Lead Exposure Control Program


Prior to 1978 the use of lead-based paint was common in homes, buildings, child-care facilities, and other schools. The use of this type of paint was banned in 1978, but many older buildings may still contain hazardous amounts of lead.

Lead poisoning is a serious health concern for everyone, but it is especially dangerous to children under the age of six. 

The most common way for lead to enter the body is through dust, which is often invisible. 

Lead-containing dust is often created from:

  • Deteriorating lead-based paint in buildings
  • Disturbance of lead-based paint during renovation activities, such as sanding, cutting, and demolition

Lead Management Plan

EHS has developed a Lead Management Plan in accordance with:

  • Oregon OSHA General Industry Lead Standard (29 CFR 1910.1025)
  • Oregon OSHA Construction Lead Standard (OAR 1926.62, Division 3)
  • EPA’s Lead-Based Paint Renovation, Repair, and Painting (RRP) Program

The Lead Management Plan provides a template for work practices to minimize the potential for exposure to lead-containing materials during demolition, maintenance, and renovation activities. 

Employees who perform tasks that may impact lead-based paint materials are covered by this plan and are required to participate in specific safety training provided by EHS. 

Contractors that may perform work that disturbs lead-containing materials in child-occupied buildings must provide documentation of current EPA Lead RRP training. 

PSU Lead Management Plan

Material Assessment

Before the onset of a construction, remodel, or repainting project begins, employees and supervisors are required to assess if any of the affected material is considered to possibly be lead-containing. 

If the affected material has the possibility to be lead-containing, Project Managers should:

  • Assess whether the material has been sampled for lead
  • Facilitate the collection of all suspect material for analysis with EHS

The EPA has identified lead-based paint as a material containing over 0.5%, or 5,000 parts per million (ppm) lead but OR-OSHA has not identified an acceptable level of lead. Materials with any detectable level of lead are considered lead-containing, therefore making the processes established in the Lead Management Plan applicable.

Waste Collection

Any lead-containing waste material generated should be collected into sturdy plastic bags (6-mil poly bags recommended), labelled as “Hazardous Waste - Lead Paint Waste”, and with the date of collection, and provided to EHS for disposal.

This includes all paint debris, drop cloths, and disposable personal protective equipment (PPE).