Lead-Based Paint & Lead Exposure Policy

SCS-HS-POL-LEAD-001 · REV 2.0 · 26 SEPTEMBER 2026

STATUS: CONTROLLED — CURRENT
OWNER: Health & Safety Lead
APPROVED BY: SCS Director / Officer
SECTION: 2 of 11

PEOPLESAFERSPACESSTRONGERTOGETHER

SECTION 01

Policy commitments

Eliminate lead exposure so far as is reasonably practicable; where it cannot be eliminated, minimise it using the hierarchy of controls.
Identify or presume lead risk before disturbing any coating where lead may reasonably be present.
Buildings from the 1980s or earlier are flagged as PRESUMED LEAD unless reliable evidence shows otherwise. Building age is a screening indicator, not proof.
Preferred methods: no disturbance / encapsulation, wet or manual low-dust methods, compatible chemical stripping, or controlled low-temperature methods.
Mechanical preparation only with approved engineered shrouded on-tool extraction connected to fit-for-purpose H-class extraction, with suitable RPE.
Prohibited on confirmed or presumed lead coatings: uncontrolled dry sanding or grinding, abrasive blasting, compressed-air clean-up and dry sweeping.
No open-flame or blowtorch removal.
No domestic or general commercial vacuum for lead dust. Lead dust / fume is treated as H-class hazardous dust. HEPA alone does not mean H-class.
High-pressure water blasting of lead-coated occupied or residential surfaces is not a routine SCS method. It requires a specific risk assessment, substrate / manufacturer acceptance, capture and filtration of debris and contaminated water, and a confirmed lawful waste route.
Occupied homes, children, vulnerable residents and public interfaces require enhanced containment, communication, exclusion, clean-up and hand-back controls.
No eating, drinking, smoking, vaping or food storage inside the lead-control zone.
Take-home contamination is prevented through a clean / dirty transition, handwashing, decontamination and controlled transport of clothing, waste and tools.
Every worker has stop-work authority when containment, extraction, RPE, waste-water control, resident exclusion or the approved method fails.

SECTION 02

Lead work classification A–D

CLASS	DESCRIPTION	EXAMPLES	APPROVAL	MONITORING
A	No / negligible disturbance	Overcoating sound surfaces without sanding, encapsulation, cleaning intact coatings, inspection only.	Supervisor confirms method at prestart.	Not normally required. Review if scope changes.
B	Controlled low-dust disturbance	Wet scraping, wet hand sanding, spot repair, compatible chemical stripping in small areas, low-temperature controlled heat.	Pre-Work Assessment & Permit to Proceed authorised by supervisor.	Consider exposure monitoring if work is repeated, prolonged or controls are uncertain.
C	Higher potential / recurring / mechanical	Mechanical sanding with shrouded on-tool H-class extraction, recurring lead work across jobs, poor ventilation, uncertain exposure.	Permit authorised by H&S Lead. Monitoring decision record required before Send to Prestart.	Occupational-health / hygiene review. Baseline BLL and breathing-zone monitoring where recommended by a competent practitioner.
D	Outside standard SCS method — STOP	Abrasive blasting, open-flame removal, uncontained high-pressure water blasting, major contamination, work beyond SCS competence or resources.	HARD STOP. SSSP cannot be approved until a specialist / competent adviser escalation pathway is documented.	Set by the specialist / competent adviser.

CLASS D — STOP AND ESCALATE

Abrasive blasting, open-flame removal, uncontained high-pressure water blasting, major contamination or work beyond SCS competence or resources is not performed under the SCS standard method.

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SECTION —

Document approval

ROLE	NAME / POSITION	STATUS
Prepared / reviewed	Health & Safety Lead	REVIEWED
Approved	SCS Director / Officer	APPROVED