Lead Based Paint (LBP) Protocol
Ann Arbor Public Schools is committed to ensuring all who learn and work in AAPS school buildings are safe every day and throughout any construction process. Your patience is appreciated as the district prepares to complete significant capital investments in existing school buildings throughout the AAPS.
With a current average age of 65 years, AAPS school buildings have many unique characteristics and challenges, some of which include legacy environmental materials considered hazardous if disturbed. Because of this, the district requires a systematic approach to construction safety to protect all students, staff and building occupants.
When renovating school buildings older than 1978, specific areas of a building may need to be impacted and certain surfaces and materials disturbed, including some areas potentially containing Lead Based Paint (LBP). AAPS prepares and proceeds with a standard process for these events:
Surveys and Documentation
The district and its professional teams review historical documentation and conduct onsite inspections and best-practice analysis to prepare the following:
- National Emissions Standards for Air Pollution (NESHAP) reports
- Targeted Lead Based Paint (LBP) related testing, as needed.
- Asbestos related testing
- Reports are included in District procurement documents.
- Additional regulatory requirements/submissions, as needed.
- Phasing plans for Construction teams and school building teams, as needed
Contractor Training and Requirements
Construction Managers working for AAPS are required to take lead and asbestos awareness training and maintain up-to-date continuing education on best practices for hazard mitigation.
District public procurement for construction projects (Invitations for Bid, or IFB) include the following language in reference to the EPA’s Lead Renovation, Repair and Painting (RRP) rule:
EPA's Lead Renovation, Repair and Painting (RRP) Rule requires that renovations of child-occupied facilities be carried out only by Lead-Safe Certified renovation firms, using certified renovators trained in lead-safe work practices. Renovation is broadly defined as any activity that disturbs painted surfaces and includes most repair, remodeling, and maintenance activities, including window replacement.
The MIOSHA Construction Safety and Health Standard Part 603 Lead Exposure in Construction applies to all construction work operations where an employee may be occupationally exposed to lead. Any employer who has a workplace or operation that is covered by the standard is required to initially determine if employees are exposed to lead at or in excess of the eight-hour Action Level of 30 ug/m3 (micrograms per cubic meter of air). If work operations include tasks such as spray painting with lead paint, manual demolition or disturbance of any structure that contains lead paint/coatings or other products, the employer is required to provide the affected employees with appropriate interim protection (i.e., respiratory protection, personal protective clothing, change areas, hand washing facilities, biological monitoring, and training) until such time that employee exposures have been determined.
Child occupied facilities, as defined by the United States Environmental Protection Agency’s (EPA’s) Lead; Requirements for Lead-Based Paint Activities in Target Housing and Child Occupied Facilities (40 CFR 745) and the State of Michigan’s Lead Abatement Act (MCL 333.5451-5477):
Department of Housing and Urban Development’s (HUD’s) Guidelines for the EPA’s Lead; Requirements for Lead-Based Paint Activities in Target Housing and Child Occupied Facilities (40 CFR 745); HUD’s Requirements for Notification, Evaluation and Reduction of Lead-Based Paint Hazards in Federally Owned Residential Property and Housing Receiving Federal Assistance (24 CFR Part 35); the EPA’s Lead: Renovation, Repair, and Painting Program Rule (40 CFR 745, Subpart E); the Occupational Safety and Health Administration’s (OSHA’s) Lead in Construction Standard (29 CFR 1926.62); State of Michigan’s Lead Abatement Act (MCL 333.5451-5477); the State of Michigan Department of Community Health’s Lead Hazard Control (R 325.99101-99409); the State of Michigan’s Occupational Health Standard Part 603 – Lead Exposure in Construction (R 325.51991-51993); and all other applicable federal, state, and local regulations and standards.
On an annual basis (at minimum), AAPS will review these training requirements and update to reflect the best practice requirements.
New Construction, Renovation and Repair
AAPS requires recognized best-practice methods to prevent exposures to environmental health hazards, including LBP, by installing and maintaining engineering controls to eliminate or reduce the hazard. Construction Managers and contractors working on existing school buildings constructed prior to 1978 follow standard procedures, including:
Conduct bulk material analysis to determine if hazard is present, as needed.
Conduct site surveys of planned renovation areas for hazards, as needed.
Provide interim protection until air monitoring determines exposure levels.
Use exhaust ventilation and dust collection systems. For example, power tools used for grinding surfaces coated with lead containing paint can be equipped with dust collection systems.
Use local exhaust ventilation where feasible.
Use wet methods or a vacuum equipped with a high efficiency particulate (HEPA) filter to clean work areas contaminated with lead or other hazardous materials.
Do not dry sweep or use compressed air.
Comply with all requirements of Part 603 with regard to air monitoring, compliance program, use of protective work clothing and equipment, housekeeping, hygiene facilities, medical surveillance and medical removal protection, employee information and training, warning signs, and record keeping;
When engineering and work practice controls cannot be used or do not reduce exposure to an acceptable level, then the employer must provide respiratory protection. The type of respiratory protection required is based on the level of exposure determined by air monitoring. At a minimum, the respirator should be a half mask, air-purifying respirator with HEPA filters. Remember, the employer must then implement a respiratory protection program as required by MIOSHA Occupational Health Standards Part 451, Respiratory Protection
If respirators are used to protect employees, then a regulated area should be established to prevent unprotected employees from entering the exposure area.
Conduct site monitoring and personal exposure monitoring as needed for planned renovation activities.
Site Visits and Safety Reviews
The Capital Programs team regularly visits renovation and construction sites to review site safety during the course of a project.
Final Review Prior to Re-occupancy
Prior to re-occupancy of newly renovated spaces, an additional week has been added to the schedule to allow for the following to occur:
Full construction cleaning and final deep cleaning.
Completing punch-list items.
Moving furniture into place.
Conducting air monitoring tests as needed.
Inspecting all areas by Capital Programs staff for completion of the construction work and cleaning
Post work Dust Wipes / Clearance
The protocols listed above are followed and areas inspected prior to moving back into the space. This inspection includes the construction management team, capital projects staff, and school building representative(s).
Additional cleaning is scheduled as required.
AAPS is committed to meeting all other applicable federal, state, and local requirements for new construction and renovation projects in order to protect the health and safety of our students, staff, building occupants and all those who work in District school buildings.
For additional information on this subject, visit the following websites at:
- EPA Lead RRP Rules - Entity Compliance Guide
- OSHA, Safety and Health Topics, Construction - Lead
- NIOSH, Preventing Lead Poisoning in Construction Workers
- NIOSH, Protecting Workers Exposed to Lead-Based Paint Hazards
- MIOSHA Consultation Education and Training Division
- Housing and Urban Development 40 CFR 745
- Housing and Urban Development 24 CFR Part 35
- Housing and Urban Development 29 CFR 1926.62
- State of Michigan’s Lead Abatement Act (MCL 333.5451-5477)
- State of Michigan Occupational Health Standard Part 603 – Lead Exposure in Construction (R 325.51991-51993)
- National Emissions Standards for Air Pollution (NESHAP) reports