Environmental Health & Safety

Lead Abatement Policy


January 2010


Scope:

In accordance with the requirements of the Environmental Protection Agency (EPA), the Massachusetts Departments of Environmental Protection and Labor and Workplace Development, Amherst College has developed, implemented and maintained a Lead Abatement Policy that is designed to recognize, control and mitigate lead hazards at academic facilities, dormitories, and residential occupancies across campus.

Purpose:

Amherst College has implemented a policy to identify, inspect, control, maintain and improve our handling of lead related issues across the campus. In an effort to reduce potential hazards, Amherst College through training has put together abatement / maintenance programs that will not only better protect the environment, but the employees of the college as well. Risks associated with lead, including painting activities, drinking water concerns and soil contamination will be addressed in the most expeditious manner possible in an effort to reduce negative environment impact. The use of proper engineering controls, the elimination of unwanted material through recycling (when possible) and the use of proper maintenance methods will all be employed in an effort to reduce potential risk and liability.

Applicability:

The Amherst College Lead Abatement Policy shall apply too not only employees of the Physical Plant but to outside contractors as well. Personnel, regardless of affiliation working on or for Amherst College will be held contractually accountable to the same health and safety standards that are required of our own Carpentry and Paint Shops. No outside painting contractor will be permitted to work for Amherst College after January 01, 2000 unless they can show proof of training relative to lead abatement or maintenance from an accredited training institution.

Lead Abatement Activities:

As required by Massachusetts General Law, Amherst College Physical Plant shall properly abate or maintain a college owned property and obtain the "Letter of Compliance" when a person under the age of six is living in said property. Properties that have been abated in the past shall be re-inspected annually by the Office of Environmental Health and Safety or their designee to ensure compliance. Areas of concern will be immediately addressed to either:
  1. The Physical Plant Paint Shop Supervisor, or
  2. A recognized and approved abatement contractor.
The office of Environmental Health and Safety shall maintain inspections and "letters of compliance". Copies of the inspection shall be placed in a binder with a letter of compliance. In addition, a separate letter of compliance shall be placed in the folder pertaining to that particular property.

Lead Paint Maintenance Procedures:

Lead safe work practices shall be used both inside and outside of any building on which lead paint may be present. If the potential for lead paint is not readily apparent, and the contractor or employee opts not to follow "lead safe work practices" then the building or area must be inspected by the office of Environmental Health and Safety, first. If the site is found to be free of lead based paint, the contractor/employee will be permitted to work without plastic and the required personal protective equipment. Under no circumstances shall an employee of the college or an outside contractor working for the college be permitted to drop lead paint to the ground without providing some type of barrier at or above grade. Contractors and employees found not using "lead safe work practices" will be shut down at the site until corrective action takes place. In addition to having to clean up the site, the contractor / employee will also be cited for non-compliance and will most likely be fined for not following Amherst College Policy.The Amherst College Lead Abatement Policy includes proper disposal requirements for lead painted waste and paint chips. Outside contractor and employees of the Amherst College Physical Plant are obligated to locate old, unwanted lead paint waste material, with the exception of paint chips and dusts to the west side of the Gray Barn (aka Hills Barn) on the East side of the railroad tracks behind the Physical Plant. Material that is relocated to this point from elsewhere on campus shall be properly wrapped in plastic to prevent contamination of the site. Paint chips and dusts shall be properly packaged on site, placed in a 4 or 6 mil plastic bags (without holes) and then turned over to the Paint Shop for placement into the Lead Paint Drum, located in Bay 4 of the Hazardous Material Universal Waste Building. Physical Plant Paint Shop Personnel and the Environmental Health and Safety Office shall verify that the container is properly labeled and covered at all times, as required by law.