Brett Eddinger
The hazards of lead in paints are regulated by both EPA and OSHA.
Under EPA, Lead-Based Paints (LBPs) are defined as those with lead concentrations of 5,000 parts per million (ppm) or more and related rules are generally intended to protect the public. However, OSHA regulates worker/employee exposure to paints that contain any lead.
LBPs are found in virtually every building constructed before 1978. Lead-containing paints are produced to this day. Given this, a Lead Paint Management Program was developed to avoid exposures and ensure proper waste handling and disposal. This is ensured by training, implementation of standard procedures and work practices, inspections, and exposure monitoring.
Program Applicability
The Lead‑Based Paint Program applies to Penn State employees, students, contractors, and visitors who may work in or occupy University buildings where lead‑based paint is present.
Lead‑based paint is commonly found in buildings constructed before 1978 and may be present on painted surfaces such as walls, doors, windows, trim, railings, and other building components. When lead‑based paint is damaged or disturbed, it can create lead dust or debris that poses a health risk.
This program exists to:
- Prevent exposure to lead‑based paint and lead dust
- Ensure safe work practices during maintenance, renovation, and demolition activities
- Maintain compliance with applicable federal and state regulations
Program Requirements
General Requirements
- All damaged or deteriorated painted surfaces must be reported promptly to a supervisor or maintenance contact.
- No one may disturb, remove, or work on lead‑based paint unless they are:
- Properly trained and authorized, or
- Working under the direction and approval of Environmental Health and Safety (EHS)
Responsibilities of Safety Officers, Facility Coordinators, Managers, and Supervisors
- Ensure employees who may encounter lead‑based paint receive appropriate training
- Prevent non‑authorized employees and students from disturbing painted building materials
- Respond promptly to reports of damaged painted surfaces
- Contact EHS before renovations, maintenance activities, or demolitions that may impact painted surfaces
- Coordinate lead‑based paint evaluations when required
Responsibilities of Employees and Students
- Not disturb painted surfaces that may contain lead unless authorized and trained
- Report peeling, chipping, or damaged paint to supervisors or maintenance contacts
- Follow posted warnings and instructions related to lead‑based paint hazards
Training Requirements
- Employees whose job duties may involve disturbing painted surfaces must receive lead awareness or task‑specific training, as determined by EHS
- Training requirements vary based on job tasks and potential exposure
Recordkeeping Requirements
- Training completion and related documentation must be maintained in accordance with Penn State EHS requirements
- EHS maintains records of lead assessments, sampling, and compliance activities
Documents and Forms
- Lead Paint and Other Heavy Metal Pigments Exposure Control and Disposal Procedures
Additional Resources
- Occupational Safety and Health Administration (OSHA) – Lead
- U.S. Environmental Protection Agency (EPA) – Lead
- Pennsylvania Department of Environmental Protection (PA DEP)
- Lead-based paint disclosure rule requirements (HUD/EPA)
- "Protect Your Family From Lead in Your Home" Brochure (HUD/EPA)
- "Lead Paint Safety: A Field Guide for Painting, Home Maintenance, and Renovation Work" (HUD/EPA/CDC)
- OSHA Lead Information
- Pennsylvania Department of Labor and Industry (PA L&I) Lead Paint Regulations and Information