A07 ATTACHMENT 0045 TE 4.24 Lead Based Paint Management.pdf

LEAD-BASED PAINT MANAGEMENT PLAN

ROCK ISLAND ARSENAL

ROCK ISLAND ILLINOIS 61299-5000

This plan is consistent with EPA, OSHA, and Illinois Department of Public Health regulations, and provides guidelines for the effective management of lead-based paint and associated hazards at the Rock

Island Arsenal.

I. Section A – Policy Pg. 2

II. Section B – Lead-Based Paint Management Program Pg.2

A. Objective

B. Background

C. Scope

III. Section C – Lead-Based Paint Control Program Pg.3

A. Program Responsibility

B. Lead Based Management Team

C. Authority and Responsibility

IV. Section D - Practices and Procedures Pg. 9

A. Lead Based Paint Inspections

B. Training

C. Lead Based Paint Control Actions

D. Disposal

TE 4.24 Lead Based Paint Management

I. Section A - Policy

A. It is the policy of the Rock Island Arsenal to provide a healthful living and working environment for housing occupants, employees and other personnel working in or using RIA facilities. Prevention of lead poisoning is an integral part of this policy. The following policies have been adopted to reach the goal of lead hazard free environments.

1. No paint in liquid form, which contains more than 0.06% lead by weight, shall be used in family housing units or RIA buildings.

2. Lead-Based Paint (LBP) shall be handled, stored, transported and disposed of in accordance with (IAW) Federal, State, Local and Dept. of Army requirements.

3. Exposure to lead hazards shall be minimized by risk assessment surveys, reassessment surveys, properly implemented work practices, an aggressive LBP operation and maintenance program and the use of appropriate personal protective equipment (PPE) as required.

4. The RIA will identify budgetary requirements for the abatement of lead hazards to higher headquarters and will provide interim controls for known lead hazards within family housing units.

II. Section B - Lead-Based Paint Management Program

A. OBJECTIVE: The Lead-Based Paint Management Program (LBPMP) is the mechanism for implementing actions necessary to protect Rock Island Arsenal housing occupants and personnel from exposure to lead hazards such as lead containing dust, paint chips and soil, through the following:

1. The control of health hazards to building occupants to ensure environmental protection.

2. Identify, record and assess existing deteriorated paint conditions at the RIA.

3. Proper management of identified LBP (through hazard reduction, abatement and Operation and Maintenance [O&M] actions).

4. Compliance with applicable laws and regulations pertaining to lead-based paint.

B. BACKGROUND: LBP has been proven to be a health hazard when ingested or inhaled, especially by children under six years old and pregnant women. LBP was used extensively in facilities constructed prior to 1960 and randomly up to 1978.

C. Scope: The LBPMP encompasses all activities involved in the management and control of LBP hazards at the Rock Island Arsenal. The program consists of five elements:

1. Risk Assessment Survey: Risk Assessments are conducted to determine the presence of lead based paint hazards and suggest appropriate hazard control measures. The assessment consists of a review of facility painting records, visual inspections, wipe samples for lead dust, paint chip samples from deteriorated paint surfaces, limited soil sampling, and interviews with occupants of the facility when applicable. All assessments will be conducted by non-government licensed personnel.

2. Evaluation of Findings: Data gathered from interviews, visual inspections and environmental sampling are reviewed by a non-government licensed risk assessor to determine whether any lead-based paint hazards are present.

3. Interim LBP Control Hazards: Lead-based paint hazards, which have been identified, are reviewed to ascertain the location of lead paint that created the hazard. A cost effective, interim control is then implemented to clean up and eliminate the lead hazard and source. Interim controls include methods such as specialized cleaning, minor wet scraping and encapsulation.

4. Long Term Abatement: Lead hazards, which have been identified and corrected by interim controls, will be scheduled for permanent repair as funding becomes available. These repairs may be accomplished by many different methods such as building component replacement, enclosure or actual paint removal.

5. Operation and Maintenance (O&M): The O&M program monitors LBP conditions through re-evaluation, risk assessments and occupant awareness training. Reevaluations and risk assessments are scheduled at routine intervals as determined by statute, regulations, and technical bulletins.

III. Section C - Lead-Based Paint Control Program

A. PROGRAM RESPONSIBILITY: The RIA Commander is responsible for the overall management of lead-based paint and associated hazards. The Commander will:

1. Establish an Installation Lead Hazard Management Team (LHMT) to administer the Rock

Island Arsenal's lead-based paint program.

2. Appoint the Director of Public Works as installation Lead-Based Paint Program Manager to ensure that the goals and requirements of RIA lead-based paint program are met.

3. Ensure that all personnel involved in LBP related activities receive appropriate training.

4. Support program efforts and attempt to obtain funding for projects.

B. LEAD HAZARD MANAGEMENT TEAM:

1. The Lead-Based Paint Management Team coordinates and executes the LBP Management plan to include:

Assessment of the program to ensure it remains current with new regulatory requirements.

b. Assure that accurate records of LBP assessments, projects and actions are maintained.

c. Ensure that required LBP reevaluations and risk assessments are conducted.

d. Review and update the installation lead hazard management plan.

e. Develop public awareness notifications.

2. The Lead-Based Paint Management Team shall meet annually or as required. The LBP

Program Manager shall be the Director of Public Works. The LBP Team shall be comprised of personnel representing the following:

a. Director of Public Works

b. Directorate of Public Works Environmental Division

c. Preventive Medicine Office

d. RIA Safety Office

e. RIA Public Affairs Office

f. RIA Legal Service Office

g. RIA Housing Office

h. Child and Youth Services

i. Directorate of Public Works Engineering Services

j. Division

C. Authority and Responsibility:

1. LBP Program Manager will:

a. Appoint by letter a LBP Control Officer and an alternate to administer lead policies in non-housing buildings.

b. Carry out the goals and objectives of the RIA LBP Management Plan.

c. Advise the Installation Commander on LBP related issues.

d. Assure that up-to-date LBP records are kept.

e. Annotate master planning documents to indicate on the government property book which properties contain LBP.

f. Provide supervision and input as necessary to assure that an effective lead-based paint management program is maintained.

g. Ensure that the LBP Control Officer is properly trained.

h. Ensure that the RIA housing manager is properly trained.

i. Monitor the lead program to ensure compliance with the RIA Lead-Based Paint

Management Plan.

j. Establish a database for the purpose of documenting lead hazard inspections and associated actions in all RIA facilities.

2. Lead-Based Paint Control Officer will:

a. Report to LBP Program Manager on matters relating to the status of the RIA Lead

Hazard Management Team.

b. Maintain and update lead files after each reevaluation or new assessment for RIA buildings and child care facilities excluding RIA housing.

c. Maintain current EPA certification as a Lead-Based Paint Risk Assessor, and Inspector.

d. Organize and oversee the activities of the Lead Hazard Management Team (LHMT), coordinating efforts and expertise of the LHMT.

e. Review the LBP Management Plan at a minimum annually to determine compliance with the latest Federal, State, local and Dept. of Army requirements and recommend changes to the plan to the LHMT.

f. Respond to complaints, in conjunction with Preventive Medicine, and the RIA Safety

Office to assess materials, their condition and the exposure hazard they represent.

g. Arrange for the testing of dust wipe samples, paint chip samples and soil samples by a laboratory successfully participating in the American Industrial Hygiene Association's Environmental

Lead Proficiency Analytical Testing Program.

h. Coordinate the Directorate of Public Works lead abatement program, with funding available and known lead hazards

i. to form a comprehensive, cost effective lead management program.

j. Coordinate cleanup efforts to assure compliance with

k. applicable laws, regulations, and technical bulletins.

l. Review design plans, specifications and contracts for lead related work.

m. Ensure that waste generated by LBP cleanup or abatement projects is disposed of in accordance with applicable statutes and regulations.

n. Conduct periodic surveys of lead abatement work and cleanup efforts to assure that all work meets applicable standards and regulations.

o. Coordinate the RIA LBP maintenance program to assure that a safe and healthful living and working environment is maintained for all employees, and visitors to RIA facilities.

p. Ensure that all government and contractor personnel involved with lead work receive proper training, which complies with Federal, State, local, and Dept. of Army requirements.

q. Review proposed contracts and recommend LBP abatement projects to the LBP

Program Manager.

r. Maintain training records of employees performing LBP duties.

3. Directorate of Public Works Engineering and Services Division will:

a. Assume responsibilities and authority for lead matters in RIA buildings.

b. Assure proposed construction sites are tested for the presence of LBP prior to design procedures.

c. Inspect all lead-related work with Safety, Health, and Environmental Offices to ensure that projects are accomplished in a safe, efficient manner and comply with statutory and regulatory standards.

4. Directorate of Public Works Environmental Division will:

a. Review Federal, State, local laws and Dept. of Army regulations related to lead-based paint work and forward recommendations to the Lead-Based Paint Program Manager concerning compliance requirements.

b. Refer any health and safety problems to the Safety or the Preventive Medicine Offices as appropriate.

5. The Local Medical Authority will:

a. Institute a Medical Surveillance Program for children under six years old and employees in accordance with Federal, State, Army and local regulations.

b. Ensure that all medical examinations and procedures are performed by or under the supervision of a licensed physician IAW all Federal, State and Dept. of Army regulations.

c. Maintain an accurate medical record for each employee and child subject to medical surveillance.

d. Bi-annually inspect Family Child Care homes to assure local compliance. Report problems to the Lead-Based Paint program manager.

e. Notify the Lead-Based Paint program manager of all elevated blood lead test results.

6. Industrial Hygiene Activity will:

a. Ensure that air sampling and laboratory analysis procedures used by contractors are in compliance with Federal, State and Dept. of Army regulations.

b. Conduct periodic work site visits of lead abatement projects to assure compliance with applicable statutes and regulations.

$2000.00.

c. Review design plans and contract specifications for all work related to lead exceeding

Manager.

d. Function as a program monitor and report deficiencies to the Lead-Based Paint Program

e. Provide quantitative respirator fit testing and respirator selection for employees that are required to utilize them.

7. Safety Office will:

a. Assist in safety matters related to lead-based paint abatement.

b. Respond to and investigate lead related employee/ occupant complaints of unsafe living or working conditions.

c. Conduct periodic surveys of lead-based paint abatement projects to determine compliance with applicable regulations.

d. Review design plans, contractor specifications and contracts for lead abatement projects and construction work.

e. Review the RIA LBP Management Plan annually to determine compliance with current statutes and regulations. Recommend required changes to the Lead Program Manager.

8. Legal Office will:

a. Review Federal, State, local laws and Dept. of Army regulations related to lead

b. Assist in interpreting laws and regulations.

9. Public Affairs Office will:

a. Respond to inquiries regarding LBP from the media or local based agencies based on input from the appropriate RIA offices.

b. Initiate press releases when authorized by the RIA Garrison Manager.

c. Provide command information to employees when necessary.

10. Child and Youth Services will:

a. Assure that pre-1960 housing coded amber will not be certified for family childcare.

b. Assure that no housing unit classified as red will be certified for family childcare.

11. The RIA Housing Office will:

a. Be responsible for compliance with all lead-based paint statutory and regulatory requirements as well as the RIA Lead-Based Paint Management Plan in RIA housing.

b. Ensure that annual and between occupancy risk assessment inspections of all regulated housing units are conducted.

c. Ensure that lead hazard clean up and associated clearance sampling as required by statute or regulation are conducted.

d. Maintain up to date lead-based paint files after each reevaluation, risk assessment, and lead hazard clean up or lead paint abatement action for each housing unit. These files shall contain all lead-related documentation for each housing unit to include risk assessment documents, laboratory results, work orders, contracts, estimates etc.

e. Arrange for the testing of dust wipe samples, paint chip samples and soil samples by a laboratory successfully participating in the American Industrial Hygiene Association's Environmental

Lead Proficiency Analytical Testing Program.

f. Coordinate the RIA housing lead abatement program, with the lead control officer to form a comprehensive, cost effective lead management program.

g. Ensure that waste generated by LBP cleanup or abatement projects is disposed of in accordance with applicable regulations.

h. Provide a safe and healthful living environment for all housing tenants.

i. Ensure that all personnel involved with lead work are properly trained and licensed.

or red.

j. Notify Child Youth Services should a post 1960 housing unit status change from amber k.Distribute a LBP awareness package to all military families assigned to the RIA. This package shall contain information on lead poisoning prevention and State and local program requirements pertaining to lead-based paint hazards.

l. Disclose the presence of known lead-based paint and lead paint hazards in RIA housing to housing tenants. Provide housing inspection records and appropriate lead warning statements as requested.

m. Ensure that all housing occupants acknowledge, in writing, the receipt of the LBP disclosure and awareness package.

n. Ensure that all families who occupy housing with lead paint or lead paint hazards are instructed on general cleaning procedures and monitoring for deteriorating conditions.

o. Maintain a file of contractor training certificates and licenses.

p. The housing manager shall review the risk assessor’s report after each inspection and categorize the housing units into one of three groups (green, amber or red).

1) A green unit is free of LBP with all painted surfaces intact.

2) An amber unit is a unit, which contains LBP. The paint must be in good condition;

dust wipe sample results must show no lead hazards present.

3) A red unit is a unit, which contains deteriorated paint or dust wipe sample results show lead hazards present.

q. Coordinate with the lead control officer and the local medical authority and institute appropriate inspections and cleanup measures when notified of an elevated blood lead test result.

IV. Section D - Practices and Procedures

A. Lead-Based Paint Risk Assessment Inspections:

1. Purpose: To perform a systematic inspection of housing and child day care facilities to obtain reliable information on the presence and condition of lead-based paint and any lead hazards which might exist.

2. Risk Assessment Survey Requirements and Procedures In RIA Housing Units:

a. Risk assessments shall be conducted in accordance with 24 CFR Part 35 and Chapters 5 and 6 of HUD Lead-Based Paint Guidelines.

b. The Chapter 5 requirements for targeted sampling shall be used.

c. Visual assessments of painted surfaces, building conditions and common areas shall be conducted in accordance with HUD Guidelines.

d. Dust sampling by single surface method shall be conducted in all scattered site housing, multifamily housing, community buildings, day-care facilities, recreational areas and any other space frequented by children.

e. Paint chip samples shall be collected from deteriorated painted surfaces.

f. Composite soil samples shall be collected from areas, which are frequented by children.

g. All dust, paint, and soil sample laboratory results shall be evaluated and site-specific hazard controls implemented where required.

h. Long term plans for LBP remediation shall be developed along with an estimated cost for the remediation process.

i. Reassessments shall be conducted annually and between occupancies, or more frequently as required by law or regulation.

j. Tenant education shall be an integral part of the risk assessment process. Tenants shall receive information on identified hazards and how to reduce exposure to LBP and possible health effects.

k. The risk assessor shall provide a written report of identified hazards as well as hazard control recommendations to the RIA housing office.

B. Training:

1. All RIA and contractor personnel conducting LBP risk assessment and inspections shall have successfully completed EPA and IDPH recognized courses in LBP Inspection and Risk Assessment and possess a current license.

2. RIA personnel shall keep required LBP credentials current as required by applicable regulations.

3. Contractor personnel conducting LBP abatement or other related type lead work shall have successfully completed an EPA and IDPH recognized course as a worker or a contractor supervisor and have current IDPH licenses.

4. All on-going LBP abatement work shall be directly superintended by a lead accredited contractor supervisor.

C. Lead-Based Paint Control Actions:

1. Housing with children younger than 6 years old or pregnant women shall receive hazard correction first. Hazard correction encompasses various techniques such as cleaning, encapsulation, and removal.

2. All identified lead hazards shall be assessed and prioritized by the potential the hazard has to create health-related problems within the facility. Hazards with the greatest health risk shall receive repairs first.

3. Interim controls shall be implemented as required to provide a safe and healthful living and working environment.

4. Plans for long-term LBP remediation shall be developed and appropriate documentation forwarded to higher headquarters.

D. Disposal:

1. All debris associated with lead work shall be collected and placed into an appropriate container and properly labeled.

2. When the drum has been filled it shall receive a toxicity characteristic leaching procedure test to determine the type of waste and proper disposal method.

3. Hazardous wastes or special wastes shall be disposed of at a proper site in strict accordance with Federal, State, and local regulations.

4. All hazardous or special wastes shall be properly manifested and documented.