xvEPA
EPA/540/F-98/030
PB98-963244
OSWER Directive #9200.4-27P
August 1998
MEMORANDUM:
OSWER DIRECTIVE:
CLARIFICATION TO THE 1994 REVISED
INTERIM SOIL LEAD (Pb) GUIDANCE FOR
CERCLA SITES AND
RCRA CORRECTIVE ACTION FACILITIES
Office of Solid Waste and Emergency Response
U.S. Environmental Protection Agency
Washington, DC 20460
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NOTICE
This document provides guidance to EPA staff. It also provides guidance to the public and to the
regulated community on how EPA intends to exercise its discretion in implementing the National
Contingency Plan. The guidance is designed to implement national policy on these issues. The
document does not, however, substitute for EPA's statutes or regulations, nor is it a regulation
itself. Thus, it cannot impose legally-binding requirements on EPA, States, or the regulated
community, and may not apply to a particular situation based upon the circumstances. EPA may
change this guidance in the future, as appropriate.
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MEMORANDUM
SUBJECT: Clarification to the 1994 Revised Interim Soil Lead Guidance for CERCLA Sites
and RCRA Corrective Action Facilities
FROM: Timothy Fields, Jr.
Acting Assistant Administrator
TO: Regional Administrators I-X
PURPOSE
This directive clarifies the existing 1994 Revised Interim Soil Lead Guidance for CERCLA Sites
and RCRA Corrective Action Facilities, OSWER Directive 9355.4-12. Specifically, this directive
clarifies OSWER' s policy on (1) using EPA's Science Advisory Board (SAB) reviewed
Integrated Exposure Uptake Biokinetic Model (IEUBK) and blood lead studies, (2) determining
the geographic area to use in evaluating human exposure to lead contamination ("exposure
units"), (3) addressing multimedia lead contamination and (4) determining appropriate response
actions at lead sites. The purpose for clarifying the existing 1994 directive is to promote national
consistency in decision-making at CERCLA and RCRA lead sites across the country.
BACKGROUND
OSWER Directive 9355.4-12, issued on July 14, 1994 established OSWER's current approach to
addressing lead in soil at CERCLA and RCRA sites. The existing directive established a
streamlined approach for determining protective levels for lead in soil at CERCLA sites and
RCRA facilities as follows:
• It recommends a 400 ppm screening level for lead in soil at residential properties;
• It describes how to develop site-specific preliminary remediation goals (PRGs) at
CERCLA sites and media cleanup standards at RCRA Corrective Action facilities for
residential land use; and,
• It describes a strategy for management of lead contamination at CERCLA sites and
RCRA Corrective Action facilities that have multiple sources of lead.
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The existing interim directive provides direction regarding risk assessment and risk management
approaches for addressing soil lead contaminated sites. The OSWER directive states that, "...
implementation of this guidance is expected to provide more consistent decisions across the
country ..." However, since that directive was released, OSWER determined that clarification of
the guidance is needed. Key areas being clarified by issuance of this directive include: (1) using
the IEUBK model and blood lead studies, (2) determining exposure units to be considered in
evaluating risk and developing risk management strategies, (3) addressing multimedia lead
contamination and (4) determining appropriate response actions at residential lead sites. The
existing directive provides the following guidance on these areas:
1. The OSWER directive recommends using the Integrated Exposure Uptake Biokinetic
(IEUBK) Model for Lead in Children (Pub. # 9285.7-15-1, PB93-963510) for setting site-
specific residential preliminary risk-based remediation goals (PRGs) at CERCLA sites and
media cleanup standards (MCSs) at RCRA corrective actions Facilities. The directive
states that the IEUBK model is the best tool currently available for predicting the potential
blood lead levels of children exposed to lead in the environment. OSWER's directive also
recommends the evaluation of blood lead data, where available, and states that well-
conducted blood lead studies provide useful information to site managers. The directive
however recommends that"... blood lead data not be used alone to assess risk from lead
exposure or to develop soil lead cleanup levels."
2. The directive describes OSWER's risk reduction goal as "...generally, OSWER will
attempt to limit exposure to soil lead levels such that a typical (or hypothetical) child or
group of similarly exposed children would have an estimated risk of no more than 5% of
exceeding a 10 ug/dl blood lead level." The directive also states that"... EPA
recommends that a soil lead concentration be determined so that a typical child or group
of children exposed to lead at this level would have an estimated risk of no more than 5%
of exceeding a blood lead of 10 ug/dl." OSWER generally defines an exposure unit as a
geographic area where exposures occur to the receptor of concern during the time of
interest and believes that for a child or group of similarly exposed children, this is typically
the individual residence and other areas where routine exposures are occurring.
3. The directive recommends that risk managers assess the contribution of multiple
environmental sources of lead to overall lead exposure (e.g., consideration of the
importance of soil lead levels relative to lead from drinking water, paint, and household
dust) which promotes development of risk reduction strategies that address all sources
that contribute significantly to exposure.
4. The OSWER directive states that the IEUBK model is not the only factor to be considered
in establishing lead cleanup goals. Rather, the IEUBK model is the primary risk
assessment tool available for evaluating lead risk and the results of the model are used to
guide selection of appropriate risk management strategies for each site.
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Since the OSWER directive was issued in 1994, there has been a trend toward a more consistent
approach to managing risk at residential lead sites, however, OSWER was interested in identifying
areas requiring additional clarification to facilitate more effective implementation of the directive.
As a first step in the process, meetings were held with various EPA Regions, States and local
governments to discuss how the directive has been implemented nationally at lead sites since
1994. By participating in these meetings and by reviewing the decisions that are being made
across the country, OSWER believed that clarification of certain aspects of the 1994 directive
would be useful.
All of the documents and guidance referenced in this directive are available through the National
Technical Information Service (NTIS) at 703-605-6000 or could be downloaded electronically
from: http//epa.gov/superfund/oerr/ini_prod/lead/prods.htm.
OBJECTIVE
At lead contaminated residential sites, OSWER seeks assurance that the health of the most
susceptible population (children and women of child bearing age) is protected and promotes a
program that proactively assesses and addresses risk. OSWER believes that predictive tools
should be used to evaluate the risk of lead exposure, and that cleanup actions should be designed
to address both current and potential future risk.
While health studies, surveys, and monitoring can be valuable in identifying current exposures and
promoting improved public health, they are not definitive tools in evaluating potential risk from
exposure to environmental contaminants. In the case of lead exposure, blood lead monitoring
programs can be of critical importance in identifying individuals experiencing potential negative
health outcomes and directing education and intervention resources to address those risks.
However, CERCLA §121(b) requires EPA to select cleanup approaches that are protective of
human health and the environment and that utilize permanent solutions to the maximum extent
practicable. To comply with the requirements set forth in CERCLA § 121(b), OSWER will
generally require selection of cleanup programs that are proactive in mitigating risk and that do
not simply rely on biological monitoring programs to determine if an exposure has already
occurred.
To meet these objectives, OSWER will seek actions that limit exposure to soil lead levels such
that a typical child or group of similarly exposed children would have an estimated risk of no
more than 5% of exceeding a 10 |ig/dl blood lead level. If lead is predicted to pose a risk to the
susceptible population, OSWER recommends that actions be taken to significantly minimize or
eliminate this exposure to lead.
The principles laid out in the four attached fact sheets (Appendix) support OSWER's goals by
encouraging appropriate assessment and response actions at CERCLA and RCRA lead sites
across the country.
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This clarification directive emphasizes the following key messages regarding the four areas and
encourages the users of this directive, be they EPA Regions, States, or other stakeholders, to
adopt these principles in assessing and managing CERCLA and RCRA lead sites across the
country. The critical elements of the attached papers are as follows:
/. Using Blood Lead Studies and IEUBK Model at Lead Sites:
OSWER emphasizes the use of the IEUBK Model for estimating risks for childhood lead
exposure from a number of sources, such as soils, dust, air, water, and other sources to predict
blood lead levels in children 6 months to 84 (7 years) months old. The 1994 directive also
recommended evaluation of available blood lead data and stated that data from a well-conducted
blood lead study of children could provide useful information to site managers. In summary,
OSWER's clarification policy on the appropriate use of the IEUBK and blood lead studies is that:
• OSWER recommends that the IEUBK model be used as the primary tool to generate risk-
based soil cleanup levels at lead sites for current or future residential land use. If Regions
propose an alternative method for generating cleanup levels, they are required to submit
their approach to the national Lead Sites Consultation Group (LSCG)1 for review and
comment;
• Response actions can be taken using IEUBK predictions alone; blood lead studies are not
required; and
• Blood lead studies and surveys are useful tools at lead sites and can be used to identify key
site-specific exposure pathways and to direct health professionals to individuals needing
immediate assistance in minimizing lead exposure; however, OSWER recommends that
blood lead studies not be used for establishing long-term remedial or non-time-critical
removal cleanup levels at lead sites.
//. Determining Exposure and Remediation Units at Lead Sites
OSWER recommends that cleanup levels at lead sites be designed to reduce risk to a typical or
individual child receiving exposures at the residence to meet Agency guidelines (i.e., no
greaterthan a 5% chance of exceeding a 10 ug/dl blood-lead level for a full-time child resident).
Therefore, it is recommended that risk assessments conducted at lead-contaminated residential
sites use the individual residence as the primary exposure unit of concern. This does not mean
that a risk assessment should be conducted for every yard, rather that the soil lead contamination
lrThe Lead Sites Consultation Group (LSCG) is comprised of senior management representatives from the
Waste Management Divisions in all 10 EPA regions along with senior representatives from the Office of
Emergency and Remedial Response in EPA headquarters. The LSCG is supported by EPA's Technical Review
Workgroup (TRW) for lead and the national Lead Sites Workgroup (LSW). The TRW consists of key scientific
experts in lead risk assessment from various EPA Regions, labs and headquarters. The LSW is comprised of
senior Regional Project Managers from various Regions and key representatives from headquarters who are
experienced in addressing lead threats at Superfund sites.
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data from yards and other residential media (for example, interior dust and drinking water) should
be input into the IEUBK model to provide a preliminary remediation goal (PRO) for the
residential setting. When applicable, potential exposure to accessible site-related lead sources
outside the residential setting should also be evaluated to understand how these other potential
exposures contribute to the overall risk to children, and to suggest appropriate cleanup measures
for those areas.
///. Addressing Multimedia Contamination at Lead Sites
EPA generally has limited legal authority to use Superfund to address exposure from interior
lead-based paint. As a policy matter, OSWER recommends that such exposures not be
addressed through actual abatement activities. However, EPA Regions should promote
addressing interior paint risks through actions by others (e.g., potentially responsible parties
(PRPs), other government programs, etc.) as a component of an overall site management strategy.
Because of other competing demands on the Superfund Trust Fund, OSWER recommends that
EPA Regions avoid using the Superfund Trust Fund for removing exterior lead-based paint and
soil contaminated from lead-based paint. Superfund dollars may however be used in limited
circumstances to remediate exterior lead-based paint in order to protect the overall site remedy
(i.e., to avoid re-contamination of soils that have been remediated) but generally only after
determining that other funding sources are unavailable. As with interior lead-based paint
abatement, EPA Regions should promote remediation of exterior lead-based paint by others, such
as PRPs, local governments or individual homeowners.
IV. Determining Appropriate Response Actions at Lead Sites
In selecting site management strategies, it is OSWER's preference to seek early risk reduction
with a combination of engineering controls (actions which permanently remove or treat
contaminants, or create reliable barriers to mitigate the risk of exposure) and non-engineering
response actions. All potential lead sources should be identified in site assessment activities.
Non-engineering response actions, such as education and health intervention programs, should be
considered an integral part of early risk reduction efforts because of their potential to provide
immediate health benefits. In addition, engineering controls should be implemented early at sites
presenting the greatest risk to children and other susceptible subpopulations.
As a given project progresses, OSWER's goal should be to reduce the reliance on education and
intervention programs to mitigate risk. The goal should be cleanup strategies that move away
from reliance on long-term changes in community behavior to be protective since behavioral
changes may be difficult to maintain over time. The actual remedy selected at each CERCLA site
must be determined by application of the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP) (55 FR 8666- 8865, March 8, 1990) remedy selection criteria to site-
specific circumstances. This approach also recognizes the NCP preference for permanent
remedies and emphasizes selection of engineering over non-engineering remedies for long-term
response actions.
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This directive clarifies OSWER's policy on four key issue areas addressed in the 1994 OSWER
soil lead directive in order to promote a nationally consistent decision-making process for
assessing and managing risks associated with lead contaminated sites across the country. The
policy presented in these specific issue areas supersedes all existing OSWER policy and directives
on these subjects. No other aspects of the existing 1994 directive are affected.
IMPLEMENTATION
The principles laid out in this directive (which includes the four attached factsheets) are meant to
apply to all residential lead sites currently being evaluated through the CERCLA Remedial
Investigation/Feasibility Study process and all future CERCLA Sites and RCRA Corrective
Action Facilities contaminated with lead. The Regions will be required to submit their rationale
for deviating from the policies laid out in this directive to the Lead Sites Consultation Group.
This directive does not apply to previous remedy selection decisions.
Attachments
cc: Waste Management Policy Managers (Regions I-X)
Stephen Luftig, OERR
Elizabeth Cotsworth, OSW
James Woolford, FFRRO
Barry Breen, OSRE
Larry Reed, OERR
Tom Sheckells, OERR
Murray Newton, OERR
Betsy Shaw, OERR
John Cunningham, OERR
Paul Nadeau, OERR
Bruce Means, OERR
Earl Salo, OGC
NOTICE: This document provides guidance to EPA staff. The document does not,
however, substitute for EPA's statutes or regulations, nor is it a regulation itself. Thus it cannot
impose legally-binding requirements on EPA, states, or the regulated community, and may not
apply to a particular situation based upon the circumstances. EPA may change this guidance in
the future, as appropriate.
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Appendix
OSWER Directive # 9200.4-27P
August 1998
Factsheet: Using the IEUBK Model and Blood Lead Studies at Residential Lead Sites
Question: What is OSWER's policy on using the IEUBK model and blood-lead studies in
conducting risk assessments and setting cleanup standards at residential lead contamination sites?
Answer: OSWER's policy on using the IEUBK model and blood-lead studies in conducting
risk assessment and setting cleanup standards is as follows:
A. Use of the IEUBK Model:
1. The IEUBK model is a good predictor of potential long-term blood-lead levels for
children in residential settings. OSWER recommends that the IEUBK model be used as
the primary tool to generate risk-based soil cleanup levels at lead sites for current or future
residential land use. If Regions propose an alternative method for generating cleanup
levels, they are required to submit their approach to the National Lead Sites Consultation
Group (LSCG) for review and comment.
2. Blood-lead distributions predicted by the IEUBK model illustrate a plausible range of
variability in children's physiology, behavior, and household conditions.
3. Response actions can be taken, and remedial goals developed, using IEUBK predictions
alone.
B. Use of Blood-Lead Studies/Data:
1. Blood-lead studies, surveys, and monitoring are useful tools at lead sites and can be used
to help identify key site-specific exposure pathways and direct health professionals to
individuals needing immediate assistance in minimizing lead exposure.
2. The utility of blood lead testing results and studies depends on how representative the
information is of the population being evaluated, the design of the data collection, and the
quality of the laboratory analysis. To this end, OSWER recommends that EPA Regions
consult with ATSDR or CDC to assess or design studies according to their intended use.
3. Many blood-lead screening, monitoring, or testing programs differ from blood lead studies
in that they do not attempt to identify risk factors for childhood exposure to lead sources.
Although these programs may be extremely beneficial in identifying children with elevated
blood lead levels and identifying candidates for referral to medical professionals for
evaluation, they may not provide an accurate representation of community-wide exposure.
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Appendix
OSWER Directive # 9200.4-27P
August 1998
4. Well-designed blood lead studies may be used to identify site specific factors and
pathways to be considered in applying the IEUBK model at residential lead sites.
However, OSWER recommends that blood-lead studies not be used to determine future
long-term risk where exposure conditions are expected to change over time; rather, they
should be considered a snapshot of ongoing exposure under a specific set of circumstances
(including community awareness and education) at a specific time. Long-term studies may
be helpful in understanding exposure trends within a community and evaluating the
effectiveness of cleanup strategies over time.
C. IEUBK and Blood-Lead Studies/Data:
1. Blood-lead data and IEUBK model predictions are expected to show a general
concordance for most sites. However, some deviations between measured and predicted
levels are expected. On some occasions, declines in blood-lead levels have been observed
in association with lead exposure-reduction and health education. However, long-term
cleanup goals should be protective in the absence of changes in community behavior as
there is little evidence of the sustained effectiveness of these education/intervention
programs over long periods of time.
2. Where actual blood-lead data varies significantly from IEUBK Model predictions, the
model parameters should not automatically be changed. In such a case, the issue should
be raised to the Lead Technical Review Workgroup (TRW) to further identify the source
of those differences. Site work need not be put on hold while the issue is being reviewed
by the TRW; the site manager should review other elements of the lead directive and the
"Removal Actions at Lead Sites" guidance to determine appropriate interim actions to be
taken at the site.
The Regions will be required to submit their rationale for deviating from the policies laid out in
this factsheet to the Lead Sites Consultation Group.
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Appendix
OSWER Directive # 9200.4-27P
August 1998
Factsheet: Determining Exposure and Remediation Units at Residential Lead Sites
Question: How does OSWER define an exposure unit, and subsequently apply this definition
in conducting risk assessment and risk management activities at residential lead sites?
Answer: OSWER recognizes that defining and characterizing exposure unit(s) for a site is
critically important in undertaking risk assessment activities and in designing protective cleanup
strategies. An exposure unit is defined as a geographic area where exposures occur to the
receptor of concern during the time of interest and that for a child, or group of similarly exposed
children, this is typically the individual residence and other areas where chronic or ongoing
exposures are occurring.
Various approaches to characterizing and managing risks by exposure units have been examined
by OSWER. OSWER recognizes that lead ingestion can also cause adverse health effects in
adults and fetuses but believes that by adequately limiting lead exposures to young children at
residential sites, these other receptors will generally be likewise protected from adverse health
impacts.
EPA's goal is to protect human health and the environment under current and future exposure
scenarios. At lead sites, OSWER wants to assure that children's health is protected and promotes
a program that proactively assesses risks rather than relying on biological monitoring to determine
if an exposure has already occurred. OSWER emphasizes actions be taken at lead sites that will
minimize or eliminate exposure of children to environmental lead contamination.
To achieve the above stated goal, OSWER recommends characterizing exposure units as
exposure potential at the individual residence as the primary unit of concern for evaluating
potential risk at lead contaminated residential sites This recognizes that there are children
whose domain and activities occur principally within the confines of a particular residential
property. For determining exposure potential (and ultimately developing protective cleanup
levels) at the individual home, OSWER recommends the scenario to be evaluated (through use of
the IEUBK Model) would be a young child in full-time residence. This approach helps achieve
OSWER's recommended health protection goal that an individual child or group of similarly
exposed children would have <5% chance of exceeding a blood-lead concentration of 10 ug/dl.
In designing community wide cleanup strategies, it is essential that non-residential areas (e.g.,
parks, day care facilities, playgrounds, etc.), where lead exposure may occur, also be
characterized with respect to their contribution to soil-lead exposure, and appropriate cleanup
actions implemented.
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Appendix
OSWER Directive # 9200.4-27P
August 1998
OSWER recommends that risk management decisions for response to residential lead
contamination sites focus on reducing risk at residences, but also recommends that response
strategies be developed for other site locations (exposure units) where children receive exposure.
Flexibility in determining appropriate response actions that provide protection at the individual
residence should be considered in context of the NCP remedy selection criteria. The lead
exposure issues are complex and OSWER recommends that EPA Regions try to communicate
clearly the risk characterization and risk management decisions to the site residents. Affected
communities must clearly understand the context of risk management decisions, how these
decisions affect the health of their children, and how cleanup actions will influence the future
growth and development of the community.
The Regions will be required to submit their rationale for deviating from the policies laid out in
this factsheet to the Lead Sites Consultation Group.
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Appendix
OSWER Directive # 9200.4-27P
August 1998
Factsheet: Addressing Multimedia Contamination at Residential Lead Sites
Question: What is OSWER's policy on addressing multimedia contamination at residential
lead sites?
Answer: OSWER recognizes that several sources of lead-contamination, including soil,
ground water, airborne particulates, lead plumbing, interior dust, and interior and exterior lead-
based paint may be present at Superfund sites where children are at risk or have documented lead
exposure. These lead sources may contribute to elevated blood-lead levels and may need to be
evaluated in determining risks and cleanup actions at residential lead sites. However, there are
limitations on the Agency's statutory authority under CERCLA to abate some of these sources,
such as indoor lead-based paint and lead plumbing because CERCLA responses may be taken
only to releases or threatened releases into the environment (CERCLA §104 (a)(3) and (4)).
When EPA's resources, or authority to respond or to expend monies under Superfund is limited,
OSWER recommends that EPA Regions identify and coordinate to the greatest extent possible
with other authorities and funding sources (e.g., other federal agencies and state or local
programs). EPA Regions should coordinate with these other authorities to design a
comprehensive, cost-effective response strategy that addresses as many sources of lead as
practicable. These strategies should include actions to respond to lead-based paint, interior dust,
and lead plumbing, as well as ground water sources and lead-contaminated soil.
Although OSWER will encourage that EPA Regions fully cooperate in the development of a
comprehensive site management strategy, OSWER realizes that complete active cleanup of these
other sources may be difficult to complete due to limited funding available to other authorities.
Since complete cleanups of these sources is not guaranteed, and at most sites may be unlikely,
OSWER recommends that the soil cleanup levels not be compromised. In other words, the soil
cleanup levels should be calculated with the IEUBK model using existing pre-response action site
specific data. This is due to the fact that soil cleanup levels at residential lead sites are generally
established to protect individuals, from excess exposures to soils, and house dust attributable to
those soils, and are not attributable to exposure to other sources such as interior lead paint which
should be managed on a residence specific basis. Remediation of non-soil lead sources to mitigate
overall lead exposure at individual residences should therefore not be used to modify sitewide soil
lead cleanup levels.
The recommendations provided below represent OSWER's policy on addressing lead-
contaminated media and/or sources for which EPA has limited or no authority to remediate.
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Appendix
OSWER Directive # 9200.4-27P
August 1998
Interior Paint: EPA has limited legal authority to use Superfund to address exposure from
interior lead-based paint. As a policy matter, OSWER recommends that such exposures not be
addressed through actual abatement activities. However, EPA Regions should promote
addressing interior paint risks through actions by others, such as HUD, local governments, or
individual home owners as a component of an overall site management strategy. Any activities to
clean up interior lead-based paint by PRPs or other parties should not result in an increase of the
risk-based soil cleanup levels.
Exterior Paint: Because of other competing demands on the Superfund Trust Fund,
OSWER recommends that EPA Regions avoid using the Superfund Trust Fund for removing
exterior lead-based paint and soil contaminated from lead-based paint. Superfund dollars may be
used to respond to exterior lead-based paint for protecting the overall site remedy (i.e., to prevent
re-contamination of soils that have been remediated) but only after determining that other funding
sources are unavailable. Where other sources of funding are not available, EPA may utilize the
CERCLA monies to remediate exterior lead-based paint on homes/buildings, around which soil
contaminated by other sources has been cleaned up to prevent recontamination of the soil. The
Superfund should not be used to remediate exterior lead-based paint where no soil cleanup has
occurred. As with interior lead-based paint abatement, EPA Regions should promote remediation
of exterior lead-based paint by others, such as PRPs, local governments or individual
homeowners. Cleanup activities of exterior paint conducted by PRPs or other parties should not
result in an increase of the risk-based soil cleanup levels.
Interior Dust: Lead contaminated interior dust can be derived from several sources,
including interior paint, home owner hobbies, exterior soil, and other exterior sources. In many
cases, it may be difficult to differentiate the source(s) for the lead contamination in the dust. In
general, EPA Regions should refrain from using the Superfund Trust Fund to remediate interior
dust. Because of the multi-source aspects of interior dust contamination, potential for
recontamination, and the need for a continuing effort to manage interior dust exposure, OSWER
recommends the use of an aggressive health education program to address interior dust exposure.
Such programs, administered through the local health department (or other local agency), should
be implemented in conjunction with actions to control the dust source. At a minimum, the
program should include blood-lead monitoring, and personal hygiene and good housekeeping
education for the residents. OSWER believes that EPA Regions can also support the program by
providing HEPA vacuums to the health agency for use in thoroughly cleaning home interiors.
Lead Plumbing: Generally CERCLA does not provide for legal authority to respond to risks
posed by lead plumbing within residential dwellings. It should be noted that the water purveyor is
responsible for providing clean water to the residences. As with interior dust, OSWER
recommends that EPA Regions coordinate with local agencies to establish a health education
program to inform residents of the hazards associated with lead plumbing and how to protect
themselves by regularly flushing, or preferably, replacing lead pipes. Soil cleanup levels should
not be adjusted to account for possible remediation of lead plumbing.
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Appendix
OSWER Directive # 9200.4-27P
August 1998
Factsheet: Determining Appropriate Response Actions at Residential Lead Sites
Question: What is OSWER's position on the appropriate use of engineering and non-
engineering response actions in developing risk management strategies for lead sites?
Answer: One goal emphasized in the recent third round of Superfund Reforms is for EPA to
take a consistent approach in selecting and implementing both long- and short-term response
actions at lead sites in all regions. One obstacle to achieving this consistency has been differing
degrees of reliance on non-engineering response actions in reducing risk.
Site management strategies at lead sites typically include a range of response actions. Alternatives
range from engineering controls that permanently remove or treat the contaminant source to non-
engineering response actions, such as educational programs and land use restrictions. This
continuum represents the range of response options available to risk managers. This position
paper clarifies the relationship between engineering and non-engineering response actions in
developing site management strategies.
In selecting site management strategies, OSWER's policy will be to seek early risk reduction with
a combination of engineering controls (actions which permanently remove or treat contaminants,
or which create reliable barriers to mitigate the risk of exposure) and non-engineering response
actions. All potential lead sources should be identified in site assessment activities. Non-
engineering response actions, such as education and health intervention programs, should be
considered an integral part of early risk reduction efforts due to their potential to provide
immediate health benefits.2 In addition, engineering controls should be implemented early at sites
presenting the greatest risk to children and other susceptible subpopulations. Community
concerns should receive a high priority in site decision-making; local support is vital to the success
of health intervention and education programs.
As the project progresses, OSWER's goal should be to reduce reliance on education and
intervention programs to mitigate risk. The goal should be cleanup strategies that move away
from reliance on long-term changes in community behavior to be protective; behavioral changes
The actual effectiveness of health intervention and educational programs in reducing risk continues to be
a subject of discussion. Anecdotal information suggests that such programs can provide short-term benefits in
some populations. Rigorous statistical studies demonstrating the benefits of educational programs in preventing
lead exposure are lacking. It is generally recognized that not all segments of the population will be influenced by
such programs, and that long-term benefits are less certain. Local support for such programs is critical. The
active (and long-term) participation of local and state public health agencies is needed in implementing
institutional controls, including health intervention and education programs; without local implementation of such
programs their success is uncertain. Additional research on the effectiveness of these programs is critical to
consideration of their use in future cleanups.
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Appendix
OSWER Directive # 9200.4-27P
August 1998
may be difficult to maintain over time. The actual remedy selected at each site must be
determined by application of the NCP remedy selection criteria to site-specific circumstances.
However, this approach recognizes the NCP preference for permanent remedies and emphasizes
the use of engineering controls for long-term response actions. This approach also recognizes
that well-designed health intervention and education programs, when combined with deed
restrictions and/or other institutional controls, may be appropriate for reducing future exposure
potential and may supplement engineering controls.
In instances where Regions believe that the use of engineering controls is impracticable, and
education, health intervention, or institutional controls are proposed as the sole remedy, Regions
will be required to consult with the LSCG.
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