08 - Middle School OSHA Paint Sampling 20260914.pdf

September 14, 2026

Whitehall District Schools 541 E. Slocum Street Whitehall, MI 49461

RE: OSHA Paint sampling for lead, cadmium, chromium Whitehall Middle School

To Whom it May Concern:

As requested, paint sampling was performed for the upcoming renovations to take place at 401 South Elizabeth Street in Whitehall, Michigan. Erick Knuth and Catherine Phelps, certified lead inspectors, conducted the sampling on August 10, 2026. The building was constructed in 1953 and has various additions.

Paint Sampling

The paint chip sampling and analysis was performed to identify the levels of lead, cadmium and chromium in the paint, as per the Occupational Safety and Health Administration (OSHA) Lead in Construction Standard (29 CFR 1926.62), Cadmium Standard (29 CFR 1926.1127) and Chromium Standard (29 CFR 1926.1126). The samples were sealed and delivered to SanAir Technologies Laboratory in Virginia.

SanAir is certified for metals analysis under the National Lead Laboratory Accreditation Program (NLLAP). The results are as follows:

# Description Lead Result

Cadmium Result

Chromium Result

1 Cream on cafeteria walls (1957) <0.00236% <0.000944% <0.00236% 2 Cream on cafeteria I-beams 0.673% <0.000894% <0.00224% 3 White on boiler room walls (1957) 0.035% <0.000962% <0.00241% 4 Gray on boiler room I-beams 0.0794% 0.00749% 0.00252% 5 Gray on boiler room floor 0.0389% 0.000997 <0.00249 6 Green paint on boiler 1.59% <0.000981% 0.471% 7 Gray on block walls (1957) 0.00581% <0.000881% <0.0022% 8 Gray on block walls (1953) <0.00249% <0.000997% <0.00249%

Based on the paint chip sample results, the highest levels are on the I-beams, boiler rooms, and paint on the green boiler. The classroom results (samples 7, 8, 11) are either below the laboratory detection limits or slightly above.

Summary of OSHA Recommendations

The dust levels created during demolition or renovation work can only be established by performing air monitoring while the paint is being disturbed, and OSHA has established acceptable levels for lead, cadmium and chromium exposure based on air monitoring results. Air monitoring should be performed at the start of renovation activities, for each specific task that will disturb the paint.

All aspects of the OSHA Construction Standards will apply until the air levels are shown to stay below the Action Levels. This includes the following:

1. All workers on the job site that may be exposed to dust above the Action Levels must attend an OSHA training program which meets the requirements of 29 CFR 1926.62, 1926.0027 and 1926.1126. This must take place before work begins. The workers should also have their blood tested to establish a baseline level for lead in the blood.

2. Air monitoring (exposure assessment) must be conducted for each activity performed on the site where the paint is disturbed, and further action will become necessary if the air monitoring results exceed certain levels. A previous exposure assessment with similar levels and similar work activities may be sufficient.

However, if one does not exist, then air monitoring must be conducted. The requirements based on exposure levels established by OSHA are as follows:

o If the job exceeds the Action Level on any single shift, the employer MUST do lead blood testing on all employees exposed.

Lead Action Level: 30 ug/m3 Cadmium Action Level: 2.5 ug/m3 Chromium Action Level: 2.5 ug/m3 o If the job exceeds the Action Level for 30 days in any year, the employer must also conduct medical surveillance including a comprehensive six part medical exam and ongoing blood testing. This entails blood testing at 2 months, 4 months, 6 months and each 6 months thereafter.

# Description Lead

Result Cadmium

Result Chromium

Result 9 Gray on boiler room walls (1953) 0.0123% 0.00383% <0.00247%

10 Gray on boiler room floor (1953) 0.12% <0.000832% 0.0106% 11 Gray on block walls (1967) 0.00383% <0.000887% 0.00222% o Permissible Exposure Limit (PEL): The standard requires that no employee is exposed to lead or cadmium at concentrations greater than the permissible exposure limits, averaged over an eight-hour period.

Lead PEL: 50 ug/m3 Cadmium PEL: 5 ug/m3 Chromium PEL: 5 ug/m3 o If the initial determination reveals exposure to be above the PEL, full OSHA protection is required. This includes, but is not limited to, regulating the area with caution tape and approved signs; implementing engineering controls such as air filtration devices, HEPA vacuums, and wet methods; respiratory protection; personal protective equipment; cleaning facilities.

o Until the worker exposure levels are established, it must be assumed that the levels are above the PEL. This means that respirators must be worn throughout the exposure assessment, the area must be regulated, and engineering controls utilized.

3. If the PEL is exceeded, the following programs will also be required:

o A Medical Surveillance Program to monitor the blood lead levels of all employees exposed.

o A Respiratory Protection Program to keep exposure to a minimum.

o A written job specific OSHA Compliance Program must be on site at all times.

4. Throughout any demolition activities, and with any other work practices that disturb the paint, air monitoring must be conducted to determine the level of lead and cadmium in the work environment. Once it can be established that the levels are staying below the action level, air monitoring will only need to be performed once every six months throughout the project. However, in the beginning it is very important for the protection of all employees on site that air monitoring be performed on a regular basis.

All laboratory results are included on the following pages. If you have any questions or need additional assistance, please feel free to contact me at (616) 364-9200.

Sincerely, AAA Lead Inspections, Inc.

Catherine Phelps Certified Lead Inspector/Risk Assessor (#P-00581)

SanAir ID#: 26047211

Project Name: 401 S Elizabeth Whitehall Report Date: 8/19/2026

Analysis Report prepared for AAA Lead Inspections, Inc.

Dear Erick Knuth, We at SanAir would like to thank you for the work you recently submitted. The 11 sample(s) were received on Wednesday, August 12, 2026 via FedEx. The final report(s) is enclosed for the following sample(s): PC-1, PC-2, PC-3, PC-4, PC-5, PC-6, PC-7, PC-8, PC-9, PC-10, PC-11.

These results only pertain to this job and should not be used in the interpretation of any other job. This report is only complete in its entirety. Refer to the listing below of the pages included in a complete final report.

Sincerely, Abisola Kasali Metals Laboratory Director SanAir Technologies Laboratory

Final Report Includes:

- Cover Letter

- Chemistry Analysis

- Disclaimers and Additional Information

Sample conditions:

- 11 samples in Good condition.

10501 Trade Ct., N. Chesterfield, VA 23236 | 804.897.1177 | Fax: 804.897.0070 | www.SanAir.com | LabReports@SanAir.com

Project Number:

P.O. Number:

Project Name: 401 S Elizabeth Whitehall

8/10/2026Collected Date:

8/12/2026 9:55:00 AMReceived Date:

8/19/2026 6:16:57 PM

26047211 SanAir ID Number

FINAL REPORT

AAA Lead Inspections, Inc.Name:

Address: 15 N Park St NW

Grand Rapids, MI 49544

616-364-9200Phone:

Name: AAA Lead Inspections, Inc. Project Number:

Address: 15 N Park St NW P.O. Number:

Grand Rapids, MI 49544 Project Name:

Phone: 616-364-9200

Collected Date:

Received Date:

Report Date:

Analyst: Madison Simpson

Analyte Requested: Paint: Cadmium (Cd), Chromium (Cr), Lead (Pb) Test Method: EPA M3050B /6010C

Lab Sample # Field Sample # Description Analyte ug In

Sample

Sample Size

(grams)

Results in ug/g

Cadmium (Cd) <1.00 <9.44

Chromium (Cr) <2.50 <23.6

Lead (Pd) <2.50 <23.6

Cadmium (Cd) <1.00 <8.94

Chromium (Cr) <2.50 <22.4

Lead (Pd) 752 6730

Cadmium (Cd) <1.00 <9.62

Chromium (Cr) <2.50 <24.1

Lead (Pd) 36.3 350.0

Cadmium (Cd) 8.55 74.9

Chromium (Cr) 2.88 25.2

Lead (Pd) 90.7 794

Cadmium (Cd) <1.00 <8.21

Chromium (Cr) <2.50 <20.5

Lead (Pd) 47.4 389

Cadmium (Cd) <1.00 <9.81

Chromium (Cr) 480 4710

Lead (Pd) 1620 15900

Cadmium (Cd) <1.00 <8.81

Chromium (Cr) <2.50 <22.0

Lead (Pd) 5.88 51.8

Note: ug/g=ppm

Signature: Reviewed:

Analysis Date: 8/19/2026 Date: 8/19/2026

SanAir ID Number

26047211

FINAL REPORT

0.1059

Calculated

RL ug/g

9.44

401 S Elizabeth Whitehall

8/19/2026

8/12/2026 9:55 AM

REPORT OF ANALYSIS

PC-1 23.6

23.6

26047211-01

8/10/2026

Cream

26047211-02

26047211-03

26047211-04

26047211-05

PC-2

PC-3

PC-4

PC-5

26047211-06

26047211-07

9.81

24.5

24.5

8.81

PC-6

The method reporting limit is based on 1.0ug for As, Cd, and Se; and 2.5ug for all other metal analytes. The Calculated Reporting Limit

(RL) indicates the lowest concentration that can be reliably calculated and reported for the sampled weight used for analysis.

0.1118

0.1039

0.1142

0.1218

0.1019

0.1135PC-7

Cream

White

Gray

8.94

22.4

22.4

9.62

24.1

24.1

Gray

Green

Gray 22.0

22.0

8.76

21.9

21.9

8.21

20.5

20.5

10501 Trade Ct., N. Chesterfield, VA 23236 | Phone: 804.897.1177 | Fax: 804.897-0070 | www.SanAir.com | LabReports@SanAir.com

Analyst: Madison Simpson

Lab Sample # Field Sample # Description Analyte ug In

Sample

Sample Size

(grams)

Results in ug/g

Cadmium (Cd) <1.00 <9.97

Chromium (Cr) <2.50 <24.9

Lead (Pd) <2.50 <24.9

Cadmium (Cd) 3.88 38.3

Chromium (Cr) <2.50 <24.7

Lead (Pd) 12.5 123

Cadmium (Cd) <1.00 <8.32

Chromium (Cr) 12.8 106

Lead (Pd) 144 1200

Cadmium (Cd) <1.00 <8.87

Chromium (Cr) <2.50 <22.2

Lead (Pd) 4.33 38.3

Note: ug/g=ppm

Siganture: Reviewed:

Analysis Date: 8/19/2026 Date: 8/19/2026

Analyte Requested: Paint: Cadmium (Cd), Chromium (Cr), Lead (Pb)

Test Method: EPA M3050B /6010C

REPORT OF ANALYSIS

26047211-08

26047211-09

26047211-10

26047211-11

The method reporting limit is based on 1.0ug for As, Cd, and Se; and 2.5ug for all other metal analytes. The Calculated Reporting Limit

(RL) indicates the lowest concentration that can be reliably calculated and reported for the sampled weight used for analysis.

PC-8

PC-9

PC-10

PC-11

Gray

Light Gray

Gray

Gray

0.1003

0.1011

0.1201

0.1128

Calculated

RL ug/g

8.32

20.8

20.8

8.87

22.2

22.2

9.97

24.9

24.9

9.89

24.7

24.7

10501 Trade Ct., N. Chesterfield, VA 23236 | Phone: 804.897.1177 | Fax: 804.897-0070 | www.SanAir.com | LabReports@SanAir.com

Metals ICP-OES Disclaimer

This report is the sole property of the client account named on the chain-of-custody (COC) submitted to SanAir Technologies Laboratory, Inc. (SanAir). Results in the report are confidential information intended only for the use by the customer listed on the chain of custody. Neither results nor reports will be discussed with or released to any third party without our client’s written permission. Final reports cannot be reproduced, except in full, without written approval from SanAir to assure that parts of the report are not taken out of context. This report and any information contained within shall not be edited, altered, or modified in any way by any persons or agencies receiving, viewing, distributing, or otherwise possessing a copy of this final report. The laboratory reserves the right to perform amendments to any finalized report, of which shall supersede and make obsolete any previous editions. Such changes, modifications, additions, or deletions shall be effective immediately upon notice thereof, which may be given by means including but not limited to posting on the SanAir client portal website, electronic or conventional mail, or by any other means.

The information provided in this report applies only to the samples submitted and is relevant only for the date, time, and location of sampling. The accuracy of the results of the analysis is dependent upon the method of sample procurement and information provided by the client on the COC. SanAir is not responsible for the method of sample procurement. SanAir assumes no responsibility for information provided by the client on the COC such as project number, project name, collection dates, po number, special instructions, samples collected by, sample numbers, sample identifications, sample type, selected analysis type, flow rate, total volume or area, and start stop times that may affect the validity of the results in this report. SanAir only assures the precision and accuracy of the data it generates and assumes no responsibility for errors or biasing that occur during collection prior to SanAir’s receipt of the sample(s). Evaluation reports are based solely on the sample(s) in the condition in which they are received at the laboratory and on the information provided by the client on the COC. Sample(s) were received in good condition unless otherwise noted on the report. All quality control results are acceptable unless otherwise noted. SanAir does not make contamination corrections to reports based upon analysis of laboratory and/or field blanks. When the client requires samples to be tested that deviate from a specific method or condition, all reported results may be affected by the deviation. SanAir assumes no responsibility or liability for the manner in which the results are used or interpreted.

SanAir’s Method Detection Limits (MDL) and Reporting Limits (RL) have been derived using various materials meeting each accrediting agencies’ standards; the MDL and RL may not be relevant or applicable for other forms of materials. Measurement uncertainty has been evaluated for this test method and is available upon request. All bulk samples are disposed of after 60 days unless otherwise requested by the client. Air samples are consumed during sample preparation and analysis, therefore there is no sample retention for this matrix.

SanAir Technologies Laboratory, Inc. participates in the Environmental Lead Accreditation Program (ELAP) administered by AIHA LAP, LLC (Laboratory ID LAP-162952) and has met the EPA's NLLAP program standards;

and the Industrial Hygiene Laboratory Accreditation Program. SanAir also participates in the State of New York’s DOH-ELAP program (NY Lab Id No. 11983) and the Commonwealth of Virginia DCLS Program (VA Lab ID#460251). This report does not constitute nor shall be used by the client to claim product, process, system, or person certification, approval, or endorsement by AIHA LAP, LLC, NELAC, NIST, and/or any other U.S.

governmental agencies. All or some test results contained in this report may not be accredited by every local, state or federal regulatory agency. Refer to the SanAir website at www.sanair.com for copies of current certificates and scopes of various accreditations, certifications, and licenses or contact the laboratory for inquiries regarding the status or scope of an accreditation or certification.

AIHA LAP, LLC Lab ID: LAP-162952 Commonwealth of VA Department of General Services DCLS, VELAP Laboratory ID#460251 New York State Department of Health Laboratory ID No: 11983 State of Connecticut Department of Public Health Environmental Laboratory Registration Number: PH-0105

Revision Date 4/6/2026

Summary of OSHA Recommendations