TEMPLE UNIVERSITY ENVIRONMENTAL HEALTH AND RADIATION SAFETY

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1 Page 1 of 5 ISSUED: 5/00 REVISED: 08/06 Introduction Purpose This chapter has been developed to inform the University community of the University s lead management program, and to outline work procedures for employees that disturb or contact potential lead containing materials during the course of their work. Applicability This chapter is applicable to all Temple University employees and contractors who may be occupationally exposed to lead. Reference Regulations The current regulations referenced concerning occupational exposure to lead are as follows: Lead -Occupational Safety and Health Administration (OSHA) 29CFR & Residential Lead-Based Paint Hazard -Environmental Protection Agency (EPA) 40 CFR 745 Prohibition on use of lead pipes, solder, and flux, (EPA) 40 CFR & & Lead Contamination -U.S. Department of Housing and Urban Development (HUD) Control Act of 1988, 42 U.S.C. 201 Preventing Lead Poisoning in Construction Workers -National Institute for Occupational Safety and Health (NIOSH) Publication No a Definitions Action Level for Airborne Concentrations of Lead - employee exposure, without regard to the use of respirators, to an airborne concentration of lead of 30 micrograms per cubic meter of air (30 ug/m 3 ) calculated as an 8-hour time weighted average (TWA). Action Level for Lead in Drinking Water - action level is exceeded if the concentration of lead in more than 10 percent of tap water samples collected during any monitoring period conducted is greater than.015 mg/l. Certified Inspector - an inspector who is certified as an inspector under a Federally accredited State certification program or under a Federal or State certification program. Lead - includes all metallic lead, all inorganic lead compounds, and organic lead soaps. Lead-Based Paint - defined by the EPA as paint or other surface coatings that contain lead equal to or in excess of 1.0 milligram per square centimeter (mg/cm 2 ) or 0.5 percent by weight.

2 Page 2 of 5 ISSUED: 5/00 REVISED: 08/06 Lead-Based Paint Free - defined by the EPA as target housing that has been found not to contain paint or surface coatings with lead equal to or in excess of 1.0 mg/cm 2 or 0.5 percent by weight. A certified inspector must make this determination. Lead Containing Material (LCM) - building materials containing lead at any detectable concentration. Lead Free plumbing materials used in public water systems such as solders and flux which contain no more than 0.2 percent lead, and pipes and pipe fittings no more than 8.0 percent lead. Permissible Exposure Limit (PEL) - occupational exposure to lead concentrations greater than 50 micrograms per cubic meter (50 ug/m 3 ) calculated as an 8-hour time weighted average (TWA). Target Housing - residential housing built before 1978 including private housing, public housing, and housing receiving federal assistance. Target Housing does not include: Housing built after Zero bedroom units (such as efficiencies), lofts and dormitories, unless children under the age of 6 reside or are expected to reside there. Housing leased for less than 100 days. Housing reserved for the elderly, or handicapped, unless children under the age of 6 reside or are expected to reside there. Rental housing inspected by a certified inspector and found to be lead-based paint free. Health Effects Short-term exposure may cause adverse effects on the gastrointestinal tract, blood, central nervous system and kidneys, resulting in colics, shocks, anemia, kidney damage and encephalopathy. Exposure may result in death. However, effects may be delayed. Long-term exposure may cause adverse effects on the gastrointestinal tract, nervous system, blood, kidneys and the immune system resulting in severe lead colics, paralysis of muscle groups of the upper extremities (forearm, wrist and fingers), mood and personality changes, and anemia. Repeated exposure may also cause retarded mental development, and nephropathy, as well as retarded development of the newborn. Responsibilities for Lead Safety Environmental Health and Radiation Safety Department (EHRS) The EHRS has the following responsibilities related to lead activities: 1. Policy development. 2. Surveillance as requested by responsible supervisor.

3 Page 3 of 5 ISSUED: 5/00 REVISED: 08/06 3. Training as requested by responsible supervisor. 4. Exposure Monitoring: Coordinate and/or contract consulting services to survey and monitor lead disturbance activities. 5. Monitoring Drinking Water: Coordinate with Facilities Maintenance and/or contract consulting services to survey and monitor any plumbing installed prior to June 19, 1986 which provides water for human consumption. Supervisors and Managers Assure that employees who may disturb lead containing material during construction and renovation activities receive training in accordance with this Guideline. In addition, assure that employees practice safe work procedures in accordance with their training, and use the proper equipment and controls. Allocate resources to support the implementation of this Guideline. Contact EHRS to request technical assistance and to provide air monitoring when necessary. Employees Comply with this Guideline and any further safety recommendations initiated by your Supervisor or EHRS. Conduct assigned tasks in a safe manner, wear appropriate personal protective equipment, and use only equipment for which training has been provided. Contact the EHRS to evaluate health and safety conditions within your unit. Facilities Planning, Design and Construction Management Contact the EHRS during the design phase of projects that may involve the disturbance of suspect lead containing material when the scope of the project will include: Scraping, hand-sanding, or otherwise removing lead containing material/paint from existing surfaces. Cutting, drilling, abrading, demolishing, or otherwise disturbing building elements coated with lead containing material/paint. Removal of lead sheet products such as, radiation shielding, soundproofing, flashing, and piping. Coordinate with Facilities Maintenance and/or contract consulting services to survey and monitor for lead in any plumbing installed prior to June 19, 1986, which provides water for human consumption. Engineering Controls and Personal Protective Equipment (PPE) Depending upon the work performed involving lead, engineering controls and PPE will vary. Please contact the EHRS at for recommendations, and technical support. Target Housing or Lease Disclosure

4 Page 4 of 5 ISSUED: 5/00 REVISED: 08/06 Before the sale or rental of pre-1978 target housing can take place, the University must provide the following information to the potential purchaser or lessee before being obligated under any contract to purchase or lease the property: The EPA booklet "Protect Your Family from Lead in Your Home". Any and all reports and records the University has that contains information on the presence, location or condition of any known lead-based paint and/or lead-based paint hazards in any portion of the target housing. The University is not obligated to perform any testing, but if testing reports exist, they must be disclosed. A "Disclosure of Information" form attached to the contract, which contains a Lead Warning Statement" as prescribed by 40 CFR Part 745 of the EPA Lead Disclosure regulation. A statement disclosing the presence of known lead-based paint or indicating no knowledge of lead-based paint. A statement by the purchaser or lessee affirming receipt and review of the information provided, and signatures of the purchaser or lessee and a University representative. Before the sale or rental of residential property, the University must give the purchaser or lessee a 10- day period to conduct a risk assessment or inspection for the presence of lead-based paint and/or leadbased paint hazards, unless the parties mutually agree in writing to a different period of time. The purchaser or lessee may waive the risk assessment or inspection opportunity by so indicating in writing. The "Disclosure of Information" will be kept on file for three years with the University department holding the contract or closing documents. All building lead survey reports will be kept on file at the EHS department. The University is not obligated to perform residential building surveys before the sale or rental of residential property under this regulation. However, the University may choose to conduct a survey performed by a certified inspector and become exempt from the disclosure requirements if the building is found to be lead-based paint free. Water Management Federal and State regulations require that any plumbing in a residential or non-residential facility providing water for human consumption that is connected to a public water system is to be lead free. Any water system designed for drinking that was installed on Temple University property prior to June 19, 1986 must be randomly sampled for lead contamination. All documentation of sampling will be kept on file in the EHRS department. Medical Surveillance Program The medical surveillance program is provided to monitor the health of all employees who have the potential to be exposed to lead above the action level in their work environment. Medical Evaluation of Records Records shall consist of:

5 Page 5 of 5 ISSUED: 5/00 REVISED: 08/06 1. The name and social security number of the employee. 2. The physician's written opinion. 3. A list of employee health complaints that may be related to lead exposure. 4. A copy of the employee's medical examination results, medical questionnaires, and results of medical tests that are required by the regulation or mandated by the examining physician. Medical evaluation records shall be kept for the duration of the employee's employment plus at least 30 years. Record keeping Requirements Environmental Health and Radiation Safety (EHRS) and Facilities Maintenance (FM) will keep accurate and complete records for all lead related work areas. The records shall consist of: Exposure Monitoring Records 1. The date the measurement was taken. 2. The operation that is being monitored. 3. The sampling and analytical methods used and evidence of their precision and accuracy. 4. The number, duration, time of day, and results of samples obtained. 5. The types of protective devices worn. 6. The names, job classifications, social security numbers, and exposure estimate of employees whose exposure is represented by actual monitoring results. When it is felt that objective data will relieve exposure-monitoring requirements, records shall consist of the objective data and calculations that demonstrate that no employee is exposed to lead at or above the Action Level. Exposure monitoring records shall be kept for at least 30 years.