Additional Requirements for Asbestos-lead.docx

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Y1DA--663A4-22-202 AMLK Install Sprinkler and Water Main Connection to Building 16
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36C26025R0053
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This document details additional requirements for handling lead-based paint and asbestos during a VA construction project at Veterans Health Administration facilities. The contractor must treat unpreviously sampled painted surfaces as containing lead-based paint until certified by a Washington State Department of Commerce LBP Inspector and analyzed by an EPA-accredited laboratory. All work disturbing painted surfaces must comply with OSHA 29 CFR 1926.62 Lead regulations, including engineering practices, employee training, protective equipment, and lead exposure assessments. While the VA can provide existing asbestos and lead-based paint survey reports, these do not meet pre-renovation/demolition NESHAP requirements, necessitating a comprehensive survey of impacted building areas prior to project commencement.

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Lead-based paint Any painted surfaces that have not been previously sampled for lead must be treated as containing lead-based paint until determined otherwise by a Washington State Department of Commerce certified LBP Inspector and analyzed by an accredited lab under the EPA’s National Lead Laboratory Accreditation Program (NLLAP).

The Contractor must ensure that all work that disturbs painted building substrates, including but not limited to, manual demolition, removal of paint from building substrates, removal of building components, and preparation of surfaces for painting, must comply with requirements of OSHA 29 CFR 1926.62 Lead. This including, but not limited to: engineering and work practices; employee training, personnel protective equipment, and employee lead exposure assessment while working at the VA owned properties.

Asbestos VA can provide both the current asbestos and lead based paint survey reports to the contractor. However, these reports do not meet the pre-renovation/demolition requirements as described in the National Emission Standards for Hazardous Air Pollutants (NESHAP) regulation. Therefore, the impacted areas of the building must be surveyed for asbestos/Lead prior to the start of the project.

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