classroom contamination from lead bearing ceramic art glaze … · 2018. 1. 31. · ceramic art...
TRANSCRIPT
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Classroom Contamination from Lead Bearing Ceramic Art Glaze
William R. Rath
Industrial health & Safety Consultants, Inc.
Woodbridge, CT
Woodhall Stopford, MD, MPH
Duke University Medical Center
Durham, NC
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Abstract
On April 4, 2006, the Connecticut Department of Public Health (DPH) issued a Product
Advisory and Information Sheet regarding the “Use of Leaded Ceramic Glazes in School Art
Classes.” This sheet advised Connecticut school districts to determine if leaded ceramic art
glazes had been used in the district and, if so, to coordinate with the local health departments to
identify and remedy any lead hazards that may have been created by such use.
This paper follows the response of two Connecticut school districts from the time the
advisory was issued until the affected art rooms were reoccupied. It examines the regulatory,
technical, scientific, and emotional aspects of the process, and includes the following topics:
Chemistry and toxicology of ceramic art glazes
Health concerns from the use of leaded art glazes
DPH guidance (risk assessment & clearance standards)
School issues (Cost factors, scheduling, loss of use, emotional issues)
Local health department issues
Survey techniques, results, and trends
Lead abatement plans
Decontamination processes and techniques
Waste management
Lead in “lead free” art glaze
Potential for lead contamination and exposure from “lead free” art glaze
Kiln and kiln accessory contamination considerations
ASTM guidelines for safe use of art products
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The paper concludes with a discussion of the appropriateness of applying childhood lead
poisoning standards to art rooms for older children, and a call for more research to clarify the
following issues:
How much lead contamination will result from the use of “lead-free” ceramic art
glazes?
What surface contamination standards are appropriate for older children and
adults?
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Introduction
On April 4, 2006, the Connecticut Department of Public Health (DPH) issued a Product
Advisory and Information Sheet regarding the “Use of Leaded Ceramic Glazes in School Art
Classes.” This sheet advised Connecticut school districts to determine if leaded ceramic art
glazes had been used in the district and, if so, to coordinate with the local health departments to
identify and remedy any lead hazards that may have been created by such use. The advisory
specified the EPA lead dust hazard level of forty micrograms of lead dust per square foot of
surface area (40 ug/ft2) as the trigger value to initiate decontamination activities and as the
clearance standard to determine the efficacy of decontamination activities. William R. Rath of
Industrial Health & Safety Consultants, Inc. assisted two Connecticut school systems with their
response to this advisory. Thirteen buildings were evaluated for lead dust contamination,
including two high schools, four middle schools, six elementary schools, and a multi-use
building that included space used for art instruction. Lead dust contamination levels in excess of
the EPA hazard level were identified in all 18 art rooms within the 13 buildings. This paper will
describe the response of these two school districts from the time the advisory was issued until the
affected art rooms were reoccupied.
Art Room Lead Contamination Issues
Lead in Ceramic Art Glazes
Ceramic art glazes are used to strengthen and decorate art formed from clay. Modern
ceramic art glazes are pre-mixed liquids that contain frit made from finely ground glass. When
the glaze is fired in a high-temperature oven called a kiln, the glaze vitrifies into a permanent,
impermeable coating over the clay. Various other materials, including lead, are added to the
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glass frit to improve the performance of the glaze during the firing process or to enhance the
color of the finished product. According to Material Safety Data Sheets provide by ceramic
glaze manufactures, ceramic frit represents approximately fifty percent of the weight of liquid
glazes (American Art Clay Company, Inc., 2005) and, depending upon the formulation, up to 28
percent of that frit can be lead oxide (Duncan Enterprises, 2005).
Leaded glazes can be found in several settings. They are used commercially for making
dinnerware, both for decorating and for creating an impervious, clear surface using a dipping
glaze. The hobby ceramic industry developed based on the use of pre-mixed liquid glazes, many
containing lead frits. Individuals would decorate greenware with lead-based glazes in controlled,
commercial ceramic studios. During the last decade contemporary ceramic studios have, for the
most part, replaced hobby ceramic studios. Contemporary ceramic studios are commercial
ventures where individuals decorate fired bisqueware with lead-free glazes. The decorated ware
is then dipped in a glaze and fired by studio workers. Most of the dipping glazes used in these
establishments are lead-based.
The use of ceramic art glazes in schools varies according to the age and expertise of the
students. In primary school art classes, student involvement usually consists of decorating
bisqueware that is fired by the teacher. In middle and high schools, art students become involved
in the firing process as well, and advanced art students may apply and fire dipping glazes as well
as decorative glazes.
Lead-related health concerns in ceramic studios
Lead exposure can result in both acute effects, including acute mental changes
(encephalopathy) as well as chronic effects such as difficulty with school work, poor attention,
anemia, kidney effects and motor and sensory nerve damage. In one studio of both professional
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ceramic decorators and hobby ceramicists using leaded glazes, blood lead levels in both groups
were no different from un-exposed controls and there were no findings of anemia in either group
(Stopford, 1988). In commercial studios working with leaded dipping glazes, blood lead levels
can range as high as 50 µg/dL. In some operations, such glaze making (not a component of
contemporary ceramic studios or hobby ceramic studios), blood levels have been found to be as
.high as 84 µg/dL. The maximum acceptable blood lead level in the workplace is 30 µg/dL
(ACGIH, 2001). In children, however, central nervous system and kidney effects can occur at
lower levels of exposure than in adults (Goldwater, et al, 1988).
During the glazing process, lead from the liquid glaze can contaminate surrounding
surfaces in several ways. The most direct means of contamination is spillage of the liquid glaze
product. When allowed to air dry, the dried glaze is easily crumbled into a fine, talc-like dust
that readily spreads throughout the surrounding area.
Studies have been completed of the extent of lead contamination in contemporary
ceramic studios. Stopford and Stanion (1998) found lead contamination of surfaces in such
studios ranged from 33 to 793,000 µg/ft2 while contamination levels in customer areas ranged
from non-detectable to 2295 µg/ft2. The investigation described in this paper identified
contamination levels in public school art classrooms from below detection limits to 68,000
µg/ft2.
Lead in ceramic art glaze can also volatilize during the firing process, contaminating the
inside of the kiln, other objects within the kiln, and, potentially, adjacent work areas. All modern
kilns, however, are ventilated preventing contamination of the studio with lead fumes from the
firing process. Prior to mandatory kiln ventilation, studio exposure levels from firing leaded
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glazes could reach as high as 17 µg lead/m3 in unventilated studios. With use of dilutional
ventilation, exposures were found to be
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Stop using and properly dispose of lead-bearing ceramic art glazes
Notify the local health department
Determine the extent of contamination
Develop a site-specific clean-up plan
Notify parents that ceramic art projects may be contaminated with lead
Henceforth, stock and use only “non-hazardous” ceramic art glaze bearing the
“AP” seal of the Art and Creative Materials Institute.
The advisory specified the EPA lead dust hazard level of 40 ug/ft2 as the trigger value to
initiate decontamination activities and as the clearance standard to determine the efficacy of
decontamination activities. Lead dust contamination levels in excess of 40 ug/ft2 were identified
in every art room in the two school systems described in this paper.
Local Health Department Issues
The April 4 advisory recommended that schools contact their Local Health Department
(LHD) for guidance on dealing with potential contamination issues. The two school districts
described in this paper spanned political areas that included four local health departments. Three
of the four health directors were physicians. The fourth director was a public health professional
that was not a physician.
As suggested in the DPH advisory, all of the health directors advised the school systems
to engage a licensed “Lead Inspector Risk Assessor” (LIRA) to identify the extent of the lead
contamination. After the initial surveys were complete, meetings were held to discuss sample
results and remediation options. The LIRA then developed site-specific decontamination plans
that were approved by the health directors. None of the health directors recommended blood
lead screening for the teachers or students.
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The LIRA briefed the health directors periodically as the decontamination work
progressed, and contacted them for guidance in situations that were not covered by the
decontamination plans. The LIRA reviewed the final clearance sample results with the health
directors before opening the rooms for unrestricted access. One of the health directors stipulated
a final pre-occupancy inspection by a member of the health department staff that was a certified
lead inspector.
School Issues
Loss of Use
The April 4 advisory recommended that schools “. . . stop use of and restrict access to all
areas where ceramic/pottery operations were conducted in conjunction with leaded glazes,
including glaze storage areas, kilns, and ventilation systems, until further evaluation is
conducted.” Based upon this recommendation, most school systems simply stopped using the
affected art rooms until they could be tested for lead contamination. As noted earlier, lead
contamination levels in excess of 40 ug/ft2 were identified in every art room tested during this
study, so the 18 art rooms were not available for use from the time the advisory was issued until
the decontamination activities were complete. This period of restricted access ranged from
slightly less than a month to well into the summer break.
The loss of art room use affected different schools in different manners. Generally
speaking, elementary schools were the least affected, as the art teachers were able to deliver art
programs from carts that could be wheeled room to room. At the other extreme were the high
school art rooms, some of which were being used by students that were completing their
portfolios for admission into art colleges.
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Both of the school systems considered in this paper elected to focus their first efforts on
the high school art rooms, followed by the middle and elementary schools. For budgetary
reasons, one system deferred the decontamination work in one elementary school and one a
middle school until after the July 1 start of the new fiscal year.
Emotional Factors
The decontamination process is described in detail later in this paper, but the basic
operating principle was to decontaminate items that could readily be decontaminated, and to
discard those that could not. This guideline was easily applied to some items, such as an
expensive stainless steel table that was easy to clean or a cheap pair of pom-poms that might
never be successfully decontaminated. It was more difficult to apply to other items that could be
decontaminated, but only at a cost that exceeded the value of the item. At a fully burdened labor
rate of $75 per hour, it was simply more cost-effective to discard many items rather than to
attempt decontamination and subsequent representative clearance wipe sampling.
The art teachers encountered during this project were dedicated, highly creative
professionals that were both intellectually and emotionally involved with their work. All had
spent many years supplementing the materials available through normal procurement methods
with supplies, props, and accessories that were bought at yard sales, cajoled from local
merchants, and salvaged from the recycle bin. It is likely that as much as half of the creative
materials encountered during this project were personally procured by the art teachers at their
own time and expense.
The presence of these additional creative materials created an interesting situation. It was
not in the best interest of the school system to decontaminate items that were cheaper to replace
than decontaminate. However, many of the items to be discarded were not purchased by, and
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presumably would not be replaced by, the school system. To address this situation and the
apparently competing interests of the school system and the art teachers, it was necessary to
formalize the means by which the clean/discard decision was made.
The first step in this process was to work with art department personnel to educate the
consultant and the abatement contractor foreman on the value of items found in the art room.
Objets d’art were presumed to be worth decontaminating unless extraordinary efforts were
required. Art supply catalogs were provided so that the cost of decontaminating ordinary art
equipment and supplies could be compared to replacement costs. The use of props and models
were described so that an old boot used for sketching exercises would not be discarded without
due consideration of their intangible value.
The clean/discard decision for any given item could be made at any one of three
progressive levels. The abatement contractor foreman made the vast majority of clean/discard
decisions as the work progressed. Questionable items were referred to the consultant. Items that
could not be readily classified by the consultant were placed in clear plastic bags and set aside
for evaluation by the art teacher.
All of the art teachers understood the necessity of making the clean/discard decisions, and
most of the questionable materials set aside by the consultant were ultimately discarded. But
none of the art teachers could ignore the years of effort required to amass their inventory of
creative materials, and there were times when making these decisions evoked strong emotions.
Direct Cost
The direct cost of decontaminating all eighteen art rooms, which includes the cost of the
industrial hygiene consultant, analytical laboratory, abatement contractor, and hazardous waste
disposal, was $199,134, or an average cost of approximately $11,063 per room. Indirect costs
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are difficult to quantify, partly because not all of the discarded items were immediately replaced,
and partly because many of the discarded items had been personally accumulated by the art
teachers outside of normal procurement channels.
Survey Techniques, Results, and Trends
Lead Wipe Samples
Lead wipe samples were collected in accordance with ASTM E1728, “Standard Practice
for Field Collection of Settled Dust Samples Using Wipe Sampling Methods for Lead
Determination by Atomic Spectrometry Techniques.” Samples were collected on ASTM E1792
compliant Environmental Express “Ghost Wipe“ lead wipes. Wipe samples were analyzed by
flame atomic absorption spectroscopy, EPA Method SW846 (7420), by laboratories accredited
under the Environmental Lead Laboratory Accreditation Program (ELLAP).
The goal of wipe sampling was to determine the extent to which the art rooms were
contaminated. If portions of an art room could be clearly identified as not contaminated, then it
would not be necessary to decontaminate the entire room. Accordingly, more wipe samples were
collected during the initial investigation of the art rooms than would typically be collected during
a lead paint hazard assessment or post-abatement clearance. Depending upon the size and use of
the room, as few as five or as many as 26 samples were collected in each art room, with an
average count of 19 wipe samples per room (includes blanks).
Wipe samples were collected in the following locations
Floors
Horizontal working surfaces (tables, desks, counters, etc.)
Storage shelves & cabinets
Elevated horizontal surfaces (tops of wall cabinets, bookcases, etc)
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Kilns & Associated Exhaust Hoods
Ventilation Systems
This sampling strategy generated enough data to allow portions of 14 of the 18 art rooms
to be excluded from the decontamination process. Examples of sample data collected from a
high school, a middle school, and an elementary school are included in Attachments 2, 3, and 4,
respectively.
Results and Trends
Liquid Glaze Storage Areas The highest levels of contamination were identified on
horizontal surfaces in liquid glaze storage areas. Not surprisingly, storage areas with visible
accumulations of dried glaze returned higher results, with the highest storage area returning
results of 68,000 ug/ft2.
LEAD CONTAMINATION IN GLAZE STORAGE AREAS (16 ART ROOMS)
Contamination Level Number of Areas
Less Than 40 ug/ft2 1
40 ug/ft2 to 500 ug/ft2 6
500 ug/ft2 to 1,000 ug/ft2 1
1,000 ug/ft2 to 10,000 ug/ft2 6
10,000 ug/ft2 to 68,000 ug/ft2 2
Contamination in glaze storage areas proved to be remarkably persistent. One middle
school art room evaluated during this study had been occupied by the same teacher for over
fifteen years. This teacher had stopped using the ceramic arts kiln shortly after she moved into
the room because the dust from the kiln aggravated her allergies. Modeling clay and paint were
substituted for ceramic clay and glaze, and the kiln-fired ceramic art materials were discarded.
Over the years this room had been partially remodeled, with new paint and floor covering, but
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the original wall cabinets remained in place. The only sample in this room to return results
greater than 40 ug/ft2 was collected in one of these cabinets at a location where ceramic art gazes
would likely have been stored. The contamination level in this cabinet was 2,500 ug/ft2.
A similar situation was observed at a nearby elementary school. The art teacher at that
school had moved in five years earlier and discarded all materials that were either hazardous or
in unmarked containers. Two years after that the entire room was remodeled except for the
inside of the storage closets. A wipe sample collected from the glaze storage shelf, which at the
time contained only lead-free glazes, returned results of 1,300 ug/ft2. All other surfaces in that
room returned result near or below the 10 ug/ft2 detection limit.
It also appears that contamination builds up quickly in glaze storage areas. Three of the
art rooms evaluated during this study were in a new elementary school that was placed in service
only eight months earlier. The glaze storage cabinets in these rooms returned wipe sample
results of 20, 59, and 370 ug/ft2.
Art Storage Areas After the glaze storage areas, the areas with the most contamination
were locations where ceramic art work was dried, cooled and stored while work was in progress.
Many of these were purpose-built drying cabinets, with difficult to clean mesh sides and
tempered pegboard shelves designed to enhance airflow around the artwork. Contamination in
these areas ranged from below the 10 ug/ft2 detection limit on open storage shelves in a new (less
than one year old) art room to 4,900 ug/ft2 in an older drying/cooling cabinet in a high school art
room.
LEAD CONTAMINATION IN DEDICATED CERAMIC ART
COOLING AND TEMPORARY STORAGE AREAS (12 ART ROOMS)
Contamination Level Number of Areas
Less Than 40 ug/ft2 2
40 ug/ft2 to 100 ug/ft2 2
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100 ug/ft2 to 500 ug/ft2 9
500 ug/ft2 to 1,000 ug/ft2 2
1,000 ug/ft2 to 4,900 ug/ft2 3
Kilns Results from wipe samples collected from within the kilns were inconsistent. Part
of this inconsistency can be attributed to the nature of the refractory materials used within the
kiln, which present a difficult surface from which to collect wipe samples. Another part of this
inconsistency was the sampling sites selected by the inspector. Samples within the kilns were
initially collected from the horizontal surface on the bottom of the kilns, which the inspector
assumed to be the most likely surface to be contaminated. This assumption turned out to be
incorrect because ceramic art is placed on a series of moveable shelves that are stacked vertically
within the kiln, so any glaze shed by the artwork falls upon the shelves rather than the floor of
the kiln. Based upon this information, the inspector started collecting samples from the inside
walls of the kilns to detect lead that may have volatilized and contaminated the kiln walls.
The results of the samples collected from the kiln walls were more consistent from kiln to
kiln, and were generally higher than those collected from the floors of the kilns. The floors of
three kilns returned results below detection limits and one very old kiln returned a floor
contamination result of a 450 ug/ft2, with four other kilns returning an average floor
contamination level of approximately 45 ug/ft2. The average contamination level detected on the
walls of six other kilns was approximately 76 ug/ft2, with results ranging from 16 to 120 ug/ft2.
Contamination levels on the exterior top surfaces of kilns varied in direct proportion to
the age of the kilns. These levels ranged from a low of 10 ug/ft2 on a kiln that was less than two
years old a high of 3,100 ug/ft2 on a kiln that had been in use for more than 25 years.
The newer kilns were equipped with direct ventilation systems that transport air directly
from the kiln to an exhaust location outside of the building. Most of the older kilns were located
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under ventilation hoods. One kiln considered during this study was located in a boiler room and
was provided with no specific ventilation equipment.
The inside potions of direct ventilation systems are not normally accessible to building
occupants and were not considered during this survey. Samples collected from the underside of
the exhaust hoods returned results from below detection limits to 1000 ug/ft2, with no apparent
trend related to the age or use of the kilns. It is possible that variations in custodial practices
caused the variations in contamination levels.
Working Surfaces
Working Surfaces Working surfaces included desks, tables, and counter tops.
Contamination on these surfaces was directly related to the location of the surface and the
activities that took place on the surface. The highest contamination levels were found on
working surfaces adjacent to glaze storage areas, typically countertops on base cabinets located
under glaze storage wall cabinets. Elevated levels were also observed on working tables where
glazes were applied, but at lower levels than might be expected, presumably because these
surfaces are routinely cleaned. However, most of the working surfaces in the classrooms were
well below 40 ug/ft2, also a likely result of routine cleaning activities.
LEAD CONTAMINATION ON WORKING SURFACES (18 ART ROOMS)
Contamination Level Number of Surfaces
Less than 10 ug/ft2 26
10 ug/ft2 to 40 ug/ft2 12
40 ug/ft2 to 100 ug/ft2 3
100 ug/ft2 to 500 ug/ft2 6
500 ug/ft2 to 1,000 ug/ft2 1
1,000 ug/ft2 to 3,200 ug/ft2 3
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Floors Floor contamination also varied by location. The highest contamination levels
were found on floors adjacent to glaze storage areas, with one area in front of open glaze storage
shelves returning results of 18,000 ug/ft2. The next highest levels of contamination were
identified on floors adjacent to kilns, the highest of which returned results of 450 ug/ft2.
Floor contamination in other areas of elementary and middle school art rooms was below
40 ug/ft2. However, both of the ceramic-intensive high school art rooms considered during this
study had prevailing floor contamination levels above 40 ug/ft2.
LEAD CONTAMINATION ON FLOORS (18 ART ROOMS)
Contamination Level Number of Locations
Less than 10 ug/ft2 37
10 ug/ft2 to 40 ug/ft2 13
40 ug/ft2 to 100 ug/ft2 15
100 ug/ft2 to 500 ug/ft2 8
500 ug/ft2 to 1,000 ug/ft2 1
1,000 ug/ft2 to 18,000 ug/ft2 2
Ventilation Systems Most of the rooms evaluated during this study were equipped with
unit ventilators. The two high schools were equipped with centralized air handling systems.
Both types of systems were approached in the same manner - return air components were tested
for lead contamination and further investigation was conducted only if these components were
contaminated in excess of 40 ug/ft2. None of the unit ventilators indicated return air component
contamination in excess of 40 ug/ft2, but one of the high school return air ducts did.
All of the high school art rooms considered during this study had been completely
renovated within the previous three years. Two of the renovated art rooms had been equipped
with completely new HVAC systems. The third room was upgraded with new distribution
equipment that was tied into the existing circa 1970 HVAC system. Wipe samples collected
within the old HVAC trunks leading to and from the art room indicated lead contamination
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levels from 230 to 5,200 ug/ft2 in the return air system and 310 to 910 ug/ft2 in the supply air
system.
There were no records or other indication that these ducts have been cleaned since they
were installed in 1970. The dirt in these ducts is a sticky black substance that is adhered to the
inside surfaces of the ducts. It is quite possible that the lead dust trapped within this dirt could
remain there indefinitely until disturbed by some outside force. Nevertheless, the air handling
system serving this art room and adjacent rooms in the fine arts wing was shut down as a
precautionary measure until the ducts can be properly decontaminated.
Testing of local exhaust ventilation systems was limited to portions of the systems, such
as intake grills, that could be contacted by the occupants. Contamination inside of the local
exhaust systems was not an issue because dust from these systems is unlikely to work its way
back into occupied portions of the room.
Elevated Surfaces Elevated surfaces were sampled to provide insight into the extent of
the art room contamination. Surfaces such as the tops of storage cabinets, light fixtures, and
bookcases are generally not included in routine cleaning, and can add a historical perspective to
the sample results. Contamination in these elevated, out of the way areas suggests a history of
widespread contamination and a need for a wall-to-wall, top-to-bottom decontamination.
In most cases, contamination levels on elevated surfaces reflected contamination levels
elsewhere in the room, that is, rooms with generally high levels of contamination on floors,
working surfaces, and storage areas had high levels of contamination on elevated surfaces, and
vice-versa. The high school art rooms with intensive ceramic art programs returned elevated
surface contamination results from 61 to 370 ug/ft2. A middle school art room with a 25 year
history of ceramic arts work returned an elevated surface contamination result of 92 ug/ft2.
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Roll-Around Carts Roll-around carts were identified in four elementary school art
rooms. Wipe samples collected from the shelves of these carts returned results of 96, 200, 880,
and 1,500 ug/ft2. These shelves had been used for temporary storage of in-progress ceramic art
work, and the contamination profiles were similar to those in the fixed ceramic art storage areas.
It is interesting to note that the cart that returned results of 880 ug/ft2 had been placed in service
only eight months earlier in a completely new elementary school.
Other Metals
The first art room considered during this study was evaluated before the Connecticut
DPH issued their advisory, so hazard evaluation protocols were developed to address all of the
potential hazards presented by ceramic art glaze contamination. The glaze of concern in this art
room contained both lead and cadmium, so both metals were included as analytes of interest in
the wipe samples. A level of 145 ug/ft2 was selected as the trigger level for cadmium
contamination, based upon the 1,560 ug/m2 “Health-Based Benchmark” proposed by the EPA’s
World Trade Center Contaminants of Potential Concern committee.
None of the wipe samples collected in this art room returned cadmium results in excess
of 145 ug/ft2. However, cadmium contamination tended to follow the trend of lead
contamination, with the areas of highest lead contamination having the highest cadmium
contamination. The sample data from this art room is shown in Attachment 4.
The DPH advisory did not consider contaminants other than lead, so response activities
initiated in response to that advisory were limited to issues of lead contamination. However, the
correlation that was observed between lead and cadmium contamination levels in this one
classroom suggests that decontamination activities suitable for reducing lead levels to below 40
ug/ft2 will also reduce cadmium contamination to levels well below the health-based benchmark.
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Lead Abatement Plans
The Connecticut Childhood Lead Poisoning Prevention and Control regulations
implement abatement activities in child-occupied housing through lead abatement plans. These
plans are developed by a licensed “Lead Planner Project Designer” and are submitted to Local
Health Department (LHD) for review and approval.
The DPH advisory recommended a similar approach for the lead abatement plans
developed for art rooms. This approach expedited the planning and approval process by taking
advantage of the personnel and procedure infrastructure already in place for the childhood lead
poisoning program.
All of the abatement plans developed for this project identified the extent of the
decontamination work area and specified the following activities within that area:
Decontaminate all surfaces in the work area up to and including the top of the
highest horizontal surface in these areas.
Decontaminate all furnishings and other items within the work area
Dispose of items within the work area that cannot readily be decontaminated
Relocate decontaminated furnishings and other decontaminated items to
temporary storage provided by the Contractor
The plans also specified decontamination methods, clearance procedures, and waste
management requirements that are described in detail in the following section.
Abatement Techniques
Work Area Preparation
Because all items and surfaces within the defined abatement areas were presumed to be
contaminated with lead, preparing the abatement work areas was a simple matter of isolating
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them from adjacent areas. Ventilation systems were shut down, and systems that did not require
cleaning were sealed with two layers of plastic sheeting. Openings to the work areas were sealed
with plastic sheeting and posted with lead warning signs. Access to the work areas was via a
two-chamber “change area” constructed and operated in accordance with OSHA regulations.
Decontamination Procedures
As described earlier in this paper, the basic operating principle was to decontaminate
items that could readily be decontaminated, and to discard those that could not. Items that could
not readily be decontaminated were packaged for disposal in clear, leak-tight, six-mil
polyethylene bags.
Most of the items decontaminated during these projects were non-porous items such as
chairs, jars, tools, and equipment. These items were cleaned using HEPA vacuums and wet
cleaning. Porous items deemed worth saving were cleaned using HEPA vacuums only.
A clearance standard of 40 ug/ft2 demands methodical decontamination and a constant
awareness of the potential for cross-contamination. The abatement contractors devised processes
by which contaminated items were moved progressively from the most contaminated areas to the
least contaminated areas as they were cleaned, with the final cleaning taking place in an area
immediately adjacent to the change area. Rags used for wet cleaning were not rinsed and re-
used, but were discarded after each clean surface of the rag had been used once.
One of the abatement supervisors used glass windows to train his crew on a three-step
decontamination process. A backlighted window was first cleaned with a rag soaked in a
trisodium phosphate solution to remove the grime, then rinsed with a rag soaked in clear water,
and then wiped dry with a dry rag. After demonstrating the effectiveness of this three-stage
process, the supervisor challenged the workers to achieve the same results using only two of the
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three steps. By the end of the demonstration the workers were not only proficient in this three-
stage cleaning process, but were also convinced that this was the most expedient way to achieve
the “no visible dust, dirt, debris, or residue” standard for the final visual inspection.
Clearance Procedures
The lead abatement plan places the responsibility for the first visual inspection upon the
abatement supervisor. After decontaminated items passed the supervisor’s inspection, they were
placed on trays and moved through the change area to a well-lit inspection area immediately
adjacent to the change area. At this area the consultant inspected the decontaminated items to
make sure that they were free of visible dust, dirt, debris, and residue. Items that failed to meet
these criteria were returned to the work area for additional cleaning or set aside for further
evaluation of their value.
Representative post-abatement wipe samples were collected from items that met the
clearance criteria. Examples of post abatement wipe samples collected from articles
decontaminated and removed from a high school art room are included in Attachment 5.
Cleared items were placed in temporary storage pending laboratory analysis of the wipe
samples. Temporary “roll-off” closed-top storage containers were provided for this purpose at
most sites. Roll-off containers previously used to transport waste materials were lined with
plastic sheeting to avoid contamination of the items in storage.
Similar clearance procedures were applied to the inside of the abatement area. All
surfaces were inspected first by the abatement supervisor and then by the consultant to make sure
that they were free of visible dust, dirt, debris, and residue. The consultant then collected post-
abatement wipe samples in locations similar to those sampled during the pre-abatement
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Page 23 of 28
inspection. Examples of post abatement wipe samples collected from surfaces and equipment
within a high school art room are included in Attachment 6.
Waste Management
Waste Segregation
It was anticipated that the vast majority of the waste generated by the work would not
demonstrate the lead toxicity characteristic of “hazardous waste.” Accordingly, waste streams
were segregated as follows in order to minimize the volume of material that had to be discarded
as “hazardous waste”:
Lead-Bearing Ceramic Art Materials
Cleaning Rags, Protective Clothing, and Highly Contaminated Discarded Items
Lightly Contaminated Discarded Items
Waste Packaging
Lead-bearing ceramic art materials were packaged in leak-tight, metal 55-gallon drums
labeled in accordance with EPA and DEP regulations. Cleaning rags, protective clothing, and
highly contaminated discarded items were also packaged in this manner.
Lightly contaminated discarded items made up the vast majority of waste from these
projects. These items were packaged in clear, leak-tight, six-mil polyethylene bags labeled,
“DEBRIS FROM ART ROOM– ON HOLD PENDING LAB RESULTS.”
Packaged waste materials were placed in secure storage pending the results of waste
characterization samples.
Waste Characterization
Lead-bearing ceramic art material were identified as “hazardous waste” based upon
information available from product labels and material safety data sheets. These materials were
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Page 24 of 28
inventoried by product name and profiled as liquid waste containing lead, cadmium, copper,
cobalt, lithium and/or manganese. An example of ceramic art material waste inventory is shown
in Attachment 7.
Other materials in the waste stream were characterized by collecting representative
samples for analysis by the Toxicity Characteristic Leaching Procedure (TCLP). Of the 31
TCLP samples collected from barrels containing cleaning rags, protective clothing, and highly
contaminated items, only two returned results greater than the “hazardous waste” limit of 5.0
milligrams of lead per liter of leachate solution (5.0 mg/l). None of the 18 TCLP samples
collected from the “lightly contaminated” bagged waste returned results of 5.0 mg/l or greater.
Example TCLP sample data from a high school art room decontamination project is shown in
Attachment 8.
Waste materials returning TCLP results of less than 5.0 mg/l lead were released for
disposal as ordinary municipal waste. This lead to an interesting situation at several schools
where the art teachers asked if they could salvage discarded art materials that had “passed the
lead test.” Additional efforts were required to explain to the teachers and administration that
even though most of the waste from the decontamination work was not "hazardous waste" in
accordance with waste disposal regulations, it was nevertheless contaminated with small
amounts of lead and was not suitable for salvage.
Kiln and Kiln Accessory Considerations
Kiln Refractory Materials
The DPH advisory identified kilns as an area of concern, and recommended contacting
kiln manufacturers to determine how to clean refractory materials in kilns that had been used to
fire lead-bearing ceramic art glaze. Four kiln manufacturers were contacted for their cleaning
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Page 25 of 28
recommendations. None had refractory material cleaning recommendations per se, but two of
the manufacturers recommended prolonged maximum-temperature firing of the empty kiln under
conditions of maximum ventilation. Any lead remaining in the kiln after these conditions would
presumably be fused with the refractory materials and unlikely to re-emerge under normal
operating conditions. One of the kiln manufacturers recommended vacuuming after the high-
temperature firing.
Kiln Accessories
The capacity of the kilns is increased through the use of movable shelves stacked in
vertical layers. These shelves are stacked on square cross-section hollow legs called shelf
supports. Items to be fired are elevated from the shelves with a variety of stands, stilts, and
triskelion-shaped “triangles.” All of these accessories are fabricated from refractory materials,
and many are small and have complicated shapes. These features made kiln accessories difficult
to decontaminate, and, much to the chagrin of the art teachers, many of the smaller stands, stilts,
and triangles were simply discarded as a cost-effective alternative to decontamination.
Re-Contamination Considerations
Three ceramic art glaze manufacturers were contacted during the course of the art room
decontamination projects to determine what is meant by the term “lead free” when used to
describe ceramic art glazes. Several different answers were offered, but the only universally
agreed-upon answer was that "lead-free” means that the manufacturer does not intentionally
introduce lead into the glaze.
These intentions notwithstanding, testing by other parties (Stopford, unpublished data)
indicates that glazes marked as "lead-free" may contain up to 34.6 parts per million of lead. At
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Page 26 of 28
34.6 ppm lead, a 16 fluid ounce jar of glaze (which weighs about 800 grams) will contain about
0.028 grams, or 28,000 micrograms, of lead.
This lead in "lead-free" glaze can be problematic in two areas. First, dried glaze on the
outside of the glaze jars readily crumbles to powder and can easily cause local contamination
over 40 micrograms per square foot. Second, some of the available lead in the glaze will
volatilize during the firing process and may contaminate interior surfaces of the kiln.
The potential for lead contamination when using “lead free” glazes significantly changed
the expectations for the decontamination projects. The assumption that lead contamination
would cease to be a problem at the completion of the decontamination projects was now
questionable.
This change in expectations led to a change in kiln decontamination practices. There is
little point in discarding kilns and kiln accessories that cannot be decontaminated to less than 40
micrograms per square foot, only to have the contamination return a year later from using “lead
free” glazes. Instead, IH&SC developed a set of kiln use recommendations designed to
minimize lead contamination from ceramic art activities and to minimize the risk to occupants
from any lead contamination that may be inevitable. These recommendations are reproduced in
Attachment 9. Further recommendations for controlling exposures in a ceramic studio can be
found in the Safety Appendix to the American Society for Testing and Materials Standard
Practice C1023, Labeling Ceramic Art Materials for Chronic Adverse Health Hazards (ASTM,
2006)
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Page 27 of 28
Trigger Levels and Clearance Standards
The DPH advisory specified the EPA’s lead dust hazard level 40 ug/ft2 as the trigger
value to initiate decontamination activities and as the clearance standard to determine the
efficacy of decontamination activities. This hazard level was promulgated by the EPA in 2001
(EPA, 2001) as required by the Residential Lead-Based Paint Hazard Reduction Act of 1992, and
applies to all federal agencies that own residential property and all property owners that receive
assistance through federal housing programs. This hazard level has also been adopted by many
states, including Connecticut, as the standard for state childhood lead poisoning and prevention
programs
Presumably, the Connecticut DPH used the 40 ug/ft2 hazard level because no other lead
dust contamination standard was available. It is important to note, however, the EPA hazard
level was developed for residential dwellings occupied by children under six years old, with a
specific target population of children aged one to two years (Lead; Identification of Dangerous
Levels of Lead; Final Rule. 66 FR 4, 01/05/2001). This setting and target population is
significantly different than public school art rooms occupied by adults and older children. It is
difficult to imagine that any health benefit gained from decontaminating the art rooms to the
hazard level established for children from one to two years of age is commensurate with the
effort and expense required to achieve this level.
It should be possible to derive a lead dust contamination limit appropriate for adults and
older children from the EPA hazard level by applying exposure factors that account for age-
specific differences in behavioral factors. Two obvious factors are exposure periods and
ingestion rates. Both of these factors are well documented for the EPA target population and can
be readily calculated for any other population. A preliminary study of this topic by William Rath
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Page 28 of 28
suggests that application of these two exposure factors would support an art room lead
contamination standard of 320 ug/ft2. If this limit had been applied in lieu of the 40 ug/ft2 limit
specified by the Connecticut DPH, six of the 18 art rooms inspected during this project would
not have required decontamination. Furthermore, the scope of the decontamination work in nine
of the 12 remaining rooms would have decreased by fifty percent or more. Applying a 320 ug/ft2
limit would have saved each of the two school systems tens of thousands of dollars that were
spent to decontaminate art rooms and replace discarded materials and supplies.
Conclusions
Lead-bearing ceramic art glazes can cause significant and persistent lead contamination
in art studios and classrooms.
Lead contamination in art classrooms can be reduced to 40 ug/ft2 or less using standard
decontamination methods
Trace amounts of lead in “lead free” ceramic art gazes have the potential to contaminate
kilns and other art classroom surfaces
Adverse health effects from lead-bearing art materials can be minimized by following the
ASTM Guidelines for the Safe Use of Hobby Ceramic Art Materials.
Age and activity appropriate lead dust contamination standards should be derived
whenever the EPA lead dust hazard level of 40 ug/ft2 is contemplated for use for
populations other than children under six years of age in residential dwellings.
References
ACGIH. TLVs and BEIs. Threshold Limit Values for Chemical Substances and Physical Agents.
Cincinnati, OH, 2001.
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Page 29 of 28
American Art Clay Company, Inc. Material safety data sheet, Lead / cadmium gloss glazes,
Product code: LG series. 2005. Indianapolis, IN.
American Society for Testing and Materials, Safety Appendix to Standard Practice C1023,
Labeling Ceramic Art Materials for Chronic Adverse Health Hazards. 2006.
http://duketox.mc.duke.edu/recenttoxissues.htm
Duncan Enterprises. Material safety data sheet, Leaded ceramic glaze. 2005. Fresno, CA:
Goldwater, LJ, Wysocki, LM, Volpe, RA, eds. Edited Proceedings: Lead Environmental Health -
The Current Issues. May 29 - 30, 1985, Duke University. Published by Division of Occupational
Medicine, Duke University, Durham, North Carolina, USA.
Rath WR. Identifying lead dust contamination limits appropriate for adults and older children.
2006. http://duketox.mc.duke.edu/recenttoxissues.htm
Roberge RJ, Martin TG, Dean BS, Lasek RW. Ceramic lead glaze ingestions in nursing home
residents with dementia. Am J Emerg Med. 1994 Jan;12(1):77-81.
Stopford W. Safety of lead-containing hobby glazes. North Carolina Medical Journal, 1988; 49:
31-34.
Stopford W., Stanion CV. Lead Contamination in Contemporary Ceramics Studios:
Potential for Community and Worker Exposure. Research Report Submitted to the American
Society for Testing and Materials in Support of Test Method C1023, Labeling of Ceramic
Materials for Chronic Health Hazards, 1998. http://duketox.mc.duke.edu/recenttoxissues.htm
U.S. Environmental Protection Agency. Lead; Identification of Dangerous Levels of Lead; Final
Rule. Washington, DC: 66 FR No. 4, 1206-40. Jan. 5, 2001. Codified at 40 CFR Part 745.
http://duketox.mc.duke.edu/recenttoxissues.htmhttp://duketox.mc.duke.edu/recenttoxissues.htmhttp://www.ncbi.nlm.nih.gov/entrez/query.fcgi?db=pubmed&cmd=Retrieve&dopt=AbstractPlus&list_uids=8285980&query_hl=5&itool=pubmed_docsumhttp://duketox.mc.duke.edu/recenttoxissues.htm
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ATTACHMENT 1
CT DPH ADVISORY ”USE OF LEADED CERAMIC GLAZES IN SCHOOL ART CLASSES”
Page 1 of 3
-
ATTACHMENT 1
CT DPH ADVISORY ”USE OF LEADED CERAMIC GLAZES IN SCHOOL ART CLASSES”
Page 2 of 3
-
ATTACHMENT 1
CT DPH ADVISORY ”USE OF LEADED CERAMIC GLAZES IN SCHOOL ART CLASSES”
Page 3 of 3
-
ATTACHMENT 2
PRE-ABATEMENT LEAD WIPE SAMPLE DATA FROM A HIGH SCHOOL ART ROOM
SAMPLE
LOCATION WIPE
AREA (IN2) RESULT (UG/FT2)
Page 1 of 2
XXHS-0413-00 FIELD BLANK (RESULTS ARE IN MICROGRAMS PER WIPE) N/A
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ATTACHMENT 2
PRE-ABATEMENT LEAD WIPE SAMPLE DATA FROM A HIGH SCHOOL ART ROOM
SAMPLE
LOCATION WIPE
AREA (IN2) RESULT (UG/FT2)
Page 2 of 2
XXHS-0413-20 STORAGE ROOM, VCT FLOOR, CENTER OF ROOM 144 92.0
XXHS-0413-21 STORAGE ROOM, PAINTED METAL SHELF, WEST SIDE SHELVES, SECOND SHELF FROM BOTTOM
144 42.0
XXHS-0413-22 KILN ROOM, VCT FLOOR IN FRONT OF KILN 144 450.0
XXHS-0413-23 KILN ROOM, PAINTED METAL SHELF, POTTERY STORAGE SHELVES IN SOUTHEAST CORNER, BOTTOM SHELF
144 300.0
XXHS-0413-24 KILN ROOM, EXHAUST DUCT GRILL (NOTE: THE “AREA” RECORDED FOR THIS SAMPLE IS THE GROSS AREA OF THE RETURN AIR GRILL. BECAUSE THIS GRILL IS MOSTLY OPEN SPACE, THE ACTUAL AREA OF THE SURFACE THAT WAS WIPED IS SIGNIFICANTLY LESS.)
441 130.0
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ATTACHMENT 3
PRE-ABATEMENT LEAD WIPE SAMPLE DATA FROM A MIDDLE SCHOOL ART ROOM
SAMPLE
LOCATION WIPE
AREA (IN2) RESULT (UG/FT2)
Page 1 of 2
XXMS-0413-00 FIELD BLANK (RESULTS ARE IN MICROGRAMS PER WIPE) N/A
-
ATTACHMENT 3
PRE-ABATEMENT LEAD WIPE SAMPLE DATA FROM A MIDDLE SCHOOL ART ROOM
SAMPLE
LOCATION WIPE
AREA (IN2) RESULT (UG/FT2)
Page 2 of 2
XXMS-0413-20 ART ROOM 103 STORAGE ROOM/DARKROOM, VCT FLOOR, CENTER OF ROOM
144 57.0
XXMS-0413-21 ART ROOM 103 STORAGE ROOM/DARKROOM, LAMINATE PANEL, TOP OF UNIT VENTILATOR
136
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ATTACHMENT 4
PRE-ABATEMENT LEAD & CADMIUM WIPE SAMPLE DATA FROM AN ELEMENTARY SCHOOL ART ROOM
SAMPLE
LOCATION WIPE AREA (IN2)
LEAD (UG/FT2)
CADMIUM (UG/FT2)
Page 1 of 1
XXES-0328-01 VCT FLOOR, CENTER OF ART ROOM 144
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ATTACHMENT 5
POST-ABATEMENT LEAD WIPE SAMPLE DATA ITEMS DECONTAMINATED AND REMOVED FROM A HIGH SCHOOL ART ROOM
SAMPLE
LOCATION WIPE
AREA (IN2) RESULT (UG/FT2)
Page 1 of 3
XXHS-0517-06 VINYL COVER OF 3-RING BINDER, “GLAZE BOOK BY DENNIS ROCCHIO”, DECONTAMINATED AND REMOVED FROM ROOM B116
121
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ATTACHMENT 5
POST-ABATEMENT LEAD WIPE SAMPLE DATA ITEMS DECONTAMINATED AND REMOVED FROM A HIGH SCHOOL ART ROOM
SAMPLE
LOCATION WIPE
AREA (IN2) RESULT (UG/FT2)
Page 2 of 3
XXHS-0519-05 MISCELLANEOUS PLASTIC BOTTLES AND JARS, DECONTAMINATED AND REMOVED FROM B 116
32 OZ, “MODGE PODGE” MATTE
16 OZ. CRAYOLA TEMPURA
8 OZ. LEAK DETECTOR
179
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ATTACHMENT 5
POST-ABATEMENT LEAD WIPE SAMPLE DATA ITEMS DECONTAMINATED AND REMOVED FROM A HIGH SCHOOL ART ROOM
SAMPLE
LOCATION WIPE
AREA (IN2) RESULT (UG/FT2)
Page 3 of 3
XXHS-0520-05 OUTSIDE SURFACES OF SMALL (8-INCH DIAMETER) TABLE-TOP KILN (ONE OF TWO), DECONTAMINATED AND REMOVED FROM ROOM B 116
71
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ATTACHMENT 6
POST-ABATEMENT LEAD WIPE SAMPLE DATA HIGH SCHOOL ART ROOM INTERIOR SURFACES AND EQUIPMENT
SAMPLE
LOCATION WIPE
AREA (IN2) RESULT (UG/FT2)
Page 1 of 1
XXHS-0522-02 BUTCHER BLOCK TABLE TOP, NORTH WORK TABLE ON EAST SIDE
144 12.0
XXHS-0522-03 WOOD TOP, STORAGE BIN CABINET NEAR KILN ROOM DOOR 144
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ATTACHMENT 7
HIGH SCHOOL ART ROOM CERAMIC ART GLAZE WASTE INVENTORY
Page 1 of 1
INVENTORY OF LIQUID CERAMIC GLAZES IN WASTE BARREL #1
ACCORDING TO THE MANUFACTURERS’ LABELS ON THE CONTAINERS, THESE LIQUID GLAZES CONTAIN LEAD, CADMIUM, COPPER, COBALT, LITHIUM AND/OR MANGANESE
MANUFACTURER PART
NUMBER COLOR
JAR SIZE (FL. OZ.)
NO. OF JARS
AMACO LG 2 BLACK 16 1
AMACO LG 53 FLAME 16 4
AMACO LG 133 PINKISH BROWN 16 3
AMACO LT 24 ANTIQUE BLUE 16 5
AMACO LT 48 MOSS AGATE 16 2
AMACO LT 113 SAND 16 2
AMACO LT 115 FROSTED JADE 16 4
AMACO LT 122 DARK BLUE 16 2
AMACO LT 142 ANTIQUE GREEN 16 7
DUNCAN GL 610 CLEAR DIPPING GLAZE (ONE 5-GALLON BUCKET)
640 1
DUNCAN GL 612 TRANSPARENT GLOSS GLAZE (FIVE 1-GALLON JUGS)
128 5
DUNCAN GL 632 TANGERINE 16 1
DUNCAN GO 134 CALYPSO RED 16 1
MAYCO AG 251 BLACK BEAUTY 16 1
MAYCO CG 721 CANDY CANE 16 1
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ATTACHMENT 8
HIGH SCHOOL ART ROOM TCLP SAMPLE DATA
SAMPLE
MATERIAL
LOCATION
ANALYTE RESULT (MG/L)
Page 1 of 2
XXHS-01 REPRESENTATIVE SAMPLES OF THE FOLLOWING MATERIALS IN BAGGED WASTE:
ARTIST’S CRAYONS
CANVAS
CHALK
CLAY DEBRIS, DRIED
CLAY DEBRIS, FIRED
CLAY DEBRIS, GREEN
CLAY PALLETS, FIBERBOARD
CLAY PALLETS, MASONITE
CLAY TOOLS
COLORED PENCILS
CORD
CORRUGATED CARDBOARD
DECORATING WHEEL – METAL
DINING UTENSILS, PLASTIC
DOWELS, WOOD
ERASERS
EXPANDED POLYSTYRENE “PEANUTS”
FABRIC
KRAFT PAPER COVERED WITH SPILLED PAINT
LATEX GLOVES
NEWSPAPERS
PAINTER’S PALETTE, CARDBOARD
PLASTER MIXING TUB, PLASTIC
RAWHIDE
REFRACTORY BRICK
SANDPAPER
SPONGE MOP HEAD
SPONGE PACKING
SPONGES
STRING
TRAYS, PLASTIC
WORK GLOVES
BAGGED WASTE
LEAD 1.0
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ATTACHMENT 8
HIGH SCHOOL ART ROOM TCLP SAMPLE DATA
SAMPLE
MATERIAL
LOCATION
ANALYTE RESULT (MG/L)
Page 2 of 2
XXHS-02 REPRESENTATIVE SAMPLES OF THE FOLLOWING MATERIALS IN BARREL #2:
CARPET FROM FRONT OF SINKS
CLEANING RAGS
CLOTH APRON
SPONGE MOP HEAD (DIRTY)
BARREL # 2 LEAD 0.99
XXHS-03 REPRESENTATIVE SAMPLES OF THE FOLLOWING MATERIALS IN BARREL #3:
CLEANING RAGS
DIP-GLAZE DRUMS (PLASTIC)
PAINTBRUSHES
BARREL # 3 LEAD 0.073
XXHS-04 REPRESENTATIVE SAMPLES OF THE FOLLOWING MATERIALS IN BARREL #4:
CLEANING RAGS
COVERALLS (DISPOSABLE SPUN FABRIC)
BARREL # 4 LEAD 0.30
XXHS-05 REPRESENTATIVE SAMPLES OF THE FOLLOWING MATERIALS IN BARREL #5:
CLEANING RAGS (CLOTH)
CLEANING RAGS (PAPER)
KILN STILTS (BROKEN)
BARREL # 5 LEAD 0.18
XXHS-06 REPRESENTATIVE SAMPLES OF THE FOLLOWING MATERIALS IN BARREL #6:
CLEANING RAGS (CLOTH)
CLEANING RAGS (PAPER)
BARREL # 6 LEAD 0.55
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ATTACHMENT 9
RECOMMENDATIONS FOR KILN OPERATIONS
Page 1 of 1
RECOMMENDATIONS FOR KILN OPERATIONS
During the course of our study of kiln contamination issues, IH&SC contacted four kiln manufacturers, the Edward Orton Jr. Ceramic Foundation, the Art & Creative Materials Institute, Inc. (ACMI - the people that provide the standards for the safety labels on art materials), and the American Society for Testing & Materials (ASTM). Based upon our interviews with these organizations, we have developed the following ceramic art operations guidelines that will minimize lead contamination and minimize the risk from the contamination that may be inevitable, even when using “lead-free” glazes: 1. Before resuming glazing operations, operate the kiln at maximum temperature
for two hours with downdraft ventilation, followed by a normal cool-down 2. HEPA vacuum the inside of the kiln to remove all dust and debris (note that kiln
manufacturers recommend vacuuming the kiln after every firing to minimize dust that could adversely affect the finished product)
3. Always operate the kiln and kiln ventilation system in strict accordance with the
manufacturer’s instructions 4. Use only "lead free" glazes marked "AP Non-Toxic" 5. Relocate the kilns that are within classrooms to separate rooms that are not
routinely occupied by students 6. Follow the ASTM "Guidelines for the Safe Use of Hobby Ceramic Art Materials" 7. Conduct a follow-up evaluation after six months of use to verify the
implementation and effectiveness of these guidelines.