Hi Monona,

Based on years training others in the lead poisoning prevention field in Maine, collecting wipe samples at an e-waste facility as well as at a light manufacturing facility with lead solder used (and elsewhere), this course ranks up there among some of the worst ideas in high school curricula.  My advice is as the saying goes, "Don't bring a knife to a gun fight." 

Forget trying to use reg's and compliance - GA EPA already bowed out and as you said, OSHA doesn't apply to students (and the reg's aren't the most effective persuasion tools). 

Instead, bring out the big guns - tell 'em an affective story (or two or three as needed).  Stories, and especially emotionally laden ones, are well known to be effective convincers.

Construct purpose-told stories (i.e., fiction with a specific goal).  Weave some narrative with them (decision-makers) as characters with your main person as the protagonist.  Some plot points:

• Sending home permission forms for parents/guardians to sign approving their minor child to be exposed to lead, a known teratogen and reproductive toxin (and neurotoxin, ototoxin, nephrotoxin, hepatotoxin, etc.)
  
• No safe level of lead in the body, especially for children/babies and those who may attempt conception, become pregnant, "help" someone have a baby (i.e., a male partner)
  
• Having even just one female student have trouble conceiving, carrying to term, and/or giving birth to a healthy child
• Having at least one female student show a detectable level of lead in her blood - it won't matter how much or where it's from.  Try proving it wasn't from the course
• Detectable lead on surface samples
• What it'll be like at public meetings with outraged parents
• What it'll be like at depositions and in court trying to defend their decisions when you advised them against it

If you need help with story ideas, just chat me up - happy to help prevent lead poisoning.

Good luck!

Jon

Jonathan Klane, M.S.Ed., CIH, CSP, CHMM, CIT

Senior Safety Editor, Lab Manager Magazine

PhD candidate, Human + Social Dimensions of Science + Technology

College of Global Futures

School for the Future of Innovation in Society

On Thu, Jan 26, 2023 at 5:43 PM Monona Rossol <0000030664c37427-dmarc-request**At_Symbol_Here**lists.princeton.edu> wrote:

I really need some advice from all you smart people.  I'm working on the plans for a new building in Georgia.  It is a rather progressive high school.  One of the classes they teach is called engineering and they take old electronics from the 1950s - 2010, break them apart and resolder them into new electronics, games and objects.  They even break into old CRT tubes.  The solders they use are all lead.  These are minors and this is a high-lead activity.

 

I have only run into this once before in a College in California and in that state is it clear you need a license to recycle toxic e-waste and then there must be a risk assessment for the Title 8 CalOSHA Lead Standard.  The college's EH&S department got the license, and we specified vented soldering stations and air monitoring.  The program is doing fine last I heard.

 

But I contacted the GA EPA and they don't have any rules about recycling at this level and it's OK with them.  They suggested I talk to the GA OSHA and that's my next stop. That should be an issue with the OSHA Lead standard.  But those rules only apply to protecting teachers and other employees.  They have no jurisdiction over students.  

Any advice about protecting students would be GREATLY appreciated.    Monona

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