Syracuse University

This document is the official University position on procedures and operations involving the disturbance of lead-containing materials at Syracuse University (SU) by outside contractors. This document was developed to ensure the University is in compliance with the Occupational Safety and Health Administration (OSHA) Lead in General Industry Standard 29 CFR 1910.1025.

2.0 PURPOSE

The purpose of the Syracuse University Lead Management Program is to prevent lead exposure of all workers, regardless of job title and to help prevent the potential for building contamination from lead during demolition, maintenance and renovation activities in non-residential structures. The requirements in this Program set standards for work that disturbs lead-containing materials. Contractors engaged in such projects are expected to possess the managerial expertise and to employ workers with skill, training, and experience so that the work is carried out in compliance with these requirements.

3.0 DEFINITIONS

Component - An object that is a constituent part of another aggregate, but by itself does not fulfill the function of the aggregate. Common components of a buildings are, roofs, walls, doors, and windows.

Hazardous Waste – Generation and disposal of hazardous waste is regulated under the Resource Conservation and Recovery Act (RCRA). If a waste exhibits toxicity, corrosivity, ignitability, or reactivity characteristics it is considered hazardous. Waste may also be “hazardous” under RCRA if included on EPA’s list of hazardous waste.

HEPA Vacuum Cleaner - An electrical device that cleans surfaces by suction and discharges

transport air through a HEPA filter.

Lead Containing Material (LCM) – Any material that has been confirmed, through laboratory analysis or XRF testing, to contain lead.

Multi-Employer Program - In accordance with the Hazard Communication Standard, each outside employer working on Syracuse University operated property (on-site) is responsible for developing, implementing and informing the other on-site employers of hazard communication related information. Under the Multi-Employer Program, each outside employer must provide Syracuse University, and other employer(s) working on-site, with unrestricted, on-site access to material safety data sheets (MSDSs) for all hazardous materials used, handled or stored on-site to which an employee may potentially be exposed to during their normal course of work.

Presumed Lead Containing Material (PLCM) – Any material that is presumed to contain lead.

Representative Sample – Sample that accurately captures a particular material or area based on the typical characteristic of that material or area.

Substrate – The underlying material a building component is made from, over which is often applied a surface finish such as paint. Common substrates include, plaster, concrete, wood, metal, and gypsum.

4.0 DUTIES AND RESPONSIBLITIES

The Environmental Health (EHO) shall:

1. Provide technical guidance to University personnel concerning lead hazard evaluation and control.

2. Review results of area air monitoring and clearance dust wipe sampling and provide interpretation for departments managing work.

3. Direct the Syracuse University Department conducting the work to modify or stop lead related work practices if employees, students or the public are being exposed to lead hazards.

4. Maintain records of all sampling data submitted to EHO.

5. Communicate requirement of Lead Management Program.

6. Periodically review the Lead Management Program and revise as necessary.

7. Review for approval Statement of Qualifications provided by the Sampling and Analysis Vendors.

8. Provide Lead Awareness Training to Syracuse University Employees anticipated to have occupational lead exposure.

9. Develop and maintain a database of know lead containing materials in campus buildings, based on information provided by Departments conducting lead sampling.

The Syracuse University Department Managing Work shall:

Disclose known information regarding the presence of lead in building and construction materials to any contractor retained to conduct demolition or renovation work at SU.

Contact EHO a minimum of 30 working days in advance of upcoming projects that may generate lead dust or fumes.

Ensure that the Contractor has read, understands and will abide by the minimum performance standards required in this Program for controlling lead hazards.

Report any problems associated with implementation of the Lead Management Program to EHO.

Provide EHO with a Statement of Qualifications of the Contractor scheduled to conduct the area air sampling, 10 working days prior to the intended start date, for review and approval.

Stop or modify lead related work practices if employees, students or the public are being exposed to lead hazards.

Conduct area air monitoring and clearance sampling as required by this program and provide EHO with all sample results.

Ensure all lead related work-sites and all areas that have been contaminated resulting from the work conducted are properly cleaned and meet the clearance criteria required by this Program.

Ensure all hazardous waste is properly identified, labeled, segregated and stored at the job-site until removed by EHO.

5.0 LEAD IDENTIFICATION

Because of its physical properties, lead has been widely used as an additive to many building materials. Although lead has been banned from the use on portable water supplies and residential paint, it may still be present in older buildings. Some lead containing building materials continue to be used to this day. The following materials should be presumed to contain lead unless manufacturer information, MSDS, or testing proves otherwise.

Presumed Lead Containing Materials (PLCM):

Interior and exterior paint applied prior to 1980
Steel and iron primer
Industrial paint
Industrial electrical jacketing
Roof flashing
Tank linings
Soft solder
Glazed Ceramics

The OSHA Lead Standard applies to any detectable concentration of lead in a material. The presence of any lead in a material triggers the worker protection and work practice requirements in this program.

The Syracuse University department managing the work may decide to conduct lead identification sampling to determine if a presumed lead containing material contains lead and requires lead management. The only two lead identification methods currently recognized are bulk sampling for laboratory analysis and x-ray florescent (XRF) analysis. Sampling may only be conducted by a qualified individual(s).

At a minimum, a qualified person conducting lead identification sampling will:

Have previous bulk sampling for lab analysis experience and or, submit proof of training specific to the XRF instrumentation used.

Have a working understanding of the National Institutes for Occupational Safety and Health (NIOSH) sampling methodologies.

Capable of determining appropriate sampling methodologies documenting and submitting a “representative” sampling plan.

EHO has reviewed the following companies Statement of Qualifications and has determined their Sampling Staff meets the minimum qualifications listed above. These laboratories provide a sampling service for a fee and all associated cost will be the responsibility of the department managing the work. The EHO approved laboratories are as follows:

CES

1401 Erie Boulevard East

Syracuse, NY 13210

315-478-2374

At a minimum, Lead Identification Sampling must provide the following:

Sampling must be representative of the material selected. One sample is needed for each homogenous (same color and substrate) component and each individual component must be sampled separately. For example, if a door is painted 2 different colors, a sample is needed for each color, or if a wall is half plaster and half drywall, a sample is need for each substrate.

A collection of all paint layers from the substrate, and minimize the collection of actual substrate.

A record of the component, substrate, color, and location for each sample taken.

Sampling results must be provided to the Department Managing the work and EHO.

When submitting result to EHO, please attach all results to a completed Sample Result Notification Form located in Attachment C.

6.0 LEAD EXPOSURE

According to the Occupational Safety and Health Association (OSHA), any lead containing material has the potential to create an airborne exposure to lead. Contractors that disturb lead-containing material or presumed lead containing material must protect their employees from airborne lead exposure in compliance with the OSHA Lead Standard 1926.62. In accordance with OSHA, Contractors must protect their own employees with personal protective equipment, training, and medical surveillance. Contractors conducting lead work on multi-contractor sites must also inform all site workers of potential exposure to lead .

Syracuse University must also protect employees, regardless of job title, from lead exposures according to the OSHA General Industry Standard 1910.1025. Protecting these individuals from lead exposure will be accomplished by making sure the Contractor contains all airborne lead to the work site by using appropriate work practice controls and meeting the minimum performance criteria listed below.

7.0 WORK CATEGORIES

Projects involving lead can be categorized according to the tasks preformed. In order to ensure the appropriate measure will be taken to protect all individual at SU, all projects must be categorized by the department managing the work prior to initiation. Use the following tasks described below to categorize the work being conducted.

Level 0

Tasks conducted with lead containing material that are not anticipated to create dust or debris and are not listed as Level 1, 2 or 3 Tasks

Level 1

Example tasks may include, but are not limited to:

Spray painting with lead-based paint
Manual demolition of lead containing materials or coatings
Manual scraping or sanding of lead containing materials or coatings
Use of a heat gun on lead containing materials or coatings
Power tool disturbance of lead containing materials or coatings with a dust collection system

Level 2

Example tasks may include, but are not limited to:

Using lead-containing mortar
Lead burning
Rivet busting on lead containing materials or coatings
Power tool disturbance of lead containing materials or coatings without a dust collection system
Clean-up of dry expendable abrasives used to remove a lead containing coating

Level 3

Example tasks may include, but are not limited to:

Abrasive blasting on lead containing materials or coatings
Welding on lead containing materials or coatings
Cutting on lead containing materials or coatings
Torch burning on lead containing materials or coatings
Large Scale Demolition of lead containing materials or coatings

8.0 PROJECT NOTIFICATION

Prior to the initiation of any interior or exterior work involving lead containing or presumed lead containing material, the Syracuse University department managing the work must provide EHO with an Initial Lead Project Notification. The initial notification must contain the general scope of work to be done, dates for the start and proposed completion of the work, and the precautions which will be employed to protect building occupants. The Syracuse University Department Managing the work must complete and submit the Initial Lead Notification Form, located in Attachment A, 30 days prior to the start of the project.

9.0 NOTIFICATION TO BUILDING OCCUPANTS

Prior to the initiation of any interior or exterior work involving lead containing or presumed lead containing material, the Syracuse University department managing the work will forward an informational memo to all appropriate department chairs and directors of departments located in the building that lead work is conducted. This memo will contain the general scope of work to be done, dates for the start and proposed completion of the work, and the precautions which will be employed to protect building occupants.

10.0 TRAINING

All SU employees that are anticipated to enter a lead work-site which may result in an occupational lead exposure must receive a Lead Awareness Training. Lead Awareness Training shall be conducted annually by EHO and will consist of the following:

16 Lead Management Plan

The content of the OSHA Lead in Construction Standard

The specific nature of the operations which could result in exposure to lead above the action level

The purpose, proper selection, fitting, use and limitations of respirators

The purpose and description of the medical surveillance and medical removal programs, including health effects of lead exposure and potential reproductive consequences

Explanation of engineering controls and work practices for lead-related work

The employee’s right of access to records under 29 CFR 1910.20

11.0 PERFORMANCE CRITERIA FOR CONTRACTORS

Minimum Performance Criteria have been established for contractors conducting lead related work to ensure that no Syracuse University employee is unnecessarily exposed above the OSHA Action Level of 30ug/m3 of airborne lead or has the potential to come into contact with lead dust as a result of contractor’s activities. At a minimum, Contractor disturbing lead related materials must meet the following requirements.

Limit access to worksites in which Level 1, 2 and 3 tasks are taking place to trained and authorized personnel only.

Adequately limit all migration of lead containing dust and debris to any areas outside the worksite.

Ensure that SU employees not associated with the worksite are not exposed to lead level above the OSHA action Level of 30ug/m3.

Prevent the contamination of SU property (ie., computers, chairs, desks, carpet, floors, walls, etc.) from lead dust and debris.

Collect and manage hazardous wastes produced in accordance with University Program requirements.

Ensure that workers contaminated with lead containing dust and debris do not transfer that material outside the worksite

The Syracuse University department managing the work will ensure airborne lead and dust is contained to the worksite by conducting or contracting for third party Area Air Monitoring and Clearance Dust Wipe Sampling (information on Area Air Monitoring and Clearance Dust Wipe Sampling can be found in Sections 9 and 10).