Lead-Based Paint Management/Abatement

Asbestos and Lead Program Manager

858-380-6786

The Lead-Based Paint Management Program consistently provide regulatory oversight for the management, maintenance, control, and abatement of materials containing lead-based paint (LBP), while sustain and promote interactive environment with all MCAS Miramar departments and commands.  The program applies to disturbance activities and non-disturbance hazardous conditions associated with identified and suspect materials containing LBP.  The objective is to protect the public by minimizing the release of lead dust and exposures.

The term “lead” as used in OPNAVINST 5100.23 (Series) means metallic lead, all inorganic lead compounds and organic lead soaps.  Since ancient times, people have used the soft, “gray metal” lead to make pipes, jars and bright pottery glazes.  LBP is defined as paint, varnish, shellac, or other coatings on surface that contain more than 1.0 mg/cm² of lead or more than 0.5% lead by weight.  Lead has been shown through years of research to be toxic to the human body.  Lead can be absorbed into your body by inhalation and ingestion.  For the most part, lead is not absorbed through the skin.  Inhalation of airborne lead is primarily the source of occupational exposure.  Ingestion is primary from handing food, tobacco or make-up which has lead on them or on your hands.  In recognition of the serious health hazards associated with and numerous sources of potential lead exposure, strict controls to limit both occupational and environmental exposures are required.

Building materials containing LBP that are in good condition pose no health hazard risk.  Hazardous condition exists when materials containing LBP become damaged, causing the release of lead dust or paint chips.  To avoid any mishap or create any potential of lead hazard condition, here are the following preventative measures:

• DO NOT disturb (e.g. break, cut, grind, sand, or remove) materials that contain any paint, varnish, shellac, or other coatings, even when no LBP content had been previously identified.
• DO NOT perform building component repairs, alterations, renovations, or demolitions work. 
• REPORT damaged building component to your Building Manager, the installation Asbestos and Lead Program Manager (ALPM), or MCAS Miramar Public Works Department – Facilities Management Division (PWD-FMD)’s Zone Manager.

Please contact the installation ALPM if you have any question or concern pertaining to the Lead Management Program. 

The following regulations apply to MCAS Miramar’s Lead Program:

Federal Laws and Regulations

• EPA 40 CFR 745, Identification of Dangerous Levels of Lead
• OSHA 29 CFR 1926.62 Safety and Health Regulations for Lead in Construction (i.e. Construction Standard)
• OSHA 29 CFR 1910.1025 Safety and Health Regulations for Lead in Industry (i.e. Industry Standard)

Department of Defense, Navy Policy, & Unified Facilities Guide Specifications

• NAVMC Occupational Safety & Health Program Directive 5100.8
• UFGS 02 83 13.00 20 Lead in Construction
• UFGS 02 82 33.13 20 Removal/Control & Disposal of Lead in Paint
• NAVFACINST 5100.11 Navy Safety & Health Program Chapter 5 Asbestos & Lead
• OPNAVINST 5100.23 Chapter 21 Lead

It is the responsibility of the ALPM to:

• Update the Lead Management Plan, as necessary, to reflect changes such as material condition, regulations, requirements, etc.

• Review and/or provide comments to Site Approval Request from Public Works Department (PWD) – Assets Management Division (AMD)
• Review and/or provide comments to proposed project’s scope of work (SOW) from PWD – Engineering Division (ED)
• Review and/or provide comments to proposed project’s SOW from Facilities, Engineering & Acquisition Division (FEAD)
• Attend project meeting that pertains to disturbing LBP, LCP, and LCM

• Review, comment, and/or provide approval of Lead Abatement/ Work Plan submitted by Contractors to the installation
• Ensure that the Lead Abatement/ Work Plan complies with the MCAS Miramar’s Asbestos and Lead Program Management – Pre & Post Work Submittal Documents

• Ensure that work performed by the General Contractor (GC), in which may potentially disturb lead materials is approved before commencing work. 
• Monitor lead construction-related work activity once field work has commenced.

• A pre-construction survey identified potential lead disturbances (repair, alteration, renovation, modernization, etc.).
• The contractor/ organization must involve the ALPM in the project kick-off meeting.
• A Lead Abatement/ Work Plan must be certified by a California Department of Public Health – Lead Project Monitor, Lead Project Designer, Lead Supervisor.  The Lead Abatement/ Work Plan must address all Pre-Package Submittal Requirements issued by the ALPM.
• All ALPM comments must be appropriately addressed.  A revised Lead Abatement/ Work Plan may be required depending on the ALPM comments provided.
• The ALPM approval of the Lead Abatement/ Work Plan permits the proposed lead activity.  A copy of the Lead Abatement/ Work Plan and Lead Assessment/ Survey Report must be available at the worksite at all time.

• During lead project monitoring, the responsible party must submit the air monitoring results on a timely basis.
• Respond to elevated or irregular results with the responsible party.
• Review Incident Reports.
• Correct minor deficiencies with verbal or written communication to the responsible party.
• Correct major deficiencies with written communication and discipline the responsible party, if appropriate.
• Review lead sampling results with the responsible party.
• Review clearance or final project reports.
• The contractor/ organization is responsible for submitting and managing all regulatory notifications and comply with all regulatory requirements.  A copy of the notification must be sent to the ALPM.

NAVMC OSH Directive 5100.8, MCAS Miramar Station Order 5100.8, and the NAVMC OSH Program identify the necessity for a qualified and certified individual (Lead Program Manager) to perform duties on the station related to activities that may disturb lead containing materials and the necessary actions required to safely address these materials. The person selected to perform this duty is required to have extensive experience in lead related issues and hold specific certifications recognized by the U.S. DOD and the U.S. EPA. These certifications include:  Lead Project Supervisor, Lead Inspector, Lead Risk Assessor, and Lead Project Designer.