SEC-008: Lead-Based Paints Management

Date: 06/30/2005 Status: Final
Last Revised: 07/18/2011
Policy Type: University
Oversight Executive: Vice President for Research
Applies To: Academic Division and the Medical Center.
Table of Contents:

Policy Statement

Reason for Policy:

To prevent harmful exposure to lead and to ensure compliance with all local, state and federal regulations, including OSHA 29 CFR 1926.62, OSHA 29 CFR 1910.1025, EPA 40 CFR 260-270, the Virginia Administrative Code and the Virginia Department of Professional and Occupational Regulation.

Policy Summary:

All Lead-Based Paints within University buildings must be properly managed.

Definition of Terms in Statement:
  • LBP Abatement Activity:

    The total removal of LBP or LBP hazard from a UVA residential property by a State Licensed LBP Abatement Contractor with Licensed Abatement Workers and Supervisors using methods specified by a State Licensed LBP Abatement Project Designer.

  • LBP Abatement Activity Monitoring:

    Daily inspections of lead abatement activities, which include confirming integrity of work site enclosures, abatement equipment, worker credentials, regulatory and specifications compliance, and taking air and settled dust samples during and after abatement to insure a healthy environment for UVA housing residents.

  • LBP Inspection:

    Inspection of a building, portion of a building or other painted surfaces by a State Licensed LBP Inspector/Risk Assessor, which includes taking paint chip samples of suspected LBP for analysis by an accredited laboratory, or analyzing the painted surface on-site by use of an XRF meter, and a report summarizing the lead concentrations and locations of identified LBP.

  • LBP Management Activity:

    Any activity that involves the incidental disturbance of LBP, including repair, surface preparation or repainting of surfaces that contain LBP, or the removal/disturbance of building components containing LBP. This does not require State-Licensed Contractors, Workers or Supervisors, but does require OSHA and EPA compliance.

  • LBP Risk Assessment:

    An assessment performed by a State Licensed LBP Inspector/Risk Assessor of the condition of LBP and the relative hazard potential resulting from its presence. This assessment includes a combination of visual inspection of painted surfaces, settled dust testing, soil testing and a report detailing the results and plans for proper in-place management to insure the safety of building residents, occupants, visitors and maintenance/custodial personnel, until such paints are properly removed.

  • Lead–Based Paints:

    Paints that contain greater than 0.5% lead by laboratory paint chip analysis, or greater than 1 mg per square centimeter by portable X-ray fluorescence (XRF) meter analysis.

  • Project Manager:

    University of Virginia representative who may be the Facilities Management Project Manager, Maintenance Superintendent, Cost Center Manager, or other person who either oversees, plans, supervises or arranges for a maintenance, construction, renovations or demolition project within University of Virginia facilities.

Policy Statement:

All Lead-based Paints (LBP) within University buildings must be properly managed. Any University building or architectural component built prior to 1978 may have high concentrations of lead in the paints. All such painted surfaces must be presumed to contain lead at regulated concentrations until properly tested and proven otherwise.

Environmental Health & Safety (EHS) maintains records of all past LBP inspections within University buildings and miscellaneous components, and all past residential LBP abatement activities. EHS provides lead awareness training to maintenance and renovations employees to inform them of the health hazards of LBP, proper procedures for safely working with materials containing LBP, use of personal protective equipment, engineering controls, and clean-up and disposal of LBP debris.

To prevent accidental disturbance of LBP, which could lead to air-borne or settled lead dust hazards, EHS performs inspections prior to maintenance, repainting, renovations or demolition projects to determine the concentrations of lead in paints. Disturbance of surfaces with regulated concentrations of LBP must either be avoided during the projects or properly controlled during these projects. If LBP hazards abatement is necessary, EHS designs and monitors these activities.


All UVA faculty, staff and students must follow these procedures in buildings constructed prior to 1978:

  1. Prior to any maintenance, renovations, repainting, construction or demolition project that could disturb painted surfaces, or involve work in areas where LBP may be present, the Project Manager (PM) must first contact EHS to request a hazardous materials inspection. A representative from EHS shall discuss the project scope with the PM and review past inspection records. If the area(s) in question have already been inspected, a copy of the report shall be sent to the PM. If an inspection is needed, the PM shall meet an EHS representative on site and provide a floor plan which specifies the area(s) and scope of work involved with the project. The EHS representative will perform the inspection, and once the results are known, a report will be sent to the PM detailing lead concentrations within the various paints tested.

  2. Unless the EHS representative determines the identified LBP are in stable condition and will not be disturbed by the planned project, the LBP must be properly managed during the project. Any residential LBP abatement activities must be designed by EHS, performed only by State Licensed LBP abatement professionals, and the activity monitored by EHS. Only persons who have been trained in accordance with the OSHA Lead Standard shall perform an activity that involves the incidental disturbance of LBP (i.e., repainting, renovations, building component removal, etc.). These activities must be monitored either by EHS or a properly trained LBP Project Supervisor from the University Facilities Management Department. All air or settled dust testing related to LBP work must be performed by a representative from EHS. The PM must contact EHS well in advance of a planned LBP abatement or incidental disturbance activity, to schedule any necessary design or monitoring work.

  3. EHS will provide "Lead in Construction" training to all University maintenance, renovations and painting staff who are required to disturb painted surfaces in University buildings or architectural components built prior to 1978. Such training shall require 2-8 hours, depending on type of LBP work involved. Attendees of these courses are trained in LBP recognition, regulations, health effects, personal protection, engineering controls, lead debris clean up, disposal and this policy.

  4. University employees who are required to perform residential LBP abatement, must attend a State approved Lead Abatement Worker or Supervisor course, an annual update course and must be qualified to obtain a State Department of Professional and Occupational Regulation Lead Abatement Worker or Supervisor License.

  5. Anyone who discovers damaged or deteriorated LBP needing repairs or LBP debris requiring clean up must report it immediately to EHS. Arrangements will be made by EHS to have this work performed properly.

  6. EHS is available to conduct, upon request, personal air testing as required by the OSHA Lead Standard to determine airborne lead dust exposures for the effected University faculty, staff and students. EHS will send results of such monitoring to the PM and will maintain records of the activities for an indefinite period.

  7. All University employees who are required to wear respirators for LBP work, shall follow all applicable sections of policy SEC-021, Controlling Hazardous Air Contaminants and Respiratory Protection.

Related Information:

SEC-021, Controlling Hazardous Air Contaminants and Respiratory Protection

Major Category: Safety, Security and Environmental Quality
Approved by, Date: Policy Review Committee, 06/30/2005
Revision History: Updated 7/18/11.
Supersedes (previous policy):
Lead-based Paints Management XIV.N.1