1.1
It is the policy of the University of Pennsylvania in coordination with the Office of Environmental Health and Radiation Safety to provide the University community with a safe and healthful environment. This policy is designed to ensure that University employees follow the appropriate procedures to prevent building occupants, visitors, maintenance personnel and contractors from exposure to hazardous levels of lead.
1.2
This policy applies to all University employees and students involved with, or affected by, activities that may result in the disturbance of lead-containing materials
1.3
This policy does not apply to the University of Pennsylvania Health System or University City Associates who are covered under their own policies.
2.1
Dormitory Apartment
An apartment, located within a dormitory building, occupied by students with children or employees residing with their partners and/or children.
2.2
Lead-Based Paint Abatement
As defined by the Pennsylvania Department of Labor and Industry's Title 34 Code Chapter 203. "A set of measures designed to eliminate or reduce lead-based paint hazards in accordance with standards established by EPA. The term does not include renovation and remodeling activities by contractors whose primary intent is not to permanently eliminate or reduce lead-based paint hazards, but is instead to repair, restore or remodel a given structure or dwelling."
2.3
Lead Paint Activities
As defined by the Pennsylvania Department of Labor and Industry's Title 34 Code Chapter 203. With respect to target housing, the term includes risk assessment, inspection and abatement. With respect to a public building - Identification of lead-based paint and materials containing lead-based paint, deleading and removal or lead activities where the specific purpose of the work is to abate lead-based paint or lead-based paint hazards.
2.4
Lead-Based Paint Hazard
A condition that causes exposure to lead from lead-contaminated dust, lead-contaminated soil, or lead-contaminated paint that is deteriorated or present in accessible surfaces, friction surfaces, or impact surfaces that would result in adverse human health effects.
2.5
Lead Hazard Evaluation
A quantitative determination of employee exposure to lead. Includes full shift personal samples that are representative of the monitored employee's regular, daily exposure to lead.
2.6
OSHA Action Level (AL)
Under the US Department of Labor, Occupational Safety and Health Administration (OSHA) Lead in Construction Standard 29 CFR 1926.62 and Lead in General Industry Standard 29 CFR 1910.1025 is defined as an exposure of 30 ug/m3 as averaged over the course of an eight-hour workday.
2.7
OSHA Permissible Exposure Limit (PEL)
Under the US Department of Labor, Occupational Safety and Health Administration (OSHA) Lead in Construction Standard 29 CFR 1926.62 and Lead in General Industry Standard 29 CFR 1910.1025 is defined as a time-weighted average exposure of 50 ug/m3 as measured over the course of an eight-hour workday.
2.8
Public Building
As defined by the Pennsylvania Department of Labor and Industry's Title 34 Code Chapter 203 - "A building constructed prior to 1978 which is generally open to the public or occupied or visited by children."
2.9
Target Housing
Housing constructed prior to 1978. Any dwelling, such as a dormitory, in which the living area is not separated from the sleeping area is classified as a zero-bedroom dwelling and is not considered target housing.
3.1
The Office of Environmental Health and Radiation Safety (EHRS) is responsible for identifying at-risk job tasks, conducting task-specific lead hazard evaluations, sampling, evaluation of renovation activities, inspections of dormitory apartments target housing, notification and lead education for occupants residing in dormitory apartments and target housing undergoing renovatons or maintenance where lead paint will be disturbed, abatement oversight, waste characterization / disposal, training and record keeping.
3.2
The University of Pennsylvania Office of Housing and Conference Services is responsible for disclosure, to occupants moving into dormitory apartments/target housing, of all lead-based paint data for the unit to be occupied. They will also provide occupants of dormitory apartments/target housing with an EPA pamphlet entitled "Protect Your Family from Lead in Your Home" and Philadelphia Department of Health pamphlet "Get The Lead Out" and ensure that signed disclosure forms are obtained and maintained.
3.3
The University of Pennsylvania Division of Facilities Services is responsible for notifying EHRS of changes in job descriptions and/or work tasks that may result in rendering initial EHRS lead hazard assessments as being unrepresentative and notifying EHRS of any renovation or maintenance projects that may involve working with suspected lead-based paint surfaces.
3.4
The Hospital of the University of Pennsylvania (HUP) Department of Occupational Medicine (OM) is responsible for the medical surveillance program including the biological monitoring of at-risk employees.
3.5
Supervisors are responsible for requesting lead hazard evaluations for employees and notifying EHRS of unusual conditions or changes in work practices that would make initial lead hazard evaluations non-representative of actual lead exposure. Supervisors are also responsible for scheduling and ensuring employee attendance at annual EHRS Hazard Communication training and enrolling employees exposed to lead above the OSHA action level into a medical surveillance program with HUP Occupational Medicine.
3.6
Employees are responsible for participating in annual EHRS Hazard Communication training and participating in the medical surveillance program. Employees are also responsible for using personal protective equipment, engineering controls and adhering to administrative work practices as instructed and notifying supervisors of unusual conditions or changes in work practices that would make initial lead hazard assessments as being non-representative of actual lead exposures.
4.1
Written Standard Operating Procedures
The Lead Exposure Control Plan outlines lead management procedures and controls implemented by EHRS to prevent lead exposures to building occupants, visitors, maintenance personnel and renovation contractors within University-owned and operated facilities covered by this policy.
4.2
Determination of Employee Lead Exposure
EHRS shall perform lead hazard assessments on all tasks having the potential to expose employees to levels of lead above the OSHA action level of 30 ug/m3 as an eight-hour time-weighted average. The assessments shall include air monitoring and observation of work practices and engineering controls typically used for each task. EHRS shall provide the employee and supervisor with a written copy of the sampling results and findings within five working days of the assessment. The report will describe any required changes in work practices or engineering controls based upon EHRS observation of the task and also notify the employee of the frequency of follow-up sampling if applicable.
4.3
Paint Sampling
A Commonwealth of Pennsylvania accredited Lead Inspector or Risk Assessor shall perform all sampling associated with lead paint activities. As a matter of prudent practice, EHRS will perform testing of painted surfaces, by request, for non-regulated demolition and renovation projects. EHRS will conduct testing of any painted surfaces to be disturbed within dormitory apartments or target housing. Testing of painted surfaces will be performed either in-house by portable X-Ray Fluorescence (XRF) and/or by lab analysis of bulk paint chip samples by an AIHA accredited laboratory. Following paint testing, EHRS will provide a written response and recommend case-specific procedures to be followed. Generally, this will include notifying all contractors of sample results and requesting that written work practices be submitted to EHRS for review.
4.4
Project Oversight
EHRS requires that Commonwealth of Pennsylvania-accredited lead paint contractors and personnel are used for lead paint activities within target housing and public buildings. EHRS recommends the use of accredited contractors and personnel in unregulated renovation projects involving the disturbance of lead-based paint. EHRS will provide occupants of dormitory apartments and target housing with EPA pamphlet entitled "Protect Your Family from Lead in Your Home" prior to renovations or maintenance activities that disturb more than two square feet of lead-based paint. EHRS will perform air and clearance wipe sampling as required to ensure the safety of building occupants.
4.5
Waste Disposal
EHRS shall perform waste stream characterization of suspected lead containing waste materials by laboratory analysis following EPA Toxicity Characteristic Leaching Procedure (TCLP) for lead (40 CFR 261.24). EHRS will coordinate waste disposal of lead-containing materials.
4.6
Training
EHRS, as part of its annual Hazard Communication training, shall discuss the Lead Exposure Control Plan and job tasks that are likely to result in exposure to lead above the OSHA action level of 30 ug/m3 as an eight hour time-weighted average and discuss the importance of worker input in identifying other tasks that may not have been identified by OSHA. Employees will be informed of lead-related services offered through EHRS and trained on the importance of proper hygiene during and after performing tasks that may involve exposure to lead.
4.7
Recordkeeping
EHRS maintains all documents relating to lead exposure including sampling data, waste disposal manifests, regulatory agency and other correspondence. The Office of Housing and Conference Services maintains all lead paint disclosure forms. All records are kept indefinitely.