• Background
• Exposures in the workplace
• Work practices/protection for employees
• Regulatory agencies
• Samples and sampling
• Procedures for handling
• Regulatory levels tables

BACKGROUND
Lead can be found in many places on campus, including paint, solder, ceramic products and water. MIT is committed to providing students and employees with safe work environments free from any health hazards, to that extent, we comply with pertinent Federal and State guidelines and regulations. Such regulations require the identification of lead-containing materials, maintaining painted surfaces, effective and proper abatement when necessary, and proper disposal of waste generated by the abatement project.

Lead and its compounds are toxic and present a health hazard when ingested or inhaled. Once absorbed it is carried throughout the body by the blood stream to other organs. Excessive lead levels can result in damage to the brain, kidney, CNS, blood and reproductive systems. Lead is extremely hazardous to children because it is easily absorbed into their bodies and interferes with the developing brain, central nervous systems and other organs. Lead is excreted mainly through the urinary and GI tract. Not all the lead is excreted though; some is absorbed in the bones.

The following Institute groups shall work cooperatively following specific regulations and guidelines. Their responsibilities are identified below.

Facilities Department

1. Identify specific areas of construction/demolition projects that may potentially generate paint dust or fumes. As part of the pre-work planning notify the Industrial Hygiene Program to perform a lead paint survey. IHP will need 2-4 weeks depending on the size of the project to perform the survey and prepare a report. Small jobs will require at least 2-3days notice.
   
2. Supply workers with qualitative lead test kits to identify the presence of lead. If the kit yields a positive or questionable result call IHP 2-3477 for a quantitative survey.
   
3. If lead paint is found, include the finding in bid specifications to initiate appropriate work practices and waste disposal. Facilities Department design/construction coordinators would ensure that only licensed lead abatement contractors are used for lead abatement projects.
   
4. Facilities Department is also responsible for ensuring that all pertinent agencies are notified, including the Mass. Dept. of Labor, Childhood Lead Poisoning Program, building occupants and the local health board. As of Dec. 1997 formal notification is only required for lead abatement work in housing. Check with IHP to see if this has changed.
   
5. The design/construction coordinator for demolition or renovation projects through the abatement contractor shall be responsible for the proper disposal of any waste.
   
6. The Facilities training coordinator, in conjunction with the Industrial Hygiene Program, shall identify, train and keep records of MIT facilities workers who may be exposed to lead. Workers should be advised of the hazards of exposure to lead, appropriate work practices to reduce exposure, and available personal protective equipment.
   
7. Identify processes that may result in the generation of lead dust or fumes.
   
8. The Zone coach or shop supervisor shall ensure facilities personnel follow recommended work practices to minimize exposure to lead dust or fumes.
   
9. When necessary collect water samples and deliver to IHP for lead analysis.

Industrial Hygiene Program

1. Perform lead paint surveys for the MIT community and submit results to interested parties.
   
2. Help develop and review lead abatement plans and work practices.
   
3. Select proper respiratory protection and administer respiratory program.
   
4. Monitor processes that may produce lead dust or fumes in order to document exposures and evaluate the effectiveness of controls.
   
5. Analyze water, air, wipe, soil and paint chip samples for regulatory compliance.
   
6. Train MIT personnel involved in processes that may generate lead dust or fumes in the hazards of lead exposure.

Environmental Management Program

1. Dispose of small-scale lead containing hazardous waste on campus.
   
2. Supply information to help characterize waste to determine disposal method (i.e. TCLP analysis).
   

Medical Department

1. Establish a medical surveillance program

• biological monitoring
• medical removal
• chelation
  

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LEAD EXPOSURES IN THE WORKPLACE

Trades Potentially Exposed to Lead:

• plumbers
• welders
• painters (Scraping old lead paint prior to applying new paint)
• demolition workers
• carpentry/renovation/remodeling
• glaziers

Operations That Generate Lead Dust and Fumes

• welding, flame-torch cutting of structures covered with lead paint
• sanding, scraping and grinding of lead painted surfaces
• maintaining process equipment
• soldering
  

Other Sources of Lead

• lead in air from industrial emissions, incinerators etc.
• lead in soils from flaking, chipping paint; leaded gasoline; paint abatement
• lead in foods from foods grown in soil with high lead levels, leaded glasses and glazes on plates
• lead in drinking water from lead pipes, solder or leaded glass
• hobbies that may involve lead or lead products like solder, paints, target shooting or stained glass making

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WORK PRACTICES/WORKER PROTECTION FOR EMPLOYEES EXPOSED TO LEAD

• Perform a hazard evaluation and exposure assessment based on type of operation, % lead and exposure time.
  
• Use engineering controls including ventilation and enclosure to contain and exhaust any lead dust or fumes.
  
• Follow approved work practices in lead abatement to minimize the generation of any lead dust or fumes.
  
• Use respiratory protection as a supplement to engineering controls and work practices.
  
• Good personal hygiene should always be practiced to reduce the risk of cross contamination, accidental ingestion or carrying lead dust home. There should be washing facilities and a clean change area. Always wash contaminated clothes separately and do not take contaminated clothes home.
  
• Use protective clothing like coveralls, gloves, goggles.
  
• Medical Surveillance includes biological monitoring, chelation and possibly medical removal.
  
• Awareness level training is available to all to become familiar with lead its uses and hazards. Lead abatement workers must take more detailed training at an approved training site.
  

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REGULATORY AGENCIES GOVERNING LEAD EXPOSURE

• OSHA STANDARD 29 CF R 1926.62 LEAD IN CONSTRUCTION
  • Protect workers exposed to lead at work sites
  • Implement protective measures for certain tasks until exposure assessment completed, i.e. welding, demolition, paint removal
  • Training for workers exposed to lead at or above the action level of 30ug/m3 (<30ug/m3 Hazard Communication Std.)
  • Medical Surveillance Program
    
• EPA 40CFR PARTS 141 & 142 LEAD IN DRINKING WATER
• To minimize drinking water as a source of lead contributing to the total body burden
  
• OSHA STANDARD 40 CFR Part 261
• Requirements to help determine and classify waste material for proper disposal
• 
  RESIDENTIAL LEAD BASED PAINT REDUCTION ACT, SECTION 1017, "TITLE X"LEAD IN PAINT
  • Provide lead safe environment for children
  • Guidelines for working with LBP in federally supported housing
  • Evaluate and control lead hazards in soil, dust and water
  • Disclosure of LBP in privately owned dwellings upon sale or rental
    
• MASSACHUSETTS DEPARTMENT OF LABOR AND WORKFORCE DEVELOPMENT
  • License qualified lead inspectors and abatement workers

   

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LEAD SAMPLES AND SAMPLING.

There are several reasons and methods for sampling for lead in the environment. The most common reasons on construction sites are to determine the lead content in paint; to determine worker risk and exposure; and to determine whether materials are classified as hazardous waste as a result of their lead content. The following are discussions of each of these aspects of lead sampling.

Determination of the lead content in paint
There are two quantitative ways of determining the lead content in paint. They are paint chip sampling with laboratory analysis and measuring the lead-in-paint directly with a portable X-Ray Fluorescence analyzer. IHP can do both. For hazardous waste determination a Toxic Characteristic Leaching Procedure (TCLP) test will need to be done on the waste (see section below).

Paint Chip Sampling
Paint chip sampling is a destructive method, which involves removing all of the layers of paint from a surface, down to the substrate. Depending on the detection limit needed and the analytical method employed sample size can vary but generally a chip the size of a nickel is taken. The paint chip samples are sent to a laboratory for analysis. The analysis reports the weight percentage of the lead in the paint. The laboratory weighs the sample to get its total weight. The chips are then digested in a strong acid. All of the lead is dissolved into the acid solution, which is analyzed by Atomic Absorption Spectrometer (referred to as AA or AAS). The total amount of lead (determined by AA) is divided by the total weight of the sample and multiplied by 100 to get weight percent (%). Results are reported as parts per million (ppm) by weight (1,000,000 ppm = 100%). The concentration of lead in the sample will depend not only upon the concentration of the lead in the original lead containing paint, but also anything else bound to that layer of paint. Care must be exercised when taking the paint chip samples. If too much of the substrate material is taken the reported results will be low because although you have the same sample weight you will have less paint. It must also be kept in mind that painted surfaces are not homogeneous. The relative thickness of each layer of paint can vary. This variation could be from the initial paint application; from wear of the painted surfaces; or from the peeling of surfaces. Care must be exercised when taking samples to avoid sampling areas that have these potential problems. Sampling in multiple locations and averaging the results will be more representative of the architectural feature tested. Care must be exercised not to contaminate the environment while taking the paint chip samples.

X-Ray Fluorescence
X-Ray Fluorescence (XRF) sampling measures the lead content of the paint in place. It does not involve removing or disturbing any of the layers of paint from a surface. Sampling and analysis are performed in one process and lead is detected through all layers of paint to the substrate. The analysis reports the lead in the paint as milligrams lead per square centimeter of surface area. The instrument measures the total amount of lead in the paint. It does not matter how many coats of non-lead paint are on the surface.

Some XRFs have problems with different substrates, giving too low or high a reading. In this case, a separate measurement is taken of the substrate and subtracted from the paint reading (called substrate correction). While there are not currently levels that would require automatic abatement actions in commercial buildings, levels of 0.5 % (paint chips) (5000 parts per million) or 1.0 mg/cm2 (XRF) are most often used for residential properties. These two criteria are not exactly equal to each other but are approximate to each other in most cases.

The determination of whether materials are hazardous waste
The Toxic Characteristic Leaching Procedure (TCLP) is a test designed to simulate the leaching a waste will undergo if disposed in a sanitary landfill. Samples are taken which will be representative of the waste that is generated. The samples are then extracted with a weak acid solution in a way that will mimic the release of toxic materials into the environment at the landfill. Lead that is weakly bound chemically will be leached into solution. Lead that is more tightly bound will not. The solution is then analyzed and if greater than five parts per million (5ppm) of lead is in solution it is considered hazardous waste. A material may be thousands of parts per million of lead and still leach less than five parts per million into solution. Conversely, another sample with the same amount of total lead in the sample may have that lead weakly bound and give a TCLP result greater than the 5ppm.

The Environmental Management Program must always be consulted about waste issues.

The determination of worker exposure
OSHA regulation 29CFR1910.1025 requires that a judgment be made as to whether there is a possibility that workers will be exposed to lead levels at or above the action limit of 30ug/m3. This hazard evaluation is done before a work process begins. The total amount of lead in the material, the generation rate of lead into the air and exposure time would need to be known (along with other factors such as particle size distribution being generated, ventilation rate, etc.). If the possibility exists for exposures to lead at or near the action limit then air sampling is required. This is accomplished by drawing air through a filter (which traps dusts and fumes) with a vacuum pump. The filter is then sent to the lab for lead analysis. The amount of lead in the sample is then divided by the volume of air sampled to get the results reported in micrograms of lead per cubic meter of air (µg/m3). This will help to determine worker exposures. The less lead in the material and the less dust generated the lower the air concentrations from a disturbance of that material will be.

If you would like further discussion on these issues please call the Industrial Hygiene Program x2-3477.

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PROCEDURES FOR HANDLING LEAD PAINT AT MIT

Lead Paint in Construction Activities
For any activity that may produce airborne dust or fumes from painted surfaces the lead content of the paint must be determined. IHP can perform this analysis. Such activities include demolishing walls, removing painted surfaces and dismantling metal structures such as stairs or railings by cutting or burning techniques. OSHA has listed typical activities and the presumed exposures associated with each in Table 1. At least 3 days are needed by IHP for complete sampling and laboratory analysis. The Consumer Product Safety Commission has indicated > 600 PPM lead in paint is cause for concern. Mass uses 1.0mg/cm2 or 0.5% by weight for residences. If lead paint is present and airborne dust will be produced the following procedures shall be followed by outside contractors or MIT workers.

• Contractors must be notified by the MIT Project Manager and will follow OSHA regulations (29 CFR 1926.62).
• IHP should be consulted during planning and preparation of specifications.
• Unless concentrations are shown to be less than the OSHA PEL, a written compliance program is required by OSHA prior to any lead work.
• Work practices must be followed to minimize exposure and spread of dust.
  They include:
  • Containment of area (physical barriers and ventilation to maintain negative pressure)
  • Use of personal protective equipment (coveralls, respirators) for all people inside the work area.
  • Change of clothes before leaving area
  • Washing all exposed skin.
    • Air sampling may be performed by IHP outside the work area
    • IHP will do final inspection before an area is released for re-occupancy or further construction activities. This involves visual analysis for debris and wipe samples for lead contamination. Criteria used in Massachusetts as satisfying the levels (105 CMR 460.170(b)) for reoccupancy of a lead-abated area is in Table 2

Lead in Maintenance Activities

1. For any activity that may produce airborne dust or fumes the lead content must be determined. Such activities may include painting, scraping painted surfaces, welding, plumbers working with lead materials, window glazers. Analysis to be done by IHP
2. If lead is present and airborne dust/fume may be produced the following procedures shall be followed.

• All workers will have received training on the hazards of lead
• Initial and periodic exposure monitoring will be done by IHP
• Routine medical monitoring will be provided by Medical.
• The work practices and procedures in section I will be followed.

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Table 1.

Many modify these personal exposures based upon the duration of each of the tasks.
The OSHA Permissible Exposure Limit (PEL) is 50 ug/m3 as an 8-hour average.

Table 2

OTHER LEAD REGULATORY OR GUIDANCE LEVELS

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