1. Program Description
2. Scope
3. Definitions
4. Responsibilities
5. Program Components
6. Reporting Requirements
7. Training Requirements and Competency Assessment
8. Information and External References

1. Program Description

The UCI Child Care Facility Lead Management Program is designed to identify, assess, and manage lead containing building components in UCI managed child care facilities in order to prevent and/or minimized potential lead exposure to occupants.

The regulatory agency requirements mentioned here are protocols for the performance of lead risk assessments and inspections. There are no state or federal regulations that require risk assessments or inspections to be performed on childcare facilities unless elevated blood lead levels have been found in a child using the facility. However, UCI EH&S deemed it in the best interest of the University and the children using the facilities to proactively assess potential lead hazards.

2. Scope

Applies to all UCI managed Child Care facilities.

3. Definitions

Abatement – Means any set of measures designed to reduce or eliminate lead hazards or lead-based paint for public and residential buildings, but does not include containment or cleaning.

Certified Inspector Assessor - A certified inspector assessor, in accordance with Title 17 CCR Division 1 Chapter 8 Lead-Based Paint and Lead Hazards part 35005, is defined as an individual who has received a certificate or an interim certificate from the Department of Health Services-Childhood Lead Poisoning Prevention Branch.

Child Occupied Facility - A child-occupied facility, in accordance with 40 CFR part 745 (I), (B), is defined as a building, or portion of a building constructed prior to 1978, visited by the same child, 6 years of age or under, on at least 2 different days within any week, provided that each day's visit lasts at least 3 hours, the combined weekly visits lasts at least 6 hours, and the combined annual visits last at least 60 hours. Child occupied facilities may include, but are not limited to, day-care centers, preschools, and kindergartens.

Lead-Based Paint – Paint or other surface coatings that contain an amount of lead equal to, or in excess of, one milligram per square centimeter (1.0 mg/cm 2 ) or more than half of one percent (0.5%) by weight.

Lead Hazard - 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.

Lead-Related Construction Work - Any construction, alteration, painting, demolition, salvage, renovation, repair, or maintenance of any residential or public building, including preparation and cleanup, that, by using or disturbing lead-containing material or soil, may result in significant exposure of adults or children to lead.

Paint Inspection - A Paint Inspection measures the concentration of lead in paint on a surface-by-surface basis. Inspection results enable the owner to manage all lead-based paint since the exact locations of the lead-based paint have been identified. They shall be performed by a certified inspector/assessor.

Because an inspection usually identifies only the presence of lead-based paint, it does not determine whether the paint presents an immediate hazard. Therefore, it is prudent to also conduct a risk assessment along with the paint inspection, so that a full determination of the location and nature of all lead-based paint hazards may be made.

A paint inspection is the preferred evaluation method when an owner has decided to abate all lead-based paint. Because abatement activities can be costly, it is usually cost effective to complete a paint inspection before using resources to abate assumed hazards. Inspections are also appropriate when extensive renovation that is about to occur will disturb painted surfaces.

Presumed Lead-Based Paint - Paint or surface coating affixed to a component in or on a structure, excluding paint or surface coating affixed to a component in or on a residential dwelling constructed on or after January 1, 1979, or a school constructed on or after January 1, 1993.

Risk Assessment - A Risk Assessment determines the presence or absence of potential lead hazards and suggests appropriate hazard control measures. Risk assessments not only identify lead-based paint but also lead-based paint hazards. They can be performed only by a certified inspector/assessor. Risk assessments go beyond assessing the condition of paint. Risk assessments take into account both resident and owner use patterns and management and maintenance practices that will affect the paint. Risk assessments also identify other potential sources of lead hazards, such as dust, soil and water. By considering all hazards and examining resident and owner practices, a risk assessor determines appropriate ways to control hazards and to modify management practices so that the chance of hazards recurring is reduced. To provide the necessary guidance, a risk assessment must cover the following:

• Identification of existence, nature, severity, source, and locations of potential lead hazards.
• Presentation of the various options for controlling lead hazards in the event that hazards are found, including interim controls, abatement measures, and any recommended changes to the management and maintenance systems.

4. Responsibilities

EH&S Lead Program Manager - Responsible to:

• Coordinate annual lead identification assessments and health hazard summary as well as follow-up actions to any identified lead hazards.
• Oversee lead contractors who conduct lead assessments and/or lead-related construction activities.
• Ensure any lead related regulatory notifications are performed.
• Notify occupants, facilities, and maintenance staff or affected personnel of known lead painted surfaces.
• Provide assessment and control report and lead assessment summary letter of all findings for each site to the Director of Child Care Services.
• Ensure lead contractors meet all regulatory training and certification requirements.
• Coordinate and oversee any lead-related construction work.

Child Care Facility Site Director - Responsible to:

• Coordinate access for the lead assessments and lead-related construction activities if necessary.
• Provide updates to EH&S when any facility building component has been altered and/or new equipment is acquired that will need to be assessed for potential lead content.
• Retain lead assessment summary results for their facility on site.
• Complete the course Hazard Communication for Trades, Building, Facilities & Custodial Workers. Register online at www.ted.uci.edu .

Child Care Services Director - Responsible to:

• Retain lead assessment summary results for all UCI childcare facilities.

5. Program Components

• Identification
• Paint Inspection - A Paint Inspection measures the concentration of lead in paint on a surface-by-surface basis. Inspection results enable the owner to manage all lead-based paint since the exact locations of the lead-based paint have been identified. They shall be performed by a certified inspector/assessor.

Because an inspection usually identifies only the presence of lead-based paint, it does not determine whether the paint presents an immediate hazard. Therefore, it is prudent to also conduct a risk assessment along with the paint inspection so that a full determination of the location and nature of all lead-based paint hazards may be made.

A paint inspection is the preferred evaluation method when an owner has decided to abate all lead-based paint. Because abatement activities can be costly, it is usually cost effective to complete a paint inspection before using resources to abate assumed hazards. Inspections are also appropriate when extensive renovation that is about to occur will disturb painted surfaces.

Paint Identification - Two methods are commonly used to identify the presence of lead based paint:

1. To test for lead based paint.

Methods used to identify lead based paint include x-ray fluorescence (XRF) and/or bulk sampling.

2. Presume lead paint is present in building components.

Presume - Excludes paint or surface coating affixed to a component in or on a residential dwelling constructed on or after January 1, 1979, or a school constructed on or after January 1, 1993.

•  Risk Assessment

A Risk Assessment determines the presence or absence of potential lead hazards and suggests appropriate hazard control measures. It identifies lead-based paint hazards. It also takes into account both resident and owner use patterns and management and maintenance practices that will affect the paint. The risk assessment also identifies other potential sources of lead hazards, such as dust, soil and water. By considering all hazards and examining resident and owner practices, a risk assessor determines appropriate ways to control hazards and to modify management practices so that the chance of hazards recurring is reduced. A risk assessment must be performed by a certified inspector/assessor. It must include the following:

1. Identification of existence, nature, severity, source, and locations of potential lead hazards. Identification includes:

• Soil sampling,
• Dust wipe sampling,
• Analysis of deteriorated paint, and
• If applicable, water sampling.

2. Presentation of the various options for controlling lead hazards in the event that hazards are found, including interim controls, abatement measures, and any recommended changes to the management and maintenance systems.

•  Management

• Lead Database – Utilize a record management system that houses all paint inspection survey results, including methods such as XRF and bulk sampling, date and location identified.
• Maintenance - Maintain identified lead based paint in place that includes periodic visual inspection of painted surfaces.
• Abatement – Removal of lead based paint by qualified personnel.
• Project management – Coordinate abatement activities including contractor selection and oversight.

•  Training – see section 7.

• Notification - Notify occupants, facilities, and maintenance staff or affected personnel of known lead painted surfaces.

6. Reporting Requirements

Department of Health Services, Lead Hazard Evaluation Report form, DHS form 8552.

Summary letter to UCI Director of Child Care Services

7. Training Requirements and Competency Assessment

Trades, Building, Facilities & Custodial Workers must complete the course Hazard Communication for Hazard Communication for Trades, Building, Facilities & Custodial Workers. Register online at www.ted.uci.edu .

8. Information and External References

Lead Regulations- Title 8 CCR 1532.1; Title 29 CFR 1910.1025; Title 29 CFR 1926.62, 40 CFR part 745 (I), (B), Title 17 CCR Division 1 Chapter 8 Lead-Based Paint and Lead Hazards

INITIATOR: Susan Robb
DATE: 10/05