This Lead Management Plan has been developed to fulfill University policy and to comply with applicable regulations. It describes lead-related program responsibilities, hazard assessment and control, safe work practices, training, and recordkeeping.

The purpose of the Lead Management Plan is to:

• Protect the campus community from overexposure to lead hazards
• Ensure compliance with local, state, and federal laws and regulations governing the identification and control of lead-related hazards on campus

Reference documents

All procedures specified in the Lead Management Plan conform to the following applicable regulations. Where conflicting or overlapping regulations exist, the more stringent requirements apply.

Laws and regulations

Federal laws and regulations: Occupational Safety and Health Act, 29 USC 651 et seq., and all applicable Occupational Safety and Health Administration (OSHA) regulations thereunder; Clean Air Act, 42 USC 7401 et seq., and all applicable US Environmental Protection Agency (EPA) regulations thereunder; Toxic Substances Control Act, Title IV, and all EPA regulations thereunder; Residential Lead-Based Paint Act, Title X, and all EPA regulations thereunder; EPA Lead Renovation, Repair and Painting Rule (RRP Rule, 40 CFR 745); Hazardous Materials Transportation Act, 49 USC 1801 et seq., and all applicable Department of Transportation (DOT) regulations thereunder.

State of California laws and regulations: Childhood Lead Poisoning Prevention Act, Health and Safety Code 105275 to 105310; Accreditation of Training Providers, Health and Safety Code 105250; Reporting of Elevated Blood Lead Levels, Health and Safety Code 124125 to 124165; Lead Exposure Screening, Health and Safety Code 1367.3 to 1374.15; Real Estate Disclosure, Civil Code 1102 to 1102.6; Lead-Safe Schools Protection Act, Education Code 32240 to 32245; Lead Construction Activities, Labor Code 6716 to 6717; Lead in Children’s Toys, Health and Safety Code 108550 to 108585; Occupational Lead Poisoning Prevention, Health and Safety Code 105185 to 105197; Accreditation of Training Providers, 17 CCR Section 35001 et seq.; all applicable regulations of the Department of Industrial Relations (DIR) including 8 CCR Section 1532.1; Hazardous Waste Control Law, Health and Safety Code 25100 et seq., and all applicable Department of Toxic Substances Control (DTSC) regulations thereunder, including 22 CCR Div. 4.5 et seq.; Safe Drinking Water and Toxic Enforcement Act of 1986, Health & Safety Code 25249.5 et seq., and all applicable regulations thereunder, including 22 CCR 12100 et seq.

Codes, standards, and guidance documents

• National and State Fire Code, Electrical Code, Plumbing Code, Building Code, and other related codes where applicable.
• ASTM: American Society for Testing and Materials
• ANSI: American National Standards Institute
• ULI: Underwriters Laboratories, Inc.
• NIOSH: National Institute for Occupational Safety and Health

Stanford manages lead safety issues through the EH&S Lead Management Program.

EH&S Lead Management Program responsibilities

The Lead Management Program must:

• Represent the University on matters of regulatory compliance and act as a liaison to agencies having jurisdiction over lead-related issues
• Ensure lead-related activities are conducted in compliance with applicable laws and regulations
• Provide lead surveys of areas scheduled for demolition or renovation
• Provide consultation to project managers on lead-related requirements
• Evaluate employee exposure and work practices to ensure that protective measures are adequate and conform to regulatory requirements
• Conduct training needs assessment for employees and provide training as requested by schools or departments
• Provide notifications and ensure that warning signs are installed, as required by applicable laws and regulations
• Develop and provide lead safety requirements that are included in all vendor contracts
• Evaluate contractor Lead Work Plans and provide oversight of lead-related activities
• Manage lead-containing waste
• Provide recommended procedures to schools and departments
• Respond to lead-related concerns or questions raised by the campus community
• Provide consultation and maintain technical expertise on lead-related issues
• Manage and maintain lead-related records

Residential and Dining Enterprises responsibilities

Residential and Dining Enterprises must:

• Include the mandated lead-based paint disclosure statement and disclosure letter in lease agreements of family housing units
• Provide lead blood testing free of charge to children (when requested) in Escondido Village family housing units
• Provide copy of the EPA pamphlet entitled “Protect Your Family From Lead In Your Home” to occupants of family housing units
• Include the mandated Lead-Based Paint Disclosure Form, complete with required signatures and dates, in all married housing lease files
• Ensure all contractors hired for renovation of family housing units constructed prior to 1978 are lead certified, in accordance with the EPA’s Lead Renovation, Repair and Painting Rule (RRP Rule, 40 CFR 745)

School and department responsibilities

Schools and departments must:

• Ensure that school or department personnel responsible for management of demolition or renovation projects are aware of lead-related impacts prior to any disturbance of building materials
• Notify the Lead Management Program of any visible damage or deterioration to known or suspected lead-based coatings in a timely fashion

Supervisor responsibilities

Supervisors must:

• Coordinate and schedule required training and medical surveillance
• Provide personal protective equipment (if applicable) for employees
• Maintain employee records
• Ensure that employees are aware of, and comply with, lead-related protocols and procedures

Project Manager responsibilities

Project Managers must:

• Contact the Lead Management Program at least 30 days prior to the start of renovation or demolition projects to request a lead survey, if applicable
• Provide any descriptions, plans, drawings, or specifications of renovation or demolition work to the Lead Management Program, as requested
• Notify general contractors engaged in construction-related activities of the presence and location of known lead-containing materials within their defined project areas

Employee responsibilities

Employees must:

• Attend required training
• Use protective equipment properly
• Follow lead-related protocols and procedures
• Notify their supervisor or the Lead Management Program of any visible damage or deterioration to known or suspected lead-containing coatings in a timely fashion

Stanford Real Estate responsibilities

Stanford Real Estate (SRE), which manages leased properties owned (lessor) or occupied (lessee) by Stanford University, is responsible for managing all lead-related issues and compliance obligations for these properties. The Lead Management Program is available to SRE for consultation as needed.

SLAC and Stanford Health Center responsibilities

The Stanford Linear Accelerator and Stanford Health Center maintain independent EH&S offices that are responsible for managing all lead-related issues and compliance obligations. The Lead Management Program is available to SLAC and the Health Center for consultation.

Family housing units

The Residential and Dining Enterprises Department coordinates non-construction-related, lead-based paint surveys and hazard assessments covered by Federal Title X regulations and California Health and Safety Codes. Only consultants certified by the State Department of Health Services may conduct surveys of this nature.

Project-related surveys

All paints and surface coatings applied prior to 1978 are presumed to be lead-based, unless proven otherwise through approved testing methods. The Lead Management Program may collect, and submit for analysis, representative paint chip samples from impacted surfaces at the request of a project manager to confirm lead content.

Hazard assessment

During the course of an inspection or survey, the inspector will assess the condition of confirmed or suspected lead-containing materials and determine if a potential exposure or environmental hazard exists. The Lead Management Program will then determine if an appropriate response action is necessary. The Program will initiate any action and provide oversight.

Inspection data management

The Lead Management Program maintains building inspection and survey information.

Lead work plans

Contractor submittal

Contractors that disturb lead-containing materials are required to submit a site-specific work plan that contains the following elements:

• A description of the removal method and the control measures that will be used to protect contractor employees, other individuals in the vicinity of the work, and the environment.
• A description of the contractor’s Injury and Illness Protection Program (IIPP) specific to lead. The IIPP must address the requirements of Cal/OSHA’s lead construction standard (CCR Title 8, Section 1532.1) and also include:
  • Safety data sheets (SDSs) for all chemicals used on the job site
  • A list of personal protective equipment to be used by the contractor’s employees
  • A description of hazard communication, respiratory protection, and lead training programs administered to the contractor’s employees
  • A description of the employee medical surveillance and exposure monitoring program, including personal air monitoring, blood lead, and ZPP level monitoring.

Water-blasting of painted surfaces

Contractors shall comply with Santa Clara County Storm Water Pollution Prevention requirements and shall prevent water-blasting runoff that contains paint chips from entering the soil or storm drains. Paint chips shall be filtered, or otherwise collected and disposed of, in accordance with all federal, state, and local regulations. Water-blasting shall not be used on surfaces that contain loose or flaking paint.

Notifications

Family housing unit notifications

Occupants of family housing units covered under Federal Title X receive mandated disclosure statements within their lease agreements and a copy of the EPA pamphlet entitled “Protect Your Family From Lead In Your Home”. R&DE also distributes a lead notification letter to Escondido Village tenants that includes safety information and protocols for reporting potential hazards.

Contractor notifications

• Project managers: Notify general contractors engaged in construction-related activities of the presence and location of known or presumed lead-containing materials within their defined project areas through contract documents or other means.
• Contractors: Stop work and notify the project manager within 24 hours if additional (hidden) lead-containing materials that are in a hazardous condition are discovered during the course of work.

Construction-related notifications

Contractors: Post Cal/OSHA lead-regulated area warning signs and Proposition 65 notification signs at the entrance to any lead-regulated area.

Project managers: Notify tenants who occupy building areas adjacent to lead activity of the nature and duration of the work, by written communication or posted sign.

Air monitoring

Environmental monitoring

Environmental air monitoring may be used to evaluate airborne lead concentrations within a prescribed building area or at the boundary of a regulated work area.

The Lead Management Program determines the necessity of ambient airborne lead monitoring, as well as the appropriate sample collection and analysis method. The Program evaluates sampling results to determine if airborne lead levels comply with established regulatory requirements and, if not, designates the appropriate response action to abate lead levels.

Personal exposure monitoring

The Lead Management Program performs personal exposure monitoring of employees engaged in lead-related work to evaluate exposure to airborne lead and to determine the adequacy of respiratory protection. Separate monitoring is provided for each distinct OSHA trigger task, as defined in 8 CCR 1532.1.

Incidental release

Incidental release of lead-containing dust may occur during an inadvertent disturbance.

• For release during normal work hours, contact the Lead Management Program.
• For release during off-hours or weekends, evacuate and isolate the area until the Lead Management Program can provide an assessment of the situation or until the campus Emergency Response Team is activated to respond.
• The Lead Management Program will provide a hazard assessment and determine the appropriate response to an incidental release.
• The Lead Management Program coordinates evacuation and isolation of the area, if necessary, and abatement of the hazard. By environmental monitoring or other means, the Program also determines when it is safe to re-enter the restricted area.

Training

The Lead Management Program, or an approved consultant, provides lead training.

Lead awareness

Lead awareness training is recommended for employees engaged in construction or maintenance activities, or who may otherwise disturb lead-containing materials during the course of their work.

Respiratory protection

Employees engaged in lead-related activities are required to participate in the University’s respiratory protection program. The EH&S Occupational Health & Safety (OH&S) Group provides respiratory protection training and fit testing.

Respirator training is required initially, and annually thereafter.

Medical surveillance

Employees who perform lead-related operations and maintenance tasks, or are required to wear respiratory protection during the course of their work, receive annual physical examinations. The EH&S OH&S Group reviews the individual elements of the examinations periodically to ensure that they comply with regulations on lead and respiratory protection.

Recordkeeping

Lead Management Program

The Lead Management Program maintains the following records:

• Building inspection and survey reports
• Lead abatement project documentation
• Environmental and personal exposure monitoring
• Equipment calibration and maintenance information
• Sampling and analysis data
• All other documentation directly related to the Lead Management Program

Supervisors

Supervisors are responsible for maintaining the following lead-related documentation for their employees:

• Lead training certificates
• Medical surveillance reports
• Respirator fit testing data
• Lead work procedures