MIT has developed guidelines to protect employees, students and their families and the rest of the MIT community from the hazards of lead-based paint. For all buildings built before 1978, MIT is taking the position that lead paint is present, unless an inspection report has determined otherwise.
The main objectives of this policy are to:
- provide a consistent approach to addressing potential lead exposure to families living on campus with children under the age of 6;
- inform employees of the potential hazards of lead paint; and
- promote appropriate work practices that comply with the OSHA Lead in Construction Standard, 29 CFR 1926.62 or, when applicable, the EPA/MA Renovation, Repair, and Painting (RRP) rule when performing tasks that have the potential to disturb lead-based paint in MIT-owned buildings.
Outside contractors are responsible for complying with these regulations when applicable, as well as MA DPH Lead Poisoning Prevention and Control (105 CMR 460.000), and MA DOS de-leading regulations (454 CMR 22.00) for MIT-owned residential buildings, when performing lead abatement.
Background
Lead is a heavy, soft metal that used to be added to paint to make it last longer, resist moisture, speed drying, and adhere to surfaces better, until it was determined to be toxic and was banned for residential use in 1978. The Department of Housing and Urban Development’s (HUD) National Survey of Lead and Allergens in Housing estimated that 38 million permanently occupied housing units (40% of all housing units) in the United States contain some lead-based paint that was applied before the residential use of lead-based paint was banned. Exposure to lead is especially harmful to children and lead hazards in a child’s environment must be identified and controlled or removed safely. The most common routes of exposure to lead are inhalation and ingestion. Children may be exposed to lead through contact with paint chips and dust from lead paint in older buildings and homes. Lead paint is regulated when the concentration of lead paint is 1 mg per square centimeter.
Commitment
MIT is committed to providing a safe workplace and campus living environment and protecting employees and the MIT community from the hazards of lead paint. MIT employees and/or contractors are required to comply with all applicable laws regarding the prevention of lead exposure and containment of lead-based materials, including donning the proper personal protective equipment (PPE) , when required, and expected to follow the safe work practices posted here or otherwise provided by EHS.
What We Do To Manage Lead-based Paint
MIT is responsible for management and testing paint in and on buildings where it is reported to be deteriorated, damaged, peeling, flaking or otherwise loose, as well as areas where paint will be disturbed due to remodel, repair, or other construction. For renovation, repair and renewal projects, testing will be conducted of areas and surfaces pre-construction.
Residential and Childcare Facility Requirements
The Commonwealth of Massachusetts regulates lead paint through 105 CMR 460, the Massachusetts Lead Law. The goal of the Lead Law is to prevent children from being poisoned through ingestion of lead paint or inhalation of lead dust and requires all lead paint hazards removed or covered in residences built before 1978 where children under the age of six (6) reside. Lead paint hazards in residences include loose lead paint and lead paint on windows and other surfaces accessible to children.
A licensed lead inspector will test the residence for lead and note all lead hazards. If necessary, MIT will use a licensed deleading contractor, or other trained and authorized person, to remove or cover all lead hazards. A Certificate of Compliance is issued by the lead inspector if either:
- No lead paint hazards are noted during the initial inspection or
- All the lead paint hazards have been removed (verified by reinspection)
For those areas that contain regulated lead paint, MIT will periodically reinspect the space to ensure that lead paint remains intact.
The RRP rule, effective 4/22/10, requires that contractors performing renovation, repair, and painting projects that disturb lead-based paint in residential and child-occupied facilities (includes day care centers and schools occupied by children under 6) built before 1978 must be certified and must follow specific work practices to prevent lead contamination (now covered under 454 CMR 22.00 – Deleading and lead-safe renovation regulations).
At MIT, all childcare centers were built after 1978 and, therefore, don’t have lead-based paint, and are not subject to deleading regulations. Campus housing built prior to 1978 where children under age 6 may live are subject to compliance with certain lead disclosure, prevention and containment regulations. For those residential buildings and/or units, unless the repairs meet the definition of a minor repair, or testing determines lead is not present, any work must be performed by a certified lead-safe renovator-supervisors, or a licensed lead abatement or certified lead-safe renovation contractor.
The following minor repairs or maintenance activities are not subject to lead-safe certification or licensing:
- activities that disturb 6 square feet or less of paint per room within the residential unit or common areas of a residence hall.
- activities that disturb 20 square feet or less on the exterior of the residence or building
Minor repairs and maintenance activities do not include window replacement, demolition activities of any kind or prohibited practices (burning or torching, sanding, grinding, or other highspeed operations).
How You Can Help
If you notice loose paint in an MIT-owned building, please report the issue to MIT EHS (environment@mit.edu or call 617-452-3477). Loose paint can refer to paint, other coatings, plaster or putty on a surface that is peeling, flaking, chipping, crumbling, cracking, deteriorated or damaged in any manner. EHS will respond quickly and determine if the paint contains lead. If lead is identified, the paint will then be handled properly and safely by trained staff or contractors and all state and federal protocols for lead abatement will be followed.
If abatement work is taking place, DO NOT enter the work area. Unauthorized entry can expose you and others to lead dust that can be tracked out of the containment zone. Staff and/ or contractors performing lead abatement are required to capture all dust generated through use of enclosures, ventilation systems, HEPA vacuums or other methods to protect you and others from exposure.
Additional Information
For more detailed information on residential lead paint regulations in Massachusetts, we encourage you to explore the following reputable sources and websites:
- Massachusetts Department of Public Health (DPH) – Massachusetts DPH Lead Paint Program: The Massachusetts DPH website provides comprehensive information on lead paint regulations, including details on the Lead Law, requirements for property owners, and resources for homeowners and tenants.
- Massachusetts Department of Environmental Protection (MassDEP) – MassDEP Lead Paint Program: MassDEP also plays a role in regulating lead paint and hazardous waste in the state. Their website offers information on lead paint, regulations, and compliance.
MIT has developed guidelines to protect employees, students and their families and the rest of the MIT community from the hazards of lead-based paint. For all buildings built before 1978, MIT is taking the position that lead paint is present, unless an inspection report has determined otherwise.
The main objectives of this policy are to:
- provide a consistent approach to addressing potential lead exposure to families living on campus with children under the age of 6;
- inform employees of the potential hazards of lead paint; and
- promote appropriate work practices that comply with the OSHA Lead in Construction Standard, 29 CFR 1926.62 or, when applicable, the EPA/MA Renovation, Repair, and Painting (RRP) rule when performing tasks that have the potential to disturb lead-based paint in MIT-owned buildings.
Outside contractors are responsible for complying with these regulations when applicable, as well as MA DPH Lead Poisoning Prevention and Control (105 CMR 460.000), and MA DOS de-leading regulations (454 CMR 22.00) for MIT-owned residential buildings, when performing lead abatement.
Background
Lead is a heavy, soft metal that used to be added to paint to make it last longer, resist moisture, speed drying, and adhere to surfaces better, until it was determined to be toxic and was banned for residential use in 1978. The Department of Housing and Urban Development’s (HUD) National Survey of Lead and Allergens in Housing estimated that 38 million permanently occupied housing units (40% of all housing units) in the United States contain some lead-based paint that was applied before the residential use of lead-based paint was banned. Exposure to lead is especially harmful to children and lead hazards in a child’s environment must be identified and controlled or removed safely. The most common routes of exposure to lead are inhalation and ingestion. Children may be exposed to lead through contact with paint chips and dust from lead paint in older buildings and homes. Lead paint is regulated when the concentration of lead paint is 1 mg per square centimeter.
Commitment
MIT is committed to providing a safe workplace and campus living environment and protecting employees and the MIT community from the hazards of lead paint. MIT employees and/or contractors are required to comply with all applicable laws regarding the prevention of lead exposure and containment of lead-based materials, including donning the proper personal protective equipment (PPE) , when required, and expected to follow the safe work practices posted here or otherwise provided by EHS.
What We Do To Manage Lead-based Paint
MIT is responsible for management and testing paint in and on buildings where it is reported to be deteriorated, damaged, peeling, flaking or otherwise loose, as well as areas where paint will be disturbed due to remodel, repair, or other construction. For renovation, repair and renewal projects, testing will be conducted of areas and surfaces pre-construction.
Residential and Childcare Facility Requirements
The Commonwealth of Massachusetts regulates lead paint through 105 CMR 460, the Massachusetts Lead Law. The goal of the Lead Law is to prevent children from being poisoned through ingestion of lead paint or inhalation of lead dust and requires all lead paint hazards removed or covered in residences built before 1978 where children under the age of six (6) reside. Lead paint hazards in residences include loose lead paint and lead paint on windows and other surfaces accessible to children.
A licensed lead inspector will test the residence for lead and note all lead hazards. If necessary, MIT will use a licensed deleading contractor, or other trained and authorized person, to remove or cover all lead hazards. A Certificate of Compliance is issued by the lead inspector if either:
- No lead paint hazards are noted during the initial inspection or
- All the lead paint hazards have been removed (verified by reinspection)
For those areas that contain regulated lead paint, MIT will periodically reinspect the space to ensure that lead paint remains intact.
The RRP rule, effective 4/22/10, requires that contractors performing renovation, repair, and painting projects that disturb lead-based paint in residential and child-occupied facilities (includes day care centers and schools occupied by children under 6) built before 1978 must be certified and must follow specific work practices to prevent lead contamination (now covered under 454 CMR 22.00 – Deleading and lead-safe renovation regulations).
At MIT, all childcare centers were built after 1978 and, therefore, don’t have lead-based paint, and are not subject to deleading regulations. Campus housing built prior to 1978 where children under age 6 may live are subject to compliance with certain lead disclosure, prevention and containment regulations. For those residential buildings and/or units, unless the repairs meet the definition of a minor repair, or testing determines lead is not present, any work must be performed by a certified lead-safe renovator-supervisors, or a licensed lead abatement or certified lead-safe renovation contractor.
The following minor repairs or maintenance activities are not subject to lead-safe certification or licensing:
- activities that disturb 6 square feet or less of paint per room within the residential unit or common areas of a residence hall.
- activities that disturb 20 square feet or less on the exterior of the residence or building
Minor repairs and maintenance activities do not include window replacement, demolition activities of any kind or prohibited practices (burning or torching, sanding, grinding, or other highspeed operations).
How You Can Help
If you notice loose paint in an MIT-owned building, please report the issue to MIT EHS (environment@mit.edu or call 617-452-3477). Loose paint can refer to paint, other coatings, plaster or putty on a surface that is peeling, flaking, chipping, crumbling, cracking, deteriorated or damaged in any manner. EHS will respond quickly and determine if the paint contains lead. If lead is identified, the paint will then be handled properly and safely by trained staff or contractors and all state and federal protocols for lead abatement will be followed.
If abatement work is taking place, DO NOT enter the work area. Unauthorized entry can expose you and others to lead dust that can be tracked out of the containment zone. Staff and/ or contractors performing lead abatement are required to capture all dust generated through use of enclosures, ventilation systems, HEPA vacuums or other methods to protect you and others from exposure.
Additional Information
For more detailed information on residential lead paint regulations in Massachusetts, we encourage you to explore the following reputable sources and websites:
- Massachusetts Department of Public Health (DPH) – Massachusetts DPH Lead Paint Program: The Massachusetts DPH website provides comprehensive information on lead paint regulations, including details on the Lead Law, requirements for property owners, and resources for homeowners and tenants.
- Massachusetts Department of Environmental Protection (MassDEP) – MassDEP Lead Paint Program: MassDEP also plays a role in regulating lead paint and hazardous waste in the state. Their website offers information on lead paint, regulations, and compliance.