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'LEAD
(Awareness
Program
United States
Environmental Protection
Agency
Office of Pollution Prevention,
and Toxics
(7404)
EPA 747-B-OO-OOE
September 2000
Model
Training
Course
Minimizing Lead-Based
Paint Hazards During
Renovation, Remodeling,
& Painting
Student Manual
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
isar
Minimizing Lead-Based Paint
Hazards During
Residential Renovation,
Remodeling and Painting
9/30/2000
i-'
1200 Per.
!'
. enue NW
20460
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Introduction and Welcome
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Introduction Overview
Introductions
4- Course objectives
Course manual
Course agenda
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SERA
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Introductions
In less than 1 minute please tell us:
Your name
Company you work for
What you want to learn in this course
Do you currently use lead-safe work practices?
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Course Objectives
Minimize creation and dispersal of lead-
contaminated dust and debris during
Renovation and Remodeling
Painting
Any activity that disturbs paint
Protect residents, especially children, from
exposure to lead-contaminated dust and
debris
Set-up and Containment
Safe Work Practices
Clean-up
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Objective
Upon completion of this course, participants will be able to perform renovation, remodeling, painting, and
other activities in a manner that minimizes creation and dispersal of lead-contaminated dust and protects
residents, especially children, from possible lead exposure.
Minimize dust and protect residents
This course will show contractors how to perform their work in a manner that creates the least amount of
dust possible, and how to contain and clean up the dust that they do create so that it does not spread
throughout the house or to neighboring properties.
Who can use this course
The techniques discussed in this course apply to work performed by a variety of contractors, including
plumbers, electricians, residential renovators, remodelers, and painters.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
This Course...
is voluntary and can demonstrate your
company's competence to prospective clients
Is not an abatement course
Does not satisfy OSHA training requirements
May not satisfy state and local training
requirements
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Lead abatement training
Lead abatement work is done for the sole purpose of permanently removing lead-based paint hazards from
a home. This type of work requires special training that is not provided by this course. Many states have
defined the term abatement differently and have specific training and certification requirements, therefore,
check with your state to obtain information about any state specific requirements.
Voluntary training
Completing this course is voluntary. Voluntary training is useful in demonstrating a company's competence
to prospective clients and can be a marketing advantage that distinguishes a company from the
competition.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Training Manual Overview
Six modules
Interactive exercises
Appendices
Lead Paint Safety Field Guide
Optional Video
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Modules
In addition to this Introduction and Welcome, there are six modules in this course:
Module 1 Why Should I Be Concerned About Lead Dust? (1 hour)
Module 2 Set-up Your Work Space to Contain Lead Dust (1 hour)
Module 3 Safe Work Practices (1 hour)
Module 4 Clean-up and Check Your Work (1 hour)
Module 5 Talking to Clients and Planning Work (1 hour)
Module 6 Supervisory and Business Issues (30 minutes)
Activities and Exercises
The course includes activities and exercises to help you identify methods of reducing the amount of dust
you create, and containing and cleaning up the dust you created. Many of the exercises and activities take
place in smalt groups, so you will have an opportunity to share your experiences and ideas with others in
the class.
Appendices
As indicated in the table of contents, this manual has several appendices that provide extra information that
will help contractors.
Field Guide
This manual also provides you with a copy of the Lead-Based Paint Safety Field Guide. This handy Field
Guide is easy to use and has illustrations of suggested methods for reducing, containing, and cleaning up
dust in work areas. Take it with you to work.
Optional Video
The course also includes an optional video that addresses concepts in modules 2, 3, 4, and 5: set-up, safe
work practices, clean-up, and talking with clients and planning work.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Course Agenda
Registration and refreshments
Introduction and welcome
Module 1
Break
Module 2
Module 3
Lunch
Module 4
Module 5
Break
Module 6
Adjourn
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
&EPA
uiwaiiB
Module 1
Why Should I Be Concerned
About Lead Dust?
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1-1
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Module 1 Overview
BB
Exercise
Why is lead-contaminated dust a problem?
Health risks and effects of lead?
What is lead-based paint?
How many homes contain lead-based paint?
What the government is doing about lead-
based paint?
* Summary
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1-2
Upon completion of this module, you will be able to explain
Why we are concerned with lead-contaminated dust
The health risks of lead to children and adults
The federal regulations that affect lead-based paint
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Why Is Dust and Debris a
Problem?
Dust and debris can contain lead
Lead-contaminated dust and debris is
poisonous
Small amounts of lead-contaminated dust can
poison children and adults
Children swallow it during ordinary play activities
Adults swallow or breathe it during work activities
Workers can bring lead-contaminated dust
home and poison their families
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1-3
Dust and debris from renovation, remodeling, and painting jobs in pre-1978 housing
may contain lead
Pre-1978 paint may contain lead,
Renovation, remodeling, and painting jobs disturb paint that may contain lead.
Any activity involving surface preparation, such as hand scraping, power sanding, the use of heat guns, and
open flame burning, can generate significant amounts of dust. More complicated tasks such as removing
building components and demolishing walls also can create a lot of dust.
Renovation, remodeling, or painting jobs that disturb lead-based paint can create a
hazardous situation
If proper precautions are not taken prior to and during jobs that may generate dust, workers, residents, and
children may become lead-poisoned.
Workers may bring home lead-contaminated dust
A worker's family may be most at risk from being exposed to lead-contaminated dust because dust can be
tracked home and into vehicles on the worker's clothing and shoes.
Small amounts of lead-contaminated dust can poison
A tiny amount of lead can be extremely harmful. A lead-contaminated paint chip the size of your fingernail
contains enough lead to poison an adult.
Lead particles are often so small that you cannot see them, and yet you can breathe or swallow them.
Smaller dust particles that are inhaled or swallowed are more easily absorbed by the body than larger
particles, and can therefore cause poisoning more easily.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Lead-contaminated dust is dangerous to children and adults
* Lead particles in dust, fumes, or mists may be breathed or swallowed by children, residents, and workers,
* Dust settles on everything, including toys, clothes, hands, faces, work surfaces, and equipment.
Through normal hand-to-mouth activities, children may swallow or inhale:
Dust on their hands, toys, food, or other objects
Paint chips
Adults can swallow or breathe dust during work activities.
When workers perform activities such as scraping and sanding by hand or use a power sander or
grinding tool, it creates dust These particles get into the air that they are breathing.
If workers eat, drink, smoke, or put anything into their mouths without washing up first, they will be
swallowing lead.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Health Risks of Lead
Very hazardous to children
* Reading and learning difficulties
Behavioral problems
Difficulty paying attention and hyperactivity
May result in seizures, coma, and death
Hazardous to pregnant women
Damage to fetus
Also hazardous to workers and other adults
Loss of sex drive
Physical fatigue
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Children, particularly children under six, are most at risk from small amounts of lead
Children absorb more lead than adults because they are growing. Because children's brains and nervous
systems are still developing, lead causes irreversible brain, nervous system, and organ damage. This can
lead to:
Reading and learning difficulties in school
Behavioral problems
Difficulty paying attention and hyperactivity
In some cases, exposure to lead may have devastating health effects including seizures, coma, and death.
Children are at a greater risk than adults because during normal and frequent playing or hand-to-mouth
activity, children may swallow or inhale dust from their hands, toys, food, or other objects.
Among adults, pregnant women are especially at risk from exposure to lead
Changes 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. Lead poisoning can cause:
* Miscarriages
Premature births
Low birth weight
Health effects of lead in adults include
Loss of sex drive
Physical fatigue, lack of
coordination, dizziness, muscle
or joint aches
Kidney damage or failure
Damage to male and female
reproductive organs
Miscarriages in pregnant women
Headaches and memory loss
Nausea and stomach aches
Heart disease and high blood
pressure
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
&EPA
Lead Poisoning
Lead poisoning does not always have obvious
symptoms
Symptoms are easily misdiagnosed, thus delaying
effective treatment and increasing likelihood of
permanent physical and mental damage
Only sure way to determine lead poisoning is to take a
blood lead level (BLL) test.
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Lead poisoning does not always have obvious symptoms
Lead poisoning often has no obvious symptoms, so symptoms are frequently attributed to other causes.
Specific symptoms that people with lead exposure sometimes complain of include:
Headache
Stomach ache
Irritability
Fatigue
Loss of appetite
Pain in joints
Because many symptoms are vague or similar to flu symptoms, parents may not get immediate medical
attention for their children. This is critical for young children. The longer lead remains in the body of a
young child, the higher the risk of permanent damage.
The best way to determine if lead is present in the body is by testing a person's blood.
Blood Lead Level (BLL)
Because lead poisoning does not always have symptoms, the most common way to measure the amount of
lead in your blood is the Blood Lead Level (BLL) test. The BLL test:
Measures the amount of lead that is circulating in your blood.
Tells you about your exposure to lead in the last 2-3 weeks.
Does Qol tell you the total amount of lead in your body.
Does DO! tell you if any long-term damage has occurred.
A blood lead level above 10 micrograms per deciliter 0*g/dl) is not safe for children or for women during
pregnancy. The Centers for Disease Control and Prevention consider this to be the "level of concern." A level of
39 & g/dl or less may mean that damage to your body is occurring, even if you have no symptoms. A level of 40 to
49 ^g/dl means that serious health damage may occur. A level of 50 ^g/dl or greater means that severe health
damage is likely, may be permanent, and may occur quickly.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
What Is Lead-Based Paint?
Lead-based paint is
Any paint or surface coating that contains more lead
than 0.5% or 5,000 ppm by dry weight or 1.0 mg/cm2
Some states regulate paint with lower concentrations of
lead
Why was lead used in paint?
Primary pigment
Added color
Durability
Drying agent
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Lead-Based Paint
Lead-based paint is any paint or other surface coating that contains lead equal to or greater than than 0.5
percent or 5,000 parts per million by weight or 1.0 milligram per square centimeter (mg/cm2) as measured
by laboratory analysis or X-ray fluorescence (XRF).
Paint with concentrations of lead lower than the standard definition above can still cause health problems.
Some states regulate paint with lower concentrations of lead
You should check with your state health department to see if the state has requirements that are more
stringent than the federal requirements.
Why was lead added to paint?
Lead was added to paint for color and durability. Lead-based paints stood up to wear and tear, temperature
and weather changes, and resisted mold and mildew in moist areas.
Before the 1950's concentrations of lead in paint were as high as 50 percent by weight. From about 1950 to
1973, the concentration of lead in paint was reduced as other pigment materials became more popular.
Lead-based paint was banned from residential use in 1978
In 1978 the Consumer Products Safety Commission banned the sale of lead-based paint for residential use.
In practice, this means that homes built in 1978 could still have used lead-based paint because existing
supplies of paint containing lead would still have been available.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
How Widespread is Lead in
Housing?
Year House Was Built
Before 1940
1940-1959
1960-1978
All Housing
Percent of Houses with
Lead-Based Paint
87 percent
69 percent
24 percent
40 percent
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1-8
Source of data in table above: HUD Report on the National Survey of Lead-Based Paint in Housing,
2001.
Approximately 38 million pre-1978 housing units may contain paint that meets the federal definition of "lead-
based paint" (Source: HUD Report on the National Survey of Lead-Based Paint in Housing, 2001.).
Homes built before 1960
Homes built before 1960 are more likely than homes built after 1960 to contain higher concentrations of
lead and to have deteriorated paint surfaces. In the 1950's paint companies began to use less lead.
Homes built in 1978 and earlier
Play it safe. You should assume that any house built in 1978 or earlier contains lead-based paint unless the
house has been tested for lead and the results indicate that the house does not contain lead-based paint.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
&EPA
What Is Being Done About Lead?
Laws
Lead-based paint was banned from residential use in
1978
Title X ("ten")
Education
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1-9
Title X
The Residential Lead-Based Paint Hazard Reduction Act of 1992 (PL 102-550, October 28, 1992) is also
known as "Title X of the Housing and Community Development Act of 1992."
The key provisions in Title X that affect remodelers and renovators are Section 1031 and the amendments
impacting the Toxic Substance Control Act (TSCA), Title IV Sections 402 and 406. Key provisions that
affect Federally-assisted housing are in Sections 1012 and 1013.
Title X is the cornerstone of the national lead program. Most lead regulations issued by federal agencies
were developed based on direction found in Title X.
Purpose of Title X
Develop a national strategy to eliminate lead-based paint hazards and to evaluate and reduce lead-based
paint hazards on a priority basis. To summarize, some of the key features of Title X are that it:
Emphasizes the prevention of lead-based paint hazards before children are poisoned;
Shifts focus away from abating intact lead-based paint to controlling lead-based paint hazards and
allows for new technology for evaluating and reducing those hazards;
Redefines the concept of lead-based paint hazards to include lead-contaminated dust and soil;
Acknowledges that some lead-based paint hazards are of more immediate concern than others; and
Recognizes that resources are limited and allows for the tailoring of lead-based paint hazard programs
to fit the financial and environmental conditions of specific properties.
* Reduce and prevent childhood lead poisoning.
Ensure that dealing with lead-based paint hazards are integrated into government housing policies.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Education
Training courses like this one inform housing providers and renovation, remodeling, and painting
contractors about the potential dangers of lead-based paint and how to prevent potential problems. Over
time, contractors, real estate agents, and public health departments will educate homeowners. EPA and
HUD offer outreach materials and training courses over the Internet on aspects of lead-based paint --see
the web addresses on page 1-15.
The Centers for Disease Control (CDC), an agency of the Department of Health and Human Services, is
responsible for promoting health and quality of life by preventing and controlling disease, injury, and
disability. CDC first published guidance on the prevention of childhood lead poisoning in 1975. CDC issued
updates to these guidelines in 1978, 1985, and 1991. The current guidance is entitled, "Screening Young
Children for Lead Poisoning: Guidance for State and Local Public Health Officials." The guidance makes
recommendations to improve the effectiveness of lead screening. Other audiences include public health
agencies, health care organizations including managed-care organizations, pediatricians, and other
providers of health care to children. CDC guidelines and materials can be obtained on the Internet
(www.cdc.gov) or by contacting 800 / 311-3435.
State and local health departments and other agencies also provide information about lead.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
What Is Being Done About Lead?
Regulations affecting renovation, remodeling,
and painting
EPA: Contractors distribute lead information pamphlet
OSHA: Worker protection standards
Other environmental regulations
RCRA
Clean Water Act
Regulations affecting Federally-assisted
housing
HUD: 1012/1013 rule
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EPA Regulations Under Title X
Title X amended the Toxic Substances Control Act (TSCA), which is the primary statutory authority under
which EPA issues regulations on working with lead-based paint.
* TSCA Title IV, Section 402(c). Section 402(c) requires EPA to (1) develop and issue guidelines for the
conduct of renovation and remodeling activities which may create a risk of exposure to dangerous levels of
lead; (2) study the extent to which people engaged in renovation and remodeling activities are exposed to
lead or disturb lead and create a lead-based paint hazard; and (3) revise regulations to apply to renovation
and remodeling activities that create a lead-based paint hazard.
TSCA Title IV, Section 402/404 Rule. Title X directed EPA to develop training and certification
requirements for lead professions. In response, EPA developed a rule to establish specific training course
content, model curricula, certification requirements, and work practice standards for individuals performing
the following disciplines:
Inspector
Risk Assessor
Project Designer
Abatement Worker
Abatement Supervisor
Individuals performing these activities must be trained in EPA or State accredited training programs and
certified. States may also have specific requirements about certification and training of lead professionals,
so you may need to contact your State lead certification program regulator.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
TSCA Title IV, Section 406(b). This section states that those performing renovation or remodeling shall
provide the lead hazard information pamphlet to the owner and occupant prior to conducting such
activity. This requirement applies to renovations of target housing performed for compensation. Following
are specific requirements:
The pamphlet must be provided no more than 60 days before the start of the activity;
The pamphlet must be provided at least seven days before the start of the activity if sending by certified
mail;
Must obtain written acknowledgement of receipt of the pamphlet from the owner and occupant;
* Must keep this written acknowledgement for a minimum of three years
This requirement does not apply to:
Minor repair and maintenance activities that disrupt 2 square ft. or less of painted surface per
component;
Emergency renovation operations. An emergency renovation is an unplanned renovation or activity
done in response to a sudden, unexpected event which if not immediately attended to presents a safety
or public health hazard or threatens property with significant damage (such as repairing damage
caused by a tree falling on a house or repairing a pipe break in an apartment complex);
Renovations on components which a certified LBP inspector has determined are free of LBP;
Housing units with no bedrooms (zero-bedroom units);
Housing designated for the elderly or persons with disabilities unless a child under the age of 6 years
resides or is expected to reside in the the unit.
The regulation implementing this requirement was published on June 1, 1998 in the Federal Register and
became effective on June 1, 1999. Persons who fail to provide the pamphlet as required may be subject to
civil and criminal sanctions. Responsibility for compliance rests with the renovator, who, for this regulation
is defined as "any person who performs for compensation a renovation."
You can get a free copy of this pamphlet by calling The National Lead Information Center at 1-800-424-
LEAD. A camera-ready version is also available on the EPA Website at www.epa.gov/lead.
TSCA Title IV, Section 403 Rule: Dust Lead Sampling Standards
EPA recommends dust sampling but currently does not require it
When conducting dust sampling, the goal should be to adhere to the following standards:
Floors 40 /wg/ft2 (micrograms per square foot)
Interior window sills 250
Window troughs 400
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Regulations Issued Under the Resource Conservation and Recovery Act and the
Clean Water Act
The Resource Conservation and Recovery Act (RCRA) and the Clean Water Act (CWA) may apply to
renovation and remodeling work because they regulate waste disposal and discharges of dirty water. This
course concentrates on minimizing waste to avoid running into problems with these regulations. This
module concentrates on Title X and OSHA regulations because they most directly affect renovation and
remodeling activities.
Most states are authorized by EPA to implement their own regulatory programs under RCRA and CWA.
This means that their requirements are at least as stringent as EPA's. As a result, contractors should
contact their state environmental agency for guidance on how to manage waste and waste water generated
during renovation and remodeling.
EPA has issued an advisory opinion that waste generated during renovation and remodeling is not
considered hazardous and therefore should not be regulated under RCRA. However, a state must adopt
this position for it to become effective in that state. Contact your state environmental agency to determine
whether it has adopted EPA's advisory opinion. A copy of EPA's interpretation is included in Appendix 6
EPA's Waste Policy Guidance.
OSHA Regulations
Title X, Section 1031 directed the Occupational Safety and Health Administration (OSHA) to develop
standards for occupational exposures to lead in the construction industry. A comprehensive treatment of
OSHA regulations requires additional training.
The major OSHA regulations pertaining to lead are:
Lead Exposure in Construction (29 CFR 1926.62);
Hazard Communication for Construction (29 CFR 1926.59); and
Hazard Communication for General Industry (29 CFR 1910.1200).
OSHA Requirements Under Lead Exposure in Construction (29 CFR 1926.62). While Title X attempts
to provide protection to the occupants of target housing, OSHA regulations attempt to provide protection to
workers who encounter lead-based paint on any job that involves lead - not just in pre-1978 target housing.
Construction workers may be especially at risk because they create dust and debris that can poison them
as well as those with whom they come into contact off the job. This regulation went into effect June 3,
1993. It applies to all workers doing construction work who may be exposed to lead on the job. This
specifically includes repair and renovation work.
Types of work covered by the OSHA lead exposure in construction rule include:
Demolition or salvaging of structures where lead or materials contain lead. For example, in performing
gut rehabilitation of an older home, walls covered with lead-based paint will be demolished and create
large amounts of debris.
Removal, enclosure or encapsulation of materials containing lead. For example, removing a window
creates dust and debris.
*
New construction, alteration, repair or renovation of structures, substrates, or portions thereof, that
contain lead or materials containing lead. For example, a structural member that is exposed to weather
such as a car port.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Types of work covered by the OSHA lead exposure in construction rule (continued):
Installation of products containing lead. Examples of such products include: using lead-based paint
(special industrial applications), lead roofing materials (flashing installation), installation of lead
shielding in doctors' offices or in a hospital.
Contamination and emergency clean-up.
Transportation, disposal, storage, or containment of lead or materials containing lead on the
construction site.
Maintenance operations associated with the previous activities. For example paint repair, repainting,
and cleaning.
Employer responsibilities under the OSHA lead exposure in construction rule
Determine if any employee is exposed above the action level (30 ^g /m3) using full-shift personal air sampling.
Under 30 ^g /m3 - no special action level (micrograms of lead per cubic meter of air measured inside the worker's
breathing zone as 8 hour time weight average).
30 -50 ^9 /m3 - requires worker blood lead monitoring and training
Over 50 ^ g /m3 permissible exposure limit (pel) - requires blood lead monitoring, training, and worker protections
such as respiratory protection and protective work clothing.
The OSHA regulations contain specific requirements and guidelines covering construction employer and worker
safety and responsibilities.
A "traffic light" illustration is useful to explain the different levels of protection that take effect for different amounts
of dust particles in the air:
Green Light: Less than 30^ g/m3. This level requires no special precautions.
Yellow Light: 30 n g/m3 to 50 n g/m3. This level requires protection such as blood tests to monitor lead levels
in the blood and training in accordance with the standard for workers. This is the Action Level (AL).
Red Light: Greater than 50 ^ g/m3. This level requires protection such as respirators in addition to protection
provided under "Yellow." This is the Permissible Exposure Limit (PEL). Employers must provide appropriate
protective clothing and equipment to workers free of charge.
If possible, using work practices that keep the level below 30 ng/m3 is best because workers are not required to
have special protection or monitoring. Maintaining the required low level of dust particles is possible but you need
to prove that it is being maintained by monitoring dust particle levels. You need to know what practices keep dust
levels to a minimum.
Additional OSHA Regulations
Additional applicable OSHA regulations include: Respiratory Protection (29 CFR 1910.134); Persona!
Protective Equipment (29 CFR 1910.132); Sanitation (29 CFR 1926.27).
Many OSHA regulations have similar requirements:
Keep work area clean and free of hazards.
Assess the job and protect employees. »
Use safe work practices.
Provide hygiene facilities for washing hands and face, or showering if feasible.
Train employees about workplace hazards.
Do the job right and keep good records.
Provide access to medical and exposure records.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
HUD Regulations Under Title X
Title X, Sections 1012 and 1013, required HUD to develop regulations to address lead-based paint in pre-
1978 Federally-assisted and Federally-owned housing which is being sold. Housing owned and operated
by a Federal agency other than HUD is not covered by this regulation.
The 1012 /1013 regulation is called the "Lead Safe Housing Rule" and is found at 24 CFR Part 35.
Under Title X, HUD has developed
Regulations that apply to how contractors and their employees must work with lead-based paint when doing lead
hazard reduction or abatement work in pre-1978 HUD-assisted or HUD-owned homes;
Regulations affecting training and work practices for operations and maintenance work on housing receiving
Federal assistance; and
Required training in lead-safety for all workers performing rehabilitation activities in housing units built before 1978.
Lead Information Resources
EPA. On the Internet at www.epa.gov/lead.
OSHA. Onthelnternetatwww.osha-slc.gov/SLTC/lead. Note that this URL is case sensitive (the letters
SLTC must be capitalized).
HUD. On the internet at www.hud.gov.offices/lead or by contacting HUD User at 1-800-245-2691.
National Lead Information Center at 1-800-424-LEAD.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Now You Know
Why we are concerned with lead-contaminated
dust
The health risks of lead to children and adults
The regulations that affect lead-based paint
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1-16
The modules in the rest of the course describe how proper set-up and containment,
safe work practices, and clean up techniques leave less lead-contaminated dust and
debris than standard renovation, remodeling, and painting work practices.
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1-16
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
MODULE 1 EXERCISE
Identify common work practices that produce a lot of dust and debris.
Total Time: 20 minutes.
In groups of 3 to 5 take 10 minutes to answer the questions below. Assign one
person to report your group's answers to the rest of the class.
1. Rank the work practice descriptions according to the amount of dust and paint chips you
think they make. In the table betow, under the column labeled Rank, write:
1 next to the work practice that makes the most dust and debris.
2 next to the work practice that makes the second most amount of dust and debris.
3 next to the work practice that makes the third most amount of dust and debris.
Continue until you have ranked each work practice according to how much dust and
debris you think it will make. A smaller number means that you think the work practice
will create more dust or debris than a larger number.
If you think that some work practices make about the same amount of dust or debris you can
give them the same rank. If you think that each practice makes different amounts of dust, rank
them from 1 to 7. If you think you need more detail to make a decision, just make that detail part
of your assumptions and be sure to note that assumption when explaining your ranking.
Work Practice Description
A.
B.
C.
D.
E.
F.
G.
Using a power sander with no vacuum attachment to remove interior
paint from a plaster wall.
Hand sanding a small (less than 2 square feet) area for surface
preparation on an interior room where the paint is in good condition.
Ripping out old kitchen cabinets in a 50 year-old house where the paint
on the walls and cabinets is in good condition {e.g., it is not peeling or
flaking).
Repairing a sticking window. Loosen the painted sashes, remove inside
stop molding, remove top and bottom sash, use a power planer to
remove old paint, regiaze and repair the sash as necessary, repair and
paint the jamb, reinstall the sash.
Removing old carpeting placed over a hardwood floor in one room.
Demolishing one interior wall using hand or power tools.
High pressure power washing or hydro blasting exterior paint.
Rank
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
2. For the work practices) that you ranked #1 (it makes the most dust and debris), tell why you
think it makes the most dust and debris.
3. For the work practice(s) that you ranked last (it makes the least amount of dust and debris)
tell why you think it makes the least amount of dust and debris.
4. If you actually did any of the jobs described above, what would you do to clean-up when the
job was finished?
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Module 2
Set-Up Your Workspace to
Contain Lead Dust
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2-1
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Video Segment: Set-Up
Your Workspace
Think about the following points as you view
the video
What are the most important things you see to properly
set-up a workspace?
What would it take for you to begin doing these
practices in your work?
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2-2
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Module 2 Overview
What is containment?
Four steps for interior activities
Special considerations for high dust jobs
Two steps for exterior activities
Special considerations for high dust jobs
9/30/2000
2-3
Upon completion of this module you will be able to
Perform set-up techniques to contain lead dust and allow for easier cleanup at the end of the day and at the
completion of the job.
Identify appropriate set-up techniques for high dust jobs that may require additional containment.
What is a high dust job?
A working definition of a high dust job is one that creates dust and debris that will spread beyond five feet
from the area that you are working on. Conversely, a low dust job is one in which dust and debris wifl not
spread beyond five feet from the work area.
In general, jobs that involve only a small work area create less dust than jobs that involve a larger work
area. However, in addition to the size of the job, the work practices (e.g., sanding), and equipment (e.g.,
power sander) used will affect how much dust is created. So, for example, using a power sander without a
HEPA filter vacuum attachment on a two square foot area could be considered a high dust job. Using
power tools equipped with HEPA filtered vacuum attachments will create less dust than using power tools
without these attachments.
Examples of high dust jobs include:
* Hand scraping large areas
Using power sanders (e.g., orbital, belt) without HEPA equipped vacuum attachments and shrouds
Using electric planer without a HEPA equipped vacuum attachment and shroud
Removing paint with a heat gun
Using circular or reciprocating saw
Removing dry residue and paint after using chemical strippers
Demolishing painted surfaces using hand or power tools
Removing building components with painted surfaces that are in poor condition
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2-3
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
What Is Containment?
Keeping lead-contaminated dust in the work
area
Benefits of containment
Protects residents and workers
Easier clean-up at the end of the job
9/30/2000
2-4
What is containment?
In general, there are many degrees of containment, ranging from simple plastic sheeting on the floor
surrounding a small work area to a fully sealed dust room (discussed later in this module). Some types of
containment are more effective than other types. For example, a drop cloth might be considered a form of
containment by some, but because it is reusable and can trap and hold dust and paint chips, it can transport
lead-contaminated dust from one job site to another. It is not an effective form of containment for working in
homes with lead-based paint.
For purposes of this training, "containment" is anything that stops lead-contaminated dust from
spreading beyond the work area to non-work areas.
Benefits of containment
Reduces the risk to you and residents. Following the work area set-up suggestions of this module will
protect you, your co-workers, and residents from the negative health effects of lead while remodeling,
renovating, or painting. Reduced risk to you and co-workers is also dependent upon wearing proper personal
protection equipment.
Easier clean-up. The pre-work set-up process is essential to keeping lead contaminated dust within the work
area where it can be easily cleaned. Proper containment of the work area helps to limit the areas you need
to clean up after the job is complete. This saves time and money for cleanup.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
&EPA
Current Interior Set-Up Practices ©**
Spread Lead-Contaminated Dust
Reusable drop cloth
Furniture in the room
Open doors and
windows
Broom or shop vacuum
n°t use these practices
when lead is present!
9/30/2000
2-5
Current practice for interior set-up typically involves
A reusable drop cloth is an improvement over not using any drop cloth, but it can carry dust from one job
site to other job sites, and contaminate vehicles and storage areas. Some of the dust captured by a drop
cloth falls to the floor when folding the cloth to carry away. However, some of the dust stays with the drop
cloth. When it is used again it may contaminate the new (clean) job site with lead-contaminated dust.
* Allowing furniture to remain in the work area while the work is being performed. Lead-contaminated
dust may fall and remain on these furnishings after the job is completed. Residents could easily come into
contact with the lead-contaminated dust on the furnishings and get poisoned.
Allowing residents access to work area while the work is underway. The residents are then exposed to
the lead-contaminated dust and can track the dust to other parts of the building where it could linger. Again,
residents could easily be exposed to the lead-contaminated dust on the furnishings and get poisoned.
Open windows and doors allows lead dust to float into other parts of the building or over onto neighboring
property.
Brooms and shop vacuums are typically used to clean-up. Both clean-up methods capture some dust,
but shop vacuums especially can put more dust into the air than they clean up if the filters are dirty or
inadequate. Vigorous sweeping may also put a lot of dust into the air. To be effective, containment must
be practiced even when cleaning up after the job.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
oEPA
Overview of Interior Set-Up Steps
Step 1: Limit access
Step 2: Cover belongings that can not be
moved
* Step 3: Cover floors
Step 4: Close windows, doors, and HVAC
system
Special consideration for high dust jobs
9/30/2000
2-6
Overview of interior set-up steps
Details for these steps are on the following several pages. These four steps will help contain lead dust to
the work area for interior jobs.
* See page 13 in the Lead Paint Safety Field Guide for additional information. Appendix 1 contains a copy of
the text from the Lead Paint Safety Field Guide.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
«EPA
Set-up Toolkit
Barriers
* Coverings for furniture,
fixtures, plants, or
outdoor play areas
Other set-up
containment items
9/30/2000
2-7
Typical items for work area set-up to contain lead-contaminated dust
Barriers
12Rope or other barrier
ETape (bright color preferable)
ElSaw horses
ElOrange cones or other similar m arker
Coverings for Furniture, Fixtures, Plants or Out door Play areas
EJDuct tape, painters tape, or masking tape
ElStapler
04-6 mil protective sheeting
HUtility knife or scissors
^Disposable mesh materials such as burlap, cheesecloth, or landscaping mesh
Other Set-Up Containment Items
0Tack pad (sticky pad for walking on to remove dust from soles of shoes)
HSmall disposable towels or wipes
ElMisting bottle
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Interior Set-Up
Step 1: Limit Access
* Instruct residents to * Do not allow eating,
stay away from work drinking, or smoking
area 'n *ne work area
Do not allow small
children (under 6
years) or pets near
work area
Place a barrier or tape
across entrances
9OCV2000
2-8
Restrict access to the work area and ask residents to stay away while work is
underway
Restricting access to the work area will avoid unnecessary exposure of residents, especially children, to
lead dust and minimize its spread to non work-areas.
Tell the residents to stay away from the area as much as possible. Residents and pets coming and going
can easily track lead-contaminated dust throughout the home and into areas that are not being worked on
and therefore to areas that are unlikely to be cleaned up promptly.
This is especially true for small children under six years old. Be sure to explain to residents that this is for
their own protection and that small children are most at risk of health problems from exposure to lead.
You may need to provide an indication of how long you will be working in a particular area so that residents
can plan ahead to obtain items that they may need before you begin working.
Place a barrier across entrances
A physical barrier, such as a cone or masking tape, should be placed across doorways to remind residents
to stay away, especially in buildings where more than one family lives. The barrier serves as a reminder to
residents that they should not enter the work area, and also signals that the area has not yet been cleaned
up.
Do not allow eating, drinking or smoking in the work area
This is primarily a protection for workers, but is also important if residents are living in or near the work
area. Post signs that prohibit eating, drinking, or smoking in the work area. Dust in the air can land on food
or be breathed when smoking. If food is set on an unwashed surface, it can easily pick up lead-
contaminated dust, which is swallowed when eating the food.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Interior Set-Up
Step 2: Cover Belongings
&EPA
Cover furniture and
objects in protective
sheeting
Furniture
Carpet
Lamps, pictures, and other
fixtures
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2-9
Cover furniture and other objects in the room with protective sheeting
Cover all objects that were not removed from the room in protective sheeting. Completely cover all non-
movable furniture, carpets, and other personal items with protective sheeting. Secure the protective
sheeting to the floor with tape so that no dust can get onto the covered items.
Protective sheeting such as thick (4-6 mils) polyethylene plastic sheeting is commonly used in many
remodeling jobs. Protective sheeting can be bought at many hardware stores.
If it is a high-dust job, remove the furniture from the work area.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Interior Set-Up
Step 3: Cover Floors
9/30/2000
Cover floors with
protective sheeting
At least five feet on all sides
of work area
2nd smaller layer if using
chemical strippers
Place a tack pad at edge of
protective sheeting, lay
protective sheeting on
frequently used walking
paths to outdoors and
bathrooms
2-10
Cover Floors
Use protective sheeting to cover the floor. The protective sheeting should extend at least five feet to the
left, right and front-and in some cases to the back-of the work area. It should be tightly secured to
baseboard or flooring using duct tape, painters tape, or masking tape. The corner edge of the protective
sheeting should be reinforced using duct tape or a staple.
A second smaller layer of protective sheeting should be used with chemical strippers. This second layer
should be taped to the top of the first layer. Place the second layer immediately below the work area. This
layer will capture any waste and aid in cleaning up.
Tools that are used frequently should be left within the work area throughout the job to avoid tracking dust
to non-covered areas.
Consider covering shoes with removable shoe covers, wiping off the tops and soles of shoes with a damp
paper towel each time you step off the sheeting, or using a "tack pad" that removes dust from the soles of
shoes. Immediately place used paper towels in a covered garbage bin. A tack pad can be found at most
hardware stores or bought through a supply catalog; it is a sticky pad that you walk on to remove dust from
the soles of your shoes. The tack pad can be taped to an outer corner of the sheeting.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
oEPA
Interior Set-Up
Step 4: Close Windows, Doors, HVAC
Close and seal all windows and doors
Close and seal HVAC vents
9/30/2000
2-11
Close and cover windows and doors
Close and seal windows (if no work is being done on the window) and doors, including closet and cabinet
doors in the work area.
Seal windows with protective sheeting to prevent dust from getting into the trough or on sill.
Cut plastic sheeting layer slightly larger than the window that you are covering.
Attach the plastic sheeting with tape over the window to completely seal it.
Make sure that the tape or the sheeting does not cover part of the area that you are working on.
Close and seal HVAC vents
Heating ventilating and air conditioning (HVAC) systems distribute air throughout the building and thus can
allow dust to move to other rooms. Close and cover the HVAC vents in the work area to prevent air from
blowing the dust out of the contained work area and to prevent dust from getting into the HVAC system.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Special Considerations for
Interior High Dust Jobs
Remove furniture,
fixtures and belongings
from work area
Cover door openings
with a 2 layers of
protective sheeting to
form an "airlock"
Close and cover HVAC
vents
9/30/2000
2-12
Remove rugs, draperies, and furniture from the work area when completing a high
dust job
Before starting work, request that the homeowner remove furniture and fixtures from the room. This will
prevent lead-contaminated dust from getting into these items.
Cover door openings with a 2 layers of protective sheeting
Covering the door with this two-layer system will contain the dust within the work area. Follow the steps
below:
1)Cut first plastic sheeting layer slightly wider and longer (three inches) than door frame.
2)Make small "s" fold at the top of sheeting and tape to top of door frame. Make a similar "s" fold at the
bottom of the sheeting and tape to flooring. This will ensure that the plastic is not taut. Staple top
corners for reinforcement.
3)For exiting and entering the room, cut a long vertical slit in middle of protective sheeting; leave six
inches at top and bottom uncut. Reinforce the top and bottom of the slit with tape to prevent the plastic
from tearing,
4)Tape a second layer of protective sheeting to top of door frame. This layer is cut slightly shorter than
door frame so that it will hang down flat against the first sheet of plastic.
5)Tape and staple top corners of second layer to door frame and first layer. Leave hanging over first
layer.
See Page 46 in the Lead Paint Safety Field Guide for more information on how to put the two layer system
in place.
Close and seal HVAC vents in the room
* Turn off the HVAC system for work area. The vents should then be closed and covered with cardboard and
protective plastic sheeting. After the work is complete the vent covers should be removed and washed. All
filters for the HVAC system should be changed after any work that disturbs lead-based paint.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Special Considerations For
Interior High Dust Jobs
oEPA
9/30/2000
For work on removable
objects that create lots
of dust
Select a room that can
be easily closed off
Follow Steps 1 through 4 for
interior set-up
Follow the procedures for
high dust jobs
2-13
Consider setting up a work room ("dust room") for high dust-generating work on
components that can be moved out of their original room and into the dust room
A dust room prevents the spread of lead-contaminated paint and dust to non-work areas and also makes
clean-up easier.
Use this technique for high dust activities, for example, planing and scraping doors or window sashes where
you are maintaining the original windows.
Set up a dust room if work is being done on components in a room that residents must have access to, such
as the kitchen. Rather than keeping the resident out of the kitchen, remove the components to the separate
dust room and complete surface preparation there. After preparation is complete, the components can be
returned to the kitchen.
Select a room that can be easily closed off from the rest of the home to use as a
dust room
A dust room can be any room that can be closed off. Residents should not have to enter this space for the
duration of the job. For example, a spare bedroom or other unused room that residents do not need to
access during the time that the work is being performed.
The dust room should be close to the work area, if possible.
Follow the four set-up steps for all work with minor modifications or additions: 1) limit access, 2) remove
furnishings, 3) cover the floor, 4) seal windows, doors, and HVAC vents.
Workers should wear protective clothing, NIOSH approved respirators (e.g., N100), and safety goggles.
Plan your work so that necessary supplies and equipment are in the room to minimize the number of trips
outside the room while work is being performed.
See Page 14 in the Lead Paint Safety Field Guide for more information.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
&EPA
Current Exterior Set-Up Practices^*"*"
Spread Lead-Contaminated Dust
9/30/2000
Ground uncovered
Reusable drop cloth
Paint chips
No barriers
Windows and doors
open
Do not use these practices
when lead is present!
2-14
Current practices for exterior set-up
Leaving the ground uncovered allows lead contaminated dust to get into the dirt, washed into storm
drains, and into nearby play areas.
Covering with reusable drop cloth. Similar to the problems associated with using a reusable drop cloth
for interior jobs, a reusable drop cloth for exterior jobs can carry dust from one job site to other job sites.
Some of the dust captured by a drop cloth falls to the floor when folding it to carry away. However, some of
the dust stays with the drop cloth to the next work site, thus potentially spreading lead-contaminated dust to
a new work site.
Small paint chips and piles of dirt are often overlooked. This poses a considerable hazard to small
children.
Residents and passers-by usually have unlimited access to area. Similar to interior work, residents
and passers-by may come into contact with lead-contaminated dust and breathe or swallow it.
Windows and doors are left open and may allow lead contaminated dust to enter the house.
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2-14
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
oERA
Overview of Exterior Set-up Steps
Step 1: Establish work area
Step 2: Close windows and doors
Special considerations for high dust jobs
9/30/2000
2-15
Two steps for exterior set-up to contain lead dust
Details for these steps are on the following two pages. These two steps will help contain lead dust to the
work area for exterior jobs. These steps may be modified for high dust jobs.
See page 22 in the Lead Paint Safety Field Guide for more information.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Exterior Set-Up
Step 1: Establish Work Area
&EPA
asss,
U'*
""w
Cover the ground with
protective sheeting
If space permits, extend at
least 10 feet from work area
Cover nearby vegetable
gardens and children's play
areas
Limit work area access
Establish a 20 foot
perimeter around work area
if space permits
9/30/2000
Cover the ground with protective sheeting
If space permits, lay protective sheeting on the ground below the work area to at least 10 feet from the
house. This creates a visible work area and helps remind residents and passers-by that they should not
enter the work area unless they have a compelling need. Note: Plastic sheeting can kill plants.
Cover grass, shrubs, and gardens with a disposable mesh material such as landscape fabric or burlap.
Landscape fabric is an inexpensive plastic mesh that is often used by landscapers. It can be found in many
plant nurseries or hardware stores. This covering will protect the soil and plants from lead contamination.
Remember children often play in the dirt and may put their hands in their mouth while playing. Any dirt on
their hands will go into their mouths and may be swallowed.
* Remove toys and other items from work area and cover all play areas including sandboxes.
Staple or tape the protective sheeting to the wall of the building, or use a 2x4 to hold the material next to
the wall. Use heavy objects (e.g., rocks) to weight the other edges of the protective sheeting to the ground
so that it won't blow in the wind.
When using ladders on plastic sheeting consider placing a sturdy piece of plywood on the plastic and
then setting the ladder on the plywood. This will prevent the ladder from puncturing the plastic and also will
provide a stable surface for the ladder.
Limit work area access
Limit access to work area by placing orange cones, saw horses, or tape around a 20 foot perimeter of the
work area. This will help to discourage residents and passersby from entering the work area.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Exterior Set-Up
Step 2: Close Windows &Doors
oEPA
tuiofUMn
Close nearby doors and
windows within 20 feet
of the work area
9/30/2000
2-17
Close and cover windows and doors
All windows and doors within 20 feet work area should be closed to prevent dust from entering the home.
Consider requesting that the neighbors also close their windows and doors.
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2-17
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
dEPA
Special Considerations For
Exterior High Dust Jobs
For high dust jobs:
Cover doors and windows with protective sheeting
Use the two-layer protective sheeting system to cover the door
For multi-story jobs, attach protective sheeting to scaffolding to
cover house entrance
9/30/2000
2-18
Cover windows and doors with protective sheeting
For high dust jobs, close, lock, and seal windows and doors with protective sheeting. Follow the procedures
for sealing doors and windows that were described earlier for interior high dust jobs.
Entrances that must be used while work is underway should be protected with a covering when performing
high dust jobs. Either place the 2 layer protective sheeting flap system over the entrance or cover the
entrance with protective sheeting that is attached to scaffolding.
* If working with water, consider using landscaping mesh on the ground as described on the previous page.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
MODULE 2 EXERCISE
Objective: Review set-up methods to contain lead dust and allow for easier clean-up.
Length: 30 minutes, including discussion of answers
Directions: In groups of three or four take 20 minutes to review the three illustrations below
and:
Identify three set-up methods that encourage the spread of lead dust beyond
the work area;
Identify three techniques that could be used to reduce the spread of lead-
contaminated dust to non-work areas;
Assign one person to report your group's answers to the rest of the class.
Full size illustrations are attached.
Illustration 1: Replace Window
Increase the Spread of Dust and Debris
Reduce the Spread of Dust and Debris
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Illustration 2: Remove Exterior Paint
j!; I .-...'.;-'-:-.;v..."V>
*Pilfe - ..-£
'? 'itlC^s^''-'-;' *""' ^v '*-<:»
^iafe:gl||^ .'£":
Increase the Spread of Dust and Debris
Reduce the Spread of Dust and Debris
Illustration 3: Rework and Paint Interior Components
Increase the Spread of Dust and Debris
Reduce the Spread of Dust and Debris
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Module 3
Safe Work Practices
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3-1
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Video Segment: Safe Work
Practices
Think about the following points as you view
the video
What are the most important safe work practices you
see?
What would it take for you to begin doing these
practices in your work?
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3-2
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
oEPA
Module 3 Overview
High risk practices to avoid
Safe work practices and safe work practices
toolkit
Protect yourself and make a personal
protection equipment toolkit
Control the spread of dust
Exercise
Discussion
9/30/2000
3-3
Role of safe work practices
In addition to proper set-up at the start of a job and cleanup at the end of the job, the third key strategy to
minimize the spread of dust is using safe work practices.
Upon completion of this module, you will know
What high risk work practices to avoid because they create dangerous amounts of dust and paint chips
What safe work practices to use to reduce and control dust and paint chips
What tools you will need
* How to apply safe work practices to common renovation, remodeling, and painting jobs
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
&EPA
Typical Lead Dust Creation
Hand Sanding . Power Sanding Interior Demolition
Traditional Work Practices
9/30/2000
3-4
Traditional work practices create large amounts of dust
This chart shows amounts of lead dust created by three common construction practices: hand sanding,
power sanding, and interior demolition.
The amount of lead dust for each practice is significantly higher than the level where worker protection,
such as respirators and protective clothing, is required by OSHA. This airborne dust is hard to control.
By using safe work practices, you can control and significantly reduce the amount of dust created on the
job. Controlling lead dust at the source of generation is important because dust generated into the air will
eventually become settled dust on the ground. Later in this chapter, you will learn safe work practices that
can replace these restricted work practices.
The data used in the chart above are from Lead Exposure Associated with Renovation and Remodeling
Activities: Summary Report, Prepared by Battelle for the U.S. Environmental Protection Agency, May 1997,
EPA 747-R-96-005.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
High Risk Practices
Open flame burning or
torching
Heat gun above 1,100
degrees Fahrenheit
Power sanding,
grinding, abrasive
blasting without HEPA
vacuum attachment
Extensive dry scraping
and dry sanding
9/30/2000
Avoid these traditional work practices
A key to minimizing the spread of dust and paint chips is to not use certain traditional work practices known
to create large^amounts of dust and debris.
Open flame burning or torching of paint and using a heat gun above 1,100° F create fumes that are
dangerous for workers to breathe. Smalt lead particles created by burning and heating also settle on surrounding
surfaces and are very hard to clean up.
Power sanding, grinding or abrasive blasting, even on a small surface, creates a large amount of leaded dust
that floats in the air and then settles on surfaces inside and outside the work area.
Extensive dry hand sanding and hand scraping can also create large amounts of dust and paint chips.
See pages 9-10 in the Lead Paint Safety Field Guide for more information about these practices.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
&EPA
Safe Work Practice Alternatives
to High Risk Practices
High Risk
Open flame burning or
torching
Heat gun on high (1,100+
degrees F)
Dry scraping and sanding
Power sanding, grinding,
abrasive blasting without-
attachment to HEPA vacuum
Safe
Wet scraping and sanding,
chemical stripping, heat gun
below 1,100 degrees F
Heat gun below 1,100
degrees F
Wet scraping and sanding
Use of power tools with
attachment to HEPA vacuum
9/30/2000
3-6
Alternative safe work practices for each high risk practice
For both large and smalt paint removal jobs, there are safe work practice alternatives.
Some possible alternatives are listed on the slide.
* With experience, you will determine which safe work practices work best for different tasks.
Note: HEPA (high efficiency participate air) vacuums have HEPA-rated filters that stop 99.97% of particles of 0.3
microns or larger.
Also keep in mind
Chemical strippers can be dangerous. Some can cause burns. Methylene chloride is suspected to cause
cancer but may be appropriate for exterior work. Types of strippers range from citrus-based (safer) to more
dangerous caustic strippers. Follow the manufacturer's directions when using any chemical stripper.
If building components to be stripped can be removed, such as doors, consider having them stripped off-site
at a paint stripping facility.
Half-face negative respirators do not provide sufficient breathing protection when using methylene chloride
strippers.
* See pages 9-10 in the Lead Paint Safety Field Guide for more information.
9/30/2000
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
&EPA
More Safe Work Practices
Mist before drilling and cutting
(hand tools only)
* Score paint
Minimize pounding and -J- ^
hammering -- pry and pull instead
Mist surroundings
9/30/2000
3-7
Additional safe work practices
Mist before drilling and cutting to reduce dust creation and keep dust from becoming airborne and spreading
beyond the work area.
Scoring paint before separating components helps prevent paint from chipping when a paint seal is broken.
Prying and pulling apart components and pulling nails instead of pounding create less dust and fewer paint
chips. Vise grips may be useful when pulling nails.
Frequent misting of surrounding surfaces with water helps keep dust and paint chips from becoming
airborne when disturbed by work activity.
Using power tools on heavily misted surfaces can be dangerous if they are wet. Tool blades can slip and
water can cause electric shock. When misting, lightly mist the surface and use hand tools only. If power
tools are to be used, they should be attached to a HEPA vacuum.
EPA encourages contractors to use ground fault circuit interrupters (GFCI's) to help ensure safety while
using electrical equipment.
9/30/2000
3-7
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
"
Benefits of Safe Work Practices
Protect your family by not bringing dust home
with you
Enhance reputation for knowledge and
professionalism
Reduce resident exposure to lead
+ Protect children
Simplify daily and final cleanup
Help protect workers from inhaling dust
9/30/2000
3-8
Advantages for contractors
In addition to being safer for residents, safe work practices have advantages for contractors and workers.
By effectively using safe work practices, you can
Foster your reputation as an informed and professional contractor who recognizes the risks of lead-based
paint and takes steps to help ensure resident and worker safety.
Gain a reputation for leaving the job site cleaner than when you arrived.
Help your customers feel safe and reduce their anxiety about the risks of remodeling and renovations.
Have less dust and debris to clean up at the end of the job.
Reduce risk of taking leaded dust home to your family.
Because contractors are required to give customers the lead information pamphlet before starting work,
those who use safe work practices can better respond to customer concerns raised by the pamphlet. A
copy of the pamphlet is provided in Appendix 2. Information about the law requiring that contractors give
customers the pamphlet is provided in Appendix 3. We will discuss this information in more detail in Module
5: Talking to Clients and Planning Work.
9/30/2000
3-8
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Safe Work Practices Toolkit:
Tools, Equipment, and Supplies
Wet/dry sandpaper, sanding sponge
Mist bottle, pump sprayer
Tape (painter's, duct, masking)
Heavy duty (4-6 mil) plastic sheeting
Heavy duty garbage bags
Chemical stripper
Utility knife
+ Heat gun
Vacuum with HEPA filter
9/30/2000
Safe work practices toolkit tools, equipment, and supplies
There are some basic low-cost tools that you will need for safe work practices. Most of these tools and
supplies are widely available from suppliers and home improvement stores.
These tools are used to help reduce dust and for cleaning while working to keep dust under control.
You will need several basic supplies to protect floor and ground surfaces, and bag, wrap, and clean dust as
work is performed. If dust and debris are contained in plastic right after they are created, there is less
chance that they will be spread beyond the work site.
More toolkit supplies are listed on the next three pages of this manual.
HEPA (high efficiency particulate air) filters are able to filter very small particles-to be considered a HEPA
filter, it must be able to filter 99.97% of particles of 0.3 microns or larger.
See pages 75-76 Tool and Supply List in the Lead Paint Safety Field Guide for more information.
9/30/2000
3-9
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Safe Work Practices Toolkit:
Consider Investing in New Tools
Large jobs may require special tools
Power sanders, grinders, planers, shavers with HEPA
filter vacuum attachment
9/30/2000
3-10
HEPA equipment for power tools
Because wet methods are appropriate and practical only when using hand tools, adapters and HEPA
vacuums are necessary for power tools.
For contractors who frequently remove paint from large surfaces, an investment in attachments to control
dust can make the job go quickly and safely.
These tools use HEPA vacuums and adapters that help contain dust and debris as they are created. A
shroud helps to contain the dust and paint chips as they are created. They are carried to a HEPA vacuum
by a hose attached to the shroud.
It may be possible to rent these tools, if you decide to not invest in them.
Power washing
Power washing can be used if runoff is properly contained and disposed.
Set-up is still important
Proper set-up and cleanup is still important because HEPA attachments do not eliminate the possibility that
work will spread dust. Nonetheless, these attachments will reduce dust levels and thereby shorten cleaning
time and lower costs.
See pages 75-76 Tool and Supply List in the Lead Paint Safety Field Guide for more information.
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3-10
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Protect Yourself
+ Workers should wear
Painter's hat - helps keep dust out of hair
Disposable coveralls
- Can be reused if not ripped
- Repair tears with duct tape
- Store in plastic bag
Disposable N100-rated respirator
Wash face and hands frequently
Helps to reduce hand-to-mouth ingestion of lead dust
OSHA may require more protection
9/30/2000
3-11
Workers should protect themselves
Minimum steps that workers can take to protect themselves include:
Painter's hats are an inexpensive way to keep dust and paint chips out of workers' hair. Painter's hats
can be easily disposed of at the end of the day or job.
Disposable coveralls are a good way to keep dust off of workers clothes and reduce the chances for
carrying dust to other areas of the residence as workers come and go. The coveralls can be removed
when workers leave the work site and stored in a plastic bag overnight. To keep costs down, consider
buying extra large size coveralls in bulk and sizing to fit workers with duct tape. Some coveralls have a
hood to keep dust out of hair.
Respiratory protection. Workers should wear respiratory protection, such as an N100 disposable
respirator, to prevent them from breathing leaded dust.
Workers should wash their hands and faces periodically to avoid ingesting leaded dust. It is especially
important to wash well before eating, drinking or smoking and to not do any of these in the work site. Some of
the dust that settles on the face around the mouth invariably finds its way into the mouth. Workers
should also wash at the end of the day before getting in their car or going home. They can take leaded
dust home to their families.
OSHA rules may require employers to take further steps to protect the health of workers on the job.
See page 17 in the Lead Paint Safety Field Guide for more information on worker protection.
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3-11
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
&EPA
Personal Protection
Equipment (PPE) Toolkit
Disposable hand towels
* Pre-moistened disposable wipes // ''
Painter's hats
Gloves
Coveralls
Disposable shoe covers
N100-rated disposable respirators
_. .*
>?
9/30/2000
Personal protection equipment
* Disposable hand towels (such as paper towels) and pre-moistened wipes have multiple uses on the job.
They can be used to quickly clean surfaces and by workers to wipe dust before leaving the work site and
washing before eating, smoking, or drinking.
"N100" is a NIOSH rating for respirators. Respirators with an N100 (or HEPA) rating are approved for use
when working on lead-based paint surfaces. OSHA may require a different type of respirator rated for use
around lead, depending on work conditions.
* All of the items on this list are readily available at hardware and home improvement stores. N100
disposable respirators cost approximately $6-7.
See pages 75-76 Tool and Supply List in the Lead Paint Safety Field Guide for more information.
Additional equipment you should consider
First Aid kit
Safety glasses
Ear protection for when using power tools
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3-12
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
oEPA
Control the Spread of Dust """
When you leave the work site
Remove shoe coverings
HEPA vacuum or wipe shoes
Remove coveralls or HEPA vacuum clothes
At the end of the day don't take lead home to
your family on your clothes or in your car
HEPA vacuum clothes, shoes
Change your clothes and dispose or place in plastic
bag to wash separately from household laundry
Wash hands, face
Shower as soon as you get home
9/30/2000 ' ° 3
Precautions to take when leaving the work site
When you leave the work site (the area covered by protective sheeting or the room), take precautions to
prevent spreading dust and paint chips to other parts of the residence on your clothes and shoes.
* Every time you leave the work site, wipe or vacuum your shoes before you step off of the plastic sheeting. A
large tack pad on the floor can help to clean the soles of your shoes. Remove shoe coverings if you are
using them.
At the end of the day, change your clothes and wash yourself to reduce the risk of contaminating your car
and taking leaded dust home to your family.
Before leaving the worksite-- remove any protective clothing, HEPA vacuum dust from non-protective clothing,
and thoroughly wash your hands and face. Throw away disposable clothing or place clothing in a plastic bag to
stop dust from getting on other clothes at home..
At home-- as soon as you arrive at home, take a shower and be sure to thoroughly wash your hair, especially
before playing with children. Wash work clothes separately from regular household laundry to stop lead particles
from getting on your other clothes.
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3-13
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
oEPA
Cleaning During the Job
A clean work site reduces the spread of dust
and paint chips
Clean as you work
HEPA vacuum horizontal surfaces
Remove debris frequently
Remove paint chips as they are created
As building components are removed, wrap and
dispose of them immediately
Clean frequently (in stages, at least daily)
9/30/2000
3-14
Clean the work site frequently
Cleaning the work site frequently as the job progresses will reduce the spread of dust and paint chips. The
cleaning need not be as thorough as the final cleanup. It should, however, keep debris, dust, and paint
chips from piling up and spreading beyond the immediate work site.
Cleanup during the job includes
Removing debris frequently. During demolition jobs, seal and dispose of construction debris as it is
created.
Vacuuming horizontal surfaces frequently. HEPA vacuum dust and paint chips that settle on surfaces,
including protective sheeting. As workers come and go during the work day, this debris is easily spread.
Periodic cleaning throughout the work day will help to minimize workers tracking dust.
* Collect paint chips as they are created. When removing paint, piles of paint chips can also spread
outside the immediate work area as workers come and go from the work site. To keep paint chips from
spreading beyond the work site, make sure that they are collected as they are created. Also, periodically
vacuum (with HEPA filtered vacuum) or wet sweep and dispose of paint chips.
Wrapping and disposing of removed components. When removing painted components such as
windows, trim, and cabinets, wrap them in plastic sheeting and dispose of them in stages. This will prevent
the spread of debris and keep residents, especially children, from conning into contact with leaded dust
created by work.
How often should cleaning during the job take place? The goal is to keep dust and debris under control,
not to maintain a completefy spotless site at all times. Every job is different, so clean when it makes sense
to without hindering progress. Remove large amounts of dust, paint chips, and debris frequently, at least
daily.
9/30/2000
3-14
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
ynuta
Discussion
What are the key safe work practices and
equipment?
9«0/2000
3-15
9/30/2000
3-15
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Minimizing Lead-Based Paint Hazards During Renovation and Remodeling
MODULE 3 EXERCISE
Objective: Identify safe work practices for typical renovation and remodeling tasks.
Length: Total time: 25 minutes
Directions: Take 5 minutes to read the background and the jobs below. When you are
finished, the instructor will ask you and the other students to contribute
approaches to each of the jobs listed below. You may take notes on approaches
under each description.
Background
You own a small contracting firm which has been hired by a couple to renovate the interior and
exterior of their large Victorian-style home built around 1910. This is a prominent home in the
neighborhood (it sits on the comer) and you are looking forward to doing a quality job and getting
a good reference. You also like that your truck parked in the driveway with your name on it will
make good advertising to the neighbors who drive by. Furthermore, it will keep you and your
workers busy for at least three solid weeks.
As the law requires, you give the couple the lead pamphlet Protect Your Family from Lead in
Your Home. The day before you are to start working, they call and ask you if they have lead-
based paint in their home and whether they should be worried about it. (They have a four-year
old daughter and plan to remain in the house during the two-week work period). You inform them
that, short of having the place tested, you have no way of knowing for sure. To be safe, you tell
them that you assume that some layers of paint in the home are lead-based paint.
You get the feeling that they are having second thoughts and might cancel the job. You inform
them that there are steps that can be taken to reduce the risk of creating a lead hazard. You also
point out that you and two of your steady workers have taken an EPA course on how to do work
safely. This seems to reassure them and they tell you to go ahead as planned.
On the Job: Day One
In addition to yourself and your two experienced employees, you have hired a full-time worker to
help with the demolition and prep work. You have several specific jobs in mind for this worker
which are listed below. Keeping in mind that your clients are concerned about lead-based paint,
and that the jobs will create a lot of debris and dust, you want to be sure that the jobs are done
right and use safe work practices. You decide that the best course of action is to take the time to
explain to the worker, step-by-step, how to do each.
The instructor will ask you and the others in the class to give instructions the new worker. Be
clear about what safe work practices you want used, in what order, and the tools that the worker
will need. Also tell the worker how you want the work site prepared and what you want it to look
like before the next stage of work starts.
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Minimizing Lead-Based Paint Hazards During Renovation and Remodeling
The Jobs
How will you tell the new worker to do each of the following jobs?
1. Remove worn green carpet from vestibule, first floor hallway, and staircase. The carpet is
tacked to the floor and its edges are covered with quarter round at all of the walls. The carpet is
being removed to expose hardwood flooring which is to be refinished.
2. Enlarge the door size opening in the wall between the living and dining rooms to make way for
an enlarged passageway. There is trim at the base of the walls and trim at the top and sides of
the opening. As much of the trim as possible should be saved to be reused on the enlarged
opening. The new opening will be as tall as before but wider.
3. Remove the old painted wooden cabinets in the kitchen. These built-in cabinets line two walls
in the kitchen. The walls will be repainted and new cabinets installed.
4. Remove sections of deteriorated siding and peeling paint from the east exterior wall of the
house. Water has leaked behind the siding causing large sections to deteriorate. There are two
large patches of peeling paint where the siding is still solid. New clapboard siding will be installed
later and the entire exterior repainted by a painting contractor.
9/30/2000
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WORKSHEET: EVALUATING THE JOB
1. Was the property constructed prior to 1978? or
If the work area is limited to an addition, was the addition
constructed prior to 1978?
If no, you are not required to perform lead safe work
practices.
Do you have documentation that the work area has been
designed as lead-free by a certified inspector or risk
assessor?
2. Wiil this work disturb painted surfaces or otherwise create
or disturb dust that may contain lead?
Is this a high dust job?
If yes, you must take added precautions.
3. How will the lead activities affect my job?
How much additional time will lead-safe work practices
take? See Hours and Cost Calculation aid.
How much will these practices cost? See Materials and
Supplies Checklist.
4. What activities should the residents perform before I begin
my lead-safe work practices?
Examples include removing draperies, small furniture,
and other fixtures from the work area.
5. Other job related notes
Yes
Yes
Yes.
Yes
Yes.
No
No
No.
No
No.
Set Up hours
Work hours
Cleanup hours
Labor Cost $
Supplies Cost $_
Talk to residents about
specific activities
-------
CHECKLIST: MATERIALS and SUPPLIES
Set up Tool Kit
Barriers
Q Rope
Q Tape (bright color
preferable)
Q Saw horses
Q Orange cones or
other similar marker
Coverings
4-6 mil protective
sheeting
Disposable mesh (e.g.,
burlap, cheesecloth,
landscaping mesh)
Stapler
Tape (duct, painters, or
masking)
Utility knife or scissors
Other Items
Tack pad
Small disposable
towels or wipes
Misting bottle
Safe Work Practices Tool Kit
Wet/dry sandpaper
or sanding sponge
Mist bottle or pump
sprayer
Chemical stripper
Heat gun
4-6 mil protective
sheeting
Tape (duct, painters, or
masking)
Utility knife or scissors
Heavy duty garbage
bags
Vacuum with HEPA
filter
Specialized Tools
Q HEPA exhaust
attachments for power
tools (sanders,
grinders, planers,
shavers)
Qj Power washing
equipment
Q Needle gun with HEPA
exhaust
-------
Personal Protection Equipment (PPE) Tool Kit
Painter's hats
Gloves
Coveralls
Disposable shoe
covers
N-100 disposable
respirators or equivalent
Pre-moistened
disposable wipes
Disposable hand towels
(e.g., paper towels)
Additional Items to
Consider
First aid kit
Safety glasses
Ear protection (when
using power tools)
Clean Up Tool Kit
Q Misting bottle
Q Vacuum with HEPA
filter
Q Heavy duty garbage
bags
Tape (duct)
Q Detergent
Q Two buckets or two-
sided bucket
Q Mop with disposable
heads
Q Disposable hand towels
(e.g., paper towels)
Pump sprayer
Shovel and rake
Hours and Cost Calculation
Labor Hours (total)
Labor Cost (total)
Supplies
Total
Setup
$
$
$
Work
$
$
$
Clean up
$
$
$
Total
$
$
$
-------
RESOURCES FOR ADDITIONAL INFORMATION
Where can I get copies of the Protect Your Family From Lead in You Home pamphlet?
Download electronic copies at: www.epa.gov/lead
Use camera-ready copies from the National Lead Information Center to reproduce the
pamphlet, providing that you reproduce the text and graphics in full: 1-(800) 424-LEAD
(5323).
Order bulk copies from the Government Printing Office (GPO) which cost $26.00 for a
package of 50 pamphlets: (202) 512-1800; refer to the pamphlet by name or by GPO
Stock Number 055-000-00507-9.
Where can I get copies of The Lead-Based Paint Pre-Renovation Education Rule
handbook?
Download electronic copies of the interim edition (June 1999) in PDF format at
http://www.epa.gov/lead/Ieadrenf.htm.
Contact the National Lead Information Center at: 1-(800) 424-LEAD (5323)
Where can I find additional information and resources related to lead-based paint?
Lead Information Center: 1-800-424-LEAD (5323)
EPA's Office of Pollution Prevention and Toxics (OPPT): www.epa.aov/lead
202-260-3810
HDD's Office of Lead Hazard Control: www.hud.aov/offices/lead 202-755-1785
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
USA
Module 4
Clean-up and Check Your Work
9/30/2000
9/30/2000
4-1
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
&EPA
Video Segment: Clean Up and
Check Your Work
Think about the following points as you view
the video
What are the most important clean up practices you
see?
What would it take for you to begin doing these
practices in your work?
9/30/2000
4-2
9/30/2000
4-2
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
&EPA
Module 4 Overview
What is effective clean-up?
Clean up toolkit
Interior clean up techniques
Exterior clean up techniques
How to check your work
Safe disposal methods
Keep in mind
9/30/2000
4-3
What you will learn in this module
In this module, we will cover all the topics listed on the slide above.
The goal of cleanup is to leave the work area as clean or cleaner than when you arrived so that, as a result
of your work, lead dust is not left behind to poison the residents of the home.
At the end of this module, you will know how to check your work to ensure the work area is clean
enough to pass a clearance examination, if it is required.
By using the techniques described in the following pages of this module you will be able to clean a work
area quickly and efficiently. Remember, approaching a clean-up is similar to approaching a job. Proper
preparation and planning will help make your cleaning efforts more effective and faster.
Always schedule time at the end of each day to clean thoroughly.
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4-3
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
&EPA
What is Effective Clean Up?
sssr
Containing dust during clean up to the area
that will be cleaned
Using proper cleaning techniques
Cleaning all surfaces, tools and clothing
Checking your work
Safe and secure disposal
9/30/2000
Containment
Effective cleaning begins with proper preparation and containment. Clean-up wilt be much easier and
efficient if proper containment has kept all dust and debris confined to the work area. Also, containing dust
to the area that is being cleaned is important.
Proper cleaning techniques
You should be careful not to spread dust and contaminate other areas while cleaning. Using the techniques
outlined in this module and following the proper sequence will help ensure that you do not contaminate
other areas while cleaning.
Cleaning all surfaces
* "All surfaces" includes vertical surfaces such as walls and windows and horizontal surfaces such as floors,
door tops, window troughs, and window sills. Cleaning should proceed from high to low, i.e., from top of
wall to window to floor.
Checking your work
Always conduct a visual inspection after any job. Look for any visible paint chips, dust or debris.
Safe and secure disposal
Bag and "gooseneck seal" all waste in 4-6 mil poly-bags. Safely dispose of all waste in accordance with
state and federal regulations.
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4-4
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Clean Up Toolkit
UUMO
9/30/2000
Vacuum with HEPA filter
Misting bottle and pump
sprayer
Mop with disposable heads
Detergent
Two buckets or two-sided
bucket
Disposable hand towels
Heavy duty garbage bags
Duct tape
Shovel and rake
4-5
Clean Up Toolkit
The tools listed on the slide above are for cleaning interior and exterior jobs. Some tools, such as the pump
sprayer, shovel, and rake are used primarily for exterior clean up. Other tools, such as the buckets and
mops are used primarily for interior clean up.
The following pages discuss clean up for both interior and exterior situations.
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4-5
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
&EPA
Interior Clean-Up Techniques
Pick up all paint chips with wet, disposable
cloth
Pick up protective sheeting
Mist sheeting before folding
Fold dirty side inward
Tape shut to seal in dirty side
Dispose of protective sheeting at end of job
9/30/2000
4-6
Pick up
Always begin a clean-up by picking up all paint chips and any visible debris with a wet disposable cloth.
Protective sheeting
Protective sheeting may be used again within the Same work area if it has not already been folded {see pp.
47, Lead Paint Safety Field Guide). When the job is complete, clean protective sheeting using a HEPA
vacuum. Protective sheeting should then be folded and taped shut. Always fold dirty side inwards, seal
and place in 4-6 mil poly-bag. "Gooseneck-seal" the poly-bag and dispose with the rest of your waste at the
end of the job.
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4-6
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Interior Clean-Up Techniques
HEPA Vac work area
from high to low
Start with walls, tops of
doors, window troughs
HEPA Vac at least two feet
beyond contained area
Wet clean from high to
low
Change cloths and rinse
water often
Clean the floor iast
Achieve visual clearance
9/30/2000
HEPA vacuum the contained work area from high to low
Start with the walls, tops of doors, and window troughs (high) and work your way down to the floor (low),
Clean walls with a HEPA vacuum or by lightly wiping with a damp disposable cloth.
Be thorough-don't rush.
When cleaning wet, you can either mist the surface with cleaning solution or use a
wet disposable cloth
Work from high surfaces to low. If a surface is very dirty use a moist paper towel before beginning to scrub
with a wet cloth.
Replace cloths and change rinse water often.
Clean the floor last
Mist floor and clean with a wet mop using cleaning solution and the two-sided bucket.
Clean at least two feet beyond contained area.
Then, repeat the process using a new mop head and clean water.
Remember, always keep one side of the bucket for cleaning solution and the other side for rinsing and
wringing out the cloth or mop-head. Change the rinsing water often.
it may be necessary to repeat the HEPA Vacuum and Wet Clean. Always clean to
visual clearance.
9/30/2000
4-7
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Interior Checking Your Work
Always conduct a visual inspection after
cleaning
Focus on child access areas such as floors, window
troughs, window sills
Look for paint chips, dust, debris, and deteriorated paint
Inspect beyond work area
Repeat clean-up steps if necessary
Dust sampling
Encouraged to check work
Sometimes required
9/30/2000
4-8
Visual inspection
A thorough visual inspection should be the first step of checking your clean-up. Any visible paint chips, dust
or debris should be collected and disposed.
Visual inspection will not verify that a work area has been cleaned adequately. In many instances
lead dust is not visible to the naked eye and will be not be detected during a visual inspection. To ensure
that a work area is properly cleaned, follow the practices outlined in this section and take a dust wipe
sample for verification.
Dust sampling
Dust sampling can be performed to check the effectiveness of the clean-up efforts.
In some cases, dust sampling may be required as part of "clearance" (a defined process to ensure that a
work area is not contaminated with lead dust after work is completed). In such cases, dust sampling must
be performed by a certified or trained person. Supervisors should be aware of state laws regarding
renovation and remodeling work.
9/30/2000
4-8
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Exterior Clean-Up Techniques
For high-dust jobs mist area to keep dust down
Visually inspect work area
Look for dust, debris, and paint chips
Focus on child access areas such as:
- Window sills
Bare soil and ground
- Play areas
9/30/2000
4-9
High-dust jobs
After completing a high-dust job, such as power sanding a painted surface, mist the entire work area to
keep dust from spreading.
Visual inspection
A thorough visual inspection of the work area should be conducted after any exterior job. Any visible paint
chips, wood chips or other debris from the work area should be collected and disposed with the rest of your
waste.
Focus your visual inspection on areas where children may play or be exposed to lead contaminated dust or
debris. Such areas include exterior porches, outside play areas, bare soil and ground, and window sills.
Remember
Lead contaminated soil can poison children.
Avoid dry raking and spreading dust.
9/30/2000
4-9
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Exterior Clean-Up Techniques
Pick up protective sheeting
Collect and dispose of any debris or chips on sheeting
HEPA vacuum sheeting
Clean sheeting to visual clearance
Fold and store securely for reuse
Visually inspect beyond work area
9/30/2000
4-10
Protective sheeting
Use of screen mesh, screen tarp, or landscape fabric is recommended to cover vegetation. This material
should be fine enough to collect all chips and debris. Although recommended to be disposed of after use, if
you intend to reuse the protective sheeting it must be cleaned thoroughly and pass visual clearance before
being securely stored for reuse.
If protective sheeting will be disposed at the end of the job, it should be cleaned and disposed with the rest
of your waste.
Specific exterior jobs
If work takes place on an exterior porch or stairwell, HEPA vacuuming, wet cleaning and mopping, in
addition to a thorough visual inspection, should be used to clean the work area. For such jobs the clean-up
can be similar to clean-up after interior jobs. Collect and dispose of any dust or debris with the rest of your
waste.
9/30/2000
4-10
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
&EPA
Exterior Checking your Work
Visual inspection
Always conduct a visual inspection after any cleaning
Focus on child access areas such as
- Bare soil or ground
-Window sills
- Exterior porches
- Play areas
Inspect beyond work area
Collect and dispose all paint chips, dust,
debris, and deteriorated paint
9/30/2000
Checking your work
A thorough visual inspection is the main part of checking your clean-up after an exterior job. You should
collect and dispose of any visible paint chips, wood chips and debris found during the visual inspection.
Child access areas include porches, play areas, bare soil or ground, and window sills.
You may notice that the processes of clean-up and checking your work are similar for exterior jobs. A
visual inspection is conducted once while cleaning and again after completing clean-up to check your work.
Both visual inspections should be thorough and focus on collecting and disposing all visible paint chips, dust
and debris.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Disposal
9/30/2000
What should I do with
my waste?
At the work site
Place waste in 4-6 mil poly-
bag
"Gooseneck Seal" the bag
with duct tape
Carefully dispose of waste
in accordance with state and
federal regulations
Store waste in a secure
area
4-12
At the work site
Always collect, bag and seal your waste at the work site and in the work area. Do not carry your waste to
another room or another area before bagging and sealing the waste. Store all waste in a secure container
or dumpster until disposal. Limit on-site storage time. Avoid transporting waste in an open truck. Some
examples of waste include:
Protective sheeting
HEPA filters
All paint chips, dust and dirty water
Used cloths, wipes and mop heads
Any debris
Protective clothing, respirators, gloves
Architectural components
Waste water
Water used for clean-up should be filtered and dumped in a toilet. Never dump this water down a sink,
storm drain, on the ground, or in a tub. Always be aware of state and local regulations regarding waste
water disposal.
Remember
If needed, "double-bag" your waste to help prevent the waste from escaping if the bag is cut or ripped.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Disposal - Local and Federal -
Information
Segregate hazardous and non-hazardous
waste
Minimize generation of hazardous waste
Always check state regulations!
grao/zooo
4-13
Waste disposal issues
* Because the U.S. EPA considers most renovation and remodeling as "routine residential maintenance" the
waste generated during these activities is classified as solid, non-hazardous waste and should be taken to a
licensed solid waste landfill.
You should determine whether you generate more than 220 pounds of hazardous waste per job site per
month. If you have less than 220 pounds per location per month then manage this waste as solid, non-
hazardous waste. If you generate more than 220 pounds of hazardous waste you should contact your state
and local regulators to find out how to dispose of this waste properly.
Some possible examples of hazardous waste may include: paint chips; vacuum debris; sludge or
chemical waste from strippers; and HEPA filters.
Some possible examples of non-hazardous waste may include: disposable clothing; respirator filters;
rugs and carpets; protective sheeting; and solid components with no peeling paint. Please list and suggest
any other examples.
AH waste should be handled carefully and sealed in heavy duty (6 mil) poly-bags.
Large architectural components should be wrapped and sealed in plastic sheeting and disposed along with
your waste.
Remember
Some states have enacted more stringent waste management and disposal regulations.
Supervisors must be aware of state regulations concerning hazardous and solid waste management and
disposal.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Keep In Mind
SSS2
*!«<»
Schedule time to clean thoroughly at the end
of each day
Assign responsibilities to specific personnel
Create and maintain a checklist for cleaning
procedures
Always maintain sufficient cleaning and
disposal supplies
9/30/2000
Example check list for cleaning procedures
The list below is an example checklist for cleaning procedures. You may wish to add to or modify it to fit your
needs.
Was the work completed?
Have all visible paint chips, dust and debris been removed and disposed?
Was the protective sheeting folded, sealed, and disposed?
Was the interior work area HEPA vacuumed?
Were ail surfaces wet cleaned? Was the floor cleaned last?
* Was the interior work area HEPA vacuumed again?
Was all waste placed safely in 4-6 mil poly-bags?
* Were all bags properly sealed?
Was all waste disposed in accordance with state and federal regulations?
Was a visual inspection completed?
Were dust samples taken?
Is the property owner satisfied?
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4-14
I
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
&EPA
Module 5
Talking to Clients and Planning
Work
9/30/2000
5-1
9/30/2000
5-1
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
AEPA
Video Segment: Talking to ClieftfS
and Planning Work
Think about the following points as you view
the video
What are the most important points you see for talking
to clients and planning your work?
What would it take for you to begin doing this in your
work?
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S-2
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Module 5 Overview
At the end of this module, you will be able to
answer the following questions:
Do I need to use lead safe work practices?
How can I communicate information about the
associated planning, cost, and time demands to the
residents?
9/30/2000
5-3
Planning Ahead
You should also talk to the residents about why you are performing lead safe work practices and describe
what the residents can do to help prevent the spread of dust both before you start the project and while you
are working.
To safely work in homes with lead-based paint, it is essential that you plan a strategy to reduce the creation
of dust and contain any dust created. The time invested in these activities will ensure your project is
conducted safely with regards to lead dust hazards and expedite the cleanup process.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
What are Your Responsibilities?
Under federal law, you MUST:
Give residents copies of the pamphlet Protect Your
Family From Lead In Your Home
Get confirmation that residents received the pamphlet
Keep confirmation records for three years
See The Lead Pre-Renovation Education Rule
for confirmation forms and guidance (40 CFR
Part 745)
9/30/2000
5-4
Legal Obligations
Federal law requires contractors to tell occupants about the risks of lead-based paint before non-emergency
repair, maintenance, and home renovation work begins. This law applies to all work on surfaces greater
than 2 square feet per component. Contractors MUST:
Give residents a copy of the pamphlet Protect Your Family From Lead In Your Home before starting
any work.
Either have the resident sign an acknowledgement form after receiving the pamphlet or send the
resident a copy of the pamphlet via certified mail.
Keep copies of the residents' confirmation of receipt of the lead pamphlet or certificate of mailing for
three years as documentation of your compliance with the regulations.
Forms for confirmation of receipt of the lead pamphlet are included in the Lead Pre-Renovation Education
Rule handbook.
Copies of both the Protect Your Family From Lead In Your Home and the Lead Pre-Renovation Education
Rule handbook are included in Appendices 2 and 3, respectively. See the handout: Resources for
additional information that accompanies the exercise later in this lesson for a list of where you can obtain
these documents.
Some states and local governments may have additional requirements for working on homes with lead-
based paint. You can periodically check with the National Council of State Legislatures (NCSL) for updates
to state laws affecting lead-based paint for all states. The 1999 compilation is located at:
http://www.ncsl,org/programs/ESNR/pblaw99.htm.
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5-4
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Talking to Residents About
Your Skills
Why are you using lead-safe work practices?
Keep the house safe
Protect health of children and pregnant women
Good professionalism
Why are you qualified to conduct these
activities?
Completed this course
Use lead-safe tools and supplies
Experience with lead-safe work practices
9/30/2000
5-5
In addition to any generic communication you have with residents during a renovation, remodeling, or
painting job, you must inform them that your work has the potential to create lead dust. The EPA pamphlet
The Lead-Based Paint Pre-Renovation Rule provides good pointers for talking to clients. You should
discuss the following topics with the homeowner prior to beginning any renovation or remodeling job that
has a potential to create lead dust:
Why are lead safe work practices a good idea?
Incorporating lead safe work practices into your renovation, remodeling, and painting activities will:
Protect children's and workers' health
* Keep the house safe from increased levels of lead dust
Is an example of good professionalism
Module 1 presented more detailed information on these topics. Also, you can refer to the field guide or to
EPA pamphlet Protect Your Family From Lead in Your Home for additional information.
Why are you qualified to conduct these activities?
Currently, there are no federal regulations requiring you to be certified or trained in lead safe practices.
However, you voluntarily took the time to complete this course because you care about the well-being of
your clients and are concerned about protecting the environment and your workers. Through this course,
you learned the dangers associated with lead dust, how to identify lead dust, how to plan, set-up, and
conduct your work to minimize the distribution of lead dust, and how to clean up afterwards to ensure you
did no harm. Your prior experience working with lead-safe work practices also enhances your
qualifications.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
oEPA
Discussing the Work Plan
Discussing the work plan with residents
What lead safe work practices are planned?
How will this work affect the residents' use of the
house?
How will you protect the residents' possessions from
lead dust contamination?
What activities will you expect the residents to perform
before you begin your work?
9^0/2000
5-6
Discussing the work plan with residents
In addition to discussing the hazards associated with lead-based paint and and lead dust, you should review
your plan for lead-safe work practices with the residents. This includes:
Outlining the work schedule, highlighting lead safe work practices that will minimize lead dust exposure
Describing how you will protect residents' possessions from further lead dust contamination
Identifying the activities you expect the residents to perform before you begin your work
It is much easier to prevent possible problems during set-up than to do extra cleaning afterward. You may
want to ask resident(s) to move some items before you begin your work. These include moving any
furniture and fixtures out of the work area and storing them away from any work that may create dust. Seal
over remaining items with polyethylene protective sheeting where possible. Moving items such as drapes,
area rugs, and plants will reduce the potential for contaminating them with lead dust, if the paint in the work
area is already deteriorated, you may suggest that the residents clean these items prior to moving them to
other areas of the house to minimize the amount of lead dust that is distributed to other areas of the house.
If the residents move and clean these items before the renovation work begins, you will not have to worry
about being responsible for damaged or lost items.
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5-6
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
&EPA
Why Evaluate the Job for LeadT
Reduce your potential liability from lead dust
Incorporate lead activities into your work
schedule
Use lead-safe work practices
Have the right materials and equipment
Include the cost of lead-safe work practices
Discuss occupant protection with residents
OSHA regulations require employers to
determine if employees will be exposed
9/30/2000
5-7
Why Evaluate Your Job
There are a number of reasons why you should determine if your job will create lead dust prior to starting to
work. These include:
Ensuring your activities will not create additional hazards or potential liabilities from lead dust.
Including lead dust control activities in your work schedule.
Using appropriate lead safe work practices.
Having materials and equipment on hand to safely manage lead dust, minimize the amount of dust
created, and reduce the potential for spreading dust to other parts of the dwelling or surrounding area.
Accurately estimating the costs of the additional time, labor, and supplies needed to perform lead-safe
work practices.
Making sure that this is a job you want to go into.
Developing a list of issues and preparing to discuss them with owners and occupants.
It is a good idea to discuss lead-based paint, lead dust, and occupant protection with the residents before
beginning the work. This allows you to sell this service to the residents and positively distinguish yourself
from the competition.
See the Field Guide pp. 11, 75, and 76.
9/30/2000
5-7
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
oEPA
Evaluating the Property
Was the residential building constructed
before 1978?
If yes, take proper action and use lead-safe work
practices
If no, you do not have to worry about lead dust.
How can I get this information?
Ask the resident for tax records or other documentation
Has the paint been tested for lead?
If yes, collect documentation of what and where
9/30/2000
5-8
Was the property constructed prior to 1978?
The majority of buildings constructed before 1978, especially those constructed prior to 1960, contain some
lead-based paint. Unless otherwise documented, you should always assume that painted surfaces from
pre-1978 houses include lead-based paint and that all dust generated from these surfaces may contain
lead. Although the amount of lead-based paint found in homes varies, older dwellings typically contain
higher concentrations of lead paint. For pre-1950 properties, you should assume that lead-based paint is
present on most painted surfaces. Some localities may have restricted lead paint prior to 1978.
What is the age Of the property? If the property was constructed after 1978, you do not need
to worry about performing lead safe work practices. The resident should be your first source for this
information. They can get information on the age of the property from tax records or property deeds.
Has any prior renovation work been done? if all of your work will be conducted in a
dwelling constructed or renovated after 1978, you do not need to utilize lead-safe work practices, even
if the rest of the property was built earlier. You should ask the resident for this information. If the
resident does not know if or when renovation work was conducted, and the property was constructed
prior to 1978, you should assume all paint surfaces contain lead-based paint.
Has a lead evaluation been conducted? Lead evaluations cover a range of activities that
test for lead-based paint. If the resident has documentation that a certified inspector or risk assessor
performed a lead evaluation and found that no lead-based paint is present in the work area, you do not
have to utilize lead safe work practices, regardless of the age of the property.
9/30/2000
5-8
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Evaluating the Work
Will this job:
Disturb painted surfaces?
Otherwise create or disturb lead dust?
If yes, take proper precautions:
Set-up
Work practices
Clean up
Will this job create high levels of dust?
9/30/2000
5-9
Will the work disturb painted surfaces, or create / disturb dust that may contain
lead?
All renovation, remodeling, and painting activities that disturb painted areas, including scraping paint,
removing siding, replacing windows, will create some dust. Additionally, some areas, such as window
troughs and loose areas near a building's foundation, typically accumulate dust and paint chips. You must
consider these factors when approaching the job and develop an appropriate plan to deal with the potential
lead dust. If your work will NOT disturb ANY painted surfaces or areas where lead dust can accumulate,
you do not have to use lead-safe work practices.
What precautions are needed?
The amount of dust created is directly related to the size of the work area, condition of the structure, and
tools, materials, and dust control methods used. Previous modules presented descriptions of the
necessary precautions you should take while setting up the work areas, performing renovation, remodeling,
or painting activities, and cleaning up.
If the job will disturb paint surfaces, will it create high dust that will cause you to
take extra precautions?
As highlighted in previous modules, some projects create more dust than others. Major renovation work,
such as demolition, or removing old paneling, siding, windows, or wall-to-wall carpeting, can create high
dust levels. Additionally, surfaces with deteriorated or chipped paint are more likely to generate high levels
of dust than intact surfaces. The level of dust a job will create directly affects other parts of your job,
including the materials and equipment required, precautions taken during set up, and the control methods
used.
9/30/2000
5-9
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Scheduling Work
How will I schedule lead-safe work practices?
Minimize hassle to residents
Limit the size of the work area
Minimize labor costs
Take high dust jobs into account
9/30/2000
5-10
How will I schedule the lead safe work practices?
When scheduling lead safe work practices, you should keep three goals in mind:
Minimize the hassle to the residents
Limit the size of the work area
* Minimize extra labor costs
In most cases, it is preferable to complete lead hazard control activities before beginning other renovation,
remodeling, or painting activities. This will minimize the possibility of distributing lead dust outside of the
work area. This may also allow most of your work to be done using traditional methods - without the
precautions necessary when working with lead-based paint - thereby simplifying the coordination of other
project-related activities. It would also minimize the hassle to the residents by reducing the areas of the
house they should not enter because lead dust activities are taking place.
For large projects, it may make more sense to conduct lead safe practices at the beginning of each phase
of the project. For example, if you are renovating all of the bathrooms in a house, you may work in one
bathroom at a time. In this case, it makes sense to perform lead-safe work practices at the beginning of
each individual renovation activity as opposed to at the beginning of the entire job.
NIOSH and OSHA will have data for the level of dust generated by jobs. These will vary from job to job.
You need to use your experience and common sense to determine which jobs are high dust jobs.
9/30/2000
5-10
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Evaluating the Effects on
Your Job
&EPA
KSSb
How much extra time will the lead-safe work
practices take?
Talking with client
Set-up
Work
Clean up
What elements of the job can increase costs?
Labor
Supplies (see checklist)
9/30/2000
5-11
How will the lead activities affect my job?
How much extra time will the lead-safe work practices take?
This question only applies to the portion of the renovation, remodeling, or painting job dealing with lead-safe
work practices. These activities will affect both worker and resident access to areas of the house where the
work is taking place. The length of time the lead-safe practices requires could significantly affect the
scheduling of other activities throughout the house. It is important to estimate the extra time associated with
each phase of the lead-safe work practices when you are planning the project and developing cost
estimates. Talking with the client and educating the client about lead-safe practices will also take up time.
What are the extra costs?
The cost of lead-safe work practices and lead dust control techniques will vary depending on the project's
size, scope, and scheduling. You should consider the following factors when developing a cost estimate:
Extra labor costs associated with performing the activities
Extra supplies needed
To ensure you have the necessary materials on hand at the beginning of a project, it is helpful to review the
checklist of supplies and materials listed on the back of the worksheet. This list includes supplies that will
typically be used on all jobs as well as specialized materials and supplies that may be required only under
unique circumstances. All of the materials and tools in this checklist have been discussed in previous
modules.
9/30/2000
5-11
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
MODULE 5 EXERCISE
Objectives: The objective of this exercise is fourfold:
To evaluate a project's potential to create lead dust and plan your work to
minimize the creation and dispersion of this dust.
To familiarize yourself with the worksheets included in this module and
use them to evaluate a potential scenario.
To discuss ways to talk to clients about lead safe work practices and
ensure they are informed about the dangers of lead dust.
To ensure you understand your requirements related to disseminating
information related to lead-based paint.
Length: Total Time: 35 minutes - 20 minutes working in groups and 15 minutes
discussion
Directions: The following exercise presents a scenario that may be similar to situations
routinely encountered by you or your company. In groups of three to five
(depending on class size), take the next 20 minutes to read over the scenario and
answer the questions on the next two pages. Before answering the questions,
however, complete the attached worksheet. If you need to make assumptions in
order to complete the questions or the worksheet, please be sure to write down
your assumptions and include them in your worksheet and answers.
Background
New property owners have contracted with your company to perform major remodeling work
throughout a house constructed in the 1950's. On the main floor, the work consists of
remodeling the kitchen (existing dimensions are 12' x 15') and adding a new 15' x 15' sunroom
off of the kitchen. This remodeling work includes tearing out existing cabinets, flooring, and a
painted wall. Upstairs, the residents have asked you to renovate the half-bath by removing the
existing linoleum flooring and sink (porcelain sink attached to the wall with plumbing beneath
exposed) and then laying new floor tiles and installing a new sink and cabinet unit. To the best of
the residents' knowledge, no major renovation work has been done on the house since it was
constructed and the former residents never mentioned lead-based paint.
Although the house is currently vacant, the new owners are planning on moving into the house in
the very near future. It is highly likely that they will move in before all of the renovation work has
been completed. The new owners are a couple in their early thirties with two children under the
age of six, and two pet cats that are kept indoors.
9/30/2000
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
MODULE 5 EXERCISE
Complete the attached worksheet based on the information provided in the scenario. After
completing the worksheet, answer the following questions. At the end of the exercise, you may
be asked to share your answers with the class. Be prepared to defend your responses.
1. Was the property constructed prior to 1978 and do you have to utilize lead-safe work
practices?
2. Is this a high dust job? If yes, what components could create high dust levels? What
special precautions should you take to minimize the hazards associated with high levels
of lead dust?
3, How would you schedule the work? When would you perform lead-safe work practices
in relation to the other renovation and remodeling work? Why?
4. How did you develop your cost and labor estimates? Will any special tools or equipment
be needed for this job?
9/30/2000
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
MODULE 5 EXERCISE
The following questions pertain to talking to the residents.
5. What topics, related to lead dust and lead-safe work practices, should you highlight when
discussing the renovation job with the residents? Where could you refer the residents if
they ask for additional information?
6. After discussing the potential lead dust hazards and the associated lead-safe work
practices with the residents, they insist that these actions are not necessary because the
house does not contain any LBP. How do you respond?
9/30/2000
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Module 6
Supervisory and Business Issues
9/30/2000
6- 1
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6-1
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Lesson Overview
Key supervisor responsibilities
Benefits of performing work in a lead-safe
manner
Discussion: Next Steps
9/30/2000
6-2
In addition to understanding how to perform renovation, remodeling, or painting work in a lead safe manner,
supervisors must also be aware of a number of other issues. This module will highlight those issues as well
as the benefits of performing work in a lead safe manner.
9/30/2000
6-2
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
K3S
Key Supervisor Responsibilities
4- Stay informed
Ensure job performance
Manage liability
Manage workers
Maintain records
9/30/2000
6-3
Key supervisor responsibilities are discussed in detail on the following slides.
9/30/2000
6-3
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Stay Informed
State and local regulations pertaining to LBP
> OSHA requirements for worker safety
Waste management and disposal
requirements
9/30/2000
6-4
State and Local Regulations
As noted earlier, states and local jurisdictions (e.g., counties and cities) may have additional requirements
for working on homes with lead-based paint. Supervisors must be familiar with these additional
requirements to ensure that work is performed properly. The National Council of State Legislatures (NCSL)
provides periodic updates to state laws affecting lead-based paint for all states. The 1999 compilation is
located at: http://www.ncsl.org/programs/ESNR/pblaw99.htm
OSHA
Although this training does not specifically address worker safety issues, supervisors are responsible for
ensuring that their workers are properly trained and equipped to work on lead-based paint.
Waste Management and Disposal
As indicated earlier in Module 4 (Cleanup and Disposal), state regulations for waste management and
disposal vary and may be more stringent than federal requirements. Supervisors must be aware of state
requirements. To find out about requirements, contact your state's department of environmental protection
or equivalent. To access State hazardous waste websites go to
http://www.epa.gov/epaoswer/osw/stateweb.htm. This website will point you to specific state sites.
9/30/2000
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
&EPA
Ensure Job Performance
Skill building
Tool kits
4- Planning
Client education
9/30/2000
6-5
Skill building
Supervisors must ensure that their workers have the necessary skills to accomplish the tasks they are
expected to perform. For working on homes with lead-based paint, workers need to know how to contain
and cleanup lead dust created while working.
Tool kits
Supervisors should ensure that their workers have access to the tools and supplies necessary to perform
their jobs in a manner
Planning
Supervisors must be able to plan work on homes with lead-based paint to be efficient in using workers with
the background and skills to accomplish the job. This requires a different set of specs than other jobs.
Know who Is allowed in which spaces. Planning also, as we saw in Module 5 (Planning) requires practice
and skill in estimating the cost of jobs and determining what tasks will need to be performed, how they will
be performed, by whom, and how long it will take to accomplish.
Client education
Using the pamphlet Protect Your Family From Lead In Your Home as an opportunity to explain to your
clients how you will do your work and how that will benefit your client. This information will assist in
educating the client about lead-based paint and help to inform their expectations of the work that you do.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
&EPA
Tool Kits
Setup
+ PPE
* Safe Work Practices
Clean-Up
9/30/2000
6-6
Tool kit tips
Keep kits in separate, labeled containers.
The checklist of materials and supplies in the Module 5 exercise provides in one location a list of all tool kit
items. Additional information on the tool kits can be found in this manual on pages 2-6, 3-8, 3-11, and 4-4.
Tools can be purchased from wholesale tool suppliers, and vendors can be found by looking online and
searching the Internet.
Tool kit summary:
Setup kit: knives (e.g., utility knife), tape, protective sheeting, cones.
PPE kit: disposable coveralls, hat, gloves, respirators, first aid kit, shoe covers, safety glasses, ear
protection for power tools.
Safe work practices kit: HEPA vacuum, other HEPA tools, box of brushes, wet/dry sandpaper.
Clean-Up kit: bottle mister, wet wipes, mop heads, mops, buckets, mop wringer.
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
&EPA
Liability Management
Four methods to limit liability
Contract modifications
Post clean-up testing
Quality control
Insurance
Failure to comply with applicable regulations
could expose contractors to liability
Voluntary work practices presented in this
training may create a new legal standard
913012000
6-7
Liability Management
To avoid legal liability the supervisor should:
Be familiar with industry standards and any applicable laws and regulations
Train workers to handle LBP issues
Provide explanation and records of work in written form, including any hazards to the client
Give written job descriptions that specify tasks, methods, results, and time frame
Be aware of new developments
Provide close supervision of work site
Possible claimants include: clients, residents, health or regulatory agencies, workers and other contractors,
and owners of neighboring properties.
Contract Modifications
Note that the work being performed is not abatement work. Contract modifications should be protective of
contractor.
Contractors have a legal duty to
* Exercise reasonable care in performing work
Warn clients of potential hazards
Be informed about applicable standards and requirements
Supervisors have a duty to act as any reasonable, competent supervisor given the circumstances of the
situation and in accordance with industry standards. Failure to do so can be used as evidence of negligence.
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6-7
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Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Scope of Work for Proposal
Lead Paint Safety Field Guide
Model Specifications
HUD Guidelines
Associations
DUMB
9/3W2000
6-8
Proposals for working in lead-safe manner will require a scope of work different from traditional jobs. The
sources listed below can provide information about the activities for working in a home with lead-based
paint that are different from working on traditional jobs in homes without lead-based paint.
Lead Paint Safety Field Guide
The Field Guide can be found in Appendix 1 of this training. It wilf provide information that can help you
identify the key activities to be performed when working on a home with lead-based paint.
Model specifications
The National Center for Lead-Safe Housing has model job and contract specifications for contractors
working on homes with lead-based paint. Information on how to obtain these model specifications is
available on the internet at http://www.leadsafehQusing.org/html/lead specs.html
HUD Guidelines
These guidelines, formally known as Guidelines for the Evaluation and Control of Lead-Based Paint
Hazards in Housing, are available on the internet at http://www.hud.gov/lea/iearules.htmlfdownloador by
searching on http://www.hud.gov/offices/lead.
Associations
Home construction and similar trade or professional associations can provide assistance, especially if you
are a member.
For example, the National Association of Home Builders (NAHB) could provide assistance on developing a
work scope that identifies critical aspects of working in homes with lead-based paint. NAHB is located on
the internet at http://www.nahb.com
9/30/2000
6-8
-------
Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Insurance
General liability insurance
Certain state and local laws may require it
Most policies contain a pollution exclusion clause
Pollution liability insurance
Errors and omissions insurance
Typically for consultants, risk assessors, inspectors
6-9
See Appendix 4 Liability Insurance Summary Factsheet for a discussion of types and uses of insurance.
Commercial General Liability (CGL) Insurance
CGL Exclusion Section F
CGL policies are readily available at reasonable cost, but typically specifically exclude coverage of
pollution-related claims.
Should include premises and operations liability, contractual liability, independent contractor liability, and
products and completed operations liability.
Try to get the policy endorsed to modify or eliminate the "pollution exclusion"
The policy should be written on an "occurrence" basis. Occurrence policies require that there be bodily
injury or property damage caused by an accident during the policy period, including continuous or repeated
exposure to harmful conditions. There are no restrictions on when a resulting claim or suit must be made or
brought against the insured, as there is in a "claims-made" policy.
Errors and Omissions (E&O) Insurance
Covers professional services rendered, such as by a certified lead-based paint inspector, or a consultant.
Pollution Liability Insurance
Usually attached to CGL or E&O insurance as a policy rider or written as a separate insurance policy
altogether.
9/30/2000
6-9
-------
Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Work Crew Management
Personal protection equipment
Match work crew skills to job requirements
Lead and non-lead work environments
Daily oversight
Daily quality control
Daily checking on cleaning
9/30/2000
6-10
Personal Protection Equipment
Includes respirators (such as an N-100), work suits, hats, shoe covers, etc.
Not only will proper use of this equipment protect workers, but it will also protect clients and worker families
from exposure to lead.
Improper use of PPE can endanger workers.
* Proper training in use of personal protection equipment is essential to ensuring that the equipment will
function as designed.
Skill Matching
This includes ensuring that workers with specific types of training or skills are assigned to tasks that make
use of those skills. For example, you would not assign sole responsibility for laying poly on the floor,
covering vents, windows, and doors to a worker with no previous experience in setting up a room for
renovation.
Daily Oversight
Supervisors are responsible to make sure that workers at the work sites for which they are responsible are
performing work in a manner consistent with containing dust and cleaning it up. Usually this involves
spending time at the work site during the day to verify that work is progressing as planned.
9/30/2000
6-10
-------
Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
&EPA
UMBB
Records Maintenance
Pamphlet
Record of providing Protect Your Family From Lead In
Your Home pamphlet required under the 406(b) rule
Recommend review with client the punch list
of work completed
9(30(2000
Client review
Keeping a record of client approval of work performed can assist in building client confidence in your work
as a contractor and also in managing your liability. The act of obtaining client approval is an opportunity for
a positive interaction with the client.
May be useful for liability protection as proof that contractor completed job and client was satisfied.
Sign-off not always practical: final check clearing bank is legal proof of completion.
Cleanup to a standard of no visible dust may be included in the punch list, and punch list may be reviewed
with client at end of job.
Pamphlet
A copy of this pamphlet is in Appendix 2. Guidance on the 406(b) rule for contractors, property managers,
and maintenance personnel is in Appendix 3. This consists of:
Part I (Revised June 25, 1999)
Correction and clarification of Part I regarding timing of pamphlet delivery (Jun 25, 1999)
Part 11 (October 15,1999)
EPA Questions and Answers on the Pre-Renovation Lead Information Rule (TSCA 406(b)) (June 1998)
9/30/2000
6-11
-------
Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Benefits of Using LBP Safe
Practices
Reduced liability exposure
Increased employee morale
Safer work sites
Better worker health
Marketing benefit
Differentiation from other contractors
Generate positive word-of-mouth and publicity
Market as higher quality work
Provide clients with peace of mind
9/30/3000
6-12
Reduced Liability Exposure
Using work practices that minimize generation of LBP, contain LBP that is generated, and clean up LBP
after completing the work is a critical element in demonstrating that you have performed the work in a
reasonable manner, therefore reducing potential liability.
Employee Morale
Efforts to ensure safer work sites; by extension, better worker health can improve worker morale and
productivity.
Marketing Benefit
Relying on the work practices discussed in this training will lead to satisfied and knowledgeable customers
who will be happy to tell their friends about the work you did. It also allows you to differentiate your
business from other contractors. Word-of-mouth advertising and increased visibility are key elements in
being able to attract new business.
Remember: Your bid may be higher, so you should be prepared to discuss why it makes sense to hire a
more knowledgeable and experienced worker to perform renovation, remodeling, or painting.
9/30/2000
6-12
-------
Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
AEPA
Discussion: Next Steps
What can you do to make each of these
happen?
Prepare toolkits
Set-up to contain lead dust
Use safe work practices
Clean up and check work
Inform and educate clients about lead paint hazards
Revise contract and work scope forms
Other next steps?
9/3012000
6-13
9/30/2000
6-13
-------
Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting
Thank You!
Thank you for your time and for attending
this training course!
9/30/2000
6- 14
9/30/2000
6-14
-------
APPENDIX 1
Lead Paint Safety: A Field Guide for
Painting, Home Maintenance, and
Renovation Work
-------
This page is intentionally blank.
-------
CDC
Pain
Safet
A Field Guide for
Painting, Home
Maintenance, and
Renovation Work
-------
Foreword
The Department of Housing and Urban Development has had great success in
alerting the public to the problems of lead poisoning. With the support of indus-
try, other federal agencies, and community-based organizations, we've helped to
reduce the number of children poisoned by lead in America. But much more
needs to be done if we want every child in America to live in a safe home.
As part of our outreach efforts, we are publishing this field guide on lead safety
work practices. If you perform routine maintenance on homes or apartments built
prior to 1978, this guide will help you plan and safely carry out the work, while
minimizing the disturbance of lead-based paint. Step-by-step instructions detail
what you need to do to work smart and work safe. Our new guide is easy to
understand and small enough to carry to work sites so you can easily follow the
instructions inside.
It's going to take action by all of us to reach our common goal of a lead-safe
America. You can do your part by using this guide and applying lead safety prac-
tices on the job. The families in the homes you work on, the people you work with
- and your own family - will be grateful for it.
Andrew Cuomo, Secretary
U.S. Department of Housing and Urban Development
Acknowledgements
The U.S. Department of Housing and Urban Development (HUD) developed this
guide with the assistance and input of the Centers for Disease Control and
Prevention (CDC), the U.S. Environmental Protection Agency (EPA), and the
Occupational Safety and Health Administration (OSHA). HUD would like to thank
the staff of these agencies for their participation in developing this Field Guide.
HUD would also like to thank all of the renovation, painting, maintenance, and lead
professionals who provided useful feedback. Vicki Ainslie, Dana Bres, Robert
Brown, Kevin deary, Alan Isaac, David Levitt, Linda Lewis, Dennis Livingston, Eric
Oetjen, Roy Reveilles, Ron Rupp, Joe Shirmer, Aaron. Sussefl, Peter Tiernan, David
Thompson, Richard Tobin, Ellen Tohn, Veda Watts, and Mike Wilson served on the
Technical Panel for this project. A special thanks goes to these individuals for their
contributions.
This Guide was developed by the U.S. Department of Housing and Urban
Development's Office of Lead Hazard Control through a contract with ICF
Incorporated. Dennis Livingston created the illustrations and provided technical
content for this Field Guide.
-------
WHY SHOULD I FOLLOW THIS GUIDE?
Renovation of a two-
story, 19th century
house included
removing paint
from floors
and woodwork
; using power
sanders, hand
sanders, scrapers,
torches, heat guns,
and chemical paint strip-
pers. Ceilings were also repaired, and
wallpaper and paint were removed from
several walls. The family that owned the
home temporarily moved out of the house.
They returned when the work was only
partly completed. There was dust through-
out the house.
The family discovered that something was
wrong when one of the family's dogs began
to have seizures. A veterinarian found that
the dog had been lead poisoned. The
mother and children had their blood tested,
and found that all of them had very high
levels of lead in their blood. All three were
admitted to the hospital for severe lead
poisoning.
A painter
was hired to
repaint the
exterior
of
an
old
Vermont home occupied by a
couple expecting the birth of
their first child. The painter
used a power grinder to
remove the old paint from
the exterior siding. While the
painter worked, the window
to the baby's nursery was left
open, and the entire room,
including the crib, became
covered with dust.
Fortunately, the couple
noticed the dust, and under-
stood the potential risk.
They called in another
painter who was qualified to
control lead hazards. He
cleaned up the paint dust
and the newborn baby
moved into a clean, safe
home.
Most Old Homes Contain Lead-Based Paint
Most homes built before 1978 contain some lead-based paint. Lead-
based paint is more common and was used more extensively in homes
built before 1950.
Probability of a House Containing Lead
built before:
1940
V
1960
1978
Homes built before 1950 also used paint that had a higher concentration
of lead.
-------
Poor Maintenance Endangers Children
In poorly maintained houses, lead-based paint, which may be several
layers down, flakes and peels off. Paint failure is usually caused by
moisture problems. Sometimes rubbing or impact causes paint failure.
Doing work improperly can also cause a lot of dust.
Lead-based paint chips and dust then mix with house dust and build up
in window troughs and on floors.
Children are endangered when lead in paint chips, dust, and soil gets on
their hands and toys which they may put in their mouths.
Lead can make children very sick and cause permanent brain and nerve
damage. It can also result in learning difficulties and behavior problems.
This damage is irreversible. It is a tragedy we can prevent.
If paint is kept intact and surfaces are kept clean, children can live safely
in a home painted with lead-based paint.
Uncontrolled or uncontained dust and debris from repainting and/or
renovation that disturbs lead-based paint in a weJi-maintained home can
also expose children to unsafe levels of lead.
Changing Common Work Practices Can Protect Workers and Children
Lead-based paint can also pose a threat to workers by causing damage
to their brains, and nervous and reproductive systems.
With small changes in work practices, workers can protect themselves
and their customers from lead exposure.
These changes include:
a Keeping dust to a minimum.
Confining dust and paint chips to the work area.
a Cleaning up during and after work. Special cleanup procedures must
always be used.
H Taking dust wipe samples to make sure cleaning removed lead-
contaminated dust. (Dust wipe sampling is described in Section 5D,
P-71.)
Who Should Use This Guide?
Building maintenance workers and their supervisors
Painters
Repair, renovation, and remodeling contractors
Property managers and owners
Homeowners
Local housing agency staff and public health staff
When Should I Follow This Guide?
To fix a specific problem.
During routine maintenance or apartment turnover.
In homes where there may be a young child or a pregnant woman.
During work supported by Federal funds that must be performed using
safe work practices under Federal regulations.
-------
OW TO USE THIS GUI
This guide is divided into 5 sections.
To locate a section, bend the bottom
of these pages. Look for the section
you want by lining up the boxes at
the bottom of each page.
-------
CONTENTS OF THIS GUIDE
I. The Basics 5
Remember these Principles 5
Routine Work Practices 6
Correcting the Cause of the Problem 7
Restricted Practices 9
Key Stages of a Job 11
2. Before You Start Work 13
Set Up the Work Area - Interior 13
Set Up the Work Area - Exterior 15
Worker Protection 17
3. Doing the Work 19
Painting Jobs
Q interior Surface Prep 19
Q Exterior Surface Prep 22
Q Paint Removal 23
Home Maintenance and Renovation Jobs
Q Walls/Ceilings 25
Q Windows 29
Q Doors 37
Q Stairs/Floors 41
Q Trim 43
Q High Dust Jobs 45
4. At The End of the Job 47
Cleaning Up 47
Disposal of Waste 49
Checking Your Work 51
Ongoing Monitoring & Maintenance 53
5. Resources 55
A. Glossary 55
B. For More Information 57
C. Getting the Word Out 65
Q How Owners and Occupants Can Work Together to
Improve Lead-Safety in Homes
Q Notice Prior to Renovation
Q Why Lead Safety Makes Sense for Property Owners and
Contractors
D. More About Technical Topics 69
Q Respiratory Protection
Q Testing Dust for Lead
Q Setting Up a Dust Room
Q Building a Door Hold
E. Tool and Supply List 75
F. Notes and Special Instructions 77
G. Work Checklist and Disclaimer Back Cover
-------
REMEMBER THESE PRINCIPLES
1. ASSUME:
2. CHECK:
3. AVOID:
Paint in Homes Built Before 1978 Contains Lead
(Unless a lead-based paint inspection shows it doesn't.)
Exposing Anyone to Dust, Especially Children, is Bad
Federal, State, and Local Regulations
OSHA has rules for worker safety
EPA and your local community have rules for
waste disposal
Creating Dust
Use low dust work practices (for example, mist
surfaces with water before sanding or scraping)
Spreading Dust
Cover area under work with durable protective
sheeting (plastic or poly)
Keep dust contained to immediate work area
4. PROTECT: Occupants, Particularly Children
Keep them away from work area
Clean up work site before they return
Workers
Wear proper respiratory protection for lead dust
Keep clean
Don't take dust home
5. CLEAN UP: After All Work
Clean up is particularly important if painted
surfaces were broken or wall cavities were opened
Take dust wipe samples to make sure that it is
safe for children to return
6. MAINTAIN: A Dry Building
Moisture problems can cause paint failure,
building deterioration, and encourage pests
All Painted Surfaces
Well-maintained paint generally does not pose a
health risk
Clean and Cleanable Surfaces
Keep floors and painted surfaces smooth
Damp mop them often
Clean rugs and carpet well
-------
ROUTINE WORK PRACTICES
The following pictures appear throughout the Guide and refer to specific
sections covering these practices.
Correct the Cause of the Problem. Before work
starts, correct the conditions causing damage to
the home. See Correcting the Cause of the
Problem, p. 7.
Set Up Work Area. Set up the work area
properly. See Section 2: Set Up the Work
Area - Interior & Exterior, p. 13 and p. 15,
respectively.
Clean Up and Clear. Thoroughly clean up the
work area using the procedures described in this
guide. Then, take dust wipe samples to see if it is
safe for children to return. See Section 4:
Cleaning Up. p. 47 and Check Your Work, p. 51.
High Dust Jobs. Some activities are likely to
create high amounts of dust during the job. See
Section 3: High Dust Jobs, p. 45 and follow the
guidelines in this section to ensure that this work
is performed safely.
Important!! This symbol points out important
details where special attention is needed.
-------
CORRECTING THE CAUSE OF
THE PROBLEM
If a job involves repairs to a damaged paint surface, it is
important to correct the cause of the damage, or the
damage will occur again. Damaged surfaces that contain
lead-based paint represent a health threat to the
occupants.
The following conditions are examples of potential causes of damage
to painted surfaces. Be sure that the planned work will correct these
conditions if they are present.
Moisture
From
Outside
Moisture
From Inside
Roof leaks; incorrectly
installed flashing; defective
downspouts and gutters;
water collecting in window
troughs; puddles of water
at foundations; leaking
basement walls; wet crawl
spaces.
Attic condensation due to
poor ventilation; unvented
steam from showers
and cooking; leaking
plumbing and failed seals
around tubs and toilets;
condensation in walls;
unvented dryers; wet and
poorly maintained
basements.
N Ice damv$? »"
-O *
Window
trough
Puddles
Condensation
Insulation
^holding moisture
Unvented steam
Defective seals
, ^-Leaking pipes
^
^Unvented dryer
rO^
Wet basement
'/S/S/' ' ''
-------
Rubbing
and Impact
of Painted
Surfaces
Places that
Collect Dust
and Paint
Chips
Structural
Damage
Binding doors; unprotected
painted walls and trim; and
rubbing from opening and
closing painted windows.
Where feasible, repair or
remove places where dust
and paint chips may
accumulate and can't be
easily cleaned (such as old
wall-to-wall carpet and
unused items stored in the
basement). If
Window
troughs
trapping
dust
Low spots at
foundation
these places
are damp,
they may
also be
home to
mold.
Keep flat
surfaces
(such as
window stools
or interior sills
and troughs)
clean and cleanable.
Some surface damage may
be caused by structural
damage such as wood rot,
termites, foundation
settlement, and foundation
shift. These problems
must be addressed before
surface repairs are made.
Loose
paneling over
failing paint
Wall-to-wall
carpet (use
rugs)
Stored
'cardboard,
newspapers,
old
mattresses,
and unused
cloth
furniture
-------
ESTRICTED PRACTICES
Goal: Don't use unsafe work methods. Some work methods
create such high levels of dust that they must not be used
when working on surfaces that may contain lead-based
paint.
Don't Use Power Sanders or Grinders Without HEPA
Vacuum Attachment.
These machines create a lot of dust that can contaminate a
building and the ground around a building endangering work-
ers, neighbors, and occupants.
Controlled Sanding or Grinding With HEPA Vacuum
Shroud,
Hose to
HEPA
vacuum
Attachment Is Acceptable.
If the sanding or grinding machines
are "shrouded," which means sur-
rounded with a barrier that prevents
dust from flying out around the
perimeter, AND attached to a HEPA
vacuum, they can be used. Because
some dust may still blow out around
the perimeter, workers near the
machine should wear half-mask respi-
rators rated by NIOSH as N100 (or
HEPA) at a minimum. Also, the
work area must be completely
isolated if the machine is used
inside (see Section 3: High Dust
Jobs, p.45). Because these tools
can create high levels of dust and require additional precau-
tions, their use is beyond the scope of this guide.
Don't Use Open Flame/High Heat Removal of Paint.
There is no acceptable use of an open flame torch or high
temperature heat gun (above 1100 degrees F) to remove
paint.
It produces toxic gases that a HEPA dust canister on a res-
pirator cannot filter out on its own (a second, organic filter
is necessary).
It creates high levels of very toxic dust that is extremely
difficult to clean up.
It can burn down a house.
Do Use a Heat Gun on Low Setting.
A heatgun set below 1100 degrees F may be used with cau-
tion. It is recommended for small areas only, such as the
edge of a door, the top of a window stool, or the friction sur-
face of a window jamb.
-------
10
Don't Use Paint Strippers Containing Methylene Chloride.
Many paint strippers are potentially dangerous. Strippers con-
taining methylene chloride should not be used because this
chemical is extremely toxic and is known to cause cancer.
Other Chemical Strippers with Appropriate Precautions Are
Acceptable.
Chemical strippers without methylene chloride are safer to
use, as long as the precautions printed on the container are
followed. Take extra precautions to mask areas near stripping.
Don't Use Uncontained Hydroblasting.
Removal of paint using this method can spread paint chips,
dust, and debris beyond the work area. This result makes it
difficult to clean up these hazards at the end of the job.
Contained Pressure Washing Is Acceptable.
Removal of paint using contained pressure washing within a
protective enclosure to prevent the spread of paint chips,
dust, and debris may be done. Because this method requires
additional precautions that are beyond the scope of this
guide, it should only be used by certified lead abatement
workers.
Don't Use Uncontrolled Abrasive Blasting.
This work method can also spread paint chips, dust, and
debris beyond the work area. This result makes it difficult to
clean up these hazards at the end of the job.
Contained Blasting Is Acceptable.
Contained abrasive blasting within a protective, locally
exhausted enclosure to prevent the spread of paint chips,
dust, and debris may be used. Because this method requires
additional precautions that are beyond the scope of this
guide, it should only be used by certified lead abatement
workers.
Avoid Extensive Dry Scraping or Sanding.
Extensive dry scraping or sanding create large amounts of
paint chips, dust, and debris that are hard to contain.
Use Wet Methods or Limited Dry Scraping and Sanding.
Mist surfaces before scraping and sanding. Continue to mist
while working. Dry scraping or sanding of very small areas
(for example, around light switches or outlets) may be done if
flat surfaces below these areas are covered with protective
sheeting. These methods should be avoided on areas larger
than 2 square feet per room, and workers must have
adequate respiratory protection.
-------
KEY STAGES OF A JOB
Quality work requires thinking through the job from start to finish.
Here are the basic stages of the jobs described in this guide.
Before
Starting
Work
Finish the
Job
Maintain the
Work
Find the causes of damage
Prioritize work
Hand out lead hazard information pamphlet (see
note below)
Set up work area
Separate work space from occupied space
Isolate high dust areas
Correct cause(s) of problem(s)
Complete the job using safe work practices, such as
those shown in this guide
Clean up thoroughly
Dispose of waste safely
Check quality of work and correct problems
Educate occupants about risks from lead-based
paint
Maintain a safe and healthy home
Renovation Notice About Lead Safety
Note: Federal law requires that owners and occupants of a house or
apartment built before 1978 receive the pamphlet Protect Your
Family From Lead In Your Home prior to the start of renovation
work. The requirement applies to any work that will disturb a paint-
ed surface larger than 2 square feet when the work is done by:
Contractors who have been hired to dp any kind of work.
Among others, this can apply to painting, drywall, and electri-
cal trades.
Owners of rental properties who have work performed by
maintenance staff.
See p. 67 for more information about this requirement.
-------
12
-------
SET UP THE WORK AREA INTERIOR
Restrict
Access
Protect
Floor
Protect
Furnishings
Stock the
Work Area
Ask occupants to leave
the room where work will
be done.
Have them stay out until
final cleanup.
Place "DO NOT ENTER"
tape across doorway or
post sign.
Caution: If the work will
create a large amount of
dust, follow the guidelines
in Section 3: High Dust
Jobs, p. 45.
Place protective sheeting
on floor extending about
5 feet from the work area.
Tape protective sheeting
to the baseboard under
work area using masking
tape (or durable tape
where masking tape
doesn't work).
Remove drapes, curtains,
furniture, and rugs within
5 feet of work area.
Cover any furniture within
5 feet of work area that
cannot be moved.
* Put all necessary tools
and supplies on protec-
tive sheeting before
beginning work to avoid
stepping off the protec-
tive sheeting.
^^
Use
protective
sheeting,
such as
poly
Reinforce
corners
with duct
tape and
a staple
Cover furniture with
protective sheeting
-------
Tracking
SetUp
Dust Room
(Optional)
To avoid tracking dust off
the protective sheeting,
wear non-skid shoe cov-
ers on protective sheeting
and remove them each
time you step off the pro-
tective sheeting.
OR
Wipe both top and bot-
tom of shoes with a
damp paper towel each
time you step off the pro-
tective sheeting.
OR
Clean off shoes using a
tack pad (a large sticky
pad that helps remove
dust).
OR
Remove shoes every time
you step off the protec-
tive sheeting.
When working on compo-
nents that can be moved,
such as doors and win-
dow sashes, consider set-
ting up a dust room. A
dust room is an area
isolated from occupied
areas where workers
can do dust generating
work. The door of the
room is covered
with a flap and the
floor is covered with
protective sheeting. See
Section 5D: Setting Up a
Dust Room, p. 73.
Using a dust room con-
tains dust and paint
chips, and makes cleanup
easier. It also helps pro-
tect occupants, as well as
other workers.
-------
SET UP THE WORK AREA EXTERIOR
Protect
Ground
Attach
Protective
Sheeting to
Wall
Build Curb
When working on the
ground floor, lay protec-
tive sheeting 10 feet
from work surface or as
space permits. When
working on the 2nd
story or above, extend
the sheeting farther out.
Vertical shrouding on
scaffolding should be
used if work is close to a
sidewalk, street, or
another property, or the
building is more than
three stories high.
Important: Covering the
ground protects the soil
from contamination by
lead-based paint chips
and dust.
Protective sheeting can
be taped and/or stapled
to wood siding or ribbon
board. A wood strip
may need to be attached
to a masonry wall.
Build a curb around
work perimeter when a
sidewalk or another
property is near, or when
wind may blow debris
off protective sheeting.
Caution: This may pose a
tripping hazard.
Duet tape
and
staple
protective
sheeting
Attach wood
strip to brick
to secure
protective sheeting
Curb edge of protective
sheeting
-------
Cover
Windows
and Doors
Use Ladder
Safely
All windows and doors
within 20 feet of the work
area must be closed. If
they cannot be closed,
seal with protective
sheeting during work.
If an entrance must be
used that is closer than
20 feet, place a shroud
above and on the sides
of the entrance.
Don't use a metal ladder
near power lines.
Check feet and rungs of
ladder to make sure they
are sound.
Place the base of the
ladder at a distance from
the wall using a height
to base ratio of 4:1.
Ladder should extend 3
feet past the top of the
surface area where work
will be done.
If using protective
sheeting to cover the
ground, cut slots in the
sheeting and place the
ladder feet directly on
the groundnot on top
of the protective sheeting.
Tie off the top of the
ladder, where possible.
If the work is taking
place at heights above
10 feet, tie off the ladder
and secure yourself with
a lanyard and harness.
16
20'-
20'
Stand
off
Safety
harness
Tie
-------
WORKER PROTECTIO
Protect Your
Eyes
Keep
Clothes
Clean
Use
Disposable
Covers
Wear
Respiratory
Protection
Post
Warning
Wash Up
Always wear safety
goggles or safety glasses
when scraping,
hammering, etc.
* At end of work period,
remove dusty clothes
and/or vacuum off dust.
Wash them separately. Do
not use compressed air to
blow dust off clothing.
Wear disposable protec-
tive clothing covers.
Disposable protective
clothing covers can be
stored in a plastic bag
and reused if fairly clean
and there are no rips.
Small tears can be
repaired with duct tape.
Wear painter's hat to pro-
tect head from dust and
debris.
When work creates dust
or paint chips, workers
should wear at least a
NIOSH-approved respira-
tor for lead work. See
Section 5D: Respiratory
Protection, p. 69.
Post sign and avoid eat-
ing, drinking, or smoking
on site.
Wash hands and face each
time you stop working.
Disposable
suit&
shoe
covers
-------
-------
INTERIOR SURFACE PREP
SOLUTION
A wall or ceiling is sound, but has holes, uneven surfaces,
or flaking and peeling paint.
Prepare wall or ceiling to create a sound, intact surface
for painting. Use methods that create a minimum
amount of dust.
Setup
Remove
Deteriorated
Paint
Fill and
Patch
Holes
Prep
Surface
Clean Up
and Clear
See Section 2, p. 13.
Wet scrape any
loose, peeling, or flak
ing paint.
If removal of damaged
edges is necessary, mist
surface before removal.
Skim and fill holes and
cracks less than 1/16 inch
wide with a non-shrinking
spackle compound.
If sanding is necessary
to feather edge, use wet
abrasive sponge or wet-
dry sandpaper with water.
Clean wall, particularly in
kitchen area.
De-gloss surfaces as
necessary (use liquid
sandpaper or wet-dry
sandpaper with water).
Important: Allow surface to
thoroughly dry before priming.
Prime surface using
high-grade primer.
Apply top coat. Use one
or two coats as
necessary.
See Section 4, p. 47.
-------
20
INTERIOR SURFACE PREP COIMT'D
ILIITIOM
A wall or ceiling has cracking, peeling, or alligatoring paint,
but most of the surface is sound.
Use a coating designed for longer durability than paint.
Some of these coating systems include mesh.
Setup
Test
Surface
Apply
System
Base Coat
Apply Mesh
See Section 2, p. 13.
Liquid Coating
Where a long-lasting system (sometimes called
encapsulant) is to be brushed, sprayed, or rolled,
surface preparation is very important.
If an encapsulant is used, use one that is approved
by a state government. If your state does not have
a list of approved encapsulants, it is recommended
that you check with a state that does. Contact the
National Lead Information Center at 1-800-424-
LEAD for the telephone numbers of states with lists.
A sample area should be tested before application.
Follow manufacturer's instructions exactly.
Apply system base coat with a high nap
(approximately 3/4 inch) roller. Follow the
product instructions.
Mesh System
Where there is extensive
cracking or alligatoring,
consider using a system
that includes mesh
because it can add
strength and durability.
Cut the mesh leaving a 2
inch overlap at ceiling
and baseboard.
Install so that mesh is
plumb.
Important: For mesh sys-
tems, follow manufacturer's
instructions exactly.
-------
Apply Mesh
Confd
Clean Up
and Clear
Press mesh into the
base coat with a wall-
paper brush, spackle
knife, or roller.
Overlap seams by 1
inch. Cut down the cen-
ter of the seam and
remove the 2 waste
strips. Let seams butt
against each other.
Using a spackle knife,
press the mesh at the bot-
tom and top. Then cut off
the excess.
Roll on the top coat.
Make sure that there is
complete and even
coverage.
If there is a risk of
further peeling, the top
edge of mesh can be
reinforced with cove or
crown molding, and the
bottom reinforced with
base cap.
See Section 4, p. 47.
Cut off excess
top and bottom
-------
22
EXTERIOR SURFACE PREP
Exterior wood surface is chipping and peeling and may be
painted with lead-based paint.
Prepare a sound, intact surface for painting. Use methods
that create minimal dust.
Setup
Clean
Surface
Wet Scrape
Mist and
Sand
Paint
Clean Up
and Clear
Dispose of
Water
See Section 2, p. 15.
Clean wood with deter-
gent {or lead-specific
cleaner) and scrub brush
Wet scrape woodwork
and siding. Mist small
areas frequently to keep
down dust. Using a
pump sprayer in a
knapsack is convenient.
Wet sand using wet-dry
sandpaper or wet
sanding sponges. A
power sander may be
used if attached to a
HEPA vacuum, and the
worker is wearing
respiratory protection.
Prime and paint.
See Section 4, p. 47.
If you dislodge paint
using pressure washing,
water must be collected
and may need to be test-
ed (see local regulations
for water disposal proce-
dures in your area).
-------
P A I
E M O V A L
SetUp
Chemical
Removal
Areas of paint are peeling or flaking or there is evidence
that a child has been chewing on a painted surface. An
example of a surface accessible to children is the inside
nose of a window stool {inside sill).
Remove all paint using methods that do minimum harm to
the surface, create minimal dust, and are safe for workers.
See Section 2, p. 13
or p. 15.
When using chemical
strippers, the edge of
the protective covering
below the painted surface
must be tightly fastened
to the wall so that the
stripper doesn't damage
other surfaces.
Second layer
of protective
sheeting
Recommendations:
Use a second fay
protective sheeting
collect stripping
waste. The
first layer
remains in place
protect surfaces below.
For removable components, consider having
paint stripped off-site or installing an
entirely new component.
If a large area of paint is to be stripped, consider
hiring a professional.
Follow the manufacturer's instructions carefully when
using chemical paint strippers.
Caution: If using a caustic stripper, neutralize the
surface according to the manufacturer's directions
before applying new paint
-------
Chemical
Removal
Cont'd
Hand
Stripping
Mechanical
Stripping
Heat
Stripping
Clean Up
and Clear
24
After stripping paint from
wood, a paint residue
will remain in the wood.
Use caution when
sanding the bare wood
because it may contain
lead residue.
Paint can also be
removed with a paint
scraper. Be sure to mist
areas where paint is to
be removed. Using a
hand plane removes all
paint and all residue. It
also creates very little
dust.
When using power tools,
such as sanders or
grinders to remove or
feather paint, make sure
the tool is shrouded and
attached to a HEPA
vacuum. Respiratory
protection is still
necessary.
Caution: High dust
potential.
When using a heat gun
to remove paint, be sure
the temperature setting
is kept below 1100
degrees F.
See Section 4, p. 47.
Hose to
HEPA
vacuum
-------
DAMAGED INTERIOR WALL OR CEILING
SOLUTION
SetUp
Cover With
Dry wail
On Base
Behind
Base
Wall or ceiling area is too
badly damaged to repair, and
demolition would create a
large amount of dust.
Install a new durable surface
over the damaged area using
methods that create little dust
and do not require demolition.
See Section 2, p. 13.
Mechanically fasten
drywall or veneer board
through damaged plaster
to studs.
Seal the perimeter, par-
ticularly the bottom edge.
Lath
Stuo\
Plate
Damaged plaster
Cap
Base
Shoe
Avoid removing existing
base.
Caution: High dust
potential.
Where drywall lami-
nate will end above exist-
ing base, install shoe or
cove molding into bead of
caulk to seal.
If laminate comes close
to flush with base face, a
strip of lattice bedded in
caulk can be used to
seal joint.
Where base will be
replaced, bed the new
base in bead of caulk on
the back and bottom.
Then, bed shoe molding
in a bead of caulk to seal.
Old
plaster
Drywall laminate sits
on old base
/New drywall
bedded
in caulk
Lattice
strip if
, necessary
.X/^
&*-^ Original
base
New base over drywall
laminate
Old
plaster
New
drywall
Old plaster Mew drywall
1 laminate
New base
in
-------
Install
Wainscoting
Repair
Holes in
Ceilings
Clean Up
and Clear
1 Where bottom 3 or 4 feet
of wall is damaged
beyond repair, the wall
can be enclosed with
wainscoting. The wain-
scoting can be installed
above the existing base-
board.
Bed the lower edge in a
bead of caulk with a trim
piece also bedded in caulk.
Finish top with cap
molding.
When laminating
drywall to ceil-
ings, it is critical
to screw into
joists, not lath.
Old joists may
be irregularly
spaced, so each joist
center must be located.
A drywall dagger can be
used to find the joist
edge, as can a heavy
gauge wire pushed
through the plaster.
The drywail edges
should be taped
and spackled.
If walls will not
be spackled,
perimeter edges
can be finished
with "J" channel bed-
ded in a bead of
caulk.
See Section 4, p. 47
26
1-piece cap
2-piece
cap
Fill center of hole
if larger than 16"
Chalk line
mark
Start first
row in center
Push
wire through
plaster to find
edge of joist
dagger
hits joist
"J" channel
Once against ceiling, push
"J" channel into bead of
caulk
-------
DETERIORATED EXTERIOR SURFACES
An exterior painted surface is badly damaged.
SOLUTION
SetUp
Install
Siding
Whenever possible, repair the surface, prep, prime, and paint
exterior trim and siding, and then maintain the surface. This
method is the preferred approach.
When a surface is too badly damaged to repair, install vinyl or
aluminum siding, or aluminum wrap to create a safe, durable
covering that protects the surface and does not cause further
deterioration.
Note: Siding must be installed correctly or it may lead to
wood rot and/or interior paint failure. Siding may also
become home to insects and mold. Correct installation is
critical in both hot and cold climates.
Cover Deteriorated Surface With Siding
See Section 2, p. 15.
Carefully follow the
manufacturer's
instructions for installing
siding over an existing
surface.
Use a styrene backboard
with an R-value of at
least R2.
Take care to properly
install flashing,
especially at horizontal
trim and window and
door heads.
The siding system must
be well vented but sealed
at the bottom to prevent
flaking and peeling paint
from falling from behind
the siding to the ground.
Be sure that water can
drain out.
MEW:
Flashing
EXISTING:
Trim
Sheathing
Siding
Backer-
board
J channel J
(end \ /i
drain) \j^
Flashing
Window
head
/
-------
Clean Up
and Clear
Important: The entire home
should be well ventilated to
prevent moisture build-up
that can cause structural
damage and/or paint
failure.
See Section 4, p. 47.
28
-------
STICKING
SOLUTION
Setup
Loosen
Painted
Sashes
Remove
Inside Stop
Molding
Remove
Bottom
Sash
Window sticks,
and paint on
window is flaking.
Remove window,
scrape or plane,
repaint, and
reinstall, OR
install a new
window.
Top sash
Parting bea
Stool (or interior sill)
Jamb
extends
to
outside
Inside
stop
Bottom sash
Outside stop
Trough
Apron
See Section 2, p. 13.
If window is painted
shut, mist and cut win-
dow joint with utility
knife. Then open joint
between sash and stop
with a "window opener."
Mist while working.
Mist and remove stop
molding from sides and
head. Dispose of
properly unless it has
historic value.
If counterweight cord or
chain is attached to the
sash, knot it or tie it to a
stick when removing
from sash so it does not
get pulled into the
weight compartment.
-------
Remove
Top Sash
Wet Scrape
or Plane
Repair,
Reglaze,
Seal, and
Paint
Repair and
Paint Jamb
Reinstall
Sash
Clean Up
and Clear
Mist and remove parting
bead. Then remove the
top sash.
Set sash on a work bench,
clamp, and wet scrape all
surfaces. Or use a power
planer attached to a HEPA
vacuum.
Caution: High dust poten-
tial. This work can be done
in a dust room. See
Section 50: Setting Up
a Dust Room, p. 73.
Reglaze and repair as
necessary. Wet sand,
prime, and paint sash
and jamb. Seal, but do
not paint sash edges.
Important: Seal bottom
edge of sash, particularly
end grain.
Repair jamb it necessary.
To prevent dust and chips
from falling outside the
window, install a scoop
of protective sheeting.
Then wet scrape, prime,
and paint.
Reinstall sash with new
or wet scraped and
repainted stop and part-
ing bead.
See Section 4, p. 47,
30
Wet scrape these
ridges of paint
Seal this bottom edge very well,
particularly the end grain. Use
linseed oil or other sealant.
Protective sheeting
-------
LOOS
W I
D O W
SOLUTION
Setup
Remove
Sashes and
Paint
Cut Jamb
Liners
Install Jamb
Liners
Loose sashes (lower and upper) do not operate smoothly,
and they allow heat loss. Also, sashes rubbing against a
painted jamb create paint dust.
Install sashes in window compression jamb liner to seal
window and allow sashes to move easily without rubbing
against jamb. If sashes or window components are badly
deteriorated, replace window.
See Section 2, p. 13.
Install Window Jamb Liners
Follow directions on
pages 29 and 30.
Cut liners to fit in jamb
(1/4 inch short of dimen-
sion). If pulley system is
being saved, cut off
directly below pulley.
Press jamb liners onto
sash.
Attach jamb liners with
brass screws on top and
bottom of each side.
Window jamb
liner installed
below pulleys
to keep
counterweight
system
working
Press
jamb
liners
onto
edge of
each
sash
Slide sashes
and liners into -
jamb and f(
put two
brass
screws into
each side
-------
Install Stop
Molding
Choose an
Option
Clean Up
and Clear
Install new inside stop
molding tight against
jamb liner.
32
Counter-
weight
If top sash is painted
shut and is to remain
fixed, adjust the above
steps as follows:
Cut away flange
between channels of
jamb liner.
Leave parting bead
intact and install
bottom sash as above
Replace Sash/Window
If the sashes or other
components are too
badly deteriorated to
save, consider one of the
following options:
Install new sashes in
tilt-in jamb liners.
Replace sashes,
stops, and parting
bead with a vinyl or
aluminum window
unit.
Replace entire
window includ-
ing jamb casing,
stool, and apron.
See Section 4, p. 47.
/
/ Window
New jamb liner
stop
Cut flange of jamb liner
with plexiglass cutter.^
-------
WINDOW WON'T STAY OPE
Setup
Open
Counter-
weight
Panel
Vacuum
Remove
Counter-
weight
System
Reinstall
Counter-
weight
System
Window sash is loose and won't stay up without sup-
port. Propping the window open presents a
danger to occupants, particularly children.
When a window jamb liner is used, it may
not be sufficient to keep the window
open. (See page 31.)
Repair counterweight system or
install hardware so the window will
stay open securely, or replace window.
See Section 2, p. 13.
Option #1: Reinstall Counterweight System
Find top of panel. Mist
and scrape paint from
top edge to find screw or
nail holding in panel.
Remove screw and pry
off panel.
Vacuum weight compart-
ment with HEPA vacuum.
Remove old rope or
chain from counter-
weight and edge of
sash.
Cut chain so weight is
above bottom of weight
compartment when open
and weight is below pul-
ley when closed.
-------
Reinstall
Counter
Weight
System
Cont'd
Install
Spring Clips
Install Slide
Bolt
Attach
Hardware
Clean Up
and Clear
Drop chain over pulley
into weight compart-
ment, pull out through
panel opening, and
attach to weight.
Attach other end to edge
of window sash using
spring fixture. You may
want to secure chain
with fence staple.
Option #2: Install Spring Clips
Screw spring clips on to
window as directions
indicate. (2 styles
shown.)
Weight
hardware
34
Option #3: Install "Hold Open" Hardware
Screw slide bolt to bot-
tom of window sash. Tap
bolt to mark where you
want to drill holes for
bolt. Drill holes in inside
stop at 3 or 4 points.
Attach hardware that
uses spring to press
against stop. To move
sash, press lever. Release
lever when window is at
desired height.
See Section 4, p. 47.
Bolt slides
into
holes in
inside stop
Spring forces
rubber shoe
against stop
I
I
-------
DETERIORATED WINDOW TROUGH
SOLUTION
SetUp
Drill
Dent
Storm window traps water
behind the frame causing paint
deterioration and damage to
the sill.
Drill a drain hole through bottom
of the storm window frame.
Window trough surface is dam-
aged and difficult to clean.
Install smooth and cleanable
surface in window trough.
BEFORE
Water trapped
behind storm
window frame
AFTER
See Section 2, p. 13.
Drill Drain Hole
To allow drainage, drill 2
holes through frame of
storm window flush with
sill. Drill holes approxi-
mately one quarter of
the way from both sides.
First, drill a 1/8 inch pilot
hole, then the 3/8 inch
hole.
If flashing is installed in
window trough and cov-
ers any part of the drain
hole, run awl through
drain hole. Tap with
hammer to form dent in
flashing to drain out
water.
with
exterior sill lets
6 ' water out
-------
36
Wet Scrape
Cut
Chisel or
Notch
Check Fit
Fasten
Install
Flashing
Seal
Clean Up
and Clear
Cover Trough with Flashing
To make surface flat, wet
scrape high points and
remove any fasteners
from trough.
Cut flashing 1/4 inch
shorter than the width
and length of trough.
To allow flashing to fit
tight to jamb, drive chis-
el under parting bead
and outside stop or
notch each side of the
flashing at these two
points.
Then slide flashing in to
check fit. Remove and
trim if needed.
To fasten flashing, run
bead of adhesive cauik
around perimeter of trough.
Bed flashing in adhesive
caulk bead and press
down.
Run a bead of caulk
around perimeter of flash-
ing. If necessary wipe off
excess caulk with damp
cloth. Try not to smear
caulk on face of flashing.
Important: Do not cover
drain hole with caulk,
See Section 4, p. 47.
-------
DOOR NEEDS ADJUSTMENT
SetUp
Check Door
Remove
Screws
Fill Hole
Edge of door is crush-
ing against jamb on
hinge side; or door is
rubbing on latch side
because hinges are
loose. When paint on
a door rubs or is
crushed, dust and
paint chips can result.
Adjust the door so that
it opens and closes
without damaging
painted surfaces.
Head
casing
See Section 2, p. 13.
Grasp knob and try to
move door up and down
If hinges are loose, door
move.
Remove screws that are
most loose, but not all
screws, so door remains
hung.
Clear paint from
screw notch with
hammer and small
screwdriver.
Unscrew. If screw head
is stripped, use screw-
driver bit in a brace.
Drive 3/16 inch or 1/4 inch
dowel into screw holes as
necessary to fill each hole.
Cut dowels flush.
Head jamb
Casing
-Door
stop
u Insert dowel
in old screw
holes
-------
Install New
Screws
Adjust Stop
Check
Clearance
Adjust
Depth of
Hinge Leaf
Clean Up
and Clear
Replace screws. Use
longer screws if necessary.
Using a screwdriver bit on
a brace makes this easier.
Then remove and replace
remaining screws as
necessary.
Face of door should only
contact the stop on the
latch side of doorframe.
It should not crush or rub
head or hinge side stop.
Where stop is nailed,
remove and replace with
new matching stop.
Leave 1/8 inch space be-
tween hinge, head stop,
and the face of the door.
If putty knife can't fit in
gap between door and
jamb at all points, crush-
ing of painted surfaces
may be occurring.
If door is crushing hinge
side and there is more
clearance than necessary
on the latch side, install
metal shims behind hinge
leaves. Keep at least 1/8
inch clearance on leaf side
and 1/8 inch clearance on
latch side. If not enough
clearance, see p. 39.
If only a small increase
is needed between leaves
of hinge to create a gap
between door edge and
jamb, place a steel rod
between hinge leaves
near pin and close door
to slightly bend apart
leaves.
See Section 4, p. 47.
38
Contact
Check perimeter
of door for
clearance
of 1/8"
to 3/16"
Crushing
Space
Add shim
stock
Use steel rod
(like screwdriver) to
bend open hinge
(Drawing is exaggerated)
-------
OOR RUBS O
STICKS
SOLUTION
Door is scraping on latch side; or door is crushing jamb on
latch side and there is not enough clearance on latch side to
add shims to hinges. When paint on a door rubs or is
crushed, paint chips can result.
Plane edges of door so that it operates smoothly and does
not rub.
Setup
Remove
Hinge
Leaves
Hand Plane
Edge
Recut
Gains
Seal Edges
Clean Up
and Clear
See Section 2, p. 13.
Remove pins from
hinges and hinge leaves
from door.
Set door on edge in a door
hold. (See Section 5: Build-
ing a Door Hold, p. 74.)
Mist surface and hand
plane a chamfer edge.
Use a smooth bench or
jointer plane (not a block
plane) to remove the rest
of the paint from the
edge. Continue to mist
while working. If a power
planer is used to remove
paint, it must be attached
to a HEPA vacuum.
Some power planers need
an adaptor to accept
HEPA attachments.
Once paint is removed, use
either a hand or power
planer.
Then, recut gains as
necessary so hinge leaf is
set about halfway into gain.
Seal edges of door, par-
ticularly the bottom,
and rehang.
See Section 4, p. 47.
Floor
covered
? with
protective
. j^ sheeting
Door hold
(See Section 5D, p. 74)
Only contact
point i All other spaces
1/8" to 3/16" wide
Chamfer.
edge
Hinge gain
-------
40
-------
CHIPPING PAINT ON STAIRS OR FLOOR
SOLUTION
Painted staircase treads, risers or floors are worn, or the
paint is chipping. Paint and other coatings used on staircas-
es and floors in older homes often contain lead. Everyday
friction and wear can produce paint chips and dust.
Cover portions of stairs or floor that are worn with durable
material.
Setup
Stairs -
Wet Scrape
Prime and
Paint
Install Riser
Enclosure
Fasten
Cut and
Install
Tread Cover
,, v/
Stringer
See Section 2, p. 13.
Option #1: Install Tread Covers and Riser Enclosures
Nose of tread
Mist and wet scrape any
loose paint on treads
and risers, particularly
on edges.
Prime treads and risers.
Paint edges that will not
be covered by enclosures.
Cut 1/4 inch lauan ply-
wood to fit each riser.
Sand exposed edges of
lauan.
Back caulk perimeter of
riser with adhesive
cauik. Press tight or nail
with finish naits.
// nose tread is not worn
Cut cover to fit over the
tread and nose.
Install cover with adhe-
sive caulk or screws.
Lauan
plywood
-------
42
Cut and
Install
Tread Cover
Install
Metal Nose
Cover
Wet Scrape
Prime and
Paint
Install
Runner
// nose tread is worn (|lji
Installing a rubber tread over a worn
tread nose creates a hollow space
under the rubber tread cover. This can
cause the rubber tread cover to tear,
posing a tripping hazard.
Cut tread cover to fit from
the riser to rear edge of
nose. Install with adhe-
sive caulk or screws.
Screw metal cover over
edge of tread nose. It
will span the worn area
of the nose.
Stairs - Option #2: Install Staircase Runner
Mist and wet scrape any
loose paint on tread and
riser, particularly on edges.
Prime and paint treads
and risers.
Staple runner to top of
top riser. Then fasten
with staircase bars so
runner may be easily
removed for cleaning.
Prep
Surface
Cover
Clean Up
and Clear
important: Do not install runner
or tread cover on landing of
upper floor where its rear edge
may become a tripping hazard.
Floors
If a floor needs to be refinished, use a
floor sander attached to a HEPA vacuum.
Caution: High dust potential.
Apply a coating to the floor to keep it
smooth and cleanable.
To maintain a smooth and cleanable
surface, it is recommended that the use
of wall-to-wal! carpeting be avoided.
Area rugs can be used instead.
See Section 4, p. 47.
-------
CHIPPED OR DAMAGED IMPACT SURFACES
ILSmOH
Outside corners of waits, edges at passages, as well as
trim, base cap, and shoe molding are being chipped due to
impact from doors, furniture, and other objects. If these
surfaces are covered with lead-based paint, the paint chips
and the dust created may pose a health threat.
Protecting these surfaces with a durable material can pre-
vent the creation of paint chips and dust.
Setup
Enclose
Outside
Corner
Protect
Base
Clean Up
and Clear
See Section 2, p. 13.
Cover outside corners of
walls with corner mold-
ing. Attach with nails
and/or with a bead of
adhesive.
In places where a base-
board shows signs of
impact, replace shoe and
protect cap with lattice
strip.
When replacing shoe,
bed new shoe in bead of
caulk to seal out mois-
ture and prevent infiltra-
tion of dust.
See Section 4, p. 47.
Decorative
corner f
molding .]
Straight
corner
molding
New
lattice
Pi
L.u
*
Bead of
ulk
New
shoe
molding
DOING THE WORK
-------
44
-------
HIGH
DUST
JOBS
Some jobs create large amounts of dust. To be safe, workers
doing this type of work should:
1. Wear half-mask respirators rated by NIOSH as N100 (or
HEPA) at a minimum and be trained to wear and maintain
them, or conduct air monitoring to show that they are not needed.
(See Section 5D: Respiratory Protection, p. 69.)
2. Completely isolate the work space from occupied spaces and use con-
tainment to protect other workers. (See next page.)
3. Receive lead worker or supervisor training from an accredited trainer.
In most states, accredited courses are available. To locate a course in
your state, contact the Leadlisting at 1-888-Leadlist (1-888-532-3547)
orwww.leadlisting.org.
Remember: All house dust is unhealthy to breathe. It may
contain lead, mold, asbestos, gypsum, roach waste, dust
mites, coal dust, fiberglass, etc.
Examples of
High Dust Jobs
The following types of work are likely to create
high levels of dust:
Demolition. Demolition
includes tearing off siding i
and/or demolishing old
plaster walls.or ceilings.
Removing old
paneling can
release large
amounts of
dust.
Opening Up Wat!
Cavities. These jobs
include:
Removing old paneling and
baseboards
Removing door casings and frames or window
casings or jambs
"It's not just what's on the wall,
it's the dust behind it."
Removing Old Drop Ceilings. Lots of dust can
accumulate above ceiling panels.
Improperly Removing Wall-To-Wall Carpet. A
carpet that's been on the floor for many years has
gathered large amounts of household dust, which
may include lead dust, improperly removing it can
release a large amount of dust.
-------
46
Paint Scraping. Scraping large painted areas, such
as the side of a house or an entire room, even when
done correctly, can create a large amount of dust.
Containing Dust
Use this system to keep dust from spreading to
another room.
Slack
Foid protective sheeting at top
and bottom before taping to
leave slack.
Duct tape protective sheeting to perimeter of
opening. Leave slack at the top and bottom.
Staple corners for reinforcement.
Cut slit in protective sheeting to with-
in 6" of top and bottom. Duct tape
may be used for reinforcement.
Then tape another sheet of
protective sheeting to top of
door. Cut just short of floor.
Staple top corners.
If a job creates extremeVhTgl) amounts of dust (for
example, demolition) or large amounts of dust in the
air for more than short periods, the protective flap
system shown above may not be sufficient to pre-
vent dust from spreading beyond the work area.
For these types of jobs, a more protective system
called "isolation" is needed so that dust does not
spread beyond the work area. Isolation means that
the work area is sealed with no direct access to
occupied areas of the home. Workers need to use
an entrance that is separate from occupants until
cleanup is completed.
-------
I
It is very important to use proper cleanup procedures at the end of the 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.
Pick Up
Work Area
Pick Up
Protective
Sheeting
Vacuum
Mist and
Scrub
Pick up large chips with
damp paper towel.
AND/OR
Mist then push dust into
dust pan.
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 again within the
same work area if it has
not already been folded.
HEPA vacuum all hori-
zontal surfacesslowly.
Vacuum ail ledges, sills,
stools, molding tops,
dusty surfaces, etc.
Vacuum floor under
work area. Use corner
tool in corners, cracks of
trim, and between floor
boards.
Vacuum floor with floor
brush and carpet with a
carpet tool.
Important: Vacuum carpet
very slowly.
Wet rag with detergent
then wring out.
Mist surface or rag as
you clean.
Lead needs scrubbing, not
just wiping.
Make dust pan from
flashing and clean
with a whisk
broom.
Vacuuming
the cracks
is very
important.
Rinse
side
AT THElEND'OF/iTlilEilliB.
-------
Rinse Rag
Mist and
Scrub
Squeeze
Out and
Wash
Rinse
Dispose of
Waste
Take Dust
Wipe Sample
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.
Clean until dust and
debris are removed.
Cleaning Floors
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 rinse in
rinse water. Rinse often.
Squeeze out and rinse
again. Mop small areas at
a time.
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.
See following section.
See Section 5D: Testing
Dust for Lead, p. 71.
48
Double bucket
Rinse bucket
& string mop
Pump sprayer
-------
ISPOSAL OF WASTE
After cleanup of the work area, take care to safely handle and remove dust
and debris from the job. Supervisors should check with the EPA and their
state's agency responsible for waste to find out about specific Federal,
state, and local regulations regarding disposal of waste that may contain
lead-based paint.
Key Principle:
Confine dust and waste to the work area that will be cleaned.
Disposal
Practices
Water
Specific guidelines are:
Avoid carrying construction waste through an
occupied space. If you must carry it through an
occupied space, first place it in a heavy duty plas-
tic bag or wrap it in protective sheeting and seal
with tape.
When a dumpster is used, keep the dumpster
covered. If a chute is used, cover the chute (or
use a barrel chute) and cover the dumpster.
Store all waste in a secure container or dumpster
until disposal. Do not transport waste in an open
truck, unless it is bagged and sealed.
Water used for clean up should be dumped into a
toilet. Never dump this water in a sink, tub, on the
ground, or down a storm drain.
Water used to remove paint through pressure wash-
ing must be collected in drums and may need to be
tested to determine if it is hazardous. Check with
your state agency responsible for waste.
-------
50
-------
CHECK YOUR WORK!
Check
Quality of
Work&
Cleanup
How to
Check:
1. Visual
Checks
2. Take a
Dust Wipe
Sample
Check work quality during the job and at the end of
the job.
Was the cause of the problem corrected?
Were proper work practices used?
Was cleanup done thoroughly?
Checking your work involves two important steps.
Use the checklist inside the back cover of this guide
when performing visual checks.
During the Job. Be sure that:
the cause of the problem is being corrected;
the work area is safely set up;
the practices in this guide are being used; and
dust and debris are not spreading beyond the
work area.
End of the Job. Be sure that the repairs were
done properly and that no dust or paint chips
remain.
When interior work disturbs painted surfaces or pro-
duces dust, have dust wipe samples taken at the end
of the job to check for harmful levels of lead-contami-
nated dust.
To be accurate, these tests must be done according to
specific procedures. See Section 5D, p. 71, for more
information about these tests, and who should per-
form them.
AT THE EN DO F T H E JO B
-------
How to
Check
Cont'd
Why Is It
Important
to Check
Work?
52
Dust wipe testing is recommended at the end of any
job that disturbs paint or produces dust. It is strongly
recommended when:
Work that disturbs paint is done in homes
built before 1978.
A young.child or pregnant woman lives in the
home.
Performing unit turnover or regular maintenance
in rental properties.
Checking that work was done properly is important
because:
Failing to correct conditions causing damage or
deterioration results in repairs that do not last.
Work that fails to follow the recommendations in
this guide may spread dust and paint chips beyond
the work area and may endanger children in the
home.
Dust and paint chips left behind due to poor cleaning
may contain lead and may also endanger children in
the home.
For contractors, checking your work improves the
quality of a job and is likely to reduce the risk of a
lawsuit in the event a child in the home is later
found to have high levels of lead in his/her blood.
Leaving a clean job site is greatly appreciated by
customers.
-------
ONGOING MONITORING & MAINTENANCE
Regularly
Check
Repairs for
Deterioration,
Paint Chips,
and Dust
Maintain
Surfaces and
Thoroughly
Clean
Methods of
Monitoring
When to
Monitor?
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.
Lead dust hazards are present. Important: This
can only be done by dust wipe sampling.
Then:
Perform repairs, as needed, to maintain surfaces in
a smooth and cleanable condition using the meth-
ods recommended in this guide; and
Clean the area thoroughly using the practices
described earlier in this section.
Follow the same methods used to check your work:
Visual Check. Look for deterioration, paint failure,
dust and paint chips. Use the checklist inside the
back cover of this guide.
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.
To be accurate, these tests must be done according
to specific procedures. See Section 5D, p. 71, for
more information about these tests, and who should
perform them.
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 test done at
least every two years. This type of test is strongly
recommended when a young child or pregnant
woman lives in the home.
-------
Why is It
Important to
Monitor &
Maintain
Work?
54
Monitoring and maintenance helps:
Plan and implement maintenance tasks
Protect occupants and neighbors, particularly chil-
dren, from lead exposure
* Give owners, contractors, and residents a record of
the condition of the unit
-------
A.
R
Aluminum flashing - thin aluminum sheeting, also known as coil
stock.
Aviation snips - metal cutters.
Chamfer - a small bevel on an edge.
Enclosure - a rigid, durable construction material that is
mechanically fastened to the structure to cover painted surfaces.
Fit testing - a method to check if a respirator fits properly over the
face.
Gain - notch chiseled in a door for a hinge leaf.
HEPA filter - High-Efficiency Particulate Air filter. A filter that can
remove particles of 0.3 micrometers or larger from the air at
99.97 percent or greater efficiency.
HEPA vacuum - a vacuum with a HEPA filter.
HUD Guidelines - HUD's Guidelines for the Evaluation and Control
of Lead-Based Paint Hazards in Housing.
Interim controls - a set of measures to reduce exposure to lead
hazards. Interim control measures include special cleaning,
repairs, paint stabilization, enclosure, and containment. For a full
discussion, see HUD's Guidelines for the Evaluation and Control
of Lead-Based Paint Hazards in Housing.
Lauan plywood - 1/4 inch plywood made of lauan with a smooth face.
N100 - a NIOSH filter class that describes a respirator's ability to filter
airborne particles. A respirator filter rated as N100 removes
particles of 0.3 microns or larger from the air at 99.97 percent or
greater efficiency.
NIOSH - National Institute for Occupational Safety and Health, an
agency within the Centers for Disease Control and Prevention that
tests and certifies safety equipment including respirators.
RESOURCES
-------
56
OSHA - Occupational Safety and Health Administration, an agency of
the U.S. Department of Labor that oversees worker safety.
Paint stabilization - a process of wet scraping, priming, and finish
coating of a deteriorated painted surface to prevent further
deterioration.
Permissible Exposure Limit (PEL) - a dust exposure threshold set
by OSHA. Work that creates lead dust levels in the air greater than
the PEL must meet OSHA lead safety requirements for workers.
OSHA has set the PEL for airborne lead dust at 50 micrograms
per cubic meter fag/m3) as a time weighted average. See Section
5D, p. 69, for technical information about OSHA requirements and
Section 58, p. 61, for information about OSHA regulations.
Pilot hole - a small hole drilled to guide the drilling of a larger hole.
Protective sheeting - made of plastic, poly or other material.
Protective sheeting must be puncture and tear resistant, imperme-
able to liquids, durable, flexible, and lightweight.
R-value - a measure of heat containment; used for rating insulation
effectiveness.
Shim - small piece of wood or metal used to fill space between two
fastened components.
Shroud - a protective covering that contains dust and chips.
Substrate - a solid surface such as plaster, drywall, wood, etc.
Tack pad - a sticky pad that helps remove dust from shoes.
Window trough - the area of the sill between a window stool or inte-
rior sill and the frame of the storm window where the bottom sash
rests when closed (also called a window well or exterior sill).
-------
B. FOR MORE INFORMATION
This section lists useful documents, web sites, and other lead-based paint
information resources. Additional sources also exist. Use the reference let-
ter on the right to locate the contact for each information resource.
Contacts are listed by letter on pages 62-64. Publications marked with an *
are for sale; others are available for free.
Where can I get more information on...
Work practices and lead-safety?
Publications
Guidelines for the Evaluation 'and Control of
Lead-Based Paint Hazards in Housing (July
1995).* Technical guidance on methods for iden-
tifying and controlling lead-based paint and lead-
based paint hazards. The Guidelines can also be
downloaded for free from the HUD Office of Lead
Hazard Control web site. (About 750 pages)
Residential Lead Desktop Reference (2nd Edition,
June 1998).* A CD-ROM containing a targe vari-
ety of lead-based paint information resources.
Maintaining a Lead Safe Home (1997).* A do-it-
yourself manual for homeowners and property
managers. (89 pages)
Lead-Based Paint: Operations and Maintenance
Work Practices Manual for Homes and Buildings
(May 1995).* Technical guidance on safe work
practices. (200 pages)
Guide Specifications for Reducing Lead-Based
Paint Hazards (May 1995).* Technical guidance
on purchasing lead-hazard control reduction ser-
vices and developing lead-hazard reduction work
specifications. (About 500 pages)
Lead Safety for Nonprofit Property Owners,
Developers, and Managers (July 1998). Practical
guide to developing policies and activities that
incorporate lead safety in property management.
(About 30 pages)
Reference
Letter
B, C
B
-------
Publications
Guide to Working Safely with Residential Lead
Paint (1999). Pamphlet with key lead safety pre-
cautions to follow during repainting and home
improvement.
Reducing Lead Hazards When Remodeling Your
Home (September 1997). Pamphlet providing
basic information about lead-based paint risks and
precautions when remodeling pre-1978 homes.
Web Sites
* HUD. Office of Lead Hazard Control. Provides
information on HUD regulations, technical and
educational documents, and links to other lead
resources.
EPA. Office of Pollution Prevention and Toxics.
Provides information on EPA regulations, technical
and educational documents, and links to other
lead resources.
Worker protection methods?
Publications
Protecting Workers and Their Communities from
Lead Hazards: A Guide for Protective Work
Practices and Effective Worker Training (1993).*
Guidance on worker protection methods, training
workers, and complying with OSHA regulations.
(About 500 pages)
Lead Exposure in the Construction Industry
(1993). Fact sheets that describe worker protec-
tion measures needed to meet OSHA requirements
for lead including respiratory protection and pro-
tective clothing. (Series of 6 fact sheets)
Web Site
OSHA. Occupational Safety and Health
Administration. Provides information on OSHA
regulations, technical and educational documents,
and links to other lead resources.
58
Reference
Letter
B, I, K
B
K
-------
Preventing children's exposure to lead
hazards?
Publications
Protect Your Family From Lead In Your Home
(May 1995). Pamphlet that provides basic infor-
mation about addressing and preventing lead-
based paint hazards in the home.
Lead Poisoning Prevention: Directory of State
Contacts (1997-98).* Booklet that contains pro-
files of state programs to reduce lead hazards.
(150 pages)
Directory of State and Local Lead Poisoning
Prevention Advocacy Organizations (1998)* List
of state and local non-profit organizations that are
working to prevent lead poisoning. (About 300
pages)
Web Site
Alliance to End Childhood Lead Poisoning.
Information on lead poisoning prevention, lead
issues, and program design. Site has publications
that can be copied from the web.
Public education and outreach materials?
Web Site and Hotline
National Lead Information Center. Information about
lead hazards and poisoning prevention.
Locating certified abatement contractors and
clearance inspectors?
Web Site and Hotline
Leadlistina. List of qualified lead professionals
including inspectors, risk assessors, abatement
contractors, and analysis laboratories.
Reference
Letter
B,I,K
-------
Disclosure requirements?
Publications
* Protect Your Family From Lead in Your Home
(May 1995). Pamphlet that provides basic infor-
mation about addressing and preventing lead-
based paint hazards in the home.
Disclosure of Lead-Based Paint Hazards in
Housing (March 1996). Fact sheet that provides
information on how to meet Federal disclosure
requirements.
Questions and Answers on the HUD/EPA
Disclosure Rule. Answers to commonly asked
questions about Federal disclosure requirements.
(5 pages)
Interpretive Guidance for the Real Estate
Community on the Requirements for Disclosure of
Information Concerning Lead-Based Paint in
Housing, Parts I and II (1996). In-depth guidance
on the disclosure requirements for real-estate pro-
fessionals. {27 pages)
Resource Handbook on Lead Hazard Disclosure
for Homes and Apartments (1996)* Comprehen-
sive reference book on disclosure procedures
including advice for renters and owners, a glos-
sary of key terms, and copies of disclosure docu-
ments. {Approximately 300 pages)
Respirators?
Web Sites
National Institute of Occupational Safety and
Health. Provides information on the proper use of
respiratory protection and various types of NIOSH-
approved respirators that are available.
Occupational Safety and Health Administration.
Provides information on OSHA regulations regard-
ing the use of respiratory protection.
Reference
Letter
B,l, K
H
-------
Where can I find...
HUD's lead regulations?
» 24 Code of Federal Regulations (CFR) 35 (Lead
Rule). Contains lead hazard evaluation and reduc-
tion requirements for properties that receive HUD
funding.
OSHA's lead regulations?
29 CFR 1926.62 {Lead in Construction) and
29 CFR 1910.1025 (Lead in General Industry).
These regulations cover Federal worker protection
requirements for workers in industry, construc-
tion, remodeling, and renovation.
EPA's lead regulations?
40 CFR 745 (Lead-Based Paint Poisoning
Prevention in Certain Residential Structures).
Contains the Federal regulations for the disposal
of lead waste and contractor notification require-
ments.
40 CFR 745.80 (Residential Property Renovation).
Federal rule requiring contractors to provide notifi-
cation before the start of any work that disturbs a
painted surface in pre-1978 homes.
Disclosure regulations?
24 CFR 35 (HUD) and 40 CFR 745 (EPA).
Regulations for disclosure of known lead-based
paint and lead-based paint hazards by home sell-
ers and landlords. This rule was published jointly
by HUD and EPA.
Reference
Letter
B
K
B,K
-------
State lead laws?
Publication
Summary of Lead Poisoning Prevention Statutes
(February 1999). A state-by-state listing of local
lead-related regulations, such as waste disposal
requirements. Available by fax. (24 pages)
Reference
Letter
B
D
Contacts
Organization
Alliance to End Childhood Lead
Poisoning
227 Massachusetts Avenue, NE,
Suite 200
Washington, DC 20002
202-543-1147
http://www.aeclp.org
Office of Lead Hazard Control (OLHC)
U.S. Department of Housing and
Urban Development (HUD)
451 Seventh Street, SW, Room P-3206
Washington, DC 20410
202-755-1785
http://www.hud.gov/lea/leahome.html
HUD USER
P.O. Box 6091
Rockville, MD 20849
1-800-245-2691
http://www.huduser.org
Leadlisting
1-888-Leadlist (1-888-532-3547)
http://www.leadlisting.org
National Conference of State
Legislatures
1560 Broadway, Suite 700
Denver, CO 80202
303-830-2200
http://www.ncsl.org
Reference
Letter
Types of
Resources
Publications
Publications
Program
development
Publications
Technical
consultation
Publications
-------
Reference
Letter
H
Organization
National Center for Lead Safe
Housing
10227 Wincopin Circle, Suite 205
Columbia, MD21044
410-992-0712
http://www.leadsafehousing.org
National Institute of Building
Sciences (NIBS)
Publications Department
1201 L Street, NW, Suite 400
Washington, DC 20005-4014
202-289-7800
http://www.nibs.org
National Institute of Occupational
Safety and Health (NIOSH)
Hubert H. Humphrey Building, Room
7154
200 Independence Avenue, SW
Washington, DC 20201
800-35-NIOSH (800-356-4674)
http://www.cdc.gov/niosh/home-
page.html
National Lead Information Center
(NLIC)
8601 Georgia Avenue, Suite 503
Silver Spring, MD 20910
Information Clearinghouse: 1-800-
424-Lead (1-800-424-5323)
http://www.epa.gov/lead/nlic.htm
Types of
Resources
Publications
Technical
consultation
Publications
Training
Publications
Publications
Training
-------
Reference
Letter
Organization
Occupational Safety and Health
Administration (OSHA)
U.S. Department of Labor, OSHA
Publications Office
200 Constitution Avenue, NW, Room
N3101
Washington, DC 20210
OSHA Lead web page:
http://www.osha-slc.gov/
SLTC/lead/index.html
OSHA Respirator web page:
http://www.osha-slc.gov/SLTC/
respiratory_advisor/mainpage.html
Office of Pollution Prevention and
Toxics (OPPT)
U.S. Environmental Protection
Agency (EPA)
401 M Street, SW (7401)
Washington, DC 20460
202-260-3810
http://www.epa.gov/lead
Society for Occupational &
Environmental Health
6728 Old McLean Village Drive
McLean, VA 22101
703-556-9222
http://www.soeh.org
64
Types of
Resources
Technical
consultation
Enforcement
Publications
Program
development
Publications
-------
C. GETTING THE WORD OUT
How Owners and Occupants Can Work Together to Improve
Lead Safety In Homes
Gaining tenant cooperation can help rental property owners and
managers respond promptly to conditions that could pose a health
threat to occupants.
Owner Responsibilities
1, Check the building to be sure that:
Q The building shell is sound,
Q Water isn't coming in from the out-
side and causing damage.
Q Sources of moisture inside are not
causing damage.
Q Painted surfaces are intact.
Q Doors and windows work properly.
Q All surfaces are clean and clean-
able.
When Maintenance or
Renovation Work is
Done
Give occupants the Lead
Safety pamphlet required
by Federal regulations
(see page 66).
Tell occupants:
Why repairs are
necessary.
The work schedule.
How they and their
possessions will be
protected.
Why they may need to
leave during the work.
2. Maintain the building.
Q Train maintenance staff to minimize
dust, clean up effectively, and pro-
tect themselves.
Q Conduct regular building checks for
potential problems, such as:
Flaking or peeling paint
Water damage to paint, plaster, or wood
Plumbing or roof leaks
Painted doors and windows that do not operate smoothly
3. Educate occupants and gain their cooperation.
Q Fulfill Federal notice and disclosure requirements.
a Have occupants inform you of damaged paint and other main-
tenance problems.
-------
66
Q Explain to occupants why
steps, such as regular clean-
ing, prevent lead-based paint
hazards. (See below.)
Q Consider providing cleaning
supplies and tools (see page
75) to occupants to encour-
age cleaning.
a Remind tenants that it is a
good practice to provide
notice of problems in writing.
Q Make sure occupants under-
stand the property's mainte-
nance reporting procedures
and indicate that these prob-
lems require priority attention.
Precautions Tenants Can Take to
Protect Their Family
Occupants should pay special atten-
tion to page 7 of the pamphlet
Protect Your Family From Lead In
Your Home. It describes steps that
occupants can take to reduce the
chance that they will be exposed to
lead hazards. Suggestions from this
Federal Notice and
Disclosure Requirements
(24 CFR Part 35 or
40 CFR Part 745)
Landlords and home sell-
ers must notify future
occupants about lead-
based paint hazards by
giving them the pamphlet
Protect Your Family From
Lead in Your Home.
Landlords and home sell-
ers must disclose infor-
mation about known lead-
based paint and/or lead-
based paint hazards
before dwelling leases or
home sales contracts take
effect. Leases and sales
contracts must also
include a form about
lead-based paint that
meets Federal require-
ments. Contact HUD or
EPA for more information
about these requirements
(see Section 5B, p. 57).
pamphlet include:
Q Clean floors, window frames, interior window sills, and other
flat surfaces each week using warm water and an all-purpose
cleaner.
Q dean up any paint chips immediately.
Q Keep child play areas clean.
Q Wash children's hands often.
Q Keep children from chewing interior window sills and other
painted surfaces.
-------
Notice Prior to Renovation
Federal law requires contractors and owners of rental properties to
inform occupants about the risks of lead-based paint before non-
emergency repair, maintenance, and home renovation work begins.
This law applies for all work on surfaces greater than 2 square feet
per component. Contractors and property owners must distribute
copies of the pamphlet Protect Your Family From Lead In Your Home
before any work starts. See EPA's regulation at 40 CFR 745.80.
Also see Section 5B, p. 57, for sources that can provide copies of
this pamphlet.
Contractors and owners must make sure that occupants have
received the pamphlet.
For owner-occupied homes, the contractor must have the home-
owner sign an acknowledgement form after receiving the pam-
phlet. Or, the contractor can send the pamphlet by certified mail.
For tenants, the contractor or property owner must have an adult
occupant sign an acknowledgement form after receiving the pam-
phlet. Or, the contractor or owner can send the pamphlet by certi-
fied mail. If the contractor cannot get a signed acknowledgement,
the contractor must sign a statement documenting this.
For work in common areas, such as the lobby, of an apartment
building, the contractor must give the pamphlet to the owner and
to the occupants of all affected areas and inform them of the
nature, location, timing, and length of the job.
Why Lead Safety Makes Sense for Property Owners and
Contractors
Property owners and contractors that use safe work practices benefit
in several ways.
Advantages for Owners of Residential Rental Properties
Owners who maintain their rental properties using work practices that
increase lead safety can use this information to attract tenants who are
concerned for their child's health. Some local agencies may even
maintain a listing of housing units that meet certain lead-safety stan-
dards. When giving prospective tenants the lead-based paint pam-
phlet and the required disclosure information, they can tell the tenant
that the property has a program to minimize the risk of hazards from
lead-based paint. A safety program would include:
-------
Educating and training maintenance workers.
Examining property at turnover and then every year for deteriorat-
ing paint.
* Correcting conditions that may cause paint to flake and peel
(excessive moisture, binding doors, etc.).
* Doing work safely and cleaning up well.
Making sure surfaces are cleanable and doing a professional
cleaning at turnover.
Performing dust wipe tests before occupancy, and after every
maintenance job that disturbs.old paint. It is also recommended
to perform a dust wipe sample test at least every two years. Keep
the results on file.
* Encouraging tenants to inform property owners if there is a problem.
Advantages for Contractors
Doing work safely can enhance a contractor's reputation, maintain
the safety of workers, and protect the health of customers and their
children.
A program for lead safety can also help contractors when bidding
new jobs. For example, contractors performing repairs and improve-
ments in homes built before 1978 must give potential customers a
pamphlet about the risk of lead-based paint during renovation.
Contractors that follow practices for lead safety can demonstrate to
customers that they understand the risks and show that their work-
ers take specific precautions to protect against lead-based paint haz-
ards. Lead-safety can help "give you a leg up" on the competition.
Safe work practices also offer benefits that are important to cus-
tomers:
Dust and debris are confined to the work area.
A "clean" work area at the end of the job.
* Some work offers additional benefits. (For example, repairs to
windows can improve their operation, prevent damage from mois-
ture, and lower energy and maintenance costs.)
Lead safety also helps protect you as a contractor. For example,
having an independent, certified professional take dust wipe sam-
ples of the work area promptly after cleanup provides strong doc-
umentation that no lead hazards were present in the work area at
the end of the job.
-------
D. MORE ABOUT TECHNICAL TOPICS
Respiratory Protection
Respiratory protection helps prevent workers from breathing harmful
amounts of lead and other substances, touching their mouths with
dusty hands, or swallowing paint chips.
When work creates high levels of dust in the air, properly trained and
certified lead-based paint professionals should do these high dust
jobs. If you work for someone, and plan on doing this type of work,
your employer must meet the requirements of the OSHA Lead in
Construction Standard (29 CFR 1926.62). These requirements include
respiratory protection when work'creates lead dust in air that exceeds
the "permissible exposure limit" (PEL) see Air Monitoring and
Results sections below. See Section 5B, p. 57, for sources of informa-
tion about OSHA requirements.
Respirators may be required for activities that generate high levels of
dust such as:
Demolishing painted surfaces
* Opening up wall and ceiling cavities
Using power tools on painted surfaces
Dry scraping large painted areas
For this type of work, OSHA requirements include the following:
* Training workers on how to properly use and maintain respirators.
Making sure proper respirators are
always available and that workers have
been fit tested. Where respirator use is
required, workers must be part of a writ-
ten respiratory protection program that
meets OSHA standards (29 CFR
1910.134).
Many types of respirators can be used:
Disposable respirators can be
used if they are rated by NIOSH worker
as N100 (or HEPA)this
information can be found on
approved
the respirator's package or the disposable
respirator itself. respirator
Dust
mask not
NIOSH
approved
Metal nose
bridge
HEPA
filter
material
RESOURCES
xriv.^S^p-l'"*11'*^*^^*"^ ' :/ ...,'-
-------
Non-disposable respirators,
also rated by NIOSH as IM100,
often have replaceable car-
tridges and require regular
maintenance.
70
Worker
wearing a
non-disposable
respirator
Having a trained person do air
monitoring that measures the
amount of dust in the air to determine if respirators are required
by OSHA, and the appropriate level of protection. Workers must
wear proper respirators while air monitoring is being done.
Air Monitoring
Air monitoring is done to ensure that workers are not being exposed
to dangerous levels of lead dust in the air, and to comply with OSHA
requirements. It must be done by a person with special training. A
worker being monitored wears a small plastic canister clipped to
his/her clothing near the face. A pump in a device clipped to the belt
draws air and dust into the canister. The canister is then sent to a
lab to measure how much lead dust was in the air.
What Do the Results Mean?
The results are measured in micrograms per cubic meter (ug/m3). If
the amount of lead dust in the air exceeds the permissible exposure
limit (PEL) of 50 ug/m3, workers must wear at least a half-face respi-
rator with an N100 (or HEPA) rating and certain OSHA requirements
must be followed.
Results may show that respirators are not necessary or that a
greater level of protection is needed. If the results show lead dust
levels in the air above 500 ug/m3, a more protective respirator is
required.
Other Protection
In addition to respiratory protection for activities that generate high
levels of dust, compliance with OSHA's Lead in Construction
Standard may involve blood tests for workers, medical monitoring,
hand washing facilities, other personal protective equipment, shower
and changing areas, and additional training.
-------
Testing Dust for Lead
By having dust wipe samples taken, job supervisors and property
owners can locate dust lead hazards and test the effectiveness of
cleaning at the end of a job.
Where Are Dust Samples Taken?
Samples are taken in the area of the
dwelling where work has been com-
pleted. The following surfaces within
the work area should be sampled:
Floor
Interior window sills (also referred
to as window stools)
Window troughs
Interior
window
"» . X * ^l
.../ Floor
When Should Dust Samples Be Taken?
At the end of a job
If there is a child or pregnant woman living in the home
Before a family moves into a home
What Do the Results Mean?
The results of the laboratory analysis will show the amount of lead
found in the dust from the area sampled. The results are measured
in micrograms per square foot (pg/ff).
To determine if a lead-based paint hazard exists, based on HUD's
requirements as of winter 1999, compare the results to the follow-
ing standards.
100 ug/ft2 on the floor
500 ug/ft2 on the interior window sil! (stool)
800 ug/ft2 in the window trough
HUD-assisted, and some federally-owned housing: After
9/14/2000, use 40 for floors, 250 for sills, and use trough value
only for clearance.
If the results for a sample are higher than these standards, a dust
lead hazard is present.
-------
72
Who Can Take Dust Wipe Samples?
Following painting, home maintenance, and renovation work:
In homes receiving Federal assistance, dust wipe samples, if
required by regulations, must be taken by a trained and certified
person.
For al! other homes, it is recommended that dust wipe samples be
taken by a trained person, and it is preferable that they be certi-
fied. Some states require that dust wipe samples be taken by cer-
tified persons.
What Actions Do I Take Based On the Results?
If the results show dust lead levels higher than the standards listed
above, the area where the work was performed should be cleaned to
remove the dust lead hazard.
If the dust wipe samples were taken as part of ongoing monitoring
by maintenance staff or the property owner, the surfaces where work
was performed should be examined to see if the work has failed or
new conditions that generate dust have developed. In either case,
these conditions should be corrected using lead-safety principles
and work practices.
If the work required to correct the likely source of the dust lead haz-
ard is beyond the scope of this guide, the property owner should
seek the help of a lead-based paint professional trained to safely cor-
rect lead-based paint hazards.
-------
Setting Up a Dust Room
A dust room can be useful for dusty work on building components
that can be moved. For example, scraping or planing doors or win-
dow sashes can be done in a dust room. A dust room is particularly
useful when working in occupied spaces.
The dust room can be any room that can be closed off. The door
can be covered with a flap system (see page 46) and the floor can be
covered with protective sheeting taped to the baseboard.
Workers in this room should wear disposable clothing and wear res-
piratory protection. Wall and ceiling
vents inside the room should
be sealed off.
Containment sheeting
over door (See page 46)
Hand components
(doors, sashes, etc.)
through flap in
protective sheeting
Worker in room wears
respiratory protection
Protective sheeting
on floor
HEPA vacuum for
power tools
RESOURCES
-------
Building a Door Hold
A door hold makes working on doors easier and safer.
74
The weight of the door
will close the vertical
1x6sand hold the
door.
10" to 12"
1x6
j Nail and
I glue
Screw
and glue
Screw
and glue
Door hold at
work
2" or more
Cover with rug or
thick material to
protect door finish
5" hinge
{or 5" spring hinge)
-------
TOOL AND SUPPLY LIST
Additional Tools Needed for Lead-Safety Work
(Not every tool is needed for every job.)
Paint scrapers - A variety of scrapers are useful; carbon blades last
longest. A mill file works well to keep scraper blades sharp.
Sanding sponges and wet/dry sandpaper - Where areas need to be
smoothed or feathered, these abrasive tools, when used wet, keep
dust to a minimum.
Wlist bottles - Misting a surface being scraped or cut keeps down
dust. Squeeze bottles work best in small areas. For larger jobs, a
pump pressure sprayer in a knapsack works best.
Plane - A jack, smooth, or jointer (not block) plane. Hand planes are
good for removing paint from edges such as the edge of a win-
dow, stool, or door. They create very little dust.
Cleanup station - A kitchen counter with a working sink is a good
place for a cleanup station. If not available, set up a board with 3
buckets and a pump sprayer.
The station should have:
Hand
wash
buckets
p
sprayer
Eye-wash
station
First
aid kit
Drinking
water
Paper towels and soap
Pads for cleaning
respirators
A 2-bottle eye-wash station
A first aid kit
Clipboard with emergency
numbers
Drinking water and cups
Personal Protective Clothing and Equipment
A disposable respirator rated by NIOSH as N100 (or HEPA)
A half-face, air cartridge respirator rated by NIOSH as N100 (or
HEPA)
Protective, lightweight, disposable suits with elastic sleeves and
ankles
Shoe covers (slip resistant is recommended)
Safety glasses (vented goggles if working in high dust conditions
or when using liquids or strippers)
Ear protection if using power toots
-------
76
Cleaning Equipment
Bottle mister and pump sprayer for detergent
* Mops and buckets
Tack cloths for wiping furnishings that may be damaged by water
Heavy-duty paper towels and/or rags
Vacuums - At the end of a job, use a HEPA vacuum because it will
capture even the finest dust. For regular household cleaning, use
a HEPA vacuum if available. If one is not available, use a fine filter
in your vacuum known as micron or allergen bags.
Painting Supplies
Use commercial grade cleaners; there are also lead-specific clean-
ers. (Note: Trisodium phosphate [TSP] is banned in some states.)
Degreasers may be necessary on some walls.
Use deglosser or wet sanding supplies.
Where wood is exposed, use a sealer and then apply a best grade
primer or primer-sealer.
Other Tools
Coil stock for covering window troughs. Coil stock is available
with white and brown sides to match window trim color
(see page 36).
Window opening tool for windows that are painted shut
(see page 29).
Brace with screwdriver tips for removing and replacing hinge
screws.
Power planer with exhaust port that can be attached to HEPA vac-
uum. A power pfaner can be used for stripping window sashes
and doors in a contained work area with respiratory protection.
-------
R NOTES AND SPECIAL INSTRUCTIONS
RESOURCES
-------
78
-------
-------
80
-------
G. WORK CHECKLIST
Before Work Begins
Q Are the possible risks to occupants identified?
Q Are the occupants informed of the possible risks and their
responsibilities?
Q Are the causes of the problems located?
Q Is the work area set up?
Q Is the work area closed off from occupants?
During Work
Q Are dust and debris being contained in the work area?
Q Are workers wearing necessary protective clothing and
equipment?
Q Are workers cleaning up each time they leave the work site?
At the End of the Job
Q Did workers fix the cause of the problem?
Q Did workers remove visible dust and debris?
Q Did workers properly dispose of dust and debris?
Q Did workers wet wash the surfaces?
Q Were dust samples taken to make sure that cleanup worked?
For Long-Term Maintenance
Is there a plan to:
Q Maintain painted surfaces?
Q Keep surfaces clean and cteanable?
Q Prevent water and moisture damage?
This Guide may be reproduced and distributed without prior permission from the
U.S. Department of Housing and Urban Development or any other Federal Agency.
Disclaimer: The guidance offered in this document is based upon the latest lead hazard con-
trol knowledge and technology available at the time it was written, Users bear all risks asso-
ciated with reliance on these work practices and have sole responsibility for evaluating the
information it contains. Users bear sole responsibility to form their own independent judg-
ments on the document's use, modification, and adaptation as appropriate. Neither the
United States Government nor any of its employees makes any warranty, expressed or
implied, or assumes any legal liability for any use of, or the results of, any information, prod-
uct, or process discussed in this document.
-------
, . .
₯iifi
J/iiiIS«J!rfii«,«ioS&«BS»S!₯»l »W.«g
-------
APPENDIX 2
Protect Your Family from Lead in
Your Home Pamphlet
-------
This page is intentionally blank.
-------
Protect
Your
From
Lead In
Your
Home
\
U.S. EPA Washington DC 20460
U.S. CPSC Washington DC 20207
U.S. HUD Washington DC 20410
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
Junel, 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 jurisdictional 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 born.
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.
+ Eat paint chips or soil that contains
lead.
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
4- Headaches
Lead is also harmful to adults. Adults
can suffer from:
+ Difficulties during pregnancy
4 Other reproductive problems (in both
men and women)
^ High blood pressure
^ Digestive problems
+ Nerve disorders
+ Memory and concentration problems
+ Muscle and joint pain
til:ifi :ir Mrrve
Hiwrr
'j'll r».M-"m '..=
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-
eis 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:
4- Children at ages 1 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.
4- Doors and door frames.
Stairs, railings, and banisters.
4 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.
-------
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:
41 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 Now 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
less lead.
-------
How To Significantly Reduce lead Hazards
Removing
lead
improperly
can increase
the hazard to
your family
by spreading
even more
lead 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 problemssomeone
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.
-------
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
could 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 lead-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 Water 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.
11
-------
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 1100 (CPT)
One Congress Street
Boston. MA 02114-2023
1 (888) 372-7341
Region 2 (New Jersey. New York,
Puerto Rico, Virgin Islands)
Regional Lead Contact
U.S. EPA Region 2
2890 Wbodbridge Avenue
Building 209. Mail Stop 225
Edison. NJ 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-8J)
77 West Jackson Boulevard
Chicago, IL 60604-3666
(312) 886-6003
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
12
-------
CPSC Regional Offices
Your Regional CPSC Office can provide further information regard-
ing regulations and consumer product safety.
Eastern Regional Center Western Regional Center
6 World Trade Center 600 Harrison Street, Room 245
\fesey Street, Room 350 San Francisco, CA 94107
New York, NY 10048 (415)744-2966
(212) 466-1612
Central Regional Center
230 South Dearborn Street
Room 2944
Chicago, IL 60604-1601
(312)353-8260
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
13
-------
Simple Steps To Protect Your Family
From Lead Hazards
Sf 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.
Recycled/Recyclable
Printed on paper that contains at feast 20 percent postconsurner fiber.
-------
APPENDIX 3
Lead Pre-Renovation Education Rule Flyer
Lead-Based Paint Pre-Renovation Regulation Tri-
fold Pamphlet
Pre-Renovation Lead Information Rule: Questions
and Answers
Pre-Renovation Lead Information Rule: Fact Sheet
Lead-Based Paint Pre-Renovation Education Rule:
Handbook
Lead-Based Paint Pre-Renovation Education Rule:
Interpretive Guidance Part 1
Lead-Based Paint Pre-Renovation Education Rule:
Interpretive Guidance Correction to Part 1
Lead-Based Paint Pre-Renovation Education Rule:
Interpretive Guidance Part 2
-------
This page is intentionally blank.
-------
ATTENTION!
Remodeler/Renovator/Contractor/Landlord
Does the New Federal Lead-Based Paint
Regulation Apply to You?
Yes, if:
Your work involves pre-1978
houses or apartments
You receive any form of
compensation for your work
You disturb more than 2 square
feet of painted surfaces
Your work is not specifically
excluded from this law
Federal law requires distribution of
this lead hazard information pamphlet
BEFORE starting a renovation.
Applicable to:
Carpenters
Renovators & Remodelers
Electricians & Plumbers
Painters
Home Improvement Contractors
Landlords/Property Managers
Apartment Maintenance Staff
Anyone whose work disturbs paint
Find Out More on How to Comply
Information on back
U.S. Environmental
Protection Agency
EPA 747-F-00-002
March 2000
1 -800-424-LEAD
www.epa.gov/lead
r
\s=jSm Awareness
IP. *i Program
-------
The Lead Pre-Renovation Education (PRE) Rule
In general, the Lead PRE Rule applies to:
Renovations performed in pre-1978 housing
which are performed for compensation.
"Renovation" means any modification of all or part of any existing structure
in the housing that disturbs painted surfaces. "Renovation" includes:
Removal/modification of painted surfaces,
components, or structures
Surface preparation activities {sanding/scraping/
other activities that may create paint dust)
Window replacement.
"Compensation" is the receipt of anything of value
(not only money), and may include:
Exchanges of money, goods, or services
Payment of rent to landlords/property managers.
Renovation Examples:
Demolition of painted walls or ceilings
Large surface replastering
Major plumbing repairs or improvements
Any other activities which disturb more
than 2 square feet of painted surfaces
Are there exemptions from these requirements? YES...
Lead abatement activities performed by certified lead abatement contractors
Emergency renovations
Renovation of certified lead-based paint free components
Minor repair/maintenance activities which disturb less than 2 square feet of painted surfaces
Renovations in dormitories/studio apartments/housing for the elderly or disabled
What am I required tO dO? Specific requirements depend on the following criteria:
In owner-occupied housing you must:
Provide an EPA-appraved lead information pamphlet to owner and get written acknowledgment or receipt from owner, OR
Mail the pamphlet to owner 7 days prior to renovation and document with certificate of mailing.
In tenant-occupied housing you must:
Provide an EPA-approved pamphlet to both building owner and an adult occupant by one of above methods.
« If attempted delivery to adult occupant fails, you may comply by leaving the pamphlet at unit and preparing certification
describing delivery attempts for your files.
For renovations in "common areas" in multi-family housing (more than 4 units), you must:
Provide an EPA-approved pamphlet by one of the methods listed under owner-occupied housing above.
Provide notice to each tenant in the building describing:
Nature/location/timing of renovation.
Availability of the EPA-approved pamphlet (free upon request).
Retain written documentation describing notification procedures for 3 years.
For more information or to obtain lead hazard information pamphlets:
1 -800-424-LEAD www.epa.gov/lead
-------
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United States Prevention, Pesticides, June, 1998
Environmental Protection and Toxic Substances (http://www.epa.gov/lead)
Agency (7404)
<&EPA Questions and Answers
Pre-Renovation Lead Information Rule (TSCA 406B)
Following the questions and answers are several example scenarios.
Q: What is the Pre-Renovation Lead Information rule?
A: The Pre-Renovation Lead Information Rule (PLIR), also known as section 406(b) of the Toxic
Substances Control Act, is a rule requiring people performing renovation for compensation to
distribute a lead hazard information pamphlet prior to commencing the renovation.
Q: Why Is the Pre-Renovation Lead Information rule necessary?
A: Through Title IV of the Toxic Substances Control Act, Congress directed EPA to address the
public's risk of exposure to lead-based paint hazards through regulations, education, and other
activities. Of particular concern to Congress were potential lead exposure risks that could occur
during renovations of housing containing lead-based paint.
Congress believed that informed owners and occupants of housing slated for renovation could act
to avoid lead exposure to themselves and their families. So Congress directed EPA to:
create a lead hazard information pamphlet containing information on lead-based paint in
housing, the risks of exposure, and the precautions for avoiding exposure
issue PLIR so that compensated renovators would distribute the pamphlet to owners and
occupants of most pre-1978 residential housing before beginning renovations
Q: Does the Pre-Renovation Lead Information rule apply to me?
A: If your job is for compensation and will require you to disturb more than 2ft2 of paint in pre-1978
housing, then you are a renovator for the purposes of PLIR. This is not dependent upon whether
what you do is typically considered a renovation. Whether you are a plumber, a drywaller, a
painter, or an electrician, if your job requires that you disturb more than 2ft2 of paint, then you must
comply with PLIR.
The term compensation extends beyond money. Providing services in exchange for other services
(e.g., bartering) is included within the term. PLIR applies to owners renovating their own
apartment buildings using maintenance staff as well as neighborhood handymen providing services
to those in the neighborhood for services or goods other than money.
Work that is performed for free (e.g., no exchange of money, goods, or services) or work
performed by Do-It-Yourselfers in their own homes is not covered by PLIR. Work that is
performed during an emergency (i.e., a hazardous, non-routine situation that could either threaten
public health or cause substantial property damage) is also excluded from this rule.
-------
Q:
A:
Q:
A:
What exactly do I have to do if the Lead Pamphlet Distribution rule applies to me?
If you are performing a renovation in pre-1978 housing and that renovation will disturb more than 2
ft2 of paint, then you must give the owner of the housing a copy of the pamphlet and get her
acknowledgment of receipt. If the housing is tenant occupied, then in addition to giving a copy of
the pamphlet to the owner, you must provide a copy to the tenant and get her signature as well.
The same requirements apply to apartments in housing with more than four separate dwelling units.
If the renovation is to occur in a common area (e.g., laundry room, hallway, playground) of housing
with more than four separate dwelling units, you must provide all residents of the building
information on the timing and extent of the renovations slated to occur.
How do I get copies of the pamphlet?
The pamphlet has been made available to the general public as well as the regulated community.
Single copies of the pamphlet are available in both English and Spanish from the NLIC, by calling
1-800-424-LEAD. Multiple copies are available through the Government Printing Office (GPO),
and may be ordered by calling the GPO Order Desk at (202) 512-1800, faxing (202) 512-2233, or
writing to Superintendent of Documents, P.O. Box 371954, Pittsburgh, PA 15250-7954. Request
the publication by title, Protect Your Family From Lead in Your Home, and/or GPO stock #055-
000-00507-9.
Q: When do I have to start complying with the Lead Pamphlet Distribution rule?
A: PLIR is effective one year after the date of publication.
Q: What if the tenant or owner won't accept or isn't home to accept the pamphlet?
A: If the tenant or owner refuses or is unavailable to accept the pamphlet, PLIR allows for the
renovator to certify the attempt. PLIR also allows the renovator to mail the pamphlet (at least 7
days prior to the renovation) if she purchases a certificate of mailing from the Post Office when
mailing the pamphlet.
PRE-RENOVATION INFORMATION RULE EXAMPLES
The following scenarios are designed to facilitate your understanding of how the Pre-Renovation
Information Rule (PLIR- also known as the Toxic Substances Control Act (TSCA) §406(b) rule)
requirements are likely to be met by regulated parties.
Background
Jane General-Contractor has four impending contracts. One contract is for the re-shingling of the roof
and re-painting of the exterior of a home. One contract is for the renovation of the interiors and shared
entry-way foyer of a "duplex" (two separate dwelling units, typically one over the other, that occupy a
single residential structure). Another contract is for the renovation of several apartments and the re-
painting of the outdoor playground equipment of a large apartment building. The last contract is for the
renovation of several apartments in a small, six-unit apartment building. Jane is aware of PLIR and plans
to take the affirmative steps necessary to comply with the law.
Page 1 of 4
-------
Example 1 - The Home Renovation
The first step that Jane takes is to determine whether PLIR is applicable to this job. Based upon a brief
examination of her plans and a brief telephone discussion with the home owner, Jane knows:
The re-painting will disturb more than 2 ft2 of exterior paint
The house was built in 1930
The house exterior has not been inspected by a certified inspector
This is not an "emergency" renovation
During a meeting to discuss the plans and costs with the homeowner, Jane gives the owner the lead
hazard information pamphlet. The homeowner signs a certification of pamphlet receipt (modeled on the
sample language in PLIR) that Jane has added to her contracts. Jane returns to her office and files the
certification, aware that the certification must be retained for three years. Jane has met the PLIR
requirements.
Example 2 - The Duplex Renovation
As described in Example 1, Jane acts to determine whether PLIR is applicable to this job. Based upon a
brief examination of her renovation plans and a brief telephone discussion with the owner, Jane knows:
The renovation is likely to disturb more than 2ft2 of paint inside dwelling unit 1
The renovation will not disturb any paint inside dwelling unit 2
The renovation will disturb more than 2ft2 of the shared foyer paint
The duplex was built in the 1950's
The duplex has not been inspected by a certified inspector
This is not an "emergency" renovation
The owner does not live in the duplex
The dwelling units in the duplex are rented to two families
During a meeting to discuss the plans and costs with the duplex owner, Jane gives the owner the lead
hazard information pamphlet. The duplex owner then signs a certification of pamphlet receipt (modeled
on the sample language in PLIR) that Jane has added to her contracts. Jane files the certification.
A few days before the renovation, Jane sends an employee over to the duplex to take a few foyer
measurements. She also directs the employee to deliver a lead hazard information pamphlet to an adult
occupant of duplex unit 1 and gives him a checklist, a lead hazard information pamphlet, and a pamphlet
receipt certification form.
The employee knocks on the door of duplex unit 1 and a child answers the door. After ascertaining that
no adult is home, the employee slips the pamphlet under the door and makes note of the address, date,
time, and that the pamphlet was delivered when only a child was present. That information is later used
by Jane or the employee to complete a certification that a pamphlet was delivered to duplex unit 1 but
that an acknowledgment could not be obtained due to the lack of an adult occupant at the time of
delivery. Jane puts this certification in her filing cabinet.
Page 2 of 4
-------
Jane knows that she does not have to notify the duplex residents about the activities in the shared foyer of
the duplex because the "common area" notification requirements are only applicable to a building with
more than four dwelling units. Jane also knows that she does not have to provide a pamphlet to an
occupant of duplex unit 2 because no paint will be disturbed. Jane is aware that she must retain the filed
certifications for three years. Jane has met the PLIR requirements.
Example 3 - The Large Apartment Building Renovation
As described in Example 1, Jane determines whether PLIR is applicable to this job. Based upon a brief
examination of her renovation plans and a brief telephone discussion with the owner, Jane knows:
The apartment renovations are likely to disturb more than 2ft2 of paint
The re-painting of the playground equipment may disturb more than 2ft2 of paint
The building was built before 1969
Neither the apartments nor the playground equipment have been inspected by a certified
inspector
This is not an "emergency" renovation
During a meeting to discuss the plans and cost with the building owner, Jane gives the building owner the
lead hazard information pamphlet. The building owner then signs a certification of pamphlet receipt
(modeled on the sample language in PLIR) that Jane has added to her contracts.
Jane is aware of the fact that the playground is an apartment building common area. A few days before
the scheduled re-painting of the playground equipment, Jane gives two employees several pamphlets and
a stack of notices containing information on the general nature, location, and start/end dates of the re-
painting. Jane, in creating the notices with a generous time line, has purposefully allowed for work
delays. The notices also indicate that copies of the lead hazard information pamphlet can be obtained at
the building's management office. Jane directs the employees to "shove" a notice under the door of each
apartment in the building. Jane further directs the employees to leave the pamphlets with the secretary of
the owner's on-site management office (per an agreement between Jane and the owner). After the
employees return, Jane certifies a basic description of the steps taken to notify the residents about the
playground re-painting activity.
Jane arranges that her secretary send a pamphlet to each to-be-renovated apartment via certificate of
mailing at least a week before renovation begins. The secretary accomplishes this by working with the
on-site foreman to track renovation progress in the preceding units. Ten days before the renovations are
scheduled to begin in each unit, the secretary goes to the Post Office, and mails a pamphlet by purchasing
a certificate of mailing from the teller,
Jane puts the common area certification and the certificate of mailing receipts in her filing cabinet, fully
aware that they must be retained for three years. Jane has met the PLIR requirements.
Example 4 - The Small Apartment Building Renovation
As described in Example 1, Jane determines whether PLIR is applicable to this job. Based upon a brief
examination of her renovation plans and a brief telephone discussion with the owner, Jane knows:
Page 3 of 4
-------
The apartment renovations are likely to disturb more than 2ft2 of paint
The building was built in 1987
This is not an "emergency" renovation
Jane correctly concludes that because the building was built after 1978, PLIR is not applicable.
Page 4 of 4
-------
-------
United States
Environmental Protection
Agency
Prevention, Pesticides,
and Toxic Substances
(7404)
EPA-747-F-98-003
May, 1998
FACT SHEET
EPA Releases Final Rule Requiring Distribution of Lead
Hazard Information Prior to Renovations
ACTION
A new EPA regulation will require renovators, working
for compensation, to distribute a pamphlet to owners
and occupants of most housing built prior to 1978
before commencing renovation activity. The pamphlet,
entitled Protect Your Family From Lead In Your Home,
discusses ways in which individuals can protect
themselves and their families from lead-based paint
hazards.
The pre-renovation lead information rule differentiates
between renovation activities and excluded activities,
such as routine maintenance or repair. Sanding,
scraping, and other surface preparation activities that
disrupt paint and generate dust are the two key sources
of lead exposure during renovation.
Renovation activities that disrupt more than 2 square
feet of paint per component will be covered by this
rule. A general rule-of-thumb would be to include
activities not specifically excluded in the rule, that
disturb more than 2 square feet of a painted surface.
Specific exclusions include activities that are less likely
to pose a risk of exposure to lead-based paint dust or
other lead hazards. Prominent examples are minor
housing repairs and maintenance activities, emergency
renovation operations (specifically defined in the rule),
and renovation activities that take place in housing that
has already been determined by a certified inspector to
be lead free.
The pre-renovation lead information rule will also
require that before renovating common areas (e.g.,
hallways, stair wells) in multi-family housing, a
renovator must inform building residents about the
nature and extent of the renovations and make the
pamphlet available in a central location.
LEGAL AUTHORITY
In an effort to protect families from exposure to the
hazards of lead-based paint, Congress amended the
Toxic Substances Control Act (TSCA) in 1992 to add
Title IV, entitled Lead Exposure Reduction, Title IV
of TSCA directs EPA to address the general public's
risk of exposure to lead-based paint hazards through
regulations, education, and other activities. One
particular concern of Congress and EPA is the
potential lead exposure risks that can occur during
renovations of housing containing lead-based paint
unless certain safety measures are taken.
Recognizing that many families might be unaware that
their homes might contain lead-based paint, section
406(a) of TSCA directed EPA to publish, after notice
and comment, a lead hazard information pamphlet
providing comprehensive information to the general
public on lead-based paint in housing, the risks of
exposure, and the precautions for avoiding exposure.
Section 406(b) of the law directed EPA to issue
regulations requiring that compensated renovators
distribute the pamphlet to owners and occupants of
most pre-1978 residential housing before beginning
renovations (1978 is the year that lead-based paint was
banned from residential use).
PURPOSE
People have sometimes created a health hazard for
their families without realizing it by disturbing
surfaces containing lead-based paint during housing
renovations. Activities like scraping, sanding, or
using a heat gun on surfaces that contain lead-based
paint can release large amounts of lead dust and
fumes. Lead dust from renovations can remain in the
home long after the work is completed.
EPA is promulgating this pre-renovation lead
information rule to ensure that families are fully aware
-------
of the importance of preventative measures to protect
housing occupants before beginning renovations in
housing that may contain lead-based paint.
LEAD HAZARDS IN HOUSING
Approximately three quarters of the nation's housing
stock contains lead-based paint. When properly
managed and maintained, this paint poses little risk. If
improperly managed, however, lead from paint can
threaten the health of occupants, especially children
under 6 years of age. Over time, low-level exposure to
lead from paint, dust, and soil can cause a range of
health problems including permanent damage to the
brain, nervous system and kidneys. In sufficient levels,'
lead can also cause health problem in adults. Because
of its effects on fetal development, lead exposure can
also be harmful to pregnant women and women of
child-bearing age. Such exposure is largely preventable
if individuals take precautionary measures.
PUBLIC COMMENT
EPA published a proposed section 406(b) rule in March
1994. Approximately 30 comments were received in
response from such groups as associations representing
builders and renovators, State and local health officials,
and consumer advocacy groups. The final pre-
renovation lead information rule will impose
requirements on a large number of businesses and self-
employed individuals. While this rule's requirements
are minor, its effectiveness is dependent on the
regulated community's understanding of their
obligations.
LEAD HAZARD PAMPHLET
EPA developed a lead
hazard
Protect
Your
Family
From
Lead In
Your
Home
&EFK
SSSS.
KSK
information
pamphlet entitled
Protect Your Family
From Lead In Your
Home. This pamphlet
provides families with
prevention tips on
reducing exposure to
lead hazards from
various sources.
FOR MORE INFORMATION
For a copy of Protect Your Family from Lead in Your
Home (in English or Spanish) or the rule call the
National Lead Information Center at 1-(800) 424-
LEAD.
Bulk copies of the pamphlet are available from the
Government Printing Office (GPO) at (202) 512-1800.
Refer to the complete title or GPO Stock Number 055-
000-00507-9. The price is $26.00 for a pack of 50
copies. Alternatively, persons may reproduce the
pamphlet, for use or distribution, providing that the
text and graphics are reproduced in full. Camera-
ready copies of the pamphlet are available from the
National Lead Information Center.
For specific questions about lead-based paint and lead-
based paint hazards, call the National Lead
Information Center at I-(800) 424-LEAD.
The EPA pamphlet and rule are available
electronically and may be accessed through the
Internet at the following URL:
http://www.epa.gov/lead
EFFECTIVE DATE
June I. 1999
-------
The Lead-Based Paint
Pre-Renovation
Education Rule
A Handbook for Contractors, Property
Managers, and Maintenance Personnel
Summary of Requirements Under
Section 406(b) of the Lead-Based Paint
Hazard Reduction Act of 1992
INTERIM EDITION JUNE 1999
Prepared by the
Office of Pollution Prevention and Toxics
U.S. Environmental Protection Agency
Washington, D.C. 20460
Note:
This Interim Edition of the handbook is being made
available to increase public awareness and under-
standing of the rule requirements pending publica-
tion of the Final Edition of this handbook. While
every effort has been made to make this handbook
accurate and specific to individual circumstances,
this handbook does not replace the definitive lan-
guage of the official rule. Users are encouraged to
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described on page 6 of the handbook.
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Interim Edition June 1999
The Lead Pre-Renovation Education
Rule (Lead PRE) At-A-Glance
If you will be working for compensation in a pre-1978 home or apartment
building, answer the questions below to determine if Lead PRE requires you
to give the lead pamphlet to the owner and occupants.
Does this job involve renovations
which disturb painted surfaces?
Are ANY of f/?e following conditions present?
- The work is an emergency renovation
- The work is a lead abatement project
- The work consists of minor repairs or
maintenance that disturbs 2 square feet
or less of painted surfaces
- The housing or its components have
been determined to be lead-based paint
free by a certified inspector or risk
assessor
- The housing is a zero-bedroom dwelling
(studio apartments, dormitories, etc.)
- The housing is housing for the elderly or
disabled AND children are not expected
to reside there
if All No
Lead
PRE
Does
Not
Apply
If no, then you need to read this book!
Rental property owners and managers,
renovators, and maintenance personnel
are affected by Lead PRE.
Bold Type = Key Terms (see pages 8-10 inside)
-------
-------
THE LEAD-BASED PAINT PRE-RENOVATION
EDUCATION RULE
INTERPRETIVE GUIDANCE FOR CONTRACTORS, PROPERTY MANAGERS, AND
MAINTENANCE PERSONNEL UNDER SECTION 406(b) OF THE LEAD- BASED PAINT
HAZARD REDUCTION ACT OF 1992
PARTI
May 28, 1999
[Revised June 25, 1999]
Prepared by the
Office of Pollution Prevention and Toxics
U.S. Environmental Protection Agency
Washington, D.C. 20460
-------
1. When a home or an apartment unit is re-painted in preparation for a new tenant, is the
painting activity always considered a "renovation" for purposes of the 406(b) rule even if
no surface preparation activity is performed prior to painting ?
No. The primary determinant of whether a given activity constitutes a "renovation" under the
rule is whether that activity disturbs painted surfaces. The practice of recoating painted surfaces
in preparation of new tenants would not constitute "renovation" unless accompanied by surface
preparation activities (sanding, scraping, or other activities that may generate paint dust). Minor
"spot" scraping or sanding can qualify for the exemption from the rule for "minor repair and
maintenance activities" if no more than 2 square feet of paint is disturbed on any component to be
painted. (See question 5 below for further explanation of that exemption). Washing down of
walls or other components prior to painting does not constitute "surface preparation" for
purposes of the rule.
2. If the letter of the regulation is strictly followed, tenants in a large apartment complex
will receive several notices regarding repairs to common areas every month, sometimes
several in a single week. Is there anyway to avoid such duplication?
EPA believes that in enacting section 406(b) of the Residential Lead-Based Paint Hazard
Reduction Act of 1992, Congress intended to provide persons residing in both single family and
multi-family housing with information needed to protect against exposure to lead-based paint and
lead-based paint hazards during renovations. In multi-family housing, advance knowledge of
location and timing of renovation activities in lobbies, hallways, and other common areas is
essential for residents wishing to minimize exposures to lead, especially those residents with
young children. At the same time, however, neither residents nor owners/managers are well-
served if duplicative notifications are issued repeatedly for essentially similar renovation activities.
For this reason, EPA wishes to encourage o"wners/managers to use one or more of the methods
described below to provide residents with needed information in the most efficient manner.
(1) Category Notices - When renovation activities fall within distinct categories which
are performed on a cyclical or recurring basis (e.g., hallway painting), they may be
grouped into a single notice which describes the categories and provides a description of
the locations affected. To fulfill the requirement for providing timing information for the
renovations, owners/managers may either list the expected starting and ending dates, or
employ one of the other methods for meeting the timing requirements described below.
(2) Bi-monthly Notices - Section 745.85(a) of the rule requires that notifications be
-2-
-------
given no more than 60 days before renovation activities begin. To minimize the number of
notices required, owners/managers may group all of the renovation activities expected to
occur over a 60-day period into a single notice distributed bi-monthly (every other month).
Renovation activities which were expected to occur within a given 60-day period, but
which were canceled or postponed, would simply be addressed in the subsequent bi-
monthly notice. Including renovation notices in, or as an attachment to, a pre-existing
newsletter is acceptable provided that the cover of the newsletter prominently indicates
that lead-based paint renovation notices are contained in or attached to the newsletter.
(3) Descriptions of Renovation Timing Section 745.85(b)(2) of the rule requires that
notices contain the "expected starting and ending dates" of the proposed common area
renovations. Although providing specific dates is preferable wherever possible, the
Agency is aware that unexpected events or circumstances often result in delays and/or
cancellations of planned renovation activities. To provide sufficient flexibility without
unduly compromising residents' rights to information on timing of renovations in common
areas, owners/managers may employ the following terminology to address the following
timing scenarios to avoid the needing to issue supplemental notices:
-"On or about" - acceptable when the expected starting or ending dates occurs
one week before or after the date given.
-"Early finsert month name!" - acceptable when the expected starting or ending
dates occurs during the first half of the specified month.
-"Late [insert month nameV ~ acceptable when the expected starting or ending
dates occurs during the second half of the specified month.
-"Ongoing for the 12-month period beginning [insert month namel" acceptable
when the renovation commences within 60 days of the issuance of the notice and
continues throughout the 12-month period. If an interruption of more than 60
days occurs anytime after commencement of such activity, a new notice will be
required before the activity may restart.
(4) Descriptions of Renovation Ending Dates - Due to the inherent difficulties in
estimating the duration of many renovation activities, owners/managers are encouraged to
make allowances for unexpected delays when providing descriptions of ending days under
Section 745.85(b)(2) of the rule. Any estimated ending date with a rational basis is
acceptable.
-3-
-------
3. Pamphlet distribution requirements may interfere with prompt responses to
maintenance/repair requests. Specifically, the requirement for obtaining a tenant's
signature on an acknowledgment of receipt prior to commencement of the work may delay
the repairs for a day or more.
EPA believes that potential delays in making requested repairs can be readily avoided either
through minor revisions of existing administrative procedures or by employing the "self-
certification" delivery procedures enumerated in section 745.85(a)(2) of the rule. [Regarding the
former, an owner/manager may attach or incorporate the required acknowledgment statement
into any existing repair request forms; and may distribute a copy of the pamphlet along with the
form to all tenants on a one-time basis. Whenever a repair is needed, the tenant would simply
Jill out a repair request form and acknowledge receipt of the lead information pamphlet at the
same time.] Alternatively, the self-certification provisions provide that a person delivering a
pamphlet to a unit where an adult occupant is unavailable for signing an acknowledgment may
sign and date a statement attesting to that unavailability and to the delivery of the pamphlet to the
unit. Owners/managers are reminded that they may also employ the "emergency renovation
operations" exemption under section 745.82 where the needed repairs pose a safety or health
health hazard, or threaten significant equipment or property damage. See section 745.83 for the
specific definition of this term.
[NOTE: The bracketed language in italics above contains incorrect information regarding
timing of pamphlet delivery. Consult the June 25,1999 Correction and Clarification for
amended guidance.]
4. Must notifications for common area renovations be provided to every unit in a
multifamily housing complex in all cases?
Section 745.85(b)(2) states that notification of renovations in common areas of multi-family
housing "shall be accomplished by distributing written notice to each affected unit." (Emphasis
added). In most cases where such renovations are performed, all units in the housing are
"affected units" because a common area is, by definition, "a portion of a building that is generally
accessible to all occupants." Section 745.103. In some limited instances in large apartment
buildings, however, EPA recognizes that certain areas of the building, while meeting the literal
definition of a common area, are, in practice, used almost exclusively by an identifiable subset of
tenants, e.g., a hallway on an upper floor of a multi-story building. EPA believes that providing
notices to every unit in a large building when renovations are occurring in only one such "limited
use common area" is unduly burdensome and does not result in appreciable reductions in lead
exposures. Therefore, for purposes of this rule, EPA will interpret the common area notification
requirements of the rule as follows: First, where renovation activity takes place in an area within a
common area which is used almost exclusively by an identifiable subset of residents of a large
apartment building, the Agency will interpret the term "affected units" to refer only to those units
.4-
-------
serviced by, or in close proximity to, the limited use common area. Second, the term "large
apartment building" shall mean multifarnily housing with 50 or more dwelling units. EPA believes
that need for special treatment for limited use common areas is less compelling when dealing with
apartment buildings with fewer than 50 units because (1) the burden of providing notifications to
every unit in the building is not unreasonable, and (2) in general, there are fewer areas within
smaller apartment buildings which would meet the criteria for a limited use common area
designation. Third, to ensure notification of tenants who may enter a limited use common area
but are not among the subset of tenants identified for individual notification, the renovator must
post placards at all accessible entrances to the renovation work site which prominently conveys
the same information required under section 745.85(b)(2).
5. Please provide guidance on how the Agency will interpret the exemption for "minor
repair and maintenance activities," e.g., what constitutes a "component"? May the 2
square feet value be aggregated among several components? Does the exemption apply to
window replacement activities?
The exemption applies to "minor repair and maintenance activities (including minor electrical
work and plumbing) that disrupt 2 square feet or less of painted surface per component." 40
C.F.R. section 745.82(b)(l). The term "component^]" is defined, in relevant part, in the section
402 rule as
*'. . . specific design or structural elements or fixtures of a ... dwelling . . . that are
distinguished from each other by form, function, and location. These include, but are not
limited to, interior components such as: ceilings, crown molding, walls, chair rails, doors,
door trim, floors, fireplaces, radiators and other heating units, shelves, shelf supports, stair
treads, stair risers, stair balustrades, windows and trim (including sashes, window heads,
jambs, sills or stools and troughs), built-in cabinets, columns, beams, bathroom vanities,
counter tops, and air conditioners; and exterior components such as: painted roofing,
chimneys, flashing, gutters and downspouts, ceilings, soffits, fascias, rake boards,
cornerboards, bulkheads, doors and door trim, fences, floors, joists, lattice work, railings
and railing caps, siding, handrails, stair risers and treads, stair stringers, columns,
balustrades, window sills or wells, and air conditioners." 40 C.F.R. 745.223
The Agency wishes to emphasize several aspects of this exemption which have been overlooked
by some readers of the final rule. First, the central tenet of the exemption was that it was
designed to apply only to activities which can reasonably be characterized as "minor repair and
maintenance." Any over-emphasis on the mechanics of the exemption serves to inappropriately
divert attention from the central purpose of the exemption: to provide regulatory relief for those
activities which are truly minor in scope. Common examples of the types of activities the Agency
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wanted to exempt in the final rule were repairs to electrical outlets and switches,
replacement/repair of plumbing fixtures, and spot repairs of painted walls, ceilings, trim, and
molding. Second, the exemption was not intended to provide an avenue to circumvent the
requirements of the rule; some have questioned the permissibility of dividing up a renovation
project into separate sub-projects, each of which disturbs 2 square feet or less of painted surfaces,
or of multiplying the number of components in a room by 2 square feet to come up with an overall
de minimis value . If any aspect of a renovation project results in disturbance of more than 2
square feet on any component in the area renovated, the entire project is subject to the rule.
Finally, EPA wishes to clearly state that window replacements do not qualify for this exemption to
the rule because (a) the definition of the term "renovation" specifically includes window
replacement; and (b) replacement of a window(s) cannot reasonably be classified as "minor repair
and maintenance activities."
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THE LEAD-BASED PAINT PRE-RENQVATIQN
EDUCATION RULE
INTERPRETIVE GUIDANCE FOR CONTRACTORS,
PROPERTY MANAGERS, AND MAINTENANCE
PERSONNEL UNDER SECTION 406(b) OF THE LEAD-
BASED PAINT HAZARD REDUCTION ACT OF 1992
Correction and Clarification to Part I Interpretive Guidance
Regarding Timing of Pamphlet Delivery
June 25, 1999
Prepared by the
Office of Pollution Prevention and Toxics
U.S. Environmental Protection Agency
Washington, D.C. 20460
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Correction and Clarification Regarding Timing of Pamphlet Delivery
EPA wishes to issue the following correction and clarification regarding timing of the lead hazard
pamphlet distribution, addressed in the May 28, 1999 Interpretive Guidance:
In response to question number 3. of the Interpretive Guidance, it was stated that an
"owner/manager may attach or incorporate the required [lead pamphlet] acknowledgment
statement into any existing repair request forms, and may distribute a copy of the pamphlet
along with the form to all tenants on a one-time basis. Whenever a repair is needed, the
tenant would simply fill out a repair request form and acknowledge receipt of the lead
information pamphlet at the same time."
The portion of the above statement related to distribution of the lead hazard pamphlet is incorrect:
although copies of the acknowledgment form may be provided to all tenants on a one-time basis,
section 745.85(a) of the regulations clearly states that the lead hazard pamphlet must be
distributed no more than 60 days before the subject renovation begins. Therefore, although an
owner/manager may choose to distribute copies of the acknowledgment form and pamphlet to all
tenants on a one-time basis to introduce tenants to the new pre-renovation rule requirements, an
additional pamphlet delivery would be needed if any renovation is to begin more than 60 days
after such a mass distribution.
In comments on the proposed section 745.85(a), several persons and organizations pointed out
that the requirement to deliver the pamphlet no more than 60 days in advance of any renovation
activity covered by the rule would result in some tenants receiving multiple copies of the
pamphlet. In developing the final pre-renovation education rule, EPA carefully weighed whether
a one-time pamphlet distribution would be adequate to meet the objectives of section 406(b) of
the lead statute, and concluded that many, if not most, tenants would benefit from receiving the
information in the lead pamphlet closer to the time that a renovation is to begin. Although some
tenants may read lead information delivered on a "for-your-information" basis, many others are
not likely to focus on potential lead hazards until a renovation affecting their unit is imminent, and
would welcome receiving information on protecting their families from lead in a more timely
fashion. To alleviate potential delays in performing repairs when tenant acknowledgments are not
obtainable, section 745.85(a)(2)(i) of the final rule permits owners/managers to "self-certify" that
a pamphlet has been delivered to the unit before the renovation begins.
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THE LEAD-BASED PAINT PRE-RENQVATION
EDUCATION RULE
INTERPRETIVE GUIDANCE FOR CONTRACTORS, PROPERTY MANAGERS, AND
MAINTENANCE PERSONNEL UNDER SECTION 406(b) OF THE LEAD- BASED PAINT
HAZARD REDUCTION ACT OF 1992
PART II
October 15, 1999
Prepared by the
Office of Pollution Prevention and Toxics
U.S. Environmental Protection Agency
Washington, D.C. 20460
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(See Part I for questions 1. - 5.)
6. Who is responsible for providing required notifications when multiple contractors are
involved in a given renovation?
If the renovation activity on a given job is overseen by a general contractor, the general contractor
is considered to be the "renovator" under the rule, and thus is responsible for ensuring that the
requirements of the rule are met. A subcontractor would not be considered a "renovator" so long
as he/she has no direct contractual relationship with the property owner or manager relating to the
given job. If a general contractor is not involved, any contractor who performs work on a job
which constitutes "renovation" under the rule is responsible for complying with the information
distribution and recordkeeping requirements of the rule. However, after those requirements have
been met by one contractor on a given job, subsequent contractors working on the same job need
not provide additional distributions/notifications. To verify that an earlier contractor has
complied with the rule, subsequent contractors are advised to personally review and, if possible,
obtain copies of pamphlet delivery confirmations and related records. If such records or copies
thereof are not present at the job site or otherwise not readily available, however, subsequent
contractors may rely upon representations by the earlier contractor, a property manager, or a
property owner that the rule requirements have been met, provided that such representations are
documented in writing and signed by the party making the representations. Subsequent
contractors who rely upon verbal representations of a prior contractor's compliance with the rule
may be held liable for non-compliance if those representations are incorrect.
7. If an outside contractor is hired to perform a renovation in an apartment building, can
the contractor effect delivery of the lead hazard pamphlet to the owner of the building via
the property manager?
The statutory language of section 406(b) specifically requires that the pamphlet be provided to
both owners and occupants of target housing. This provision underscores the importance of
notifying building owners of the potential hazards of lead-based paint during renovations.
Awareness of these potential hazards helps not only to ensure protection of tenants, but also to
alert building owners of potential liabilities if appropriate work practices are not followed. In
many apartment buildings, however, it is the property managers who are the day-to-day operators
of the facilities, and as such, they are acting in the capacity of agents for the building owners.
For this reason, EPA believes it is appropriate to permit a property manager to receive, and
acknowledge receipt of, the lead hazard pamphlet on behalf of the owner.
In situations where property managers or their employees are performing the renovations
themselves, they are acting both as "renovators" and as agents for the owner under the rule, and
thus no separate action is required to satisfy the requirement to deliver the lead hazard pamphlet
to the owner because documents in the possession of an agent are deemed to be also on the
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possession of the person or entity represented by the agent.
8. Is a renovation performed by a landlord or by employees of a management firm
considered a "compensated" renovation under the rule?
Yes. By paying rent, tenants are, in virtually all instances, contracting for both the right to
occupy a unit, and for repair/maintenance services to the unit. Therefore, even though money
does not typically change hands at the time repair or maintenance services are rendered, such
services, if they meet the definition of "renovation" under the rule, are considered to be
compensated renovations for purposes of section 406(b).
9. Is the installation of new exterior siding over an existing painted surface considered a
"renovation" under the rule?
Installation of new exterior siding requiring any removal or modification of existing painted
surfaces or painted components to ensure a uniform and structurally secure underlayment for the
new siding is considered "renovation" under the section 406(b) rule. In some cases, however,
installation activities consist solely of attaching the new siding to the existing painted surface or
structural members under the existing painted surface with nails, screws, or other fastening
devices or materials. In these cases, the Agency believes that the disturbance to the existing
painted surfaces is minimal, and therefore does not consider these latter types of re-siding
activities to be "renovation" for purposes of the section 406(b) rule.
10. Does the "limited uses common area" rule discussed in the Part I Interpretive
Guidance (question no. 4) apply to multi-building apartment complexes?
Yes. The Agency determined that it was reasonable to permit alternative notification procedures
in large apartment buildings where the renovations were occurring in an area within a common
area which is used almost exclusively by an identifiable subset of residents. The Agency stated
that in such "limited use common areas", the section 406(b) notification requirements would be
satisfied if (1) individual renovation notices were distributed to those units serviced by, or in close
proximity to, the limited use common area, and (2) placards were posted at all accessible
entrances to the renovation work site which prominently conveyed the information required under
section 745.85(b)(2) of the regulations. The Agency believes that the same logic should be
applied to multi-building apartment complexes; therefore, whenever a renovation occurs in a
limited use common area, multi-building apartment complex comprised of 50 or more dwelling
units on a contiguous site, the notification procedures described above are adequate under the
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rule.
11. Is the exterior of a building included within the meaning of a "common area"? If an
apartment complex consists of several separate buildings, does a common area renovation
in one building trigger the requirement to notify tenants in all buildings?
The examples cited in the definition of the term "common area" under section 745.103 clearly
indicate that both interiors and exteriors of buildings are included within the meaning of the term.
If a renovation is being performed in a common area on the interior of one building in a multi-
building complex, then only the units located in that.building need to receive renovation notices.
If the renovation is being performed on the exterior of one of the buildings or elsewhere on the
complex grounds, however, written notice of the renovation must be provided to every unit in the
complex unless the renovation is occurring in an area which qualifies as a "limited use common
area" as described in questions 4 and 9 above.
12. If renovation activity is being performed on a balcony of a unit, does that activity
trigger the common area notification requirements?
Under section 745.103 of the rule, a "common area" is defined as "a portion of a building that is
generally accessible to all occupants." A balcony which is generally accessible only by the
occupants of an individual dwelling unit does not fall within this definition. Therefore, renovation
activities taking place within the confines of a balcony would be subject only to the requirements
applicable to renovations within an individual unit. Note, however, that if such renovations are
not confined to the balcony, i.e., result in the release of dust, paint chips, or other construction
debris to the outside of the building, the persons performing the renovation would be required to
follow the rule requirements applicable to renovations in common areas.
13. Can common area renovation notices be delivered to the mailboxes of a unit, or only to
the unit itself?
The requirement to distribute common area renovation notices to dwelling units in multi-family
housing may be satisfied either through delivery of the notices directly to tenant units or through
delivery to tenant mailboxes. If mailbox delivery is used, both hand delivery and delivery via U.S.
mail is acceptable; however, U.S. mail deliveries must be sent 7 days prior to the commencement
of renovations and documented with a certificate of mailing.
14. If you "seal off a common area for the duration of a renovation, does the renovator
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still have to provide notifications to all tenants?
When tenant accessibility to a work site within a common area can be precluded for the duration
of a renovation, the Agency considers that work site to be temporarily excluded from the common
area of the building because it is not accessible to the residents and users of the building. To
qualify for this exclusion, however, the work site must be in an area which is enclosed by a wall,
fence, or other permanent or temporary physical barrier which prevents access by tenants and
other building users. Rope, tape lines, pylons, and similar work area designation devices which
can be easily surmounted or bypassed are not acceptable barriers.
15. Does the "emergency repair" exemption apply to the entire repair, or only that portion
of the repair which addresses the source of the emergency.
The exemption for emergency renovations was added to the final rule to address situations in
which non-routine failures of equipment necessitate immediate action to address safety or public
healths hazards or threats of significant damage to equipment and/or property. In these types of
situations, the need for immediate action clearly outweighs the need to provide lead hazard
information to tenants before the renovation is commenced. Once the portion of the repair that
addresses the source of the emergency is completed, however, the justification for the exemption
from the rule is no longer operative; therefore, any additional renovation activity needed to return
the renovation work area to its pre-emergency condition would be subject to the requirements of
the rule. Thus, for example, repairing a hole in a wall after a broken water pipe has been repaired
would be subject to the rule, as would repainting any water-stained walls or ceilings resulting
from the pipe break.
16. Does a renovator need to attempt personal delivery of the lead information pamphlet to
a tenant more than one time before utilizing the "self-certification of pamphlet delivery"
option?
Personal delivery of the lead information pamphlet is preferable, wherever possible, because EPA
believes that tenants will be more likely to read the information if it is handed directly to them. It
also affords tenants an opportunity to raise concerns and ask questions about the renovation. In
drafting the final rule, however, the Agency recognized that personal delivery would not always
be viable option, especially when a renovation needs to be commenced on short notice and an
adult occupant of the apartment is not available. For this reason, the Agency included a provision
in the final rule which permits the person delivering the pamphlet to "self-certify" the delivery
(40 C.F.R. 745.85(a)(2)(i)). Although it is recommended that delivery be attempted on more than
one occasion, a single good faith delivery attempt is acceptable for purposes of the rule.
SPECIAL NOTE: the self certification provisions of the rule apply only to pamphlet deliveries to
rental units: renovators cannot self-certify a pamphlet delivery to the owner of the dwelling unit.
Pamphlet deliveries to unit owners must be made directly to the owner, an agent of the owner, or
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via mailing.
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17. In a typical co-operative apartment building, occupants do not own the individual
units; rather they "own" an undifferentiated share in the entire building and then "rent"
back a specific unit from the co-operative corporation. Similarly, in a typical condominium
building, owners of individual units jointly own the common areas of the building. For
purposes of the rule, who are the "owners" in such situations?
EPA recognizes that co-operative apartments ("co-ops") and condominiums ("condos") can be
structured in a variety of ways. For example, in the case of co-ops, a corporation (sometimes
referred to as a "co-op association") is often established and owns all the units and common areas
comprising the co-op; in such circumstances, individual unit "shareholders" own shares in the
corporation and also own occupancy rights or lease a unit from the corporation. In the case of
many condos, individuals hold title to their individual units, and all condo unit owners jointly own
the common areas (with a condo association established to represent the interests of all the unit
owners).
For purposes of this rule, the following general principles will be applied:
(a) if title to a building is held by a corporation which leases back dwelling units to individual
corporation shareholders, as in typical co-op apartment buildings, the corporation/association will
generally be considered to be the "owner" of the entire building, and individual resident
shareholders, or persons who rent from individual shareholders, will generally be considered to be
tenants.
(b) In buildings where individuals hold title to specific dwelling units and jointly hold title to
common areas of the building, as in typical condo buildings, the individual owners each will be
considered to be the owners of his/her individual units, and the association (or its equivalent body
composed of, or representing, the group of owners) will be considered the owner of the common
areas of the building.
See the attached Table A for more specific guidance on meeting the requirements of the rule as
they relate to various renovation scenarios in co-ops and condos.
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TABLE A
COMPLIANCE WITH §406(b) PRE-RENOVA TION RULE FOR
COOPERATIVE APARTMENTS AND CONDOMINIUMS
RENOVATION
LOCATION
RULE
REQUIREMENT
COMPLIANCE FOR
CO-OPs
COMPLIANCE FOR
CONDOs
Renovations Inside
Individual Unit
1. Deliver Pamphlet to
Owner
§745.85(a)(l)
2. Deliver Pamphlet to
Adult Occupant
(Tenant)
§745.85(a)(2)
1. Deliver Pamphlet to
Co-op Corp./Assoc.
or Property Manager
2, Deliver Pamphlet to
Resident Co-op Share
holder or Adult
Occupant
1. Deliver Pamphlet to
Condo Unit Owner
(Or Agent of Owner)
2. If Condo is Leased,
Deliver Pamphlet to
Adult Occupant
Renovations In a
Common Area
1. Deliver Pamphlet to
Owner
§745.85(b)(l)
2. Deliver Notice to
Each Unit
§745.85(b)(2)
1. Deliver Pamphlet to
Co-op Corp./Assoc.
or Property Manager
2. Deliver Notice to
Each Unit
1. Deliver Pamphlet to
Condo Association
or Property Manager
2. Deliver Notice to
Each Unit
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APPENDIX 4
Liability Insurance Summary
Fact Sheet
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FACT SHEET
Liability Insurance Summary
There are three types of liability insurance that individuals and firms involved in residential
renovation, remodeling and painting should consider when evaluating their insurance
needs:
Commercial General Liability (CGL);
Professional liability errors and omissions (E&O); and
Pollution liability.
In addition, there are two coverage "triggers" in liability insurance policies:
Occurrence-based; and
Claims-made.
This document discusses the types of insurance and policy coverage triggers, and then
provides a list of questions to consider when deciding what type of insurance to purchase.
Types of Insurance
Commercial General Liability Insurance. CGL policies are typically carried by
contractors and contracting firms. They cover claims arising from business premises
liability exposures, on-site contracting operations liability, liability assumed in a
construction contract, liability arising out of the work performed by hired independent
contractors, liability arising out of products that are manufactured, sold or installed, and
liability arising out completed work or projects.
Professional Liability Errors and Omissions Insurance. E&O policies are usually
carried by those persons and firms that render "professional services," such as architects,
engineers, designers, management planners, risk assessors, lead paint inspectors and
others that design and write specifications for renovation, remodeling and painting
projects. These policies cover liability that results from providing or failing to provide such
professional services.
Under the law, "professionals" are held to a higher standard of care than laymen, and most
CGL policies have exclusions for claims that result from the performance, or failure, of the
professional service. E&O policies cover only the professional act itself; therefore, they
cover a far narrower range of potential claims than CGL policies. CGL coverage protects
contractors from liability due to accidents while E&O coverage protects professionals from
liability that results from giving advice or providing other professional services. For
example, a lead inspector who drops a flashlight onto and injures a passing tenant will be
covered by CGL insurance if a claim is brought. If the lead inspector fails to identify lead-
containing materials and there is a resulting claim, he or she will be covered by E&O
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insurance. An architect who designs a defective containment scaffold that collapses would
be covered by E&O. If a worker incorrectly assembles a properly designed scaffold, any
resulting accidents would be covered by CGL.
Pollution Liability Insurance. Standard CGL and E&O insurance almost always
contains a "pollution exclusion" or other clause that excludes coverage for liability caused
by "pollution." To the extent that residential renovation, remodeling and painting projects
generate lead-related "pollutants" or "contaminants," CGL and E&O policies may not cover
any resulting claims. Therefore, it may also be necessary to consider acquiring special
pollution liability insurance and/or a CGL or E&O policy that has been specifically written or
endorsed to include coverage of claims and suits for bodily injury and property damage
contamination caused by lead.
Occurrence-based Versus Claims-made Insurance
Liability insurance policies are written as either "occurrence-based" or "claims-made." An
occurrence-based policy is one that covers claims that result from an accident that
occurs during the term of the insurance policy, regardless of how long it takes for the claim
to be made. It does not matter if the policy expired years before the claim finally arises; as
long as the accident or exposure to injurious conditions or substances happened or
"occurred" during the policy term, the resulting claim will be covered by the insurance.
Some occurrence-based policies may include sunset clauses. A sunset clause states
that the coverage lasts for a limited time beyond the expiration date of the policy. For
example, if a policy has a sunset clause after five years, and expires on December 31,
2001, then any claims made after December 21, 2006 will not be covered. These clauses
are not very prevalent although they sometimes appear in pollution liability policies.
A claims-made policy covers a claim for an accident, as long as both the accident and the
claim take place while the policy is in force. The policyholder must have a claims-made
policy in effect when the claim is first made against the policyholder and reported to the
insurance company in order to have coverage. If the policy has expired or been canceled
after the accident but before the claim comes in, the policyholder has no insurance
coverage. Most claims-made policies include a retroactive or retro-date clause. The
retroactive clause states that the policy will not cover any claims resulting from accidents
that happened more than a specified amount of time before the inception date of the
policy.
Insurance companies may be willing to modify insurance policy provisions during
negotiations and before policy inception. Some insurers offering occurrence-based
insurance will drop or extend the periods of sunset clauses prior to writing the policy.
Some insurers offering claims-made insurance can be persuaded to push the retro-date
back to an earlier time, so that the policyholder will be covered for all claims arising from
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the insured's previous activities. Also, most insurers now provide or offer extended
discovery periods endorsements for claims-made policies. For an additional premium,
the policyhotder gains an extension of time during which to file claims after the policy
expires, as long as the accident occurred during a time period covered by the expiring
policy. Extended discovery periods of one year are common. Longer periods are less
common.
Generally, most CGL policies are occurrence-based while most E&O policies are claims-
made.
Financial Viability of Insurers
Regulation of insurance is left to the states and, depending on the structure of insurance
companies and the types of insurance coverage being offered, that regulation and financial
oversight might be extensive, limited or non-existent. Pre-approval of policy forms and
rates, and periodic financial and operational audits may or may not be required. However,
most all insurance companies have some minimum capitalization requirements before
they can write any business. Yearly financial statements should be available that provide
details on the company's financial viability.
Additionally, there are independent commercial rating services that report on the insurance
company's relative financial strength, balance sheet, profit and loss statement,
investments, financial reserves to pay for claims, claims payment history, management
expertise and lines of business written. These services include A. M. Best Company and
Moody's. The reports published by A. M. Best and Moody's provide another source of
information on insurers' financial viability and stability.
Insurance Availability
CGL and E&O policies are widely available in the commercial insurance market, but lead-
specific and other pollution liability policies are not. Further, those pollution liability policies
currently available have high minimum premiums and vary in terms of the coverage
provided. This coverage is often very narrowly written and may have a number of
conditions and exclusions that will limit applicability to certain claim and/or suit situations.
Questions to Ask When Choosing Insurance
To determine what types of insurance are appropriate for residential renovation,
remodeling and painting projects and whether a particular insurer is financially viable and
stable, individuals and firms engaged in this work should consult with their insurance agent
or broker, professional risk manager and/or attorney. Questions that should be asked and
answered include the following:
1 -. Is CGL insurance adequate for the types of claims exposures my work will create?
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2. Does my work specifically include providing professional services for which E&O
insurance is intended?
3. Does my existing insurance cover "bodily injury" or "property damage" caused by
exposure to lead?
4. Will I be working in properties that might contain lead-based paint and result in my
work generating lead contamination and exposure?
5. Is my exposure to lead-specific or pollution-related claims so small as to eliminate
the need for special pollution liability insurance? How often will painted surfaces
and components in properties where I work be tested for lead-based paint?
6. If I choose not to purchase CGL, E&O or special pollution liability insurance policies
that cover lead liability claims, will it limit my ability to bid on projects or to be
deemed acceptable for some residential renovation, remodeling or painting
projects? If so, is that acceptable to me?
7. If I choose not to purchase CGL, E&O and/or special pollution liability insurance
policies that cover lead liability, can I afford to bear the out-of-pocket cost and
responsibility of handling, investigating, defending and paying for any claims or
suits against me?
8. For those insurance policies that I am considering, what are the financial ratings of
the insurers under consideration, as determined by independent insurance
company rating services such as the A. M. Best Company and Moody's? Have any
state insurance departments placed such insurers on a financial "watch" list or
under supervision?
9. For those insurance policies that I am considering, are there any policy conditions
or exclusions that would limit coverage of a claim or law suit?
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APPENDIX 5
Overview of EPA and State
Certification Requirements
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EPA AND STATE CERTIFICATION PROGRAMS AND THEIR TREATMENT OF
INTERIM CONTROLS
1. EPA and State Certification. On March 1, 2000, the training and certification requirements of TSCA
section 402 were in full effect in the Federal program operating in non-authorized States and Tribes. All
individuals and firms performing "lead-based paint activities" as defined in 745.223 must be certified under
745.226 and must perform lead-based paint activities according to the work practice standards in 745.227.
EPA has developed regulations under TSCA sections 402/404 covering individuals and firms who are
conducting lead-based paint activities in target housing and child-occupied facilities. Lead-based paint
activities include inspection, risk assessment, and abatement. The requirements that individuals and firms
must meet depend where they wish to work. Some States and Indian tribes are running their own programs
that were authorized by EPA ("EPA-authorized programs"). In other States and Tribes that do not have an
authorized program, EPA is running the program ("Federal program").
On March 1,2000, EPA's Federal program under 40 CFR part 745 subpart L became fully affective in
every State and Tribe that did not already have an EPA-approved authorized program in operation.
Therefore, since March 1, 2000, anyone conducting inspections, risk assessments and/or abatements in
target housing or child-occupied facilities has been subject to training, certification and work practice
standard requirements either under EPA's Federal Program or an EPA-authorized State or Tribal program.
In EPA's Federal program, individuals who want to work as inspectors, risk assessors, abatement
supervisors, abatement workers, and/or project designers, must be certified first. Each of the five disciplines
has different education, experience and training requirements. Individuals who wish to be certified as
inspectors, risk assessors, or abatement supervisors must also take a third party certification exam.
Certification is granted after individuals have sent in an application indicating they have completed an
accredited training course, met any other qualifications, and sent in a certification fee. Certified individuals
agree to follow EPA's work practice standards. EPA's federal program also requires that firms whose
employees conduct lead-based paint activities also be certified. In the EPA application, the firm agrees (1)
to use only certified employees for inspection, risk assessment and abatement; (2) to use the work practice
standards that EPA requires; and (3) to keep appropriate records.
Some EPA-authorized programs (State Lead Programs) may have certification requirements for different
individual disciplines than EPA's Federal program and may or may not certify firms. There may also be
differences in the types of activities regulated by EPA-authorized programs. For this reason, it is important
for individuals and firms to understand the specific regulations that apply in the locations where they intend
to work.
II. Qualification for Interim Controls. EPA, under the Federal program, does not regulate interim controls.
However, EPA-authorized State and Tribal programs may regulate interim controls. Therefore, it is important
for individuals and firms to review the specific regulations for the locations where they will be working.
HUD's Lead Safe Housing rule requires individuals conducting interim controls to be trained in one of
the acceptable training courses listed in the rule. Among courses listed are (1) an accredited lead-based
paint abatement supervisor course, or (2) an accredited lead-based paint abatement worker course. Those
two courses refer to courses accredited in EPA's Federal program or an EPA authorized program.
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EPA-AUTHORIZED STATES
As of January 1,2001, the following states operate their own lead programs:
Alabama
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Georgia
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
New Hampshire
New Jersey
North Carolina
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
Tennessee
Texas
Utah
Vermont
Virginia
West Virginia
Wisconsin
EPA LEAD PROGRAM STATES
As of January 1, 2001, the EPA operates the lead programs on behalf of the state:
Alaska, EPA Reg 10
Arizona, EPA Reg 9
Florida, EPA Reg 4
Guam, EPA Reg 9
Hawaii, EPA Reg 9
Idaho, EPA Reg 10
Montana, EPA Reg 8
Nebraska, EPA Reg 7
Nevada, EPA Reg 9
New Mexico, EPA Reg 6
New York, EPA Reg 2
North Dakota, EPA Reg 8
South Carolina, EPA Reg 4
South Dakota, EPA Reg 8
Virgin Islands, EPA Reg 2
Washington, EPA Reg 10
Wyoming, EPA Reg 8
For more information and a list of state lead contacts, visit the web site of the National
Conference of State Legislatures: www.ncsl.oru/prourarns/ESNR/pplans-99.htm, or call 1-
800-424-LEAD.
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APPENDIX 6
EPA Waste Policy Guidance
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r~ r% A United States Office of Pollution Prevention
|^ /V Environmental Protection Agency and Toxics
Lead-based Paint for Residential Contractors.
Lead-Based Paint is Household Waste.
August 2000
Agency Policy
Aiming to further reduce lead poisoning in children, the Environmental Protection Agency (EPA) clarified that
contractors can manage residential lead-based paint (LBP) waste as household waste. Allowing LBP waste to
be managed this way makes it more affordable for people to reduce lead in and around their homes.
Contractor Waste
Residential contractors frequently work on residential dwellings like single family homes, apartment buildings,
row houses, military barracks, or college dormitories. They routinely generate LBP waste during lead
abatement, remodeling, or rehabilitation work on these residences. The waste consists mostly of building parts,
such as doors, window frames, painted woodwork, and paint chips. Because the standards were unclear,
contractors who needed to dispose of lead-based paint waste were uncertain about how to properly manage it.
EPA's policy statement allows contractor-generated LBP waste to be disposed of as household waste.
Household waste is regular garbage or trash that is disposed of as municipal waste, and managed according to
state and local requirements. Residents are already entitled to manage their own LBP waste in this manner.
Extending this option to contractors simplifies abatement work and lowers its cost, which will allow more lead
paint removal from more homes nationwide. Consequently, people's homes everywhere will be safer for both
children and adults.
Safe Handling
EPA encourages everyone who handles lead-based paint to follow several common sense measures:
Collect paint chips, dust, dirt, and rubble in plastic trash bags for disposal. Store larger LBP building parts in
containers until ready for disposal. If possible, use a covered mobile dumpster (such as a roll-off container) to
store LBP debris until the job is done. Contact local solid waste authorities to determine where and how LBP
debris can be disposed of.
The Toxic Substances Control Act (TSCA) contains training and certification requirements that contractors also
should learn and follow. These requirements are under TSCA 402/404, and can be found on the Internet at
http://www.epa.gov/lead/leadcert.htm. Note also that the US Department of Housing and Urban Development
(HUD) established guidelines for contractors performing lead-based paint activities (see
http://www.hud.gov/lea/learules.html).
Proposed TSCA Standards
EPA intends to pursue additional measures to promote LBP abatement activities. For example, in 1998 the
Agency proposed new standards under TSCA that would replace existing Resource Conservation and Recovery
Act (RCRA) hazardous waste regulations covering the disposal of LBP. This change, if adopted, would provide
greater waste management flexibility and efficiency in numerous circumstances where lead-based paint is
generated. Full details of the LBP proposal are available on the Internet at http://www.epa.gov/lead.
For More Information
For general information on lead-based paint and lead-based paint hazards, call the National Lead Information
Center at 1 800 424 LEAD (5323). You may also obtain information by calling the RCRA Hotline. Callers within
the Washington Metropolitan Area must dial 703-412-9810 or TDD 703-412-3323 (hearing impaired). Long-
distance callers may call 1-800-424- 9346 or TDD 1-800-553-7672. The RCRA Hotline operates weekdays, 9:00
a.m. to 6:00 p.m. Write to the RCRA Information Center (5305W), US EPA, Ariel Rios Building, 1200
Pennsylvania Avenue, NW, Washington, DC 20460.
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EPA OSW 7/31/2000 memo: Regulatory Status of Waste Generated by Contractors and
Residents from Lead-Based Paint Activities Conducted in Households I
July 31,2000
MEMORANDUM
From: /sf Elizabeth A. Cotsworth, Director
Office of Solid Waste
To: RCRA Senior Policy Advisors
EPA Regions 1-10
Subject: Regulatory Status of Waste Generated by Contractors and Residents from Lead-
Based Paint Activities Conducted in Households
What is the purpose of this interpretation?
This memorandum clarifies the regulatory' status of waste generated as a result of lead-based
paint (LBP) activities (including abatement, renovation and remodeling) in homes and other
residences. Since 1980, EPA has excluded "household waste" from the universe of RCRA
hazardous wastes under 40 CFR 261.4(b)(l). In the 1998 temporary toxicity characteristic (TC)
suspension proposal, we clarified that the household waste exclusion applies to "all LBP waste
generated as a result of actions by residents of households (hereinafter referred to as "residents")
to renovate, remodel or abate their homes on their own." 63 FR 70233, 70241 (Dec. 18, 1998).
In this memorandum, EPA is explaining that we believe lead paint debris generated by
contractors in households is also "household waste" and thus excluded from the RCRA Subtitle
C hazardous waste regulations. Thus, the household exclusion applies to waste generated by
either residents or contractors conducting LBP activities in residences.
What is the practical significance of classifying LBP waste as a household waste?
As a result of this clarification, contractors may dispose of hazardous-LBP wastes from
residential lead paint abatements as household garbage subject to applicable State regulations.
This practice will simplify many lead abatement activities and reduce their costs. In this way,
the clarification in today's memorandum will facilitate additional residential abatement,
renovation and remodeling, and rehabilitation activities, thus protecting children from continued
exposure to lead paint in homes and making residential dwellings lead safe for children and
adults.
LBP debris (such as architectural building components ~ doors, window frames, painted wood
work) that do not exhibit the TC for lead need not be managed as hazardous waste. However,
LBP waste such as debris, paint chips, dust, and sludges generated from abatement and deleading
activities that exhibit the TC for lead (that is, exceed the TC regulatory limit of 5 mg/L lead in
the waste leachate), are hazardous wastes and must be managed and disposed of in accordance
with the applicable RCRA subtitle C requirements (including land disposal restrictions) except
when it is "household waste." Under 40 CFR 261.4(b)(l), household wastes are excluded from
the hazardous waste management requirements. Today, EPA is clarifying that waste generated
as part of LBP activities conducted at residences (which include single family homes, apartment
buildings, public housing, and military barracks) is also household waste, that such wastes are
no longer hazardous wastes and that such wastes thus are excluded from RCRA's hazardous
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EPA OSW 7/31/2000 memo: Regulatory Status of Waste Generated by Contractors and
Residents from Lead-Based Paint Activities Conducted in Households 2
waste management and disposal regulations. Generators of residential LBP waste do not have to
make a RCRA hazardous waste determination. This interpretation holds regardless of whether
the waste exhibits the toxicity characteristic or whether the LBP activities were performed by the
residents themselves or by a contractor.
Where can I dispose of my household LBP waste?
LBP waste from residences can be discarded in a municipal solid waste landfill (MSWLF) or a
municipal solid waste combustor. Dumping and open burning of residential LBP waste is not
allowed. Certain LBP waste (such as large quantities of concentrated lead paint waste paint
chips, dust, or sludges) from residential deleading activities may be subject to more stringent
requirements of State, local, and/or tribal authorities.
What is the basis for this interpretation?
The household waste exclusion implements Congress's intent that the hazardous waste
regulations are "not to be used either to control the disposal of substances used in households or
to extend control over general municipal wastes based on the presence of such substances." S.
Rep. No. 94-988, 94th Cong., 2nd Sess., at 16. EPA regulations define "household waste" to
include "any waste material (including garbage, trash, and sanitary wastes in septic tanks)
derived from households (including single and multiple residences, hotels and motels,
bunkhouses, ranger stations, crew quarters, campgrounds, picnic grounds and day-use recreation
areas)." 40 CFR 261.4(b)(l). The Agency has applied two criteria to define the scope of the
exclusion: (1) the waste must be generated by individuals on the premises of a household, and
(2) the waste must be composed primarily of materials found in the wastes generated by
consumers in their homes (49 FR 44978 and 63 FR 70241).
In 1998, EPA concluded that LBP waste resulting from renovation and remodeling efforts by
residents of households met these criteria. (63 FR 70241-42, Dec. 18, 1998). In short, the
Agency found that more and more residents are engaged in these activities and thus the waste
can be considered to be generated by individuals in a household and of the type that consumers
generate routinely in their homes. Wastes from LBP abatements performed by residents were
also considered household wastes.
EPA clarifies that this interpretation also applies to contractor-generated LBP waste from
renovations, remodeling and abatements in residences. Both the definition of household waste in
section 261.4(b)(l) and the Agency's criteria for determining the scope of the exclusion focus on
the type of waste generated and the place of generation rather than who generated the waste (e.g.,
a resident or a contractor). This approach is consistent with prior Agency policy.' Since
In the final rule establishing standards for the tracking and management of medical waste, EPA concluded
that waste generated by health care providers (e.g., contractors) in private homes would be covered by the household
waste exclusion. 54 FR 12326, 12339 (March 24, 1989). In the specific context of LBP, the Agency stated in a
March 1990 "EPA Hotline Report" (RCRA Question 6) that lead paint chips and dust resulting from stripping and
re-painting of residential walls by homeowner or contractors (as part of routine household maintenance) would be
part of the household waste stream and not subject to RCRA Subtitle C regulations. Similarly, in a March 1995
memorandum on the "Applicability of the Household Waste Exclusion to Lead- Contaminated Soils," we found that
if the source of the lead contamination was as a result of cither routine residential maintenance or the weathering or
chalking of lead-based paint from the residence, the hazardous waste regulations do not apply so long as the lead-
contaminated soil is managed onsite or disposed offsite according to applicable solid waste regulations and/or State
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EPA OSW 7/31/2000 memo: Regulatory Status of Waste Generated by Contractors and
Residents from Lead-Based Paint Activities Conducted in Households 3
contractor-generated LBP waste from residential renovations, remodeling, rehabilitation, and
abatements are of the type generated by consumers in their homes, it is appropriate to conclude
that such waste, whether generated by a resident or contractor, falls within the household waste
exclusion. This clarification will facilitate lead abatements and deleading activities in target
housing by reducing the costs of managing and disposing of LBP waste from residences.
What is the relationship of this interpretation to the on-going LBP debris rulemaking?
On December 18, 1998, EPA proposed new TSCA standards for management and disposal of
LBP debris (63 FR 70190) and simultaneously proposed to suspend temporarily the applicability
of the RCRA hazardous waste regulations that currently apply to LBP debris (63 FR 70233).
This memorandum responds to stakeholders requests that EPA clarify whether the existing
household waste exclusion applies to both homeowners and contractors conducting LBP
activities in residences. While the Agency still intends to finalize aspects of the two proposals,
we are making this clarification in advance of the final rule to facilitate LBP abatement in
residences without unnecessary delay.
How does this interpretation affect EPA's enforcement authorities?
Under this clarification, LBP wastes generated by residents or contractors from the renovation,
remodeling, rehabilitation, and/or abatement of residences are household wastes that are
excluded from EPA's hazardous waste requirements in 40 CFR Parts 124, and 262 through 271.
The household waste provision of 40 CFR 261,4(b)(l) only excludes such wastes from the
RCRA regulatory requirements. However, it does not affect EPA's ability to reach those wastes
under its statutory authorities, such as RCRA §3007 (inspection) and §7003 (imminent hazard).
See40CFR§261.1(b).
What are the "best management practices" for handling residential LBP waste?
Although excluded from the hazardous waste regulations, EPA encourages residents and
contractors managing LBP waste from households to take common sense measures to minimize
the generation of lead dust, limit access to stored LBP wastes including debris, and maintain the
integrity of waste packaging material during transfer of LBP waste. In particular, we continue to
endorse the basic steps outlined in the 1998 proposals for the proper handling and disposal of
LBP waste (63 FR 70242) as the best management practices (BMPs) including:
D Collect paint chips and dust, and dirt and rubble in plastic trash bags for disposal.
D Store larger LBP architectural debris pieces in containers until ready for disposal.
D Consider using a covered mobile dumpster (such as a roll-off container) for storage of
LBP debris until the job is done.
D Contact local municipalities or county solid waste offices to determine where and how
LBP debris can be disposed.
In addition, contractors working in residential dwellings are subject to either one or both of the
following:
law mandated by RCRA.
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EPA OSW 7/31/2000 memo: Regulatory Status of Waste Generated by Contractors and
Residents from Lead-Based Paint Activities Conducted in Households
D The HUD Guidance for contractors doing publically-funded rehabilitation/renovation
projects in public housing. (See Guidelines for the Evaluation and Control of Lead-
Based Paint Hazards in Housing. U.S. Department of Housing and Urban Development,
June 1995) The HUD guidelines can be accessed via the Internet at:
http://www.hud.EQv/lea/learules.html
D TSCA 402/404 training and certification requirements. (See 40 CFR Part 745; 61 FR
45778, August 29, 1996) and the proposed TSCA onsite management standards (See 40
CFR Part 745, Subpart P; 63 FR 70227 - 70230, Dec. 18, 1998). [EPA expects to issue
the final rule next year.]
The above-mentioned BMPs for households are similar to those included in the HUD Guidelines
for individuals controlling LBP hazards in housing. HUD requires that contractors using HUD
funding adhere to LBP hazard control guidelines. Non-adherence to these guidelines can
potentially result in the loss of funding.
Does this interpretation apply in my State and/or locality?
We encourage contractors and residents to contact their state, local and/or tribal government to
determine whether any restrictions apply to the disposal of residential LBP waste. This
verification is necessary since, under RCRA, States, local and tribal governments can enforce
regulations that are more stringent or broader in scope than the federal requirements. Thus,
under such circumstances, LBP waste from households may still be regulated as a hazardous
waste as a matter of State regulations.
We are distributing this memorandum to all 56 States and Territories, and Tribal Programs and
various trade associations. We encourage States to arrange for implementation of the
interpretation discussed in this memo in their States to facilitate residential LBP abatements
making residential dwellings lead-safe. We encourage trade associations to inform their
memberships about this memo and instruct them about ways to manage residential LBP waste.
Whom should I contact for more information?
If you have additional questions concerning the regulatory status of waste generated from lead-
based paint activities in residences, please contact Ms. Rajani D. Joglekar of my staff at 703/308-
8806 or Mr. Malcolm Woolf of the EPA General Counsel's Office at 202/564-5526.
cc: Key RCRA Contacts, Regions 1-10
RCRA Regional Council Contacts, Regions 1-10
RCRA Enforcement Council Contacts, Regions 1 - 10
Association of State and Territorial Solid Waste Management Officials ( ASTSWMO)
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EPA Model Training
Minimizing Lead-Based Paint Hazards During Renovation,
Remodeling, and Painting
Course Evaluation
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