What Building Owners Need to Know about Lead
August 31, 2021
Lead is a naturally occurring, but toxic metal that has been used in paint, ceramics, caulk, pipe solder, and various other products. The U.S. government banned the consumer use of lead-based paint in residential structures in 1978. It’s important to note, any building constructed before 1978 is at risk of containing lead-based paint.
With over 30 years of experience, Envirologic has the experience to assess lead-based paint in commercial and residential structures and manage any associated hazards. Our commercial services include sampling painted surfaces to determine if lead-based paint is present and overseeing renovation and demolition activities where lead-based paint is present to ensure compliance with Michigan Occupational Safety Health and Administration (MIOSHA) regulations. Our residential services include conducting Lead Inspections and Risk Assessments on Target Housing and Child-Occupied Facilities in compliance with U.S. Department of Housing and Urban Development (HUD) guidelines and U.S. Environmental Protection Agency (EPA) standards.
I own a commercial structure with planned renovations. What do I need to know?
The MIOSHA Part 603 Lead Exposure in Construction standard applies to all construction work activities where an employee may be occupationally exposed to lead. Therefore, any amount of lead in paint triggers the standard, and lead-safe work practices and employee exposure monitoring should be performed in compliance with the standard.
During demolition activities of lead-based painted surfaces, employee exposure above the Permissible Exposure Limit (PEL) of 50 ug/m3 should be assumed until air monitoring results dictate otherwise. For this reason, in compliance with the standard, proper personal protective equipment (PPE) and hygiene facilities and practices should be utilized and air monitoring conducted until exposure assessment monitoring determines that airborne results are below the Action Level of 30 ug/m3 for lead.
Additionally, some landfills require that calculations be performed for landfill approval of demolition debris with respect to lead on painted surfaces. Coordination with the selected landfill should be made to assess disposal approval requirements.
I own a mixed-use property or residential property receiving federal funds. What type of lead-based paint testing is required?
The Lead Safe Housing Rule (LSHR) establishes procedures for assessing whether a hazard is present, controlling or eliminating the hazard, and informing occupants. The LSHR specifically encompasses housing that is receiving assistance from the federal government or is being sold by the federal government. Therefore, financing through the Michigan State Housing Development Authority (MSHDA), HUD, and in some cases the Small Business Administration (SBA) may require a Lead Inspection, Lead Risk Assessment, or a combination of the two.
- A Lead Inspection determines if lead-based paint is present. It does not determine if hazards associated with lead-based paint exist. Only persons certified as a Lead Inspector or Lead Risk Assessor by the Michigan Department of Health and Human Services (MDHHS)-Healthy Homes Section (HHS) can perform a Lead Paint Inspection.
- A Lead Risk Assessment determines if a residence, or Child Occupied Facility (i.e., a daycare), of a young child is lead safe through an assessment of hazards including lead in paint, lead in soil, lead in dust, and sometimes lead in water. Only persons certified as a Lead Risk Assessor by the MDHHS-HHS can perform Lead Risk Assessments.
- A combined Lead Paint Inspection and Risk Assessment identifies all lead-based paint and all lead-based paint hazards.
The LSHR does not apply to properties where emergency repair actions are being conducted or where emergency housing assistance is being applied (unless assistance lasts more than 100 days). The following properties are also exempt from the LSHR because lead paint is unlikely to be present or children will not occupy the house in the future:
- Housing built on or after January 1, 1978
- Housing exclusively for the elderly or persons with disabilities, unless a child under six years old is expected to reside there for prolonged periods of time
- Zero-bedroom dwellings, including efficiency apartments, single-room occupancy housing, dormitories, and military barracks
- Property that has been found to be free of lead-based paint by a certified inspector
- Property from which all lead-based paint has been removed and clearance has been achieved
- Unoccupied housing that will remain vacant until it is demolished
- Non-residential property (unless it meets the definition of a “Child Occupied Facility”)
- Any rehabilitation or housing improvement that does not disturb a painted surface
If you have questions about whether lead-based paint could be present on your commercial or residential property, or if you need more information about the lead-based paint services we can provide, please contact Therese Searles, Project Manager. She can be reached by phone at (800) 272-7802 or by email.