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Frequently
Asked Questions
Q . Do I have to test the paint on a school building for lead?
A.
No, but schools constructed before 1993 are presumed to have
lead paint on them. If you don't test, you have to assume the
paint has lead in it unless you have documentation that the
building has never been painted with lead paint (for example,
it has only been painted with latex paint). If there is a possibility
a building has lead paint, you must follow lead-safe work practices.
Q.
When might I want to test the paint for lead?
A. Anytime you are planning a large-scale project, such as remodeling
a room, modernizing, demolishing, or preparing for lead abatement,
you should test the paint for lead. Cal/OSHA requires notification
prior to the job if more than 100 square feet or 100 linear feet
of lead-based paint will be disturbed. You might also want to test
the paint for lead when you are planning work on a newer building.
If you find there is no lead in the paint, you won't have the added
expenses of using lead-safe work practices and state certified lead
workers.
Q.
What are acceptable methods for testing the paint for lead and what
are the advantages and disadvantages of each method?
A.
The two acceptable methods of testing paint for lead are XRF analysis
and paint chip analysis. They may be used separately, or in combination:
1. XRF Analysis (use of an electronic instrument to read
whether there is lead in the paint. Results are reported in milligrams
per square centimeter (mg/cm 2). It has to be used by a licensed,
certified lead inspector/assessor.)
Advantages of XRF Analysis
-
Not destructive to the painted surface.
-
Results are immediate.
-
Cheaper than paint chip analysis if you are taking
a large number of samples.
Disadvantages of XRF Analysis
- Requires
a licensed, certified lead inspector/assessor, costing several
hundred dollars per day.
- Negative
results (less than or equal to 0.0 mg/cm2) must be verified
by paint chip analysis, as required by Cal/OSHA.
2.
Paint Chip Analysis (analysis by a lab of a measured amount
of lead-containing paint, e.g., a 2" x 2" section of
paint).
Advantages of Paint Chip Analysis
- The
lab can determine whether there is any lead in the paint.
- Cost
per individual sample is low (approximately $5 - $25 per sample),
although it may be a more costly method if you are taking numerous
samples.
- Anyone
can be trained how to do lead paint chip sampling, if the purpose
is to determine what worker protections are needed. If the purpose
is to assess whether your school has a lead problem that could
expose children, it's required to be done by a certified lead
inspector.
Disadvantages of Paint Chip Analysis
- Destructive
to the painted surface.
-
Takes time to collect the necessary samples.
-
You don't get an immediate reading; you have to wait for the
lab results to come back.
-
May underestimate the lead level in the paint if material under
the paint (substrate) is included in the paint sample.
3.
Combination of XRF and paint chip analysis
First conduct XRF analysis on the components of each building
that may have lead paint and then follow up on those for which
you have received negative readings with paint chip analysis.
This approach provides quick answers when lead levels are high.
When the XRF result suggests there is no lead in the paint, a
paint chip sample is sent to the laboratory for a confirmation
of the analysis.
Q.
Are employers required to conduct personal air sampling on each
worker who does a lead-related construction or maintenance task?
A.
No. Cal/OSHA requires that each different lead-related task be sampled,
not each worker. This means that you can characterize the exposure
of all workers doing a particular type of task by sampling one worker
as he/she does the task. However, the sampling should be done when
the worker is working on the building with the highest lead content
and over the longest period of time the job is done, otherwise you
won't know the worst case exposure.
Q.
Why is personal air sampling important?
A.
The level of lead in the air workers breathe determines what type
of protection they need (and is required by law) and what work practices
to follow to protect themselves.
Q.
Are there any circumstances when I don't have to conduct personal
air monitoring?
A.
Yes, there are currently three situations when you don't have to
conduct personal air sampling for lead. These are:
1. When you have documentation that the building (or the areas
in which work is taking place) has no lead in the paint, as documented
by paint chip analysis.
2. You have conducted air sampling on closely similar operations
and conditions within the past 12 months.
3. When you have documentation that there is less than 600 ppm
(parts per million of lead in the paint) by paint chip analysis
and you are not performing a trigger task. The following list
of trigger tasks is found in the Cal/OSHA Lead in Construction
Standard:
Cal/OSHA
Trigger Tasks
Where lead containing coatings or paint are present:
-
manual demolition of structures (e.g., dry wall)
-
manual scraping
-
manual sanding
-
heat gun applications
-
power tool cleaning with dust collection systems
-
using lead containing mortar
-
lead burning - rivet busting
-
power tool cleaning without dust collection systems
-
cleanup activities where dry expendable abrasives are used
-
abrasive blasting enclosure movement and removal
-
spray painting with lead paint
-
abrasive blasting
-
welding
-
cutting
-
torch burning
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