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Second Quarter 2014

A Subcontractor Guide to Lead Abatement

Lead in construction is a complex issue involving multiple factors, OSHA standards, and work practices.  This guide is to serve as informational only, as it in no way covers every scope of work or safe work practice that may be required while working with or around lead hazards.

Lead Abatement Procedures

Assessment of Conditions


There are certain procedures to be followed when determining the existence of lead and lead-based paint and assessing the risk to employees and /or building occupants. The following situations may initiate the need for assessment:

Lead exposure from normal maintenance work, which might include lead containing materials such as solder or lead-based paint, and which falls under OSHA 29 CFR 1926.62, will be initially monitored to assess employee exposure levels. Depending on the exposure levels, steps as specified in OSHA 29 CFR 1926.62 will be taken. Lead determination in materials such as solder may be based on material safety data sheet (MSDS) information. If MSDS is not available, lead exposure may be estimated from past assessments. For lead-based paint, use the methods specified under Monitoring and Sampling.

In reference to abatement of lead-based paint, assessments may be made:

·         At the discretion of the Project Manager, or other designated Subcontractor 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 specifically requested by a representative an appropriate state agency; and

·         When developing the program and/or scope of work for the planned renovation of an existing facility.


Monitoring and Sampling


This section covers lead-based paint abatement. For construction and renovation monitoring and sampling, refer to the previous section, Assessment of Conditions.

Generally, buildings constructed after 1978 can be assumed to be lead-free. For buildings constructed prior to 1978, lead-based paint assessments must be performed for any surface that will be disturbed and is suspected of containing lead-based paint except where it is documented that the building received a complete interior renovation after all interior components were demolished and removed from the structure. Lead-based paint located under newer coatings must also be identified. The assessment may use any of the following methods:

·         Referencing existing building surveys, construction notes or as-built drawings may be used where the surfaces involved are referenced. Renovation file notes and updated drawings may be used to identify surface replacements.

·         Substrate testing using an XRF in-paint analyzer, a lead swab, or by collecting a sample of the intact paint and submitting it to an accredited laboratory for lead analysis.

·         Dust wipe tests.

·         Lead testing on the windows and floors on surfaces in question.

·         Visual inspection of condition of paint.

·         Soil tests for lead contamination.

If a lead-based paint inventory exists for the surfaces involved in the work, Project Managers shall refer to the inventory for the location of lead-based paint. If an inventory does not exist, and the building was constructed or renovated prior to 1980, substrate testing will be required to ascertain the existence of lead-based paint. If possible, reference should be made to as-built drawings to ascertain the location of lead-based painted structures.

X-ray Fluorescence (XRF)

XRF is used to identify lead content of flat surfaces. It is the sampling method of choice because it is accurate, results are immediate, and replaces the time-consuming method of obtaining a paint chip sample and analyzing it in a laboratory. Direct reading XRFs provide the operator with a readout of lead concentration in paint in terms of lead per square centimeter (cm2).

Before an XRF is used, the technician shall have passed an instructional seminar demonstrating the correct use of the instrument. Since the instrument uses a radioactive source, all UM technicians must shall be entered in the UM Radiation Safety Program.

Paint Chip Sampling

Paint chip sampling may be used to:

·         Clarify an inconclusive XRF result.

·         Test a surface that does not lend itself to XRF instrumentation, as defined by the instrument's manufacturer (for example, moldings, windows, playground equipment, and other surfaces that are not flat).

·         Determine the percent of lead to identify material that must be disposed as a hazardous waste. (However, the material must be tested according to Toxicity Characteristic Leaching Procedures (TCLP).

Spot Testing Using Sodium Rhodonzonate (Lead Swabs)

This method is not intended to measure the concentration of lead but to determine if lead is present. A color change as specified in the test kit directions (i.e., pink) indicates the likely presence of lead paint. The test can alert the user to the presence of lead in paint so that proper precautions can be taken while removing it. If when using this type of spot testing no color change occurs, this should not be interpreted as the absence of lead.

Accordingly, before concluding an area or surface does not contain lead-based paint, XRF or paint chip sampling is required.

Surface Wipe Testing

Surface Wipe Testing may be required under the following conditions:

·         To perform a risk assessment of UM buildings, such as residential or day care centers, particularly those buildings which are occupied by young children;

·         To determine the effectiveness of work practices and/or decontamination activities.

Exposure Monitoring

Exposure monitoring should be conducted for activities involving the disturbance of lead-based paint, unless the same type of job has been assessed previously. In this case, a review of the previous assessment can be used to decide if additional monitoring is necessary.

Exposure Monitoring

If the assessment determines that lead exposure should be monitored, personal exposure monitoring may be conducted. Monitoring and Sampling and analysis will be performed in accordance with NIOSH Method 7082, Sampling Airborne Particulate for Lead. Analysis will be conducted by an American Industrial Hygiene Association accredited laboratory. Results in excess of the Action Level (AL) will require additional employee protection measures in accordance with either OSHA 29 CFR 1926.62 or OSHA 29 CFR 1910.1025, depending how the work is classified, that is, construction or general industry.

Exposure monitoring will be performed by a representative of the Department of Environmental Safety for maintenance work performed by University employees. Exposure monitoring for private contractors’ employees will be performed by an independent industrial hygiene consultant coordinated by the Project Manager.

As required by the Project Manager, area samples may be taken during large scale maintenance work to determine if lead particulates are infiltrating into occupied spaces. Sampling and analysis will be performed as described above. Results in excess of the AL of 30 µg/m3 will require additional employee protection measures as outlined in Personal Hygiene Practices, Respiratory Protection, and Appendix C of this Plan.

Medical Surveillance


In accordance with OSHA 29 CFR 1910.25 and 1926.62, employees who are performing construction work and are occupationally exposed on any day to lead at or above the AL, shall have initial medical surveillance consisting of biological monitoring in the form of blood sampling and analysis for lead and zinc protoporphyrin (ZPP) levels. This will be provided by Subcontractor choice of an Occupational Health Center. Additionally, employees who are or may be exposed at or above the AL for more than 30 days in any consecutive 12 months will be offered the following medical surveillance:

·         blood sampling and analysis at least every 2 months for the first 6 months and every 6 months thereafter;

·         workers with blood lead levels at or above 40 ug/dl will have a blood test at least every two (2) months until two (2) consecutive tests (a week apart) show levels less than 40 ug/dl;

·         if an employee is medically removed due to elevated blood lead levels, a second (follow-up) blood sampling must be performed within two weeks after the employer receives the results of the first test; and,

·         blood tested upon termination of employment.

A ZPP is required on each occasion that a blood lead level measurement is made.

Employees will receive the confidential results of blood tests through the Occupational Health Unit. All medical records remain confidential unless the employee grants permission for his/her records to be released. However, the employee's supervisor will both be notified of an employee’s fitness to continue performing lead work and in the event of an employee's blood lead level exceeds 40 ug/dl so that the employee may be moved or transferred to another area until blood lead levels decrease as verified through subsequent blood testing. Environmental Safety will investigate the work practices used to determine why the employee's blood tested high for lead.

In accordance with OSHA 29 CFR 1910.1025, employees not working in construction shall have medical surveillance if they are exposed above the AL for more than 30 days per year. Employees will be offered the following medical surveillance:

·         Blood lead and ZPP analysis shall be performed at least every 6 months.

·         At least every 2 months for each employee whose last blood sampling and analysis indicated a blood lead level at or above 40 µg/dl of whole blood.

·         The frequency shall continue until two consecutive blood samples and analyses indicate a blood lead level below 40 µg/dl of whole blood.

·         At least monthly during the removal period of each employee removed from exposure to lead due to an elevated blood lead level.

·         Whenever the results of a blood lead test indicate that an employee's blood lead level is at or above 60 µg/dl and the employee is exposed to lead at or above the action level, the employer shall provide a second (follow-up) blood sampling test within two weeks after the employer receives the results of the first blood sampling test.

Medical Consultation

A medical examination shall be provided to each person enrolled in the lead medical surveillance program if at any time the individual experiences symptoms consistent with lead intoxication, needs consultation concerning the potential effects of past lead exposure or on the ability to procreate or carry a healthy child, or has difficulty breathing during fit-testing or the use of a respirator. The examination shall be conducted annually for any individual who has had a blood-lead level of 40 ug/dl or greater or has been medically removed in the past 12 months. The content of the physical exam shall be at the discretion of the attending physician but shall include at a minimum the elements listed in OSHA 29 CFR 1926.62 (j) (3) for construction workers or OSHA 29 CFR 1910.1025 (j)(3) for workers not involved in construction.

Enrollment Information

The supervisor must provide the Occupational Health Unit with the following information with each new employee enrolled:

·         A description of the affected employees duties as related to potential lead exposure;

·         The employees anticipated exposure level to lead and other toxic substances (if applicable); and

·         A description of personal protective equipment to be used.

The employee must provide the attending physician with prior blood lead determinations and written medical opinions related to lead exposure.


OSHA prohibits prophylactic chelation except by a licensed physician and conducted in a clinical setting with thorough and appropriate medical monitoring.


Medical Removal Protection

Any employee who has a blood lead level of 50 ug/dl or more shall be excluded from work with potential for lead exposure until the employee has had two (2) consecutive blood samples at or below 40ug/dl.

An employee may also be excluded from lead-related work when written results of a medical consultation determine that the employee may be at increased risk of impairment to the employees' health from exposure to lead. The employee may return to former duties upon receipt of a written opinion from the consulting physician that the conditions placing the employee at increased risk are no longer present or of material concern.

Where the employee is unable to return to normal duties within 18 months, the Occupational Health Unit shall make a final determination based upon the employees medical evaluation identifying conditions that could allow an employee to safely return to work or a final medical determination that the employee is incapable of ever safely returning to work. In the event that the employee is found incapable of performing lead-related work, the employee's department shall attempt to find an alternate job assignment in the employee's job classification that does not have lead exposure. In the event that no acceptable alternate assignment can be found, the employee's options shall be reviewed. These may include disability retirement, termination, or other options as determined by Personnel Services.


Personal Hygiene Practices


Subcontractor 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.

Respiratory Protection


Workers engaged in lead work will require respiratory protective equipment when industrial hygiene air monitoring indicates anticipated exposures in excess of the PEL.

The use of respiratory protection shall be in accordance with OSHA 29 CFR 1910.134, Respiratory Protection. All workers must be medically evaluated by the Occupational Health Unit to determine the ability of the worker to perform the work while wearing a respirator. Training in the care, use and fitting of the respirator in addition to fit-testing is conducted by the Safety Director for those employees who are medically authorized to wear a respirator. Any worker who is not authorized by the Occupational Health Unit to wear a respirator will be prohibited from engaging in activities which may expose the worker to airborne lead if exposures are anticipated to exceed the OSHA permissible exposure level.

All employee respirators worn at the work site must be placed in a plastic bag prior to leaving the site and thoroughly cleaned before being worn again. Cleaning should include inspection of the respirator and replacement of worn parts. Fit-checks should be done each time the respirator is worn. The medical exam, fit-test and training must be repeated annually.

Respirators shall be selected as follows:

Airborne concentration of lead

Required respirator1

Not in excess of 50 µg/m3

Half-mask air-purifying respirator equipped with high efficiency filters2,3.

Not in excess of 250 µg/m3

Full facepiece, air-purifying respirator with high efficiency filters3.

Not in excess of 500 µg/m3

(1) Any powered, air-purifying respirator with high efficiency filters3; or
(2) Half-mask supplied-air respirator operated in positive-pressure mode2.

Not in excess of 1000 µg/m3

Supplied-air respirators with full facepiece, hood, helmet, or suit, operated in positive pressure mode.

Greater than 1000 µg/m3, unknown concentration or fire fighting.

Full facepiece, self-contained breathing apparatus operated in positive-pressure mode.

  1. Respirators specified for higher concentrations can be used at lower concentrations of lead.
  2. Full facepiece is required if the lead aerosols cause eye or skin irritation at the use concentrations.
  3. A high efficiency particulate filter means 99.97 percent efficient against 0.3 micron size particles.


Occupant Health and Safety


Disturbance of lead paint surfaces within a building's interior should only occur under proper work controls. Methods of controlling lead exposure to other occupants may include isolating the area by use of plastic sheeting and sealing all ventilation ducts in the area of the work and/or turning off and securing the ventilation system (lockout-tagout). Other methods to minimize distribution of lead dust may include wet sanding and the use of HEPA vacuum cleaners. (See Work Practices Section).

Notification to Building Occupants

Prior to the initiation of any large scale interior or exterior work involving lead-based paint, the Project Manager will forward lead-based paint information to the appropriate department chair or director. This bulletin will contain the general scope of work to be done, dates for the start and proposed completion of the work, and the precautions which will be employed to protect building occupants. This bulletin will also alert staff to the increased hazard that lead contamination may present for pregnant or nursing women. Based on a determination by the Project Manager in consultation with Environmental Safety, further measures to reduce potential lead exposure, will be taken if necessary.




Warning signs shall be posted at each job site where the employees exposure to lead is above the PEL. Where an exposure assessment has not been completed, signs shall be posted until the results are known. The signs shall consist of the following wording:

Lead Work Area
No Smoking, Eating of Drinking

for further information contact (Supervisor's name, location, phone)



Work Practices


Work practices have been divided into 3 categories:

  1. Operations and Maintenance (O&M) tasks that have been assessed and do not require any precautions and/or protective measures. (See Appendix A)
  2. Operations and Maintenance (O&M) tasks that have not been assessed and may require precautions and/or protective measures. (See Appendix B)
  3. Operations and Maintenance (O&M) tasks that may require other precautions and/or protective measures. (NIBS Work Practices) (See Appendix C).

Acceptable Practices (Do's)

  • If the condition of an interior or exterior surface (e.g. walls, trim, ceiling, doors, etc.) does not require sanding or scraping prior to repainting, and the surface is in good condition, the surface may be painted even if the paint has not been tested to determine its lead content.
  • Doors or other building components which can be removed without disturbing the painted surface can be removed without the use of any special protection or requirements. The disposal of these items if found to contain lead must be disposed of according to the requirements specified in the Waste Disposal Section.
  • If air monitoring has not been performed to characterize the job, it should be performed at the start of the job.
  • If a lead-based painted surface is flaking or peeling, the loose paint may be removed using wet scraping. This involves wetting the surface to be scraped (in addition to the scraping tool) with water during the entire process.
  • If an interior surface must be scraped, the area will be vacated of all occupants prior to the initiation of any work and all furnishings shall be removed from the area or covered with 6 mil plastic, the floor covered with 6 mil plastic and the area secured to limit access . For exterior scraping, windows and doors in the immediate area should remain closed and secured until the preparation and required cleanup is complete.
  • Window sills and the floor beneath it in residential buildings should be HEPA vacuumed, washed with trisodium phosphate (TSP) and re-vacuumed following any LBP work
  • When dust or debris from a window or other opening may contaminate an exterior area, 6 mil plastic sheeting must be securely fastened to the ground next to the work area. The ground should be covered and weighted with sheeting at least five (5) feet from the side of the building and extend three (3) feet per story being abated.
  • Employees involved shall wear protective clothing as described in Personal Hygiene Practices.
  • Return air vents in the room or immediate area shall be covered.
  • Debris and contaminated clothing shall be collected, placed in 4-mil plastic bags and disposed according to Waste Management practices. Debris should be sprayed with water prior to sweeping and placed in 4-mil plastic bags. A HEPA vacuum should be used to remove any visible dust from interior/exterior surfaces.

Unacceptable Practices (Don'ts)

  • Dry sanding.
  • Allowing dust to become airborne.
  • Circulating dust through the ventilation system.
  • Lead contamination of the floor/ground surrounding the work.







Appendix A

Lead-Based Paint (LBP) Deminimus Activities

  1. Removal of nails, screws, picture hangers, or other fasteners, etc. from a painted wall surface.
  2. Removal of cover plates, switch covers, etc. from a painted surface.
  3. Removal of hinge pins or painted door hinges.
  4. Removal of lock hardware, closers, or other hardware accessories from a painted door.
  5. Wet sanding drywall compound or spackle using a sponge.
  6. Separating and removing shoe mold (base shoe) from a painted baseboard.
  7. Planing painted wood with manual tools.
  8. Drilling or preparing a painted door from installation of new door hardware (lock set, closers, kick plates, etc.)
  9. Renailing or refastening loose building trim, moldings or panels.
  10. Reglazing of window glass.
  11. Removal of painted phone line or electrical wire.
  12. Freeing an inoperable window.
  13. Housekeeping including emptying trash, vacuuming carpets, dust mopping hallways, cleaning water fountains, buffing floors, disinfecting bathrooms.
  14. Maintenance including replacing air filters, replacing toilet flush valve, replacing light bulbs, checking and repairing shower valves, unclogging a shower drain using a "snake", mechanical repair of an air-conditioning unit, and repairing a shower leak.
  15. Carpentry activities including removing wooden windows to measure to make screens, sweeping out the carpentry shop, planning the edge of a door and re-install the hinges, re-hang the door, removing outside entrance door, removing the kickplate, and removing the screws.
  16. Carpentry activities including removing door hinges and lockset and replacing.
  17. Carpentry activities including sanding floor with "stand-behind" power disc sander, scraping floor near corner, clean-up of debris and placing debris in container.
  18. Carpentry activities including wet hand scraping and wet sanding a column
  19. Carpentry activities including removing wooden baseboards, cut and pull up wall-to-wall carpeting, scrape walls near baseboard, scrape carpet adhesive residue from floor, sweep floor.
  20. Carpentry activities including removing window casing and wooden molding, removing the window sash, heating the glazing, scraping and removing the softened glazing, re-installing the sash, rehanging the window, and installing the wooden molding.
  21. Removing old plaster and re-plastering, manually sanding new plaster.
  22. Maintenance activities including wet scraping of window and door.
  23. Plumber activities including manually removing old lead and oakum from around shower drains, heating lead in an open ladle using a propane torch, pouring the molten lead from the ladle into the cavity surrounding the drain, rapidly cooling the unused hot lead using cooling water from a sink faucet
  24. Chipping and sanding plaster.
  25. Painter activities including spreading plastic material around the hot-water radiator and wet scraping old paint from hot-water radiator, folding up the plastic on the floor, broom sweeping the floor.




Appendix B

Non-Assessed Tasks

Operations in Appendix A where the activity has not been assessed, for example, where an operation is performed many times during a shift, such as drilling multiple holes to install screening on multiple windows.





Appendix C

Operations and Maintenance (O&M) Tasks on LBP That May Require Precautions And/Or Protective Measures.
(National Institute of Building Sciences (NIBS) Work Practices)

Cleaning Damaged or Deteriorated LBP Surfaces
Removing LBP Chips and Debris
Removing Small Areas of LBP
Wet Sanding of LBP
Penetrating LBP
Removing Components from LBP Surfaces
Attaching to a LBP Surface
Applying Coatings to LBP Surfaces
Installing Materials Over LBP Surfaces
Enclosing a LBP Surface
Patching a LBP Surface
Exposing LBP Contaminated Cavities
LBP Door and Window Maintenance
Changing Filters and Waste Bags in LBP Contaminated HEPA Vacuums
Cleaning Lead Dust Contaminated Carpet
Landscaping in Soil Containing Elevated Levels of LBP

Each Work Practice comes with three levels of protection, depending on the scope of the task, how long the work will continue, and especially the condition of the LBP and substrate which will be disturbed.
The higher the Level of activity, the higher the level of preparation and worker protection required.
Level 1 is described as those activities requiring a minimal amount of preparation and worker protection because a negligible amount of lead dust may be generated or disturbed.
Level 2 consists of activities producing moderate amounts of dust and debris.
Level 3 are activities which could generate substantial quantities of dust and debris.

Complex activities not specifically described in the work practices can usually be performed by modifying and combining various parts of several different work practices. For example, to replace a metal fireplace unit might require the following combination of work practices:

Removing LBP Chips and Debris
Removing Components from LBP Surfaces
Attaching to a LBP Surface
Patching a LBP Surface
Exposing LBP Contaminated Cavities



"Occupational Safety and Health Administration." Occupational Safety and Health Administration. N.p., n.d. Web. 24 Mar. 2014.


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