to include wipe testingresults and documentation of worker and management feedback you havereceived. See the discussion of evaluation later in this chapter.


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Is Recordkeeping Required?

Yes. You are required to maintain certain records tocomply with the law. Recordkeeping is required by severalCal/OSHA standards, including the Lead in Construction,Respiratory Protection, Hazard Communication, andInjury and Illness Prevention standards. It is also requiredby EPA regulations, the state Lead-Safe Schools ProtectionAct, and the state Lead Accreditation and CertificationProgram (Title 17). For example, air sampling and bloodlead test results must be kept on file according to the Cal/OSHA Lead in Construction standard, and records ofworker lead training and certification must be maintainedto comply with Title 17.

For recordkeeping requirements of the Cal/OSHA standards check thewebsite www.dir.ca.gov. Click on “Occupational Safety & Health” and go toTitle 8 Regulations. Summaries of some Cal/OSHA standards also appear inAppendices B–D of this Guide. For information on recordkeeping under otherlaws and regulations involving lead, check the website www.childlead.com.

In some cases, recordkeeping requirements overlap. Records maintained tocomply with one law or regulation may also help you comply with others.

Check individual standards, laws, and regulations to determine how longrecords must be kept. Often specific retention periods are specified, rangingfrom less than a year to much longer.

How and Where Should Records Be Kept?

You will need a system to keep track of all the informationyour program generates—for example, policies,procedures, survey data, and test results. Determine whattype of recordkeeping system makes sense for yourdistrict. It is best if original records are kept in a centrallocation in the district, such as the lead-safe schoolsprogram manager’s office. This permits management andstaff at the district’s headquarters to have easy access tothem, and also puts them readily at hand in the event of aregulatory agency inspection.

Duplicate copies of some records may also be kept at individual schools soadministrators and maintenance staff there can refer to them. If the schooldistrict’s Maintenance and Operations (M&O) department has its owncentral facility, copies may also be kept there. Some districts may choose to


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computerize their records and make them immediately available at alllocations via a network.

Also consider how you will record your information. For example, you maywant to adopt standard forms to use for site surveys; tests of paint, soil, andwater; personal air sampling results; worker training; work scheduled andcompleted; and waste disposal. A few sample forms are provided in thisGuide, but you may want to create your own forms to meet the special needsof your district. In some cases, existing school district forms, such as M&Owork orders, may have to be modified to provide information that your lead-safe schools program needs.

How Should You Evaluate Your Program?

Your lead-safe schools program will improve only if you periodicallyevaluate its progress. Try to determine what’s working and what isn’t, andsee what can be done better. But evaluation takes place only if it is built intothe program from the beginning. Develop systematic methods and a regularschedule for your evaluation activities.

Evaluate the program on every level, from the local school to topadministration. For example, on the local level, interview M&O staff to getfeedback 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 controllinglead contamination?

◆ Do staff feel they have enough training, equipment, and time?

◆ Have there been any accidents or mishaps during lead work thatresulted in contamination? Why did they happen? What could havebeen done differently?

On the local or district level, involve existing health and safety committeesin the evaluation by asking them to consider questions like those above. Alsoget worker feedback at safety trainings.

Look at objective results as well. For example, perform wipe samples aftersome lead jobs to test the effectiveness of the containment. You may want todo such sampling to compare various work methods and see which are mosteffective. If lead levels begin to rise on wipe samples, evaluate theprocedures used and make necessary changes. Re-training may also beneeded.


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The lead program manager should review the input received from all thesesources and try to form an overall picture of how well the program isworking. Identify problem areas and target them for improvement. Alsoshare information with managers of similar programs in other districts.

The ultimate question for the lead program manager to answer is how wellthe program is meeting its basic goals—protection of children and workersfrom lead.

F O R M S

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◆R◆M◆S

◆F◆O


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F O R M S

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Program Planning Form

Name of School District ___________________________________ Date ______________________

Program Manager

� A Program Manager has been appointed.

Name ___________________________________ Title _______________________________

Location _________________________________ Phone ______________________________

� The Program Manager reports to:

Name ___________________________________ Title _______________________________

Location _________________________________ Phone ______________________________

� The Program Manager has DHS lead certification.

Level ___________________________________ Renewal date ________________________


� 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 ___________________________________ Title _______________________________

Location _________________________________ Phone ______________________________

Attach a sheet with additional names if necessary. Also attach a completed BuildingInventory Form—Paint and Soil Hazards for each school building surveyed.


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� Paint chip samples were collected for testing. (Optional.)

Sampling locations and dates _____________________________________________________

______________________________________________________________________________

Samples collected by ____________________________________________________________



� Soil samples were collected for testing. (Optional.)


� Drinking water has been tested at all schools.




� 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 onsampling results and/or other data.

Attach list of tasks.

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� Personal protective equipment (PPE) necessary for lead work has been purchased (booties,goggles, gloves, respirators, etc.).


� 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.


� Written policies and procedures on lead-safe work practices have been developed anddistributed to workers.


� Equipment and supplies necessary for lead work have been purchased (caution tape, plasticsheeting, sprayers, detergent, HEPA vacuums, etc.).


� Wipe sampling has been conducted on a few jobs to check quality of containment and cleanup.

Attach sampling results.


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� Policies and procedures on lead waste disposal have been developed.


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. Alsoattach dated sign-in sheets for trainings.


� Information on the Lead-Safe Schools Program has been sent to key administrators and M&Omanagers.

� The program has been explained to all M&O workers.

� A system for maintaining records has been developed.

� 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-trainingprograms, etc.).

Attach schedule.

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Lead-Safe Schools Program

District Target Schools Form

School District _________________________ Number of Schools in District ______________

Completed By__________________________ Title __________________________________

Use this form to develop a priority list of schools to survey for deteriorated paint andpossible lead contamination of soil.

◆ Target Schools are those that have children eight and under and were built before1993. List all your target schools at the left.

◆ Check Possible Hazards (Paint, Soil) columns if you have information that theremay be a problem. Otherwise skip this section.

◆ In the Priority column, rank schools high, medium, or low. High priority targetschools should be surveyed first.

Total Number of Target Schools _______________ Date Completed _____________

Target School Name Children

Childcare K – 2

Possible Hazards

Paint Soil

PriorityYear Built


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F O R M S

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(✽✽ ✽✽✽)

PR

IOR

ITY

: Rank high/m

edium/low

depending on hazard and accessibility to children eight and under.P

age _____ o

f _____

Building Inventory Form—

Paint and Soil Hazards

School __________________ Building ________________________

Date of Survey ________________________________________

Address __________________________________________________

Site Contact and Phone _________________________________

Survey Com

pleted By _______________________________________

Title ________________________________________________

Ro

om

or

Ou

tdo

or A

rea &U

se of S

pace

Pain

t Co

nd

ition

Prio

rityH

igh

/Med

ium

/Lo

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)

Po

ssibleH

azardN

earby S

urfaces

to C

heck

Resp

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seN

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Fo

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-up

Actio

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Date Taken


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F O R M S

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◆A

◆S

◆P◆P◆E◆N◆D◆I

◆C◆E


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A P P E N D I X A — D H S R E P O R T

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1998

California Department of Health Services

Childhood Lead Poisoning Prevention Branch

Report to the Legislature:

Lead Hazards in California’s Public Elementary Schoolsand 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, § 32240-32245) in response to concerns about the presence of lead hazards inschools. The Act required the California Department of Health Services (DHS) to conduct a studyto determine the prevalence of lead and lead hazards in California’s public elementary schools andchildcare facilities, to report individual findings to participating schools, to makerecommendations on the feasibility and necessity of conducting statewide lead testing in schools,to develop environmental lead testing methods and standards, to evaluate lead abatementtechnologies, and to work with the California Department of Education (CDE) to develop voluntaryguidelines to minimize lead hazards in schools.

Beginning in 1994, DHS conducted a study of the extent of lead contamination in paint, soil, andwater in California schools. Data were collected from 200 randomly selected schools between 1995and 1997. This report presents the findings of the study to the State Legislature and makesrecommendations 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 forDisease Control and Prevention (CDC) has found that “lead poisoning remains the most commonand societally devastating environmental disease of young children” (CDC, 1997). Most childrenwith lead poisoning have no overt symptoms, but can suffer permanent neurological deficits andbehavioral problems, including attention deficit disorder and loss of IQ points. Childhood leadpoisoning has a significant financial cost as lead poisoned children incur significant medical andspecial education costs and have reduced lifetime earning potential.

◆A


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Sources of Lead

There are numerous sources of lead in the environment, ranging from paint pigments to industrialand 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 industryadopted a voluntary one percent limit on lead concentration in interior paint. In 1978, theConsumer Product Safety Commission (CPSC) banned the manufacture of most paints containingmore than 0.06 percent lead. Any existing lead-based paint that is in poor condition is a potentialhazard. Components coated with lead-based paint that abrade one another as they are moved, suchas 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 nearbystructures. Lead is also present in soil as a result of gasoline emissions prior the 1980s when leadwas phased out as a gasoline additive.

Water can become lead-contaminated when lead leaches from plumbing and fixtures, or when thewater supply is contaminated. Plumbing installed before 1930 is considered most likely to containlead. However, newer plumbing is often connected with lead solder, the use of which was notprohibited until 1984.

Children at highest risk for lead poisoning are younger than school age. Most children withelevated 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 environmentalhealth staff investigate possible sources of lead exposure. Nearly always, lead sources in the homeenvironment are identified. Lead hazards at school have not been found to be the primary source oflead in any childhood lead poisoning case in the DHS lead poisoning surveillance system.

Study Methods

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 andmaintenance practices as they may contribute to (or protect against) the generation of lead hazardson 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 daycare facilities. To address the second goal, researchers administered a questionnaire regardingmaintenance 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 andseven exterior paint chip samples were collected. Researchers assessed the overall condition of thepainted surface from which samples were taken. Wherever possible, paint chip samples wereobtained from areas where the paint was visibly deteriorated, as these areas represent the highestpotential hazard. A maximum of seven soil samples were taken at each school. Soil samples werecollected from within five feet of painted walls or windows, within play areas, and from a locationon the school grounds which was as far away from any buildings as possible in order to establish a


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background level. Four drinking water samples were collected from each school: two from aninside outlet and two from an outside outlet. The first sample was taken immediately after thespigot 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 ofSchool Business Officials conference in 1997. Participation was voluntary and anonymous. Thequestionnaire was designed to survey awareness and use of lead-safe work practices, as well asknowledge 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 partslead per million parts paint (ppm). Given the findings of the study, it is estimated that 77.7percent of California’s public elementary schools and child care centers have been painted withlead-based paint. Lead in paint at schools was found at about the same frequency as has beenfound in California homes of similar age.

Cal/OSHA defines lead-containing paint as paint with any detectable lead. This stringentdefinition is useful for protecting workers and others when disturbing lead-containing paintwith activities like surface preparation for repainting, and where paint is deteriorating. Usingthis definition, it is likely that 95.8 percent of schools have some lead-containing paint. Thestudy also shows that only 37.8 percent of the schools with some lead-containing paint alsohave 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 1979.Exterior trim paint tended to have the highest average lead content, followed by (in descendingorder 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 schoolshave bare soils with lead levels that exceed the USEPA reference value for bare soil in areaswhere children play (400 ppm). Soils that contain lead at or above that level are likely to belocated close to school buildings and more likely to occur at schools built before 1940. It is notpossible to determine from study data the source of the lead in the sampled soil. Characterizingsoils at any particular school site will require a more detailed sampling protocol than this studycould 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) partswater. The action recommended by USEPA is to remove the drinking water outlet from serviceimmediately until the lead content falls below the action level. Study data indicate that anestimated 18.1 percent of California schools are likely to have lead in drinking water at or


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above the federal action level. Lead exceeding this level was found at 10.5% of schools wherethe sampled outlet had been used within 24 hours of testing. These findings indicate that insome situations drinking water from school water outlets could contribute to children’s leadexposure, 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 tocontain 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 actionlevel. 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 facilitiesmanagers believe that lead hazards in school pose a significant problem. However, only 11percent 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-relatedconstruction training course. Additionally, most of the respondents reported using unsafe workpractices for managing lead-containing paint. Seventy-four percent of respondents thought thattraining 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 mostCalifornia 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, moreefficient, and more cost effective than wholesale removal of lead-containing paint. Removinglead-containing paint incorrectly can actually increase the risk of exposure to children. Interimcontrol 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 exteriorwalls. Simple steps such as limiting access to these areas or permanently covering them caneliminate potential exposure hazards to children.

3. Drinking Water

Lead may be present in drinking water in up to one in five of California public elementaryschools and child care facilities. A testing and replacement program will identify and eliminatethis potential source of exposure. The USEPA standard of 15 ppb has a safety factor built intoit. Thus it is very unlikely that a child who drinks tap water with the exceedances which were


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found in this study would develop significantly elevated blood lead levels from this sourcealone. Many of California’s public schools have already completed testing of school drinkingwater outlets.

DHS Action Plan

The findings of this study require immediate action, and DHS has begun to work with CDE todevelop, implement, and support a four-year California Lead-Safe Schools Program to promotesafe and cost-effective lead-safe work practices among Local Education Agencies (county and localschool districts). The program will concentrate on lead-based paint maintenance practices that willdecrease childhood exposures to lead. It will include the following key elements: 1) voluntary lead-safe work practice guidelines for schools, 2) identification of high risk tasks and occupationalgroups, 3) training programs aimed at reducing exposure risks to children and staff, 4) a time-limited technical assistance and support program, and 5) evaluation.

Recommendations

These recommendations are designed specifically to address the needs of public elementaryschools and child care facilities that are located on public elementary school grounds. Theyincorporate 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 beapplicable in other settings where young children are present on a regular basis.

1. Paint

Prioritize deferred maintenance activities to classrooms that house the most vulnerablechildren. Deteriorated paint that contains lead presents the greatest opportunity for exposingyoung children to lead hazards. The most vulnerable children in public schools settings arethose in pre-kindergarten through grade 2, and those with developmental disabilities. Targetingtheir classrooms is the surest way to reduce opportunities for exposure to lead, but only if thedeferred maintenance activities are conducted when children are not present and if the workarea is thoroughly cleaned afterwards. Assume that painted surfaces contain lead and use lead-safe work practices, unless the paint is tested. These practices include using sprayers to mistpainted 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 minimizecontamination of the environment. Keep children, pregnant women, and school pets away frompotentially contaminated work areas.

2. Soil

Fence off or cover bare soil adjacent to painted exterior walls of buildings constructed prior to1940 because these areas are likely to contain lead levels that exceed the USEPArecommendation of no more than 400 parts per million lead in bare soils in which children play


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or garden. Unless they are tested for lead content, soils adjacent to painted exterior walls arenot appropriate to use for children’s demonstration gardens, rainbow gardens, or othereducational 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 atschools that have not already done so. The lead content of drinking water was not completelypredicted by age of the school, the length of time the water had been standing in the pipes, orby using the USEPA “flushing” procedure. When lead content exceeds the USEPA action levelof 15 parts per billion and USEPA-recommended remedial action does not reduce lead contentto below 15 parts per billion, Local Education Agencies should make that outlet inoperable andsupply 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 andunnecessary over spending. Program activities should be fully integrated into daily practices sothat they become a standard part of regular work activities.

Use the expertise of DHS Certified Lead-Related Construction personnel. The Lead-SafeSchools Protection Act of 1992 requires that LEAs use DHS Certified Lead-RelatedConstruction personnel for identifying and abating lead hazards. Always verify certification.Each Lead-Related Construction professional who is properly certified has received a photoidentification card from the Department of Health Services. The identification card lists thecategories 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 orthe public at large should accept.

Assure that workers are properly trained. Although existing training materials have not beenmodified to meet the specific needs of the public school environment, LEAs can use existingguidance 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.

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◆BCal/OSHA Lead in Construction Standard

—Summary

Cal/OSHA’s Lead in Construction standard is found in Title 8 of the California Code of Regulations,Construction Safety Orders, section 1532.1. Note that Cal/OSHA’s standard has additional provisionsnot found in the federal OSHA Lead in Construction standard. Following is a summary of the relevantportions of Cal/OSHA’s requirements as of August, 1999. For the complete standard, see the websitewww.dir.ca.gov. 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 leadcompounds.

(b) Definitions

An airborne lead level of 30 µg/m3 is called the Action Level (AL). Having airborne leadconcentrations at or above the AL triggers certain health and safety measures described in thisstandard.

(c) Permissible Exposure Limit (PEL)

The 8-hour Permissible Exposure Limit (PEL) is 50 µg/m3 of airborne lead. If the work day islonger than 8 hours, the PEL is 400/number of hours worked per day. The employer mustensure 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 basicprotective measures where lead is present, until the employer performs an employeeexposure assessment. (Exposure assessment is an initial determination via airmonitoring, 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 basicprotective measures until air monitoring indicates exposure levels are at or below the PEL:

◆ Appropriate respiratory protection (type of respirator is specified according toassumed airborne lead level and requirements of Table 1 on page 136).


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◆ Appropriate personal protective equipment—clean work clothes such as coveralls atleast weekly (daily if greater than 200 µg/m3 lead in air); gloves, hats, shoes ordisposable shoe coverlets, face shields, vented goggles or other appropriateequipment.

◆ Change areas with separate storage facilities for work and street clothes—theemployer shall assure that employees do not leave the workplace with work clothesor equipment.

◆ Hand washing facilities—the employer shall assure that employees wash their handsand face at the end of each work shift.

◆ Biological monitoring—consisting of initial or baseline blood sampling for lead andzinc protoporphyrin (ZPP).

◆ Training—includes Hazard Communication, respirator and lead training.

Lowest Exposure Trigger Tasks:

Assume exposures greater than 50 and up to 500 µg/m3 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 beexposed over the PEL.

Medium Exposure Trigger Tasks:

Assume exposures greater than 500 and up to 2,500 µg/m3 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


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Highest Exposure Trigger Tasks:

Assume exposures greater than 2,500 µg/m3 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 samplesrepresentative of an employee’s regular, daily exposure to lead. Monitoring should include atleast one sample for each job classification in each work area either for each shift or for theshift with the highest exposure level. (For the initial determination, the employer may monitoronly 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 beemployee 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 wereobtained within the past 12 months during closely similar workplace operations andconditions, the employer may rely on the earlier results; or

◆ Where the employer has objective data, demonstrating that a particular product ormaterial containing lead or specific process, operation or activity involving leadcannot 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 implementinginitial monitoring. Objective data confirming that materials or surface coatingscontain less than 0.06% (600 ppm) of lead may be used to demonstrate thatemployee exposure will not exceed the AL, as long as every unique surface ormaterial has been sampled and analyzed.

Note: Objective data are not permitted to be used for exposure assessment inconnection 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 isneeded until there has been a change of equipment, process, control, personnel or a newtask has been initiated.


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If the initial determination is at or above the AL but at or below the PEL, thenmonitoring 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 shallnotify each employee in writing of the results which represent that employee’s airbornelead exposure.

(e) Methods of Compliance

Exposures over the PEL shall be reduced through engineering, work practice and administrativecontrols, 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 shallestablish and implement a written compliance program, describing the lead-emitting activitiesand the means by which exposures will be controlled.

The compliance program shall provide for frequent, regular jobsite inspections by a person whois capable of identifying lead hazards and has authorization to take prompt corrective measures.

Where mechanical ventilation is used, the employer shall evaluate the performance asnecessary to maintain effectiveness.

(f) Respiratory Protection

Where respirators are used, they shall be selected on the basis of air monitoring results, withthe minimum level of respirator as indicated in Table 1 on page 136. Until monitoring resultsare available, the appropriate respirator is determined according to the assumed exposureassociated with the task being performed, as per subsection (d)(2).

Where respirators are used, the employer shall institute a complete, written respiratoryprotection program in accordance with Cal/OSHA’s Respiratory Protection standard, §5144.The program shall outline procedures for selection, use, training, cleaning and sanitizing,storage, inspection, and maintenance of respirators. The program shall be evaluated by regularinspections.

§5144 requires that any respirators used shall be certified by NIOSH. Also, employers shallperform quantitative or qualitative fit testing of respirators at the time of initial fitting, and atleast annually thereafter, for employees wearing tight-fitting facepiece respirators.

If an employee exhibits difficulty breathing with the respirator, the employer shall makeavailable a medical examination to determine whether the employee can wear a respiratorsafely while performing the work.


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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 isworn), or to lead compounds which may cause irritation, the employer shall provide and assurethe employee uses appropriate protective work clothing, such as coveralls or other full-bodywork clothing, gloves, hats, shoes or shoe coverings, and face shields, goggles or otherprotective equipment as needed.

Work clothing shall be provided at least weekly for employees exposed over the PEL, exceptdaily for those exposed at levels higher than 200 µg/m3.

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 containslead, 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 thatdisperses 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 cleaningsurfaces 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 hasbeen tried and found to be ineffective.

Use of compressed air for cleaning is prohibited, unless there is a ventilation system to capturethe 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 handsand face prior to eating, drinking, smoking or applying cosmetics.

The employer shall provide, for ALL employees exposed to lead, adequate hand washingfacilities, and assures (in the absence of shower facilities) that employees wash their hands andface at the end of the work shift.

In areas where employees are exposed to lead above the PEL, the employer shall assure thatfood or beverages are not present or consumed, tobacco products are not present or used andcosmetics are not applied.


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Employees exposed to lead above the PEL shall be provided with clean change areas withseparate storage facilities for work and street clothing, to prevent cross-contamination.

The employer shall assure that employees do not leave the workplace wearing any protectiveclothing or equipment that was worn during the work shift.

Shower facilities, soap and towels shall be provided, where feasible, for employees exposed tolead above the PEL, and the employer shall assure that these employees shower at the end ofthe work shift.

Employees exposed to lead above the PEL shall be provided with a clean lunchroom or eatingarea. The employer shall assure that the lunch area is kept free from lead accumulation and thatemployees do not enter the lunch area with protective work clothing or equipment that has notbeen cleaned by vacuuming or other method that limits dispersion of lead dust.

Employers shall establish regulated areas, where feasible, wherever employees are exposedabove 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 protectiveequipment shall be provided to and worn by employees and other persons who enter theregulated area.

(j) Medical Surveillance

The employer shall assure that the lead medical program (including all medical examinationsand procedures performed) is under the supervision of a licensed physician.

The employee has the right to seek a second medical opinion regarding the lead medicalevaluation, at the expense of the employer, and if necessary a third physician may be requestedto resolve any disagreements between the first two.

Prophylactic chelation, the routine use of chelating drugs to lower blood lead levels in personsoccupationally 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 forany 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 anyconsecutive 12 months, must be enrolled in a medical surveillance program, includingBLL and ZPP at least every 2 months for the first 6 months, and every 6 monthsthereafter.

Any employee with a BLL at or above 40 µg/dl shall have a BLL and ZPP every twomonths until two consecutive samples are less than 40 µg/dl.


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Any employee with a BLL above 50 µg/dl shall receive a follow-up BLL within 2 weeksafter the employer receives the results of the first test.

For those employees temporarily removed from their jobs involving lead exposure (seesubsection (k), Medical Removal Protection), a BLL and ZPP must be provided everymonth 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 resultswithin 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 orabove 40 µg/dl during the preceding 12 months.

A medical exam shall be provided to any employee who reports signs or symptomsrelated to lead poisoning, desires medical advice regarding the effects of lead exposureon the employee’s ability to produce a healthy child, is pregnant, or has difficultybreathing while wearing a respirator.

A medical exam shall be provided as medically appropriate to any employee removedfrom his/her usual job involving exposure to lead.

A medical exam shall include: detailed work history, with particular attention to pastlead exposure; history and physical exam, with particular attention to teeth, gums,hematologic, gastrointestinal, renal, cardiovascular, neurological systems, andpulmonary system if respirators are used; blood pressure measurement; blood sampleand analysis including BLL, ZPP, hemoglobin and hematocrit determinations, red cellindices, examination of peripheral smear morphology, blood urea nitrogen, serumcreatinine; urinalysis with microscopic examination; pregnancy or male fertilityevaluation, if requested by the employee; any other test deemed necessary by thephysician.

(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 orabove 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/herformer 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 orabove the AL on each occasion that a final medical determination results in a medical


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finding, determination, or opinion that the employee has a detected medical conditionwhich places the employee at increased risk of material impairment to health fromexposure to lead.

An employee who has been removed due to a final medical determination can return tohis/her former job when a subsequent medical determination indicates he/she no longerhas a medical condition which places that employee at increased risk of healthimpairment from exposure to lead.

(k)(2) Medical Removal Protection Benefits

As long as the job the employee was removed from continues, the employer shallprovide up to 18 months of MRP benefits on each occasion that an employee is removedfrom exposure to lead.

MRP benefits means the normal earnings, seniority and other employment rights, andbenefits, 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 HazardCommunication 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 compoundsthat cause eye or skin irritation, or who perform any of the specified trigger tasks, the employershall provide initial (pre-placement) training that includes: the content of this standard andappendices; 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 themedical surveillance program, including the adverse health effects of lead exposure (especiallyon reproduction); the engineering controls and work practices relevant to the employee’s jobassignment; the contents of any compliance plan in effect; the location of regulated areas; theprohibition 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 beprovided annually.

(l)(3) Training and Certification for Residential and Public Buildings

All employees and supervisors who are engaged in lead-related construction inresidences or buildings generally accessible to the public, and shown to be exposed tolead at or above the PEL, shall be trained by state-accredited training providers andcertified by the California Department of Health Services (CDHS).

[Call 1-800-597-LEAD for information about accredited training providers and CDHScertification.]


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(m)Signs

In regulated areas (work areas where employee exposure is above the PEL and/or trigger tasksare performed), the employer shall post a warning sign with the words:

WARNING: LEAD WORK AREAPOISON—NO SMOKING OR EATING

(n) Record Keeping

The employer is required to maintain detailed records on exposure assessment, including anyobjective data used for exemption from air monitoring requirements, medical surveillance andmedical removals.

(o) Observation of Monitoring

The employer shall provide affected employees or their designated representatives anopportunity to observe any monitoring of employee lead exposure. Observers shall be providedwith and use protective equipment if required in the area, receive an explanation of the measure-ment 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 symbol meaning “times,” as in 50 x PEL (50 times the PEL).

ppm parts per million—The units used to specify the concentration of lead in a material suchas a paint chip sample. 1% is equivalent to 10,000 ppm.

µg/dl micrograms per deciliter—The units used to specify the amount of lead in a person’sblood sample, i.e., the weight of lead in a deciliter of whole blood.

µg/m3 micrograms per cubic meter—The units used to specify the concentration of lead dust orfume in air. These units are used to express the results of personal air monitoring.

AL Action Level—A concentration of lead in air of 30 µg/m3 averaged over an 8-hour shift.

BLL blood lead level—A measurement of how much lead is in a person’s blood.

HEPA high efficiency particulate air—A type of filter that efficiently captures very smallparticles and is used in respirators, vacuums, and ventilation systems for toxic dusts suchas lead.


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PAPR powered air-purifying respirator—A respirator equipped with a battery-powered blowerwhich draws air through filters and into the facepiece.

PEL Permissible Exposure Limit—A concentration of lead in air of 50 µg/m3 averaged over an8-hour shift.

ZPP zinc protoporphyrin—A blood test that can indicate an effect of lead on the blood-forming system. This test is required whenever a BLL is done, and is analyzed from thesame blood sample.

Table 1Respiratory Protection for Lead Aerosols

Airborne Lead Concentration Required Respirator

Lowest exposure Not > 500 µg/m3 (up to 10 x PEL) half-mask air purifying with high efficiencytrigger tasks, or (P-100) filters, or half-mask supplied air in

negative pressure mode

Not > 1,250 µg/m3 (up to 25 x PEL) loose-fitting or helmet PAPR* with highefficiency (P-100) filters, or supplied air incontinuous-supply mode

Medium exposure Not > 2,500 µg/m3 (up to 50 x PEL) full facepiece air purifying with hightrigger tasks, or efficiency (P-100) filters, or tight fitting powered

air purifying respirator with high efficiency(P-100) filters, or full facepiece supplied air indemand mode, or half-mask supplied air incontinuous-flow mode, or SCBA** in demandmode

Highest exposure Not > 50,000 µg/m3 (up to 1,000 x PEL) half-mask supplied air in positive-pressure modetrigger tasks, or

Not > 100,000 µg/m3 (up to 2,000 x PEL) full facepiece supplied air in positive-pressuremode

> 100,000 µg/m3 (> 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 PoisoningPrevention Program/California Department of Health Services

A P P E N D I X C — C A L / O S H A H A Z C O M

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◆CCal/OSHA Hazard Communication Standard

—Summary

Cal/OSHA’s Hazard Communication (HAZCOM) standard is found in Title 8 of the California Code ofRegulations, General Industry Safety Orders, section 5194. It provides workers with the right toinformation about hazardous chemicals and other hazardous materials used in the workplace. EachCalifornia employer must establish a written Hazard Communication Program which includes:

◆ A detailed list of all hazardous substances in the workplace. (Materials that contain lead, suchas paints and coatings, are included.)

◆ A description of the labeling system used for hazardous substances. Labels must include thename of the hazardous substance, warnings about its health effects and other hazards, and thename and address of the manufacturer, importer, or other responsible party.

◆ Training about each hazardous substance an employee may be exposed to on the job. Suchtraining must be provided at the time of initial assignment and whenever a new substance isintroduced in the workplace. Training must include information on the health effects and otherhazards of the substance, the methods used to detect its presence or release, and appropriateprotective measures including appropriate work practices, emergency procedures, and personalprotective equipment.

◆ MSDSs (Materials Safety Data Sheets) for all hazardous materials on site. These sheets areprovided by the manufacturer and must be made readily accessible to every employee. MSDSsmust 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 takesamples and have them analyzed by a laboratory, or assume that the substance is hazardous andact accordingly.

Both employers and employees benefit from a written Hazard Communication Program in theworkplace. Employers can use the information to design engineering controls, substitute lesshazardous chemicals, and selects appropriate personal protective equipment for workers.


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A P P E N D I X D — C A L / O S H A I I P P

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◆DCal/OSHA Injury and IllnessPrevention Program Standard

—Summary

Cal/OSHA’s Injury and Illness Prevention Program (IIPP) standard is found in Title 8 of the CaliforniaCode of Regulations, sections 1509 and 3203. It requires every California employer to establish,implement, and maintain an effective Injury and Illness Prevention Program (IIPP) to promote healthand 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) withthe authority and responsibility for carrying out the program must be identified and givenmanagement’s full support.

◆ Safety communication system. Employers should communicate with employees about healthand safety issues in a language they can understand, and in a manner that does not depend onliteracy skills. Communication systems may include safety meetings, written materials, jointlabor-management health and safety committees, and/or other communication methods.

◆ Hazard assessment and control. There must be specific procedures for identifying andevaluating hazards, including periodic inspections of the workplace. Employees should beencouraged to participate in inspections without fear of reprisal. Hazards should be corrected assoon 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 andillnesses. Written documentation should be maintained indicating why each accident or nearmiss” occurred, and what actions can be taken to preclude recurrence.

◆ Safety planning, rules, and work procedures. There must be a means for ensuring that thesafety rules and procedures established for the workplace are followed.

◆ Training. At a minimum, training and instruction should be provided to all employees whenthe IIPP is established, and thereafter to all new employees, to all employees with a new jobassignment, 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 aneffective program in place. These records should include scheduled inspections, actions taken tocorrect problems, and types, dates, and providers of training.


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A P P E N D I X E — L S S P A

141

◆ELead-Safe Schools Protection Act

The Lead-Safe Schools Protection Act is found in the California Education Code,sections 32240-32245. Following is the complete text.

§ 32240

This article shall be known, and may be cited, as the “Lead-Safe Schools Protection Act.”

§ 32241

(a) The State Department of Health Services shall conduct a sample survey of schools in thisstate for the purpose of developing risk factors to predict lead contamination in publicschools. The survey shall include schools that are representative of the state bygeographical region and size of enrollment. The schools to be surveyed shall be selected onthe basis of their ability to provide data necessary to make scientifically valid estimates ofthe 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 oraround the facility, numbers of children enrolled under the age of six, and results of leadscreening programs established pursuant to Chapter 5 (commencing with Section 105275)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” meanpreschools and day care facilities, respectively, located on public school property.

§ 32242

The department shall do all of the following:

(a) Design and implement a strategy for identifying the characteristics of high-risk schools andprovide a basis for statewide estimates of the presence of lead in schools attended by youngchildren.

(b) Conduct a sample survey, as described in Section 32241, to determine the likely extent anddistribution of lead exposure to children from paint on the school, soil in play areas at theschool, drinking water at the tap, and other potential sources identified by the departmentfor this purpose. To the maximum extent possible, limited sample testing shall be used tovalidate survey results. The department shall compile and summarize the results of thatsurvey 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 theprincipal of the school or director of the schoolsite of the survey results. Within 45 days of


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receiving the survey results, the principal or director, as the case may be, shall notify theteachers and other school personnel and parents of the survey results.

(d) Make recommendations to the Legislature and the State Department of Education, based onthe survey results and consideration of appropriate federal and state standards, on thefeasibility and necessity of conducting statewide lead testing and any additional actionneeded relating to lead contamination in the schools.

(e) As deemed necessary and appropriate in view of the survey results, develop environmentallead testing methods and standards to ensure the scientific integrity of results, for use byschools 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 fordistribution to requesting schools to ensure that lead hazards are minimized in the course ofschool repair and maintenance programs and abatement procedures.

§ 32243

(a) When a school subject to this article has been determined to have significant risk factors forlead, the school shall be advised of this finding, and the school shall notify parents of theprovisions of the Childhood Lead Poisoning Prevention Act of 1991 (pursuant to Chapter 5(commencing with Section 105275) of Part 5 of Division 103 of the Health and SafetyCode). Within 45 days of receiving this finding, the school principal or the director of theschoolsite 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 forenvironmental lead testing and abatement, any school that undertakes any action to abateexisting risk factors for lead shall utilize trained and state certified contractors, inspectors,and workers.

§ 32244

Lead-based paint, lead plumbing and solders, or other potential sources of lead contaminationshall not be utilized in the construction of any new school facility or the modernization orrenovation of any existing school facility.

§ 32245

Funding to implement this article shall be provided for the Child Health and Safety Fundcreated under Chapter 4.6 (commencing with Section 18285) of Part 6 of Division 9 of theWelfare and Institutions Code, upon appropriation by the Legislature pursuant to Section 18285of the Welfare and Institutions Code.

A P P E N D I X F — T I T L E 1 7

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◆FTitle 17, California Code of Regulations

—Summary

Title 17, Division 1, Chapter 8, “Accreditation, Certification, and Work Practices for Lead-Based PaintAnd Lead Hazards,” is the key regulation for lead work in California. This summary of its majorprovisions is based on the revision dated January 8, 1999. The regulation is jointly enforced by theDepartment 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 thisGuide. This summary emphasizes work practice requirements. To read the complete text of theregulation, check the Department of Health Services’ Childhood Lead Poisoning Prevention Program’swebsite at www.childlead.com.

Article 1

Definitions

This Article provides definitions for terms used throughout the regulation. Key terms includeabatement, accreditation, clearance inspection, containment, deteriorated lead-based paint, lead-contaminated dust, lead-contaminated soil, lead hazard, lead hazard evaluation, and presumed lead-based 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 becomeapproved training providers. It gives the minimum qualifications for instructors and requirementsfor 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 requiredtraining methods for each type of course that training providers may offer. The courses describedinclude: Core Instruction, Lead-Related Construction Inspection and Assessment, Lead-RelatedConstruction Supervision and Project Monitoring, Lead-Related Construction Project Design,Lead-Related Construction Work, Lead-Related Construction Supplemental Supervision andProject Monitoring, Lead-Related Construction Certified Industrial Hygienist, and ContinuingEducation.


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Article 11

Application Requirements and Procedures for Training Provider Accreditation, Renewal, orCourse Approval

This Article provides information about the forms and documents required for making applicationto the Department of Health Services for accreditation as a training provider, renewal ofaccreditation, and approval of specific courses.

Article 12

Suspension or Revocation of Accreditation, Provisional Accreditation, or DHS CourseApproval

This Article describes the process for revoking a training provider’s accreditation or courseapproval.

Article 13

Eligibility Requirements and Application Procedures for Certification or Interim Certification

This Article lists the minimum qualifications for becoming a certified Lead Worker, LeadSupervisor, Lead Project Monitor, Lead Project Designer, and Lead Inspector/Assessor. Theapplication process is discussed as well as the educational level, specific training, experience, andtests 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 certifiedindividual.

Article 15

Enforcement

This Article describes the amount of money allocated to the Division of Occupational Safety andHealth annually for costs of enforcing compliance with the training and certification requirementsof Title 17.


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Article 16

Work Practice Standards

This Article sets out the requirements that must be followed when evaluating and abating leadhazards in public and residential buildings (including schools). It incorporates the requirements setout 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.

§ 36000

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 samestructure.

(2) Be conducted in a manner in which paint, dust, and soil samples are tested inaccordance with the procedures described in the HUD Guidelines.

(3) Be conducted in a manner in which paint, dust, and soil samples taken for laboratoryanalysis are analyzed by a laboratory that is recognized by the U.S. EnvironmentalProtection Agency pursuant to United States Code, Title 15, Section 2685(b).

(4) Be documented in a lead hazard evaluation report which shall include a completedDepartment of Health Services (DHS) Form 8552 (12/97) and the followingattachments: a foundation diagram, site map, or sketch of the structure, indicating thespecific locations of each lead hazard or presence of lead-based paint, and results of thevisual inspection, if applicable; a summary of each testing method, device, andsampling procedure used; a description of testing and sampling locations; and theresults 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 orresidential building shall retain the original completed copy of DHS Form 8552 (12/97) andattachments for a minimum of three years and distribute copies as follows: a copy of thecompleted DHS Form 8552 (12/97) and attachments to the person who ordered the leadhazard evaluation; a copy of the completed DHS Form 8552 (12/97) to DHS within thirtydays 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 theHUD Guidelines (as revised in 1997).


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(2) A risk assessment shall be conducted in accordance with procedures described in theHUD Guidelines and shall include a written description of abatement options for eachidentified lead hazard, a suggested prioritization for addressing each lead hazard, andrecommendations for a maintenance and monitoring schedule.

(3) A clearance inspection shall be conducted by a certified lead inspector/assessor or acertified lead project monitor and in accordance with the procedures described in theHUD Guidelines.

§ 36100

Abatement for Public and Residential Buildings

(a) Abatement for public and residential buildings which is designed to reduce lead paint orlead 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 supervisorshall be onsite during all work site preparation and during the post-abatement cleanupof work areas. At all other times when abatement is conducted, the certified leadsupervisor shall be onsite or available by telephone, pager or answering service, andable 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-workareas 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, certifiedlead 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 preventexposure to lead hazards;

2. A detailed written description of abatement, including methods of abatement andlocations 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 threeyears by the preparer.


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(5) After notification is posted and delivered pursuant to subsection (c). The certified leadsupervisor conducting abatement shall retain records of notification for at least threeyears.

(6) In a manner in which after abatement is completed, a clearance inspection is conductedin accordance with Sections 36000(a) and 36000 (c)(3) of Title 17.

(b) Abatement for public and residential buildings which is designed to reduce lead paint orlead 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-workareas 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 thecompletion of abatement.

(4) In a manner to ensure that a clearance inspection is conducted following the completionof abatement, if abatement was conducted in response to an identified case of leadpoisoning as defined in Section 105280(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 providenotification 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 notbe removed until abatement has been completed and, for abatement conducted pursuantto subsection (a), a clearance inspection has been completed; and

(2) Delivering a copy of the completed form to DHS. Except for abatement conducted inresponse to an identified case of lead poisoning as defined in Section 105280(b) of theHealth and Safety Code, the completed form shall be delivered to DHS at least five daysprior to conducting abatement.

(d) Any individual conducting abatement or disturbing lead-based paint without containmentshall permit the Department, or enforcement agencies, as specified in the California Healthand Safety Code Sections 17960, 17961, and 17965, to access work areas to determinecompliance with the requirements of this section.


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◆GContractor Requirements forHigh Risk Lead Tasks

All high risk lead tasks performed on school district property must be doneby trained and state-certified workers. This policy should apply both to the schooldistrict’s own personnel and to outside contractors.

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 ExposureLimit (PEL) of 50 µg/m3, or

◆ Is considered to be lead abatement work that is designed to reduce a lead hazard for a minimumof 20 years.

If an outside contractor is hired to perform abatement work or other high risk lead tasks, the followingelements should be incorporated into any written contract.

A. License

The Contractor shall have a valid California State Contractors License in the classificationappropriate to the work.

B. Worker Certification

1. All high risk lead tasks and lead abatement work shall be under the supervision of a CertifiedLead Supervisor with a current DHS certificate. This individual shall have direct control of alltasks, ensure that work is conducted in a lead-safe manner without producing lead hazards, andbe responsible for enforcing safe work practices that comply with Cal/OSHA and other staterequirements. The Certified Lead Supervisor shall be on site during all preparation and cleanupof work areas. At all other times when lead-related activities are underway, the Certified LeadSupervisor shall be on site or available by telephone, pager, or answering service, and shall beable 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 minimumof 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-certifiedsupervisors and workers for any task that disturbs or may disturb lead-based paint, presumedlead-based paint, or lead-contaminated soil, as defined by Title 17 of the California Code ofRegulations, Division 1, Chapter 8. Certain tasks may not require state-certified supervisorsand workers. In any event, the Contractor shall be responsible for ensuring worker safety andCal/OSHA compliance.


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C. Insurance

In addition to any insurance requirements stated elsewhere in the Job Specifications or othercontract documents, the Contractor shall provide the District with evidence of insurance coveragefor 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 damageper 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 wastetransporter, except as allowed under small-quantity transportation rules. Hazardous waste shall bedisposed 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 asan additional insured.

4. A schedule, if required by the Scope of Work or the School District Representative. Submitthree days before starting work. Include specific dates for the beginning and ending of eachphase of the work and dates for testing. The schedule shall be updated weekly.

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5. A copy of the completed DHS Form 8551, “Abatement of Lead Hazards Notification.” The formmust 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 applicableregulation.

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.”


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◆HGuidelines for Volunteers

A letter similar to the model below can be provided to parents and communityvolunteers who wish to assist schools with painting and related projects.The letter is intended to inform volunteers about district guidelines regardinglead paint.

To: Parent and Community Volunteers

The Lead-Safe Schools Protection Act of 1992 requires California public elementary schoolsand childcare facilities to use specially trained personnel when carrying out activities thatdisturb lead-based paint. Such activities include removal (scraping or sanding) of paint, oralteration of painted surfaces. Complying with the Act can help schools protect children andstaff from serious health damage.

Lead poisoning can affect a child’s growth and mental development. Adults may experiencekidney, nervous system, blood, and reproductive disorders. Lead can get into the body bybreathing (inhaling) or swallowing (ingesting) lead dust, particles, or chips. These may be onsurfaces or in air, water, or soil.

The primary source of lead in schools is older paint. Lead hazards can be controlled byfollowing 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 thedistrict’s trained Maintenance and Operations staff.

All paint used must have the prior approval of the District’s Maintenance and Operationsdepartment. District-approved paint is “lead-free” and meets or exceeds the Consumer ProductSafety Commission’s current standard. Note that industrial paints and marine paints can behazardous and shall not be used.

Please contact the District’s Maintenance and Operations department if you have any questions.

Sincerely,

Maintenance and Operations Manager


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◆IResources for More Information

Federal Government Agencies

Centers for Disease Control & Prevention (CDC)

CDC Headquarters1600 Clifton Road NEAtlanta, GA 30333

(404) 639-3311 (Operator)(800) 311-3435 (Public Inquiry)(888) 232-6789 (Healthline)Web www.cdc.gov

An agency of the Department of Health and Human Services whose mission is to promotehealth and quality of life by preventing and controlling disease, injury, and disability.

CDC Childhood Lead Poisoning Prevention Program4770 Buford Highway NE, MS F-42Atlanta, GA 30341

(770) 488-7330Web www.cdc.gov/nceh/programs/lead/lead.htm

Develops programs and policies to prevent childhood lead poisoning, educates the public andhealth care providers, provides funding to state and local health departments, and supportsresearch 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-29Atlanta, GA 30341

(888) 232-6789Web www.cdc.gov/nceh/ncehhome.htm

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 NEAtlanta, GA 30333

(888) 422-8737Web www.atsdr.cdc.gov


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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 Control451 7th Street SW, Room P-3206Washington, D.C. 20410

(202) 755-1785 (National Office)(415) 436-6532 (San Francisco Office)Web www.hud.gov

Advises all HUD program offices and field offices on lead poisoning prevention. Committed toproviding lead-safe housing to the nation’s children while preserving affordable housing.

Environmental Protection Agency (EPA)

EPA National Lead Information Center8601 Georgia Avenue, Suite 503Silver Spring, MD 20910

(800) 424-LEADWeb www.epa.gov/lead/nlic.htm

NLIC is funded by the EPA to maintain a Lead Educational Materials Database which they cansearch in response to a caller’s needs. They provide information to help parents protect theirchildren from poisoning in the home, and can furnish a list of state and local contacts. Writtenmaterials and recordings are available in English and Spanish.

EPA Office of Pollution Prevention and Toxics—Lead Programs

Web www.epa.gov/opptintr/lead

Responds to inquiries about lead and lead-based paint. Has information and materials inEnglish and Spanish. Also involved in regulating training and certification programs.

EPA Safe Drinking Water Hotline

(800) 426-4791Web www.epa.gov/safewater/

Provides educational materials, explanation of lab analysis results, and other information aboutcontaminants in drinking water, including lead.


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Food and Drug Administration (FDA)

FDA California Office1431 Harbor Bay ParkwayAlameda, CA 94502

(510) 337-6700Web www.fda.gov

Regulates food, drugs, cosmetics, and medical devices. Also regulates, investigates, andsamples dinnerware, pottery, etc. for metals content such as lead.

California State Agencies

Cal/OSHA (Division of Occupational Safety and Health)

Cal/OSHA Compliance—Headquarters455 Golden Gate Ave., 10th FloorSan Francisco, CA 94102

(415) 703-5100Web www.dir.ca.gov/occupational_safety.html

Investigates worksite fatalities, serious injuries or illnesses, and complaints about workplacehazards. Also conducts scheduled inspections of high-risk workplaces.

Cal/OSHA Compliance—District Offices

Anaheim ..................................... (714) 939-8611Concord ...................................... (925) 602-6517Fresno ......................................... (209) 445-5302Foster City/San Mateo ............... (650) 573-3812Los Angeles ................................ (213) 576-7451Oakland....................................... (510) 622-2916Pico Rivera ................................. (562) 949-7827Redding....................................... (530) 224-4743Sacramento ................................. (916) 263-2800San Bernardino ........................... (909) 383-4321San Diego ................................... (858) 637-5534San Francisco ............................. (415) 703-5210San Jose ...................................... (408) 452-7288Santa Rosa .................................. (707) 576-2388Torrance ...................................... (310) 516-3734


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Van Nuys..................................... (818) 901-5403Ventura........................................ (805) 654-4581West Covina................................ (626) 966-1166

Cal/OSHA Consultation Service—Headquarters455 Golden Gate Avenue, 10th FloorSan Francisco, CA 94102

(415) 703-5270(800) 963-9424

Provides free services to employers, including on-site evaluation of health and safetyconditions in the workplace, training, publications, and information.

Cal/OSHA Consultation Service—Area Offices

Oakland....................................... (510) 622-2891Sacramento ................................. (916) 263-0704San Diego ................................... (858) 467-4048Van Nuys/San Fernando Valley .. (818) 901-5754

Department of Education

California Department of EducationSchool Facilities Planning Division660 J Street #350Sacramento, CA 95814

(916) 445-2144

Assists school districts and their communities in creating well-planned K-12 learningenvironments in safe, clean, and up-to-date schools.

Department of Health Services

Childhood Lead Poisoning Prevention Branch (CLPPB)1515 Clay Street, Suite 1801Oakland, CA 94612

(510) 622-5000 (General Information)(800) 597-5323 (Hotline)Web www.childlead.com

Helps eliminate childhood lead poisoning by identifying and caring for lead burdened children,and preventing environmental exposures to lead.


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Division of Drinking Water and Environmental Management (DDWEM)Drinking Water ProgramPO Box 942732Sacramento, CA 94234-7320

(916) 323-6111Web www.dhs.ca.gov/ps/ddwem

Assures protection of the public through the regulation and monitoring of public water systems.

Occupational Lead Poisoning Prevention Program (OLPPP)1515 Clay Street, Suite 1901Oakland, CA 94612

(510) 622-4300 (Information)(510) 622-4328 (Free Publications)Web www.ohb.org/olppp.htm

Provides information and services designed to prevent and control lead poisoning in Californiaworkplaces. Activities directed towards workers, unions, employers, industry groups, healthprofessionals and the general public.

Environmental Protection Agency (Cal/EPA)

Cal/EPA Department of Toxic Substances Control400 P Street, PO Box 806Sacramento, CA 95812

(916) 324-1826 (General Information(916) 322-7676 (Hazardous Waste)Web www.dtsc.ca.gov

Protects public health and the environment by regulating hazardous waste and enforcingpollution prevention laws.

Cal/EPA Office of Environmental Health Hazard Assessment (OEHHA)310 Capitol Mall #205Sacramento, CA 95814

(916) 324-7572Web www.oehha.ca.gov

Regulates lead exposure under California’s Proposition 65.


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Local Government Agencies

California Childhood Lead Poisoning Prevention Programs

City and County Offices

Many city and county lead programs provide information on testing children for lead, generallead information, and lead poisoning prevention services.

Alameda County ......................... (510) 567-8282Alpine County ............................ (530) 694-2146Amador County .......................... (209) 223-6407Berkeley (City) ........................... (510) 644-6500Butte County............................... (530) 538-7831Calaveras County ....................... (209) 754-6460Colusa County ............................ (530) 458-0380Contra Costa County .................. (925) 313-6217 or (510) 374-3184Del Norte County ....................... (707) 464-7227El Dorado County ....................... (530) 621-6109Fresno County ............................ (559) 445-3330Glenn County.............................. (530) 934-6588Humboldt County ....................... (707) 445-6200Imperial County ......................... (760) 339-4451Inyo County ................................ (760) 878-0231Kern County ............................... (661) 868-0360Kings County .............................. (559) 584-1401, ext 2619Lake County ............................... (707) 263-2241Lassen County ............................ (530) 251-8183Long Beach (City) ...................... (562) 570-4208Los Angeles County ................... (213) 738-2209Madera County ........................... (559) 675-7893Marin County ............................. (415) 499-3254Mariposa County ........................ (209) 966-3689Mendocino County ..................... (707) 463-4134Merced County ........................... (209) 381-1113Modoc County ............................ (530) 233-6311Mono County .............................. (760) 924-5410Monterey County........................ (831) 755-4611Napa County ............................... (707) 253-4807Nevada County ........................... (530) 265-1228Orange County............................ (714) 834-7979Pasadena (City) .......................... (626) 744-6128Placer County ............................. (530) 889-7141


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Plumas County ........................... (530) 283-6346Riverside County ........................ (909) 358-5424Sacramento County .................... (916) 875-0859San Benito County...................... (831) 637-5367San Bernardino County .............. (909) 387-6212San Diego County....................... (619) 515-6656San Francisco (City & County) .... (415) 554-8930San Joaquin County .................... (209) 468-3824San Luis Obispo County............. (805) 781-5502San Mateo County ...................... (650) 573-2877Santa Barbara County................. (805) 681-5117Santa Clara County..................... (408) 299-5850Santa Cruz County...................... (831) 763-8937Shasta County ............................. (530) 225-5176Sierra County.............................. (530) 993-6700Siskiyou County ......................... (530) 841-4040Solano County ............................ (707) 553-5402Sonoma County .......................... (707) 565-6580Stanislaus County ....................... (209) 558-8858Sutter County.............................. (530) 822-7215Tehama County........................... (530) 527-6824Trinity County ............................ (530) 623-1358Tulare County ............................. (559) 733-6123Tuolumne County ....................... (209) 533-7403Ventura County ........................... (805) 652-6159Yolo County ................................ (530) 666-8645 or (916) 375-6380Yuba County ............................... (530) 741-6366

Regional and Statewide Organizations

University Programs

Labor Occupational Health Program (LOHP)Lead-Safe Schools ProjectUniversity of California, Berkeley2223 Fulton St., 4th FloorBerkeley, CA 94720-5120

(510) 642-5507Web socrates.berkeley.edu/~lohp

Produces materials and presents training programs for school personnel on lead safety inCalifornia schools. LOHP also has information on many other workplace safety and health issues.


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UCLA Labor Occupational Safety and Health Program6350 B Public Policy BuildingPO Box 951478Los Angeles, CA 90095-1478

(310) 794-5964Web www.sppsr.ucla.edu/res_ctrs/iir/losh

Provides training, publications and technical assistance on occupational health and safetyissues in Southern California.

Other Programs

California Child Care Health Program1322 Webster Street, Suite 402Oakland, CA 94612-3218

(510) 839-1195 (General Information)(800) 333-3212 (Healthline)Web www.childcarehealth.org

Links the childcare and health communities to promote quality childcare in California vialegislation, advocacy, technical assistance, training, and materials development. Developed alead poisoning training curriculum for childcare providers. Also administers childcare leadpoisoning and anemia prevention projects in three counties—Los Angeles, Humboldt, andKern.

California Communities Against ToxicsPO Box 845Rosamond, CA 93560

(661) 256-0968

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 #506 605 West Olympic Boulevard #850San Francisco, CA 94105 Los Angeles, CA 90015

(415) 243-8373 (213) 486-5114Web www.cbela.org

A community-based state wide organization that promotes clean air and water, and advocatesfor toxic free communities


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Occupational and Environmental Health Clinics

California Clinics

Many doctors do not have experience in treating patients with lead poisoning or other work-related health problems. To consult with experts in lead-related health effects and otheroccupational and environmental health problems, contact the following clinics.

Drew University of Medicine and Science, Los Angeles ...................... (800) 351-5323University of California, Davis (Sacramento) ....................................... (530) 752-8051University of California, Irvine ............................................................. (949) 824-8641University of California, Los Angeles ................................................... (310) 794-8144University of California, San Diego ...................................................... (619) 294-6206University of California, San Francisco ................................................ (415) 206-4320

Nationwide Clinics

Association of Occupational and Environmental Clinics1010 Vermont Avenue NW, Suite 513Washington, DC 20005

(202) 317-4976Web giligan.mc.duke.edu/oem/aoec.htm

Has a complete list of affiliated occupational and environmental health clinics nationwide.


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Glossary of Terms

Abatement. See Lead Abatement.

Accreditation. Under Title 17, refers to a training provider obtaining state approval to offercourses that workers must take to become lead-certified.

Action Level (AL). According to Cal/OSHA’s Lead in Construction standard, this is aconcentration of 30 micrograms of lead per cubic meter of air (µg/m3), averaged over an8-hour workday. Employees exposed to lead at or above the Action Level but below thePermissible Exposure Level (PEL) must be trained annually in the hazards of lead and mustbe included in a Medical Surveillance Program. There are other required health and safetymeasures for these employees also. See Appendix B.

Air Purifying Respirator (APR). A type of respirator that uses filters to reduce the amountof dust, fumes, or vapors that workers inhale. APRs require the wearer to draw air throughthe filters when inhaling.

Air Quality Management District (AQMD). One of several regional agencies that issue andenforce local air pollution regulations in California.

Air Resources Board (ARB). California’s state agency that oversees enforcement of airpollution regulations.

Air Sampling. See Personal Air Sampling.

Air Supplied Respirator (ASR). A type of respirator that supplies clean air. This may befrom an air compressor and hose or from a tank on the worker’s back (SCBA). (See Self-Contained Breathing Apparatus.)

Biological Monitoring. Required by Cal/OSHA for workers exposed to lead. Includes testsfor Blood Lead Level (BLL), which measures the amount of lead in the blood, and ZincProtoporphyrin (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 alsomay be high if the person has a large amount of lead stored in the body.

◆b

◆a ◆J


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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 filterwithin the breathing zone (around the collar), attached to a pump which operates while theperson is working.

Cal/EPA. California Environmental Protection Agency, the state agency responsible forissuing and enforcing environmental regulations. These include regulations on air and waterpollution and hazardous waste.

Cal/OSHA. The Division of Occupational Safety and Health within the CaliforniaDepartment of Industrial Relations. The state agency that issues and enforces regulations toprotect worker health and safety.

Cal/OSHA Consultation Service. A program of Cal/OSHA that provides free, voluntaryassistance to employers to help evaluate and correct health and safety hazards in theworkplace.

California Department of Health Services (DHS). The state government public healthdepartment.

Centers for Disease Control and Prevention (CDC). The federal public health agencythat oversees the National Institute for Occupational Safety and Health (NIOSH). CDC alsoprovides guidance on the management of childhood lead poisoning cases.

Certification. Under Title 17, the process by which a worker obtains a state certificate to dolead work. Only certified workers and supervisors may do high risk lead jobs. There are fivelevels of certification, each with different training and experience requirements.

Chelation. A medical treatment for severe lead poisoning. Can be dangerous. Prophylacticchelation of lead poisoned workers is prohibited by Cal/OSHA regulations.

Childhood Lead Poisoning Prevention Branch (CLPPB). A program within DHS thatdoes training and research designed to protect children from lead poisoning. Also accreditslead training programs and certifies contractors.

Clearance Inspection. An on-site investigation to determine if lead work has been doneas specified, and if the work area is safe to enter. Does not include sampling to ensureCal/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 workarea. One common step is using “poly” (plastic sheeting).

◆c


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◆d

◆e

Department of Toxic Substances Control (DTSC). A program within the Cal/EPA that isresponsible for issuing and enforcing hazardous waste regulations.

Deteriorated Lead-Based Paint. Defined by Title 17 as lead-based paint or surface coatingthat is cracking, chalking, flaking, chipping, peeling, non-intact, failed, or otherwiseseparating from a component.

DHS. See California Department of Health Services.

Engineering Controls. Changes that can be made in the work environment to reducehazards on the job, such as ventilation or special ventilated tools. Cal /OSHA requiresemployers to use all possible engineering controls to reduce lead exposure that is higherthan the PEL.

EPA. Environmental Protection Agency, the federal agency responsible for protecting thepublic from the effects of toxic substances in the environment.

Fit Check. Also called a User Seal Check. Tests that should be done by individual workersevery time they put a respirator on to make sure it seals to the face properly. There areseveral types of fit checks (positive and negative pressure) described in Cal/OSHA’sRespiratory Protection standard.

Fit Test. Testing that should be done every six months by the employer to ensure thatrespirators continue to fit properly. In qualitative fit tests, a chemical that is irritating orhas an odor is introduced in the air around the respirator wearer’s head. If the wearer detectsthe chemical through the respirator, the respirator does not fit well enough to protect theworker. A quantitative fit test can be done if the respirator is of a special type. Theserespirators have the ability to detect a chemical inside themselves (or detect a difference indust levels between inside and outside). Procedures for fit testing are described in theCal/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 hightemperatures. Fumes are very easily breathed deep into the lungs.

◆f


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Hazard Communication (HAZCOM). A Cal/OSHA standard that requires employers toprovide information and regular training to workers about hazardous substances in theirworkplace. (Title 8, California Code of Regulations, Section 5194.)

Hazardous Waste. Any waste that is defined as dangerous to people or the environment byfederal or state laws. There are specific federal, state, and local regulations governing theproper 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 offilter 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 orfumes such as lead.

HUD. The U.S. Department of Housing and Urban Development, the federal agency responsiblefor federally financed housing. Assists in enforcing certain federal lead regulations.California’s Title 17 incorporates many regulations found in HUD’s “Guidelines for theEvaluation and Control of Lead-Based Paint Hazards in Housing,” June 1995.

Injury and Illness Prevention Program (IIPP). A Cal/OSHA standard that requires everyemployer 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 mustinvolve 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 eliminatelead hazards or lead-based paint in public or residential buildings. Does not includecontainment or cleaning. Title 17 requires the use of certified workers and supervisors forabatement 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 anamount of lead equal to, or in excess of, one milligram per square centimeter (1 mg/cm2);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 leadequal to, or in excess of, 50 micrograms per square foot (50 µg/ft2) for interior floorsurfaces, 250 µg/ft2 for interior horizontal window surfaces, and 800 µg/ft2 for exteriorfloors and exterior horizontal window surfaces.

◆l

◆i

◆h


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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 withoutcontainment, or any other nuisance which may result in persistent or quantifiable leadexposure.

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, andclearance inspection, for public and residential buildings. Does not include activitiesintended to determine adequacy of containment or compliance with regulatoryrequirements.

Lead in Construction Standard. A Cal/OSHA standard that spells out protective measuresthat employers must use to protect workers exposed to lead during construction work.(Title 8, California Code of Regulations, Section 1532.1.)

Lead-Safe Schools Protection Act (LSSPA). Bans lead paint, plumbing, and other sourcesof lead exposure in new schools, and requires use of certified personnel for school leadabatement. (Sections 32240–32245 of the California Education Code.)

Lead Stick. See Sodium Rhodizonate.

Lockout/Tagout. Defined procedures for shutting down systems or equipment capable ofmovement (such as a heating or ventilation systems) so they cannot be accidentallyrestarted. (Title 8, California Code of Regulations, Section 3314.)

Material Safety Data Sheet (MSDS). A factsheet provided by manufacturers or suppliersabout the hazards of chemical products used in the workplace. According to Cal/OSHA’sHazard Communication standard, employers must make MSDSs available to workers onrequest.

Medical Removal Protection (MRP). A requirement of Cal/OSHA’s Lead in Constructionstandard. Employers must temporarily remove workers from lead exposure at or above theAction Level if they have a BLL of 50 µg/dl or higher on two consecutive tests, or whenrecommended by a doctor for health reasons. Workers on MRP may be given work in lead-free areas. They must be paid their usual wages as long as their original job exists, or for upto 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 anemployer must make available to exposed workers under the Lead in Construction standard.

Methylene Chloride. A chemical sometimes used in paint strippers. Never use methylenechloride strippers because they can cause cancer and other serious health damage.

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Mil. One thousandth (1/1,000) of an inch. Poly sheeting used for containment on lead jobsmust be at least 4 mil.

NIOSH. The National Institute for Occupational Safety and Health. An agency within CDC thatconducts research and education on worker health and safety.

NLLAP. National Lead Laboratory Accreditation Program.

Occupational Lead Poisoning Prevention Program (OLPPP). A program within DHSthat 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 andsafety nationwide. Its state counterpart in California is Cal/OSHA, some of whose standardsare stricter and supersede federal OSHA standards.

Paint Chip Sampling. Testing done by an accredited laboratory to measure the amount oflead in a paint chip sample that was removed from a surface.

Permissible Exposure Limit (PEL). According to Cal/OSHA’s Lead in Constructionstandard, 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/m3).

Personal Air Sampling. Tests done to measure the amount of lead in the air a workerbreathes on the job. Sometimes called “air monitoring.” (See Breathing Zone.)

Poly. Polyethylene plastic sheeting, used to protect surfaces during lead work. Must be at least4 mil thick.

Power Tool Cleaning. The use of power tools (such as grinders, sanders, brushes, and needleguns) to remove dirt or paint from surfaces.

Powered Air Purifying Respirator (PAPR). A respirator equipped with a battery-poweredblower 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 toa component in or on a structure (except on residences built on or after January 1, 1979, oron schools built on or after January 1, 1993).

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Resource Conservation and Recovery Act (RCRA). A federal law which regulateshazardous 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 thesubstances. It may be half-mask or full-face. An air supplied respirator provides a separatesource of clean air from a hose or tank. Respirators must be NIOSH-approved. (See AirPurifying Respirator and Air Supplied Respirator.)

Respiratory Protection Program. A program required by Cal/OSHA. Employersmust 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 ofthese requirements. (Title 8, California Code of Regulations, Sections 1531 and 5144.)

Self Contained Breathing Apparatus (SCBA). A type of Air Supplied Respirator. Suppliesair 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 certainamounts. It is used in color-indicating tests like “lead sticks.”

Supplied Air Respirator (SAR). See Air Supplied Respirator.

Take-Home Lead. Lead that is brought home from the job on a worker’s clothing, shoes, orbody. 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 requiresaccreditation of training providers by DHS. Workers who perform high risk lead work orabatement work designed to reduce lead hazards for a minimum of 20 years must be trainedin accredited programs and be certified by DHS. Title 17 also specifies work practicesrequired for lead jobs. (Section 35001 et seq of the California Code of Regulations.)

Total Threshold Limit Concentration (TTLC) Test. A test to measure the amount of leadin a waste sample, which is one step in determining whether the waste should be classifiedand 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.

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Trigger Task. Any of the specific lead tasks listed as high risk in Cal/OSHA’s Lead inConstruction standard. These tasks almost always expose workers to lead above the PELand 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 ofcleaning. It binds well to lead and was added to water for cleaning up lead dust. It can causeeye irritation and environmental damage, and has been banned by some states and allfederal projects. Other cleaning agents are available.

TWA. Time-weighted average, a way of expressing the amount of chemical exposure to aworker by averaging the exposure over a period of time. For example, an eight-hour TWAaverages exposure over an eight-hour workday.

User Seal Check. See Fit Check.

Waste Extraction Test (WET). A test to measure the concentration of soluble lead in a wastesample, which is one step in determining whether the waste should be classified anddisposed of as “hazardous waste.”

Wipe Sampling. A test to measure how much lead is present on a surface. A surface of aspecific size is wiped with a baby wipe, which is sent to a laboratory for analysis. Usedafter lead work to determine if thorough cleanup has been done. See Clearance.

X-ray Fluorescence (XRF) Analyzer. An electronic instrument used to test for lead inpaint. The testing is non-destructive, and the results are reported in milligrams per squarecentimeter (mg/cm2).

Zinc Protoporphyrin (ZPP). A blood test that reflects a person’s lead exposure over theprior 3 to 4 months, showing how much the blood-forming system has been damaged.

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