Dealing With Lead-Based Paint
A Guidance Document for University System of Georgia Facilities
This guidance document was prepared by the Board of Regents’ Office of Environmental Affairs to assist University System of Georgia (USG) institutions in dealing with lead-based paint (LBP) in facilities. While the primary focus of this document is on renovation and demolition projects in “Child-Occupied Facilities”, it also applies to other USG facilities. The intent of this document is to provide guidance to facilities planners, project designers, staff project managers and campus Environmental Safety Department personnel who may need to render judgements as to whether to inspect facilities, remove or otherwise contain LBP prior to renovation or demolition. Additional clarifications or interpretations may be necessary for certain projects or situations.
Adherence to the Georgia Environmental Protection Division (EPD) Rules for Lead-Based Paint Abatement and Certification (OCGA Chapter 391-3-24) shall be required for all “child-occupied” facilities within the University System of Georgia (USG) such as day care facilities, married housing, kindergarten classrooms, etc. These Rules do not mandate LBP abatement. However, if and when abatement is done, the Rules specify training requirements and procedures which shall be followed. The Board of Regents Office of Environmental Affairs recommends that all child-occupied facilities within the USG should be inspected and should have a risk assessment conducted by a Georgia Certified Lead Inspector/Risk Assessor as soon as possible to determine if lead exposure risks are present. If lead exposure risks are present, a plan should be developed and implemented by the institution to eliminate them. For cases where it is determined that the LBP must be removed from the facility, or if other lead removal work is deemed necessary (such as lead dust or soil removal), the work should be performed by a Georgia Certified Lead Abatement Contractor. NOTE: LBP abatement projects (for non-auxiliary services facilities) may be submitted to the Board of Regents’ Office of Facilities as MRR Regulatory Project requests.
For renovation projects in USG child-occupied facilities, all LBP in affected areas should be removed by a Georgia Certified Lead Abatement Contractor prior to beginning renovation work. All other USG renovation projects in non-child-occupied facilities should be evaluated on a “case-by-case” basis to determine if lead abatement is necessary. For the vast majority of USG renovation projects, if the existing painted surface is in good condition (e.g. not flaking or falling off the wall) and the workers/contractor are not planning to use “abrasive” work practices or surface preparation methods (such as scraping, sanding, etc.), it is generally acceptable to conduct the renovation work or to paint over the existing surface using normal work practices. However, if the painted surface is flaking or otherwise in poor condition - OR if the workers/contractor will use abrasive work practices or surface preparation methods, the paint should be tested by a Georgia Certified Lead Inspector/Risk Assessor before beginning the work to determine if a lead hazard is present. The Inspector/Risk Assessor should then determine whether the LBP must be removed, or if other control methods (such as the use of worker personal protective equipment or containment methods) are appropriate, to prevent harmful exposures to renovation workers or the facility environment. NOTE: For certain minor “spot” renovations or repairs, safe work practices such as employee lead exposure awareness training, personal protective equipment and containment methods may be used in lieu of detailed risk assessment and abatement procedures by “certified” personnel.
For USG demolition projects, LBP removal should generally not be required unless it is determined in advance (either by the campus Environmental Safety Department if they have appropriate training, or by a Georgia Certified Lead Inspector/Risk Assessor) that there could be harmful exposures to demolition workers or the surrounding environment as a result of the demolition activity. If it is determined in advance of the project that the demolition activity will pose a personnel or environmental exposure risk, appropriate control measures should be implemented. Appropriate control measures may include complete LBP removal, partial LBP removal, removal of structural components containing LBP, or other worker/environmental protection techniques. It is also important to insure that all LBP-containing demolition waste is properly characterized and disposed of in accordance with local, state and federal regulations.