35.4.1 NASA ARC Division of Occupational Safety, Health and Medical Services
35.4.2 Project Managers and Contracting Officer's Technical Representatives (COTRs)
35.4.3 DHS-Certified Lead Inspector/Assessor and Project Monitor
35.4.4 General Contractors Involved in Lead-Related Work
35.4.5 Lead Abatement Contractors/Subcontractors
35.4.6 The NASA ARC Acquisition Office
35.4.7 The NASA ARC Health Unit

35.14.1 Appendix A: Asbestos and Lead Survey Form
35.14.2 Appendix B: Lead Removal Inspection Form

1. Minimize exposure of lead to employees and visitors.
2. Comply with all pertinent, regulatory, and NASA requirements related to lead-containing materials. NASA ARC recognizes and will comply with all applicable Federal, State, and local governing regulatory agency regulations/guidelines pertaining to lead-containing materials.
3. Establish procedures for the identification, evaluation, control, disturbance, abatement, and waste storage/disposal of lead-containing material at NASA ARC.
4. Remove, enclose, encapsulate, or repair hazardous lead-containing material as required by government or NASA regulations, and as needed to protect human health.
5. Provide lead awareness training.
6. Provide California Department of Health Services (DHS)-certified lead personnel to evaluate potential lead-related hazards, sample suspect materials, and oversee lead abatement projects.
7. Eliminate the installation of new lead-containing material whenever possible.
8. Treat all painted surfaces as containing lead until laboratory documentation proves otherwise.
9. Ensure that lead-related contracted/subcontracted work is properly planned, reviewed, and conducted.

1. Oversee development and implementation of the Ames Lead Management Plan.
2. Provide DHS-certified (or interim certified) lead inspectors/assessors/project monitoring services for lead-related work activities as requested. This service will be implemented on a budget-reimbursable basis to the Center.
3. Review and evaluate the impact of regulatory changes on the Center.
4. As requested, provide a thorough review and evaluation of lead abatement plans, specifications, and abatement contractor submittals prior to abatement.
5. Verify that personnel who perform lead abatement work on NASA property have appropriate training and credentials to perform their assignment.
6. Approve the selection of accredited laboratories used to analyze lead bulk/air/soil/water samples.
7. Determine the need for baseline air monitoring or wipe sampling in occupied buildings.
8. Periodically inspect the abatement area and contractor/subcontractor for compliance with the Ames Lead Management Plan.
9. Establish criteria for post-abatement clearance inspection and testing and approve re-occupancy of buildings/areas upon a successful clearance testing.
10. Provide lead hazard awareness training to e mployees that work with lead containing materials or supervise employees that work with lead containing materials.
11. Maintain a central location for all lead management documentation.

1. Ensure that a survey to determine the presence, location, and quantity of lead-containing material(s) has been conducted prior to any work performance. A copy of the survey shall accompany the construction permit for review. All painted surfaces located on NASA property are assumed to contain lead, unless written information is provided stating that specific surface coatings do not contain lead.
2. Ensure that lead-related work activities are conducted in accordance with the laws, regulations, and guidance set forth in the Ames Lead Management Plan.
3. Ensure that the Occupational Safety, Health and Medical Services is notified of construction before the 30-percent design review phase, or ten days prior to maintenance-related lead work.
4. Coordinate with the Occupational Safety, Health and Medical Services to ensure that any lead-related work activity is monitored by DHS-certified lead personnel.
5. Provide DHS notifications for inspections and/or abatement, etc., as required by DHS.
6. Provide the DHS-certified lead personnel with accurate drawings and relevant information depicting the locations that shall be affected by any demolition/renovation, or maintenance activities.
7. Ensure that all construction specification documents that relate to lead specify the material, quantity, type, and location(s) of any lead-containing material to be removed.
8. Provide notification to all building occupants prior to all lead-related work being conducted in occupied buildings.
9. Ensure that the following documents are provided by the abatement contractor/subcontractor before any notice to proceed is granted. These documents should be reviewed by a DHS-certified lead individual for regulatory/NASA policy compliance:
• Lead abatement written compliance program.
• Site-specific health and safety plan.
• Any/all training plans required by the scope of work.
• Site drawings that depict contractor’s/subcontractor’s removal methods, containment location(s), and emergency evacuation routing.
• Contractor’s/subcontractor’s Hazard Communication Program, including copies of any/all Material Safety Data Sheets (MSDS) for materials to be utilized during performance of work.
• Contractor’s/subcontractor’s Respiratory Protection Program.
• A copy of all applicable licenses/permits.
• A copy of contractor’s/subcontractor’s lead abatement supervisor(s) and lead abatement workers DHS-certification cards authorizing them to conduct lead-related work.
• A copy of each employee’s biological monitoring, medical evaluations, and respirator-fit test certifications.
• A copy of hazardous waste landfill licenses/permits.
• A copy of hazardous waste hauler’s licenses/permits.
10. Ensure that only NASA Environmental Services Office personnel sign the hazardous waste manifest(s).
11. Ensure that maintenance personnel do not enter a regulated area without proper Personal Protective Equipment (PPE) and appropriate training.
12. Ensure that all original laboratory reports and negative air pressure manometer records are provided to the Ames Occupational Safety, Health and Medical Services.
13. Ensure that any contractor/subcontractors who conduct lead-related work on NASA property receive a copy of the Ames Lead Management Plan and sign a letter of receipt. Ensure that this document is incorporated as part of the required bid documents for each bidder.
14. Provide proof of medical surveillance and successful completion of a lead physical evaluation to NASA Occupational Safety, Health and Medical Services before any NASA employee engages in lead-related work.
15. Ensure that copies of all lead-related work documents are available, upon request, to the NASA Occupational Safety, Health and Medical Services.

1. Monitor compliance to the Ames Lead Management Plan.
2. Conduct or oversee bulk/air sampling as requested by the Ames Occupational Safety, Health, and Medical Services and present findings in a user-friendly format.
3. Assist in pre-lead abatement projects concerning bids, specifications, and procedures.
4. Review contractor/subcontractor submittals for compliance with the Ames Lead Management Plan.
5. Act as NASA ARC primary health and safety contact for inspection and compliance concerning lead-related work activities.
6. Conduct pre-& post-lead abatement inspections.
7. Conduct daily inspections on lead abatement projects including cleanup operations, and document these inspections (see Appendix B, section 35.14.2). Notify the project manager and contracting officer of any contractor/subcontractor deficiencies. Should any deficiency pose an imminent safety and health hazard, the DHS-certified individual may stop the project and immediately follow up with the project manager and contracting officer.
8. Determine final clearance criteria (wipe and/or air/bulk sampling) in concurrence with the Ames Occupational Safety, Health and Medical Services as described in section 35.4.5, 12.
9. Conduct area air monitoring on lead abatement projects as requested by the project manager or Ames Occupational Safety, Health and Medical Services. Background monitoring should be conducted before conducting area monitoring.

1. Exercise supervisory authority over all work covered by this chapter. As supervisor of the entire project, the general contractor shall comply and require all subcontractors to comply with the Ames Lead Management Plan, and all regulatory requirements including but not limited to the Department of Occupational Safety and Health Administration (OSHA), California Department of Health Services (DHS), Bay Area Air Quality Management District (BAAQMD), and the Environmental Protection Agency (EPA).
2. The general contractor must ensure that the site lead abatement plan is submitted and approved by DHS Lead Certified personnel and that all subcontractors comply with the plan.
3. The general contractor must ensure that DHS Lead Certified personnel monitor the lead abatement.
4. Notify the NASA project manager immediately upon discovery of any previously unidentified lead-containing material or material suspected of containing lead that will be disturbed.

1. Adhere to the Ames Lead Management Plan, and all Federal, State, and local regulatory agency regulations/guidelines that pertain to lead. Any deviations from the Ames Lead Management Plan must have the approval of the NASA ARC Occupational, Safety, Health and Medical Service and the NASA project manager. NASA Ames will not be responsible for contractor’s/subcontractor’s failure to read and understand this chapter/policy.
2. It is the sole responsibility of the contractor/subcontractor to perform exposure assessments and determine appropriate hazard control measures. Contractors must assume that all painted surfaces located on NASA property contain lead, unless written information is provided stating that specific surface coatings do not contain lead.
3. Contractors must assume that all painted surfaces located on NASA property contain lead, unless a lead survey written report is provided stating that specific surface coatings do not contain lead.
4. All lead-related work, unless directed by the Ames Occupational, Safety, Health and Medical Service, shall be conducted under the surveillance of DHS-certified lead personnel who are independently procured and financed by NASA ARC and approved by the Ames Occupational, Safety, Health and Medical Service.
5. On multi-employer worksites, a contractor who performs work that requires the establishment of a regulated area shall inform other employers on the site of the nature of the employer’s work with lead, of the existence of the requirements that pertain to regulated areas, and the measures taken to ensure that employees of the other employer are not exposed to lead.
6. Lead hazards at the contractor’s/subcontractor’s worksite shall be abated by the contractor/subcontractor who created the hazard.
7. Notify the NASA project manager immediately upon discovery of any previously unidentified lead-containing material.
8. Adhere to section 35.9 of this document, Storage /Disposal/Transportation of Waste Material.
9. The following documents must be delivered to the project manager and approved before any lead-related work is conducted:
• Lead abatement written compliance program.
• Site-specific health and safety plan.
• Any/all training plans required by the scope of work.
• Site drawings that depict contractor’s/subcontractor’s removal methods, containment location(s), and emergency evacuation routing.
• Contractor’s/subcontractor’s Hazard Communication Program, including copies of any/all Material Safety Data Sheets for materials to be utilized during performance of work.
• Contractor’s/subcontractor’s Respiratory Protection Program.
• A copy of all applicable licenses/permits.
• A copy of contractor’s/subcontractor’s supervisor(s) and workers DHS certification to conduct lead-related work.
• A copy of each employee’s biological monitoring, medical evaluations, and respirator fit- test certifications.
• A copy of hazardous waste landfill licenses/permits.
• A copy of hazardous waste hauler’s licenses/permits.
• There shall be no deviations from the contractor’s/subcontractor’s approved health and safety plan without prior consent of the Occupational Safety, Health and Medical Services and the NASA project manager.
10. All contractors/subcontractors shall be responsible for conducting personal monitoring needed to demonstrate regulatory compliance. Copies of this monitoring must be delivered to the contracting officer or representative within 48 hours. NASA may conduct area air-monitoring/wipe sampling at its discretion. Should contractors/subcontractors or NASA’s monitoring results exceed regulatory limits, engineering controls and/or work practices and/or respiratory protection must be modified for compliance.
11. NASA has set the following process for clearance of buildings or areas prior to reoccupancy. A DHS-certified lead inspector/assessor/project manager must evaluate the adequacy of the contractor’s decontamination of the affected area before it is released for occupancy. The clearance process includes a visual inspection and air and surface dust sampling when appropriate. If it is determined by the DHS certified lead professional that lead dust wipes will be collected for clearance then the following criteria will be used: 400 ug/ft2 on interior surfaces and 40 ug/ft2 on surfaces with high potential for hand to mouth contact. In child occupied facilities (the child care center), public and residential buildings, the current CA DHS, US EPA, or HUD regulations, whichever applies will be followed.
12. When soil is affected by a lead abatement project, the Environmental Services Office should be consulted to determine appropriate clearance levels for soil.
13. All work areas must be kept clean at all times, and thoroughly cleaned before the end of each shift. A DHS-certified lead inspector/assessor or project monitor must visually inspect all work areas prior to the removal of any barriers, and approve removal of barriers. NASA may conduct final clearance visual inspections and sampling at its discretion. Should any work area not pass visual inspection and/or air/wipe sampling, the contractor/subcontractor must reclean the entire work area until approval to remove barriers is granted. The contractor/subcontractor is responsible for cleaning up any lead contamination inside/outside the work area that results from the contractor’s/subcontractor’s actions to the satisfaction of the DHS-certified lead project monitor.
14. Any deviation from contractor’s/subcontractor’s original approved work plan must be submitted as a request to the contracting officer and approved before changes are implemented. The contracting officer shall have 48 hours to deny/approve procedures. NASA shall not be responsible for any job-related delays due to contractor’s/subcontractor’s request to change work practices/methods.

1. Require all contracts associated with lead-related work to include a copy of this entire document and to abide by its contents.
2. Require, as part of the bid documents, a signed letter from the contractor/subcontractor stating they have read and understand the Ames Lead Management Plan.

1. Provide medical evaluations to NASA ARC employees for lead exposure as required by OSHA.
2. Schedule and recall NASA ARC employees for lead-related medical evaluations as required by OSHA.
3. Counsel concerned employees about the health risk of lead exposure.

1. Use of power tools that are not equipped with High Efficiency Particulate Air (HEPA)-filtered exhaust air.
2. Dry scraping , sweeping, shoveling, non-HEPA vacumming or othersimiliar uncontrolled dry cleanup or removal of lead-containing material.
3. Employee rotation as a means to reduce employee exposure to lead.
4. Torch cutting, or any application of heat above 1100°F to a lead-containing surface.

1. Confined Space
2. Dusts, Fumes, Mists, Vapors, and Gasses
3. Electrical
4. Emergency Medical Services
5. Fire Protection and Prevention
6. Hazard Communication
7. Ladders
8. Log of Injury and Illness
9. Permits, Excavations, Trenches, Construction and Demolition, Air Tanks
10. Personal Protective Equipment
11. Safety Belts and Nets
12. Sanitation
13. Scaffolds
14. Stairways
15. Standard Railings
16. Ventilation

1. Respirator Training Records (for NASA personnel).
2. Air/wipe/water/soil sampling data from abatement projects.
3. Laboratory results from air/ wipe /water/soil sampling and personnel monitoring.
4. Results from bulk sampling analysis.
5. Hazardous waste manifests (records are maintained by the Environmental Services Office).
6. Medical Surveillance Records (all medical surveillance records of NASA employees will be located in the NASA Health Unit).
7. Proof of medical surveillance and successful completion of a lead physical evaluation shall be provided to NASA Safety Office before any NASA employee engages in lead-related work.

1. Emergency Demolition/Renovation Operations:

   Before any lead-related work is conducted pursuant to and classified as an emergency demolition/renovation project, the Ames Occupational Safety, Health and Medical Services must be notified and acknowledge notification.

2. Drilling Holes:

   Drilling holes into sheetrock, which is coated with lead-containing material, may be performed as described in this section. Impermeable drop cloths must be placed under/around area(s) to be drilled, and a wet sponge or shaving cream must be used during the operation to prevent airborne fiber contamination. Upon project completion, the area must be cleaned using wet methods and/or HEPA vacuums if necessary. Notification must be provided to the Ames Occupational Safety, Health and Medical Services, and acknowledged by the Ames Occupational Safety, Health and Medical Services prior to any drilling operation that affects lead painted surfaces. All persons who conduct this work shall have, at minimum, two-hour lead awareness training.

1. U.S. Department of Labor, Occupational Safety & Health Administration (OSHA)
   • 29 CFR Part 1910.1025 (Lead Regulations)
   • 29 CFR Part 1926.62 (Construction Lead Regulations)
   • 29 CFR Part 1910.134 (Respirator Regulations)
2. Toxic Substances Control Act (TSCA), Title 4
3. California Labor Code Sections 6501.5, 6501.7, 6501.8, and 6505.5
4. California Code of Regulations (CCR)
   • Title 8, Section 5216 (Lead Regulations)
   • Title 8, Section 1532.1 (Construction Lead Regulations)
   • Title 8 Sections 5141 & 5144 (Respirator Regulations)
   • Title 17 Division 1, Chapter 8 (Accreditation, Certification, and Work Practices for Lead-Based Paint and Lead Hazards))
5. The Department of Housing and Urban Development (HUD), Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing.
6. Environmental Protection Agency, 40 CFR Part 745, Lead; Indentification of Dangerous Levels of Lead
7. Resource Conservation Recovery Act (RCRA)
8. Health and Safety Code Section 25914
9. American National Standards Institute (ANSI) Fundamentals Governing the Design & Operation of Local Exhaust Systems (ANSI, Z.9.2)
10. National Electrical Code
11. National Plumbing Code
12. California Business & Professions Code Section 7058.5