Industrial Hygiene
Lead 

Lead InformationLead Sign

 EPA – Lead external link icon
 OSHA – Safety and Health Topics – Lead external link icon
 OSHA Fact Sheet – Lead external link icon
 CDC – Lead external link icon
 NIOSH – Lead external link icon
 Agency for Toxic Substances and Disease Registry - ToxFAQs for Lead external link icon

Occupational Exposures

Soldiers and Army Civilians may be exposed to lead from weapons emissions, industrial operations, systems maintenance, and leaded dust releases during the maintenance, renovation, repair, or demolition of Army facilities containing leaded paint.

OSHA Regulations and Guidance – General Industry

The OSHA lead regulation for general industry applies to Army industrial exposures and weapons emission exposures during training. 
It does not apply to construction, renovations, repair, abatement and related activities other than routine maintenance.

 OSHA Lead Page external link icon – General industry

 Chapter 29 CFR Part 1910.1025, Lead external link icon (General Industry)

 General Industry Lead Advisor external link icon - Expert advisor software providing a framework to facilitate compliance


OSHA Regulations and Guidance - Construction 

The OSHA Lead in Construction regulation applies to construction, renovations, repair, lead hazard abatement, and related activities other than routine maintenance.

Indoor Firing Ranges

 DA Pam 385-63 external link icon, Range Safety, Section 2-7 provides active Army requirements for control of lead exposures in indoor ranges.Indoor Firing Range

Useful criteria and guidance for design, operation, and evaluation of indoor ranges are also provided in the  Navy Environmental Health Center Technical Manual 6290.99 external link icon, Indoor Firing Ranges Industrial Hygiene Technical Guide,  National Guard Regulation 385-15 external link icon, Safety: Policy and Responsibilities for Inspection, Evaluation and Operation of Army National Guard Indoor Firing Ranges, and  Air Force Engineering Technical Letter 11-18 external link icon, Small Arms Range Design and Construction.

Guidance for decontamination of indoor ranges that will be used for other purposes is provided in  National Guard Pam 420-15 external link icon, Facilities Engineering: Guidelines and Procedures for Rehabilitation and Conversion of Indoor Firing Ranges.

Lead Hazard Management in Army Facilities

Lead hazard management regulations currently apply to Army family housing and other facilities regularly occupied by children under 6 years of age, including Child Development Centers. 
The EPA plans to issue regulations that will apply to renovations to the exteriors of all public and commercial buildings.

Federal and State Regulations and Guidance

EPA regulations apply in 10 states that do not have EPA-authorized state lead hazard management programs. 
The remaining states, the District of Columbia, and Puerto Rico have authorized programs. 
Army installations in these areas must keep track of all regulations, and comply with the more stringent of the individual requirements among them.
This is because (unlike asbestos) individual requirements under State lead programs may be either more or less stringent than the corresponding Federal regulations.

Army Policy:  Lead-Based Paint (LBP) Versus Leaded PaintsLead Based Paint on Window

Federal and state regulations focus on lead-based paint.
The Federal definition of LBP is 0.5% or more lead by weight or 1.0 milligrams or more lead per square centimeter of surface; state definitions may vary.
The Army recognizes that this definition is not health based. 
Intact LBP is not a hazard, while paint containing much less lead than LBP can create significant lead hazards in dust and soil when it deteriorates. 
The Army emphasis is on any deteriorating paint containing lead, as well as lead hazards in dust and soil as defined by Federal or State programs.


Key DoD and Army Lead Regulations, Policies, and Guidance

Shoot HouseThe Office of the Assistant Chief of Staff for Installation Management (ACSIM) maintains the  U.S. Army Lead Program external link icon website. 
The site is a resource for Major Army Commands and installations for managing lead hazards in the Army.

Army lead policy and compliance requirements are summarized in an ACSIM  Army Lead Hazard Management Information Paper external link icon

Developing and Implementing a Lead Hazard Control Program

 AR 420-1 Army Facilities Management external link icon is the Army facilities policy for lead.
Each installation is required to develop and implement a lead hazard management program to evaluate and control lead hazards in pre-1978 Army family housing and other child-occupied facilities.
Lead hazards are to be managed in place whenever this is effective and more economical than abatement. Installations must follow Federal, State, and local regulations.

 Public Works Technical Bulletin (PWTB) 420-70-2 external link icon Installation Lead Hazard Management provides guidance to installations for setting up a program to manage lead hazards in buildings.
Note: A new PWTB is expected to replace this one later CY 2013. 

ASTM Manual 38,  Lead Hazard Evaluation and Control in Buildings external link icon provides detailed guidance for developing and implementing a lead hazard management program.


Performing Lead Hazard Assessments Including Risk Assessments, Clearance Examinations and Lead-Based Paint Inspections

The Army discourages the use of (LBP inspections because of the considerations discussed above.)
LBP inspections should only be performed when regulations require them.

A lead hazard risk assessment is the best method for identifying actual lead hazards in dust and soil as well as in deteriorated paints. 

Clearance examinations ensure that cleanup after lead abatement removes any remaining dust lead hazard.
See
HUD Guidelines
 Chapter 5 external link icon Risk Assessment and Reevaluation and  Chapter 15 external link icon Clearance.   

The U.S. Army Corps of Engineers has developed scopes of work for lead hazard assessments:

  •  EP 1110-1-28 external link icon Lead Hazard Risk Assessment for Target Housing and Child-Occupied Facilities 

  •  EP 1110-1-29 external link icon Lead Hazard Clearance Inspection

  •  EP 1110-1-31 external link icon Combined Lead Inspection and Risk Assessment for Target Housing Property Transfer  

ASTM International has developed consensus standards for lead hazard assessments:

  • ASTM  E2115 external link icon Standard Guide for Conducting Lead Hazard Assessments of Dwellings and of Other Child-Occupied Facilities
     
  • ASTM  E2255 external link icon Standard Practice for Conducting Visual Assessments for Lead Hazards in Buildings|

  • ASTM  E2271 external link icon Standard Practice for Clearance Examinations Following Lead Hazard Reduction Activities in Dwellings, and in Other Child-Occupied Facilities

Planning and Performing Lead Hazard Control Work

Lead hazards can usually be controlled by methods other than abatement. 
Leaded paint is removed during projects such as whole-house renovations, or when lead hazards cannot be controlled by other methods.

ASTM  E2252 external link icon Standard Practice for Selection of Lead Hazard Reduction Methods for Identified Risks in Residential Housing or Child Occupied Facilities, provides useful guidance.

 

The HUD Guidelines  Chapter 11 external link icon Interim Controls, provides information on methods to control lead hazards other than abating them. 
 Chapter 12 external link icon Abatement, provides information on abatement methods. 
 Chapter 13 external link icon Abatement by Encapsulation, provides information on encapsulation systems.  
Some State regulations may require State approval of certain encapsulation products.

 

ASTM International has developed consensus standards for encapsulants:

  • ASTM  E1796 external link icon Standard Guide for Selection and Use of Liquid Coating Encapsulation Products for Leaded Paint in Buildings
     
  • ASTM  E1795 external link icon Standard Specification for Non-Reinforced Liquid Coating Encapsulation Products for Leaded Paint in Buildings

  • ASTM  E1797 external link icon Standard Specification for Reinforced Liquid Coating Encapsulation Products for Leaded Paint in Buildings

Proper cleaning of leaded dust after lead hazard controls are implemented is essential. 
The
HUD Guidelines  Chapter 14 external link icon Cleaning Throughout Hazard Controls, provides the necessary standard of care.

 

 

Planning and Performing Renovations and Repairs That Disturb Leaded Paint

EPA regulations apply to renovations and repairs that disturb LBP. 
As discussed above, disturbing any paint containing lead, whether or not it is LBP, can create significant dust lead hazards.
Installations should consider extending the EPA requirements to cover any such situation.



Providing Information to Occupants of Army Family Housing

Installations must inform all new tenants of Army family housing what is known about lead-based paint and lead-based paint hazards in their units.

The requirements are listed in:  Lead; Requirements for Disclosure of Known Lead-Based Paint and Lead-Based Paint Hazards in Housing; Final Rule external link icon. (HUD 24 CFR Part 35 & EPA 40 CFR Part 745).
A summary of the rule is at: Lead Disclosure Rule external link icon.
 Protect Your Family from Lead in Your Home external link icon (EPA Pamphlet 747-K-12-001) must be provided as part of the information package.

Installations and contractors must also provide information to the present tenants of housing units where renovations will disturb lead-based paint.
The requirements are listed on the EPA
 Renovation, Repair, and Painting external link icon website.
 Renovate Right: Important Lead Hazard Information for Families, Child Care Providers, and Schools external link icon (EPA Pamphlet 740-K-10-001) must be provided as part of the information package.

 HUD 24 CFR Part 35) external link icon Requirements for Notification, Evaluation and Reduction of Lead-Based Paint Hazards in Federally Owned Residential Property and Housing Receiving Federal Assistance; Final Rule, specifies notification procedures for prospective purchasers of Army housing. 


Disposing of Lead-Contaminated Waste

EPA considers lead-contaminated waste from residential buildings (including both Army family housing and barracks) to be household waste rather than hazardous waste.
States may not concur with this view, so check with State regulators before assuming this is the case.
Otherwise, it is necessary to determine if wastes from lead hazard control activities are hazardous waste based on their lead content as determined by a toxicity characteristic leaching procedure (TCLP) analysis.
Samples submitted for TCLP analysis should be representative of all of the building components.
The protocol for taking samples should allow the determination to be made before the job begins.

ASTM  E1908 external link icon Standard Guide for Sample Selection of Debris waste from a Building Renovation or Lead Abatement Project for Toxicity Characteristic Leaching Procedure (TCLP) testing for Leachable Lead (Pb), is a suitable protocol.

Note: wastes from paint stripping may be determined to be hazardous wastes based on toxicity or corrosivity, regardless of the TCLP results for Lead.


Guidance for the Disposal of Lead on Army Real Property

 HUD 24 CFR Part 35, et al., external link icon Requirements for Notification, Evaluation and Reduction of Lead-Based Paint Hazards in Federally Owned Residential Property and Housing Receiving Federal Assistance; Final Rule, lists the requirements for lead abatement for the sale of Army real property.


Lead Hazard Management Program Evaluation

The  Environmental Performance Assessment Systems (EPAS) external link icon mandated in  AR 200-1, Environmental Protection and Enhancement external link icon uses evaluation protocols that are updated quarterly.


Training and Certification Requirements

Installation personnel and contractors must be trained and certified to perform lead hazard evaluation or abatement work.
They must meet any applicable State training, certification, and licensing requirements.
EPA’s own training and certification requirements apply in states that do not have their own regulations.
The  EPA
 Evaluating and Eliminating Lead-Based Paint Hazards external link icon web page discusses the requirements.

 EPA 40 CFR Part 745 external link icon Lead; Requirements for Lead-Based Paint Activities in Target Housing and Child-Occupied Facilities; Certification Requirements and Work Practice Standards for Individuals and Firms; Amendment ensures individuals conducting lead-based paint activities in target housing and child-occupied facilities are properly trained and certified.
Also, training programs are accredited and activities are conducted according to reliable, effective, and safe work practice standards.

Sampling and Analyzing for Lead

Laboratory Qualifications

Laboratories performing lead air monitoring analyses should be accredited by the  American Industrial Hygiene Association (AIHA) Laboratory Accreditation Programs, LLC external link icon, Industrial Hygiene Laboratory Accreditation Program (IHLAP) for metals analyses. (Non-government resource) 

Dust wipe samples collected to support occupational lead compliance (for example, to verify the effectiveness of housekeeping procedures) should be analyzed by a  laboratory recognized by the National Lead Laboratory Accreditation Program external link icon (NLLAP).

The  USAPHC Directorate of Laboratory Sciences is accredited by IHLAP and recognized by NLLAP.

 Blood Lead Laboratories external link icon is the OSHA list of laboratories approved for blood lead analysis. The OSHA lead standards (general industry and construction) require employers to provide biological monitoring for workers exposed to airborne lead above the action level.
Monitoring must be provided for lead and zinc protoporphyrin (or free erythrocyte protoporphyrin) in blood.
The employer is required to have these analyses performed by a laboratory that meets accuracy requirements specified by OSHA.

Methods - Generallead based paint on radiator

USAPHC  Technical Guide 141 Industrial Hygiene Air Sampling and Bulk Sampling Instructions

Methods for Lead in Air

NIOSH Method  7082 external link icon, Lead by FAAS

NIOSH Method  7105 external link icon, Lead by GFAAS

NIOSH Method  7300 external link icon, Elements by ICP

NIOSH Method  7303 external link icon, Elements by ICP

 

 OSHA Sampling and Analytical Methods external link icon provides five standard analytical methods.

 

NIOSH Method  7702 external link icon, Lead by Field Portable XRF Screening method for air filters

ASTM  E1979 external link icon, Standard Practice for Ultrasonic Extraction of Paint, Dust, Soil, and Air Samples for Subsequent Determination of Lead

ASTM  D6785 external link icon, Standard Test Method for Determination of Lead in Workplace Air Using Flame or Graphite Furnace Atomic Absorption Spectrometry

ASTM  E1613 external link icon, Standard Test Method for Determination of Lead by Inductively Coupled Plasma Atomic Emission Spectrometry (ICP-AES), Flame Atomic Absorption Spectrometry (FAAS), or Graphite Furnace Atomic Absorption Spectrometry (GFAAS) Techniques

ASTM  D7439 external link icon, Standard Test Method for Determination of Elements in Airborne Particulate Matter by Inductively Coupled Plasma–Mass Spectrometry

ASTM  D7035 external link icon, Standard Test Method for Determination of Metals and Metalloids in Airborne Particulate Matter by Inductively Coupled Plasma Atomic Emission Spectrometry (ICP-AES)

 

 

Methods for Lead in Surface Dust Lead Surface Wipe

 

ASTM  D7659 external link icon, Standard Guide for Strategies for Surface Sampling of Metals and Metalloids for Worker Protection

 

ASTM  E1792 external link icon, Standard Specification for Wipe Sampling Materials for Lead in Surface Dust – Commercially available, individually wrapped, pre-wetted wipes with minimal background lead content.  Always consult your lab when selecting the brand!

 

ASTM  E1728 external link icon, Standard Practice for Collection of Settled Dust Samples Using Wipe Sampling Methods for Subsequent Lead Determination

 

ASTM  D7144 external link icon, Standard Practice for Collection of Surface Dust by Micro-vacuum Sampling for Subsequent Metals Determination – For fabrics and other rough or porous surfaces where wipe sampling would not be effective. 

Results cannot be correlated with wipe sampling results.
 

ASTM  E1644 external link icon, Standard Practice for Hot Plate Digestion of Dust Wipe Samples for the Determination of Lead

 

ASTM  E1979 external link icon, Standard Practice for Ultrasonic Extraction of Paint, Dust, Soil, and Air Samples for Subsequent Determination of Lead

 

NIOSH Method  9102 external link icon, Elements on Wipes (ICP-AES)

NIOSH Method  7082 external link icon, Lead by FAAS for micro-vacuum samples

NIOSH Method  7105 external link icon, Lead by GFAAS for micro-vacuum samples

NIOSH Method  7300 external link icon, Elements by ICP for micro-vacuum samples

NIOSH Method  7303 external link icon, Elements by ICP for micro-vacuum samples

ASTM  E1613 external link icon, Standard Test Method for Determination of Lead by Inductively Coupled Plasma Atomic Emission Spectrometry (ICP-AES), Flame Atomic Absorption Spectrometry (FAAS), or Graphite Furnace Atomic Absorption Spectrometry (GFAAS) Techniques

 

 

Methods for Lead in Paint

 

ASTM  E1729 external link icon, Standard Practice for Field Collection of Dried Paint Samples for Subsequent Lead Determination

 

ASTM  E1645 external link icon, Standard Practice for Preparation of Dried Paint Samples by Hotplate or Microwave Digestion for Subsequent Lead Analysis

 

ASTM  E1979 external link icon, Standard Practice for Ultrasonic Extraction of Paint, Dust, Soil, and Air Samples for Subsequent Determination of Lead

 

 

Methods for Lead in Soil

 

ASTM  E1727 external link icon, Standard Practice for Field Collection of Soil Samples for Subsequent Lead Determination

 

ASTM  E1726 external link icon, Standard Practice for Preparation of Soil Samples by Hotplate Digestion for Subsequent Lead Analysis

 

ASTM  E1979 external link icon, Standard Practice for Ultrasonic Extraction of Paint, Dust, Soil, and Air Samples for Subsequent Determination of Lead

 

ASTM  E1613 external link icon, Standard Test Method for Determination of Lead by Inductively Coupled Plasma Atomic Emission Spectrometry (ICP-AES), Flame Atomic Absorption Spectrometry (FAAS), or Graphite Furnace Atomic Absorption Spectrometry (GFAAS) Techniques

 

Testing for Lead in Paint and Other Coatings (for 1926.62 compliance)

Portable X-ray fluorescence (XRF) instruments and chemical spot test kits cannot be used to rule out the presence of lead for compliance purposes. 
Positive results do confirm its presence without the need for laboratory testing. 
See the following OSHA letters of interpretation:

 Acceptability of rhodizonate-based spot test kits for determining the presence or absence of lead in paint coatings external link icon.

 Using X-ray fluorescence for analysis of lead in paint and applicability of other agencies’ lead levels external link icon.