Bates College is required to maintain a written Lead Workplace Safety Program for employees who are exposed or potentially exposed to lead hazards in the workplace.  This program covers the topics required by the OSHA standard for Lead in Construction, 29CFR Part 1926.62.  This plan does not cover Lead in General Industry, which includes standards for industrial processes, not lead paint in construction.  

This policy is to help ensure proper management of lead, primarily in the form of lead-based paint in buildings owned by Bates College, and applies to all Bates’ employees and outside contractors who work with or who are responsible for work with lead-based paint or suspected lead-containing materials in Bates buildings.  The abatement, renovation, repair work and painting shall not inadvertently contaminate the building and create a lead exposure problem.  The Bates EHS Director is responsible for maintaining and implementing this policy.

Lead is a toxic metal that can lead to a number of serious health problems, especially in children.  Most lead poisonings are caused by exposure to dust from old paint.  More than half of Maine homes may have lead paint, and lead paint should be suspected to exist in any building built before 1978 which was when lead-based house paint was prohibited.

If lead exposure is found to be in excess of the PEL (Permissible Exposure Limit), a written compliance plan must be developed which documents: 

• Lead-emitting activities, equipment, materials, controls, crew size, employee responsibilities, operating and maintenance procedures
• How compliance is achieved
• Reports on technology to meet the PEL
• Air monitoring data
• Implementation schedule
• Work practice program
• Administrative control schedule, and 
• Methods to inform employees

Pure lead (Pb) is a basic chemical element and is a heavy metal in normal conditions, but it can combine with various substances to form numerous compounds used commercially (i.e. crystal and batteries). Lead and it’s compounds are toxic, potentially being absorbed through inhalation and ingestion, such as breathing lead dust or eating paint chips. Food, tobacco, and/or make-up could become contaminated in a lead work area .

As lead exposure accumulates in the body, irreversible nervous system damage can occur. Lead is especially dangerous to children under the age of six and to women of childbearing age.

Acute Effects of Overexposure: Lead is a potent, systemic poison, and can kill in a matter of days if taken in large enough doses.

Chronic Effects of Overexposure: Long term overexposure may result in severe damage to blood-forming, nervous, urinary, and reproductive systems.

Bates College is required to protect employees with a Lead Workplace Safety Plan through implementation, maintenance, monitoring of the plan. Specific requirements include:

• Semi-annual Revisions and Updates
• Engineering and Administrative Controls
• Employee Training
• Medical Surveillance
• Respiratory Protection
• Lead Disposal
• Housekeeping, and
• Personal Protective Equipment (PPE)

Supervisor Responsibilities

Supervisors of the lead work will:

• Provide effective and continuous control of all lead operations
• Conduct routine inspections and monitoring
• Immediately inform Management or EHS of any deficiencies
• Immediately correct any deficiencies
• Ensure all affected employees are properly trained
• Provide immediate “spot” training to any employee who exhibits lack of knowledge or application of safety requirements

Employee Responsibilities

Employees involved with lead work are required to:

• Follow all operational and lead safety procedures
• Conduct operations in accordance with the required lead training
• Properly use, store, and dispose of issued and assigned PPE
• Maintain cleanliness and organization of change and shower areas
• Immediately report to a Supervisor or EHS any deficiency
• Seed immediate Supervisor guidance to resolve questions

In situations where employees might be exposed to lead, Bates College is required to monitor the lead levels that an employee would encounter in a typical day. A typical day is at least 7 continuous hours representing employees regular work routine for each job classification per shift per work area. Monitoring will be conducted by a trained and certified lead-safet consultant at all times.

If any Faculty, Staff, or Student observes lead in the workplace that could pose a hazard, Bates EHS should be contacted immediately for an assessment.

Lead in the home is governed in Maine by the Department of Human Services and the Department of Environmental Protection. Tenants of Bates College have a right to request information regarding lead in the specific property they reside in. If lead hazards are observed or conditions in a Bates owned property warrant concern, contact Bates EHS for an appointment or information regarding your residence.