Office of Pollution EPA 747-B-00-002
UnitedStates *" Prevention and Toxics July 2000
Environmental Protection
Agency
LEAD SAMPLING TECHNICIAN
TRAINING COURSE
TRAINER MANUAL
Program Assessment and Outreach Branch
National Chemicals Division
Office of Pollution Prevention and Toxics
Office of Prevention, Pesticides, and Toxic Substances
United States Environmental Protection Agency
Washington DC 20460
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DISCLAIMER
This document has been prepared for the Office of Pollution Prevention and Toxics (OPPT), U.S.
Environmental Protection Agency. The material in this document has been subject to EPA
technical and policy review and approved for publication as an EPA report. The use of trade
names and commercial products does not constitute Agency endorsement or recommendation for
use.
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CONTRIBUTING ORGANIZATIONS
This training manual was funded by the United States Environmental Protection Agency (EPA).
The manual was managed by EPA and developed by ICF Consulting, under contract to EPA.
Each organization's responsibilities are listed below.
ICF Consulting
ICF Consulting worked with EPA to develop training materials for the lead sampling technician
course, including a student manual, trainer manual, and a field guide. ICF Consulting was
assisted by Georgia Tech Research Institute, the National Center for Lead-Safe Housing, and
Community Resources.
United States Environmental Protection Agency
EPA was responsible for managing the manual development, providing technical oversight,
guidance and directions, and overseeing the peer review and finalization of the manual. Ms.
Darlene Watford was the Work Assignment Manager for this task and the EPA Project Officer was
Mr. Samuel F. Brown.
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ACKNOWLEDGEMENTS
The following individuals on a Review Panel for the development of the training course materials.
They provided valuable insights and advice.
Jim Bland, Mets Laboratories
Karen Garbarino, Vermont Department of Health
Liz Hernandez, Cleveland Housing Network
Stevenson Weitz, HUD Office of Lead Hazard Control
Jim Yannarelly, St. Paul - Ramsey County, Department of Public Health
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TABLE OF CONTENTS
Trainer Overview
PART 1: INTRODUCTION AND BACKGROUND
Introduction
Module 1: Background
PART 2: SKILLS
Module 2: Visual Assessment
Module 3: Dust Wipe Sampling
Module 4: Selecting a Laboratory and Interpreting Results
PART 3: APPLICATION
Module 5: Putting the Skills Together
Module 6: Writing and Delivering the Report
Appendix A: Regulatory Guidance
Appendix B: Blank Clearance Examination Report Form and Handouts
Appendix C: Model Clearance Examination Report
Appendix D: Glossary
Appendix E: Answers to Exercises
Sample of Student Manual
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Trainer Overview
This Model Curriculum
The U.S. Environmental Protection Agency (EPA)
has produced this model curriculum to teach
individuals how to conduct lead sampling in
housing.
This document is the Trainer Manual that
accompanies this EPA-sponsored training course.
This manual guides trainers through the
presentation of the course materials and is
designed to be used in conjunction with the
Student Manual for the course.
Objectives for the Course
At the end of the course, students will be able to:
* Conduct a visual assessment and correctly
identify visible dust, debris, and deteriorated
paint;
• Collect dust samples in accordance with
standard acceptable procedures;
* Interpret the results of a laboratory analysis
accurately;
• Apply these skills to conduct an appropriate
lead sampling examination in post-renovation,
HUD-required, and other circumstances;
* Understand the Federal, State, and Indian Tribe
regulatory requirements for lead clearance and
other lead sampling;
* Write a complete, accurate, and
understandable report of sampling results; and
• Explain the results to the client.
Audience for the Course
Organizations that will be interested in this course
include:
• State and local public agencies that administer
federal funds for housing;
* Non-profit and community housing
organizations, particularly those that assist
public agencies in administering federal
housing funds;
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Lead Sampling Technician Course
• State and local health departments;
* Home inspection firms; and
» Lead and other environmental services firms.
Appropriate staff to send to this course will
include:
* Housing quality standard (HQS) inspectors;
• Rehabilitation specialists;
* Home inspectors; and
* Other staff who are involved in evaluating
dwelling units.
Overview of Lead Sampling Technician
Training Curriculum
This training course consists of three parts and six
modules including:
Part 1: Introduction and Background
* Introduction provides a brief overview to the
course and includes an icebreaker activity.
• Module 1: Background introduces the course
objectives and provides general background on
the health risks of lead and the purpose of lead
sampling.
Part 2: Skills
• Module 2: Visual Assessment explains how to
perform a visual assessment.
• Module 3: Dust Wipe Sampling describes
how to prepare for and collect dust wipe
samples.-
• Module 4: Selecting a Laboratory and
Interpreting Results describes how to select
an accredited lab, how to submit samples, and
how to interpret the results and ensure that they
are acceptable.
Part 3: Application
• Module 5: Putting the Skills Together gives
an overview of the various Federal
requirements that apply to lead sampling and
explains how to perform lead sampling in three
different situations:
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Trainer Overview
>• Post-renovation clearance
>• HUD-required clearance
>• Other lead sampling examinations
• Module 6: Writing and Delivering the Report
covers how to prepare the report and explain
the results to a client.
Course Schedule
The following table provides time estimates for
each module allowing time for exercises and
participant questions. If two 10-minute breaks are
included, the whole course takes approximately 5
hours.
Course Schedule
Part 1: Introduction and Background
Introduction
Module 1 : Background
Part 2: Skills
Module 2: Visual Assessment
Module 3: Dust Wipe Sampling
Module 4: Selecting a Laboratory and Interpreting Results
Part 3: Application
Module 5: Putting the Skills Together
Module 6: Writing and Delivering the Report
Total Time
45 minutes
15 minutes
30 minutes
155 minutes
20 minutes
90 minutes
45 minutes
90 minutes
60 minutes
30 minutes
-5 hours
Course Materials
Course materials include trainer and student
materials.
Trainer materials. The trainer's materials include
overhead slides, other visual teaching aides, and
this manual. (See the end of this introduction for a
checklist of materials and supplies needed to teach
this course.) The trainer manual is organized as
follows:
• Trainer notes. Each chapter of this manual
includes full notes for each module of the
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Lead Sampling Technician Course
training course. The left column has pictures of
the overhead slides and the right column has
the trainer script that goes with them. The
script highlights key points and provides useful
examples. Note that the script is not meant to
be used verbatim by the trainer; however, it
does include all the information that must be
covered by the trainer. The trainer notes are
formatted to highlight activities.
Activities. Exercises, actions, reference materials,
and discussion questions are all highlighted in
shaded textboxes like this one.
Attachments. The trainer's manual includes a
number of attachments at the end of each
chapter. These attachments are also included
in the Student Manual. They include checklists,
summaries, mode) forms, exercises, and other
resources. Appendix E contains answers to the
exercises included in the modules. Whenever
they are used, they are highlighted in the text of
the trainer manual with the following icon:
Additional information for the trainer. The
trainer's manual also includes additional
information that can be used by the trainer to
supplement the material that is taught during
the course. The trainer does not have to use
this information while teaching the course. This
additional information will be designated by the
following icon:
Pictures. The trainer's manual also includes
photographs of the various activities to be
performed by the lead sampling technician.
Whenever a picture should be shown to the
students, it will be designated by the following
icon:
* Field Guide. Refer students to the Field Guide
as appropriate. The icon shown here serves as
a reminder to instruct students to refer to the.ir
field guides.
IV
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Trainer Overview
Student materials. Student materials include a
Student Manual and a Field Guide. The Student
Manual provides course participants with copies of
the overhead slides that are used by the trainer
during the course and with attachments that
summarize key information. The student manual is
formatted to leave space on each page where
student's can take notes as they follow along. The
Field Guide summarizes key points and
procedures in one easy-to-read reference tool. The
trainer should encourage students to bring the Field
Guide on the job with them when they conduct
examinations.
In presenting the course, trainers are encouraged
to use the student materials in the following ways:
* Recommend to the students that they follow
along with the overhead slides as they are
presented and take notes in the space
provided;
* Refer students to the attachments and
appendices with helpful information and
encourage them to mark pages with important
information, summaries, checklists, tables, or
tools they can use; and
* Refer students to the Field Guide as
appropriate.
Instructional Information
Trainer responsibilities. The success of each
training session depends upon good preparation
and effective delivery of course materials. While
this manual provides specific guidance about
presenting this course, trainers will need to use
their professional expertise and training experience
in preparing their lessons and adapting their
deliveries to address the needs of students in each
session. The key responsibilities of each trainer
are:
» Understand the course material;
* Prepare for each lesson based on the guidance
and instructions in the Trainer Manual;
• Deliver lessons and accomplish objectives
within each module and course time frames;
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Lead Sampling Technician Course
* Make sure that questions from students are
answered, or refer them to an appropriate
resource; and
* Reinforce course objectives throughout the
training session.
Instructional methods. This course is primarily
lecture-based; however, it is designed to be
interactive. Several of the modules include
exercises and activities. Throughout the
presentation, trainers are encouraged to be
conversational in tone and solicit student input.
The trainer notes highlight appropriate times to
prompt students for input. Trainers may modify
lesson activities, as long as the learning objectives
for the module are accomplished and the key points
identified are effectively covered.
Preparing for a training session. Prior to each
course delivery, trainers are responsible for making
the following preparations:
• Planning the delivery of their lessons;
» Reviewing the participant registration forms to
familiarize themselves with the students, their
agency and position, and any special issues
they have identified;
• Ensuring that the training room is properly set-
up; and
* Confirming that all the necessary training
supplies, materials, and equipment are
available at the training site.
VI
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Trainer Overview
Attachment - Trainer's Checklist
Supplies and Materials for the Course
Trainer manual - including notes and attachments
Student manuals - including copies of trainer overhead slides and attachments
Field guide
Overhead slides
Dust sampling materials
- Disposable wipes
- Gloves
Centrifuge tubes
- Templates (Floor and window templates)*
- Tape
Measuring tape
- Sample collection forms
- Labeling and clean-up supplies
Ink pen
Flipchart and/or blank transparencies for recording additional information
Trainers may choose to provide samples of floor and window templates to the students during
the course. As a resource, the trainer may find a list of sources of templates on the National
Center for Lead-Safe Housing's web site at www.leadsafehousinQ.org.
VII
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Introduction
|I Course Objectives
Conduct a visual assessment
Collect dust samples
Interpret results
Apply skills to conduct an exam
Understand requirements
Write a report
Explain the results to the client
Introduction (15 minutes)
Before starting Module 1, do a brief introduction to
the course. Introduce trainees), the course, the
purpose of lead sampling, and logistical
information. Take five minutes to do the icebreaker
activity.
The Training Course
In 1999, Congress urged the U.S. Environmental
Protection Agency (EPA) to make lead dust testing
more available and affordable by developing a
relevant one-day sampling technician training
course. In response, EPA has produced this model
curriculum to teach individuals how to conduct lead
sampling in housing. This course supports the
upcoming EPA renovation and remodeling
regulation as well as Housing and Urban
Development's (HUD) regulation on lead-based
paint in Federally Owned Housing and Housing
Receiving Federal Assistance.
Lead sampling is often performed to find out if dust
or deteriorated paint remain after lead hazard
reduction, renovation, remodeling, rehabilitation,
and maintenance work.
At the end of this course, students will be able to:
* Conduct a visual assessment and correctly
identify deteriorated paint, visible dust, and
debris;
* Collect dust samples in accordance with
standard acceptable procedures;
* Interpret results of a laboratory analysis
accurately;
» Apply these skills to conduct an appropriate
lead sampling examination in post-renovation,
HUD-required, and other circumstances;
* Understand the Federal, State, and Indian Tribe
regulatory requirements, if applicable, for lead
clearance and other lead sampling;
* Write a complete, accurate, and
understandable report of sampling results; and
* Explain the results to the client.
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Lead Sampling Technician Course
11ntroduce Yourself
i Name
i Occupation/organization
i How does your work involve lead-
based paint?
Logistical Information
» Provide the students with a brief overview of the
schedule for the day including breaks, lunch,
etc.
* Also indicate where the restrooms and phones
can be found.
* Discuss any ground rules that are appropriate.
Icebreaker Activity for Participants (5
minutes)
Instructions: The purpose of this activity is to
involve students actively at the beginning of the
course and gather relevant background information
about the participants, such as name, occupation,
and work experience.
Ask each of the participants to introduce
themselves by stating their name, occupation, and
the type of work they do that involves lead-based
paint.
If it is a large group, have the participants do this
exercise in small groups where they are seated.
Overview of Student Materials
Overview of Student Materials
Student Manual
Attachments
Appendices
Field Guide
Describe and explain how the course materials are
to be used by the students during the course. Walk
the participants through their materials as you
describe them. After this brief overview, begin
Module 1.
The student materials include a Student Manual,
Attachments, Appendices, and a Field Guide.
* The student manual provides course
participants with copies of the overhead slides
that are used by the trainer during the course
and with attachments and appendices that
summarize key information. The student
manual is formatted to leave enough space on
each page where student's can take notes as
they follow along.
» The attachments and appendices provide
important summaries, checklists, tables, or
tools they can use.
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Introduction
The field guide summarizes key points and
procedures in one easy-to-read reference tool
that can be taken along on the job.
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Module 1: Background
ibjectives
Health effects of lead exposure
Conditions that cause lead poisoning
Purpose of lead sampling
The difference between:
• Lead sampling technician (LST)
•Risk assessor (RA)
• Lead paint inspector (PI)
Module 1: Background (30 minutes)
This module will provide general background on the
purpose and requirements for lead sampling,
including the health effects of lead, the conditions
that cause lead poisoning, and the responsibilities
of lead sampling technicians.
Objectives
After completing this module, students will be able
to:
* Understand the health effects of lead exposure
and the danger to children posed by improper
renovation or remodeling. (Note: Remodeling
includes surface preparation for repainting
work. Repainting requiring surface preparation
should follow these guidelines.)
• Understand the conditions that can cause lead
poisoning.
* Explain the purpose of lead sampling.
* Recognize the differences between a lead
sampling technician, risk assessor, and lead
paint inspector.
ealth Effects of Lead
Lead is especially hazardous to children:
•Loss of intelligence
•Behavioral difficulties
•Problems in school
Lead is also a danger 10:
• Pregnant women
•Other adults
Lead poisoning does not always have
symptoms.
Health Effects of Lead
Before we get started, it helps to understand why
we are here. The primary reason we care about
lead is because it concerns our health, particularly
children's health.
Lead is a naturally occurring element that is harmful
to. humans when taken into the body. Lead is
especially hazardous to children because it can
cause serious and long-lasting physical and mental
problems. In extreme cases, high levels of lead in
the body can kill a child.
What happens when people are exposed to
lead?
Discussion. Ask participants if they know what
happens when people are exposed to lead.
Children under the age of six are the most at risk
to the health effects of lead poisoning because their
bodies and their nervous systems are still
developing. Lead enters the body when children
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Lead Sampling Technician Course
inhale or swallow it through normal hand-to-mouth
activity when they play. The lead is stored in
bones, organs, and the brain. It then inhibits
normal growth and development.
Children who are poisoned by lead are likely to
have problems in school because of:
• Loss of intelligence
• Learning difficulties
• Behavioral difficulties
» Damage to brain and nervous system
* Slowed growth
Pregnant women and women of childbearing age
are at risk because changes that occur in a
woman's body during pregnancy may cause lead
stored in her bones to be released into her blood.
Lead can then be passed from the mother to the
fetus. Pregnant women are likely to inhale lead-
contaminated dust when proper precautions are not
taken during and after renovation, remodeling, or
repainting activities. Lead poisoning can cause:
• Miscarriages
* Premature births
* Low birth weight
Other adults can also be lead-poisoned if exposed
to high levels of lead. This type of exposure may
happen to people whose professions expose them
to lead, such as painting, renovation and
remodeling, lead smelting or bridge painting. Other
sources of exposure could include stained glass,
ammunition loading, fishing sinkers, and soldering.
Symptoms include loss of sex drive, impotence,
nausea, weakness, anemia, and fatigue.
Additional information for the trainer. When
discussing the effects of lead poisoning, emphasize
the effects that people care most about. These are
children having problems in school and adults
becoming impotent.
Lead poisoning does not always have
symptoms. Lead poisoning often has no
symptoms or symptoms that are attributed to other
causes. The best way to determine if lead is
present in the body is by testing a person's blood.
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Module 1: Background
ow Do People Get Lead Poisoned?
Dust and soil
Paint chips
Inhalation
at Conditions Cause Poisoning?
Lead-based paint:
• 1 mg/cm2 of lead
•0.5% |5.000 parts per million (ppm)J
Exposure from:
•Lead-contaminated dust
• Deteriorated paint
•Lead-contaminated soil
How Do People Get Lead Poisoned?
In the past 20 years, we have learned a lot about
how people get poisoned by lead and the
conditions that put people most at risk.
Discussion. Ask participants if they know how
people get poisoned.
Lead-contaminated dust and soil. The most
common way to be poisoned is by ingesting lead-
contaminated dust or soil. This is one reason why
young children are more likely to be poisoned than
adults. While they play, children put their hands
and their toys in their mouths and in the process,
consume lead-contaminated dust and soil.
Paint chips. Children can also be poisoned when
they consume lead-contaminated paint chips.
Children are less likely to be poisoned by eating
paint chips than by consuming dust, but paint chips
do represent a danger. (Most clinical cases of
severe childhood lead poisoning are caused by
eating paint chips.)
Inhalation. It is also possible to inhale lead. This
is most common among workers who burn lead
(and breathe the fumes) or perform activities which
create fine dust (such as machine sanding painted
surfaces).
The key message is that dangerous sources of lead
poisoning exist in and around the home. Most
children get poisoned around their home and
neighborhood.
What are the conditions that cause poisoning?
To understand the conditions that cause lead
poisoning better, it is useful to know what lead-
based paint is and the conditions that cause
exposure to it.
Lead-based paint is paint that contains lead above
a certain amount. The federal guidelines for lead-
based paint are:
» Greater than or equal to 1 mg/cm2 of lead; and
* Greater than or equal to 0.5% [5,000 parts per
million (ppm)] lead by dry weight.
Lead-based paint that is intact is usually not likely
to be consumed and cause exposure. We are
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Lead Sampling Technician Course
more concerned with the conditions that cause
exposure to it.
The conditions that can result in harmful levels of
exposure to lead include the following:
• Lead-contaminated dust. Children may
consume lead-contaminated dust during
ordinary play. Dust is considered a lead hazard
if its lead content reaches a certain level. Dust
sampling measures the lead content of dust
and determines if it is at a hazardous level.
(Federal standards for lead-contaminated dust
will be discussed in Module 5 and are included
in the Field Guide.)
• Deteriorated lead-based paint. Deteriorated
lead-based paint may be harmful if swallowed
by a child. It also creates lead-contaminated
dust as it deteriorates. Since we don't always
know the lead content of paint, we treat all
deteriorated paint as a potential hazard.
• Lead-contaminated soil. Lead-contaminated
(bare) soil can pose a threat to children who
come into direct contact with it as they play in
the soil or surrounding areas. Lead-
contaminated soil also can be tracked inside
the home on shoes and by pets.
• Lead-contaminated drinking water. Drinking
water can be contaminated with lead,
regardless of the water's source. Many faucets
in homes and on store shelves contain leaded
components that can leach lead into the water.
We will not discuss lead-contaminated water in
this course, because it is not an item that is
- investigated by a lead sampling technician.
here are Hazardous Conditions Found?
Pre-1978 units
Units renovated or remodeled
Units in poor condition
Units with exterior lead-
contaminated soil
Where are Hazardous Conditions Found?
The dwellings most likely to contain conditions that
can cause exposure to lead-based paint are listed
below.
* Pre-1978 units. Lead-based paint was used in
homes until 1978, when it was banned by the
Consumer Product Safety Commission for
residential use. Homes built prior to 1950 are
more likely than newer homes to contain higher
concentrations of lead and to have deteriorated
paint surfaces.
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Module 1: Background
• Units renovated or remodeled. Renovation,
remodeling, repainting, and rehabilitation in pre-
1978 units is likely to disturb surfaces painted
with lead-based paint and create hazardous
conditions.
* Units in poor condition. Pre-1978 units in
poor condition are likely to have deteriorated
paint and lead-contaminated dust.
• Units with lead-contaminated soil.
Deteriorating exterior paint that contains lead
and past emissions of leaded gasoline are the
primary sources of lead in soil. Lead-
contaminated soil can be tracked into the home
as lead-contaminated dust.
-• A Lead Sampling Technician is...
A lead sampling technician has
successfully completed training to:
/perform a visual assessment
•/collect dust wipe samples
jit A Lead Sampling Technician can...
Perform clearance:
Rafter renovation and remodeling work
/ as required by HUD
/but not post-abatement
' • May also identify dust and deteriorated
paint in other situations such as:
', /pre-sale home inspections or unit turnover
! ./housing with a pregnant woman or a child
; under 6 years
What is a Lead Sampling Technician?
EPA and many states have established rules that
require individuals and firms involved in lead
evaluation and reduction activities to obtain training
and certification. These rules establish various
disciplines. A lead sampling technician is one of
them.
A lead sampling technician is ... A lead
sampling technician has successfully completed
training to perform lead sampling, including
performing a visual assessment and collecting dust
wipe samples. For the purposes of this
discipline, clearance refers to non-abatement
clearance activities.
» Clearance. A lead sampling technician is
qualified to perform clearance.
- > Clearance is performed following renovation
and remodeling or hazard reduction
, activities to determine if a work site has
been cleaned properly.
> It is required by HUD after HUD-funded
rehabilitation, lead hazard reduction, or
other activities that involve disturbance of
painted surfaces. (HUD has a number of
other requirements regarding the lead
sampling technician's qualifications and
where they are permitted to perform
clearance. These will be discussed in
Module 5.)
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Lead Sampling Technician Course
'I A Lead Sampling Technician is Not...
i A risk assessor:
/evaluates dwelling units to identify
all potential lead hazards
i A lead paint inspector:
•/evaluates the painted surfaces in a
unit to determine which surfaces
have lead-based paint
> Note: Only individuals certified as either a
risk assessor or lead paint inspector can
perform post-abatement clearance.
• Other sampling. A lead sampling technician
may also conduct lead sampling to identify dust
and deteriorated paint in other situations such
as:
> pre-sale home inspections {not a lead-
based paint inspection)
*> unit turnover
> to assess lead levels where there is a
pregnant woman or a child under 6 years
living in a pre-1978 home
A lead sampling technician is not... A lead
sampling technician is not trained to identify lead
hazards or make judgments about the overall lead-
safety of a dwelling. This is the job of a risk
assessor or lead paint inspector.
• Risk assessors evaluate dwelling units to
identify all lead hazards.
> The evaluation involves a visual
examination as well as dust, soil, and paint
chip sampling.
> The risk assessor then writes a report that
describes the nature, severity, and location
of all identified lead-based paint hazards.
» A risk assessor provides options for
remediation of each identified lead hazard.
>- The risk assessor can perform clearance in
post-abatement situations.
• Lead paint inspectors evaluate the painted
surfaces in a unit to determine which surfaces
have lead-based paint.
>> They measure the concentration of lead in
paint on a surface-by-surface basis.
y> They present a report that identifies the
location and concentration of lead for each
surface tested.
>> Like risk assessors, they can do post-
abatement clearance.
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Module 1: Background
y is Lead Sampling Important?
Lead sampling tells us:
• If lead-contaminated dust is present
•If additional cleaning is necessary to
protect children from lead poisoning
ummary: You Now Know
The health effects of lead poisoning
The conditions that cause lead
poisoning
The purpose of lead sampling
The differences between a lead
sampling technician, a risk assessor.
and a lead paint inspector
Reference Materials. Refer students to
Attachment 1-A for a summary table that
describes the difference between these different
lead evaluation professionals.
Why is Lead Sampling Important?
Discussion. Ask the participants why lead
sampling is important.
• Lead sampling is important because it tetls us if
lead-contaminated dust is present. If it is,
additional cleaning is necessary to protect
children from exposure to lead.
Activity: Photographs tell the story. Before
summarizing the module, show the students the
series of photographs that illustrate lead sampling:
1. Technician getting a call from a client
2. Preparing to go to the site - gathering materials
3. Technician doing a visual assessment
4. Technician dust sampling - the first pass of the
wipe
5. Technician dust sampling - the second pass of
the wipe (in the other direction)
6. Technician delivering the report
Summary of Module 1
Students should now be able to:
* Explain the health effects of lead exposure and
. the danger to children posed by improper
renovation, remodeling, repainting, and lead
hazard reduction work.
• Understand the conditions that can cause lead
poisoning.
* Explain the purpose of lead sampling.
* Recognize the differences between a lead
sampling technician, a risk assessor, and a lead
paint inspector.
Student Materials for Module 1
* Copies of trainer slides
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Lead Sampling Technician Course
• Attachment 1-A: Comparing Lead Evaluation
Professionals
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Attachment 1-A
COMPARING LEAD EVALUATION PROFESSiONALS
Qualified to perform
the following types
of evaluations
Is not qualified to
perform
Training!
Certification
required to perform
evaluations
Skills
LEAD SAMPLING
TECHNICIAN (LST)
• Clearance
• Other dust wipe
sampling
• Post-abatement
clearance
• Certain situations
as defined in the
HUD regulations
(See Module 5)
• 5 hour training
Perform:
• Visual
assessment
•. Dust wipe
sampling
To give a "pass/fail"
result.
RISK ASSESSOR
(RA)
• Risk
assessments
• Paint inspections
• Clearance
• Other lead
sampling
• Certification
• 5 days of training
Perform:
• interview of
residents
• Visual evaluation
• Dust wipe
sampling
• Soil sampling
• Paint chip
sampling
• XRF testing
To assess a unit,
identify lead hazards,
and recommend
methods for lead
hazard reduction.
LEAD PAINT
INSPECTOR (PI)
• Paint inspections
• Clearance
• Other lead
sampling
• Risk
assessments
• Certification
• 3 days of training
Perform:
• Visual evaluation
• Paint chip
sampling
• Paint testing by
XRF
Can also perform:
• Lead sampling
(dust wipe, soil)
To identify the
existence and
location of lead-
based paint.
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Lead Sampling Technician Course
Technician Receiving Call
Gathering Materials
Visual Assessment
Dust sampling (first pass)
M.-Ink- I Ujik-ri. I
Dust sampling (second pass)
Delivering the Report to Client
Module I: Background
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Module 2: Visual Assessment
objectives
Identify:
•Visible dust
•Paint chips
•Painted debris
•Deteriorated paint
Record the results on a visual
assessment form
hv Perform Visual Assessments?
Determines if the area is visibly
clean
•If the area is not clean, it is less
likely to pass dust sampling
Required for HUD clearance
•Clean up was done properly
•Deteriorated paint repaired
Steps in a Visual Assessment
Walk through sampling area
•Inside and outside (if applicable)
Identify:
•Visible dust
• Paint chips
• Painted debris
• Deteriorated paint
Record results
Mioilllc ? \ tnul Awwncnl
Module 2: Visual Assessment (20
minutes)
This module will outline the steps a lead sampling
technician must take to perform a visual
assessment. A visual assessment is the first
activity to perform on-site for any lead sampling
examination.
Objectives
By the end of this module, students will be able to:
• Identify visible dust, paint chips, painted debris,
and deteriorated paint.
» Record the results of the visual assessment on
a visual assessment form.
Why Perform Visual Assessments?
Discussion. Give students some context for the
visual assessment. Explain that it is the first thing
they will do when they arrive on site. Ask
participants why they think it is important to perform
visual assessments.
* The visual assessment determines if the
dwelling unit is clear of conditions that can
result in lead poisoning, such as obvious dust,
paint chips, painted debris, and deteriorated
paint.
* If these conditions are present, it is likely that
the unit will not meet the standards/guidance for
dust wipe samples.
* It is required for HUD clearance purposes:
=- To demonstrate that the contractor has
cleaned up properly.
> To document that deteriorated paint was
repaired as required by the HUD regulation.
What are the Steps in a Visual
Assessment?
* Walk through the sampling area. This usually
involves the inside of a dwelling unit, including
common areas, and may involve the areas
outside.
2-1
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Lead Sampling Technician Course
ocation of Visual Assessment
Appropriate areas may include:
•entire unit and exterior,
•only areas where work occurred
Look at horizontal surfaces
•floors
•window sills
• window troughs
indow Sills and Troughs
• Identify visible dust, paint chips, painted debris,
and deteriorated paint.
* Record the results on a visual assessment
form.
Reference Materials. Show participants the model
form provided as Attachment 2-A.
Where Does a Visual Assessment Take
Place?
* Appropriate areas for the visual assessment
include both interior and exterior places. The
evaluation may be limited to areas where work
has occurred or it may include the entire
dwelling unit and exterior. (This will be
discussed in more detail in Module 5.)
* Look at horizontal surfaces such as floors,
window sills (the horizontal piece at the base of
a window opening), and troughs (the area of the
sill between a window stool or interior sill and
the frame of the storm window or screen where
the bottom sash rests when closed [also called
a window well or exterior sill]). These items are
diagramed on Slide #5. Note that in the first
picture, the sill is labeled C and the trough is
labeled A. In the second picture, the trough is
defined by the storm window and is labeled A +
B.
• Also look at exterior surfaces, such as bare soil
areas and exterior troughs.
ust and Paint Chips/Debris
Dust
•dust you can see
Paint chips
•little pieces of paint
Painted debris
•paint on wood, plaster, or building
pieces
What Do Visible Dust, Paint Chips, and
Paint Debris Look Like?
• Visible dust is dust that you can see.
« Paint chips are little pieces of paint or paint on
wood or plaster. Chips can be as small as your
fingernail or as large as your hand. Look for
paint chips on floors, windows and soil close to
the work area (if the technician knows where
the work took place).
* Painted debris can be pieces of wood, plaster
or building pieces covered with paint that are
left in the room or on the soil near where the
work was done.
2-2
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Module 2: Visual Assessment
hy Look for Deteriorated Paint?
Deteriorated paint creates dust
If the deteriorated paint is lead-
based paint, it can cause lead
poisoning
What Does Deteriorated Paint Look Like?
First, answer the question "why are we looking for
deteriorated paint? The answer is that deteriorated
paint creates dust, which if lead-based paint, can
cause lead poisoning. If you want to address lead-
contaminated dust in a housing unit, you need to
address its sources and one of them is deteriorated
lead-based paint. Since we don't always know if
paint is lead-based paint or not, we treat all
deteriorated paint as a potential source of exposure
to lead. (See Handout 1 in Appendix B.)
Activity- Pictures teli the story. Show slides of
different types of deteriorated paint. Ask students to
tell you whether they would consider the paint
shown as deteriorated and what they think caused
the problem. This activity should take
approximately 5-10 minutes.
The photographs include:
1. Peeling paint - paint can peel due to poor
surface preparation, moisture, or wear and tear
due to the weather.
2. Peeling paint - separating from the substrate.
This is due to poor surface preparation.
3. Chipping paint - this can be the result of
impact ot the surface, moisture or poor surface
preparation.
4. Chalking paint - Some paint is designed to
chalk so that there is always a fresh surface. It
is hard to see on the picture but it looks like fine
dust on the surface.
5. Cracking paint - Cracks caused by moisture or
. vibration will continue to deteriorate so they
need to be fixed (by addressing the cause).
Note - settlement cracks do not deteriorate
further and are less of a concern.
6. More cracking paint - this is obviously
deteriorated.
7. Holes in the wall - this deterioration is the result
of an impact. Note: Nail holes do not constitute
deterioration.
8. Moisture damage — moisture in this case
caused bubbling.
9. Friction damage - friction caused this damage
to the window.
2-3
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Lead Sampling Technician Course
Jteriorated Paint
Any paint that is not intact
•Chipping
• Peeling
•Chalking
•Cracking
• Holes, moisture and friction damage
Smalt amounts count!
Deteriorated paint is any paint that is not intact.
It does not have to be peeling paint.
As seen in the previous photographs,
deteriorated paint can include:
5- Chipped paint on door and window trim
*• Peeling and flaking paint on walls and
window sashes
*• Paint with little bubbles that look like blisters
>- Paint with lines and cracks that make it easy
to peel the paint away
>- Paint that is chalking creating chalk-like dust
>• Note: Hairline cracks and nail holes are not
considered deteriorated paint
Reference Materials. See Handout 1 in
Appendix B for more detail on deteriorated paint
and the conditions that cause it. This handout can
be useful when explaining to clients why they
should fix the deteriorated paint. Also, give clients
Handout 3 which describes how to fix the
deteriorated paint safely.
Record Results
Be
precise about locations
Write down results as you go
Write down other information
Use a form
How to Record the Results of a Visual
Assessment
* Be precise about locations where visible dust,
paint chips, painted debris, and deteriorated
paint were found.
* Write down results as you go along.
4 Write down other information the client provides
about the surface in question. For example, the
client may tell you that a surface has been
tested and found not to be lead-based paint.
• See Attachment 2-B for a sample, completed
visual assessment form.
Reference Materials. Refer students to
Attachment 2-B. Review the sample, completed
form with participants. Highlight the specificity of
locations recorded.
2-4
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Module 2: Visual Assessment
summary: Now You Can
i List the items that should be
identified in a visual assessment
i Identify visible dust, paint
chips/debris, deteriorated paint
Record results on a visual
assessment form
Ml*Ink- ;- VlMUJ
Summary of Module 2
In this module, you learned the steps a lead
sampling technician must take to perform a visual
assessment.
Students should now be able to:
» List the items that should be identified in a
visual assessment.
• Identify visible dust, paint chips, painted debris,
and deteriorated paint.
* Record the results of the visual assessment on
a visual assessment form.
Additional information for the trainer Students
may ask about the implications of the visual
assessment. A common question is "what if I
document debris or deteriorated paint but the client
wants me to take dust samples anyway?"
The answer depends on the purpose of the
examination. We will talk about this more in
Module 5 (Putting It All Together). The short
answer is:
- For HUD-required clearance it is required that a
unit pass a visual assessment before samples
can be taken.
- In all other cases, it is recommended that a unit
pass a visual but it is not required. However, it
is unlikely that a unit that cannot pass a visual
assessment can pass the dust wipe sampling.
Provide the client information on the conditions
that cause lead poisoning (See Handout 1 in
- Appendix B) to help them understand why they
should correct these conditions.
Student Materials for Module 2
• Copies of trainer slides
• Attachment 2-A: Model Visual Assessment
Form
• Attachment 2-B: Model of Completed Visual
Assessment Form
2-5
-------
Attachment 2-A: Model of Visual Assessment Form
VISUAL ASSESSMENT FORM
Date:
Address:
Client:
Technician:
Location
Entry Area
Living Room
Dining Room
Kitchen
Common Area
Bedroom #1
Bedroom #2
Bath #1
Exterior
Other:
Other:
Identify visible areas of dust, paint chips, painted debris, and
deteriorated paint. (Note location: walls, ceiling, floors, doors,
windows, trim, cabinets, etc.)
-
-------
Attachment 2-B: Model of Completed Visual Assessment Form
VISUAL ASSESSMENT FORM
Date of clearance:
Clearance Technician:
Client:
Property address:
8/5/99
JoeSmA
SafyJanes
78Ea£tMa±iSt,ApLA
Hanmcrd, W 89898
Location
Entry Area
Living Room
Dining Room
Kitchen
Common Area
_
Bedroom #1
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Bedroom #2
(Backcffhehzs^
Bath #1
Exterior
Identify visible areas of dust, paint chips, painted debris, and
deteriorated paint. (Note location: walls, ceiling, floors, doors,
windows, trim, cabinets, etc.}
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Lead Sampling Technician Course
Peeling Paint
Separating from Substrate
Chipping Paint
Chalking Paint
Cracking Paint
More Cracking Paint
Module 2: Visual Assessment
-------
Lead Sampling Technician Course
Holes in the Wall
Moisture Damage
Friction Damage
Module 2: Visual Assessment
-------
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Module 3: Dust Wipe Sampling
bjectives
Demonstrate how to take a dust
wipe sample
Identify 3 surfaces where dust
wipes are collected
Define single-surface and
composite sampling
•verview of Module 3
Part 1: Background
Part 2: How to Collect Samples
Part 3: Composite Samples
urpose of Dust Wipe Sampling
Determine if lead levels exceed
guidelines or standards
Demonstrate contractor has
removed hazardous levels of lead-
contaminated dust
Module 3: Dust Wipe Sampling (90
minutes)
This module will describe how to prepare for and
take dust wipe samples. Students will also practice
taking samples.
Objectives
By the end of this module, students will be able to:
* Demonstrate the correct way to collect a dust
wipe sample.
» Identify three surfaces where dust wipes can be
collected.
* Define single-surface and composite sampling
and describe their benefits and limitations.
Overview of Module 3
• Part 1: Background. Why do we collect
samples and what do they mean?
• Part 2: How to collect samples. We will
explain the techniques and steps involved in
collecting dust wipe samples. We will also
discuss common mistakes and how to avoid
them.
• Part 3: Composite samples. We will explain
what composite samples are and how they
differ from single samples.
Part I: Background
Purpose of Dust Wipe Sampling
The purpose of dust wipe sampling is to:
• Determine the levels of lead in household dust
in order to compare the levels to the Federal
and/or State guidance levels and standards for
lead.
* Demonstrate that the contractor has thoroughly
cleaned the work site to remove hazardous
levels of lead-contaminated dust.
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j-gad Sampling Technician Course
y Collect Samples
Tiny bits of lead can contaminate
You cannot tell by looking at dust
if it contains lead
Even experienced contractors fail
dust wipe tests
Why Collect Samples
Discussion. Ask participants why they think it is
important to measure accurately the level of lead in
dust inside homes instead of simply looking to see
if dust is present. Then review the following points.
» It is often difficult to see tiny specs of dust.
• It takes very little lead to contaminate a room,
making it difficult to see if the room has enough
dust to be contaminated.
* Not all dust contains lead. You cannot tell by
looking if dust is contaminated with lead. A
laboratory test is needed.
* Even experienced contractors can fail dust wipe
testing because you cannot always see the lead
dust. Research on several thousand homes
where lead hazard control work occurred
demonstrated that contractors fail dust wipe
testing in about one-third of the dwelling units
where they work.1
Example. Review this example with the students.
Hold up a package of sweetener to illustrate.
It only takes a little lead to contaminate a room.
For example, imagine each granule of sweetener in
a sweetener package represents a tiny piece of
lead. If only two of these "lead" granules were
placed in a one square-foot area of floor, enough
lead would be present to exceed the EPA guidance
for lead-contaminated dust. An individual granule
is very small and would be nearly impossible to find
by simply looking at an area, especially if the
granule was ground-up into smaller particles and
spread throughout the area.
1 HUD. Evaluation of the HUD Lead-Based Paint
Hazard Control Grant program: Fifth Interim Report.
1998.
3-2
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Module 3: Dust Wipe Sampling
at a Dust Wipe Measures
Total amount of lead in an area
•Federal guidelines and standards use
this type of measurement
Lead present at the moment
• Lead levels can change
• Does not tell you about past or
future levels
Additional information for the trainer. If students
ask for an explanation of the above description,
consider the following:
* A gram can be broken down into one million
smaller particles called micrograms (ug) that
would be too small to see, so imagine that one
gram contains 10,000 particles each weighing
100 ng. Assuming the packet of sweetener
weighs one gram and contains approximately
10,000 granules of sweetener, each granule
would weigh approximately 100 jig.
* Assuming each granule of sweetener
represents one particle of lead-contaminated
dust. If each particle contains 50% lead (a
reasonable estimate for a granule from lead-
based paint in an older home), then each
particle would contain 50 u,g of lead (50% of
100
* If two of these lead-contaminated particles were
spread across a one square-foot (ft2) area, the
amount of lead-contaminated dust would equal
the current EPA clearance guidance for floor
dust. (The current EPA clearance guidance for
floor dust is 1 00 ^tg/ft2. This may be reduced).
What a Dust Wipe Measures
• A wipe measures the total amount of lead in a
specific area. This measurement is called lead
"loading." Lead loading is a good indicator of
the amount of lead to which a child is exposed.
* It measures lead-contaminated dust at a
- particular point in time.
>- Lead levels can change depending upon the
activity in the house.
3- The measurement tells you how much lead
exists when the sample was collected; it
does not tell you about past or likely future
lead levels.
** You may need to explain this to clients if
dust wipe sampling shows no lead-
contaminated dust.
3-3
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Lead Sampling Technician Course
lere to Coilect Dust Samples
i Floors- all jobs
! Interior window sills & troughs
•Interior sill if work was done on
windows
•Interior sill or trough for Federally-
assisted housing
See Module 5 for more detail
Mwluk V Dull Wipe Sampling
Discussion. Ask participants to describe reasons
why the level of lead in the dust may change over
time. Possible answers are: future work that
disturbs paint, track-in of lead dust from outside,
paint begins to peel or flake due to moisture
problems creating lead dust; and windows coated
with lead-based paint produce paint chips and dust.
On What Surfaces Do We Take Dust Wipes?
Certain places best represent the lead levels in a
unit and are good predictors of potential lead
poisoning risks in children. These places are:
» Floors - including carpeted areas
* Interior window sills - A trim piece that extends
from the bottom of the window frame and acts
as a narrow shelf
* Window troughs - the area between the interior
window sill and the frame of the storm window
where the bottom sash rests when closed (also
called a window well)
Finding interior window sills and troughs. You
need to know the difference between an interior
window sill and a window trough. (More detail will
be provided on sampling locations in Module 5.)
Additional information for the trainer. Some
contractors may refer to interior window sills as
window stools. However, the terminology "interior
window sill" is used in this training to ensure the
surface is easily recognizable by all individuals and
to limit the amount of industry jargon. (See Module
2 for a diagram of a window.)
Discussion. Ask participants to explain why
samples are collected on floors, interior window
sills, and window troughs.
These areas are the key areas to sample because:
4 Dust from renovation and repainting jobs tend
to fall and collect there.
* Children play in these areas.
3-4
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Module 3: Dust Wipe Sampling
Studies have shown that dust samples taken in
these areas are good predictors of lead
poisoning in children.
Wipe Sampling Materials and Supplies
ipe Sampling Materials
Disposable wipes
Gloves
Centrifuge tubes or equivalent
Templates
Masking or painters tape
Measuring tape
Sample collection forms
Markers, trash bags, labels, pens
Discussion. Ask students to list the supplies they
think they will need to collect a dust wipe sample.
Then refer them to the Field Guide for a full list.
Key supplies are listed below. The lab will often
provide most of these materials.
Demonstration. Show photograph #1 illustrating
all the supplies needed to conduct dust sampling.
• Disposable wipes. Use individually packaged
wipes or bulk packed baby wipes. Make sure
the wipes are thin and do not use any wipes
that contain aloe or lanolin. (Laboratories often
provide them.)
• Gloves. They should be disposable, non-
sterilized, and non-powdered. (Laboratories
often provide them.)
• Centrifuge tubes or other hard plastic, non-
glass container. They should be non-
sterilized, plastic tubes equipped with a
scalable lid.
* Templates. Floor templates should have a 12
inches by 12 inches opening (1 square foot)
and be made of a durable and reusable
material, such as plastic or metal. Templates
for interior window sills and window troughs can
. be purchased in various dimensions.
• Tape. Painters or masking tape work well.
Tape is used to both secure templates while
taking dust samples and to outline sample
areas when templates are not available.
• Measuring tape. To measure sampling areas
if templates are not available.
• Sample collection forms. Laboratories will
generally provide their own forms.
• Labeling and clean-up supplies. Permanent
markers, trash bags, labels.
3-5
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j.ead Sampling Technician Course
ingle-Surface Dust Wipes
One wipe from I surface
Measures total lead in sample area
Wait 1 hour after work is done
before collecting sample
ow to Collect Samples
tep 1: Lay out the sample area
tep 2: Prepare the tubes
tep 3: Put on clean gloves
tep 4: Wipe sample area
tep 5: Measure the sample area
tep 6: Clean-up
• Ink pen. A pen should be used to complete the
sample collection form and write down notes.
Additional information for the trainer. Trainers
may want to stress to the students that most of
these supplies should be made available by labs.
To research labs that provide supplies, trainers
may consult the National Center for Lead-Safe
Housing's web site at www.leadsafehousina.org.
Single-Surface Dust Wipe Samples
• Single surface dust wipe samples contain one
wipe.
* They measure lead dust from a specific surface
such as a floor or an interior window sill.
* They measure the total lead in the surface area.
* They do not tell you about dust lead levels in
other places on the same surface. Dust lead
levels can vary substantially.
Wait a minimum of one hour after work that creates
dust or after the final cleanup is completed before
collecting dust wipe samples. This allows the dust
to fall out of the air and land on the floor and other
surfaces.
Part 2: How to Collect Samples
Explain to the students that this slide presents an
overview of the dust sample collection process.
The process has six key steps. Each step is
introduced here. More detail is provided on each
step later in this module.
You may choose to demonstrate the proper
techniques for collecting lead dust samples as you
go over each step. Demonstration boxes
highlighting these activities have been included
throughout Part 2. Alternatively, you may choose
to demonstrate the proper techniques at the end of
the section.
A series of photos illustrating the various steps
taken when collecting dust samples are included in
the trainer materials. Show these photographs as
you go over the different dust sampling steps.
3-6
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Module 3: Dust Wipe Sampling
Step 1: Lay out the sample area. Carefully
outline the area you will sample using a template or
tape. (Show photograph #2 of the template taped
on the floor and photograph #3 of technician taping
the window sill.)
Step 2: Prepare the tubes. Label the tube and
place partially opened tubes near the spot you will
sample. (Show photograph #4 of tube being
labeled.)
Step 3: Put on clean gloves. Put on clean gloves
before collecting each sample. This helps minimize
contamination.
Step 4: Wipe sample area. Wipe the area you
measured with a moist towelette or baby wipe.
(Show photograph #5 of a hand wiping the sill with
a dust wipe. Then show photograph #6 and ask
participants what is wrong. Answer: The wipe is
hanging over the edge of this sill. It must be folded
first to make it smaller.)
>• Wipe the entire area you have measured for
the sample.
*• Fold the wipe up and place it in a nearby
centrifuge tube.
Step 5: Measure the sample area. Measure the
area sampled and record it on the sample collection
form. (Show photograph #7 of the sill being
measured and photograph #8 of completing the
form.)
Step 6: Clean up. Sampling materials must be
cleaned or removed from the site because they
may be contaminated.
- >• Clean the template with a wipe and place in
a clean plastic bag. This decontaminates
the template between uses and helps avoid
contamination when it is not being used.
Throw wipe away in trash bag.
5- Remove gloves and tape. Throw them
away in plastic bag.
»• Be sure you have recorded the location of
the sample area before removing tape.
Reference Materials. Point out that students have
this list of steps in the Field Guide.
3-7
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_Lead Sampling Technician Course
tep 1: Lay Out Sample Area
Use a template
•Durable material
• Floor is generally 12 in. by 12 in.
•Dimensions of interior window sill
and trough templates vary in size
tep l:cont'd.
Tape template to surface
If no template, outline with tape
•Area must be at least 16 square
inches (2 in. by 8 in.)
• Measure exact area after sample is
taken.
Do NOT touch area inside template
Step 1: Lay Out the Sample Area - Using a
Template
Distribute floor and interior window sill templates
and tape measures to the students. These tools
are critical for careful measurement of the dust
sample locations.
Demonstration. Demonstrate the proper
technique for laying out the sample using a
template.
The following describes how to lay out the sample
area for floors and interior window sills. Templates
are not available for window troughs.
» Whenever possible, use a template to avoid
measurement errors on floors and interior
window sills. Using a tape measure can be less
precise. If a template is not available, use a
tape measure and be precise in measuring the
area.
* The templates used for floors and windows will
vary in their dimensions:
>- The floor template should have a 12-inch by
12-inch opening. This opening is 144
square inches or 1 square foot (12 inches is
equivalent to 1 foot). A square foot is the
basic measurement used by EPA and HUD
in lead dust clearance guidance and
standards. (Ask students to measure the
opening of the template. This gives them
practice measuring and demonstrates that
the template is one square foot.)
» The interior window sill or window trough
template should have an opening of at least
16 inches. (This guidance comes from the
HUD guidelines.) Interior sills can vary in
width. Along the short side of the template
are dash marks indicating other distances
and their respective conversion factors.
Match up the end of the interior sill to one of
these dash marks. The area included in the
template is equal to the square inch
calculation next to this mark.
* Tape the template to the appropriate surface
(floor, interior sill, or interior trough) using
masking or painters tape. Be careful to avoid
placing your hands in the sample area as this
3-8
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Module 3: Dust Wipe Sampling
will remove or add lead-contaminated dust and
give you a misleading result.
Special Considerations if a Template is Not
Available
* If you are sampling a window sill or trough
where the template does not fit, forget the
template, or do not have a template, you may
use tape to outline the sample area. Masking
or painters tape work well. Do not re-use this
tape because it may contain lead dust on it.
Demonstration. Demonstrate the technique for
laying out a sample area when a template is not
available. Be careful to avoid placing your hands or
tape measure inside the sample area.
* For floors, pre-measure four 12-inch strips of
masking or painters tape. Lay them out in a
square.
* For interior window sills and troughs:
>- Always take the dust sample on the interior
window sill before taking a sample of a
window trough. Alternatively, you can
sample the interior window sill and window
trough areas of different windows.
*• Use a tape measure along the edge of the
interior sill or trough to measure its length.
The wipe area must be at least 16 square
inches (2 inches by 8 inches) to provide
enough surface area to produce an
accurate lead loading.
=- Lay out the sample area and take the dust
wipe. The ideal sample area is the entire
width of the interior sill or trough and the
length between the two strips of tape on
either end of the interior sill or trough. It is
not necessary to tape the length of the
interior sill or trough if you plan to sample
the entire length.
» Do NOT touch or otherwise disturb the area
inside the measured sample area. This will
remove or add lead-contaminated dust and give
you a misleading result. (You will measure the
exact area of the sample area after collecting
the dust sample).
3-9
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Lead Sampling Technician Course
tep 2: Prepare the Tubes
Use clean tubes
Label tube with ID number
Record ID number on sample
collection form
Place tube near sample area
Partially unscrew tube cap
Step 2: Prepare the Tubes
Tubes must be prepared so that they are properly
labeled and are accessible to you when you are
ready to put your sample in.
Demonstration. Demonstrate the proper
technique for preparing the tubes.
• Make sure the tubes are clean.
• Label each tube with a unique identification
number.
* Record the identification number on the sample
collection form.
• Place the tube near the area you plan to
sample. This avoids possible contamination of
the wipe and loss of sampled dust between the
time you collect the sample and place it in the
tube.
* Partially unscrew the cap on the tube to be sure
you can open it easily.
• Do not use plastic bags to transport or
temporarily hold wipes. Dust can fall into the
bag and not be measured by the lab.
3: Put on Clean Gloves
Use disposable gloves
Use new gloves for each sample
Do NOT touch anything besides
the wipe after putting on the gloves
Step 3: Put on Clean Gloves
Wearing clean gloves avoids transferring lead dust
from your hands to the wipe.
• Use disposable gloves.
» Use new gloves for each sample collected.
* Do not put on the gloves until you are ready to
take the sample. You can contaminate the
gloves if you touch other surfaces, such as
when measuring the sample area.
• Do not touch anything other than the wipe after
putting on the gloves. If you do, put on new
gloves. This will avoid sample contamination.
Step 4: Wipe the Sample Area
Reference Materials. Trainers should demonstrate
this process while describing it. Refer students to
the Field Guide for a full description.
3-10
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Module 3: Dust Wipe Sampling
tep 4: Wipe the Sample Area
See Field Guide, step 4
Same for carpet or bare floor.
Vtrekb '• UtM ftiiv
Demonstration. Demonstrate the proper
technique for wiping the sample area on both floors
and carpeted areas. Stress the proper wipe
handling technique, wiping motion, and pressure.
Floors and Carpeted Areas
• Remove the wipe from its individual package or
container. Check that the material is moist.
Throw the wipe away if it is not moist. A moist
wipe makes it easier to collect dust. If you use
wipes packaged in a multi-wipe container,
discard the first wipe you pull out to avoid
contamination and to help ensure that the first
wipe is moist.
* Hold the wipe between your thumb and the rest
of your hand.
* Do not touch other objects. They can
contaminate the wipe.
* Press the wipe down firmly at an upper corner
of the sample area.
s- Press down with your fingers flat on the
floor.
>• Do not use the heel of your hand.
> Keep your thumb from slipping off the wipe.
» Make as many "S" like motions as needed to
wipe the entire sample area, moving from side
to side. Do not cross the outer border of the
tape or template.
* Apply constant pressure when wiping to remove
all the dust you can see.
* Fold the wipe in half, keeping the dirty side in.
This helps to prevent the loss of any collected
dust.
* Using the folded wipe, repeat "S" motions,
starting from an upper corner and moving from
top to bottom. Do not cross the outer border of
the tape or template.
* Fold the wipe again, keeping all the dust in the
wipe.
* Place the folded wipe in the centrifuge tube.
Avoid contact with other surfaces. Wipes
3-11
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Lead Sampling Technician Course
should be stored only in their original container
or in the tube. Do not use plastic bags or other
items to hold wipes.
Note: This technique applies to bare floors and
carpets. While it is preferable to sample bare
floors, in some cases, the only surface available
is carpeted.
tep 4: cont'd.
Sampling interior sills and troughs
•Use side-to-side "S" motions
• Do not touch other parts of the
window
•Measure length and width of
samples after wipe is done
Special Considerations for Interior Window
Sills and Troughs
* Use two passes of "S" motions from side-to-
side instead of up and down. This approach is
best because it is often difficult to wipe up and
down in a smalt area.
* Avoid touching other parts of the window that
may contaminate the wipe. You may need to
fold the wipe in half so it is small enough.
3- Do not touch the sash or trim.
»• When sampling the interior sill, avoid the
trough, by keeping the window closed.
*• If sampling the trough, avoid the interior sill.
Reference Materials. Refer students to
Attachment 3-A that provides a model sample
collection form and Attachment 3-B that provides
an example of a completed model sample
collection form.
>tep 5: Measure the Sample Area
Measure width and length (unless
template was used)
•Length of sill or trough between
tape
•Tape across width of sill or trough
Measure to 1/8 inch
Record measurement on lab form
Step 5: Measure the Sample Area
If.a template was used, record the dimensions of
the template on the lab collection form. If a
template was not used, you must measure the
sample area.
Demonstration. Demonstrate the proper
technique for measuring the sample area if a
template was not used. Stress the importance of
measuring the area after the dust wipe sample has
been taken to minimize the possibility of
contamination.
• Measure the exact length and width of the
sample area with a tape measure after the dust
3-12
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Module 3: Dust Wipe Sampling
sample has been taken. This allows you to get
an accurate measurement without
contaminating the sample area.
• Make sure you measure the area inside the
tape, not the outside border.
» Always measure to an eighth of an inch {1/8").
Sloppy measurement can produce misleading
results.
* Record the appropriate area outlined by the
tape on the form provided by the laboratory.
Demonstration. Point out the Model Sample
Collection Form in Attachment 3-A and the Model
Completed Sample Collection Form in Attachment
3-B
Go over the forms with the students, describing the
purpose and the type of information included in
each column. Point out that some conversions may
need to be performed to fill out the form - e.g.
inches must be converted to feet.
Additionally, to facilitate these calculations,
students should convert the dimensions of the
sample to from fractions to decimals (e.g., Yz to
0.5). Refer students to the Worksheet for
Performing Mathematical Calculations in
Attachment 3-C for help.
Additional information for the trainer. If
necessary, show students how to measure area for
collecting dust samples without using a template.
Be sure each student has a tape measure or ruler.
Have each student familiarize him or herself with
the tool. Ask each student to locate 2 inches, 2 and
>2 inches, 2 and V* inches and 2 and 1/a inches.
Use the slide with the rufe markings to assist you in
this exercise.
Possible exercise: Distribute a rectangular piece of
paper that was previously measured to be 2 inches
by 17 and V* inches. Ask students to measure the
rectangle and record the measurements. This will
help the instructor determine if any students have
difficulty reading a tape measure and show
students the minimum area necessary to sample
for interior window sills and troughs.
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Lead Sampling Technician Course
tep 6: Clean Up
Clean template with wipe, place in
plastic bag
Remove materials from site:
•Gloves, tape from floors & windows
•Put items in trash bag
•NOT in client's containers
Step 6: Clean Up
Sampling materials may be contaminated and
therefore must be cleaned or removed from the
site.
* Clean the template with a wipe and place in a
clean plastic bag. This decontaminates the
template between uses and helps avoid
contamination when it is not being used. Throw
wipe away in trash bag (unless the template is
disposable).
» Be sure you have recorded the location of the
sample area before removing tape.
* Remove gloves and tape. Throw them away in
trash bag.
Reference Materials. Refer students to Field
Guide, which summarizes all the steps just
described and the Dust Wipe Practicum Checklist
in Attachment 3-D.
Activity: Taking a Dust Wipe. This activity is
estimated to take 30 minutes - 20-25 minutes of
group time followed by 5-10 minutes of discussion.
Alert students when 10 and 5 minutes of the activity
time remain.
Note: To be effective, at most, a 10 to 1 student to
teacher ratio is recommended. The instructor may
want to bring in additional qualified instructors to
oversee this activity.
• Distribute sampling materials (dust wipes,
- tubes, gloves, tape, ruler, etc.) and a blank
sample collection form to the students.
• Divide students into groups of three or four
individuals, depending on class size.
• Using the templates and dust sampling
materials, have each student practice dust wipe
sampling techniques and complete the blank
sample collection form. Have students refer to
the Dust Wipe Practicum Checklist in
Attachment 3-D for assistance.
• Encourage students to take samples on a
variety of surfaces - window sills, troughs, and
both carpeted and uncarpeted floors.
3-14
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Module 3: Dust Wipe Sampling
Common Mistakes
Measurement error
Contaminated wipe
i Contaminated gloves
i Contaminated sample area
Sloppy recording
Go to each of the groups and review the
student's sampling, measuring, and recording
techniques. Correct any errors and answer any
questions students may have.
Have students briefly discuss any problems
they encountered and ask any relevant
questions.
Common Mistakes
Discussion. Ask students to tell you the mistakes
they make while sampling. Then review the items
listed below.
The following are common mistakes when
sampling.
Measurement error. Small mistakes in reading
the tape measure can produce misleading results.
Being off by a V4 of an inch can make the difference
between passing or failing clearance.
Example. Give the students an example. Write
the following on a flipchart or transparency as you
explain it.
NOTE: You have not yet taught the students how to
do the math or what the EPA clearance guidance
and HUD standards are. Do not go into detail on
these. Simply walk through the steps below without
spending time on the math or guidance levels I
standards.
You record the interior sill sample area as 3 inches
by 24 inches. That's 72 square inches (in2).
But suppose the sample area was really 3 1/8
inches by 24 inches. That gives you 75 in2. This is
significantly more than 72 in2 and will affect the
results.
Additional information for the trainer. If students
question the impact of the mistake, here is
additional information.
Imagine the lab analyzes this sample and tells you
it has 255 micrograms (u,g) of lead.
• 255 ng over 72 in2 translates to 510 jig/ft2.
• 255 u.g over 75 in2 translates to 490 u,g/ft2.
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Lead Sampling Technician Course
This is a big difference, especially since the EPA
clearance guidance for interior window sills is 500
ng/ft2. In the first case, you passed the clearance
test and in the second you failed. (We will talk
more about the EPA guidance levels and HUD
standards in later modules.)
The point is a small error in measurement can
produce an incorrect clearance result.
Wipe is contaminated. It is important that the
wipe is clean before you collect the sample and that
you do not lose any dust before putting the wipe in
the tube.
Discussion. Ask students to describe situations
when a wipe may be contaminated and how to
avoid these problems. Review the examples below
with the students.
» Wipe touches the floor or window before you
place it in the tube.
* Wipe falls to the floor before you begin wiping
and you do not get a new one.
* Wiping motions go beyond the template outline
or taped area collecting added dust or debris.
* Wipe is placed on the floor or interior siil while
unscrewing the tube cap, collecting dust.
Gloves are contaminated. The gloves can
contaminate the sample if they are not clean.
Discussion. Ask the students to describe common
problems with glove contamination and review the
below examples with them.
* Gloves are put on too early and you touch dust
on other surfaces.
* Gloves are not changed for each sample.
Previously used gloves carry lead-contaminated
dust from the previous sample.
Sample area is disturbed. Contamination may
remove or add lead dust to sample area before you
wipe the area.
Discussion. Ask students to list possible errors
and review the following with them.
3-16
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Module 3: Dust Wipe Sampling
* Place hand or tape measure inside measured
area before you wipe it.
* Place hand inside sample area while taping
down template to the floor.
• Slide template across sample area as you tape
it down.
4 Use template that has not been cleaned.
Sample area is recorded incorrectly. To avoid
errors:
* Record measurements for interior sills and
troughs immediately after measuring the area.
* Review forms before you submit them to double
check measurements.
Part 3: Composite Samples
'verview of Composite Dust Wipes
Measures average lead on a surface
Use separate composite samples
for each dwelling unit
Sample holds up to 4 dust wipes
• Do not use more than 4 wipes
•Do not mix samples from different
types of surfaces
ules for Composite Samples
Collect samples in rooms where
work occurred
Sample no more than 4 rooms
•Select rooms where children are likely to be
•Living room or playroom
•Youngest child's bedroom (smallest)
•Kitchen
Overview of Composite Dust Wipes
A composite is a sample that holds up to four dust
wipes in one container. Each wipe is called a sub-
sample.
A composite tells you the average level of lead
contaminated dust across all the areas you
sampled. This provides a measure of average
exposure. Sub-samples need to be collected from
equal areas for the results to be an average.
In contrast to single wipe samples, composite
samples do not define the location of lead-
contaminated dust, if it exists. Rather, they simply
identify that lead dust exists somewhere in the
building or property.
Composite samples may be used during lead
sampling.
Rules for Collecting Composite Samples
Because composite samples tell you the average
level of lead across a number of areas, you must
follow some specific rules to ensure the accuracy of
the sub-samples.
» Each composite can only include sub-samples
from one type of location - floor, interior window
sill, or window trough. Do not mix samples from
floors with windows and do not mix samples
from interior sills with troughs.
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Lead Sampling Technician Course
.ules for Composite Samples
Check that the lab has experience
analyzing composite samples
Sample same area with each wipe
use templates where possible
•Floors - 12 inches by 12 inches
• Interior sills or troughs - use
smallest sil! or trough to set area
Make sure the area sampled for each of the
sub-samples is the same size. If you include
wipes that collected dust from areas with
varying sizes, you will not get an accurate
reading of the average exposure. This should
not be a problem if templates are used.
»• Floors. Use a 12 inch by 12 inch sample
area. Use a template or tape outline.
>• Interior window sills and window troughs.
Identify the smallest interior window sill
and/or trough you plan to sample. Measure
the length and width after you lay down the
template or tape and take the dust sample.
Use these measurements to outline the
same sample area for all of the other interior
sills and/or troughs. This will guarantee that
all the interior sills or troughs sampled are
the same size.
Do not combine sub-samples across units. A
composite sample can only include dust wipes
from a single dwelling unit.
Do not use more than four wipes in a composite
sample. It is difficult for labs to analyze
composites holding more than four wipes.
Check that your lab has experience analyzing
composite wipes. (In Module 4, we will talk
about selecting laboratories.)
Composite Sampling Procedures
Outline all areas to wipe for
composite before collecting sample
Follow single wipe sampling
procedures
Use new wipe for each sub sample
Not necessary to change gloves
between sub samples
Composite Sampling Procedures
* Whenever possible, use a template when
collecting composite samples. If a template is
not available, outline the areas you plan to wipe
before collecting the sub-samples. Remember
the sample size must be the same for all sub-
samples included in composite.
* Follow the single wipe sampling procedures.
»• You can use one set of gloves for all
subsamples in the composite. However, if
your glove touches an area outside the
sample area, put on a new one.
>• Use a separate wipe for each sub-sample
area wiped.
3-18
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Module 3: Dust Wipe Sampling
ummary: Now You Can
Identify 3 surfaces where dust
wipes can be collected
Demonstrate how to take a dust
wipe sample
Define single-surface and
composite sampling
5* After wiping each area, carefully place the
wipe into the tube.
Summary of Module 3
In this module, you learned why, where, and how to
collect dust wipe samples.
Discussion. Ask students if they can now do the
activity described in the objectives.
* Identify the three surfaces where dust wipes
can be collected.
» Demonstrate the correct way to collect a dust
wipe sample on floors, interior window sills, and
window troughs.
* Define single-surface and composite sampling.
Student Materials for Module 3
Student materials will include:
• Copies of trainer slides
• Attachment 3-A: Model Sample Collection
Form
* Attachment 3-B: Model of Completed Sample
Collection Form
• Attachment 3-C: Worksheet for Performing
Mathematical Conversions
• Attachment 3-D: Dust Wipe Practicum
Checklist
3-19
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Attachment 3-A: Model Sample Collection Form
Field Sampling Form for Dust
Name of Inspector:
Name of Property Owner:
Property Address:
Apt.#
Sample
Number
Room
(name of room used
by owner)
Surface
Type*
(circle one)
FL WS WT
FL WS WT
FL WS WT
FL WS WT
FL WS WT
FL WS WT
FL WS WT
FL WS WT
FL WS WT
FL WS WT
FL WS WT
Dimensions
of Sample
Area (in x in)
Area
(ft2)
Lab Results
«ft2)
* Surface types FL = Floor; WS = Window Silt; WT = Window Trough
Total number of samples on this page:
Date of Sample Collection: / /
Shipped by
Shipped by
Shipped by
Shipped by
Shipped by
Date Shipped to Lab: / /
Received by
Received by
Received by
Received by
Received by
Page of
-------
Attachment 3-B: Model of Completed Sample Collection Form
Field Sampling Form for Dust
Name of Clearance Technician:
Name of Property Owner:
Property Address: 78 EaEtMcDn SL,Hanmcnd, U 89898 AptJ 25_
Sample
Number
98-1
98-2
98-3
98^
98-5
98-6
Room
(name of room used by
owner)
Upstairs ]g. bateau
Upstairs Ig-bstaan
Upetaicssn .
bsJrcan
Upstanssm .
bEtroam
KirfHi
K itj±ei - abc^esink
Surface Type*
(circle one)
(7j) WS WT
Fl(^Wj)wT
VEE WS WT
FLVWJS' WT
(Tj). WS WT
Fl(w5> WT
FL WS WT
FL WS WT
FL WS WT
Dimensions of
Sample Area (in
x in)
12x12
24x25
12x12
24x3.0
12X12
24x225
Area
(ft2)
1JOO
0.42
1JQO
050
1JDO
038
Lab Results
(Jig/ft2)
* Surface types FL = Floor; WS = Window Sill; WT = Window Trough
Total number of samples on this page:
. 6
Date of Sample Collection: 8/05/L999
Date Shipped to Lab: 8/07/1999
Shipped by
Shipped by
Shipped by
Shipped by
Shipped by
Received by.
Received by.
Received by.
Received by.
Received by.
Page of
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3-C: Worksheet for Performing Mathematical Calculations From Fractions to Decimals
When recording the sample area on the dust wipe collection form, you may need to perform on*
or both of the following conversions: converting fractions to decimals and converting inches to
square feet. To facilitate the mathematical calculations, fractions should always be converted tt
decimals first. Refer to the following Table of Common Conversions for assistance.
1. Converting Fractions to Decimals: Table of Common Conversions
Fraction
1/8
2/8
3/8
4/8
5/8
6/8
7/8
Decimal
0.125
0.250
0.375
0.500
0.625
0.750
0.875
Fraction
1/4
2/4
3/4
Decimal
0.250
0.500
0.750
1/3
2/3
0.333
0.667
1/2
0.500
2. Converting inches to square feet (ft)
If the area you sampled was not a square foot, you will need to convert it to this dimension.
One foot equals 12 inches, and one square foot equals 144 square inches.
* Record the sample area in inches (in) as opposed to feet (ft).
4 Convert the sample area to square inches (in). Round the number to a maximum of three
decimal places.
* Divide the square inches by 144 to get square feet (fy. Round the number to a maximum
of three decimal places.
Dimensions of sample area in inches (in)
Multiply length times width to calculate et the
area in square inches (irf)
Divide the area in square inches (in") by 144 to
calculate the area in square feet (#).
Length = in
inx in
in2 -5- 144 =
Width:
irf
ff
in
3. Example: Convert an area with a length of 20 V* inches and a width of 5 % inches to
square feet.
* Convert fractions to decimals: 20 '/, in -> 20.500 in 5 V* in-» 5.250 in
» Calculate the area in square inches: 20.500 in x 5.250 in = 107.625 ir?
» Calculate the area in square feet: 107.625 in2 + 144 = 0.747 ff
-------
Attachment 3-D: Oust Wipe Practicum Checklist
The following checklist lists the steps involved in taking a dust wipe sample. When someone is
collecting dust samples, he/she should take each of these steps.
Step
1.
2.
3.
4.
5.
6.
7.
Criteria
Lay out sample area
• Tapes down template; or
• Lays out sample area using tape
Uses clean technique
• Puts gloves on after set-up
• Has adequate method for handling wipe
• Removes wipe and shakes open correctly
First swipe: side-to-side
• Presses down firmly - palms & finger
• S-like motions
• Pressure adequate
• Wipes entire surface
• Does not cross boundary tape
Second swipe: top-to-bottom
• Folds in half, wipes on clean side
• Does not shake out contents during folding
• S-like motion
• Wipes entire surface
• Does not cross boundary tape
Folds and inserts into tube
• Does not touch other objects
• Does not lose surface debris
Measures and records accurately
Completes form and labels tube
V
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Lead Sampling Technician Course
Dust Sampling Tools
Taping Template to Floor
Taping Window Sill
Labeling Sample Container
Wiping Sill
What's Wrong?
Module 3: Dust Wipe Sampling
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Lead Sampling Technician Course
Measuring Window Sill
Completing Dust Sampling Form
Module 3: Dust Wipe Sampling
-------
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Module 4: Laboratory Results
)bjectives
i Select an accredited lab
i Ensure lab results are accurate
i Maintain a "chain-of-custody"
i Evaluate lab results
electing a Laboratory
Submit samples to an accredited lab
recognized by EPA's:
•National Lead Laboratory
Accreditation Program (NLLAP)
Call National Lead Information Center
(NLIC) Clearinghouse for a listing:
• 1-800-424-LEAD
Module 4: Selecting a Laboratory and
Interpreting Results (45 minutes)
After performing dust wipe sampling, you will need
to submit the samples to a laboratory for analysis
and interpret the laboratory results to determine if
the unit sampled has lead-contaminated dust. This
module describes the steps you will need to take to
accomplish this goal.
Objectives
At the end of this module, students will be able to:
• Select a reliable, accredited laboratory and
explain why proper selection is important.
• Describe the steps they will take to ensure that
the laboratory results are accurate and that the
sampling media were not contaminated.
* List the important steps to ensure samples are
not tampered with or lost - "maintaining a
chain-of-custody."
• Evaluate the adequacy of laboratory results and
identify missing data or a need for more testing.
Selecting a Laboratory
All samples must be submitted to a laboratory
recognized by EPA's National Lead Laboratory
Accreditation Program (NLLAP).
«• The NLLAP provides the public with a list of
recommended laboratories for analyzing lead in
dust, soil, and paint samples. You can contact
the National Lead Information Center (NLIC)
Clearinghouse at 1-800-424-LEAD for an up-to-
date list of NLLAP-recognized laboratories.
The NLIC also distributes a technical bulletin
entitled: "Selecting a Laboratory for Lead
Analysis: The EPA NLLP," EPA 747-F-99-002,
April 1999.
» For a laboratory to become EPA-NLLAP
recognized it must participate in the
Environmental Lead Proficiency Analytical
Testing Program (ELPAT), and undergo a
quality system audit, including an on-site
assessment by a laboratory accreditation body
participating in the NLLAP.
4-1
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Lead Sampling Technician Course
uestions to Ask Laboratories
Recognized by NLLAP?
Sample detection limit?
Turnaround lime for analysis?
Cost per sample?
Sampling materials?
Supply spiked dust wipe samples?
Perform calculations?
Analyze composite samples?
Mthlk J Vkvtalq, • I «l*l»w«y JB.1 InKlpMll* Kt-oill.
It is important to recognize that not every
accredited laboratory will meet your needs. Taking
the time to select a good laboratory will save you
time and effort in the long run. Knowing the costs
associated with laboratory supplies and analysis
will also help you calculate the fees you will charge
customers. Even if your company has selected a
laboratory for you to work with, it is a good idea to
ask a few simple, straightforward questions so you
can find out if a laboratory meets some basic
quality criteria.
Discussion. Ask the students what types of
questions should be asked, making sure that the
following questions are discussed.
Reference Materials. After the discussion, refer
students to the Attachment 4-A for a list of
questions and appropriate laboratory responses.
Questions. Listed below are some questions you
should ask.
• Is the laboratory recognized by NLLAP? All
samples must be analyzed by an NLLAP
laboratory. You can contact the NLIC
Clearinghouse at 1-800-424-LEAD for an up-to-
date list of NLLAP-recognized laboratories.
Even after selecting a laboratory, you should
check the laboratory's accreditation every six
months.
• What is the detection limit of the
methodology used by the laboratory? The
detection limit is the minimum concentration of
an analyte that, in a given matrix and with a
specific method, has a 99% probability of being
. identified, qualitatively or quantitatively
measured, and reported to be greater than
zero. The detection limit of 10 u.g/ft2by any
means will guarantee accurate laboratory
results. It is important that the laboratory report
its results in either micrograms (ug) or
micrograms per square foot (ug/ft ).
• What is the turnaround time for sample
analysis? Because the occupants often
cannot occupy a unit until sampling and
analysis is complete, the laboratory turnaround
time is important. Labs usually provide results
within 1 to 3 days. A faster turn around time
allows you to be more responsive to your client
but may cost more money.
4-2
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Module 4: Laboratory Results
• What is the cost per sample? You should be
able to get your samples analyzed for $7 to $15
per sample. However, prices can vary
depending on how quickly you want the results
and the volume you send. A 6-hour turn around
will cost more than samples analyzed over a
few days. Remember to incorporate these
costs into your standard fee.
• Will the laboratory provide sampling
materials? Many laboratories will provide you
with all of the materials necessary to perform
sampling. Sampling materials will likely include
wipes, gloves, templates, tubes for submitting
the samples to the laboratory, necessary
sample collection forms, and overnight mailing
envelopes. You may want to select a
laboratory that provides these materials
because laboratory-supplied materials and
forms can help minimize potential errors in the
analysis and record keeping. Additionally, it
can save you time by not requiring you to find
and purchase all of the necessary supplies.
• Does the laboratory supply spiked samples?
In addition to the sampling materials, some
laboratories will supply you with spiked dust
wipe samples. Spikes are dust wipes that have
been measured by a laboratory with a known
weight of lead-based paint dust, measured to
the nearest 0.1 jig. They are used to ensure
adequate quality assurance of the process at
the laboratory. Although submitting spiked
samples is optional, they are useful in
determining if a laboratory reports back
accurate results. If you decide to submit spiked
samples, it is important that they are obtained
from the laboratory so the sampling materials
are consistent with the other wipes and to
ensure the laboratory can accurately digest the
wipe.
• Does the laboratory perform all the
necessary mathematical calculations?
The federal standards for lead-contaminated
dust are provided in particular units {e.g., ug/ft2,
ppm, ug/g). Depending on the size of the
sample or sample area, some mathematical
calculations may need to be performed to
convert to the appropriate units. Selecting a
laboratory that will perform this calculation for
4-3
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Lead Sampling Technician Course
you will save valuable time and reduce the
possibility of mathematical errors. Note: Even
if a laboratory performs this calculation, it is still
a good idea to spot check the math.
• Will the laboratory accept composite
samples? If you intend to take composite
samples, make sure that the laboratory is able
to analyze composite samples.
hain-of-Custody
Documents each person who
handles sample
Ensures samples are not lost or
tampered with
Included on sampling form
Your responsibility to maintain
Chain-of-Custody
It is important that samples are not tampered with
or lost before or during the analysis process. To
trace the path of the sample, you should establish a
"chain-of-custody." This simply means that every
person who handles the sample must sign and date
a form.
Discussion. Ask the trainees who they think would
need to sign a chain-of-custody form. Have them
list the people. Then review any of the people they
missed as listed below.
Who is in the chain-of-custody? The people in
the chain-of-custody may include the:
• Lead sampling technician
* Technician's supervisor
• Individual packing the samples for shipment
• Individual picking-up and shipping the samples
(maybe)
* Individual receiving the shipment at the
„ laboratory
* Technician performing the laboratory analyses
* Lab technician's supervisor
Maintaining the chain of custody. You are
responsible for ensuring that the chain-of-custody is
maintained from the time you take the samples until
you receive the sampling results from the
laboratory.
• Generally, space for documenting the chain-of-
custody is included as part of the sample
collection form. There should be enough space
for each individual handling the sample to sign
4-4
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Module 4: Laboratory Results
and date the form - 5 to 7 lines should be
sufficient.
Some laboratories maintain internal chain-of-
custody forms. You should have learned about
this when asking the laboratory about their
quality control procedures. If so, the laboratory
should provide you with a copy of the internal
chain-of-custody form in addition to your
completed form.
You should also keep a copy of any shipping or
mailing forms documenting when the samples
were sent to the laboratory.
uality Control: How?
Three steps:
•Accurately fill out the sample
collection form
•Submit blank dust wipe samples
•Submit spiked dust wipe
samples (recommended)
uality Control: Why?
Simple and cost effective
Essential to legally document
clearance test
Ensures accuracy of results,
sampling media, and sampling
techniques
Completing Collection Form
i Confirm all information is
recorded clearly and correctly
•Sample numbers
•Sample locations
•Sample dimensions
Vkvlllljl l I .iK'litlwy ln.1 jllknlvllli| Ktf.Lllh
Quality Control
Lead sampling and analysis requires a great deal of
care and precision by both you and the laboratory.
There are three steps you should take to help
control the quality of the lab results.
* Fill out the sample collection form completely
and accurately.
* Submit blank samples with dust wipe samples.
• Submit spiked samples with dust wipe samples
(recommended).
Why should you take these steps? These steps
are simple, cost effective ways to control quality.
To ensure your samples are as accurate as
possible, quality control activities should be
performed as part of each sampling inspection.
Performing these activities is essential to document
the accuracy of the laboratory, sampling media, or
your sampling techniques.
Completing the sample collection form. In
Module 3, we described how to clearly and
accurately record sample information on the
collection form. Before you send the samples to
the laboratory, you should check your sample
collection form to confirm that all of the following
information is recorded clearly and correctly.
• Sample numbers. Samples should be
numbered sequentially, in the order you took
them. (Except for spikes and blanks which are
discussed below.)
• Sample locations. These should be precise.
For example, "left window on back wall in
4-5
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Lead Sampling Technician Course
lank Samples
What? Unused wipes sent to the
lab
Why? Determine if sampling
media are contaminated
When? Submit one blank sample:
•For each unit tested
•From each wipe lot
master bedroom" is better than "bedroom
window".
• Sample dimensions for dust wipe samples.
As discussed in Module 3, these dimensions
are extremely important and should be
recorded to the nearest 1/8 of an inch.
After completing the form, it is essential that you
keep a copy for your records.
Blank Samples
Blank samples are new, unused wipes that are sent
to the laboratory to determine if the sampling media
are contaminated. Because you should prepare
blank samples on every job, it is a good idea to
factor the costs associated with these samples into
your fee.
Discussion. Ask students why wipes might be
contaminated. Answers include technician error,
laboratory error, or bad wipes.
Submitting blank samples is important to test the
accuracy of your sampling techniques, the
sampling media, and the laboratory's analysis.
Preparing blank samples. You should prepare
blank samples in the same manner as other dust
wipes.
* Prepare blank samples at the end of a job -
after collecting all of your dust wipe samples.
* Remove a new wipe from the container with a
new glove, shake the wipe open, and refold it
as you would if you were taking a dust sample.
* Insert the unused wipe into a sampling
container without touching any surfaces.
Labeling and submitting blank samples. Blank
samples should be labeled so you can identify them
but the lab cannot. Do not label blank samples as
"blank."
* Give the sample a fictitious number that looks
like your other sample numbers and provide a
fictitious sample location and measurements to
the lab.
* Keep notes in your records identifying blank
sample number.
4-6
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Module 4: Laboratory Results
piked Samples (Recommended)
What? Wipe containing a known
weight of lead-based paint dust
Why? Check laboratory's analytic
techniques
How?
•Submit every 10 jobs
• Submit one blank sample for each unit
sampled. Additionally, one blank should be
included from each wipe lot used to ensure that
the lots are not contaminated. The wipe lot
number is usually found on the bottom of the
wipe container.
Interpreting blank samples. If the laboratory
detects more than 10 jug/wipe, one of three errors
may have occurred:
* The dust wipes were contaminated before you
began using them;
* You contaminated the wipes during your
sampling; or
* The laboratory contaminated them during the
analysis.
If the blank sample is contaminated, then the data
should not be used and the unit in question should
be re-sampled.
Spiked Samples (Recommended)
Spiked samples are used to ensure adequate
quality control of the digestion process at the
laboratory. Submitting spiked samples is optional.
A spiked sample is a dust wipe sample that
contains a known weight of lead-based paint dust,
measured to the nearest 0.1 ng of lead dust. In
general, wipes should be spiked with between 25
ug and 1,000 jig of lead-contaminated dust.
Laboratories can usually prepare spiked wipes
upon request. You should have learned about this
when asking the laboratory about spiked samples.
Discussion. Ask students why they should submit
a spiked dust wipe to the laboratory if they already
know the amount of lead it contains. (Answer: to
see if the lab reports back accurate results.)
The spiked wipes are sent to the lab to see if they
report back accurate results.
Labeling and submitting spiked samples. You
should label spikes as any other sample so the
laboratory cannot identify them. However, it is
essential that you keep a record of which samples
are spikes. Do not label spiked samples as "spike."
• Give the sample a fictitious number that looks
like your other sample numbers and provide a
4-7
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Lead Sampling Technician Course
fictitious sample location and measurements to
the lab. It is a good idea to record the spiked
sample as a floor sample with a measurement
of 1 ft2 to facilitate future calculations.
* Keep notes in your records identifying the
spiked sample.
* Submit one spiked sample the first time you use
a laboratory followed by 1 spike for every 10
dwelling units tested.
If you plan on using spiked samples, you should
incorporate their cost into your fee, remembering
that one spike is submitted for every 10 dwelling
units tested.
Interpreting spiked samples. When you get the
results back from the laboratory, compare the
spiked sample results to their known lead
concentrations.
* For the laboratory results to be accurate, the
measured sample loading must fall within 80 to
1 20 percent of the true value.
* If the sample area was recorded as 1 ft2, you
can compare the spiked sample lead dust
loading directly to the laboratory result.
For example, if loading is 100u.g and the
sample area was recorded as 1 ft2, the
laboratory must report results between 80
and 120ng/ft2.
Reference Materials. Refer students to
Attachment 4-B, a worksheet for interpreting
spiked dust wipe samples.
* If this is not the case, immediately submit
another spike in your next shipment to the lab.
• If this second spike also fails the laboratory
results, all of the results must be considered
invalid. Before you consider finding a new
laboratory to perform the analyses, you should
discuss this with the laboratory who must take
corrective actions.
4-8
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Module 4: Laboratory Results
Evaluating Laboratory Results
i Step 1: Check for appropriate units
- Hg/ft2
Step 2: Do the math
Step 3: Compare results to Federal
guidance and standards for lead-
contaminated dust
r>km 4*1 lnt.-l|*utlRy Kvttlilt
Interpreting and Evaluating Laboratory
Results
When you receive the results from the laboratory,
you will need to interpret them to determine if lead-
contaminated dust is present. This section of the
module describes what constitutes lead-
contaminated dust and the process used to
evaluate the sample results.
Specifically, you will need to:
* Evaluate the laboratory results and convert
them, if necessary.
* Compare the results to the Federal or state
standards.
Reference Materials. As you talk through this
process, refer to Attachment 4-C, which provides a
model of laboratory results.
Evaluating Laboratory Results
To compare the laboratory results to Federal
standards for lead contaminated dust you may
need to take the following three steps:
1. Check that the laboratory results are reported in
appropriate units - ug/ft2
2. Do the Math.
=- If the laboratory gave results in the
appropriate units, check the laboratory's
math.
s- If necessary, convert the result to
appropriate units.
3. Compare the results to Federal guidance and
standards for lead contaminated dust. Note:
These standards are interim guidance. The
numbers may change.
Evaluating Dust Wipe Sampling Results
Here is how we implement the above steps for dust
wipe samples.
• Step 1: Checking the units. Laboratories
should always report the weight of lead found in
your sample in micrograms per square foot
(ng/ft2). Whenever you receive results from a
4-9
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Lead Sampling Technician Course
lab, make sure the results are provided as jig/ft2
and not \ig.
Discussion. Understanding the units. Ask the
students if they are familiar with the concepts of
micrograms and square feet. If not, write the
symbols on a flip chart and explain that:
* A microgram is a very small unit of weight.
There are one thousand micrograms in one
milligram. A penny weighs two grams. To get
a microgram you would have to cut a penny into
2 million pieces. Also, one grain of sand
generally weighs approximately one micrograw.
The symbol for a microgram is "fig."
* A square foot is a measure of area. One
square foot is equal to an area that has a length
of one-foot (12 inches) and a width of one-foot
(12 inches). The symbol for a square foot is
"ft2."
Step 2: Doing the math. Even if the laboratory
provides the results of the lead analysis in jig/ft2, it
is a good idea for you to check the laboratory's
calculations. This process generally involves two
steps and is described in Attachment 4-D. It is
important to do the math because:
* The laboratory could have used the wrong
dimensions when converting the sample area to
u.g/ft2. For example, they may assume that the
sample area was one ft2 when the area was
actually larger or smaller.
» Sometimes laboratories use computers that
calculate jag/ft2 using rounded numbers.
Depending on the level of accuracy and the
degree of the rounding, this can lead to errors.
Reference Materials. Refer students to
Attachment 4-D, a worksheet for performing the
necessary mathematical calculations to check the
laboratories math.
Step 3: Compare the results to the Federal
guidance/standards. Once you have made the
necessary conversions, you can compare the
laboratory results to the appropriate Federal
guidance/standards. Individual standards have
been developed for lead-contaminated dust on
floors, interior window sills, and window troughs. It
4-10
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Module 4: Laboratory Results
is important to recognize that the levels for lead-
contaminated dust are different for these three
surfaces. If your laboratory results report lead
concentrations to be above the levels indicated in
the guidance/standards, this indicates lead-
contaminated dust.
Reference Materials. Refer students to the Field
Guide for a summary of the Federal guidance and
standards. See the shaded boxes listing the
guidance/standards at the bottom of the three
pages describing the sampling protocols. Note that
there are different guidance and standards for:
' HUD and EPA
S Different surfaces
ommon Mistakes
Mistaking ng for Ug/ft2
Not checking the laboratory's math
Not submitting spike and blank
samples
Not maintaining a chain-of-custody
Activity. Reference Materials. Refer students to
Attachment 4-E for the exercise on interpreting lab
results.
1. Have students work individually to complete the
exercise. (5 minutes)
2. Debrief the exercise as a group and give the
correct answers. (5 minutes) See Appendix E
for the answers.
3. After the exercise, review common mistakes, as
described below.
Common Mistakes and How to Avoid Them
Listed below are some common mistakes you
might make while performing any of the activities
listed above.
Activity. You should review these mistakes with
the students and ask if they can identify any other
mistakes they might make while performing the
described activities. For any potential mistakes,
make sure you discuss both the mistake and the
proper way to perform and activity.
Failing to record measurements accurately
on the form. As shown in Module 3 (Dust
Wipe Sampling), a small error in measurement
can produce an incorrect sampling failure.
Failing to accurately record measurements can
result in similar errors.
4-11
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Lead Sampling Technician Course
ummary: Now You Can
Select an accredited lab
•Call 1-800-424-LEAD
Ensure iab results are accurate
Maintain a chain-of-custody
Evaluate lab results
Use Federal guidance / standards
• Mistaking the units. One common mistake is
using the wrong units of measurement. When
the results come from the laboratory, check
whether they are provided in ^ig or jag/ft2. If
they are in jug, you must convert them to ^ig/ft2.
Some laboratories will do these conversions for
you, however it is always a good idea to check
a laboratory's calculations.
• Failing to check the laboratory's math.
Laboratories can make errors when converting
results to ug/ft*. Check the laboratory's math to
ensure the calculations were done correctly.
• Failing to submit spike and blank samples.
Another common mistake is not submitting
spikes and blanks. Without these mechanisms,
you have no way of verifying if the laboratory
results were accurate, if the sampling media
were uncontaminated, or if you used good
sampling techniques. Although submitting
spikes and blanks is optional, it is
recommended that you submit one blank
sample for every unit sampled and one spiked
sample for every 10 units.
• Failing to maintain the chain-of-custody.
The chain-of-custody form must be maintained
from the time you take the dust wipe sample
until you receive the laboratory results. This is
your only mechanism to ensure that the
samples were not contaminated, tampered with,
or lost during the analysis process.
Additionally, a documented chain-of-command
is essential for a result to have any kind of legal
standing.
Summary of Module 4
In this module you learned to submit samples to a
laboratory for analysis, check and interpret the
laboratory results, and determine if the unit tested
has lead-contaminated dust above the Federal
standards.
Discussion. Ask students whether they can now
do the activities listed in the objectives:
Select a reliable, accredited laboratory and
explain why proper selection is important.
4-12
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Module 4: Laboratory Results
* Describe the steps they will take to ensure that
the laboratory results are accurate and that the
sampling media were not contaminated.
* List the important steps to ensure samples are
not contaminated, tampered with, or lost-
"maintaining a chain-of-custody."
* Evaluate the adequacy of laboratory results and
identify missing data or a need for more testing.
* State the Federal guidance and standards for
lead-contaminated dust.
Student Materials for Module 4
Student materials will include:
* Copies of trainer slides
• Attachment 4-A: Questions to Ask Laboratory
* Attachment 4-B: Worksheet for interpreting
spiked samples
» Attachment 4-C: Model of laboratory results for
dust sampling
* Attachment 4-D: Worksheet for performing
mathematical conversions for dust sampling
• Attachment 4-E: Exercise: Interpreting Lab
Results (Note: Answers to this exercise can be
found in Appendix E.)
4-13
-------
Attachment 4-A: Questions to Ask Laboratory
Is the laboratory
recognized by NLLAP?
All samples must be analyzed by an NLLAP laboratory. You can
contact the National Lead Information Center (NLIC)
Clearinq house at 1-800-424-LEAD for an up-to-date list of
NLLAP-recoqnized laboratories. Even after selecting a laboratory,
you should check the laboratory's accreditation every six months.
What is the detection
limit of the
methodology used by
the laboratory?
The detection limit is defined as the level below which the
laboratory cannot report an accurate level of lead. For dust wipe
sampling results to be accurate, the detection limit must be 10
ug/ft2 or iower. It is important that the laboratory report its results
in either micrograms (ug) or micrograms per square foot (ug/ft2).
What is the turnaround
times for sample
analysis?
Because the occupants often cannot occupy the units until
sampling is complete, the laboratory turnaround time is important.
Labs usually provide results within 1 to 3 days. A faster turn
around time allows you to be more responsive to your client but
may cost more money.
What is the cost per
sample?
You should be able to get your samples analyzed for under $7 to
$15 per sample. However, prices can vary depending on how
quickly you want the results. A 6-hour turn around will cost more
than samples analyzed over a few days. You should also be wary
that low laboratory costs that may be indicators of poor lab work.
Will the laboratory
provide sampling
materials?
Many laboratories will provide you with all of the materials
necessary to perform sampling. Sampling materials provided will
likely include wipes, gloves, templates, tubes for submitting the
samples to the laboratory, necessary sample collection forms, and
overnight mailing envelopes. You may want to select a laboratory
that provides these materials because laboratory-supplied
materials and forms can help minimize potential errors in the
analysis and record keeping.
• Does the laboratory
supply spiked dust
wipe samples?
In addition to the sampling materials, some laboratories will supply
you with spiked dust wipe samples. Spikes are dust wipes
contaminated by a laboratory with a known weight of lead-based
paint dust, measured tot he nearest 0.1 u.g of lead dust. They are
used to ensure adequate quality control of the digestion process
at the laboratory. Although submitting spiked samples is optional,
they are useful in determining if a laboratory reports back accurate
results. If you decide to submit spiked samples, it is important that
they are obtained from the laboratory so the sampling materials
are consistent with the other wipes and to ensure the laboratory
can accurately digest the wipe.
Does the laboratory
perform all the
necessary
mathematical
calculations?
The Federal guidance is provided in ng/ft . Depending on the size
of the sample or sample area, some mathematical calculations
may need to be performed to convert the sample area to one
square foot. Selecting a laboratory that will perform this
calculation for you will save valuable time and reduce the
possibility of mathematical errors. Note: even if a laboratory
performs this calculation, it is still a good idea to spot check the
math.
-------
Attachment 4-B: Worksheet for Interpreting Spiked Dust Wipe Samples
When you get the results back from the laboratory, compare the spiked sample results to the
known lead concentrations. For the laboratory results to be accurate, the measured sample
loading must fall within 80 to 120 percent of the true value. Recording the spiked sample area
as 1 ft will facilitate this process.
You will need to perform four separate calculations to ensure that the spiked sample falls within
80 to 120 percent of the true value:
• Calculate the lead loading of the spiked sample;
4 Calculate 80 percent of the true value - lower bound;
» Calculate 120 percent of the true value - upper bound; and
4 Compare these numbers to the analysis results.
1 . Write down the true lead loading
contained in spiked sample (jag).
2. Calculate the lower limit (80% of true
value). Multiply the true value (from[1]
above] by 0.8.
3. Calculate the high limit (120% of true
value). Multiply the true value (from [1]
above) by 1 .20.
4. Write down the results you received
from the laboratory analysis.
5. Compare laboratory results with the
low and high bounds for the analysis.
Does the laboratory result fad between the
lower and high limits?
True value: u,g
Lower limit: ugx0.80 =
High limit: ngx1.20 =
Laboratory results: fig
Lower limit [2]: (ig
Laboratory [4]: ug
High limit [3]: ng
WJ
WJ
Does the spike pass or fail?
* Pass: laboratory results fall within 80 percent to 120 percent of the true value
«• Fail: laboratory result do NOT fall within 80 and 120 percent of the true value
>- Submit another spike in your next shipment to the lab.
2- If this second spike also fails the laboratory results, all of the results must be
considered invalid and you should consider finding a new laboratory to perform the
analyses.
-------
Attachment 4-C: Model of Laboratory Results
DUST SAMPLING RESULTS FORM
Date of clearance:
Clearance Technician:
Client:
Property address:
8/5/99
joe^mitk,
$aUtyj)(we4,
78£a6tMawgt.,Api.A
Jlammowt, 9ft 89S9B
Sample #
98- f
98-2
98-3
98-4
98-5
98-6
Location
fypdttuM, l&Ufe
b&bia&m
fypAtaiM. Icwfe.
^edwtutt-
It-pAt&iM, im&ll
Jtedwxun
IdpdiaiM, 6m&tt
hednoaw.
Kjtchea
KjiicJiea
Surface
<$W
fyuwiifacwq.
int. window-tiU
ttylww
£icte ffOciwj, ltd.
window- -aU
&OW
Itfittdow- above.
tistkisd. till
Dimensions
of sample
area
/J?x/.?
34X3.0
'•2*U
34X3.0
12^12
24^3.0
Total jig
Lead
23
to
200
29
f2
2ff
ug/ft2
23
20
200
58
i2
422
-------
Attachment 4-D: Worksheet for Performing Mathematical Conversions for Dust Samples
Unit of Measurement
Inches
Square inches
Feet
Square feet
Symbol
in
in2
ft
ft2
Unit of Weight
Micrograms
Micrograms per square foot
Symbol
ng
ng/ft2
1. Convert the sample area to square feet (ft2)
If the area you sampled was not a square foot, you will need to convert it to this dimension.
One foot equals 12 inches, and one square foot equals 144 square inches.
» Record the sample area in inches (in) as opposed to feet (ft).
» Convert the sample area to square inches (in2). If you have a decimal, round the number to
three decimal places.
* Divide the square inches by 144 to get square feet (ft2). If you have a decimal, round the
number to three decimal places.
Dimensions of sample area in inches (in)
Multiply length times width to calculate et the
area in square inches (in2)
Divide the area in square inches (in2) by 144 to
calculate the area in square feet (ft2).
Length = in Width:
in x in = in2
in2 -144= ft2
in
2. Convert the results to micrograms per square foot (pig/ft2)
After you have converted the sample area to square feet, you need to find the amount of fead
dust contained in that area. The micrograms per square foot (fig/ft2) describes the quantity of
lead dust contained in a one square foot area.
* Divide the lead concentration (pg) by the area (ft2).
Dimensions of sample area in square feet (ft2)
Quantity of lead in micrograms (ug)
Divide micrograms (ng) by square feet (ft2) to
calculate micrograms per square foot (|*g/ft2)
Area = ft2
Lead = ug
ug+ ft2= (ng/ft2
-------
Attachment 4-E: Activity - Interpreting Laboratory Results
• Instructions; Trie purpose cf this activity is to test your ability to verify the resdts received fram the laboratcjry,
compare these results to the clearance guidance levels, and interpret the results. Using the following excerpt from a
Dust Sampling Results Form, check the laboratory s^cdaticn of the v^ (Note: the
numbers used in this exercise have been simplified to facilitate calculations).
Sample #
92-1
92-2
92-3
Location
T It, Mt* urf ffilrf Tin
U[/w ir^Fttt 1 m
Kiiitei — Jru jLwnxlw
Surface
Ebx
ItetrwhiwalL
Tto'r'rwTTJwgTl
Dimensions of
Sample Area (fi^)
1JDO
05
05
Total Lead
(UQ)
23
150
260
M9*2
23
300
130
1. Check the results (pg Lead/g) for each sample If the resute are incorrect, prxwde the correct results in ^
Leac/ft2.
After verifying the laboratory's results, compare these results to the appropriate clearance guidance. Dd the
individual samples pass or fail the clearance test?
92-1: Ftesult:
EPA Guidance for Lead-Contaminated Dust
* ROOTS:
* Interior window sills: SOOugft2
* VMndowtrough: 800pgffi2
Qearance Guidance:
Pass a Fail?
92-2: Result:
Clearance Guidance:
Pass or Fail?
92-3: Ftesult:
Qearance Guidance:
PassorFa'l?
-------
Module 5: Putting the Skills Together
bjectives
Describe three situations in which
lead sampling is performed
Use the Field Guide to plan for
and perform an examination
MtJuir* liming aicSblh I
y Different Types of Exams?
Post-renovation clearance
•To determine if the unit is clean
HUD-required clearance
•As required by the HUD Lead-Based
Paint Regulation
Other lead sampling examinations
•For information on potential lead hazards
Module 5: Putting the Skills Together
(60 minutes)
This module will outline the steps a lead sampling
technician must take from start to finish when
conducting an examination. It will differentiate
among the different types of examinations,
including post-renovation clearance examinations,
HUD-required clearance examinations, and other
lead sampling examinations.
This module includes an exercise (Attachment 5-
B) to help practice implementing the protocols.
Objectives
By the end of this module, students will be able to:
* Describe three situations in which lead
sampling is performed.
• Use their Field Guides to plan for and perform
an examination appropriate to that particular
situation.
Why are There Different Types of Lead
Sampling Examinations?
Now that you have learned how to perform visual
assessments, take dust wipe samples, and analyze
the results, you have the skills you need to perform
lead sampling examinations in people's homes.
Before you perform an examination, however, you
need to know some protocols for putting these skills
together.
Lead sampling can be performed for various
reasons. Depending on the situation, different
actions are appropriate. To understand the
different situations, it helps to think of them in three
categories:
• Post-renovation clearance. After renovation
or remodeling, it is appropriate to perform
clearance in the work site to confirm that the
dwelling unit was adequately cleaned and that
the renovation work has not created any
hazardous conditions that might cause lead
poisoning. In this case, we rely on dust wipe
sampling to tell us if lead-contaminated dust
was created by the work. (Note: Remodeling
includes surface preparation for repainting
5-1
-------
Lead Sampling Technician Course
work. Repainting requiring surface preparation
should follow these guidelines.)
HUD-required clearance. HDD's regulation on
lead hazard evaluation and reduction in HUD-
associated housing requires clearance after
lead hazard reduction activities are performed.
These clearance examinations are affected by
specific HUD regulations. (24 CFR 35)
Other lead sampling examinations. There
are other situations in which a resident,
property owner, or potential dwelling purchaser
may want to find out if hazardous conditions
exist in a dwelling unit. (For example, a
pregnant woman may want to find out if her
home has potential lead hazards that could
affect the health of her child. Or, a property
owner may want to perform dust wipe sampling
before unit-turnover to ensure that the rental
unit is free of potential lead hazards for its next
tenants.) Procedures for these more general-
purpose lead sampling examinations allow for
the flexibility of the client's concerns.
Reference Materials. For more guidance on
Federal regulations that may affect lead sampling
see the Appendix A to this manual. Note: States
and Indian Tribes may add their own regulations to
the Appendix.
What are the Differences in the Protocols?
ey Differences in Protocols
Qualifications of the examiner
Examination procedures
Standards for evaluating hazards
ee Field Guide for protocols
Reference Materials. Refer students to the Field
Guide. It provides additional detail on each type of
examination. As you look at these you will notice
some differences.
Discussion. Ask students to point out some of the
differences. Explain the nature of the differences.
Do not go into detail but provide the general
rationale.
Some differences include the following:
• The qualifications of the examiner. Because
HUD-required clearance is needed to meet
regulatory requirements, the standards for the
technician performing the clearance are higher
than for voluntary examinations.
5-2
-------
Module 5: Putting the Skills Together
efore the Examination
nlbrmaiion to give the client:
Purpose of the examination
•Not a risk assessment or paint inspection
Examination procedures
•Clean first
Implications of results
• Disclosure
•Occupancy tSee Attacluamt S-A)
MMiik * humid (lit Skilli (i^vitef 4
* Procedures for sampling. The procedures
are related to the purpose of the exam. For
example, for post-renovation clearance, the
emphasis is on the work site because we want
to ensure that the work did not create any lead-
contaminated dust and debris. HUD-required
and other clearance exams tend to be aimed at
establishing the condition of the entire unit and
therefore test the entire dwelling unit.
• The guidance used in evaluating the results.
At this time, HUD and EPA provide different
thresholds for evaluating lead-contamination.
What Does this Mean for Each Lead
Sampling Examination?
The rest of this module walks you through each
type of clearance examination. It highlights:
• Steps to take before doing the examination.
These steps apply to all three types of
examinations; and
* The procedures for doing each type of
clearance examination.
Steps to Take Prior to the Examination
Discussion. Ask participants to describe the steps
they would take to prepare for any job. Then review
the following points.
Information to Give to the Client
Your first contact with the client will probably be
over the phone. The client may not know much
about lead sampling exams. Use this initial contact
to explain the examination's purpose and
procedures.
The client needs to know the following things:
• The purpose of the examination. The
clearance or lead sampling examination
identifies some conditions that can cause lead
exposure, including lead-contaminated dust. It
is not to be confused with a risk assessment or
a paint inspection (as described in Module 1).
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Lead Sampling Technician Course
• Examination procedures. The client should
understand the examination procedures. In
particular, they need to know that:
> They should clean the site before the exam
takes place. Explain that clean-up involves a
thorough, wet cleaning and vacuuming of the
unit preferably with a HEPA vacuum.
Generally, it should be done at least one
hour after the work is done to give time for
the dust to settle out of the air. (Cleaning
methods are further addressed in Handout 2
provided in Appendix B.)
> They should allow at least one hour to pass
after cleaning before the clearance
examination occurs. This allows time for
dust to settle after cleaning.
• The implications of finding lead*
contaminated dust. Before hiring a lead
sampling technician, clients should understand
the implications of finding lead-contaminated
dust in their homes. For example:
> An area that is found to have lead-
contaminated dust may require additional
cleaning.
> Federal disclosure laws require that if lead-
contaminated dust is found during the
examination, these results must be disclosed
to future purchasers or tenants.
iefore the Examination
[Information to get from the client:
Age of dwelling (pre-78?)
Was abatement performed?
Why is the client requesting the exam?
|5ee Attachment 5-A
Vt..liib < Vvumr Ik still* l<
Background Information to Collect from the
Client
Before you go to a site to begin a lead sampling
examination, you need to collect some information
from the client.
Discussion. Ask participants what types of
information they might like to have before they
begin a job. Have them explain why they would
want this information.
The information collected from the client will help
you confirm that a lead sampling examination is
appropriate and help you plan your on-site work.
Questions to ask include:
5-4
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Module 5: Putting the Skills Together
• When was the dwelling built? If the unit was
built after 1978, there is generally little need to
perform a lead sampling examination. Lead-
based paint was banned from residential use in
1978.
• Was lead abatement conducted? If so, this is
not an appropriate job for a lead sampling
technician.
> Lead abatement jobs are designed to
permanently control lead-based paint
hazards and must be done by certified and
trained abatement professionals.
> Clearance after abatement must be done by
a risk assessor or a paint inspector.
• Why is the client requesting an
examination? The answer they give to this
question will determine the protocol you use
when conducting the examination.
> Because remodeling/renovation recently
occurred in the unit.
> Because it is a HUD requirement.
> For other reasons.
Reference Materials. See Attachment 5-A for a
checklist of items to ask before any clearance
examination.
What Next?
What you do next depends on the type of lead
sampling exam being performed.
Next, we will go step by step through each type of
examination and discuss the protocol for each one.
The steps for each protocol are listed in the Field
Guide.
Reference Materials. Go to the Field Guide. Talk
through each of the protocols. This trainer manual
provides detailed guidance on each type of
examination. As you go through the procedures for
each type of exam, refer the students to the
summaries provided in the Field Guide. Remind
them that they can use these later to remember
these rules. There is no need to memorize the
protocols.
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Lead Sampling Technician Course
ost-Renovation Ciearance
ose
determine if:
•A dwelling is clear of lead-
contaminated dust
•After renovation or remodeling
Voluntary examination
'ost-Renovation Clearance
iner Qualifications
Risk Assessor, Paint Inspector, or
Lead Sampling Technician
Lead Sampling Technician cannot
perform post-abatement clearance
Check State, local, and Tribal laws
too
Post-Renovation Clearance
This section summarizes the steps involved in a
post-renovation clearance examination.
Reference Materials. Refer students to the
summaries provided in their Field Guide. Talk
through each of the steps in the process. As you
talk through the process, make sure you highlight
the following:
- The purpose of post-renovation clearance
examinations
- Qualifications of the examiner
- Getting ready for the exam - pre-clearance
cleaning
- Visual assessment - the implications of the
visual assessment results
- Dust sampling - locations for dust sampling
- Analysis - guidance used for analyzing results
- Results - what to do if lead-contaminated dust
is found
Allow students to ask questions about why the
clearance examination protocol is established in
this way. Use the guidance below to enhance your
description and answers.
Note: Overhead slides are provided to guide the
discussion below. You can choose to use them or
to refy solely on the summary in the Field Guide.
Purpose of Post-Renovation Clearance
The purpose of post-renovation clearance is to
determine if a unit is clear of lead-contaminated
dust after renovation or remodeling. These
activities can create lead-contaminated dust, so
proper clean-up is critical. Clearance is the only
way to tell if clean-up was effective. (Note:
Remodeling includes surface preparation for
repainting work. Repainting requiring surface
preparation should follow these guidelines.)
Qualifications of the Clearance Examiner
To conduct a post-renovation clearance
examination, the clearance examiner should be
trained as a risk assessor, paint inspector, or lead
5-6
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Module 5: Putting the Skills Together
'ost-Renovation Clearance
}reparing for the Examination
Tell client to clean unit
•At least one hour after work is done
•At least one hour before clearance
Provide guidance on cleaning
•See Appendix B
Ask where work occured
Mo** <; Pwrio* lb< Skill TifrtlWT
'ost-Renovation Clearance
Visual Assessment
i Perform in clearance area
•All rooms where work occurred
i If poor conditions:
•Correct poor conditions before dusl
sampling
•Provide the client wiih information on
potential sources oflcad exposure (See
Appendix B)
U«fcjk-<- PUHU* the Sfclll Top**!
>ost-Renovation Clearance
)ust Sampling—I ocations
i Take dust wipe samples in work
area
•Up to four rooms
Surfaces to sample:
• Floors - one in each room sampled
• Window sills - only in rooms where
work was done on windows
sampling technician. No certification is required
unless state or local law requires it.
Preparing for the Examination
To prepare, follow the procedures outlined earlier in
this module and summarized on this slide. It is
important to remember to:
» Make sure you encourage the client to clean
the area at least one hour after the work is done
and at least one hour before the clearance
examination.
* Gather information from the client about where
the work occurred so that you can identify the
clearance area to be sampled.
Performing the Examination
When you arrive on site, if possible, you should
confirm the clearance area with the client. Then
take the following steps:
1. Perform a visual assessment. Follow the
protocol outlined in Module 2.
• If the visual assessment reveals visible dust, or
paint chips/debris, the client should be advised
to correct these conditions prior to continuing
the examination.
• If the visual assessment reveals deteriorated
paint, the lead sampling technician may indicate
such information on the visual assessment form
and the client should be informed that
deteriorated paint represents a potential source
of lead exposure.
Additional information for the trainer. The
following discussion on where to perform dust
sampling is very important. While Module 3
described how to perform dust sampling, it did not
instruct participants where to take the samples.
2. Perform dust sampling. Follow the protocol
outlined in Module 3.
* Areas to sample include the rooms where work
occurred (up to four areas).
* Surfaces to sample include:
> Floors — in each room tested
5-7
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Lead Sampling Technician Course
> Interior window sills — in rooms where work
was done on the windows (Note: It is
optional in other cases).
ost-Renovation Clearance
ults and Reporting
Analyze the results and use EPA
Guidance
•Floors: 100 ug/ft2
•Interior window sills: 500 ug/ft2
•Window troughs: 800 ug/ft2
ost-Renovation Clearance
suits and Rennrtinp
Write the report (See Appendix B)
Clearance Failures
•Re-clean unit
•Re-testing
•Recommend fixing deteriorated
paint
Results and Report Writing
When analyzing the data, follow the guidance
provided in Module 4. When writing the report and
explaining it to the client, follow the guidance in
Module 6.
1. Analyzing Data. Use the EPA guidance as
your standard for evaluating sample results. These
standards are:
• Floors: 100 ug/ft2
4 Interior window sills: 500 ug/ft2
* Window troughs: 800 pg/ft2
Note: These are interim guidance. These
numbers may change. This current guidance is in
the Field Guide.
2. Writing the report. Use the blank format
provided in Appendix B for writing the report. (See
Appendix C for a model report.)
3. Clearance failures. If a unit fails the clearance
examination, there are no requirements; however,
the following is recommended:
* Reclean the areas represented by the sample
that failed clearance. (For example, if a floor
failed , re-clean the floors. If an interior window
sill failed, re-clean interior window sills.) Ideally
the whole unit should be recleaned.
• Conduct a second clearance examination.
• In addition, the lead sampling technician could
recommend to repair any deteriorated paint that
was identified. Use safe practices as described
in Handout 3 in Appendix B.
* If the problem persists, consider having a risk
assessment conducted.
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Module 5: Putting the Skills Together
UD-Required Clearance
Clearance is required by HUD
after
•Lead hazard reduction activities
•Rehabilitation that disturbs paint
•Maintenance activities required by
HUD to address lead hazards
HUD-Required Clearance
HUD-required clearance looks much like a post-
renovation clearance, however, there are some
differences.
Cover the following general background on HUD-
required clearance before addressing the protocol.
When is Clearance Required by HUD?
The Department of Housing and Urban
Development (HUD) published its regulation, at 24
CFR 35, addressing lead-based paint in Federally-
owned and assisted housing. These rules affect
public housing as well as private housing that
receives HUD or other Federal assistance (for
example, Section 8, HOME, Community
Development Block Grant assistance, Federal
mortgage insurance for multifamily properties,
interest subsidies, Rural Housing Service
assistance, etc). Note: The clearance inspector is
not responsible for knowing when these
requirements apply.
HUD requires clearance in pre-1978 residential
dwellings that receive Federal financial assistance
or are sold by the Federal government after:
• Lead hazard reduction activities are performed.
• Rehabilitation that disturbs painted surfaces is
performed.
• Maintenance activities that are required under
the HUD Lead-Based Paint Regulation to
address lead hazards.
UD-Required Clearance
Key differences with other
clearance
•Qualifications of examiner
•Standards for evaluating hazards
•Examination procedure
What are the Key Differences Between
HUD-Required Clearance and Other
Clearance Examinations?
There are a few new things we need to learn to
understand how clearance examinations must be
conducted for HUD-required clearance jobs. These
differences address:
* The qualifications of the lead sampling
technician;
• Standards used for evaluating hazards; and
* Clearance examination procedures.
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Lead Sampling Technician Course
Each of these items is discussed in the following
sections.
UD-Required Clearance
iminer Qualifications
Examiner must be
•Certified (or supervised)
•Independent (unless in-house employee)
Lead sampling technician can perform
clearance in single units
•But not in multifamily properties where a
sample of units is tested to represent the
whole properly
Reference Materials. Refer students to the Field
Guide. Walk through the process. Remind
students that it is the same general process as
previously covered for post-renovation clearance.
Highlight the following:
- The qualifications of the clearance examiner
- HUD Clearance Standards
- The clearance area
- Consequences of the visual assessment
- Sampling locations
- Clearance failures
Refer to the guidance below to describe the
protocol and to answer the students' questions.
Overhead slides are provided and can be used at
the trainer's discretion. Remind students, they do
not need to memorize this material as it is provided
to them in summary table in their field guide.
Qualifications of the Clearance Examiner
To meet HUD clearance requirements the lead
sampling technician must be certified or be under
the supervision of a certified risk assessor or paint
inspector. In addition:
* A lead sampling technician can perform
clearance only on single family dwellings or on
individual dwelling units in multifamily
properties. In multifamily dwellings where only
a sample of units are being examined to
represent the whole property, a certified paint
inspector or risk assessor must oversee the
work. A lead sampling technician is not
qualified to conduct clearance following an
abatement.
* The lead clearance examiner must be
independent of the persons or entities
performing the hazard reduction, rehabilitation,
or maintenance work.
> However, a property owner may use a
qualified in-house employee to conduct
clearance, provided such employee does not
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Module 5: Putting the Skills Together
UD-Required Clearance
hat is tbe Clearance Area?
Entire unit
•In most cases
Work site only
•Small rehabilitation jobs (< 55,000)
•Some maintenance activities
required by HUD
Ask the client
Mrtijk-*: hitting Ihe Skiifo Titgtflhei I*
f UD-Required Clearance
Assessment
If clearance area does not pass
visual assessment, do npt perform
dust sampling
•Deteriorated paint must be stabilized
•Area must be visually clean
conduct clearance examinations of work in
which he or she participated.
Procedures for HDD-Required Clearance
HUD has specific requirements regarding how the
clearance examination is performed. The
procedures are similar to those described for post-
renovation clearance with some subtle differences
in several areas. These are explained in the next
few slides.
Defining the clearance area. The area in which
the lead sampling technician will perform a visual
assessment and dust sampling depends on the
nature of the activity that preceded the clearance.
• Unit-wide clearance. For most jobs, the
clearance area is the entire unit, interior and
exterior. This means that the lead sampling
technician must look at the following:
> Inside: All rooms in the unit, regardless of
whether work was done, and any common
areas servicing the unit.
> Outside: Exterior painted surfaces, the
ground near the structure, and areas of bare
soil.
• Work site clearance. In some cases, the
clearance area is limited to the work area.
These cases include small HUD-funded
rehabilitation jobs (up to and including $5000 of
assistance per unit) and maintenance work
required by HUD's Lead-Based Paint
Regulation to address hazards.
Note: The client is responsible for telling the
clearance examiner the area that constitutes the
work site.
Consequences of the visual assessment. The
HUD regulation requires that the unit pass a visual
assessment prior to dust testing. Therefore:
* Dust and debris must be removed from the
clearance area, including the exterior, before
the clearance examiner proceeds with dust
sampling.
• Any deteriorated paint must be stabilized to
pass clearance.
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Lead Sampling Technician Course
UD-Required Clearance
pling Locations — Rooms
Unit-wide clearance (most cases)
•4 rooms unit-wide
•Areas where work took place and
where children spend time
Work site clearance
•Up to 4 rooms in work areas
IUD-Required Clearance
ipling I .ocations — Surfaces
Floors
•One per room sampled
i Windows
•If no work was done on windows -
sample window sills only
• If work was done on windows —
alternate sills and troughs
UD-Required Clearance
ills
Analyze the results
•Use HUD Interim Standards:
•Floors: 40 ng/ft2
• Interior window sills: 250 ug/ft:
• Window trough: 800 ug/ft2
Additional information for the trainer. The
following information on sampling locations is very
important. Make sure you emphasize the locations,
particularly the sampling of window troughs in
rooms where work was performed on windows.
Sampling locations. When performing dust
sampling in the clearance area, HUD specifies
sampling locations that are slightly different from
those described for post-renovation clearance. The
main difference is the addition of window troughs
to the areas sampled. The sampling protocol,
including window troughs is described in the Field
Guide.
* Areas to sample include the rooms where work
occurred and areas where children spend time.
> For work site clearance - up to four rooms
where work occurred.
> For unit-wide clearance - four rooms where
work occurred or children spend time.
• Surfaces to sample include:
> Floors — One in each room tested
> Windows — One in each room tested. If
work was done on windows, alternate
between interior sills and troughs. If no work
was done on windows, simply sample the
interior sills.
Results: HUD Clearance Standards. Until EPA
publishes its final rule on standards for lead
hazards, HUD has its own interim standards for
defining lead-contaminated dust. These standards
must be used whenever a HUD-required clearance
examination is performed. The standards are:
• Floors: 40 ug/ft2
» Interior window sills: 250 ug/ft2
• Window trough: 800 ug/ft2
Reporting. The clearance examination report
described in Module 6 meets HUD requirements. It
is critical that all reports for HUD-required
clearance include all the information listed,
including the results of the visual assessment.
5-12
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Module 5: Putting the Skills Together
UD-Required Clearance
Analyze the results
•Use HUD Interim Standards
Write the report (See Appendix B)
•Signed by examiner
Clearance Failures
•Correct conditions
•Conduct clearance again
Additional information for the trainer. The
clearance examination report provided by the lead
sampling technician will be added to other
information to create a HUD-required "Clearance
Report" (distinct from the "clearance examination
report"). The clearance report includes additional
information about the work done on the property.
The lead sampling technician may be asked to
write the clearance report, but in such cases, must
be provided all the necessary information.
Alternatively, the client may use the clearance
examination report to develop the full clearance
report.
Clearance failures. If the clearance examination
reveals unacceptable conditions -for example,
they show deteriorated paint or lead-contaminated
dust -those conditions must be corrected and
reexamined by the lead sampling technician before
the unit passes clearance. HUD requirements for
re-cleaning and re-testing are as follows:
* Any areas represented by the sample that failed
must be re-cleaned. For example, if a floor
failed, all floors in the clearance area must be
re-cfeaned.
* However, any specific surfaces that were tested
and passed do not have to be re-cleaned. If, in
the example above, one floor sample failed and
three passed, the three rooms where the floors
passed do not need to be re-cleaned. Note: It
is a good practice to clean everything again.
* When taking dust wipe samples for clearance
again, do not sample the same locations as
before. Since they were sampled before, the
dust has already been removed.
• Deteriorated paint must be stabilized using
appropriate practices. (See Handout 3 in
Appendix B for guidance.)
* Owners of rental properties must inform the
occupants of the results of the clearance
examinations.
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Lead Sampling Technician Course
ther Lead Sampling Exams
For information on potential lead
hazards
Voluntary examination
fciJ: hitlmi UK Stall* Tt.s«h«
ther Lead Sampling Exams
'reparing for the Examination
Cleaning — does client want results
for:
•Clean home, or
•Ordinary conditions
Sampling area
Single vs. composite sampling
Other Lead Sampling Examinations
Other lead sampling examinations look much like
post-renovation clearance; however, because these
tend to be voluntary examinations for the purpose
of finding out about lead hazards in the home, the
protocols are more flexible. An ideal protocol would
include the following steps.
Note: Adjustments to this protocol can be made at
the request of the client based on their own
concerns.
Reference Materials. This material may need to
be taught quite briefly if time is short. In this case,
refer students to the Field Guide. Emphasize that
this is a voluntary clearance examination and
therefore the protocol described here is
recommended. Walk through the steps briefly.
Use the information below to inform your
description of the protocol and to answer students'
questions. Then skip to the exercise provided as
Attachment 5-B.
Examiner Qualifications
A trained risk assessor, paint inspector, or lead
sampling technician can perform clearance in these
situations, subject to state and local laws.
Preparing for the Examination
Provide appropriate information to client before the
examination, such as:
• Cleaning the unit. Advise the client that the
home is more likely to meet the federal
standards if it is cleaned first. However, if the
client's goal is to identify lead-contaminated
dust in the home in its usual state, the unit
should not be cleaned prior to the examination.
• Sampling area. Does the client want to
sample the entire unit or just one particular
area?
• Pros and cons of single vs. composite
samples. Composite samples are less
expensive but provide less specific information
about the location of lead-contaminated dust.
5-14
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Module 5: Putting the Skills Together
ther Lead Sampling Exams
rforming the Exam
Conduct visual assessment first
•Advise client of potential hazards
• Provide information (Appendix B)
Conduct dust sampling
her Lead Sampling Exams
ust Sampling Locations
Rooms - where children spend
time
Surfaces
•Floors —4 single or 1 composite
•Windows
* 2 window sills or 1 composite
• 2 window trough* or I composite
ther Lead Sampling Exams
;nlts and Reporting
Use EPA Guidance
Use standard report form
Examination failures
• Advise client to re-clean and retest
•Consider risk assessment
•e Appendix Bfor handouts
Performing the Examination
Visual assessment. Perform a visual assessment.
Inform the client of any of the following conditions
— visible dust, debris/paint chips, or deteriorated
paint. Suggest that these should be corrected prior
to dust wipe testing.
Dust sampling locations. Perform dust testing in
four rooms/areas. This testing may be done with
single surface or composite samples.
» Appropriate areas include rooms where children
are most likely to spend time — the living room,
kitchen, playroom, and child's bedroom.
• Sample a floor in each area and alternate
window sills and troughs.
Results and Reporting
Analysis. Use EPA guidance to analyze samples.
See the Field Guide.
Report writing. Write the report following the
format provided in Module 6.
Examination failures. In the event of that the
sampling shows lead contaminated dust, advise the
client to clean the unit, repair deteriorated paint
(using the practices outlined in Handouts 2 and 3
provided in Appendix B), and perform a second
clearance examination. Alternatively, suggest the
services of a risk assessor.
Exercise. This exercise allows students to apply
the three protocols to different situations. Refer to
Attachment 5-B for the exercise which includes
three scenarios.
'\. Divide students into at least three groups
2. Assign each group a scenario.
3. Allow each group *\ 5 minutes to work on their
scenario.
4. Have the groups report their answers to the
whole group.
Answers are provided in Appendix E.
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Lead Sampling Technician Course
Student Materials for Module 5
Student materials include:
• Copies of trainer slides
* Attachment 5-A: Checklist — Preparing for the
Job
• Attachment 5-B: Exercise
5-16
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Attachment 5-A: Preparing for the Job - Checklist
INFORMATION TO PROVIDE THE CLIENT
4 Clean the unit prior to the
lead sampling
examination.
Wait one hour before
clearance.
If the lab results show
hazardous levels of lead
in the dust further action is
required.
Units with dust and debris are unlikely to pass a lead
sampling examination. Ideally, cleaning should take place
at least one hour after any renovation work is completed to
allow dust to settle out of the air. (See Handout 2 in
Appendix B lor more guidance on appropriate cleaning
methods.)
If the clearance is being done after renovation, remodeling,
or hazard reduction work, the lead sampling technician
should not take samples until one hour after the clean-up is
complete.
If the lab results show hazardous levels of lead in the dust:
* Clean the unit and repair paint to address the hazards.
In addition, the client may want to hire a risk assessor to
do a more thorough evaluation of the unit.
« The client has a responsibility, under Federal law, to
disclose any knowledge of lead-based paint or lead
hazards to future purchasers or tenants of the unit (even
if those hazards have been corrected).
INFORMATION TO COLLECT FROM THE CLIENT
Was the dwelling built
after 1978?
Was lead abatement
conducted?
Why is the client
requesting this
examination?
If the unit was built after 1978, there is no reason to perform
clearance. Lead-based paint was banned from residential
use in 1978.
If so, this is not an appropriate job for a lead sampling
technician, except under the direct supervision of a certified
risk assessor or paint inspector.
See Field Guide for appropriate protocol:
• Post-renovation clearance
* HUD-required clearance
• Other lead sampling
-------
Attachment 5-B: Exercise - Putting the Skills Together
For the following scenarios, answer these questions:
a. Are there additional questions you want to ask the client?
b. What protocol will you follow? (post-renovation clearance, HUD-required, or other
sampling)?
c. Where will you conduct the visual examination? What will you look for?
d. Will you take dust wipe samples? jr^what rooms? On what surfaces?
1. You just received a call from Mrs. Green to perform an examination of her home. Mrs.
Green tells you that her home was built in 1952. She has just had her kitchen and two
bathrooms remodeled and she is concerned about that her home was properly cleaned after
the remodeling was done.
2. The owner of Parkview Apartments asks you to do a clearance examination of a unit in his
building. He tells you that the unit receives HUD Section 8 assistance and he just did some
paint stabilization in the unit to meet HUD Housing Quality Standards. He says he needs to
pass clearance before his tenant moves in.
3. Mr. and Mrs. Johnson are moving into a new home. They have a two year old son and Mrs.
Johnson is expecting a second child in three months. Before they move in, they want to
make sure their home is safe for their children. They ask you to perform an examination of
their home.
-------
Module 6: Writing and Delivering the Report
Objectives
i List the key contents of a clearance
examination report
i Provide appropriate responses to
client questions
Module 6: Writing and Delivering the
Report (30 minutes)
This module teaches students to prepare a
complete clearance examination report and gives
guidance on how to explain the sampling results to
the client.
Because the most common type of report at this
time is likely to be a clearance examination report,
it is used it as the model report for this module.
The module is divided into two instructor-led
activities. The first activity covers what information
a clearance examination report should contain and
describes what makes a report easy-to-read. The
second activity explains how to respond to client
questions.
Objectives
At the end of the module, students will be able to:
* List the key contents of a complete clearance
examination report and describe ways to make
the report easy to read; and
• Respond appropriately to questions that clients
may ask upon receiving their report.
Contents of the Report
Activity # 1 (10 minutes). This activity uses a
sample report to teach students the items that
should be included in clearance examination
reports and points out features that make reports
reader-friendly.
Instructions:
1. Refer students to Appendix C: Model
Clearance Examination Report.
2. Introduce the activity to the students. Explain
that the purpose of the activity is to show them
what items must be included in reports and
ways to make the report easy to read for their
non-technical clients.
3. Ask the class to use the report to answer the
questions listed below. As a group, answer
each question one at a time. Use slide 2 to
present the questions to the group and check
off each question as it is answered.
6-1
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Lead Sampling Technician Course
Correct each answer as necessary using the
answers below. Make sure that you highlight
the key point made by each question. Finally,
refer students to Appendix B which includes a
blank report form including useful factsheets
that can be included in a report..
Activity: Reading a Report
I. Who performed the clearance? What is his/her certification
number?
2. Where was lead-contaminated dust found?
3. Where is one location that was tested and passed
clearance?
4. What does the report say about deteriorated patnt. debris.
and visible dust?
5. Where does the report provide the Federal guidance for
window sitls?
6. What additional guidance does the report provide to the
client?
Mftlufcjft: WnuitiimlIfelitwitg**K*r«n I
Questions to Answer
1. Who performed the clearance examination?
What is his/her certification number?
A: See the cover page. The lead sampling
technician is Joe Smith and his certification
number is IN 77777. Key point: This
information is provided up-front on the cover
sheet.
2. Where was lead-contaminated dust found?
A: See the summary of results on the cover
page. Lead-contaminated dust was found on a
window and the floor of the small bedroom, on
the window above the kitchen sink, and in the
upstairs hallway. Key point: This information
was provided in the summary results on the
cover page and that clients will want to know
where the hazards are right away.
3. Where is one location that was tested but
passed clearance?
A: See the results form that comes from the
lab. Possible answers include:
» Floor in the upstairs large bedroom.
*> Window sill in the upstairs large bedroom.
>> Kitchen floor.
Key point: This information was provided on
the "Dust Sampling Results Form" that came
from the lab and was attached to the report.
4. Does the report say anything about the
presence of deteriorated paint, debris or
visible dust?
A: See the visual assessment form. It shows
that there is no debris, or dust because those
conditions were corrected prior to the
examination. In cases where there is
deteriorated paint, the lead sampling technician
has written that the client has said that the paint
6-2
-------
Module 6: Writing and Delivering the Report
Questions Related to the Report
Can the occupants use the area
where work was done?
Does the clearance exam have to
be conducted again?
What are the client's disclosure
responsibilities?
has been tested and found not to be lead-
based paint. Key point: Such conditions
should be corrected before clearance is done.
5. Where does the report provide the Federal
guidance for interior window sills?
A: See the section called "Understanding Your
Report. The Federal guidance for window sills
is 500 ^g/ft2 (micrograms per square foot)."
Key point: It is important to document for
clients what standards were used for their
clearance test.
6. What additional guidance does the report
provide to the client?
A: The report includes factsheets to help
answer client questions on potential sources of
lead exposure, proper cleaning, monitoring
paint, paint repair and frequently asked
questions. Key point: These factsheets provide
important guidance to the client and answer
critical questions that they may have. These
handout factsheets can be found in Appendix
B. Encourage students to include them when
writing reports.
Reference Materials. To close out the activity,
walk quickly through the whole report, pointing out
what is included. Refer students to Appendix B
for a blank report form which includes copies of the
handouts.
How to Deliver the Report
When delivering the report, the client will likely
have questions about what the results mean and
what they should do. This activity starts with a brief
lecture on answers to the most pressing questions
clients may ask. Following this, an activity will
allow students to develop responses to questions
that clients may ask after receiving their clearance
examination report.
Pressing Questions
The following are questions a client is likely to ask
if they fail the clearance examination.
6-3
-------
Lead Sampling Technician Course
f» Activity: Delivering the Report
* • Refer to the Attachment 6-A
[I • Answer the questions
/Determine whether your are trained to
answer each question- check yes or no
J..T /Provide an answer or resource in the
right column
!-• • Provide an answer to the class
Can the occupants use the area where work
was done?
Failing the clearance examination indicates that
lead-contaminated dust is present in the work area.
Using this area puts the unit's occupants in danger
of lead poisoning. HUD generally does not allow
occupants to go into the clearance area until
clearance is passed. In other cases, it is
recommended that people, especially children,
refrain from entering the clearance area. A proper
re-cleaning to remove the lead-contaminated dust
is necessary to remove the problem. A second
clearance examination is recommended after
cleaning, and prior to allowing access to the area
where work was done.
Does sampling have to be conducted again?
A second sampling is strongly recommended to
make sure that the dwelling is safe for occupants to
return. (It is not required, except by HUD, as
discussed in Module 5.)
What are the client's disclosure
responsibilities?
It is the client's responsibility to inform future
occupants or potential homebuyers of the results of
the clearance examination. If a second clearance
test shows levels below the guidance, the results of
the first test must still be disclosed. The second
test should also be disclosed to show that the
problem has been addressed.
Activity # 2: Delivering the Report (10 minutes).
To provide the most accurate and appropriate
answers, lead sampling technicians must
understand what the results of clearance do and do
not indicate and what a lead sampling technician is
qualified to recommend.
1. Refer students to Attachment 6-A: Exercise:
Answering Client Questions in their student
materials.
2. Call on individual students to read and answer
each question. For each question, the student
must first determine whether lead sampling
technicians are trained to answer the question.
If they are qualified to answer the question,
students should provide the answer in the right
6-4
-------
Module 6: Writing and Delivering the Report
Some Resources
• Appendix B: Blank Report Form
and Handouts
/Understanding Your Report
/Sources of Lead in Your Home
/Cleaning Up
/Safe Repair of Paint
/Monitoring and Maintenance
/Frequently Asked Questions
Sj.i*il
-------
Attachment 6-A: Exercise - Answering Client Questions
You have just given your client the clearance examination report and she has a lot of questions
for you. You have been trained to answer some of the questions, but several questions go
beyond the scope of your training. Using what you have learned so far in this course, respond to
each of the questions.
1. Decide whether your training as a lead sampling technician qualifies you to answer the
question and check either "yes" or "no."
2. In the far right column, provide an appropriate response by either answering the question or
referring your client to the appropriate source for further information.
Question
1 . What kind of cleaning
will remove the lead-
contaminated dust?
2. Where is the dust
coming from?
3. If lead contaminated
dust was found to be
below Federal
guidance, does that
mean that my property
is "lead-free?"
4. The results indicated
that lead was
undetectabie, is my
property "lead-free?"
5. Do I have to have
clearance testing done
again?
6. What should I do
about the lead-
contaminated dust?
7. Do I have to tell
anyone else about the
clearance results?
I've been trained
to provide an
answer
Yes
No
if you checked "yes," provide an answer. If
you checked "no," provide a source for
further information.
-------
Pamphlet:
Protect Your Family From Lead in Your Home
-------
U.S. EPA Washington DC 20460
U.S. CPSC Washington DC 20207
U.S. HUD Washington DC 20410
Protect
Your
From
Lead In
Your
Home
United States
Environmental
Protection Agency
United States
Consumer Product
Safety Commission
United States
Department of Housing
and Urban Development
EPA747-K-99-001
April 1999
-------
Are You Planning To Buy, Rent, or Renovate
a Home Built Before 1978?
Many houses and apartments built before 1978 have
paint that contains lead (called lead-based paint). Lead
from paint, chips, and dust can pose serious health
hazards if not taken care of properly.
Federal law requires that individuals receive certain information
before renting, buying, or renovating pre-1978 housing:
LANDLORDS have to disclose known infor-
mation on lead-based paint and lead-based
paint hazards before leases take effect.
Leases must include a disclosure form
about lead-based paint.
SELLERS have to disclose known informa-
tion on lead-based paint and lead-based
paint hazards before selling a house. Sales
contracts must include a disclosure form
about lead-based paint. Buyers have up to
10 days to check for lead hazards.
RENOVATORS have to give you this
pamphlet before starting work. (After
June 1, 1999.)
IF YOU WANT MORE INFORMATION
on these requirements, call the
National Lead Information Clearinghouse
at 1-800-424-LEAD.
This document is in the public domain. It may be reproduced by an individual or
organization without permission. Information provided in this booklet is based
upon current scientific and technical understanding of the issues presented and
is reflective of the jurisdictignat boundaries established by the statutes governing
the co-authoring agencies, Following the advice given will not necessarily pro-
vide complete protection in all situations or against all health hazards that can
be caused by lead exposure.
-------
IMPORTANT!
Lead From Paint, Dust, and
Soil Can Be Dangerous If Not
Managed Properly
FACT: Lead exposure can harm young
children and babies even before they
are bom.
FACT: Even children who seem healthy can
have high levels of lead in their bodies.
FACT: People can get lead in their bodies by
breathing or swallowing lead dust, or by
eating soil or paint chips containing
lead.
FACT: People have many options for reducing
lead hazards. In most cases, lead-based
paint that is in good condition is not a
hazard. '
FACT: Removing lead-based paint improperly
can increase the danger to your family.
If you think your home might have lead
hazards, read this pamphlet to learn some
simple steps to protect your family.
-------
Lead Gets in the Body in Many Ways
In the
United
States,
about
900,000
children ages
1 to 5 have a
blood-lead
level above
the level of
concern.
Even children
who appear
healthy can
have danger-
ous levels of
lead in their
bodies.
People can get lead in their body if they:
^ Put their hands or other objects
covered with lead dust in their mouths.
4- Eat paint chips or soil that contains
lead.
4- Breathe in lead dust (especially during
renovations that disturb painted
surfaces).
Lead is even more dangerous to children
than adults because:
+ Babies and young children often put
their hands and other objects in their
mouths. These objects can have lead
dust on them.
^ Children's growing bodies absorb more
lead,
^ Children's brains and nervous systems
are more sensitive to the damaging
effects of lead,
-------
Lead's Effects
If not detected early, children with high
levels of lead in their bodies can suffer
from:
+ Damage to the brain and
nervous system
+ Behavior and learning
problems (such as hyperactivity)
+ Slowed growth
+ Hearing problems
+ Headaches
Lead is also harmful to adults. Adults
can suffer from:
+ Difficulties during pregnancy
+ Other reproductive problems (in both
men and women)
^ High blood pressure
+ Digestive problems
+ Nerve disorders
^ Memory and concentration problems
+ Muscle and joint pain
i at Nerve Damage
Hwrtng
Lead affects
the body in
many ways.
-------
Where Lead-Based Paint is Found
In general,
the older your
home, the
more likely it
has lead-
based paint.
Many homes built before 1978 have lead-
based paint. The federal government
banned lead-based paint from housing in
1978. Some states stopped its use even
earlier. Lead can be found:
+ In homes in the city, country, or suburbs.
^ In apartments, single-family homes, and
both private and public housing.
+ Inside and outside of the house.
• In soil around a home. (Soil can pick up
lead from exterior paint or other sources
such as past use of leaded gas in cars.)
Checking Your Family for Lead
Get your
children and
home tested
if you think
your home
has high lev-
els of lead.
To reduce your child's exposure to lead,
get your child checked, have your home
tested (especially if your home has paint
in poor condition and was built before
1978), and fix any hazards you may have.
Children's blood lead levels tend to increase
rapidly from 6 to 12 months of age, and
tend to peak at 18 to 24 months of age.
Consult your doctor for advice on testing
your children. A simple blood test can
detect high levels of lead. Blood tests are
usually recommended for:
+ Children at ages I and 2.
^ Children or other family members who
have been exposed to high levels of lead.
+ Children who should be tested under
your state or local health screening plan.
Your doctor can explain what the test results
mean and if more testing will be needed.
-------
Where Lead is Likely To Be a Hazard
Lead-based paint that is in good condition
is usually not a hazard.
Peeling, chipping, chalking, or cracking
lead-based paint is a hazard and needs
immediate attention.
Lead-based paint may also be a hazard
when found on surfaces that children can
chew or that get a lot of wear-and-tear.
These areas include:
+ Windows and window sills.
+ Doors and door frames.
+ Stairs, railings, and banisters.
^ Porches and fences.
Lead dust can form when lead-based paint
is dry scraped, dry sanded, or heated. Dust
also forms when painted surfaces
bump or rub together. Lead chips and
dust can get on surfaces and objects
that people touch. Settled lead dust
can re-enter the air when people vac-
uum, sweep, or walk through it.
Lead in soil can be a hazard when
children play in bare soil or when
people bring soil into the house on
their shoes. Call your state agency
(see page 11} to find out about test-
ing soil for lead.
Lead from
paint chips,
which you
can see, and
lead dust,
which you
can't always
see, can both
be serious
hazards.
vfi/^y/.
-------
Checking Your Home for Lead Hazards
Just knowing
that a home
has lead-
based paint
may not tell
you if there
is a hazard.
You can get your home checked for lead haz-
ards in one of two ways, or both:
^ A paint inspection tells you the lead
content of every different type of painted
surface in your home. It won't tell you
whether the paint is a hazard or how you
should deal with it.
• A risk assessment tells you if there are
any sources of serious lead exposure
(such as peeling paint and lead dust). It
also tells you what actions to take to
address these hazards.
Have qualified professionals do the work.
There are standards in place for certifying
lead-based paint professionals to ensure the
work is done safely, reliably, and effectively.
Contact your state lead poisoning prevention
program for more information. Call 1 -800-
424-LEAD for a list of contacts in your area.
Trained professionals use a range of methods
when checking your home, including:
^ Visual inspection of paint condition and
location.
^ A portable x-ray fluorescence (XRF)
machine.
^ Lab tests of paint samples.
^ Surface dust tests.
Home test kits for lead are available, but
studies suggest that they are not always
accurate. Consumers should not rely on
these tests before doing renovations or to
assure safety.
-------
What You Can Do iMow To Protect
Your Family
If you suspect that your house has lead
hazards, you can take some immediate
steps to reduce your family's risk:
• If you rent, notify your landlord of
peeling or chipping paint.
• Clean up paint chips immediately.
• Clean floors, window frames, window
sills, and other surfaces weekly. Use a
mop or sponge with warm water and a
general all-purpose cleaner or a cleaner
made specifically for lead. REMEMBER:
NEVER MIX AMMONIA AND BLEACH
PRODUCTS TOGETHER SINCE THEY
CAN FORM A DANGEROUS GAS.
• Thoroughly rinse sponges and mop
heads after cleaning dirty or dusty
areas.
• Wash children's hands often, especial-
ly before they eat and before nap time
and bed time.
• Keep play areas clean. Wash bottles,
pacifiers, toys, and stuffed animals
regularly.
+ Keep children from chewing window
sills or other painted surfaces.
• Clean or remove shoes before
entering your home to avoid
tracking in lead from soil.
• Make sure children eat
nutritious, low-fat meals high
in iron and calcium, such as
spinach and dairy products.
Children with good diets absorb J \
less lead. >-
-------
How To Significantly Reduce Lead Hazards
Removing
lead
improperly
can increase
the hazard to
your family
by spreading
even more
tead dust
around the
house,
Always use a
professional who
is trained to
remove lead
hazards safely.
In addition to day-to-day cleaning and good
nutrition:
+ You can temporarily reduce lead hazards
by taking actions such as repairing dam-
aged painted surfaces and planting grass
to cover soil with high lead levels. These
actions (called "interim controls") are not
permanent solutions and will need ongo-
ing attention.
+ To permanently remove lead hazards,
you must hire a certified lead "abate-
ment" contractor. Abatement (or perma-
nent hazard elimination) methods
include removing, sealing, or enclosing
lead-based paint with special materials.
Just painting over the hazard with regular
paint is not enough.
Always hire a person with special training
for correcting lead problems—someone
who knows how to do this work safely and
has the proper equipment to clean up
thoroughly. Certified contractors will employ
qualified workers and follow strict safety
rules as set by their state or by the federal
government.
Call your state agency (see page 11) for
help with locating certified contractors in
your area and to see if financial assistance
is available.
8
-------
Remodeling or Renovating a Home With
Lead-Based Paint
Take precautions before your contractor or
you begin remodeling or renovations that
disturb painted surfaces (such as scraping
off paint or tearing out walls):
• Have the area tested for lead-based
paint.
• Do not use a belt-sander, propane
torch, heat gun, dry scraper, or dry
sandpaper to remove lead-based
paint. These actions create large
amounts of lead dust and fumes. Lead
dust can remain in your home long
after the work is done.
^ Temporarily move your family (espe-
cially children and pregnant women)
out of the apartment or house until
the work is done and the area is prop-
erly cleaned. If you can't move your
family, at least completely seal off the
work area.
+ Follow other safety measures to
reduce lead hazards. You can find out
about other safety measures by calling
1 -800-424-LEAD. Ask for the brochure
"Reducing Lead Hazards When
Remodeling Your Home." This brochure
explains what to do before, during,
and after renovations.
If you have already completed renova-
tions or remodeling that could have
released lead-based paint or dust, get
your young children tested and follow
the steps outlined on page 7 of this
brochure.
If not
conducted
properly,
certain types
of renova-
tions can
release lead
from paint
and dust into
the air,
-------
Other Sources of Lead
While paint, dust,
and soil are the
most common
lead hazards,
other lead
sources also exist.
Drinking water. Your home might have
plumbing with lead or lead solder. Call
your local health department or water
supplier to find out about testing your
water. You cannot see, smell, or taste
lead, and boiling your water will not get
rid of lead. If you think your plumbing
might have lead in it:
• Use only cold water for drinking and
cooking.
• Run water for 15 to 30 seconds
before drinking it, especially if you
have not used your water for a few
hours.
The job. If you work with lead, you
couid bring it home on your hands or
clothes. Shower and change clothes
before coming home. Launder your work
clothes separately from the rest of your
family's clothes.
Old painted toys and furniture.
Food and liquids stored in lead crystal
or iead-glazed pottery or porcelain.
Lead smelters or other industries that
release lead into the air.
Hobbies that use lead, such as making
pottery or stained glass, or refinishing
furniture.
folk remedies that contain lead, such as
"greta" and "azarcon" used to treat an
upset stomach.
10
-------
For More information
The National Lead Information Center
Call 1-800-424-LEAD to learn how to protect
children from lead poisoning and for other
information on lead hazards. (Internet:
www.epa.gov/lead and www.hud.gov/lea).
For the hearing impaired, call the Federal
Information Relay Service at 1 -800-877-
8339 and ask for the National Lead
Information Center at 1-800-424-LEAD.
EPA's Safe Drinking \Afater Hotline
Call 1-800-426-4791 for information about
lead in drinking water.
Consumer Product Safety
Commission Hotline
To request information on lead in
consumer products, or to report an
unsafe consumer product or a prod-
uct-related injury call 1 -800-638-
2772. (Internet: www@cpsc.gov).
For the hearing impaired, call TDD 1
800-638-8270.
State Health and Environmental Agencies
Some cities and states have their own rules for lead-based
paint activities. Check with your state agency to see if state
or local laws apply to you. Most state agencies can also pro-
vide information on finding a lead abatement firm in your
area, and on possible sources of financial aid for reducing
lead hazards. Receive up-to-date address and phone infor-
mation for state and local contacts on the Internet at
www.epa.gov/lead or contact the National Lead Information
Center at 1-800-424-LEAD.
I i
-------
EPA Regional Offices
Your Regional EPA Office can provide further information regard-
ing regulations and lead protection programs.
EPA Regional Offices
Region 1 (Connecticut, Massachusetts,
Maine, New Hampshire, Rhode Island,
Vermont)
Regional Lead Contact
U.S. EPA Region 1
Suite HOO(CPT)
One Congress Street
Boston, MA 02114-2023
I (888) 372-7341
Region 2 (New Jersey, New York,
Puerto Rico, Virgin Islands)
Regional Lead Contact
U.S. EPA Region 2
2890 Woodbridge Avenue
Building 209, Mail Stop 225
Edison, N| 08837-3679
(732) 321-6671
Region 3 (Delaware, Washington DC,
Maryland, Pennsylvania, Virginia, West
Virginia)
Regional Lead Contact
U.S. EPA Region 3 (3WC33)
1650 Arch Street
Philadelphia. PA 19103
(215)814-5000
Region 4 (Alabama, Florida, Georgia.
Kentucky, Mississippi, North Carolina.
South Carolina, Tennessee)
Regional Lead Contact
U.S. EPA Region 4
61 Forsyth Street, SW
Atlanta. GA 30303
(404) 562-8998
Region 5 (Illinois, Indiana, Michigan,
Minnesota, Ohio, Wisconsin)
Regional Lead Contact
U.S. EPA Region 5 (DT-8))
77 West Jackson Boulevard
Chicago, IL 60604-3666
(312)886-6003
12
Region 6 (Arkansas. Louisiana, New
Mexico, Oklahoma. Texas)
Regional Lead Contact
U.S. EPA Region 6
1445 Ross Avenue. 12th Floor
Dallas, TX 75202-2733
(214)665-7577
Region 7 (Iowa. Kansas. Missouri,
Nebraska)
Regional Lead Contact
U.S. EPA Region 7
(ARTD-RALI)
901 N. 5th Street
Kansas City. KS 66101
(913) 551-7020
Region 8 (Colorado, Montana, North
Dakota, South Dakota, Utah, Wyoming)
Regional Lead Contact
U.S. EPA Region 8
999 18th Street, Suite 500
Denver, CO 80202-2466
(303)312-6021
Region 9 (Arizona, California, Hawaii.
Nevada)
Regional Lead Contact
U.S. Region 9
75 Hawthorne Street
San Francisco, CA 94105
(415) 744-1124
Region 10 (Idaho, Oregon, Washington,
Alaska)
Regional Lead Contact
U.S. EPA Region 10
Toxics Section WCM-128
1200 Sixth Avenue
Seattle, WA 98101-1128
(206) 553-1985
-------
CPSC Regional Offices
Your Regional CPSC Office can provide further information regard-
ing regulations and consumer product safety.
Eastern Regional Center
6 World Trade Center
Vfesey Street, Room 350
New York. NY 10048
(212)466-1612
Central Regional Center
230 South Dearborn Street
Room 2944
Chicago. IL 606O4-160I
(312) 353-8260
Western Regional Center
600 Harrison Street. Room 245
San Francisco, CA 94107
(415) 744-2966
HUD Lead Office
Please contact HUD's Office of Lead Hazard Control for informa-
tion on lead regulations, outreach efforts, and lead hazard control
and research grant programs.
U.S. Department of Housing and Urban Development
Office of Lead Hazard Control
451 Seventh Street. SW. P-3206
Washington. DC 20410
(202) 755-1785
!3
-------
Simple Steps To Protect Your Family
From Lead Hazards
If you think your home has high
levels of lead:
Get your young children tested for lead, even if
they seem healthy.
Wash children's hands, bottles, pacifiers, and toys
often.
Make sure children eat healthy, low-fat foods.
Get your home checked for lead hazards.
Regularly clean floors, window sills, and other
surfaces.
Wipe soil off shoes before entering house.
Talk to your landlord about fixing surfaces with
peeling or chipping paint.
Take precautions to avoid exposure to lead dust
when remodeling or renovating (call 1-800-424-
LEAD for guidelines).
Don't use a belt-sander, propane torch, heat gun,
dry scraper, or dry sandpaper on painted surfaces
that may contain lead.
Don't try to remove lead-based paint yourself.
RecycletMRecyclatale
Printed on paper that contains at least 20 percent postconsumer fiber.
-------
40 CFR Part 745:
Lead-Based Paint Hazards
-------
Federal Register / Vol. 63. No. 106 / Wednesday, June 3, 1998 / Proposed Rules
30353
among young children by supporting
the implementation of the national lead
program. Because exposure to lead in
paint, dust, and soil is mostly limited to
children under the age of 6, young
children are, in fact, the primary
beneficiaries of this proposed rule, as
well as the program.
G. National Technology Transfer and
Advancement Act
This proposed regulatory action does
not involve any technical standards that
would require Agency consideration of
voluntary consensus standards pursuant
to section 12(d) of the National
Technology Transfer and Advancement
Act of 1995 (NTTAA), Pub. L. 104-113.
section 12(d) (15 U.S.C. 272 note).
Section 12(d) directs EPA to use
voluntary consensus standards in its
regulatory activities unless to do so
would be inconsistent with applicable
law or otherwise impractical. Voluntary
consensus standards are technical
standards (e.g., materials specifications,
test methods, sampling procedures,
business practices, etc.) that are
developed or adopted by voluntary
consensus standards bodies. The
NTTAA requires EPA to provide
Congress, through OMB. explanations
when the Agency decides not to use
available and applicable voluntary
consensus standards. EPA invites public
comment on this conclusion.
List of Subjects in Part 745
Environmental protection. Hazardous
substances. Lead-based paint, Lead
poisoning. Reporting and recordkeeping
requirements.
Dated: May 26, 1998.
Carol M. Browner.
Administrator.
Therefore, it is proposed that 40 CFR
part 745 be amended as follows:
PART 745—[AMENDED]
1. The authority citation for part 745
continues to read as follows:
Authority: 15 U.S.C. 2605, 2607. 2615.
2681-2692 and U.S.C. 4852d.
2. By adding new subpart D to read
as follows:
Subpart D—Lead-Based Paint Hazards
Sec.
745.61 Scope and applicability.
745.63 Definitions.
745.65 Lead-based paint hazards.
745.69 Determining whether lead-based
paint hazards are preseni.
Subpart D—Lead-Based Paint Hazards
§ 745.61 Scope and applicability.
(a) This subpart identifies lead-based
paint hazards.
(b) The standards for lead-based paint
hazards apply to target housing and
child-occupied facilities.
(c) Nothing in this subpart requires
any person to evaluate the property(ies)
for the presence of lead-based paint
hazards or to take any action to control
these conditions if one or more of them
is identified.
§745.63 Definitions.
The following definitions apply to
this subpart.
Arithmetic mean means the algebraic
sum of data values divided by the
number of data values (e.g., the sum of
the concentration of lead in several soil
samples divided by the number of
samples).
Certified risk assessor means an
individual who has been trained by an
accredited training program, as defined
by § 745.223, and certified by EPA
pursuant to § 745.226 or by an
authorized State or Tribal program to
conduct risk assessments. A certified
risk assessor also samples for the
presence of lead in dust and soil for the
purposes of abatement clearance testing.
Child-occupied facility means a
building, or portion of a building.
constructed prior to 1978, visited
regularly by the same child, 6 years of
age or under, on at least two different
days within any week (Sunday through
Saturday period), provided that each
day's visit lasts at least 3 hours and the
combined weekly visit lasts at least 6
hours, and the combined annual visits
last at least 60 hours. Child-occupied
facilities may include, but are not
limited to, day-care centers, preschools,
and kindergarten classrooms.
Deteriorated paint means paint that is
cracking, flaking, chipping, peeling, or
otherwise separating from the substrate
of a building component.
Interior window sill means the portion
of the horizontal window ledge that
protrudes into the interior of the room.
Lead-based paint means paint or
other surface coatings that contain lead
equal to or exceeding 1.0 milligram per
square centimeter or 0.5 percent by
weight.
Lead-based paint hazard means
hazardous lead-based paint, a dust-lead
hazard, or a soil-lead hazard as
described in § 745.65.
Paint in poor condition means more
than 10 square feet of deteriorated paint
on exterior components with large
surface areas; or more than 2 square feet
of deteriorated paint on interior
components with large surface areas
(e.g., walls, ceilings, floors, doors); or
more than 10 percent of the total surface
area of the component is deteriorated on
interior or exterior components with
small surface areas (e.g., window sills,
baseboards, soffits, trim).
Risk assessment means an on-site
investigation to determine the existence,
nature, severity, and location of lead-
based paint hazards, and the provision
of a report by the individual or the firm
conducting the risk assessment,
explaining the results of the
investigation and options for reducing
lead-based paint hazards.
Target housing means any housing
constructed prior to 1978. except
housing for the elderly or persons with
disabilities (unless any one or more
children age 6 years or under resides or
is expected to reside in such housing for
the elderly or persons with disabilities)
or any 0-bedroom dwelling.
Weighted arithmetic mean means the
arithmetic mean of sample results
weighted by the number of subsamples
in each sample. Its purpose is to give
influence to a sample relative to the
number of subsamples it contains. A
single surface sample is comprised of a
single subsample. A composite sample
may contain from two to four
subsamples. The weighted arithmetic
mean is obtained by summing for all
samples, the product of the sample's
result multiplied by the number of
subsamples in the sample, and dividing
the sum by the total number of
subsamples contained in all samples.
For example, the weighted arithmetic
mean of a single surface sample
containing 60 Ug/ft2, a composite sample
(3 subsamples) containing 100 jig/ft3,
and a composite sample (4 subsamples)
containing 110 |ag/ft2 is 100 Ug/ft2. This
result is based on the equation
[60+(3*100)+(4* 110)]/8.
Wipe sample means a sample
collected by wiping a representative
surface of known area with an
acceptable wipe material (e.g., moist
towelette).
§ 745.65 Lead-based paint hazards.
(a) Hazardous lead-based paint.
Hazardous lead-based paint is lead-
based paint in poor condition.
(b) Dust-lead hazard. A dust-lead
hazard is dust that contains lead equal
to or exceeding 50 Mg/ft2 on uncarpeted
floors or 250 ng/ft2 on interior window
sills based on wipe samples.
(c) Soil-lead hazard. A soil-lead
hazard is bare soil that contains total
lead equal to or exceeding 2.000 parts
per million.
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The Lead-Based Paint
Pre-Renovation Education Rule
-------
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Disclosure Forms on Lead-Based Paint and/or
Lead-Based Paint Hazards
-------
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 known 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
(a) Presence of lead-based paint and/or lead-based paint hazards (check (i) or (ii) below):
(i) Known lead-based paint and/or lead-based paint hazards are present in the housing
(explain).
(ii) 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 (!) or (ii) below):
(i) 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 (initial)
(c) Lessee has received copies of all information listed above.
(d) Lessee has received the pamphlet Protect Your Family from Lead in Your Home.
Agents Acknowledgment (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
The following parties have reviewed the information above and certify, to the best of their knowledge, that
the information they have provided is true and accurate.
Lessor
Lessee
Agent
Date
Date
Date
Lessor
Lessee
Agent
Date
Date
Date
-------
Disclosure of Information on Lead-Based Paint and/or Lead-Based Paint Hazards
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
(a) Presence of lead-based paint and/or lead-based paint hazards (check (i) or (ii) below):
(i) Known lead-based paint and/or lead-based paint hazards are present in the housing
(explain).
(ii) 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 (i) or (ii) below):
(i) 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).
(ii) Seller has no reports or records pertaining to lead-based paint and/or lead-based paint
hazards in the housing.
Purchaser's Acknowledgment (initial)
(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 (i) or (ii) below):
0) received a 10-day opportunity (or mutually agreed upon period) to conduct a risk assess-
ment or inspection for the presence of lead-based paint and/or lead-based paint hazards; or
(ii) 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 (initial)
(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
The following parties have reviewed the information above and certify, to the best of their knowledge, that the
information they have provided is true and accurate.
Seller
Date
Seller
Date
Purchaser
Date
Purchaser
Date
Agent
Date
Agent
Date
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Blank Report Form
The following is a blank report form that you can use to write your clearance reports.
Photocopy it as needed, fill in the appropriate information, and attach appropriate reports
and handouts.
1. Fill out the cover page:
* Name of your firm with contact information and certification number
* Name and certification number of the Lead Sampling Technician
* Client and property information
« Name, address, and certification number of the lab used
* Summary table with results of the dust sampling. Only copy in the items that did
not pass clearance.
2. Attach the following:
* Dust Sampling Results form (from the lab)
* Visual Assessment Form (from your visual assessment)
* Understanding Your Report (included in this blank form)
• Handouts (also included in this blank form)
Handouts
The handouts included in the blank report form are useful factsheets that can be given to
clients to provide additional information about lead-based paint and how to address it.
They can be given to clients before the exam and they can also be attached to reports
as shown in Appendix C. The handouts include:
* Handout 1: What Are the Sources of Lead in Your Home?
* Handout 2: Cleaning Up
* Handout 3: Safe Repair and Maintenance of Lead-Based Paint
* Handout 4: Ongoing Monitoring and Maintenance
* Handout 5: Frequently Asked Questions
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Name, Address and Phone Number of the Clearance Firm:
Firm certification number:
CLEARANCE EXAMINATION REPORT
Date of inspection:
Lead Sampling
Technician:
Certification number:
Property address:
Apartment:
Client name:
Client address:
Laboratory:
Address:
Telephone number:
NLLAP number:
SUMMARY RESULTS
Lead-contaminated dust was found in the following areas:
Location
Surface
Mg lead/ft"
Signature:
Date:
-------
VISUAL ASSESSMENT
Date of clearance:
Clearance Technician:
Client:
Property address:
Location
Entry Area
Living Room
Dining Room
Kitchen
Common Area
Bedroom #1
Bedroom #2
Bath #1
Exterior
Identify visible areas of dust, paint chips, painted debris, and
deteriorated paint. (Note location: walls, ceiling, floors, doors,
windows, trim, cabinets, etc.)
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Attach Laboratory Results Here.
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Understanding Your Report
1 .
2.
3.
4.
The Summary Results section lists all of the areas that failed the clearance
examination. The entire area represented by the sample needs to be re-cleaned and
then re-tested to see if the cleaning removed the contaminated dust.
Written information on proper cleaning, monitoring, addressing sources of lead in the
home, and safe repair of paint are included with this report. Further information can
be obtained by contacting the National Lead Information Center Clearinghouse at 1-
800-424-Lead (1-800-424-5323). You may consider hiring a risk assessor to
evaluate lead hazards in your home and prepare a lead hazard control plan. Risk
assessors in your area can be located through the Lead Listing at 1-888-Leadlist (1-
888-532-3547).
The laboratory result forms attached to the report list all of the areas sampled inside
and outside the dwelling and the laboratory analysis results for each sample.
The results of dust wipe samples are presented in micrograms per square foot
(/ug/ft2); soil samples are presented in micrograms per gram
Areas that failed the clearance examination showed lead levels in dust or soil at or
above Federal guidance, HUD standards, or state standards. The guidance and
standards that were used for this clearance examination are:
Federal (EPA) Guidance for Lead in Dust
Floors: 100^g/ft
Interior window sill (stool): 500 /ug/ft2
Window trough: 800^g/ft2
HUD Standards for Lead in Dust*
Floors: 40
Interior window sill (stool): 250 ,ug/ft
Window trough: 800/^g/ft2
*For dwellings that receive funding from the U.S. Department
of Housing and Urban Development (HUD), standards set by
HUD may apply.
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Handout #1
What Are the Sources of Lead in Your Home?
There are four major sources of lead that can pose a health hazard to people in and around the home. The
sources are:
1. Lead-based paint. Lead-based paint can be found in housing built before 1978. It can be a hazard,
especially if it deteriorates or, if it is disturbed during maintenance or normal wear and tear. If lead-
based paint is peeling, chipping, chalking or cracking, it will create lead-contaminated dust that poisons
children through normal hand-to-mouth activity. Children may also eat paint chips or chew on painted
surfaces that are accessible to them, resulting in poisoning. Even lead-based paint that appears to be
in good condition can be a problem if it is on surfaces that get a lot of wear and tear, such as door
jambs and window tracks. It is important to remove the causes of deteriorating paint such as water
leaks. Repair areas where lead paint is deteriorating by repainting using a good latex paint or lead
sealer. (See Handout #3 on safe paint repair).
2. Lead-contaminated dust. Lead-contaminated dust is created when lead-based paint is sanded or
scraped during maintenance or repair, or just through every day wear and tear. When maintenance or
renovation takes place, the dust from these operations settles on surfaces such as floors, countertops,
window sills and furniture. If the paint being worked on contains lead, the lead is deposited on surfaces
as dust. Window tracks and door jambs can be another source of lead-contaminated dust. If these
components rub during normal opening and closing, lead-contaminated dust can be created and
deposited on surfaces throughout the home. Lead from work done on house exteriors can be tracked
into the home, becoming an additional source of lead dust. After routine home maintenance or
remodeling renovation and painting, the home should be thoroughly cleaned to remove any dust that
may be left behind because it may contain lead. Lead dust sampling should then be performed to verify
that the cleaning was effective.
3. Lead-contaminated soil. Soil can become contaminated when exterior lead-based deteriorates and
gets into the soil. Homes near certain industries such as smelters or battery manufacturers may have
lead into the soil as a result of these operations. Past use of leaded gasoline has also left lead deposits
in our nation's soil. Playgrounds and gardens should not be placed in areas where the soil is
contaminated with lead. Soil can be tracked into the home so it is important for workers to clean shoes
or remove them before entering the home.
4. Lead-contaminated drinking water. Drinking water can be contaminated with lead, regardless of the
water's source. Many faucets in homes and on store shelves contain leaded components that can
leach lead into the water. Leaded solder in household piping and leaded components in well pumps
have been in use for many years, and continue to leach lead into the drinking water of thousands of
homes even today. Many public water delivery systems still have old lead piping through which the
water must pass before it reaches the home. Water with a high pH has a tendency to leach more lead
than water with a neutral pH, and warm water leaches more lead than cold. Allow cold water to run
before drinking.
The following are sources of information about lead-based paint in your home:
* National Lead Information Center (NLIC) - 1-800-424-LEAD (1-800-424-5323). NLIC is a
clearinghouse for information on lead. They provide copies of pamphlets, reports, and other resources.
» Safe Drinking Water Hotline -1 -800-426-4791. This hotline provides information and assistance to the
public on safe drinking water.
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Handout#2
CLEANING UP
It is very important to use proper cleanup procedures at the end of any remodeling, repainting, or
maintenance job. Dust and paint chips left behind at the end of the job may contain lead and may endanger
children. Have dust wipe samples collected at the end of the job to be sure that it is safe for children to
return.
Cleaning the Work Area
1. Pick Up Work Area
• Pick up large chips with damp paper towel.
• Mist then push dust into dust pan.
2. Pick Up Protective Sheeting
* Clean off protective sheeting. Fold dirty side inward (dirty side to dirty side). Dispose of protective
sheeting at the end of each job. Protective sheeting may be used gain within the same work area if it
has not already been folded.
3. Vacuum
* HEPA vacuum all horizontal surfaces—slowly.
• Vacuum all ledges, sills, stools, molding tops, dusty surfaces, etc.
• Vacuum floor under work area. Use vacuum comer tools in comers, cracks of trim, and between floor
boards.
• Vacuum floor with floor brush and carpet with a carpet tool.
* Important: Vacuum carpet very slowly.
4. Mist and Scrub
* Wet rag with detergent then wring out.
• Mist surface or rag as you clean.
• Lead needs scrubbing, not just wiping.
5. Rinse Rag
• Squeeze rag into empty side of split bucket. Rinse out rag. Squeeze into empty side. Repeat as
needed.
• Change rinse water often. Use paper towels first if surfaces are very dirty. Replace rag when it looks
dirty.
• Recommendation: Make a final pass with a HEPA vacuum.
Cleaning Floors
1. Mist and Scrub
* At start of cleaning, soak mop in detergent water then mist small area with detergent before mopping.
* Scrub with mop.
• Squeeze mop into empty bucket then rise in rinse water. Rinse often. Squeeze out and rinse again.
Mop small areas at a time.
2. Rinse
• Repeat above process using clean water rather than detergent. When cleaning up a work site, use a
new mop head for rinse stage.
• Recommendation: Make a final pass with a HEPA vacuum.
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Handout#3
Safe Repair and Maintenance of Lead-Based Paint
Repairing, removing or maintaining lead-based paint improperly can spread lead-contaminated
dust throughout the home. It is very important to use safe work methods when working on
surfaces that may contain lead-based paint.
1. Use the proper equipment. You will need the proper tools and supplies to do the job
correctly. In addition to tools such as scrapers and putty knives, it is important to have: A
HEPA vacuum (a vacuum equipped with a very fine filter capable of filtering very small
particles of lead); double sided mop bucket and mop; a good household detergent; ample
disposable paper towels or rags; plastic sheeting; tack cloth; disposal waste bags; wet sanding
blocks; and misting bottle filled with water.
2. Set up the work area property. The key is to contain the dust and debris created by the
work. Create a barrier between the work area and the rest of the house. Use plastic sheeting
over the doorways to seal off the area and protect the rest of the house from exposure. Work
over a plastic drop cloth (never use cloth) to catch any debris created as a result of paint
removal. Wear disposable shoe covers and remove them before exiting the work area, or step
onto a tack cloth to remove paint chips and dust from the soles of shoes. Keep doors and
windows closed to prevent dust from blowing and close off vents to central air or heating
systems to avoid spreading dust to other parts of the house. Remove all furniture, or cover
tightly with plastic sheeting. Do not allow children or pregnant women into the work area.
3. Safe work practices. Never remove lead-based paint by dry-sanding, dry scraping or
burning. Use power sanders, grinders, planers only with a HEPA exhaust attachment. Using
your misting bottle, wet the painted surface before sanding with a wet sanding block, or
scraping. Be sure to work over a plastic drop cloth to catch any large particles. Do not eat,
smoke or chew gum while working.
4. Clean as you work. Be sure to wet clean the areas you are working on as you go along.
Though it will be necessary to clean the entire house at the end of the project, it is important to
clean as you work in order to keep lead-contaminated dust from spreading. Clean using a
good household detergent. Rinse your cleaning utensils in clean water.
5. Proper disposal. When the work is done, mist the plastic sheeting with water to keep down
the dust. Roll the plastic sheet up, keeping the dirty side in. Pick up any paint chips or other
debris that may have fallen elsewhere. Be sure to place all disposable items used in the repair
and clean up into plastic waste bags. The bags must be tightly sealed and properly can be
disposed of with the household trash*, Once the bags are sealed, do not reopen them.
6. Have dust sampling done. You should have dust sampling done after all renovations,
painting, maintenance and cleaning activities. The results of this test will tell you if your work
practices and final cleaning have been effective at removing lead-contaminated dust. Since
lead dust levels in the home may change over time, it is strongly suggested that you perform
dust testing periodically to help safeguard your family. If lead-contaminated dust levels begin
to rise, re-inspect the home for deteriorating paint, repair where necessary repeating the steps
outlined in this fact sheet, and be sure to wet clean thoroughly.
*Check with your State lead program to make sure that there is no regulation prohibiting this in your state.
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Handout #4
Ongoing Monitoring and Maintenance
Take the following steps to make sure that paint is not deteriorating in your home and creating
lead-contaminated dust and paint chips. This will help prevent children from being lead poisoned.
1. Regularly Check Repairs for Deterioration, Paint Chips, and Dust
Property owners should regularly monitor painted surfaces where maintenance or
improvements were performed. Check to see if:
* New evidence of deterioration or paint failure is present.
* The cause of the problem was corrected.
4 Lead dust hazards are present. Important: This can only be done by dust wipe
sampling.
2. Maintain Surfaces and Thoroughly Clean
Then:
« Perform repairs, as needed, to maintain surfaces in a smooth and cleanable condition
using safe work methods; and
* Clean the area thoroughly using safe cleaning practices.
3. Methods of Monitoring
Follow the these steps to check your work:
* Conduct Visual Check. Look for deterioration, paint failure, dust and paint chips.
* Test for Lead Dust. Have dust wipe samples taken to check for dust that may be
contaminated with lead. A test is needed to determine when dust contains harmful
amounts of lead.
4. When to Monitor?
* Annually. Perform a visual check of past repairs and improvements involving painted
surfaces.
• During Unit Turnover or Routine Maintenance. Perform a visual check of past
repairs and improvements involving painted surfaces.
+ Every Two Years. Get a dust wipe done at least every two years. This type of test is
strongly recommended when a young child or pregnant women lives in the home.
5. Why is it Important to Monitor and Maintain Work?
Monitoring and maintenance helps:
* Plan and implement maintenance tasks
* Protect occupants and neighbors, particularly children, from lead exposure
» Give owners, contractors, and residents a record of the condition of the unit
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Handout #5:
Frequently Asked Questions about Clearance Examinations
Question
Answer
1. If lead-contaminated
dust was found to be
below Federal standards,
does that mean that my
property is "lead-free?"
No. Lead-based paint may be present. The lower levels can still be dangerous, and
the sources of dust may still be present. Because the clearance tested for levels of
lead in dust at the time samples were taken, the levels could change over time.
2, The results indicated
that lead was
undetectable, is my
property "lead-free?"
No, only paint testing can determine for certain whether a property is free of lead-
based paint. A clearance test only tests for the presence of lead in dust at the time of
testing. Lead in dust could exist later.
3. Where did the dust
come from?
Dust can come from many sources including renovation or maintenance work, lack of
regular cleaning, deteriorated painted surfaces, or sources from outside the property.
The test does not evaluate the quality or effectiveness of renovation or maintenance
or the state of existing building conditions. Only a certified/licensed risk assessor is
qualified to determine the source of lead dust. If the clearance test occurred right
after maintenance or renovation work was done, a thorough re-cleaning and second
clearance test may be the most prudent course of action.
4, What kind of cleaning
will remove the lead dust?
See the advice on proper cleaning is also provided as Handout #2.
5. Who is responsible for
removing the dust?
The property owner is ultimately responsible. If the owner has an agreement with a
contractor who just performed work, the contractor may have to perform another
cleaning and have the clearance test conducted again.
6. The clearance report
shows lead in dust above
the Federal standards.
What should I do?
The answer to this question depends on whether clearance was performed for HUD-
related work or not.
For non-HUD projects: There are no regulatory requirements to respond to lead-
contaminated dust. However, a proper re-cleaning is recommended to remove the
lead-contaminated dust and make the home safe for occupancy. A second clearance
test after re-cleaning is recommended. A property owner must disclose to future
occupants or potential homebuyers the results of the clearance testing. If a second
clearance test shows levels below the standards, this result should also be disclosed
to show that you have dealt with the lead hazard.
For HUD-related clearance. Proper re-cleaning followed by another clearance
examination is required. The unit must be re-cleaned and clearance performed until
the clearance shows no lead dust above the HUD standards. If the clearance
examination identifies lead-contaminated dust, owners of rental properties must
inform the occupants of the results of the clearance examinations even if the lead
dust was successfully removed. It is important that occupants be aware that there
has been lead-contaminated dust in the property because it could occur again in the
future.
7. What should I do to
monitor the lead-based
paint hazards?
If paint is disturbed in the future, follow lead-safe work practices and conduct
clearance again. If a child under six or a pregnant woman moves into the unit,
consider having dust wipe samples collected and tested for lead-contaminated dust.
If you want to know more about lead hazards or lead-based paint in the unit, consider
hiring a certified risk assessor or lead paint inspector.
8. Should I keep the
report? For how long?
The report should be kept as a reference in case issues arise later. For example,
you may need it to comply with Federal disclosure requirements if you rent or sell
your home. For work on HUD projects, the report documents whether a unit meets
HUD requirements for clearance after rehabilitation or maintenance. In any case, it is
most prudent to plan to keep the report indefinitely.
-------
Model Clearance Examination Report
This is a model clearance examination report for clearance done after renovation on a
privately owned rented single-family home. The renovation was paid for by the property
owner.
Renovation work was performed on the upstairs bedrooms and kitchen area. It included
work on the windows. Because workers may have contaminated the upstairs hallway
as they passed through the hallway on their way to and from the work areas, the
clearance examination also included the hallway.
Note that this report includes:
* A cover page with summary
* Copies of all test results
* Handouts - fact sheets with useful additional information
-------
Home Environmental Inspection Services, Inc.
345 Hammond Road
East Chicago, IN 12345
123-123-1235
345-789-5678 (fax)
Firm certification number: IN 78787
CLEARANCE EXAMINATION REPORT
Date of inspection:
Lead Sampling
Technician:
Certification number:
Property address:
Apartment:
Client name:
Client address:
Laboratory:
Address:
Telephone number:
NLLAP number:
8/5/99
Joe Smith
IN 77777
78 East Main St., Apt. A
Hammond, IN 89898
A
Sally Jones
80 East Main St.
Hammond, IN 89898
Analysis Services, Inc.
990 45tn St., Suite 500
Gary, IN 44444
222-222-2222
IN 999999
Summary Results
Dust above Federal standards was found in the following areas:
Location
Small bedroom
Small bedroom
Kitchen
Second floor hallway
Surface
Side facing window- sill
Floor
Window above sink-- sill
Floor
Atg lead/ft2
600
200
525
150
Signature: floe.£»utlt
Date: 8/13J99
-------
VISUAL ASSESSMENT FORM
Date of clearance:
Clearance Technician:
Client:
Property address:
8/5/99
Joe Smith
Salty Jones
78 East Main
Hammond, IN
St., Apt. A
89898
Location
Entry Area
Living Room
Dining Room
Kitchen
Common Area
Bedroom #1
Small bedroom
(Street Side)
Bedroom #2
Small bedroom
(Back of the house)
Bath #1
Exterior
Identify visible areas of dust, paint chips, painted debris, and
deteriorated paint. (Note location: walls, ceiling, floors, doors,
windows, trim, cabinets, etc.)
Window above sink; deteriorated paint on window sash; Client
said deteriorated paint was tested and is not lead-based paint
East window: deteriorated paint on lower sash; Cl ient said
deteriorated paint was tested and is not lead-based paint
Ok
-------
DUST SAMPLING RESULTS FORM
Date of clearance:
Lead Sampling
Technician:
Client:
Property address:
8/5/99
floeSmttk
golly $o«e4.
78 CaAtM&iti St., Apt. A
JlatK*HG«dr Oft 89898
Sample #
1-3
1-3
1-4
3-1
3-1
4-1
4-3.
5-1
Location
fyp&t&iM,
4*n
-------
Understanding Your Report
1. The Summary Results section lists all of the areas that failed the clearance
examination. The entire area represented by the sample needs to be re-cleaned and
then re-tested to see if the cleaning removed the contaminated dust.
Written information on proper cleaning, monitoring, addressing sources of lead in the
home, and safe repair of paint are included with this report. Further information can
be obtained by contacting the National Lead Information Center Clearinghouse at 1-
800-424-Lead (1-800-424-5323). You may consider hiring a risk assessor to
evaluate lead hazards in your home and prepare a lead hazard control plan. Risk
assessors in your area can be located through the Lead Listing at 1-888-Leadlist (1-
888-532-3547).
2. The laboratory result forms attached to the report list all of the areas sampled inside
and outside the dwelling and the laboratory analysis results for each sample.
3. The results of dust wipe samples are presented in micrograms per square foot
tug/ft2); soil samples are presented in micrograms per gram (yug/g).
4. Areas that failed the clearance examination showed lead levels in dust or soil at or
above Federal guidance, HUD standards, or state standards. The guidance and
standards that were used for this clearance examination are:
Federal (EPA) Guidance for Lead in Dust
Floors:
Interior window sill (stool): 500
Window trough:
HUD Standards for Lead in Dust*
Floors: 40 ,ug/ft2
Interior window sill (stool): 250 jug/ft2
Window trough: 800/^g/ft2
*For dwellings that receive funding from the U.S. Department
of Housing and Urban Development (HUD), standards set by
HUD may apply.
-------
Handout#1
What Are the Sources of Lead in Your Home?
There are four major sources of lead that can pose a health hazard to people in and around the home. The
sources are:
1. Lead-based paint. Lead-based paint can be found in housing built before 1978. It can be a hazard,
especially if it deteriorates or, if it is disturbed during maintenance or normal wear and tear. If lead-
based paint is peeling, chipping, chalking or cracking, it will create lead-contaminated dust that poisons
children through normal hand-to-mouth activity. Children may also eat paint chips or chew on painted
surfaces that are accessible to them, resulting in poisoning. Even lead-based paint that appears to be
in good condition can be a problem if it is on surfaces that get a lot of wear and tear, such as door
jambs and window tracks. It is important to remove the causes of deteriorating paint such as water
leaks. Repair areas where lead paint is deteriorating by repainting using a good latex paint or lead
sealer. (See Handout #3 on safe paint repair).
2. Lead-contaminated dust. Lead-contaminated dust is created when lead-based paint is sanded or
scraped during maintenance or repair, or just through every day wear and tear. When maintenance or
renovation takes place, the dust from these operations settles on surfaces such as floors, countertops,
window sills and furniture. If the paint being worked on contains lead, the lead is deposited on surfaces
as dust. Window tracks and door jambs can be another source of lead-contaminated dust. If these
components rub during normal opening and closing, lead-contaminated dust can be created and
deposited on surfaces throughout the home. Lead from work done on house exteriors can be tracked
into the home, becoming an additional source of lead dust. After routine home maintenance or
remodeling renovation and painting, the home should be thoroughly cleaned to remove any dust that
may be left behind because it may contain lead. Lead dust sampling should then be performed to
verify that the cleaning was effective.
3. Lead-contaminated soil. Soil can become contaminated when exterior lead-based deteriorates and
gets into the soil. Homes near certain industries such as smelters or battery manufacturers may have
lead into the soil as a result of these operations. Past use of leaded gasoline has also left lead
deposits in our nation's soil. Playgrounds and gardens should not be placed in areas where the soil is
contaminated with lead. Soil can be tracked into the home so it is important for workers to clean shoes
or remove them before entering the home.
4. Lead-contaminated drinking water. Drinking water can be contaminated with lead, regardless of the
water's source. Many faucets in homes and on store shelves contain leaded components that can
leach lead into the water. Leaded solder in household piping and leaded components in well pumps
have been in use for many years, and continue to leach lead into the drinking water of thousands of
homes even today. Many public water delivery systems still have old lead piping through which the
water must pass before it reaches the home. Water with a high pH has a tendency to leach more lead
than water with a neutral pH, and warm water leaches more lead than cold. Allow cold water to run
before drinking.
The following are sources of information about lead-based paint in your home:
* National Lead Information Center (NLIC) - 1-800-424-LEAD (1-800-424-5323). NLIC is a clearinghouse for
information on lead. They provide copies of pamphlets, reports, and other resources.
* Safe Drinking Water Hotline -1-800-426-4791. This hotline provides information and assistance to the public on
safe drinking water.
-------
Handout #2
CLEANING UP
It is very important to use proper cleanup procedures at the end of any remodeling, repainting, or maintenance job.
Dust and paint chips left behind at the end of the job may contain lead and may endanger children. Have dust wipe
samples collected at the end of the job to be sure that it is safe for children to return.
Cleaning the Work Area
1. Pick Up Work Area
* Pick up large chips with damp paper towel.
• Mist then push dust into dust pan
2. Pick Up Protective Sheeting
• Clean off protective sheeting. Fold dirty side inward (dirty side to dirty side). Dispose of protective sheeting at
the end of each job. Protective sheeting may be used gain within the same work area if it has not already been
folded.
3. Vacuum
* HEPA vacuum all horizontal surfaces—slowly.
• Vacuum all ledges, sills, stools, molding tops, dusty surfaces, etc.
• Vacuum floor under work area. Use vacuum corner tools in comers, cracks of trim, and between floor boards.
* Vacuum floor with floor brush and carpet with a carpet toot.
* Important: Vacuum carpet very slowly.
4. Mist and Scrub
* Wet rag with detergent then wring out.
• Mist surface or rag as you clean.
• Lead needs scrubbing, not just wiping.
5. Rinse Rag
* Squeeze rag into empty side of split bucket. Rinse out rag. Squeeze into empty side. Repeat as needed.
» Change rinse water often. Use paper towels first if surfaces are very dirty. Replace rag when it looks dirty,
• Recommendation: Make a final pass with a HEPA vacuum.
Cleaning Floors
1. Mist and Scrub
* At start of cleaning, soak mop in detergent water then mist small area with detergent before mopping.
* Scrub with mop.
* Squeeze mop into empty bucket then rise in rinse water. Rinse often. Squeeze out and rinse again. Mop small
areas at a time,
2, Rinse
* Repeat above process using clean water rather than detergent. When cleaning up a work site, use a new mop
head for rinse stage.
* Recommendation: Make a final pass with a HEPA vacuum.
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Handout#3
Safe Repair and Maintenance of Lead-Based Paint
Repairing, removing or maintaining lead-based paint improperly can spread lead-contaminated dust
throughout the home. It is very important to use safe work methods when working on surfaces that may
contain lead-based paint.
1. Use the proper equipment. You will need the proper tools and supplies to do the job correctly. In
addition to tools such as scrapers and putty knives, it is important to have: A HEPA vacuum (a vacuum
equipped with a very fine filter capable of filtering very small particles of lead); double sided mop bucket
and mop; a good household detergent; ample disposable paper towels or rags; plastic sheeting; tack
cloth; disposal waste bags; wet sanding blocks; and misting bottle filled with water.
2. Set up the work area property. The key is to contain the dust and debris created by the work.
Create a barrier between the work area and the rest of the house. Use plastic sheeting over the
doorways to seal off the area and protect the rest of the house from exposure. Work over a plastic
drop cloth (never use cloth) to catch any debris created as a result of paint removal. Wear disposable
shoe covers and remove them before exiting the work area, or step onto a tack cloth to remove paint
chips and dust from the soles of shoes. Keep doors and windows closed to prevent dust from blowing
and close off vents to central air or heating systems to avoid spreading dust to other parts of the house.
Remove all furniture, or cover tightly with plastic sheeting. Do not allow children or pregnant women
into the work area.
3. Safe work practices. Never remove lead-based paint by dry-sanding, dry scraping or burning. Use
power sanders, grinders, planers only with a HEPA exhaust attachment. Using your misting bottle, wet
the painted surface before sanding with a wet sanding block, or scraping. Be sure to work over a
plastic drop cloth to catch any large particles. Do not eat, smoke or chew gum while working.
4. Clean as you work. Be sure to wet clean the areas you are working on as you go along. Though it
will be necessary to clean the entire house at the end of the project, it is important to clean as you work
in order to keep lead-contaminated dust from spreading. Clean using a good household detergent.
Rinse your cleaning utensils in clean water.
5. Proper disposal. When the work is done, mist the plastic sheeting with water to keep down the dust.
Roll the plastic sheet up, keeping the dirty side in, Pick up any paint chips or other debris that may
have fallen elsewhere. Be sure to place all disposable items used in the repair and clean up into
plastic waste bags. The bags must be tightly sealed and properly can be disposed of with the
household trash. Once the bags are sealed, do not reopen them,
6. Have dust sampling done. You should have dust sampling done after all renovations, painting,
maintenance and cleaning activities. The results of this test will tell you if your work practices and final
cleaning have been effective at removing lead-contaminated dust. Since lead dust levels in the home
may change over time, it is strongly suggested that you perform dust testing periodically to help
safeguard your family. If lead-contaminated dust levels begin to rise, re-inspect the home for
deteriorating paint, repair where necessary repeating the steps outlined in this fact sheet, and be sure
to wet clean thoroughly.
'Check with your State lead program to make sure that there is no regulation prohibiting this in your state.
-------
Handout #4
Ongoing Monitoring and Maintenance
Take the following steps to make sure that paint is not deteriorating in your home and creating lead-
contaminated dust and paint chips. This will help prevent children from being lead poisoned.
1. Regularly Check Repairs for Deterioration, Paint Chips, and Dust
Property owners should regularly monitor painted surfaces where maintenance or improvements were
performed. Check to see if:
4 New evidence of deterioration or paint failure is present.
4 The cause of the problem was corrected.
4 Lead dust hazards are present. Important: This can only be done by dust wipe sampling.
2. Maintain Surfaces and Thoroughly Clean
Then:
4 Perform repairs, as needed, to maintain surfaces in a smooth and cleanable condition using safe
work methods; and
4 Clean the area thoroughly using safe cleaning practices.
3. Methods of Monitoring
Follow the these steps to check your work:
• Conduct Visual Check. Look for deterioration, paint failure, dust and paint chips.
• Test for Lead Dust. Have dust wipe samples taken to check for dust that may be contaminated
with lead. A test is needed to determine when dust contains harmful amounts of lead.
4. When to Monitor?
4 Annually. Perform a visual check of past repairs and improvements involving painted surfaces.
• During Unit Turnover or Routine Maintenance. Perform a visual check of past repairs and
improvements involving painted surfaces.
* Every Two Years. Get a dust wipe done at feast every two years. This type of test is strongly
recommended when a young child or pregnant women lives in the home.
5. Why Is It Important to Monitor and Maintain Work?
Monitoring and maintenance helps:
4 Plan and implement maintenance tasks
* Protect occupants and neighbors, particularly children, from lead exposure
4 Give owners, contractors, and residents a record of the condition of the unit
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-------
Appendix D: Glossary
Abatement - Measures to permanently (at least 20 years) control lead-based paint or
lead-based paint hazards.
Blank sample - A blank sample is a new, unused dust wipe that is sent to the
laboratory to determine if the wipes are contaminated.
Chain-of-custody - The chain-of-custody includes all the people who handle a sample.
To establish a "chain-of-custody," every person who handles the sample must sign and
date a form.
Clearance examination - Clearance involves a visual assessment and dust sampling.
It is performed following renovation and remodeling or hazard reduction activities to
determine if a work site has been cleaned properly. HUD requires it after HDD-funded
rehabilitation, lead hazard reduction, or other activities that involve the disturbance of
painted surfaces.
Composite dust wipe samples - A composite dust wipe sample is a sample that holds
up to four dust wipes in one container. Each wipe is called a sub-sample. A composite
tells you the average of level of lead-contaminated dust across all the areas you
sampled.
Detection limit - The detection limit is defined as the level below which the laboratory
cannot report an accurate level of lead.
Deteriorated paint - Deteriorated paint is any paint that is not intact. Examples include
chipped, peeling, flaking, chalking, or cracking paint.
Dust wipe sampling - Dust wipe sampling determines the levels of lead in dust in order
to compare the levels to the Federal and/or State guidance. It involves wiping a surface
with a moistened wipe following a specific protocol and sending the sample to a
laboratory for analysis.
HUD-required clearance - HUD requires clearance in pre-1978 residential dwellings
that receive Federal financial assistance or are sold by the Federal government after
lead hazard reduction activities are performed in accordance with the regulation. (These
lead hazard reduction activities may be performed in conjunction with initial or periodic
unit inspections, rehabilitation, or maintenance.)
Interim controls - Set of measures to temporarily control lead-based paint hazards.
Interim control methods must be completed by qualified workers using safe work
practices. Follow-up monitoring is needed.
Lead abatement - A procedure to address lead-based paint permanently (for at least 20
years) by making the lead-based paint inaccessible or by removing it. Examples include
component removal, paint removal, enclosure, and encapsulation.
Lead paint inspector - Lead paint inspectors evaluate the painted surfaces in a unit to
determine which surfaces contain lead-based paint. They measure the concentration of
lead in paint on a surface-by-surface basis and present a report that identifies the
location and concentration of lead for each component tested.
-------
Appendix D: Glossary
Lead sampling technician - A lead sampling technician has successfully completed
training to perform lead sampling, including performing a visual assessment and
collecting dust wipe samples.
Lead-based paint - Lead-based paint is paint that contains lead above a certain
amount. The federal guidelines for lead-based paint are: (1) greater than or equal to
1 mg/cm2 of lead; and (2) greater than or equal to 0.5% [5,000 parts per million (ppm)]
lead by dry weight.
Lead-contaminated dust - Lead-contaminated dust is dust that contains lead above a
specific threshold. HUD and EPA have different thresholds. The HUD Standards are
40 ug/ft2 (for floors), 250 ug/ft2 (for interior window sills), and 800 ug/ft2 (for window
troughs). The EPA guidance is 100 ug/ft2 (for floors), 500 ug/ft2 (for interior window
sills), and 800 ug/ft2 (for window troughs).
Lead-contaminated soil - Lead-contaminated soil is soil that contains lead above a
specific threshold. The thresholds are 400 ppm (if soil is in a play area used by children)
and 2000 ppm (for other bare soil).
National Lead Laboratory Accreditation Program (NLLAP) - The NLLAP accredits
laboratories to perform lead related analyses and provides the public with a list of its
accredited laboratories for analyzing lead in dust samples.
Paint chip sampling - Paint chip sampling involves taking a sample of paint to
determine whether areas of paint contain lead-based paint.
Paint testing - Paint testing involves evaluating the painted surfaces in a unit to show
how much lead is in the paint. It measures the concentration of lead in paint on a
surface-by-surface basis. It can be done in a laboratory or by using an XRF analyzer.
Post-renovation clearance - After renovation, remodeling, or repainting, it is
appropriate to perform clearance in the work site to confirm that the dwelling unit was
adequately cleaned and that the renovation work has not created any lead hazards.
Risk assessor - A risk assessor evaluates dwelling units to identify all lead hazards.
The evaluation involves a visual examination as well as dust, soil, and paint chip
sampling. The risk assessor then writes a report that describes the nature, severity, and
location of all identified lead-based paint hazards. A risk assessor also provides options
for remediation of each identified lead hazard.
Single-surface sampling - Single-surface dust wipe samples contain one wipe. It
measures the lead dust level from a specific surface such as a floor or an interior
window sill.
Soil sampling - Soil sampling involves testing soil samples for lead to determine if the
lead levels exceed Federal and/or State guidance for hazardous levels of lead in soil.
Spiked sample - A spiked sample is a dust wipe sample that contains a known weight
of lead-based paint dust. Spiked samples are used to ensure adequate quality control of
the digestion process at the laboratory. The spiked samples are sent to the laboratory to
see if it reports back accurate results.
-------
Appendix D: Glossary
Templates - Templates are used to outline the measured area that is to be wiped for a
dust sample. Templates are usually made of wood, plastic, or metal.
Visual assessment - A visual assessment determines if a dwelling unit is clear of
certain conditions that can cause exposure to lead, such as obvious dust, paint chips,
painted debris, and deteriorated paint.
Window sill - A trim piece that extends from the bottom of the window frame and acts
as a narrow shelf.
Window trough - A window trough is the area between the interior window sill and the
frame of the storm window where the bottom sash rests when closed (also called a
window well).
XRF - An electronic instrument often used by lead paint inspectors to test for lead in
paint.
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-------
Appendix E
Answers to Attachment 4-C: Interpreting Laboratory Results
Instructions: The purpose of this activity is to test your ability to verify the results received
from the laboratory, compare these results to the clearance guidance levels, and interpret
the results. Using the following excerpt from a Dust Sampling Results Form, check the
laboratory's calculation of the weighted lead-dust sample. {Note: the numbers used in this
exercise have been simplified to facilitate calculations).
Sample #
92- 1
92-2
92-3
Location
fypiiaiM, bedw&m.
fypAtaiM. bedwowi.
fytckett — jf>uwi
window-
Surface
<#W
9nie>liM,
uwtd&w-Aill
9nie'u&i.
wind(MAi-4M
Dimensions
of Sample
Area (ft2)
f.OO
0.50
0,50
Total
Lead (ng)
23
150
260
W/ft2
23
300
/JO
1. Check the results (jxg Lead/g) for each sample. If the results are incorrect, provide the
correct results in jig Lead/ft2.
92-1: 23/1 = 23 - correct
92-2: 150/0.50 = 300 - correct
92-3: 260/0.50 = 520 - incorrect
2. After verifying the laboratory's results, compare these results to the appropriate
clearance guidance. Did the individual samples pass or fail the clearance test?
92-1: Result: 23
Guidance for Lead-Contaminated Dust
• Floors: 100ug/ft2
• Interior window sills: SOOpg/ft2
* Window trough: 800 |jg/ft2
Clearance Guidance: 100
Pass or Fail? Pass
92-2: Result: 300 Clearance Guidance: 500
Pass or Fail? Pass
92-3: Result: 520 Clearance Guidance: 500
Pass or Fail? Fail
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Appendix E
Answers to Attachment 5-B: Scenarios
Scenario #1:
You just received a call from Mrs. Green to perform an examination of her home. Mrs. Green tells you
that her home was built in 1952. She has just had her kitchen and two bathrooms remodeled and she is
concerned about that her home was properly cleaned after the remodeling was done.
a. Are there any additional
questions that you want to ask
the owner?
b. What protocol will you follow
(post-renovation clearance,
HUD-required, or other
sampling)?
c. Where will you conduct the
visual assessment? What will
you look for?
d. Will you take dust wipe
samples? In what rooms? On
what surfaces?
What kinds of work were done in the kitchen and bathrooms?
Post-renovation clearance.
In the work area (the kitchen and the bathroom) and the hallways
leading to those areas. Look for dust, debris, and paint chips. If you
see deteriorated paint, tell Mrs. Green that this is a potential hazard
and give her a handout on how to fix it safely.
Yes. In the kitchen, two bathrooms. If the hall had dust and debris
tracked in, test there too. On floors. On windows only if work was
done on windows.
Scenario #2:
The owner of Parkview apartments asks you to do a clearance examination of a unit in his building. He
teiis you that the unit receives HUD Section 8 assistance and he just did some paint stabilization in the
unit to meet HUD Housing Quality Standards. He says he needs to pass clearance before his tenant
moves in.
a. Are there any additional
questions that you want to ask
the owner?
b. What protocol will you follow?
c. Where will you conduct the
visual assessment? What will
jrou look for?
d. Will you take dust wipe
samples? In what rooms? On
what surfaces?
Do we need to perform clearance on the unit or just a portion of the
unit? (Note: Because this is Section 8 assistance, we are not talking
about rehabilitation under $5000 or maintenance activities, therefore
the answer should be unit-wide clearance.)
HUD-required Clearance
Throughout the entire unit. Dust, debris, paint chips, and deteriorated
paint.
If the unit passes the visual assessment, then take dust samples.
Take it in up to four rooms in the unit. Take it on floors and windows.
If paint stabilization included the windows, alternate samples on sills
and troughs.
Scenario #3:
Mr. and Mrs. Johnson are moving into a new home. They have a two year old son and Mrs. Johnson is
expecting a second child in three months. Before they move in, they wan to make sure their home is safe
for their children. They ask you to perform an examination of their home.
a. Are there any additional
questions that you want to ask
the owners?
b. What protocol will you follow?
c. Where wilt you conduct the
visual assessment? What will
you look for?
d. Will you take dust wipe
samples? In what rooms? On
what surfaces?
Do they want to hire a risk assessor? Do they want to clean the unit
before the exam?
Other lead sampling examination
Throughout the dwelling. Look for dust, debris, paint chips, and
deteriorated paint.
Yes. In four rooms most likely to have children in them. Floor and
windows. Alternate sills and troughs.
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Appendix E
Answers to Attachment 6-A: Answering Client Questions
You have just given your client the clearance examination report and she has a lot of questions
for.you. You have been trained to answer some of the questions, but several questions go
beyond the scope of your training. Using what you have learned so far in this course, respond to
each of the questions in the left-hand column.
1. Decide whether your training as a clearance technician qualifies you to answer the question
and check either "yes" or "no."
2. In the far right column, provide an appropriate response by either answering the question or
referring your client to the appropriate source for further information.
Question
1. What kind of cleaning
will remove the lead-
contaminated dust?
2. Where is the dust
coming from?
3. If lead contaminated
dust was found to be
below Federal guidance,
does that mean that my
property is "lead-free?"
4. The results indicated
that lead was
undetectable, is my
property "lead-free?"
5. Do I have to have
clearance testing done
again?
6. What should I do about
the lead-contaminated
dust?
Have I been
trained to provide
an answer?
Yes
^
^
^
No
^
^
If you checked "yes," provide an answer, if
you checked "no," provide a source for
further information.
Refer client to the factsheet that describes proper
cleaning procedures. {See Handout #2 in
Appendix B.)
The dust may be left over from a poor cleanup
job but it may come from other sources. Other
sources of dust can be located by a risk
assessor, who is specifically trained to identify
sources of lead dust.
No, lead-based paint may still be present.
Passing the clearance examination only shows
that no lead-contaminated dust (and soil, if
tested) was found at the time clearance was
conducted. Further, lead dust may become a
hazard in the future.
No, lead-based paint may still be present. If lead
in samples was found to be "undetectable," then
either no lead exists or there is so little in the
sample as to be undetectable. Further, if lead-
based paint exists in the dwelling, lead dust may
become a hazard in the future.
The client does not have to have it re-tested but
it is recommended. Ideally, the client should have
the areas that failed the clearance examination
re-cleaned and re-tested to make sure the area
is safe for occupants to return.
If the clearance follows HUD-funded work,
additional cleaning and clearance are required.
The unit should be re-cleaned to remove the dust
and then re-tested. (See Handout #4 in Appendix
B for guidance on cleaning procedures.) If the
dust is from an unknown source, consider having
a risk assessment done.
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Module 1: Background
[•• Objectives
Health effects of lead exposure
Conditions that cause lead poisoning
Purpose of lead sampling
The difference between:
• Lead sampling technician (LST)
• Risk assessor (RA)
• Lead paint inspector (PI)
Miidutc I Hackpniund
[I Health Effects of Lead
Lead is especially hazardous to children:
• Loss of intelligence
• Behavioral difficulties
•Problems in school
Lead is also a danger to:
• Pregnant women
•Other adults
Lead poisoning does not always have
symptoms.
' MiKluL- I ItiickjiruimJ
: • How Do People Get Lead Poisoned?
• • Dust and soil
I • Paint chips
» • Inhalation
Lead Sampling Technician Course: Student Manual
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Module I: Background
[» What Conditions Cause Poisoning?
Lead-based paint:
• I mg/cm2 of lead
•0.5% [5,000 parts per million (ppm)]
Exposure from:
• Lead-contaminated dust
• Deteriorated paint
• Lead-contaminated soil
Where are Hazardous Conditions Found?
i Pre-1978 units
i Units renovated or remodeled
Units in poor condition
Units with exterior lead-
contaminated soil
A Lead Sampling Technician is.
A lead sampling technician has
successfully completed training to:
•perform a visual assessment
•collect dust wipe samples
Lead Sampling Technician Course: Student Manual
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Module 1: Background
i» A Lead Sampling Technician can.
- *> __________^^
"'• • Perform clearance:
Rafter renovation and remodeling work
•as required by HUD
•but not post-abatement
• May also identify dust and deteriorated
paint in other situations such as:
•pre-salc home inspections or unit turnover
•housing with a pregnant woman or a child
under 6 years
12 A Lead Sampling Technician is Not...
A risk assessor:
•evaluates dwelling units to identify
all potential lead hazards
A lead paint inspector:
•evaluates the painted surfaces in a
unit to determine which surfaces
have lead-based paint
m Why is Lead Sampling Important?
Lead sampling tells us:
• If lead-contaminated dust is present
• If additional cleaning is necessary to
protect children from lead poisoning
Lead Sampling Technician Course: Student Manual
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Module 1: Background
[-» Summary: You Now Know
The health effects of lead poisoning
The conditions that cause lead
poisoning
The purpose of lead sampling
The differences between a lead
sampling technician, a risk assessor,
and a lead paint inspector
Lead Sampling Technician Course: Student Manual
4
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Attachment 1-A
COMPARING LEAD EVALUATION PROFESSIONALS
Qualified to perform
the following types
of evaluations
Is not qualified to
perform
Trainingl
Certification
required to perform
evaluations
Skills
LEAD SAMPLING
TECHNICIAN (LST)
Clearance
Other dust wipe
sampling
Post-abatement
clearance
Certain situations
as defined in the
HUD regulations
(See Module 5)
5 hour training
Perform:
• Visual
assessment
• Dust wipe
sampling
To give a "pass/fail"
result.
RISK ASSESSOR
(RA)
• Risk
assessments
• Paint inspections
• Clearance
• Other lead
sampling
Certification
5 days of training
Perform:
• Interview of
residents
• Visual evaluation
• Dust wipe
sampling
• Soil sampling
• Paint chip
sampling
• XRF testing
To assess a unit,
identify lead hazards,
and recommend
methods for lead
hazard reduction.
LEAD PAINT
INSPECTOR (PI)
Paint inspections
Clearance
Other lead
sampling
Risk
assessments
Certification
3 days of training
Perform:
• Visual evaluation
• Paint chip
sampling
• Paint testing by
XRF
Can also perform:
• Lead sampling
(dust wipe, soil)
To identify the
existence and
location of lead-
based paint.
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Lead Sampling Technician Course
Technician Receiving Call
„,__.
Gathering Materials
M.ntuk-1 Iti
Visual Assessment
Dust sampling (first pass)
Dust sampling (second pass)
Delivering the Report to Client
Module 1: Background
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