LEAD PAINT MANAGEMENT WORK PROCEDURES

 

WORK PROCEDURE:

Identification

 

• If property was constructed prior to 1970 - assume all painted surfaces contain lead and complete paint sample testing in accordance to
  

 

Refer To: Work Procedure 2: Paint Sampling Prior to Painting

• If property was constructed after 1970 - allow to perform lead tests on surfaces that will be required to be sanded or stripped. Complete Stick Test in Accordance with Work Procedure 1 - Determination of a Lead Based Paint Job. If stick test is positive, the Company representative will complete paint sample testing in accordance with Work Procedure 2: Paint Sampling Prior to Painting; AND
  
• Document results and send to WHS&E Officer so Lead Paint Register may be updated.
  

  
   

Determine Scope of Work

The Company Representative shall determine the scope of work:

• Determine whether the paint surface is suitable for encapsulation (i.e. painting over the paint surface) or whether the paint surface will require removal to facilitate painting in accordance with AS/NZS 2311: 2000;
  
• Individual walls will be treated separately according to the soundness of the existing coatings
  
• Document results of inspection and decision to repaint or remove paint layers prior to painting.
  
  

 

Results of Test

• If there is no lead paint present, proceed in accordance with a Specification for General Maintenance to Residences - External Painting Services, OR
  
• If the job is a Lead Based Paint Job and requires surface preparation of any kind (including washing down surface only), to facilitate painting, all work shall be done in accordance with:
  

  
   

  Refer To: Work Procedure 2: Paint Sampling Prior to Painting, AND
  

  Refer To: Work Procedure 3: Soil and Dust Sampling Prior to Painting, AND
  

  Refer To: Work Procedure 4: Site Management for Lead Based Painting – Exterior, AND/OR
  

  Refer To: Work Procedure 5: Site Management for Lead Based Painting – Interior, AND
  

  Refer To: Work Procedure 6: Completion and Testing of the Lead Based Paint Job, AND
  

  Refer To: Work Procedure 7: General Waste Management Procedures for Painting, OR
  

  Refer To: Work Procedure 8: Site Management for Lead Based Painting - Wall Wash Down Only
  

(See Appendix 1)

 

Notify the tradespersons:

• That the job is a lead based paint job and that their quote must allow for costings to address all Company's parameters in relation to lead based paint including taking paint and soil samples, AND
  
  
• That the tradesperson is a "Certified Lead Paint Contractor", OR
  
• That the work procedures (through a site specific work plan) reflect the current standard procedures to manage a lead based paint job.
  
• Keep owner and occupier of the premises informed of all times throughout the painting job;
  
• Document results of inspection on the job file;
  

  
   

Sampling

• Conduct paint sampling prior to the commencement of the job in accordance with Work Procedure 2: Paint Sampling Prior to Painting, AND
  
• Conduct soil and dust sampling prior to the commencement of the job in accordance with Work Procedure 3: Soil and Dust Sampling Prior to Painting, AND
  
• Proceed in accordance with the Specification for Minor Works and General Maintenance to Residences - External Painting Services
  

 

Removal

• Barricades and appropriate lead based paint signage will be erected at an appropriate distance (at least 3metres) from the immediate work areas whilst the lead based paint is being removed to prevent persons from entering the sites and to ensure all persons near the sites are protected;
  
• In high risk areas (e.g. schools or housing), children are not to be exposed to the hazards associated with lead based paint work by appropriate containment of the work site and/or working out of hours;
  
• Work procedure for carrying out the Wall Wash Down procedure for a lead based paint job of the premises shall be in accordance with Work Procedure 8: Site Management for Lead Based Painting - Wall Wash Down Only
  
• Work procedure for removal of lead based paint on the exterior of the premises shall be in accordance with Work Procedure 4: Site Management for Lead Based Painting – Exterior
  
  
• Work procedure for removal of lead based paint on the interior of the premises shall be in accordance with Work Procedure 5: Site Management for Lead Based Painting - Interior
  
  

  
   

Testing and Inspection Process

• Clean – up on completion of a lead paint job in accordance with Work Procedure 6: Completion and Testing of the Lead Based Paint Job, AND
  

  
   

• Work Procedure 7: General Waste Management Procedures for Painting
  
• Inspect work and take soil samples (within 4 weeks) in accordance with Work Procedure 6: Completion and Testing of the Lead Based Paint Job;
  
• If the laboratory results of the final soil samples tested reveal lead contamination on site contact Safety Professional.;
  
• Job is completed when the soil samples are tested at a lead level in the soil at or below <300 mg/Kg.
  
• Document results and record on the job file and send a copy to the WHS&E Officer so the lead paint register may be updated.
  

  
   

APPENDIX 1 - Environmental Paint Management Work Procedures

 

Work Procedure 1:

Determination of a Lead Based Paint Job

 

1. Determination of a Lead Based Paint Job
   

   
    

Appropriate personal protective equipment (PPE) eg. gloves should be worn for this procedure.

The Project Coordination Representative for the job site will:

 

• Use a lead stick test kit (2 tests per pack) to test if the type of paint on the structure is lead based. Areas to be tested shall be soffit, window frames and sills, handrail areas and walls (especially if they are powdering).
  
• Scratch back test sample points to bare wood at the sample point exposing all the layers of paint.
  
• Wipe the stick over all exposed layers of paint.
  
• Determine if the lead stick test chemical changes to a red colour, then the presences of lead is confirmed - the job is suspected of being a Lead Paint Job;
  
• Determine if the lead stick test chemical does not change to a red colour, then the presences of lead is not confirmed - the job is not a Lead Paint Job;
  
• Document results and send to WHS&E Officer so Lead Paint Register may be updated
  
• As soon as lead is confirmed, the Project Coordination representative shall immediately contact the Housing Area Office Representative and advise that the work involves lead based paint.
  

 

Work Procedure 2:

Paint Sampling Prior to Painting

• If the paint job has been determined as a lead based paint job, the following procedures must be followed by the tradespersons, in the presence of a Company Representative, prior to the commencement of the job.
  
• Appropriate personal protective equipment (PPE) eg. gloves / dust mask should be worn for this procedure.
  

 

Taking Paint Samples for laboratory testing:

• Top layers of possible non-lead paint need to be removed to expose the old base paint that needs to be tested to achieve an accurate quantitative reading.
  
• A good amount of sample paint (about a tablespoon) shall be taken from each sample point and must include the base paint back to the timber.
  
• This sample shall be placed in a laboratory sample bag, labelled e.g. Sample No. 1 Paint from front window sill and each sample must be recorded on a sample register kept with the job documentation. DO NOT COMPOSITE SAMPLES.
  
• A laboratory request form (including Company work order, name and place to be recorded) and a chain of custody form signed by the tradesperson, the courier and the laboratory (on receipt of the sample) shall be filled out when the sample is sent for testing. (Approximate costs are $16 /sample).
  
• Document results on job file and send a copy of the results to the Environmental Officer so a Register may be updated.
  

 

 

Work Procedure 3:

Soil and Dust Sampling Prior to Painting

• If the paint job has been determined as a lead based paint job, the following procedures must be followed by the tradespersons, in the presence of a Company Representative, prior to the commencement of the job.
  
• Appropriate personal protective equipment (PPE) e.g. gloves / dust mask should be worn for this procedure.
  

 

Soil and Dust Sampling

• Soil and dust sampling should occur before and after a job to advise the owner as to whether contamination already exists and to establish that lead contamination existed prior to the work being carried out - and did not result from the actions of the current painter. If the lead levels in the post samples of the soil increase, it is possible that contamination has taken place during the work. The owner and occupier of the premises should be kept informed.
  

 

Soil Sampling

• A minimum of 4 samples shall be collected from around the perimeter of the building as detailed below. One sample in every 15-20 linear metres shall be taken in each sampling area. The samples should be collected from the centre of the sample area, within 300mm from the face of the wall, since most contamination results from rainwater run off or from previous sanding activities.
  

 

 

 

• Sampling locations to be repeated on each side of the building. (One sample every 15-20 Metres)
  
• Samples taken to a depth of 100mm by a core sampler or hand spade from sample locations (in each sampling area on each side of the building)
  
• Each sample shall be placed in a sealed polythene bag and labelled (e.g. Sample No. 1 Soil from northern wall of house)
  
• Each sample must be recorded on a sample register and kept with the job documentation. When tested, each sample will be tested as a single sample by the laboratory.
  
• Each pre-job soil sample is to be stored in a labelled laboratory sample container, not tested, and sent to the Company's Supervisor. (Supervisor will retain samples until job is completed in case the site is contaminated and these initial samples are needed for testing).
  

 

 

Dust Sampling

• Dust samples can be taken from anywhere but usually the dust will accumulate in corners or on ledges etc. At least one composite sample from each building face should be collected.
  
• This sample shall be placed in a laboratory sample bag, labelled (e.g. Sample No. 2 Dust from front window sill), and each sample must be recorded on a sample register and kept with the job documentation.
  
• Each pre-job dust sample is to be stored in a laboratory sample container, not tested, and sent to the Company's Supervisor (Supervisor will retain samples until job is completed in case the site is contaminated and the samples are needed for testing).
  

 

Work Procedure 4:

Site Management for Lead Based Painting - Exterior

• If the paint job has been determined as a lead based paint job, the following procedures must be followed by the tradespersons.
  
• Appropriate personal protective equipment (PPE) should be worn for this procedure.
  

 

Exterior Site Management for Lead Based Painting

In carrying out physical removal of the external lead based paint job, the following procedures shall be implemented:

• Barricades and appropriate lead based paint signage will be erected at an appropriate distance (at least 3metres) from the immediate work areas whilst the lead based paint is being removed to prevent persons from entering the sites and to ensure all persons near the sites are protected;
  
• In high risk areas (e.g. schools or housing), children are not to be exposed to the hazards associated with lead based paint work by appropriate containment of the work site and/or working out of hours;
  
• All windows shall be taped to prevent dust entering the building
  
• Plastic disposable tarps shall be placed against the walls and a second tarp shall be draped from the edge of the awning to the ground, encapsulating the working face
  
• Appropriate PPE will be used at all times while carrying out the lead based paint job
  
• Removal of old paint from the building shall only occur when the air is still
  
• Removal techniques include wet stripping or wet sanding, chemical stripping, or dry sanding with HEPA filters only
  
• Collect contaminated water from wet processes
  
• All surfaces are to be wiped down and vacuumed and the work area cleaned to remove all potential airborne particles at the conclusion of every work day and at the end of the job
  
• At the conclusion of the job, all plastic tarps will be disposed of appropriately through a Licensed Waste Contractor.
  

 

 

Work Procedure 5:

Site Management for Lead Based Painting - Interior

• If the paint job has been determined as a lead based paint job, the following procedures must be followed by the tradespersons.
  
• Appropriate personal protective equipment (PPE) should be worn for this procedure.
  

 

Interior Site Management for Lead Based Painting

In carrying out physical removal of an internal lead based paint job, the following procedures shall be implemented:

• Barricades and appropriate lead based paint signage will be erected at an appropriate distance (at least 3metres) from the immediate work areas whilst the lead based paint is being removed to prevent persons from entering the sites and to ensure all persons near the sites are protected;
  
• In high risk areas (e.g. schools or housing), children are not to be exposed to the hazards associated with lead based paint work by appropriate containment of the work site and/or working out of hours;
  
• Remove all furniture from room
  
• Remove soft furnishings, curtains and unattached carpets and rugs. Permanent carpets must be securely tarped and sealed to prevent dust and water from wet processes entering the carpets.
  
• Cover any furnishings which can not be removed with plastic and seal
  
• Remove food and medicines
  
• Install plastic drop sheets over floor surface, sealing joins and edges with heavy duty tape
  
• Seal windows, doors, vents, air ducts etc. with tape to seal the room
  
• Paint removal techniques include wet stripping or wet sanding, chemical stripping, or dry sanding with HEPA filters only
  
• Collect contaminated water from wet processes
  
• To minimise the airborne lead dust in the building, seal the work area in the room with a containment system (plastic drop sheets to encapsulate the work area on a wall of the room etc.)
  
• Remove dust regularly, vacuuming with a HEPA equipped filter and wet mop plastic floor sheeting
  
• Wet wipe all treated surfaces and dispose of cloth. Wipe all horizontal surfaces and dispose of cloth with paint debris
  
• Thoroughly clean any contaminated soft furnishings and replace
  

 

Work Procedure 6:

Completion and Testing of the Lead Based Paint Job

• If the paint job has been determined as a lead based paint job, the following procedures must be followed at the completion of the job, by the tradespersons, in the presence of a Company Representative.
  
• Appropriate personal protective equipment (PPE) e.g. gloves / dust mask should be worn for this procedure.
  

 

Clean – up on completion of a lead based paint job

• At the conclusion of the paint job, the site shall be cleaned up including removal of all debris, spills and physical collection of all visible chips of paints. All waste shall be placed in plastic bags, sealed and disposed of to a Licensed Waste Contractor.
  
• Clearance Testing at the conclusion of the job
  

 

Within 4 weeks, the operator shall:

 

• At the conclusion of the job, in the presence of Company Representative, a minimum of 4 soil samples from around the perimeter of a building shall be taken (as per the soil sampling methodology in Work Procedure 3).
  
• Samples taken to a depth of 100mm by a core sampler or hand spade from sample locations (in each sampling area on each side of the building),
  
• Each sample shall be placed in a separate sealed polythene bag and labelled (e.g. Sample No. 3 Soil from northern wall of house).
  
• Each sample must be recorded on a sample register kept with the job file documentation.
  
• A laboratory request form (including Company work order, name and place to be recorded) and a chain of custody form signed by the tradesperson, the courier and the laboratory (on receipt of the sample) shall be filled out when the sample is sent for testing.
  
• Each sample will be tested as a single sample by the laboratory.
  
• If the lead levels in the soil samples tested at the conclusion of the job are elevated above >300 mg/Kg, the initial samples will be tested and the results used as a reference baseline value to check operator work procedures and to determine clean up methodology (if applicable). If site is contaminated, consult the Company Supervisor for site-specific clean-up methodology.
  
• Job is completed when the samples are tested at a lead level at or below <300 mg/Kg. File all records on job file.
  
• Document results and send to WHS&E Officer so Lead Paint Register may be updated.
  

 

NOTE:
No dust should be available to sample at the completion of the job as the site will have been vacuumed as part of the clean up process.

Work Procedure 7:

General Waste Management Procedures for Painting

Solvent Management – Management of contaminated solvents

• Clean (uncontaminated) Mineral Turpentine
  
• Clean (uncontaminated) Mineral Turpentine will be retained for reuse.
  
• Mineral Turpentine contaminated with enamel paint will be disposed of by one of the following means:
  
• By allowing the contaminated Turps to stand, the residue will sink to the bottom, after which, the clean turps (in the top layer in the container) can be drained off and reused, while the contaminated bottom layer will be allowed to stand unsealed until dry and disposed of (with it's container) – off site.
  
• Removal from site to a recognised trade waste treatment plant.
  
• Clean (uncontaminated) thinners
  
• Clean (uncontaminated) thinners will be retained for re-use.
  
• Thinners contaminated with paint
  
• Thinners contaminated with paint shall be treated in the same ways as contaminated turps.
  
• Solvent Management - Management of contaminated wash water
  
• Clean (uncontaminated) water
  
• Clean (uncontaminated) water will be retained for reuse, or disposed of to normal drainage or to natural ground away from the works
  
• Water contaminated with water based paints
  
• Water contaminated with water based paints will be disposed of by one of the following means:
  
• Where the total volume is small and the site conditions allow, the contaminated water may be disposed of by pouring it on to natural ground where the waste water cannot discharge into a drain or watercourse.
  
• By the addition of a flocculating agent in accordance with the manufacturers instructions, after which the clean water may be disposed of to drainage or natural ground and the settled residue will be allowed to dry and be disposed of (with it's container) – off site.
  
• Removal from site to a recognised trade waste treatment plant.
  

 

Disposal of Excess Paints and Containers

• Excess Paints - Water Based Paints (Acrylics and PVA's)
  

1. Excess paint can be collected in a sealed commercial drum with a tap. As required, the paint can be REUSED as an undercoat etc. or disposed of in accordance with Company procedures.
   
2. If waste paint is <5% of the total volume of the original paint can, then it can be evaporated off and disposed to landfill as a solid (as the quantity is insignificant).
   

 

• Excess Paints - Oil Based Paints (Enamels and Varnishes)
  

1. Excess paint can be collected in a sealed commercial drum with a tap. As required, the paint can be REUSED as an undercoat etc. or disposed of in accordance with Company procedures.
   
2. If waste paint is <5% of the total volume of the original paint can, then it can be evaporated off and disposed to landfill as a solid (as the quantity is insignificant).
   

 

• Excess Paints - Epoxy Based Paints and Coatings
  

1. Part A and Part B, if not mixed, will be used as required with no excess resulting;
   
2. The hardened mixed solid can be disposed of at landfill.
   

 

• Excess Paints - Zinc and Lead Based Paints (Kill Rust/White Knight)
  

1. Excess paint can be collected in a sealed commercial drum with a tap and disposed of in accordance with Company procedures.
   
2. If waste paint is <5% of the total volume of the original paint can, then it can be evaporated off and disposed as a Regulated Waste to a Licensed Waste Contractor.
   

 

• Containers
  

  Excess paints, of any type, will not be disposed of on-site. Empty drained cans must be brushed out and then wiped out with a rag. This rag and can are allowed to dry and are then placed into a skip bin at the depot for disposal to a disposal facility as designated by the Company.
  

Equipment Clean – up

Water Based Paints (Acrylics and PVA's)

The cleaning of brushes, rollers, spray equipment, etc. that have been used with water-based paints will be carried out using the two-container method.

1. Any excess paint should be initially removed with newspaper or rags.
   
2. Two containers of clean water are then prepared.
   
3. The first container shall be used for the substantial removal of paint to a point where the equipment is no more contaminated than the water.
   
4. The equipment will then be transferred to the second container for a final clean.
   
5. The wastewater resulting from this process shall then be disposed of as described under – SOLVENT MANAGEMENT.
   

   
    

N.B.

Equipment contaminated by water-based paints shall not be cleaned under a tap or where sullied water can escape. If equipment requires more thorough cleaning that the two-container method allows, this activity will be carried out off-site or where trade waste treatment facilities are available.

 

Oil Based Paints (Enamels and Varnishes) / Epoxy Based Paints and Coatings

• Any excess paint should be initially removed with newspaper or rags.
  
• Two containers of clean solvent are then prepared.
  
• The first container shall be used for the substantial removal of paint to a point where the equipment is no more contaminated than the solvent.
  
• The equipment will then be transferred to the second container for a second clean. This process is repeated with successive containers having progressively lower levels of contamination, until a final rinse is appropriate.
  
• The equipment will then be transferred to the final container for a final clean.
  
• The solvent resulting from this process shall then be disposed of as described under – SOLVENT MANAGEMENT.
  

 

N.B.

• Further cleaning shall be carried out off-site.
  
• Rags, newspapers, etc. used for cleaning purposes may be disposed of in a site bin where that use complies with the builder's environmental work plan. Otherwise rags, newspapers, etc. used for cleaning shall be removed from site.
  

Work Procedure 8:

Site Management for Lead Based Painting Wall Wash Down Only

If the paint job has been determined as a lead based paint job, the following procedures must be followed by the tradespersons when the scope of work is deemed to be a sugar soap wash down and hand wet sand.

 

Appropriate personal protective equipment (PPE) should be worn for this procedure.

1. Site Management for Lead Based Painting - Wall Wash Down

In carrying out the Wall Wash Down
procedure for a lead based paint job, the following procedures shall be implemented:

• Barricades and appropriate lead based paint signage will be erected at an appropriate distance (at least 3metres) from the immediate work areas whilst the lead based paint is being removed to prevent persons from entering the sites and to ensure all persons near the sites are protected;
  
• In high risk areas (e.g. schools or housing), children are not to be exposed to the hazards associated with lead based paint work by appropriate containment of the work site and/or working out of hours;
  
• All windows shall be taped to prevent dust entering the building
  
• Plastic disposable tarps shall be placed on the ground/floor against the walls out at least 1metre from the work face to trap the contaminated wastewater from the activity
  
• Appropriate PPE will be used at all times while carrying out the lead based paint job
  
• Removal of old paint from the building shall only occur when the air is still
  
• Removal techniques include wall wash down and wet hand sanding only
  
• Collect contaminated water from wet processes
  
• All surfaces are to be wiped down and vacuumed and the work area cleaned to remove all potential airborne particles at the conclusion of every work day and at the end of the job
  
• At the conclusion of the job, all plastic tarps will be disposed of appropriately through a Licensed Waste Contractor.