Attach__No__1B_-_AF_Policy_on_LBP.pdf

Air Force Policy and Guidance on Lead-Based Paint in Facilities

DEPARTMENT OF THE AIR FORCE

OFFICE OF THE CHIEF OF STAFF

UNITED STATES AIR FORCE:

WASHINGTON DC 2033

24 MAY 1993

FROM: HQ USAF/CC

1670 Air Force Pentagon Washington, DC 20330-1670

SUBJ: Air Force Policy and Guidance on Lead-Based Paint in Facilities

TO: ALMAJCOM-FOA/CC HQ AFDW/CC

1. Ingestion of lead or lead dust can cause serious adverse health effects in adults and especially in children. The attached policy specifies the actions required to protect facility occupants and workers and the environment from hazardous exposure to lead in lead-based paints. The policy applies to all Air Force active, Air National Guard and Air Force Reserve installations and facilities, regardless of location.

2. Please give this matter your prompt attention so that personnel living on our installations, their families and all who work there will be adequately protected.

MERRILL A. McPEAK, General, USAF Chief of Staff 2 Atch

1. Lead-Based Paint Policy

2. Lead-Based Paint Guidance

AIR FORCE POLICY

ON

LEAD-BASED PAINT IN FACILITIES

1. References.

a. House of Representatives Report 102-95, Fiscal Year 1992 Department of Defense (DoD) Appropriations Act.

b. 16 C.F.R. 1303, Ban of Lead-Containing Paint and Certain Consumer Products Bearing Lead-Containing Paint, implementing the Consumer Product Safety Act of 1977.

c. 24 C.F.R., Part 35, Lead-Based Paint Poisoning Prevention in Certain Residential Structures.

d. Title 42 U.S-C., Section 4822, as amended, Lead-Based Paint Poisoning Prevention Act (LBPPPA) of 1971.

e. Federal Register, 18 April 1990, Vol. 55, No. 75, Department of Housing and Urban Development, Lead- based Paint:

Interim Guidelines for Hazard Identification and Abatement in Public and Indian Housing, as amended, September 1990.

f. 29 C.F.R. 1926, Safety and Health Regulations for Construction.

g. 29 C.F.R. 1910.1025, Occupational Safety and Health Standards, Lead.

h. 40 C.F.R. 50.12, National Primary and Secondary Ambient Air Quality Standards for Lead.

i. 40 C.F.R. 240 through 280, implementing the Resource Conservation and Recovery Act (RCRA).

j. 40 C.F.R. 302, implementing the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).

k. DoD Directive (DODD) 6050.16, DoD Policy for Establishing and Implementing Environmental Standards at Overseas Installations.

1. P.L. 102-550, Title X, Residential Lead-Based Paint Hazard Reduction Act of 1992.

m. 15 U.S.C. 2601 et seq., The Toxic Substances Control Act (TSCA).

2. Application.

a. This policy applies to all Air Force, Air National Guard, and Air Force Reserve active installations and facilities, including overseas locations.

b. Compliance with applicable federal, state, interstate, and local laws and regulations for LBP/activities, environmental protection, and occupational health and safety is required.

Refer to the attached guidance for procedures and practices needed to implement this policy.

3. Background. Ingestion of lead or lead dust can cause a variety of adverse health effects in children and adults. Lead pigments in paint applied to facilities can be a source of hazardous exposure to lead. Children are at greater risk due to their lower body weight, developing nervous system, and greater tendency to ingest paint chips and dust. Based on common painting practices and legal restrictions, LBP is likely to be found in all industrial facilities, on all steel structures (water tanks, pipelines, etc.), in yellow painted pavement markings, and in non-industrial facilities constructed priority 1980. Painted ferrous metal surfaces in non-industrial facilities constructed during or after 1980 are also likely to contain LBP.

4. Legislation and Regulations. Congress directed the Department of Defense (DoD) to take a more active role in ensuring military dependent children are not affected by LBP health hazards (reference la.). Prior legislation restricted lead in paint used in non-industrial facilities effective ift-1948 (reference 1b) and in residential structures constructed and rehabilitated by federal agencies (reference 1c). The LBPPPA and associated guidelines took steps to eliminate LBP in Public and Indian Housing (references 1d and 1e). Occupational Safety and Health Administration regulations specify worker protection requirements in the construction and general industry (references if and 1g), and environmental regulations address restrictions on emissions (reference 1h) and when LBP debris must be controlled as a hazardous waste (references 1i and lj). The LBPPPA and TSCA were amended and a program established to evaluate and reduce LBP in housing (references 1l and 1m).

5. Terms Explained.

a. LBP Hazard Determination. A specific determination made by Base Bioenvironmental Engineering in consultation with Base Civil Engineering. A hazardous situation generally exists if children under age seven are chewing on painted surfaces or are exposed to LBP dust, soil contaminated with lead or deteriorated LBP (i.e., flaking, peeling, chipping, or cracking), or if other occupants or workers are subjected to prolonged or repeated exposure to airborne LBP dust.

b. In-Place Management. Interim measures which reduce an LBP hazard to acceptable levels. They include monitoring the condition of painted surfaces and reducing dust by high phosphate detergent washing or top coating by painting or wall coverings, repairing deterioration by painting, and performing cleanup activities such as high-efficiency particle air (HEPA) vacuuming, disposing of contaminated carpeting, and decontaminating upholstered furniture to the maximum extent possible and the establishment and operation of resident and management education programs.

c. Abatement. Long-term or permanent measures which eliminate the possibility of hazardous exposure by replacement of building components (doors, cabinets, molding, etc.) , encapsulation with drywall or siding, and removal (reference 1d).

May be applied throughout a facility or in selected areas only.

6. Actions To Be Taken. Air Force installations will:

a. Identify, evaluate, control, and eliminate existing LBP hazards. Give priority to facilities or portions of facilities which are frequented by children under age seven and areas in those facilities which contain painted surfaces in deteriorated condition. Consider using in-place management first to reduce the risk of hazardous exposure to acceptable levels. Perform abatement when in-place management will not control the hazard effectively or when it is cost-effective during normal facility renovation and upgrade programs.

b. Protect facility occupants, especially children, and workers from existing LBP hazards. Ensure facility occupants are removed from a hazard area and blood lead level determinations are performed as soon as possible on children under seven who have been exposed. Perform investigations when children with elevated blood lead levels are identified and determine the source of lead and remedial actions.

c. Prevent-LBP hazards from developing. Take precautions when disturbing LBP and when maintenance, repair, modification, and renovation activities disturb painted surfaces in priority facilities and other facilities likely to contain LBP.

d. Restrict Use of LBP. Do not specify, purchase. use, or approve for use on any existing or proposed industrial or non-industrial facility paints or coatings containing lead above the regulated amount specified for non-industrial facilities.

e. Comply with Environmental Protection Regulations.

Evaluate LBP debris in accordance with RCRA and comply with transportation, treatment, storage, and disposal requirements.

Comply with CERCLA requirements if a reportable amount of hazardous debris is released. Comply with TSCA requirements for LBP activities. Ensure ambient air quality standards are not violated.

f. Identify, evaluate, and remediate past LBP hazards. Determine the use of LBP on facilities and the potential for LBP debris to have accumulated in the area surrounding facilities.

7. Responsibilities. The following functional area responsibilities are assigned to implement this policy.

a.Civil Engineering (AF/CE): Ensures that facilities are inspected on a prioritized basis for deteriorated painted surfaces, appropriate in-place management and abatement are performed, and occupant relocation actions are taken when an LBP hazard determination is made. Ensures that precautions for occupant, worker, and environmental protection requirements for proper disposal of LBP debris, and restrictions on lead in paints are included in all maintenance, repair, modification, renovation, and construction activities performed in-house or by contract or self-help. Ensures all lead-paint activities are performed by workers or designers certified by the appropriate agency. Plans for abatement of LBP when cost-effective during facility renovation and upgrade programs.

b .Medical Services (AFMOA/SG): Ensures that facilities are evaluated for LBP hazards on a prioritized basis and appropriate LBP hazard determinations are made. Ensures that investigations to determine the sources of elevated blood lead levels are performed. Provides consultation on and supports all activities which disturb or may disturb LBP including maintenance, repair, modification, renovation, in-place management, and abatement.

Provides lead exposure prevention education to occupants of military family housing, facility managers, and other appropriate personnel.

c.Logistics (AF/LG): Ensures paints with lead above the regulated amount are not issued for use in any facility.

d.Other Functional Areas (AF/JA, SAF/PA, AF/MW): Ensure consultative services and other necessary support are provided to AF/CE and AF/SG for activities involving LBP.

8. Funding. Each Air Force organization will program and budget for their requirements using the applicable appropriations: Operations and Maintenance; Military Construction; military Family Housing (MFH); Research, Development, Test and Evaluation; Defense Environmental Restoration Account; Medical; and other base tenant funding.

a. Table I and accompanying notes cite Element of Expense Investment Codes (EEICs) and Program Element Codes (PECs) used for the major activity categories outlined in this policy. These codes provide a mechanism to identify requirements in the budget advocacy process and capture expenditures during program execution.

b.In addition, installations must track in-house costs for all LBP activities. Each installation will assign at least three work orders, and others as applicable, for LBP activities:

O&M General Base Facilities RDT&E General Base Facilities O&M Environmental MFH OR RDT&E Environmental MFH

(1) In-house costs to capture in these work orders include site visits, inspections, management, in-place controls, removal, and disposal. Also include all documentation, record keeping, special training, documentation of training, base awareness programs, environmental controls, and disl5osal documentation costs associated with LBP. Supplies, travel and the costs of moving out of LBP contaminated facilities into "clean" ones must also be collected.

(2)To ease recognition, the first two characters used in the description of these work orders should be "LB."

c.Major commands will separately identify LBP activities in their financial plans and provide full justification. The annual budget call letter from Air Staff will provide detailed instructions.

TABLE 1: FUNDING FOR LEAD-BASED PAINT REQUIREMENTS

Categories Civil Engineering Medical

FACILITY INSPECTION X

HAZARD EVALUATION X

ABATEMENT/IN-PLACE MANAGEMENT X

DISPOSAL X

TRAINING/CERTIFICATION X X

CLEANUP LINDER THE DEFENSE X

ENVIRONMENTAL RESTORATION ACCOUNT (DERA)

NOTES:

1) Element of Expense Investment Codes (EEICs) for LBP requirements will follow the standard Air Force three digit EEICs in accordance with AFR 700-20. The LBP sub-shred (suffix) will be added as follows and will apply within all PECs:

EEIC

XXX41 LBP activities, DERA funded XXX75 LBP activities, not DERA funded (for all EEICs except 534) 53476 LBP activities, not DERA funded (EEIC 534 only)

2) Program Element Codes (PECS) applicable to LBP requirements are as follows:

a) Costs for LBP activities associated with work or projects primarily justified for non-environmental reasons (renovation, upgrade, disposal, maintenance, repair, construction, etc.) are not eligible for environmental compliance funding. This work should be programmed and costed to the PEC for which the work is primarily justified. For work in this category, all the project costs, including LBP costs, must be within statutory and other approval limits.

b) The PEC for civil engineering environmental compliance requirements (other than MFH) is *****56F. This PEC will be restricted to those projects justified by the need to comply with environmental laws. Note, all civil engineering work categories listed in Table I are potentially eligible for environmental compliance funding (except for cleanup under DERA). The eligibility of environmental compliance funding will be updated as EPA promulgates its regulations.

c) MPH environmental compliance funding is tracked by BEIC under the following PECs (note civil engineering work in the Table 1 categories could fall into any of these PECs):

0808741F Construction 0808742F Improvements 0808744F Leasing 0808745F Operations 0808746F Maintenance

The PEC for medical environmental compliance requirements is 0807756F. Both categories listed as medical in Table I are eligible for this funding code.

e) The PEC for DERA is 0708008F. If contamination is determined to have been caused by past practices and contamination is found to be above the maximum contaminant levels (MCLs), the funding of the cleanup may be eligible from the DERA account. Contact your Installation Restoration Program Manager for specific details, and note that all programming of funds for this account must be submitted to the Installation Restoration Program Manager.

AIR FORCE GUIDANCE

LEAD-BASED PAINT IN FACILITIES

TABLE OF CONTENTS

INTRODUCTION

1. References

2. Purpose

3. Background

4. Legislation and Regulations

5. Terms Explained

PROCEDURES AND PRACTICES

6. Management Plan .

7. Identifying and Evaluating Existing and. Potential Lead,.

Based Paint Hazards

8. Lead-Based Paint Inspection and Evaluation Procedures

9. Testing for Lead in Paint Films

10. Precautions To Take When Disturbing LBP

11. Facility Maintenance, Repair, Modification, and Renovation Activities

12. Restricting the Use of Lead-Based Paint

13. Personnel Training Requirements

14. Lead Toxicity Investigations (LTI)

15. Major Command (MAJCOM) Responsibilities

16. Base-Level Responsibilities

17. Points of Contact

Figure 1, Page 7. Procedures for Inspecting and Evaluating High Priority Facilities

Table 1. Pages 12 and 13. Summary of Likelihood of Lead-Based Paint (LBP) Being Present and Regulations/Guidelines Which Normally Must Be Followed

AIR FORCE GUIDANCE

LEAD-BASED PAINT IN FACILITIES

INTRODUCTION

1.References.

a. 16 C.F.R. 1303, Ban of Lead-Containing Paint and Certain Consumer Products Bearing Lead-Containing Paint, implementing the Consumer Product Safety Act of 1977.

b. 24 C.F.R., Part 35, Lead-Based Paint Poisoning Prevention in Certain Residential Structures.

c. Title 42 U.S.C., Section 4822, as amended, Lead-Based Paint Poisoning Prevention Act (LBPPPA) of 1971.

d. Federal Register, 18 April 1990, Vol. 55, No. 75, Department of Housing and Urban Development (HUD), Lead-Based Paint. Interim Guidelines for Hazard identification and Abatement in Public and Indian Housing, as amended, September 1990.

e. 29 C.F.R. 1926, Safety and Health Regulations for Construction.

f. 29 C.F.R. 1910.1025, Occupational Safety and Health Standards, Lead.

g. 40 C.F.R. 50.12, National Primary and Secondary Ambient Air Quality Standards for Lead.

h. 40 C.F.R. 240 through 280, implementing the Resource Conservation and Recovery Act (RCRA) .

i. 40 C.F.R. 302, implementing the Comprehensive Environmental Response, Compensation, and Liability AC'C-

(CERCLA)-.

j. AFM 85-3, 15 June 1981, Paints and Protective Coatings, Section 1.5, Restrictions on Use of Lead-Based Paints.

k. P.L. 102-550, Title X, Residential Lead-Based Paint Hazard Reduction Act of 1992.

1. 15 U.S.C. 2601 et seq., The Toxic Substances Control Act (TSCA) .

2. Purpose. Provides guidance needed to implement and execute the Air Force policy to protect facility occupants and workers who perform maintenance, repair, modification, and renovation activities from hazardous exposure to lead in lead-based paints

(LBP) .

3. Background.

a. Ingestion of paint chips or dust containing lead can cause adverse health effects in children and adults. Lead compounds in paint applied to facilities can be a source of hazardous exposure to lead for military and civilian employees , their families, and contractors performing work in facilities. Children are at greater risk of lead poisoning due to their lower b.6dy weight, developing nervous system, and greater tendency to ingest paint chips/dust.

b. The Consumer Products Safety Act (reference 1a), restricted the amount of lead in paints manufactured after 27 February 1978 for sale directly to consumers and in paints to be used in residences, schools, hospitals, parks, playgrounds, public buildings, and other areas where consumers have direct access to painted surfaces (non-industrial facilities). Lead in paints used in industrial facilities was and is not restricted by federal law. Allowing two more years for stocks to be depleted, it is reasonable to make some assumptions concerning the use of LBP it facilities using 1980 as a transition year.

c. Certain types of paint applied before 1980 are more likely to contain lead. These are oil-based paints used in industrial facilities, on steel structures (water towers, pipelines, etc.), and in yellow airfield and roadway pavement markings. They have excellent sealing (stain resistance) and anticorrosion properties and are very durable and resistant to ultraviolet light in sunlight. They were also applied primarily to kitchens, bathrooms, and interior and exterior wood trim in residences. Latex paint for architectural use, which normally does not contain lead, became popular after 1960, and nearly all paint applied after 1980 to the interior and exterior of houses and non-industrial buildings was latex paint. This was reinforced by the Consumer Product Safety Act. However, because of their desirable properties and lack of federal regulation, LBP continued to be used in industrial facilities, on steel structures, and for pavement markings. Additionally, due to complex wording of the Consumer Product Safety Act, LBP may also be found in non-industrial facilities, primarily in primers on ferrous metal surfaces.

4. Legislation and Regulations. As previously stated, the Consumer Product Safety Act restricted lead in paints used in non-industrial facilities (reference 1a). Part 35 of 24 C.F.R. placed similar restrictions on paints used in residential structures constructed and rehabilitated by federal agencies (reference 1b). The LBPPPA and resulting HUD guidelines took steps to eliminate LBP in Public and Indian Housing (references 1c and 1d). P.L. 102-550 (reference 1k) amends the LBPPPA and TSCA (reference 1l) and requires HUD, EPA, Center for Disease Control, and Department of Labor to develop standards, guidelines, regulations, and training requirements for LBP activities. Occupational Safety and Health Administration (OSHA) regulationsspecify worker protection requirements/in the construction and general industry (references 1e and 1f), and environmental regulations address restrictions on emissions (reference 1g) and when LBP debris must be controlled as a hazardous waste (references 1h and 1i). These are described in greater detail in paragraphs 10 and 12.

5. Terms Explained.

a. High-Priority Facilities. Facilities or portions of facilities which are or may be frequented or used by children under age seven, which are further prioritized as follows: child development centers, annexes, and playground equipment; on-base Air Force licensed family day care homes; youth centers, recreational facilities, and playgrounds; waiting areas in medical and dental treatment centers; Air Force-maintained Department of Defense (DoD) schools; military family housing (MFH) currently occupied by families with children under age seven; and remaining MFH.

b. Facilities Likely to Contain LBP. LBP is likely to be found in all industrial facilities, on all steel structures (water tanks, pipelines, etc.), in yellow painted pavement markings, and in non-industrial facilities constructed prior to 1980. Painted ferrous metal surfaces in non-industrial facilities constructed during or after 1980 are also likely to contain LBP.

c. LBP Hazard Determination. P.L. 102-550 defines the term "lead-based paint hazard" as "any condition that causes exposure to lead from lead-contaminated dust, lead-contaminated soil, lead-contaminated paint that is deteriorated or present in accessible surfaces, friction surfaces, or impact surfaces that would result in adverse human health effects as established by the appropriate Federal agency." Until final regulations are promulgated by EPA under this law, a specific determination of actual (versus potential) hazard must be made by Base Bioenvironmental Engineering in consultation with Base Civil Engineering personnel. LBP will generally result in adverse human health effects and is considered to be hazardous under the following conditions:

(a) Children under age seven chewing or mouthing on painted surfaces or when they are exposed to LBP dust, soil contaminated with lead, LBP which is in deteriorated condition (i.e., flaking, peeling, or cracking).

(b) Prolonged or repeated exposure of other facility occupants or workers to airborne LBP dust.

d. In-Place Management. Interim measures which reduce the LBP hazard to acceptable levels. They include monitoring the condition of painted surfaces; reducing or eliminating dust by high phosphate detergent washing or top coating with latex paint or wall coverings; repairing deterioration with latex paint; and performing cleanup activities such as high-efficiency particle air (HEPA) vacuuming, disposing of contaminated carpeting, and decontaminating upholstered furniture to the maximum extent possible.

e. Abatement. Long-term or permanent measures which eliminate the possibility of hazardous exposure by replacement of building components (doors, cabinets, molding, etc.), encapsulation with drywall or siding, and removal (reference 1d).

May be applied throughout a facility or in selected areas only.

f. Paint Deterioration. Any degradation of the paint film that produces dust or paint chips such as chalking, peeling, flaking, blistering, or loose paint.

g. Clearance Sampling. The procedure used in high-priority facilities to determine if cleanup activities following maintenance or disturbance of LBP surfaces have been effective in reducing the amount of surface lead dust. Following cleanup activities, lead dust concentrations must not exceed 200 micrograms per square foot (200 ug/ft2) on floors, 500 ug/ft2 on window sills, or 800 ug/ft2 in window wells as determined by wipe sampling performed in accordance with a procedural guidance manual provided by Armstrong Laboratory. Facilities with lead dust levels in excess of these limits will be recleaned, sampled, and meet these standards prior to reoccupancy.

PROCEDURES AND PRACTICES

6. Management Plan. Each installation must develop and implement a plan for identifying, evaluating, managing, and abating LBP hazards. The plan should:

a. Include a strategy for (1) identifying, evaluating, controlling, and eliminating existing LBP hazards and preventing new hazards from developing; (2) protecting facility occupants, especially children, and workers from LBP hazards; and (3) ensuring compliance with all applicable environmental protection requirements and all laws and regulations pertaining to LBP activities.

b. Be an integral part of their overall plan for inspecting, constructing, upgrading, repairing, maintaining, and demolishing the facility inventory.

c. Be based on local conditions and an evaluation of the health risk from LBP on base which considers available information on the condition of facilities, the results of facility inspections and evaluations, and incidents of lead toxicity resulting from LBP.

d. Give priority to finding and reducing or eliminating the risk of existing hazardous conditions in high-priority facilities.

e. Emphasize in-place management to control existing hazards and reduce the risk of hazardous exposure to acceptable levels.

f. Consider abatement of LBP as part of the normal facility renovation and upgrade programs when it is cost-effective.

g. Ensure precautions and procedures are incorporated into all maintenance, repair, renovation, and upgrade activities which are performed in-house, by contract, or self-help and which disturb painted surfaces known or likely to contain lead.

7. Identifying and Evaluating Existing and Potential LBP Hazards.

a. Depending on local circumstances, any of the following procedures may be needed to identify and evaluate existing and potential LBP hazards:

(1) Evaluations of observations from routine facility inspections and activities such as MFH walk-throughs, fire and, safety inspections, inspections for family day care home licensing, and occupant reports of deteriorated paint.

(2) Inspections and evaluations specifically designed to locate existing and potential LBP hazards do -that appropriate measures can be taken to avoid hazardous lead exposures.

(3) Facility investigations to determine the source of documented lead exposures.

b. When determining the number, extent, and schedule for each type of evaluation to be performed, maximum use should be made of available information on the condition of facilities from construction and painting histories, maintenance records, and past routine facility inspections (MFH condition walk-throughs, etc).

c. Routine facility inspections:

(1) Expand the scope of routine facility inspections by instructing appropriate personnel (e.g., facility managers; child and youth facilities managers; MFH, safety, and fire inspectors; planners; designers; O&M work force) to report signs of paint deterioration or children chewing on painted surfaces in high-priority facilities.

(2) Develop procedures to document and respond to information reported from inspections and occupants concerning potential LBP problems and the resulting evaluations and actions.

d. Facility inspections and evaluations specifically designed to locate existing and potential LBP hazards:

(1) These inspections and evaluations should focus on high-priority facilities and areas within those facilities with painted surfaces in deteriorated condition.

(2) The evaluations will be performed by a team consisting of Base Civil Engineering and Base Bioenvironmental Engineering representatives or by a qualified contractor in conjunction with a certified testing laboratory (paragraphs 10 and 13). Data reflecting facility conditions, investigative results, and resulting actions will be collected, consolidated, and analyzed by the Chief, Aerospace Medicine for reporting through Air Force medical channels.

(3) Inspections and evaluations of facilities base wide (base-wide surveys) to characterize the current state of LBP in all facilities are time-consuming and require considerable resources and a sophisticated data management system to manage large amounts of data and information. They are not recommended unless there are compelling reasons to do so.

(4) Incidents of lead toxicity and/or results obtained from routine inspections may provide justification to conduct or not conduct surveys of facilities with similar characteristics.

(5) The number of units and locations within units to be tested as described in Chapter 4 of the HUD guidelines (reference 1d) were developed solely to provide a high degree of confidence that all units would be lead free if all test results did not detect lead-based paint. This level of testing is excessive for other purposes, and testing substantially fewer units and locations within units should be adequate to characterize the extent of the hazard on base or within a facility and to prioritize evaluation and corrective actions. .

e. Investigations of facilities to determine if LBP is the source of documented lead exposures should follow procedures in paragraph 8 and any additional requirements established by the Lead Toxicity Investigation Team (paragraph 14).

f. When facility evaluations are performed, permanent records must be maintained by Base Civil Engineering and/or Base Bioenvironmental Engineering to document findings and actions in each facility evaluated. The facility jacket should be annotated the equivalent management procedure followed to show where records are kept. Examples of suggested documents to keep are found in the HUD guidelines (reference 1d) . Additional record keeping may be required to support bioenvironmental reporting, lead toxicity investigations, and RCRA requirements.

8. LBP Inspection and Evaluation Procedures. The following are general procedures for inspecting and evaluating interior surfaces of high-priority facilities and actions to take based on the resulting LBP risk assessment. See Figure 1. Exterior surfaces will be evaluated in accordance with procedural guidance provided by Armstrong Laboratory.

a. Evaluate the condition of the painted surfaces for chipping, peeling, cracking, dust and visible signs of paint chips, and evidence that children have been chewing or mouthing on painted surfaces.

b. If the surfaces are in good condition and there are no signs of paint deterioration or chewing:

(1) Instruct the occupants on proper care and maintenance of painted surfaces (vacuum frequently, wash surfaces with high-phosphate detergents' and watch for and immediately report signs of surface deterioration to Base Civil Engineering and Base Bioenvironmental Engineering).

(2) Schedule the facility for LBP testing and analysis in accordance with the established management plan. If the analysis for lead is negative, document findings. No further action is required. if the analysis for lead is positive, in-place management, including painting with latex paint, must be performed, and the facility must be considered for abatement based on the established management plan.

(3) When evaluating the risk of hazardous exposure and determining appropriate actions (abatement, in-place management, etc.) in child development centers and annexes, ensure adequate consideration is given to the number of children present, the level of supervision available, the potential for day-to-day activities to damage painted surfaces, and the potential for contamination of playground soil near the building.

c. If there are signs of paint deterioration, including evidence of chewing, and the facilities are currently occupied by families with children under seven years of age or are otherwise considered high priority (child development centers, etc), action must be taken as soon as possible to make a confirmed determination of whether or not the facility paint contains lead.

(1) Quantitatively test the paint for lead using an X-ray fluorescent spectrum analyzer according to the guidance manual to be provided by Armstrong Laboratory (paragraph 9a).

(2) If lead is found exceeding an action level of 0.5 milligrams per square centimeter in confirmation mode (or 0.5 percent by weight by laboratory test) or testing cannot be completed in an expedient time frame as determined by Base

Bioenvironmental Engineering:

(a) Ensure children are removed from the hazard area as soon as possible and instruct the occupants to report to the medical treatment facility to have blood lead level determinations performed on children under age seven.

(b) Based on the degree of hazard determined by the professional judgment of Base Bioenvironmental Engineering in consultation with Base Civil Engineering representatives, complete actions determined to be appropriate for the circumstances: closing off the area, occupant relocation, in-place management, abatement, and/or cleanup. If the area involved is in a child development center, annex, or playground or an AF-licensed day care home, coordinate actions with the Morale, Welfare, Recreation, and Services office responsible for child care facilities. Perform clearance sampling before reoccupying the facility. If total abatement has not been performed, instruct the occupants on proper care of painted surfaces and determine follow-up inspection requirements and future disposition of any remaining LBP in the facility based on the established management plan.

(c) See additional considerations for child development centers and annexes in paragraph 8b(3).

(3) If lead above the action level is not found, document the finding. No further action is required.

d. If there are signs of paint deterioration in MFH units which are not currently occupied by children under seven years of age and are not used as a family day care home, instruct the occupants that the facility will be scheduled for in-place management and cleanup at the earliest possible date and that the painted surfaces should not be disturbed by self-help or other activities. Base Civil Engineering should ensure that the facility is evaluated for LBP content during normal facility renovation and upgrade. They must also ensure no children under age seven occupy the facility until it is either confirmed not to contain LBP or appropriate in-place management or abatement, clean-up, and occupant education on care of painted surfaces have been completed.

9. Testing for Lead in Paint Films. There are two methods for testing paint films for lead content:

a. Quantitative Testing. In-place testing of paint films by a portable X-Ray Fluorescence (XRF) Spectrum Analyzer, laboratory analysis of paint samples by an Atomic Absorption Spectrum (AAS) Analyzer, or other accurate techniques approved by the American Society for Testing Materials (ASTM) or similar recognized technical authorities. Procedures for quantitative determination of lead are available from Armstrong Laboratory.

Note that the XRF action level is set lower than that specified by the KM guidelines (reference 1d) to compensate for inaccuracies in the instrument and to reduce-the need for laboratory confirmation of readings close to 1.0 milligrams per square centimeter.

b. Qualitative Testing. Spot testing which can determine the presence but not the amount of lead in paint films.

(1) Solvent Resistance Test. Paint binders or polymers vary in their resistance to solvent spot tests, and paints can be separated into generic types by these tests. The following are the most common types and their solvent resistance:

(a) Latex paints, which normally do not contain lead, soften in alcohol. Other paints do not.

(b) Alkyds and oleoresinous paints (enamels, trim paints, exterior house paints) soften in methyl ethyl ketone.

They are the binders most often used for LBP.

(c) Epoxy and polyurethane paints do not soften in alcohols and methyl ethyl ketone. They may contain lead pigments.

(2) Lead Detection Spot Tests. There are two Consumer Products Safety Agency recommended spot tests for lead:

sodium sulfide and sodium rhodizonate. These reagents change color in the presence of lead but do not accurately indicate the amount of lead.

(3) Since all layers of paint down to the substrate must be exposed to the solvent or reagent, these tests are slightly destructive and touch-up will be required unless work is to be performed immediately afterwards. Ensure a sufficient number of tests are performed on the various types of surfaces and locations where work is to be performed.

10. Precautions To Take When Disturbing LBP. Precautions must be taken to protect facility occupants (especially children), workers, and the environment when disturbing LBP during in-place management, abatement, maintenance, repair, modification, renovation, upgrade, and demolition activities. Table 1 (pages 12 and 13) contains a summary of which regulations and guidelines normally apply depending on the type of facility and surface involved if acceptable qualitative or quantitative testing is not used to clearly establish the absence of LBP. Personnel performing these activities must be properly trained so that they understand the potential hazards involved and can apply the appropriate measures to prevent hazardous exposure (paragraph 13). Additional application guidance is provided in paragraph 11.

a. HUD Guidelines (reference 1d) were developed in response to the LBPPPA. They address occupant protection measures, as well as many of the precautions contained in other regulations, to be taken when performing abatement activities.

They also specify an action level (more than 1 milligram of lead per square centimeter or more than 0.5 percent of lead by weight) which determines when LBP must be abated in Public and Indian Housing. They are considered to be the best available information for safely performing abatement activities in housing facilities. Due to their emphasis on protection of children, the following general precautions should be considered for all activities disturbing LEP in high-priority facilities. These are in addition to the worker and environmental protection requirements specified in the regulations below.

(1) Preplanning

(2) Choosing an Abatement Strategy

(3) Occupant Protection When Abating LBP

(4) Laboratories for Paint, Dust, and Blood Lead Analysis

(5) Quality Assurance Guidance

(6) Cleanup and Clearance Sampling Process,

(7) Worker Training

b. The 29 C.F.R. 1926 and 29 C.F.R. 1910.1025 (references 1e and 1f) specify measures to protect workers against hazardous exposure to lead in the construction and general industry. They include the permissible exposure limit (PEL), exposure monitoring, engineering, work practice and administrative controls, respiratory protection, protective clothing, house-keeping and hygiene, medical surveillance, employee training, warning signs, and "hazard communication." Air Force activities (in-house and contract) must adhere to the stricter general industry standard (29 CFR 1910) for all work. Do not use the construction work standard (29 CFR 1926). Refer to the general industry standard in contract specifications. Note that many requirements can be simplified or avoided if work practices which reduce and control dust (wet sanding, wet drilling, etc.) are used.

c. The 40 C.F.R. 50.12 (reference 1g) contains ambient air quality standards that are levels of air quality which the Environmental Protection Agency determines necessary to protect public health and welfare. Check with the local regulatory agency to determine the applicability of ambient air quality standards to large-scale, lead-abatement projects.

d. RCRA regulations (reference 1h) specify that LBP debris is considered a hazardous waste when the leachant exceeds 5 parts per million from a 100-gram sample or 5 milligrams per liter by the Toxicity Characteristic Leaching Procedure (TCLP) . They also specify transportation, treatment, storage, and disposal requirements.

e. The 40 C.F.R. 302 (reference 1i) implements the Comprehensive Environmental Response, Compensation, and Liability

Act (CERCLA). CERCLA regulations contain notification requirements when hazardous substances are accidentally released into the environment in quantities equal to or in excess of the reportable quantity (RQ) . The RQ for lead is one pound.

f. P.L. 102-550, enacted 29 October 1992, makes the Federal Government subject to the same stringent LBP laws and regulations as nongovernment entities, including certification, licensing, TABLE 1

Summary of Likelihood of Lead-Based Paint (LBP) Being Present and Regulations/Guidelines Which Normally Must Be Followed

HIGH-PRIORITY (H-P) FACILITIES

Facility Type LBP Likely HUD OSHA RCRA AIR

MFH/Day Care Home, Yes Yes Yes Yes No Before 1980

MFH/Day Care Home, No Yes No No No During/After 1980

Other H-P Facilities Yes Yes Yes Yes No Before 1980

Other H-P Facilities, Yes* Yes Yes Yes No During/After 1980, Ferrous Metal Surface

Other H-P Facilities, No** Yes No No No During/After 1980, Other Surfaces

OTHER FACILITIES (NOT H-P)

Facility Type LBP Likely HUD OSHA RCRA AIR

Steel Structures Yes No Yes Yes Yes

Industrials Yes No Yes Yes No

Painted Yellow Pave- Yes No Yes Yes No ment Markings

Nonindustrials, Yes* No Yes Yes No Ferrous Metal Surfaces

Nonindustrials, No** No No No No During/After 1980, Other Surfaces

* CPSC restriction uncertain but common practices favor lead present ** CPSC restriction uncertain but common practices favor lead absent

TABLE I

(CONTINUED)

HUD - Housing and Urrban Development Interim Guidelines

OSHA - Occupational Safety and Health Administration

RCRA - Resource Conservation and Recovery Act

AIR - National Primary and Secondary Ambient Air Quality Standards

CPSC - Consumer Product Safety Act

Notes:

1. Likelihood of finding LBP on a particular surface in a facility is based on when it was constructed (before 1980 or during/after 1980), applicability of CPSC restrictions on use of LBP, and common painting practices (paragraphs 3b and 3c).

2. Although LBP may hot be likely, some precautions described in the HM guidelines will normally be considered in high-priority facilities since children are potentially at risk and there is some possibility that LBP is present.

3. Occupant protection measures which must be followed during and after activities which disturb LBP in high-priority facilities are covered in the HUD guidelines. In other facilities, ensure occupants are not exposed to lead above the OSHA permissible exposure level (PEL) during these activities and all dust and debris are removed afterwards.

4. Refer to paragraphs 10 and 11 for detailed information on applying regulations and guidelines record keeping, and the payment of reasonable service charges. The statute' s wording is broad. It applies to all personnel of all Federal Government agencies which have control over Federal property, or who may be engaged in any activity which does or may relate to a LBP hazard.

The statute requires compliance with all laws dealing with LBP, LBP activities, and LBP hazards, whether the law is a federal, state, interstate, or local law. To permit effective enforcement of this statute, the United States has waived its immunity from lawsuit, subjecting the United States Government to all remedies provided for in the violated federal, state, interstate, or local laws.

g. Occupant Protection Measures. HUD guidelines cover occupant protection measures which must be followed during and after activities which disturb LBP in high-priority facilities.

In other facilities, ensure occupants are not exposed to lead above the OSHA PEL by removing them from the work area, isolating the area with physical barriers and warning signs and, if necessary, providing a containment system to ensure other areas are not contaminated by dust and debris. A thorough normal cleanup and washing of the work area must be performed afterwards to ensure all dust and debris are removed.

11. Facility Maintenance, Repair, Modification, and Renovation Activities. Perform or specify that the following actions, be performed when activities will disturb painted surfaces in high-priority facilities and other facilities likely to contain lead:

a. Determine if LBP is present prior to start of work.

Qualitative testing (paragraph 9b) should be conducted on surfaces most likely to contain LBP and that will be disturbed during the project. Testing should be done in the early planning phase of the project to ensure adequate funds are programmed. Take or require additional precautions depending on the amount of LBP to be disturbed. The determination of whether the work is a small or large project must be made by trained workers or by Base Bioenvironmental Engineering in, consultation with Base Civil Engineering. For contract work, a complete description of the testing used to determine the presence or absence of LBP must be provided to the contractor.

b. For small jobs which are performed over a limited area and can easily incorporate work practices which reduce, contain, and prevent dust from contaminating any area of the facility:

(1) If lead is found, take the following precautions:

Ensure occupants, especially children, are removed from the work location and the area closed off. Prevent creation of dust using wet sanding, wet drilling, etc. Do not use dry sanding, heat guns, or compressed air. Keep debris wet until it is collected and dispose of it properly. Note: For small amounts of debris, it may be more economical to assume it is hazardous waste without TCLP testing.

(2) If no lead is found, no LBP precautions are required.

c. For large projects which disturb large painted surfaces and dust and debris cannot be reliably controlled solely by work practices specified above:

(1) If lead is found, the in-house workers or contractor must follow all regulatory requirements to ensure adequate occupant, worker, and environmental protection (paragraph 10). A plan for, performing the work must be submitted to Base Environmental Engineering (and Base Civil Engineering if performed by contract) for approval. In high-priority facilities, special cleanup actions such as those specified for in-place management and abatement activities and clearance testing must be performed and coordinated with Base Bioenvironmental Engineering. Collect and dispose of all debris. Debris must be tested (TCLP) to determine if it must be classified as hazardous waste.

(2) If no lead is found, normal cleanup of the work areas should be performed.

12. Restricting the Use of Lead-Based Paint. The Consumer Product Safety Act (reference la) restricted lead in liquid paints or coatings to no more than 0.06 percent lead by weight of the nonvolatile solids for use in non-industrial facilities.

Part 35 of 24 C.F.R. (reference 1b) placed a similar restriction on paints and coatings used by federal agencies in the construction or rehabilitation of any residential structure. In accordance with Air Force policy, this restriction is now applicable to paints used in all facilities, industrial and non-industrial. This is to reduce the potential LBP risk on installations and to minimize the precautions which will be needed when working on painted surfaces in the future.

13. Personnel Training Requirements. Personnel who perform tests for LBP and work on painted surfaces must be trained to varying degrees so they will understand the potential hazards involved and will be able to competently handle assigned tasks.

a. The Environmental Protection Agency (EPA) has established EPA-Approved Regional Lead Training Centers at the following sites: University of, Massachusetts Amherst, University of Maryland, University of Cincinnati, Georgia Institute of Technology, University of Kansas, and University of California - San Diego.

b. Training Certification and Documentation. At least one person from Base Civil Engineering at each installation should attend one of the above EPA-approved courses and receive certification of attendance. This person can then be the certified trainer for the installation and train other employees on the proper precautions to take and the potential hazards involved when performing activities which disturb painted surfaces. All training must be documented in the employee's official personnel folder and must be conducted by personnel who have been trained at an EPA-Approved Regional Lead Training Center or an equivalent in-house training program presented by a certified trainer.

c. Level of Training. The level of training that various workers will receive should be determined locally based an the in-house capability desired.

(1) A minimum level of training must be provided to all workers who perform activities which disturb painted surfaces.

This minimum training, which is adequate for workers performing small jobs, must include the potential hazards of' ' LBP (hazard communication), work practices to reduce and control dust and debris, handling of debris, hygiene, and cleanup procedures.

Those who will be performing qualitative testing for the presence of lead must also receive training in the applicable procedures.

(2) Workers who will be performing larger jobs in which simple work practices will not reliably reduce or control dust and those who will be assisting in LBP evaluations (paragraph 7d) must receive additional training in OSHA and HM requirements.

(3) The LBP point of contact (POC), on-site supervisors of crews performing large projects involving LBP, and inspectors of such projects must be trained at one of the EPA-Approved Regional Lead Training Centers or an equivalent in-house training program presented by. a certified trainer.

14. Lead Toxicity Investigation (LTI) . LTIs are required when children with elevated blood lead levels are identified.

a. The Chief of Aerospace Medicine (SGP) will establish an LTI team consisting of representatives from Base Civil Engineering, Base Bioenvironmental Engineering, Military Health (MPH), Public Affairs (PA), and Judge Advocate (,TA) as needed.

b. When notified of a child with elevated blood lead levels:

(1) MPH will interview the family.

(2) SGP will convene a meeting of the LTI team to review questionnaire results and determine the history of LBP in the subject facility.

(3) The LTI team will establish an investigation plan to determine the source of lead (facility paint, water, soil, ceramics, etc.).

(a) For investigations of-Air Force facilities, follow the procedures in paragraph 8.

(b) If the source is located off base, consult with JA to determine appropriate actions.

(4) The LTI team will recommend actions needed to remediate the source of lead and protect facility occupants.

15. Major Command (MAJCOM) Responsibilities.