Lead Management Plan (Environmental)

Purpose

This plan establishes the lead exposure and handling process for St. Mary’s University. The purpose of this program is to reduce the risk of lead exposure to University maintenance personnel, contractor / construction workers, and the general public; reduce the risk of contamination of the environment; and comply with federal, state and local requirements. The primary goals for the Lead Management Program are:

• To protect the health and safety of employees who perform construction, repair or renovation activities that disturb lead containing materials from occupational exposure to lead dust and fumes that have potential for toxic health effects.
• To ensure employees that conduct activities on lead or lead-based paints follow established methods/procedures, are properly trained and aware of lead hazards, and protect themselves to prevent lead poisoning.
• To protect the health and safety of the campus community & environment.

St. Mary’s University is an institution of Higher Education and does not have small children as its primary client nor does the University operate a daycare. The University does not have HUD target housing. The University is also not an industrial setting such as refinery or factory. These factors place the University in a low risk category for the potential of lead exposure. Remediation of lead on University campus has included:

• Drinking fountains: In 1988, as the result of the implementation of the Lead Contamination Control Act, all lead-lined campus drinking fountains were tested. The drinking fountains that tested positive were replaced.
• Shooting Range: In 1993-94, the shooting range in the old gym was removed and renovated. As part of the renovation, Synergistic Environmental Systems was hired to perform lead abatement to the facility. The space was converted into a health and fitness center.

Scope

This plan applies to all St. Mary’s University employees and contractors that handle or otherwise work with lead containing material and have risk of exposure to lead through inhalation or ingestion. Exposure to lead can occur when workers inhale or ingest lead dust or fumes during construction activities including but not limited to demolition, renovation, or repair of surfaces or materials containing lead (including painting and decorating). In particular, the use of abrasive blasting, mechanical or manual sanding, manual scraping, manual demolition of structures, heat gun applications, power tool cleaning, welding, cutting and torch burning are covered by this program.

Environmental contamination can occur to air and water through:

• Emission from lead based gasoline spills, storage container venting
• Leaks from UST or AST containing lead-based gasoline and flushing of lead-based paint and/or cuttings from lead plumbing pipe and fitting into water drain.

St. Mary’s is dedicated to providing safe and healthful work facilities for students and employees, and complying with federal and state occupational health and safety standards. Administrators, project managers, faculty, staff and students all share responsibility for minimizing their exposure to lead.  The Lead Management Program applies to all facilities on campus where potential exposure to lead may occur. The Lead Management Program shall be reviewed and evaluated for its effectiveness annually, and updated as necessary.

Regulatory References

• Federal (EPA) – Title 42 Chapter 116, Emergency Planning and Community Right-to-Know Act (EPCRA); 40 CFR Parts 260-265 and 268, Resource Conservation and Recovery Act (RCRA); Federal Dept of transportation (DOT) Hazardous Substances Title 49CFR Parts 117-177
• State (TCEQ) – Texas Administrative Code (Lead Abatement Project Designer: Certification Requirements, Title 25 Part 1 295.209; Texas Environmental Lead Reduction, Title 25 Part 1 295.202
• OSHA – Lead Exposure in Construction, 29 CFR1926.62; Lead Exposure in General Industry, 29 CFR 1910.1025
• Texas Department of State Health Services (TDSHS) – Texas Environmental Lead Reduction Rules applies to target housing and child-occupied facilities (children under 6 years of ago) such as child care facilities and family housing. St. Mary’s University owns and operates four apartments on campus that qualify as target housing. No child-occupied facilities are own or operated on campus.

Duties and Responsibilities

Achieving the goals identified in this plan shall require participation of all leadership personnel affected by this program. This will be accomplished by: providing formal classroom education/training, site specific instruction by supervisors, establishing and following safe work practices, establishing a medical surveillance program, and comprehensive supervisor oversight to ensure components of this program are met. Supervisors & project managers should continuously communicate their expectation of the importance of lead poisoning prevention and monitor work to ensure it is performed in compliance with this program. Supervision of the activities required by the Lead Management Program is the responsibility of the Facilities Services. St. Mary’s may also use the services of an Environmental Consultant to process the lead containing material (Geo International Management).

Specific responsibilities of University personnel are as follows:

Office of Facilities Services shall

• Develop and distribute the written Lead Management Plan
• Provide Lead Safety Awareness training and maintain records of employee participation in training.
• Identify employee and contractor requirements for compliance with applicable Federal and State lead regulations in contract specifications.
• Periodically review the lead management plan and revise as necessary.
• Periodic review for status of Lead Paint Notification to target housing applicability: Chaminade (notified 10/2013); Dougherty (notified 10/2013); Marian (notified 10/2013); and Treadaway (notified 10/2013).

Associate Director, Operations and Construction Management shall

• Maintain Lead Survey information.
• Oversee contracts requiring disturbance of lead-bearing materials;
• Communicate requirements to contractors;
• Verify contractor qualifications / certifications to perform Lead Renovation / Lead Abatement
• Interface with contractors where enforcement of related contract provisions is required;
• Maintain submittal documents and related records from abatement contracts in a manner that is readily retrievable in case of a regulatory inspection;
• Ensure lead waste is managed according to all applicable regulations of this Plan; and
• Ensure that paint used contains less than 0.06% lead, which is considered lead-free by the Consumers Product Safety Commission (CPSC).
• Initiate medical surveillance for any employee who has the potential for exposure to lead as outlined in 29 CFR 1910.1025 or 29 CFR 1926.62;

Facilities Supervisors shall

• Assure employees with potential of exposure to lead have received the appropriate training
• Ensure contractors performing abatement of lead-based paint have completed training through an approved lead abatement program
• Assure employees under contractor supervision follow the lead-based paint work practices described in this program
• Identify potential lead hazards: paint lead, dust lead, and soil lead.
• Comply with safe work practices (lead warning signs, barrier tape if indoors or where pedestrians could be exposed
• Control lead chips/dust (drop cloth, poly tent, source ventilation) during work
• Ensure employees use respiratory protection and personal protective equipment (coveralls) as needed
• Ensure employees use proper hygiene prior to all breaks (hand and face washing) and proper cleaning of work clothing
• Ensure employees use proper cleanup of lead dust/paint chips (wet clean/hepa vac)

Employees shall

• Perform his/her work as safely as possible and follow all work safety procedures;
• Comply with the provisions of the Lead Management Plan and work practices identified for individual tasks;
• Report existing health or safety hazards to the supervisor.

Contractors shall

Comply with any additional requirements for lead handling and management as documented in the Facilities Guidelines for Contractors.

Conditions of Assessment

All buildings on the University campus shall be assessed to determine if a full or partial lead survey is required. The enclosed Lead Survey Master Plan (refer to Table – 1) provides the schedule for lead surveys for the buildings that are covered under the Lead Management Program. In addition to the planned survey schedule, a lead survey shall be scheduled when any of the following conditions are identified:

• Flaking and deteriorated paint is on metal surfaces in buildings constructed prior to 1978.
• Any building or hardscape surface constructed prior to 1978 that will be subjected to sandblasting, grinding or heavy sanding.
• Any building that was constructed prior to 1978 and will be demolished or renovated in whole or part. Renovations will be defined as removing interior walls or parts of walls, ceilings, windows, doors, or door frames.
• Any building or facility in an area of campus (i.e. CEFLC) that regularly deals with children as clients.
• All buildings that were constructed prior to 1978 and have not yet been renovated.

Special Circumstances that May Require a Lead Survey (Assessment):

• At the discretion of the Facilities Services or other designated University representative;
• When proposed maintenance work may expose building occupants and/or residents to lead-containing paint and/or dust;
• When elevated blood lead levels are reported in employees or building occupants /residents;
• When an employee or building occupant experiences symptoms which are indicative of lead poisoning;
• When performing risk assessment activities in University owned buildings;
• When specifically requested by a representative of the Texas Commission for Environmental Quality or other appropriate state agency; and
• When developing the program and/or scope of work for the planned renovation of an existing facility.

The University’s Lead Survey Master Plan is intended to mitigate the risk of exposure to lead materials in campus buildings, especially the buildings constructed prior to 1978. The Lead Survey will follow the Lead Survey sample specification (refer to Construction Standards and Specifications).

Available in the Office of Facilities Services:
Lead Survey Master Plan (buildings constructed prior to 1978

Exposure Determination / Actions

Large Projects (Building Renovations / Abatements):

• Before the project starts, the results of the Lead Survey will be made available to all contractors and employees who will be performing the work or otherwise required to be in the vicinity of the work being performed to determine exposure risk.
• Contractors are required to follow all safety procedures as required based on the level of lead abatement to be performed per the RRP Rule and Lead Renovation / Abatement Certification status.
• University employees will not perform work or work within an area where the lead exposure risk may be greater than the action level (refers to employee exposure, without regard to the use of respirators, to an airborne concentration of lead of 30µg/m³ of air averaged over an 8-hour period).

Small Projects (based on RRP Rule Exclusions (<6 sq ft interior or <20 sq ft exterior):

• University employees will be trained on Advanced Lead Safety Awareness before working in area of potential lead exposure.
• University employees will be trained by a Certified Lead Renovator on proper PPE and work procedures to minimize lead dust and exposure risk. Safe work practices shall include: Segregation of the area to be repaired; minimizing the dust and chips generated due to sanding or grinding; using chemical stripping if practical and waste can be contained for proper disposal; and avoid penetrating to lower layers of paint (lead paint will typically be at the lower surface layers of paint).
• Contractors are required to follow all safety procedures as required per their Lead Renovation / Abatement Certification status based on the level of lead abatement to be performed.

Training

Annual Lead Awareness training shall be made available to all Facilities personnel. Facilities personnel that have the potential to directly handle or otherwise work with lead containing substances in which there is a risk of exposure above the regulatory action levels will require additional safety training Training content, duration, and frequency will be based on the level of work planned and/or anticipated exposure.

Medical Monitoring Program

Initial Medical Surveillance [biological monitoring – blood lead level and ZPP]

St. Mary’s will arrange for medical services to provide initial medical surveillance to any worker occupationally exposed to lead at or above the action level of 30 mcg/m³ for a TWA of 8 hrs or more (at no cost to the employee).

Personal Hygiene Practices

St. Mary’s recognizes that even when airborne lead exposure levels are low, the potential exists for significant lead ingestion due to poor personal hygiene practices. No eating, drinking, application of cosmetics (including lip balm) or smoking is permitted at work sites where lead and lead-based paints are being disturbed. Workers shall wash their hands, arms and faces prior to eating, drinking, applying cosmetics or smoking.

When chemical strippers are used to remove lead-based paint, appropriate impermeable gloves and chemical resistant clothing shall be worn for worker protection as well as safety goggles or face shields to protect the eyes from chemical splashes. Portable eye wash equipment must be available on site. The area where the chemical stripper is being used must be well ventilated to avoid exposure to potentially toxic vapors.

OSHA Record Keeping

All records relevant to the Lead Survey / Renovation/ Abatement work performed will be maintained by the Facilities Services Office per University record retention policy.

Waste Disposal Requirements

All disposal of lead-contaminated waste generated on site shall be approved by Facilities personnel. The disposal service provider will provide documentation to verify segregation, packing, labeling, and management of these waste materials per federal, state, and local regulatory requirements. Hazard material generated from any St. Mary’s project shall only be transported using the routes on campus that have been authorized by Facilities and the University Police Department.