i JOINT EPA - HUD CURRICULUM
Safet
for Renovation,
Repair, an
Painting
i
Module 1: Regulations
Module 2: Using
EPA-Recognized Test Kits
Module 3: Review of Setup
Practices
Module 4: Review of Vi
Prohibited Practices, Personal
Protective Equipment, and Dust
Control
Module 5: Cleaning Activities
and Checking Your Work
Module 6: Recordkeeping
Module 7: Training
Non-Certified Renovators
.-740-R-09-004
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CO
CD
O
CD
Refresher
Student
Manual
EPA-740-R-09-004
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Introduction
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Lead Safety for Renovation, Repair, and Painting Refresher
Lead Safety for Renovation, Repair
and Painting
Welcome and Introductions
Please tell the class:
Your name, the company you work for, and what you do.
Module Overview:
Course agenda
Course manual
xvEPA
Mar 09
Why Are You Here?
Traditional renovation work, without lead safe work practices, creates significant dust-lead
hazards if lead-based paint is disturbed.
The leaded dust generated by traditional renovation work can cause lead poisoning in children.
It can also poison pregnant women, yourself and other workers and even pets. Practical
changes in work practices can minimize and contain dust. The use of lead-safe work practices
makes the job safer and reduces your liability exposure.
EPA's Renovation, Repair and Painting Final Rule (40 CFR 745) requires that renovations
conducted for compensation, must be performed by Certified Firms using Certified
Renovators. Renovation firms that wish to work in pre-1978 homes and child-occupied
facilities must apply to EPA and pay a fee in order to become certified. Renovators seeking to
become Certified Renovators must successfully complete an EPA-accredited renovator course
or a course accredited by an EPA authorized State or Tribe. This course is the EPA model
course for Certified Renovators and as such meets all requirements in 40 CFR 745.90.
This course will teach you how to comply with the EPA Renovation, Repair and Painting Rule
and the HUD Lead Safe Housing Rule, and how to perform lead-safe work practices safely
and effectively.
Once you have successfully complete this Certified Renovator refresher course, delivered by
an EPA-accredited training provider, you will be an EPA Certified Renovator. EPA Certified
Renovator status will allow you to do lead safe renovation, repair, and painting work in pre-
1978 housing and in child-occupied facilities where work will disturb lead-based paint. Your
certification is valid for five years from the date of completion of the course. To renew
certification after five years, you must successfully complete another EPA-accredited Certified
Renovator Refresher Course before your initial certification expires. Refresher training must be
taken every five years to maintain certification. If the certified renovator training is not
refreshed within five years of the previous training, you must retake the initial course to
become certified again.
Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
Course Agenda
Introduction and welcome
Module 1: Federal Regulations
Module 2: Using EPA-
Recognized Test Kits
Module 3: Review of Setup
Practices
Module 4: Review of Prohibited
Practices, Personal Protective
Equipment and Dust Control
Module 5: Review of
Cleanup Practices,
Cleaning Verification
Procedure and Hands-on
Module 6: Recordkeeping
Module 7: Training Non-
Certified Renovation
Workers
Mar 09
Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
Training Manual Overview
Seven modules
Key appendices
Appendix 1 - EPA's Renovation, Repair, and Maintenance
Program Final Rule (40 CFR Part 745)
Appendix 2 - U.S. Department of Housing and Urban
Development (HUD) Requirements
Appendix 3 - Renovate Right: Important Lead Hazard
Information for Families, Child Care Providers and Schools
Appendix 4 - Small Entity Compliance Guide to Renovate Right
Appendix 5 - Steps to LEAD SAFE Renovation, Repair, and
Painting
Appendix 6 - Hands-on Exercises
Mar 09
Modules - In addition to this introduction, there are eight modules in this course:
Module 1: Regulations
Module 2: Using EPA-Re cognized Test Kits
Module 3: Review of Setup Practices
Module 4: Review of Prohibited Practices, Personal Protective Equipment and Dust Control
Module 5: Cleaning Activities and Checking Your Work
Module 6: Recordkeeping
Module 7: Training Non-Certified Renovators
Appendices - This manual has nine appendices that provide extra information that will help
contractors.
Appendix 1 - EPA's Renovation, Repair, and Maintenance Program Final Rule (40 CFR Part
745)
Appendix 2 - U.S. Department of Housing and Urban Development (HUD) Requirements
Appendix 3 - Renovate Right: Important Lead Hazard Information for Families, Child Care
Providers and Schools
Appendix 4 - Small Entity Compliance Guide to Renovate Right
Appendix 5 - Steps to LEAD SAFE Renovation, Repair, and Painting
Appendix 6 - Hands-on Exercises
Appendix 7 - State and Local Regulatory Requirements
Appendix 8 - Regulatory Status of Waste Generated by Contractors and Residents from Lead-
Based Paint Activities Conducted in Households
Appendix 9 - For More information
Test - Renovators must pass the test administered at the end of the course in order to earn
certification. Failure to pass the test means you must retake the course.
Mar 09
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Module 1: Regulations
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Lead Safety for Renovation, Repair, and Painting Refresher
Module 1: Regulations - The RRP
Rule
Addresses activities that disturb lead-based paint in
target housing and child-occupied facilities. It requires:
Renovators to be certified through training.
Firms to be certified.
Training providers to be accredited.
Lead-safe work practices during renovations.
Pre-renovation education in target housing and child-occupied
facilities.
After April 22, 2010, firms working in pre-1978 homes
and child-occupied facilities must be certified and use
lead-safe work practices during renovations.
EPA may authorize states, territories and tribes to
enforce the Rule.
Mar 09
1-1
EPA's Renovation, Repair and Painting Final Rule:
Published April 22, 2008, under the authority of the Toxic Substances Control Act (section
402(c)(3)ofTSCA).
The final rule addresses lead-based paint hazards created by renovation, repair and painting
activities that disturb lead-based paint in "target housing" and "child-occupied facilities."
Target Housing is a home or residential unit built on or before December 31, 1977, except:
Housing designated for the elderly or persons with disabilities (unless any child who is less
than 6 years of age resides or is expected to reside in such housing).
Any zero-bedroom dwelling (e.g. studio apartments, hospitals, hotels, dormitories, etc).
A Child-Occupied Facility is a pre-1978 building that meets all three of the criteria below:
Visited regularly by the same child, under 6 years of age.
The visits are on at least two different days within any week (Sunday through Saturday
period), provided that each day's visit lasts at least 3 hours.
Combined weekly visits last at least 6 hours, and the combined annual visits last at least 60
hours.
Child-occupied facilities may be located in a public or commercial building or in target
housing. These facilities include schools, child care facilities, and daycare centers.
State Authorization: EPA may authorize states, territories and tribes to enforce all aspects of the
RRP Rule. Such states are called "authorized states." EPA enforces the Rule in non-authorized
states.
The Rule is effective April 2010:
Training providers must be accredited.
Renovation firms must be certified.
Renovators and dust sampling technicians must be trained and certified.
Non-certified workers must work under and be trained on-the-job by a Certified Renovator.
Work practices must be followed for renovations covered by the rule.
Renovators must educate owners/occupants.
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Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
The RRP Rule: Exclusions
Renovation activities where affected
components do not contain lead-based paint.
Emergency renovations (requires cleanup and
cleaning verification).
Minor repair and maintenance activities. Note:
This does not apply to window replacement,
demolition or activities involving prohibited
practices.
Renovations performed by homeowners in
their own homes.
"-
Mar 09
1-2
The Renovation, Repair, and Painting rule does not apply to renovation work that meets the following
exclusions.
If the renovation only affects components that do not contain lead-based paint, the rule does not apply to
renovation of these components.
EPA has established limits (see below) for minor repairs or maintenance. Work that does not exceed
these limits is exempt from the work practice requirements in the Rule. The EPA limits for minor repairs
and maintenance are larger than the HUD limits (see the HUD box below).
Minor repair and maintenance activities have been defined in the Rule.
EPA has defined minor repair and maintenance activities as below.
Interior work disturbing less than 6 square feet (6 ft2) per room of painted surface is exempt from
the work practices requirements in the Rule. Cleanup and cleaning verification are not required
after minor repair and maintenance activities, unless they involve window replacement, demolition,
or prohibited practices.
Exterior work disturbing less than 20 square feet (20 ft2) of painted surface is exempt from
the work practices requirements in the Rule. Cleanup and cleaning verification are not required
after minor repair and maintenance activities, unless they involve window replacement, demolition,
or prohibited practices.
1. Minor repair and maintenance activities do not include window replacement, demolition or activities
involving prohibited practices.
2. When removing painted components, the entire surface area removed is the amount of painted
surface disturbed. Work, other than emergency renovations, performed within a 30-day period
must be considered the same job when determining the amount of paint disturbed.
The HUD Lead Safe Housing Rule applies to every home built prior to 1978 that receives
Federal housing assistance, where greater than HDD's de minimis amounts of painted
surfaces will be disturbed. HDD's de minimis amounts are: 2 square feet of interior lead-
based paint, 20 square feet of exterior lead-based paint or 10% of the total surface area on
an interior or exterior type of component with a small surface area that contains lead-
based paint. Examples include window sills, baseboards, and trim.
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Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
The RRP Rule:
"Opt-Out" Provision
Homeowners may sign a statement to opt out
of the work practice requirements in the Rule,
if all of the following are true:
The owner resides in the house;
No child under 6 years old resides in the house;
No pregnant woman resides in the house;
No child-occupied facility exists on the property;
and,
The owner signs a written acknowledgement that
the Certified Firm is not required to use work
practices found in the Rule. ซ>EPA
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Certified Firms have the knowledge and training necessary to prevent lead contamination of the
home through the use of safe work practices in the home where lead will be disturbed. EPA strongly
encourages those homeowners who qualify to opt out of the work practice requirements to seriously
consider the use of Certified Firms when performing renovations that disturb known or presumed
lead-based paint.
Prior to the decision to opt out of the lead-safe work practices requirements, the homeowner must
receive the Renovate Right pamphlet as required under the Pre-Renovation Education Rule. Once
informed about the safety issues related to disturbing lead during renovation, the homeowner must
meet all four qualifications to be eligible to opt out of the work practice requirements in the Rule.
1. The owner must reside in the residence to be renovated; and,
2. There must not be children under 6 years of age residing in the home; and,
3. There must not be a pregnant woman residing in the home; and,
4. No child-occupied facility is present on the property; and,
5. The homeowner must sign a statement that the Certified Firm is not required to follow the
work practices requirements found in the Rule.
HUD does not allow owners to opt out of lead-safe work practices in its
assisted housing. The HUD Lead Safe Housing Rule applies to every home
built prior to 1978 that receives Federal housing assistance where greater
than 2 square feet of interior lead-based paint, 20 square feet of exterior
lead-based paint or 10% of the total surface area on an interior or exterior
type of component with a small surface area that contains lead-based paint
will be disturbed during renovation, repair or painting.
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Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
The RRP Rule: Firm Certification
To become certified, firms must submit an
application and fee to EPA. Firms may begin to
apply for certification on October 22, 2009.
Certifications will be good for 5 years.
Certification allows the firm to perform
renovations in any non-authorized state or Indian
tribal area.
Mar 09
1-4
On or after October 22, 2009, firms may apply to EPA to become certified.
On or after April 22, 2010 no firm working in target housing or child-occupied facilities, where
lead-based paint will be affected by the work, may perform, offer or claim to perform
renovations without Firm Certification from EPA, an EPA-authorized agreement state, territory,
or Indian tribe.
One EPA renovation firm certification is all that is needed for a renovation firm to work in any
non-authorized state/territory/tribal area. Firm certification is not the same as the personal
certification attained by each renovator's successful completion of this course.
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Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
The RRP Rule:
Firm Responsibilities
Ensure overall compliance with the RRP Rule.
Ensure that all renovation personnel are Certified
Renovators or have been trained on-the-job by
Certified Renovators.
Assign a Certified Renovator to all jobs.
Meet Pre-Renovation Education Requirements.
Meet recordkeeping requirements.
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1-5
The Certified firm must ensure that everyone on the renovation, repair or painting job is
trained to perform lead-safe work practices during the work. EPA requires all persons on
the job to be trained. The person responsible for lead-safe work practices must be a
Certified Renovator. Other firm employees (non-certified renovation workers), working on
the job, must be trained on-the-job by Certified Renovators, or must be Certified
Renovators themselves. This could be accomplished by:
Having all employees trained as Certified Renovators; or,
Having at least one person trained as a Certified Renovator, who will then train the
rest of the employees in lead-safe work practices. Note that this training must be
performed by a Certified Renovator.
The Certified Firm must designate a Certified Renovator: to conduct setup activities; to
insure that the renovation is performed in accordance with work practice standards; to
verify work and cleanup activities using the cleaning verification procedure; and, to train
non-certified renovation personnel on-the-job in lead-safe work practices.
The Certified Firm must ensure that the renovation is performed in accordance with the
work practice requirements in the Rule.
The Certified Firm is responsible for complying with pre-renovation education
requirements.
The Certified Firm is also responsible for keeping all records including:
Pre-renovation education documentation (proof of receipt, proof of delivery, waivers,
etc.);
Documentation of lead-based paint;
Training and certification records; and,
Cleaning verification records.
Note: Recordkeeping is covered in detail in Module 6.
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Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
The RRP Rule:
Individual Certification
To become a Certified Renovator, an individual must either
take an EPA-approved 8-hour training course, or for those
with previous training an EPA-approved 4-hour training
course, from an EPA-accredited training provider.
The course completion certificate serves to certify
renovators (no application to EPA is required).
Refresher training is required every 5 years.
Workers do not need certification so long as on-the-job
training is received from a Certified Renovator and the
work is not HUD-regulated.
xvEPA
waass^s
Mar 09
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On or after April 22, 2010, all renovations must be directed by Certified Renovators. Individuals
may become Certified Renovators by completing either:
1) An EPA-approved 8-hour training course in lead-safe work practices taught by an EPA-
accredited training provider, or
2) An EPA-approved 4-hour lead-safe work practices refresher training course taught by an
EPA-accredited training provider, if they have successfully completed an EPA or HUD
renovation course, or an abatement worker or supervisor course accredited by EPA or by a
State or Tribal program authorized by EPA.
Successful completion of the appropriate course will result in a 5 year certification as a Certified
Renovator. To maintain certification, Certified Renovators must take an EPA-approved 4-hour
refresher course taught by an EPA-accredited training provider, before their certification
expires.
No application or fee is required to become a Certified Renovator. Instead, the course
completion certificate serves as the renovator certification. A "copy" of the initial and/or
refresher course completion certificate must be available on-site during the work.
States, territories and tribes may establish requirements for individual renovators working within
their jurisdictions. Be sure to determine if your state, territorial or tribal government has
additional regulations that may affect what you must do and where you may work.
HUD requires instructor-led training for all workers unless they are
supervised by a certified abatement supervisor (who, under the RRP
Rule, must also be a Certified Renovator).
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Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
The RRP Rule: Certified Renovator
Responsibilities
Perform work and direct lead-safe work practices.
Provide on-the-job training to non-certified workers.
Keep a copy of the initial and/or refresher training certificates
onsite.
Use EPA-recognized test kits to identify lead-based paint.
Be physically present while posting signs, containing work
areas, and cleaning work areas.
Be available by telephone when off-site.
Maintain the containment to keep dust and debris within the
work area.
Implement the cleaning verification procedure.
Prepare and maintain required records.
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Lead Safety for Renovation, Repair, and Painting Refresher
Pre-Renovation Education
Requirements
The RRP Rule updated the Pre-
Renovation Education Rule. This slide
summarizes the changes.
Renovation firms must provide the new Renovate
Right pamphlet (Appendix 3) to owners and
occupants of target housing before renovation starts.
In a child-occupied facility, Renovate Right must be
provided to the owner or an adult representative
before renovation.
For work in common areas of multifamily housing or
child-occupied facilities, firms must notify tenants or
parents/guardians of the children, or post
informational signs about the renovation or repair.
See the Compliance Guide (Appendix 4) for more
information.
Mar 09
1-8
Exclusions: The Pre-Renovation Education Rule covers the same renovation activities that are covered by the
Renovation, Repair, and Painting Rule. The same exclusions apply, except that the owner/occupant cannot opt
out of pamphlet delivery. (Refer to Module 2 for more information on exclusions.)
Work in Homes: No more than 60 days before beginning a renovation, Certified Renovation Firms must
distribute the Renovate Right pamphlet to the owners and residents of the pre-1978 housing to be renovated.
Firms must either obtain the owner's written acknowledgment or proof that the pamphlet was sent by certified
mail, return receipt requested, at least 7 days before the renovation began. For tenants, Certified Firms must
either obtain a written acknowledgment of receipt, or document that the firm delivered the pamphlet and was
unable to obtain a written acknowledgment. All proof of receipt/mailing/delivery records must be kept for 3 years
after completion of the renovation. Sample forms to document confirmation of receipt are included in the
Renovate Right pamphlet.
Work in Common Areas: No more than 60 days before beginning a renovation, Certified Renovation Firms
must provide the Renovate Right pamphlet to the owner of pre-1978 housing being renovated. Firms must
provide written notification to all residents in the affected units of the property being renovated, must notify
affected residents about where information is posted if work in nearby common areas will affect them. The
following information should be posted about work in common areas:
Describing the nature and location of the work;
Listing the work start and end dates; and,
Providing the Renovate Right pamphlet or information on how to obtain a free copy of the pamphlet. This
information may be provided to tenants by mail, hand-delivery, or by posting signs containing this
information where they are likely to be seen by the residents of all affected units.
Work in Child-Occupied Facilities: No more than 60 days before beginning a renovation, Certified Renovation
Firms must distribute the Renovate Right pamphlet to the owner of the building and to an adult representative of
the child-occupied facility, following the same documentation requirements as for homes. Firms must also
provide notification to parents and guardians of children using the child-occupied facility, following the same
requirements as for tenants affected by renovations in common areas.
To obtain copies of the Renovate Right pamphlet visit the EPA website at www.epa.gov/lead, or contact the
National Lead Information Center at 1-800-424-LEAD (5323). The pamphlet may be copied for distribution as
needed to comply with pre-renovation education requirements.
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Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
The RRP Rule:
Work Practice Standards
The Renovation, Repair, and Painting Final Rule
covers setup of the work area, prohibited work
practices, cleanup and the cleaning verification
procedures.
Setup practices, such as posting signs and containing
the work area, will be covered in Module 3.
Prohibited practices and dust control will be covered
in Module 4.
Cleanup practices and cleaning verification
procedures will be covered in Module 5.
Recordkeeping will be covered in Module
Mar 09
1-9
Beginning 4/22/2010, work practice standards found in the Renovation, Repair, and Painting
Rule are required during all renovations in target housing and child-occupied facilities if lead-
based paint is disturbed.
HUD has additional work practice requirements. See Slide 1-11.
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Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
The RRP Rule: Enforcement
EPA may suspend, revoke, or modify a
firm's certification if the Certified Firm or
Certified Renovator is found to be in non-
compliance.
Those firms found to be non-compliant
may be liable for civil penalties for each
violation.
Those firms who knowingly or willfully
violate this regulation may be subject to
additional fines per violation, or
imprisonment, or both.
vvEPA
Mar 09
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Enforcement:
EPA has the authority to seek civil fines for each violation and an additional criminal fine plus
jail time for knowing and willful violations of the Renovation, Repair, and Painting Rule
requirements.
EPA can also revoke certification for of a Certified Firm or a Certified Renovator who violates
Renovation, Repair, and Painting Rule requirements.
Note that violators may be both Certified Renovation Firms and non-certified contractors who
are not aware of or have ignored the requirement to become a Certified Renovation Firm.
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Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
HUD's Lead Safe Housing Rule
(LSHR)
Covers target t that is
Federally-owned or assisted.
Does not cover child-occupied facilities.
Key differences between the LSHR and
the RRP Rule are shown in text boxes
with the HUD logo.
See Appendix 2 for a complete
discussion of additional requirements
imposed by the LSHR on Certified
Renovators working in Federally-
assisted target housing.
Mar 09
1-11
Renovators must determine if a property is Federally-assisted by asking the owner or a designated
party. When conducting renovation activities in Federally-assisted target housing, renovators must
follow all requirements of the RRP Rule as well as LSHR. The major differences are as follows:
Training: EPA requires that Certified Renovators be responsible for renovation projects. Because of
this requirement, there are now two major training options for renovation work under the LSHR:
All renovation workers on the job are trained as Certified Renovators; or,
The designated Certified Renovator is also a Certified Lead Abatement Supervisor, and all
workers who are not certified renovators have on-the-job training in lead-safe work practices (see
Module 7).
Determination that Lead-Based Paint is present: EPA-recognized test kits may not be used to
test for lead-based paint (LBP); only a Certified Lead Inspector or Risk Assessor may determine
whether or not LBP is present.
Prohibited Practices: HUD prohibits the same practices as the EPA RRP Rule, plus three more:
Heat guns that char paint;
Dry scraping or sanding except within 1 ft. of electrical outlets; and,
Use of a volatile paint stripper in a poorly ventilated space.
De minimis levels: In Federally-assisted target housing, all areas of deteriorated paint in the work
area must be repaired. Work affecting less than "cte minimis" amounts of LBP is not required to
follow the lead safe work practices and clearance requirements in the LSHR. HUD's "cte minimis"
limits are smaller than the limits for minor repair and maintenance activities in the EPA's RRP
Rule.
Clearance Testing: HUD requires a clearance examination after renovation work above the cte
minimis level, in homes regulated by the LSHR. HUD requires a clearance examination by a party
independent of the renovator, and, therefore, does not allow acceptance of the Certified
Renovator's visual inspection or use of the cleaning verification procedure. When the HUD LSHR
applies to your work (see Appendix 2), a clearance examination must be performed by a certified
professional such as a Lead Inspector, Lead Risk Assessor, or Dust Sampling Technician. Some
state and local authorities have different clearance requirements and standards.
Occupant Notification: HUD requires notices to be distributed to occupants within 15 days after
lead hazard evaluation and control activities in their unit (or common areas, if applicable).
1-11
Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
State and Local Regulations
States and localities may have different
regulations than EPA and HUD for
renovations in target housing.
Check with your state and local housing and
environmental agencies to obtain
information about such requirements.
Appendix 7 is reserved for copies or
summaries of state and local regulations.
Mar 09
1-12
States, territories and tribes may seek authorization from EPA to operate their own
programs. Also, states, territories and tribes, whether authorized by EPA or not, can
establish additional requirements for firms working within their jurisdictions. Be sure to
determine if your state, territorial or tribal government has additional regulations that may
affect renovation in your community.
1-12
Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
Know the Rules!
To obtain a copy of the EPA or HUD regulations contact the
National Lead Information Center at 1-800-424-LEAD or
download them from the following websites:
www.epa.gov/lead
www.hud.gov/offices/lead
U.S. Occupational Safety and Health Administration
(OSHA):
Establishes worker protection standards.
For more information, on the OSHA Lead in
Construction Standard, see
www.osha.gov/Publications/osha3142.pdf.
State and local regulations:
Renovators must follow all applicable state and local
regulations during renovations.
Mar 09
1-13
EPA Renovation, Repair, and Painting Rule:
Individuals and firms performing renovation, repair, and painting in pre-1978 dwellings and child-
occupied facilities should understand the EPA Renovation, Repair, and Painting Final Rule. The
EPA Renovation, Repair, and Painting Final Rule can be found in Appendix 1.
HUD's Lead Safe Housing Rule:
Individuals performing renovation, remodeling, and rehabilitation in pre-1978 housing that is
Federally-assisted, need to understand the HUD Lead Safe Housing Rule. Appendix 2 contains
more information on the HUD Lead Safe Housing Rule.
U. S. Occupational Safety and Health Administration (OSHA):
OSHA has a Lead in Construction Standard which outlines worker protection requirements. Your
employer should be aware of these. For more information, on the OSHA Lead in Construction
Rule, see www.osha.gov/Publications/osha3142.pdf.
State and Local Regulations:
State and local regulations may also apply to the renovation work you do. Where applicable, these
requirements will be covered at this point in this module.
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Mar 09
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Module 2: Using EPA-Recognized
Test Kits
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Lead Safety for Renovation, Repair, and Painting Refresher
Module 2: Using EPA-Recognized
Test Kits
Overview
This module teaches you:
To determine if lead-based paint is present.
To use EPA-recognized test kits to check for
lead-based paint.
ซEPA
Mar 09
2-1
Module Overview
This module teaches how and when to use EPA-recognized test kits to determine if lead-
based paint affects renovation activities.
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Lead Safety for Renovation, Repair, and Painting Refresher
How to Determine if Lead-Based
Paint is Present
Paint testing must be performed prior to renovation on
all surfaces to be affected by the work, or you must
presume the paint is lead-based. Any testing must be
performed by the appropriate qualified professional.
Type of Paint Testing for
Renovations
EPA-recognized test kits
X-Ray Fluorescence instruments
(surface-by-surface)
Paint chip sampling and
laboratory testing
Who can do the testing?
Certified renovators
Certified lead-based paint
inspectors or risk assessors
Certified lead-based paint
inspectors or risk assessors
&EPA
Mar 09
Surface-by-Surface or Limited Testing: Lead-based paint can only be identified by testing paint. A
surface-by-surface evaluation of painted surfaces (a lead inspection) and all paint-chip sampling must be
conducted by a Certified Lead Inspector or Certified Lead Risk Assessor. Whether paint testing is
accomplished by an inspection or by limited testing, the results of testing only apply to the work if the
surfaces covered by the renovation are covered by the testing report. A property owner may provide a
report from a Certified Lead Inspector/Risk Assessor that proves no lead-based paint is present, in lieu of
testing affected surfaces. If no testing result is available, test the paint or presume lead-based paint is
present.
EPA-Recognized Test Kits: Check the EPA website at www.epa.gov/lead for information on EPA-recognized
test kits and how to use them. EPA is currently reviewing more sensitive test kits which may
come on the market. All test kits currently on the market are colorimetric tests for lead; that is, they change
color when lead is present. Different test kit chemicals produce different colors when lead is present. All
paint layers must be tested when using test kits. Make sure to follow the manufacturer's instructions when
using this testing method. If there is no color change on the paint film tested, lead-based paint is not
present and lead-safe work practices are not required on that surface. Test kit sampling is intrusive and
damages each surface tested. Common kit types include:
Rhodizonate-based test kits that produce a pink to red color when lead is present. This test cannot be used on
paint colors such as reds, oranges and pinks which make seeing any color change difficult. Rhodizonate test kits
should not be used to test paint on drywall and plaster surfaces; and,
Sulfide-based test kits that produce a dark grey to black color when lead is present. Dark colored paints, like dark
greens blues and, especially, black make seeing any color change difficult. Sulfide test kits should not be used to
test paint on metal surfaces.
X-Ray Fluorescence Testing: Requires a special instrument and a specially-trained Certified Lead
Inspector or Certified Lead Risk Assessor. The instrument tests by bombarding the paint film with gamma
radiation that causes the lead in the paint to emit x-rays that can be read by a sensor in the instrument.
The amount of lead in the paint is directly related to the x-rays read by the sensor. A computer program in
the instrument calculates how much lead is in the paint film. This testing method is non-intrusive and is the
most used.
Paint-Chip Collection for Laboratory Analysis: Paint-chip testing requires intrusive sampling. All paint
layers are removed from the surface being tested. The resulting sample is sent to an EPA-recognized
laboratory where it is analyzed to determine how much lead is present. Paint chips may only be collected
by Certified Lead Inspectors or Certified Lead Risk Assessors. Laboratory charges are based on
turnaround time, and it usually requires a day or two to get results. Intrusive sampling makes repair of
tested surfaces necessary.
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Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
Using EPA-Recognized Test Kits
to Check for Lead-Based Paint
EPA-recognized test kits:
Until 9/01/10, EPA will only require the use of test kits that verify the
absence of lead-based paint.
After 9/01/10, test kits must be able to determine whether or not lead-
based paint is present.
Provide a testing report of results from use of an EPA-recognized
test kit to the client as soon as possible, but no later than 30 days
after completing the renovation.
EPA-recognized spot test kits identify lead-based paint, which
has lead at or above the EPA standard. Paint may have lead even
when a test kit result is negative. EPA and HUD recommend
taking precautions whenever lead in paint, dust or soil is
&EPA : I
Mar 09
If test kits are used, you must use an EPA-recognized test kit.
Until September 1, 2010, EPA is only requiring the use of test kits that determine that lead-based
paint, above regulatory limits, is not present on the surfaces tested. If a color change does not
occur, lead-safe work practices are not required. If a color change occurs, the change does not
with certainty mean that lead-based paint is present. However, the surface must still be presumed
to be coated with lead-based paint unless paint chip or X-ray fluorescence testing shows it is not.
To be EPA-recognized after September 1, 2010, a test kit must be able to identify lead-based
paint. At that time, a test kit positive test result will mean that lead-based paint is present in the
coating and that lead-safe work practices must be followed when that surface is disturbed. A
negative test result will mean that lead safe-work practices are not required. These kits may be
available as early as September 2009.
Sampling may be performed by a Certified Lead Inspector or Risk Assessor to determine whether
or not lead-based paint is present.
If a test kit is used, it must be EPA-recognized. EPA-recognized test kits are listed on the EPA
website at www.epa.gov/lead/pubs/kits.htm.
What should be tested?
Each building component to be renovated or disturbed by renovation must be tested, unless the
component is a part of a larger component system and is representative of the whole system. In
this case, a single component may represent the larger system. For instance, a stair tread may
represent the whole stair system if the painting history of both is similar. If the painting histories are
similar and the tested tread shows a negative test for lead-based paint, then the RRP Rule does
not apply to the stair system.
Reporting
When EPA-recognized test kits are used, the Certified Firm must provide a report to the client
within 30 days after completion of the renovation. The date of testing, identification of and contact
information for the Certified Firm and Certified Renovator performing the testing, test kit
manufacturer's name and kit identification, locations of surfaces tested, descriptions of the
surfaces tested, and the results of testing must be included in the report to the owner.
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Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
Test Kit Hands-on
Purpose: The purpose of this hands-on exercise
is to teach Certified Renovators how to correctly
use EPA-recognized test kits to determine if
lead-based paint is present on components and
surfaces affected by renovation work.
&EPA
Mar 09
2-4
2-4
Mar 09
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Skill Set #1: Using EPA-Recognized Test Kits
Time: 15 minutes
Mar 09
Supplies needed:
EPA-recognized test kit(s) w/ manufacturer's instructions
Kit-specific supplies as required in the manufacturer's instructions
Disposable plastic drop cloth 2' by 2'
Tape (duct, painters, and masking)
Disposable, non-latex gloves
Disposable shoe covers
Manufacturer provided test verification card with lead-based paint layer
Disposable wet cleaning wipes
Heavy duty garbage bags
Painted wood surface with no lead-based paint layer
Test Kit Documentation Form
Participant Progress Log
Pen or pencil
Digital camera (Optional)
Numbered index cards (Optional)
HEPA vacuum with attachments (for cleanup after sampling)
Note to Instructor: It is strongly suggested that instructors prepare plastic bags containing all
materials needed for the hands-on exercises, prior to the exercise, in order to meet the time
limits allocated to Skill Set #1.
Purpose: The purpose of this hands-on exercise is to teach students how to correctly use EPA-
recognized test kits to determine if lead-based paint is present on components and surfaces
affected by renovation work.
Note to Instructor: Read the purpose of this activity to students and remind them to document
all areas where the paint color or substrate reactions may cause an incorrect result. These
surfaces should not be tested with a test kit, but should either be tested by Certified Inspectors
or Certified Risk Assessors, or must be assumed to contain lead-based paint.
Demonstration: The course instructor must show and explain all of the steps involved in the use
of EPA-recognized test kits. The demonstration should not take longer than 5 minutes including the
time needed to hand out materials.
Evaluating the Students: Allow students to practice the eight steps on the following page. Watch
each student follow the steps. Make corrections and suggestions as the exercise proceeds and
determine if additional practice is necessary. This should take no longer than 10 minutes. Students
must complete all required steps to be "Proficient". Evaluate the work of each student and once the
student can use a test kit correctly, the instructor should write the word "Proficient" in the field on
the Participant Progress Log that corresponds to Skills Set#1 and that particular student's name.
Skill Set #1: Using EPA-Recognized Test Kits
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Skill Set #1: Using EPA-Recognized Test Kits - Continued
Purpose: The purpose of this hands-on exercise is to teach Certified Renovators how to
correctly use EPA-recognized test kits to determine if lead-based paint is present on
components and surfaces affected by renovation work.
Skills Practice:
Step 1: Read the manufacturer's instructions
Step 2: Write required information and observations about the test location on the Test Kit
Documentation Form*
Step 3: (Optional) Secure a small disposable plastic drop cloth (2ft x 2 ft) on the floor beneath the
test location with masking tape.
Step 4: Put on disposable non-latex gloves and shoe covers.
Step 5: Follow the manufacturer's instructions for use of the test kit to conduct the test.* Perform
one test on the test card provided by the manufacturer, to observe a positive test result;
conduct one test of a painted wood surface with no lead-based paint layer, to observe a
negative test result*
Step 6: Use one wet cleaning wipe to remove residual chemicals left on the surface tested. Use a
second cleaning wipe to remove any visible debris or dust on the floor beneath the
sample collection area and place the used cleaning wipe in the trash bag.*
Step 7: Check documentation for completeness and note the result of the testing on the Test Kit
Documentation Form*
Step 8: (Optional) Number the test location in sequence on the Test Kit Documentation Form,
then select the corresponding numbered index card and tape it next to the test location
with masking tape and take a picture of the numbered test location to photo-document
conduct and possibly the result of the test.
indicates required skills that must be accomplished for a "Proficient" rating.
Interpreting the Results of Test Kit Sampling:
The manufacturer's instructions will indicate the targeted indicator color change for lead in paint.
Once the test is conducted, note the result and refer to the manufacturer's guidelines for
interpreting the result. All painted surfaces that show the manufacturer's listed color change for
lead in paint (a positive test result) must be treated as lead-based paint until additional testing
performed by a Certified Lead Inspector or Risk Assessor proves it is not.
Documenting Test Kit Results:
A report of the findings from use of the test kit must be provided to the person contracting the work
within 30 days following the completion of the renovation work. The completed Test Kit
Documentation Form should be kept by the Certified Firm for 3 years after the work is completed.
Skill Set #1: Using EPA-Recognized Test Kits
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Test Kit Documentation Form Page 1 of
Owner Information
Name of Owner/Occupant:
Address:
City: State: Zip code: Contact #:
Email:
Renovation Information
Fill out all of the following information that is available about the Renovation Site,
Certified Renovator.
Renovation Address:
City: State: Zip code:
Certified Firm Name:
Firm, and
Unit#
Address:
City: State: Zip code: Contact #:(
Email:
Certified Renovator Name: Date Certified:
}
1 1
Test Kit Information
Use the following blanks to identify the test kit or test kits used in testing components.
Test Kit #1
Manufacturer: Manufacture Date: / /
Model: Serial*:
Expiration Date:
Test Kit #2
Manufacturer: Manufacture Date: / /
Model: Serial #:.
Expiration Date:
Test Kit #3
Manufacturer: Manufacture Date:
Model: Serial*:
Expiration Date:
Skill Set #1: Using EPA-Re cognized Test Kits
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Test Kit Documentation Form Page of
Renovation Address: Unit#
City: State: Zip code:
Test Location # Test Kit Used: (Circle only one) Test Kit #1 Test Kit #2 Test Kit #3
Description of test location:
Result: Is lead present? (Circle only one) YES NO PRESUMED
Test Location # Test Kit Used: (Circle only one) Test Kit #1 Test Kit #2 Test Kit #3
Description of test location:
Result: Is lead present? (Circle only one) YES NO PRESUMED
Test Location # Test Kit Used: (Circle only one) Test Kit #1 Test Kit #2 Test Kit #3
Description of test location:
Result: Is lead present? (Circle only one) YES NO PRESUMED
Test Location # Test Kit Used: (Circle only one) Test Kit #1 Test Kit #2 Test Kit #3
Description of test location:
Result: Is lead present? (Circle only one) YES NO PRESUMED
Test Location # Test Kit Used: (Circle only one) Test Kit #1 Test Kit #2 Test Kit #3
Description of test location:
Result: Is lead present? (Circle only one) YES NO PRESUMED
Test Location # Test Kit Used: (Circle only one) Test Kit #1 Test Kit #2 Test Kit #3
Description of test location:
Result: Is lead present? (Circle only one) YES NO PRESUMED
Test Location # Test Kit Used: (Circle only one) Test Kit #1 Test Kit #2 Test Kit #3
Description of test location:
Result: Is lead present? (Circle only one) YES NO PRESUMED
Skill Set #1: Using EPA-Recognized Test Kits
4 of 4
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Module 3: Review of Setup Practices
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Lead Safety for Renovation, Repair, and Painting Refresher
Module 3: Review of Setup Practices
Overview
Containing dust for interior activities.
Containing dust for exterior activities.
Mar 09
3-1
Upon completion of this module you will be able to:
Establish containment systems that will keep dust inside of the work area to allow you to clean more
efficiently at the end of the day and at completion of the job;
Identify containment requirements for interior renovations; and,
Identify containment requirements for exterior renovations.
In general, there are many degrees of containment, ranging from simple plastic sheeting on the
floor surrounding a small work area to a fully enclosed space. Some types of containment are
more effective than other types.
For purposes of this training, "containment" is what is required under the RRP Rule to prevent dust
and debris from spreading beyond the work area to non-work areas.
Containment is required by the RRP Rule because it:
Reduces the risk to you and residents. Following the work area setup requirements of this module
will protect you, your co-workers and residents by confining lead-contained dust and debris to a
defined and demarcated area. Confining the lead is an important consideration in avoiding exposure.
Reducing the risk to you and co-workers is also dependent upon use of personal protective
equipment.
Facilitates efficient cleaning of the work area. The pre-work setup process is essential to keeping
lead-contaminated dust confined to the work area where it can be easily cleaned. Proper containment
of the work area helps to limit the area you need to clean after the job is complete. Knowing exactly
where to clean is an important factor in saving time (and money) spent on cleanup.
Containing the work area includes:
Removing objects and furniture from the work area, or covering them with plastic sheeting.
Covering floors (or the ground) with plastic sheeting a minimum of 6 feet beyond surfaces being
renovated, repaired or painted.
Closing, and using plastic sheeting to seal, all windows, doors and air ducts in the work area.
Covering doors used to enter the work area with plastic sheeting in a manner that allows workers to
pass through but contains dust and debris within the work area.
Exterior containment includes protecting the ground with disposable plastic sheeting a minimum of 10
feet in all directions from the area of lead disturbance and isolation of the work area a minimum of 20
feet in all directions from the area of lead disturbance.
Larger areas of disposable plastic sheeting may also be necessary to prevent the spread of dust.
Smaller areas of containment may be used if additional precautions such as plastic walls are used to
stop the spread of dust and minimize the area of cleanup.
3-1
Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
Keep Dust Within the Containment
Containment is required.
You are responsible for making sure dust
does not migrate out of containment.
Consider how much dust the renovation will
generate.
Plan the size and configuration of containment
to keep the generated dust within
containment.
.11:,
Mar 09
3-2
If you do not plan and contain the work area correctly, the dust and debris created by renovation
can spread beyond the minimum contained area required by the RRP Rule. This means that:
For interior locations, dust may migrate more than 6 feet from the surface being renovated; or,
For exterior locations dust may migrate more than 10 feet from the surface being renovated.
Controlling dust and debris may require more extensive containment than is specified in the rule if the
job is particularly dusty. Plan accordingly.
In general, renovations that involve only a small amount of paint disturbance create less dust than jobs
that involve larger areas of paint disturbance. However, in addition to the size of the area of paint
disturbed, the work practices (e.g., sanding) and equipment used will also affect how much dust is
created and how the dust migrates. The location of the work activity also has a bearing on the amount of
dust that is distributed. For example, small areas of ceiling work can spread dust over the entire room
and are very difficult to control.
Required containment is similar for all jobs, but jobs that generate more dust and debris may require
protection of larger areas. While the RRP and HUD Rules do not require vertical containment, such
systems may be helpful in limiting the size of the area affected by the work and may reduce the area that
must be cleaned at the end of the job. Pre-engineered containment systems (purchased and home-
made) are very helpful in cutting time spent on the job erecting containment and are easier to install than
hanging plastic sheeting with tape. These systems also allow the contractor to create a sealed area
within a room where the dust can be completely contained to a limited and controlled area.
Examples of dusty jobs include:
Hand scraping large areas.
Removing paint with a low temperature heat gun and scraper.
Removing dry residue and paint after using chemical strippers.
Demolishing painted surfaces.
Removing building components with painted surfaces that are in poor condition.
Remember, you are responsible for making sure that dust and debris remain inside of the
contained work area. When planning containment, keep in mind how, how much, and where the
work practices to be used will create dust, and plan accordingly.
3-2
Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
Overview of Interior Setup Steps
The goal of these interior setup practices
is to prevent dust and debris from
escaping the work area.
Limit access and post signs.
Remove or cover belongings
Cover floors.
Close windows, doors, and HVAC
system.
Work area entry.
CAUTION
RENOVATION WORK
DO NOT ENTER WORK AREA
UNLESS AUTHORIZED
NO SMOKING, EATING, OR
DRINKING
ซEPA
Mar 09
3-3
RRP Rule: Interior Containment General Requirements:
Posted signs: These must be posted on all sides of the work area to define the work
area, must be in the primary language of occupants, must be posted before the
beginning of the renovation, and must remain until cleaning verification (or clearance) is
achieved.
Contain the work area: Before renovation, isolate the work area to prevent the escape of
dust. During work, maintain the containment integrity and ensure that containment does
not interfere with occupant and worker egress from the home or work area.
Remove or cover furniture/objects: Remove (preferred) objects like furniture, rugs,
window coverings; or, cover them with plastic sheeting with all seams and edges taped.
Cover floors: Cover floors including carpets in the work area with taped down plastic
sheeting or other impermeable material to 6 feet beyond the perimeter of surfaces
undergoing renovation or to a distance sufficient to contain dust, whichever is greater.
Close and seal doorways and close windows: Close and seal doorways and close
windows in the work area with plastic sheeting or other impermeable material. Doors
used as entrances to the work area must be covered with plastic sheeting that allows
workers to pass through while confining dust to the work area.
Cover duct openings: Close and cover all HVAC vents in the work area with taped down
plastic sheeting or other impermeable materials (e.g., magnetic covers).
3-3
Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
Overview of Exterior Containment
Steps
Establish the work area.
Close all windows and doors.
Establish, as necessary, additional
containment to prevent spread of dust to
adjacent properties.
Mar 09
3-4
RRP Rule: Exterior Containment General Requirements:
Posted signs: Signs must be placed on all sides of the work area to define the area, must be
posted in the primary language of occupants, and must be posted before the beginning of
the renovation and remain until cleaning verification is achieved.
Close doors and windows: Close all doors and windows within 20 feet of the work area. For
multi-story buildings close all windows and doors on the same floor within 20 feet of the
work area and all windows on all floors below that are the same horizontal distance from the
renovation.
Doors used as entrances to the work area: Cover doorway openings with plastic sheeting
that allows workers to pass through while confining dust to the work area.
Cover the ground: Cover the ground with plastic sheeting or other impermeable material
extending 10 feet beyond the perimeter of surfaces undergoing renovation or to a sufficient
distance to contain dust, whichever is greater, unless the property line prevents 10 feet of
such ground cover.
Ensure that dust and debris do not contaminate or migrate to adjacent areas or properties:
In certain situations, the renovation will require extra precautions for containing the exterior
work area to ensure that dust and debris does not contaminate other properties. Examples
of these situations include high wind, over-spray issues, or short distances between
properties that require vertical containments to keep dust in the work area. The RRP Rule
establishes performance standards that the contractor must meet, but does not specify how
the contractor must meet them. This allows the contractor flexibility in how to comply with
the requirement to ensure that no dust or debris leaves the work area.
3-4
Mar 09
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Module 4: Review of Prohibited
Practices, Personal Protective
Equipment and Dust Control
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Lead Safety for Renovation, Repair, and Painting Refresher
Module 4: Review of Prohibited
Practices, Personal Protective
Equipment and Dust Control
Overview:
Prohibited practices.
Protect yourself
Control the spread of dust.
Mar 09
4-1
Requirements in the EPA RRP Rule:
The RRP Rule prohibits the use of certain practices. These prohibited practices are discussed
in this module. This module also contains recommendations regarding how to reduce dust
during work activities that are not specifically required or addressed in the RRP Rule. The
practices you choose to use in the contained work area must not include prohibited practices. Beyond
this you are free to use whatever practices get the job done, provided that all dust and debris you
generate stays in the work area and does not migrate to other areas or properties. The
recommendations in this section will assist you by reducing the amount of dust released during work.
Dust reduction in the work area will make the workplace safer for employees, and will make cleaning
easier.
Upon completion of this module, you will know:
What work practices are prohibited under the RRP Rule because they create dangerous amounts
of dust and paint chips;
What practices to use to control dust, debris or paint chips; and,
What personal protection you need to work safely.
4-1
Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
Prohibited Practices
Open-flame burning or
torching.
Heat gun above 1100ฐ F.
Power sanding, power
grinding, power planing,
needle guns, abrasive
blasting and
sandblasting, without
HEPA vacuum
attachment.
Mar 09
4-2
The EPA Renovation. Repair, and Painting Rule lists three Prohibited
Practices that must not be used on the job.
1. Open-flame burning or torching.
2. Heat gun above 1,100ฐ F (degrees Fahrenheit).
3. The use of machines that remove lead-based paint through high-speed operation such as
sanding, grinding, planing, needle gun, abrasive blasting, or sandblasting is prohibited unless
such machines are used with attached HEPA-filtered local capture ventilation.
A key to minimizing the spread of dust and paint chips is not to 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 1,100ฐ F create very
fine leaded dust particulates ("fume") that are dangerous for workers to breathe. The small
leaded dust particles created by burning and heating also settle on surrounding surfaces and
are very hard to clean up.
Power sanding, power grinding, power planing, needle guns, abrasive blasting, and
sandblasting create a large amount of dust that floats in the air and then settles on surfaces
inside and outside of the work area. These activities are prohibited unless equipped with
attached HEPA-filtered local capture ventilation devices to control the dust-laden exhaust.
See Appendix 5 Steps to LEAD SAFE Renovation, Repair and Painting for more information.
The practices listed on the slide are also prohibited in pre-1978 properties
with lead-based paint that receive Federal housing assistance. The HUD
Rule also prohibits extensive dry scraping and sanding by hand, and paint
stripping in a poorly ventilated space using a volatile paint stripper. States,
localities, or tribes may also prohibit these practices.
4-2
Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
Dust Reducing Techniques
Wet scraping and sanding
Heat gun below 1,100 degrees F
Use of power tools with attachment to HEPA
vacuum
Chemical stripping
oEPA
Mar 09
4-3
Wet Methods:
Wet methods are a major part of dust reducing practices under the HUD Lead Safe Housing
Rule. While they are neither prohibited nor required under the EPA RRP rule, they are a very
good work practice and should be considered as a good way to control dust in the work area.
They can also help meet requirements of the OSHA lead in construction standard (29 CFR
1926.62). OSHA also requires the use of ground fault circuit interruption (GFCI) protection on
circuits in wet areas to prevent electric shock.
Also keep in mind:
Chemical strippers can be dangerous. Some can cause burns. Methylene chloride is suspected
to cause cancer. The spectrum of chemical strippers ranges from citrus-based (safer) to more
dangerous caustic strippers. Follow the manufacturer's directions when using any chemical
stripper. OSHA requires hazardous materials communications.
If building components to be stripped can be removed, such as doors, consider having them
stripped off-site at a paint stripping facility.
Negative pressure respirators do not provide sufficient breathing protection when using
methylene chloride strippers. The OSHA standard for methylene chloride is 29 CFR 1910.1052.
4-3
Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
Specialized Tools
Large jobs may require special
considerations to get the job done,
like:
Power sanders, grinders and planers,
needle guns, and abrasive and sand
blasters, each with required HEPA-filtered
capture attachments.
Pneumatic and battery powered tools to
protect against shock hazards.
Specialized planning and containment.
Mar 09
4-4
Only power tools equipped with attached HEPA-filtered local capture
ventilation may be used when lead-based paint is present or presumed to be
present.
Electric power tools such as sanders, grinders, circular saws, reciprocating saws, planers and
drills produce dust and debris. Because they are electric, wet methods are not safe. Pneumatic
and battery powered tools prevent shock hazards. Attached HEPA-filtered tools or the use of
vacuum attached shrouds on these tools contain the dangerous leaded dust and paint chips that
are generated by their use.
Tools with attached HEPA-filtered capture ventilation collect and filter dust and debris as it is
created. A shroud at the head of the tool helps to contain the dust and paint chips as the vacuum
draws away dust and debris for safe storage in the vacuum canister. This makes the job cleaner
and safer.
Abrasive blasting is very effective at removing large areas of paint quickly, but these practices
require special HEPA filtration equipment that contains the blast medium, dust and paint chips
without releasing dust into the air or into the containment.
Containment is even more important when using specialized tools.
Proper containment and cleaning are crucial even when using HEPA-filtered specialized tools.
These tools generate a lot of dust inside a localized negative pressure (vacuum) environment. If
the vacuum fails or if the vacuum seal created by the shroud is broken, large volumes of dust can
be released. Nonetheless, HEPA-filtered specialized tools can reduce dust levels when used
properly, and can aid work production by shortening the cleaning time and lowering cost.
See the Shopping List of tools and supplies found in Appendix 5 Steps to LEAD SAFE
Renovation, Repair and Painting for more information.
4-4
Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
Protect Yourself
Workers should wear:
Disposable painter's hat.
Disposable coveralls.
Repair tears with duct tape.
Dispose of in plastic bag.
Disposable N-100, R-100 or P-100 respirator.
Wash face and hands frequently and at
the end of each shift.
Washing helps to reduce hand-to-mouth
ingestion of leaded dust.
OSHA may require more protection
depending on what work is done.
xvEPA
Mar 09
4-5
Workers should protect themselves.
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, and should be disposed of at the end of each day or at the end of
the job.
Disposable coveralls are a good way to keep dust off workers' street clothes and reduce the
chance of carrying dust away as they come and go. The coveralls can be removed when workers
leave the work site and stored in a plastic bag overnight. Remember to use a HEPA vacuum to
remove dust and debris from coveralls or other outerwear (a "dry decon") before exiting the work
area. To keep costs down, consider buying extra large coveralls in bulk and sizing down to fit
workers using duct tape. Some coveralls have a hood to keep dust out of hair.
Respiratory protection. Employers should consider that workers should wear respiratory
protection, such as a disposable N-100, R-100 or P-100 respirator, to prevent them from inhaling
leaded dust. These respirators are particulate-filtering respirators and would not be appropriate as
protection from chemical stripping compounds. OSHA provides additional information on
respirators in 29 CFR 1910.134. To further protect workers, wet sanding and scraping will reduce
airborne dust.
You must wash your hands and face at the end of each shift. Workers should wash their
hands and faces periodically to avoid ingesting leaded dust. It is required that you wash well before
eating, drinking or smoking. It is forbidden for anyone to eat, drink, or smoke in the work area.
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
shouldn't take leaded dust home to their families.
Personal protection is especially important on high dust generating jobs when lead-based paint or
lead-contaminated dust is disturbed, and while cleaning is being performed. However, the same
level of protection is not necessary during the planning, testing or setup phases of the work when
lead is not being disturbed.
The protective equipment listed above is meant to show what is needed during activities that
disturb lead-based paint and lead-contaminated dust. Depending upon work practices used, OSHA
rules may require employers to take further steps to protect the health of workers on the job.
OSHA provides additional information on working with lead in their Safety and Health Regulations
for Lead in the Construction Industry (29 CFR 1926.62).
4-5
Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
Control the Spread of Dust
When you leave the work site, clean yourself and your tools.
Remove shoe coverings and HEPA vacuum or wipe shoes.
Walk on disposable tack pads to remove dust from your soles.
HEPA vacuum and remove coveralls, and HEPA vacuum your
clothes.
Remove gloves if used, and carefully wash your hands and face.
Dispose of all used disposable clothing in plastic bags.
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, etc.
Change your clothes, and dispose of or place dusty work cloths
in a plastic bag to wash separately from household laundry.
Don't hug your family until you get clean!
Wash your hands and face.
Shower as soon as you get home.
Mar 09
4-6
Precautions to take when leaving the work site
When you leave the work site (the area covered by protective sheeting or the work
room), take precautions to prevent spreading dust and paint chips on your clothes and
shoes to other parts of the residence.
Every time you leave the plastic sheeting around the surfaces being renovated, remove
the disposable shoe covers and wipe or vacuum your shoes before you step off the
plastic sheeting. A large disposable tack pad on the floor can help to clean the soles of
your shoes.
Every time you leave containment, HEPA vacuum and remove your disposable coveralls
and disposable shoe covers. Clean/vacuum your shoes, and wash your hands and face.
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.
If you cannot clean yourself at the work site get a piece of plastic to protect the
floor and seat of your car from lead contamination.
As soon as you arrive home, take a shower and be sure to thoroughly wash your
hair, especially before playing with children. Wash your work clothes separately
from regular household laundry to stop lead from getting on your other clothes.
Be clean before you come in contact with family members, especially children.
Remember the video about the contractor who lead-poisoned his own kids.
HUD requires wet scraping and wet sanding to stabilize defective paint
surfaces, except within 1 ft. of electrical outlets, or for very small projects
(under 2 sq. ft. in a room or 20 sq. ft. on exterior surfaces).
4-6
Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
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).
Mar 09
4-7
Clean the work site frequently.
Cleaning the work site frequently as the job progresses will reduce the spread of dust and paint
chips. Daily cleaning need not be as thorough as the final cleaning. It should, however, keep debris,
dust and paint chips from piling up and spreading beyond the immediate work site.
Daily cleaning during the job includes:
Removing debris frequently. 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 helps minimize the spread of dust.
Collect paint chips as they are created. When removing paint, paint chips can 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. Periodically
HEPA vacuum 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 coming into contact with
leaded dust created by the work.
Safe Waste Disposal. All renovation waste from the work area must be contained prior to its
removal, storage, or disposal to prevent releases of dust and debris. Chutes for removing waste from
the work area must be covered. At the conclusion of each work day, collect waste and store it in
containment, in an enclosure, or behind a barrier that prevents the release of, and access to, dust
and debris. When transporting waste from the renovation work area it must be contained to prevent
the release of dust and debris.
How often should cleaning during the job take place?
The goal is to keep dust and debris under control, not to maintain a completely 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.
4-7
Mar 09
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Module 5: Cleaning Activities and
Checking Your Work
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Lead Safety for Renovation, Repair, and Painting Refresher
Module 5: Cleaning Activities and
Checking Your Work
Overview
Interior cleaning techniques.
Exterior cleaning techniques.
How to check your work.
Cleaning verification procedure.
Clearance testing.
Safe disposal practices.
Mar 09
5-1
What you will learn in this module:
This module will cover all the topics listed on the slide above.
The goal of cleaning is to leave the work area as clean as or cleaner than when you arrived so
that, as a result of your work, leaded dust is not left behind to poison the residents.
At the end of this module, you will know how to check your work to ensure the work area is
clean enough to pass the visual inspection and cleaning verification procedure, or pass a
clearance examination.
By using the techniques described in this module, you will be able to clean a work area quickly
and efficiently. Remember, approaching a cleanup is similar to approaching a job. Proper
preparation and planning will help make your cleaning efforts more effective and efficient.
Always schedule time at the end of each day to thoroughly clean the work area.
5-1
Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
Interior Cleaning
Requirements
-M
Collect all paint chips and debris, and seal in heavy duty plastic
bags.
Mist, remove, fold (dirty side in) and tape or seal protective
sheeting. Dispose of sheeting as waste.
Plastic sheeting between non-contaminated rooms and work areas
must remain in place until after cleaning and removal of other
sheeting.
HEPA vacuum or wet wipe walls from high to low, then HEPA
vacuum remaining surfaces and wipe with a damp cloth.
Clean 2 feet beyond the contained work area.
Use disposable wipes or change cloths frequently.
For carpet or rug, use HEPA vacuum with beater bar.
HEPA vacuum and wet mop uncarpeted floors.
Mar 09
5-2
Pick up
Always begin cleaning activities by picking up visible paint chips and debris with a wet disposable cloth
without dispersing any of it, and sealing this material in a heavy-duty bag.
When the job is complete, mist the sheeting, fold it (dirty side in), and either seal it with tape, or seal it
in a heavy-duty bag. Always fold dirty side inwards, and seal with tape or place in a heavy duty plastic
bag. If it is placed in a heavy-duty bag, "gooseneck-seal" the bag and dispose of the bag with the rest of
your waste. Dispose of all sheeting as waste by using the correct folding and disposal procedure, after
it has been vacuumed.
Clean with a Plan
Start cleaning at the far end of the work area and work back to the exit.
Clean walls with a HEPA vacuum or by wiping with a damp disposable cloth: Start with the tops of the
walls, tops of doors and door frames and work down to the floor.
Thoroughly vacuum all remaining surfaces and objects, including furniture and fixtures, in the work
area. The HEPA vacuum must be equipped with a beater bar when vacuuming carpeting or rugs.
Wipe all surfaces and objects that remained in the work area, except carpeted or upholstered surfaces,
with a damp cloth.
Clean the floor last
Clean with a wet mopping system or a two-sided bucket and mop.
Clean the entire work area and the area within 2 feet of the work area.
If using the two-bucket mopping system, repeat the process using a new mop head and clean water.
Remember, always keep one bucket for cleaning solution and the other bucket for wringing out the
cloth or mop head. You must keep wash and rinse water separate. Change the rinse water often.
Check your work
Before a Certified Renovator visually inspects the work area, check your work to determine whether
dust, debris or residue is still present. If dust, debris or residue is still present, these conditions must be
corrected before the visual inspection is performed.
5-2
Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
Visual Inspection Procedure
1. Conducted by Certified Renovator.
2. Put on disposable foot covers before entering the work area.
3. Make sure there is adequate lighting in the work area.
Turn on all of the lights or use a bright, white-light flashlight.
4. Systematically look for dust and debris on every horizontal
surface in the work area and 2 feet beyond.
Work from the farthest area from the entry to the entry.
Closely examine each surface.
5. If you find visible dust or debris, then re-clean the work area and
repeat step 4.
6. Once you have carefully looked at all of the surfaces and found
no dust or debris, proceed to the cleaning verification procedure
or clearance.
&EPA
Mar 09
5-3
Visual inspection after cleaning is required by the RRP Rule.
A visual inspection must be conducted by a Certified Renovator once cleaning is complete,
and prior to the cleaning verification or clearance examination of the work area.
In a visual inspection, the Certified Renovator looks for visible paint chips, dust and debris.
Make sure that adequate lighting is provided during the cleaning and visual inspection of the
work area. You cannot see dust and small paint chips without adequate lighting.
Inspect the entire work area and the area 2 feet beyond the work area on all sides of the
containment.
Visual inspection of the work area alone will not verify that the work area has been cleaned
adequately - visual inspection is only the first step. In many instances, leaded dust is not
visible to the naked eye and will not be detected during a visual inspection.
Once the visual inspection has been completed and no visible dust and debris are present,
the work area must pass either the cleaning verification procedure or a clearance examination
in order for the project to be completed in compliance with the RRP Rule.
Whether the cleaning verification procedure or clearance examination is conducted will be
based on regulatory requirements or terms in the renovation contract.
5-3
Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
Cleaning Verification (CV)
Procedure
Wipe each window sill within the work area. Use a single wet
disposable cleaning cloth per window sill.
Wipe uncarpeted floors and all countertops with wet disposable
cleaning cloths. Wipe up to a maximum of 40 ft2 per cloth.
Compare each wipe to the CV card. If the cloth matches or is lighter
than the CV card, the surface has passed cleaning verification and
no further action is required.
If the cloth is darker than the CV card, re-clean and repeat the CV
process.
If the second wet cloth fails, wait 1 hour or until surfaces are dry,
and then wipe with an electrostatically-charged white disposable
cleaning cloth designed to be used for cleaning hard surfaces. This
completes the cleaning verification.
Mar 09
5-4
After visual inspection, one of two activities must be conducted. A Certified Renovator must perform
cleaning verification or other certified professionals must conduct a clearance examination. The steps for
the cleaning verification procedure are explained below.
Window Sills
Using a single, wet, disposable cleaning cloth, wipe the entire surface of each window sill in the work
area.
Wipe Countertops and Floors
Wipe the entire surface of each countertop and uncarpeted floor within the work area with wet
disposable cleaning cloths. Floors must be wiped using a wet cleaning system, including a long handle
device with a head to which a wet disposable cleaning cloth is attached. The cloth must remain damp
at all times while being used to wipe the floor.
If the surface of a countertop or floor within the work area is greater than 40 square feet, the surface
within the work area must be divided into roughly equal sections that are each less than 40 square feet.
Wipe each surface section separately using a new wet disposable cleaning cloth.
Interpret the Cleaning Verification Procedure.
Compare each wipe representing a specific surface section to the cleaning verification card. If the cloth
used to wipe each surface section within the work area matches or is lighter than the cleaning
verification card, that surface section has been adequately cleaned.
If the cloth is darker than the cleaning verification card, re-clean that surface section, then use a new
wet disposable cleaning cloth to wipe the surface section. If the cloth matches or is lighter than the
cleaning verification card, that surface section has been adequately cleaned.
If the second cloth does not match and is not lighter than the cleaning verification card, re-clean the
surface and wait for 1 hour or until the surface section has dried completely, whichever is longer. Then
wipe the surface section with an electrostatically charged white disposable cleaning cloth designed to
be used for cleaning hard surfaces. The cleaning verification procedure is now complete and the
surface is considered clean.
When cleaning verification has been completed for all of the surfaces in the work area (including
window sills), warning signs may be removed.
5-4
Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
Dust Clearance Examination
A dust clearance examination may be performed
instead of cleaning verification.
A clearance examination must be a conducted by a
Certified Lead Inspector. Risk Assessor, or Dust
Sampling Technician.
If clearance fails, the renovation firm must re-clean the
work area until dust clearance standards and any
state, territorial, tribal and local standards are met.
wEPA
Mar 09
5-5
Clearance Examination (Dust Clearance Testing) - Optional under the RRP Rule
Dust clearance testing may be performed to check the effectiveness of the cleaning efforts.
Clearance is an option under the EPA Renovation, Repair, and Painting Rule and is required
by the HUD Rule in many cases.
Dust clearance testing is performed to check the effectiveness of cleaning efforts.
In some cases, dust clearance testing may be required as part of "clearance" (a regulation-
defined process to ensure that a work area is not contaminated with leaded dust after work is
completed). Cleaning verification need not be performed if dust clearance testing is required
at the conclusion of a renovation. In such cases, dust clearance testing may only be
performed by a Certified Lead Inspector, Risk Assessor, or Dust Sampling Technician. The
Certified Renovation Firm is required to re-clean the work area until dust-lead levels in the
work area meet the clearance standards. Some state, local, and tribal laws may require a
clearance examination following renovation and remodeling work, to levels that differ from
the Federal clearance standards. The selection of a CV or a clearance examination will be
based on regulatory requirements or the renovation contract.
Clearance is required by HDD's Lead-Safe Housing Rule in many pre-1978
properties receiving Federal housing assistance. The clearance examination
may be scheduled by the agency administering the assistance. A clearance
examination is performed by a trained person independent of the renovation firm
performing the work. Ask your client or contact the agency administering the
assistance to the property to find out if a clearance examination is required at the
end of the job and to find out who will schedule it. Remember, if the property fails
clearance, the unit must be re-cleaned and another clearance examination
performed. Sometimes the cost of re-cleaning and the additional clearance
examination will be the responsibility of the contractor. Cleaning well the first time
will saves both time and money.
5-5
Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
Exterior Cleanup Requirements
Clean all surfaces in the work area until no visible
dust, debris, or residue remains.
Remove all dust and debris without dispersal, and
seal in heavy plastic bags.
Remove protective plastic sheeting and mist before
folding it dirty side inward.
Check your work.
Focus on areas such as window sills, bare soil, and
children's play areas.
Look for dust, debris and paint chips.
SEPA
Mar 09
5-6
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 cleanup can be similar to cleanup after interior jobs. Collect and dispose of
any dust and debris with the rest of your waste.
Remember
Lead contaminated soil can poison children.
Avoid dry raking and shoveling, and spreading dust. However, raking and shoveling the soil is
appropriate if it is misted first.
Protective sheeting
Collect all dust and debris on the sheeting and place in plastic bags.
Mist sheeting, fold dirty side inward, and dispose of as waste. This is especially important
since you will not be cleaning the ground afterward. Remember that you are responsible to
make sure you do not leave dust and debris behind.
The Certified Renovator should visually inspect the plastic after cleaning for dust and debris.
Remember the Certified Renovator is required to certify that the work area was cleaned
properly at the end of the job.
Protective sheeting is to be disposed of as waste.
Visual inspection
A thorough visual inspection of the work area should be conducted after any exterior job. Any
visible paint chips, wood chips and other debris from the work area should be collected and
disposed of with the rest of your waste.
Focus your visual inspection on areas such as exterior porches, outside play areas, bare soil
and ground, and window sills, but don't ignore or neglect other areas.
5-6
Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
Exterior - Check Effectiveness of
Cleaning
Visual inspection
A Certified Renovator conducts a visual inspection
after any cleaning.
Determines if any visible dust and debris are present
in and beyond the boundaries of the work area.
If visible dust or debris are found, collect and dispose
of all paint chips, dust, and debris identified during the
visual inspection.
After re-cleaning, the Certified Renovator conducts
another visual inspection.
When all areas pass, warning signs may be removed.
Mar 09
5-7
Checking your work
A thorough visual inspection is the main part of checking your cleanup after an exterior job. You
should collect and dispose of any paint chips, wood chips and debris found during the visual
inspection.
A visual inspection is conducted after completing cleanup, to check your work.
The Certified Renovator must perform the visual inspection to determine whether dust, debris or
residue is still present on surfaces in or below the work area, including window sills and on the
ground.
If dust or residue is present, clean again, and then repeat the visual inspection.
Warning signs may be removed after passing visual inspection.
Clearance on exterior jobs. For exterior jobs, HUD requires only a visual
assessment of the work area to pass clearance. No dust or soil testing is
required. If you follow procedures taught in this course you will satisfy HUD
requirements.
5-7
Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
Disposal
What should I do with waste generated on the job?
At the work site:
Place waste in heavy duty plastic bag.
"Gooseneck seal" the bag.
Carefully dispose of waste in accordance with
Federal and other regulations.
HEPA vacuum the exterior of the waste bag before
removing it from the work area.
Store waste in a secure area.
Always check local waste
requirements.
Mar 09
5-8
At the Work Site
Always collect, bag and seal all waste at the work site and in the work area. HEPA vacuum or
wipe the exterior of waste bags before removing them from the work area. Do not carry your waste
to another room or another area before bagging and sealing it. Store all waste in a secure
container ordumpster until disposal. Limit on-site storage time. Avoid transporting waste in an
open truck or in a personal vehicle. Some examples of waste include protective sheeting, HEPA
filters, paint chips, dust, dirty water, used cloths, used wipes, used mop heads, used protective
clothing, used respirators, used gloves, and architectural components. Architectural components
that are too big to fit into bags must be wrapped in plastic and sealed with tape prior to removal
from the work area. If needed, "double-bag" your waste to help prevent the waste from escaping if
the bag is cut or ripped.
Federal, State, and Local Waste Requirements
Because EPA considers most renovation and remodeling as "routine residential maintenance",
most waste generated during these activities is classified as solid, non-hazardous waste, and
should be taken to a licensed solid waste landfill (see Appendix 8 and
www.epa.gov/lead/pubs/fslbp.htm). This does not apply to commercial, public or other non-
residential child-occupied facilities.
Always check state and local requirements before disposing of waste. Some are more stringent
than Federal regulations.
Waste Water
Water used for cleanup should be filtered and dumped in a toilet if local rules allow. Never dump
this water down a sink or tub, down a storm drain or on the ground. Always dispose of waste water
in accordance with Federal, state and local regulations.
EPA's website has links to state information on solid and hazardous waste disposal at
http://www.epa.gov/epawaste/wyl/stateprograms.htm.
HUD recommends that when building components are recycled or sold,
painted building components should be stripped before re-installation. If
components are not stripped, they should never be reinstalled in housing.
5-8
Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
Exercise: Cleaning Verification
Procedure
Work in groups of 2-6.
Assignment:
Skill Set #2: Cleaning Verification Procedure
You have 20 minutes.
xvEPA
Mar 09
5-9
Exercise: Cleaning Verification Procedure
This exercise gives you a chance to learn the cleaning verification procedure in the RRP Rule.
The slide provides basic instruction. Stay in your groups of 2 to 6 students, in your work area.
5-9
Mar 09
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Skill Set #2: Cleaning Verification Procedure
Time: 20 minutes
Mar 09
Supplies needed:
Baby powder or corn starch
Cleaning verification card, one per student to take away and retain
Disposable foot covers
Disposable non-latex gloves
Disposable wet cleaning wipes
Electrostatically charged, white, disposable cleaning cloths designed for cleaning hard
surfaces
Flashlight
Long-handled mop designed for wet cleaning wipes
Tape measure
Watch or clock
Purpose: The purpose of this hands-on exercise is to show the students the proper steps for
conducting the cleaning verification procedure.
The course instructor should explain all of the steps involved in performing the cleaning
verification procedure.
Evaluating the Students: Watch each student conduct the cleaning verification procedure and
listen as they point out problems that must be fixed. Students must complete all required steps
to be "Proficient". Evaluate the work of each student and once the student has completed all
required elements of the exercise correctly, record the performance as "Proficient" in the field on
the Participant Progress Log that corresponds to Skills Set #11 and that particular student's
name.
Skill Set #2: Cleaning Verification Procedure
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Skill Set #2: Cleaning Verification Procedure - Continued
Skills Practice:
Step 1: As you enter the work area put on disposable foot covers so that you do not track
dust and debris into the work area.*
Step 2: Turn on all of the lights that are available in the work area. Make sure there is
adequate lighting.*
For window sills:
Step 3: While wearing gloves, wipe each windowsill in the work area with a clean, white,
damp cleaning wipe.*
Step 4: Compare the cleaning wipe to the cleaning verification card. If the first wipe is the
same as or whiter (lighter) than the cleaning verification card, the windowsill is clean;
continue to Step 6. If the first cleaning wipe is not the same as or whiter (lighter) than
the cleaning verification card, re-clean the window sill, and, repeat Step 3 and then
proceed to Step 5 (skip this step).*
Step 5: Compare the second cleaning wipe to the cleaning verification card. If the second
wipe is the same as or whiter (lighter) than the cleaning verification card, the
windowsill is clean; continue to Step 6. If the second cleaning wipe is not the same
as and not whiter (not lighter) than the cleaning verification card, wait one hour or
until the wet surface is dry (for the purposes of this exercise you do not wait). Then
re-clean the surface with a dry, electrostatically charged, white, disposable cleaning
cloth designed for use on hard surfaces. The windowsill is now clean and has
completed the cleaning verification procedure.*
For Floors and Countertops:
Step 6: While wearing gloves, wipe each floor or countertop in the work area with a clean,
white, damp cleaning wipe. For floors, use a long handled mop designed to hold a
wet cleaning wipe. For floors, wipe no more than 40 square feet per wipe. For
countertops wipe the whole surface of the countertop up to 40 square feet per wipe.*
Step 7: Compare each floor and countertop cleaning wipe to the cleaning verification card. If
the first wipe is the same as or whiter (lighter) than the cleaning verification card, the
floor or countertop is clean. If the first cleaning wipe is not the same as and not
whiter (not lighter) than the cleaning verification card, re-clean the floor section or
countertop section, wipe the floor or countertop section with a wet cleaning wipe, and
repeat Step 6 for that section and proceed to Step 8 (skip this step).*
Step 8: Compare the second floor or countertop cleaning wipe to the cleaning verification
card. If the second wipe is the same as or whiter (lighter) than the cleaning
verification card, the floor or countertop section has been adequately cleaned. If the
second cleaning wipe is not the same as and not whiter (not lighter) than the
cleaning verification card, wait one hour or until the wet surface is dry (for the
purposes of this exercise you do not wait). Then re-clean the surface with a dry,
electrostatically charged, white, disposable cleaning cloth designed for use on hard
surfaces. The floor or countertop section is now clean and has completed the
cleaning verification procedure.*
Skill Set #2: Cleaning Verification Procedure
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Step 9: Once the cleaning verification shows that all areas have been adequately
cleaned, remove the signs and critical barriers around the work area.*
Indicates required skills that must be accomplished for a "Proficient" rating
Skill Set #2: Cleaning Verification Procedure
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Module 6: Recordkeeping
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Lead Safety for Renovation, Repair, and Painting Refresher
Module 6: Recordkeeping
Overview:
In this section, you will learn about
records required for each job.
Records must be retained and made
available to EPA, upon request, for 3
years following completion of
renovation.
Language of the RRP Rule is:
"Firms performing renovations must retain and, if requested, make available to EPA,
all records necessary to demonstrate compliance...for a period of three years
following completion of the renovation."
HUD also has a three year record retention requirement for
notices, evaluations, and clearance or abatement reports
(24CFR35.175).
6-1
Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
On-The-Job Records
Copies of Certified Firm and Certified Renovator
certifications (must be kept on site).
Lead-based paint testing results when an EPA-
recognized test kit is used.
Proof of owner/occupant p re-re novation education,
including receipt of Renovate Right pamphlet.
Opt out certification by owner/occupant, when they
qualify to and decide to opt out of the lead-safe work
practice requirements.
Non-certified renovation worker training
documentation (must be kept on site).
The Certified Firm must designate (in writing) a Certified Renovator to be responsible for each
renovation job in target housing or a child-occupied facility. This is the logical person to organize
and maintain on-the-job records during the work. On the jobsite, the records should be kept in a safe,
secure, clean and dry place. Once the project is complete, some records can be filed with other firm
records while others may need to be moved to the next job site.
Records to be maintained on site include:
Copy of Certified Firm and Certified Renovator(s) certifications.
Non-certified worker training documentation.
Records to be maintained to document the job:
Copy of Certified Firm and Certified Renovator(s) certifications.
Non-certified worker training documentation.
Designation of a Certified Renovator to the job.
Information on and results of use of EPA-recognized test kits provided by a Certified Renovator
who acted as the representative of the Certified Firm at the job site and who conducted testing
for the presence of lead-based paint on surfaces to be affected by the renovation.
Lead-based paint inspection reports provided by a Certified Lead Inspector or Certified Lead
Risk Assessor, if applicable.
Proof of owner/occupant pre-renovation education, including receipt of the pamphlet Renovate
Right: Important Lead Hazard Information for Families, Child Care Providers and Schools.
Opt-out certification by owner-occupant, when they qualify to, and decide to, opt-out of lead safe
work practice requirements.
Any other signed and dated documents from the owner(s) and/or residents regarding conduct of
the renovation and requirements in the EPA RRP Rule.
All reports required from the Certified Firm and the Certified Renovator by the EPA RRP Rule.
6-2
Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
Non-Certified Renovator Training
Records
Name and Signature of the Certified Renovator.
Description of the lead safe work practices the
non-certified renovation worker is trained to
perform.
Completed and signed skills evaluation
checklists.
Date(s) of training.
Name and signature of the Certified Renovator
who conducted the training. A
&EPA
Documentation of Non-Certified Renovator Training
The Certified Renovator who conducted the non-certified renovator worker training must
document the information taught to, and skill set proficiencies achieved by, each individual
trainee. This training can be conducted in a classroom setting with simulated hands-on or on the
job. Documentation may vary for each trainee as not all trainees may be assigned to conduct all
lead-safe work practices and the training is only required to be task specific.
To simplify this documentation, your training manual includes a form that can be adapted for
documenting hands-on and topical training for non-certified renovation workers (See Appendix 6).
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Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
Post-Renovation Reporting
At the end of each renovation, the Certified Renovator
must sign a report including the following information:
Name of Certified Renovator assigned to lead the project;
Copy of Certified Renovator certification(s);
Certification from a Certified Renovator of non-certified
renovation worker training, and a list of the topics covered;
Certification of posting of warning signs;
Description of chemical spot testing, if any performed;
Certification by the Certified Renovator of work area
containment, on-site waste containment and transport, proper
post renovation work area cleaning, and of successful
cleaning verification.
Clearance report, if performed.
Post-Renovation Reporting
The end of renovation report should describe the whole project from posting signs to cleaning
verification or clearance. The report should name the Certified Renovator designated by the
Certified Firm as responsible for lead-safe work practices on that project. Also include proof
of certification for the designated Certified Renovator. The report also must have a signed
statement from the Certified Renovator that covers the following areas:
Proof of non-certified worker training;
Proof of posting warning signs;
Description of results from used of EPA-recognized chemical spot test kits;
Description of work area containment;
Description of on-site waste containment and transport;
Proof of proper post-renovation work area cleaning; and,
Proof of successful cleaning verification or (if performed) the clearance examination
report.
Records of inspections and/or risk assessments conducted by Certified Lead
Inspectors or Risk Assessors, if applicable.
6-4
Mar 09
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Future Sample Renovation Recordkeeping Checklist
(effective April 2010)
Name of Firm:
Dafe and Location of Renovation:.
Brief Description of Renovation:
Name of Assigned Renovator:
Name(s) of Trained Worker(s), if used:.
Name of Dust Sampling Technician,
Inspector, or Risk Assessor, if used:
Copies of renovator and dust sampling technician qualifications (training certificates, certifications) on file.
Certified renovator provided training to workers on (check all that apply):
Posting warning signs Setting up plastic containment barriers
Maintaining containment Avoiding spread of dust to adjacent areas
Waste handling Post-renovation cleaning
Test kits used by certified renovator to determine whether lead was present on components affected
by renovation (identify kits used and describe sampling locations and results):
- Warning signs posted at entrance to work area.
- Work area contained to prevent spread of dust and debris
All objects in the work area removed or covered (interiors)
HVAC ducts in the work area closed and covered (interiors)
Windows in the work area closed (interiors)
Windows in and within 20 feet of the work area closed (exteriors)
Doors in the work area closed and sealed (interiors)
Doors in and within 20 feet of the work area closed and sealed (exteriors)
Doors that must be used in the work area covered to allow passage but prevent spread of dust
Floors in the work area covered with taped-down plastic (interiors)
Ground covered by plastic extending 10 feet from work areaplastic anchored to building and
weighed down by heavy objects (exteriors)
If necessary, vertical containment installed to prevent migration of dust and debris to adjacent
property (exteriors)
-Waste contained on-site and while being transported off-site
- Work site properly cleaned after renovation
All chips and debris picked up, protective sheeting misted, folded dirty side inward, and taped for
removal
Work area surfaces and objects cleaned using HEPA vacuum and/or wet cloths or mops (interiors)
- Certified renovator performed post-renovation cleaning verification (describe results, including the
number of wet and dry cloths used):
If dust clearance testing was performed instead, attach a copy of report.
-1 certify under penalty of law that the above information is true and complete.
Name and title Date
29
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Module 7: Training Non-Certified
Renovators
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Lead Safety for Renovation, Repair, and Painting Refresher
Module 7: Training Non-Certified
Renovators
Certified Renovators are responsible for
teaching lead-safe work practices to non-
certified renovators.
Mar 09
7-1
The RRP Rule requires that you, the Certified Renovator, be responsible for instruction
of non-certified renovation workers.
7-1
Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
Teaching Lead Safe Work
Practices Means:
Training non-certified renovators to properly use
signs, dust barriers, dust minimizing work practices,
and dust cleanup practices during the course of
renovation, repair, and painting activities to prevent
and/or reduce potentially dangerous dust-lead
contamination in the home.
To effectively train non-certified renovators you need
to:
Know lead safety yourself.
Show non-certified renovators what you know.
Review "shopping lists" and have materials at hand.
oEPA
Mar 09
7-2
Remember all the skills you mastered during the Skill Set exercises? You will be
teaching non-certified renovators to master them.
All that follows are presented to aid you in conduct of the training.
The Steps to LEAD SAFE Renovation, Repair, and Painting contains a
"shopping list" for materials and supplies needed for setting up containment, clean
the work area, protect yourself during work, and verify that the work area is clean.
This "shopping list" or another similar list must be reviewed prior to on-the-job
training to make sure all of the materials needed for work are available. Failure to
gather all supplies and equipment will delay on-the-job training and related work.
7-2
Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
The Role of the Certified
Renovator
Certified Renovators:
Perform lead safe work as described in the RRP Rule
(Sections 40 CFR 745.85 (a) and (b)).
Train all non-certified renovators in lead safe
practices.
Provide onsite and regular direction for all non-
certified workers during setup and cleanup.
Are available by phone when not physically present at
the work site during work.
Maintain onsite proof of certification as a Certified
Renovator and training records for all non-certified
renovators.
Mar 09
7-3
What Are the Responsibilities of a Certified Renovator? Certified Renovators are responsible for
ensuring overall compliance with Renovation, Repair, and Painting Program requirements for lead-safe
work practices at renovations to which they are assigned.
A Certified Renovator:
1. Must use an EPA-recognized test kit, when requested by the party contracting for renovation
services, to determine whether components to be affected by the renovation contain lead-based
paint (EPA will announce which test kits are "recognized" prior to April 2010. See
www.epa.gov/lead).
2. Must provide lead-safe work practices training to non-certified workers so those workers can
perform assigned tasks safely. This training can be provided by the Certified Renovator on-the-job
or in the classroom, provided adequate hands-on practice is available. This training could also be
conducted by a third party although the instructor must be a Certified Renovator.
3. Must be physically present at the work site when warning signs are posted, while the work area
containment is being established, and while the work area cleaning is performed. (Note: Use the
terms Setup and Cleanup to describe this work).
4. Must monitor work being performed by non-certified individuals to ensure that lead-safe work
practices are being followed. This includes maintaining the integrity of the containment barriers and
ensuring that no dust or debris migrates from the work area.
5. Must be available, either on-site or by telephone, at all times during performance of the renovation.
6. Must perform project cleaning verification.
7. Must have copies of their initial course completion certificate and their most recent refresher course
completion certificate at the work site. Certification as a Certified Renovator lasts for 5 years. The
Certified Renovator must take a refresher course every 5 years in order to maintain certification.
8. Must prepare required work documentation.
EPA RRP Rule requirements are found at 40 CFR 745.85 (a) and (b).
7-3
Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
Role of Trained, Non-Certified
Renovators
Trained, non-certified renovators are persons, working
on renovation, repair and painting jobs who have had
on-the-job training or similar classroom training from
a Certified Renovator to perform tasks in conformance
to the EPA RRP Rule.
They must perform lead-safe work practices as
described in the RRP rule.
Protect the home by "setting up" the work area.
Protect themselves.
Perform renovation work safely.
Prohibited Practices must not be used.
Clean the work area.
Control dust and debris.
Mar 09
7-4
On-the-job training must be provided for each non-certified renovator and for each job to the extent
that each non-certified renovator is adequately trained for the tasks he or she will be performing. This
training may occur while the non-certified renovator is engaged in productive work, which provides
knowledge and skills essential to the full and adequate performance of the job. However, work
conducted during training must be in full compliance with the RRP Rule.
Trainees will benefit by seeing the "Steps" to lead safety found in Steps to LEAD SAFE Renovation,
Repair and Painting in Appendix 5 (this document is also referred to as the "Steps Guide"). It contains
a seven step primer on lead safety and can be used as a field text to hand out to non-certified
renovator in the field. In the "Steps Guide", steps 2 through 6 contain information specific to work
performed by non-certified personnel, while step 1 and step 7 contain information on testing painted
surfaces and cleaning verification which are Certified Renovator responsibilities. Step 7 also
discusses clearance examination which is performed only by Certified Lead Inspectors, Certified Lead
Risk Assessors, and Certified Dust Sampling Technicians.
The information in the "Steps Guide" can be covered in about 5 minutes per Step and then reinforced
by on-the-job practical exercises such as setting up barriers and signs, demonstrations of cleaning
procedures, etc. It is recommended that the material in the "Steps Guide" be covered in a toolbox (on-
site) meeting format with handouts on the specific information to be covered.
It is very important that non-certified renovators be allowed to participate in hands-on learning as work
progresses and that skill sets that are learned by each non-certified renovator are documented.
Documentation is required by the RRP Rule to assure that non-certified renovators are trained to
perform renovation activities to which they are assigned. Remember that the RRP Rule requires all
non-certified renovators on the job to be given skills training specific to the tasks that they will perform
on the job and that each non-certified renovator's training must be documented by topic area covered
in the on-the-job training that is performed. The required documentation will be discussed in more
detail later.
7-4
Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
Teaching Lead Safety During
Renovations - Use the Steps
Steps to LEAD SAFE Renovation,
Repair and Painting covers basic
lead safe practices and can be
used as a training guide outside of
the classroom in conjunction with
on-the-job demonstrations and
hands-on training.
It is strongly recommended that
you use this guide as a basis for
training. &EPA
Mar 09
Training for non-certified renovators can be delivered in one session covering all 7 Steps or the
information can be covered in a series of "toolbox" meetings over the course of several days. You
should spend about 5-10 minutes on the information contained in each "Step" and then conduct on-
the-job training to teach the skills needed to renovate lead safely.
If this training is offered in the classroom, Slides 8-5 through 8-12 could be used to teach the material
found in the Steps to LEAD SAFE Renovation, Repair, and Painting. This document is included as
Appendix 5 of your student manual. Use the Steps to LEAD SAFE Renovation, Repair, and
Painting as a student handout for training non-certified renovators. The handout should also include
write-ups of demonstrations and practical hands-on exercises, and a checklist of desired skills to
reinforce the "toolbox" talks or classroom training. During either "toolbox" talks or classroom
instruction, have non-certified renovators refer to the training handout while you teach the information.
Before You Train: Print copies of Steps to LEAD SAFE Renovation, Repair, and Painting and
give one copy to each non-certified renovator.
7-5
Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
Step 1: Determine If the Job
Involves Lead-Based Paint
Lead-based paint (LBP) is found many older homes:
1960-1978 homes - 1 in 4 have LBP.
1940-1960 homes - 7 in 10 have LBP.
Pre-1940 homes - 9 in 10 have LBP.
Renovation, repair or painting that disturbs lead-based paint can
create significant lead-based paint hazards in homes.
Just a little lead-based paint can poison kids and their parents,
poison pets, and cause problems for pregnant women and their
unborn children.
The Certified Renovator will determine if lead-based paint is
present on work surfaces.
If information about lead-based paint is not available for a pre-1978
homes or a child-occupied facility, assume that lead-based paint is
present and use lead-safe work practices.
Mar 09
7-6
During Training:
Review the information on this slide with the non-certified renovators as they follow along on pages
4 & 5 of the Steps to LEAD SAFE Renovation, Repair, and Painting.
Notes to the On-The-Job Instructor:
This information is included in the on-the-job training so non-certified renovators will understand
why they need to use lead-safe work practices. Non-certified renovators are not required to
determine whether lead-based paint is present, but they should understand that when it is
identified as present, generating dust can cause significant problems if not properly and safely
controlled.
More information:
Review pages 4 and 5 of the Steps to LEAD SAFE Renovation, Repair and Painting.
7-6
Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
Step 2: Set It Up Safely
Containment is used to keep dust IN the work
area and non-workers OUT!
Signs and barriers are used to limit access.
Inside versus outside jobs:
Review all procedures and differences in setup.
oEPA
Mar 09
7-7
What To Do
To keep the dust in, and people out, of your work area, you will need to take slightly different
steps for inside or outside jobs.
For Inside Jobs
Place signs, barrier tape, and/or cones to keep all non-workers, especially children, out
of the work area. Keep pets out of the work area for their safety and to prevent them
from tracking dust and debris throughout the home.
Remove furniture and belongings from the work area. If an item is too large or too heavy
to move, cover it with heavy plastic sheeting and tape the sheeting securely in place.
Use heavy plastic sheeting to cover floors in the work area 6 ft. or more our from the
surface being renovated. Close and seal doors, close windows.
Close and cover air vents in the work area. This will keep dust from getting into the
system and moving through the home.
For Outside Jobs
Keep non-workers away from the work area by marking it off with signs, tape and/or
cones. Have owners keep pets out of the work area.
Cover the ground and plants with heavy plastic sheeting to catch debris. The covering
should extend at least 10 feet out from the building. Secure the covering to the exterior.
Close windows and doors within 20 feet of the work area to keep dust and debris from
going into the home.
Move (if possible) or cover play areas and equipment within 20 feet of the work area.
7-7
Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
Step 3: Protect Yourself
Without the right personal protective equipment (PPE)
workers can swallow and inhale lead from the job, and
can carry lead on their skin and work clothes home to
their families.
Review the "shopping list."
Advise workers to:
Protect your eyes.
Keep clothes clean or use disposable clothing.
Wear a respirator. The appropriate respirator keeps
lead out of your lungs and stomach.
Wash-up each time you leave the work
area and especially at the end of the
day.
Mar 09
7-8
Protect your eyes
Always wear safety goggles or safety glasses when scraping, hammering, etc.
Wear protective clothing and consider wearing gloves
Protective clothing and shoe covers are very important in preventing "take home" lead and to
prevent you from tracking lead out of the work area. They can also help prevent contamination
of areas that have already been cleaned during final cleanup.
Keep clothes clean. At the end of the workday, vacuum off dust or change out of dusty
clothes. Do not use compressed air to blow dust off clothing. Wash dirty work clothes
separately from household laundry.
Wear a painter's hat to protect your head from dust and debris.
Gloves are not required by the RRP Rule, but they also help prevent ingestion exposures to
lead.
Wear respiratory protection
When work creates dust or paint chips, employers should consider respiratory protection, such
as a N-100 disposable respirator, to prevent workers from breathing leaded dust.
Wash up
Workers should wash their hands and faces each time they stop work. It is especially
important to wash up before eating and at the end of the day.
Note: OSHA rules may require employers to take further steps to protect the health of workers on
the job.
7-8
Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
Step 4: Control the Spread of
Dust
The goal is to control the spread of dust that
is created.
Review the "shopping list."
Use the right tools.
If possible, work wet.
Disposable plastic drop cloths control the
spread of dust and debris.
Avoid prohibited practices. **CDA
Mar 09
7-9
Control the spread of dust
Keep the work area closed off from the rest of the home.
Don't track dust and debris out of the work area.
Stay in the contained work area and on the contained paths.
Vacuum off suits when exiting the work area so the dust stays inside containment.
Remove disposable shoe covers and make sure your shoes are clean by using tack pads or damp
paper towels to wipe off your shoes each time you step off the protective sheeting.
Keep components in the work area until they are wrapped securely in heavy plastic sheeting or
bagged in heavy duty plastic bags. Once wrapped or bagged, HEPA vacuum the exterior and
remove them from the work area and store them in a safe area away from residents.
Launder non-disposable protective clothing separate from family laundry.
Do not use Prohibited Practices, including:
Open-flame burning or high heat removal of paint;
Power tools such as sanders without HEPA attachments; and,
The practices prohibited by EPA's RRP Rule are also prohibited in pre-1978
properties with lead-based paint that receive Federal housing assistance.
The HUD Rule also prohibits extensive dry scraping and sanding by hand, use of
heat guns that char paint and paint stripping in a poorly ventilated space using a
volatile paint stripper. States, localities, or tribes may also prohibit these
practices.
7-9
Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
Step 5: Leave the Work Area
Clean
The goal should be to leave the work area
completely free of dust and debris.
Review the "shopping list."
Discuss daily cleaning procedures.
Discuss end of job cleaning procedures.
oEPA
Mar 09
7-10
On a daily basis, pick up the work area (recommended)
Pick up as you go. Put trash in heavy-duty plastic bags.
Vacuum the work area with a HEPA vacuum several times during the day and for sure
at the end of the day. Use only HEPA vacuums. Do not use standard household or
shop vacuum cleaners.
Clean tools at the end of the day.
Wash your hands each time you leave the work area and especially well before you go
home.
Dispose of all disposable personal protective clothing daily.
When the job is complete, clean the work area (required)
Carefully remove plastic sheeting on the floor, fold it with the dirty side in, tape the
edges shut or seal it in a heavy duty plastic bag, and dispose of it. Keep plastic
sheeting in doorways and openings that separate the work area from non-work areas in
place until the work area is released as clean.
Make sure all paint chips, dust, trash and debris, including building components, are
removed from the area to be cleaned and disposed of properly.
HEPA vacuum or wet wipe all wall surfaces. HEPA vacuum all other surfaces in the
work area. Use a beater bar attachment on carpets.
Wet wipe all remaining surfaces in the work area and wet mop all uncarpeted floors
until dust and debris are removed.
Visually inspect your work. Look around the work area and pathways where debris was
carried, both inside and out. You should see no dust, paint chips or debris.
Re-clean the area thoroughly if you find dust or debris.
7-10
Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
Step 6: Control the Waste
Discuss the waste bagging procedure.
Demonstrate folding a small section of plastic
with the dirty side turned in.
Discuss temporary storage of waste.
Discuss how to deal with waste water
appropriately.
Discuss waste disposal rules that apply to the
specific job.
oEPA
Mar 09
7-11
Bag or wrap your waste at the work site and in the work area.
Collect and control all your waste. This includes dust, debris, paint chips, protective sheeting,
HEPA filters, dirty water, clothes, mop heads, wipes, protective clothing, respirators, gloves,
architectural components, and other waste. Use heavy plastic sheeting or bags to collect
waste. Gooseneck seal the bag with duct tape. Consider double bagging waste to prevent
tears. Large components should be wrapped in protective sheeting and sealed with tape. Bag
and seal all waste before removing it from the work area. HEPA vacuum the exterior of waste
bags and bundles before removing them from the work area. Store all waste in a secure
container ordumpster until disposal. Limit on-site storage time. Avoid transporting waste in
an open truck or a personal vehicle.
Dispose of waste water appropriately.
Water used in the work area to remove paint or to clean surfaces should be filtered. Never
dump this water down a sink or tub, in a storm drain, or on the ground. It may be dumped in a
toilet if local rules allow. If local regulations do not allow this, you may be required to contain
and test the water, and contact a waste disposal company to assist you with disposal. Check
with your local water treatment authority, and in Federal and state regulations for
more information.
Be aware of waste disposal rules.
EPA considers most renovation, repair and painting activities in residential housing to be
"routine residential maintenance." The waste generated by these activities is classified as
solid, non-hazardous waste and can be disposed of in an ordinary waste landfill (see
Appendix 8 and www.epa.gov/lead/pubs/fslbp.htm). Some states and localities have more
stringent waste disposal requirements that must be followed.
7-11
Mar 09
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Lead Safety for Renovation, Repair, and Painting Refresher
Step 7: Cleaning Verification or
Clearance Testing
Cleaning verification will be performed by a
Certified Renovator after most renovations.
A clearance examination may be requested in
place of cleaning verification by the owner.
A clearance examination is required in many
pre-1978 properties receiving Federal housing
assistance.
Discuss what happens when cleaning
verification and/or clearance is not passed.
Mar 09
7-12
When all the cleaning is complete, and before the space is reoccupied, a cleaning verification
procedure or clearance examination must be conducted to make sure leaded dust is not left behind.
If the HUD Rule applies, a clearance examination is required in place of the cleaning verification
procedure. Before conducting either cleaning verification or clearance examination, the Certified
Renovator performs a visual inspection of the work area. The HUD regulations also require a person
trained in visual inspection, who is independent of the renovation firm, to perform a visual inspection
as part of a clearance examination. If dust or debris are present in the work area, cleaning must be
repeated and the visual inspection repeated until the work area is free of visible dust and debris.
After the project passes visual inspection by the Certified Renovator (and, for HUD-regulated
projects, by the independent trained person), either the cleaning verification procedure or clearance
examination can proceed.
7-12
Mar 09
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-------
Appendix 1:
EPA's Renovation, Repair, and
Painting Program Final Rule
(40 CFR Part 745)
-------
Tuesday,
April 22, 2008
Part II
Environmental
Protection Agency
40 CFR Part 745
Lead; Renovation, Repair, and Painting
Program; Lead Hazard Information
Pamphlet; Notice of Availability; Final
Rule
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EPA will recognize those kits that meet
certain performance standards for
limited false positives and negatives.
EPA will also recognize only those kits
that have been properly validated by a
laboratory independent of the kit
manufacturer. For most kits, this will
mean participating in EPA's
Environmental Technology Verification
(ETV) program. With stakeholder input,
EPA is adapting a volunary consensus
standard, ASTM's "Standard Practice
for Evaluating the Performance
Characteristics of Qualitative Chemical
Spot Test Kits for Lead in Paint" (Ref.
28), for use as a testing protocol to
determine whether a particular kit has
met the performance standards
established in this final rule.
/. Environmental Justice
Executive Order 12898, entitled
Federal Actions to Address
Environmental Justice in Minority
Populations and Low-Income
Populations (59 FR 7629, February 16,
1994) establishes federal executive
policy on environmental justice. Its
main provision directs federal agencies,
to the greatest extent practicable and
permitted by law, to make
environmental justice part of their
mission by identifying and addressing,
as appropriate, disproportionately high
and adverse human health or
environmental effects of their programs,
policies, and activities on minority
populations and low-income
populations in the United States.
EPA has assessed the potential impact
of this rule on minority and low-income
populations. The results of this
assessment are presented in the
Economic Analysis, which is available
in the public docket for this rulemaking
(Ref. 24). As a result of this assessment,
the Agency has determined that this
final rule will not have
disproportionately high and adverse
human health or environmental effects
on minority or low-income populations
because it increases the level of
environmental protection for all affected
populations without having any
disproportionately high and adverse
human health or environmental effects
on any population, including any
minority or low-income population.
VI. Congressional Review Act
The Congressional Review? Act, 5
U.S.C. 801 et seq., as added by the Small
Business Regulatory Enforcement
Fairness Act of 1996, generally provides
that before a rule may take effect, the
agency promulgating the rule must
submit a rule report, which includes a
copy of the rule, to each House of the
Congress and to the Comptroller General
of the United States. EPA will submit a
report containing this rule and other
required information to the U.S. Senate,
the U.S. House of Representatives, and
the Comptroller General of the United
States prior to publication of the rule in
the Federal Register. A major rule
cannot take effect until 60 days after it
is published in the Federal Register.
This action is a "major rule" as defined
by 5 U.S.C. 804(2). This rule is effective
June 23, 2008.
List of Subjects in 40 CFR Part 745
Environmental protection, Child-
occupied facility, Housing renovation,
Lead, Lead-based paint, Renovation,
Reporting and recordkeeping
requirements.
Dated: March 31, 2008,
Steven L. Johnson,
Administrator.
Therefore, 40 CFR chapter I is
amended as follows:
PART 745[AMENDED]
1. The authority citation for part 745
continues to read as follows:
Authority: 15 U.S.C. 2605, 2607, 2681-2692
and 42 U.S.C. 4852d.
2. Section 745.80 is revised to read as
follows:
ง745.80 Purpose.
This subpart contains regulations
developed under sections 402 and 406
of the Toxic Substances Control Act (15
U.S.C. 2682 and 2686) and applies to all
renovations performed for
compensation in target housing and
child-occupied facilities. The purpose of
this subpart is to ensure the following:
(a) Owners and occupants of target
housing and child-occupied facilities
receive information on lead-based paint
hazards before these renovations begin;
and
(b) Individuals performing
renovations regulated in accordance
withง 745.82 are properly trained;
renovators and firms performing these
renovations are certified; and the work
practices in ง 745.85 are followed
during these renovations.
3. Section 745.81 is revised to read as
follows:
ง745.81 Effective dates.
(a) Training, certification and
accreditation requirements and work
practice standards. The training,
certification and accreditation
requirements and work practice
standards in this subpart are applicable
in any State or Indian Tribal area that
does not have a renovation program that
is authorized under subpart Q of this
part. The training, certification and
accreditation requirements and work
practice standards in this subpart will
become effective as follows:
(1) Training programs. Effective June
23, 2008, no training program may
provide, offer, or claim to provide
training or refresher training for EPA
certification as a renovator or a dust
sampling technician without
accreditation from EPA under ง 745.225.
Training programs may apply for
accreditation under ง 745.225 beginning
April 22, 2009.
(2) Firms, (i) Firms may apply for
certification under ง 745.89 beginning
October 22, 2009.
(ii) On or after April 22, 2010, no firm
may perform, offer, or claim to perform
renovations without certification from
EPA under ง 745.89 in target housing or
child-occupied facilities, unless the
renovation qualifies for one of the
exceptions identified in ง 745.82(a) or
(c).
(3) Individuals. On or after April 22,
2010, all renovations must be directed
by renovators certified in accordance
with ง 745.90(a) and performed by
certified renovators or individuals
trained in accordance with
ง 745.90(b)(2) in target housing or child-
occupied facilities, unless the
renovation qualifies for one of the
exceptions identified in ง 745.82(a) or
(c).
(4) Work practices. On or after April
22, 2010, all renovations must be
performed in accordance with the work
practice standards in ง 745.85 and the
associated recordkeeping requirements
in ง 745.86(b)(6) and (b)(7) in target
housing or child-occupied facilities,
unless the renovation qualifies for one
of the exceptions identified in
ง 745.82(a) or (c).
(5) The suspension and revocation
provisions in ง 745.91 are effectiveApril
22, 2010.
(b) Renovation-specific pamphlet.
Before December 22, 2008, renovators or
firms performing renovations in States
and Indian Tribal areas without an
authorized program may provide
owners and occupants with either of the
following EPA pamphlets: Protect Your
Family From Lead in Your Home or
Renovate Right: Important Lead Hazard
Information for Families, Child Care
Providers and Schools. After that date,
Renovate Right: Important Lead Hazard
Information for Families, Child Care
Providers and Schools must be used
exclusively.
(c) Pre-Renovation Education Rule.
With the exception of the requirement
to use the pamphlet entitled Renovate
Right: Important Lead Hazard
Information for Families, Child Care
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Providers and Schools, the provisions of
the Pre-Renovation Education Rule in
this subpart have been in effect since
lune 1999.
4. Section 745.82 is revised to read as
follows:
ง745.82 Applicability.
(a) This subpart applies to all
renovations performed for
compensation in target housing and
child-occupied facilities, except for the
following:
(1) Renovations in target housing or
child-occupied facilities in which a
written determination has been made by
an inspector or risk assessor (certified
pursuant to either Federal regulations at
ง 745.226 or a State or Tribal
certification program authorized
pursuant to ง 745.324) that the
components affected by the renovation
are free of paint or other surface
coatings that contain lead equal to or in
excess of 1.0 milligrams/per square
centimeter (mg/cm2) or 0.5% by weight,
where the firm performing the
renovation has obtained a copy of the
determination.
(2) Renovations in target housing or
child-occupied facilities in which a
certified renovator, using an EPA
recognized test kit as defined in ง 745.83
and following the kit manufacturer's
instructions, has tested each component
affected by the renovation and
determined that the components are free
of paint or other surface coatings that
contain lead equal to or in excess of 1.0
mg/cm2 or 0.5% by weight. If the
components make up an integrated
whole, such as the individual stair
treads and risers of a single staircase,
the renovator is required to test only one
of the individual components, unless
the individual components appear to
have been repainted or refinished
separately.
(b) The information distribution
requirements in ง 745.84 do not apply to
emergency renovations, which are
renovation activities that were not
planned but result from a sudden,
unexpected event (such as non-routine
failures of equipment) that, if not
immediately attended to, presents a
safety or public health hazard, or
threatens equipment and/or property
with significant damage. Interim
controls performed in response to an
elevated blood lead level in a resident
child are also emergency renovations.
Emergency renovations other than
interim controls are also exempt from
the warning sign, containment, waste
handling, training, and certification
requirements in งง 745.85, 745.89, and
745.90 to the extent necessary to
respond to the emergency. Emergency
renovations are not exempt from the
cleaning requirements of ง 745.85(a)(5),
which must be performed by certified
renovators or individuals trained in
accordance with ง 745.90(b)(2), the
cleaning verification requirements of
ง 745.85(b), which must be performed
by certified renovators, and the
recordkeeping requirements of
ง 745.86(b)(6) and (b)(7).
(c) The training requirements in
ง 745.90 and the work practice
standards for renovation activities in
ง 745.85 apply to all renovations
covered by this subpart, except for
renovations in target housing for which
the firm performing the renovation has
obtained a statement signed by the
owner that the renovation will occur in
the owner's residence, no child under
age 6 resides there, no pregnant woman
resides there, the housing is not a child-
occupied facility, and the owner
acknowledges that the renovation firm
will not be required to use the work
practices contained in EPA's renovation,
repair, and painting rule. For the
purposes of this section, a child resides
in the primary residence of his or her
custodial parents, legal guardians, and
foster parents. A child also resides in
the primary residence of an informal
caretaker if the child lives and sleeps
most of the time at the caretaker's
residence.
5. Section 745.83 is amended as
follows:
a. Remove the definitions of
"Emergency renovation operations" and
"Multi-family housing."
b. Revise the definitions of
"Pamphlet," "Renovation," and
"Renovator."
c. Add 13 definitions in alphabetical
order.
ง745.83 Definitions.
A A A A A
Child-occupied facility means a
building, or portion of a building,
constructed prior to 1978, visited
regularly by the same child, under 6
years of age, on at least two different
days within any week (Sunday through
Saturday period), provided that each
day's visit lasts at least 3 hours and the
combined weekly visits last at least 6
hours, and the combined annual visits
last at least 60 hours. Child-occupied
facilities may include, but are not
limited to, day care centers, preschools
and kindergarten classrooms. Child-
occupied facilities may be located in
target housing or in public or
commercial buildings. With respect to
common areas in public or commercial
buildings that contain child-occupied
facilities, the child-occupied facility
encompasses only those common areas
that are routinely used by children
under age 6, such as restrooms and
cafeterias. Common areas that children
under age 6 only pass through, such as
hallways, stairways, and garages are not
included. In addition, with respect to
exteriors of public or commercial
buildings that contain child-occupied
facilities, the child-occupied facility
encompasses only the exterior sides of
the building that are immediately
adjacent to the child-occupied facility or
the common areas routinely used by
children under age 6.
Cleaning verification card means a
card developed and distributed, or
otherwise approved, by EPA for the
purpose of determining, through
comparison of wet and dry disposable
cleaning cloths with the card, whether
post-renovation cleaning has been
properly completed.
Component or building component
means specific design or structural
elements or fixtures of a building or
residential 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
stringers, newel posts, railing caps,
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,
windowsills or stools and troughs,
casings, sashes and wells, and air
conditioners.
Dry disposable cleaning cloth means
a commercially available dry,
electrostatically charged, white
disposable cloth designed to be used for
cleaning hard surfaces such as
uncarpeted floors or counter tops.
Firm means a company, partnership,
corporation, sole proprietorship or
individual doing business, association,
or other business entity; a Federal, State,
Tribal, or local government agency; or a
nonprofit organization.
HEPA vacuum means a vacuum
cleaner which has been designed with a
high-efficiency particulate air (HEPA)
filter as the last filtration stage. A HEPA
filter is a filter that is capable of
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capturing particles of 0.3 microns with
99.97% efficiency. The vacuum cleaner
must be designed so that all the air
drawn into the machine is expelled
through the HEPA filter with none of
the air leaking past it.
Interim controls means a set of
measures designed to temporarily
reduce human exposure or likely
exposure to lead-based paint hazards,
including specialized cleaning, repairs,
maintenance, painting, temporary
containment, ongoing monitoring of
lead-based paint hazards or potential
hazards, and the establishment and
operation of management and resident
education programs.
Minor repair and maintenance
activities are activities, including minor
heating, ventilation or air conditioning
work, electrical work, and plumbing,
that disrupt 6 square feet or less of
painted surface per room for interior
activities or 20 square feet or less of
painted surface for exterior activities
where none of the work practices
prohibited or restricted by ง 745.85(a)(3)
are used and where the work does not
involve window replacement or
demolition of painted surface areas.
When removing painted components, or
portions of painted components, the
entire surface area removed is the
amount of painted surface disturbed.
lobs, other than emergency renovations,
performed in the same room within the
same 30 days must be considered the
same job for the purpose of determining
whether the job is a minor repair and
maintenance activity.
Pamphlet means the EPA pamphlet
titled Renovate Right: Important Lead
Hazard Information for Families, Child
Care Providers and Schools developed
under section 406(a) of TSCA for use in
complying with section 406(b) of TSCA,
or any State or Tribal pamphlet
approved by EPA pursuant to 40 CFR
745.326 that is developed for the same
purpose. This includes reproductions of
the pamphlet when copied in full and
without revision or deletion of material
from the pamphlet (except for the
addition or revision of State or local
sources of information). Before
December 22, 2008, the term
"pamphlet" also means any pamphlet
developed by EPA under section 406(a)
of TSCA or any State or Tribal pamphlet
approved by EPA pursuant to ง 745.326.
A A A A A
Recognized test kit means a
commercially available kit recognized
by EPA under ง 745.88 as being capable
of allowing a user to determine the
presence of lead at levels equal to or in
excess of 1.0 milligrams per square
centimeter, or more than 0.5% lead by
weight, in a paint chip, paint powder,
or painted surface.
Renovation means the modification of
any existing structure, or portion
thereof, that results in the disturbance of
painted surfaces, unless that activity is
performed as part of an abatement as
defined by this part (40 CFR 745.223).
The term renovation includes (but is not
limited to): The removal, modification
or repair of painted surfaces or painted
components (e.g., modification of
painted doors, surface restoration,
window repair, surface preparation
activity (such as sanding, scraping, or
other such activities that may generate
paint dust)); the removal of building
components (e.g., walls, ceilings,
plumbing, windows); weatherization
projects (e.g., cutting holes in painted
surfaces to install blown-in insulation or
to gain access to attics, planing
thresholds to install weather-stripping),
and interim controls that disturb
painted surfaces. A renovation
performed for the purpose of converting
a building, or part of a building, into
target housing or a child-occupied
facility is a renovation under this
subpart. The term renovation does not
include minor repair and maintenance
activities.
Renovator means an individual who
either performs or directs workers who
perform renovations. A certified
renovator is a renovator who has
successfully completed a renovator
course accredited by EPA or an EPA-
authorized State or Tribal program.
Training hour means at least 50
minutes of actual learning, including,
but not limited to, time devoted to
lecture, learning activities, small group
activities, demonstrations, evaluations,
and hands-on experience.
Wet disposable cleaning cloth means
a commercially available, pre-moistened
white disposable cloth designed to be
used for cleaning hard surfaces such as
uncarpeted floors or counter tops.
Wet mopping system means a device
with the following characteristics: A
long handle, a mop head designed to be
used with disposable absorbent cleaning
pads, a reservoir for cleaning solution,
and a built-in mechanism for
distributing or spraying the cleaning
solution onto a floor, or a method of
equivalent efficacy.
Work area means the area that the
certified renovator establishes to contain
the dust and debris generated by a
renovation.
ง745.84 [Removed]
6. Section 745.84 is removed.
ง 745.85 [Redesignated as ง 745.84]
7. Section 745.85 is redesignated as
ง 745.84.
8. Newly designated ง 745.84 is
amended as follows:
a. Revise the introductory text of
paragraph (a) and revise paragraph
b. Revise the introductory text of
paragraph (b) and revise paragraphs
(b)(2) and (b)(4).
c. Redesignate paragraph (c) as
paragraph (d).
d. Add a new paragraph (c).
e. Revise the introductory text of
newly designated paragraph (d).
ง745.84 Information distribution
requirements.
(a) Renovations in dwelling units. No
more than 60 days before beginning
renovation activities in any residential
dwelling unit of target housing, the firm
performing the renovation must:
A A A A A
(2) * * *
(i) Obtain, from the adult occupant, a
written acknowledgment that the
occupant has received the pamphlet; or
certify in writing that a pamphlet has
been delivered to the dwelling and that
the firm performing the renovation has
been unsuccessful in obtaining a written
acknowledgment from an adult
occupant. Such certification must
include the address of the unit
undergoing renovation, the date and
method of delivery of the pamphlet,
names of the persons delivering the
pamphlet, reason for lack of
acknowledgment (e.g., occupant refuses
to sign, no adult occupant available), the
signature of a representative of the firm
performing the renovation, and the date
of signature.
A A A A A
(b) Renovations in common areas. No
more than 60 days before beginning
renovation activities in common areas of
multi-unit target housing, the firm
performing the renovation must:
A A A A A
(2) Comply with one of the following.
(i) Notify in writing, or ensure written
notification of, each affected unit and
make the pamphlet available upon
request prior to the start of renovation.
Such notification shall be accomplished
by distributing written notice to each
affected unit. The notice shall describe
the general nature and locations of the
planned renovation activities; the
expected starting and ending dates; and
a statement of how the occupant can
obtain the pamphlet, at no charge, from
the firm performing the renovation, or
(ii) While the renovation is ongoing,
post informational signs describing the
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21761
general nature and locations of the
renovation and the anticipated
completion date. These signs must be
posted in areas where they are likely to
be seen by the occupants of all of the
affected units. The signs must be
accompanied by a posted copy of the
pamphlet or information on how
interested occupants can review a copy
of the pamphlet or obtain a copy from
the renovation firm at no cost to
occupants.
A A A A A
(4) If the scope, locations, or expected
starting and ending dates of the planned
renovation activities change after the
initial notification, and the firm
provided written initial notification to
each affected unit, the firm performing
the renovation must provide further
written notification to the owners and
occupants providing revised
information on the ongoing or planned
activities. This subsequent notification
must be provided before the firm
performing the renovation initiates work
beyond that which was described in the
original notice.
(c) Renovations in child-occupied
facilities. No more than 60 days before
beginning renovation activities in any
child-occupied facility, the firm
performing the renovation must:
(l)(i) Provide the owner of the
building with the pamphlet, and comply
with one of the following:
(A) Obtain, from the owner, a written
acknowledgment that the owner has
received the pamphlet.
(B) Obtain a certificate of mailing at
least 7 days prior to the renovation.
(ii) If the child-occupied facility is not
the owner of the building, provide an
adult representative of the child-
occupied facility with the pamphlet,
and comply with one of the following:
(A) Obtain, from the adult
representative, a written
acknowledgment that the adult
representative has received the
pamphlet; or certify in writing that a
pamphlet has been delivered to the
facility and that the firm performing the
renovation has been unsuccessful in
obtaining a written acknowledgment
from an adult representative. Such
certification must include the address of
the child-occupied facility undergoing
renovation, the date and method of
delivery of the pamphlet, names of the
persons delivering the pamphlet, reason
for lack of acknowledgment (e.g.,
representative refuses to sign), the
signature of a representative of the firm
performing the renovation, and the date
of signature.
(B) Obtain a certificate of mailing at
least 7 days prior to the renovation.
(2) Provide the parents and guardians
of children using the child-occupied
facility with the pamphlet and
information describing the general
nature and locations of the renovation
and the anticipated completion date by
complying with one of the following:
(i) Mail or hand-deliver the pamphlet
and the renovation information to each
parent or guardian of a child using the
child-occupied facility.
(ii) While the renovation is ongoing,
post informational signs describing the
general nature and locations of the
renovation and the anticipated
completion date. These signs must be
posted in areas where they can be seen
by the parents or guardians of the
children frequenting the child-occupied
facility. The signs must be accompanied
by a posted copy of the pamphlet or
information on how interested parents
or guardians can review a copy of the
pamphlet or obtain a copy from the
renovation firm at no cost to the parents
or guardians.
(3) The renovation firm must prepare,
sign, and date a statement describing the
steps performed to notify all parents and
guardians of the intended renovation
activities and to provide the pamphlet.
(d) Written acknowledgment. The
written acknowledgments required by
paragraphs (a)(l)(i), (a)(2)(i), (b)(l)(i),
(c)(l)(i)(A), and (c)(l)(ii)(A) of this
section must:
A A A A A
9. Section 745.85 is added to subpart
E to read as follows:
ง 745.85 Work practice standards.
(a) Standards for renovation activities.
Renovations must be performed by
certified firms using certified renovators
as directed in ง 745.89. The
responsibilities of certified firms are set
forth in ง 745.89(d) and the
responsibilities of certified renovators
are set forth in ง 745.90(b).
(1) Occupant protection. Firms must
post signs clearly defining the work area
and warning occupants and other
persons not involved in renovation
activities to remain outside of the work
area. To the extent practicable, these
signs must be in the primary language
of the occupants. These signs must be
posted before beginning the renovation
and must remain in place and readable
until the renovation and the post-
renovation cleaning verification have
been completed. If warning signs have
been posted in accordance with 24 CFR
35.1345(b)(2) or 29 CFR 1926.62(m),
additional signs are not required by this
section.
(2) Containing the work area. Before
beginning the renovation, the firm must
isolate the work area so that no dust or
debris leaves the work area while the
renovation is being performed. In
addition, the firm must maintain the
integrity of the containment by ensuring
that any plastic or other impermeable
materials are not torn or displaced, and
taking any other steps necessary to
ensure that no dust or debris leaves the
work area while the renovation is being
performed. The firm must also ensure
that containment is installed in such a
manner that it does not interfere with
occupant and worker egress in an
emergency.
(i) Interior renovations. The firm
must:
(A) Remove all objects from the work
area, including furniture, rugs, and
window coverings, or cover them with
plastic sheeting or other impermeable
material with all seams and edges taped
or otherwise sealed.
(B) Close and cover all ducts opening
in the work area with taped-down
plastic sheeting or other impermeable
material.
(C) Close windows and doors in the
work area. Doors must be covered with
plastic sheeting or other impermeable
material. Doors used as an entrance to
the work area must be covered with
plastic sheeting or other impermeable
material in a manner that allows
workers to pass through while confining
dust and debris to the work area.
(D) Cover the floor surface, including
installed carpet, with taped-down
plastic sheeting or other impermeable
material in the work area 6 feet beyond
the perimeter of surfaces undergoing
renovation or a sufficient distance to
contain the dust, whichever is greater.
(E) Use precautions to ensure that all
personnel, tools, and other items,
including the exteriors of containers of
waste, are free of dust and debris before
leaving the work area.
(ii) Exterior renovations. The firm
must:
(A) Close all doors and windows
within 20 feet of the renovation. On
multi-story buildings, close all doors
and windows within 20 feet of the
renovation on the same floor as the
renovation, and close all doors and
windows on all floors below that are the
same horizontal distance from the
renovation.
(B) Ensure that doors within the work
area that will be used while the job is
being performed are covered with
plastic sheeting or other impermeable
material in a manner that allows
workers to pass through while confining
dust and debris to the work area.
(C) Cover the ground with plastic
sheeting or other disposable
impermeable material extending 10 feet
beyond the perimeter of surfaces
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undergoing renovation or a sufficient
distance to collect falling paint debris,
whichever is greater, unless the
property line prevents 10 feet of such
ground covering.
(D) In certain situations, the
renovation firm must take extra
precautions in containing the work area
to ensure that dust and debris from the
renovation does not contaminate other
buildings or other areas of the property
or migrate to adjacent properties.
(3) Prohibited and restricted practices.
The work practices listed below shall be
prohibited or restricted during a
renovation as follows:
(i) Open-flame burning or torching of
lead-based paint is prohibited.
(ii) The use of machines that remove
lead-based paint through high speed
operation such as sanding, grinding,
power planing, needle gun, abrasive
blasting, or sandblasting, is prohibited
unless such machines are used with
HEPA exhaust control.
(iii) Operating a heat gun on lead-
based paint is permitted only at
temperatures below 1100 degrees
Fahrenheit.
(4) Waste from renovations(i) Waste
from renovation activities must be
contained to prevent releases of dust
and debris before the waste is removed
from the work area for storage or
disposal. If a chute is used to remove
waste from the work area, it must be
covered.
(ii) At the conclusion of each work
day and at the conclusion of the
renovation, waste that has been
collected from renovation activities
must be stored under containment, in an
enclosure, or behind a barrier that
prevents release of dust and debris out
of the work area and prevents access to
dust and debris.
(iii) When the firm transports waste
from renovation activities, the firm must
contain the waste to prevent release of
dust and debris.
(5) Cleaning the work area. After the
renovation has been completed, the firm
must clean the work area until no dust,
debris or residue remains.
(i) Interior and exterior renovations.
The firm must:
(A) Collect all paint chips and debris
and, without dispersing any of it, seal
this material in a heavy-duty bag.
(B) Remove the protective sheeting.
Mist the sheeting before folding it, fold
the dirty side inward, and either tape
shut to seal or seal in heavy-duty bags.
Sheeting used to isolate contaminated
rooms from non-contaminated rooms
must remain in place until after the
cleaning and removal of other sheeting.
Dispose of the sheeting as waste.
(ii) Additional cleaning for interior
renovations. The firm must clean all
objects and surfaces in the work area
and within 2 feet of the work area in the
following manner, cleaning from higher
to lower:
(A) Walls. Clean walls starting at the
ceiling and working down to the floor
by either vacuuming with a HEPA
vacuum or wiping with a damp cloth.
(B) Remaining surfaces. Thoroughly
vacuum all remaining surfaces and
objects in the work area, including
furniture and fixtures, with a HEPA
vacuum. The HEPA vacuum must be
equipped with a beater bar when
vacuuming carpets and rugs.
(C) Wipe all remaining surfaces and
objects in the work area, except for
carpeted or upholstered surfaces, with a
damp cloth. Mop uncarpeted floors
thoroughly, using a mopping method
that keeps the wash water separate from
the rinse water, such as the 2-bucket
mopping method, or using a wet
mopping system.
(b) Standards for post-renovation
cleaning verification(1) Interiors, (i) A
certified renovator must perform a
visual inspection to determine whether
dust, debris or residue is still present. If
dust, debris or residue is present, these
conditions must be removed by re-
cleaning and another visual inspection
must be performed.
(ii) After a successful visual
inspection, a certified renovator must:
(A) Verify that each windowsill in the
work area has been adequately cleaned,
using the following procedure.
(l) Wipe the windowsill with a wet
disposable cleaning cloth that is damp
to the touch. If the cloth matches or is
lighter than the cleaning verification
card, the windowsill has been
adequately cleaned.
(2) If the cloth does not match and is
darker than the cleaning verification
card, re-clean the windowsill as
directed in paragraphs (a)(5)(ii)(B) and
(a)(5)(ii)(C) of this section, then either
use a new cloth or fold the used cloth
in such a way that an unused surface is
exposed, and wipe the surface again. If
the cloth matches or is lighter than the
cleaning verification card, that
windowsill has been adequately
cleaned.
(3) If the cloth does not match and is
darker than the cleaning verification
card, wait for 1 hour or until the surface
has dried completely, whichever is
longer.
(4)After waiting for the windowsill to
dry, wipe the windowsill with a dry
disposable cleaning cloth. After this
wipe, the windowsill has been
adequately cleaned.
(B) Wipe uncarpeted floors and
countertops within the work area with
a wet disposable cleaning cloth. Floors
must be wiped using anapplication
device with a long handle and a head
to which the cloth is attached. The cloth
must remain damp at all times while it
is being used to wipe the surface for
post-renovation cleaning verification. If
the surface within the work area is
greater than 40 square feet, the surface
within the work area must be divided
into roughly equal sections that are each
less than 40 square feet. Wipe each such
section separately with a new wet
disposable cleaning cloth. If the cloth
used to wipe each section of the surface
within the work area matches the
cleaning verification card, the surface
has been adequately cleaned.
(1) If the cloth used to wipe a
particular surface section does not
match the cleaning verification card, re-
clean that section of the surface as
directed in paragraphs (a)(5)(ii)(B) and
(a)(5)(ii)(C) of this section, then use a
new wet disposable cleaning cloth to
wipe that section again. If the cloth
matches the cleaning verification card,
that section of the surface has been
adequately cleaned.
(2) If the cloth used to wipe a
particular surface section does not
match the cleaning verification card
after the surface has been re-cleaned,
wait for 1 hour or until the entire
surface within the work area has dried
completely, whichever is longer.
(3) After waiting for the entire surface
within the work area to dry, wipe each
section of the surface that has not yet
achieved post-renovation cleaning
verification with a dry disposable
cleaning cloth. After this wipe, that
section of the surface has been
adequately cleaned.
(iii) When the work area passes the
post-renovation cleaning verification,
remove the warning signs.
(2) Exteriors. A certified renovator
must perform a visual inspection to
determine whether dust, debris or
residue is still present on surfaces in
and below the work area, including
windowsills and the ground. If dust,
debris or residue is present, these
conditions must be eliminated and
another visual inspection must be
performed. When the area passes the
visual inspection, remove the warning
signs.
(c) Optional dust clearance testing.
Cleaning verification need not be
performed if the contract between the
renovation firm and the person
contracting for the renovation or another
Federal, State, Territorial, Tribal, or
local law or regulation requires:
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(1) The renovation firm to perform
dust clearance sampling at the
conclusion of a renovation covered by
this subpart.
(2) The dust clearance samples are
required to be collected by a certified
inspector, risk assessor or dust sampling
technician.
(3) The renovation firm is required to
re-clean the work area until the dust
clearance sample results are below the
clearance standards in ง 745.227(e)(8) or
any applicable State, Territorial, Tribal,
or local standard.
(d) Activities conducted after post-
renovation cleaning verification.
Activities that do not disturb paint, such
as applying paint to walls that have
already been prepared, are not regulated
by this subpart if they are conducted
after post-renovation cleaning
verification has been performed.
10. Section 745.86 is revised to read
as follows:
ง 745.86 Recordkeeping and reporting
requirements.
(a) Firms performing renovations
must retain and, if requested, make
available to EPA all records necessary to
demonstrate compliance with this
subpart for a period of 3 years following
completion of the renovation. This 3-
year retention requirement does not
supersede longer obligations required by
other provisions for retaining the same
documentation, including any
applicable State or Tribal laws or
regulations.
(b) Records that must be retained
pursuant to paragraph (a) of this section
shall include (where applicable):
(1) Reports certifying that a
determination had been made by an
inspector (certified pursuant to either
Federal regulations at ง 745.226 or an
EPA-authorized State or Tribal
certification program) that lead-based
paint is not present on the components
affected by the renovation, as described
inง745.82(b)(l).
(2) Signed and dated
acknowledgments of receipt as
described inง 745.84(a)(l)(i), (a)(2)(i),
(b)(l)(i), (c)(l)(i)(A), and (c)(l)(ii)(A).
(3) Certifications of attempted
delivery as described in ง 745.84(a)(2)(i)
and (c)(l)(ii)(A).
(4) Certificates of mailing as described
in ง 745.84(a)(l)(ii), (a)(2)(ii), (b)(l)(ii),
(c)(l)(i)(B), and (c)(l)(ii)(B).
(5) Records of notification activities
performed regarding common area
renovations, as described in
ง 745.84(b)(3) and (b)(4), and
renovations in child-occupied facilities,
as described in ง 745.84(c)(2).
(6) Any signed and dated statements
received from owner-occupants
documenting that the requirements of
ง 745.85 do not apply. These statements
must include a declaration that the
renovation will occur in the owner's
residence, a declaration that no children
under age 6 reside there, a declaration
that no pregnant woman resides there,
a declaration that the housing is not a
child-occupied facility, the address of
the unit undergoing renovation, the
owner's name, an acknowledgment by
the owner that the work practices to be
used during the renovation will not
necessarily include all of the lead-safe
work practices contained in EPA's
renovation, repair, and painting rule,
the signature of the owner, and the date
of signature. These statements must be
written in the same language as the text
of the renovation contract, if any.
(7) Documentation of compliance
with the requirements of ง 745.85,
including documentation that a certified
renovator was assigned to the project,
that the certified renovator provided on-
the-job training for workers used on the
project, that the certified renovator
performed or directed workers who
performed all of the tasks described in
ง 745.85(a), and that the certified
renovator performed the post-renovation
cleaning verification described in
ง 745.85(b). If the renovation firm was
unable to comply with all of the
requirements of this rule due to an
emergency as defined in ง 745.82, the
firm must document the nature of the
emergency and the provisions of the
rule that were not followed. This
documentation must include a copy of
the certified renovator's training
certificate, and a certification by the
certified renovator assigned to the
project that:
(i) Training was provided to workers
(topics must be identified for each
worker).
(ii) Warning signs were posted at the
entrances to the work area.
(iii) If test kits were used, that the
specified brand of kits was used at the
specified locations and that the results
were as specified.
(iv) The work area was contained by:
(A) Removing or covering all objects
in the work area (interiors).
(B) Closing and covering all HVAC
ducts in the work area (interiors).
(C) Closing all windows in the work
area (interiors) or closing all windows in
and within 20 feet of the work area
(exteriors).
(D) Closing and sealing all doors in
the work area (interiors) or closing and
sealing all doors in and within 20 feet
of the work area (exteriors).
(E) Covering doors in the work area
that were being used to allow passage
but prevent spread of dust.
(F) Covering the floor surface,
including installed carpet, with taped-
down plastic sheeting or other
impermeable material in the work area
6 feet beyond the perimeter of surfaces
undergoing renovation or a sufficient
distance to contain the dust, whichever
is greater (interiors) or covering the
ground with plastic sheeting or other
disposable impermeable material
anchored to the building extending 10
feet beyond the perimeter of surfaces
undergoing renovation or a sufficient
distance to collect falling paint debris,
whichever is greater, unless the
property line prevents 10 feet of such
ground covering, weighted down by
heavy objects (exteriors).
(G) Installing (if necessary) vertical
containment to prevent migration of
dust and debris to adjacent property
(exteriors).
(v) Waste was contained on-site and
while being transported off-site.
(vi) The work area was properly
cleaned after the renovation by:
(A) Picking up all chips and debris,
misting protective sheeting, folding it
dirty side inward, and taping it for
removal.
(B) Cleaning the work area surfaces
and objects using a HEPA vacuum and/
or wet cloths or mops (interiors).
(vii) The certified renovator
performed the post-renovation cleaning
verification (the results of which must
be briefly described, including the
number of wet and dry cloths used).
(c) When test kits are used, the
renovation firm must, within 30 days of
the completion of the renovation,
provide identifying information as to
the manufacturer and model of the test
kits used, a description of the
components that were tested including
their locations, and the test kit results to
the person who contracted for the
renovation.
(d) If dust clearance sampling is
performed in lieu of cleaning
verification as permitted by ง 745.85(c),
the renovation firm must provide,
within 30 days of the completion of the
renovation, a copy of the dust sampling
report to the person who contracted for
the renovation.
11. Section 745.87 is amended by
revising paragraph (e) to read as follows:
ง745.87 Enforcement and inspections.
A A A A A
(e) Lead-based paint is assumed to be
present at renovations covered by this
subpart. EPA may conduct inspections
and issue subpoenas pursuant to the
provisions of TSCA section 11 (15
U.S.C. 2610) to ensure compliance with
this subpart.
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12. Section 745.ฃ
as follows:
[ is revised to read
ง 745.88 Recognized test kits.
(a) Effective lime 23, 2008, EPA
recognizes the test kits that have been
determined by National Institute of
Standards and Technology research to
meet the negative response criteria
described in paragraph (c)(l) of this
section. This recognition will last until
EPA publicizes its recognition of the
first test kit that meets both the negative
response and positive response criteria
in paragraph (c) of this section.
(b) No other test kits will be
recognized until they are tested through
EPA's Environmental Technology
Verification Program or other equivalent
EPA approved testing program.
(1) Effective September 1, 2008, to
initiate the testing process, a test kit
manufacturer must submit a sufficient
number of kits, along with the
instructions for using the kits, to EPA.
The test kit manufacturer should first
visit the following website for
information on where to apply.http://
www.epa.gov/etv/howtoapply.html.
(2) After the kit has been tested
through the Environmental Technology
Verification Program or other equivalent
approved EPA testing program, EPA
will review? the report to determine
whether the required criteria have been
met.
(3) Before September 1, 2010, test kits
must meet only the negative response
criteria in paragraph (c)(l) of this
section. The recognition of kits that
meet only this criteria will last until
EPA publicizes its recognition of the
first test kits that meets both of the
criteria in paragraph (c) of this section.
(4) After September 1, 2010, test kits
must meet both of the criteria in
paragraph (c) of this section.
(5) If the report demonstrates that the
kit meets the required criteria, EPA will
issue a notice of recognition to the kit
manufacturer, provide them with the
report, and post the information on
EPA's website.
(6) If the report demonstrates that the
kit does not meet the required criteria,
EPA will notify the kit manufacturer
and provide them with the report.
(c) Response criteria(1) Negative
response criteria. For paint containing
lead at or above the regulated level, 1.0
mg/cm2 or 0.5% by weight, a
demonstrated probability (with 95%
confidence) of a negative response less
than or equal to 5% of the time.
(2) Positive response criteria. For
paint containing lead below the
regulated level, 1.0 mg/cm2 or 0.5% by
weight, a demonstrated probability
(with 95% confidence) of a positive
response less than or equal to 10% of
the time.
13. Section 745.89 is added to subpart
E to read as follows:
ง745.89 Firm certification.
(a) Initial certification. (1) Firms that
perform renovations for compensation
must apply to EPA for certification to
perform renovations or dust sampling.
To apply, a firm must submit to EPA a
completed "Application for Firms,"
signed by an authorized agent of the
firm, and pay at least the correct amount
of fees. If a firm pays more than the
correct amount of fees, EPA will
reimburse the firm for the excess
amount.
(2) After EPA receives a firm's
application, EPA will take one of the
following actions within 90 days of the
date the application is received:
(i) EPA will approve a firm's
application if EPA determines that it is
complete and that the environmental
compliance history of the firm, its
principals, or its key employees does
not show an unwillingness or inability
to maintain compliance with
environmental statutes or regulations.
An application is complete if it contains
all of the information requested on the
form and includes at least the correct
amount of fees. When EPA approves a
firm's application, EPA will issue the
firm a certificate with an expiration date
not more than 5 years from the date the
application is approved. EPA
certification allows the firm to perform
renovations covered by this section in
any State or Indian Tribal area that does
not have a renovation program that is
authorized under subpart Q of this part.
(ii) EPA will request a firm to
supplement its application if EPA
determines that the application is
incomplete. If EPA requests a firm to
supplement its application, the firm
must submit the requested information
or pay the additional fees within 30
days of the date of the request.
(iii) EPA will not approve a firm's
application if the firm does not
supplement its application in
accordance with paragraph (a)(2)(ii) of
this section or if EPA determines that
the environmental compliance history
of the firm, its principals, or its key
employees demonstrates an
unwillingness or inability to maintain
compliance with environmental statutes
or regulations. EPA will send the firm
a letter giving the reason for not
approving the application. EPA will not
refund the application fees. A firm may
reapply for certification at any time by
filing a new, complete application that
includes the correct amount of fees.
(b) Re-certification. To maintain its
certification, a firm must be re-certified
by EPA every 5 years.
(1) Timely and complete application.
To be re-certified, a firm must submit a
complete application for re-certification.
A complete application for re-
certification includes a completed
"Application for Firms" which contains
all of the information requested by the
form and is signed by an authorized
agent of the firm, noting on the form
that it is submitted as a re-certification.
A complete application must also
include at least the correct amount of
fees. If a firm pays more than the correct
amount of fees, EPA will reimburse the
firm for the excess amount.
(i) An application for re-certification
is timely if it is postmarked 90 days or
more before the date the firm's current
certification expires. If the firm's
application is complete and timely, the
firm's current certification will remain
in effect until its expiration date or until
EPA has made a final decision to
approve or disapprove the re-
certification application, whichever is
later.
(ii) If the firm submits a complete re-
certification application less than 90
days before its current certification
expires, and EPA does not approve the
application before the expiration date,
the firm's current certification will
expire and the firm will not be able to
conduct renovations until EPA approves
its re-certification application.
(iii) If the firm fails to obtain
recertification before the firm's current
certification expires, the firm must not
perform renovations or dust sampling
until it is certified anew pursuant to
paragraph (a) of this section.
(2) EPA action on an application.
After EPA receives a firm's application
for re-certification, EPA will review? the
application and take one of the
following actions within 90 days of
receipt:
(i) EPA will approve a firm's
application if EPA determines that it is
timely and complete and that the
environmental compliance history of
the firm, its principals, or its key
employees does not show an
unwillingness or inability to maintain
compliance with environmental statutes
or regulations. When EPA approves a
firm's application for re-certification,
EPA will issue the firm a new? certificate
with an expiration date 5 years from the
date that the firm's current certification
expires. EPA certification allows the
firm to perform renovations or dust
sampling covered by this section in any
State or Indian Tribal area that does not
have a renovation program that is
authorized under subpart Q of this part.
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(ii) EPA will request a firm to
supplement its application if EPA
determines that the application is
incomplete.
(iii) EPA will not approve a firm's
application if it is not received or is not
complete as of the date that the firm's
current certification expires, or if EPA
determines that the environmental
compliance history of the firm, its
principals, or its key employees
demonstrates an unwillingness or
inability to maintain compliance with
environmental statutes or regulations.
EPA will send the firm a letter giving
the reason for not approving the
application. EPA will not refund the
application fees. A firm may reapply for
certification at any time by filing a new
application and paying the correct
amount of fees.
(c) Amendment of certification. A
firm must amend its certification within
90 days of the date a change occurs to
information included in the firm's most
recent application. If the firm fails to
amend its certification within 90 days of
the date the change occurs, the firm may
not perform renovations or dust
sampling until its certification is
amended.
(1) To amend a certification, a firm
must submit a completed "Application
for Firms," signed by an authorized
agent of the firm, noting on the form
that it is submitted as an amendment
and indicating the information that has
changed. The firm must also pay at least
the correct amount of fees.
(2) If additional information is needed
to process the amendment, or the firm
did not pay the correct amount of fees,
EPA will request the firm to submit the
necessary information or fees. The
firm's certification is not amended until
the firm complies with the request.
(3) Amending a certification does not
affect the certification expiration date.
(d) Firm responsibilities. Firms
performing renovations must ensure
that:
(l) All individuals performing
renovation activities on behalf of the
firm are either certified renovators or
have been trained by a certified
renovator in accordance with ง 745.90.
(2) A certified renovator is assigned to
each renovation performed by the firm
and discharges all of the certified
renovator responsibilities identified in
ง745.90.
(3) All renovations performed by the
firm are performed in accordance with
the work practice standards in ง 745.85.
(4) The pre-renovation education
requirements of ง 745.84 have been
performed.
(5) The recordkeeping requirements of
ง 745.86 are met.
14. Section 745.90 is added to subpart
E to read as follows:
ง 745.90 Renovator certification and dust
sampling technician certification.
(a) Renovator certification and dust
sampling technician certification. (1) To
become a certified renovator or certified
dust sampling technician, an individual
must successfully complete the
appropriate course accredited by EPA
under ง 745.225 or by a State or Tribal
program that is authorized under
subpart Q of this part. The course
completion certificate serves as proof of
certification. EPA renovator certification
allows the certified individual to
perform renovations covered by this
section in any State or Indian Tribal
area that does not have a renovation
program that is authorized under
subpart Q of this part. EPA dust
sampling technician certification allows
the certified individual to perform dust
clearance sampling under ง 745.85(c) in
any State or Indian Tribal area that does
not have a renovation program that is
authorized under subpart Q of this part.
(2) Individuals who have successfully
completed an accredited abatement
worker or supervisor course, or
individuals who have successfully
completed an EPA, HUD, or EPA/HUD
model renovation training course may
take an accredited refresher renovator
training course in lieu of the initial
renovator training course to become a
certified renovator.
(3) Individuals who have successfully
completed an accredited lead-based
paint inspector or risk assessor course
may take an accredited refresher dust
sampling technician course in lieu of
the initial training to become a certified
dust sampling technician.
(4) To maintain renovator certification
or dust sampling technician
certification, an individual must
complete a renovator or dust sampling
technician refresher course accredited
by EPA under ง 745.225 or by a State or
Tribal program that is authorized under
subpart Q of this part within 5 years of
the date the individual completed the
initial course described in paragraph
(a)(l) of this section. If the individual
does not complete a refresher course
within this time, the individual must re-
take the initial course to become
certified again.
(b) Renovator responsibilities.
Certified renovators are responsible for
ensuring compliance with ง 745.85 at all
renovations to which they are assigned.
A certified renovator:
(l) Must perform all of the tasks
described in ง 745.85(b) and must either
perform or direct workers who perform
all of the tasks described in ง 745.85(a).
(2) Must provide training to workers
on the work practices they will be using
in performing their assigned tasks.
(3) Must be physically present at the
work site when the signs required by
ง 745.85(a)(l) are posted, while the work
area containment required by
ง 745.85(a)(2) is being established, and
while the work area cleaning required
by ง 745.85(a)(5) is performed.
(4) Must regularly direct work being
performed by other individuals to
ensure that the work practices are being
followed, including maintaining the
integrity of the containment barriers and
ensuring that dust or debris does not
spread beyond the work area.
(5) Must be available, either on-site or
by telephone, at all times that
renovations are being conducted.
(6) When requested by the party
contracting for renovation services,
must use an acceptable test kit to
determine whether components to be
affected by the renovation contain lead-
based paint.
(7) Must have with them at the work
site copies of their initial course
completion certificate and their most
recent refresher course completion
certificate.
(8) Must prepare the records required
by ง 745.86(b)(7).
(c) Dust sampling technician
responsibilities. When performing
optional dust clearance sampling under
ง 745.85(c), a certified dust sampling
technician:
(1) Must collect dust samples in
accordance with ง 745.227(e)(8), must
send the collected samples to a
laboratory recognized by EPA under
TSCA section 405(b), and must compare
the results to the clearance levels in
accordance with ง 745.227(e)(8).
(2) Must have with them at the work
site copies of their initial course
completion certificate and their most
recent refresher course completion
certificate.
15. Section 745.91 is added to subpart
E to read as follows:
ง745.91 Suspending, revoking, or
modifying an individual's or firm's
certification.
(a)(l) Grounds for suspending,
revoking, or modifying an individual's
certification. EPA may suspend, revoke,
or modify an individual's certification if
the individual fails to comply with
Federal lead-based paint statutes or
regulations. EPA may also suspend,
revoke, or modify a certified renovator's
certification if the renovator fails to
ensure that all assigned renovations
comply with ง 745.85. In addition to an
administrative or judicial finding of
violation, execution of a consent
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agreement in settlement of an
enforcement action constitutes, for
purposes of this section, evidence of a
failure to comply with relevant statutes
or regulations.
(2) Grounds for suspending, revoking,
or modifying a firm's certification. EPA
may suspend, revoke, or modify a firm's
certification if the firm:
(i) Submits false or misleading
information to EPA in its application for
certification or re-certification.
(ii) Fails to maintain or falsifies
records required in ง 745.86.
(iii) Fails to comply, or an individual
performing a renovation on behalf of the
firm fails to comply, with Federal lead-
based paint statutes or regulations. In
addition to an administrative or judicial
finding of violation, execution of a
consent agreement in settlement of an
enforcement action constitutes, for
purposes of this section, evidence of a
failure to comply with relevant statutes
or regulations.
(b) Process for suspending, revoking,
or modifying certification. (I) Prior to
taking action to suspend, revoke, or
modify an individual's or firm's
certification, EPA will notify the
affected entity in writing of the
following:
(i) The legal and factual basis for the
proposed suspension, revocation, or
modification.
(ii) The anticipated commencement
date and duration of the suspension,
revocation, or modification.
(iii) Actions, if any, which the
affected entity may take to avoid
suspension, revocation, or modification,
or to receive certification in the future.
(iv) The opportunity and method for
requesting a hearing prior to final
suspension, revocation, or modification.
(2) If an individual or firm requests a
hearing, EPA will:
(i) Provide the affected entity an
opportunity to offer written statements
in response to EPA's assertions of the
legal and factual basis for its proposed
action.
(ii) Appoint an impartial official of
EPA as Presiding Officer to conduct the
hearing.
(3) The Presiding Officer will:
(i) Conduct a fair, orderly, and
impartial hearing within 90 days of the
request for a hearing.
(ii) Consider all relevant evidence,
explanation, comment, and argument
submitted.
(iii) Notify the affected entity in
writing within 90 days of completion of
the hearing of his or her decision and
order. Such an order is a final agency
action which may be subject to judicial
review?. The order must contain the
commencement date and duration of the
suspension, revocation, or modification.
(4) If EPA determines that the public
health, interest, or welfare warrants
immediate action to suspend the
certification of any individual or firm
prior to the opportunity for a hearing, it
will:
(i) Notify the affected entity in
accordance with paragraph (b)(l)(i)
through (b)(l)(iii) of this section,
explaining why it is necessary to
suspend the entity's certification before
an opportunity for a hearing.
(ii) Notify the affected entity of its
right to request a hearing on the
immediate suspension within 15 days of
the suspension taking place and the
procedures for the conduct of such a
hearing.
(5) Any notice, decision, or order
issued by EPA under this section, any
transcript or other verbatim record of
oral testimony, and any documents filed
by a certified individual or firm in a
hearing under this section will be
available to the public, except as
otherwise provided by section 14 of
TSCA or by part 2 of this title. Any such
hearing at which oral testimony is
presented will be open to the public,
except that the Presiding Officer may
exclude the public to the extent
necessary to allow presentation of
information which may be entitled to
confidential treatment under section 14
of TSCA or part 2 of this title.
(6) EPA will maintain a publicly
available list of entities whose
certification has been suspended,
revoked, modified, or reinstated.
(7) Unless the decision and order
issued under paragraph (b)(3)(iii) of this
section specify otherwise:
(i) An individual whose certification
has been suspended must take a
refresher training course (renovator or
dust sampling technician) in order to
make his or her certification current.
(ii) An individual whose certification
has been revoked must take an initial
renovator or dust sampling technician
course in order to become certified
again.
(iii) A firm whose certification has
been revoked must reapply for
certification after the revocation ends in
order to become certified again. If the
firm's certification has been suspended
and the suspension ends less than 5
years after the firm was initially
certified or re-certified, the firm does
not need to do anything to re-activate its
certification.
16. Section 745.220 is amended by
revising paragraph (a) to read as follows:
ง 745.220 Scope and applicability.
(a) This subpart contains procedures
and requirements for the accreditation
of training programs for lead-based
paint activities and renovations,
procedures and requirements for the
certification of individuals and firms
engaged in lead-based paint activities,
and work practice standards for
performing such activities. This subpart
also requires that, except as discussed
below, all lead-based paint activities, as
defined in this subpart, be performed by
certified individuals and firms.
A A A A A
17. Section 745.225 is amended as
follows:
a. Revise paragraph (a).
b. Revise the introductory text of
paragraph (b), revise paragraph (b)(l)(ii),
and add paragraph (b)(l)(iv)(C).
c. Revise the introductory text of
paragraph (c), add paragraphs (c)(6)(vi),
(c)(6)(vii), (c)(8)(vi), and (c)(8)(vii), and
revise paragraphs (c)(8)(iv) and (c)(10).
d. Remove the phrase "lead-based
paint activities" and add in its place the
phrase "renovator, dust sampling
technician, or lead-based paint
activities" wherever it appears in
paragraph (c)(13).
e. Add paragraph (c)(14)(ii)(D)(6).
f. Add paragraphs (d)(6) and (d)(7).
g. Revise the introductory text of
paragraph (e).
h. Remove the word "activities"
wherever it appears in paragraph (e)(l).
i. Revise paragraph (e)(2).
ง 745.225 Accreditation of training
programs; target housing and child-
occupied facilities.
(a) Scope. (1) A training program may
seek accreditation to offer courses in
any of the following disciplines:
Inspector, risk assessor, supervisor,
project designer, abatement worker,
renovator, and dust sampling
technician. A training program may also
seek accreditation to offer refresher
courses for each of the above listed
disciplines.
(2) Training programs may first apply
to EPA for accreditation of their lead-
based paint activities courses or
refresher courses pursuant to this
section on or after August 31, 1998.
Training programs may first apply to
EPA for accreditation of their renovator
or dust sampling technician courses or
refresher courses pursuant to this
section on or after April 22, 2009.
(3) A training program must not
provide, offer, or claim to provide EPA-
accredited lead-based paint activities
courses without applying for and
receiving accreditation from EPA as
required under paragraph (b) of this
section on or after March 1, 1999. A
training program must not provide,
offer, or claim to provide EPA-
accredited renovator or dust sampling
technician courses without applying for
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21767
and receiving accreditation from EPA as
required under paragraph (b) of this
section on or after June 23, 2008.
(b) Application process. The
following are procedures a training
program must follow to receive EPA
accreditation to offer lead-based paint
activities courses, renovator courses, or
dust sampling technician courses:
(1) * * *
(ii) A list of courses for which it is
applying for accreditation. For the
purposes of this section, courses taught
in different languages are considered
different courses, and each must
independently meet the accreditation
requirements.
A A A A A
(iv) * * *
(C) When applying for accreditation of
a course in a language other than
English, a signed statement from a
qualified, independent translator that
they had compared the course to the
English language version and found the
translation to be accurate.
A A A A A
(c) Requirements for the accreditation
of training programs. For a training
program to obtain accreditation from
EPA to offer lead-based paint activities
courses, renovator courses, or dust
sampling technician courses, the
program must meet the following
requirements:
A A A A A
(6) * * *
(vi) The renovator course must last a
minimum of 8 training hours, with a
minimum of 2 hours devoted to hands-
on training activities. The minimum
curriculum requirements for the
renovator course are contained in
paragraph (d)(6) of this section. Hands-
on training activities must cover
renovation methods that minimize the
creation of dust and lead-based paint
hazards, interior and exterior
containment and cleanup methods, and
post-renovation cleaning verification.
(vii) The dust sampling technician
course must last a minimum of 8
training hours, with a minimum of 2
hours devoted to hands-on training
activities. The minimum curriculum
requirements for the dust sampling
technician course are contained in
paragraph (d)(7) of this section. Hands-
on training activities must cover dust
sampling methodologies.
A A A A A
(8) * * *
(iv) For initial inspector, risk assessor,
project designer, supervisor, or
abatement worker course completion
certificates, the expiration date of
interim certification, which is 6 months
from the date of course completion.
A A A A A
(vi) The language in which the course
was taught.
(vii) For renovator and dust sampling
technician course completion
certificates, a photograph of the
individual.
A A A A A
(10) Courses offered by the training
program must teach the work practice
standards contained in ง 745.85 or
ง 745.227, as applicable, in such a
manner that trainees are provided with
the knowledge needed to perform the
renovations or lead-based paint
activities they will be responsible for
conducting.
A A A A A
(14) * * *
(ii) * * *
(D) * * *
(6) A digital photograph of the
student.
(d) * * *
(6) Renovator, (i) Role and
responsibility of a renovator.
(ii) Background information on lead
and its adverse health effects.
(iii) Background information on EPA,
HUD, OSHA, and other Federal, State,
and local regulations and guidance that
pertains to lead-based paint and
renovation activities.
(iv) Procedures for using acceptable
test kits to determine whether paint is
lead-based paint.
(v) Renovation methods to minimize
the creation of dust and lead-based
paint hazards.
(vi) Interior and exterior containment
and cleanup methods.
(vii) Methods to ensure that the
renovation has been properly
completed, including cleaning
verification, and clearance testing.
(viii) Waste handling and disposal.
(ix) Providing on-the-job training to
other workers.
(x) Record preparation.
(7) Dust sampling technician, (i) Role
and responsibility of a dust sampling
technician.
(ii) Background information on lead
and its adverse health effects.
(iii) Background information on
Federal, State, and local regulations and
guidance that pertains to lead-based
paint and renovation activities.
(iv) Dust sampling methodologies.
(v) Clearance standards and testing.
(vi) Report preparation.
A A A A A
(e) Requirements for the accreditation
of refresher training programs. A
training program may seek accreditation
to offer refresher training courses in any
of the following disciplines: Inspector,
risk assessor, supervisor, project
designer, abatement worker, renovator,
and dust sampling technician. To obtain
EPA accreditation to offer refresher
training, a training program must meet
the following minimum requirements:
A A A A A
(2) Refresher courses for inspector,
risk assessor, supervisor, and abatement
worker must last a minimum of 8
training hours. Refresher courses for
project designer, renovator, and dust
sampling technician must last a
minimum of 4 training hours.
A A A A A
18. Section 745.320 is amended by
revising paragraph (c) to read as follows:
ง745.320 Scope and purpose.
A A A A A
(c) A State or Indian Tribe may seek
authorization to administer and enforce
all of the provisions of subpart E of this
part, just the pre-renovation education
provisions of subpart E of this part, or
just the training, certification,
accreditation, and work practice
provisions of subpart E of this part. The
provisions of งง 745.324 and 745.326
apply for the purposes of such program
authorizations.
A A A A A
19. Section 745.324 is amended as
follows:
a. Revise paragraph (a)(l).
b. Remove the phrase "lead-based
paint training accreditation and
certification" from the second sentence
of paragraph (b)(l)(iii).
c. Revise paragraph (b)(2)(ii).
d. Revise paragraphs (e)(2)(i) and
e. Revise paragraph (f)(2).
f. Revise paragraph (i)(8).
ง 745.324 Authorization of State or Tribal
programs.
(a) Application content and
procedures. (1) Any State or Indian
Tribe that seeks authorization from EPA
to administer and enforce the provisions
of subpart E or subpart L of this part
must submit an application to the
Administrator in accordance with this
paragraph.
A A A A A
(b) * * *
(2) * * *
(ii) An analysis of the State or Tribal
program that compares the program to
the Federal program in subpart E or
subpart L of this part, or both. This
analysis must demonstrate how the
program is, in the State's or Indian
Tribe's assessment, at least as protective
as the elements in the Federal program
at subpart E or subpart L of this part, or
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21768
Federal Register/Vol. 73, No. 78/Tuesday, April 22, 2008/Rules and Regulations
both. EPA will use this analysis to
evaluate the protectiveness of the State
or Tribal program in making its
determination pursuant to paragraph
(e)(2)(i) of this section.
A A A A A
(e) * * *
(2) * * *
(i) The State or Tribal program is at
least as protective of human health and
the environment as the corresponding
Federal program under subpart E or
subpart L of this part, or both; and
A A A A A
(4) If the State or Indian Tribe applies
for authorization of State or Tribal
programs under both subpart E and
subpart L, EPA may, as appropriate,
authorize one program and disapprove
the other.
A A A A A
(f) * * *
(2) If a State or Indian Tribe does not
have an authorized program to
administer and enforce the pre-
renovation education requirements of
subpart E of this part by August 31,
1998, the Administrator will, by such
date, enforce those provisions of subpart
E of this part as the Federal program for
that State or Indian Country. If a State
or Indian Tribe does not have an
authorized program to administer and
enforce the training, certification and
accreditation requirements and work
practice standards of subpart E of this
part by April 22, 2009, the
Administrator will, by such date,
enforce those provisions of subpart E of
this part as the Federal program for that
State or Indian Country.
(8) By the date of such order, the
Administrator will establish and enforce
the provisions of subpart E or subpart L
of this part, or both, as the Federal
program for that State or Indian
Country.
20. Section 745.326 is revised to read
as follows:
ง745.326 Renovation: State and Tribal
program requirements.
(a) Program elements. To receive
authorization from EPA, a State or
Tribal program must contain the
following program elements:
(1) For pre-renovation education
programs, procedures and requirements
for the distribution of lead hazard
information to owners and occupants of
target housing and child-occupied
facilities before renovations for
compensation.
(2) For renovation training,
certification, accreditation, and work
practice standards programs:
(i) Procedures and requirements for
the accreditation of renovation and dust
sampling technician training programs.
(ii) Procedures and requirements for
the certification of renovators and dust
sampling technicians.
(iii) Procedures and requirements for
the certification of individuals and/or
firms.
(iv) Requirements that all renovations
be conducted by appropriately certified
individuals and/or firms.
(v) Work practice standards for the
conduct of renovations.
(3) For all renovation programs,
development of the appropriate
infrastructure or government capacity to
effectively carry out a State or Tribal
program.
(b) Pre-renovation education. To be
considered at least as protective as the
Federal program, the State or Tribal
program must:
(1) Establish clear standards for
identifying renovation activities that
trigger the information distribution
requirements.
(2) Establish procedures for
distributing the lead hazard information
to owners and occupants of housing and
child-occupied facilities prior to
renovation activities.
(3) Require that the information to be
distributed include either the pamphlet
titled Renovate Right: Important Lead
Hazard Information for Families, Child
Care Providers and Schools, developed
by EPA under section 406(a) of TSCA,
or an alternate pamphlet or package of
lead hazard information that has been
submitted by the State or Tribe,
reviewed by EPA, and approved by EPA
for that State or Tribe. Such information
must contain renovation-specific
information similar to that in Renovate
Right: Important Lead Hazard
Information for Families, Child Care
Providers and Schools, must meet the
content requirements prescribed by
section 406(a) of TSCA, and must be in
a format that is readable to the diverse
audience of housing and child-occupied
facility owners and occupants in that
State or Tribe.
(i) A State or Tribe with a pre-
renovation education program approved
before June 23, 2008, must demonstrate
that it meets the requirements of this
section no later than the first report that
it submits pursuant to ง 745.324(h) on or
after April 22, 2009.
(ii) A State or Tribe with an
application for approval of a pre-
renovation education program
submitted but not approved before June
23, 2008, must demonstrate that it meets
the requirements of this section either
by amending its application or in the
first report that it submits pursuant
toง 745.324(h) of this part on or after
April 22, 2009.
(iii) A State or Indian Tribe
submitting its application for approval
of a pre-renovation education program
on or after June 23, 2008, must
demonstrate in its application that it
meets the requirements of this section.
(c) Accreditation of training programs.
To be considered at least as protective
as the Federal program, the State or
Tribal program must meet the
requirements of either paragraph (c)(l)
or (c)(2) of this section:
(1) The State or Tribal program must
establish accreditation procedures and
requirements, including:
(i) Procedures and requirements for
the accreditation of training programs,
including, but not limited to:
(A) Training curriculum
requirements.
(B) Training hour requirements.
(C) Hands-on training requirements.
(D) Trainee competency and
proficiency requirements.
(E) Requirements for training program
quality control.
(ii) Procedures and requirements for
the re-accreditation of training
programs.
(iii) Procedures for the oversight of
training programs.
(iv) Procedures and standards for the
suspension, revocation, or modification
of training program accreditations; or
(2) The State or Tribal program must
establish procedures and requirements
for the acceptance of renovation training
offered by training providers accredited
by EPA or a State or Tribal program
authorized by EPA under this subpart.
(d) Certification of renovators. To be
considered at least as protective as the
Federal program, the State or Tribal
program must:
(1) Establish procedures and
requirements for individual certification
that ensure that certified renovators are
trained by an accredited training
program.
(2) Establish procedures and
requirements for re-certification.
(3) Establish procedures for the
suspension, revocation, or modification
of certifications.
(e) Work practice standards for
renovations. To be considered at least as
protective as the Federal program, the
State or Tribal program must establish
standards that ensure that renovations
are conducted reliably, effectively, and
safely. At a minimum, the State or
Tribal program must contain the
following requirements:
(1) Renovations must be conducted
only by certified contractors.
(2) Renovations are conducted using
lead-safe work practices that are at least
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Federal Register/Vol. 73, No. 78/Tuesday, April 22, 2008/Rules and Regulations
21769
as protective to occupants as the
requirements in ง 745.85.
(3) Certified contractors must retain
appropriate records.
21. Section 745.327 is amended by
revising paragraphs (b)(l)(iv) and
(b)(2)(ii) to read as follows:
ง 745.327 State or Indian Tribal lead-based
paint compliance and enforcement
programs.
A A A A A
(b) * * *
(1) * * *
(iv) Requirements that regulate the
conduct of renovation activities as
described at ง 745.326.
(2) * * *
(ii) For the purposes of enforcing a
renovation program, State or Tribal
officials must be able to enter a firm's
place of business or work site.
A A A A A
22. Section 745.339 is revised to read
as follows:
ง745.339 Effective date.
States and Indian Tribes may seek
authorization to administer and enforce
subpart L of this part pursuant to this
subpart at any time. States and Indian
Tribes may seek authorization to
administer and enforce the pre-
renovation education provisions of
subpart E of this part pursuant to this
subpart at any time. States and Indian
Tribes may seek authorization to
administer and enforce all of subpart E
of this part pursuant to this subpart
effective lune 23, 2008.
[FR Doc. E8-8141 Filed 4-21-08; 8:45 am]
BILLING CODE 6560-50-S
ENVIRONMENTAL PROTECTION
AGENCY
40 CFR Part 745
[EPA-HQ-OPPT-2004-0126; FRL-8358-6]
Lead Hazard Information Pamphlet;
Notice of Availability
AGENCY: Environmental Protection
Agency (EPA).
ACTION: Notice of availability.
SUMMARY: This notice announces the
availability of EPA's new lead hazard
information pamphlet for renovation
activities, Renovate Right: Lead Hazard
Information for Families, Child Care
Providers and Schools (Renovate Right).
There is an increased risk of exposure
to lead-based paint hazards during
renovation activities, particularly for
children under 6 years of age. To better
inform families, child care providers,
and schools about the risks and to
encourage greater public health and
safety during renovation activities in
target housing and child-occupied
facilities, EPA has developed a
renovation-specific information
pamphlet. This new pamphlet gives
information on lead-based paint
hazards, lead testing, how to select a
contractor, what precautions to take
during the renovation, and proper
cleanup activities.
DATES: After June 23, 2008, the new
pamphlet or Protect Your Family From
Lead in Your Home may be used for
compliance with the Pre-Renovation
Education Rule under TSCA section
406(b). After December 22, 2008, the
new pamphlet must be used
exclusively.
FOR FURTHER INFORMATION CONTACT: For
general information contact: Colby
Lintner, Regulatory Coordinator,
Environmental Assistance Division
(7408M), Office of Pollution Prevention
and Toxics, Environmental Protection
Agency, 1200 Pennsylvania Ave., NW.,
Washington, DC 20460-0001; telephone
number: (202) 5541404; e-mail address:
TSCA-Hotline@epa .gov.
For technical information contact:
Mike Wilson, National Program
Chemicals Division, Office of Pollution
Prevention and Toxics, Environmental
Protection Agency, 1200 Pennsylvania
Ave., NW., Washington, DC 20460-
0001; telephone number (201) 566-
0521; e-mail address:
wilson .mike@epa .gov.
SUPPLEMENTARY INFORMATION:
I. General Information
A. Does this Action Apply to Me?
You may be potentially affected by
this action if you perform renovations of
target housing or child-occupied
facilities for compensation. "Target
housing" is defined in section 401 of
TSCA as any housing constructed prior
to 1978, except housing for the elderly
or persons with disabilities (unless any
child under age 6 resides or is expected
to reside in such housing) or any 0-
bedroom dwelling. EPA's Renovation,
Repair, and Painting rule defines a
child-occupied facility as a building, or
a portion of a building, constructed
prior to 1978, visited regularly by the
same child, under 6 years of age, on at
least 2 different days within any week
(Sunday through Saturday period),
provided that each day's visit lasts at
least 3 hours and the combined weekly
visits last at least 6 hours, and the
combined annual visits last at least 60
hours. Child-occupied facilities may be
located in public or commercial
buildings or in target housing.
Potentially affected entities may
include, but are not limited to:
Building construction (NAICS
code 236), e.g., single family housing
construction, multi-family housing
construction, residential remodelers.
Specialty trade contractors (NAICS
code 238), e.g., plumbing, heating, and
air-conditioning contractors, painting
and wall covering contractors, electrical
contractors, finish carpentry contractors,
drywall and insulation contractors,
siding contractors, tile and terrazzo
contractors, glass and glazing
contractors.
Real estate (NAICS code 531), e.g.,
lessors of residential buildings and
dwellings, residential property
managers.
Child day care services (NAICS
code 624410).
Elementary and secondary schools
(NAICS code 611110), e.g., elementary
schools with kindergarten classrooms.
This listing is not intended to be
exhaustive, but rather provides a guide
for readers regarding entities likely to be
affected by this action. Other types of
entities not listed in this unit could also
be affected. The North American
Industrial Classification System
(NAICS) codes have been provided to
assist you and others in determining
whether this action might apply to
certain entities. To determine whether
you or your business may be affected by
this action, you should carefully
examine the applicability provisions in
40 CFR 745.82. If you have any
questions regarding the applicability of
this action to a particular entity, consult
the technical person listed under FOR
FURTHER INFORMATION CONTACT.
B. How Can I Get Copies of the
Pamphlet and Other Related
Information?
1. The pamphlet. Single copies of the
pamphlet may be obtained by calling
the National Lead Information
Clearinghouse (NLIC) at 1-800-424-
LEAD or TDD: 1-800-526-5456, or the
EPA Public Information Center at (202)
260-2080. Multiple copies are available
through the Government Printing Office
(GPO). The public may order 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,
Renovate Right: Lead Hazard
Information for Families, Child Care
Providers and Schools. The pamphlet is
also available on EPA's website at
http://www.epa.gov/lead. The pamphlet
may be reproduced by an individual or
corporation without permission from
EPA.
-------
Appendix 2:
U.S. Department of Housing and
Urban Development
(HUD) Requirements
-------
EPA Certified Renovation Firms and Certified Renovators
Additional Requirements of HUD's Lead Safe Housing Rule
The U.S. Department of Housing and Urban Development's Lead Safe Housing Rule (HUD's
Lead Safe Housing Rule (LSHR), which is found in HUD's regulations at 24 CFR Part 35,
Subparts B through M), generally applies to work performed in target housing units receiving
HUD housing assistance, such as rehabilitation or acquisition assistance.
Under the LSHR, the program participant (governmental jurisdiction, non-profit, community
organization or the property owner who accepts HUD funds) becomes responsible for
compliance with the LSHR and is referred to as the designated party (or DP). Renovation firms
may include, for example, for-profit contractors, non-profit organizations, or a designated party
using its own employees for renovation. In the spirit of maintaining good customer relations,
certified renovation firms should ask their client if:
1) The work involves lead hazard control (including abatement, interim control of lead hazards
or ongoing lead-based paint maintenance); and
2) The housing receives financial assistance. If so, the renovator should ask the client to find
out if the assistance is federal assistance.
Most clients would appreciate these questions so they may avoid violating HUD or EPA rules.
See www.hud.qov/offices/lead/enforcement/lshr.cfm for more information.
The information below and in the table explain the basic requirements of HUD's regulation for
renovators who have not yet had experience with HUD-funded work. The term "rehabilitation" is
used by HUD to describe residential renovation work. When HUD funds pay for this work,
funding often flows from HUD through cities, states or other program participants, and
addressing lead-based painted surfaces becomes a routine part of the job. HUD's specific
requirements depend on the amount of Federal rehabilitation assistance the project is receiving:
1) Up to $5,000 per unit: "Do no harm" approach. Lead safety requirements cover only the
surfaces being disturbed. Program participants can either test these surfaces to determine if
they contain lead-based paint or presume they contain lead-based paint. Work which
disturbs painted surfaces known or presumed to contain lead-based paint is done using lead
safe work practices, and clearance of the worksite is performed at the end of the job (unless
it is a very small "de minimis" scale project) to ensure that no lead dust hazards remain in
the work area. Training that meets the EPA's RRP Rule requirements is sufficient for this
work.
2) Greater than $5,000 and up to $25,000 per unit: Identify and control lead hazards. Identify
all lead hazards at the affected units and common areas servicing those units by performing
a lead-based paint risk assessment. Control the hazards using interim controls. Participants
may skip the risk assessment and presume that all potential lead hazards are present, and
then must use standard treatments to address them. In addition to training that meets the
EPA's RRP Rule requirements, HUD-approved interim control training (such as the HUD-
EPA RRP curriculum) is required for renovators and workers.
3) Greater than $25,000 per unit: Identify and abate lead hazards. Identify all lead hazards at
the property by performing a risk assessment and then abate all the hazards. Participants
may skip the risk assessment and presume that all potential lead hazards are present and
abate them. This approach requires certified abatement contractors perform the abatement
part of the job.
Additional Requirements for HUD's LSHR Mar 09 A2-1
-------
EPA Certified Renovation Firms and Certified Renovators
Additional Requirements of HUD's Lead Safe Housing Rule
These approaches also include all the basic HUD requirements describe in the slide
presentations in Module 2. They clearly demonstrate the importance to the renovator of asking
the client whether federal housing assistance is provided for the project.
The differences between HUD's LSHR and the Environmental Protection Agency's (EPA's)
Renovation, Repair and Painting (RRP) regulation, part of EPA's regulations at 40 CFR
Part 745, and the changes for HUD LSHR projects, are summarized in the following table and
explained in the narrative after the table:
Differences between HUD LSHR and EPA RRP regulations
Stage of
Job
Planning
and Set-
Up
Requirement
Determination
that lead-based
paint (LBP) is
present.
Training
HUD LSHR
EPA- recognized test
kits cannot be used
to say paint is not
LBP. Only a certified
LBP inspector or risk
assessor may
determine whether
LBP is present.
HUD does not certify
renovators or firms.
All workers and
supervisors must
complete a HUD-
approved curriculum
in lead safe work
practices, except that
non-certified
renovation workers
need only on-the-job
training if they are
supervised by a
certified LBP
abatement supervisor
who is also a certified
renovator.
EPA RRP
Certified renovators
use an EPA-
recognized test kit to
determine if RRP
rule applies or not.
EPA or EPA-
authorized States
certify renovation
firms and accredit
training providers
that certify
renovators. Only the
certified renovator is
required to have
classroom training.
Workers must
receive on-the-job
training from the
certified renovator.
Changes to
LSHR Projects to
Comply with
RRP.
None.
Renovation firms
must be certified.
At least one
certified renovator
must be at the job
or available when
work is being
done. (The
certified renovator
may be a certified
LBP abatement
supervisor who
has completed the
4-hour RRP
refresher course.)
Additional Requirements for HUD's LSHR Mar 09
A2-2
-------
EPA Certified Renovation Firms and Certified Renovators
Additional Requirements of HUD's Lead Safe Housing Rule
Stage of
Job
During
the Job
Requirement
Pre-Renovation
Education
Treating LBP
hazards
Prohibited Work
Practices
HUD LSHR
HUD requires
conformance with
EPA regulations,
including EPA's Pre-
Renovation
Education Rule. EPA
had required
renovators to hand
out the EPA /HUD/
CPSC Protect Your
Family from Lead in
Your Home (Lead
Disclosure Rule)
pamphlet.
Depending on type
and amount of HUD
assistance, HUD
requires that lead
hazards be treated
using "interim
controls" or "ongoing
lead-based paint
maintenance."
HUD prohibits 6 work
practices. These
include EPA's
3 prohibited work
practices plus: heat
guns that char paint,
dry scraping or
sanding farther than
1 ft. of electrical
outlets, and use of a
volatile stripper in
poorly ventilated
space.
EPA RRP
Renovators must
hand out the EPA /
HUD Renovate
Right: Important
Lead Hazard
Information for
Families, Child Care
Providers and
Schools pamphlet.
(This requirement
went into effect on
December 22,
2008.)
EPA generally
requires that
renovations in target
housing be
performed using
lead-safe work
practices.
EPA prohibits 3 work
practices (open
flame burning or
torching, heat guns
above 1100 degrees
F, machine removal
without H EPA
vacuum
attachment).
Changes to
LSHR Projects to
Comply with
RRP.
None.
None.
None.
Additional Requirements for HUD's LSHR Mar 09
A2-3
-------
EPA Certified Renovation Firms and Certified Renovators
Additional Requirements of HUD's Lead Safe Housing Rule
Stage of
Job
End of
Job
Requirement
Threshold
minimum
amounts of
interior paint
disturbance
which trigger
lead activities.
Confirmatory
Testing
Notification to
Occupants
HUD LSHR
HUD has a lower
interior "de minimis"
threshold (2 sq. ft.
per room, or 10% of
a small component
type) than EPA for
lead-safe work
practices. HUD also
uses this lower
threshold for
clearance and
occupant notification.
HUD requires a
clearance
examination done by
an independent party
instead of the
certified renovator's
cleaning verification
procedure.
HUD requires the
designated party to
distribute notices to
occupants within 15
days after lead
hazard evaluation
and control activities
in their unit (and
common areas, if
applicable).
EPA RRP
EPA's interior
threshold (6 sq. ft.
per room) for minor
repair and
maintenance
activities is higher
than HUD'sde
minimis threshold.
EPA allows cleaning
verification by the
renovator or
clearance
examination. The
cleaning verification
does not involve
sampling and
laboratory analysis
of the dust.
EPA has no
requirement to notify
residents who are
not the owners after
the renovation.
Changes to
LSHR Projects to
Comply with
RRP.
None.
None.
None.
Additional Requirements for HUD's LSHR Mar 09
A2-4
-------
EPA Certified Renovation Firms and Certified Renovators
Additional Requirements of HUD's Lead Safe Housing Rule
A. Responsibilities Shifted from the Renovator to the Designated
Party under HUD's LSHR:
1. Under the LSHR, the designated party is generally responsible to either have the paint
tested by a certified lead inspector or risk assessor or presume the presence of lead-
based paint. Therefore, when HUD's rule applies, the Certified Renovator may not use a
paint test kit to determine that the paint is not lead-based paint. Note: Some states may
have conflict-of-interest regulations prohibiting renovators from testing paint on which
they will be working.
2. When the HUD LSHR applies, the designated party must have a qualified person,
independent of the renovation firm, conduct a lead clearance examination. The Certified
Renovator does not conduct a cleaning verification. See below for more information on
clearance testing.
B. Additional HUD Requirements for the Renovator:
1. Training requirements for workers and supervisors performing interim controls.
To meet the requirements of both rules:
a. If the supervisor (in HUD terms) or Certified Renovator (in EPA terms) is certified as
a lead-based paint abatement supervisor or has successfully completed an
accredited abatement supervision or abatement worker course, that person must
complete a 4-hour RRP refresher course.
b. For workers who are not themselves supervisors / Certified Renovators:
If their supervisor on this project is a certified lead-based paint abatement
supervisor who has completed a 4-hour RRP refresher course, the workers must
obtain on-the-job training in lead-safe work practices from the supervisor.
. Otherwise, the workers must successfully complete either a one-day RRP
course, or another lead-safe work practices course approved by HUD for this
purpose after consultation with the EPA. HUD has approved the one-day RRP
course, the previously-published HUD/EPA one-day Renovation, Remodeling
and Repair course, and other one-day courses listed on HUD's website, at
www.hud.gov/offices/lead.
c. Where the work is being done in a State or Tribal jurisdiction that has been
authorized by the EPA to operate an RRP training and certification program, the
one-day RRP course and half-day RRP refresher course must be accredited by the
State or Tribe. HUD will approve all one-day RRP courses accredited by EPA-
authorized States or Tribes.
d. The 4-hour RRP refresher course is not sufficient on its own to meet either the EPA
or HUD training requirements.
2. The certified renovation firm and the certified renovator must take additional
precautions to protect residents from lead poisoning beyond those in EPA's RRP
Rule.
a. Renovators must use lead-safe work practices in work exempt from the RRP
Rule that:
Disturbs between 2 and 6 ft2 of paint per room, the LSHR's de minimis threshold
and the RRP's minor repair and maintenance activities threshold, respectively.
Note: Window replacement, window sash replacement, and demolition of
painted surface areas disturb more paint than the LSHR's de minimis threshold.
Additional Requirements for HUD's LSHR Mar 09 A2-5
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EPA Certified Renovation Firms and Certified Renovators
Additional Requirements of HUD's Lead Safe Housing Rule
Disturbs more than 10% of a component type with a small surface area (such as
window sills, baseboards, and trim).
Note: The square foot and percent thresholds above apply to all work performed
within a thirty day period.
Is in target housing where the owner-occupant signs a statement under the RRP
Rule that lead safe work practices are not required.
Note: HUD does not allow any owner, whether an owner-occupant or landlord, to
opt out of the use of lead safe work practices at any time, even though the EPA
allows an owner-occupant to sign a statement that lead safe work practices are
not required.
b. Not using HUD's 3 additional prohibited work practices:
Heat guns that char the paint even if operating at below 1100 degrees F.
Dry sanding or dry scraping, except dry scraping in conjunction with heat guns or
within 1 ft of electrical outlets.
Paint stripping using a volatile stripper in a poorly ventilated space.
c. Taking additional measures to protect occupants during longer interior hazard
reduction activities: Temporarily relocating the occupant before and during longer
interior hazard reduction activities to a suitable, decent, safe, and similarly accessible
dwelling unit that does not have lead-based paint hazards. Temporary relocation is
not required for shorter projects, where:
The work is contained, completed in one period of 8-daytime hours, and does not
create other safety, health or environmental hazards; or
The work is completed within 5 calendar days, after each work day, the worksite
and the area within 10 feet of the containment area are cleaned of visible dust
and debris, and occupants have safe access to sleeping areas, and bathroom
and kitchen facilities.
C. Additional Designated Party Responsibilities that may Affect the
Renovator
On jobs covered by the HUD LSHR, the certified renovation firm and the certified
renovator should know other requirements for the designated party that may affect their
role on the project.
1. Designated party must provide occupants with two notices, if the amount of work
is above HUD's de minimi's threshold:
a. NOTICE OF EVALUATION OR PRESUMPTION: This notice informs the occupants
that paint has been evaluated to determine if it is LBP or that paint has been
presumed to be LBP. The designated party must notify the occupants within 15
calendar days of receiving the evaluation report or making the presumption. The
renovator should ask the client if he/she has made this notice. The owner may
provide a copy of this notice to the renovator so the renovator knows where LBP is
located.
b. NOTICE OF HAZARD REDUCTION ACTIVITY: This notice describes the hazard
reduction work that was completed and gives the contact for occupants to get more
information. The designated party must notify the occupants within 15 calendar days
of completion the hazard reduction work. The renovator may be given a copy of this
notice, or may be asked to prepare or distribute the notice for the owner at part of the
renovator's work for the owner.
Additional Requirements for HUD's LSHR Mar 09 A2-6
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EPA Certified Renovation Firms and Certified Renovators
Additional Requirements of HUD's Lead Safe Housing Rule
2. Depending on the type and amount of housing assistance provided, HUD
generally requires that identified LBP hazards be treated. Treatments may include
LBP hazard abatement, interim controls or ongoing LBP maintenance. Renovators
should inquire if their contract with the owner requires them to perform lead hazard
treatment tasks listed below. If so, all workers and supervisors must have the proper
training and qualifications. Generally, interim controls include the following activities,
which are required if the amount of work is above HUD's de minimis threshold; for work
below the de minimis threshold, any deteriorated paint must be repaired, but the work
need not be done using lead-safe work practices, although HUD strongly encourages
their use:
a. Deteriorated LBP must be stabilized. This means that physical defects in the
substrate of a paint surface or component that is causing the deterioration of the
surface or component must also be repaired.
b. Friction surfaces that are abraded must be treated if there are lead dust hazards
nearby.
c. Friction points must be either eliminated or treated so the LBP is not subject to
abrasion.
d. Impact surfaces must be treated if the paint on an impact surface is damaged or
otherwise deteriorated and the damage is caused by impact from a related building
component (such as a door knob that knocks the wall or a door that rubs against its
doorframe).
e. LBP must be protected from impact.
f. Chewable LBP surfaces must be made inaccessible for chewing by children of less
than six years of age if there is evidence that such a child has chewed on the painted
surface.
g. Horizontal surfaces that are rough, pitted, or porous must be covered with a smooth,
cleanable covering or coating.
3. For certain types of HUD assistance, when a child known to have an
environmental intervention blood lead level is present, the designated party must
take additional steps to assess the situation and respond to potential lead
hazards. An environmental intervention blood lead level is a reading in a child under 6
years old of 20 micrograms per deciliter of blood (20 ug/dL), or two readings of 15 to 19
ug/dL at least 3 months apart. For certain types of HUD assistance (tenant-based rental
assistance, project-based rental assistance, public housing, and HUD-owned multifamily
housing), the owner or designated party may ask the renovator to perform work in the
unit to address specific lead hazards identified by an environmental investigation risk
assessment. All persons participating in such work should have appropriate training and
qualifications.
4. The designated party must arrange for a party independent of the renovator to
conduct a clearance examination, if the amount of work is above HUD's de
minimis threshold:
a. A clearance examination includes a visual assessment at the end of the renovation
work for deteriorated paint, dust, debris, paint chips or other residue; sampling of
dust on interior floors, window sills and window troughs; submitting the dust samples
to a laboratory for analysis for lead; interpreting the lab results, and preparing a
clearance report. EPA also allows a clearance examination to be used instead of the
post-cleaning verification, if the clearance examination is required by federal, state or
Additional Requirements for HUD's LSHR Mar 09 A2-7
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EPA Certified Renovation Firms and Certified Renovators
Additional Requirements of HUD's Lead Safe Housing Rule
local regulations or by the contract. The unit - or, where work is contained, just the
work area and an area just outside the containment - must pass clearance, and
must not have any remaining lead hazards. If clearance fails at either the visual
assessment step or the dust testing step, cleaning has to be redone in the failed part
of the work area. The failed part of the work area is the specific area that was
tested, as well as any areas that were not tested, and any other areas that are being
represented by the sampled area. For example:
Just one bedroom was tested, because it was to represent all bedrooms in the
housing unit; it failed. Therefore, all of the bedrooms in the unit have to be re-
cleaned and re-cleared.
In a large multifamily apartment building, if a percentage of units are tested in
accordance with the HUD Guidelines, if any fail, all of the units except those that
passed clearance have to be re-cleaned and re-cleared. (If there are patterns of
just certain component types failing, just those component types need to be re-
cleaned and re-cleared in the failed and untested units.)
b. The person conducting the clearance examination must be both:
A certified lead-based paint inspector, risk assessor, clearance examiner, or dust
sampling technician, depending on the type of activity being performed. (Either
the State or the EPA certifies this person, depending on whether or not the State
the housing is in is authorized by EPA to certify people in the lead discipline.)
Independent of the organization performing hazard reduction or maintenance
activities. There is one exception, which is that designated party may use a
qualified in-house employee to conduct clearance even if other in-house
employees did the renovation work, but an in-house employee may not do both
renovation and clearance.
D. How to Find Out About Lead-Based Paint Requirements that
Apply to Planned Work in Properties Receiving HUD Housing
Assistance, such as Rehabilitation or Acquisition Assistance:
Finding out whether the work is receiving federal housing assistance is important
because failing to meet lead-based paint requirements could affect the
continuation of the assistance. For each job, the renovation firm should find out
whether:
The housing receives financial assistance; and
Any lead-based paint requirements apply to the work because of the assistance
provided.
The renovation firm should take the following steps:
1. Ask the property owner if the property or the family receives any type of housing
assistance, including low-interest loans, from a local, State, or Federal agency. If
so:
a. Find out the name of the agency, contact person, address and phone
number. (See the list of types of agencies below.)
b. Get a basic description of the type of assistance the property receives.
Additional Requirements for HUD's LSHR Mar 09 A2-8
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EPA Certified Renovation Firms and Certified Renovators
Additional Requirements of HUD's Lead Safe Housing Rule
Note: You should be able to explain to the owner that there will be information
about the work that you will need, and that you also need to check if there are
any special requirements.
2. If you have any questions about the Federal or State lead-based paint
requirements that apply to the work, contact the public agency administering the
assistance and discuss the project with the program specialist or rehabilitation
specialist working with the property. For example:
a. Is the project considered lead abatement? If so, what are the agency's
abatement requirements?
b. If the project is not abatement, what are the agency's lead-based paint
requirements for the project, and how should they be incorporated into the
work write-up?
Some types of public agencies administering housing assistance, such as
rehabilitation or acquisition assistance, include:
. State Housing Agency, Corporation or Authority
. State Community Development Agency, Corporation or Authority
. State Housing Finance Agency
. City or County Housing Authority, Corporation or Authority
. City or County Community Development Agency, Corporation or Authority
. USDA Service Center - Rural Housing Programs
Additional Requirements for HUD's LSHR Mar 09 A2-9
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Appendix 3:
Renovate Right: Important Lead
Hazard Information for
Families, Child Care Providers
and Schools
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Important Lead Hazard
Information for Families,
Child Care Providers
and Schools
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It's the Law!
Federal law requires that individuals receive certain information before
renovating six square feet or more of painted surfaces in a room for interior
projects or more than twenty square feet of painted surfaces for exterior
projects in housing, child care facilities and schools built before 1978.
Homeowners and tenants: renovators must give you this pamphlet
before starting work.
Child care facilities, including preschools and kindergarten classrooms,
and the families of children under the age of six that attend those facilities:
renovators must provide a copy of this pamphlet to child-care facilities and
general renovation information to families whose children attend those facilities.
Also, beginning April 2010, federal law will require contractors that disturb
lead-based paint in homes, child care facilities and schools, built before 1978
to be certified and follow specific work practices to prevent lead contamination.
Therefore beginning in April 2010, ask to see your contractor's certification.
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Renovating, Repairing, or Painting?
Is your home, your building, or the child care facility or
school your children attend, being renovated, repaired,
or painted?
Was your home, your building, or the child care facility
or school your children under age 6 attend, built
before 1978?
If the answer to these questions is YES, there are a
few important things you need to know about lead-
based paint.
This pamphlet provides basic facts about lead and
information about lead safety when work is being done
in your home, your building or the childcare facility or
school your children attend.
The Facts About Lead
Lead can affect children's brains and developing nervous systems, causing
reduced IQ, learning disabilities, and behavioral problems. Lead is also harmful
to adults.
Lead in dust is the most common way people are exposed to lead. People
can also get lead in their bodies from lead in soil or paint chips. Lead dust is
often invisible.
Lead-based paint was used in more than 38 million homes until it was banned
for residential use in 1978.
Projects that disturb lead-based paint can create dust and endanger you and
your family. Don't let this happen to you. Follow the practices described in this
pamphlet to protect you and your family.
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- -> -
Who Should Read This Pamphlet?
This pamphlet is for you if you:
Reside in a home built before 1978,
Own or operate a child care facility, including preschools and kindergarten
classrooms, built before 1978, or
Have a child under six who attends a child care facility built before 1978.
You will learn:
Basic facts about lead and your health,
How to choose a contractor, if you are a property owner,
What tenants, and parents/guardians of a child in a child care facility or
school should consider,
How to prepare for the renovation or repair job,
What to look for during the job and after the job is done,
Where to get more information about lead.
This pamphlet is not for:
Abatement projects. Abatement is a set of activities aimed specifically at
eliminating lead or lead hazards. EPA has regulations for certification and
training of abatement professionals. If your goal is to eliminate lead or lead
hazards, contact the National Lead Information Center at 1 -800-424-LEAD
(5323) for more information.
"Do-it-yourself" projects. If you plan to do renovation work yourself, this
document is a good start, but you will need more information to complete
the work safely. Call the National Lead Information Center at 1-800-424-LEAD
(5323) and ask for more information on how to work safely in a home with
lead-based paint.
Contractor education. Contractors who want information about working
safely with lead should contact the National Lead Information Center at
1-800-424-LEAD (5323) for information about courses and resources on
lead-safe work practices.
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Lead and Your Health
\
Lead is especially dangerous to children
under six years of age.
Lead can affect children's brains and
developing nervous systems, causing:
Reduced IQ and learning disabilities.
Behavior problems.
Even children who appear healthy can have
dangerous levels of lead in their bodies.
Lead is also harmful to adults. In adults, low
levels of lead can pose many dangers, including:
High blood pressure and hypertension.
Pregnant women exposed to lead can transfer
lead to their fetus.
Lead gets into the body when it is swallowed
or inhaled.
People, especially children, can swallow lead dust as they eat, play, and
do other normal hand-to-mouth activities.
People may also breathe in lead dust or fumes if they disturb lead-based paint.
People who sand, scrape, burn, brush or blast or otherwise disturb lead-based
paint risk unsafe exposure to lead.
What should I do if I am concerned about my family's exposure to lead?
Call your local health department for advice on reducing and eliminating
exposures to lead inside and outside your home, child care facility or school.
Always use lead-safe work practices when renovation or repair will disturb
lead-based paint.
A blood test is the only way to find out if you or a family member already
has lead poisoning. Call your doctor or local health department to arrange
for a blood test.
For more information about the health effects of exposure to lead, visit
the EPA lead website at www.epa.gov/lead/pubs/leadinfo.htm or call
1-800-424-LEAD(5323).
There are other things you can do to protect your family everyday.
Regularly clean floors, window sills, and other surfaces.
Wash children's hands, bottles, pacifiers, and toys often.
Make sure children eat a healthy, nutritious diet consistent with the USDA's
dietary guidelines, that helps protect children from the effects of lead.
Wipe off shoes before entering house.
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Where Does the Lead Come From?
Dust is the main problem. The most common way to get lead in the body is from
dust. Lead dust comes from deteriorating lead-based paint and lead-contaminated
soil that gets tracked into your home. This dust may accumulate to unsafe levels.
Then, normal hand to-mouth activities, like playing and eating (especially in young
children), move that dust from surfaces like floors and window/sills into the body.
Home renovation creates dust. Common renovation activities like sanding,
cutting, and demolition can create hazardous lead dust and chips.
Proper work practices protect you from the dust. The key to protecting yourself
and your family during a renovation, repair or painting job is to use lead-safe work
practices such as containing dust inside the work area, using dust-minimizing work
methods, and conducting a careful cleanup, as described in this pamphlet.
Other sources of lead. Remember, lead can also come from outside soil,
your water, or household items (such as lead-glazed pottery and lead crystal).
Contact the National Lead Information Center at 1 -800-424-LEAD (5323) for
more information on these sources.
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Checking Your Home for
Lead-Based Paint
CO
fl> Between
E 1960 -1978
O
^ Between
*r 1940 - 1960
*
Before 1940
Percentage of Homes Likely to Contain Lead
|.& 24%
69%
87%
\^ \^ \^
10 20 30 40 50 60 70 80 90 100
Older homes, child care facilities, and schools are more likely to contain
lead-based paint. Homes may be single-family homes or apartments. They may
be private, government-assisted, or public housing. Schools are preschools and
kindergarten classrooms. They may be urban, suburban, or rural.
You have the following options:
You may decide to assume your home, child care facility, or school contains
lead. Especially in older homes and buildings, you may simply want to assume
lead-based paint is present and follow the lead-safe work practices described in
this brochure during the renovation, repair, or painting job.
You or your contractor may also test for lead using a lead test kit. Test kits
must be EPA-approved and are available at hardware stores. They include detailed
instructions for their use.
You can hire a certified professional to check for lead-based paint. These
professionals are certified risk assessors or inspectors, and can determine if your
home has lead or lead hazards.
A certified inspector or risk assessor can conduct an inspection telling you
whether your home, or a portion of your home, has lead-based paint and
where it is located. This will tell you the areas in your home where lead-safe
work practices are needed.
A certified risk assessor can conduct a risk assessment telling you if your home
currently has any lead hazards from lead in paint, dust, or soil. The risk assessor
can also tell you what actions to take to address any hazards.
For help finding a certified risk assessor or inspector, call the National Lead
Information Center at 1 -800-424-LEAD (5323).
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For Property Owners
You have the ultimate responsibility for the safety of your family, tenants,
or children in your care. This means properly preparing for the renovation and
keeping persons out of the work area (see p. 8). It also means ensuring the
contractor uses lead-safe work practices.
Beginning April 2010, federal law will require that contractors performing
renovation, repair and painting projects that disturb lead-based paint in homes,
child care facilities, and schools built before 1978 to be certified and follow
specific work practices to prevent lead contamination.
Until contractors are required to be certified, make sure your contractor
can explain clearly the details of the job and how the contractor will minimize
lead hazards during the work.
Ask if the contractor is trained to perform lead-safe work practices and to
see a copy of their training certificate.
Ask them what lead-safe methods they will use to set up and perform the
job in your home, child care facility or school.
Ask if the contractor is aware of the lead renovation rules. For example,
contractors are required to provide you with a copy of this pamphlet before
beginning work. A sample pre-renovation disclosure form is provided at the
back of this pamphlet. Contractors may use this form to make documentation
of compliance easier.
Ask for references from at least three recent jobs involving homes built
before 1978, and speak to each personally.
Always make sure the contract is clear about how the work will be set up,
performed, and cleaned.
Share the results of any previous lead tests with the contractor.
Even before contractors are required to be certified you should specify in the
contract that they follow the work practices described on pages 9 and 10 of
this brochure.
The contract should specify which parts of your home are part of the work
area and specify which lead-safe work practices should be used in those areas.
Remember, your contractor should confine dust and debris to the work area
and should minimize spreading that dust to other areas of the home.
The contract should also specify that the contractor clean the work area, verify
that it was cleaned adequately, and re-clean it if necessary.
Once these practices are required, if you think a worker is failing to do what
they are supposed to do or is doing something that is unsafe, you should:
Direct the contractor to comply with the contract requirements,
Call your local health or building department, or
Call EPA's hotline 1 -800-424-LEAD (5323).
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For Tenants, and Families of Children
Under Age Six in Child Care Facilities
and Schools
You play an important role ensuring the ultimate
safety of your family.
This means properly preparing for the renovation and
staying out of the work area (see p. 8).
ginning April 2010, federal law will require that
contractors performing renovation, repair and painting
projects that disturb lead-based paint in homes, child
care facilities and schools built before 1978 that a child
under age six visits regularly to be certified and follow
specific work practices to prevent lead contamination.
The law will require anyone hired to renovate, repair, or
do painting preparation work on a property built before
1978 to follow the steps described on pages 9 and 10
unless the area where the work will be done contains
no lead-based paint.
Once these practices are required, if you think a worker is failing to do what
they are supposed to do or is doing something that is unsafe, you should:
Contact your landlord,
Call your local health or building department, or
Call EPA's hotline 1 -800-424-LEAD (5323).
If you are concerned about lead hazards left behind after the job is over, you can
check the work yourself (see page 10).
If your property receives housing assistance from HUD (or a state or local agency
that uses HUD funds), you must follow the more stringent requirements of HUD's
Lead-safe Housing Rule and the ones described in this pamphlet.
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Preparing for a Renovation
The work areas should not be accessible to occupants while the work
occurs. The rooms or areas where work is being done may be blocked off or
sealed with plastic sheeting to contain any dust that is generated. The contained
area will not be available to you until the work in that room or area is complete,
cleaned thoroughly, and the containment has been removed. You will not have
access to some areas and should plan accordingly.
You may need:
Alternative bedroom, bathroom, and kitchen arrangements if work is
occurring in those areas of your home.
A safe place for pets because they, too, can be poisoned by lead and can
track lead dust into other areas of the home.
A separate pathway for the contractor from the work area to the outside, in
order to bring materials in and out of the home. Ideally, it should not be through
the same entrance that your family uses.
A place to store your furniture. All furniture and belongings may have to be
moved from the work area while the work is done. Items that can't be moved,
such as cabinets, should be wrapped in heavy duty plastic.
To turn off forced-air heating and air conditioning systems while work is done.
This prevents dust from spreading through vents from the work area to the rest
of your home. Consider how this may affect your living arrangements.
You may even want to move out of your home temporarily while all
or parts of the work are being done.
Child care facilities and schools may want to consider alternative
accommodations for children and access to necessary facilities.
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During the Work
ginning April 2010, federal law will require
contractors that are hired to perform renovation,
repair and painting projects in homes, child care
facilities, and schools built before 1978 that disturb
lead-based paint to be certified and follow specific
work practices to prevent lead contamination.
Even before contractors are required to be certified
and follow specific work practices, the contractor
should follow these three simple procedures,
described below:
1. Contain the work area. The area should be
contained so that dust and debris do not escape
from that area. Warning signs should be put up
and heavy-duty plastic and tape should be used
as appropriate to:
Cover the floors and any furniture that cannot be moved.
Seal off doors and heating and cooling system vents.
These will help prevent dust or debris from getting outside the work area.
2. Minimize dust. There is no way to eliminate dust, but some methods make
less dust than others. For example, using water to mist areas before sanding
or scraping; scoring paint before separating components; and prying and
pulling apart components instead of breaking them are techniques that
generate less dust than alternatives. Some methods generate large amounts
of lead-contaminated dust and should not be used. They are:
Open flame burning or torching.
Sanding, grinding, planing, needle gunning, or blasting with power tools
and equipment not equipped with a shroud and HEPA vacuum attachment.
Using a heat gun at temperatures greater than 1100ฐF.
3. Clean up thoroughly. The work area should be cleaned up daily to keep it as
clean as possible. When all the work is done, the area should be cleaned up
using special cleaning methods before taking down any plastic that isolates
the work area from the rest of the home. The special cleaning methods
should include:
Using a HEPA vacuum to clean up dust and debris on all surfaces,
followed by
Wet mopping with plenty of rinse water.
When the final cleaning is done, look around. There should be no dust, paint chips,
or debris in the work area. If you see any dust, paint chips, or debris, the area
should be re-cleaned.
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For Property Owners:
After the Work is Done
When all the work is finished, you will want to know if your home, child care
facility, or school has been cleaned up properly. Here are some ways to check.
Even before contractors are required to be certified and follow specific work
practices, you should:
Ask about your contractor's final cleanup check. Remember, lead dust is often
invisible to the naked eye. It may still be present even if you cannot see it. The
contractor should use disposable cleaning cloths to wipe the floor of the work area
and compare them to a cleaning verification card to determine if the work area was
adequately cleaned.
To order a cleaning verification card and detailed instructions visit the EPA lead
website at www.epa.gov/lead or contact the National Lead Information Center at
1-800-424-LEAD (5323) or visit their website at www.epa.gov/lead/nlic.htm.
You also may choose to have a lead-dust test. Lead-dust tests are wipe
samples sent to a laboratory for analysis.
You can specify in your contract that a lead-dust test will be done. In this case,
make it clear who will do the testing.
Testing should be done by a lead professional.
If you choose to do the testing, some EPA-recognized lead laboratories will send
you a kit that allows you to collect samples and send them back to the lab for
analysis.
Contact the National Lead Information Center at 1-800-424-LEAD (5323) for lists
of qualified professionals and EPA-recognized lead labs.
If your home, child care facility, or
school fails the dust test, the area
should be re-cleaned and tested again.
Where the project is done by contract, it
is a good idea to specify in the contract
that the contractor is responsible for
re-cleaning if the home, child care
facility, or school fails the test.
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For Additional Information
You may need additional information on how to protect yourself and your
children while a job is going on in your home, your building, or childcare
facility.
The National Lead Information Center at 1 -800-424-LEAD (5323) or
www.epa.gov/lead/nlic.htm can tell you how to contact your state,
local, and/or tribal programs or get general information about lead
poisoning prevention.
State and tribal lead poisoning prevention or
environmental protection programs can provide
information about lead regulations and potential
sources of financial aid for reducing lead
hazards. If your State or local government has
requirements more stringent than those
described in this pamphlet, you must follow
those requirements.
Local building code officials can tell you the
regulations that apply to the renovation work that
you are planning.
State, county, and local health departments
can provide information about local programs,
including assistance for lead-poisoned children
and advice on ways to get your home checked
for lead.
The National Lead Information Center can also
provide a variety of resource materials, including
the following guides to lead-safe work practices.
Many of these materials are also available at
www.epa.gov/lead/pubs/brochure.htm.
Lead Paint Safety, a Field Guide for Painting,
Home Maintenance, and Renovation Work
Protect Your Family from Lead in Your Home
Lead in Your Home: A Parent's Reference Guide
For the hearing impaired, call the Federal Information Relay Service at
1-800-877-8339 to access any of the phone numbers in this brochure.
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EPA Contacts
EPA Regional Offices
EPA addresses residential lead hazards through several different regulations.
EPA requires training and certification for conducting abatement, education about
hazards associated with renovations, disclosure about known lead paint and lead
hazards in housing, and sets lead-paint hazard standards.
Your Regional EPA Office can provide further information regarding lead safety and
lead protection programs at www.epa.gov/lead.
Region 1
(Connecticut,
Massachusetts, Maine,
New Hampshire, Rhode
Island, Vermont)
Regional Lead Contact
U.S. EPA Region 1
Suite 1100
One Congress Street
Boston, MA 02114-2023
i 372-7341
Region 2
(New Jersey, New York,
Puerto Rico, Virgin Islands)
Regional Lead Contact
U.S. EPA Region 2
2890 Woodbridge Avenue
Building 205, Mail Stop 225
Edison, NJ 08837-3679
(732)321-6771
Region 3
(Delaware, Maryland,
Pennsylvania, Virginia,
Washington, DC,
West Virginia)
Regional Lead Contact
U.S. EPA Region 3
1650 Arch Street
Philadelphia, PA
19103-2029
(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 30303-8960
(404) 562-9900
Region 5
(Illinois, Indiana,
Michigan, Minnesota,
Ohio, Wisconsin)
Regional Lead Contact
U.S. EPA Region 5
77 West Jackson Boulevard
Chicago, IL 60604-3507
(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)665-6444
Region 7
(Iowa, Kansas,
Missouri, Nebraska)
Regional Lead Contact
U.S. EPA Region 7
901 N. 5th Street
Kansas City, KS66101
(913)551-7003
Region 8
(Colorado, Montana,
North Dakota, South
Dakota, Utah, Wyoming)
Regional Lead Contact
U.S. EPA Region 8
1595 Wynkoop Street
Denver, CO 80202
(303)312-6312
Region 9
(Arizona, California,
Hawaii, Nevada)
Regional Lead Contact
U.S. Region 9
75 Hawthorne Street
San Francisco, CA94105
(415)947-8021
Region 10
(Alaska, Idaho,
Oregon, Washington)
Regional Lead Contact
U.S. EPA Region 10
1200 Sixth Avenue
Seattle, WA 98101-1128
(206)553-1200
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Other Federal Agencies
CPSC
The Consumer Product Safety
Commission (CPSC) protects the
public from the unreasonable risk of
injury or death from 15,000 types of
consumer products under the agency's
jurisdiction. CPSC warns the public
and private sectors to reduce exposure
to lead and increase consumer
awareness. Contact CPSC for further
information regarding regulations and
consumer product safety.
CPSC
4330 East West Highway
Bethesda, MD20814
Hotline 1-(800) 638-2772
www.cpsc.gov
CDC Childhood Lead
Poisoning Prevention Branch
The Centers for Disease Control
and Prevention (CDC) assists state
and local childhood lead poisoning
prevention programs to provide a
scientific basis for policy decisions,
and to ensure that health issues are
addressed in decisions about housing
and the environment. Contact CDC
Childhood Lead Poisoning Prevention
Program for additional materials and
links on the topic of lead.
CDC Childhood Lead Poisoning
Prevention Branch
4770 Buford Highway, MS F-40
Atlanta, GA 30341
(770) 488-3300
www.cdc.gov/nceh/lead
HUD Office of Healthy Homes
and Lead Hazard Control
The Department of Housing and
Urban Development (HUD) provides
funds to state and local governments
to develop cost-effective ways to
reduce lead-based paint hazards in
America's privately-owned low-income
housing. In addition, the office enforces
the rule on disclosure of known lead
paint and lead hazards in housing,
and HUD's lead safety regulations in
HUD-assisted housing, provides public
outreach and technical assistance,
and conducts technical studies to help
protect children and their families from
health and safety hazards in the home.
Contact the HUD Office of Healthy
Homes and Lead Hazard Control for
information on lead regulations, out-
reach efforts, and lead hazard control
research and outreach grant programs.
U.S. Department of Housing
and Urban Development
Office of Healthy Homes
and Lead Hazard Control
451 Seventh Street, SW, Room 8236
Washington, DC 20410-3000
HUD's Lead Regulations Hotline
(202) 402-7698
www.hud.gov/offices/lead/
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-------
Current Sample Pre-Renovation Form
Effective until April 2010.
Confirmation of Receipt of Lead Pamphlet
Q I have received a copy of the pamphlet, Renovate Right: Important Lead Hazard
Information for Families, Child Care Providers and Schools informing me of
the potential risk of the lead hazard exposure from renovation activity to be
performed in my dwelling unit. I received this pamphlet before the work began.
Printed name of recipient Date
Signature of recipient
Self-Certification Option (for tenant-occupied dwellings only)
If the lead pamphlet was delivered but a tenant signature was not obtainable,
you may check the appropriate box below.
Q Refusal to sign I certify that I have made a good faith effort to deliver the
pamphlet, Renovate Right: Important Lead Hazard Information for Families,
Child Care Providers and Schools, to the rental dwelling unit listed below at the
date and time indicated and that the occupant refused to sign the confirmation
of receipt. I further certify that I have left a copy of the pamphlet at the unit with
the occupant.
Q Unavailable for signature I certify that I have made a good faith effort to
deliver the pamphlet, Renovate Right: Important Lead Hazard Information for
Families, Child Care providers and Schools, to the rental dwelling unit listed
below and that the occupant was unavailable to sign the confirmation of receipt.
I further certify that I have left a copy of the pamphlet at the unit by sliding it
under the door.
Printed name of person certifying Attempted delivery
date and time
lead pamphlet delivery
Signature of person certifying lead pamphlet delivery
Unit Address
Note Regarding Mailing Option As an alternative to delivery in person, you
may mail the lead pamphlet to the owner and/or tenant. Pamphlet must be mailed
at least 7 days before renovation (Document with a certificate of mailing from the
post office).
-------
3
-------
Future Sample Pre-Renovation Form
This sample form may be used by renovation firms to document compliance with the
Federal pre-renovation education and renovation, repair, and painting regulations.
Occupant Confirmation
Pamphlet Receipt
Q I have received a copy of the lead hazard information pamphlet informing me of the
potential risk of the lead hazard exposure from renovation activity to be performed in
my dwelling unit. I received this pamphlet before the work began.
Owner-occupant Opt-out Acknowledgment
Q (A) I confirm that I own and live in this property, that no child under the age of 6
resides here, that no pregnant woman resides here, and that this property is not a
child-occupied facility.
Note: A child resides in the primary residence of his or her custodial parents, legal
guardians, foster parents, or informal caretaker if the child lives and sleeps most of the
time at the caretaker's residence.
Note: A child-occupied facility is a pre-1978 building visited regularly by the same
child, under 6 years of age, on at least two different days within any week, for at least
3 hours each day, provided that the visits total at least 60 hours annually.
If Box A is checked, check either Box B or Box C, but not both.
Q (B) I request that the renovation firm use the lead-safe work practices required
by EPAs Renovation, Repair, and Painting Rule; or
Q (C) I understand that the firm performing the renovation will not be required to use the
lead-safe work practices required by EPAs Renovation, Repair, and Painting Rule.
Printed Name of Owner-occupant
Signature of Owner-occupant Signature Date
Renovator's Self Certification Option (for tenant-occupied dwellings only)
Instructions to Renovator. If the lead hazard information pamphlet was delivered
but a tenant signature was not obtainable, you may check the appropriate box below.
Q Declined - I certify that I have made a good faith effort to deliver the lead hazard
information pamphlet to the rental dwelling unit listed below at the date and time
indicated and that the occupant declined to sign the confirmation of receipt. I further
certify that I have left a copy of the pamphlet at the unit with the occupant.
Q Unavailable for signature - I certify that I have made a good faith effort to deliver
the lead hazard information pamphlet to the rental dwelling unit listed below and that
the occupant was unavailable to sign the confirmation of receipt. I further certify that
I have left a copy of the pamphlet at the unit by sliding it under the door or by (fill in
how pamphlet was left)
Printed Name of Person Certifying Delivery Attempted Delivery Date
Signature of Person Certifying Lead Pamphlet Delivery
Unit Address
Note Regarding Mailing Option As an alternative to delivery in person, you may mail the
lead hazard information pamphlet to the owner and/or tenant. Pamphlet must be mailed at
least seven days before renovation. Mailing must be documented by a certificate of mailing
from the post office.
Note: This form is not effective until April 2010.
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This Page Intentionally Left Blank
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Appendix 4:
Small Entity Compliance Guide to
Renovate Right
-------
United States
Environmental
Protection Agency
Office of Pollution Prevention and Toxics
EPA-740-F-08-003
December 2008
Illllll
Small Entity Compliance
Guide to Renovate Right
EPA's Lead-Based Paint
Renovation, Repair, and
Paintina Proaram
A handbook for contractors,
property managers and
maintenance personnel
working in homes, child
care facilities and schools
built before 1978
-------
Who Should Read this Handbook?
Anyone who owns or manages housing or child-occupied facilities built before 1978.
Contractors who perform activities that disturb painted surfaces in homes and child-occupied facilities
built before 1978 (including certain repairs and maintenance, and painting preparation activities).
About this Handbook
This handbook summarizes requirements of EPA's Lead-Based Paint Renovation, Repair and Painting
Program Rule, aimed at protecting against lead-based paint hazards associated with renovation, repair and
painting activities. The rule requires workers to be trained to use lead-safe work practices and requires reno-
vation firms to be EPA-certified; these requirements will become effective April 22, 2010.
To ensure compliance, you should also read the complete rule on which the program is based. While EPA
has summarized the provisions of the rule in this guide, the legal requirements that apply to renovation work
are governed by EPA's 2008 Lead Rule. A copy of the rule is available on EPA's website at www.epa.gov/
lead/pubs/renovation.
A companion pamphlet, entitled Renovate Right: Important Lead Hazard Information for Families, Child Care
Providers, and Schools (EPA-740-F-08-002), has been prepared in conjunction with the rule for distribution
to persons affected by work that disturbs lead-based paint. (See page 17 for information on how to get cop-
ies of the rule, the Renovate Right pamphlet, and other related materials).
Other state or local requirements that are different from or more stringent than the federal requirements
may apply in your state. For example, federal law allows EPA to authorize states to administer their own pro-
gram in lieu of the federal lead program. Even in states without an authorized lead program, a state
may promulgate its own rules that may be different or go beyond the federal requirements. For more
information on the rules that apply in your state, please contact the National Lead Information Center
at1-800-424-LEAD(5323).
Your feedback is important. Please review this guide and contact the National Lead Information Center
at 1-800-424-LEAD (5323) with any comments regarding its usefulness and readability, and improvements
you think are needed.
This document is published by the Environmental Protection Agency (EPA) as the official compliance
guide for small entities, as required by the Small Business Regulatory Enforcement Fairness Act of 1996
(SBREFA). Before you begin using the guide, you should know that the information in this guide was
compiled and published in June 2008. EPA is continually improving and upgrading its rules, policies,
compliance programs, and outreach efforts. To find out if EPA has revised or supplemented the
information in this guide call the National Lead Information Center at 1 -800-424-LEAD (5323).
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What Is the Lead-Based Paint Renovation, Repair and
Painting Program (RRP)?
The Lead-Based Paint Renovation, Repair and Painting Program is a federal regulatory program affecting
contractors, property managers, and others who disturb painted surfaces.
It applies to residential houses, apartments, and child-occupied facilities such as schools and day-care
centers built before 1978.
It includes pre-renovation education requirements as well as training, certification, and work practice
requirements.
- Pre-renovation education requirements are effective now:
Contractors, property managers, and others who perform renovations for compensation
in residential houses, apartments, and child-occupied facilities built before 1978 are required
to distribute a lead pamphlet before starting renovation work.
- Training, certification, and work practice requirements become effective April 22, 2010:
Firms are required to be certified, their employees must be trained in use of lead-safe work
practices, and lead-safe work practices that minimize occupants' exposure to lead hazards
must be followed.
Renovation is broadly defined as any activity that disturbs painted surfaces and includes most repair,
remodeling, and maintenance activities, including window replacement.
The program includes requirements implementing both Section 402(c) and 406(b) of the Toxic
Substances Control Act (TSCA). (www.epa.gov/lead/pubs/titleten.html)
EPAs lead regulations can be found at 40 CFR Part 745, Subpart E.
How Can this Handbook Help Me?
Understanding the lead program's requirements can help you protect your customers from the hazards of
lead and can, therefore, mean more business for you.
This handbook presents simple steps to follow to comply with the EPAs lead program. It also lists ways
these steps can be easily incorporated into your work.
Distributing the lead pamphlet and incorporating required work practices into your job site will help protect
your customers and occupants from the hazards of lead-based paint.
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Who Must Follow the 2008 Lead Rule's Requirements?
In general, anyone who is paid to perform work that disturbs paint in
housing and child-occupied facilities built before 1978, this may include,
but is not limited to:
- Residential rental property owners/managers
- General contractors
- Special trade contractors, including
Painters
Plumbers
Carpenters
Electricians
What Activities Are Subject to the Lead Renovation, Repair
and Painting Program?
In general, any activity that disturbs paint in pre-1978 housing and child-occupied facilities, including:
Remodeling and repair/maintenance
Electrical work
Plumbing
Painting
Carpentry
Window replacement
What Housing or Activities Are Excluded and Not Subject
to the Rule?
Housing built in 1978 or later.
Housing for elderly or disabled persons, unless children under 6 reside or are expected to
reside there.
Zero-bedroom dwellings (studio apartments, dormitories, etc.).
Housing or components declared lead-free by a certified inspector
or risk assessor.
Minor repair and maintenance activities that disturb 6 square feet or
less of paint per room inside, or 20 square feet or less on the exterior
of a home or building.
Note: minor repair and maintenance activities do not include
window replacement and projects involving demolition or prohibited practices.
-------
What Does the Program Require Me To Do?
Pre-renovation education requirements - Effective now.
In housing, you must:
Distribute EPA's lead pamphlet to the owner and occupants before renovation starts.
In a child-occupied facility, you must:
Distribute the lead pamphlet to the owner of the building or an adult representative of the child-occupied
facility before the renovation starts.
For work in common areas of multi-family housing or child-occupied facilities, you must:
Distribute renovation notices to tenants or parents/guardians of the children attending the
child-occupied facility. Or you must post informational signs about the renovation or repair job.
Informational signs must:
Be posted where they will be seen;
Describe the nature, locations, and dates of the renovation; and
Be accompanied by the lead pamphlet or by information on how parents and guardians can get a free
copy (see page 31 for information on obtaining copies).
Obtain confirmation of receipt of the lead pamphlet (see page 23) from the owner, adult representative, or
occupants (as applicable), or a certificate of mailing from the post office.
Retain records for three years.
Note: Pre-renovation education requirements do not apply to emergency renovations.
Emergency renovations include interim controls performed in response to a resident child
with an elevated blood-lead level.
Training, Certification, and Work Practice Requirements-
Effective after April 22, 2010.
Firms must be certified.
Renovators must be trained.
Lead-safe work practices must be followed. Examples of these practices include:
Work-area containment to prevent dust and debris from leaving the work area.
Prohibition of certain work practices like open-flame burning and the use of power tools without HEPA
exhaust control.
Thorough clean up followed by a verification procedure to minimize exposure to lead-based
paint hazards.
The training, certification, and work practice requirements do not apply where the firm obtained a signed
statement from the owner that all of the following are met:
The renovation will occur in the owner's residence;
No child under age 6 resides there;
No woman who is pregnant resides there;
The housing is not a child-occupied facility; and
The owner acknowledges that the renovation firm will not be required to use the work practices
contained in the rule.
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When Do These Requirements Become Fully Applicable to Me?
- April 2009:
Training providers may begin applying for accreditation.
Once training providers are accredited, they may offer training courses that will allow
renovators to become certified.
- October 2009 - Renovation firms may begin applying to EPA for certification.
- April 2010 - Program fully effective. Work practices must be followed.
How Will a Firm Become Certified?
Beginning in October 2009, firms may apply to EPA for certification to perform renovations or dust sampling.
To apply, a firm must submit to EPA a completed "Application for Firms," signed by an authorized agent of
the firm, and pay the correct amount of fees. To obtain a copy of the "Application for Firms" contact the NLIC
at 1 -800-424-LEAD (5323) or visit www.epa.gov/lead/pubs/renovation.htm.
Ill HII FBI
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What Are the Responsibilities of a Certified Firm?
Firms performing renovations must ensure that:
1. All individuals performing activities that disturb painted surfaces on behalf of the firm are either certified
renovators or have been trained by a certified renovator.
2. A certified renovator is assigned to each renovation and performs all of the certified renovator
responsibilities.
3. All renovations performed by the firm are performed in accordance with the work practice standards of the
Lead-Based Paint Renovation, Repair, and Painting Program (see the flowchart on page 9 for details
about the work practice standards).
4. Pre-renovation education requirements of the Lead-Based Paint Renovation, Repair, and Painting
Program are performed.
5. The program's recordkeeping requirements are met.
How Will a Renovator Become Certified?
To become a certified renovator an individual must successfully complete an eight-hour initial renovator
training course offered by an accredited training provider (training providers are accredited by EPA, or by an
authorized state or tribal program). The course completion certificate serves as proof of certification. Training
providers can apply for accreditation for renovator and dust sampling technician training beginning in April
2009. Once accredited, trainers can begin to provide certification training.
Are There Streamlined Requirements for Contractors with
Previous Lead Training?
Yes. Individuals who have successfully completed an accredited lead abatement worker or supervisor
course, or individuals who have successfully completed an EPA, Department of Housing and Urban
Development (HUD), or EPA/HUD model renovation training course, need only take a four-hour refresher
renovator training course instead of the eight-hour initial renovator training course to become certified.
What Are the Responsibilities of a Certified Renovator?
Certified renovators are responsible for ensuring overall compliance with the Lead-Based Paint Renovation,
Repair, and Painting Program's requirements for lead-safe work practices at renovations they are assigned. A
certified renovator (see the flowchart on page 9 for details about the work practice standards):
1. Must use a test kit acceptable to EPA, when requested by the party contracting for renovation services,
to determine whether components to be affected by the renovation contain lead-based paint (EPA will
announce which test kits are acceptable prior to April 2010. Please check our Web site at www.epa.gov/
lead).
2. Must provide on-the-job training to workers on the work practices they will be using in performing their
assigned tasks.
3. Must be physically present at the work site when warning signs are posted, while the work-area
containment is being established, and while the work-area cleaning is performed.
-------
4. Must regularly direct work being performed by other individuals to ensure that the work practices are
being followed, including maintaining the integrity of the containment barriers and ensuring that dust or
debris does not spread beyond the work area.
5. Must be available, either on-site or by telephone, at all times renovations are being conducted.
6. Must perform project cleaning verification.
7. Must have with them at the work site copies of their initial course completion certificate and their most
recent refresher course completion certificate.
8. Must prepare required records.
How Long Will Firm and Renovator Certifications Last?
To maintain their certification, renovators and firms must be re-certified by EPA every five years. A firm must
submit to EPA a completed "Application for Firms," signed by an authorized agent of the firm, and pay the
correct amount of fees. Renovators must successfully complete a refresher training course provided by an
accredited training provider.
What Are the Recordkeeping Requirements?
All documents must be retained for three years following the completion of a renovation.
Records that must be retained include:
Reports certifying that lead-based paint is not present.
Records relating to the distribution of the lead pamphlet.
Any signed and dated statements received from owner-occupants documenting that the requirements
do not apply (i.e., there is no child under age 6 or no pregnant woman who resides at the home, and it
is not a child-occupied facility).
Documentation of compliance with the requirements of the Lead-Based Paint Renovation,
Repair, and Painting Program (EPA has prepared a sample form that is available at
www.epa.gov/lead/pubs/samplechecklist.pdf).
What Are the Required Work Practices?
The flow charts on the following pages will help determine if your project is subject to the Lead-Based
Paint Renovation, Repair and Painting Program's requirements and, if so, the specific requirements for
your particular project. The flowcharts, and other information included in this guide, are not intended
to be a replacement for official training.
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EPA's Lead Program Rule At-A-Glance
Do the Requirements Apply to the Renovation?
If you will be getting paid to do work that disturbs painted surfaces in a pre-1978 home, apartment
building, or child-occupied facility, answer the questions below to determine if the EPA lead program
requires you to distribute the lead pamphlet and/or if you will need to comply with training, certification,
and work practice requirements when conducting the work.
Does the job involve activities that disturb painted surfaces
home or child-occupied facility built before 1978?
in a
I MUM IB Ul
^^^^^
Are ANY of the following conditions present?
The work is a lead abatement project.
Work consists of only minor repairs or maintenance that
disturbs less than 6 square feet of painted surfaces per room
for interior activities or less than 20 square feet of painted
surface for exterior activities. Note: this does not include
window replacement, demolition, and projects involving
prohibited practices.
Housing has been determined to be free of lead-based paint
either by a certified inspector or risk assessor, or the
components being renovated have been determined to be
free of lead-based paint by a certified renovator using an
EPA recognized test kit.
Housing is a zero-bedroom dwelling (studio apartments,
dormitories, etc.).
Housing is for the elderly or disabled and no children under
six reside or are expected to reside there.
EPA
lead-based
paint renovation,
repair, and
painting program
requirements
do not apply.
Is the project an emergency renovation?
Emergency renovations are:
1. Activities that were not planned and if not immediately
attended to present a safety hazard or threaten equipment
and/or property with significant damage.
OR
2. Interim controls performed in response to an elevated blood
lead level in a resident child.
You will need to provide the lead pamphlet.
See Flow Chart 2 for specific requirements.
Pre-renovation
education
requirements
of the program
do not apply.
See Flow Chart 3
to determine which
specific renovation
training and work
practice requirements
apply to the job.
Flow Chart 1
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How Do I Comply with the Pre-Renovation Education Requirements?
Requirements to distribute pre-renovation educational materials vary based on the location of the
renovation. Select the location below that best describes the location of your project, and follow the
applicable procedure on the right.
Renovations in
Owner-Occupied
Dwelling Units
Renovations in
Tenant-Occupied
Dwelling Units
Renovations in
Common Areas
of Multi-Family
Housing Units
Renovations in
Child-Occupied
Facilities
Deliver lead pamphlet to owner before renovation begins and
obtain confirmation of receipt.
OR
Mail lead pamphlet to owner 7 days before renovation begins
and document with certificate of mailing.
r
1. Provide lead pamphlet to owner using either procedure
described in the box at the top of this page.
2. Provide lead pamphlet to tenant by either method below:
(a) Deliver pamphlet to dwelling unit before renovation
begins and document delivery with either a confirmation
of receipt of lead pamphlet or a self-certification of
delivery.
OR
(b) Mail lead pamphlet to tenant at least 7 days prior to
renovation and document with a certificate of mailing.
Provide owner with lead pamphlet using either procedure
described in the box at the top of this page.
Notify tenants and make pamphlet available, or post signs
describing the renovation. The signs must include the
pamphlet or information on how to review a copy.
Maintain written documentation describing notification
procedures.
Provide supplemental renovation notice if changes occur in
location, timing, or scope of renovation occurring.
1. Provide the owner of the building with the lead pamphlet
using either:
(a) The procedure described in the box at the top of this
page.
OR
OR
(b) If the child-occupied facility is not the building owner,
provide the lead pamphlet by either method below:
(i) Obtain a written acknowledgment that an adult
representative received the pamphlet; or certify in
writing that a pamphlet was delivered.
(ii) Obtain a certificate of mailing at least 7 days before the
renovation.
2. Provide the parents or guardians of children using the child-
occupied facility with information by either of these methods:
(a) Mail or hand-deliver the lead pamphlet and renovation
information to each parent or guardian.
k
OR
) Post signs describing the renovation. The signs must
include the pamphlet or information on how to review
a copy.
See
Flow
Chart 3
for
information
about
specific
training
and work
practice
requirements
for the job.
Flow Chart 2
-------
Do the Renovation Training and Work Practices Apply?
Has the firm obtained a signed statement from the owner that:
1. The renovation will occur in the owner's residence;
2. No child under age 6 resides there;
3. No woman who is pregnant resides there;
4. The housing is not a child-occupied facility; AND
5. Owner acknowledges that the renovation firm will not be
required to use the work practices contained in the rule.
~^^^^r
Is the project an emergency renovation?
^^^^^
Does the project include interim controls performed in
response to an elevated blood lead level of a resident
child?
^^^^^
Emergency projects are exempt from the warning sign,
containment, waste handling, training, and certification
requirements to the extent necessary to respond to the
emergency. Emergency renovations are NOT exempt
from the cleaning and cleaning verification requirements.
See Flow Chart 5 for interior cleaning and cleaning
verification requirements, and Flow Chart 8 for exterior
cleaning and verification requirements.
Training
and
work
practice
requirements
do not apply.
Continue to
Flow Chart 4
for work
practice
requirements.
Flow Chart 3
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Work Practice Requirements
General
(A) Renovations must be performed by certified firms using certified renovators.
(B) Firms must post signs clearly defining the work area and warning occupants and other persons
not involved in renovation activities to remain outside of the work area. These signs should be
in the language of the occupants.
(C) Prior to the renovation, the firm must contain the work area so that no dust or debris leaves
the work area while the renovation is being performed.
(D) Work practices listed below are prohibited during a renovation:
1. Open-flame burning or torching of lead-based paint;
2. Use of machines that remove lead-based paint through high speed operation such as
sanding, grinding, power planing, needle gun, abrasive blasting, or sandblasting, unless
such machines are used with HEPA exhaust control; and
3. Operating a heat gun on lead-based paint at temperatures of 1100 degrees Fahrenheit or higher.
(E) Waste from renovations:
1. Waste from renovation activities must be contained to prevent releases of dust and debris
before the waste is removed from the work area for storage or disposal.
2. At the conclusion of each work day and at the conclusion of the renovation, waste that has
been collected from renovation activities must be stored to prevent access to and the release
of dust and debris.
3. Waste transported from renovation activities must be contained to prevent release of dust
and debris.
Interior
Renovation
Projects.
See Flow
Chart 5.
Exterior
Renovation
Projects.
See Flow
Chart 8.
10
Flow Chart 4
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Work Practice Requirements Specific to Interior Renovations
The firm must:
(A) Remove all objects from the work area or cover them with plastic sheeting with all seams and
edges sealed.
(B) Close and cover all ducts opening in the work area with taped-down plastic sheeting.
(C) Close windows and doors in the work area. Doors must be covered with plastic sheeting.
(D) Cover the floor surface with taped-down plastic sheeting in the work area a minimum of six feet
beyond the perimeter of surfaces undergoing renovation or a sufficient distance to contain the
dust, whichever is greater.
(E) Use precautions to ensure that all personnel, tools, and other items, including the exteriors of
containers of waste, are free of dust and debris when leaving the work area.
(F) After the renovation has been completed, the firm must clean the work area until no dust, debris or
residue remains. The firm must:
1. Collect all paint chips and debris, and seal it in a heavy-duty bag.
2. Remove and dispose of protective sheeting as waste.
3. Clean all objects and surfaces in the work area and within two feet of the work area in the
following manner:
a. Clean walls starting at the ceiling and working down to the floor by either vacuuming with a
HEPA vacuum or wiping with a damp cloth.
b. Thoroughly vacuum all remaining surfaces and objects in the work area, including furniture
and fixtures, with a HEPA vacuum.
c. Wipe all remaining surfaces and objects in the work area, except for carpeted or
upholstered surfaces, with a damp cloth. Mop uncarpeted floors thoroughly using a
mopping method that keeps the wash water separate from the rinse water, or using a
wet mopping system.
Cleaning verification is required to ensure the work area
is adequately cleaned and ready for re-occupancy.
See Flow Chart 6 for instructions on performing cleaning
verification for interior projects.
Flow Chart 5
11
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Interior Cleaning Verification: Visual Inspection and Optional
Clearance Testing
Certified renovator must perform a visual inspection.
Is dust, debris or residue present?
The area must be
re-cleaned and another
visual inspection must
be performed.
Does the contract, or another federal, state, territorial, tribal, or
local regulation, require clearance testing at the conclusion of the
renovation?
Are the dust clearance samples required to be collected
by a certified inspector, risk assessor or dust sampling
technician, and is the renovation firm required to re-clean the
work area until the dust clearance sample results are below
applicable clearance standards?
When you meet the applicable clearance standards
you Ye finished!
Continue to
cleaning
verification
procedure.
See Flow
Chart 7.
12
Flow Chart 6
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Interior Cleaning Verification: Floors, Countertops, and Window Sills
Note: For areas greater than 40 square feet, separate the area into sections and use a new disposable
cleaning cloth for each section.
Certified renovator must wipe all uncarpeted floors, countertops,
and windowsills within the work area with a wet disposable clean-
ing cloth. Is the cloth used for any area darker than the cleaning
verification card?
Re-clean the areas that failed using the procedures from Flow
Chart 5, then use a new wet disposable cleaning cloth to wipe
those areas again. Is the cloth used for any area darker than the
cleaning verification card?
Wait until either the area has dried completely or 1 hour has
passed, whichever is longer. Once dry, wipe that area with a dry
disposable cleaning cloth.
The
work area
has been
adequately
cleaned
and
warning
signs
maybe
removed.
You're finished!
Flow Chart 7
13
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Work Practice Requirements Specific to Exterior Renovations
The firm must:
(A) Close all doors and windows within 20 feet of the renovation.
(B) Ensure that doors within the work area that will be used while the job is being performed are
covered with plastic sheeting in a manner that allows workers to pass through while confining
dust and debris.
(C) Cover the ground with plastic sheeting or other disposable impermeable material extending a
minimum of 10 feet beyond the perimeter or a sufficient distance to collect falling paint debris,
whichever is greater.
(D) In situations such as where work areas are in close proximity to other buildings, windy conditions,
etc., the renovation firm must take extra precautions in containing the work area, like vertical
containment.
(E) After the renovation has been completed, the firm must clean the work area until no dust, debris
or residue remains. The firm must:
1. Collect all paint chips and debris, and seal it in a heavy-duty bag.
2. Remove and dispose of protective sheeting as waste.
3. Waste transported from renovation activities must be contained to prevent release of dust and
debris.
A certified renovator must perform a visual inspection.
Is dust, debris or residue present?
~^^^^^"
"^^^^^
These conditions
must be eliminated
and another visual
inspection must
be performed.
The area has
been adequately
cleaned; remove
the warning signs.
You're finished!
14
Flow Chart 8
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How Is My Compliance Determined, and What Happens if the
Agency Discovers a Violation?
To maximize compliance, EPA implements a balanced program of compliance assistance, compliance incen-
tives, and traditional law enforcement. EPA knows that small businesses that must comply with complicated
new statutes or rules often want to do the right thing, but may lack the requisite knowledge, resources, or
skills. Compliance assistance information and technical advice helps small businesses to understand and
meet their environmental obligations. Compliance incentives, such as EPAs Small Business Policy, apply to
businesses with 100 or fewer employees and encourage persons to voluntarily discover, disclose, and cor-
rect violations before they are identified by the government (more information about EPAs Small Business
Policy is available at www.epa.gov/compliance/incentives/smallbusiness/index.html). EPAs enforcement
program is aimed at protecting the public by targeting persons or entities who neither comply nor cooperate
to address their legal obligations.
EPA uses a variety of methods to determine whether businesses are complying, including inspecting work
sites, reviewing records and reports, and responding to citizen tips and complaints. Under TSCA, EPA (or
a state, if this program has been delegated to it) may file an enforcement action against violators seeking
penalties of up to $32,500 per violation, per day. The proposed penalty in a given case will depend on many
factors, including the number, length, and severity of the violations, the economic benefit obtained by the
violator, and its ability to pay. EPA has policies in place to ensure penalties are calculated fairly. These policies
are available to the public. In addition, any company charged with a violation has the right to contest EPAs
allegations and proposed penalty before an impartial judge or jury.
EPA encourages small businesses to work with the Agency to discover, disclose, and correct violations.
The Agency has developed self-disclosure, small business, and small community policies to modify penal-
ties for small and large entities that cooperate with EPA to address compliance problems. In addition, EPA
has established compliance assistance centers to serve over one million small businesses (see Construction
Industry Compliance Assistance Center for information regarding this rule at www.cicacenter.org). For more
information on compliance assistance and other EPA programs for small businesses, please contact EPAs
Small Business Ombudsman at 202-566-2075.
15
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Frequent Questions
What is the legal status of this guide?
This guide was prepared pursuant to section 212 of SBREFA. EPA has tried to help explain in this guide
what you must do to comply with the Toxic Substances Control Act (TSCA) and EPAs lead regulations.
However, this guide has no legal effect and does not create any legal rights. Compliance with the procedures
described in this guide does not establish compliance with the rule or establish a presumption or inference
of compliance. The legal requirements that apply to renovation work are governed by EPAs 2008 Lead Rule,
which controls if there is any inconsistency between the rule and the information in this guide.
Is painting considered renovation if no surface preparation activity occurs?
No. If the surface to be painted is not disturbed by sanding, scraping, or other activities that may
cause dust, the work is not considered renovation and EPAs lead program requirements do not apply.
However, painting projects that involve surface preparation that disturbs paint, such as sanding and
scraping, would be covered.
What if I renovate my own home?
EPAs lead program rules apply only to renovations performed for compensation; therefore, if you work on
your own home, the rules do not apply. EPA encourages homeowners to use lead-safe work practices,
nonetheless, in order to protect themselves, their families, and the value of their homes.
Is a renovation performed by a landlord or employees of a property management
firm considered a compensated renovation under EPA's lead program rules?
Yes. The receipt of rent payments or salaries derived from rent payments is considered compensation under
EPAs lead program. Therefore, renovation activities performed by landlords or employees of landlords are
covered.
Do I have to give out the lead pamphlet seven days prior to beginning renovation
activities?
The 7-day advance delivery requirement applies only when you deliver the lead pamphlet by mail;
otherwise, you may deliver the pamphlet anytime before the renovation begins so long as the renovation
begins within 60 days of the date that the pamphlet is delivered. For example, if your renovation is to begin
May 30, you may deliver the pamphlet in person anytime between April 1 and start of the project on May 30,
or you may deliver the pamphlet by mail anytime between April 1 and May 23.
Tips for Easy Compliance
1. For your convenience the sample forms on pages 23 and 25 of this handbook are included in the
Renovate Right pamphlet (see page 31 for information on how to get copies). Attach the forms to
the back of your customer renovation or repair contracts. The completed forms can be filed along
with your regular paperwork.
2. Plan ahead to obtain enough copies of the lead pamphlet (see page 31 for information on how to
get copies of the pamphlet).
16
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Where Can I Get More Information?
Further information is available from the National Lead Information Center (800-424-LEAD) and on
the Internet at www.epa.gov/lead. Available resources include:
Full text version of the Lead-Based Paint Renovation, Repair, and Painting Program regulation.
Interpretive guidance which provides more detailed information on the rule's requirements.
A downloadable version of the lead pamphlet.
Why Is Lead Paint Dangerous?
Lead gets into the body when it is swallowed or inhaled. People,
especially children, can swallow lead dust as they eat, play, and do
other normal hand-to-mouth activities. People may also breathe in
lead dust or fumes if they disturb lead-based paint. People who
sand, scrape, burn, brush, blast or otherwise disturb lead-based
paint risk unsafe exposure to lead.
Lead is especially dangerous to children under 6 years of age.
Lead can affect children's brains and developing nervous
systems, causing:
Reduced IQ and learning disabilities.
Behavioral problems.
Even children who appear healthy can have dangerous levels of lead in their bodies.
Lead is also harmful to adults. In adults, low levels of
lead can pose many dangers, including:
High blood pressure and hypertension.
Pregnant women exposed to lead can transfer lead to
their fetus.
17
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Other Resources
For additional information on how to protect yourself and your customers from lead paint hazards,
visit www.epa.gov/lead or call the National Lead Information Center at 1-800-424-LEAD (5323).
Available documents include:
Renovate Right: Important Lead Hazard Information for Families, Child Care Providers and Schools
Joint EPA-HUD Curriculum: Lead Safety for Remodeling, Repair, and Painting
Lead Paint Safety: A Field Guide for Painting, Home Maintenance, and Renovation Work
Testing Your Home for Lead in Paint, Dust, and Soil
Fight Lead Poisoning with a Healthy Diet
Protect Your Family From Lead in Your Home
Lead in Your Home: A Parent's Reference Guide
e
B Remodeling, I
Repair,* Painting '
18
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Key Terms
Certificate of Mailing A written verification from fhe Postal Service that you mailed the lead pamphlet
to an owner or a tenant. This is less expensive than certified mail, which is also acceptable for meeting the
Lead-Based Paint Renovation, Repair, and Painting Program requirements. (Note: If using this delivery
option, you must mail the pamphlet at least seven days prior to the start of renovation.)
Certified Inspector or Risk Assessor An individual who has been trained and is certified by EPA or an
authorized state or Indian Tribe to conduct lead-based paint inspections or risk assessments.
Child-occupied Facility May include, but is not limited to, day care centers, pre-schools and kindergar-
ten classrooms. Child-occupied facilities may be located in target housing or in public or commercial build-
ings. The regulation defines a "child-occupied facility" as a building, or portion of a building, constructed
prior to 1978, visited regularly by the same child, under 6 years of age, on at least two different days within
any week (Sunday through Saturday period), provided that each day's visit lasts at least three hours and the
combined weekly visits last at least six hours, and the combined annual visits last at least 60 hours.
Cleaning Verification Card a card developed and distributed, or otherwise approved, by EPA for the
purpose of determining, through comparison of wet and dry disposable cleaning cloths with the card,
whether post-renovation cleaning has been properly completed.
Common Area A portion of a building that is generally accessible to all residents or users. Common
areas include (but are not limited to) hallways, stairways, laundry rooms, recreational rooms, playgrounds,
community centers, and fenced areas. The term applies to both interiors and exteriors of the building.
(Note: Lead-Based Paint Renovation, Repair, and Painting Program requirements related to common
areas apply only to multi-family housing.)
Component A specific design or structural element or fixture distinguished by its form, function, and
location. A component can be located inside or outside the dwelling.
Examples
Interior
Ceilings
Crown molding
Walls
Doors and trim
Floors
Fireplaces
Radiators
Shelves
Stair treads
Windows and trim
Built-in cabinets
Beams
Bathroom vanities
Counter tops
Air conditioners
Exterior
Painted roofing
Chimneys
Flashing
Gutters and downspouts
Ceilings
Soffits
Doors and trim
Fences
Floors
Joists
Handrails
Window sills and sashes
Air conditioners
19
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Confirmation of Receipt of Lead Hazard Information Pamphlet A form that is signed by the owner or
tenant of the housing confirming that they received a copy of the lead pamphlet before the renovation began.
(See sample on page 23.)
Emergency Renovation Unplanned renovation activities 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.
Examples
Renovation to repair damage from a tree that fell on a house.
Renovation to repair a burst water pipe in an apartment complex.
Interim controls performed in response to an elevated blood lead level in a resident child.
Firm A company, partnership, corporation, sole proprietorship or individual doing business, association,
or other business entity; a Federal, State, Tribal, or local government agency; or a nonprofit organization.
General Contractor One who contracts for the construction of an entire building or project,
rather than for a portion of the work. The general contractor hires subcontractors (e.g. plumbing,
electrical, etc.), coordinates all work, and is responsible for payment to subcontractors.
Housing for the Elderly Retirement communities or similar types of housing specifically reserved for
households of one or more persons 62 years of age or older at the time the unit is first occupied.
Interim Controls Interim controls means a set of measures designed to temporarily reduce
human exposure or likely exposure to lead-based paint hazards, including specialized cleaning, repairs,
maintenance, painting, temporary containment, ongoing monitoring of lead-based paint hazards or potential
hazards, and the establishment and operation of management and resident education programs.
Lead Abatement Work designed to permanently eliminate lead-based paint hazards. If you are hired to
do lead-abatement work only, the Lead-Based Paint Renovation, Repair, and Painting Program does not
apply. Abatement does not include renovation, remodeling, or other activities done to repair, restore, or
redesign a given building even if such renovation activities incidentally eliminate lead-based paint hazards.
(Note: Some states define this term differently than described above. Consult your state officials if you are
not sure how "lead abatement" is defined in your state.)
Lead Pamphlet The lead hazard information pamphlet for the purpose of pre-renovation education is
Renovate Right: Important Lead Hazard Information for Families, Child Care Facilities and Schools, or an
EPA-approved alternative pamphlet. (See page 31 for information on obtaining copies.)
20
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Minor Repair and Maintenance Activities that disrupt 6 square feet or less of painted surface per room
for interior activities or 20 square feet or less of painted surface for exterior activities where none of the
prohibited work practices is used and where the work does not involve window replacement or demolition of
painted surface areas. When removing painted components, or portions of painted components, the entire
surface area removed is the amount of painted surface disturbed. Jobs, other than emergency renovations,
performed in the same room within the same 30 days must be considered the same job for the purpose of
determining whether the job is a minor repair and maintenance activity.
Owner Any person or entity that has legal title to housing, including individuals, partnerships,
corporations, government agencies, Indian Tribes, and nonprofit organizations.
Prohibited Practices Work practices listed below are prohibited during a renovation:
Open-flame burning or torching of lead-based paint;
Use of machines that remove lead-based paint through high speed operation such as sanding,
grinding, power planing, needle gun, abrasive blasting, or sandblasting, unless such machines are
used with HEPA exhaust control; and
Operating a heat gun on lead-based paint at temperatures above 1100 degrees Fahrenheit.
Record of Notification A written statement documenting the steps taken to notify occupants of
renovation activities in common areas of multi-family housing. (See page 27 for sample.)
Renovation Modification of all or part of any existing structure that disturbs a painted surface,
except for some specifically exempted activities (e.g., minor repair and maintenance). Includes:
Removal/modification of painted surfaces, components, or structures
Surface preparation activities (sanding/scraping/other activities that may create paint dust)
Window replacement
Examples
1. Demolition of painted walls or ceilings
2. Replastering
3. Plumbing repairs or improvements
4. Any other activities which disturb painted surfaces
Renovation Notice Notice to tenants of renovations in common areas of multi-family housing. (See
sample form on page 27.) Notice must describe nature, location, and expected timing of renovation activity;
and must explain how the lead pamphlet may be obtained free of charge.
Renovator A person who either performs or directs workers who perform renovation. A certified renovator
is a renovator who has successfully completed a renovator course accredited by EPA or an EPA authorized
State or Tribal program. (Note: Because the term "renovation" is defined broadly by the Lead-Based Paint
Renovation, Repair, and Painting Program, many contractors who are not generally considered "renovators",
as that term is commonly used, are considered to be "renovators" under the program and must follow the
rule's requirements.)
21
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Self-Certification of Delivery An alternative
method of documenting delivery of the lead hazard
information pamphlet to a tenant. This method may be
used whenever the tenant is unavailable or unwilling to
sign a confirmation of receipt of lead pamphlet. (See
sample form on page 23.) (Note: This method is not a
permissible substitute for delivery of the lead pamphlet
to an owner.)
Supplemental Renovation Notice additional
notification that is required when the scope, location,
or timing of project changes.
Zero-Bedroom Dwelling Any residential
dwelling where the living area is not separated from
the sleeping area. This term includes efficiency and
studio apartments, dormitory housing, and military
barracks.
22
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Current Sample Pre-Renovation Form
For use until April 2010.
Confirmation of Receipt of Lead Pamphlet
I have received a copy of the lead pamphlet informing me of the potential risk of the lead hazard
exposure from renovation activity to be performed in my dwelling unit. I received this pamphlet before
the work began.
Printed name of recipient Date
Signature of recipient
Self-Certification Option (for tenant-occupied dwellings only) If the lead pamphlet was delivered but a
tenant signature was not obtainable, you may check the appropriate box below.
Refusal to sign I certify that I have made a good faith effort to deliver the lead pamphlet to the rental
dwelling unit listed below at the date and time indicated and that the occupant refused to sign the
confirmation of receipt. I further certify that I have left a copy of the pamphlet at the unit with the
occupant.
Unavailable for signature I certify that I have made a good faith effort to deliver the lead pamphlet
to the rental dwelling unit listed below and that the occupant was unavailable to sign the confirmation of
receipt. I further certify that I have left a copy of the pamphlet at the unit by sliding it under the door.
Printed name of person certifying attempted delivery
Date and time lead pamphlet delivery
Signature of person certifying lead pamphlet delivery
Unit Address
Note Regarding Mailing Option As an alternative to delivery in person, you may mail the lead pamphlet
to the owner and/or tenant. Pamphlet must be mailed at least 7 days before renovation (Document with a
certificate of mailing from the post office).
23
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30
\
'
24
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Future Sample Pre-Renovation Form
This sample form may be used by firms to documenf compliance wifh fhe requirements of fhe Federal
Lead-Based Painf Renovafion, Repair, and Painting Program after April 2010.
Occupant Confirmation
Pamphlet Receipt
I have received a copy of the lead hazard information pamphlet informing me of the potential risk of the
lead hazard exposure from renovation activity to be performed in my dwelling unit. I received this
pamphlet before the work began.
Owner-occupant Opt-out Acknowledgment
(A) I confirm that I own and live in this property, that no child under the age of 6 resides here, that no
pregnant woman resides here, and that this property is not a child-occupied facility.
Note: A child resides in the primary residence of his or her custodial parents, legal guardians, foster parents,
or informal caretaker if the child lives and sleeps most of the time at the caretaker's residence.
Note: A child-occupied facility is a pre-1978 building visited regularly by the same child, under 6 years of
age, on at least two different days within any week, for at least 3 hours each day, provided that the visits
total at least 60 hours annually.
If Box A is checked, check either Box B or Box C, but not both.
(B) I request that the renovation firm use the lead-safe work practices required by EPAs Lead-Based
Paint Renovation, Repair, and Painting Rule; or
(C) I understand that the firm performing the renovation will not be required to use the lead-safe work
practices required by EPAs Lead-Based Paint Renovation, Repair, and Painting Rule.
Printed Name of Owner-occupant
Signature of Owner-occupant Signature Date
Renovator's Self Certification Option (for tenant-occupied dwellings only)
Instructions to Renovator: If the lead hazard information pamphlet was delivered but a tenant signature was
not obtainable, you may check the appropriate box below.
Declined - I certify that I have made a good faith effort to deliver the lead hazard information pamphlet
to the rental dwelling unit listed below at the date and time indicated and that the occupant declined to
sign the confirmation of receipt. I further certify that I have left a copy of the pamphlet at the unit with
the occupant.
Unavailable for signature -1 certify that I have made a good faith effort to deliver the lead hazard
information pamphlet to the rental dwelling unit listed below and that the occupant was unavailable to
sign the confirmation of receipt. I further certify that I have left a copy of the pamphlet at the unit by
sliding it under the door or by (fill in how pamphlet was left).
Printed Name of Person Certifying Delivery Attempted Delivery Date
Signature of Person Certifying Lead Pamphlet Delivery
Unit Address
Note Regarding Mailing Option As an alternative to delivery in person, you may mail the lead
hazard information pamphlet to the owner and/or tenant. Pamphlet must be mailed at least 7 days
before renovation. Mailing must be documented by a certificate of mailing from the post office.
25
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'
PRO
26
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Sample Forms (continued)
Renovation Notice For use in notifying tenants of renovations in common areas of multi-family
housing.
The following renovation activities will take place in the following locations:
Activity (e.g., sanding, window replacement)
Location (e.g., lobby, recreation center)
The expected starting date is and the expected ending date is .
Because this is an older building built before 1978, some of the paint disturbed during the renovation
may contain lead. You may obtain a copy of the pamphlet, Renovate Right, by telephoning me
at . Please leave a message and be sure to include your name,
phone number and address. I will either mail you a pamphlet or slide one under your door.
Date Printed name of renovator
Signature of renovator
Record of Tenant Notification Procedures Future Sample Renovation Recordkeeping Checklist
Project Address
Street (apt. #)
City State Zip Code
Owner of multi-family housing Number of dwelling units
Method of delivering notice forms (e.g. delivery to units, delivery to mailboxes of units)
Name of person delivering notices
Signature of person delivering notices Date of Delivery
27
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'
f
28
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Future Sample Renovation Recordkeeping Checklist
(effective April 2010)
Name of Firm:.
Date and Location of Renovation:.
Brief Description of Renovation:
Name of Assigned Renovator:
Name(s) of Trained Worker(s), if used:.
Name of Dust Sampling Technician,
Inspector, or Risk Assessor, if used:_
Copies of renovator and dust sampling technician qualifications (training certificates, certifications) on file.
Certified renovator provided training to workers on (check all that apply):
Posting warning signs Setting up plastic containment barriers
Maintaining containment Avoiding spread of dust to adjacent areas
Waste handling Post-renovation cleaning
Test kits used by certified renovator to determine whether lead was present on components affected
by renovation (identify kits used and describe sampling locations and results):
Warning signs posted at entrance to work area.
Work area contained to prevent spread of dust and debris
All objects in the work area removed or covered (interiors)
HVAC ducts in the work area closed and covered (interiors)
Windows in the work area closed (interiors)
Windows in and within 20 feet of the work area closed (exteriors)
Doors in the work area closed and sealed (interiors)
Doors in and within 20 feet of the work area closed and sealed (exteriors)
Doors that must be used in the work area covered to allow passage but prevent spread of dust
Floors in the work area covered with taped-down plastic (interiors)
Ground covered by plastic extending 10 feet from work areaplastic anchored to building and
weighed down by heavy objects (exteriors)
If necessary, vertical containment installed to prevent migration of dust and debris to adjacent
property (exteriors)
Waste contained on-site and while being transported off-site.
Work site properly cleaned after renovation
All chips and debris picked up, protective sheeting misted, folded dirty side inward, and taped
for removal
Work area surfaces and objects cleaned using HEPA vacuum and/or wet cloths or mops (interiors)
Certified renovator performed post-renovation cleaning verification (describe results, including the
number of wet and dry cloths used):
Jf dust clearance testing was performed instead, attach a copy of report
I certify under penalty of law that the above information is true and complete.
Name and title Date
29
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30
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Where Can I Get Copies of the Lead Pamphlet?
For single copies, in Spanish or English, of Renovate Right: Important Lead Hazard Information for
Families, Child Care Facilities and Schools (EPA-740-F-08-002), call the National Lead Information
Center (NLIC) at 1 -800-424-LEAD. For any orders, be sure to use the appropriate stock reference
number listed above.
There are four ways to get multiple copies:
1. Call the Government Printing Office order desk at
(202)512-1800.
2. Send fax requests to (202) 512-2233.
3. Request copies in writing from:
Superintendent of Documents
P.O. Box 371954
Pittsburgh, PA 15250-7954
4. Obtain copies via the Internet at
www.epa.gov/lead/pubs/brochure.htm
For single copies, in Spanish or English, of
Renovate Right: Important Lead Hazard Information
for Families, Child Care Facilities and Schools
(EPA-740-F-08-002), call the National Lead Information
Center (NLIC) at 1 -800-424-LEAD. For any orders,
be sure to use the appropriate stock reference
number listed above.
The pamphlet may be photocopied for distribution as long as the text
and graphics are readable.
Paperwork Reduction Act Notice: The incremental public burden for the collection of information contained in the Lead
Renovation, Painting and Repair Program, which are approved under OMB Control No. 2070-0155 and identified under
EPA ICR No. 1715, is estimated to average approximately 54 hours per year for training providers. For firms engaged
in regulated renovation, repair, and painting activities, the average incremental burden is estimated to be about 6.5
hours per year. Comments regarding this burden estimate or any other aspect of this collection of information, includ-
ing suggestions for reducing the burden, may be sent to: Director, Collection Strategies Division, Office of Environmental
Information, U.S. Environmental Protection Agency (Mail Code 2822T), 1200 Pennsylvania Avenue, N.W., Washington,
D.C. 20460. Include the OMB number identified above in any correspondence. Do not send any completed form(s) to
this address. The actual information or form(s) should be submitted in accordance with the instructions accompanying
the form(s), or as specified in the corresponding regulations.
31
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NOTICE
This guide was prepared pursuant to section 212 of the Small Business Regulatory
Enforcement Fairness Act of 1996 (SBREFA), Pub. L. 104-121. THIS DOCUMENT IS NOT
INTENDED, NOR CAN IT BE RELIED UPON, TO CREATE ANY RIGHTS ENFORCEABLE
BY ANY PARTY IN LITIGATION WITH THE UNITED STATES. The statements in this
document are intended solely as guidance to aid you in complying with the Lead-Based
Paint Renovation, Repair, and Painting Program requirements in 40 CFR 745, Subpart E.
EPA may decide to revise this guide without public notice to reflect changes in EPA's
approach to implementing the Lead-Based Paint Renovation, Repair, and Painting
Program or to clarify and update text. To determine whether EPA has revised this guide
and/or to obtain copies, contact EPA's Small Business Ombudsman at 202-566-2075,
or contact the National Lead Information Center at 1-800-424-LEAD(5323), or on the
web at www.epa.gov/lead/pubs/nlic.htm.
1 -800-424-LEAD (5323)
www.epa.gov/lead
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This Page Intentionally Left Blank
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Appendix 5:
Steps to LEAD SAFE
Renovation, Repair and Painting
-------
Steps to -
LEAD SAFE
Renovation, Repair
and Painting ^
>
S-EPA
United States
Environmental Protection
Agency
1-800-424-LEAD
www.epa.gov/lead
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'
Renovating, Repairing or Painting?
Are you working on a home renovation, repair or painting project?
Does the project involve a home built before 1978?
If so, you need to know how to work safely with lead-based paint. This
guide is designed to help contractors and homeowners plan for and
complete a home renovation, repair or painting project using lead safe work
practices. Lead safe work practices are a group of techniques that reduce
the amount of dust produced by renovation activities. When used correctly,
they make the work area safer for workers and the home safe for residents
when renovation is complete. Following lead safe work practices will allow
you to:
Set up the job safely;
Minimize the creation of dangerous lead dust; and
Leave the work area clean and safe for residents after completing the
job.
Contractors, Painters, Landlords! If you are working"
in a home or child-occupied facility built before
1978, you are required to provide information about
lead-based paint to occupants and owners of homes,
and owners and parents of child-occupied facilities.
For more information, see page 33.
Beginning in April 2010, renovation, repair and paint-
ing contractors must be certified and use lead safe
work practices when working in homes built before 1978.
For more information, see page 6.
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Table of Contents
Learn the Facts About Lead-Based Paint
The Renovation, Repair and Painting Program Rule
Other Federal and State Regulations1'j
Step 1: Determine if the Job Involy/Bs t
Step 2: Set It Up Safely
Step 3: Protect Yourself
Step 4: Minimize the Dust
Step 5: Leave the Work Area Clean
Step 6: Control the Waste
fc__
Step 7: Verify Work Completion with the
Verification Procedure or Clearjice1
Learn More About Lead Safety
Other Resources
Pre-Renovation Education Requirements
Shopping List
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Learn the Facts about
Lead-Based Paint
About half of homes built before 1978 have lead-based paint. The
likelihood of finding lead-based paint increases with the age of the home:
Two out of three of homes built between 1940 and 1960 have
lead-based paint.
Nine out of ten homes built before 1940 have lead-based paint.
Older Homes are More Likely to
Contain Lead-Based Paint
in
I
ซ
o
I
Betvreen 1960-1977
Betvwen 1940-1959
Before 1940
'25%
\ -s\\ - x\> Oฃ^Q/
-jj!3ฃhป3Jฃr 86%
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Percentage of Homes Containing Lead-Based Paint
Source: American Healtny Homes Survey: Draft Final Report for Peer Review: Lead and Arsenic
F/ncxngs October 7, 2008
Lead-based paint may be found on any surface in the homeinside
or outside. When lead-based paint is disturbed during renovation, repair
or painting activities, dangerous amounts of lead dust can be created.
Jobs such as demolition, window replacement, opening up walls, etc., can
also release accumulated lead dust into the home. Even after a typical
renovation cleanup, dangerous levels of lead dust can remain.
-------
Lead gets into the body when it is swallowed or breathed.
People, especially children, can swallow lead dust as they eat, play,
and perform other ordinary hand-to-mouth activities.
People may also breathe in lead dust or fumes while they work
on jobs that sand, scrape, burn, brush, blast or otherwise disturb
painted surfaces that contain lead paint.
Additionally, pets may be poisoned by the same types of exposure
to lead.
Once in the body, lead can have significant effects on
human health.
In children, lead poisoning damages the nervous system and
causes developmental and behavioral problems that can affect
them for their lifetime.
In adults, lead poisoning causes health and reproductive problems.
Pregnant women are especially vulnerable to the effects of lead.
Research has shown that general residential renovation activities
are associated with an increased risk of elevated lead levels in
children.
By working
safely you can
help prevent
lead exposure
and poisoning.
This guide tells
you how.
-------
&EPA
United States
Environmental Protection
Agency
The Renovation,
Repair and Painting
Program Rule
This section summarizes requirements of EPA's Lead-Based Paint
Renovation, Repair and Painting (RRP) Program Rule for contractors,
and provides guidance to homeowners/occupants, so that each may
learn to properly address lead-based paint hazards associated with
renovation, repair and painting activities.
The RRP rule affects contractors, property managers and others who
disturb known or presumed lead-based paint during renovation. The
term renovation covers all activities done for compensation that disturb
painted surfaces including most repair, remodeling and maintenance
activities, such as window replacement, weatherization and demoli-
tion. The RRP rule applies to all renovation work performed in residential
houses, apartments and child-occupied facilities such as schools and
day-care centers built before 1978. Those affected by the RRP rule
should read the complete rule, which is available on EPA's Web site at:
http://www.epa.gov/lead/pubs/renovation.htm.
Training, certification, and work practice requirements in the Renovation,
Repair and Painting Rule are effective April 22, 2010. Pre-renovation
education requirements are effective now.
Requirements for Renovation Contractors Include:
Certification and Training Requirements
All firms performing renovation, repair or painting work must
become certified. This can be accomplished by applying to EPA or
to the State, if it has an EPA-authorized renovation program, and
paying a fee.
Firms must have one or more "Certified Renovators" assigned to
jobs where lead-based paint is disturbed. To become certified, a
renovator must successfully complete an EPA or State-approved
training course conducted by an EPA or State-accredited training
provider.
All renovation workers must be trained. Renovation workers can be
trained on-the-job by a Certified Renovator to use lead safe work
practices, or they can become Certified Renovators themselves.
-------
Pre-Renovation Education Requirements
Contractors, property managers and others who perform renova-
tions for compensation in residential houses, apartments, and child-
occupied facilities built before 1978 are required to distribute EPA's
Renovate Right lead hazard information pamphlet before starting
renovation work to occupants and owners of homes, and owners
and parents of child-occupied facilities. More information about
pre-renovation education requirements can be found on page 33.
Work Practice Requirements
Renovators must use work-area containment to prevent
dust and debris from leaving the work area.
Certain work practices are prohibited. Open-flame
burning, using heat guns at greater than 1,100 degrees
Fahrenheit and the use of power tools without high-
efficiency particulate air (HEPA) exhaust control (to collect
dust generated) are prohibited.
Thorough cleaning followed by a cleaning verification procedure to
minimize exposure to lead-based paint hazards are required.
Generally, minor repair and maintenance activities (less than 6
square feet per interior room or 20 square feet per exterior project)
are exempt from the work practices requirements. However, this
exemption does not apply to jobs involving window replacement or
demolition, or that involve the use of any of the prohibited practices
listed above.
-------
Exemption from the RRP Rule
The training, certification and work practice requirements do not apply
where the firm obtains a signed statement from the owner that all of the
following conditions are met:
The renovation will occur in the owner's residence;
No child under age 6 resides there;
No woman who is pregnant resides there;
The housing is not a child-occupied facility; and,
The owner acknowledges that the renovation firm will not be
required to use the work practices contained in the rule.
Homeowners Working in Their Own Homes
The RRP rule applies only to renovations performed for compensation.
If you work on your own home, the rules do not apply. Even so, EPA
encourages homeowners to use lead safe work practices, in order to
protect themselves, their families, and the value of their homes.
Landlords Working in Their Own Property
Landlords receive rental payments and maintenance personnel in rental
property or child-occupied facilities receive wages or salaries derived
from rent payments. This is considered compensation under the RRP
rule. Therefore, renovation and repair activities performed by landlords
or employees of landlords are covered by the rule. Work performed by
landlords or their employees in pre-1978 housing and child-occupied
facilities must be performed using lead safe work practices, if lead-based
paint or presumed lead-based paint is disturbed.
-------
Other Federal and
State Regulations
The U.S. Department of Housing and Urban Development (HUD)
Lead Safe Housing Rule
HUD's Lead Safe Housing Rule (24 CFR Part 35) covers pre-1978
federally-owned or assisted housing and federally-owned housing that is
being sold. It does not cover child-occupied facilities outside of residen-
tial housing. The requirements of HUD's rule are similar to EPA's RRP
rule, but there are some differences in the details, including:
Exemptions. HUD's rule does not allow owners of federally-
assisted housing to opt out of its requirements.
Training Requirements. HUD does not recognize on-the-job
training. To conduct lead hazard control in federally-assisted
housing, either all workers must have completed a HUD-approved
course, or the crew must be supervised by a Certified Renovator
who is also a Certified Lead Abatement Supervisor.
Minor Repair and Maintenance. HUD's definition of minor repair
and maintenance that is exempt from its rule is different than EPA's
(2 square feet interior and 20 square feet exterior or 10 percent of
the surface area of a small building component type).
Other differences between the EPA and HUD rules (concerning paint
testing, prohibited practices, clearance testing and waste disposal) are
pointed out in the appropriate places.
State and Local Regulations
Other state or local requirements that are different from or more stringent
than the federal requirements may apply. For example, federal law allows
EPA to authorize states to administer their own lead renovation program
in place of the federal lead program. Even in states without an authorized
lead renovation program, a state may promulgate its own rules that may
be different or go beyond the federal requirements.
For more information on the rules that apply in your state, please contact
the National Lead Information Center at 1-800-424-LEAD (5323) or
www.epa.gov/lead/nlic.htm.
-------
tfYTIl
Determine If the Job
Involves Lead-Based
Paint
Before you begin a job, consider whether lead-based paint will be
an issue.
Find Out the Age of the Home or Child-Occupied Facility.
The age of a home can tell you a lot about whether lead-based paint is
likely to be present.
If it was built before 1978, it may have lead-based paint.
The older the home, the greater the likelihood that lead is present in
the paint and accumulated dust.
Consider when additions were built. Some parts of the home may
have been built later than others. Later additions are less likely to
contain lead-based paint and contaminated dust.
Lead-based paint may be found either inside or outside the home
and is most common in kitchens or bathrooms and in high gloss
paint on trim, such as on window sills, door frames, and railings.
Look for Information About Lead.
Information about lead-based paint in your home may be readily
available. Under a federal disclosure law, when a pre-1978 home is sold
or leased, the seller/landlord must provide information to the buyer/
tenant about any known lead-based paint. Homeowners should check
their records to see if they have information about lead-based paint and
share this information with anyone performing work on the home.
10
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Consider Lead Testing.
If a home was built before 1978, you must either assume that lead-
based paint is present or have the work area tested for lead-based paint
before starting the job. There are two options for testing paint in a home
under the Renovation, Repair and Painting Rule:
1. Paint testing by a certified lead-based paint inspector or lead-
based paint risk assessorThese licensed professionals conduct a
surface-by-surface investigation for lead-based paint by collecting
paint chips for laboratory analysis or by testing painted surfaces
with an machine called an X-Ray Fluorescence Analyzer (XRF) which
measures the amount of lead in the paint.
2. Paint testing by a Certified RenovatorCertified Renovators, at the
request of the homeowner, can use EPA-recognized chemical spot
test kits to test all painted surfaces affected by the renovation.
Note: HUD does not recognize testing by a Certified Renovator using
spot test kits. In housing covered by the HUD Lead Safe Housing Rule,
only the first option is allowed.
All surfaces affected by a renovation covered by the Renovation,
Repair and Painting Rule must either be tested for lead-based paint or
presumed to contain lead-based paint. Testing must include all affected
surfaces coated with paint, shellac, varnish, stain, coating or even paint
covered by wallpaper, if it will be disturbed during the renovation work.
A report documenting the testing must list the surfaces tested and the
surfaces which contain lead-based paint. If lead-based paint is present
on an affected surface, then the lead safe work practices described in
this pamphlet must be used on the job.
For a list of certified lead testing professionals in your area, contact the
National Lead Information Center at 1-800-424-LEAD (5323) or visit
http://cfpub.epa.gov/flpp.
Remember, if the home was built before 1978 and there is no information
available about the paint, renovators must presume lead-based paint is
present and use the lead safe work practices described in this pamphlet.
Make sure everyone involved on the job, including workers, supervisors
and residents, uses proper safety precautions.
11
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CAUTIOM Set It Up Safely
When you work on a job with lead-based paint, you should
separate the work area from the rest of the home. The goal of
proper setup of the work area is to keep dust in the work area and
non-workers out.
The work area is the area that may become contaminated during the
work. The size of the work area may vary depending on the method used
to disturb lead-based paint and the amount of dust and debris that is
generated as a result. Whenever lead-based paint is disturbed, the work
area must be protected by plastic sheeting applied to the floor, ground
or other applicable surfaces to prevent contamination of the home or
exterior, from dust generated by the work.
The Renovation, Repair and Painting Rule requires that the work area
be protected by plastic sheeting that extends a minimum of 6 feet in
all directions from the location where paint will be disturbed. The Rule
further requires that protective plastic sheeting extend far enough from
the location of paint disturbance so that all dust or debris generated by
the work remains within the area protected by the plastic. The entire
portion of the home or exterior that is protected by plastic sheeting,
however large, is the work area.
Unauthorized persons and pets must be prevented from entering the
work area. This can be accomplished by posting warning signs and by
establishing barriers around the work area such as barrier tape, fencing,
plastic barriers in doorways, etc.
12
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Shopping List
Here is a list of supplies and tools you will need to set up the work area
safely. These items are available in hardware, paint or garden supply stores.
Materials to Restrict Access and Cover the Floor/Ground
a Signs
Q Barrier tape, rope or fencing
Q Cones
Q Heavy duty plastic sheeting
Q Tape (masking, duct or painter's)
a Stapler
Q Utility knife or scissors
What To Do
To keep the dust in and people out of your work area, you will need to take
the steps below for inside or outside jobs. Some jobs create more dust
than others and, therefore, call for additional precautions.
For Inside Jobs
Have occupants leave the room where the work will be done and
have them stay outside of the work area until after the final cleanup.
Place signs, barrier tape and/or cones to keep all non-workers,
especially children, out of the work area. Keep pets out of the work
area for their safety and to prevent them from tracking dust and debris
throughout the home. Signs should be in the primary language of
the occupants and should say "Do Not Enter - Authorized Personnel
Only" and "No Eating, Drinking, or Smoking."
13
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Remove furniture and belongings from the work area. These items
may include: drapes, curtains, furniture, rugs, etc. If an item is too
large to move, cover it with heavy plastic sheeting and tape the
sheeting securely in place.
Use heavy plastic sheeting to cover floors in the work area, to a
minimum of 6 feet from the area of paint disturbance. Secure with
tape.
Close all doors in the work area, including closet and cabinet doors,
and cover with plastic sheeting. When the work area boundary
includes a door used to access the work area, cover the door with
two layers of protective sheeting as described here:
Cut and secure one layer of
sheeting to the perimeter of
the doorframe. Do not pull the
sheeting taut. Rather, create a
few folds to leave slack at the
top and bottom of the door
before taping or stapling.
Cut a vertical slit in the middle of
the sheeting leaving 6" uncut at
the top and bottom. Reinforce
with tape.
Cut and secure a second,
overlapping layer of sheeting to
the top of the door.
Close and cover air vents in the work area. This will keep dust from
getting into vents and moving through the home. You may need to
turn off your HVAC system to prevent damage to the system.
Put all necessary tools and supplies on the protective sheeting
before you begin work to avoid stepping off the protective sheeting
before the work is complete.
14
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For Outside Jobs
Keep non-workers away from the work area by marking it off with
signs, tape and/or cones.
Cover the ground and plants with heavy plastic sheeting to catch
debris. The covering should extend at least 10 feet out from the
building. Secure the covering to the exterior wall with a wood strip
and staples, or tape.
Close windows and doors within 20 feet of the work area to keep
dust and debris from getting into the home.
Move or cover any play areas that are within 20 feet of the work
area.
When working on the 2nd story or above, extend the sheeting
farther out from the base of the home and to each side of the area
where paint is being disturbed.
Vertical shrouding on scaffolding should be used if work is close
to a sidewalk, street, or property boundary, or the building is more
than three stories high.
Avoid working in high winds if possible. The EPA Renovation, Repair
and Painting Rule does not specifically address wind speed, but
when the wind is strong enough to move dust and debris, special
precautions need to be taken to keep the work area contained.
That may mean creating a wind screen of plastic at the edge of
the ground-cover plastic to keep dust and debris from migrating.
Ultimately, you are responsible for preventing dust and debris from
leaving the work area, so take appropriate precautions when wind is
a factor.
Put all necessary tools and supplies on the protective sheeting
before you begin work to avoid stepping off the protective sheeting
before the work is complete.
15
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I
Protect Yoursei
Workers should protect themselves.
Without the right personal protective equipment, workers may ingest
or inhale lead from the job and may risk bringing lead from the worksite
home to their families. The following items are available through
hardware, paint, garden supply stores or other specialty suppliers.
Shopping List
Q Protective eye wear
Q Painter's hat
Q Disposable coveralls
Q Disposable N-100 rated respirator
Q Disposable latex/rubber gloves
Q Disposable shoe covers
What to Do
Protect your eyes.
Always wear safety goggles or safety glasses when scraping,
hammering, etc.
Keep clothes clean.
Wear disposable protective clothing covers. Disposable protective
clothing covers can be stored in a plastic bag and reused if they are
fairly clean and are not torn. Small tears can be repaired with duct
tape.
At the end of the work period, vacuum off dust, and remove dispos-
able protective clothing covers. Do not use compressed air to blow
dust off disposable protective clothing covers or clothing.
Do not hug other people until you have taken off your work clothes.
Then, wash your work clothes separately from family laundry.
16
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Wear disposable shoe covers to prevent the tracking of dust from
the work area and to protect your shoes from exposure to dust.
Wear gloves to protect your hands and prevent exposure to dust.
Wear a painter's hat to protect your head from dust and debris.
These are easy to dispose of at the end of the day.
Wear respiratory protection.
When work creates dust or paint chips, workers should wear respiratory
protection, such as an N-100 disposable respirator, to prevent them from
breathing leaded dust.
Post a warning sign.
Post a sign at the work entrance reminding workers to avoid eating,
drinking and smoking in the work area.
Your sign should say:
Warning
Lead Work Area
Poison
No Smoking, Drinking or
Eating
Wash up.
Workers should wash their hands and faces each time they stop
working. It is especially important to wash up before eating and at the
end of the day.
Note: OSHA rules may require employers to take further steps to protect
the health of workers on the job.
See www.osha.gov/SLTC/lead/index.html.
17
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Minimize the Dust
As you work, your goal is to keep down the dust.
Remember that as you scrape, drill, cut, open walls, etc., you are
creating dust. You can keep dust down by using the right tools and
following some simple practices that minimize and control the spread of
dust. The following items are available through hardware, paint, garden
supply stores or other specialty suppliers.
Shopping List
Materials for all jobs:
Q Wet-dry sandpaper, sanding sponge
Q Misting bottle or pump sprayer
Q Heavy plastic sheeting
Q Utility knife or scissors
Q Masking tape, duct tape, or painters' tape
Q High Efficiency Particulate Air (HEPA) vacuum cleaner (a special
vacuum cleaner that can remove very small particles from floors,
window sills, and carpets and not return them to the air)
Q Heavy duty plastic bags
Q Tack pads (large, sticky pads that help remove dust), paper towels,
or disposable wipes
Other tools that may be needed:
Q Low-temperature heat gun (under 1,100 degrees Fahrenheit)
Q Chemical strippers without methylene chloride
Q Power tools with HEPA filter equipped vacuum attachments
18
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What To Do
Use the right tools.
Use wet sanders and misters to keep down the dust created during
sanding, drilling and cutting.
Use HEPA vacuum attachments on power sanders and grinders to
contain the dust created by these tools.
When a heat gun is needed to remove paint, use a temperature
setting below 1,100 degrees Fahrenheit.
Use work practices that minimize dust.
Mist areas before sanding, scraping, drilling and cutting to keep the
dust down (except within 1 foot of live electrical outlets).
Score paint with a utility knife before separating components.
Pry and pull apart components instead of pounding and
hammering.
Keep components that are being disposed of in the work area until
they are wrapped securely in heavy plastic sheeting or bagged in heavy
duty plastic bags. Once wrapped or bagged, remove them from the
work area and store them in a safe area away from residents.
Control the spread of dust.
Keep the work area closed off from the rest of the home.
Don't track dust out of the work area:
Stay in the contained work area and on the contained paths.
Vacuum off suits when exiting the work area so the dust stays
inside the work area.
Every time you leave the plastic sheeting, remove your dispos-
able shoe covers, and wipe or vacuum your shoes, especially,
the soles, before you step off the plastic sheeting. A large
disposable tack pad on the floor can help to clean the soles of
your shoes.
Launder non-disposable protective clothing separately from family
laundry.
19
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Do Not Use Prohibited Practices.
The Renovation, Repair and Painting Rule prohibits the use of some
dangerous work practices by contractors. These "Prohibited Practices"
are:
Open-flame burning or torching of lead-based paint.
The use of machines that remove lead-based paint through high-
speed operation such as sanding, grinding, power planing, abrasive
blasting or sandblasting, unless such machines are used with a
HEPA exhaust control.
Operating a heat gun on lead-based paint at temperatures greater
than 1,100 degrees Fahrenheit.
In federally-assisted housing, HUD's rule prohibits additional
work practices:
Extensive dry scraping and sanding by hand.
Heat guns that char paint.
Paint stripping in a poorly ventilated space using a volatile paint
stripper.
Note: The EPA Renovation, Repair and Painting Rule does not apply to
homeowners who renovate their own property. However, because the
practices prohibited under the rules generate significant amounts of dust,
EPA recommends that they be avoided by the do-it-yourself homeowner
also.
20
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1
Leave the Won
Area Clean
*
The work area should be left clean at the end of every day and
especially at the end of the job. The area should be completely free of
dust and debris. The following cleaning supplies, tools, and equipment
are available in hardware, paint or garden supply stores.
Shopping List
Heavy-duty plastic bags
HEPA vacuum with attachments and a powered beater bar
Masking tape, duct tape, or painters tape
Misting bottle or pump sprayer
Disposable wet-cleaning wipes or hand towels
Detergent or general-purpose cleaner
Mop and disposable mop heads
Two buckets or one two-sided bucket with a wringer
Shovel and rake
Wet Mopping System
Electrostatically charged dry cleaning cloths
21
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What To Do
On a daily basis, renovators and do-it-yourself homeowners
should:
Pick up as you go. Put trash in heavy-duty plastic bags.
Vacuum the work area with a HEPA vacuum cleaner frequently
during the day and at the end of the day.
Clean tools at the end of the day.
Wash up each time you take a break and before you go home.
Dispose of or clean off your personal protective equipment.
Continue to separate the work area from the rest of the home and
remind residents to stay out of the area.
When the job is complete, renovators and do-it-yourself
homeowners should:
Remove plastic sheeting carefully, fold it with the dirty side in, tape it
shut, and dispose of it.
Make sure all trash and debris, including building components, are
disposed of properly.
Vacuum all surfaces, including walls, with a HEPA vacuum cleaner.
Mist and scrub the work area with a general-purpose cleaner on a
wet rag or mop, changing the rinse water often until dust and debris
are removed.
Vacuum all surfaces again once they are dry.
Visually inspect your work. Look around the home, both inside and
out. You should not be able to see any dust, paint chips or debris.
Re-clean the area thoroughly if you find dust or debris.
22
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1
Control the Waste
What to Do
Bag or wrap your waste at the work site and in the work area.
Collect and control all your waste. This includes dust, debris, paint
chips, protective sheeting, HEPA filters, dirty water, clothes, mop
heads, wipes, protective clothing, respirators, gloves, architectural
components and other waste.
Use heavy plastic sheeting or bags to collect waste. Seal the bag
securely with duct tape. Consider double bagging waste to prevent
tears. Large components should be wrapped in protective sheeting
and sealed with tape.
Bag and seal all waste before removing it from the work area.
Store all waste in a secure container or dumpster until disposal.
Limit on-site storage time.
Avoid transporting waste in an open truck or personal vehicle.
23
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Dispose of waste water appropriately.
Water used for cleanup should be filtered and dumped in a toilet
if local rules allow. If not, collect it in a drum and take it with you.
Never dump this water down a sink or tub, down a storm drain, or
on the ground. Always dispose of waste water in accordance with
federal, state and local regulations.
EPA's Web site has state information on solid and hazardous waste
disposal. See the following link for futher information:
http://www.epa.gov/epawaste/wyl/stateprograms.htm.
Be aware of waste disposal rules.
Because EPA considers most residential renovation and remodeling
as "routine residential maintenance," most waste generated during
these activities is classified as solid, non-hazardous waste, and
should be taken to a licensed solid waste landfill. This is not the case
for work done in commercial, public or other nonresidential child-
occupied facilities, where waste may be considered hazardous and
require special disposal methods. See the following link for futher
information: www.epa.gov/lead/pubs/fslbp.htm.
Always check state and local requirements before disposing of
waste. Some are more stringent than federal regulations.
24
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^ta
Verify Work Completion with
the Cleaning Verification
Procedure or Clearance
When all the work is complete, and before interior space is reoccupied,
you need to determine whether it is a safe environment to live in.
For Regulated Renovators and Maintenance Personnel:
If the work was performed by a contractor or landlord, either cleaning
verification or clearance testing is required by the RRP Rule. (If the
housing receives federal assistance, clearance testing is required.) If the
cleaning verification procedure is chosen, an EPA certified renovator
must perform the cleaning verification procedure. If clearance is chosen,
a certified lead inspector, certified lead risk assessor, or certified lead
sampling technician must conduct clearance testing.
For Do-it-Yourselfers:
After visual inspection in homes not receiving federal assistance, where
the homeowner has completed the work, the homeowner is not required
to conduct a cleaning verification procedure or clearance, but EPA
strongly recommends that you choose one or the other to ensure that a
complete cleaning was accomplished.
Cleaning Verification Procedure
After completion of cleaning, the cleaning verification procedure is
performed by wiping all dust collection surfaces in the work area with
a wet, disposable cleaning cloth and comparing that cloth visually to a
cleaning verification card. Dust collection surfaces include window sills,
countertops and other large horizontal surfaces such as fireplace mantles
and built-in shelving, and floors. Cleaning verification cards are available
from EPA by calling the National Lead Information Center at
1-800-424-LEAD (5323). Cleaning verification may only be performed
by an EPA Certified Renovator if renovations covered by the Renovation,
Repair and Painting rule were performed.
Note: For exterior work, only a visual inspection for dust, paint
chips or debris is required.
25
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'
-
The cleaning verification procedure for window sills is described
below:
Each window sill in the work area is wiped using a single, wet,
disposable cleaning cloth.
Once the entire window sill surface is wiped, the wipe is compared
to the cleaning verification card. (See "Interpreting the Cleaning
Verification Procedure" on page 27).
The cleaning verification procedure for countertops and floors is
described below:
Each countertop is wiped by the Certified Renovator using a wet
disposable cleaning cloth:
For smaller countertops and other horizontal surfaces such as
fireplace mantles and built-in shelving with a total surface area
less than 40 square feetwipe the entire surface with a single
wipe and compare to the cleaning verification card.
Large area surfaces, such as large countertops and floors,
have surface areas larger than 40 square feeteach of these
large countertops and floors must be divided into roughly equal
sections that are 40 square feet or less. Wipe each section
separately using a new wet disposable cleaning cloth for each
separate section. When conducting cleaning verification on
floors, the wipe will be attached to the handle of a wet mopping
system. The use of the wet mopping system handle allows the
Certified Renovator to apply uniform pressure on the cleaning
cloth. Each wipe is then compared to the cleaning verification
card.
26
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Interpreting the Cleaning Verification
Procedure
Compare each wipe representing a specific surface section to
the cleaning verification card. If the cloth used to wipe a surface
section within the work area is cleaner than the example wipes on
the cleaning verification card, then that surface section has been
adequately cleaned.
If the cloth is not cleaner than the cleaning verification card, re-clean
that surface section. Then use a new wet disposable cleaning cloth
to wipe the surface section again. If the second cloth is cleaner
than the cleaning verification card, that surface section has been
adequately cleaned.
If the second cloth is not cleaner than the cleaning verification card,
re-clean the surface, wait for 1 hour or until the surface section has
dried completely, whichever is longer.
Wipe the surface section with a dry electrostatic cleaning cloth. The
cleaning verification procedure is now complete and the surface is
considered clean.
When all of the surfaces in the work area have passed comparison
with the cleaning verification card, or have completed the post-
renovation cleaning verification, the project is complete and the area
can be turned over to occupants unless the housing is receiving
federal assistance, or state or local laws require dust clearance
testing, in which case the project must pass dust clearance testing
before the area can be turned over to occupants.
27
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Dust Clearance Testing
Clearance testing is conducted by certified lead-based paint
inspectors, certified lead risk assessors, or certified lead
dust sampling technicians. For homes receiving federal
assistance, the clearance testing must be done by a person
independent of the renovation firm.
Although optional under the Renovation, Repair and Painting
Rule, some states and localities may require clearance. Also, a
homeowner may specifically request that a clearance test be
performed in their contract. In this case, clean up the work area
and check your work, then contact a certified lead-based paint
inspector, risk assessor or lead dust sampling technician to
arrange for clearance testing.
HUD requires clearance testing after renovation or repair work in
pre-78 homes receiving federal assistance, which are regulated
under the Lead Safe Housing Rule. Contractors must determine
whether the home is federally-assisted. Federal assistance may
be channeled through a state or local government, community
development corporation or other similiar entity.
Clearance sampling for interior jobs will consist of a floor sample
taken in each room where work was performed (to a maximum
of four samples) and an additional sample on the floor outside
the entry to the work area. Where window sills and window
troughs were present in the work area, a window sill or window
trough sample will be collected in each room where work was
performed (to a maximum of four samples).
All clearance samples must be sent to an EPA-recognized
dust-lead laboratory for analysis. You can view the list of
laboratories at www.epa.gov/lead/pubs/nllap.htm.
For exterior jobs, EPA, like HUD, requires only a visual
assessment of the work area to pass clearance.
28
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Interpret the Clearance Sampling Results
The laboratory will report the amount of lead in the dust. A dust sample
at or above the following limits for lead is considered hazardous:
Floors: 40 micrograms per square foot
Window sills: 250 micrograms per square foot
Window troughs: 400 micrograms per square foot
If the laboratory report shows lead levels at or above these
thresholds, the home fails the dust wipe test. The home must be
cleaned and retested until compliance with these clearance limits is
achieved. Re-cleaning must be done by the contractor.
It is a good idea for homeowners to specify in the initial contract
that a dust clearance test will be done at the end of the job and
that the contractor will be responsible for re-cleaning if the
home fails this test. No one besides the contractor and the clearance
examiner should enter the work area until the area has been cleaned.
29
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Learn More About
Lead Safety
To learn more about lead safe work practices, contact the National Lead
Information Center at 1-800-424-LEAD (5323) and see the following link
http://www.epa.gov/lead/nlic.htm. The Center is the federal govern-
ment's leading source of quality information on lead poisoning prevention
and lead hazards.
Take a Course.
Get trained in lead safety. Professional trainers and community colleges
in your area may offer training. For information on courses, contact the
National Lead Information Center. One relevant course is:
Lead Safety For Renovation, Repair and Painting
(EPA-740-R-09-001, February 2009). EPA and HUD developed this
8 hour training course to instruct renovators, painters and mainte-
nance personnel how to work safely in homes with lead-based
paint. The course is interactive and includes hands-on activities for
practicing the skills workers need to avoid creating lead hazards in
the homes where they work. More information can be found at:
http://www.epa.gov/lead/pubs/epahudrrmodel.htm.
Find Out About Local Rules and Resources.
The National Lead Information Center can provide information on how to
contact your state, local and/or tribal programs to get general information
about lead poisoning prevention.
Local health departments can provide information about local
programs, including assistance for poisoned children.
State and tribal lead poisoning prevention or environmental protec-
tion programs can provide information about the lead regulations
that apply in your community and can tell you about possible
sources of financial aid for reducing lead hazards. They also may be
able to tell you about the costs and availability of individuals certified
to test lead paint and/or lead dust.
Building code officials can tell you the regulations that apply to the
renovation and remodeling work that you are planning.
30
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Access Additional Resource Materials.
The National Lead Information Center can also provide copies of the
following general reference and how-to guidance materials:
Renovate Right: Important Lead Hazard Information for Families,
Child Care Providers and Schools (EPA-740-F-08-002, March
2008).
http://www.epa.gov/lead/pubs/renovaterightbrochure.pdf
Small Entity Compliance Guide to Renovate Right: A Handbook
for Contractors, Property Managers and Maintenance Personnel
Working in Homes, Child Care Facilities and Schools Built Before
1978. (EPA-740-F-08-003, December 2008).
http://www.epa.gov/lead/pubs/sbcomplianceguide.pdf
Contractors: Lead Safely During Renovation (EPA 740-F-08-001,
March 2008). This short pamphlet provides a quick summary of
general information on lead safe work practices to contain, minimize
and clean up dust.
http://www.epa.gov/lead/pubs/contractor brochure.pdf
Protect Your Family from Lead in Your Home (EPA 747-K-99-001,
June 2003). This is a general information pamphlet on lead-based
paint, lead hazards, the effects of lead poisoning and steps you can
take to protect your family.
http://www.epa.gov/lead/pubs/leadpdfe.pdf
Lead Paint Safety: A Field Guide for Painting, Home Maintenance,
and Renovation Work (HUD-1779-LHC, March 2001). This guide
gives step-by-step instruction on lead safe work practices for
different jobs in the home.
http://www.hud.gov/offices/lead/training/LBPguide.pdf
31
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Other Resources
For other resources on lead, visit the following Web sites:
http://www.epa.gov/lead/ EPA is playing a major role in addressing
residential lead hazards, including deteriorating lead-based paint, lead
contaminated dust and lead contaminated residential soil. This Web site
provides information about lead and lead hazards and provides some
simple steps to protect your family. It contains links to basic information,
as well as more detailed information and documents on lead in the news,
rules and regulations, education and outreach materials, training, and
other lead links.
http://www.hud.gov/offices/lead/ The U.S. Department of Housing
and Urban Development's Office of Healthy Homes and Lead Hazard
Control (OHHLHC) is unique among federal agencies dealing with lead-
hazards, as it is staffed to bring lead health science to bear directly upon
America's housing. The site will direct you to resources on lead paint
regulations, training, guidance/technical guidelines and compliance and
enforcement.
http://www.osha.gov/SLTC/lead/index.html The mission of
the U.S. Department of Labor's Occupational Safety and Health
Administration (OSHA) is to assure the safety and health of America's
workers by: setting and enforcing standards; providing training, outreach,
and education; establishing partnerships; and encouraging continual
improvements in workplace safety and health. OSHA has established the
reduction of lead exposure as a high strategic priority. This site contains
links to lead recognition, evaluation, compliance, and training resources.
http://www.cdc.gov/lead The U.S. Department of Health and
Human Services Centers for Disease Control and Prevention (CDC)
are committed to achieving improvements in people's health. This site
provides CDC's compiled information on lead and includes materials and
links for parents, health professionals, researchers, students and others
interested in the topic of lead. The key resources include fact sheets,
guidelines and recommendations and questions and answers.
32
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Pre-Renovation
Education
Requirements
The pre-renovation education requirements of the Renovation, Repair
and Painting Rule ensure that owners and occupants of pre-1978 homes
and child-occupied facilities are provided information about potential
hazards of lead-based paint exposure before renovations are begun.
Who is affected? The requirements apply to any person paid to do
work that disturbs paint in residential housing or child-occupied facilities
built before 1978. This includes residential rental property owners and
managers, general contractors and special trade contractors such as
painters, plumbers, carpenters and electricians.
What properties are affected? All residential properties and
child-occupied facilities built before 1978 are affected unless they meet
one of the exceptions listed below.
Are there any exceptions? The requirements do not apply to housing
designated for elderly or disabled persons (unless children under age 6
live there), zero-bedroom dwellings (studio apartments, dormitories, etc.),
housing determined to be free of lead-based paint by a lead-based paint
inspection, emergency renovations and repairs, and minor repairs that
disturb less than 6 square feet of paint on interior surfaces or less than
20 square feet of paint on exterior surfaces.
What are the requirements? The Renovation, Repair and Painting Rule
requires the distribution of the lead pamphlet Renovate Right: Important
Lead Hazard Information for Families, Child Care Providers and Schools
before the work starts.
In residential housing, the pamphlet must be provided to both the
owner and occupants, and the contractor is required to document
the receipt or mailing of the brochure.
In multi-family residential housing, the pamphlet must be distributed
to each affected unit.
When common areas of multi-family residential housing are affected
by work, the pamphlet may be delivered to each unit or a notice
can be sent to each unit notifying them of the location and duration
of the work and the location of information postings about lead
hazards and the work to be performed.
In child-occupied facilities, the pamphlet must be provided to the
owner, to the responsible party and to parents.
33
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Renovate
Important Lead Hazard
n tor FumibeS,
Child Core Provide**
and Schools
Renfipdelar
l correctame
InTormacifin Important^ qobro
rtesgos causados per el plomo
farnHias.-proveedores de cuid-
tntanlil y escuelas
How do I get the pamphlet? The pamphlet is available from the
National Lead Information Center at 1-800-424-LEAD (5323).
Ask for the Renovate Right: Important Lead Hazard Information for
Families, Child Care Providers, and Schools pamphlet, or download it
at: http://www.epa.gov/lead/pubs/renovaterightbrochure.pdf.
Note: In federally-assisted housing, HUD requires notification to be
distributed to occupants within 15 days after lead-based paint or lead-
based paint hazards are identified in their unit (or common areas, if
applicable), and within 15 days after completion of hazard control work
in their unit or common areas.
34
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Shopping List
Set It Up Safely
Q Signs
Q Barrier tape or rope
Q Cones
Q Heavy duty plastic sheeting
Q Masking tape, duct tape, or
painters' tape
a Stapler
Q Utility knife or scissors
Minimize the Dust
Q Wet-dry sandpaper, sanding
sponge
Q Misting bottle or pump sprayer
Q Chemical strippers without
methylene chloride
Q High Efficiency Particulate Air
(HEPA) vacuum cleaner (a
special vacuum cleaner that
can remove very small particles
from floors, window sills, and
carpets)
Q Heavy-duty plastic bags
Q Tack pads (large, sticky pads
that help remove dust), paper
towels, or disposable wipes
Q Low-temperature heat
gun (under 1,100 degrees
Fahrenheit)
O Chemical strippers without
methylene chloride
O Power tools with HEPA filter
vacuum attachments
Protect Yourself
Q Protective eyewear
O Painter's hat
Q Disposable coveralls
O Disposable N-100 rated respi-
rator
Q Disposable latex/rubber gloves
O Disposable shoe covers
Clean the Work
Area
Q Heavy-duty plastic bags
Q HEPA vacuum cleaner
Q Masking tape, duct tape, or
painters' tape
Q Misting bottle or pump sprayer
Q Disposable wet-cleaning wipes
or hand towels
Q Detergent or general-purpose
cleaner
35
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Prevent Lead Exposure During
Renovation, Repair, and Painting
Understand that Renovation, Repair and Painting Jobs Can
Create Hazards. People, especially children, may swallow the
lead dust or paint chips created during the job and get poisoned. Lead
poisoning has serious health effects.
Read Renovate Right, EPA and HUD's Lead Hazard
Information Pamphlet. Contractors are required by law to give
clients in pre-1978 homes and child-occupied facilities a copy of
Renovate Right. Renovate Right explains the danger of lead-based paint
and its associated hazards. You can get copies of Renovate Right by
calling 1-800-424-LEAD (5323) or you can download it at
http://www.epa.gov/lead/pubs/renovaterightbrochure.pdf.
Use Lead-Safe Work Practices. Follow practices that will protect
you and residents from exposure to lead. These practices may take
a small amount of additional time and money, but they are necessary to
protect children, residents, workers and workers' families from exposure to
lead dust.
Conduct Lead Testing Before and/or After the Work is
Performed. Pre-job testing can identify any lead paint in the home
and allow workers to target lead safe work practices to the areas where
there is lead paint. Using the cleaning verification procedure or clearance
testing at the end of the job ensures that no dust has been left behind.
Learn More About Lead. To learn more about working safely with
lead, contact the National Lead Information Center at
1-800-424-LEAD (5323) or visit EPA's Web site at www.epa.gov/lead or
HUD's Web site at www.hud.gov/offices/lead.
2009, EPA-740-K-09-003
environmental Protection Agency, Office of Pollution Prev
3epf. of Housing and Urban Development, Office of Healt
inted with Vegetable Oil-Based Inks, Recycled Paper
and Toxia
nes and Lt
! Hazard Control
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Appendix 6:
Hands-on Exercises
-------
LEADSAFETY for Remodeling, Repair and Painting
Appendix 6: Hands-on Exercises
The following exercises can be used in place of the hands-on exercises or as supplemental
activities. Exercise worksheets and answers are provided.
Skill Set #1: Using EPA-Recognized Test Kits
Skill Set #2: Cleaning Verification Procedure
Recommended Supplies for Hands-on Activities
Test Kits Supplies List
Disposable plastic drop cloth 2' by 2'
Disposable shoe covers
Disposable wet cleaning wipes
Disposable, non-latex gloves
HEPA vacuum with attachments (for cleanup after sampling)
EPA-recognized test kit(s) w/ manufacturer's instructions
Heavy duty garbage bags
Kit-specific supplies as required in the manufacturer's instructions
Manufacturer provided test verification card with lead-based paint layer
Painted wood surface with no lead-based paint layer
Participant Progress Log
Pen or pencil
Tape (duct, painters, and masking)
Test Kit Documentation Form
Digital camera (Optional)
Numbered index cards (Optional)
Cleaning Verification Procedure Supplies List
Baby powder or corn starch
Cleaning verification card, one per student to take away and retain
Disposable foot covers
Disposable non-latex gloves
Disposable wet cleaning wipes
Electrostatically charged, white, disposable cleaning cloths designed for cleaning hard
surfaces
Flashlight
Long-handled mop designed for wet cleaning wipes
Tape measure
Watch or clock
Hands-on Exercises Mar 09 A6-1
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LEADSAFETY for Remodeling, Repair and Painting
Participant Progress Log:
Name of Trainee
Module 3
(15Min)
Skill Set 1: Using EPA-
Recognized Test Kits
Module 6
(20 Min)
Skill Set 2: Cleaning
Verification Procedure
Date of Training:
Certified Renovator Name:
Hands-on Exercises
Mar 09
A6-2
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LEADSAFETY for Remodeling, Repair and Painting
Certified Renovator Training Hands-On Skills Assessment
Date:
Address:
City & State.
Student Name:
Student Signature:
Skill
Set
#1
#2
Skill
Description
Using EPA-
Recognized
Test Kits
Cleaning
Verification
Procedure
Student has demonstrated proficiency at the following skills
consistent with the requirements of the EPA RRP Rule.
Using test kit to properly test for lead-based paint and
document results.
Conducting cleaning verification procedure.
Trainer's
Initials
I am the trainer for the Certified Renovator course offered on the date and location
described above. I verify that the student has demonstrated the skills as described above.
Trainer Name: _
Trainer Phone:
Trainer Signature:
Organization:
Date:
Hands-on Exercises
Mar 09
A6-3
-------
LEADSAFETY for Remodeling, Repair and Painting
Skill Set#1: Using EPA-Recognized Test Kits
Time: 15 minutes
Mar 09
Supplies needed:
EPA-recognized test kit(s) w/ manufacturer's instructions
Kit-specific supplies as required in the manufacturer's instructions
Disposable plastic drop cloth 2' by 2'
Tape (duct, painters, and masking)
Disposable, non-latex gloves
Disposable shoe covers
Manufacturer provided test verification card with lead-based paint layer
Disposable wet cleaning wipes
Heavy duty garbage bags
Painted wood surface with no lead-based paint layer
Test Kit Documentation Form
Participant Progress Log
Pen or pencil
Digital camera (Optional)
Numbered index cards (Optional)
HEPA vacuum with attachments (for cleanup after sampling)
Note to Instructor: It is strongly suggested that instructors prepare plastic bags
containing all materials needed for the hands-on exercises, prior to the exercise, in
order to meet the time limits allocated to Skill Set #1.
Purpose: The purpose of this hands-on exercise is to teach students how to correctly use
EPA-recognized test kits to determine if lead-based paint is present on components and
surfaces affected by renovation work.
Note to Instructor: Read the purpose of this activity to students and remind them to
document all areas where the paint color or substrate reactions may cause an incorrect
result. These surfaces should not be tested with a test kit, but should either be tested by
Certified Inspectors or Certified Risk Assessors, or must be assumed to contain lead-
based paint.
Demonstration: The course instructor must show and explain all of the steps involved in
the use of EPA-recognized test kits. The demonstration should not take longer than 5
minutes including the time needed to hand out materials.
Evaluating the Students: Allow students to practice the eight steps on the following page.
Watch each student follow the steps. Make corrections and suggestions as the exercise
proceeds and determine if additional practice is necessary. This should take no longer than
10 minutes. Students must complete all required steps to be "Proficient". Evaluate the work
of each student and once the student can use a test kit correctly, the instructor should write
the word "Proficient" in the field on the Participant Progress Log that corresponds to Skills
Set #1 and that particular student's name.
Hands-on Exercises Mar 09 A6-4
-------
LEADSAFETY for Remodeling, Repair and Painting
Skill Set #1: Using EPA-Recognized Test Kits - Continued
Skills Practice:
Step 1: Read the manufacturer's instructions
Step 2: Write required information and observations about the test location on the Test Kit
Documentation Form*
Step 3: (Optional) Secure a small disposable plastic drop cloth (2ft x 2 ft) on the floor
beneath the test location with masking tape.
Step 4: Put on disposable non-latex gloves and shoe covers.
Step 5: Follow the manufacturer's instructions for use of the test kit to conduct the test.*
Perform one test on the test card provided by the manufacturer, to observe a
positive test result; conduct one test of a painted wood surface with no lead-based
paint layer to observe a negative test result.*
Step 6: Use one wet cleaning wipe to remove residual chemicals left on the surface
tested. Use a second cleaning wipe to remove any visible debris or dust on the
floor beneath the sample collection area and place the used cleaning wipe in the
trash bag.*
Step 7: Check documentation for completeness and note the result of the testing on the
Test Kit Documentation Form*
Step 8: (Optional) Number the test location in sequence on the Test Kit Documentation
Form, then select the corresponding numbered index card and tape it next to the
test location with masking tape and take a picture of the numbered test location to
photo-document conduct and possibly the result of the test.
indicates required skills that must be accomplished for a "Proficient" rating.
Interpreting the Results of Test Kit Sampling:
The manufacturer's instructions will indicate the targeted indicator color change for lead in
paint. Once the test is conducted, note the result and refer to the manufacturer's guidelines
for interpreting the result. All painted surfaces that show the manufacturer's listed color
change for lead in paint (a positive test result) must be treated as lead-based paint until
additional testing performed by a Certified Lead Inspector or Risk Assessor proves it is not.
Documenting Test Kit Results:
A report of the findings from use of the test kit must be provided to the person contracting
the work within 30 days following the completion of the renovation work. The completed
Test Kit Documentation Form should be kept by the Certified Firm for 3 years after the work
is completed.
Hands-on Exercises Mar 09 A6-5
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LEADSAFETY for Remodeling, Repair and Painting
Test Kit Documentation Form Page 1 of
Owner Information
Name of Owner/Occupant:
Address:
City: State: Zip code: Contact #:
Email:
Renovation Information
Fill out all of the following
Certified Renovator.
Renovation Address:
Citv:
Certified Firm Name:
information that is available about the Renovation Site, Firm, and
Unit#
State: Zip code:
Address:
Citv:
Email:
Certified Renovator Name:
State: Zip code: Contact #: ( )
Date Certified: / /
Test Kit Information
Use the following blanks to identify the test kit or test kits used in testing components.
Test Kit #1
Manufacturer: Manufacture Date: /
Model: Serial #:.
Expiration Date:
Test Kit #2
Manufacturer: Manufacture Date:
Model: Serial*:
Expiration Date:
Test Kit #3
Manufacturer: Manufacture Date:
Model: Serial*:
Expiration Date:
Hands-on Exercises Mar 09 A6-6
-------
LEADSAFETY for Remodeling, Repair and Painting
Test Kit Documentation Form Page of
Renovation Address: Unit#.
City: State: Zip code:
Test Location # Test Kit Used: (Circle only one) Test Kit #1 Test Kit #2 Test Kit #3
Description of test location:
Result: Is lead present? (Circle only one) YES NO Presumed
Test Location # Test Kit Used: (Circle only one) Test Kit #1 Test Kit #2 Test Kit #3
Description of test location:
Result: Is lead present? (Circle only one) YES NO Presumed
Test Location # Test Kit Used: (Circle only one) Test Kit #1 Test Kit #2 Test Kit #3
Description of test location:
Result: Is lead present? (Circle only one) YES NO Presumed
Test Location # Test Kit Used: (Circle only one) Test Kit #1 Test Kit #2 Test Kit #3
Description of test location:
Result: Is lead present? (Circle only one) YES NO Presumed
Test Location # Test Kit Used: (Circle only one) Test Kit #1 Test Kit #2 Test Kit #3
Description of test location:
Result: Is lead present? (Circle only one) YES NO Presumed
Test Location # Test Kit Used: (Circle only one) Test Kit #1 Test Kit #2 Test Kit #3
Description of test location:
Result: Is lead present? (Circle only one) YES NO Presumed
Test Location # Test Kit Used: (Circle only one) Test Kit #1 Test Kit #2 Test Kit #3
Description of test location:
Result: Is lead present? (Circle only one) YES NO Presumed
Hands-on Exercises Mar 09 A6-7
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LEADSAFETY for Remodeling, Repair and Painting
Skill Set #2: Cleaning Verification Procedure
Time: 20 minutes
Mar 09
Supplies needed:
Baby powder or corn starch
Cleaning verification card, one per student to take away and retain
Disposable foot covers
Disposable non-latex gloves
Disposable wet cleaning wipes
Electrostatically charged, white, disposable cleaning cloths designed for cleaning
hard surfaces
Flashlight
Long-handled mop designed for wet cleaning wipes
Tape measure
Watch or clock
Purpose: The purpose of this hands-on exercise is to show the students the proper steps
for conducting the cleaning verification procedure.
The course instructor should explain all of the steps involved in performing the
cleaning verification procedure.
Evaluating the Students: Watch each student conduct the cleaning verification procedure
and listen as they point out problems that must be fixed. Students must complete all
required steps to be "Proficient". Evaluate the work of each student and once the student
has completed all required elements of the exercise correctly, record the performance as
"Proficient" in the field on the Participant Progress Log that corresponds to Skills Set #11
and that particular student's name.
Hands-on Exercises Mar 09 A6-8
-------
LEADSAFETY for Remodeling, Repair and Painting
Skill Set #2: Cleaning Verification Procedure - Continued
Skills Practice:
Step 1: As you enter the work area put on disposable foot covers so that you do not
track dust and debris into the work area.*
Step 2: Turn on all of the lights that are available in the work area. Make sure there is
adequate lighting.*
For window sills:
Step 3: While wearing gloves, wipe each windowsill in the work area with a clean, white,
damp cleaning wipe.*
Step 4: Compare the cleaning wipe to the cleaning verification card. If the first wipe is
the same as or whiter (lighter) than the cleaning verification card, the windowsill
is clean; continue to Step 6. If the first cleaning wipe is not the same as or whiter
(lighter) than the cleaning verification card, re-clean the window sill, and, repeat
Step 3 and then proceed to Step 5 (skip this step).*
Step 5: Compare the second cleaning wipe to the cleaning verification card. If the
second wipe is the same as or whiter (lighter) than the cleaning verification card,
the windowsill is clean; continue to Step 6. If the second cleaning wipe is not the
same as and not whiter (not lighter) than the cleaning verification card, wait one
hour or until the wet surface is dry (for the purposes of this exercise you do not
wait). Then re-clean the surface with a dry, electrostatically charged, white,
disposable cleaning cloth designed for use on hard surfaces. The windowsill is
now clean and has completed the cleaning verification procedure.*
For Floors and Countertops:
Step 6: While wearing gloves, wipe each floor or countertop in the work area with a
clean, white, damp cleaning wipe. For floors, use a long handled mop designed
to hold a wet cleaning wipe. For floors, wipe no more than 40 square feet per
wipe. For countertops wipe the whole surface of the countertop up to 40 square
feet per wipe.*
Step 7: Compare each floor and countertop cleaning wipe to the cleaning verification
card. If the first wipe is the same as or whiter (lighter) than the cleaning
verification card, the floor or countertop is clean. If the first cleaning wipe is not
the same as and not whiter (not lighter) than the cleaning verification card, re-
clean the floor section or countertop section, wipe the floor or countertop section
with a wet cleaning wipe, and repeat Step 6 for that section and proceed to Step
8 (skip this step).*
Step 8: Compare the second floor or countertop cleaning wipe to the cleaning
verification card. If the second wipe is the same as or whiter (lighter) than the
cleaning verification card, the floor or countertop section has been adequately
cleaned. If the second cleaning wipe is not the same as and not whiter (not
lighter) than the cleaning verification card, wait one hour or until the wet surface
is dry (for the purposes of this exercise you do not wait). Then re-clean the
surface with a dry, electrostatically charged, white, disposable cleaning cloth
designed for use on hard surfaces. The floor or countertop section is now clean
and has completed the cleaning verification procedure.*
Hands-on Exercises Mar 09 A6-9
-------
LEADSAFETY for Remodeling, Repair and Painting
Step 9: Once the cleaning verification shows that all areas have been adequately
cleaned, remove the signs and critical barriers around the work area.*
Indicates required skills that must be accomplished for a "Proficient" rating
Hands-on Exercises Mar 09 A6-10
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This Page Intentionally Left Blank
-------
Appendix 7:
State and Local Regulations
(Note: This Appendix is intentionally blank to allow training providers to add applicable
state and local regulations.)
-------
Appendix 7
State and Local Regulations
Appendix 7 is reserved for state and local regulations that apply to the Certified Renovator and
the Certified Firm. Instructors must determine what additional state and local regulations apply
to renovation work and include that information in Appendix 7. Provide copies or summaries of
applicable state and local regulations, web links and/or copies of important pages, contact lists,
training materials such as slides, brochures and pamphlets, etc.
Mar 09 A7-1
-------
Appendix 8:
Regulatory Status of Waste
Generated by Contractors and
Residents from Lead-Based Paint
Activities Conducted in Housing
-------
MEMORANDUM
From: Elizabeth A. Cotsworth, Director
Office of Solid Waste
To: RCRA Senior Policy Advisors
EPA Regions 1-10
Subject: Regulatory Status of Waste Generated by Contractors and Residents from Lead-
Based Paint Activities Conducted in Households
What is the purpose of this interpretation?
This memorandum clarifies the regulatory status of waste generated as a result of lead-based paint
(LBP) activities (including abatement, renovation and remodeling) in homes and other residences.
Since 1980, EPA has excluded Ahousehold wasteฎ 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 Aall 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.ฎ 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.
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LBP debris (such as architectural building components doors, window frames, painted wood
work) that do not exhibit the TC for lead need not be managed as hazardous waste. However, LBP
waste such as debris, paint chips, dust, and sludges generated from abatement and deleading
activities that exhibit the TC for lead (that is, exceed the TC regulatory limit of 5 mg/L lead in the
waste leachate), are hazardous wastes and must be managed and disposed of in accordance with
the applicable RCRA subtitle C requirements (including land disposal restrictions) except when it
is "household waste." Under 40 CFR 261.4(b)(l), household wastes are excluded from the
hazardous waste management requirements. Today, EPA is clarifying that waste generated as part
of LBP activities conducted at residences (which include single family homes, apartment
buildings, public housing, and military barracks) is also household waste, that such wastes are no
longer hazardous wastes and that such wastes thus are excluded from RCRA's hazardous waste
management and disposal regulations. Generators of residential LBP waste do not have to make a
RCRA hazardous waste determination. This interpretation holds regardless of whether the waste
exhibits the toxicity characteristic or whether the LBP activities were performed by the residents
themselves or by a contractor.
Where can I dispose of my household LBP waste?
LBP waste from residences can be discarded in a municipal solid waste landfill (MSWLF) or a
municipal solid waste combustor. Dumping and open burning of residential LBP waste is not
allowed. Certain LBP waste (such as large quantities of concentrated lead paint waste - paint
chips, dust, or sludges) from residential deleading activities may be subject to more stringent
requirements of State, local, and/or tribal authorities.
What is the basis for this interpretation?
The household waste exclusion implements Congress's intent that the hazardous waste regulations
are "not to be used either to control the disposal of substances used in households or to extend
control over general municipal wastes based on the presence of such substances." S. Rep. No. 94-
988, 94th Cong., 2nd Sess., at 16. EPA regulations define "household waste" to include "any
waste material (including garbage, trash, and sanitary wastes in septic tanks) derived from
households (including single and multiple residences, hotels and motels, bunkhouses, ranger
stations, crew quarters, campgrounds, picnic grounds and day-use recreation areas)." 40 CFR
261.4(b)(l). The Agency has applied two criteria to define the scope of the exclusion: (1) the
waste must be generated by individuals on the premises of a household, and (2) the waste must be
composed primarily of materials found in the wastes generated by consumers in their homes (49
FR 44978 and 63 FR 70241).
In 1998, EPA concluded that LBP waste resulting from renovation and remodeling efforts by
residents of households met these criteria. (63 FR 70241-42, Dec. 18, 1998). In short, the Agency
found that more and more residents are engaged in these activities and thus the waste can be
considered to be generated by individuals in a household and of the type that consumers generate
routinely in their homes. Wastes from LBP abatements performed by residents were also
considered household wastes.
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EPA clarifies that this interpretation also applies to contractor-generated LBP waste from
renovations, remodeling and abatements in residences. Both the definition of household waste in
section 261.4(b)(l) and the Agency's criteria for determining the scope of the exclusion focus on
the type of waste generated and the place of generation rather than who generated the waste (e.g., a
resident or a contractor). This approach is consistent with prior Agency policy.l Since
contractor-generated LBP waste from residential renovations, remodeling, rehabilitation, and
abatements are of the type generated by consumers in their homes, it is appropriate to conclude that
such waste, whether generated by a resident or contractor, falls within the household waste
exclusion. This clarification will facilitate lead abatements and deleading activities in target
housing by reducing the costs of managing and disposing of LBP waste from residences.
What is the relationship of this interpretation to the on-going LBP debris rulemaking?
On December 18, 1998, EPA proposed new TSCA standards for management and disposal of LBP
debris (63 FR 70190) and simultaneously proposed to suspend temporarily the applicability of the
RCRA hazardous waste regulations that currently apply to LBP debris (63 FR 70233). This
memorandum responds to stakeholders requests that EPA clarify whether the existing household
waste exclusion applies to both homeowners and contractors conducting LBP activities in
residences. While the Agency still intends to finalize aspects of the two proposals, we are making
this clarification in advance of the final rule to facilitate LBP abatement in residences without
unnecessary delay.
How does this interpretation affect EPA's enforcement authorities?
Under this clarification, LBP wastes generated by residents or contractors from the renovation,
remodeling, rehabilitation, and/or abatement of residences are household wastes that are excluded
from EPA=s hazardous waste requirements in 40 CFR Parts 124, and 262 through 271. The
household waste provision of 40 CFR 261.4(b)(l) only excludes such wastes from the RCRA
regulatory requirements. However, it does not affect EPA's ability to reach those wastes under its
statutory authorities, such as RCRA ง3007 (inspection) and ง7003 (imminent hazard). See 40 CFR
ง261.l(b).
What are the "best management practices" for handling residential LBP waste?
JIn 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 flEPA Hotline Reportฎ (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 AApplicability of the Household Waste Exclusion to Lead-
Contaminated Soils,ฎ we found that if the source of the lead contamination was as a result of either routine
residential maintenance or the weathering or chalking of lead-based paint from the residence, the hazardous waste
regulations do not apply so long as the lead-contaminated soil is managed onsite or disposed offsite according to
applicable solid waste regulations and/or State law mandated by RCRA.
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Although excluded from the hazardous waste regulations, EPA encourages residents and
contractors managing LBP waste from households to take common sense measures to minimize the
generation of lead dust, limit access to stored LBP wastes including debris, and maintain the
integrity of waste packaging material during transfer of LBP waste. In particular, we continue to
endorse the basic steps outlined in the 1998 proposals for the proper handling and disposal of LBP
waste (63 FR 70242) as the best management practices (BMPs) including:
Collect paint chips and dust, and dirt and rubble in plastic trash bags for disposal.
Store larger LBP architectural debris pieces in containers until ready for disposal.
Consider using a covered mobile dumpster (such as a roll-off container) for storage of LBP
debris until the job is done.
Contact local municipalities or county solid waste offices to determine where and how
LBP debris can be disposed.
In addition, contractors working in residential dwellings are subject to either one or both of the
following:
The HUD Guidance for contractors doing publically-funded rehabilitation/renovation
projects in public housing. (See Guidelines for the Evaluation and Control of Lead-Based
Paint Hazards in Housing. U.S. Department of Housing and Urban Development, June
1995) The HUD guidelines can be accessed via the Internet at:
http://www.hud.gov/lea/learules.html
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
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interpretation discussed in this memo in their States to facilitate residential LBP abatements
making residential dwellings lead-safe. We encourage trade associations to inform their
memberships about this memo and instruct them about ways to manage residential LBP waste.
Whom should I contact for more information?
If you have additional questions concerning the regulatory status of waste generated from lead-
based paint activities in residences, please contact Ms. Rajani D. Joglekar of my staff at 703/308-
8806 or Mr. Malcolm Woolf of the EPA General Counsel's Office at 202/564-5526.
cc: Key RCRA Contacts, Regions 1-10
RCRA Regional Council Contacts, Regions 1-10
RCRA Enforcement Council Contacts, Regions 1-10
Association of State and Territorial Solid Waste Management Officials ( ASTSWMO)
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Appendix 9:
For More Information
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APPENDIX 9: For More Information
If you are a hearing- or speech-impaired person, you may reach the telephone numbers
below via TTY by calling the Federal Information Relay Service at 1-800-877-8339.
Where can I get copies of the Renovate Right: Important Lead Hazard Information for
Families, Child Care Providers and Schools pamphlet in English or Spanish?
S Download electronic copies at: http://www.epa.gov/lead/pubs/renovation.htm.
-S 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).
v' Order bulk copies from the Government Printing Office (GPO) which cost $53.00
for a package of 50 pamphlets: 202-512-1800; refer to the pamphlet by name or
order online at http://bookstore.gpo.gov.
Where can I get copies of Small Entity Compliance Guide to Renovate Right handbook?
-S Download electronic copies in PDF format at
http://www.epa.gov/lead/pubs/renovation.htm.
v' 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?
^ National Lead Information Center: 1-800-424-LEAD (5323)
v' EPA's Office of Pollution Prevention and Toxics (OPPT): www.epa.gov/lead
v' HUD's Office of Healthy Homes and Lead Hazard Control:
www.hud.gov/offices/lead or by email to lead.regulations@hud.gov.
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