UNIVERSITY OF COLORADO DENVER
University of Colorado Denver
Lead Control Program
I.
Purpose
It is the policy of the University of Colorado Denver (UC Denver) to protect faculty, staff, students, patients,
visitors, contractors or subcontractors and others from the release of lead particles during routine maintenance
activities; remodels or renovations; new construction-related activities; and abatement activities. Further, it is the
intention of the UC Denver to comply with applicable local, state and federal government rules and regulations.
The procedures and requirements outlined within this Control Program apply to properties owned and managed by
the University of Colorado Denver, including but not limited to the Anschutz Medical Campus and UC Denver
owned properties and managed buildings at the Downtown Denver campus.
II.
Scope
The UC Denver currently does not fall under the lead standard prescribed by the Occupational Safety and Health
Administration (OSHA), 29 CFR 1926.62. However, any private contractors working under contract to the UC
Denver do fall under the OSHA lead standard and must comply with those provisions.
The UC Denver is required to follow all environmental regulations (including 40 CFR 262 and 40 CFR 261.24)
related to identifying potential lead containing waste materials and ensuring proper disposal.
III.
Responsibilities
A.
Environmental Health and Safety Department (EHS)
1.
Employ a systematic approach to determine the hazards posed by Lead Containing Material (LCM) and
select controls/response options.
2.
Review plans, drawings, project request forms, hazard evaluation checklist submitted by the project
managers. Provide guidance on proper work practices as requested.
3.
Conduct or arrange for bulk sampling for LCMs and air monitoring as required.
4.
Review and interpret the results of sampling and monitoring.
5.
Act as the liaison to the U.S. Environmental Protection Agency (EPA) and Colorado Department of
Public Health and Environment (CDPHE).
6.
Review and revise this program document as needed.
B.
UC Denver Hazardous Waste Manager
1.
Responsible for the disposal of LCM in accordance with the local, state, and federal regulations.
2.
Checks all hazardous waste manifests prior to shipment.
3.
Ensures proper record keeping for manifests and Land Disposal restriction Notification Forms.
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C.
D.
Lead Abatement Worker
1.
Non-UC Denver contract workers are responsible for performing all lead abatement in
accordance with the local, state, and federal regulations that pertain to the UC Denver.
2.
UC Denver Facility Operations and Projects employees are responsible for following this
internal Lead Control Program.
3.
Responsible for disposing of the lead waste in accordance with the local, state, and federal
regulation in cooperation with the UC Denver Hazardous Waste Manager, which includes
reporting the amount of waste generated and ensuring hazardous waste manifests are reviewed
and signed by the UC Denver Hazardous Waste Manager or their trained representative.
Facilities Project Managers
The UC Denver Facilities Project Manager shall be responsible for coordinating (including arranging for
appropriate funding) any lead abatement projects, informing EHS of work to be performed, notifications
to affected parties, providing required regulatory information, serving as point of contact, resolving
problems and other management/coordination responsibilities between the Lead abatement personnel (inhouse or outside contractor) and EHS. To achieve this goal the responsibilities of the UC Denver
Facilities Project Manager include but are not limited to the following:
1.
Informing the UC Denver EHS Department of projects that may involve LCMs.
a. Submit a UC Denver Facility Department Project request Form (Attachment 1) and UC Denver
Facilities Project Hazard Evaluation Checklist (Attachment 2) for each project.
b. Provide written Scope of Work (SOW) for the Project.
c. Supply drawings of the area to be renovated or altered.
2.
Coordinate with the EHS Department a time to perform any necessary inspections and sampling.
3.
Coordinate with group, such as EHS, Facility Operations, and Client, to resolve questions and issues
before beginning the bid process.
4.
Invite an EHS representative to any applicable walk-through.
5.
Invite input from EHS to the bid selection process for abatement contractors.
6.
Ensure that the Lead abatement contractor understands that they are responsible for the following:
a. Compliance with this program and with all applicable local, state and federal regulations,
including but not limited to OSHA 29 CFR 1926.62, EPA, and CDPHE requirements.
b. Informing and training their workers in compliance with all applicable regulations.
c. When applicable, the contractor is responsible for supplying an air-monitoring specialist to
conduct area and personnel monitoring.
d. Responsible to ensure that all paperwork, such as notifications, air monitoring results, sample
results, waste manifests and any visual inspection reports, etc. are provided to the UC Denver
Project Manager and the EHS representative.
e. Responsible to ensure lead waste is prepared in accordance with this program document..
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E.
Facilities Management Personnel
Since Facilities Services Personnel, during the performances of their duties, may have direct contact with
LCM it is extremely important that they are aware of the hazards and reporting procedures for discovery
of disturbed LCM. They are a key element in an effective Lead Control program.
F.
III.
Custodial/Environmental Services Personnel and Grounds Personnel and Management
These personnel may also have an opportunity to come in contact with damaged LCM at UC Denver.
Cleaning and Grounds staff should have a general awareness level of the hazards of lead exposure and
proper reporting procedures in the event that they encounter debris (e.g., discarded electronics, peeling
paint, paint chip debris from deteriorating surfaces or as a result of improper paint removal procedures).
They will play a key role in reporting any damaged LCM.
Identification of Lead Hazard
The primary sources of LCMs encountered at the UC Denver are paints (painted surfaces), lead shielding materials
and electronic equipment. Some older piping or sink traps made be constructed of lead or have lead solder used at
joints. Significant exposures can arise from removing LCMs especially if the removal involves sanding, scraping,
grinding, or burning (including welding, torch cutting, brazing, etc.).
Almost all painted surfaces associated with older campus buildings should be considered suspect LCM. Likewise
the walls and floors associated with rooms used (or previously used) for radiography should be treated as
potentially containing lead paint or sheeting material.
Employees should also be alert if they encounter lead bricks and should contact the the EHS Hazardous Waste
Manager. These items should not be used for door stops, etc. and should be turned in for proper recycling unless
they are being used appropriately – such as for shielding. PPE should be worn when handling these materials.
IV.
Distrubing Lead-Containing Material
A.
Project Coordination
The UC Denver Facilities Management personnel that will be involved in any project that may result in
the disturbance of LCM must contact the UC Denver EHS Department. The EHS Department and/or the
State qualified environmental consultant contracted to conduct an assessment of LCM, in consultation
with the responsible project management personnel will determine if there is a potential to disturb LCM.
B.
Sampling and Testing for Lead
Internal UC Denver Projects
UC Denver Project Managers will coordinate with the EHS Department and/or the State qualified
environmental consultant contracted to conduct an assessment of LCM for the project to arrange for the
collection and analysis of bulk samples or XRF testing to determine if lead is present materials that will,
or may be disturbed. If lead is detected (at or above the standards set by HUD – Housing and Urban
Development) then a composite sample will be collected and submitted to a laboratory for analysis by
Toxicity Characteristic Leaching Process (TCLP). This analysis is necessary to determine if the lead
containing waste materials generated from the project need to be handled and disposed of as hazardous
waste. Determinations of waste lead content can not be made from XRF testing results. Total lead
analysis can be utilized to make a determination of lead content with the assistance of EHS Hazardous
Waste Manager.
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Contract Projects
Project work that will utilize outside contractors will follow the same sampling and testing protocol noted
above for Internal Projects. It is important for the UC Denver Project Manager to coordinate sampling
and testing prior to defining a scope of work and selecting a construction contractor since LCM control,
abatement and waste management will affect the work scope, contractor selection and project cost. The
bid package should include if lead control and disposal practices will be required for the project.
Small Routine Projects
For small routine maintenance projects where paint must be disturbed, sampling or surface testing is
recommended. Paint on exteriors, older painted materials, painted metal/equipment, should be assumed
to contain lead and handled as LCM or should be tested. For routine operations and maintenance
activities impacted smaller amount of LCM, testing may be conducted by internal personnel using lead
kits (surface sampling) that meet the NIOSH Method 7700 specifications for lead. Testing of each layer
of affected paint must be conducted.
The small amount of LCM waste generated from these activities will be properly collected and disposed
of through the UC Denver Hazardous Waste Manager. Control practices will be employed to limit or
prevent the generation of dust (e.g., for paint removal by scraping/sanding use vacuum attachment on
equipment) to avoid worker exposures and the need to construct barriers to contain dust to the work area.
Workers must wear appropriate personnel protection equipment (PPE) including (but not limited to)
gloves, eye protection, and if applicable to the extent of work and removal technique, respiratory
protection and outer clothing cover (i.e., Tyvek or coveralls that are removed after work activity and
before leaving work site). Workers must remove PPE and wash hands before eating, drinking, or
smoking.
If these activities will require the generation of dust (sanding, grinding, etc.) within occupied spaces,
contact EHS. The work activity may require implementation of indoor air quality protection measures
and post work testing.
C.
Lead Work Control Practices
Internal UC Denver Projects
The degree of work practice controls may vary depending on the complexity of the work. The
responsible project management personnel will coordinate with the EHS Department to complete the
attached (attachment 1) Compliance Plan for each project involving the disturbance of LCM. The
purpose of this plan is to ensure that the work is planned and carried-out in a manner that will minimize
exposure potential.
Contract Projects
Projects that utilize outside contractors will require the contractor to comply with the OSHA 29 CFR
1926.62, Lead Standard. This standard is applicable to any work involving demolition, removal,
encapsulation, renovation, installation, alteration, maintenance, or transportation, storage or disposal of
LCMs.
Any contracts or bid documents shall alert the contractor to the presence of any LCMs and the
requirement to comply with OSHA regulations. This regulation requires that the contractor implement a
worker protection program that includes, but may not be limited to:
 Hazard determination, including exposure determination.
 Engineering and work practice controls.
 Respiratory protection.
 Protective clothing and equipment.
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





Housekeeping.
Hygiene facilities and practices.
Medical surveillance and provisions for medical removal.
Training.
Signs.
Recordkeeping.
The contractor must designate a competent person to ensure the worker protection program is
implemented properly. This Program is subject to review by the UC Denver EHS Department upon
request.
D.
Air Monitoring
Air monitoring for Internal UC Denver projects will be conducted as determined by the EHS Department
and as indicated on the Compliance Plan for each project. Air monitoring may not be required for each
project.
Contractors will be required to comply with all air monitoring/exposure assessment provisions of OSHA.
E.
Medical Surveillance
Generally, medical surveillance will not be required for UC Denver employees with a potential for
incidental LCM exposure that is not a permanent due the minimal exposure associated with the smallscale projects they perform. The EHS Department will make this determination and include it as part of
the Compliance Plan as applicable.
Contractors will be required to comply with all medical surveillance provisions of OSHA.
F.
Training
UC Denver Employees
Any UC Denver Facilities employee conducting work that disturbs LCM shall be provided training
annually. Generally this training will be conducted as part of regularly scheduled safety meetings. A
summary of the content presented in this training is included in attachment 2.
UC Denver Project Management Personnel
Project management personnel are provided annual training that includes the information in attachment 2
as well as a more detailed discussion of the provisions of this procedure.
Contractors
Contractors and their employees are required to comply with all training and information requirements of
OSHA.
G.
Waste Determination and Disposal
If testing indicates the presence of lead, then a composite sample will be submitted for the TCLP analysis.
If the TCLP indicates a lead level of 5 parts per million or greater, then the material must be handled and
disposed of as a hazardous waste.
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Internal UC Denver Projects
The responsible project management personnel shall coordinate with the UC Denver Hazardous Waste
Manager for proper waste handling and disposal protocols. This protocol is to be included in the
Compliance Plan for the project.
Contract Projects
The contractor will also be responsible for the following:
1.
Properly training their employees with the applicable OSHA lead abatement procedures and the
Colorado hazardous waste regulations 6 CCR 1007-3 whenever lead contaminated wastes meet or
exceed the TCLP standard for lead of 5.0 parts per million.
2.
Providing UC Denver Hazardous Waste Manager with an MSDS of every product used to remove
lead based paints prior to starting the project. UC Denver has the right to select what type of
products, chemicals, or procedures may be used to remove lead-based paints at our campuses.
3.
Selecting Department of Transportation (DOT) approved shipping containers to collect leadcontaining waste.
4.
Properly labeling LCM waste containers with chemical waste labels and warning labels.
5.
Maintaining proper control over LCM waste containers so that they are not improperly disposed.
6.
Notifying the UC Denver Hazardous Waste Manager at least 24 hours before any LCM waste debris
is transported to UC Denver from an offsite location or to any other location. Contractor is
responsible for assuring that LCM waste materials are transported only by UC Denver approved
transporters. The contractor is responsible for assuring the LCM materials are in compliance with all
applicable Department of Transportation (DOT) regulations prior to being transported.
7.
Notifying the UC Denver Hazardous Waste Manager at least 24 hours before any LCM waste debris
is shipped to an offsite waste disposal facility.
8.
Providing the UC Denver Hazardous Waste Manager with copies of all Hazardous Waste Manifests
and Land Disposal Restriction Notification Forms in a timely fashion.
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Attachment 1
Lead Compliance Plan
Date: ________________________
_______________________
Submitted by:
Department:
Contact Number:
Location of Planned Work Activity: _______________________________________
Describe the work to be performed (attach Scope of Work if available):
__________________________________________________________________________________
__________________________________________________________________________________
__________________________________________________________________________________
________________________
List the materials that contain Lead:
__________________________________________________________________________________
__________________________________________________________________________________
________________ Testing performed? ___ Yes (attach copy of results as applicable)
Describe the methods/tools to be used to disturb/remove lead:
__________________________________________________________________________________
__________________________________________________________________________________
__________________________________________________________________________________
________________________
List names of UC Denver employees assigned to this work:
__________________________________________________________________________________
__________________________________________________________________________________
________________ Training completed? ___ Yes
Specific work practices to be used/followed:
__________________________________________________________________________________
__________________________________________________________________________________
__________________________________________________________________________________
__________________________________________________________________________________
________________________________
Specific protective equipment to be used:
__________________________________________________________________________________
__________________________________________________________________________________
__________________________________________________________________________________
________________________
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Specific waste handling/disposal procedures to be followed (contact EHS Hazardous Waste Manager
or representative 4-0242 or 4-0344 for information on manifest execution and to report volumes).
__________________________________________________________________________________
__________________________________________________________________________________
__________________________________________________________________________________
__________________________________________________________________________________
________________________________
Plan Reviewed by: ___________________________
UC Denver – EHS Department
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Attachment 2
Training Outline Content
Lead workers will receive training that includes the following:

Information about the potential adverse health effects of lead exposure.

Information about early recognition of lead intoxication

Instruction on how to review material safety data sheets for new paints or coatings that may
contain lead or other hazardous ingredients.

Instruction about heeding signs that mark the boundaries of lead-contaminated work areas.

Discussion of the importance of personal hygiene practices in reducing lead exposure.

Instruction about the use and care of appropriate protective equipment (including protective
clothing and respiratory protection).

Information about specific work practices for working safely with lead-containing
materials.
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