Un ted States
Env ronmenta Protect on
Agency
Developing and Implementing
a Lead Dust Outreach,
Monitoring, and Education
Program in Your Community
The Syracuse Lead Dust Project
yji.VAiiif.ipnF*
E M P A C T
Environmental Monitoring for Public Access
& Community Tracking
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Chapter 6 Errata
(when reading the pdf file,
please substitute the following corrections in bold)
Section 6.2 Requirements and Qualifications
Manufacturer's Training (page 43)
In most states, operators must be trained by the manufacturer or receive equivalent training.
Syracuse staff took a one-day free training course on the use of the XRF instrument offered by
the manufacturer, Niton. The course met New York state requirements and covered radiation
safety, XRF theory, worker exposure, as well as hands-on analysis of dust wipes, soils and
paint
Costs for the Instrument (page 44)
In addition to investing in trained, licensed, and certified staff, those seeking to implement an
extensive lead dust monitoring program may want to buy their own field-portable XRF. Syracuse
purchased a Niton Model XL-309, which costs about $21,000, making it the most substantial
expense the project faced. This model costs less than other Niton instruments (mainly the
XL-700 series) that test for a wide range of metals, yet more than instruments that only
analyze for lead-based-paint. The same model with soil analysis capability would cost an
additional $2500. Programs will face an additional expense to replace the instrument's
radioactive source once every two years, if not more frequently. NITON's 40mCi Cd-109
source costs $7,300.
Section 6.3 Quality Control
EPA Verifies Use of XRF for Measurement of Lead in Dust (Highlighted Box, Page 44)
In the fall of 2002, EPA's Environmental Technology Verification (ETV) program published a
report verifying the use of five field-portable XRF technologies for the measurement of lead in
dust. The Niton XL-300 and XL-700 series XRF instruments were among the five brands tested.
ETV evaluated overall performance of the Niton XL-300 series as "... having a slight
negative bias (but one with an acceptable range of bias) precise, and comparable to the
NLLAP [National Lead Laboratory Accreditation Program] laboratory results."
XRF Usage and Radiation Exposure (Highlighted Box, Page 46)
State regulations concerning the use of dosimetry vary, however, it is typically
recommended that an XRF operator wear a dosimetry badge, which monitors exposure to
radiation. Even though no radiation dosimetry is required for some isotopes, users should wear a
dosimetry badge for the following reasons:
Safe Operating Distance (Highlighted Box, Page 47)
XRF instruments used in accordance with manufacturer's instructions will not cause significant
exposure to ionizing radiation. But the instrument's shutter should never be pointed at anyone,
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even if the shutter is closed. Also, the operator's hand should not be placed on the end plate
during a measurement.
The safe operating distance between an XRF instrument and an individual depends on the
radiation source type, radiation intensity, quantity of radioactive material, and the density of the
materials being surveyed. As the radiation source quantity and intensity increases, the required
safe distance also increases. Placing dense materials, such as a wall, between the user and
others and a source of radiation, further help to ensure that the possible exposure to
radiation is minimal.
According to NRC rules, a radiation dose to an individual in any unrestricted area must not
exceed 2 milliremsper hour. One of the most intense sources currently used in XRF instruments
is a 40-millicurie 1 Cd (Cd-109) radiation source. Other radiation sources in current use for
XRF testing of lead-based paint generally produce lower levels of radiation. Generally, an XRF
operator following manufacturer's instructions would be exposed to radiation well below the
regulatory level. Typically, XRF instruments with lower gamma radiation intensities can use a
shorter safe distance, provided that the potential expo-sure to an individual will not exceed the
regulatory limit
Section 6.5 Maintaining Equipment (Page 48)
Day-to-day maintenance of the XRF is generally not difficult or costly. Operators should clean
the instrument's display window with cotton swabs, clean the case with a soft cloth, and charge
the batteries as directed in the owner's manual. Beyond that, operators usually just need to take
care not to drop the instrument, get it wet, or neglect the calibration checks recommended by the
manufacturer.
Over the long term, however, XRF owners face the very significant isotopes decay at a fixed
rate. The half-life of 109Cd (cadmium-109), for example, is about 15 months. After that, the XRF
can still be used, but the instrument becomes progressively less efficient. Readings that once
took 30 to 60 seconds take progressively longer. Eventually the wait becomes burdensome, and
the isotope must be replaced. Syracuse sends its instrument back to the manufacturer, which
disposes of the spent radioactive source, installs the new source, upgrades the instrument's
software, and provides whatever preventive maintenance is needed. See Chapter 7, Section 7.3
for more information on managing and disposing of hazardous wastes generated in a lead dust
monitoring and mitigation program.
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D I SCLAI MER
This document has been reviewed by the U.S. Environmental Protection Agency (EPA) and approved for publication.
Mention of trade names or commercial products does not constitute endorsement or recommendation of their use.
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EPA/625/R-02/014
February 2003
Developing and Implementing
a Lead Dust Outreach,
Monitoring, and Education
Program in Your Community
The Syracuse Lead Dust Project
U.S. Environmental Protection Agency
National Risk Management Research Laboratory
Office of Research and Development
Cincinnati, OH 45268
Recycled/Recyclable
Printed with vegetable-based ink on paper that contains a minimum of
50% postconsumer fiber.
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C DNTENTS
Chapter 1: Introduction 1
1.1 About EPA's EMPACT Program 1
1.2 About the Syracuse Lead Dust Outreach, Monitoring, and Education Project 2
1.3 Related Lead Dust or Lead Monitoring Programs 3
1.4 Alternative Programs 4
1.5 Are the Practices in this Case Study Consistent with Federal Regulations? 4
1.6 How To Use This Case Study 6
1.7 Acknowledgments 7
1.8 Resources for Additional Information 7
Chapter 2: Lead Dust: Why Is it a Problem? 9
2.1 What Is Lead Poisoning? 9
2.2 Sources of Lead in Dust 10
2.3 Exposure Pathways for Lead Dust 11
2.4 Resources for Additional Information 11
Chapter 3: Lead Dust Project Overview 15
3.1 Steps in the Development of Syracuse's Lead Dust Project 15
3-2 Project Implementation Steps 18
3-3 Selecting Project Partners 21
Chapter 4: Communicating about Lead Dust 26
4.1 Syracuse's Outreach Methods and Materials 26
4.2 Approaching and Recruiting Program Participants 28
4.3 Resources for Additional Information 29
Chapter 5: Collecting and Managing Data on Lead Dust 37
5-1 Chronology: From Data Collection to Reporting 37
5.2 Visiting the Home (Step-By-Step In-Home Sampling) 38
5.3 Quality Assurance Project Plan (QAPP) 40
5-4 Resources For Additional Information 40
Chapter 6: Analyzing Lead Dust Samples Using XRF Technology 42
6.1 Advantages of XRF Technology 42
6.2 Requirements and Qualifications 43
6.3 Quality Control 44
6.4 Health and Safety When Using XRF 46
6.5 Maintaining Equipment 47
6.6 Resources For Additional Information 48
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Chapter 7: Mitigation and Maintenance 50
7.1 Lead Dust Mitigation 50
7.2 HEPA Vacuum Loaner Program 52
7.3 Disposal of Lead Dust Debris and Used HEPA Filter 52
7.4 Maintaining Lead-Safe Practices in the Home 53
7.5 Resources for Additional Information 54
Chapter 8: Reporting 57
8.1 Participant Reports 57
8.2 Public Reports 58
8.3 Web Site 59
8.4 Resources For Additional Information 59
Chapter 9: Evaluating Syracuse's Lead Dust Project 73
Appendix A: Glossary 78
Appendix B: Quality Assurance Project Plan 80
Appendix C: Minneapolis Lead Hazard Control Program 89
Appendix D: EMPACT Lead-Safe Yard Project in Boston, Massachusetts 92
Appendix E: Memorandum from Elizabeth Cotsworth, Director, Office of Solid Waste, on
"Regulatory Status of Waste Generated by Contractors and Residents from
Lead-Based Paint Activities Conducted in Households" 95
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1
I NTRD DU CTI D N
Lead poisoning in children under the age of six continues to be a serious environmental
health problem in the United States. Children from all socio-economic segments are
potentially at risk, whether they are members of immigrant families living in old
apartment buildings in inner cities, or members of well-to-do households living in historic resi-
dences. They can be exposed to lead where they live and play primarily from the lead dust cre-
ated when lead-based paint rubs off windows and other surfaces inside their homes. The good
news is that many communities are taking effective action to raise awareness of lead-based paint
and reduce the hazards of lead exposure to young children.
The U.S. Environmental Protection Agency (EPA) and the U.S. Department of Housing and
Urban Development (HUD) share joint responsibilities for the environmental and health risks
of lead-based paint, and the two agencies are protecting children through issuing grants to local-
ities such as Syracuse with the goal of reducing childhood lead poisoning.
This technology transfer case study is designed to address two main goals. The first goal is to
show how the Lead Dust Outreach, Monitoring, and Education Project in Syracuse, New York
(Syracuse Lead Dust Project), is using a variety of effective, low-cost public information and
education techniques to reduce children's exposure to elevated levels of lead dust in their homes
and day care facilities. The second goal is to provide information, recommendations, sugges-
tions, and tools to assist individuals or groups who are developing similar programs to address
the problem of lead dust in their communities. The lessons learned are based on the experiences
of the Syracuse Lead Dust Project and several other programs that are highlighted at various
points throughout this case study.
This document is written primarily for community organizers, nonprofit groups, local govern-
ment officials, tribal officials, and other decision-makers who will implement, or are considering
implementing, lead dust outreach, monitoring, and mitigation programs. Much of the informa-
tion will also be useful to tenants and homeowners interested in finding low-cost ways to reduce
children's exposure to lead dust.
Before attempting to implement the process described in this case study, project staff, commu-
nity organizers, homeowners, and tenants must be aware of the potential hazards associated
with lead-based paint in housing. Everyone should carefully read those passages of the case
study that describe lead hazards (Chapter 2).
1.1 ABOUT EPA's EMPACT PROGRAM
This case study was developed by EPA's EMPACT Program (www.epa.gov/empact). EPA creat-
ed EMPACT (Environmental Monitoring for Public Access and Community Tracking) to pro-
mote new and innovative approaches to collecting, managing, and communicating
environmental information to the public. Working with communities across the country, the
program takes advantage of new technologies to provide community members with timely,
accurate, and understandable environmental information they can use to make informed, day-
to-day decisions about their lives. EMPACT projects cover a wide range of environmental
issues, including water quality, ground water contamination, smog, ultraviolet radiation, and
overall ecosystem quality.
INTRODUCTION
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The Technology Transfer and Support Division of the EPA Office of Research and
Development's (ORD's) National Risk Management Research Laboratory initiated the develop-
ment of this case study to help interested communities learn more about lead dust monitoring
and education programs, to provide them with the technical information they need to develop
their own programs, and to minimize the resources needed to implement similar programs in
other cities. Both print and CD-ROM versions of the case study are available for direct online
ordering from ORD's Technology Transfer Web site at . A PDF version
of the case study can also be downloaded from the Syracuse Lead Dust Outreach, Monitoring,
and Education Project at . In addition, copies of the case study
are available by contacting ORD publications at:
EPA ORD Publications
26 W. Martin Luther King Drive
Cincinnati, OH 45268-0001
EPA National Service Center for Environmental Publications (NSCEP)
Toll free: 800490-9198
Local: 513 489-8190
Available in hard copy or CD-ROM.
1.2 ABOUT THE SYRACUSE LEAD DUST DUTREACH,
MONITORING, AND EDUCATION PROJECT
Syracuse initiated its Lead Dust Outreach, Monitoring, and Education Project (the Syracuse
Lead Dust Project) in 1998. The objective was to establish a community-based effort to provide
local residents with information to assist them in reducing their exposure to lead dust in resi-
dential and public buildings. The project targets minority, immigrant, and low-income residents
with a focus on families with small children who live in buildings constructed prior to 1978.
Priority is given to households with children under the age of six.
Syracuse's Lead Dust Project collects lead dust level samples, analyzes the samples, reports
results to the residents, and coordinates community outreach and education. If a lead hazard is
present in a home, Syracuse staff contacts the participant, provides training in a three-step
cleaning method, and informs the resident about a High Efficiency Particulate Air (HEPA) vac-
uum loaner program. If the data indicate that a lead hazard is not present, the participant
receives a written copy of their individual sample results.
Syracuse, located in central New York, is a medium-sized city with a 2000 Census population of
147,000. The city's housing stock is relatively old—more than 58 percent of the housing units
were built prior to 1940, more than 22,000 of which are considered substandard.
Approximately 64 percent of the housing stock is rental property. In the city's revitalization
areas, 68 percent of children under age 5 live in poverty, and 1,435 children under the age of
six have elevated blood levels, according to 1998 data collected by Onondaga County Lead
Poisoning Control.
Working cooperatively with the county's poison control program and its Healthy
Neighborhoods Division, along with seven community-based organizations (CBOs), Syracuse is
using grant funding from EPA's EMPACT program for lead dust outreach, monitoring, and
mitigation in 350 homes located in the same neighborhoods targeted by the city's HUD lead
hazard control program.
CHAPTER
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The city of Syracuse has set up partnerships
with the following seven CBOs to implement J~| efore beginning its lead dust project, Syracuse
its EMPACT Lead Dust Project: |_| already had a HUD-funded lead hazard reduction
r „ program in place. Both programs share common goals:
• Boys & Girls Clubs of Syracuse .r , ,, ,
, to identity areas where lead dust presents a hazard, to
. / . 11111
educate homeowners and tenants about lead hazards,
Southeast Asian Center
< www. irccny. org/programs/seac. shtml;
Brighton Family Center
Girls, Inc. of Central New York
and to suggest ways to reduce exposure to lead dust.
Having the HUD lead hazard control program in place
helped pave the way for the EMPACT Lead Dust
Project because the Lead Risk Assessors had an existing
relationship with the community, as well as with the
Mayor and with other city decision-makers. Since
HUD's lead program already had a working office, EPA
Southwest Community Center able about the hazards posed by lead in the home.
Syracuse Northeast Community Center
• Westcott Community Center
These project partners play a critical role in implementing the Syracuse Lead Dust Project.
CBOs recruit residents in the neighborhood to participate in the HEPA vacuum program, store
the HEPA vacuums, assist with translation to non-English speakers, and provide critical pro-
gram feedback from the community. Read more about CBOs and their role in Chapter 3.
1 .3 RELATED LEAD DUST OR LEAD MONITORING PROGRAMS
In developing this technology transfer case study, EPA contacted several other similar lead dust
programs to gain their perspectives. EPA gathered information from the following other pro-
grams:
• The Minnesota Environmental Health Lead Hazard Control Program
Minneapolis/St. Paul (See Appendix C)
The city of Minneapolis Lead Hazard Control Program, in partnership with Atrix International
Corporation, has developed and implemented a cooperative HEPA vacuum rental program.
This program is structured to assist homeowners, tenants, rental property owners, and renova-
tors (do-it-yourselfers) in safely removing lead-based paint dust and chips from their homes.
• HELP Lead Safe Center
Providence, Pvhode Island
Health & Education Leadership for Providence (HELP) is a community partnership of colleges
and hospitals in Providence, Pvhode Island. The HELP Lead Safe Center assists families dealing
with the complex needs of the lead-poisoned child and works to prevent the poisoning of other
children in the home. The Lead Center offers medical and nonmedical case management, envi-
ronmental and nutritional education, child development assessment, housing advocacy, social
service referrals, and an innovative window replacement program for eligible families.
INTRODUCTION
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As part of its comprehensive array of services relating to lead safety, the Lead Center conducts
home environmental visual assessments. A trained assessor walks through the home with the
family, room by room, identifying lead hazards. If lead dust is discovered, the Lead Center rec-
ommends cleaning techniques and teaches proper cleaning procedures, such as wet-cleaning
lead dust using trisodium phosphate diluted in water. The organization also makes HEPA vacu-
ums available on a loaner basis and provides instructions for their proper use.
• EMPACT Lead-Safe Yard Project
Boston, Massachusetts (See Appendix D)
The EMPACT Lead-Safe Yard Project (LSYP) in Boston used a variety of low-cost techniques
to reduce children's exposure to elevated levels of lead in residential soil. The project used inno-
vative field-portable x-ray fluorescence (XPvF) technology to communicate data to residents and
implemented low-cost and sustainable landscape measures in residents' yards to reduce chil-
dren's risk of exposure to contaminated soil. The project also developed a template that other
communities and public agencies can use to address the issue of lead in residential soil.
The project improved 61 homes at no cost to the owners; conducted a number of seminars on
lead-safe yard work; and developed a "Tool Kit" for use by other communities. These methods
were then incorporated into a handbook titled Lead-Safe Yards: Developing and Implementing
a Monitoring, Assessment, and Outreach Program for Your Community.
1 .4 ALTERNATIVE PROGRAMS
Homeowners or tenants living in an area where no lead dust program exists might want to have
trained and licensed consultants determine whether they have a lead problem in their house. In
this case, the homeowner or tenant should have dust wipe samples collected by a certified lead-
based paint inspector, risk assessor, or sampling technician. For a list of qualified lead profes-
sionals, including inspectors, risk assessors, abatement contractors, and analytical laboratories,
go to and click on "Finding A Qualified Lead Professional for Your Home"
under "Additional Resources." For EPA-run states, call 1-800-424-LEAD.*
Homeowners can contact their state or local childhood lead poisoning prevention program for
more information about obtaining lead dust testing. The following Web sites list state and local
lead poisoning prevention contacts:
• The Lead Program of the National Safety Council's Environmental Health Center:
.
The National Conference of State Legislatures' Directory of State Lead Poisoning Prevention
Contacts: .
1 .5 ARE THE PRACTICES IN THIS CASE STUDY CONSISTENT
WITH FEDERAL REGULATIONS?
Syracuse's Lead Dust Project complies with the Toxic Substances Control Act (TSCA) Title IV
and the Section 403 rule, under which EPA establishes standards for lead-based paint hazards,
including hazard levels for lead-contaminated dust in houses.
EPA-run states are Alaska, Arizona, Florida, Idaho, Montana, North and South Dakota, Nevada, New
Mexico, New York, South Carolina, Washington, and Wyoming.
CHAPTER
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HUD and EPA set reference levels indicating the amounts of lead that might create adverse
health effects to pregnant women and children younger than 6 years old. These standards allow
landlords, tenants, parents, and child care providers to identify problems and make informed
decisions. The Syracuse project based its own hazardous levels of concern on these standards
(see table below).
SYRACUSE REFERENCE LEVELS FOR LEAD DUST HAZARDS
Floor 40 ug/ft.2
Window Sill 250 ug/ft.2
Window Trough1 400 ug/ft.2
1 Syracuse's Lead Dust Project uses EPA's clearance level of 400 ug/ft.2 for window
troughs.
Syracuse's Lead Dust
Project provides resi-
dents (particularly low-
income, urban,
minority residents) with
practical, low-cost dust
cleanup measures that
will reduce exposure to
lead-contaminated dust
in the home. These
low-cost measures may be used as interim shorter term solutions until permanent, higher cost
solutions are employed as long as homeowners and/or residents carefully and conscientiously
follow and continue to practice the recommended cleanup procedures.
Before applying the Syracuse Lead Dust Project's model to your situation, consult local regula-
tory authorities to determine their specific requirements, such as reference levels for lead-con-
taminated dust. State, tribal, and local government regulations might be more restrictive than
existing federal guidance.
LINKS TD REGULATIONS RELATED TD LEAD DUST
HUD Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing.
Residential Lead-Based Paint Hazard Reduction Act of 1992.
The National Conference of State Legislatures' Directory of State Lead Poisoning Prevention Contacts
The Occupational Safety and Health Administration (OSHA)
HUD's Lead Safe Housing Rule
EPA's final standards (TSCA 403) for lead-based paint hazards (including lead dust). Office of
Pollution Prevention and Toxics Web site
SW-846 is EPA's Office of Solid Waste's official compendium of analytical and sampling methods that
have been evaluated and approved for use in complying with RCRA regulations.
INTRODUCTION
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1 .6 Haw TD USE THIS CASE STUDY
This case study provides information communities can use to create and implement a lead dust
project. It provides examples of program planning and implementation along with important
background information on lead poisoning.
• Chapter 2 discusses why lead dust is a health hazard; the incidence of lead poisoning; sources
of lead; and its pathways into the body.
• Chapter 3 describes the steps taken by Syracuse to plan and implement its lead dust project,
including identifying potential target communities, getting to know the community, and
selecting program partners.
• Chapter 4 discusses Syracuse's recommendations for communicating about lead dust to resi-
dents and property owners. It covers the language and cultural challenges of communicating
with immigrant and low-literacy populations and provides examples of effective outreach
and educational materials used by Syracuse.
• Chapter 5 provides information about collecting and managing data, including how to inter-
act with residents as dust samples are collected from their homes.
• Chapter 6 discusses use of the field-portable X-ray fluorescence (XRF) instruments to collect
timely data, role of field sampling technicians, testing protocols, quality control, health and
safety precautions, and equipment maintenance.
• Chapter 7 discusses the mitigation (cleaning) process recommended by Syracuse and the
HEPA vacuum loaner program and discusses the importance of continued maintenance.
• Chapter 8 discusses data reporting to residents, landlords, and the public. It also covers
recordkeeping and confidentiality.
• Chapter 9 provides information on how Syracuse evaluates the performance of its program.
This case study also includes references to supplementary sources of information, such as Web
sites, guidance documents, and other written materials. In addition, the case study includes the
following appendices:
• Appendix A provides a glossary of technical terms used in this case study.
• Appendix B comprises Syracuse's Quality Assurance Project Plan (QAPP).
• Appendix C provides a case study on the Minneapolis Lead Hazard Control Program.
• Appendix D contains a case study on the EMPACT Lead-Safe Yard Project in Boston,
Massachusetts.
• Appendix E provides a memorandum from Elizabeth Cotsworth, Director, Office of Solid
Waste on "Regulatory Status of Waste Generated by Contractors and Residents from Lead-
Based Paint Activities Conducted in Households."
Initiating and managing a lead dust program is a challenging but worthwhile undertaking. This
case study aims to provide information and resources that will help develop new programs,
maintain current programs, and educate individuals on how to decrease occurrences of lead dust
poisoning in children. We hope that you find the case study informative and easy to use.
CHAPTER
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1 .V ACKNOWLEDGMENTS
The development of this case study was managed by Scott Hedges (U.S. Environmental
Protection Agency, Office of Research and Development, National Risk Management Research
Laboratory) with the support of Eastern Research Group, Inc., an EPA contractor. Technical
guidance was provided by the Syracuse Lead Dust Project. EPA would like to thank the follow-
ing people and organizations for their substantial contributions to the contents of this case study:
Theresa Bourbon, U.S. EPA, Region 2 EMPACT Project Officer
Jeremy Giller, Executive Director, HELP Lead-Save Center, Providence, Rhode Island
Mike Goss, Syracuse Lead Dust Project
Robert Maxfield, U.S. EPA Region 1
Pat McLaine, National Center for Healthy Housing
Johanna Miller, Minnesota Environmental Health Lead-Hazard Control Program
Betsy Mokrzycki, Syracuse Lead Dust Project
Donna Ringel, U.S. EPA, Region 2 EMPACT Program Manager
Patrick Strodel, Lead Safe, LLC
Robert Vanderslice, U.S. Department of Housing and Urban Development
Adam VanHoose, Syracuse Lead Dust Project
1 .B RESOURCES FDR ADDITIONAL INFORMATION
The following publications and resources provide a wealth of information on lead and lead-con-
taminated dust:
Department of Housing and Urban Development. 1995- HUD Guidelines for the Evaluation
and Control of Lead-Based Paint Hazards in Housing. Available online at .
Department of Housing and Urban Development. 2000. Residential Lead Desktop Reference,
2nd Edition. CD-ROM containing more than 140 documents, including ASTM scopes,
screening guidance, community outreach materials, lead resources, scientific studies and reports,
lead statutes and regulations, lead training materials, regulation support documents, reports to
Congress, HUD guidelines, and other resources. Available for $10 by calling HUDUSER at
1-800-245-2691.
Lead-Based Paint Hazard Reduction and Financing Task Force. 1995- Putting the Pieces
Together: Controlling Lead Hazards in the Nation's Housing. Available online at
< www. hud. gov/offices/lead/reports/report. pdf>.
U.S. Congress. 1992. Residential Lead-Based Paint Hazard Reduction Act of 1992. Title X (42
USC 4851). Available online at .
INTRODUCTION
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U.S. Environmental Protection Agency. 1994. EPA Guidance on Residential Lead-Based Paint,
Lead-Contaminated Dust, and Lead-Contaminated Soil. EPA540-F-94-045. Order online at
< www. epa. gov/ncepihom/ordering. htm>.
U.S. Environmental Protection Agency. 1995- EPA Residential Sampling for Lead: Protocols for
Dust and Soil Sampling. EPA747-R-95-001.
U.S. Environmental Protection Agency. 1997. Reducing Lead Hazards When Remodeling Your
Home. EPA747-K-97-001. Order online at .
U.S. Department of Housing and Urban Development. 2001. Lead Paint Safety—A Guide for
Painting, Home Maintenance, and Renovation Work. HUD-1779-LHC.
LINKS
U.S. EPA National Lead Information Center at .
A federally funded hotline and clearinghouse that provides information on lead hazard reduc-
tion and exposure prevention. To speak with one of the Center's clearinghouse specialists, call
1-800-424-LEAD Monday through Friday, 8:30 a.m. to 6:00 p.m. EST.
U.S. EPA Office of Pollution Prevention and Toxics (OPPT) at
.
Responsible for EPA programs related to lead poisoning prevention and lead regulation. OPPT
also provides educational packets for parents, teachers, day care providers, and librarians, as well
as technical information and publications.
The Department of Housing and Urban Development (HUD) at .
Sets standards for evaluating and managing lead in federal-assisted housing and promotes efforts
to reduce lead hazards in privately owned housing. In addition, provides grants to communities
to reduce lead hazards in housing.
CHAPTER
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2
LEAD DUST:
WHY IS IT A PROBLEM?
This chapter provides an overview of the problems posed by lead dust. The information
in this chapter should be useful to anyone interested in lead dust hazards and mitiga-
tion, including community organizers responsible for implementing a lead dust pro-
gram or homeowners concerned about elevated lead levels in their own homes.
• Section 2.1 discusses what lead poisoning is and how it affects children's health.
• Section 2.2 discusses the sources of lead in dust.
• Section 2.3 describes the key pathways for childhood exposure to lead.
• Section 2.4 lists resources for additional information.
2. 1 WHAT Is LEAD POISONING?
According to the Centers for Disease Control and Prevention (CDC), nearly 1 million children
living in the United States in the early 1990s had lead in their blood at levels high enough to
cause irreversible damage to their health. CDC defines elevated lead levels in children as 10
micrograms of lead per deciliter of blood (ug/dL) or higher. Although there is no known safe
level of lead in blood, lead poisoning is entirely preventable.
The CDC recommends certain actions for various blood lead levels. In its 1991 report,
"Preventing Lead Poisoning In Young Children," the CDC recommended an intervention plan,
which is currently still in use. In general, CDC recommends urgent follow up for children with
blood lead levels of 45 ug/dL. These children should be taken to a clinic or medical center with
experience in managing childhood lead poisoning. A child with a blood lead level greater than
70 ug/dL should be hospitalized immediately. The CDC recommends that treatment for lead
toxicity at any level, must always involve removing the child from further exposure. Treating a
child for lead toxicity is futile unless the child's exposure can be reduced.
Although childhood lead exposure has diminished in the past 25 years, the problem is far from
solved. Deteriorating housing, lack of resources, lack of access to medical care, poor nutrition,
and language barriers all contribute to poor and minority children being at risk for lead poison-
ing. However, no economic or ethnic/racial group is free from the risk of lead poisoning. Many
affluent families renovating older homes, for example, have inadvertently exposed themselves
and their children to lead hazards through unsafe lead paint removal techniques.
HEALTH EFFECTS OF LEAD POISONING
Lead poisoning affects nearly every system in the body and often occurs without noticeable
symptoms. Although lead can affect adults, children under the age of 6 are especially vulnerable
to the adverse effects of lead. The incomplete development of the blood-brain barrier in fetuses
and very young children (up to 36 months of age) increases the risk of lead's entry into the
nervous system. Low but chronic exposure can affect the developing nervous system in subtle
but persistent ways. In children, blood lead levels as low as 10 to 15 ug/dL can stunt growth
rates, affect attention span, cause learning disabilities, lower IQ scores, impair hearing acuity,
and cause behavioral problems. In addition, fetuses exposed to elevated levels of lead can suffer
LEAD DUST: WHY Is IT A PROBLEM?
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from low birth weight, impaired hearing, and altered gestational age, which can lead to further
complications.
In addition to damaging the nervous system, elevated blood lead levels can also affect the kid-
neys and reproductive system and cause high blood pressure. Very high levels (greater than 80
ug/dL) can cause convulsions, coma, or death. Levels greater than 150 ug/dL are fatal if not
treated quickly. Fortunately, exposures resulting in such high levels of lead are rare.
2.2 SOURCES DF LEAD IN DUST
Lead dust from deteriorated paint is the most significant contributor to childhood lead poison-
ing.1 While the use of lead paint in residential buildings was federally banned in the United
States in 1978, many homes built prior to 1978 still contain lead-based paint. Paint used in
homes built between 1950 and 1978 contained between 0.5 and 50 percent lead, and the paint
used prior to 1950 contained higher concentrations. One estimate is that more than 3 million
tons of lead-based paint remain in the 57 million homes built prior to 19802.
Lead dust forms as lead-based paint peels, chips, chalks, or cracks. Dust also forms when paint-
ed surfaces bump or rub together (called friction surfaces, particularly found on doors and win-
dows) . The primary sources of lead dust are interior painted building components that receive a
lot of wear-and-tear: windows, trim, and sills; doors and door frames; columns, stairs, railings,
and banisters; and porches and fences. Lead dust can also form when lead-based paint is dry
scraped, dry sanded, or heated during building renovations. Lead dust is especially problematic
when found on surfaces that children can reach and chew or mouth, such as window sills, rail-
ings, and stair edges that are at child height. Another important source of lead dust is lead that
has been deposited in soil. Lead in residential soil comes from several different sources, includ-
ing lead-based exterior paint. Before 1978, lead paint was widely used on the exteriors of resi-
dential and other buildings. As the paint on a building's exterior deteriorates, lead paint chips
and dust concentrate in the surrounding soil. Renovating, remodeling, and performing routine
home maintenance also will mobilize this lead if proper precautions are not taken. As with inte-
rior paint, dry scraping, sanding, and blasting of exterior lead-based paint can mobilize large
amounts of lead in a short time. Disturbing the old lead-based paint can increase lead concen-
trations in soil, especially in the "drip zone," or "drip line," the area surrounding and extending
out about 3 feet from the foundation of a building. (See Appendix D for information about an
EMPACT program that addresses lead in residential soil).
For additional information refer to an EPA fact sheet entitled, Identifying Lead Hazards in
Residential Properties, which is included at the end of this chapter.
While not primarily responsible for childhood lead poisoning, other sources of lead in the environment
include emissions from industrial sources such as smelters, mining operations, and battery-recycling plants;
soil contaminated from vehicular emissions (before leaded gasoline was banned in 1986); lead water pipes;
lead-containing tableware and crystal glassware; some hobbies, such a stained glass-making; some folk
remedies; and some types of jewelry and pewter-ware.
Centers for Disease Control, Preventing Lead Poisoning in Young Children, 1991.
ID CHAPTER
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2.3 EXPOSURE PATHWAYS FDR LEAD DUST
The main way that lead enters the body in through ingestion3. The most common way for a
child to ingest lead is by putting into their mouths objects (e.g., toys or hands) that have lead-
contaminated dust or dirt on them. The dust and dirt inside the house may contain lead from
deteriorating lead-based paint or from lead-contaminated soil tracked in from outside by people
or pets. In addition, when children play outdoors, lead-contaminated dirt and dust can get on
hands, toys, and food. Putting these items in the mouth can lead to ingestion of lead.
Young children tend to ingest more lead than adults in a given environment because of their
normal hand-to-mouth behavior. They also take in more food and water per kilogram of body
weight. Children are at higher risk when their nutritional needs are not being met. Calcium,
iron, zinc, and protein deficiencies, in particular, increase lead absorption rates.
2.4 RESOURCES FDR ADDITIONAL INFORMATION
PUBLICATIONS
American Academy of Pediatrics Committee on Drugs. 1995- "Treatment Guidelines for Lead
Exposure in Children." Pediatrics. 96:155-160. Available online at .
Centers for Disease Control and Prevention. 2002. "Managing Elevated Blood Levels Among
Young Children," Recommendations from the Advisory Committee on Childhood Lead
Poisoning Prevention. Available online at , or call (toll-free) 1-888-232-6789.
U.S. Environmental Protection Agency. 1997. Risk Analysis To Support Standards for Lead in
Paint, Dust, and Soil, volumes 1 & 2. EPA747-R-97-006. Available online at
< www epa. gov/ncepihom/ordering. htm>.
U.S. Environmental Protection Agency. 1999. Lead in Your Home: A Parent's Reference Guide.
EPA747-B-99-003.
LINKS
The Centers for Disease Control and Prevention (CDC)
Childhood Lead Poisoning Prevention Program
< www. cdc. gov/nceh/lead/lead. htm>
Provides information about childhood lead poisoning, promotes state and local screening
efforts, and develops improved treatments for lead exposure.
Lead Poisoning Prevention Outreach Program
< www. nsc. org/ehc/lead. htm>
The Lead Poisoning Prevention Outreach Program is funded through a cooperative agreement
between the U.S. Environmental Protection Agency and the Environmental Health Center
(EHC).
Children can also inhale lead dust from deteriorating paint, from clothing brought home by parents
exposed to occupational lead sources, or from fumes from hobbies that use lead. In addition, children can
breathe lead dust stirred up by conventional vacuuming or during building renovations. These instances are
not considered significant exposure pathways, however.
LEADDUSTlWHYlSlTAPROBLEM? 11
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Agency for Toxic Substances and Disease Registry (ATSDR)
ATSDR conducts a public health assessment at sites on the EPA National Priorities List to
determine if people are being exposed to hazardous substances, which includes lead. The public
can search by region to see which health assessments are currently available in an online data-
base located at: .
National Conference of State Legislatures
Contains NCSLnet Search — a directory of state lead poisoning prevention contacts.
Consumer Product Safety Commission (CPSC)
Identifies and regulates sources of lead exposure in consumer products.
The Occupational Safety and Health Administration (OSHA)
< www. osha-slc. gov/S LTC/lead/index. html>
Develops work practice standards and worker exposure limits to protect workers from occupa-
tional lead exposure.
12 CHAPTER
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United States
Environmental Protection
Agency (EPA)
Prevention, Pesticides
and Toxic Substances
(7404)
ERA747-F-01-002
April 2001
(http://www.epa.gov/lead)
V>EPA FACT SHEET
Identifying Lead Hazards in Residential Properties
EPA has developed standards to help property owners, lead paint professionals, and government agencies
identify lead hazards in residential paint, dust, and soil. These hazards may be paint chips, lead in household
dust, child-accessible or mouthable painted surfaces, friction surfaces of windows and doors, and lead in
residential soil. The Agency has released this fact sheet to summarize new standards and recommendations to
better address lead hazards in and around homes. The complete text of the final rule is available through the
National Lead Information Center or EPA 's Web site (see For More Information).
LEAD PAINT HAZARD
STANDARDS
Lead paint is usually not a hazard if the paint:
- Is in good condition.
- Is not on an impact or friction surface (like a
window, door, or a stair).
WHAT MAKES LEAD PAINT A HAZARD:
The lead paint is deteriorating. As the paint
breaks down, it releases paint chips and lead
dust that can contaminate the home and be
easily ingested by young children through hand-
to-mouth activity.
This deteriorated lead paint may be inside
residential buildings or child-occupied facilities or
on the exterior of any residential building or child-
occupied facility.
The lead paint is on friction or impact surfaces.
Impact to surfaces like door frames or stairs can
damage the paint and release lead. Also, the
paint on friction surfaces like windows, stairs,
and floors can break down during normal use
and release lead.
The lead paint is on child-accessible surfaces
that show evidence of teeth marks. Beware of
lead paint on surfaces such as window sills,
railings, and stair edges that are at child height
and have been or may be chewed on or mouthed
by a child.
All testing for, and identification of, lead
hazards should be completed per EPA
regulations.
LEAD DUST: WHY I
I T
PROBLEM?
~\ 3
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LEAD DUST HAZARD
STANDARDS
The following two standards have been set
for lead hazards in dust:
* 40 micrograms per square foot (g/ft2) for
floors (including carpeted floors).
* 250 g/ft2 for interior window sills.
LEAD SOIL HAZARD
STANDARDS
The following two standards have been set
for lead hazards in soil:
* 400 parts per million (ppm) in play areas of
bare residential soil.
* 1,200 ppm (average) in bare soil in the
remainder of the yard.
LEAD ABATEMENT
CLEARANCE
REQUIREMENTS
Following lead abatement, dust cleanup
activities must be repeated until testing
indicates that lead dust levels are below the
following:
* 40 g/ft2 for floors (including carpeted floors).
* 250 g/ft2 for interior window sills.
* 400 g/ft2 for window troughs.
THIS REGULATION AFFECTS...
The standards established in this regulation apply
to most pre-1978 housing and child-occupied
facilities (pre-1978 non-residential properties
where children under the age of six spend a
significant amount of time such as daycare
centers and kindergartens).
Anyone who must comply with other Title X
regulations, whether issued by EPA, HUD, or by a
State under an authorized program, may be
affected by this regulation. The following list
identifies some of the groups potentially affected
by these standards:
- Residential and child-occupied property owners,
and owners receiving federal housing assistance.
- Lead paint professionals.
- Training providers.
- Federal agencies.
- Parents.
WHAT HAPPENS IF A LEAD HAZARD Is IDENTIFIED?
Property are required to notify occupants if they
are aware of lead, whether or not it is identified as
a hazard. However, this regulation does not
require anyone to identify lead hazards, or that
any specific action be taken if a lead hazard is
identified. Please refer to the Protect Your Family
brochure available through the National Lead
Information Center for further information on
disclosure of lead hazards to residents.
Owners and other decision-makers should
actively seek to reduce or prevent children's
exposure to lead in paint, dust, or soil that equals
or exceeds these hazard levels. The Protect Your
Family brochure provides some of these options.
State, local, or tribal governments may have
different standards or requirements. EPA
recommends you contact them before beginning
any work with lead paint.
FOR MORE INFORMATION, CONTACT:
*The National Lead Information Center at
1-800-424-LEAD (5323).
* ERA'S Web site at .
CHAPTER
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3
LEAD DUST
PROJECT OVERVIEW
T
his chapter discusses the process followed by Syracuse to start and manage a lead dust
mitigation program.
• Section 3-1 presents a summary of the program development steps involved in planning and
launching Syracuse's Lead Dust Project. It also outlines the roles and responsibilities of pro-
gram partners and staff.
• Section 3.2 reviews the steps Syracuse took in implementing its Lead Dust Project.
• Sections 3.3 and 3.4 discusses selecting program partners, provides an overview of the role of
community-based organizations (CBOs), and discusses how to better understand the target
community. These topics are covered in greater detail in Chapter 4.
Outreach, sampling and analysis, mitigation, reporting, and evaluation are discussed briefly in
this chapter and are covered in more detail in Chapters 4 through 9.
3. 1 STEPS IN THE DEVELOPMENT DF SYRACUSE'S LEAD
DUST PROJECT
The EPA (EMPACT)-funded Syracuse Lead Dust Project works with both homeowners and
tenants—particularly those with small children—and provides free and immediate lead dust
mitigation to significantly reduce lead dust levels where small children live and play Although
the program does not eliminate the source of the lead hazard (i.e., deteriorated lead-based
paint), it treats the problem in part by providing personalized instruction of proper cleaning
techniques. The program also educates parents and child care providers to teach children about
the importance of hand washing and keeping their hands out of their mouths.
The target population for the Syracuse Lead Dust Project are households with small children
living in the city's revitalization areas. Syracuse knew from the start that essentially all of the
inner city rental housing stock had lead dust problems. To inform tenants about the lead haz-
ards and to gain their trust and participation, Syracuse partnered with seven CBOs. The rela-
tionship built by the lead dust project with these organizations has been key to the project's
development and success.
The following briefly explains Syracuse's major programmatic benchmarks in the development
of its lead dust project:
Step 1: Project Planning
First Syracuse developed a project plan with clearly defined goals and objectives, project scope,
schedule, and identification of possible funding sources. Since Syracuse decided to use XRF
technology, which is not an EPA-approved method for lead dust analysis, confirmatory labora-
tory analysis was considered necessary to demonstrate the reliability of the technology. To
accomplish this, the project was designed in two phases. In Phase I the XRF findings were veri-
fied against laboratory analysis. During Phase II the project was implemented based on the
results of this analysis.
LEADDUSTPRDJECTDVERVIEW 15
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Step 2: Identifying and Securing Funding
Syracuse spent considerable time identifying sources of funding and determining grant application
procedures and schedules. Syracuse allotted time for the application process, which included prepar-
ing the grant application, the review process, dealing with grant award procedures, and announcing
the grant award to the public with a press event (project kickoff).
Step 3: Establish Quality Assurance Plan and Procedures (QAPP)
Since Syracuse secured an EMPACT grant, the next step was to draft a Quality Assurance Plan
and Procedures (QAPP). All work performed or funded by EPA that involves the acquisition of
environmental data must have an approved QAPP, which documents the planning, implementa-
tion, and assessment procedures for a particular project, as well as any specific quality assurance
and quality control activities. It integrates all the technical and quality aspects of the project in
order to provide a "blue print" for obtaining the type and quality of environmental data and
information needed for a specific decision or use. (See Appendix B).
Step 4: Secure Necessary Equipment and Licenses
Syracuse then had to secure a New York State radiation license, purchase the HEPA vacuums
and XRF equipment, and establish other contracts as necessary. Syracuse found that city pro-
curement procedures increased the time needed to finalize this program step. Other programs
might consider other options, which include renting or leasing the necessary equipment or hir-
ing consultants who have their own equipment.
Step 5: Hire and Train Staff
Concurrent with Step 4, Syracuse recruited, hired, and trained qualified staff to perform home
walk-throughs and to collect lead samples using the XRF At the same time, Syracuse began the
process of training other project partners, such as CBO staff, about lead dust hazards and in the
use of the HEPA vacuums. Syracuse's full-time staff play multiple roles which are shown in the
table below. Syracuse required that its field sampling technicians be EPA-certified
inspectors/risk assessors. They also must be licensed by New York State to handle radioactive
equipment. It is important to check with applicable state and local regulatory agencies to deter-
mine the certification and licensing requirements for staff in comparable lead dust programs.
ROLES DF SYRACUSE LEAD DUST PROJECT STAFF
Title Role
Program Manager
Outreach Coordinator
Field Sampling Technician
HEPA Vacuum Coordinator
Data Analyst/Certified
Risk Assessor
Secures funding, recruits project partners, hires staff, oversees
project implementation
Works with CBOs, educates residents about lead dust hazards,
and enrolls them in the project.
Conducts walk-throughs of homes to identify dusty areas;
collects and analyzes lead dust samples.
Trains residents in three-step cleaning process and
demonstrates use of HEPA vacuums.
Reports site-specific results to residents, interprets significance,
and consolidates and reports data for the community.
1 6
CHAPTER
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With project staff and equipment in place, Syracuse began to develop outreach and educational
materials. These included promotional flyers, informational booklets, report templates, and
"how to" guides for wet cleaning and using the HEPA vacuums. Chapter 4 contains specific
information and examples of these outreach materials.
Step 7: Project Implementation
To get the project underway, staff worked
with the CBOs to recruit participants, con-
ducted dust sampling and analysis, set up
home visits for mitigation and training on the
cleaning process, initiated the HEPA vacuum
lending program, started conducting post-
mitigation sampling and reporting, and began
holding regular meetings with program part-
ners. Syracuse also designed a program Web
site. See Section 3.2 below for more details
on the steps taken by Syracuse to implement
its lead dust project.
In the implementation of its program,
Syracuse found that its schedule was influ-
enced by many variables—some not antici-
pated and out of its control. Project staff
successfully resolved several major implemen-
tation hurdles that affected the original proj-
ect schedule. Two steps, in particular, took
longer than expected and required significant
effort to accomplish. The first was the devel-
opment, refinement, and ultimate approval of
the Quality Assurance Project Plan (QAPP),
as required by EPA. The QAPP is discussed
in Chapters 5 and 6 and is provided in its
entirety in Appendix B. The second was the
sequence of steps involved in purchasing the
X-ray fluorescence (XRF) equipment. A New
York State radiation license is required for the
purchase of an XRF. Since Syracuse did not
already have a radiation safety officer involved
Step 8: Program Evaluation
Because of EMPACT's focus on monitoring
and outreach, measuring the effectiveness of
the mitigation component of the project has
not been elaborate. Nonetheless, the project
conducted a "spot check" of the effectiveness
of its mitigation intervention (e.g., informa-
tion about the 3-step cleaning method and
the HEPA vacuum loaner program).
MITIGATION Is NOT ABATEMENT
Using a HEPA vacuum and following the mitiga-
tion steps explained in Chapter 7 of this case
study only cleans the accumulation of lead dust but does
not abate, or eliminate, the source of lead dust in a
home. Mitigation helps curb exposure to lead dust but
will not prevent lead dust from recurring. Residents or
homeowners who want to determine whether their lead
dust problem is serious enough to require abatement
should consult with a certified risk assessor.
A certified risk assessor is trained to determine the exis-
tence, nature, severity, and location of lead-based paint
hazards in a residential dwelling. A risk assessor can rec-
ommend ways to control lead-based paint hazards,
including abatement. The National Lead Center Hotline
(800 424-LEAD) can help residents locate a certified
risk assessor, or visit
and click on "Training and Certification" then scroll
down to the bottom of this page for an interactive map
of authorized state lead programs. These links provide
lists of lead professionals. Untrained individuals should
never attempt to abate lead-based paint hazards in their
home without professional help.
When lead-based paint exists on surfaces such as walls,
ceilings, woodwork, windows, and sometimes floors, res-
idents and homeowners should take the following pre-
cautions to prevent the creation of dust:
• Do not dry scrape or dry sand on painted surfaces.
• Avoid puncturing holes in walls with lead-based paint
or encapsulated or enclosed walls.
• Do not repeatedly bump furniture or other objects
into older painted surfaces.
• Avoid unnecessarily opening and closing windows or
doors with painted sills or frames; these friction sur-
faces can cause paint to deteriorate and can cause lead
dust to be generated.
LEAD DUST PROJECT OVERVIEW
1 7
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in its lead hazard control program, staff first had to undergo training in order to apply for the
state radiation license.
3.2 PROJECT IMPLEMENTATION STEPS
The following briefly summarizes the steps taken by the Syracuse Lead Dust Project to imple-
ment its program.
PROJECT INTAKE (RECRUITING PARTICIPANTS)
Syracuse identified at-risk children by targeting neighborhoods with older, wood-framed hous-
ing (generally with wooden clapboard siding). Such houses are likely to have lead-based interior
or exterior paint. Neighborhoods made up of older housing units, especially homes built before
1978, when the use of lead paint was federally banned in the United States, are more likely than
newer communities to have a lead problem. In Syracuse, therefore, officials target buildings
built before 1978 that house children. In fact, the prevalence of such structures made intake
screening unnecessary—Syracuse accepts all referrals from CBOs that involve small children.
First, CBOs work to inform residents about the city's lead dust project. Then residents or
property owners fill out a HEPA Vacuum Intake Questionnaire (see copy at end of Chapter 5)
which is submitted to the Syracuse lead team for evaluation. This questionnaire collects basic
data, such as household size, number of children under 6, and the age of the building. The
team then contacts the resident to set up a time to collect dust wipe samples from the proper-
ty. At the same time they also provide the individual with a clear understanding of how the
process will work. See Chapter 5 for more information on in-home dust sampling conducted
by Syracuse.
LEAD DUST SAMPLING AND ANALYSIS
Once a resident is enrolled in the Syracuse project, a field sampling technician (accompanied by
a CBO representative, as needed), visits the residence and explains the sampling procedure.
Prior to sampling, the technician does an initial walk-through to locate the dustiest areas of
floors, window sills, and window wells that are most accessible or exposed to children. He col-
lects samples in the house using dust wipes. Then the dust wipe samples are analyzed by field-
portable XRF technology. In some cases confirmatory laboratory analyses are also performed, as
discussed in Chapter 6.
LEAD DUST MITIGATION (CLEANING)
In houses where lead levels exceed minimum reference levels for lead hazards, the Syracuse Lead
Dust Project provides each participating resident with training in proper cleaning techniques
and free access to a HEPA vacuum. (See Section 1.5 of this handbook for Syracuse's reference
levels for lead hazards). The project provides HEPA vacuums at no cost to all participants who
wish to use them. The Syracuse Lead Dust Project also provides ongoing training and education
to the seven participating CBOs to promote the use of the HEPA vacuums.
The resident signs a free seven-day lease agreement and takes responsibility for proper care and use
of the vacuum. The HEPA vacuum coordinator trains the resident in a three-step cleaning process,
and the actual mitigation is completed by the resident. In some cases, the field sampling techni-
cian returns to the home for post-mitigation sampling and also to collect the vacuum. The
IS CHAPTER
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Syracuse Project offers free vacuum pick-up and delivery to residents, making the use of the vacu-
um convenient and attractive to program participants. See Chapter 7 for more information on
mitigation and the cleaning process.
A WORD ABOUT LEAD DUST CLEANING COSTS
As shown below, Syracuse calculated the average unit costs for the various steps involved in lead
dust sampling and cleaning activities. Once the city had purchased its own XRF equipment and
had a licensed risk assessor on staff, it discontinued using a consultant to perform many of these tasks.
Using in-house staff and equipment, Syracuse's average costs were $181 per home, less than half the cost
of using a consultant ($375). The single most expensive cost was for laboratory analysis: $54 for pre-
cleaning sampling analysis ($9 per sample; 5—6 samples per household) and $27 for post-cleaning analy-
sis ($9 per sample; 2—3 samples per household).
SYRACUSE'S LEAD DUST CLEANING—AVERAGE UNIT COSTS
Step
Initial Sample
Analyze initial samples via XRF;
submit confirmations to lab
Generated initial results report
Home visit to drop off vacuum;
educate occupants on three-step cleaning
Post-sampling; pick up vacuum
Analyze post-cleaning samples via XRF;
submit confirmations to lab
Laboratory analysis
Time
30 minutes
1.5 hours
15 minutes
30 minutes
30 minutes
1.5 hours
Pre-samples (5—6 samples)
Post-samples (2—3 samples)
Cost
$5-25
$15-75
$2.60
$5-25
$5-25
$15-75
$54.00
$27.00
Vacuum bag replacement $ 15 - 00
Vacuum filter replacements $35-00
*Average cost per home (in-house, City of Syracuse) $181.00
*Total cost per home (contractor at $50 per hour) $375-00
*This cost does not include administrative overhead. Syracuse used a consultant and Niton instrument
until the City was able to purchase its own Niton and train its own risk assessor.
*Total costs ranged from $181.00 to $375.00 per home
CO NT. ON NEXT PAGE
LEAD DUST PROJECT OVERVIEW
1 9
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A WORD ABOUT LEAD DUST CLEANING COSTS, CDNT.
Overhead Cost:
Program Manager: Reviews all aspects of
program, reports, and development of the QAPP 10% yearly cost $6,032.00
Purchase of 30 HEPA Vacuums @ $272.00 each $8,160.00
(One-time purchase)
Training of staff (risk assessor, $470.00
EPA Region 2 certification)
Purchase of XRF machine (one-time purchase) $24,880.00
Replacement of the radiation source of Niton $7,300.00
Radiation licensing (New York State) $1,695-00
Safe for Niton $200.00
Computer equipment/XRF and office supplies $2,500.00
Dosimetry badges ($64.00 per quarter) $256.00
TOTAL $51,473.00
REPORTING
Each participating resident receives a report stating whether a sampled area was above or below
the reference levels for lead dust hazard. (See the sample pre-mitigation letter and report at the
end of Chapter 8). Originally, the Syracuse project team intended to have these report templates
translated into Spanish and Vietnamese but this was determined to be impractical due to the
need to communicate site-specific information. Instead, the report is immediately mailed to the
resident. For those households requiring mitigation, the report is also presented and explained
by the data analyst/certified risk assessor at the time of the home visit, when the HEPA vacuum
is delivered and the cleaning process is explained. When necessary, the risk assessor is accompa-
nied by a native speaker who interprets the information for the resident.
In addition to the report, each resident receives printed information on appropriate use of HEPA
vacuums, the three-step cleaning process, and a list of suggested cleaning agents. In approximate-
ly ten percent of the homes tested, the field sampling technician collects additional samples after
the resident cleans the home with a HEPA vacuum. These samples are used to present a post-
mitigation report that compares dust levels after mitigation to the reference levels. To reach a
larger segment of the public, Syracuse's Web site at posts maps
and data showing lead levels in the community, while keeping property-specific lead levels confi-
dential. See Chapter 8 for more information on reporting.
EVALUATION
The Syracuse Lead Dust project ensures program effectiveness in several ways. It solicits a direct
response from the residents who participated in the cleaning and HEPA vacuuming program.
Z O CHAPTER
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The Syracuse lead dust technician asks residents a series of questions, including their thoughts
on the effectiveness of the program and about using the HEPA vacuum. Another way the
Syracuse team measures program success is by tracking the number of lead dust walk-throughs
conducted, and the number of residents that use the HEPA vacuums through the loaner pro-
gram. In addition, the Syracuse team conducts post-mitigation sampling (see section 5-1) and
encourages residents to continue lead dust mitigation activities such as using a HEPA vacuum
(see section 7.1). See Chapter 9 for more information on program evaluation.
3.3 SELECTING PROJECT PARTNERS
Syracuse has successfully involved people with diverse and specialized skills in its lead dust proj-
ect. These include people with skills in program management, risk assessment, and communica-
tions. Syracuse has effectively partnered with several organizations, including EPA, an analytical
laboratory, the Onondaga County Health Department, and the seven CBOs. Lead Safe, LLC, a
contractor, handles coordination and implementation of sampling efforts, and coordinates with
the contracted laboratory.
TESTING LABORATORY ^ amples from potentially lead
l^_l dust-contaminated houses
Syracuse established the following requirements for laboratory , , , , , ,
1 ' should be sent to a testing laboratory
testing services: . , , rri., XT . IT j
recognized by EPAs National Lead
• The selected laboratory must be certified by EPAs National Laboratory Accreditation Program
Lead Laboratory Accreditation Program (NLLAP). (NLLAP). Labs accredited by the
I NLLAP are proficient in testing for
lead in air, paint, soil, or dust (see
Syracuse Lead Dust Project with a copy of its accreditation Selecting a Laboratory for Lead Analysis:
from the American Industrial Hygiene Association (AIHA). The EPA Nationai Lead Laboratory
• The laboratory must show proficiency during the past five Accreditation Program, EPA 747-F-99-
f~\f~\f~} A "1 1 OOO\
consecutive years in the Environmental Lead Proficiency ' Pri
Testing (ELPAT) Program which is administered by the
AIHA for paint chips, dust wipes, and soils.
• Laboratories must be New York State Department of Health ELPAT-approved.
• The selected firm is required to comply with the City of Syracuse's equal employment
opportunity requirements. A copy of these requirements can be obtained from the Office of
Economic Development upon request.
COMMUNITY-BASED ORGANIZATIONS (CBDs)
Like most urban areas in the United States, the City of Syracuse has experienced a dramatic
influx of immigrants from Latin America, Asia, and Eastern Europe. These ethnic populations
have been hard to reach with information about lead exposure, because of language barriers and
unfamiliarity with the issue. Preoccupied with pressing issues of daily survival, new immigrants
often fear government agencies or programs. Establishing a link to these people through com-
munity organizations that have bilingual members is key to reaching this population.
The CBOs involved in the Syracuse Lead Dust Project offer a diverse array of services to help
immigrants, including teaching English as a second language, child care, and job placement
LEADDUSTPRDJECTDVERVIEW 21
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services. Through its existing HUD program, the lead hazard control program already had
working relationships with some of the CBOs. Thus, when Syracuse launched its lead dust
program, it involved those CBOs that provided geographic coverage, as well as those that
already were reaching mothers and families with small children through their other program
activities. In addition, Syracuse actively advertised the project and recruited additional CBOs
to participate.
CBDs PROVIDE COMMUNITY ACCESS
As previously mentioned, one of the primary ways that Syracuse's staff gain trust and access to
potential program participants is through their involvement in CBOs that typically serve people
in a two- to three-mile radius around the center. The following CBOs participate in lead dust
education and outreach activities in Syracuse:
• Boys & Girls Clubs of Syracuse—A youth development agency whose goal is to inspire
and enable all young people in the Syracuse area, especially those from disadvantaged cir-
cumstances, to realize their potential as productive citizens,
• Brighton Family Center—A neighborhood center that provides a variety of services in a
predominantly African-American neighborhood. Services provided include a Young Mothers
Program for teens who are pregnant or parenting, preschool and after-school programs, and
teen programs.
• Girls, Inc. of Central New York—Provides opportunities for girls to meet the challenges of
the future by developing their potential through creative programs for girls and their fami-
lies.
• Syracuse Northeast Community Center—Helps ensure the physical and emotional well
being of children, families, seniors, and other individuals in the north/northeast section of
Syracuse,
• Southeast Asian Center—Serves the Southeast Asian population in Syracuse, which
includes more than 3,400 Hmong, Laotian, Vietnamese, Chinese, Korean, and Cambodian
people. The center provides various supportive community-building activities, programs, and
services to assist Southeast Asian immigrants in assimilating into the central New York com-
munity. < www irccny. org/programs/seac. shtml>
• Southwest Community Center—Works with individuals, families, and communities to
promote health and well being through prevention, intervention, and education.
• Westcott Community Center—Provides a safe, accessible community space for activities
and programs that meet community needs; strengthens and unites the community by bring-
ing together its diverse elements; raises awareness through public education and art; and pro-
motes the full inclusion of all persons,
The CBOs play a primary role in program outreach, and Syracuse's Lead Dust Project has
developed strong and cordial working relationships with them. Through the trust and positive
reputation engendered by these organizations, the city's lead program has been able to reach a
segment of the population it had difficulty reaching before. The CBOs have helped translate
information into Spanish and Vietnamese. The program also intends to produce Bosnian trans-
lations to provide that growing population with information about lead safety.
22 CHAPTER
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COMMUNICATING WITH A NON-ENGLISH SPEAKING AUDIENCE
Partnering with agencies and community based organizations (CBOs) that cater to a large non-
English speaking audience often presents special challenges, but working with these CBOs pro-
vides a vital link to the non-English-speaking community in Syracuse.
First and foremost, their clientele is often frightened. Arriving from third-world countries and war-torn
nations, these people are easily intimidated by any type of government intervention. Populations of
Vietnamese, Bosnians, and Hispanics are more concerned about getting jobs, locating housing, and appro-
priate schooling for their children. Childhood lead poisoning is not a priority issue as these people are just
struggling to survive every day in a new and foreign land. Fear of government is another obstacle when
dealing with immigrants. Syracuse partners with organizations that represent these non-English speaking
groups since they have already gained the trust of community residents. This makes the job easier—with-
out the CBOs it would be nearly impossible to reach these special groups. CBO representatives serve as
interpreters during face-to-face meetings with prospective program participants (tenants) to ensure effective
communications. This involves more time and scheduling to arrange meetings and home visits.
Many residents near the Southeast Asia Community Center speak Vietnamese, Chinese, and
Korean, so the project conducts outreach and education in those languages.
Project staff have worked to gain trust, knowing the sensitivities involved in interacting with
residents in their homes. Syracuse staff knew that homeowners or tenants might be reluctant to
participate because cleanliness and housekeeping are generally considered to be private issues.
New immigrants with few alternative housing options might be reluctant to apply for fear they
could get in trouble with the landlord. By ensuring confidentiality, Syracuse successfully avoid-
ed these pitfalls.
Because the CBOs are located in neighborhoods with high lead levels, they are the logical and
convenient locations from which to operate a HEPA vacuum-loaner program. Each participat-
ing CBO is given wide latitude in the way it recruits residents to participate in the lead dust
monitoring project. The CBOs are encouraged to design creative, effective outreach tactics.
Several CBOs have initiated competitions to increase recruitment. For example, the Boys and
Girls Clubs (of which there are three in the city), rewarded the club with the most lead dust
project applications with a pizza party.
Maintaining the strong personal relationships is also vital to the program's success. Project staff
visit each CBO at least once a week to touch base about community issues and to restock the
lead information on display there. Syracuse's outreach
coordinator is invited by the CBOs to many different
community events, including holiday parties, picnics, — _he HŁLp Lead Safe program in
| Pr
and meetings. Often, the Syracuse staff gives the CBOs | Providence) Rhode Island> ^ has found it
crayons, coloring books, pencils, and small bars of soap tremendously important to involve bilingual
to hand out to children. Much of the handout material members of the community in program out-
is donated by local businesses. The crayons are printed reach> especially mose wim lead_sick children
with an important safety message— they are labeled as themselves. Providence also has a Spanish-speak-
bemg lead free according to ASTM D-4236. The bars of ing staff member to build tmst with the large
soap are a perfect way to remind children of the impor- Latino population targeted by me program.
tance of hand-washing.
LEADDUSTPRDJECTDVERVIEW 23
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PARTNERSHIPS THAT WORK
The city of Minneapolis partnered with neighbor-
hood hardware store owners to implement the
HEPA vacuum loaner program. The city has educated
and trained hardware store personnel and has established
Neighborhood Lead Centers in several locations.
Minneapolis successfully recruits these business owners
by showing them how they can benefit and how their
knowledge about lead dust can serve as a marketing tool.
The program also educates day care providers, who then
educate the parents. Minneapolis also has enlisted the
involvement of public health nurses who educate the
children in day care settings about the importance of
washing their hands and taking off their shoes.
Once a month, Syracuse brings all seven
CBOs together to discuss successes and chal-
lenges in signing up community members for
the HEPA vacuum program. The group dis-
cusses performance goals and measures they
have taken to meet these goals. While atten-
dance at monthly EMPACT meetings is
good, high CBO staff turnover requires both
continual and often repeated training.
The CBOs also recruit bilingual community
members, who become ambassadors for the
lead dust effort and help enlist program par-
ticipants. Chapter 4 has examples of tools the
Syracuse Lead Dust Project and the CBOs
have used in conducting outreach.
Syracuse conducted a CBO survey in the
Spring of 2002 to assess program effectiveness
and to determine ways to increase program participation. A copy of the survey questionnaire is
included in Chapter 9. The survey findings indicate that:
• Tenants can be reluctant to participate in the HEPA vacuum program for a variety of rea-
sons, including not wanting strangers to come in their house, fear of upsetting their land-
lord, or thinking the program does not pertain to them.
• Tenants often are embarrassed because they feel they are being judged on their housekeeping
or cleanliness.
• CBOs need more tools like flyers, newsletters, and Web sites to educate the tenants in their
community.
Based on the survey findings, Syracuse asked the CBOs to write implementation plans to guide
their outreach activities and to bolster recruitment. As of July 2002, six of the seven plans had
been submitted. Syracuse reviews and approves the plans, which then serve as blueprints for
program implementation. The plan for the Westcott Community Center is shown on page 25
as an example.
2 4
CHAPTER
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WESTCDTT COMMUNITY CENTER
EMPACT DUTREACH ACTION PLAN
Activities within the After School Program in the month of June:
• Poster contest with the After School Program during the month of June as well as viewing the Sesame
Street video to prepare the kids with information. (Target yield is to have 7-10 kids involved).
• Dinner with the kids and their parents. We would like to have a showing of a presentation of the
HEPA VAC. Also at this time, the winner of the poster contest will be honored. (Target yield is 4-6
families that would get involved in and go through the HEPA program).
• We plan to follow-up with a letter to the parents and ask them again if they would like to go
through the process.
Membership Involvement
• We plan to target a key group of members through a letter campaign and get them to go through
the HEPA VAC program.
Board Involvement
• During a board meeting, we will request that all board members sign up to go through the HEPA
VAC process. Target yield is 11 of 15 members. This would include a letter campaign.
• We would like to have Mike Goss and Adam present on this board.
Employee Involvement
• We will request that all employees and stakeholders living within city limits go through the HEPA
VAC Program. Target yield is 5- (Susan and Gloria)
Volunteer Involvement during the Fall of 2002 and Spring of 2003
• Encourage all student volunteers (college, university, high school) to go through HEPA VAC
Program. We hope to have at least 25 percent of volunteers get involved.
Local Organization Involvement
• Attempt to partner with local schools to write articles regarding the HEPA VAC Program.
• Credit Union: Home Ownership Program.
• Partner with the Westcott Community Development Corporation in relation to joint marketing
schemes. He periodically performs outreach to the neighborhood through door hangers.
Program Involvement
• We plan to target a small group of key program users and renters to encourage them to go through
the HEPA VAC Program. (Target yield is 5-6 families).
• We have put in a grant proposal to become a site for the Parent Success Initiative. Should we
receive it, we would encourage residents to go through the HEPA VAC Program.
Direct Outreach
• Newsletter.
• Vista Volunteer.
• Letters to members and program users.
What we need to assist us in the process:
• We are hoping to receive a one-page document that can be given to potential HEPA VAC renters
that would clearly define and explain the process and what they can expect, should they go through
the process.
• Be available for the booking of speakers and presentations.
LEADDUSTPRDJECTDVERVIEW 25
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4
C D M M U N I C AT I N G
ABOUT LEAD DUST
This chapter describes how Syracuse educated residents about the problem of lead dust
in homes and the benefits of their participation in the project. Information in this
chapter is designed primarily for managers who are implementing lead dust monitoring
and outreach programs and for outreach workers who are responsible for communicating about
lead in the home.
• Section 4.1 describes the outreach methods and materials used by Syracuse to inform and
involve affected households and community members.
• Section 4.2 discusses the types of skills needed by Syracuse's outreach workers, dealing with
language and cultural barriers, interviewing potential program participants, and promoting
and advertising the lead dust program.
• Section 4.3 provides examples of some of the most effective outreach and educational mate-
rials used by Syracuse.
4.1 SYRACUSE'S DUTREACH METHODS AND MATERIALS
Syracuse's strategy for reaching parents and care givers of at-risk children was to utilize the
CBOs. Through them, the lead dust project tapped into community events. Communities with
mature lead awareness and abatement programs will probably just need to add specific lead dust
information to existing lead outreach materials and activities. A municipality without a HUD
or other lead program in place will need to develop a more comprehensive lead dust outreach
plan. The following are some of the creative lead dust education and outreach tools developed
by the city of Syracuse. Several examples are provided at the end of this chapter:
• Milk cartons. Syracuse's outreach coordinator contacted a local dairy and requested that the
lead program's message be printed on the back of its milk cartons. The dairy worked the
"Got Lead?" message into its rotation of milk carton panels. More than 100,000 households
in central New York learned about lead dust through this outreach method.
• Ce-LEAD-brity. Syracuse wrote personal letters to more than 100 local and national celebri-
ties asking them to help fight childhood lead poisoning by sending an 8" by 10" autographed
photo with a personal message, such as "Be a lead fighter," or "Keep your neighborhood lead
safe." The city collected more than 40 autographed photos from TV and radio personalities
and celebrities, including Whoopi Goldberg, Jim Carrey, Big Bird, Mr. Rogers, the Sesame
Street gang, Fats Domino, John Travolta, and numerous athletes. Syracuse's display has been
exhibited widely in the community, as well as at two national lead safety shows.
• Slide show. The City of Syracuse has created several slide shows for various conferences and
exhibitions. "Soup to Nuts", in particular, is a step-by-step sequence of the city's lead dust
program. The slide show—a useful tool for communicating to homeowners, landlords, and
other prospective clients—gives prospective applicants an idea of the various steps required
to go through the program.
• Free soap. Because the project emphasizes that children keep their hands clean, Syracuse
puts bars of soap in "goodie bags" handed out to children. The program contacted local
26 CHAPTER
-------
hotels and restaurants and persuaded them to donate thousands of small bars of soap. These
businesses benefit from the positive community relations engendered by their donation, and
the children receive a real tool that helps reduce their lead exposure.
• Holiday-related outreach. Syracuse developed a "Hol-lead-day Coloring Book" and distrib-
utes it to children during the winter holiday season. It also developed another coloring book
with a St. Patrick's Day theme. The books included holiday-themed pictures for children to
color, along with safety messages to help reduce lead exposure. The city also held a pump-
kin-painting contest at Halloween to promote National Lead Poisoning Awareness Week and
distributed information on getting children tested for lead poisoning with Thanksgiving
food baskets.
The following table summarizes the various outreach materials, languages, and distribution
channels used by three lead dust programs to provide a sense of the types of materials that can
be used to recruit program participants:
Program/City
Syracuse, NY
EXAMPLES OF COMMUNICATIONS MATERIALS AND MEDIA
USED To REACH RESIDENTS BY SEVERAL LEAD DUST PROGRAMS
Communications Format/Material Languages Media/Distribution Channels
Coloring/activity books for children
Milk cartons
Celebrity photos
"Look Out for Lead" flyer
Parents' Reference Guide
Video PSA
Publications and pamphlets
English
Spanish
Vietnamese
Hmong
Chinese
Korean
Laotian
Cambodian
Bosnian
Braille
CBOs
Directly to residents and
kids
Local food markets
Personal contact
Web site
Cable television
Holiday gift baskets
Luncheons
Special events at the
convention center
Providence, RI
Pamphlets
Videos
Minneapolis/St.
Paul, MN
Pamphlets
Video
Radio announcements
In-store posters, signs,
counter displays
English
Spanish
Cambodian
Nigerian
Liberian
HELP Lead Safe program
English
Somali
Spanish
Hmong
Cable TV
Radio
Transit ads (bus shelters)
Visiting Nursing Association
Public health clinics
Libraries
Neighborhood retailers
Day care providers
COMMUNICATING ABOUT LEAD DUST
2 7
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MINNEAPOLIS/ST. PAUL PLUGS INTO
LOCAL MEDIA OUTLETS
The Minneapolis/St. Paul area has the largest
Somali immigrant population in the United
States. Many of these residents are fearful of govern-
ment and are largely illiterate. In addition to reaching
them through CBOs and with translated material dis-
tributed in public health clinics, the program is also
using local Somali-language cable TV and radio sta-
tions. Minneapolis also is using donated advertising
space to place informational posters in bus stop shel-
ters within targeted neighborhoods. Minneapolis
finds that free "remnant" (unsold) transit advertising
space is often available in low-income neighborhoods.
• Video Public Service Announcement.
Syracuse produced a video public service
announcement (PSA) for the local cable televi-
sion station. The mayor's public relations coordi-
nator, who had been a local television news
anchor, was instrumental in getting the PSA pro-
duced and aired. The PSA text is included at the
end of this chapter.
4.2 APPROACHING AND
RECRUITING PROGRAM
PARTICIPANTS
In Syracuse, one of the biggest challenges has
been overcoming residents' discomfort with
strangers coming into their homes. Some people
might worry that if inspectors identify a lead
hazard, the government might make them move
or might call social services to report lead poisoning in the children. In addition to the frustra-
tions of trying to communicate with limited English language skills, residents might also feel
anxious about the possibility that their child might be lead-poisoned. Syracuse overcame these
challenges by hiring non-threatening, sensitive, appropriately dressed staff with strong "people
skills" to conduct home visits and to teach affected households the proper cleaning methods.
According to Syracuse's outreach coordinator, "Many people don't want someone telling them
how to clean their homes. It's like trying to teach an adult how to brush their teeth—they don't
want to learn because they've been doing it for years." As an example, a woman in Syracuse who
was remodeling her home had exposed her child to lead poisoning. She very much feared that if
she enrolled in the program, something would happen to her child or to her home. She was
finally persuaded to participate and was so pleased after using the HEPA vacuum and seeing the
post-intervention results that she purchased her own HEPA vacuum to keep treating her house.
A warm, friendly disposition goes a long way toward gaining trust. "Be assertive but still friend-
ly, and emphasize that the program promotes children's health," representatives from Syracuse
advise. Thanks to their success in relationship building, Syracuse's Lead Dust Project staff can
MINNEAPOLIS' LEAD INSPECTORS NEED "PEOPLE SKILLS"
The city of Minneapolis recognizes the important interactive role lead inspectors play. Not only are
they technical experts and program enforcers, but they also are program ambassadors. Because inter-
personal skills are so vital, the city is adding such requirements to its job description for lead inspectors.
In fact, "people skills" are necessary not only to recruit program participants, but also to interact with
property owners, who must ultimately remediate the lead contamination in their buildings. The draft job
description includes the following language:
Human relations communication and group facilitation skills are of primary importance because of the inter-
action with large numbers of people and organizations from diverse backgrounds. Excellent oral and written
communications skills are, therefore, essential, as is the ability to mediate and resolve disputes.
2 a
CHAPTER
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Syracuse project staff meet with CBO representatives
walk into any of the CBOs and be greeted
with a smile and a hug.
DTHER LESSONS LEARNED
Syracuse learned the importance of timing in
program implementation. Project staff learned
the hard way to wait until all elements were
finalized and approved before making public
announcements. Early outreach efforts drew
participants who were ready to begin treating
their homes, but EPA could not allow
Syracuse to collect dust wipe samples until the
Quality Assurance Project Plan (QAPP) was
finalized and approved. Therefore, Syracuse
staff had to delay the start of the implementa-
tion phase until all program components were
in place, but they felt the wait was worthwhile because of the valuable framework provided by
the QAPP.
Another pitfall of successful outreach occurred when a large number of people wanted to bor-
row the HEPA vacuums without formally joining the program. The solution to this dilemma
was to lend the vacuums to anyone interested but to give first priority to those who had signed
up for the full program.
4.3 RESOURCES FDR ADDITIONAL INFORMATION
EPA and the City of Syracuse have developed a variety of resources to help community mem-
bers learn more about lead dust issues. Several examples of Syracuse's lead dust materials are
included at the end of this chapter. Residents can also order the following publications to teach
them more about safely managing lead dust in their homes:
A series of pamphlets: City of Syracuse Lead Program for Homeowners and Investor-Owners;
City of Syracuse Lead Dust Outreach, Monitoring and Education Program (in English and
Vietnamese), City of Syracuse Department of Community Development. Order by calling 315
448-8710.
Lead in Your Home: A Parent's Reference Guide (in English and Vietnamese), U.S. EPA Office
of Prevention, Pesticides, and Toxic Substances, EPA 747-B-99-003, May 1999.
Identifying Lead Hazards in Residential Properties (EPA Fact Sheet), U.S. EPA Office of
Prevention, Pesticides, and Toxic Substances, EPA 747-F-01-002, April 2001.
Risk Communication in Action: Environmental Case Studies, U.S. EPA, EPA 625-R-02-011,
September 2002.
Testing Your Home for Lead in Paint, Dust, and Soil, U.S. EPA, Office of Pollution Prevention
and Toxics, EPA 747-K-00-001, July 2000.
Fight Lead Poisoning with a Healthy Diet, U.S. EPA, Office of Pollution Prevention and
Toxics, EPA 747-F-01-004, November 2001.
COMMUNICATING ABOUT LEAD DUST
2 9
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Protect Your Family from Lead in Your Home (in English and Spanish) U.S. EPA, U.S.
Consumer Product Safety Commission, and U.S. Department of Housing and Urban
Development, EPA 747-K-99-001, September 2001.
Reducing Lead Hazards When Remodeling Your Home (in English and Spanish) U.S. EPA,
Office of Pollution Prevention and Toxics, EPA 747-K-97-001, September 1997.
For more resources, visit EPA's Office of Pollution Prevention and Toxics (OPPT) Lead Web
Page at or call 1-800-LEAD FYI to order EPA publications.
3D CHAPTER
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n
D
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CT
ra
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en
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Community Fanners:
Brighton Family Ctr.
424-9378
Girls Inc. of CNY
474-0746
Boys & Girls Clubs
of Syracuse
472-6714
Southeast Asian Center
422-1593
Syracuse Northeast Com. Ctr.
472-6343
Southwest Community Ctr.
474-6823
Westcott Community Ctr.
478-8634
Working Together Jo Create Low
Cost Solutions
oEPA
MM3BH
>
LEAD-SAFE
AMERICA
Department of
Community Development
Betsy Mokrzycki
Lead Hazard Control Program
201 E.Washington St.
Syracuse, N.Y. 13202
Phone:448-8710
Fax: 448 - 8659
http://www.syracuse-empact.com
1
SEPb
•
EMPACT
© 2001 Lead Safe, LLC All Rights Reserved. (315)685-0864
CITY OF SYRACUSE
Lead Dust
Outreach,
Monitoring and
Education Project
Matthew]. Driscoll, Mayor
Deportment of
Community Development
Tel: 315-448-8710
-------
CO
N
n
i
111 WDM
EMPACT
Environmental Monitoring for PuWic Access 6 Community Tracking
WhatisEMPACT?
In 1996 a Presidential initiative charged EPA and its
partners with developing a program to improve
the measurement, access, understanding and dis-
semination of key environmental information in
the US metropolitan areas.
What are EMPACT's goals?
• D Incorporate improved and upda ted
tec hnologies for time -relevant enviro n-
mental measurement and monitoring.
• D Facilitate public access to comprehe n-
sive, easily understood environmental
information.
• D Provide effective tools for communica t-
ing, interpreting, and applying enviro n-
mental data and information.
• D Establish partnerships within metro a r-
eas to ensure the information is useful
and timely for families and communities
• D Develop a management and data
from ework within which communities
can work, but which also provide the
ability to aggregate information on a D
local, regional, and n ational scale.
.Atonic Number: 8Z
AtomkMiss. 207.20
How Does the City of Syracuse fit in?
Funded by a grant from USEPA, the City of Syracuse has
developed a program designed to measure the lead dust
content in homes. Aided by community based organiza-
tion partners, the City will make available HEPA Vacuums
that can be borrowed as needed to control leaded dust.
Also, the program will provide current data and informa-
tion on a web site.
How much of a hazard is lead dust? More children
are poisoned by exposure to lead dust from lead-based
paint in older homes than by any other source, usually
through normal hand-to-mouth activity after getting lead
dust on their hands and toys!
What is a HEPA Vacuum? A High Efficiency P articu-
late A ir vacuum is a vacuum that is equipped with a filter
that is capable of trapping 99.97% of the dust that it col-
lects.
Why can't I just use my household vacuum? The
lead dust is so fine that your regular vacuum cannot
contain the dust. It simply flows through the bag only
to be spread around your home.
A HEPA vacuum looks just like my shop vacuum,
can't I just use that? No! Shop vacuums are not
equipped with HEPA filtering equipment and therefore
cannot trap the tiny lead particles.
http://www.syracuse-empact.com
Alliance to End Childhood Lead Poisoning
How do they measure lead in the dust? The
program will collect samples from various places in
your home to determine if a lead dust hazard ex-
ists. These samples will be analyzed utilizing a
portable XRF.
What is an XRF? An XRF is a testing device
that is capable of determining the presence of lead
in a dust wipe sample. Since this is cutting edge
technology, some of the samples will be sent to a
lab for confirmatory analysis.
How do I pan icipate in the program? Simply
call the City or the partner listed on the back in
your area and request to enroll in the HEPA vac-
uum program. Its easy and it's a simple way to
protect your family from lead hazards.
CALL TODAY!!
448-8710
Department of
Community Development
Betsy Mokrzycki
Lead Hazard Control Program
201 E.Washington St.
Syracuse, N.Y. 13202
Phone:448-8710
Fax: 448 - 8659
http://www.syracuse-empact.com
-------
DEPARTMENT OF COMMUNITY DEVELOPMENT
LEAD HAZARD CONTROL PROGRAM
Matthew J. Driscoll, Mayor
PSA...EMPACT PROGRAM
If you own a home or rent an apartment in the City of Syracuse, or
if you are an investor-owner of City residential property, take
advantage of the free use of our Hepa-vacuum cleaner in your
home today. This specially designed vacuum cleaner can help
eliminate potentially hazardous lead dust, allergens, pollens and
dust mites from your home. For more information call the City of
Syracuse's Lead Hazard Control Program at 448-8710.
"We 're puttin' the ain't in lead paint!"
4/02/02
mag
COMMUNICATINGABOUTLEADDUST 33
-------
WE ARE LOOKING FOR PEOPLE ©
WHO RESIDE IN THE CITY WHO
WOULD LIKE TO USE OUR HEPA-
VAC FREE FOR 1 WEEK.
THIS SPECIALLY DESIGNED
VACUUM CLEANER CAN HELP
ELIMINATE POTENTIALLY
HAZARDOUS LEAD DUST FROM
YOUR HOME OR APARTMENT.
CALL US AT 448-8710 AND ASK
FOR ADAM OR MIKE. ©
City of Syracuse
— Lead Paint Program: 315-448-8710 —
34
CHAPTER 4
-------
ATTENTION KIDS!!!
Have your moms and dads fill out the Intake Form
and
They can use one of our special hepa-vacuum
cleaners free for one week.
These vacuum cleaners are specially designed to pick
up and trap dangerous lead dust particles. It also
removes dust mites and other particles that might
cause allergies and/or other breathing disorders.
Just bring the filled-out form back to the Boys &
Girls Club and your name will be put in our raffle
box. You could win a computer game just for
getting mom or dad to fill out the form. Now that's a
good deal!!! ©
If you mom or dad has any questions tell them to call
Mike or Adam at 448-8710. We're in 8:30 to 4:30
Monday thru Friday.
Help us make your home cleaner and healthier and
you can be our lucky winner. Be lead safe and
remember healthy kids are happy kidsl © © ©
City of Syracuse Lead Program
448-8710
COMMUNICATINGABOUTLEADDUST 35
-------
DEPARTMENT OF COMMUNITY DEVELOPMENT
LEAD HAZARD CONTROL PROGRAM
Matthew J. Driscoll, Mayor
Attention Landlords;
Enclosed is some lead-friendly information provided to you by the
City of Syracuse's Lead Hazard Control Program. We offer
money for qualified owner-occupants as well as investor-owners to
reduce potential lead hazards in City homes. Through our
EMPACT Program we can also provide homeowners and/or
tenants the use of a Hepa-vac free for one week. This specially
designed vacuum cleaner can significantly reduce hazardous lead
dust as well as dust mites and other allergens in your home.
For more information on either program, please contact us at
(315)448-8710.
We're hoping to make your homes lead-safer for your children.
Thanks for helping us!
City of Syracuse
Lead Hazard Control Program
www.syracuse.ny.us
http:.'V'\v\v\v.svrempact.!ead-safe.corn
201 E. WASHINGTON ST. • RM. SCO • SYRACUSE. NEW YORK 13Z02-143O • (315) 448-8710
Web Page: www.iyncute.ny.u*
36 CHAPTER
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COLLECTING AND MANAGING
DATA ON LEAD DUST
This chapter describes the steps taken by Syracuse to collect and manage samples on lead
dust in homes. With a target of 350 homes, Syracuse collects dust wipe samples in a
way that ensures the quality of the data and that also helps participants understand the
procedure and findings.
• Section 5-1 outlines the chronology of interactions with participants, including sampling,
mitigation, and reporting.
• Section 5-2 discusses step-by-step in-home lead dust sampling.
• Section 5-3 describes the role of the Quality Assurance Project Plan (QAPP).
• Section 5-4 offers resources for additional information.
Syracuse has integrated X-ray fluorescence (XRF) technology into its lead dust program. An
XRF is a small portable device capable of reading lead dust wipes and determining lead levels in
seconds. This technology provides significant time savings when compared to sending dust
wipes away for traditional laboratory analysis. Although XRF technology is not yet an EPA-
approved method for analyzing lead dust, it has been demonstrated to provide reliable and rep-
resentative results when compared with laboratory data.
Syracuse's QAPP specifies the procedures for using XRF analysis of lead dust samples. It also out-
lines the steps necessary to statistically correlate XRF results with laboratory results. Read more
about how Syracuse established a statistical correlation between XRF and laboratory results in
Chapter 6. See Section 5-3 below and Appendix B for more information about the QAPP
5.1 CHRONOLOGY: FROM DATA COLLECTION TO REPORTING
After a resident signs up for the program, Syracuse staff visits the home and collects lead dust
data. The protocol used by Syracuse staff to interact with participants is as follows:
Step 1. Call participant to set up appointment to collect pre-mitigation dust samples.
Step 2. Gather pre-mitigation samples from the designated sampling locations; leave residence.
Step 3. Read samples with XRF (see Chapter 6).
Step 4. If necessary, send pre-mitigation samples to accredited laboratory for confirmatory
analysis.
Step 5. Call participant to report results and mail written report.
Step 6. If necessary, set up appointment to review sample results, drop off HEPA vacuum, and
explain three-step cleaning procedure. (See Chapter 7 on Mitigation).
Step 7. Arrange for HEPA vacuum pickup and post-mitigation sampling, if necessary.
Step 8. Read post-mitigation samples with XRF.
COLLECTING AND MANAGING DATA ON LEAD DUST 37
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Step 9. If necessary, send post-mitigation samples to accredited laboratory for confirmatory
analysis.
Step 10. Mail or deliver final report to participant and landlord. (See Chapter 8 for Reporting.)
A Syracuse Lead Dust Project staff member interacts with residents during sampling and mitiga-
tion. This person is a certified inspector/risk assessor who collects the samples following the
protocol in the QAPP and ensures that the samples are labeled and recorded correctly before
sending them off for confirmatory analysis. He also sets up appointments and explains the ben-
efits of the program and the cleaning process to participants. He makes the experience pleasant
and positive for the resident and assures them that the information is confidential and will not
jeopardize their tenancy at the property. As soon as results are available they are mailed to the
resident and project staff visit the home if the resident decides to participate in the HEPA loan-
er program.
5.2 VISITING THE HOME (STEP-BY-STEP IN-HOME SAMPLING)
Syracuse usually allots about a half-hour for sampling a typical residence. Initially, sampling
took about an hour, but Syracuse soon halved that time as staff became more familiar with the
process and began using XRF to analyze samples offsite instead of at the residence.
As previously discussed in Section 3.2, project staff first interviews the resident using the HEPA
Vacuum Intake Questionnaire, a copy of which can be found at the end of this chapter. During
the home visit, staff review the information with the resident and also visually examines the
house, identifying the principal play areas and determining where children spend most of their
time. By asking questions and observing current conditions in the house, high-risk or high-use
areas are identified.
Syracuse uses the same protocol for collecting samples, whether they are analyzed by traditional
laboratory analysis, field portable XRF technology, or both. The field sampling technician col-
lects dust wipe samples in accordance with the HUD Guidelines for the Evaluation and Control
SYRACUSE USES CERTIFIED RISK ASSESSORS
New York State is one of 13 states that choose to follow federal regulations for lead hazard control
activities rather than establish their own state regulatory programs. Syracuse, therefore, requires
that their field sampling technicians be EPA-certified inspectors/risk assessors. An EPA lead inspector
conducts a surface-by-surface investigation to determine whether lead-based paint is present in the home,
how much is present, and where it is located. He determines the existence, nature, severity, and location
of lead-based paint hazards in a residential dwelling. The assessor performs visual inspections, tests house-
hold dust from floors and windows and other locations, and presents a report identifying the location of
the types of lead-based paint hazards and ways to control them.
The Syracuse Lead Dust Project initially contracted with an EPA-certified risk assessor but then trained
one of its own staff to become certified, thereby realizing a substantial cost savings.
Visit for a map of the United States with links to state lead programs,
or call 1-800-424-LEAD for information on the 13 EPA-run states (Alaska, Arizona, Florida, Idaho,
Montana, North and South Dakota, Nevada, New Mexico, New York, South Carolina, Washington, and
Wyoming).
33 CHAPTER
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of Lead-Based Paint in Housing at , and HUD's Lead Safe Housing Rule at .
The results are then compared to the EPA regulations at TSCA Chapter 4, Section 403 lead haz-
ard standards. Although each house is different and must be approached with its unique charac-
teristics in mind, Syracuse's testing typically focuses on three to four main areas: the principal
play area, the kitchen, and the bedrooms of the youngest children (there might be more than one
child's bedroom to test).
The most common method for collecting a dust sample is a surface wipe. Because XRF instru-
ments are very sensitive, however, the sampling medium (dust wipe) should meet ASTM E
1792-96a "Standard Specification for Wipe Sampling Materials for Lead in Surface Dust."
Syracuse purchased a Niton XRF, and initially, the sampling media provided by the contract
laboratory did not meet the Niton specifications for XRF use. The Syracuse team found that
the moisture content of the various wipes can affect the accuracy of the Niton XRF readings.
They researched and experimented with several different sampling media before finding the one
that met its needs. Syracuse found that Palintest and PACE wipes provided the most accurate
results for use with the XRF.
GUARDING AGAINST LEAD HAZARDS
When handling lead dust and samples, lead
can enter the body through ingestion,
which occurs as a result of routine hand-to-
mouth activities such as eating, drinking, and
smoking. Inspectors needed to wear gloves and
refrain from hand-to-mouth activities on the job.
When work is complete, inspectors wash their
hands upon leaving a site.
Although various testing formats are possible,
Syracuse's QAPP calls for the following 10 samples:
1. Principal play area floor
2. Principal play area interior window sill
3- Kitchen floor
4. Kitchen window sill
5. Kitchen window and trough
6. Youngest child's room floor
7. Youngest child's room window sill
8. Youngest child's room window trough
9. Floor of next youngest child's room
10. Sill of next youngest child's room
Two field blanks, labeled 11 and 12, are submitted to the laboratory with each set of samples.
At 10 percent of the residences, Syracuse plans post-mitigation sampling (i.e., samples are taken
after residents have completed the three-step cleaning/HEPA procedure). These samples, plus
two additional field blanks, are labeled 13 through 24.
Each sample bag is given a unique number (e.g., 012-07) that identifies the house (range: 001-
350) and the sampling location within the house (01—10). As inspectors take samples, they
record the lead level of each sampling location on a site worksheet. Any other relevant descrip-
tive information, such as the general condition of the paint, high levels of dust, or unusual use
of the area, is noted on the worksheet as well. Finally, the worksheet provides convenient spaces
to write down any relevant descriptive information such as the condition of paint or excessive
levels of dust.
COLLECTING AND MANAGING DATA
LEAD DUST
3 9
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5.3 QUALITY ASSURANCE PROJECT PLAN (QAPP)
A Quality Assurance Project Plan (QAPP) documents the planning, implementation, and
assessment procedures for a particular project, as well as any specific quality assurance and
quality control activities. It integrates all the technical and quality aspects of the project in
order to provide a "blue print" for obtaining the type and quality of environmental data and
information needed for a specific decision or use. All work performed or funded by EPA that
involves the acquisition of environmental data must have an approved QAPP. For more infor-
mation, visit EPA's Web site at .
Development of the QAPP required Syracuse to address essential project details. How will the
data be collected? How will the data be used? Will the data support the decision-making
process? How will the data be stored and presented? This up-front planning allowed Syracuse to
work through issues before actually encountering them and saved time during project imple-
mentation.
Syracuse found that the exercise of developing a QAPP imposed an important discipline that
guided the entire project. Syracuse took six months to develop the QAPP and continues to
update it as the project matures. Although the initial push can be challenging, Syracuse staff
believes that the process is worthwhile. A copy of the Syracuse QAPP appears in Appendix B.
5.4 RESOURCES FDR ADDITIONAL INFORMATION
Methods 6200, 601 OB, and 7420 from EPA (entitled Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods). Ordering information or a copy of the text can be obtained
online by accessing .
ASTM D1792-96a, Standard Specification for Wipe Sampling Materials for Lead in Surface
Dust, ASTM, 100 Barr Harbor Drive, West Conshohocken, PA 19428-2959. For individual
reprints call 610-832-9585; visit www.astm.org; or send an e-mail to service@astm.org.
4 O CHAPTER
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HEPA VACUUM
INTAKE QUESTIONNAIRE
Occupant Address:
Name:
Date:
Address:
Street, City, Zip Code
Telephone:,
Telephone:_
Day Time
Owners Address (If Different):
Name:
Evening
Date:
Address:
Street, City, Zip Code
Telephone^
Telephone:
Day Time
Tenant: (Y/N)
Evening
Owner/Occupant:_
Age of person Leasing HEPA Vacuum: (Please Check One)
18-21: 22-30: 31-45: 46-60: 61 orOIder:.
Household Size:
Number of Children 6 and under:
Do any children have a known elevated blood level?_
.(Y/N)
Do you know the approximate age/ year of the residence?
Length of time living in residence: Years Months:_
How did you become aware of the program? (Check One)
Friend/Relative Intemet_
Other
Media (Newspaper, Brochure)_
Community Organization
COLLECTING AND MANAGING DATA ON LEAD DUST
4 1
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6
ANALYZING LEAD DUST SAMPLES
USING XRF TECHNOLOGY
This chapter describes the steps taken by the Syracuse Lead Dust Project to incorporate
cutting-edge technology into its program. The field-portable X-ray fluorescence (XRF)
instrument is a hand-held, battery-powered device that produces timely data on lead
levels in household dust, soil, or paint. The XRF user must be trained and certified to meet fed-
eral, state, or local requirements for collection of environmental samples.
• Section 6.1 describes the advantages of XRF technology used by the Syracuse Lead Dust Project.
• Section 6.2 provides information on how Syracuse obtained the XRF equipment and associat-
ed licensing, operator training and certification, and laboratory verification of XRF analysis.
• Section 6.3 discusses the importance of quality control.
• Section 6.4 covers health and safety precautions for inspectors.
• Section 6.5 highlights equipment maintenance.
• Section 6.6 provides resources for more information.
6. 1 ADVANTAGES OF XRF TECHNOLOGY
Experience has shown that lead concentrations inside homes vary significantly. The XRF instru-
ment can instantly detect unusually high lead levels and the field sampling technician can tell
residents where children or other occupants of the household are most likely to be exposed to
lead. While Syracuse made a substantial capital investment to purchase XRF technology, in the
long term, the city is saving money with this equipment because it has dramatically reduced
costs for laboratory analysis.
To analyze a sample using the XRF, the technician places a folded wipe sample in the XRF sam-
ple holder and follows the manufacturer's procedures to get results. A 30- to 60-second meas-
urement should yield reliable results. An important benefit of XRF analysis is that the sample
remains intact so that the same samples subsequently can be analyzed by a laboratory.
Appropriate wipes that meet the requirements
of ASTM E1792-96a, Standard Specification for
Wipe Sampling Materials for Lead in Surface
Dust, should be used. See Chapter 5 for more
information on the types of wipes that Syracuse
used for sampling, and for important lessons
learned about the choice of sampling media.
The resource section at the end of this chapter
includes information for obtaining a copy of
the ASTM standard specification.
Although an XRF instrument has many advan-
tages, its purchase and use requires careful con-
sideration. Because XRFs contain radioactive
materials, operators must have valid licenses or
4 2
CHAPTER
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permits from the appropriate federal, state, and local regulatory bodies and must meet any
applicable state or local notification requirements.
6.2 REQUIREMENTS AND QUALIFICATIONS
Depending on the state, operators may be required to hold three forms of proof of competency:
a manufacturer's training certificate (or equivalent), a radiation safety license, and a state lead-
based paint inspection certificate or license.
MANUFACTURER'S TRAINING
In most states, operators must be trained by the manufacturer or receive equivalent training.
Syracuse staff took a one-day free training course on the use of the XRF instrument offered by
the manufacturer, Niton. The course met New York state requirements and covered radiation
safety, XRF theory, worker exposure, as well as hands-on analysis of dust wipes and paint chips.
RADIATION LICENSING AND SAFETY TRAINING
The U.S. Nuclear Regulatory Commission (NRC) requires radiation safety training for licens-
ing purposes. Radiation safety officer certification is necessary before NRC will grant a license
to own, operate, transfer, or store an XRF unit. Since Syracuse did not already have a radiation
safety officer involved, staff first had to undergo a rigorous training program required by the
state of New York to handle radioactive equipment. Once personnel were trained, Syracuse was
XRF USE LICENSES AND CERTIFICATION
In addition to training and any required accreditation, a person must have valid licenses or permits
from the appropriate federal, state, and local regulatory bodies to operate XRF instruments. All
portable XRF instrument operators should be trained by the instrument's manufacturer (or equivalent).
Depending on the state, operators may be required to hold three forms of proof of competency: a manu-
facturer's training certificate (or equivalent), a radiation safety license, and a state lead-based paint inspec-
tion certificate or license. To help ensure competency and safety, EPA and HUD recommend hiring only
operators who hold all three.
The regulatory body responsible for oversight of the radioactive materials contained in portable XRF
instruments depends on the type of material being handled. Some radioactive materials are federally reg-
ulated by the U.S. Nuclear Regulatory Commission (NRC); others are regulated at the state level. States
are generally categorized as "agreement" and "non-agreement" states. An agreement state has an agree-
ment with NRC to regulate radioactive materials that are generally used for medical or industrial applica-
tions. (Most radioactive materials found in XRF instruments are regulated by agreement states). For
non-agreement states, NRC retains this regulatory responsibility directly. At a minimum, however, most
state agencies require prior notification that a specific XRF instrument is to be used within the state. Fees
and other details regarding the use of portable XRF instruments vary from state to state. Contractors
who provide inspection services must hold current licenses or permits for handling XRF instruments,
and must meet any applicable state or local laws or notification requirements.
As an NRC-agreement state, New York regulates the handling of radioactive materials and the Syracuse
Project is in compliance with all relevant state regulations.
ANALYZING LEAD DUST SAMPLES USING XRF TECHNOLOGY 43
-------
able to apply for a New York state radiation license. A special safe had to be purchased to secure
the XRF with its radioactive source.
COSTS FOR THE INSTRUMENT
In addition to investing in trained, licensed, and certified staff, those seeking to implement an
extensive lead dust monitoring program may want to buy their own field-portable XRF.
Syracuse purchased a Niton Model XL309, which costs about $21,000, making it the most sub-
stantial expense the project faced. This model costs less than other Niton instruments because it
tests only for lead rather than a wide range of metals detectable with other models. The same
model with soil analysis capability would cost an additional $3,000. Programs will face an addi-
tional expense to replace the instrument's radioactive source once every two years, if not more
frequently. The Niton source costs $7,300.
Programs committed to a combination of dust, paint, or soil inspection for the long term will
find that the investment will more than pay for itself. In addition to its EMPACT Lead Dust
Project, the city of Syracuse also uses XRF technology for its HUD lead abatement program,
plus a new soil analysis program, making the cost per sample less than it would be for laborato-
ry analysis for each sample. Sending samples to a lab involves not only charges for the analysis
itself, but also the expenses of shipping and handling. After Syracuse completed Phase I and
started using only the XRF for most of the analysis, the cost savings became more apparent.
EPA VERIFIES USE OF XRF FOR
MEASUREMENT OF LEAD IN DUST
In the fall of 2002, EPA's Environmental Technology
Verification (ETV) program published a report veri-
fying the use of five field-portable XRF technologies for
the measurement of lead in dust. The Niton XL-300
and XL-700 series XRF instruments were among the
five brands tested. ETV evaluated overall performance
of the Niton as "... biased slightly high (but within
the limits of acceptable bias), very precise, and in good
linear agreement to an NLLAP-laboratory [National
Lead Laboratory Accreditation Program] result."
The ETV program facilitates the deployment of inno-
vative or improved environmental technologies
through the performance of verification and dissemi-
nation of information. The goal of the ETV program
is to further environmental protection by substantially
accelerating the acceptance and use of improved and
cost-effective technologies. For more information visit
the ETV Web site at .
6.3 QUALITY CONTROL
Quality control is an important component of
the Syracuse Lead Dust Project. The QAPP (See
Appendix B) ensures that staff follow consistent
protocols, test methods, and data management
procedures. Syracuse employs additional quality
control measures, as described in the following
section, that help meet its objectives of confirm-
ing the capabilities of XRF and training resi-
dents to reduce lead dust levels in homes.
DATA EVALUATION AND
CONFIRMATORY ANALYSIS
One objective of the Syracuse Lead Dust Project
is to validate the accuracy of XRF readings for
lead dust monitoring by comparing field XRF
data to laboratory data. Because there is no
EPA-approved method for lead dust analysis by
XRF, Syracuse judged XRF results against the
highest standards of accepted practice; namely,
inductively coupled plasma/atomic emission
4 4
CHAPTER
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(ICP/AE) and atomic absorption (AA) methods, both of which are conducted in a laboratory
and typically take two to four days to get results.4
During Phase I, Syracuse sent all samples from the first 15 homes to the laboratory for analysis
using these methods. In addition, Syracuse provided XRF data for these samples. The laborato-
ry performed a statistical comparison between samples analyzed by XRF and the same samples
analyzed by ICP/AE + AA, yielding a percent difference for each set of values. The EPA Region
2 laboratory reviewed these values and helped establish performance criteria to be used by the
field XRF operators. In conducting this evaluation, Syracuse took into account the fact that
XRF technology tends to have a bias to the low side of laboratory determined values. To protect
against false negative results due to instrument bias, Syracuse reviewed results from tests where
both XRF and laboratory methods were used. Results where the XRF reading taken was above
the laboratory result for the same sample were disqualified from the analysis as outliers. The
remaining data were separated by location type (i.e., floors, window sills or window wells); the
difference between the XRF and laboratory methods were taken for each set of samples; and a
standard deviation calculated for each location type. Results within one standard deviation
below the acceptable level are also considered positive results as a "worst case estimate". To pro-
tect against false positive results, where the
worst case estimates are within 2 times the
limit of detection, samples are sent to the
laboratory to confirm results.
The project team used these findings during
Phase II to determine which new samples
would be sent for laboratory confirmation.
After establishing a statistical correlation,
Syracuse started sending only those XRF
samples falling within a specific range to the
laboratory for confirmation (See table adja-
cent as well as the post mitigation report
entitled "Settled Dust Sample Results"
included at the end of Chapter 8). Syracuse
expects that the laboratory will continue to
refine this statistical analysis as more data
become available. Current results, however,
show an acceptable correlation between XRF
and laboratory data.
XRF READINGS REQUIRING LABORATORY
CONFIRMATION
Lab
Confirmation?
Sample Type XRF Reading
Floor >40 ug/ft2 (MDL)
Floor <40 ug/ft2
Window Sill < 100 ug/ft2
Window Sill 100 ug/ft2 and 250 ug/ft2
Window Sill >250 ug/ft2
Window Well < 180 ug/ft2
Window Well 180 ug/ft2 and 400 ug/ft2
Window Well >400 ug/ft2
No
Yes
No
Yes
No
No
Yes
No
DATA MANAGEMENT
In Syracuse, the XRF instrument is the main data management tool used by the field sampling
technician. The XRF has pre-loaded software that can read and store up to 3,000 entries
before data is downloaded to alternative storage. As explained in Chapter 5, each sample bag is
given a unique number designating the sampling location within the house. Upon completion
of sampling and analysis, Syracuse downloads the data from the XRF to the City of Syracuse
computers.
It should be noted that the samplings conducted by the Syracuse project are not regulatory compliance
tests and therefore do not require the use of an EPA-approved method.
ANALYZING LEAD DUST SAMPLES USING XRF TECHNOLOGY
-------
CALIBRATION
Niton XRFs are factory-calibrated, but regular checks are an essential aspect of quality control.
Before Syracuse's inspectors begin to test a property, they take readings on standard reference
materials (SRMs) whose lead levels are known to be within the anticipated range for lead in
household dust. A manufacturer's standard is used for this calibration check. If any of these read-
ings fail the quality control criteria, possible problems are investigated and the check is re-run
until the instrument passes. If the instrument does not pass, it is sent back to Niton to be re-cali-
brated. These same field checks need to be completed before and after each property is tested to
ensure that the calibration has remained intact throughout the testing period.
LABORATORY SELECTION
Using an accredited laboratory is an important quality control step for Syracuse. The residential
dust samples are analyzed by a laboratory on EPA's National Lead Laboratory Accreditation
Program (NLLAP) list for dust. Each state might have its own lead program and different regu-
lations. For example, the New York State Department of Health requires all labs analyzing sam-
ples from the state to be certified under its Environmental Laboratory Approval Program. For
more information, contact the National Lead Information Center (NLIC) at 1-800-424-LEAD,
visit , and your state and local health agencies.
PROFICIENCY THROUGH ELPAT
The Syracuse Lead Dust Project recommends that programs using XRF participate in the
Environmental Lead Proficiency Analytical Testing (ELPAT) program. ELPAT is run by the
American Industrial Hygiene Association and is designed to help a laboratory assess and/or
improve its analytical performance, by providing it with test samples on a quarterly basis and
evaluating the results. Participation in the ELPAT program is open to all laboratories, but it is
mandatory for laboratories seeking accreditation by one of the organizations recognized under
EPA's NLLAP program.
XRF USAGE AND RADIATION EXPOSURE
An XRF operator must wear a dosimetry badge, which monitors exposure to radiation. Even though
no radiation dosimetry is required for some isotopes, users should wear a dosimetry badge for the
following reasons:
• XRF instrument operators have a right to know the level of radiation to which they are exposed dur-
ing the performance of the job. In virtually all cases, the exposure will be far below applicable expo-
sure limits.
• The cost of dosimetry is low.
• Long-term collection of radiation exposure information can aid both the operator (employee) and the
employer. The employee gains peace of mind and the employer benefits by having an exposure record
that can be used in deciding possible health claims.
• The public benefits by having exposure records available to them.
• The need for equipment repair can be quickly identified.
46 CHAPTER
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SAFE OPERATING DISTANCE
XRF instruments used in accordance with manufacturer's instructions will not cause significant expo-
sure to ionizing radiation. But the instrument's shutter should never be pointed at anyone, even if the
shutter is closed. Also, the operator's hand should not be placed on the end plate during a measurement.
The safe operating distance between an XRF instrument and an individual depends on the radiation
source type, radiation intensity, quantity of radioactive material, and the density of the materials being
surveyed. As the radiation source quantity and intensity increases, the required safe distance also increas-
es. Placing materials, such as a wall, in the direct line of fire reduces the required safe distance.
According to NRC rules, a radiation dose to an individual in any unrestricted area must not exceed 2
millirems per hour. One of the most intense sources currently used in XRF instruments is a 40-millicurie
57Co (cobalt-57) radiation source. Other radiation sources in current use for XRF testing of lead-based
paint generally produce lower levels of radiation. Generally, an XRF operator following manufacturer's
instructions would be exposed to radiation well below the regulatory level. Typically, XRF instruments
with lower gamma radiation intensities can use a shorter safe distance, provided that the potential expo-
sure to an individual will not exceed the regulatory limit.
No one should be near the other side of a wall, floor, ceiling or other surface being tested. The operator
should verify this prior to initiating XRF testing activities and check on it during testing.
Finally, the effectiveness of the instrument's radiation shielding should be assessed every 6 months using a
leak test. The XRF manufacturer or owner's manual can be consulted to obtain vendors of leak test kits.
If these safety practices are observed, the risk of excessive exposure to ionizing radiation is extremely low
and will not endanger any inspectors or occupants present in the dwelling.
Each quarter, Syracuse receives sample kits with four concentration levels for each of three
matrices: paint chips, soil, and dust wipes. The city analyzes these samples and sends the results
back to ELPAT for evaluation. Performance ratings are based on accumulated results over four
rounds. The acceptable range is based on consensus values from all laboratories. A laboratory's
performance for each matrix is rated as proficient if either of the following criteria are met: in
the last two rounds, all samples are analyzed and the results are 100 percent acceptable; or,
three-fourths or more of the accumulated results over four rounds are acceptable. Syracuse has
consistently been rated as proficient using XRF.
For more information on the ELPAT Program, visit or contact the Laboratory Accreditation Department at AIHA, (703) 849-8888.
6.4 HEALTH AND SAFETY WHEN USING XRF
GUARDING AGAINST RADIATION HAZARDS
Portable XRF instruments used for lead analyses contain radioactive isotopes that emit X-rays
and gamma radiation. Proper training and handling of these instruments is needed to protect
the instrument operator and any other persons in the immediate vicinity during XRF use. The
XRF instrument should be in the operator's possession at all times. The operator should never
defeat or override any safety mechanisms of XRF equipment. The City of Syracuse has
dosimetry badges that are worn by each of the XRF operators whenever the instrument is in
ANALYZING LEAD DUST SAMPLES USING XRF TECHNOLOGY 47
-------
use. These badges are evaluated each quarter to check for
personal radiation exposure. In addition, in accordance with
New York State regulations, the instrument is leak-tested
every six months.
6.5 MAINTAINING EQUIPMENT
Day-to-day maintenance of the XRF is generally not difficult
or costly. Operators should clean the instrument's display
window with cotton swabs, clean the case with a soft cloth,
and charge the batteries as directed in the owner's manual.
Beyond that, operators usually just need to take care not to
drop the instrument, get it wet, or neglect the calibration
checks recommended by the manufacturer.
Over the long term, however, XRF owners face the very sig-
nificant maintenance concern of replacing the instrument's
radioactive source. All radioactive isotopes decay at a fixed
rate. The half-life of 109Cd (cadmium-109), for example, is
about 18 months. After that, the XRF can still be used, but
the instrument becomes progressively less efficient. Readings
that once took 30 to 60 seconds take progressively longer.
Eventually the wait becomes burdensome, and the isotope
must be replaced. Syracuse sends its instrument back to the
manufacturer, which disposes of the spent radioactive source,
installs the new source, upgrades the instrument's software,
and provides whatever preventive maintenance is needed. See Chapter 7, Section 7.3 for more
information on managing and disposing of hazardous wastes generated in a lead dust monitor-
ing and mitigation program.
6.6 RESOURCES FDR ADDITIONAL INFORMATION
XRF ACCURACY
U.S. EPA, Office of Research and Development, Environmental Technology Verification Report
on Field Portable X-ray Fluorescence Analyzer, Niton XL Spectrum Analyzer, March 1998,
EPA/600/R-97/150. Visit www.epa.gov/etv/verifications/vcenterl-22.html.
Midwest Research Institute, XRF Performance Characteristic Sheet, Edition Number 4, Niton
XL 309, 701-A, 702-A, and 703-A Spectrum Analyzers, April 17, 1998, in accordance with
EPA Methodology for XRF Performance Characteristic Sheets, September 1997, EPA 747-R-
95-008. Copies can be obtained from the National Lead Clearinghouse at 1-800-424-LEAD.
Clark, Scott, William Menrath, Mei Chen, Sandy Roda, and Paul Succop. Use of a Field
Portable X-Ray Fluorescence Analyzer to Determine the Concentration of Lead and Other
Metals in Soil and Dust Samples. To order, contact the University of Cincinnati Department of
Environmental Health at 513 558-1749.
4 a
CHAPTER
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TEST METHODS
SW-846 is EPA's Office of Solid Waste's official compendium of analytical and sampling meth-
ods that have been evaluated and approved for use in complying with RCRA regulations. Visit
to learn more about SW-846 and obtain a
copy online.
Methods 6200, 601 OB, and 7420 from EPA (entitled Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods, SW-846). For ordering information, or to obtain a copy online, go
to .
ASTM E1792-96a, Standard Specification for Wipe Sampling Materials for Lead in Surface
Dust, ASTM, 1100 Barr Harbor Drive, West Conshohoken, PA 19428-2959. For individual
reprints call 610-832-9585; visit www.astm.org or send an e-mail to service@astm.org.
ANALYZING LEAD DUST SAMPLES USING XRF TECHNOLOGY 49
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•7
MITIGATION AND MAINTENANCE
This chapter describes the mitigation (cleaning) steps for indoor areas identified as hav-
ing a lead dust hazard. This chapter presents the three-step wet cleaning method and
explains the use of High Efficiency Particulate Air (HEPA) filter vacuums used by the
Syracuse Lead Dust Project. Consistent with the goals of EMPACT, this mitigation approach is
low cost and convenient to the affected community.
• Section 7.1 is written for residents interested in learning how to mitigate (clean) lead dust in
their homes.
• Section 7.2 is written for managers and decision-makers who might be considering a lead
dust program in their community and for organizers who are actually implementing a lead
intervention program. It also describes Syracuse's HEPA vacuum loaner program.
• Section 7.3 provides information on the proper management and disposal of lead dust
debris.
• Section 7.4 contains information on maintaining lead-safe practices in the home.
• Section 7.5 provides resources for further information.
V.I LEAD DUST MITIGATION
Residents of homes and apartment buildings built before 1978 (the year a federal ban was
imposed on lead-based paint used in residential settings) should consider contacting the local
city or county health department to test for lead dust. In Syracuse,
once lead dust is detected through inspection and sampling, the
project allows participants to borrow a HEPA vacuum and recom-
mends a three-step wet cleaning process.
2002 entitled, Managing
Elevated Blood Lead Levels Among A HEPA vacuum cleaner is superior to other types of vacuums
Young Children, CDC's Advisory (including shop vacuums and other regular household vacuums)
Committee on Childhood Lead because it is equipped with a filter that can trap almost 100 percent
Poisoning Prevention states that of the dust that it collects. While the vacuum can be used without
repeated cleaning of household supervision, training might be necessary to properly and safely
lead dust has been associated with operate it, especially because lead dust is involved. Household vacu-
decreases in children's mean blood urns should never be used to pick up lead dust or paint chips.
lead levels. Conventional vacuum filters are not equipped to handle and hold
fine dust particles, and will simply redistribute lead dust through
the exhaust.
In a report published in March
2002 entitled, Managing
An area that contains lead dust or debris should also be wet cleaned with a cleaning agent and
then rinsed with water; it should never be dry wiped or dry dusted. Syracuse uses paper towels
or two disposable rags or sponges (one for the cleaning solution, and one for the rinse water).
This helps avoid recontaminating areas that have already been cleaned.
5D CHAPTER
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CLEANING AREAS
Lead dust comes from opening and closing windows and other friction surfaces painted with
old lead-based paint. Syracuse, therefore, recommends focusing wet cleaning efforts on areas
such as old windows, floors, and play areas. These areas should be cleaned at least once a week
or whenever they appear dirty, because windows can continually generate lead paint chips and
dust on their sills and wells. In addition, lead dust can get on the bottom of shoes by walking
on bare soil. This can occur if the exterior housepaint is chipping and releasing lead dust onto
porch areas or other outside surfaces. The Syracuse Lead Dust Project provides residents with
information to help them target their cleaning efforts on areas where lead dust tends to accu-
mulate in their specific living units.
MATERIALS
In addition to the HEPA vacuum, other useful items are a household cleaning agent (such as
dishwashing soap), waterproof gloves, disposable rags or towels (preferably paper towels), buck-
ets, and trash bags for disposing of any lead dust debris. The following cleaning agents can be
found in local grocery or hardware stores and are suggested by the Syracuse Lead Dust Project:
Although high-phosphate detergents such as
trisodium phosphate (TSP) are effective,
certain states have restricted the use of TSP
because of environmental concerns. TSP also is a
skin and eye irritant and must be used with cau-
tion. Non-TSP detergents developed for lead dust
removal are available at some hardware stores.
• Pine-Sol
• Liquid Tide
• Cascade (granular dishwasher formula)
• Spic and Span
• Lead Clean
CLEANING PROCESS
Once proper cleaning materials and a HEPA vacuum are obtained, removing lead dust and lead
debris from homes involves a few simple steps. In Syracuse, the coordinator meets with each
resident to explain the following cleaning procedure and to answer any potential questions:
Step 1: Vacuum. Use a vacuum cleaner equipped with a HEPA exhaust filter. Vacuum all sur-
faces in the room (e.g., ceilings, walls, trim, and floors). Start with the ceiling and work down,
while moving toward the entry door. Work from the back of the house or apartment and move
toward the main exit and finish there. Be sure to move slowly to ensure that the HEPA vacuum
can pick up all the lead dust. Use attachments, such as extension hoses, straight tubes, brushes,
crevice tools, and angular tools, to reach surfaces other than floors, including ceilings, light fix-
tures, radiators, built-in cabinets, and appliances. Pay close attention to surfaces such as window
troughs, porous concrete, old porous hardwood floors, and the corners of rooms, as they require
additional vacuuming to achieve an acceptable reduction in lead dust.
Step 2: Vffet-clean. Wear plastic or rubber gloves. Wash all surfaces with a lead-specific deter-
gent, high-phosphate detergent, or other suitable cleaning agent to dislodge any ground-in con-
tamination; then rinse. Wash the ceiling first and then proceed to the floors; plan the work so
you avoid passing through any rooms that have already been cleaned. Be careful not to scrub so
hard as to remove any intact paint. Consider using three separate buckets: one for the cleaning
solution, one for the clean rinse water, and one empty one, into which you can squeeze the
dirty sponge or rag when using the cleaning solution. Use a new batch of cleaning mixture for
MITIGATION AND MAINTENANCE
5 1
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each room to avoid recontaminating an area by cleaning it with dirty water. The cleaning mix-
ture can be put into a spray bottle, which will help keep dust levels down. Use paper towels to
avoid using dirty rags that might recontaminate areas that have already been cleaned.
Step 3: Vacuum again. Start at the far end of the unit, and again work toward the main exit.
Vacuum every inch of the windows, and use the attachments to reach difficult areas, such as
where the floor meets the floor boards. Use the brush attachment for the walls. Move slowly
and carefully to capture all the remaining dust.
V.Z HEPA VACUUM LDANER PROGRAM
The Syracuse Lead Dust Project makes HEPA vacuums available, free of charge, to the commu-
nity through the CBOs, who have trained staff that help residents implement recommended
cleaning methods. The HEPA vacuum coordinator demonstrates use of the HEPA vacuum and
instructs CBOs on proper equipment handling and
storage. Vacuum maintenance is performed by the
Syracuse staff, as explained in section 7.3 below.
Each CBO has program applications and lease agree-
ment forms for the HEPA vacuums. (See the back of
this chapter for a sample HEPA vacuum lease form).
Syracuse worked to develop a lease that not only cov-
ered legal issues, but that also avoided legal jargon that
might discourage residents from wanting to participate
in the program. After filling out a questionnaire that
requires basic information (e.g., name, address, tele-
phone, number of people living in the household), the
resident signs a lease form agreeing to properly operate
the vacuum. Syracuse arranges for the pick-up and drop-off of the HEPA vacuums at the resi-
dents' homes. This way, residents can get the vacuum in hand, avoiding the burden of transport-
ing the vacuum back and forth to the CBO storage area.
HEPA VACUUMS AVAILABLE THROUGH
RETAIL STORES IN MINNEAPOLIS
The city of Minneapolis' Lead Hazard Control
Program has established an innovative and highly
successful lead education and HEPA vacuum rental pro-
gram through local retailers.
Implemented through local community organizations,
the program provides "turnkey" information and techni-
cal assistance to local retailers such as hardware stores,
paint stores, and gardening centers, as well as neighbor-
hood churches and community centers, to establish and
run a lead center inside of their establishments. See
Appendix C for more information about Minneapolis'
Lead Dust program.
7.3 DISPOSAL DF LEAD
DUST DEBRIS AND USED
HEPA FILTER
EPA has interpreted federal hazardous waste
regulations to exclude lead dust and waste
from lead-based paint activities in residences.
This means that in states like New York that
follow federal guidelines, lead dust and debris
from cleaning activities can be disposed of
with regular household waste. EPA recom-
mends the following best management prac-
tices for the proper handling and disposal of
lead-based paint waste:
• Collect paint chips and dust, dirt, and
rubble in plastic trash bags for disposal.
5 2
CHAPTER
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• Store larger architectural debris pieces in containers until ready for disposal.
• Consider using a covered mobile dumpster (such as a roll-off container) for storage of lead-
based paint debris until the job is done.
• Contact local municipalities or county solid waste offices to determine where and ho
debris can be disposed of.
The full text of EPA's interpretation on the disposal of lead-based paint waste and lead dust is
included in a memorandum issued by the Office of Solid Waste, which is included in
Appendix E of this document.
It is important to note that certain states consider lead dust and debris to be hazardous
waste. It is imperative to contact your state government, local municipality, county solid
waste offices, and/or tribal authorities to determine if any restrictions apply to the dispos-
al of such waste. If restrictions do apply, these sources can tell you where lead dust and
debris can be disposed of, such as a household hazardous waste collection site.
In Syracuse, residents are instructed to place items used during cleaning (e.g., rags,
paper towels, paint chips, used cleaners) into a double-thick garbage bag, including the
HEPA filter if fully used. The waste bag should be sealed tightly and kept out of reach
of children and pets. In addition, wash water used for wet-cleaning should never be
poured onto the ground. Syracuse recommends consulting your local water and
sewage utility for directions on the proper disposal of the wash water in your area.
The Syracuse Lead Dust Project maintains all the HEPA vacuums. After 10 uses,
the bags are replaced; after 10 bags, the team replaces the HEPA filter. Syracuse
staff dampen the filter with water to control the potential spread of dust before
removing or disturbing it. It is extremely important that the HEPA filter not be
opened or emptied at anytime during removal as to avoid any exposure to
lead dust. The Syracuse Lead Dust Project uses triple-layered HEPA bags
that can be disposed of in the regular waste stream.
7.4 MAINTAINING LEAD-SAFE PRACTICES IN
THE HOME
Along with detecting and reducing high lead dust levels, continuing
lead-safe activities in the home is a crucial element in any lead dust program.
Syracuse HEPA vacuum coordinator provides residents with a comprehensiv
information packet that could be used in addition to, as well as independently of, the lead dust
project. Also, as explained in Chapter 9, Syracuse conducts an interview with residents who
have completed the program, during which they encourage continued lead dust cleaning.
EDUCATING RESIDENTS ABOUT CONTINUED REGULAR MAINTENANCE
Once a resident participates in the lead dust program, Syracuse staff encourages residents not
only to regularly follow the cleaning procedure for lead dust, but to contact Syracuse's lead pro-
gram or the CBO for further assistance. Residents also can request and are encouraged to have
their home rechecked for lead dust levels and to use the HEPA vacuum again.
MITIGATION AND MAINTENANCE
5 3
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Syracuse emphasizes to program participants the importance of regular cleaning and maintenance
as long as lead-based paint remains in the house. It is especially important to clean windows peri-
odically since lead dust is created every time a window with lead-based paint is opened or closed.
Paint on doors, door jambs, and walls also can be disturbed, creating paint chips or lead dust.
Syracuse has had to make clear to residents that if lead-based paint is disturbed by drilling into a
wall to hang a picture or cutting to access wiring, then the dust should be cleaned up immediately.
"7.5 RESOURCES FDR ADDITIONAL INFORMATION
For more information on EPA's final standards (TSCA 403) for lead-based paint hazards
(including lead dust), visit the Office of Pollution Prevention and Toxics Web site at
.
See Appendix E for a copy of a memorandum from Elizabeth A. Cotsworth, Director, U.S. EPA
Office of Solid Waste to RCRA Senior Policy Advisors entitled Regulatory Status of Waste
Generated by Contractors and Residents from Lead-Based Paint Activities Conducted in
Households., July 31, 2000. This document is also available at .
HUD's Requirements for Notification, Evaluation and Reduction of Lead-Based Paint Hazards
in Federally Owned Residential Property and Housing Receiving Federal Assistance (24 CFR
Part 35) can be found online at .
54 CHAPTER
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City of Syracuse Erapact Inv. #:
HEPA Vacuum Lease
THIS EQUIPMENT LEASE is made and effective 200S, by and
between (. ), herein named as
"Lessor" and "Lessee".
Name:
Home Address:
City, Sjtate, Zip:
Lessor desires to lease to Lessee, and Lessee desires to lease from Lessor, certain tangible
personal property.
NOW, THEREFORE, in consideration of the mutual covenants and promises hereinafter set forth,
the parties hereto agree as follows:
1. Lease
Lessor hereby leases to Lessee, and Lessee hereby leases from Lessor, the following described
equipment, the HEPA Vacuum.
2. Term
The term of this lease shall commence on , 200Zand shall expire seven(7) days
thereafter.
3. Use
Lessee shall use the Equipment in a careful and proper manner and shall comply with and conform
to all national, state, municipal, police and other laws, ordinances and regulations in any way
relating to the possession, use or maintenance of the equipment.[Other Restrictions]. The Lessee
shall sign an additional form stating that they have received instructions on the proper usage of the
HEPA Vacuum.
[Warranty Options] Lessor disclaims any and all other warranties express or implied.
including but not limited to implied warranties of merchantability and fitness for a particular
purpose, except that Lessor warrants that Lessor has the right to lease the equipment, as provided
in this lease.
4. Loss and Damage
A. Lessee hereby assumes and shall bear the entire risk of loss and damage to the HEPA Vacuum
from any and every cause whatsoever. If the Equipment is damages, Lessee at its own
expense, shall keep the HEPA Vacuum in good repair, condition and working order. No loss
or damage to the HEPA Vacuum or any part thereof shall impair any obligation of lessee
under this lease, which shall continue in full force and effect through the term of the lease.
B. In the event of loss or damage of any kind whatsoever to the HEPA Vacuum, Lessee shall, at
Lessor's option:
MlTIBATIDNANDMAINTENANCE 55
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I. Place the same in good repair, condition and working order; or
II. Repair the same with like equipment in good repair, condition, and working order;
III. Pay to Lessor the replacement cost of the HEPA Vacuum.
5. Surrender
Upon the expiration or earlier termination of this Lease, Lessee shall return the HEPA Vacuum to
Lessor in good repair, condition and working order, ordinary wear and tear resulting from proper
use thereof expected, by delivering the HEPA Vacuum at Lessee's cost and expense to such place
as Lessor shall specify within the city or county in which the same was delivered at Lessee.
6. Insurance
Lessee shall be responsible under their Homeowner's Insurance for-All risk insurance against loss
of and damage to the HEPA Vacuum for not less than the Ml replacement value of the HEPA
Vacuum.
7. Default
If Lessee fails to pay any rent or other amount herein provided within (10) days after the same is
due and payable, or if Lessee fails to perform any provisions of this lease the Lessor has the right
to exercise any or more of the following remedies:
A. To declare the entire amount of the HEPA Vacuum hereunder immediately due and payable
without notice or demand to Lessee.
B. To sue for and recover all costs of HEPA Vacuum and/or take possession of the HEPA
Vacuum, without demand or notice wherever same may be located, without any court order or
other process. Lessee hereby waives all damages occasioned by such taking possession.
C. To terminate his lease and/or to pursue any other remedy at law or in equity.
8. Ownership-The HEPA Vacuum is, and shall at all times be and remain, the sole and
exclusive property of Lessee; and lessor shall have no right, title or interest therein or thereto
expect as expressly set forth in this Lease.
9. Entire agreement- This instrument constitutes the entire agreement between parties and shall
not be amended or altered except by further writing signed by the parties hereto. Also, Lessee
shall not assign this Lease or its interest in the HEPA Vacuum to any other person(s) without
the prior written consent of lessor
10. Notices-Service of all notices under this Agreement shall be sufficient if given personally or
mailed certified, return receipt requested, postage prepaid, at the address hereinafter set forth.
11. Governing law-This Lease shall be enforced according to the laws of the State of New York.
12. Headings- Headings used in this Lease are provided for convenience only and shall not be
used to construe meaning or intent.
IN WITNESS WHEREOF, the parties hereto have executed this lease as of the day and first above
written.
Lessee Agency
56 CHAPTER
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B
REPORTING
This chapter discusses the tools and procedures Syracuse uses to report and disseminate
the results of its lead dust program. Reports include those to residents, tenants, and to
the public via the Internet. Since the Syracuse project is not performing formal lead
hazard screening, it does not need to comply with regulatory reporting requirements, but these
reports are meeting the project's communication and data collection objectives.
• Section 8.1 describes how written results are presented to individual program participants.
• Section 8.2 describes how Syracuse presents written results to the public, while maintaining
participant confidentiality.
• Section 8.3 reviews the use of a Web site for posting data.
• Section 8.4 lists resources for more information.
B. 1 PARTICIPANT REPORTS
Syracuse's documentation process begins upon accepting applications from potential partici-
pants. Once Syracuse staff determine how much lead dust is in the home, they present results to
the resident. As part of the reporting process, the project teaches the significance of the data,
identifies probable or potential sources of lead contamination, and recommends cleaning proce-
dures for homes with lead dust levels above the reference levels.
Syracuse uses two different reports to present findings to participants: a pre-mitigation report
after the initial sampling and a post-mitigation report for some residents who lease a HEPA vac-
uum and who agree to a second round of sampling. (Samples of these reports and a copy of
Syracuse's transmittal letters are included at the end of this chapter.) The pre-mitigation report
presents initial lead dust levels for each of the 10 areas sampled and indicates whether they
passed or failed based on the references levels established for that area (e.g., floors, window sills,
and window troughs). (See section 1.5). When lead dust levels are over the reference levels,
Syracuse staff meet with the participant to discuss and interpret the results and explain the use
of HEPA vacuums and the three-step cleaning process.
In Phase I of the Syracuse project, all residents who consented to a second round of sampling
received post-mitigation reports. During Phase II of the project, approximately 10 percent of
randomly-selected participants receive post-mitigation sampling with their consent. If HEPA
vacuuming and cleaning is successful in treating the problem, post-mitigation levels are expect-
ed to fall below the reference thresholds. In Syracuse, the project mails the final report to the
participant. If levels remain over the thresholds, staff will schedule another face-to-face meeting
with the resident.
When preparing its report format, Syracuse considered what the program participant needed to
know. Syracuse's reports present the data in a straightforward way to ensure that residents
understand the results and are not intimidated by technical jargon. For example, next to the
actual lead-dust level findings the report shows whether each sampling area passed (green) or
failed (red), presenting the information in an easy-to-understand manner to residents.
REPORTING 57
-------
Syracuse also includes a glossary of technical terms such as "lead-based paint hazard," "friction
surface," and "reference level" with these reports. Residents are also informed that, while the
report covers only those areas sampled, other areas also might contain a lead dust hazard. They
are advised that if they treat all areas in their home the same as the improved areas, then the risk
is likely reduced.
Syracuse staff find that face-to-face reporting in the home is most effective and that translating
reports into other languages is sometimes necessary. Some CBOs provide translators who
accompany project staff on site visits to explain the report findings to residents in their native
languages and to answer questions. As discussed previously, interacting with residents in their
own language is a tremendous help in building trust and enlisting participation.
When delivering a report, the field sampling technician locates areas of concern and identifies
potential sources of lead dust such as paint rubbing off window sills. If necessary, mitigation
(cleaning) is recommended. (Read about mitigation in Chapter 7). If the participant has been
randomly selected for post-mitigation sampling, that is also discussed. The resident is also
encouraged to repeatedly follow the three-step cleaning process to control lead dust levels (see
Section 7.4 on program maintenance). Residents and property owners also receive printed
material providing information on how to control lead in their home.
PROPERTY OWNER/LANDLORD DISCLOSURE REQUIREMENTS
In addition to providing the tenant with a report on the results of the lead dust mitigation, the
Syracuse Lead Dust Project provides a copy of the lead dust analysis and cleaning report to the
property owner (or landlord) after the mitigation is completed. Syracuse project staff learned
that, because the city already had a separate HUD-funded lead hazard reduction program in
place, the community was already aware of lead issues, and landlords have been responsive
when lead hazards are identified in their properties. Landlords are required to disclose this
information to future tenants when they sign a new lease, and to a purchaser if the property is
subsequently sold. A sample of Syracuse's letter to the landlord, and the sample forms used by
EPA to inform landlords of these disclosure requirements, can be found at the end of this chap-
ter. These forms are also available from EPA in Spanish.
B.Z PUBLIC REPORTS
Once Syracuse gathers enough data to determine a trend, it can report that trend to the com-
munity. Recording the results on a map to see if a geographical pattern emerges has proven to
be useful. Some target communities have relatively homogeneous housing types, and other
homes are likely to contain similar levels of lead dust. Also, homeowners or residents who have
not participated in the program need to know of potential lead hazards. Syracuse found that
maps work best when there is data from numerous houses in the community to consolidate,
because the identity of individual homes is lost in the data, thereby maintaining confidentiality.
Maps are not a good choice, however, when there are only a few data points.
Information can also be made available to the public on a Web site, which also serves to pro-
mote awareness of the lead dust problem and help homeowners and communities make more
informed decisions. (See Section 8.3 below for more on Syracuse's Web site). Other formats
used by Syracuse to report to the public include the use of posters that rotate though the CBOs,
a quarterly newsletter, monthly meetings with the CBOs, and broadcasting public service
announcements on cable television.
5B CHAPTER
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Syracuse is also in the process of finalizing a "Lead Registry," a comprehensive database that will
compile data from all lead-related programs (e.g., Lead Dust Project, HUD Program, and Lead-
Safe Yards).
RECCDRDKEEPING AND CONFIDENTIALITY
Generally, homeowners do not want information about their home shared with their neighbors.
To avoid this, Syracuse consolidates data without divulging specific locations. Consolidating
data retains the homeowner's privacy and allows the ability to track trends. One way to convey
this information is to consolidate the data on a geographical basis.
Syracuse keeps good records to help track lead dust data and protect its participants' privacy.
Staff start a file and keep records of all correspondence as soon as a participant submits an
application and is accepted into the program. A participant's file contains the application, raw
data, final reports, and other correspondence. The project also tracks the progress of each partic-
ipant by using a simple spreadsheet that includes the resident's basic information, lab results,
HEPA use, and disposition of the case. Residents' files are stamped "confidential" and kept in a
secure location in the program management office.
Syracuse staff learned that organizing and filing records by the participant's address makes them
easy to find regardless of who is living at the address. The program also keeps the property
owner's name and the resident's name in their files, since in some cases it will not only corre-
spond with the person living in the home, but also with the property owner as well. For exam-
ple, if the property has exceptionally high lead levels, Syracuse might contact the property
owner if vacuuming is only a short-term solution to a larger problem.
B.3 WEB SITE
The Syracuse Lead Dust Project Web site is at , To post lead
dust data, the site uses a map of the city showing the CBO neighborhoods. Syracuse reports aver-
age lead dust levels in micrograms per square foot for pre-mitigation and post-mitigation for
floors, sills, and window wells. Syracuse also presents individual sample points so that users can
get an impression of the range of values. Although Syracuse reports individual values, the project
does not report the property address or even the street, keeping that information confidential.
The site also provides general information about the project and links to participating CBOs and
posts educational materials and information about lead hazards. Once the web site is fully opera-
tional, project staff will be able to correspond with visitors through e-mail to respond to questions
and comments.
B.4 RESOURCES FDR ADDITIONAL INFORMATION
The following resources will provide more information on reporting the results of lead levels:
Risk Communication in Action: Environmental Case Studies, U.S. EPA, EPA 625-R-02-011,
September 2002.
The Syracuse Lead Dust Project Web site shows how a map of the city linked to the CBOs is
used to provide neighborhood-specific lead dust data. Visit .
National Lead Information Center Hotline at 1-800-424-LEAD.
REPORTING 59
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PRE-MITIGATIDN TENANT LETTER
Date-
Name
Address
Syracuse, N.Y
RE: Lead Dustiest Results
Dear Ms. XXXX
Thank you for helping us with our lead dust testing and education program.
We've enclosed the results of the tests we did in your home on -Date-. We
measured lead in house dust, which we and others have found to be the most
important source of lead in most homes. However, please be aware that there
may be other sources of lead in your home, (i.e., paint, soil, water), that this
report does not address.
Please read this report carefully and if you have any questions, please
call Adam VanHoose at 448-8708. The City of Syracuse can let you use a spe-
cial vacuum that can remove lead dust safely. For more information about the
HERA vacuum leaner program call Adam or visit our website at http://syrem-
pact.lead-safe.com. Please be advised that the information collected will be
kept confidential.
Sincerely
Betsy Mokrzycki
Program Manager
Enclosures:
Report
Cleaning instructions HUD Chapter 14
"Protect Your Family" EPA Brochure
etc.
6D CHAPTER
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PRE-MITIBATIDN REPORT
Syracuse Lead Dust Outreach Monitoring and Education Project
Funded by EPA
SETTLED DUST SAMPLE RESULTS
For The Dwelling Located at:
-Address-
-Date-
GENERAL INFORMATION
The City of Syracuse conducted sampling of settled dust at -Address-,
Syracuse, New York on -Date-.
An initial walk-through was conducted in the dwelling to locate the dustiest
areas of floors, window sills, and window wells, which were accessible or
exposed. The information contained in this report has been collected in accor-
dance with current regulations.
PURPOSE
The settled dust testing was conducted according to chapter 5 of the HUD
Guidelines. Reference levels are levels listed below:
DUSTWIPE SAMPLES
Floors 40 ug/ft2
Window Sills 250 ug/ft2
Window Troughs 400 ug/ft2
NARRATIVE
Ten samples of settled dust were collected from within the dwelling from
floors and window sills that appeared to be the dirtiest and most accessible to
the children. Samples results that exceed the reference limits are indicated in
red type on the quick summary page. Six of the ten wipe samples exceeded the
reference limits for lead content. It is our recommendation that all window sill
surfaces be cleaned using the HUD recommended three step cleaning method
as described in Chapter 14-11 of the HUD Guidelines.
REPORTING 61
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QUICK SUMMARY OF LEAD TESTING RESULTS
Dwelling: -Address-
Inspector: xxxxxxxx
Date: X/XX/XX
Job #: XX
SAMPLE
1
2
3
4
5
6
7
8
9
10
LOCATION
Princ. Play Area Floor
Princ Play Area Sill
Kitchen Floor
Kitchen Window Sill
Kitchen Window Trough
Youngest child's bedroom floor
Youngest child's bedroom window sill
Youngest child's bedrm. Win. trough
2nd Youngest child's bedroom floor
2nd Youngest child's bedroom window sill
RESULT
<20.0 |jg/ft2
306.2 |jg/ft2
<20.0 |jgft2
667.6 |jg/ft2
2,892.1 |jg/ft2
<20.0 |jg/ft2
264.9 |jg/ft2
1 , 258.0 |jg/ft2
<20.0 |jg/ft2
483.0 |jg/ft2
Pass/Fail
Pass
Fail
Pass
Fail
Fail
Pass
Fail
Fail
Pass
Fail
REFERENCE LEVELS
Glossary
Deteriorated paint means any interior or exterior paint or other coating that is peeling, chipping, chalking
or cracking, or any paint or coating located on an interior or exterior surface or fixture that is otherwise
damaged or separated from the substrate.
Friction surface means an interior or exterior surface that is subject to abrasion or friction, including, but
not limited to, certain window, floor, and stair surfaces.
Impact surface means an interior or exterior surface that is subject to damage by repeated sudden force
such as certain parts of door frames.
Interior window sill means the portion of the horizontal window ledge that protrudes into the interior of the
room.
Lead-based paint hazard
(a) Paint-lead hazard. A paint-lead hazard is any of the following: (1) Any lead-based paint on a friction sur-
face that is subject to abrasion and where the lead dust levels on the nearest horizontal surface underneath
the friction surface (e.g., the window sill, or floor) are equal to or greater than the dust-lead hazard levels
identified in paragraph (b) of this section. (2) Any damaged or otherwise deteriorated lead-based paint on an
impact surface that is caused by impact from a related building component (such as a door knob that knocks
into a wall or a door that knocks against its door frame. (3) Any chewable lead-based painted surface on
which there is evidence of teeth marks. (4) Any other deteriorated lead-based paint in any residential build-
ing or child-occupied facility or on the exterior of any residential building or child-occupied facility.
(b) Dust-lead hazard. A dust-lead hazard is surface dust in a residential dwelling or child-occupied facility
that contains a mass-per-area concentration of lead equal to or exceeding 40 mg/ft2on floors or 250 mg/ft2
on interior window sills based on wipe samples.
(c) Soil-lead hazard. A soil-lead hazard is bare soil on residential real property or on the property of a child-
occupied facility that contains total lead equal to or exceeding 400 parts per million (mg/g) in a play area or
average of 1,200 parts per million of bare soil in the rest of the yard based on soil samples.
6 2
CHAPTER
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Play area means an area of frequent soil contact by children of less than 6 years of age as indicated by,
but not limited to, such factors including the following: the presence of play equipment (e.g., sandboxes,
swing sets, and sliding boards), toys, or other children's possessions, observations of play patterns, or
information provided by parents, residents, care givers, or property owners.
Residential building means a building containing one or more residential dwellings.
Reference Level(s) means levels that have been set by HUD and EPA to indicate surface dust that con-
tains an amount of lead which may pose a threat of adverse health effects in pregnant women or children
less than the age of six years of age.
Room means a separate part of the inside of a building, such as a bedroom, living room, dining room,
kitchen, bathroom, laundry room, or utility room. To be considered a separate room, the room must be sep-
arated from adjoining rooms by built-in walls or archways that extend at least 6 inches from an intersecting
wall. Half walls or bookcases count as room separators if built-in. Movable or collapsible partitions or parti-
tions consisting solely of shelves or cabinets are not considered built-in walls. A screened in porch that is
used as a living area is a room.
Window trough means, for a typical double-hung window, the portion of the exterior window sill between
the interior window sill (or stool) and the frame of the storm window. If there is no storm window, the win-
dow trough is the area that receives both the upper and lower window sashes when they are both lowered.
The window trough is sometimes referred to as the window "well."
Wipe sample means a sample collected by wiping a representative surface of known area, as determined
by ASTM E1728, "Standard Practice for Field Collection of Settled Dust Samples Using Wipe Sampling
Methods for Lead Determination by Atomic Spectrometry Techniques, or equivalent method, with an
acceptable wipe material as defined in ASTM E 1792, "Standard Specification for Wipe Sampling Materials
for Lead in Surface Dust."
XRF means a testing device that is capable of determining the presence of lead in a dust wipe sample.
REPORTING & 2
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POST-MITIGATION TENANT LETTER
Date
Name
Address
Syracuse, N.Y 13210
RE: Lead Dustiest Results
Dear Ms.
Thank you for helping us with our lead dust testing and education pro-
gram. We've enclosed the results of the tests we did in your home on -Date-. We
measured lead in house dust, which we and others have found to be the most
important source of lead in most homes. However, please be aware that there
may be other sources of lead in your home, (i.e., paint, soil, water), that this
report does not address.
Please be advised that the lead levels in your home were found to be
below the detection limit, due to the proper use of the HEPA Vacuum. It is our
recommendation that you continue the 3-step cleaning method recommended
by HUD as described in Chapter 14 of the HUD Guidelines.
Please read this report carefully and if you have any questions, please
call Adam VanHoose at 448-8708. Please be advised that the information col-
lected will be kept confidential.
Sincerely
Betsy Mokrzycki
Program Manager
Enclosures:
Report
Cleaning instructions HUD Chapter 14
"Protect Your Family" EPA Brochure
etc.
64 CHAPTER
-------
POST-MITIGATION REPORT
Syracuse Lead Dust Outreach Monitoring and Education Project
Funded by EPA
SETTLED DUST SAMPLE RESULTS
Post Wipes
For The Dwelling Located at:
Address
Syracuse New York
-Date-
GENERAL INFORMATION
The City of Syracuse conducted post sampling of settled dust at -Address-
Syracuse, New York on -Date-.
The information contained in this report has been collected in accordance
with current regulations.
PURPOSE
The settled dust testing was conducted according to chapter 5 of the HUD
Guidelines. Reference levels are levels listed below:
DUST WIPE SAMPLES
Floors 40 ug/ft2
Window Sills 250 ug/ft2
Window Troughs 400 ug/ft2
NARRATIVE
Ten samples of settled dust were collected from within the dwelling from
floors and window sills that appeared to be the dirtiest and most accessible to
the children. Samples results that exceed the reference limits are indicated in
red type on the quick summary page. None of these ten wipe samples exceed-
ed the reference limits for lead content. It is our recommendation that you con-
tinue to clean all surfaces using the HUD recommended three step cleaning
method as described in Chapter 14-11 of the HUD Guidelines.
REPORTING 65
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QUICK SUMMARY OF LEAD TESTING RESULTS
Dwelling: Address, Syracuse N.Y
InspectorXXXXX
Date: X/XX/XX
Job # XX
SAMPLE
13
14
15
16
17
18
19
20
21
22
LOCATION
Principle .play area floor
Principle Play area sill
Kitchen floor
Kitchen sill
Kitchen Trough
Youngest child's bedroom floor
Youngest child's bedroom window sill
Youngest child's bedrm. Win. trough
2nd Youngest child's bedroom floor
2nd Youngest child's bedroom window sill
RESULT
<20.0 |jg/ft2
34.4 |jg/ft2
<20.0 |jgft2
46.0 |jg/ft2
50.2 |jg/ft2
<20.0 |jg/ft2
39.9 |jg/ft2
64.8 |jg/ft2
<20.0 |jg/ft2
42.9 |jg/ft2
Pass/Fail
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
REFERENCE LEVELS
Floors 40 ug/ft2
Window Sills 250 ug/ft2
Window Trough 400 ug/ft2
Glossary
Deteriorated paint means any interior or exterior paint or other coating that is peeling, chipping, chalking
or cracking, or any paint or coating located on an interior or exterior surface or fixture that is otherwise
damaged or separated from the substrate.
Friction surface means an interior or exterior surface that is subject to abrasion or friction, including, but
not limited to, certain window, floor, and stair surfaces.
Impact surface means an interior or exterior surface that is subject to damage by repeated sudden force
such as certain parts of door frames.
Interior window sill means the portion of the horizontal window ledge that protrudes into the interior of the
room.
Lead-based paint hazard
(a) Paint-lead hazard. A paint-lead hazard is any of the following: (1) Any lead-based paint on a friction sur-
face that is subject to abrasion and where the lead dust levels on the nearest horizontal surface underneath
the friction surface (e.g., the window sill, or floor) are equal to or greater than the dust-lead hazard levels
identified in paragraph (b) of this section. (2) Any damaged or otherwise deteriorated lead-based paint on an
impact surface that is caused by impact from a related building component (such as a door knob that knocks
into a wall or a door that knocks against its door frame. (3) Any chewable lead-based painted surface on
which there is evidence of teeth marks. (4) Any other deteriorated lead-based paint in any residential build-
ing or child-occupied facility or on the exterior of any residential building or child-occupied facility.
(b) Dust-lead hazard. A dust-lead hazard is surface dust in a residential dwelling or child-occupied facility
that contains a mass-per-area concentration of lead equal to or exceeding 40 mg/ft2on floors or 250 mg/ft2
on interior window sills based on wipe samples.
6 6
CHAPTER
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(c) Soil-lead hazard. A soil-lead hazard is bare soil on residential real property or on the property of a child-
occupied facility that contains total lead equal to or exceeding 400 parts per million (mg/g) in a play area or
average of 1,200 parts per million of bare soil in the rest of the yard based on soil samples.
Play area means an area of frequent soil contact by children of less than 6 years of age as indicated by,
but not limited to, such factors including the following: the presence of play equipment (e.g., sandboxes,
swing sets, and sliding boards), toys, or other children's possessions, observations of play patterns, or
information provided by parents, residents, care givers, or property owners.
Residential building means a building containing one or more residential dwellings.
Reference Level(s) means levels that have been set by HUD and EPA to indicate surface dust that con-
tains an amount of lead which may pose a threat of adverse health effects in pregnant women or children
less than the age of six years of age.
Room means a separate part of the inside of a building, such as a bedroom, living room, dining room,
kitchen, bathroom, laundry room, or utility room. To be considered a separate room, the room must be sep-
arated from adjoining rooms by built-in walls or archways that extend at least 6 inches from an intersecting
wall. Half walls or bookcases count as room separators if built-in. Movable or collapsible partitions or parti-
tions consisting solely of shelves or cabinets are not considered built-in walls. A screened in porch that is
used as a living area is a room.
Window trough means, for a typical double-hung window, the portion of the exterior window sill between
the interior window sill (or stool) and the frame of the storm window. If there is no storm window, the win-
dow trough is the area that receives both the upper and lower window sashes when they are both lowered.
The window trough is sometimes referred to as the window "well."
Wipe sample means a sample collected by wiping a representative surface of known area, as determined
by ASTM E1728, "Standard Practice for Field Collection of Settled Dust Samples Using Wipe Sampling
Methods for Lead Determination by Atomic Spectrometry Techniques, or equivalent method, with an
acceptable wipe material as defined in ASTM E 1792, "Standard Specification for Wipe Sampling Materials
for Lead in Surface Dust."
XRF means a testing device that is capable of determining the presence of lead in a dust wipe sample.
REPORTING 67
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POST-MITIGATION LANDLORD LETTER
July 23, 2002
Mr John Doe
123 Sesame Street
Syracuse, N.Y. 13202
RE: Lead Dustiest Results
Dear Mr. Doe:
Your tenant at 123 Sesame Street recently received lead wipe sampling
through the City of Syracuse Lead Dust Outreach, Monitoring and Education
Project. Please be advised that the information collected will be kept confidential.
We've enclosed the results of the monitoring we did on your property on July 15,
2002. We measured lead in house dust, which we and others have found to be the
most important source of lead in most homes. However, please be aware that there
may be other sources of lead in your tenants home, (i.e., paint, soil, water), that this
report does not address.
Please keep this report, which will need to be released to any future tenants
or disclosed to new owners in the event the property goes up for sale in order to
comply with Section 1018 Real Estate Disclosure Rule.
Please read this report carefully and if you have any questions, please call
Adam VanHoose at 448-8708. For more information about the HEPA vacuum leaner
program call Adam or visit our website at http://www.syracuse-empact.com.
Sincerely
Betsy Mokrzycki
Program Manager
Enclosures:
Report
Cleaning instructions HUD Chapter 14
"Protect Your Family" EPA Brochure
etc.
S3 CHAPTER
-------
Sample Disclosure Format for Target Housing Sales
Disclosure of Information on Lead-Based Paint and/or Lead-Based Paint Hazards for Sales
Property Address:
Lead Warning Statement
Every purchaser of any interest in residential real property on which a residential dwelling was built prior to 1978 is
notified that such property may present exposure to lead from lead-based paint that may place young children at risk of
developing lead poisoning. Lead poisoning in young children may produce permanent neurological damage, including
learning disabilities, reduced intelligence quotient, behavioral problems, and impaired memory. Lead poisoning also
poses a particular risk to pregnant women. The seller of any interest in residential real property is required to provide
the buyer with any information on lead-based paint hazards from risk assessments or inspections in the seller's
possession and notify the buyer of any known lead-based paint hazards. A risk assessment or inspection for possible
lead-based paint hazards is recommended prior to purchase.
Seller's Disclosure [ Seller should initial both (a) and (b) ].
(a) Presence of lead-based paint and/or lead-based paint hazards (check one below):
O Known lead-based paint and/or lead-based paint hazards are present in the housing (explain).
I I Seller has no knowledge of lead-based paint and/or lead-based paint hazards in the housing.
_(b) Records and reports available to the seller (check one below):
O Seller has provided the purchaser with all available records and reports pertaining to lead-based
paint and/or lead-based paint hazards in the housing (list documents below).
Seller has no reports or records pertaining to lead-based paint and/or lead-based
paint hazards in the housing.
Purchaser's Acknowledgment [ Purchaser should initial (c), (d) and (e) ].
(c) Purchaser has received copies of all information listed above.
(d) Purchaser has received the pamphlet Protect Your Family from Lead in your Home.
(e) Purchaser has (check one below):
Received a 10-day opportunity (or mutually agreed upon period) to conduct a risk assessment or
inspection for the presence of lead-based paint and/or lead-based paint hazards; or
Q Waived the opportunity to conduct a risk assessment or inspection for the presence of lead-based
paint and/or lead-based paint hazards.
Agent's Acknowledgment [ Seller's Agent should initial (f) ].
(f) Agent has informed the seller of the seller's obligations under 42 U.S.C. 4852(d) and is aware of
his/her responsibility to ensure compliance.
Certification of Accuracy [ Purchaser should be the last person to sign and date this form ].
The following parties have reviewed the information above and certify, to the best of their knowledge, that
the information they have provided by the signatory is true and accurate.
Seller
Date
Purchaser
Date
Seller
Date
Purchaser
Date
Seller's Agent
Date
Purchaser's Agent
Date
REPORTING
6 9
-------
Disclosure of Information on Lead-Based Paint and/or Lead-Based Paint Hazards
Lead Warning Statement
Housing built before 1978 may contain lead-based paint. Lead from paint, paint chips, and dust can
pose health hazards if not managed properly. Lead exposure is especially harmful to young
children and pregnant women. Before renting pre-1978 housing, lessors must disclose the
presence of lead-based paint and/or lead-based paint hazards in the dwelling. Lessees must also
receive a federally approved pamphlet on lead poisoning prevention.
Lessor's Disclosure [ Landlord or agent should initial both (a) and (b) ].
(a) Presence of lead-based paint and/or lead-based paint hazards (check one below):
Q Known lead-based paint and/or lead-based paint hazards are present in the housing
(explain).
Q Lessor has no knowledge of lead-based paint and/or lead-based paint hazards in the
housing.
(b) Records and reports available to the lessor (check one below):
Lessor has provided the lessee with all available records and reports pertaining to lead-
based paint and/or lead-based paint hazards in the housing (list documents below).
Lessor has no reports or records pertaining to lead-based paint and/or lead-based
paint hazards in the housing.
Lessee's Acknowledgment [ Tenant should initial both (c) and (d) ].
(c) Lessee has received copies of all information listed above.
(d) Lessee has received the pamphlet Protect Your Family from Lead in your Home.
Agent's Acknowledgment [Agent, if not landlord's direct employee, should initial (e) ].
(e) Agent has informed the lessor of the lessor's obligations under 42 U.S.C. 4852(d) and is
aware of his/her responsibility to ensure compliance.
Certification of Accuracy [ Tenant should be the last person to sign and date this form ].
The following parties have reviewed the information above and certify, to the best of their
knowledge, that the information they have provided by the signatory is true and accurate.
Lessor
Date
Lessor
Date
Lessee
Date
Lessee
Date
Agent
Date
Agent
Date
7 D
CHAPTER
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SAMPLE DISCLOSURE FORM FOR RENTALS AND LEASES - CERTIFICATION BY LANDLORD
Disclosure of Information on Lead-Based Paint and/or Lead-Based Paint Hazards
Lead Warning Statement
Housing built before 1978 may contain lead-based paint. Lead from paint, paint chips, and dust can
pose health hazards if not managed properly. Lead exposure is especially harmful to young
children and pregnant women. Before renting pre-1978 housing, lessors must disclose the
presence of lead-based paint and/or lead-based paint hazards in the dwelling. Lessees must also
receive a federally approved pamphlet on lead poisoning prevention.
Lessor's Disclosure [ Landlord or agent should initial both (a) and (b) ].
) Presence of lead-based paint and/or lead-based paint hazards (check one below):
rwj Known lead-based paint and/or lead-based paint hazards are present in the housing
(explain).
A lead inspection found lead-based paint on bannister in hallway.
Lessor has no knowledge of lead-based paint and/or lead-based paint hazards in the
housing.
(b) Records and reports available to the lessor (check one below):
Lessor has provided the lessee with all available records and reports pertaining to lead-
Si based paint and/or lead-based paint hazards in the housing (list documents below).
Report is available in office upon request.
Lessor has no reports or records pertaining to lead-based paint and/or lead-based
paint hazards in the housing.
Lessee's Acknowledgment [ Tenant should initial both (c) and (d) ].
&F (c) Lessee has received copies of all information listed above.
(d) Lessee has received the pamphlet Protect Your Family from Lead in your Home.
Agent's Acknowledgment [Agent, if not landlord's direct employee, should initial (e) ].
(e) Agent has informed the lessor of the lessor's obligations under 42 U.S.C. 4852(d) and is
aware of his/her responsibility to ensure compliance.
Certification of Accuracy [ Tenant should be the last person to sign and date this form ].
The following parties have reviewed the information above and certify, to the best of their
knowledge, that the information they have provided by the signatory is true and accurate.
Lessor Date Lessor Date
<^tj*)(\ye/iasi( /^vy^
-------
SAMPLE DISCLOSURE FORM FOR RENTALS AND LEASES - CERTIFICATION BY AGENT
Disclosure of Information on Lead-Based Paint and/or Lead-Based Paint Hazards
Lead Warning Statement
Housing built before 1978 may contain lead-based paint. Lead from paint, paint chips, and dust can
pose health hazards if not managed properly. Lead exposure is especially harmful to young
children and pregnant women. Before renting pre-1978 housing, lessors must disclose the
presence of lead-based paint and/or lead-based paint hazards in the dwelling. Lessees must also
receive a federally approved pamphlet on lead poisoning prevention.
Lessor's Disclosure [ Landlord or agent should initial both (a) and (b) ].
Presence of lead-based paint and/or lead-based paint hazards (check one below):
Known lead-based paint and/or lead-based paint hazards are present in the housing
(explain).
P^i Lessor has no knowledge of lead-based paint and/or lead-based paint hazards in the
housing.
Records and reports available to the lessor (check one below):
Lessor has provided the lessee with all available records and reports pertaining to lead-
CD based paint and/or lead-based paint hazards in the housing (list documents below).
Lessor has no reports or records pertaining to lead-based paint and/or lead-based
paint hazards in the housing.
Lessee's Acknowledgment [ Tenant should initial both (c) and (d) ].
&7 (c) Lessee has received copies of all information listed above.
JET (d) Lessee has received the pamphlet Protect Your Family from Lead in your Home.
Agent's Acknowledgment [Agent, if not landlord's direct employee, should initial (e) ].
Agent has informed the lessor of the lessor's obligations under 42 U.S.C. 4852(d) and is
aware of his/her responsibility to ensure compliance.
Certification of Accuracy [ Tenant should be the last person to sign and date this form ].
The following parties have reviewed the information above and certify, to the best of their
knowledge, that the information they have provided by the signatory is true and accurate.
Lessor Date Lessor Date
Lessee Date Lessee Date
.S$wStfaenf _ U/M/02 _ _
Agent Date Agent Date
CHAPTER
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EVALUATING SYRACUSE'S
LEAD DUST PROJECT
The goal of the EMPACT-funded Lead Dust Project in Syracuse is to provide environ-
mental information so that the public can make informed decisions to protect them-
selves and their families from environmental hazards. The program emphasis is on
monitoring; data delivery and management; and on communication and outreach, not mitiga-
tion or treatment. In response to anticipated resident concerns over elevated lead dust levels
communicated by the project, however, Syracuse also decided to provide information and train-
ing about the three-step cleaning process along with a HEPA vacuum lease program, so that res-
idents would have a low-cost measure they could immediately implement, if elevated lead dust
levels were found.
Because of EMPACT's focus on monitoring and outreach, measuring the effectiveness of the
mitigation component of the project has not been elaborate. Nonetheless, the project did build
in a "spot check" of the effectiveness of its cleaning and HEPA vacuuming methods.
To conduct this initial spot check, Syracuse reviewed sample data from a total of 119 individual
locations where both before- and after-mitigation data was available. Of these 119 locations, 74
were determined to have "pre-mitigation" lead dust levels below the project action levels, and 45
were determined to have "pre-mitigation" lead dust levels above the project action levels. After
mitigation was performed, lead dust levels were reduced below project action levels in 82 per-
cent (37 of 45) of the locations previously determined to have excessive lead dusts levels.
The following table summarizes the results of this effectiveness evaluation. The post samples
were taken an average of 37 days after initial mitigation was conducted. Based on these find-
ings, the Syracuse project continues to conduct post sampling for a minimum of 10 percent of
the locations tested.
PRELIMINARY EVALUATION OF SYRACUSE PROJECT EFFECTIVENESSB
Pre-Samples (119 Total) Percent (%) Post Samples (119 Total) Percent (%)
Below Action Levels - 74
Above Action Levels - 45
62%
38%
Below Action Levels - 70
Above Action Levels - 4
Below Action Levels - 37
Above Action Levels - 8
95%
5%
82%
18%
5 The fact that four post-mitigation samples showed increased lead dust levels is possibly attributable to the
re-accumulation of lead dust during the 37-day lag between pre- and post-sampling.
Different project goals may require different project evaluation schemes. If a project's major
focus is mitigation, as opposed to monitoring and outreach, evaluation measures should be
designed accordingly.
Syracuse also regularly solicits feedback from program participants and CBOs through ques-
tionnaires and interviews to evaluate project effectiveness, strengths, and weaknesses. Once a
EVALUATING SYRACUSE
LEAD DUST PROJECT
7 3
-------
participant completes a cleaning procedure, for example, project staff set up a time to inter-
view the resident to gather feedback. Syracuse developed a brief questionnaire that technicians
personally administer in the home with residents to learn about their experience with the pro-
gram. A copy of this questionnaire is included at the end of this chapter. Syracuse staff prefer
to do face-to-face interviews to more effectively understand residents' opinions of the program,
as well as to give the program a more personal touch and perhaps make a more significant con-
nection with residents. This interview also provides an opportunity to encourage residents to
continue the lead dust cleaning activities they learned through the program.
Syracuse also found it important to request feedback from CBOs since they interact with both
residents and landlords. The CBOs can provide a broader perspective of the program and make
it more accessible to the community. In a brief written survey, Syracuse asks its partner CBOs
about HEPA vacuum use among residents and how to better market the program to generate
greater interest. A copy of the questionnaire used to solicit this feedback is included at the end
of this chapter.
Syracuse evaluates the outreach portion of its program in a number of ways. First, it quantifies
how many residents submit a HEPA Vacuum Intake Questionnaire for participating in the proj-
ect. This shows how effectively information about the program is disseminated to the commu-
nity. The Syracuse program manager also looks at the number of residents who used the HEPA
vacuums and will review the number of "hits" to the project Web site.
CHAPTER
-------
PARTICIPANT QUESTIONNAIRE
Date: _/_/_
Participant's Name:
Address:
Pre-wipes _/__/_ HEPA Dropped Off __/_/_ Post wipes __/__/_
1. What do you think of this program?
2. Was the information provided easy to understand? If not please comment.
3. How did the vacuum perform for you? Please comment about any problems you
had if any.
4. Where did you use the vacuum? (floors, sills, wells, etc) Please specify.
5, How often did you vacuum with the HEPA vacuum? (More than once?)
6, Which attachment did you find most useful?
7. Would you recommend this program to others? Why or Why not?
8. Do you have access to the internet? Give out the web address, (syrempact.lead-
safe.com)
Please provide any additional comments - use back if necessary:
LEAD SAFE, LUC
2410 East Lak« Road - SKaneatalea, New York 13152 • (316) 685.0864 Fax (315) 686-0940
http;/M«ww.l»ad-*af6.eom
EVALUATING SYRACUSE'S LEAD DUST PROJECT
7 5
-------
VEY
EMPACT PROGRAM SURVEY
In an attempt to better serve the recipients of the EMPACT Program and to increase the
number of cases for Hepa-vac use, please take a few moments to answer the following
questions. Please be honest as your response is vital to the program's success. Thanks!
1. To increase Hepa-vac use among City homeowners and/or tenants, how can we
more effectively market the program to generate more interest? .__
2. Are you finding that people are reluctant to come through the EMPACT program?
Yes_ No If yes, please explain why they are reluctant.
3. Do you think that tenants are reluctant to go through the EMPACT program
because they fear the landlords and/or feel that the landlords may not approve of
the Hepa-vac use?
4. Do you think landlords would be reluctant having their tenant(s) go through the
EMPACT program due to liability or an "invasion of privacy" issue?
5. Is there a fear from either the tenant, homeowner or the landlord about a
government agency stepping in?
6. Is vacuuming such a private/personal issue that people may be embarrassed to
enroll in the EMPACT program? Yes No_
76 CHAPTER9
-------
7. Is any part of the EMPACT Program's process too cumbersome or too
confusing? ie; intake or she visits?
8. Do you think that there is confusion between the LEAD & EMPACT
programs? Yes No_
If yes, explain
9. Are tools such as websites, newsletters, fliers etc. important? Yes No_
What do you think would work the best?
10. How can WE help your agency to increase awareness & intake numbers?
Misc. Comments:
EVALUATING SYRACUSE'S LEAD DUST PROJECT
-------
APPEN DIX
G LDSSARY
Community based organizations (CBOs): Organizations that interact with a community on a
regular basis, and can help educate the community on lead dust hazards.
Deteriorated paint: Any exterior or interior paint that is peeling, chipping, chalking, or crack-
ing, or any other paint located on an interior or exterior surface or fixture that is otherwise
damaged or separated from the substrate.
Dosimetry badges: Used to determine radiation levels reaching a person's breathing space. It is
a small, like a luggage tag, and clips on to a person's clothing, usually around the lapel.
Dust wipe sample: A sample of lead dust collected from a surface following a specified procedure.
Friction surface: An interior or exterior surface that is subject to abrasion or friction, including,
but not limited to, certain window, floor, and stair surfaces.
Half-life: The amount of time needed for the activity of a radioactive source to decrease by
one half.
HEPA vacuum: A High Efficiency Particulate Air (HEPA) vacuum is equipped with an
enhanced air filtration device that increases the amount of dust captured by the vacuum.
Impact surface: An interior or exterior surface that is subject to damage by repeated sudden
force such as certain parts of door frames.
Interior window sill: The interior ledge of a window; it is the principal area for collecting lead
dust samples.
Lead-based paint hazard: Typically results from deteriorated paint and includes lead-based
paint chips, lead dust, and lead contaminated soil.
Lead dust hazard: Surface dust in a residential dwelling or child-occupied facility that contains
a concentration of lead equal to 40 g/ft2 on floors or 250 g/ft2 on interior window sills based
on dust wipe samples.
Lead soil hazard: Bare soil on residential property or on property of a child-occupied facility
that contains total lead equal to or exceeding 400 parts per million (ppm) in a play area, or an
average of 1,200 ppm of bare soil in the rest of the yard, based on soil samples.
Lead inspector: An EPA-certified professional who conducts a surface-by-surface investigation
to determine whether there is lead-based paint in the home and where it is located. Painted sur-
faces are inventoried and tested. Soil, dust, and water are not typically tested but are reserved
for a risk assessor.
Paint chip: A piece of dried paint. As paint deteriorates, paint chips tend to collect along the
floor or the exterior perimeter of a house.
Play area: An area of frequent contact by children less than age 6 as indicated by, but not limit-
ed to, such factors including the following: the presence of play equipment (e.g., sandboxes,
7 B APPENDIX
-------
swing sets, and sliding boards); toys; or other children's possessions; observations of play pat-
terns; or information provided by parents, residents, care givers, or property owners.
Post-intervention sample (also referred to as "post-mitigation" sample: A sample taken after
residents have completed the three-step cleaning/HEPA vacuum procedure.
Reference level(s): Levels set by the Department of Housing and Urban Development (HUD)
and EPA to indicate surface dust that contains an amount of lead that may pose a threat of
adverse health effects in pregnant women or children less than age 6.
Residential building: A building containing one or more residential dwellings.
Risk assessor: An EPA-certified professional who determines the existence, nature, severity, and
location of lead-based paint hazards in a residential dwelling.
Wet cleaning: A method for cleaning lead dust in the home; involves washing surfaces with a
suitable cleaning agent to dislodge any ground-in contamination; then rinsing with clean water.
Window trough: For a typical double-hung window, the portion of the exterior window sill
between the interior window sill and the frame of the storm window. If there is no storm win-
dow, the window trough is the area that receives both the upper and lower window sashes when
they are both lowered. The window trough is sometimes called the window "well."
X-ray fluorescence (XRF) instrument: A handheld, battery-powered device used to analyze
dust wipe samples. The device provides timely and accurate data, allowing inspectors to measure
parts per million (ppm) lead levels for individual dust wipes within seconds.
GLOSSARY
-------
APPEN DIX B
QUALITY ASSURANCE PROJECT PLAN
United States Environmental Protection Agency
Region II
Quality Assurance Project Plan
For Environmental Monitoring Projects
Revision 02
Syracuse Lead Dust Outreach. Monitoring and Education Project
Theresa Bourbon
EPA Project Officer
Signature/Organization
Marcus Kantz
EPA Quality Assurance Manager Signature/Organization
Betsy Mokrzycki
Project Manager
Signature/Organization
Rebecca Markus
Project Quality Assurance Officer Signature/Organization
Approval Date
Approval Date
Approval Date
Approval Date
B D
APPENDIX B
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1. Distribution List:
Theresa Bourbon (Terry)
U.S. Environmental Protection Agency
Region 2
2890 Woodbridge Avenue
Edison, NJ 08837
Donna Ringel
U.S. Environmental Protection Agency
Region 2
2890 Woodbridge Avenue
Edison, NJ 08837
Betsy Mokrzycki
City of Syracuse, Department of Community Development
Lead Program
201 East Washington Street
Syracuse, New York 13202
Rebecca Markus
Lead-Safe
2410 East Lake Road
Skaneateles, New York 13152
Community Based Organizations - See Attachment 1 for Addresses:
Southwest Community Center
Syracuse Northeast Community Center
Southeast Asian Center
Boys & Girls Clubs of Syracuse
Brighton Family Center
Girls Inc.
Westcott Community Center
2. Project Description/Background:
The overall goal of the proposed project is the establishment of a community-based out-
reach, monitoring, and education effort aimed at reducing exposure to lead dust in residen-
tial and public buildings throughout the City of Syracuse, New York. Dust samples will be
collected from buildings and analyzed for lead content and the results will be provided to
residents and property owners. All sampling will be coordinated through the City of
Syracuse Lead Division with assistance from the community organizations and shall include
sampling before and after the education program to examine the resulting improvement, if
any. The target buildings will be found in one of the City of Syracuse's revitalization areas
and in buildings built prior to 1950. Approximately 350 homes will be included in the proj-
ect. Users of this data include: residents, property owners, City of Syracuse Lead
Inspectors, and the general public. An EPA certified risk assessor will collect dust wipe
samples, and analyze them in the field using an XRF instrument. Samples will be collected
in accordance with the HUD Guidelines for the Evaluation and Control of Lead-Based Paint,
HUD Lead Safe Housing Regulation, and EPATSCA 402. Action levels of concern will be
based on the HUD Guidelines for the Evaluation and Control of Lead-Based Paint protocol:
Floors - 40 micrograms of lead per square foot sampled (ug/ft.2), Window Sills - 250 ug/ft.2,
and Window Troughs - 400 ug/ft.2 When action levels are exceeded, residents and proper-
QUALITY ASSURANCE PROJECT PLAN
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ty owners will be notified. All participants will be trained in dust control methods and will be
informed of the HERA-VAC leaner program.
If it were necessary to change this QAPP, Terry Bourbon and Betsy Mokrzycki would deter-
mine what changes were necessary. Changes would be documented in writing and sent to
the distribution list in section 1.
This sampling scheme is designed to be flexible and will be adjusted, as needed depending
on the correlation of the statistical analyses. All samples will be analyzed using the
portable XRF. To evaluate the data, some samples will be sent to the lab for confirmation by
atomic adsorption spectroscopy (AA). A two phase process will be used. Phase I will con-
sist of 100% confirmatory testing for the first 12 homes. This will yield approximately 120
samples including field blanks. The XRF data will be forwarded to the laboratory so that a
statistical analysis can be performed. The laboratory will be required to perform an appro-
priate statistical comparison between the XRF and AA values for the three sets of samples
in phase 1 (floor, sill and well).
Phase 1 of our sampling scheme has been completed. Based on our review of the XRF
and laboratory data from phase 1, (see attachment 8), we have revised our sampling and
analysis scheme to require confirmation analysis as follows:
Sample Type
Floor
Floor
Window Sill
Window Sill
Window Sill
Window Well
Window Well
Window Well
XRF Reading
40 ug/ft2
>40 ug/ft2
<100 ug/ft2
100 ug/ft2 and 250 ug/ft2
> 250 ug/ft2
<180 ug/ft2
180 ug/ft2 and 400 ug/ft2
>400 ug/ft2
Lab Confirmation?
Yes
No
No
Yes
No
No
Yes
No
In addition to the confirmation analysis described in the Table above, we will also confirm
10% of the XRF data that is within the acceptable ranges, (i.e., XRF readings that would not
automatically require lab confirmation).
The XRF analysis will be made available to the program participants in a written report.
When lab confirmation is required, lab results will replace the XRF results in the written
report. Post- intervention sampling will be conducted in 10% of the participating residences.
Post- intervention sampling will be conducted exactly as the pre-intervention sampling
described above, once the training and HEPA/Loaner aspects of the project have been in-
place at the property for approximately one week. Post intervention sample collection will
use the same numbering scheme as the pre-intervention sampling, only the starting number
will be 13, (i.e., principle play area - 13, principle play area interior window sill - 14, etc). In
addition, two field blank samples will also be submitted. These will be samples 23 and 24.
B 2
APPENDIX
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The XRF analysis, chain of custody, and bagging of samples, will be the same as the pre-
intervention.
The results from the post-intervention sampling will also be communicated to program par-
ticipants in a written report. Post-intervention sampling results will also be used to help
determine the effectiveness of the project in lowering dust levels within the residence.
In order to address confidentiality of the participants, the public will receive encoded general
information in a number of ways. These include monthly Internet updates, poster displays,
quarterly newsletters, monthly meetings and public service announcements on cable net-
work. Also information will be made available through contractual arrangements with
Community Based Organizations.
The success of the outreach portion of the project will be determined by the number of indi-
viduals who: 1.) Request inspections, 2.) Utilize the HERA vacuum through the leaner pro-
gram, and 3.) Utilize the web site. The success of the educational program will also be
evaluated by the evaluation of pre/post intervention lead dust levels.
3. Project/Task Technical Design:
Residents/property owners of the City of Syracuse will be made aware of this program
through various project outreach campaigns. Residents/property owners then contact their
local community-based organization, or the City of Syracuse Lead Division, to express their
interest in participating in the program. These residents are asked to complete an intake
questionnaire. This questionnaire is provided to the Lead Coordinator at the City of
Syracuse Lead Division. The Lead Coordinator schedules an appointment for a Lead
Inspector/Risk Assessor to visit the property and collect the necessary lead dust samples.
Lead levels in dust will be measured using a Niton portable XRF. Specifically, dust samples
will be collected from the following residential locations: floor and interior window sill of prin-
ciple play area, floor, window sill and window trough of kitchen, floor, window sill, and win-
dow trough of youngest child's bedroom, floor and window sill of next youngest child's
bedroom. In most instances we anticipate collecting 10 samples per dwelling.
Prior to the commencement of work on this project, the laboratory will be required to supply
either a QA Manual or other documentation substantiating the relevance of its QA procedures
for this project, certifying that it will use the required methods, stating its calibration frequency,
etc.
If some Community Based Organizations wish to evaluate lead dust at their facilities, per
HUD Guidelines for the Evaluation and Control of Lead-Based Paint and HUD Lead Safe
Housing Regulations, additional samples will need to be collected. We anticipate that dust
wipe samples collected in the warmer months will yield higher results, as the windows are
more likely to be open. (See Attachment Number 6 - Niton R factor data).
A data report is generated for each residence tested. This report is reviewed and a determi-
nation made as to whether or not a lead dust hazard is present. Written reports are then
provided to the program participant. If a lead hazard is present, the program participant is
contacted, provided training in the 3-step cleaning method, and informed about the HERA
Vacuum leaner program. If the data indicate that a lead hazard is not present, the program
participant is mailed a copy of their individual report.
QUALITY ASSURANCE PROJECT PLAN
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4. Project Organization and Task Responsibilities: See Attachment 7
5. Special Training Requirements and Responsibility:
The inspectors will need to be USEPA Certified as Lead Inspector and Risk Assessor. The
City of Syracuse will keep on file copies of the each inspector's certificate. As a USEPA cer-
tified Lead Inspector or Risk Assessor, one is trained in the basic dust sampling proce-
dures, including chain of custody requirements. In addition, those individuals that will be
performing the XRF analysis are required by New York State law to be trained by the manu-
facturer in the use of the Niton instrument and on radiation safety. Proof of all training
required will be kept on file along with the EPA certificates for each individual inspector. In
addition to these formal training requirements, the Lead Inspectors/Risk Assessors partici-
pating in this project, will be required to read this QAPP and participate in a pre- sampling
briefing to review these project-specific requirements.
The contract laboratory for this project will be accredited by the American Industrial Hygiene
Association, (AHA) and will be New York State Department of Health ELAP approved.
6. Project Schedule: See Attachment 2
7. Field Sampling Table or Related Information:
Sample Analyze/ Total # Sample Type of Sample Holding
Matrix Parameter Samples Volume Container Preservation Time
Dust wipe Lead (Pb) 4800-5000 N/A Centrifuge tube N/A N/A
8. Field Sampling Requirements:
Required materials: Latex gloves, 1ft2 template, a tape measure, a calculator, masking tape,
dust wipe media, Niton XRF.
Sample Collection Procedure:
The sample collection procedure follows ASTM Method 1728-99 for collection of a surface
dust wipe. At completion, the dust wipe has been folded three times. For floor samples the
sample will be taken from inside the 1ft2 template. If the surface to be tested is a window
sill or well, the inspector will tape off an area of the surface to be tested and measure the
length and width of this area. This measurement, expressed in square inches, will be divid-
ed by 144 and will be recorded on the sample chain of custody that is sent to the lab.
The observations of the Lead Risk Assessors will be made in accordance with the training
they have received as part of their ISAPI certification.
XRF Testing Procedure:
1. Fold wipe neatly twice more for a total of five folds and place in a plastic bag.
2. Place wipe in a sample holder provided by NITON Corporation. The holder will only shut
tightly if the wipe was folded neatly.
3. Place sample holder with wipe into filter test stand provided by NITON.
APPENDIX
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4. The NITON XRF prompts the operator for four tests, each one on different regions of the
wipe. The test stand and holder is configured to automatically position the wipe in four
fixed positions.
See Attached ASTM Method 1728-99.
9. Sample Handling and Custody Requirements:
The collected samples will immediately be placed in plastic bags for XRF analysis. These
bags will be labeled with a unique sample identification number. Samples will be numbered
as to the residence number and the specific sample location within the residence, (xxx-xx).
Residences will be identified in numerical sequence, (i.e., 001- 350). Sample location num-
bers will be as follows: 01 - principle play area floor, 02 - principle play area interior window
sill, 03 - kitchen floor, 04 - kitchen window sill, 05 - kitchen window trough, 06 - youngest
child's room floor, 07 - youngest child's room window sill, 08 - youngest child's room window
trough, 09 - floor of next youngest child's room, and 10 - sill of next youngest child's room.
Sample numbers 11 and 12 are field blanks. (Note: One field blank will be analyzed for
every 10 samples sent to the lab). After the XRF analysis is complete, the samples (still in
the plastic bag) will be placed in a plastic centrifuge tube labeled with the same sample
identification number as the plastic bag. All the centrifuge tubes a given residence will be
placed in another plastic bag with the Chain of Custody (attached). The Chain of Custody
shall be signed by the inspector and shipped via common carrier (i.e. Federal Express) to
the contract laboratory. Samples that are not being sent to the laboratory for analysis will be
held in the Syracuse Lead Division's offices until the final reports are issued. Once the final
reports are issued, the samples will be discarded. The XRF sample bags will be purchased
from Niton Corporation. The centrifuge tubes will be provided by the laboratory and are pre-
cleaned.
10. Analytical Method Requirements:
The laboratory will follow EPA Method SW846-3050 for the digestion of the samples and
EPA Method SW846-7420 for the Atomic Absorption Spectrometry. Field sampling will be
done with Niton Portable XRF using the manufacturer's method.
The detection limit, precision and accuracy of the AA are acceptable for this project, since
the methods being used are the standard HUD/EPA methods for lead dust analysis. As
part of this project, we plan to evaluate the detection limit, precision, and accuracy of the
XRF by comparing it with the AA method, (see discussion in Section 2). Thus the XRF val-
ues stated in the Table below are approximate.
Sample Analyze/
Matrix Parameter
Analytical
Method
Dust wipe Lead (Pb)/Niton Niton
Dust wipe Lead (Pb)/AA EPA S
Detection
Limit
20 ug/ft2
10 ug/ft2
Estimated
Accuracy
25%
20%
Estimate
Precision
40±1 Dug/wipe
10± 2ug/wipe
Action
Levels
floor 40ug/ft2
sill 250 ug/ft2
well 400ug/ft2
11. Secondary Data (Non-Direct Measurement) Projects: Not Applicable
12. Other Data Quality Indicators:
The purpose of the laboratory analysis is to verify the XRF analysis. The laboratory will fol-
low EPA Method SW846-3050 for the digestion of the samples and EPA Method SW846-
QUALITY ASSURANCE PROJECT PLAN
B 5
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7420 for the Atomic Absorption Spectrometry. Field analysis will be done with Niton
Portable XRF using the manufacturer's method.
a. Representativeness:
The samples collected are representative of the route of exposure to lead poisoned chil-
dren, based upon the established HUD Guidelines and EPA Regulations at 40 CAR Part
745, Requirements of Lead-Based Paint Activities in Target Housing for this type of sam-
pling. See section #3.
b. Comparability:
The data we collect will be comparable with other lead dust data collected because we are
following the same sampling protocols.
c. Completeness:
The program anticipates participation by 350 residents/property owners. This represents a
cross-section of the entire affected population and is based on the City of Syracuse's expe-
rience with the ongoing program knowledge of the population affected with lead poisoning.
For the primary purpose of this project, the minimum number of houses which participate
has no bearing on the quality of the data generated. However, a minimum of twelve resi-
dences must be tested before a comparison is made of the XRF data and the AA data. The
results of a minimum of 90% of the AA/XRF samples must be provided prior to the issuance
of a final report to any program participant.
Evaluation of the XRF as Action levels will be based on the HUD Guidelines for the
Evaluation and Control of Lead-Based Paint and HUD Lead Safe Housing Regulations.
Currently the levels are: floors - 40 ug/ft2, interior window sills - 250 ug/ft2, and window
troughs - 400 ug/ft2.
13. Peer Review:
The project proposal that was prepared for this EMPACT project has successfully under-
gone a peer review. No additional reviews are planned.
14. See Niton Documents - See Attachments 4 & 5
15. Assessments/Oversight:
Terry Bourbon, the EPA Project Officer, will be performing various reviews and audits. If any
issues need attention from the EPA they will be included in the Quarterly Progress Reports
to the EPA. Midway through our project's time span, the EPA Project Officer will plan a site
visit to review the entire project. This review will include an inspection of project files and
data reports to insure that the project is being conducted in accordance with this QAPP A
report detailing the findings of this review will be provided to the Project Manager from the
City of Syracuse.
B6 APPENDIX
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16. Data Review, Validation and Usability:
We plan to evaluate the results from the blanks against the results for the samples associat-
ed with those blanks. The impact of the blank will be assessed and the data will be quali-
fied, as appropriate. If the sample results are less than ten times the blank, the data will be
flagged and re-sampling will occur.
Aside from the XRF and AA comparisons described in Section 2, no additional replicate
sampling or analysis will be conducted.
Sample results will be reported individually for each location sampled within a dwelling.
The following limitations should be considered when data is interpreted: limit of detection,
calibration of equipment, and condition of the paint. The report template will be translated
into multiple languages. Project participants will receive relevant reports; other citizens may
see results and updates via the website. In order to maintain the integrity of the data blank
samples will be sent to the laboratory and read with the XRF. For each dwelling sampled,
both residents and owners will be provided with a report indicating the individual sample
results for each location sampled.
The affected population will be the children who reside in the City of Syracuse. We will be
following these HUD regulations and guidelines throughout the course of this project.
Therefore, the standard default assumptions are applicable to our affected population.
Data and interpretation will be provided to our primary customers (the public). The data
interpretation, which will be provided, will be based on the action levels described in section
2. We are hoping that the public will utilize the HERA vacuum leaner program and that the
training provided will be effective in controlling lead dust in contaminated homes. A phone
number and email address will be provided so that any questions can be answered.
17. Documentation and Records:
The information and data will be delivered to the public in a number of ways. The project will
provide the residents and property owners with a copy of the individual inspection report
when completed. For Phase I it is anticipated that it will take 5 to 7 days from the day of the
inspection to the individual receiving the report. The inspection report will consist of the
sample locations and results highlighting those samples that exceed the federal limit. The
report will also include any observations the Risk Assessor has made about the general
condition of the paint, and recommendations regarding the findings. Residents and property
owners will also receive printed material providing information on how to control lead in their
home. The specific residential data will be kept confidential and only released to the appro-
priate family by the City of Syracuse, and the inspectors involved in the project. There will
be poster displays at community centers, newsletter articles and presentations at communi-
ty meetings. There will be a project web site, which will contain information and data for
public access in text and map formats. Finally, all this information will be translated into a
number of languages so that they are understandable to the non-English speaking popula-
tions of the community.
Data and information on the web site will be updated monthly. Poster displays will be rotated
at least quarterly. In addition, monthly meetings will be held among the Community Based
Organizations to review progress, results and problems.
Raw data, (lab reports and XRF reports) will be kept on file at the City of Syracuse.
Individual reports will be kept in a secure file for a minimum of 3 years. All reports will be
stamped, "Confidential," to insure data is not used for other purposes.
QUALITY ASSURANCE PROJECT PLAN
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Attachment 1
Community Based Organizations
Southwest Community Center
401 South Avenue
Syracuse, New York 13204
Syracuse Northeast Community Center
716 Hawley Avenue
Syracuse, New York 13203
Southeast Asian Center
503 North Prospect Avenue
Syracuse, New York 13208
Boys & Girls Clubs of Syracuse
375 West Onondaga Street
Syracuse, New York 13202
Brighton Family Center
100 Edmund Avenue
Syracuse, New York 13205
Girls Inc.
401 Douglas Street
Syracuse, New York 13203
Westcott Community Center
826 Euclid Avenue
Syracuse, New York 13210
Onondaga County Health Department
421 Montgomery Street
Syracuse, New York 13202
APPENDIX
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APPEN DIX C
MINNEAPOLIS LEAD HAZARD
CONTROL PROGRAM
ABOUT THE PROGRAM
Minneapolis, Minnesota, implemented a Lead Hazard Control Program, a comprehensive mon-
itoring, outreach, and education program to control lead dust in homes, day care facilities, and
other areas where lead dust is a problem. This program educates businesses and the general pub-
lic about lead dust poisoning and provides "turnkey" information written for local agencies and
nonprofit organizations interested in setting up lead centers inside of retail stores in their com-
munities. Lead centers offer information and supplies to help protect children from lead poison-
ing. Minneapolis's goal is to eliminate lead hazards by the year 2010.
Established in 1998, the Lead Hazard Control Program has been well received by participating
retailers and the general public. As a result of the program's implementation, the general public
is increasing its knowledge of lead-based paint and has an effective, affordable, and convenient
way to clean up potentially harmful lead dust in their homes and apartments. People who were
potentially creating lead hazards, such as painters and home-remodeling contractors, learn about
lead-safe work practices. Retailers who set up lead centers at locations such as hardware stores,
paint stores, and garden centers attract additional customers, which increases their business and
store sales and engenders good will with their customers. Store staff provide guidance on lead-
safe work practices and offer products and resources that are needed for working safely with
lead, beyond the use of a HEPA vacuum.
PARTNER ORGANIZATIONS
The city of Minneapolis's Lead Hazard Control Program receives funding from the U.S.
Department of Housing and Urban Development. Minneapolis also collaborates with a number
of community, city, county, and state organizations to help fund and realize this effort.
IDENTIFYING THE AUDIENCE
Since children under age 6 are most susceptible to lead poisoning, the state of Minnesota passed
guidelines requiring mandatory blood testing of all children in this age group living in the
Minneapolis/St. Paul metropolitan area. These guidelines were developed and are being imple-
mented by health commissioners, pediatric doctors, and nurses working with the state health
commissioner and Department of Health. The city is alerted if lead blood levels exceed 10
micrograms of lead per deciliter of blood (ug/dL). A letter is sent to parents and the property
owner is notified if a child tests at a "low level" of concern (10 to 19 ug/dL). Members of the
child's household are invited to participate in the HEPA vacuum lender program and are
offered a free lead dust inspection of their premises. They are instructed with simple steps to
clean and reduce the child's lead exposure. For children with elevated blood levels (more than
15 ug/dL for 90 days), lead inspectors visit the home immediately. Minnesota reports a 90 per-
cent success rate in reaching the homes that need treatment.
Day care providers are another target for lead dust education in Minneapolis. The program edu-
cates the day care provider, who then educates the parents. The program also has enlisted the
involvement of public health nurses who educate the children in day care settings about the
importance of washing their hands and taking off their shoes before entering their houses.
MINNEAPOLIS LEAD HAZARD CONTROL PROGRAM B9
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DUTREACH BARRIERS AND STRATEGIES
The Minneapolis/St. Paul area has the largest Somali immigrant population in the United
States. Many of these residents are fearful of government and are largely illiterate. In addition to
reaching them through community-based organizations and with translated material distributed
in public health clinics, the program is also using local Somali-language cable TV and radio sta-
tions. Minneapolis is using donated advertising space to place informational posters in bus stop
shelters within targeted neighborhoods. Minneapolis finds that free "remnant" (unsold) transit
advertising space is often available in low-income neighborhoods.
The city of Minneapolis printed a Guide to Setting Up a Lead Center that explains in clear and
simple terms the steps involved in setting up and operating a lead center. It covers everything
from identifying suitable locations, approaching local store owners, educating store staff (who
play a major outreach role), running the HEPA vacuum rental program, disposing of hazardous
waste, understanding liability issues, and more. Local retailers, such as hardware stores, paint
stores, and gardening centers, as well as neighborhood churches and community centers, can
use this guide to establish and run a lead center inside of their establishments and to implement
the HEPA vacuum loaner program. The city has educated and trained hardware store personnel
and has established Neighborhood Lead Centers in several locations. Minneapolis successfully
recruits these business owners by showing them how they can benefit and how their knowledge
about lead dust can serve as a marketing tool.
The lead centers display bilingual brochures and videos about lead poisoning and the treatment
of lead dust. They also manage rentals of HEPA vacuums. Nine lead centers are currently oper-
ating in the Minneapolis/St. Paul area, with several more in the planning stages. In addition to
the actual HEPA vacuums, the centers are supplied with all necessary equipment and accessories
such as vacuum filters, wet wipes, disposable gloves, and disposable bags. Minneapolis provides
each center with standard rental agreement forms, vacuum equipment, supply checklists,
reorder forms, and standard lead center policy notices for posting. It also provides information
and training for retail store employees on lead-safe work practices and the HEPA loaner pro-
gram, which the employees, in turn, pass on to their customers. Additionally, the program pro-
vides tips on identifying, approaching, and recruiting potential retail partners, as well as tips on
program publicity, media relations, and general program outreach.
Minneapolis also recognizes the important interactive role lead inspectors play Not only are
they technical experts and program enforcers, but they also are program ambassadors. Because
interpersonal skills are so vital, the city is adding requirements to its job description for lead
inspectors, such as "human relations communication" and "group facilitation" skills, as well as
an ability to work with people of diverse backgrounds and to resolve disputes.
LEAD CLEAN-UP AND PREVENTION
To give residents the tools and information needed to clean up lead dust and debris,
Minneapolis's Lead Hazard Control Program developed a brochure that succinctly describes the
important steps for cleaning lead dust.
Minneapolis lends the HEPA vacuums free of charge but residents pay a $10 filter replacement
fee. Lead centers might request a deposit to cover the replacement cost of the vacuum cleaner
($175)- The deposit can be used to offset the cost of damaged or lost equipment or accessories,
and is refunded upon the safe return of the equipment. Customers can borrow the machines for
A P P E N D I X
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a 48-hour period, and centers may charge a late fee for each additional day past due. Each filter
lasts for approximately five uses, and customers may purchase additional filters if necessary at
cost using the re-order form provided in the lead center program materials. The organizations
responsible for the lead centers must visit each center periodically to collect and properly dis-
pose of used filters, as defined by municipality guidelines.
Hennepin County, Minnesota, accepts used filters as residential waste, but in other municipali-
ties, the lead center must check with its local hazardous waste disposal authority. Airtight con-
tainers, buckets, or drums may be used by a lead center to temporarily store used filters. The
organization sponsoring the lead center is responsible for periodically visiting the centers to col-
lect any generated waste. The centers also must track the number of uses for each filter by writ-
ing the address of the user with a permanent marker directly on the filter.
RESULTS
On average, 150 children per year are found to have blood levels of 20 ug/dL and 300 are
found to have a level between 10 ug/dL (the current level of concern as defined by the CDC)
and 19 ug/dL. But these numbers are still not an accurate reflection of the number of children
who are actually being exposed to and impacted by lead. In fact, the most recent reports show
that less than 20 percent of Minneapolis children have a blood lead test. And the Minnesota
Department of Health reports that 40 percent of Minneapolis's Somali and Laos population are
tested positive to have blood lead levels over 10 ug/dL.
Despite limited funds, the Minneapolis project has already made an impact. The project has
helped create 14 lead centers throughout the Minneapolis area over the last five years. And lead
programs all over the nation contact the Minneapolis program's leaders all the time asking for
guidance and assistance.
AWARDS AND RECOGNITION
In May 2001, the Minneapolis Lead Hazard Control Program received the 2001 Lead Star
Award presented by the National Lead Assessment and Abatement Council.
FOR MORE INFORMATION
Johanna (Jo) Miller
Project Coordinator
Children's Environmental Health
Minneapolis Environmental Services
250 South 4th Street, Room 401
Minneapolis, MN 55415
612 673-3856
MINNEAPOLIS LEAD HAZARD CONTROL PROGRAM
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APPEN DIX D
EM PACT LEAD-SAFE >ARD PROJECT IN
BOSTON, MASSACHUSETTS
ABOUT THE PROGRAM
The EMPACT Lead-Safe Yard Project (LSYP) in Boston, Massachusetts was a three-phased,
community-based program that used a variety of low-cost techniques to reduce children's expo-
sure to elevated levels of lead in residential soil. The project's goals were (1) to generate real-time
data of lead concentrations in residential yard soils using innovative field-portable x-ray fluores-
cence (XRF) technology and to communicate these data to residents; (2) to plan and implement
low-cost and sustainable landscape measures in residents' yards that would reduce children's risk
of exposure to contaminated soil and that residents would be taught to maintain; and (3) to
develop a template that other communities and public agencies can use to address the issue of
lead in residential soil. Each partner organization was assigned tasks to implement, including
outreach and education, safety training, sampling and analysis, soil mitigation, and creation of a
template for community action.
PARTNER ORGANIZATIONS
During the pilot phases, the project's community partners in the Boston area were Boston
University School of Public Health, the Bowdoin Street Community Health Center, and two
non-profit landscaping companies, Dorchester Gardenlands Preserve and Garden Futures.
IDENTIFYING THE AUDIENCE
The initial target community selected for the first two phases of the project was a several-block
area in the Bowdoin Street neighborhood, consisting of approximately 150 mostly older, wood-
framed houses in the North Dorchester section of Boston. This is an inner-city community,
with a large minority and immigrant population. Bowdoin Street is situated in the "lead belt" of
Boston, where the majority of children in the city with elevated blood levels reside.
During the third phase of the project, the program targeted a different community—the
Dudley Street neighborhood—which is also located in the lead belt of Boston.
DUTREACH BARRIERS AND STRATEGIES
In an effort to gain support for the project, EMPACT LSYP followed a model commonly used
for community education and outreach: a bilingual outreach worker from the community
health center conducted typical outreach activities, including walking in the neighborhood,
knocking on doors, distributing flyers, speaking at community meetings, and talking with peo-
ple one-on-one. These efforts were culturally specific to the neighborhood and conducted at an
appropriate literacy level.
After Phase 2 of the project was completed, outreach workers returned to the homes where yard
work had been performed and interviewed its occupants. They found that people had not really
comprehended the lead problem, but viewed the project more as a landscaping program. To
remedy this, the outreach worker underwent more extensive training on the lead issue and then
returned to the site with a video to teach residents about the hazards of lead. After viewing the
video, the residents were given a short quiz, and then had the opportunity to discuss the topic
afterward, thereby utilizing three modes of learning: visual, written, and oral.
APPEN DIX
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SOIL SAMPLING AND ANALYSIS
After outreach workers completed their interviews and created a list of participants who agreed
to have their yards tested for lead, the soil sample and analysis began. EMPACT LSYP found
XRF testing to be an effective tool that gives results on the spot. This process allowed trained
inspectors to get timely and accurate onsite readings of lead levels in soil with a hand-held, bat-
tery-powered device. Onsite inspectors were able to get real parts per million (ppm) lead levels
for individual soil samples within seconds. This way, lead inspectors could discover any unusu-
ally high lead levels right away as opposed to waiting two to four weeks for laboratory results to
come back. And, if necessary, inspectors could adjust their testing strategy for the property
accordingly as a whole, taking appropriate precautions. After all readings are taken, inspectors
produced a color-coded map of a property's lead levels well before the results of confirmatory
lab tests were available.
Once a sizable cross-section of properties was tested, inspectors could record the results on a
map to see if a geographical pattern emerged. If such a pattern did emerge, then this informa-
tion could be made accessible to the public.
REMEDIAL MEASURES AND YARD TREATMENTS
After a property's soil had been tested and confirmed for lead hazard, the next step was to set up
a yard treatment schedule. The EMPACT LSYP targeted areas such as drip zones and removed
plants and vegetables in those areas, replacing them with raised-perimeter boxes milled with
mulch or gravel and plantings. The program also improved existing lawns by loosening soil,
adding a seed mixture of rye, fescue, and bluegrass, topping the new seed with 1A inch of top-
soil. Where appropriate, the program installed new lawns on raised beds and created raised
mulch beds with or without plantings. Parking areas needed to be graveled or asphalted.
Children's play areas needed to be raised and covered with mulch over filter fabric weed barrier.
Porches with open soil areas underneath had to be barricaded with lattice and trim. EMPACT
LSYP used only ACQ pressure-treated wood, as opposed to wood treated with chemicals such
as arsenic and chromium which would have created another soil hazard.
RESULTS
The pilot project was funded in two phases, which took place in the summers of 1998 and
1999- During these two years, the project addressed 42 residences at no cost to the homeown-
ers; conducted a number of seminars on lead-safe yard work; and developed a "Tool Kit" for use
by other communities, which were then incorporated into a handbook titled Lead-Safe Yards:
Developing and Implementing a Monitoring, Assessment, and Outreach Program for Your
Community.
Phase 3, completed in 2001, addressed 19 homes. And, in conjunction with the EMPACT
project, the city of Boston completed 24 homes during the same period.
AWARDS AND RECOGNITION
Because of the EMPACT LSYP's innovative approaches and far-reaching impacts, project part-
ners have received several prestigious awards for their work. These include:
• 1999 Regional Science Award. Two scientists from EPA's Office of Environmental
Measurement and Evaluation also received EPA Bronze Medals for this work.
EMPACT LEAD-SAFE YARD PROJECT IN BOSTON, MA
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• 1999 Harvard Award for Excellence in Children's Health.
• 2000 Boston University School of Public Health Award for Excellence in Public Health
Practice.
FDR MORE INFORMATION
Visit the EMPACT Lead-Safe Yard Project's Web site at or
contact:
Robert Maxfield
Environmental Investigation and Analysis
EPA-New England Regional Laboratory
11 Technology Drive
North Chelmsford, MA 01863-2431
617918-8640
A P P E N D I X
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APPEN DIX E
MEMORANDUM FROM ELIZABETH CDTSWDRTH,
DIRECTOR, OFFICE DF SOLID WASTE
2000
MEMORANDUM
From: Elizabeth A. Cotsworth, Director
Office of Solid Waste
To: RCRA Senior Policy Advisors
EPA Regions 1-10
Subject: Regulatory Status of Waste Generated by Contractors and Residents from Lead-
Based Paint Activities Conducted in Households
What is the purpose of this interpretation?
This memorandum clarifies the regulatory status of waste generated as a result of lead-based paint
(LBP) activities (including abatement, renovation and remodeling) in homes and other residences.
Since 1980, EPA has excluded "household waste" from the universe of RCRA hazardous wastes
under 40 CFR 261.4(b)(l). In the 1998 temporary toxicity characteristic (TC) suspension
proposal, we clarified that the household waste exclusion applies to "all LBP waste generated as a
result of actions by residents of households (hereinafter referred to as "residents") to renovate,
remodel or abate their homes on their own." 63 FR 70233, 70241 (Dec. 18,1998). In this
memorandum, EPA is explaining that we believe lead paint debris generated by contractors in
households is also "household waste" and thus excluded from the RCRA Subtitle C hazardous
waste regulations. Thus, the household exclusion applies to waste generated by either residents or
contractors conducting LBP activities in residences.
What is the practical significance of classifying LBP waste as a household waste?
As a result of this clarification, contractors may dispose of hazardous-LBP wastes from residential
lead paint abatements as household garbage subject to applicable State regulations. This practice
will simplify many lead abatement activities and reduce their costs. In this way, the clarification
in today's memorandum will facilitate additional residential abatement, renovation and
remodeling, and rehabilitation activities, thus protecting children from continued exposure to lead
paint in homes and making residential dwellings lead safe for children and adults.
MEMORANDUM FROM ELIZABETH CDTSWDRTH
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LBP debris (such as architectural building components -- doors, window frames, painted wood
work) that do not exhibit the TC for lead need not be managed as hazardous waste. However, LBP
waste such as debris, paint chips, dust, and sludges generated from abatement and deleading
activities that exhibit the TC for lead (that is, exceed the TC regulatory limit of 5 mg/L lead in the
waste leachate), are hazardous wastes and must be managed and disposed of in accordance with
the applicable RCRA subtitle C requirements (including land disposal restrictions) except when it
is "household waste." Under 40 CFR 261.4(b)(l), household wastes are excluded from the
hazardous waste management requirements. Today, EPA is clarifying that waste generated as part
of LBP activities conducted at residences (which include single family homes, apartment
buildings, public housing, and military barracks) is also household waste, that such wastes are no
longer hazardous wastes and that such wastes thus are excluded from RCRA's hazardous waste
management and disposal regulations. Generators of residential LBP waste do not have to make a
RCRA hazardous waste determination. This interpretation holds regardless of whether the waste
exhibits the toxicity characteristic or whether the LBP activities were performed by the residents
themselves or by a contractor.
Where can I dispose of my household LBP waste?
LBP waste from residences can be discarded in a municipal solid waste landfill (MSWLF) or a
municipal solid waste combustor. Dumping and open burning of residential LBP waste is not
allowed. Certain LBP waste (such as large quantities of concentrated lead paint waste — paint
chips, dust, or sludges) from residential deleading activities may be subject to more stringent
requirements of State, local, and/or tribal authorities.
What is the basis for this interpretation?
The household waste exclusion implements Congress's intent that the hazardous waste regulations
are "not to be used either to control the disposal of substances used in households or to extend
control over general municipal wastes based on the presence of such substances." S. Rep. No. 94-
988, 94th Cong., 2nd Sess., at 16. EPA regulations define "household waste" to include "any
waste material (including garbage, trash, and sanitary wastes in septic tanks) derived from
households (including single and multiple residences, hotels and motels, bunkhouses, ranger
stations, crew quarters, campgrounds, picnic grounds and day-use recreation areas)." 40 CFR
261.4(b)(l). The Agency has applied two criteria to define the scope of the exclusion: (1) the
waste must be generated by individuals on the premises of a household, and (2) the waste must be
composed primarily of materials found in the wastes generated by consumers in their homes (49
FR 44978 and 63 FR 70241).
In 1998, EPA concluded that LBP waste resulting from renovation and remodeling efforts by
residents of households met these criteria. (63 FR 70241-42, Dec. 18,1998). In short, the Agency
found that more and more residents are engaged in these activities and thus the waste can be
considered to be generated by individuals in a household and of the type that consumers generate
routinely in their homes. Wastes from LBP abatements performed by residents were also
considered household wastes.
9 6
A P P E N D I X
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EPA clarifies that this interpretation also applies to contractor-generated LBP waste from
renovations, remodeling and abatements in residences. Both the definition of household waste in
section 261.4(b)(l) and the Agency's criteria for determining the scope of the exclusion focus on
the type of waste generated and the place of generation rather than who generated the waste (e.g., a
resident or a contractor). This approach is consistent with prior Agency policy.1 Since
contractor-generated LBP waste from residential renovations, remodeling, rehabilitation, and
abatements are of the type generated by consumers in their homes, it is appropriate to conclude that
such waste, whether generated by a resident or contractor, falls within the household waste
exclusion. This clarification will facilitate lead abatements and deleading activities in target
housing by reducing the costs of managing and disposing of LBP waste from residences.
What is the relationship of this interpretation to the on-going LBP debris rulemaking?
On December 18,1998, EPA proposed new TSCA standards for management and disposal of LBP
debris (63 FR 70190) and simultaneously proposed to suspend temporarily the applicability of the
RCRA hazardous waste regulations that currently apply to LBP debris (63 FR 70233). This
memorandum responds to stakeholders requests that EPA clarify whether the existing household
waste exclusion applies to both homeowners and contractors conducting LBP activities in
residences. While the Agency still intends to finalize aspects of the two proposals, we are making
this clarification in advance of the final rule to facilitate LBP abatement in residences without
unnecessary delay.
How does this interpretation affect EPA's enforcement authorities?
Under this clarification, LBP wastes generated by residents or contractors from the renovation,
remodeling, rehabilitation, and/or abatement of residences are household wastes that are excluded
from EPA's hazardous waste requirements in 40 CFR Parts 124, and 262 through 271. The
household waste provision of 40 CFR 261.4(b)(l) only excludes such wastes from the RCRA
regulatory requirements. However, it does not affect EPA's ability to reach those wastes under its
statutory authorities, such as RCRA §3007 (inspection) and §7003 (imminent hazard). See 40 CFR
§261.1(b).
What are the "best management practices" for handling residential LBP waste?
'in the final rule establishing standards for the tracking and management of medical waste, EPA concluded
that waste generated by health care providers (e.g., contractors) in private homes would be covered by the
household waste exclusion. 54 FR 12326,12339 (March 24,1989). In the specific context of LBP, the Agency
stated in a March 1990 "EPA Hotline Report" (RCRA Question 6) that lead paint chips and dust resulting from
stripping and re-painting of residential walls by homeowner or contractors (as part of routine household
maintenance) would be part of the household waste stream and not subject to RCRA Subtitle C regulations.
Similarly, in a March 1995 memorandum on the "Applicability of the Household Waste Exclusion to Lead-
Contaminated Soils," we found that if the source of the lead contamination was as a result of either routine
residential maintenance or the weathering or chalking of lead-based paint from the residence, the hazardous waste
regulations do not apply so long as the lead-contaminated soil is managed onsite or disposed offsite according to
applicable solid waste regulations and/or State law mandated by RCRA.
MEMORANDUM FROM ELIZABETH COTSWORTH 97
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Although excluded from the hazardous waste regulations, EPA encourages residents and
contractors managing LBP waste from households to take common sense measures to minimize the
generation of lead dust, limit access to stored LBP wastes including debris, and maintain the
integrity of waste packaging material during transfer of LBP waste. In particular, we continue to
endorse the basic steps outlined in the 1998 proposals for the proper handling and disposal of LBP
waste (63 FR 70242) as the best management practices (BMPs) including:
• Collect paint chips and dust, and dirt and rubble in plastic trash bags for disposal.
• Store larger LBP architectural debris pieces in containers until ready for disposal.
• Consider using a covered mobile dumpster (such as a roll-off container) for storage of LBP
debris until the job is done.
• Contact local municipalities or county solid waste offices to determine where and how
LBP debris can be disposed.
In addition, contractors working in residential dwellings are subject to either one or both of the
following:
• The HUD Guidance for contractors doing publically-funded rehabilitation/renovation
projects in public housing. (See Guidelines for the Evaluation and Control of Lead-Based
Paint Hazards in Housing. U.S. Department of Housing and Urban Development, June
1995) The HUD guidelines can be accessed via the Internet at:
http://www.hud.gov/lea/leaniles.htnil
TSCA 402/404 training and certification requirements. (See 40 CFR Part 745; 61 FR
45778, August 29,1996) and the proposed TSCA onsite management standards (See 40
CFR Part 745, Subpart P; 63 FR 70227 - 70230, Dec. 18,1998). [EPA expects to issue the
final rule next year.]
The above-mentioned BMPs for households are similar to those included in the HUD Guidelines
for individuals controlling LBP hazards in housing. HUD requires that contractors using HUD
funding adhere to LBP hazard control guidelines. Non-adherence to these guidelines can
potentially result in the loss of funding.
Does this interpretation apply in my State and/or locality?
We encourage contractors and residents to contact their state, local and/or tribal government to
determine whether any restrictions apply to the disposal of residential LBP waste. This
verification is necessary since, under RCRA, States, local and tribal governments can enforce
regulations that are more stringent or broader in scope than the federal requirements. Thus, under
such circumstances, LBP waste from households may still be regulated as a hazardous waste as a
matter of State regulations.
We are distributing this memorandum to all 56 States and Territories, and Tribal Programs and
various trade associations. We encourage States to arrange for implementation of the
A P P E N D I X
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interpretation discussed in this memo in their States to facilitate residential LBP abatements
making residential dwellings lead-safe. We encourage trade associations to inform their
memberships about this memo and instruct them about ways to manage residential LBP waste.
Whom should I contact for more information?
If you have additional questions concerning the regulatory status of waste generated from lead-
based paint activities in residences, please contact Ms. Rajani D. Joglekar of my staff at 703/308-
8806 or Mr. Malcolm Woolf of the EPA General Counsel's Office at 202/564-5526.
cc: Key RCRA Contacts, Regions 1 -10
RCRA Regional Council Contacts, Regions 1 -10
RCRA Enforcement Council Contacts, Regions 1-10
Association of State and Territorial Solid Waste Management Officials ( ASTSWMO)
MEMORANDUM FROM ELIZABETH CDTSWDRTH 99
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