Environmental Health & Safety

Lead Paint Policy and Procedure

January 2010


Scope:

Applicability:

This policy shall apply to all areas of the College, including Physical Plant, Rental Housing and the contractors who work at or for Amherst College. All academic, residential and support buildings including off-campus housing, apartments, condominiums, dormitories and storage facilities shall comply with the applicable sections of this policy and the regulations from which they were drawn. Residential occupancies with children under the age of six (6) will still be required to meet the more stringent regulations outlined by the Environmental Protection Agency and Massachusetts Department of Public Health 105 CMR 460.000 Lead Poisoning Prevention and Control.
  • Exception – The lead regulations outlined by the EPA for residential properties noted above does not apply to apartments, condominiums and houses that have children living within for less than 31 days.

Goal:

Amherst College will meet or exceed the appropriate regulations regarding lead for the health, safety and well being of the Amherst College community and the environment.

Areas of Concern

  • Most buildings built before 1978 contain some lead-based paint. 
  • It was used exclusively on homes built before 1950 because of its excellent adherence and durability qualities.
  • Lead paint has a pleasant, sweet taste that some children like to ingest
  • The chips, dust and flakes of lead paint have the potential to cause illness in children that is irreversible.
  • Lead dust is usually found on windowsills in window wells, near doors that rub against floors and casings. It can also be present in the soil near to the house because of years of scraping. Blistering and peeling paint can produce chips and flakes that can also be consumed
  • Homeowners, contractors and well meaning persons often disturb or improperly manage painted surfaces both inside and outside the home.
  • Employees, outside contractors and home repair enthusiasts often dry scrape, burn off or in other ways create dusts and fumes that may be injurious to themselves and others.

Proper Procedures

The Environmental Protection Agency (EPA), the Centers for Disease Control (CDC) and the department of Housing and Urban Development (HUD) have put together a field guide for painting, home maintenance and renovation work called Lead Paint Safety.
  • This booklet better identifies in words and pictures how contractors, staff and homeowners can safely handle lead paint.
For residential occupancies that have children under the age of six (6) an outside environmental agency must be called upon to inspect the apartment, condominium or home to verify the location (if any) of lead paint and the options for corrective action.
  • The Office of Environmental Health and Safety will contact, when necessary the appropriate environmental compliance companies for lead paint inspection and future abatement
  • The Environmental Health & Safety Office can be reached at (413) 542-8189 or by e-mailing the Environmental Health and Safety Manager (Rick Mears) at ramears@amherst.edu
  • Residential occupancies with children under the age of six (6), once inspected may require the services of a professional lead abatement company, even for small repairs. A list of these companies is available upon request, through the offices of Rental Housing at 542-8506 or Environmental Health and Safety.

Notification

a. Contractors and owners of rental properties must inform occupants about lead based paint before non-emergency repair, maintenance and home renovation work begins.
Exception: Work surfaces less than two (2) square feet in area.
  • Contractors and Property Owners must distribute copies of the Lead Paint Safety booklet before any work is initiated.
    • See section II for on-line obtainment of this booklet
  • For owner-occupied homes, the contractor must have the home-owner sign an acknowledgement form after receiving the pamphlet, or the contractor can send the pamphlet certified mail.
  • For tenants the contractor or property owner must have an adult occupant sign an acknowledgement form after receiving the pamphlet. Or, the contractor or owner can send the pamphlet by certified mail.
    • If the contractor cannot get a signed acknowledgement, the contractor must sign a statement documenting this.
  • For work in common areas, such as the lobby of an apartment building, the contractor must give the pamphlet to the owner and to the occupants of all affected areas and inform them of the nature, location, timing and length of job.

Painted Surfaces – Damage and Repair

If a job involves repair to a damaged surface (i.e. window sills, doorways, baseboards and/or the exterior), the cause of the damage must be correctedimage before paint scraping or painting maintenance can begin.
  • Example: If the roof of a building were found to be leaking and wall/ceiling damage affected the painted surface, the repair of the roof should take precedence over repainting of the ceiling or wall.
All painted surfaces both interior and exterior, except for new construction that have occurred after 1980, have or may contain lead paint.

Restricted Lead Paint Practices

Power Sanders and Grinders that are not equipped with HEPA vacuum filtration cannot be used on any painted surface that has or could contain lead paint.
  • These machines generate a considerable amount of airborne dusts that may adversely affect the building occupants, the workforce and the environment.
Open Flame / High Heat removal of paint using a torch or heat gun is not permitted.
  • This type of paint removal produces toxic gases that not even a HEPA respirator cartridge could filter out.
  • It is one of the most personally damaging ways of removing paint because it rapidly enters the body by inhalation, introducing the lead fumes through the lungs and directly into the blood stream in the most expeditious manner possible.
  • If other low hazard solvents are going to be used for painting activities, then the office of Environmental Health and Safety must approve its use, and a Material Safety Data Sheet for the intended product shall accompany the request.
  • Blasting methods tend to spread chip, dust and debris beyond the work area, increasing the possibility of unwanted and expensive contamination.
Dry Scraping and/or Sanding shall not be used.
  • Wet methods to limit airborne contamination are mandated.
    • Wet methods should include the use of TSP detergent or other approved cleaner.

Amherst College Responsibilities

For reasons of health and safety, Amherst College staff and approved painting subcontractors have been properly trained in Lead Safe Work Practices in accordance with D.E.P., E.P.A., and OSHA regulatory requirements.
Amherst College has provided the workforce with the appropriate equipment and engineering controls including, but not limited to fixed and portable HEPA Vacuums, Respirators and other appropriate engineering controls.
  • Amherst College personnel that have not been trained in the area of lead safe work practices and who do not have the appropriate equipment shall not engage in this type of work.
Amherst College shall monitor its lead paint trained staff for the following;
  1. Blood Lead Levels
  2. Pulmonary Function and Medical Monitoring – if the respirator is used for more than 30 days/year in accordance with the requirements of the Amherst College Respiratory Protection Policy.

  • This class is required for any painting contractor who wishes to continue working on or for Amherst College and Rental Housing.
  • The reason for this class and attached requirement is that Amherst College has made not only a commitment to the campus community with regard to lead safe work practices, but has invested a lot of time and monetary resources into the removal of existing lead hazards, including soil. Contamination of a “clean site” would negate everything the college has already properly addressed.
Effective March 01, 2002, painter(s) and painting contractors and their employees will not be permitted to work on or for Amherst College in any locations that does or may contain lead paint, unless they have taken the appropriate training, “Lead Safe Work Practices”.

Contractor(s) Responsibilities

Contractor(s) shall include but are not limited to carpenter(s), locksmiths, painters and lead or asbestos abatement contractors
  1. Only Amherst College recognized licensed asbestos/lead abatement companies shall be permitted to scrape or otherwise remove paint from known or presumed lead contaminated surfaces in apartments, condominiums, and homes where there are occupants below the age of six (6).
  2. Any contractor(s) working for Amherst College, after February 1, 2002, shall have been trained by an accredited environmental firm such as ATC for “ Lead Safe work practices”
  3. Contractor(s) shall make all appropriate notifications in accordance with section III of this policy.
  4. Contractor(s) shall adhere to the appropriate sections of this policy, including but not limited to sections II - V.
  5. Contractor(s) shall notify Amherst College Environmental Health and Safety, Physical Plant or Rental Housing about additional work surfaces, which were not previously identified that may contain lead before initiation.
  6. Contractor(s) shall place follow all appropriate work practices outlined in the Lead Safe Work Practices, as instructed by ATC Associates of East Longmeadow.
  7. Amherst College requires strict adherence of this policy by our contractors and their subcontractors for reasons of health and safety. Failure to follow these requirements could result in work stoppage, a monetary fine, or removal from the list of painting contractors working at or for Amherst College.
- See Contractor Health and Safety Guidelines at www.amherst.edu/offices/enviro_health_safety/


Comments, concerns and suggested modifications of this policy can be directed to the office of Environmental Health and Safety. E-mail us at ramears@amherst.edu (Rick Mears), wdonnell@amherst.edu (William Donnell) or call 542-8189.