Back to Basics is an article series that highlights important, but possibly overlooked, information facilities management professionals should know.
Facilities professionals seeking to renovate older buildings should do their due diligence to determine if their buildings have lead paint.
Why Lead Paint Is Dangerous
The dangers of lead-based paint (LBP) caused the federal government to ban the purchase of it in 1978, but some states prohibited these purchases even earlier. However, these bans did not address the presence of LBP.
According to the Occupational Safety and Health Administration (OSHA), lead paint is dangerous because exposure can damage the central nervous system, cardiovascular system, reproductive system, hematological system, and kidneys. Long-term exposure can even result in death.
LBP is especially dangerous to children when it is disturbed. The U.S. Environmental Protection Agency (EPA) reports that decades ago, people were concerned that children could be poisoned by eating lead paint chips. Newer research shows that the most common way children experience lead poisoning is by inhaling or ingesting the microscopic dust.
As a result, the EPA created several rules regarding lead-safe renovations, education, and disclosure of hazards, and violators can be subject to both criminal and civil penalties.
Facilities professionals doing a renovation, a repair, or repainting work on a pre-1978 hospital, childcare facility, school, apartment, or extended-stay hotel suite that is also a “child-occupied facility” need to follow the Lead Renovation, Repair, and Painting Rule (RRP) of 2008, which requires facilities professionals to hire a lead-safe certified contractor. To be certified, individuals need to attend a full-day course from the EPA on renovation, repair, and painting.
A child-occupied facility can be any building that is visited by a child under 6 years of age at least 2 days a week, with a visit lasting at least 3 hours and combined visits lasting at least 6 hours. This can be in either a public or a commercial building.
OSHA requires other public and commercial facilities to have properly trained personnel when performing renovations that could disturb lead paint.
Consequences of Not Following the Law
Failure to hire a lead-safe certified technician could result in fines of up to tens of thousands of dollars.
In fact, property managers of rental properties, especially those in underserved or overburdened communities, should be aware that the EPA now has stronger enforcement and compliance regulations. To learn more, read “Building Managers on the Hook for Lead Paint Safety Requirements” on Facilities Management Advisor.
The EPA wants to make sure that everyone is on the same page when it comes to lead paint abatement. It recently issued $149,000 fines to companies giving the wrong information on television. For more details, check out “Avoiding Lead Paint Renovation Fines” on EHS Daily Advisor.
Exceptions to the Law
Minor repair and maintenance activities are exempt from the requirement to have lead-safe certificate training.
According to the EPA, these include:
- 6 square feet or less per interior room
- 20 square feet or less per exterior project
The exception does not:
- Apply to window replacement.
- Allow dust to leave the work area.
- Allow the burning of open flames or the use of heat guns at more than 1,100 degrees Fahrenheit.
- Permit the use of power tools without high-efficiency particulate (HEPA) exhaust control to collect dust.
However, when in doubt, call in the professionals because improper work could lead to even larger hazards.
Methods of Abatement
Properly trained facilities professionals should first run a lead risk assessment to determine whether the property has lead paint, as well as select the proper personal protective equipment (PPE) and disposable overalls before entering the work area.
Choose one of the following ways to abate lead paint:
- Enclosure. Use a flexible wall covering, paneling, or gypsum board.
- Paint removal. Be aware this can lead to lots of dust, fumes, and mists.
- Replacement. Remove and replace the object with new material. This is the best way to deal with doors, windows, and moldings.
- Encapsulation. Cover and seal lead paint with a special coating.
When leaving the work area, remove loose dust using a vacuum with a HEPA filter, roll off PPE, and clean respirators with soap and water. Be sure to also properly clean the abatement area.
Disposing of Lead Waste
Properly trained individuals should dispose of lead waste in noncorrosive containers that are marked “Danger—Lead Hazard.”
Types of lead waste can include, but are not limited to:
- Paint chips
- Removed woodwork
- Plastic bags, sheeting, and duct tape
- Used cleaning supplies
- Disposable work clothes, masks, and respirator filters
Facilities professionals should ensure they properly abate lead paint, not just to follow the law but also to ensure the safety of building occupants.
The information contained in this article is provided for informational purposes only and should not be construed as legal advice.