Lead Information
EPA – Lead 
OSHA – Safety and Health Topics – Lead
OSHA Fact Sheet – Lead
CDC – Lead
NIOSH – Lead
Agency for Toxic Substances and Disease Registry - ToxFAQs for Lead
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 – General industry
Chapter 29 CFR Part 1910.1025, Lead (General Industry)
General Industry Lead Advisor - 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.
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Instruction CPL 02-02-058 , Subject: 29 CFR 1926.62, Lead Exposure in Construction; Interim Final Rule - Inspection and Compliance Procedures - Guidance on compliance requirements for OSHA inspectors
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Indoor Firing Ranges
DA Pam 385-63 , Range Safety, Section 2-7 provides active Army requirements for control of lead exposures in indoor ranges.
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 , Indoor Firing Ranges Industrial Hygiene Technical Guide, National Guard Regulation 385-15 , Safety: Policy and Responsibilities for Inspection, Evaluation and Operation of Army National Guard Indoor Firing Ranges, and Air Force Engineering Technical Letter 06-11 , 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 , 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.
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The HUD Guidelines for the evaluation and control of lead-based paint hazards in housing form the minimum standard of care for the Army.
The HUD Guidelines are the one-volume reference for lead hazard management.
Army Policy: Lead-Based Paint (LBP) Versus Leaded Paints
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
The Office of the Assistant Chief of Staff for Installation Management (ACSIM) maintains the U.S. Army Lead Program 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 .
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AR 608-10, Child Development Services includes Army policy concerning lead-based paint in child care facilities, including family child care homes, in paragraphs 5-48, 6-50, C-51, and C-212
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Developing and Implementing a Lead Hazard Control Program
AR 420-1 Army Facilities Management 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 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 2012.
ASTM Manual 38, Lead Hazard Evaluation and Control in Buildings 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 Risk Assessment and Reevaluation and Chapter 15 Clearance.
The U.S. Army Corps of Engineers has developed scopes of work for lead hazard assessments:
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EP 1110-1-28 Lead Hazard Risk Assessment for Target Housing and Child-Occupied Facilities
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EP 1110-1-31 Combined Lead Inspection and Risk Assessment for Target Housing Property Transfer
ASTM International has developed consensus standards for lead hazard assessments:
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ASTM E2115 Standard Guide for Conducting Lead Hazard Assessments of Dwellings and of Other Child-Occupied Facilities
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ASTM E2255 Standard Practice for Conducting Visual Assessments for Lead Hazards in Buildings|
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ASTM E2271 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 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 Interim Controls, provides information on methods to control lead hazards other than abating them.
Chapter 12 Abatement, provides information on abatement methods.
Chapter 13 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:
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ASTM E1796 Standard Guide for Selection and Use of Liquid Coating Encapsulation Products for Leaded Paint in Buildings
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ASTM E1795 Standard Specification for Non-Reinforced Liquid Coating Encapsulation Products for Leaded Paint in Buildings
ASTM E1797 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 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 . (HUD 24 CFR Part 35 & EPA 40 CFR Part 745).
A summary of the rule is at: Lead Disclosure Rule .
Protect Your Family from Lead in Your Home (EPA Pamphlet 747-K-94-001) 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 website.
Renovate Right: Important Lead Hazard Information for Families, Child Care Providers, and Schools (EPA Pamphlet 740-K-10-001) must be provided as part of the information package.
HUD 24 CFR Part 35) 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 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., 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) mandated in AR 200-1, Environmental Protection and Enhancement 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 Training and Certification for Lead-Based Paint Activities web page lists the requirements.
EPA 40 CFR Part 745 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 , 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 (NLLAP).
The USAPHC Directorate of Laboratory Sciences is accredited by IHLAP and recognized by NLLAP.
Blood Lead Laboratories 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 - General
USAPHC Technical Guide 141, Industrial Hygiene Air Sampling and Bulk Sampling Instructions
Methods for Lead in Air
NIOSH Method 7082 , Lead by FAAS
NIOSH Method 7105 , Lead by GFAAS
NIOSH Method 7300 , Elements by ICP
NIOSH Method 7303 , Elements by ICP
OSHA Sampling and Analytical Methods provides five standard analytical methods.
NIOSH Method 7702 , Lead by Field Portable XRF Screening method for air filters
ASTM E1979 , Standard Practice for Ultrasonic Extraction of Paint, Dust, Soil, and Air Samples for Subsequent Determination of Lead
ASTM D6785 , Standard Test Method for Determination of Lead in Workplace Air Using Flame or Graphite Furnace Atomic Absorption Spectrometry
ASTM E1613 , 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 , Standard Test Method for Determination of Elements in Airborne Particulate Matter by Inductively Coupled Plasma–Mass Spectrometry
ASTM D7035 , 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 
ASTM D7659 , Standard Guide for Strategies for Surface Sampling of Metals and Metalloids for Worker Protection
ASTM E1792 , 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 , Standard Practice for Collection of Settled Dust Samples Using Wipe Sampling Methods for Subsequent Lead Determination
ASTM D7144 , 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 , Standard Practice for Hot Plate Digestion of Dust Wipe Samples for the Determination of Lead
ASTM E1979 , Standard Practice for Ultrasonic Extraction of Paint, Dust, Soil, and Air Samples for Subsequent Determination of Lead
NIOSH Method 9102 , Elements on Wipes (ICP-AES)
NIOSH Method 7082 , Lead by FAAS for micro-vacuum samples
NIOSH Method 7105 , Lead by GFAAS for micro-vacuum samples
NIOSH Method 7300 , Elements by ICP for micro-vacuum samples
NIOSH Method 7303 , Elements by ICP for micro-vacuum samples
ASTM E1613 , 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 , Standard Practice for Field Collection of Dried Paint Samples for Subsequent Lead Determination
ASTM E1645 , Standard Practice for Preparation of Dried Paint Samples by Hotplate or Microwave Digestion for Subsequent Lead Analysis
ASTM E1979 , Standard Practice for Ultrasonic Extraction of Paint, Dust, Soil, and Air Samples for Subsequent Determination of Lead
Methods for Lead in Soil
ASTM E1727 , Standard Practice for Field Collection of Soil Samples for Subsequent Lead Determination
ASTM E1726 , Standard Practice for Preparation of Soil Samples by Hotplate Digestion for Subsequent Lead Analysis
ASTM E1979 , Standard Practice for Ultrasonic Extraction of Paint, Dust, Soil, and Air Samples for Subsequent Determination of Lead
ASTM E1613 , 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 .
Using X-ray fluorescence for analysis of lead in paint and applicability of other agencies’ lead levels .