The purpose of this document is to outline the management of
lead containing materials at UB. The information presented in this
document represents minimum safety requirements.
This program applies to all employees who work in areas where
exposures to lead may occur.
- OSHA – 29CFR 1910.1025, Lead in General Industry
- OSHA - 29CFR 1926.62, Lead in Construction
- OSHA – 29CFR1910.1200, Hazard Communication
- OSHA – 29CFR 1910.134, Respiratory Protection
- OSHA - 29 CFR 1910.1450, Laboratory Standard
- NYS Right to Know
- EPA – 40CFR Part 745, Lead Based Paint activities in
target housing and child occupied facilities
- EPA – 40CFR Parts 402, 403 and 404, Toxic Substances
Control Act Title IV – Waste Disposal
- EPA – 40CFR Parts 745, 402, Training and
- EPA under authority of TSCA- 402(c)(3), Lead Renovation, Repair
and Painting Rule
- Housing & Urban Development (HUD), “Guidelines for
the Identification and Control of Lead-Based Paint Hazards in
Housing”, June, 1995.
- Follow lead safety procedures.
- Notify supervisor of tasks or procedures that may cause lead
- Contact EH&S for sampling if materials being worked with
are suspected of containing lead.
- Ensure that employees receive appropriate training.
- Ensure that employees follow established safety procedures and
that engineering controls are properly functioning.
- Notify EH&S of employees who may have a potential exposure
to airborne lead, as well as operations or changes that may produce
or increase lead exposure to employees.
- Ensure that employees who perform work that may have a
potential to exceed the Action Level (Controlled Operation) are in
a medical surveillance program and have had a base-line blood lead
sample prior to starting work.
- Provide employees with personal air monitoring results within
two days of their receipt from EH&S.
University Facilities Planning and Design
- Contact EH&S in planning stages so that samples can be
taken on materials suspected of containing lead (by EH&S or a
- Inform EH&S of all upcoming work that may involve the
disturbance of lead-containing materials at the project design
phase, so that recommendations can be included in bid
- Submit for approval to EH&S any proposed procurement of
- Ensure that bid specifications disclose all hazardous lead
materials that may be encountered by a contractor, and the party
responsible for their mitigation.
University Facilities Operations
- Work with EH&S to monitor and minimize exposures.
- Contact EH&S for sampling when paint may contain lead.
- Operations Safety Supervisor will train Facilities Operations
personnel who perform any tasks in which there is a potential
exposure to airborne lead at any level.
Environment, Health and Safety Services (EH&S)
- Conduct exposure assessments and workplace monitoring to
determine an employee’s potential exposure to airborne
- Conduct direct reading or destructive sampling of materials to
determine potential lead content.
- Recommend appropriate engineering and administrative controls
to ensure that airborne lead levels do not exceed the OSHA Action
- Recommend appropriate personal protective equipment (PPE).
- Notify supervisors of personal lead air monitoring results
within three days of their receipt.
- Conduct training for employees outside of Facilities Operations
who perform any tasks in which there is a potential exposure to
airborne lead at any level.
- Recommend respirators and filters, and provide contacts to
obtain annual respirator fit-tests for employees who use
respiratory protection to reduce lead exposure.
- Manage and update the UB Lead Compliance Program.
- Identify employees who should be considered for the Medical
- Personal and area air sampling results collected by
subcontractors shall be submitted to Facilities Project Managers,
when applicable, for collection, retention, and distribution to EHS
Industrial Hygienists for review. Copies of the results of samples
collected by EH&S Industrial Hygienist will be forwarded to
Facilities Project Managers, when applicable, for collection and
- Determine proper packaging, shipping and paperwork for
- Maintain disposal records.
An OSHA occupational exposure limit
(without use of respirators) for airborne contaminants. For lead it
is 30 micrograms per cubic meter of air (30 µg/M3) for an
8-hour Time-Weighted Average (TWA). Employees whose exposure is
above the Action Level for more than 30 days per year are required
to be in a medical surveillance program.
Any employee whose exposure is at or
above the Action Level.
As Low As Reasonably Achievable. UB
policy is to keep employee chemical exposure as low as
Blood Lead Level (BLL)
The amount of lead, measured in
micrograms (ug), present in a deciliter (d) of whole blood.
A High Efficiency Particulate Air
Filter capable of filtering 0.3 micron particles with 99.97 percent
Metallic lead, all inorganic lead
compounds (e.g., laboratory reagents, solder), and organic lead
soaps. All other organic lead compounds, such as tetraethyl lead,
are excluded from this definition.
Paint containing greater than 0.05 %
(500 ppm) lead.
Consists of medical examinations as
well as blood sampling for lead and zinc protoporphyrin, if
applicable. Performed by or under the supervision of a physician.
The LBL EHS Health Services Group is responsible for the Medical
Permissible Exposure Limit (PEL)
OSHA occupational exposure limit
(without regard to the use of respirators) for airborne
contaminants. For lead it is 50 micrograms per cubic meter of air
(50 µg/m3) for an 8-hour Time-Weighted Average (TWA).
Exposure to airborne lead above the PEL triggers requirements such
as housekeeping, engineering controls, showers, change and lunch
rooms, area posting, personal protective equipment, and respiratory
Personal Protective Equipment. Safety
equipment worn by employees; may include safety glasses,
respirators, coveralls etc.
Time Weighted Average (TWA)
The amount of led dust a person is
exposed to (by weight), divided by the number of hours of exposure
during a day. Exposures at low concentrations will offset exposures
at higher concentrations.
Hazards of Lead
Ways in Which Lead Enters the Body
- Lead can be absorbed into the body by inhalation (breathing)
and ingestion (eating). Lead (except for some organic compounds not
covered by this program) is not absorbed through the skin.
- Inhalation of lead is considered the most important source of
- When lead is scattered in the air as a dust or fume particle,
it can be inhaled and absorbed into the blood stream through the
lungs and upper respiratory tract.
- Lead can also enter via the digestive system if it enters the
mouth and is swallowed. As an example, lead can be ingested by
handling cigarettes, food, etc., with lead contaminated hands.
- When lead gets into the body it is only partly eliminated. The
majority of the lead is stored in the bones and other tissues. As
exposure to lead continues, the amount stored in the body increases
if more lead is absorbed than is excreted. Consequently, continuous
exposure to low levels of lead can, over time, cause lead to
accumulate in the body and lead poisoning may result.
- Short term (acute) overexposure. Large doses of lead may cause
seizures, coma, and death from cardio-respiratory arrest. Short
term occupational exposures leading to these effects are unusual
- Long-term (chronic) overexposure may result in damage to the
bloodforming, nervous, urinary, and reproductive systems. Some
common symptoms of overexposure include loss of appetite, metallic
taste in the mouth, anxiety, constipation, nausea, pallor,
insomnia, headache, nervous irritability, muscle and joint pain,
Examples of Possible Lead Exposure Sources
- Lead-Based Paint (banned 1977): Sanding, scraping, burning,
welding, ingestion. Note: The paint on metal surfaces like
structural steel generally contains very high (20-40%) levels of
- Drinking Water: Some water sources, lead solder in pipes
(banned in 1986)
- Metallic Lead: Casting lead or brass, shielding and counter
weights, soldering, sawing, cutting, etc.
- Soil: Automobile exhaust, paint chips, fumes downwind of a
- Miscellaneous: Pottery glazes, leaded crystal decanters, "folk"
medicine, tin cans (banned in USA), indoor shooting ranges, hobbies
(stained glass, fishing sinkers).
This procedure shall be reviewed once every two years, or as
Document Revision History
||Add: EPA under authority of TSCA 402(c)(3)
||Reformatted for web
|Environment, Health and Safety
|Planning, Designing and Construction