Lead-Safe Schools Guide

Lead-Safe Schools Project

Labor Occupational Health Program

University of California at Berkeley

Lead-Safe

The Lead-Safe Schools Guide was developed under a grant to the Labor Occupational Health Program (LOHP) at the University of California, Berkeley by the Childhood Lead Poisoning Prevention

Program, California Department of Health Services (DHS).

The Lead-Safe Schools Project is a joint effort of U.C. Berkeley’s Labor Occupational Health Program, the Childhood Lead Poisoning Prevention Branch of the California Department of Health Services, and the California Department of Education.

Labor Occupational Health Program University of California

2223 Fulton Street

Berkeley, CA 94720-5120

Lead-Safe

Schools Guide

For Maintenance and Operations

Departments

Acknowledgments

Writers

Robin Dewey, MPH Gail Bateson, MS

Michele González Arroyo, MPH Barbara A. Plog, MPH, CIH, CSP Leonor Dionne, MS

Project Coordinator

Michele González Arroyo, MPH

Technical Coordinator

Barbara A. Plog, MPH, CIH, CSP

Editing, Design, and Production

Gene Darling Kate Oliver

Illustrator

Mary Ann Zapalac

Project Assistant

Carmen Foghorn Donna Iverson

LOHP Director

Contributors and Reviewers

Organizations

LOHP is indebted to the following organizations for their contributions to this Guide:

◆ California Department of Education (CDE)

◆ California School Employees Association (CSEA) ◆ Childhood Lead Poisoning Prevention Branch (CLPPB),

California Department of Health Services

◆ Occupational Lead Poisoning Prevention Program (OLPPP), California Department of Health Services

Technical Reviewer

Stephen C. Davis, MPH, CIH, CSP Health Science Associates

Emeryville, CA

Individual Contributors and Reviewers

Ellen Aasletten

Planning Department, California Department of Education Doug Adams

San Diego Unified School District Mark Allen

Alameda County Lead Poisoning Prevention Program Lynn Anderson

Department of Social Services, Community Care Licensing Division Amy Arcus

Office of Environmental Health Hazard Assessment (OEHHA), DHS Don Benning

Sacramento Unified School District Rachel Broadwin

Office of Environmental Health Hazard Assessment (OEHHA), DHS Duwayne Brooks

School Facilities Planning Division, California Department of Education Simone Brumis

Education and Training Unit, Cal/OSHA Consultation Kimberly Comet

North Coast Schools Insurance Group Susan Cummins

Childhood Lead Poisoning Prevention Branch, DHS Lyn Dailey

California Childcare Health Project George Datz

California School Employees Association Jill Garellick

Childhood Lead Poisoning Prevention Branch, DHS Bruce Gianini

Asbestos Control, San Francisco Unified School District David Harrington

Occupational Lead Poisoning Prevention Program, DHS Richard Henry

Maintenance and Operations, Los Angeles Unified School District John Huls

Maintenance and Operations, San Juan Unified School District Catherine Wilson Jones

Self Insured Schools of California Larrie Lance

Childhood Lead Poisoning Prevention Branch, DHS Don Lanier

U.S. Environmental Protection Agency Eleanor Long

Los Angeles Lead Poisoning Prevention Program Barbara Materna

Occupational Lead Poisoning Prevention Program, DHS Scott McAllister

Cal/OSHA, Department of Industrial Relations Jon Merkel

U.S. Environmental Protection Agency Rhonda Bacot-Milan

Hayward Unified School District Dana Polk

Childhood Lead Poisoning Prevention Branch, DHS Gary Pons

Los Angeles Unified School District Dan Scannell

Childhood Lead Poisoning Prevention Branch, DHS M.A. Stevenson

Public Utilities Commission, City and County of San Francisco Mona Thabit

San Diego County Health Department Lead Program Mike Zurich

Contents

Chapter 1

About This Guide ... 1

Chapter 2

Health Effects of Lead ... 9

Chapter 3

Elements of a Lead Program ... 19

Chapter 4

Identify Lead in Schools ... 29

Chapter 5

Analyze Maintenance Tasks ... 53

Chapter 6

Provide Worker Protection ... 61

Chapter 7

Use Safe Work Practices ... 71

Chapter 8

Train Workers ... 91

Chapter 9

Document and Evaluate the Program ... 103

Forms

... 109

Program Planning Form ... 111

District Target Schools Form ... 115

Building Inventory Form—Paint & Soil Hazards ... 117

Appendices

... 119

A. California DHS Report—Executive Summary ... 121

B. Lead in Construction Standard—Summary ... 127

C. Hazard Communication Standard—Summary ... 137

D. Injury and Illness Prevention Program—Summary ... 139

E. Lead-Safe Schools Protection Act ... 141

F. Title 17—Summary ... 143

G. Contractor Requirements ... 149

H. Guidelines for Volunteers ... 153

I. Resources for More Information ... 155

What Is a Lead-Safe Schools Program?

It has been known for a long time that children get exposed to lead at home. Could they also get exposed at school? A study published by the California Department of Health Services (DHS) in 1998 found lead in most public elementary schools in the state. Nearly 96% of schools—even some newer ones—have detectable levels of lead in the paint. The study also found lead in the drinking water at some schools, and in the soil around older school buildings. (See Appendix A for a summary of the DHS study.)

The results of the DHS study prompted a statewide effort to provide school districts with the information and training they need to address lead

problems. The Lead-Safe Schools Project was begun in late 1998. This joint effort of several state agencies and the University of California at Berkeley will help school districts to initiate or strengthen their own lead-safe schools

programs. Such programs set clear policies, procedures, and action plans for

all lead work in schools.

This Lead-Safe Schools Guide is a tool that California school districts can use to create a safer school environment. It focuses on custodial and

maintenance work in schools. This type of work, if done unsafely, can expose both children and workers to significant amounts of lead. The Guide is intended primarily for staff in California public elementary schools and childcare facilities (such as daycare centers associated with schools and daycare programs for teen parents).

The theme of this Guide is that, with proper resources and training, lead hazards can be managed and controlled safely as part of standard school

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About This Guide

maintenance practices. Controlling lead hazards is usually a safer alternative than the complete removal of lead. The measures outlined here will go a long way toward making our schools safer.

Systematic policies and procedures for lead work are also cost-effective. For example, school districts can wind up spending more than expected for renovation and maintenance work if it is done in an unsafe manner or with untrained personnel. Unsafe practices can create new problems that have to be corrected later at great expense, and can potentially result in costly legal difficulties for the school district as well.

Consider this recent news story about a California school:

Planning Could Have Saved School District $45,000

I

n 1998, a California school district planned a major

renovation of one of their older elementary schools. Several contractors were brought in. Many of them were experienced in lead work. They and their employees had received lead training and were state-certified.

In preparation for repainting, a school district maintenance crew water-blasted the outside of the school. There had been no testing of paint samples for lead. Paint chips fell to the ground, and were blown around by the wind. The contractors reported the water blasting to

government agencies, which led to site inspections by Cal/OSHA and several other agencies. It was found that the paint chips did contain lead. The district was required to clean the entire school complex with special HEPA vacuum cleaners inside and out. They also had to notify all neighbors within a two-block radius of the school about their potential lead exposure.

Unofficial estimates of the clean-up costs included: $15,000 in labor costs for the 10 days it took to vacuum around the school, $20,000 in lost wages to the

contractors who couldn’t work during the clean-up, and about $10,000 for air sampling and other testing.

Could the school have avoided the new problems that were created? Unfortunately, situations like this come up again and again for schools. Adopting lead-safe policies and procedures and putting them in writing ensures that work involving lead will be handled safely and consistently.

This Guide gives advice on controlling lead hazards in paint, water, and soil while doing routine day-to-day maintenance and custodial work. It does not cover lead abatement, demolition, renovation, or activities involving

complete paint removal, which should always be done by highly trained workers and supervisors who are state-certified in lead-related construction. However, it does provide specific guidelines on when and how to use state-certified lead workers and contractors.

Why Worry About Lead?

Lead is highly toxic to the human body. At one time, before its hazards were fully understood, lead was widely used throughout society in many industrial and consumer products. Today, it can still be found in some paints, solders, construction materials, pipes, plumbing fixtures, batteries, and even dishes and hobby supplies.

Over time, lead from such products and from manufacturing processes has contaminated air, water, soil, and food. Although recent legislation has eliminated lead in gasoline and greatly reduced it in manufactured products, widespread contamination of the environment by lead continues to be a problem.

Lead can cause serious health effects at any age, but it is especially

dangerous for children eight and under. Lead poisoning is the most common environmental health problem affecting young children. It can permanently damage the brain and nervous system, slow growth, and cause learning and behavior problems.

But lead poisoning is preventable. Lead hazards (such as deteriorating or damaged lead paint, contaminated soil, or contaminated water) can be controlled, both in the home and the school. For schools, this Lead-Safe

Schools Guide is an important first step.

Who Can Use This Guide?

The Guide is primarily intended for California school district Maintenance and Operations (M&O) departments. These departments, known by various names in different school districts, typically include both custodial and maintenance personnel.

School superintendents, principals, and other administrators also play a key role in creating lead-safe schools and can benefit from the Guide. In some cases, they may directly supervise custodial and maintenance workers. They also provide a link to all other members of the school community.

There is an increasingly aware population of parents, teachers, school staff, administrators, and school board members who are concerned about lead and other environmental matters. Informing and educating them can address unwarranted fears as well as help ensure safe work practices.

In these times of limited resources, parents, teachers, and others may want to help by taking on volunteer maintenance projects. There are numerous stories about parents’ clubs repainting buildings or playground equipment without being aware of the potential lead hazards they may create. For example, consider this recent news story:

Parent Attempt To Help School Backfires

S

taff from one small California school district vow

they will never again allow parent volunteers to help with jobs that disturb lead paint. A father, believing he was helping the school, chipped off loose paint from an outdoor play structure at the school to prepare it for repainting. The paint contained lead. All of the sand near the structure had to be removed and replaced. The sand had not been protected from the falling lead paint chips as required by law. Proper disposal and replacement of the contaminated sand cost the school district $6,000.

Administrators can use the material in this Guide to build awareness of the hazards involved in painting and other maintenance work.

It should be noted that following lead-safe work practices will probably involve an investment of money for equipment and materials, and an investment of time. The entire school community needs to be aware that following recommended procedures for controlling lead may mean that maintenance jobs take longer. But the investment of time is worthwhile. The recommendations here can help schools protect children and staff from serious health damage.

Why Follow These Recommendations?

The recommendations in this Guide will help protect the health of children, workers, and families. It’s also the law. California schools are required to use lead-safe practices under several laws and regulations (both state and federal).

These regulations include:

Lead-Safe Schools Protection Act (LSSPA) of 1992.[California Education Code. Sections 32240–32245] Requires California public elementary schools and childcare facilities to use state-certified construction personnel when abating lead hazards. Also forbids the use of lead-based paint, lead plumbing and solders, or other potential sources of lead contamination in new school construction and in school modernization or renovation projects.

Accreditation, Certification, and Work Practices for Lead-Based Paint and Lead Hazards. [Title 17, California Code of Regulations, Section 35001 et. seq.] This is the key state regulation for lead work. Defines “lead

hazard” as deteriorated lead-based paint, lead contaminated dust, lead contaminated soil, disturbing lead-based paint or presumed lead-based paint without containment, or any other nuisance which may result in persistent and quantifiable lead exposure.

Requires accreditation of training providers by California DHS. Requires training in accredited programs and subsequent certification by DHS of workers who perform abatement and other high risk lead-related

construction work such as any alteration, painting, demolition, salvage, renovation, repair, maintenance, preparation, and cleanup that may result in significant exposure of adults or children to lead. There are five categories of certification with different training and experience

requirements: Lead Worker, Lead Supervisor, Lead Project Monitor, Lead Project Designer, and Lead Inspector/Assessor.

Sets out requirements for all lead abatement work in public buildings and residential buildings. Defines “lead abatement” as any set of measures designed to reduce or eliminate lead hazards or lead-based paint in these buildings. (However, this does not include containment or cleaning.) Requires state-certified workers and supervisors for abatement work which is designed to reduce lead paint or other lead hazards for a minimum of 20 years. Requires other measures as well.

For abatement designed to reduce lead paint hazards for less than 20 years, Title 17 has a list of requirements including specific work

procedures that follow Chapter 11, Interim Controls, of the U.S. Housing and Urban Development (HUD) Guidelines for the Evaluation and

Control of Lead-Based Paint Hazards in Housing, June 1995.

Cal/OSHA Lead in Construction Standard.[Title 8, California Code of Regulations, Section 1532.1] Requires safe practices in all construction and maintenance work where an employee may be exposed to lead. California school employees are included. Activities covered include alteration, repair, and even painting of buildings.

Sets requirements related to permissible level of worker exposure, exposure assessment, work practices, personal protective equipment including respirators, medical surveillance programs (including blood testing), housekeeping, hygiene facilities and practices, signs, and recordkeeping.

Also defines a set of “trigger tasks” which are assumed to incur lead exposure over the legal limit and require respiratory and other protection until an actual exposure assessment is done. Also sets out requirements for “medical removal protection,” where an employee is removed from lead work and given alternate work, or paid leave and benefits, until medically released for return to lead work.

Federal Lead Contamination Control Act of 1988.[Title 42, United States Code, Section 300j-21] An amendment to the federal Safe Drinking Water Act of 1974. It prohibits lead-lined water coolers in schools and childcare facilities, and requires the U.S. Environmental Protection Agency (EPA) to set up an information program to help local school districts identify and eliminate lead contamination in drinking water.

Cal/OSHA Injury and Illness Prevention Program Standard.[Title 8, California Code of Regulations, Sections 1509 and 3203] Requires California

employers to have a written program that outlines how they plan to assess hazards, correct them, and communicate information to workers. This Injury and Illness Prevention Program (IIPP) must cover hazards at each specific worksite, including lead.

Cal/OSHA Hazard Communication Standard.[Title 8, California

Code of Regulations, Section 5194] Requires California employers to inform workers about the hazards that may be present in the workplace,

including lead. Requires employers to keep Material Safety Data Sheets (MSDSs) on hazardous substances and make them available to workers. Also, employers must provide training about work hazards, safe work practices, and protective measures.

Federal Toxic Substances Control Act (TSCA) of 1976.[Title 15,

United States Code, Section 2601 et seq.] Regulates all chemicals imported or produced in the U.S. Requires testing of commercial chemicals for toxic effects and regulates use and cleanup. Title IV of TSCA covers lead paint hazards. Enforced by EPA, sometimes in conjunction with other agencies such as U.S. Department of Housing and Urban Development (HUD). Enforced in California by Cal/EPA.

Summaries of certain laws and regulations above appear in Appendices B–F. For the full text of laws above, check the website www.childlead.com. For Cal/OSHA standards go to www.dir.ca.gov. Click on “Occupational Safety & Health” and go to Title 8 Regulations. For EPA regulations and related information, go to www.epa.gov/lead.

Failure to comply with these various requirements can raise legal and liability issues for a school district. But, much more importantly, following the law provides an opportunity to protect school children and employees from lead poisoning. We can hope that children are not exposed to lead at home, but we want to make sure they are not exposed at school.

How Can the Lead-Safe Schools Project Help?

The Lead-Safe Schools Project was set up to help California school districts minimize exposure of children and staff to lead in the school environment. It is a joint effort of the Labor Occupational Health Program at the University of California, Berkeley; the Childhood Lead Poisoning Prevention Branch of the California Department of Health Services; and the California Department of Education. The Project has developed recommendations for many aspects of a lead-safe schools program, including hazard surveys, custodial and maintenance work practices, training, recordkeeping, and other issues. These recommendations appear throughout this Guide and are consistent with legal requirements.

In addition to the Guide, the Project also has a training curriculum and videotape to teach school custodians and maintenance staff about lead-safe work practices. Training on how to present these materials to staff will be offered to representatives from each California school district, beginning in the fall of 1999.

The Lead-Safe Schools Project also has a technical hotline. School district staff can call with questions about material in this Guide and related issues. For more information about the Project, to reach the technical hotline, or to obtain a copy of the curriculum, call U.C. Berkeley’s Labor Occupational Health Program at (510) 642-5507. The curriculum is also available from the Childhood Lead Poisoning Prevention Branch of the California Department of Health Services. Check the website www.childlead.com.

Who Is at Risk from Lead Hazards?

Lead can harm people of any age, but it is especially hazardous for children eight and under. Young children are at a higher risk because:

◆ They often put their hands and other objects into their mouths, and can easily swallow any lead dust that is present.

◆ Their growing bodies absorb more lead than older children and adults. For example, young children absorb up to 50% of the lead they swallow, while adults typically absorb only about 10%.

◆ A developing child’s brain and nervous system are particularly sensitive to the effects of lead.

The U.S. Centers for Disease Control and Prevention (CDC) found that approximately 900,000 U.S. children between 1 and 5 years old have abnormally high levels of lead in their blood. In California approximately 239,000 children have lead levels high enough to put them at risk of health damage, according to the Department of Health Services (DHS) study summarized in Appendix A.

Lead can also be hazardous for adults. Workers who are exposed to high amounts of lead on the job can face serious health damage. Men and women who are planning to have children, and pregnant women, are especially at risk.

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Health Effects of Lead

How Does Lead Get Into the Body?

Lead can get into the body by breathing (inhaling) or swallowing (ingesting) dust, particles, or paint chips that contain lead. These may be on surfaces or in air, water, or soil. Note that lead dust can be invisible. It may be present in dangerous amounts even if it is not seen by the naked eye.

Food, drink, and cigarettes can become contaminated if they are stored or consumed in an area with lead dust. Lead may also be found in vegetables grown in lead-contaminated soil.

Once lead enters the body it gets into the bloodstream. It then circulates throughout the body. The body can eliminate some of it through the kidneys. But some lead is stored in the body, mostly in the bones where it can build up and stay for years. Many parts of the body can be damaged by lead. The more lead in the body, the more likely it is that damage will occur.

How Can Children Be Exposed to Lead?

Children are most often exposed to lead if they:

◆ Swallow lead dust that is on their hands or other surfaces.

◆ Swallow lead paint chips.

◆ Chew on surfaces with lead paint.

◆ Drink water that contains lead.

◆ Play in soil that is contaminated with lead.

How Can School Employees Be Exposed to Lead?

Workers can be exposed to lead if they:

◆ Breathe lead dust or fumes created during possibly unsafe work activities, such as: • Sanding paint • Scraping paint • Grinding paint • Carpentry • Renovation work • Welding • Demolition work • Soldering • Cleanup work.

◆ Swallow lead dust that may be on hands, food, drink, or cigarettes.

◆ Drink water that contains lead.

Are Workers’ Families at Risk?

Yes. Workers can be a source of exposure to their families. They may take lead dust with them if they wear work clothes or shoes home. Lead dust can get into the car, furniture, and carpets. It may then be spread throughout the home, endangering everyone.

What Health Problems Can Lead Cause in Children?

Lead is a poison that affects virtually every system in the body. Even exposure to low levels of lead can permanently affect children. The damage can occur soon after exposure, or many years later.

Lead is particularly harmful to a young child’s developing brain and nervous system. Lead exposure may result in:

• Learning disabilities • Attention Deficit Disorder • Decreased intelligence

• Speech and language problems • Behavior problems.

In addition, lead can:

• Slow physical growth • Cause hearing problems • Damage the kidneys.

While low-level exposure is most common, exposure to high levels of lead can have devastating effects on children, including seizures,

unconsciousness, and, in some cases, death.

What Are the Early Signs of Lead Poisoning in Children?

Many lead-poisoned children show no symptoms at all. The only sure way to know if a child has lead poisoning is to get a blood test. (There is more information on blood testing later in this chapter.)

When symptoms do occur, they are often the same as those of common illnesses like a cold or the flu. Other early signs and symptoms of lead poisoning in children can include:

• Persistent tiredness or hyperactivity • Irritability

• Loss of appetite • Weight loss

• Reduced attention span • Difficulty sleeping • Constipation.

Brain and Nervous System

Permanent brain damage can occur. This may affect the ability to think and cause personality changes.

Heart and Blood

Lead can cause anemia, which may make one feel weak and tired. Lead can also cause high blood pressure.

Kidneys

Permanent damage can occur. Kidneys may be seriously damaged before any obvious symptoms appear, and before tests show anything abnormal.

Bones

Lead can be stored in the bones for many years without causing symptoms. It is gradually released back into the bloodstream and can cause damage. Pregnancy, lactation, stress, and certain illnesses can increase this release.

Digestive System

Lead can cause nausea, constipation, diarrhea, cramps, lack of appetite, pain in the stomach or abdomen, and weight loss.

Reproductive System

Lead can damage the reproductive systems of both men and women. It may decrease sex drive, reduce the ability to have children, and

increase the risk of miscarriage, stillbirth, and birth defects.

Why Is Lead Hazardous for Pregnant Women?

Pregnant women are especially sensitive to the damage lead can cause because:

◆ Lead can easily cross the placenta and harm the developing fetus.

◆ During pregnancy, any lead stored in the bones is more likely to be released into the blood.

When pregnant women are exposed to high levels of lead their infants may:

◆ Weigh less at birth.

◆ Die more often in the first year of life.

◆ Have developmental problems.

How Is Lead in the Body Measured?

Blood Lead Level (BLL) and Zinc Protoporphyrin (ZPP) tests are used to

measure how much lead has entered the body. Both of these blood tests can be done from the same blood sample.

The results of the BLL and ZPP tests are reported in micrograms of lead per deciliter of blood (µg/dl).

◆ A microgram of lead is roughly the weight of one tiny piece of dollar bill, if the bill is torn into a million equal pieces.

◆ A deciliter of blood is about seven tablespoons.

The BLL Test. Measures the amount of lead circulating in a person’s blood. It gives an estimate of recent lead exposure, or of lead recently released from the bones. The BLL test cannot measure past lead exposure, the amount of lead stored in the body, or the effect lead is having on the body. The typical BLL for adults with no specific lead exposure is less than 3 µg/dl.

The ZPP Test. Measures a particular protein in the blood. It does not measure the amount of lead in the blood. The results estimate exposure to lead over the past three or four months.

A rise in ZPP usually lags behind a rise in BLL by two to six weeks.

Therefore a person with a normal ZPP but an elevated BLL has probably had very recent exposure to lead. The typical ZPP for adults with no specific lead exposure is 50 µg/dl or less.

Is There Any BLL That Is Safe?

No. There is no level that has been proven safe, either for children or for adults. Lead does not belong in our bodies at all. Most people, including children, are free of symptoms at BLL levels of 10 µg/dl or less. Both CDC and the California Department of Health Services consider any BLL above 10 µg/dl to be unsafe for children and for pregnant or nursing women.

What Can Be Done About High Blood Lead Levels?

Children. Action taken by health professionals depends on the child’s specific BLL. It can include:

◆ An environmental investigation to determine possible sources of the child’s lead exposure.

◆ Measures to reduce the lead hazards causing exposure.

◆ Family education about preventing future contact with lead.

◆ Medical treatment, such as chelation, if indicated.

The home is usually the primary source of childhood lead poisoning. If a child has an elevated BLL, the home is the most likely suspect, but the school or childcare environment could also be involved.

Adults. Many adults with high BLLs have been exposed to lead on the job. The best corrective action is to eliminate this job exposure. For example, the Cal/OSHA Lead in Construction standard says that workers whose BLLs are at or above 50 µg/dl (on two consecutive tests) as a result of their jobs must be removed from all lead exposure at or above the Action Level. Workers must also be removed from such exposure at any time if ordered by a doctor. They do not lose pay or benefits. This is called medical removal protection. The worker must be assigned to another job where exposure is lower than the Action Level, if one is available. For more on medical removal protection, see Chapter 6.

The Cal/OSHA standard (see Appendix B for a summary) also requires a number of other measures to monitor and lower workers’ lead exposure and BLLs. For workers whose BLLs are at or above 40 µg/dl, it provides for medical exams, medical treatment when necessary, and regular blood testing. For more information on medical monitoring requirements, see Chapter 6.

Can Good Nutrition Help Prevent Lead Poisoning in Children?

Yes. Good food can lessen the effects of exposure to lead. Although schools have limited control over children’s diets, they should encourage students to eat well and should communicate with parents about good nutrition.

Health professionals recommend that children:

• Eat at least three meals a day. Less lead is absorbed when children have food in their systems.

• Eat foods high in calcium, like dairy products. When a child does not have enough calcium in his or her body, the body mistakes lead for calcium.

• Eat foods high in iron, like meat, chicken, beans, and raisins. Most breads and cereals also have iron since they have been fortified. If children get enough iron, they won’t absorb as much lead.

• Avoid fried and fatty foods. These foods allow the body to absorb lead faster.

• Wash their hands before they eat. Lead can be found in dust and soil in and around schools. While lead cannot be absorbed through the skin, it can be swallowed.

What Is Chelation?

Chelation therapy is the primary medical treatment for severe lead poisoning in both adults and children. It can be a painful and risky treatment. Chelating drugs attach themselves to lead in the body and are then filtered out through the kidneys into the urine. Some chelating drugs are injected and others can be taken orally. Chelation should only be done on a case by case basis, always under the care of a physician who is knowledgeable and experienced in the management of lead poisoning.

Cal/OSHA strictly forbids the practice called prophylactic chelation. This is when workers who are being exposed to lead on the job are routinely given chelating drugs to keep their lead levels down. This practice is dangerous as well as illegal. The best and safest therapy for lead poisoning is to stop the exposure to lead.

Why Do You Need a Lead-Safe Schools Program?

It is essential to develop a comprehensive written lead-safe schools program for your district. A clear set of policies and procedures addressing lead hazards can help you:

◆ Protect children and employees from lead poisoning.

◆ Respond to the concerns of parents, teachers, school board members, and others in the school community.

◆ Comply with the law. As explained in Chapter 1, several state and federal laws require school districts to control lead.

◆ Avoid unnecessary costs. By knowing how much lead is present and the extent of the lead hazards, a school district can determine the most cost effective way to deal with the problem. Remember that unsafe practices can create new problems that have to be corrected later at great expense.

What’s Needed To Develop a Program?

Manager. Someone in your school district should be designated to oversee

the lead-safe schools program. This program manager should be given sufficient authority and resources to do the job effectively. The manager should be a person familiar with the Maintenance and Operations

department’s existing policies and procedures, particularly those related to

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Elements of a Lead Program

health and safety. Knowledge of lead regulations is essential. It is

recommended that the manager have training from a state-accredited lead training program and be DHS-certified at least at the Lead Supervisor level. Knowledge of Cal/OSHA regulations such as the Lead in Construction, Hazard Communication, and Injury and Illness Prevention Program standards is also important.

The role of the program manager is to design, implement, and document your lead-safe schools program. The remainder of this Guide outlines the process step by step.

Documentation. To keep track of your program’s decisions, policies, and procedures, consider compiling a file or binder devoted to lead issues. Also use this file for the various types of documentation discussed in the sections below. Sample forms that can be used for some of this documentation appear in the Forms section at the end of the Guide. Ultimately this material can be developed into a formal written lead program.

What Are the Elements of a Program?

Lead should be dealt with the same way as any other health and safety problem: identify, evaluate and control the hazard, and then document what you did.

The basic elements of a lead-safe schools program are: 1. Identify Lead in Schools.

2. Analyze Maintenance Tasks. 3. Provide Worker Protection. 4. Use Safe Work Practices. 5. Train Workers.

6. Document and Evaluate the Program.

The elements are briefly described in this chapter, and are explained in more detail throughout the rest of this Guide.

1. Identify Lead in Schools.

Collect and Review District Records. Existing records can give a first indication of which school sites are most likely to have lead hazards. Make a list of target schools—those with children eight and under that were built before January 1, 1993. Then check the painting history, dates of plumbing work, and previous air, soil, and water sampling records if any. It is also useful to collect school site maps and photos if available.

Survey Paint and Soil at Target Schools. Paint and soil should be visually inspected for lead hazards at all target schools. Visual inspections may be done by M&O personnel with at least general lead awareness training, but must always be supervised by the Lead-Safe Schools Program Manager or a state-certified Lead Inspector/Assessor. Repeat these surveys every few years or after any major damage.

By law, a “lead hazard” is defined as deteriorated lead-based paint, lead contaminated dust, lead contaminated soil, disturbing lead-based paint or presumed lead-based paint without containment, or any other nuisance that may result in persistent and quantifiable lead exposure.

Survey forms can be used to document what paint and soil problems were found. There are sample forms in the Forms section at the end of this Guide.

Test Paint and Soil Where Appropriate. The only way to know for sure if there is lead in paint is to test it. However, Title 17 of the California Code of Regulations says that all paint at schools built before January 1, 1993 is “presumed lead-based paint.” An alternative to testing is to assume that paint contains lead and always use lead-safe work practices.

Soil near buildings built before 1940 should be tested if it is accessible to children. If testing isn’t feasible, and children use the area, cover the soil or deny access to the area.

Test Water at All Schools. Drinking water should be tested for lead if records do not indicate previous testing. New tests should be done after plumbing renovations.

During the site survey of paint and soil, ask school maintenance staff about sources of drinking water and any recent plumbing work.

Set Priorities for Hazard Control. Determine how and when you plan to work on the most serious lead problems. Give them priority on the

maintenance schedule where possible. Adjust your department workplan and policies accordingly. Also decide which lead control jobs can be done by district staff and which may require state-certified contractors. For more on identifying lead in schools, see Chapter 4.

2. Analyze Maintenance Tasks.

Evaluate Tasks for High Risk and Lower Risk Exposure.

Analyze maintenance tasks done throughout the school district and categorize them as either high risk or lower risk. These categories will help you select workers for each task, give them the right training, and put appropriate work practices in place. Both routine tasks and those specifically designed to reduce lead hazards should be reviewed this way.

The district should evaluate pending maintenance requests to see if they could disturb lead paint. Current work practices might create lead hazards. Certain work may need to be postponed until your lead-safe schools program is in place. For more on analyzing maintenance tasks, see Chapter 5.

3. Provide Worker Protection.

Choose Appropriate Protection for Workers. Required

protective clothing and equipment varies according to a worker’s expected lead exposure level. For lower risk tasks, only coveralls may be necessary. For high risk tasks, workers may have to wear respirators. The employer must supply whatever clothing and equipment are required. You need a system for purchasing, distributing, and maintaining this equipment, and you must train workers in how to use it. For more on protective equipment, see Chapter 6.

4. Use Safe Work Practices.

Establish Procedures for Working Safely. Your written lead program should describe in detail the lead-safe work practices and procedures that must be followed for various types of

maintenance work. Procedures should be spelled out for all aspects of the job—initial personal air sampling, setup, doing the work, cleanup, disposing of waste, and quality assurance. It is critical to clean up properly after working and never to leave the work unattended. Depending on the level of lead exposure, you may also need policies on medical testing of workers.

Obtain Necessary Supplies. You should have a system for purchase of necessary equipment and supplies before beginning any job that may disturb lead. These include “caution” tape, plastic sheeting, and warning signs. Sometimes special power tools are needed. Provide handwashing facilities, and lunch areas separate from work areas, for workers who may have lead

5. Train Workers.

Design and Conduct Worker Training. All workers, including custodians, should be given a basic “awareness” level of lead training if they work around lead. If district maintenance staff will do either routine maintenance work involving lead, or specific lead control work, you need a more advanced training program. Design appropriate training (or locate outside sources of training) and schedule staff to attend. Keep a record of dates when individuals were trained. Some workers may need to obtain DHS-accredited training and DHS Lead Worker certification. Require all contractors doing work that involves lead exposure to provide proof of DHS-accredited training and DHS certification for lead-related construction.

Evaluate Job Duties. New job duties may raise certain personnel issues. Some tasks once done by custodial or maintenance staff may now require special training. Whether current staff are retrained or other specially trained staff are used, it may be necessary to revise job descriptions.

Educate Parents and Teachers. Alert and educate parents, teachers, and others about the hazards of lead. City and county lead poisoning prevention programs can be a source of educational materials and other resources. (See Appendix I.)

Parent volunteers and other untrained individuals are not qualified to do any work involving possible lead exposure. Establish a policy that strictly prohibits such activity. For more on training, see Chapter 8.

6. Document and Evaluate the Program.

Document Program Activities and Maintain Records. Develop

a system to keep track of all the information your program generates and decisions you make. Some state and federal regulations have specific recordkeeping requirements. For

example, air sampling and blood lead test results must be kept on file according to Cal/OSHA rules.

Keep track of the outside resources your program uses. These may include labs, industrial hygiene services, abatement contractors, equipment suppliers, waste disposal facilities, and government agencies that can answer questions. Send a copy of your lead-safe schools program policies and procedures to appropriate people in your district, such as principals, school administrators, and managers in the Maintenance and Operations (M&O) department.

Regularly Evaluate and Improve Your Program. Programs improve only if you evaluate them periodically and determine what could be done better. For example, when tasks involving lead are done, periodically monitor how much exposure the workers have. High lead levels may point to a need for future improvement in work practices or training. There should be a system to obtain this kind of input regularly and document it.

Talk to other school districts regularly to get ideas on what could be done differently to improve your program. Update your program as needed. For more on documenting and evaluating your program, see Chapter 9.

Can You Afford a Lead Program?

It’s possible to make a program affordable. Following lead-safe work practices requires spending some money to purchase necessary equipment and supplies (for example, plastic sheeting, HEPA vacuums, power tools that can take HEPA attachments, and possibly air sampling equipment). For some school districts, particularly small districts, these costs may present a

hardship. Sharing resources with surrounding districts can help small school districts save money. Maintenance departments in other districts may be able to share supplies and equipment as well as give you ideas for your own district. Many school districts are members of a Joint Powers Authority (JPA), established to share group insurance policies, transportation, and other services with nearby districts. JPAs might also be used to share equipment and other resources needed for lead-safe schools programs.

In some cases, groups of nearby California school districts have purchased items jointly and stocked a special trailer which can go from school to school. The trailer carries tools, equipment, and disposable supplies like plastic sheeting and tape. Some trailers have equipment for both asbestos and lead jobs. Certain large districts in California also have their own trailers.

How Can You Use the Program Planning Form?

The sample Program Planning Form that begins on the next page can help organize your entire lead-safe schools program. This form, used in

conjunction with other documentation, can guide you in developing your program. It covers all six elements discussed earlier in this chapter. For each element, it spells out what you need to do and what records you should keep. The completed form will also be useful later as documentation that each element of your program is in place. Keep the form on file and provide copies to appropriate school district managers.

Program Planning Form

Name of School District ___________________________________ Date ______________________

Program Manager

A Program Manager has been appointed.

Name ___________________________________ Title _______________________________ Location _________________________________ Phone ______________________________

The Program Manager reports to:

Name ___________________________________ Title _______________________________ Location _________________________________ Phone ______________________________

The Program Manager has DHS lead certification.

Level ___________________________________ Renewal date ________________________

1. Identify Lead in Schools

Target schools have been identified (pre-1993 buildings with children 8 and under).

Total number of target schools in the district _________________________________________ Attach the completed District Target Schools Form.

Survey of target schools has been done.

Date begun _______________________________ Date completed ______________________ The survey was conducted by:

Name ___________________________________ Title _______________________________ Location _________________________________ Phone ______________________________ Attach a sheet with additional names if necessary. Also attach a completed Building

Program Planning Form—page 2

Paint chip samples were collected for testing. (Optional.)

Sampling locations and dates _____________________________________________________ ______________________________________________________________________________ Samples collected by ____________________________________________________________ Name and phone of laboratory ____________________________________________________

Attach test results and lab “chain of custody” forms.

Soil samples were collected for testing. (Optional.)

Attach test results and lab “chain of custody” forms.

Drinking water has been tested at all schools.

Name and phone of laboratory ____________________________________________________ Attach test results and lab “chain of custody” forms.

2. Analyze Maintenance Tasks

Personal air sampling has been conducted for each type of lead-related maintenance task. Attach sampling results, lab “chain of custody” forms, list of workers sampled, calibration information, calculations, etc.

Workers have been notified of sampling results.

Date notified __________________________ How notified ___________________________

Typical maintenance tasks have been categorized as either lower risk or high risk based on sampling results and/or other data.

Program Planning Form—page 3

3. Provide Worker Protection

Personal protective equipment (PPE) necessary for lead work has been purchased (booties, goggles, gloves, respirators, etc.).

Attach vendor contact information.

Workers have been informed of the need for PPE and required personal hygiene measures. Date informed ___________________________ How informed _______________________

If respirators will be used, a complete written Respiratory Protection Program is in place. Attach written Program.

If high risk tasks will be performed, a Medical Surveillance Program is in place.

Attach written Program or name, address, and phone of supervising physician.

4. Use Safe Work Practices

Written policies and procedures on lead-safe work practices have been developed and distributed to workers.

Attach written policies and procedures.

Equipment and supplies necessary for lead work have been purchased (caution tape, plastic sheeting, sprayers, detergent, HEPA vacuums, etc.).

Attach vendor contact information.

Wipe sampling has been done on selected jobs to check quality of containment and cleanup. Attach sampling results and lab “chain of custody” forms.

Program Planning Form—page 4

Policies and procedures on lead waste disposal have been developed. Attach written policies and procedures.

5. Train Workers

A training policy has been developed, including training for both present workers and new hires. Attach written policy.

Trainers or outside training facilities have been identified.

Trainer(s) or facilities ___________________________________________________________ Address / phone ________________________________________________________________ Type of training offered __________________________________________________________

Workers to be trained have been identified.

Attach a sheet with the name of each worker, title, and level of training needed. Also attach dated sign-in sheets for trainings.

6. Document and Evaluate the Program

Information on the Lead-Safe Schools Program has been sent to key administrators and M&O managers.

The program has been explained to all M&O workers.

A system for maintaining records has been developed.

A system for periodic evaluation of the program has been developed.

A schedule of future actions has been prepared (follow-up lead surveys, worker re-training programs, etc.).

What Is a Lead Inventory?

The first element of a lead-safe schools program is to get an overall sense of the possible lead problems in your district. After identifying lead hazards, you will be able to set priorities and address the most serious issues first. This chapter will guide you through a lead inventory—a process of

identifying, evaluating, and prioritizing the lead hazards in all your schools district-wide.

Where Is Lead Found in Schools?

Most commonly, lead may be present in the paint, dust, soil, and water at school facilities. A recent California Department of Health Services (DHS) study of public elementary schools statewide, cited in Chapter 1, found many lead hazards. DHS discovered that nearly 96% of the schools surveyed have detectable levels of lead in the paint, 6% have lead in the nearby soil, and 18% have lead in the drinking water. Each of these sources is discussed in this chapter. (See Appendix A for a summary of the DHS study.)

Lead hazards in paint, dust, and soil are related. The main source of soil contamination is lead paint. Paint on buildings and play structures can deteriorate or be disturbed, and chips, dust, or water runoff containing lead can get into the nearby soil. Therefore, it makes sense to look at paint and soil hazards together.

On the other hand, lead contamination in water has different sources and must be considered separately. Don’t overlook the hazards of lead in water.

◆

4

Identify Lead in Schools

Fortunately it is a fairly easy problem to identify and control. While paint and soil problems are more common at older schools, there can be lead in the water at any school. Both schools with new plumbing work and very old schools (pre-1930) can have significant problems of lead in water. This chapter first discusses how to identify, evaluate, and test for lead in paint and soil. It then provides similar information for water.

Are There Other Sources of Lead in Schools?

There may be other sources in some schools. Lead is sometimes found in art supplies, photography supplies, pottery glazes, science lab materials, and also in some vinyl miniblinds. School districts should evaluate whether there are ways to eliminate these sources of potential exposure. However, this Guide only addresses lead in paint, dust, soil, and water.

Does Most Paint Contain Lead?

Yes. Almost all commercial paint sold before 1993 contained some lead. As evidence of its hazards began to emerge, industry and government took steps to eliminate it.

Lead in paint used to be a sign of quality. The higher the lead content, the better the paint. Lead was added to paint to make it last longer, dry faster, and stick better. Older schools and other buildings are more likely to have paint containing high levels of lead. This old lead paint is often covered with more recent layers of paint that may not contain lead.

Until the mid-1950s, paint contained as much as 50% lead. In 1955, the paint industry adopted a voluntary standard limiting interior paints to 10,000 ppm (or one percent) lead. In 1978, the U.S. Consumer Product Safety Commission (CPSC) banned the manufacture of residential paint containing more than 600 ppm lead. (Note that most latex paint has never contained lead.)

Non-residential paint, such as some industrial paints and marine paints used for boats, can still be lead-based. And although the CPSC ban occurred in 1978, supplies on hand extended the use of residential lead-based paint into the 1980s. In addition, schools may have received donations of older residential lead paint or industrial paint (for example, from businesses or parent groups).

California’s Lead-Safe Schools Protection Act, passed in 1992, banned lead-based paint and other sources of lead contamination from all new and renovated school facilities built on or after January 1, 1993. It is for this reason that Title 17 identifies all paint on schools built or renovated before January 1, 1993 as “presumed lead-based paint.”

Exterior painted surfaces in newer schools tend to have about twice as much lead as interior surfaces. However, according to the DHS study, interior paint in schools built before 1960 had higher average lead levels than exterior wall paint. The paint on trim components such as window sashes, door jambs, and baseboards usually has significantly more lead than wall paint—up to five times as much for trim on exterior walls, and twice as much for trim on interior walls.

IMPORTANT! The year a school was built is the best indicator of whether or not lead paint will be found.

According to the DHS study, schools built before 1960, and especially before 1940, are most likely to have a hazardous combination—paint with a high lead content and paint in need of maintenance.

If a school complex was built in stages, the oldest buildings in the complex are of greatest concern, especially if very young children spend time there. If old buildings house pre-schools, kindergartens, or cafeterias used by children eight and under, the lead hazards there should be given special attention.

State Study Highlights—Lead Paint

The California DHS study revealed that:

In schools built before 1980:

◆ 100% had detectable levels of lead in paint. ◆ 45% had some deteriorated lead paint. In schools built in 1980 or after:

◆ 45% had detectable levels of lead in paint. ◆ 3% had some deteriorated lead paint.

When Does Lead Paint Become a Hazard?

If lead paint is in good condition and left intact, it is not likely to present a hazard. The problem can arise if the paint or underlying surface is in deteriorated condition, or if the paint is disturbed.

The possibility that lead paint will become hazardous is increased by:

◆ Aging and deterioration of paint—chipping, peeling, or cracking. Paint is also subject to “chalking” (formation of a fine powder on the paint surface that may contain high levels of lead).

◆ Weather effects on the exterior of buildings (sun or rain).

◆ Water damage or mildew inside buildings.

◆ Maintenance or repair activities that disturb paint.

◆ Children chewing on sills and other painted surfaces.

◆ Impact that disturbs paint, such as doors being slammed or walls hit.

◆ Friction that disturbs paint, such as windows opening and closing or doors scraping.

In short, lead paint is a hazard when it is in poor condition or when it is disturbed It is a special concern when it is accessible to children. These are the school buildings we should be most concerned about.

How Can Soil Get Contaminated With Lead?

Soil can become contaminated when chips or dust from lead paint fall from nearby buildings or play structures.

Lead often settles into nearby soil:

◆ When exterior lead paint is chipped during preparation for repainting.

◆ When exterior lead paint deteriorates over time from sun or rain.

◆ When lead dust is created by opening and closing painted windows or doors.

Lead may also be present in soil as a result of leaded gasoline emissions. Lead was a gasoline additive used to prevent engine knocking prior to the mid-1970s. Leaded gasoline has since been banned. Prior to the ban, an estimated 200,000 tons of lead were emitted in vehicle exhaust in the U.S. each year From the air it settled into soil throughout the country. As a result, in some urban areas, lead levels in soil are high enough to poison children. Industrial air emissions are another source of lead in soil. Over the years, lead from air emissions generated by industry has settled into the soil, particularly near lead smelters, battery plants, oil refineries, power plants, and waste facilities.

Schools are more likely to have lead in soil from gasoline and from industrial sources if they are located near:

◆ Freeways, where auto exhaust has settled for years.

◆ Industrial areas (or former industrial areas), where industrial pollution has settled for years.

In summary, lead can get into the soil near schools from paint chips or dust, from auto exhaust, and from industrial pollution. According to the DHS study, it is likely that a small but significant number of California’s public elementary schools have a soil problem. In 6% of the elementary schools DHS found lead levels above the U.S. Environmental Protection Agency (EPA) limit of 400 parts lead per million parts of soil (ppm). (The EPA limit applies to bare soil where children play.)

DHS found that contaminated soil is likely to be close to school buildings, and is most prevalent at schools built before 1940. However, if lead-safe work practices have not been followed over the years, newer schools may also have contaminated soil.

What Are the Steps in a Lead Inventory?

To identify, evaluate, and prioritize the lead hazards in schools throughout your district, follow these five steps:

1. Collect and Review District Records.

2. Visually Survey Paint and Soil at Target Schools. 3. Test Paint and Soil Where Appropriate.

4. Test Water at All Schools.

5. Set Priorities for Hazard Control.

Sample Lead Inventory Forms that can help in this process are provided in the Forms Section at the end of this Guide. Some of the individual forms are also displayed at relevant points throughout this chapter. You may decide to create your own forms to meet your school district’s particular needs.

Step 1. Collect and Review District Records.

Your lead-safe schools program manager should collect and review district-wide records showing the age and maintenance history of school buildings which house children eight and under. The object is to develop a list of

target schools where a more detailed on-site survey of paint and soil hazards

can be done.

Even if your district is small and lead hazards are known, it is a good idea to collect and record this information. It is a useful way to document how the district identifies and prioritizes lead problems, and to make sure that the most serious problems are addressed first. Some districts may want to keep this information in a computerized system.

First, identify the schools that house high risk children—grades K-2 and

younger children in pre-schools or childcare programs. Include high schools with teen parent programs that provide childcare. In other words, identify all school buildings with children eight and under. Don’t forget privately

operated before and after-school programs located on school grounds.

Second, determine the date that each of these schools was built. Some

schools were built in stages. Wings, or special purpose buildings such as gyms or libraries, may have been added on later. All buildings and additions constructed before January 1, 1993, by legal definition, have “presumed lead-based paint” unless tested and proven otherwise.

Third, classify schools by the number of buildings or structures: ◆ Built before 1960.

◆ Built between 1960 and 1979.

◆ Built between 1980 and January 1, 1993.

IMPORTANT! Target schools are those that have children eight and under and were built before January 1, 1993. The highest priority target schools are the oldest schools with the youngest children.

Other information to collect for each school may include:

◆ Painting records.

◆ A map of school buildings and grounds.

◆ Construction and renovation records.

◆ Information on previous use of school grounds and the surrounding area, including land acquisition records.

◆ Previous surveys or lead test results of paint, soil, or water.

This process should give you some idea whether any of the target schools are likely to have lead problems.

How Can You Use the District Target Schools Form?

To organize the information you collect, it is useful to have a special form, other written system, or computer database. A sample District Target

Schools Form is provided on the next page. It can give you a district-wide

overview to help determine which target schools are most likely to have lead problems and should be surveyed first.

There is a blank version of the form that you can copy in the Forms section at the end of this Guide. If you wish, you can modify the sample form to meet the needs of your district. Or you may want to develop your own form. On the sample form, use the first column to list all the schools you have identified as target schools. Use the second column to record the year each of those schools was built. Next make check marks (

✓

) indicating whether the school houses children in childcare and/or grades K–2.

Where information is available, fill out the Possible Hazards columns for paint and soil hazards. (This section is optional.) Check the Paint column if you have any information indicating there may be deteriorated paint (prior test results, painting records, inspection records, requests for painting, etc.). Check the Soil column if the school is likely to have lead-contaminated soil, based on the age of the buildings or proximity to freeways or former or current industrial areas.

Finally, give each target school a Priority ranking for a site survey. Base this on the age of the school and the number of check marks the school received on the form. This is just a guide to help you set priorities, so also draw upon your own knowledge in ranking each school. Consider using either a “High / Medium / Low” ranking or a numerical scale (1–5, with 1 being the top priority for inspection).

Once the form is complete, you should have a good idea of which target schools to survey first. Develop a schedule for getting the surveys done. Set time-specific goals, such as surveying all target schools within 2–3 months, and so on. Record your projected dates on a master calendar, tracking system, or computer scheduling program.

Also determine how long it would take the district to survey all elementary schools. Consider whether the district has the resources to survey middle schools and high schools as well.

Lead-Safe Schools Program

District Target Schools Form

School District ____XYZ Unified___________ Number of Schools in District ____7________ Completed By_____John Smith____________ Title ___M&O Manager__________________

Use this form to develop a priority list of schools to survey for deteriorated paint and possible lead contamination of soil.

◆ Target Schools are those that have children eight and under and were built before

1993. List all your target schools at the left.

◆ Check Possible Hazards (Paint, Soil) columns if you have information that there may be a problem. Otherwise skip this section.

◆ In the Priority column, rank schools high, medium, or low. High priority target schools should be surveyed first.

Total Number of Target Schools ______3________ Date Completed __5/10/99_____

Target School Name Children

Childcare K – 2 Possible Hazards Paint Soil Priority Year Built School A School B School C 1945 1990 1978

✔

✔

✔

✔

✔

✔

✔

High Medium Low

Step 2. Visually Survey Paint and Soil at Target Schools.

The next step is to visit your target schools and survey them. You should use survey forms to collect and record information in a systematic way. Start with the oldest schools with the youngest children, which you ranked as high priority in Step 1.

A survey consists of two elements—a visual inspection and a written report with a summary of findings. Visual inspections may be done by M&O department personnel who have had at least general lead awareness training. They should always be done under the direction and supervision of the district’s Lead-Safe Schools Program Manager or a state-certified Lead Inspector/Assessor.

Since the focus of this Guide is on routine maintenance tasks and not lead abatement tasks, it does not describe how to do a formal risk assessment or lead inspection. These must be done by a certified Lead Inspector/Assessor. In some situations, school surveys may uncover problems that indicate the need for a risk assessment and/or a lead paint inspection.

The purpose of your informal school surveys is to identify potential lead hazards, especially in classrooms, playgrounds, and other areas where the youngest children spend time. School surveys should include both visual inspections and conversations with school custodians, principals, and teachers.

Following are some suggestions for your survey:

◆ Ask teachers what rooms and play areas are used by children eight and under. Note the condition of paint in these areas (including painted furniture and toys). Ask custodians how often carpets are cleaned, and by what method. Look for paint dust on sills and floors.

◆ Ask custodians and other maintenance staff to identify any moisture problems inside or outside the school—leaks, mildew, etc.

◆ When surveying classrooms, open and close windows and doors a few times to see if this causes friction or impact that can disturb paint. HUD Guidelines suggest that the general building condition also be

surveyed. If the building has not been well maintained, then the paint is also more likely to be in poor condition.

Indicators of poor building maintenance include a roof that is missing parts, broken gutters or downspouts, walls with large cracks or holes, water stains on interior walls or ceilings, plaster walls that are deteriorating, and windows or doors that are broken or boarded up.

Paint—What Should You Look For?

Assess the condition of painted surfaces on both the interior and exterior of buildings. Look for chipped, flaking, peeling, cracking, nicked, or chalking paint. Also look for paint dust. Pay special attention to:

Interior

◆ Painted surfaces that have water damage.

◆ Paint that exposes a different color underneath.

◆ Paint chips or dust lying at the base of a wall, or on window troughs or sills.

◆ Painted surfaces that are subject to frequent impact or friction, such as windows, doors, and trim.

◆ Painted furniture and toys used by young children.

Exterior

◆ Paint that is weathering from sun, wind, or rain exposure.

◆ Paint that exposes a different color underneath.

◆ Paint chips or dust lying at the base of a wall.

◆ Painted surfaces subject to frequent impact or friction.

Soil—What Should You Look For?

Survey around the perimeter of buildings and throughout the school grounds for locations where lead may be present in soil. Consider the age of the school. The older the school, the more likely there will be lead in the soil. Also consider whether the school is near a freeway, industrial area, or former industrial area. And take into account that lead paint may have fallen to the ground during previous maintenance activities, contaminating the soil. Assume that soil is contaminated adjacent to buildings built before 1940, or test the soil. Note on your school map any exterior walls where paint is deteriorating and there is bare soil within five feet of the base of the wall. Make a note about the ground cover under all play structures and similar areas used by children eight and under. Note locations of gardens used by children. Ask the custodian or principal when sand in the sandbox was last replaced. Check with staff to learn more about the history of the school grounds, if possible.

How Can You Use the Paint and Soil Hazards Form?

When you do on-site surveys, start with the target schools you identified as high priority earlier. See the sample Building Inventory Form—Paint and

Soil Hazards on the next page, which can be used to record basic

information about possible lead hazards at each school building you survey. There is a blank version of the form that you can copy in the Forms section at the end of this Guide. If you wish, you can modify the sample form to meet the needs of your district. Or you may want to develop your own form. When you survey a school, start by making a list (on a separate sheet of paper) of all buildings in the complex where children eight and under spend time. Also record the year each building was built, and make any notes you think would be useful (about general condition of the building, past

problems, etc.). Your sheet may look like this: Building Year Built Notes

Building # 1 1955

Building # 2 1960 Exterior paint chipping reported.

Next, fill out a separate copy of the Building Inventory Form for each building. On the form, list each room and outdoor area you plan to survey. Be sure to include outdoor areas near the building if children spend time there. You may also want to use a school site map in conjunction with the form to mark the location of exterior walls with deteriorated paint and adjacent bare soil. In the Possible Hazard column, list all areas with lead-base