Environment, Health and Safety Manual - Chapter 05.23: Lead-Based Paint Hazard Policy


Environment, Health and Safety Manual - Chapter 05.23: Lead-Based Paint Hazard Policy


Lead is a heavy metal that can produce harmful health effects to people of all ages. The effects of lead exposure have been known for centuries, and, to ensure that employees are not exposed to high levels of lead in the workplace, the Occupational Safety and Health Administration (OSHA) has created a Lead Construction Standard, 29 CFR 1926.62, to keep employee’s exposures below a permissible exposure limit (PEL). Lead can be found as an ingredient in many substances but was widely added to paint prior to 1978 for stabilization and longevity of the paint. Employees responsible for removing damaged lead containing paint, and for repainting in buildings constructed prior to 1978, must be protected from elevated exposures to lead.


Abatement: The removal of lead-based paint from target housing and child occupied facilities. These facilities have additional regulations dictated by the Environmental Protection Agency (EPA) that must be followed.

Action Level (AL): The limit set by OSHA in which several protective measures become mandatory. This level is set at 30 micrograms per cubic meter (µg/m3).

Exposure Assessment: A determination based on air monitoring data that decides if employees are exposed above the AL. A positive exposure assessment invokes numerous provisions of this program, including respiratory protection and medical surveillance.

Lead-based paint: Paint containing 1 milligram per square centimeter (mg/cm2) or more of lead as measured by x-ray florescence. For the purposes of this program, this definition will only be applicable in target housing and child-occupied facilities.

Lead-containing paint: Paint that contains any detectable level of lead.

Medical Surveillance: A program to ensure employees health is being maintained during exposure to lead paint.

Paint stabilization: The removal of damaged paint using scraping tools and the addition of a new paint layer to prevent further deterioration.

Permissible Exposure Limit (PEL): OSHA has established a maximum level governing how much lead employees can be exposed to. This limit is set at 50 µg/m3.

Representative Building: A campus building that has paint with similar lead content to other campus buildings.

Lead Testing

Paint removal projects must be reviewed by EHS so that paint can be tested for lead content. Testing is conducted by the EHS Industrial Hygienist using an XRF Lead Paint Analyzer. In order to request testing of paint involved in your project, please submit an online Request for Hazardous Material Inspection/Sampling Form. Following testing, the EHS Industrial Hygienist will contact you with the results and notify you of the requirements moving forward. The EHS Industrial Hygienist may also need to come to the worksite to perform monitoring of campus employees conducting the work to establish an exposure assessment.

Exposure Assessment

Employees exposures to lead must be determined using air monitoring utilizing NIOSH sampling method 7300. The EHS Industrial Hygienist must perform monitoring at least once per year. Monitoring must be conducted using a representative sample of employees performing paint stabilization on a representative building. The EHS Industrial Hygienist must conduct new monitoring if employees are assigned to perform new tasks that are outside of the scope of previous monitoring. The EHS Industrial Hygienist must maintain all monitoring records. An employee requesting access to historical monitoring data must do so in writing to document the request.

Protective Measures

The following protective measures must be implemented for employees performing paint stabilization:

  1. Personal Protective Equipment (PPE): Employees must use PPE throughout the paint stabilization process, including during cleanup of materials. PPE to be worn include:
    • Air purifying respirator with P100 cartridges on projects where the AL is surpassed or if exposure monitoring has not been conducted for the task.
    • Safety glasses
    • Tyvek suits
    • Booties
    • Nitrile gloves
    Employees must use the processes outlined in Appendix B to put on and remove disposable PPE. Disposable PPE, including Tyvek suits, booties, and nitrile gloves may be used for up to one shift
  2. Manual Tools: Employees must use manual tools, such as scrapers and sandpaper, when removing old paint.
  3. Wet Methods: Employees must mist old paint that is being removed with water to minimize the production of dust.
  4. Containment: Employees must place 6-mil plastic sheeting from beneath the point of work to five feet away. The sheeting must be taped on all sides. Barriers must be set up to prevent unauthorized individuals from entering the work area.
  5. Cleanup: PPE must remain on during cleanup activities. All disposable materials must be gathered in the center of the plastic sheeting and the sheeting must be folded inward to contain debris. The sheeting must be misted with water during cleanup to prevent aerosolization of dust. All waste must be placed in a 55-gallon drum provided by EHS. All surfaces affected must be cleaned using wet wipes and a HEPA vacuum. Following the cleaning process outlines in Appendix.

Prohibited Practices

The following lead removal practices are prohibited:

  1. Abrasive blasting
  2. Torch or flame burning
  3. Heating with heat guns above 1100˚ Fahrenheit.

Respiratory Protection

If employees are exposed to lead above the action level, those employees must be enrolled in a mandatory respiratory protection program. If employees are exposed to lead below the action level, those employees may choose to wear respiratory protection, provided they have been medically evaluated to do so and have been given Appendix D of 29 CFR 1910.134.

Medical Surveillance

If employees are exposed to lead above the action level, those employees must be enrolled in a medical surveillance program. The medical surveillance program will be administered by the University Occupational Health Clinic. Medical surveillance will include testing for blood lead and zinc protoporphyrin levels. Testing must occur every two months for the first six months following exposure above the action level, and every six months thereafter. Employees who are found to have a blood lead level above 50 micrograms per deciliter (µg/dL) must be removed from paint stabilization activities. The employee may be allowed to return to paint stabilization activities after two consecutive blood tests have showed levels below 40 µg/dL.

Workplace Hygiene

Employees must not eat, drink, or apply cosmetics when working in the containment area. Employees must wash their hands thoroughly following work activities.

EPA Compliance in Select Buildings

Certain buildings owned and operated by the University have additional EPA regulations to follow. These regulations pertain to renovation, repair, and painting (RRP) in housing and child occupied facilities constructed prior to 1978. The University owns and operates several buildings falling into this category. To maintain these buildings, the University is registered as a RRP firm with the North Carolina Health Hazards Control Unit (NC HHCU). This registration is renewed each year. In order to be a registered firm, the University designates a certified lead renovator, who has taken specialized training to ensure compliance with these regulations. The certified lead renovator is the EHS Industrial Hygienist. The certified lead renovator supervises the RRP work conducted in covered buildings to ensure compliance with EPA regulations.

Contact EHS for additional guidance if the work includes disturbing more than six square feet (ft2) of paint, .

Hazard Communication and Training

Employees exposed above the action level must receive training on the health effects of lead, how to protect themselves from exposure, how to properly utilize PPE, the requirements of the medical surveillance program, and the OSHA lead standard. Employees must be trained upon initial assignment and at least annually thereafter. Employees who are discovered to not be following proper protective measures must be retrained. Training will be provided in the form of EHS Online Course # 7501 ("Lead in Construction"). Employees conducting work in buildings covered by the EPA RRP regulation must also take the online RRP course 4522. A generic safety data sheet for lead is attached to this policy as Appendix A.


Contractors disturbing lead-containing paint must adhere to the OSHA Lead Construction Standard, 29 CFR 1926.62. Contractors hired to perform abatement in applicable EPA regulated buildings must be certified by the NC HHCU. Lead abatement contractors must provide an abatement plan to the EHS Industrial Hygienist for review and must follow all applicable federal and state regulations.

The abatement plan must contain the following information:

  • how lead-based paint will be abated,
  • how contractor employees and University members will be protected,
  • how regulations will be followed, and
  • a timetable for the project.

The EHS Industrial Hygienist must be notified prior to the commencement of work so that containment areas can be inspected and approved. The EHS Industrial Hygienist may inspect contractors at any time during the project to ensure compliance with all applicable laws, regulations, and policies. The contractor must perform all post-abatement wipe sampling and provide the data to the EHS Industrial Hygienist. A list of certified abatement contractors can be found at the NC HHCU website.

Please refer to section "A-32: Environmental Demolition and Remediation" of the University's Design and Construction Guidelines for additional information.

Appendix A: SDS for Lead

Please see the attached PDF.

Appendix B: Procedures for Putting On and Removing PPE

Putting On

  1. If required or if used voluntarily, place your respirator on your face, pulling the straps tight around your head to ensure a good fit. Perform a fit check, placing your hands over the filters and attempting to breathe in. If air comes in from around the seal of the respirator, adjust the respirator and tighten the straps.
  2. Put on your safety glasses if not wearing a full-face respirator.
  3. Put on your Tyvek suit, ensuring that the hood of the suit covers the seal of your respirator.
  4. Place the booties over your shoes. Secure the booties to your shoes using tape.
  5. Place nitrile gloves on your hands. Move the sleeve of the Tyvek suit over the gloves and tape the seam.


  1. While remaining on the 6-mil plastic, remove the tape connecting your booties to your Tyvek suit. Place in the center of the plastic sheeting.
  2. At the edge of the plastic sheeting, remove the booties from your feet, being careful not to step onto the plastic sheeting with your uncovered foot. Place booties onto the plastic sheeting.
  3. Remove the tape connecting your gloves and your Tyvek suit. Place tape on the plastic sheeting.
  4. Remove your Tyvek suit, being careful to turn the suit inside out during removal. Place on plastic sheeting.
  5. Remove your gloves, turning them inside out and touching only the inside of the glove during removal.
  6. Remove your respirator, pulling off the respirator by the straps.

Related Requirements

External Regulations

University Policies, Standards, and Procedures

Contact Information

Policy Contacts

Catherine Brennan, Executive Director
Department of Environment, Health & Safety
Phone: 919-843-5331
Email: crbrennan@ehs.unc.edu

Back to Chapter 05.22 - Indoor Air Quality Policy

Proceed to Chapter 06.01 - Occupational Health Requirements for University Employees Located in Healthcare Facilities

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Article ID: 131976
Thu 4/8/21 9:21 PM
Thu 8/31/23 4:18 PM
Responsible Unit
School, Department, or other organizational unit issuing this document.
Environment, Health and Safety
Issuing Officer
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Executive Director
Next Review
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08/08/2024 12:00 AM
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08/08/2023 12:00 AM
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08/08/2023 12:00 AM
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08/08/2023 12:00 AM
Date on which the original version of this document was first made official.
08/01/2001 12:00 AM