H 10.003 lead paint
Rev 03 [Jan 09]
Designing to reduce the hazards associated with lead in paint
Introduction
1. Designers can play a major part in making it easier to manage old, lead based paint (LBP)
2. Lead-containing pigments were widely used in oil-based domestic and industrial paints until the 1960s and were added in substantial amounts. A few minor uses continued until the 1980s.
3. Lead can seriously damage human health, whether ingested or inhaled, and its use in modern paints is banned.
4. To deal with situations where lead is present, it has its own set of regulations - the Control of Lead at Work Regulations 2002 or "CLAW" *. (*Note: Lead is not included in the COSHH reference EH40 for this very reason, but must still be fully considered.)
5. High exposures to lead dust and fumes can occur in the construction industry during renovation, refurbishment and demolition, if proper precautions are not followed.
6. This guidance note assumes that designers are not specifying lead-based paints. Instead, it provides information on where lead paint may be found on existing sites, as a result of its specification in the past, when its use was not prohibited. This issue is emerging as a hidden health hazard in refurbishment projects mainly because those people who have been exposed to lead at levels sufficient to cause them symptoms have presented to GP surgeries or hospital departments and not been recorded under the HSE reporting requirements of CLAW.
Risks associated with lead based paint
7. Lead can seriously damage human health with symptoms including everything from headaches and nausea to kidney, nerve and brain damage. Diminished fertility and erectile dysfunction are also known symptoms. A developing unborn child is at particular risk from exposure to lead, which could result in still birth. The risk of developing any of these conditions depends on the degree and frequency of exposure. All exposure should, therefore, be reduced to the lowest level reasonably practicable. Although lead can be discharged naturally from the body over time it is a cumulative poison and its adverse effects can cause permanent, irreversible damage – especially in children, even at the lowest levels.
What designers should do
8. The list in 22 illustrates the extent to which lead-based paint was used. Strict controls relating to the marketing and use of lead paint have been in place since 1992. Designers should be aware that when designing for works on or in any building or structure built before 1970 recommended best practice is to commission a lead paint survey. It is not unusual to find lead paint on some of the surfaces in mid-1980s buildings.
9. Designers as well as contractors, working on demolition, renovation or refurbishment contracts will both need information about the location of lead paint because it can affect the way the project proceeds due to the hazardous nature of lead dust and lead fumes. Clients have a statutory duty to provide such information. Lead-based paint is a significant hazard when damaged or disturbed. Therefore, clients should be advised that the location of any lead- painted surfaces should be established prior to any work on the fabric of the building. This is particularly important when work is to be carried out adjacent to unprotected third parties.
10. While the safe handling of lead-based paint on site remains a contractor’s responsibility, designers should ensure that they contribute to making the hazard safe by:
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a) Informing clients about the importance of carrying out a lead paint survey; and
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b) Alerting contractors to its presence; its likely categorisation as hazardous waste for site waste management planning purposes; and the need for medical surveillance.
11. The best way to eliminate the risks associated with lead-based paint is to leave it undisturbed, if it is possible to do so. For example:
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a) If the paintwork is in good condition, seal it in with an overcoating of modern paint or
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b) Panel over or apply a wallpaper covering.
But in doing so:
12. To help a contractor to plan the work, designers should supply the contractor with at least the following information:
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a) Any lead paint survey reports (received from the duty holder) – see 20;
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b) A physical description of the work area, eg:
Number of windows and doors
Number of other ventilation points
Number of penetrations, eg for pipes, ducts and other services, lift shafts etc, in the fabric of the work area.
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a) Approximate areas, and their lead concentrations, of LBP to be distrubed. (This should be carried out by a specialist lead paint removal contractor);
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b) The physical state of the LBP, eg is it badly degraded (friable to touch, which means that it can become airborne easily) or completely intact.
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c) A schedule for turning off ventilation systems if they have to be left active while the work is ongoing;
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d) Location of the nearest licensed dump (if known).
13. Generally, designers have two situations to consider:
Where LBP is to be retained
14. When the Lead Paint Survey report indicates that LBP surfaces are in a degenerated state, discuss their retention carefully with an expert before making a decision about removal.
15. Where LBP surfaces are to be retained, designers should follow the recommendations in 10.
16. Designs, which would require operations to be carried out close to LBP surfaces and are likely to increase the chances of an (accidental) impact with such surfaces, should be reconsidered where it is possible to do so.
17. In addition, designers should not require processes to be used which are aggressive and likely to cause the LBP or its protective barrier to dust, break, disintegrate or crumble, allowing it to become airborne or produce fumes. Operations, which could be classed as aggressive include any form of:
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a) Cutting
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b) Sanding
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c) Hammering
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d) Drilling or
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e) Burning
18. Where existing protective coatings are degraded or otherwise damaged, a new and effective protective barrier should be specified*. The project should be designed, as far as it is possible to do so, to allow this remedial work to take place at the earliest opportunity. In addition, the location of LBP surfaces should be recorded and included in the Health and Safety Plan and File. (*Waterborne coatings do not adhere well to poorly prepared LBP surfaces and may fail prematurely, creating a source of further exposure).
Where LBP is to be removed
19. Where LBP is to be removed, designers should follow the recommendations in 10.
20. In addition, any restrictions that apply to the site should be transmitted to the Contractor, eg restrictions on transportation routes.
21. To prevent the spread of LBP dust, contractors should be informed about any ventilation systems that cannot be shut off.
Background on lead based paints
22. Until the 1960s lead-based paint (LBP) containing lead pigments, such as white lead, were widely used in oil-based domestic and industrial paints. It was added in substantial amounts. It can be found in the following:
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a) Domestic paints for windows, doors and interior woodwork.
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b) Exterior woodwork.
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c) Protective paints for iron and galvanized metalwork, including: radiators, railings and structural steelwork.
Note: this list is not exhaustive. It is intended as a general guide to illustrate where lead-based paint may have been used.
23. The Control of Lead at Work Regulations 2002 (as amended) place a duty on employers not to carry out work liable to expose any employees to lead, or a substance or material containing it (such as lead-based paint) without fulfilling certain requirements. They also place a like duty on an employer, so far as reasonably practicable, in respect of any other person, whether at work or not, who may be affected by such work. This may include, but is not limited to:
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a) other workers, including those employed by another employer, not engaged on work with lead, such as maintenance staff, cleaners etc.
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b) visitors to the worksite;
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c) users of the structure who may be exposed to residual dust or, if not properly segregated from the work, to fumes and dust generated during work with lead based paint
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d) families of those who are exposed to lead at work and who may be affected by lead carried home unintentionally on clothing and footwear.
Recognising competent lead survey reports
24. Competent lead-based paint survey reports should contain all the information in 10 c) and d). In addition, they should indicate:
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a) The exact location of any LBP surfaces;
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b) The lead content of those surfaces
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c) Any areas that could not be accessed for surveying.
Lead based paint: the future
25. The position and condition of LBP must be recorded and a management plan put in place to manage it safely. This information must be made available to anyone who may need to know, such as the occupants (especially if this includes children), contractors, maintenance staff or any others who may need to work on the building structure.
26. Modern technology can facilitate LBP compliance for surveys and remediation:
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a) Portable XRF-i (X-Ray Fluorescence - isotope) for in-situ, non-destructive analysis is the most cost-effective option for comprehensive project screening.
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b) Low-heat, infrared (IR) paint removal avoids the production of toxic fumes or dust, both of which are hazardous.
27. Appropriate in-place management can provide satisfactory control of lead exposure risks where LBP surfaces are to be retained. These will include regular vacuum cleaning with HEPA-filtered equipment and wet mopping or wiping down, of all dust-holding surfaces, with lead-specific cleaning materials. Periodic sampling of residual surface contamination can provide a quantitative assessment of the effectiveness of such measures.
Useful references
http://www.LiPSA.org.uk Lead in Paint Safety Association
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Lead Paint
