Lead Based Paint Management

Lafayette’s Lead-Based Paint Management Program was developed to protect the college community from exposure to lead hazards, through the application of administrative and engineering controls.

This policy establishes the responsibilities of College staff to ensure that lead-based paint (LBP) is properly identified and managed in accordance with applicable regulations. Contractors are also expected to comply with these regulations and procedures.


Lead is a naturally occurring, highly toxic soft metal that was added to paint to make it last longer, resist moisture, speed drying and adhere to surfaces better. Lead was a common component in paints until 1978 when it was banned for residential use due to health concerns.

All building surfaces painted before 1978 shall be assumed to contain lead-based paint, even if only a single layer of many contains lead. In 2011, inspection of surface coatings was conducted in all Lafayette College owned property constructed prior to 1980. The inspection was conducted by SSM Group, Inc., in accordance with the U.S. Department of Housing and Urban Development (HUD) “Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing”. The corresponding reports and LBP inventory is maintained by Environmental, Health & Safety.

The presence of LBP in a building does not mean that the health of the occupants is endangered. When left undisturbed and in good condition, LBP does not pose a health threat.

regulatory requirements

Lead is regulated by the following government agencies:

Roles and REsponsibilities

Environmental, Health & Safety will maintain the college’s Lead Management Plan and:

  • perform air monitoring of at-risk employees as requested by project managers, supervisors or employees;
  • maintain the College’s LBP surveys of residence halls, target housing or other facilities;
  • keep all records relating to lead exposure, including hazard assessments, sampling data, and all contractor renovation records;
  • coordinate waste characterization and disposal;
  • provide to student occupants of moving into College apartments or target housing information on lead-based paint data for the unit to be occupied;
  • provide to student occupants of College apartments or target housing an EPA pamphlet entitled “Protect Your Family from Lead in Your Home”; and
  • obtain occupant lead disclosure forms and maintain for record-keeping.

Purchasing Department will make available to faculty/staff with children moving into College apartments or target housing information on lead-based paint data for the unit to be occupied, and supply to the occupants the EPA pamphlet entitled “Protecting Your Family from Lead in your Home.” Lead disclosure forms will be obtained and sent to EHS for record-keeping.

Project Managers / Supervisors – Contractors will notify EHS of any renovation or maintenance projects within target housing or child-occupied facilities that may involve disturbance of painted surfaces, including paint surface preparation and removal projects, or other dust/fume generating construction projects. All contractor records for work performed in target housing and child-occupied facilities under the EPA’s RRP rule must be forwarded to EHS for record-keeping.

Project Managers / Supervisors – College Employees will

  • request lead hazard evaluations for employees;
  • notify EHS of unusual conditions or changes in work practices that would make initial lead hazard evaluations non-representative of actual exposure;
  • ensure employee attendance in safety trainings; and
  • enroll employees exposed to lead above the OSHA action level into a respiratory protection program, including medical surveillance, training and fit testing.

Employees will

  • participate in safety training;
  • participate in medical surveillance program, if needed;
  • follow proper procedures to prevent disturbance of lead-containing materials while performing assigned tasks; 
  • use engineering controls, personal protective equipment and follow administrative controls designed to minimize lead exposure; and
  • notify supervisors of unusual conditions or changes in work practices that would invalidate initial lead exposure results.

Bailey Health Center will assist EHS in implementing the medical surveillance program, if necessary.

Topics covered by the Plan

Review the LBP Management Plan for detailed information on the following topics

  • Lead-Based Paint Activities
  • Renovation, Repair & Painting Projects
  • Determination of Employee Lead Exposure
  • Procedures for working with LBP
  • Waste Disposal
  • Training
  • Record-Keeping