Lead Program
The Harvard University Lead Program establishes the minimum requirements for the control of lead exposures to University employees, students and dependents living in university housing.
The Massachusetts Department of Public Health (MDPH) regulates issues related to lead exposures in residential premises. Specific requirements are found in the Lead Poisoning Prevention and Control Regulation (105 CMR 460.00). The regulation is designed to protect young children (children under 6 years old) from potential lead poisoning due to lead exposures in the home. The requirements focus on young children because they have a much higher risk of lead poisoning due to lead exposures in residential settings.
The Massachusetts Department of Labor and Work Place Development’s deleading regulation (454 CMR 22.00) requires deleaders and construction contractors to take special precautions to limit the spread of lead dust during any work that disturbs lead based paint.
The Occupational Safety and Health Administration (OSHA) 29CFR 1926.62 Lead in Construction has specific requirements for employers when their employees may be exposed to airborne lead levels above the action level set by the standard.
Requirements
- Identify all dwelling units covered by lead law (units with separate living, sleeping and cooking areas) and distribute the Lead Law Notification/Tenant Certification forms to all tenants.
- Have a licensed lead inspector conduct lead inspection in all dwelling units and common areas where children under six will live. Remove, cover or encapsulate lead base paint (LBP) as required by MDPH using a certified delead contractor.
- Determine if LBP will be disturbed during any construction project and take precautions as specified by DLWD.
- Determine tasks performed by employees where they may be exposed to lead.
- Perform exposure assessments and draft a written compliance program for employees exposed to lead levels above the action levels.
Responsibilites for Building Managers
- Determine if you are responsible for any residential dwelling units covered by MDPH.
- Send Lead Notification/Tenant Certification forms to all tenants in units covered by MDPH.
- Have a licensed lead inspector inspect premises where children under six will live.
- Remove, cover or encapsulate LBP as required by MDPH in residences where children under six will live.
- Determine if LBP will be disturbed during any construction/renovation including interior and exterior painting. Ensure that contractors take appropriate site control measures as required by DLWD if LBP is present.
- Ensure that construction waste containing LBP is disposal complies with MassDEP solid waste regulations.
- Determine if any employees require exposure assessment for OSHA compliance.
- Ensure written compliance program for employees covered by OSHA is implemented.
Resources
EH&S Training and Technical Assistance
- Hazard Communication Training
- Assistance with exposure assessments
- Respirator Training
- Assistance with LBP contract review
- Respirator Fit Testing
- Assistance with written program
