Lead Management Program
The Dartmouth College Lead Management Program (Program) aims to safeguard the well-being of all students, faculty, and staff at Dartmouth College (Dartmouth). The Dartmouth Environmental, Health, and Safety (EHS) department has established this Program to inform students, faculty, staff, stakeholders, and contractors about the standardized, systematic procedure for preventing exposure to hazardous lead concentrations. This Program applies to all students, faculty, staff, stakeholders, and contractors involved in or potentially impacted by activities that disturb lead-containing materials.
About the Program
This program provides a framework for identifying, evaluating, and controlling lead exposure hazards across campus operations, maintenance, renovation, and construction activities to protect employees, occupants, and the surrounding community.
Key Regulatory Components:
- Occupational Safety and Health Administration (OSHA) Lead Standards (General Industry and Construction): Sets exposure limits and requires monitoring, engineering controls, work practices, personal protective equipment (PPE), and medical surveillance. All work activities must be evaluated and controlled in accordance with the applicable standard.
- Appendix A – Lead Work Practices: Provides detailed procedures for operations and maintenance involving lead-based paint, adapted from the National Institute of Building Sciences manual. Practices are organized into three tiers based on dust-generation potential, with increasing controls for containment, worker protection, and cleaning.
- Environmental Protection Agency (EPA) Renovation, Repair, and Painting (RRP) Rule: Applies to activities disturbing lead-based paint in pre-1978 housing and child-occupied facilities. Requires EPA-certified firms and renovators using lead-safe work practices. On campus, this may include student housing, childcare facilities, historic structures, and other pre-1978 buildings.
- New Hampshire Lead Paint Poisoning Prevention and Control Statute: Governs reporting of elevated blood lead levels, investigations, inspections, corrective actions, contractor licensing, occupant notification, and compliance for sale/rental/conversion of pre-1978 properties. Particularly relevant for older Dartmouth buildings, student housing, and childcare facilities.
Key goals of this Program:
- Lead hazards are proactively identified and managed
- Regulatory requirements are consistently met across all applicable standards
- Certified personnel and approved work practices are utilized
- Implement protective measures, including engineering controls, personal protective equipment (PPE), hygiene practices (such as access to washing facilities), and proper housekeeping.
- Limit worker exposure below the OSHA permissible exposure limit (PEL) of 50 micrograms of lead per cubic meter of air (50 μg/m³) averaged over an 8-hour workday.
- Provide training and education about the dangers of lead and how to protect oneself.
Monitor workplace air and conduct medical surveillance (like blood lead level testing) for at-risk employees.