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Initial Training Course
Instructor Manual
EPA-740-R-09-001
Module 1: Why Should I Be
Concerned About Lead Paint?
Module 2: Regulations
Module 3: Before Beginning
Work
Module 4: Contain Dust
During Work
Module 5: During the Work
Module 6: Cleaning Activities
and Checking Your Work
Module 7: Recordkeeping
Module SlTraining Non-
Certified Renovation Workers
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Initial
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Manual
EPA-740-R-09-001
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Lead Safety for Renovation, Repair, and Painting
February 2009
This course was initially issued in June 2003 as a joint effort of the U.S. Environmental
Protection Agency's Office of Pollution Prevention and Toxics, in partnership with the U.S.
Department of Housing and Urban Development's Office of Healthy Homes and Lead Hazard
Control. The course was originally developed by ICF Consulting under contract with EPA. The
course was extensively revised in 2008 by QuanTech, Inc. following issuance of EPA's
Renovation, Repair, and Painting Rule.
FebOQ
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Lead Safety for Renovation, Repair, and Painting
February 2009
CERTIFIED RENOVATOR INITIAL TRAINING COURSE
INSTRUCTOR MANUAL
TABLE OF CONTENTS
Title
A Note to Instructors on How to Use this Curriculum
Introduction
Module 1: Why Should I Be Concerned About Lead Paint?
Module 2: Regulations
Module 3: Before Beginning Work
Module 4: Contain Dust During Work
Module 5: During the Work
Module 6: Cleaning Activities and Checking Your Work
Module 7: Recordkeeping
Module 8: Training Non-Certified Renovation Workers
Appendix 1: EPA's Renovation, Repair, and Painting 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 Regulations (Note: this Appendix is
intentionally blank to allow training providers to add applicable state and
local regulations.)
Appendix 8: Regulatory Status of Waste Generated by Contractors and
Residents from Lead-Based Paint Activities Conducted in Households
Appendix 9: For More Information
Page Number
iii
1
1-1
2-1
3-1
4-1
5-1
6-1
7-1
8-1
A1-1
A2-1
A3-1
A4-1
A5-1
A6-1
A7-1
A8-1
A9-1
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Lead Safety for Renovation, Repair, and Painting
A Note to Instructors on How to Use This Curriculum
This course was developed by the U.S Environmental Protection Agency (EPA), in collaboration
with the U.S. Department of Housing and Urban Development (HUD) to train renovation, repair,
and painting contractors how to work safely in housing with lead-based paint and comply with
EPA's Renovation, Repair, and Painting (RRP) Rule, and HUD's Lead Safe Housing Rule.
The audience: The audience for this course includes renovators, remodelers, painters,
maintenance personnel, and any other workers removing or modifying painted surfaces. They
likely will be taking the course to obtain EPA certification as a Certified Renovator, which will
enhance their credentials as private contractors and also satisfy HUD requirements for interim
controls training in Federally-assisted target housing. As the trainer, you will want to tailor the
course to highlight information and exercises that best meet audience needs. Although
customizing the course to your audience is appropriate to a certain degree, the HUD-related
material should be taught to all trainees, even if they are not currently working in Federally-
assisted target housing units. All renovators are potential HUD contractors and should know and
understand this information.
The curriculum and schedule: The curriculum consists of an introduction and eight
instructional modules. Most of the modules include interactive exercises. The timing of the
course will depend on the choices the trainer makes about activities, and how much time is
needed to discuss state and local requirements. Two possible course schedules for a one-day
delivery are provided below. The second schedule concentrates most of the exercises in a
single session towards the end of the day, before the review and test. The course can also be
delivered in several shorter sessions.
Overview of Proposed Schedule (Lesson Plan 1)
Registration and Introduction
(Includes Taking Pictures of Students)
Module 1 : Why Should I Be Concerned
About Lead Paint?
Module 2: Regulations
Break
Module 3: Before Beginning Work
Module 4: Contain Dust During Work
Lunch
Module 5: During the Work
Break
Module 6: Cleaning Activities and Checking Your
Work
Module 7: Recordkeeping
Break
Module 8: Training Non-Certified Renovation
Workers
Review
Test
15 minute
lecture/discussion
15 minute lecture
5 minute exercise
45 minute lecture
15 minutes
25 minute lecture
15 minute exercise
45 minute lecture
45 minute exercise
1 hour
40 minute lecture
10 minute exercise
10 minutes
40 minute lecture
50 minute exercise
20 minute lecture
5 minutes
40 minutes
10 minutes
30 minutes
8:00-8:15
8:15-8:35
8:35-9:20
9:20-9:35
9:35-10:15
10:15-11:45
11:45-12:45
12:45-1:35
1:35-1:45
1:45-3:15
3:15-3:35
3:35-3:40
3:40-4:20
4:20-4:30
4:30-5:00
Feb09
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Lead Safety for Renovation, Repair, and Painting
A Note to Instructors on How to Use This Curriculum
Overview of Proposed Schedule (Lesson Plan 2)
Registration and Introduction
(Includes Taking Pictures of Students)
Module 1 : Why Should I Be Concerned
About Lead Paint?
Module 2: Regulations
Break
Module 3: Before Beginning Work
Module 4: Contain Dust During Work
Module 5: During the Work
Lunch
Module 6: Cleaning Activities and Checking Your
Work
Module 7: Recordkeeping
Module 8: Training Non-Certified Renovation
Workers
Break
Hands-on Activities
Review
Test
15 minute
lecture/discussion
15 minute lecture
5 minute exercise
45 minute lecture
15 minutes
25 minute lecture
15 minute exercise
45 minute lecture
40 minute lecture
1 hour
40 minute lecture
20 minute lecture
40 minutes
15 minutes
105 minutes exercises
10 minutes
30 minutes
8:00-8:15
8:15-8:35
8:35-9:20
9:20-9:35
9:35-10:15
10:15-11:00
11:00-11:40
11:40-12:40
12:40-1:20
1:20-1:40
1:40-2:20
2:20-2:35
2:35-4:20
4:20-4:30
4:30-5:00
Preparing for the course: Read the course materials well in advance of course delivery. While
the lesson plans and slides provide comprehensive approaches to teaching this course, you will
have some decisions to make and some materials to prepare. Specifically:
Know your audience. If you are delivering this course to contractors consider their work and
specific needs. Pick examples and structure exercises around activities that are familiar to
them. Instructors must cover the HUD requirements in all course deliveries. Some
renovators not doing HUD work at the time of training may do HUD work during the five
years of their certification. In this course, HUD requirements are covered in Module 2 and in
the HUD-specific text boxes in the student notes to the slides, and are summarized in
Appendix 2.
Know your training facility. When training in your own facility, you have more control over
your environment and generally have access to many more supplies, tools, and equipment
than when you are training in a hotel room or community space. As you make decisions
about the types of exercises you plan to do during the training, consider your training facility,
the space and tools available, and plan accordingly.
Plan your schedule. The lesson plans provided in this section illustrate different ways to
organize the course. While the hands-on exercises are presented as integral parts of
Modules 3, 4, 5, and 6, (as shown in Lesson Plan 1), the majority can also be delivered as
one single hands-on module at the end of the course (as shown in Lesson Plan 2). Note that
these lesson plans are provided for reference purposes only. The trainer is free to create
his/her own lesson plan that combines the various options in other ways, as long as the
content and course length are not substantively altered. As you plan your schedule,
consider how to time your breaks and activities appropriately depending on whether your
course is scheduled for one full day, two half-days or several evening sessions. As you plan
your time, you should not substantively alter the time allotted to cover specific subjects, e.g.,
the content of Module 4: Contain Dust During Work should receive 90 minutes of total
instructional time (45 minutes lecture and 45 minutes hands-on), regardless of whether the
job setup component of the hands-on exercise is delivered during the module or with the
Feb09
IV
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Lead Safety for Renovation, Repair, and Painting
A Note to Instructors on How to Use This Curriculum
other hands-on components at the end of the course. You may find that compression of the
modules is needed in order to provide adequate time to discuss state and local
requirements. However the course is delivered, two hours of hands-on training must be
included to meet the RRP Rule requirements.
Plan to administer the test. In addition to reinforcing participant learning and helping
evaluate their understanding, passing the course test is required to allow each student to
become an EPA Certified Renovator. Renovator certification is required for all workers and
supervisors working in Federally-assisted target housing unless they are supervised by a
Certified Abatement Supervisor. Renovator certification includes successful completion of
the training course and end-of-course test. You must develop a test blueprint from the
course material and submit it to EPA for approval with the accreditation application.
Gather all the materials necessary. A list of recommended supplies and tools is provided in
this section. Make sure you have all the materials necessary to perform the activities and
demonstrations you have planned.
Course Materials: Materials needed to deliver this course include Student Manuals, an
Instructor Manual, Overhead Slides, Supplies Lists and a Test, as described below.
Course Materials
Student Manual
Each student must receive a printed copy of the student manual. The
student manual includes pictures of all overhead slides used in the course
and the student notes. Student manuals should not be printed without the
student notes; PowerPoint slides alone do not provide sufficient
information for students. The student manual also has appendices, which
include optional exercises and a copy of the Steps to LEAD SAFE
Renovation, Repair and Painting, which can be used on the job to
teach non-certified workers how to work lead safe.
Instructor Manual
The instructor manual includes all the materials from the Student Manual,
plus instructor notes for trainers. The right-hand page shows the slide and
notes for the student manual while the left hand page has the instructor
notes for that slide. The Instructor Manual also includes answers to the
exercises. This manual provides several complete lesson plans with
suggestions for hands-on exercises.
Overhead Slides
The trainer should have overhead slides, electronically or on
transparencies. The slides are available in PowerPoint and can be copied
onto transparencies if desired.
Supplies Lists
The instructor is responsible for creating three Supplies Lists: Setup,
Personal Protective Equipment, and Cleanup. Recommended items to be
included in the Supplies Lists are shown in the next table.
Test
This course includes a test. Trainers are responsible for developing their
own test blueprint and submitting it for approval with their application to
become an accredited training provider. The course lesson plans provide
30 minutes for the test. If your test blueprint requires a longer testing time
adjust the lesson plan times accordingly.
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Lead Safety for Renovation, Repair, and Painting
A Note to Instructors on How to Use This Curriculum
Classroom Supplies and Tools: To correctly deliver this course, the trainer needs standard
classroom supplies as well as a number of special tools to demonstrate lead safe work practices
and perform hands-on exercises. The table below provides a list of recommended supplies. We
recognize that trainers may not be able to transport all the tools and materials listed below to a
given training site, or may vary the supply list slightly depending on whether the trainer is
simulating an interior or exterior activity. Therefore the list serves only as a checklist of
recommended items. The trainer should consult the lesson plan and the individual modules to
determine which supplies are critical to the delivery that he/she has planned.
Recommended Classroom Supplies
Instructor manual
Student manuals, one per student
Computer, laptop computer or flash drive
Overhead or computer-driven projector
Course PowerPoint presentation or overhead transparencies
Projection screen
Blackboard, white board, or flip chart paper and stand
Markers appropriate for blackboard, white board, or flip chart
Masking tape
Table tents with each student's name (a table tent is an 81/4" x 11" sheet of heavy stock
paper that is folded in half lengthwise; the paper should be heavy enough that it will not
flatten when set on the table after being folded)
Heavy-duty disposal bag and duct tape
Packet of sweetener
Broom and dust pan
Lead test kits
Disposable cleaning cloths (white, electrostatically charged, designed for cleaning hard
surfaces)
Long handled mop to which a disposable cleaning cloths can be attached
A laminated paint chip (1 cm2) on a cardboard display or in a sealed test tube
Power strip
Recommended Supplies for Hands-on Activities
Test Kit Supplies List
Disposable plastic drop cloth 2' by 2'
Disposable shoe covers
Disposable wet cleaning wipes
Disposable, non-latex gloves
EPA-recognized test kit(s) w/ manufacturer's instructions
Heavy duty garbage bags
HEPA vacuum with attachments
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)
Feb 09 vi
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Lead Safety for Renovation, Repair, and Painting
A Note to Instructors on How to Use This Curriculum
Recommended Supplies for Hands-on Activities (continued)
Setup Supplies List
Barrier tape
Broom handle, or dowels, or 1" x 1" x 30" wood or metal stock
Cutting tool (e.g., razor knife, box cutter or scissors)
Disposable tack pad
Doorway to use for work area entry setup
Fencing stakes
Heavy duty plastic sheeting
Magnetic covers
Orange cones
Rope and/or barrier tape (bright color preferable)
Stapler and Staples
Tape (duct, painters, and masking) Tape measure
Warning signs
Pre-engineered containment systems (Optional for Skill Set 2)
Personal Protective Equipment (PPE) Supplies List
Disposable coveralls
Disposable non-latex gloves
Disposable foot covers
Eye protection
Leather or canvas work gloves
N-100 respirators
Disposable waste bags
Duct tape
Hand washing facilities and hand soap
Cleanup Supplies List
Baby powder or corn starch
Cleaning verification card, one per student to take away and retain
Cutting tool (e.g., razor knife, box cutter or scissors)
Disposable foot covers
Disposable non-latex gloves
Disposable wet cleaning wipes
Electrostatically charged, white, disposable cleaning cloths designed for cleaning hard
surfaces
Flashlight
Garden sprayer
Heavy duty plastic bags
Heavy duty plastic sheeting
HEPA vacuum with attachments and a powered beater bar
Long-handled mop designed for wet cleaning wipes
Tape (duct, painters, and masking)
Tape measure
Two-sided mop bucket with wringer (or equivalent), disposable mop heads, long handled
mop to which disposable cleaning cloths can be attached; or, a wet mopping system.
Watch or clock
Feb 09 vii
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Lead Safety for Renovation, Repair, and Painting
A Note to Instructors on How to Use This Curriculum
Lesson Plans: The two lesson plans illustrate different ways to teach the course. Note that the
instructor is free to borrow from these two lesson plans to create a lesson plan that best fits the
needs of a given audience and setting. However, to meet the learning objectives of this course,
the instructor should adhere to the guidelines about the time allotted to each subject.
Course Outline
Module
Introduction
Module 1: Why Should 1
Be Concerned About
Lead Paint?
Module 2: Regulations
Module 3:
Before Beginning Work
Module 4: Contain Dust
During Work
Module 5: During the
Work
Module 6: Cleaning
Activities and Checking
Your Work
Module 7:
Recordkeeping
Module 8: Training
Non-Certified
Renovation Workers
Test
Components
Lecture
Introductions of course
participants
Lecture
Exercise/Demonstration
(See Exercises)
Lecture
Exercise and checklist
Lead test kit demo and
exercise (See Exercises)
Lecture
Setup Exercise (See
Exercises)
Lecture
Personal Protective
Equipment Exercise (See
Exercises)
Lecture
Gooseneck seal
demonstration/exercise
Cleaning verification
demonstration
Clearance demonstration
Cleanup Exercise
Lecture
Lecture
Test
Exercises
None
Paint chip exercise
Sweetener packet exercise
Note: These are instructor
demonstrations.
None
Test kits demonstration and hands-
on exercises
Exercise can be completed during
Module 4 or deferred until after
Module 8 in combination with
hands-on exercises from Modules
5 and 6.
Exercise can be completed during
Module 5 or deferred until after
Module 8 in combination with
hands-on exercises from Modules
4 and 6.
Exercise can be completed during
Module 6 or deferred until after
Module 8 in combination with
hands-on exercises from Modules
4 and 5.
None
None
Test
FebOQ
VIII
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Lead Safety for Renovation, Repair, and Painting
A Note to Instructors on How to Use This Curriculum
Lesson Plan 1: Hands-On Activities Included in Modules
Introduction 15 minutes
1: Lead Safety for Renovation, Repair, and
Painting
2: Course Agenda
3: Training Manual Overview
4: You Will Learn...
5: This Course...
Key message: Renovators have a role to
play in preventing lead poisoning.
Notes: This module is straightforward.
Move quickly through the slides.
Emphasize that this training applies to
work in pre-1978 housing and additional
precautions are needed when a residential
property receives Federal funds. There
may also be additional requirements when
the property receives state or local funds.
Preparing for this module: Review the
class list before the session so you know
something about your audience.
Module 1 : Why Should I Be Concerned About Lead Paint? 20 minutes
1-1: Module 1: Why Should I be Concerned
about Lead Paint
1-2: What Is Lead-Based Paint?
1-3: Health Risks of Lead
1-4: Symptoms of Lead Poisoning are Not
Always Obvious
1-5: Why are Dust and Debris a Problem?
1-6: A Little Dust Goes a Long Way
1-7: Video Clip of Contractor Who Poisoned
His Own Kids
1-8: Video Clip of Parent of a Child Poisoned
by Renovation
1-9: Now You Know...
Key message: Dust is the problem and
contractors make dust. By working lead
safe, you can make a difference.
Notes: This module has a demonstration
by the instructor, followed by slides.
Lectu re ( 1 5 m i n utes)
Sweetener packet and paint chip
demo (5 minutes).
Preparing for this module: Have materials
ready for the exercise and demonstration.
Materials needed: Laminated paint chip,
sweetener packet, dustpan, broom, dust
wipe kit.
Module 2: Regulations 45 minutes
2-1: Module 2: Regulations
2-2: The RRP Rule
2-3: The RRP Rule: Exclusions
2-4: The RRP Rule: "Opt-Out" Provision
2-5: The RRP Rule: Firm Certification
2-6: The RRP Rule: Firm Responsibilities
2-7: The RRP Rule: Individual Certification
2-8: The RRP Rule: Certified Renovator
Responsibilities
2-9: The RRP Rule: Work Practice Standards
2-10: The RRP Rule: Enforcement
2-11: HUD's Lead Safe Housing Rule
2-12: HUD's Lead Safe Housing Rule: Safe
Work Practices
2-13: HUD's Rule Addresses:
Key message: Know the EPA and HUD
Rules. These rules set forth specific and
performance-based requirements that
must be mastered to achieve compliance.
Notes: Know your audience. All contractors
need to know all the regulations.
Preparing for this module: Review
materials in advance. Read all Federal,
state and local regulations.
FebOQ
IX
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Lead Safety for Renovation, Repair, and Painting
A Note to Instructors on How to Use This Curriculum
Lesson Plan 1: Hands-on Activities Included in Modules (Continued)
Module 2: Regulations - Continued
2-14: Know the EPA and HUD Rules!
2-15: State and Local Regulations
2-16: Now You Know...
Module 3: Before Beginning Work
40 minutes
3-1: Module 3: Before Beginning Work
3-2: Educate Owners and Residents
3-3: How Widespread is Lead-Based Paint in
Housing?
3-4: How to Determine if Lead-Based Paint is
Present
3-5: Using EPA-Recognized Test Kits to
Check for Lead-Based Paint
3-6: Test Kit Hands-on
3-7: Using Decision Logic Charts
3-8: Now You Know...
Key message: Plan before you start the
work.
Notes: This module is very interactive. A
short scenario precedes each topic.
Participants brainstorm questions before
discussing the material and completing a
planning checklist. Participants also learn
when and how to use lead test kits.
Lecture (25 minutes)
Hands-On Exercise (15 Minutes):
Students will learn when and how to
use lead test kits. See Skill Set #1.
Preparing for this module: Review Skill Set
#1 in advance. See Test Kit Supplies List
for materials needed.
Module 4: Contain the Dust During Work
90 minutes
4-1: Module 4: Contain Dust During Work
4-2: What is Containment?
4-3: Keep Dust Wthin the Containment
4-4: Interior Containment: Limit Access and
Post Signs
4-5: Interior Containment: Remove or Cover
Belongings
4-6: Interior Containment: Cover Floors
4-7: Interior Containment: Close Wndows,
Doors, HVAC
4-8: Interior Containment: Work Area Entry
Doorway
4-9: Overview of Interior Containment Steps
4-10: Exterior Containment: Establish the
Work Area
4-11: Exterior Containment: Close Wndows
and Doors
4-12: Exterior Containment: Extra Precautions
4-13: Overview of Exterior Containment Steps
4-14: Hands-on Exercise: Interior and Exterior
Containment (Skill Sets #2-#5)
4-15: Debrief of Hands-on Exercise
4-16: Now You Know...
Key message: Keep the dust in the work
area and make it easier to clean up.
Notes: Slides are followed by an exercise.
Slides (45 minutes)
Hands-On Exercise (45 minutes):
Students set up containment in a small
area. They lay plastic and secure it.
Trainer demonstrates how to do a
door flap.
Preparing for this module: Prepare
materials for hands-on exercise and
identify appropriate locations for groups to
work in.
Materials needed: See Setup Supplies List
for materials needed.
FebOQ
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Lead Safety for Renovation, Repair, and Painting
A Note to Instructors on How to Use This Curriculum
Lesson Plan 1: Hands-on Activities Included in Modules (Continued)
Module 5: During the Work
50 minutes
5-1: Module 5: During the Work
5-2: Traditional Renovations Create Airborne
Leaded Dust
5-3: Prohibited Practices
5-4: Specialized Tools
5-5: Protect Yourself
5-6: Control the Spread of Dust
5-7: Cleaning During the Job
5-8: Exercises: Personal Protective Equipment
(Skill Set #6)
5-9: Now You Know...
Key Message: Traditional practices
produce dust, while lead safe practices will
reduce dust making the renovation, repair,
or painting work safer.
Notes: Slides are followed by an exercise
Slides (40 minutes)
Hands-On Exercise (10 minutes)
Preparing for this module: Prepare a list of
tasks for participants to work on and the
materials for the hands-on exercise.
Materials needed: See the Personal
Protective Equipment Supplies List.
Module 6: Cleaning Activities and Checking Your Work
90 minutes
6-1: Module 6: Cleaning Activities and
Checking Your Work
6-2: What is Effective Cleanup?
6-3: Interior Cleaning Requirements
6-4: Visual Inspection Procedure
6-5: Cleaning Verification (CV) Procedure
6-6: Dust Clearance Examination
6-7: Exterior Cleanup Requirements
6-8: Exterior - Check Effectiveness of Cleaning
6-9: Disposal
6-10: Disposal - Federal, State and Local
Information
6-11: Exercise: Cleaning and the Cleaning
Verification Procedure (Skill Sets #7 - #11)
6-12: Now You Know...
Key message: Do cleanup right. Use wet
mops and HEPA vacuums. Traditional
methods don't do the job.
Notes: Slides followed by an exercise
Slides (40 minutes)
Hands-on Exercise (50 minutes)
Preparing for this module: Prepare
materials for the hands-on exercise, and
the cleaning verification and clearance
demonstrations.
Materials needed: Disposable cleaning
cloths, cleaning verification cards, dust
wipe sampling materials, and tools listed in
the Cleanup Supplies List.
FebOQ
XI
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Lead Safety for Renovation, Repair, and Painting
A Note to Instructors on How to Use This Curriculum
Lesson Plan 1: Hands-on Activities Included in Modules (Continued)
Module 7: Recordkeeping 20 minutes
7-1: Module 7: Recordkeeping
7-2: On-The-Job Records
7-3: Recordkeeping: Pre-Renovation Education
Records
7-4: Sample Confirmation of Receipt of Renovate
Right
7-5: Recordkeeping: Non-Certified Worker Training
7-6: Recordkeeping: Test Kit Reporting
7-7: Recordkeeping: Post-Renovation Reporting
7-8: Now You Know...
Key message: Records must be
complete, accurate and organized.
Notes: This module is all lecture.
Participants learn what records they
must keep.
Preparing for This Module: Review so
you are familiar with the content.
Module 8: Training Non-Certified Renovation Workers 40 minutes
8-1: Module 8: Training Non-Certified Renovation
Workers
8-2: Teaching Lead-Safe Work Practices Means:
8-3:The Role of the Certified Renovator
8-4: Role of Trained, Non-Certified Renovation
Workers
8-5: Steps for Teaching Lead Safety During
Renovations
8-6: Use the "Steps" Guide
8-7: Step 1: Determine if the Job Involves Lead-
Based Paint
8-8: Step 2: Set It Up Safely
8-9: Step 2: Set It Up Safely - Continued
8-10: Step 3: Protect Yourself
8-11: Step 4: Control the Spread of Dust
8-12: Step 5: Leave The Work Area Clean
8-13: Step 6: Control the Waste
8-14: Step 7: Cleaning Verification or Clearance
Testing
8-15: Training Documentation
8-16: Now You Know...
Key message: Certified Renovators
are responsible for teaching lead-
safe work practices to non-certified
renovation workers.
Notes: Emphasize that this training is
to give Certified Renovators the tools
and skills necessary to conduct either
on-site "toolbox" training or
classroom training for non-certified
renovation workers. All training
should focus mainly on teaching
students to perform the tasks
necessary to work as non-certified
renovators on the job. Special
emphasis should be placed on the
practical skills and activities of lead
safe-work practices using as much
hands-on instruction as possible.
Preparing for This Module: Review so
you are familiar with the content.
Review 10 minutes
Review key topics and rules for test
Test 30 minutes
Administer the test (30 minutes)
Trainers are responsible for
developing their own test blueprint
and submitting it for approval with
their application to become an
accredited training provider.
Total Instructional Time 7 hours 30 minutes
FebOQ
XII
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Lead Safety for Renovation, Repair, and Painting
A Note to Instructors on How to Use This Curriculum
Lesson Plan 2: Hands-On Activities Combined into One Unit
NOTE: Modules are the same as in Lesson Plan 1 except that all practical exercises from
Modules 4 through Module 6 have been moved and combined into one large hands-on block in
the afternoon session.
Introduction 15 minutes
1: Lead Safety for Renovation, Repair, and
Painting
2: Course Agenda
3: Training Manual Overview
4: You Will Learn...
5: This Course...
Key message: Renovators have a role to
play in preventing lead poisoning.
Notes: This module is straightforward.
Move quickly through the slides.
Emphasize that this training applies to work
in pre-1978 housing and additional
precautions are needed when a residential
property receives Federal funds. There may
also be additional requirements when the
property receives state or local funds.
Preparing for this module: Review the class
list before the session so you know
something about your audience.
Module 1 : Why Should I Be Concerned About Lead Paint? 20 minutes
1-1: Module 1: Why Should I be Concerned
about Lead Paint
1-2: What Is Lead-Based Paint?
1-3: Health Risks of Lead
1-4: Symptoms of Lead Poisoning are Not
Always Obvious
1-5: Why are Dust and Debris a Problem?
1-6: A Little Dust Goes a Long Way
1-7: Video Clip of Contractor Who Poisoned
His Own Kids
1-8: Video Clip of Parent of a Child Poisoned
by Renovation
1-9: Now You Know...
Key message: Dust is the problem and
contractors make dust. By working lead
safe, you can make a difference.
Notes: This module has a demonstration by
the instructor, followed by slides.
Slides (15 minutes)
Sweetener packet and paint chip
demo (5 minutes).
Preparing for this module: Have materials
ready for the exercise and demonstration.
Materials needed: Laminated paint chip,
sweetener packet, dustpan, broom, dust
wipe kit
Module 2: Regulations 45 minutes
2-1: Module 1: Regulations
2-2: The RRP Rule
2-3: The RRP Rule: Exclusions
2-4: The RRP Rule: "Opt-Out" Provision
2-5: The RRP Rule: Firm Certification
2-6: The RRP Rule: Firm Responsibilities
2-7: The RRP Rule: Individual Certification
2-8: The RRP Rule: Certified Renovator
Responsibilities
2-9: The RRP Rule: Work Practice Standards
2-10: The RRP Rule: Enforcement
2-11: HUD's Lead Safe Housing Rule
Key message: Know the EPA and HUD
Rules. These rules set forth specific and
performance-based requirements that must
be mastered to achieve compliance.
Notes: Know your audience. All contractors
need to know all the regulations.
Preparing for this module: Review materials
in advance. Read all Federal, state and
local regulations.
FebOQ
XIII
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Lead Safety for Renovation, Repair, and Painting
A Note to Instructors on How to Use This Curriculum
Lesson Plan 2: Hands-on Exercises Combined into One Unit (Continued)
Module 2: Regulations (Continued)
45 minutes
2-12: HUD's Lead Safe Housing Rule: Safe
Work Practices
2-13: HUD's Rule Addresses:
2-14: Know the EPA and HUD Rules!
2-15: State and Local Regulations
2-16: Now You Know...
Module 3: Before Beginning Work
40 minutes
3-1: Module 3: Before Beginning Work
3-2: Educate Owners and Residents
3-3: How Widespread is Lead-Based Paint in
Housing?
3-4: How to Determine if Lead-Based Paint is
Present
3-5: Using EPA-Recognized Test Kits to
Check for Lead-Based Paint
3-6: Test Kit Hands-on
3-7: Using Decision Logic Charts
3-8: Now You Know...
Key message: Plan before you start the
work.
Notes: This module is very interactive. A
short scenario precedes each topic.
Participants brainstorm questions before
discussing the material and completing a
planning checklist. Participants also learn
when and how to use lead test kits.
Lecture: (25 minutes)
Hands-On Exercise (15 Minutes): Students
will learn when and how to use lead test
kits. See Ski 11 Set #1.
Preparing for this module: Review Skill Set
#1 in advance. See Test Kit Supplies List
for materials needed.
Module 4: Contain Dust During Work
45 minutes
4-1: Module 4: Contain Dust During Work
4-2: What is Containment?
4-3: Keep Dust Within the Containment
4-4: Interior Containment: Limit Access and
Post Signs
4-5: Interior Containment: Remove or Cover
Belongings
4-6: Interior Containment: Cover Floors
4-7: Interior Containment: Close Windows,
Doors, HVAC
4-8: Interior Containment: Work Area Entry
Doorway
4-9: Overview of Interior Containment Steps
4-10: Exterior Containment: Establish the
Work Area
4-11: Exterior Containment: Close Windows
and Doors
4-12: Exterior Containment: Extra Precautions
4-13: Overview of Exterior Containment Steps
4-14: Hands-on Exercise: Interior and Exterior
Containment
4-15: Debrief of Hands-on Exercise
4-16: Now You Know...
Key message: Keep the dust in the work
area and make it easier to clean up.
Notes: Slides are followed by an exercise.
Slides: 45 minutes
Hands-On Exercise: Deferred to large
exercise in the afternoon.
Preparing for this module: Prepare
materials for hands-on exercise and identify
appropriate locations where groups will
work.
Materials needed: See Setup Supplies List
for materials needed.
FebOQ
XIV
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Lead Safety for Renovation, Repair, and Painting
A Note to Instructors on How to Use This Curriculum
Lesson Plan 2: Hands-on Exercises Combined into One Unit (Continued)
Module 5: During the Work
40 minutes
5-1: Module 5: During the Work
5-2: Traditional Renovations Create Airborne
Leaded Dust
5-3: Prohibited Practices
5-4: Specialized Tools
5-5: Protect Yourself
5-6: Control the Spread of Dust
5-7: Cleaning During the Job
5-8: Exercises: Personal Protective Equipment
(Skill Set #6)
5-9: Now You Know...
Key Message: Traditional practices produce
dust, while lead safe practices will reduce
dust making the renovation, repair, or
painting work safer.
Notes: Slides are followed by an exercise
Slides: 40 minutes
Hands-on Exercise: Deferred to large
exercise in the afternoon.
Preparing for this module: Prepare a list of
tasks for participants to work on and the
materials for the hands-on exercise.
Materials needed: See the Personal
Protective Equipment Supplies List.
Module 6: Cleaning Activities and Checking Your Work
40 minutes
6-1: Module 6: Cleaning Activities and
Checking Your Work
6-2: What is Effective Cleanup?
6-3: Interior Cleaning Requirements
6-4: Visual Inspection Procedure
6-5: Cleaning Verification (CV) Procedure
6-6: Dust Clearance Examination
6-7: Exterior Cleanup Requirements
6-8: Exterior - Check Effectiveness of Cleaning
6-9: Disposal
6-10: Disposal - Federal, State and Local
Information
6-11: Exercise: Cleaning and the Cleaning
Verification Procedure (Skill Sets #7 - #11)
6-12: Now You Know...
Key message: Do cleanup right. Use wet
mops and HEPA vacuums. Traditional
methods don't do the job.
Notes: Slides followed by an exercise
Slides (40 minutes)
Hands-On Exercise: Deferred to large
exercise in the afternoon.
Preparing for this module: Prepare
materials for the hands-on exercise and
clearance demonstration.
Materials needed: Disposable cleaning
cloths, cleaning verification cards, dust wipe
sampling materials, and tools listed in the
Cleanup Supplies List.
FebOQ
xv
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Lead Safety for Renovation, Repair, and Painting
A Note to Instructors on How to Use This Curriculum
Lesson Plan 2: Hands-on Exercises Combined into One Unit (Continued)
Module 7: Recordkeeping
20 minutes
7-1: Module 7: Recordkeeping
7-2: On-The-Job Records
7-3: Recordkeeping: Pre-Renovation
Education Records
7-4: Sample Confirmation of Receipt of
Renovate Right
7-5: Recordkeeping: Non-Certified Worker
Training
7-6: Recordkeeping: Test Kit Reporting
7-7: Recordkeeping: Post-Renovation
Reporting
7-8: Now You Know...
Key message: Records must be complete,
accurate and organized.
Notes: This module is all lecture.
Participants learn what records they must
keep.
Preparing for This Module: Review so you
are familiar with the content.
Module 8: Training Non-Certified Renovation Workers
40 minutes
8-1: Module 8: Training Non-Certified
Renovation Workers
8-2: Teaching Lead-Safe Work Practices
Means:
8-3:The Role of the Certified Renovator
8-4: Role of Trained, Non-Certified Renovation
Workers
8-5: Steps for Teaching Lead Safety During
Renovations
8-6: Use the "Steps" Guide
8-7: Step 1: Determine if the Job Involves
Lead-Based Paint
8-8: Step 2: Set It Up Safely
8-9: Step 2: Set It Up Safely - Continued
8-10: Step 3: Protect Yourself
8-11: Step 4: Control the Spread of Dust
8-12: Step 5: Leave The Work Area Clean
8-13: Step 6: Control the Waste
8-14: Step 7: Cleaning Verification or
Clearance Testing
8-15: Training Documentation
8-16: Now You Know...
Key message: Certified Renovators are
responsible for teaching lead-safe work
practices to non-certified renovation
workers.
Notes: Emphasize that this training is to
give Certified Renovators the tools and
skills necessary to conduct either on-site
"toolbox" training or classroom training for
non-certified renovation workers. All training
should focus mainly on teaching students to
perform the tasks necessary to work as
non-certified renovators on the job. Special
emphasis should be placed on the practical
skills and activities of lead safe-work
practices using as much hands-on
instruction as possible.
Preparing for This Module: Review so you
are familiar with the content.
FebOQ
XVI
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Lead Safety for Renovation, Repair, and Painting
A Note to Instructors on How to Use This Curriculum
Lesson Plan 2: Hands-on Exercises Combined into One Unit (Continued)
Hands-On Activities 105 minutes
Appendix 6: Hands-on Exercises for Modules 4, 5
and 6.
Skill Set #2: Setting Up Barriers, Signs and
Flapped Entry Doors
Skill Set #3: Cover or Remove Furniture
Skill Set #4: Establish Interior Containment
Skill Set #5: Establish Exterior Containment
Skill Set #6: Personal Protective Equipment
Skill Set #7: Interior Final Cleaning
Skill Set #8: Exterior Final Cleaning
Skill Set #9: Bagging Waste
Skill Set #10: Visual Inspection
Skill Set #1 1 : Cleaning Verification Procedure
Key message: Practice what you have
learned.
Notes: This section is completely hands-on.
Preparing for this section: Use the hands-
on exercises that are included in Modules
4, 5 and 6 to run this eleven-part hands-on
exercise. The slides for these exercises
are:
Slides 4-14 and 4-1 5
Slide 5-8
Slide 6-11
These exercises are also included (with
Skill Set #1) in Appendix 6. Make sure you
have an appropriate facility, all necessary
tools and equipment (see Supplies Lists),
and have read carefully through and
understand each of the exercises.
Review 10 minutes
Review key topics and rules for test
Test 30 minutes
Administer the test (30 minutes)
Trainers are responsible for developing
their own test blueprint and submit it for
approval with their application to become
an accredited training provider.
Total Instructional Time 7 hours 30 Minutes
FebOQ
XVII
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Lead Safety for Renovation, Repair, and Painting
A Note to Instructors on How to Use This Curriculum
Guidance on Conducting Hands-On Activities: Hands-on training is a required element of
this curriculum. It is recommended that trainers consider the following factors when planning for
and conducting the hands-on training segments:
Have the right kind of supplies available. Use the lists provided to plan appropriately and
bring the right sorts of supplies to the training site. For example, household garbage bags
are not equivalent to heavy-duty disposal bags.
Have supplies in adequate quantities. Depending on how you structure the activity, you may
need varying numbers of supplies. For example, if the trainer demonstrates how to seal and
gooseneck a disposal bag, you will use one bag. If each student practices this procedure,
the training will consume a larger number of bags. Plan ahead so you have enough
supplies.
Have an adequate number of instructors. Depending on the class size, some hands-on
activities require more than one instructor to properly supervise and provide feedback.
Make sure you have enough trainers available to deliver the course to the number of
students attending. This is important because each student will be evaluated individually.
The training can be structured so that extra trainers need to be available only during the
hands-on activities. It is recommended that, at most, a 6:1 student-to-trainer ratio (i.e., one
trainer for every 6 students) for the hands-on exercises be maintained. Even with a 6:1 ratio,
trainers should expect to be quite busy during the hands-on exercises.
Carefully estimate the time you will need to conduct the hands-on exercises. This curriculum
contains a large amount of course content. Be mindful of class size and time constraints
when planning the hands-on exercises.
Make sure your equipment is clean and in working order before the class. Test your
equipment before the training begins. Trainers must not conduct training with lead-
contaminated equipment or dirty respirators.
The use of actual lead-based paint for training purposes is not allowed. Participants are in
your class to learn the skills to safely work around lead-based paint. Should they make a
procedural error during training, they should not be placed at risk of being exposed to lead.
The training facility must be appropriate for this course. For example, some locations
prohibit the use of water inside their facility. Know what is required for this course, and what
is allowed in the facility to be used. Match course requirements to the facility to be used.
Coach participants through the hands-on activities and document their proficiency. Hands-
on activities in Modules 3, 4, 5 and 6 list specific tasks that each participant must perform
correctly during that activity. Record achievement of these skills in a Participant Progress
Log. See Appendix 6 for an example Participant Progress Log.
Feb 09 xviii
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Introduction
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Lead Safety for Renovation, Repair, and Painting
Introduction - Instructor Notes
Overview of this module: The table below summarizes the content and teaching methods for
this module. This is for your reference. Do not cover this with the participants.
Introduction
15 minutes
1: Lead Safety for
Renovation, Repair,
and Painting
2: Course Agenda
3: Training Manual
Overview
4: You Will Learn...
5: This Course...
Key message: Renovators have a role to play in preventing
lead poisoning. Dust from renovations, repairs, and surface
preparation during painting activities creates potential lead
hazards when lead-based paint is disturbed and lead-safe work
practices are not used. EPA requires certification for renovation
firms, and training and certification for renovators to prevent lead
poisoning resulting from unsafe renovation practices.
Notes: This module is straightforward.
Move quickly through the slides.
Emphasize that this training applies to work in pre-1978 housing
and child-occupied facilities, and provides certification to conduct
renovations for compensation as required by the EPA
Renovation, Repair, and Painting Rule.
Preparing for this module: Review the class list before the
session so you know something about your audience.
Slide 1: Lead Safety for Renovation, Repair, and Painting
Welcome everyone and introduce the course.
Be sure to verify that participants intended to take this course.
Introduce yourself. Write your name on the board, flip chart, or transparency. Highlight
your background and experience.
Read the Course Objective: "To prepare Certified Renovators to use lead-safe work
practices to prevent creation of lead hazards during renovation, repair and painting work
in pre-1978 housing and child-occupied facilities."
Ask the participants to introduce themselves, stating:
Their name.
The company they work for.
The work they do (e.g., carpentry).
Meeting facility and logistics:
Indicate where the emergency exits, restrooms and public telephones can be found.
Provide any logistical information.
Discuss ground rules, as necessary. Examples of ground rules include:
o Come back from breaks on time and ready to continue.
o Raise a hand to be recognized.
o Turn off or silence cellular telephones and other electronic devices.
This introduction covers the bulleted list of topics on the slide. Briefly review this list with
the class participants. Do not go into detail about any of the topics.
Identify and address English language and reading issues. Watch for this during the
student introductions.
FebOQ
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Lead Safety for Renovation, Repair, and Painting
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
You will learn...
This course...
Feb09
Why Are You Here?
The traditional renovation work you do now can create 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 completed a Certified Renovator Course, delivered by an
EPA-accredited training provider, you are 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 an EPA-accredited Certified
Renovator Refresher Course before your initial certification expires. Refresher training
must betaken 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.
Feb09
-------
Lead Safety for Renovation, Repair, and Painting
Introduction - Instructor Notes
Slide 2: Course Agenda
This slide contains the course agenda, if you are using Lesson Plan 1 review it with the
students. If you are using Lesson Plan 2 or are conducting this training over several days,
you should provide a suitable agenda. It is also recommended that you make changes to the
PowerPoint slides in both the student manual and the presentation that reflect the changes
to the agenda.
The agenda on the slide does not contain times (because the training could be offered over
several days), so you may want to write the agenda (with times) on a flip chart, blackboard
or whiteboard so that participants can refer to it throughout the course, or you could make a
hardcopy of the agenda and distribute it to participants. Training time must total 8 hours.
Walk participants through the agenda for the training.
Mention the test.
Notes to Instructors on How to Use This Curriculum (see earlier in the introduction) has
a proposed course schedule and lesson plan options to help you plan your schedule.
This slide assumes that you will use Lesson Plan 1. Modify the slide if
you will be using Lesson Plan 2.
FebOQ
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Lead Safety for Renovation, Repair, and Painting
Course Agenda
Introduction and welcome
Module 1: Why Should I
Be Concerned About
Lead Paint?
Module 2: Regulations
Module 3: Before
Beginning Work
Module 4: Contain Dust
During Work
Module 5: During the
Work
Module 6: Cleaning
Activities and
Checking Your Work
Module 7:
Recordkeeping
Module 8: Training
Non-Certified
Renovation Workers
Feb09
FebOQ
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Lead Safety for Renovation, Repair, and Painting
Introduction - Instructor Notes
Slide 3: Training Manual Overview
Walk participants through the eight modules by highlighting the module title and length of
time needed to cover the material.
Emphasize that the course is intended to be interactive, with discussions and exercises to
practice some of the activities discussed in the modules.
Highlight each of the appendices.
Take the time to have participants turn to the Small Entity Compliance Guide to Renovate
Right (Appendix 4) and the Steps to LEAD SAFE Renovation, Repair, and Painting
(Appendix 5). Explain that these two documents will be covered in greater detail in Modules
3 and 8, respectively, and that they can take them to the job to help provide guidance on
working in a lead safe manner. The pamphlet Steps to LEAD SAFE Renovation, Repair, and
Painting (Appendix 5) contains illustrations of suggested methods for reducing, containing
and cleaning up dust in work areas.
FebOQ
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Lead Safety for Renovation, Repair, and Painting
Training Manual Overview
Eight modules
Interactive and hands-on exercises, in 11 Skill
Sets
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
Feb09
Modules - In addition to this introduction, there are eight modules in this course:
Module 1: Why Should I Be Concerned About Lead Paint?
Module 2: Regulations
Module 3: Before Beginning Work (includes Skill Set #1)
Module 4: Contain Dust During Work (includes Skill Sets #2 - #5)
Module 5: During the Work (includes Skill Set #6)
Module 6: Cleaning Activities and Checking Your Work (includes Skill Sets #7 - #11)
Module 7: Recordkeeping
Module 8: Training Non-Certified Renovation Workers
Activities and Exercises - The course includes activities and exercises to help you identify
methods for reducing the amount of dust you create, and containing and cleaning up the dust you do
create. Many of the exercises and activities take place in small groups, so you will have an opportunity
to share your experiences and ideas with others in the class.
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 Regulations
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.
Feb09
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Lead Safety for Renovation, Repair, and Painting
Introduction - Instructor Notes
Slide 4: You Will Learn...
This slide summarizes what the students will learn during the delivery of each module in this
course.
Read through the bullets and emphasize what will be learned in each module.
FebOQ
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Lead Safety for Renovation, Repair, and Painting
You Will Learn...
Why lead-based paint is a problem during
renovations.
What the EPA and HUD regulations require of Certified
Firms and Certified Renovators.
How to determine if lead-based paint affects work.
How to begin the work.
How to set up the work area to contain dust.
How to work in a lead-safe manner.
How to clean the work area and verify cleanliness.
How to dispose of waste safely.
How to document your work.
Feb09
Module 1: Teaches the health problems related to lead, why lead is a problem you need
to deal with, and who is put at risk if renovations are not handled correctly.
Module 2: Teaches what EPA and HUD rules require of Certified Firms and Certified
Renovators.
Module 3: Teaches how to determine if lead-based paint affects your work, and how to
educate owners and residents in target housing, or owners and adult representatives in
child-occupied facilities about how the work will affect lead in their property. This module
also discusses how to plan the work so that it is lead safe.
Module 4: Teaches how to properly set up the work area so that dust and debris created
by your work do not contaminate the property and leave behind lead dust.
Module 5: Teaches how to work in a lead-safe manner and what practices are prohibited
by the EPA and/or HUD rules; provides information on personal protective equipment.
Module 6: Teaches how to effectively clean up dust generated by the work performed in
the home or child-occupied facility, and teaches Certified Renovators how to conduct a
cleaning verification. This section also contains information about how to dispose of
renovation waste.
Module 7: Teaches the requirements in the EPA and HUD Rules for creating and
maintaining documentation of the work.
Module 8: Teaches the Certified Renovator how to train non-certified renovation workers
in lead safe practices while on the job.
Feb09
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Lead Safety for Renovation, Repair, and Painting
Introduction - Instructor Notes
Slide 5: This Course...
The main point of this slide is to inform participants that completing the training is a way to
be distinctive in the marketplace and bring added value to clients.
Successfully completing this training also qualifies them to work on jobs in Federally-
assisted target housing where lead-safe work practices are required. They must pass the
test at the end of this course and keep the course completion certificate to demonstrate that
they are qualified.
This course is not an abatement course and does not qualify participants to conduct
abatement activities, nor does it meet OSHA requirements. Note that employers are
responsible for complying with any OSHA requirements.
FebOQ
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Lead Safety for Renovation, Repair, and Painting
This Course...
Meets EPA and HUD requirements.
Produces EPA Certified Renovators.
Demonstrates your commitment to safety.
BUT,
Is not an abatement course.
Does not satisfy OSHA training requirements.
May not satisfy state, local or tribal training
requirements.
Feb09
The Value of this Training
This course meets EPA and HUD requirements for lead-safe work practices training
under the RRP Rule.
Renovators obtain EPA certification after successful completion of the course.
Completing this training demonstrates your company's competence to prospective
clients and can be a marketing advantage that distinguishes your company from the
competition.
Lead Abatement Training
Lead abatement refers to work that is done for the specific purpose of permanently
removing lead-based paint and lead-based paint hazards from a home. This course is
not an abatement course designed to address the removal, encapsulation or enclosure
of lead-based paint or lead-based paint hazards. This course is not an Operations and
Maintenance course designed to manage lead-based paint in place using interim
controls. To perform lead abatement work requires additional specialized training.
OSHA
OSHA has training requirements for workers that employers should be aware of. For
more information on OSHA requirements, visit
www.osha.gov/Publications/osha3142.pdf.
State, Local, and Tribal Requirements
Many states, localities and Indian tribes have their own lead-based paint requirements,
including specific training and certification requirements. Check with your State, local or
tribal housing and environmental agencies to obtain information about such
requirements.
Feb09
-------
-------
Module 1: Why Should I Be
Concerned About Lead Paint?
-------
Lead Safety for Remodeling, Repair, and Painting
Module 1 Instructor Notes
Feb09
Overview of this module: The table below summarizes the content and teaching
methods for this module. This is for your reference. Do not cover this with the
participants.
Module 1: Why Should I Be Concerned About Lead Paint?
20 Minutes
1-1: Module 1: Why Should I be
Concerned about Lead Paint
1-2: What Is Lead-Based Paint?
1-3: Health Risks of Lead
1-4: Symptoms of Lead Poisoning are
Not Always Obvious
1-5: Why are Dust and Debris a
Problem?
1-6: A Little Dust Goes a Long Way
1 -7: Video Clip of Contractor Who
Poisoned His Own Kids
1 -8: Video Clip of Parent of a Child
Poisoned by Renovation
1-9: Now You Know...
Key message: Dust is the problem and
contractors make dust. By working lead
safe, you can make a difference.
Notes: This module has a demonstration
by the instructor, followed by slides.
Paint chip and sweetener packet
demo (5 minutes).
Slides (15 minutes)
Preparing for this module: Have materials
ready for the exercise and demonstration.
Materials needed: Laminated paint chip,
sweetener packet, dustpan, broom, dust
wipe kit.
Slide 1-1: Module 1: Why Should I Be Concerned About Lead Paint?
This module covers the bulleted list of topics on the slide. Review this list with the
class participants.
Module objective: The purpose of this module is to identify and describe the health
effects of lead exposure and thereby establish the importance of protecting residents
(and workers) from exposure to lead-contaminated dust.
Upon completion of this module, participants will be able to explain:
The federal definition of lead-based paint.
The health risks of lead to children and adults.
Why we are concerned with lead-contaminated dust.
1-1
-------
Lead Safety for Renovation, Repair, and Painting
Module 1: Why Should I be
Concerned about Lead Paint?
Overview
What is lead-based paint?
What health risks and health effects are related to
lead exposure?
Why is lead-contaminated dust a problem?
Feb09
1-1
Upon completion of this module, you will be able to explain:
What lead-based paint is and why it is a problem for renovators.
The health risks of lead to children and adults.
Why we are concerned with lead-contaminated dust.
1-1
Feb09
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Lead Safety for Remodeling, Repair, and Painting
Module 1 Instructor Notes
Feb09
Slide 1-2: What Is Lead-Based Paint?
The purpose of this slide is to provide the Federal definition of "lead-based paint."
Emphasize that identifying lead-based paint will be covered in Module 3. Also be
sure to cover relevant state and local definitions of lead-based paint.
Read the Federal definition of lead-based paint and point out that state and local
governments may have different definitions for lead-based paint.
Instructors should only briefly touch on why lead was used in paints.
A discussion of the health effects of lead and the problems associated with
exposures to lead dust should not be introduced with this slide, at this time.
Review the notes beneath the slide.
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Lead Safety for Renovation, Repair, and Painting
What Is Lead-Based Paint?
Federal standards define lead-based paint as:
Any paint or surface coatings that contain lead equal to or in
excess of 1.0 milligram per square centimeter or more than 0.5
percent by weight.
Some states and localities regulate paint with lower
concentrations of lead.
It is the primary source of lead-contaminated dust in housing.
Why was lead used in paint?
Lead was added for color and durability.
Lead-based paint was banned in 1978.
Feb09
1-2
Federal standards define lead-based paint.
Lead-based paint is any paint or surface coatings that contain lead equal to or in excess of 1.0
milligram per square centimeter or more than 0.5 percent by weight.
Paint with concentrations of lead lower than the definition above can still cause health problems.
Even paint with a small amount of lead can account for a lot of lead in airborne or settled dust.
Information on how to determine if a property contains lead-based paint is provided in Module 3.
Some states and localities regulate paint with lower concentrations of
lead.
You should check with your state and local health departments to see if they have requirements
that are more stringent than the Federal requirements.
Why was lead added to paint?
Lead was added for color and durability.
Lead was also added to some other surface coatings, such as varnishes and stains.
Lead-based paint was banned from residential use in 1978
In 1978, the Consumer Products Safety Commission banned the sale of lead-based paint for
residential use. In practice, this means that homes built in 1978 could still have used lead-based
paint, because existing supplies of paint containing lead would still have been available.
This is why the year of construction is such an important consideration.
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Lead Safety for Remodeling, Repair, and Painting
Module 1 Instructor Notes
Feb09
Slide 1-3: Health Risks of Lead
This slide and the next cover similar points, so review both slides before presenting
to the class to be sure you make the connection and the necessary points
appropriate for each slide.
Health Effects in Children
Children, particularly children under age 6, are most at risk from small amounts of
lead.
For children, the major route of entry of lead into the body is through ingestion of
leaded dust by normal hand-to-mouth contact as they swallow dust from their hands,
toys, and other things they put in their mouths.
Children's bodies absorb a much greater percentage (-50%) of the lead that they
ingest or breathe, compared to adults (-10%).
In children, lead can cause:
Decreased intelligence, attention deficit disorder and learning disabilities.
Behavioral problems.
Nervous system and kidney damage.
Speech and language problems.
While low-lead exposure is most common, exposure to high levels of lead can have
devastating effects on children, including seizures, unconsciousness, and, in some
cases, death. Many studies suggest that once lead has damaged a child, the damage is
permanent. You can remove the child from the exposure but the damage remains.
Health Effects in Adults
Emphasize that for most adults, the major route of entry of lead into the body is
through inhalation (breathing) of leaded dust via occupational exposures.
In pregnant women:
Lead in their blood is transferred to the fetus (unborn child).
Harm to the fetus may include brain damage and death.
In adults, lead can cause:
High blood pressure.
Fertility problems in both men and women.
Digestive problems.
Nerve disorders.
Sexual disorders.
Memory and concentration problems.
Muscle and/or joint pain.
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Lead Safety for Renovation, Repair, and Painting
Health Risks of Lead
Very hazardous to children.
Damages the brain and central nervous system; can cause
decreased intelligence, reading and learning difficulties,
behavioral problems, and hyperactivity.
Damage can be irreversible, affecting children throughout their
lives.
Hazardous to pregnant women.
Damage to the fetus.
Also hazardous to workers and other adults.
High blood pressure.
Loss of sex drive and/or capability.
Physical fatigue.
Lead exposure causes permanent damage.
&EPA
Feb09
1-3
Children under six are most at risk from small amounts of lead.
Children are at a greater risk than adults because their bodies are developing. During
normal and frequent playing or hand-to-mouth activity, children may swallow or inhale
dust from their hands, toys, food or other objects.
In children, lead can cause:
Nervous system and kidney damage.
Decreased intelligence, attention deficit disorder, and learning disabilities.
Speech, language, and behavior problems.
Among adults, pregnant women are especially at risk from exposure to
lead.
Lead is passed from the mother to the fetus and can cause:
Miscarriages
Premature births
Brain damage
Low birth weight
Health effects of lead in adults include:
High blood pressure.
Fertility problems in men and women.
Digestive problems.
Nerve disorders.
Memory and concentration problems.
Sexual disorders.
Muscle or joint pain.
1-3
Feb09
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Lead Safety for Remodeling, Repair, and Painting
Module 1 Instructor Notes
Feb09
Slide 1-4: Symptoms of Lead Poisoning Are Not Always Obvious
Lead poisoning often has non-specific symptoms, such as irritability in children or
high blood pressure in adults.
The signs and symptoms of lead poisoning are easily misdiagnosed by medical
personnel, thus delaying effective treatment and increasing the likelihood of
permanent physical and mental damage. You should let your doctor know about your
work history and any lead related exposures in order to receive an accurate
diagnosis and proper treatment.
Testing a person's blood is the best way to measure exposure to lead.
The most common way to measure the amount of lead in blood is the Blood Lead
Level (BLL) test.
It is not necessary to describe the BLL test to participants. The information on BLL
testing below is provided for your purposes in case of questions.
The point to emphasize is that even small amounts of lead in the blood are cause for
concern. Make sure to review and cite the examples in the Student Notes concerning
what a microgram is and how small it is.
The BLL test:
Measures the amount of lead that is circulating in your blood.
May provide information about recent exposures to lead.
Does not measure the total amount of lead in your body.
Does not predict if any long-term damage will occur.
The Occupational Safety and Health Administration (OSHA) is responsible for
establishing acceptable blood-lead and airborne-lead exposure limits for adults in
the workplace.
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Lead Safety for Renovation, Repair, and Painting
Symptoms Of Lead Poisoning are
Not Always Obvious
Symptoms are easily misinterpreted by medical
personnel, thus delaying effective treatment and
increasing the likelihood of permanent physical and
mental damage.
Only sure way to determine lead poisoning is to
take a blood lead level (BLL) test.
Feb09
1-4
Lead poisoning does not always have obvious symptoms.
The symptoms of lead poisoning are often non-specific, and are frequently attributed to
other causes.
Specific symptoms that people with lead exposure sometimes complain of include:
Headache
Stomach ache
Irritability
Fatigue
Loss of appetite
Joint and/or muscle pain
Because many symptoms are non-specific or similar to flu symptoms, parents may not be
alerted to get immediate medical attention for their children. This is critical for young
children. The longer a young child stays untreated, the higher the risk of permanent brain
damage.
Workers with an occupational exposure to lead need to inform their doctors in order to give
them all the background needed for an adequate evaluation of symptoms as possibly
related to lead exposure.
The best way to determine if lead is present in the body is by testing blood.
The amount of lead in blood is measured in micrograms per deciliter (u.g/dl) of the blood, a
very small unit of measurement. A microgram is one millionth of a gram. That is like one
penny out of $10,000. For reference, a standard size paper clip weighs about one gram, or
one million times more than a microgram. A microgram is a very small amount of lead.
Remember how small this amount of lead is as it applies to dust cleanup when we get to
Module 4: Contain Dust During Work, Module 5: During the Work, and Module 6:
Cleaning Activities and Checking Your Work.
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Feb09
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Lead Safety for Remodeling, Repair, and Painting
Module 1 Instructor Notes
Feb09
Slide 1-5: Why are Dust and Debris a Problem?
Review the notes beneath the slide.
Highlight the following points:
Tiny amounts of lead can be extremely harmful, especially over time.
If dust contains lead, it can poison workers, residents, and children.
Workers may bring home lead-contaminated dust in their vehicles and on their
clothes and shoes, and expose children and other adults to the lead.
Leaded dust particles are often so small that you cannot see them, yet you can
breathe or swallow them.
Children often inhale or swallow lead-contaminated dust during normal hand-to-
mouth activities. Such activities may include: handling toys followed by putting
fingers into the mouth; directly soiling hands while crawling; and, using window
sills to pull themselves up.
Adults can swallow or breathe dust during work activities.
Pass around a laminated 1 square centimeter paint chip (a piece cut from a paint
sample and glued to a piece of card stock or placed in a test tube will also work) to
show the amount of lead-based paint it takes to poison a child if it were ground and
spread over a room. Lead-based paint contains a minimum of 1 milligram of lead per
square centimeter. Assume that the paint chip contains 1.0 milligram of lead. That
1.0 milligram of lead is equivalent to 1000 micrograms of lead. If this paint chip were
ground into dust, it would contaminate 25 square feet of floor area, more than 15
linear feet of 4-inch window sills, or more than 15 linear feet of 2 inch window troughs
to the regulatory clearance limits. Now you see why only a little lead causes lots of
problems.
Emphasize that even when paint with concentrations of lead lower than the Federal
standard is disturbed, the disturbance can still result in high concentrations of lead in
dust, which can cause health problems.
Emphasize that if proper precautions are not taken prior to, during and after jobs
that generate dust, workers, residents and children may become lead poisoned.
1-5
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Lead Safety for Renovation, Repair, and Painting
Why are Dust and Debris a
Problem?
Renovation activities that disturb lead-based paint
create dust and debris. Debris becomes dust.
Lead-contaminated dust is poisonous.
Very small amounts of lead-contaminated dust can
poison children and adults.
Children swallow dust during ordinary play activities.
Adults swallow or breathe dust during work activities.
Workers can bring lead-contaminated dust home and
poison their families.
Feb09
1-5
Dust and debris from renovation, repair, and painting jobs in pre-1978
housing and child-occupied facilities may contain lead.
Pre-1978 paint may contain lead.
Renovation, repair and painting jobs disturb paint that may contain lead. Any activity
involving surface preparation, such as hand-scraping, power sanding, the use of heat
guns above 1100ฐ Fahrenheit, and open flame burning, can generate lead dust. More
complicated tasks such as removing building components and demolishing walls also
can create a lot of dust.
Small amounts of lead-contaminated dust can poison children and
adults.
A tiny amount of lead can be extremely harmful.
Leaded-dust particles are often so small that you cannot see them, yet you can breathe
or swallow them. These smaller, inhaled or swallowed dust particles are more easily
absorbed by the body than larger particles, and can therefore more easily cause
poisoning.
Leaded dust may be breathed or swallowed by children, residents and workers.
Through normal hand-to-mouth activities, children may swallow or inhale dust on their
hands, toys, food, or other objects. Children may also ingest paint chips.
Adults can swallow or breathe dust during work activities.
When workers perform activities such as scraping and sanding by hand, or use a
power sander or grinding tool, dust is created. The dust goes into the air that they
breathe.
If workers eat, drink, smoke or put anything into their mouths without washing up
first, they may swallow the leaded dust present.
1-5
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Lead Safety for Remodeling, Repair, and Painting
Module 1 Instructor Notes
Feb09
Slide 1-6: A Little Dust Goes a Long Way
For this slide you need a sweetener packet, and a broom and dustpan. Note: You can
also do this demonstration with a powder called "Glo Germ" which shows up under a
black light (http://www.glogerm.com).
Do the following demonstration to emphasize the points on this slide.
Tear open a packet of artificial sweetener and sprinkle it on the floor. (Note: Use
artificial sweetener rather than sugar. It is finer.) You might also tear the package
open in the beam of light from a powerful flashlight or projector to demonstrate how
fine the dust is and then point out how hard it is to see on the floor or in the carpet
once it settles. The point is that it takes some time for fine particles to settle.
Ask a few participants to walk through the spilled sweetener.
Now give a participant a broom, and tell him or her to sweep up the sweetener.
Questions to the class - "Do they think the sweetener is all gone?" (No.) Ask them if
there is any on the soles of the feet that walked through it. (Yes.) Where is that
sweetener now? (Probably all over the room).
Explain that one way to test the amount of sweetener on the floor is to do a dust
wipe.
Question for the class: "Do you think a lab analysis would show sweetener on the
wipe?" (Yes.)
Now tell the class to imagine that the packet was actually full of lead dust. The fact is
that a packet of crushed lead-based paint that size (one gram) could contaminate an
entire room to levels above the Federal clearance limit. The math that substantiates
this assertion is provided below. You do not need to go into it in detail but use it if
questioned.
Sweetener Packet Math (Use the information below only if asked by participants.)
A packet of sweetener contains one gram of sweetener. Imagine that one-gram packet
contained, instead, crushed paint with just enough lead to be defined as lead-based
paint (0.5% by weight). The sweetener packet would then contain 5,000 micrograms of
lead dust, enough to contaminate 125 square feet to a level of 40 micrograms per
square foot. If the dust had a higher lead content, it could contaminate an even larger
area: At 1 % lead, one gram could contaminate 250 square feet; at 5% lead, it could
contaminate 1,250 square feet.
1-6
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Lead Safety for Renovation, Repair, and Painting
A Little Dust Goes a Long Way
You can't see it.
It's hard to sweep up.
And, it travels.
One gram of lead-based paint can
contaminate a large area!
Feb09
1-6
A little dust goes a long way.
You can't see it. Even a floor that looks clean can have leaded dust on it. Only a
laboratory test can tell you for sure if an area is contaminated with lead.
It's hard to sweep up. Normal cleaning methods will not pick up all the dust in a work
area. Sweeping is not enough. You need to use water, detergent and a HEPA vacuum
to clean up dust effectively.
It travels. Once dust is released, it is easily tracked around, inside and outside the
work area. And, an exterior painting job can contaminate the inside of a home as the
dust, chips and leaded soil are tracked inside.
Later in this course we will discuss in detail the EPA and HUD dust-lead hazard and
clearance standards. The limits are included here to reinforce the idea that a very small
amount of lead can cause health problems. These numbers represent the amount of
lead measured in micrograms (1 millionth of a gram) that is allowed in an area one foot
wide and one foot long (one square foot). More than this amount of lead in the specified
areas is hazardous.
EPA & HUD use these standards when clearance is performed:
Floors 40 |ag/ft2
Interior window sills 250 M-g/ft2
Window troughs 400 M-g/ft2
NOTE: States and localities may enforce lower standards.
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Lead Safety for Remodeling, Repair, and Painting
Module 1 Instructor Notes
Feb09
Slide 1-7: Video Clip of Contractor Who Poisoned His Own Kids
Introduce the video by reading the student note.
"The following video shows Kevin Sheehan, a lead contractor who discusses how he
poisoned his family while working on older houses which contained lead-based paint.
Kevin discusses the need for lead safety precautions during renovation work, shares the
lessons he has learned, and reveals what can be done to keep people safe during work
in older homes with lead-based paint."
Show the video to the class.
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Lead Safety for Renovation, Repair, and Painting
S-EPA
ff.'f.T,;'
Feb09
Contractor discusses how lead safe work practices could have protected
his kids from becoming lead poisoned.
The video shown at this point in the course is of Kevin Sheehan, a lead contractor, who
discusses how he poisoned his family while working on older houses which contained lead-
based paint. Kevin discusses the need for lead safety precautions during renovation work,
shares the lessons he has learned, and reveals what can be done to keep people safe during
work in older homes with lead-based paint.
1-7
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Lead Safety for Remodeling, Repair, and Painting
Module 1 Instructor Notes
Feb09
Slide 1-8: Video Clip of Parent of a Child Poisoned by Renovation
Introduce the video by reading the student note.
"The following video shows Maurci Jackson, a parent whose child became lead
poisoned, discussing how hard it was to watch her daughter undergo chelation therapy
(the chemical removal of lead from the body). Maurci shares her fears about her child's
future health after being lead poisoned and her frustration that lead poisoning is
completely preventable if those who disturb lead-based paint would just consider the
consequences of working with lead improperly. She emphasizes the need for lead safety
precautions and planning to prevent lead poisoning."
Show the video to the class.
1-8
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Lead Safety for Renovation, Repair, and Painting
lead, (led), n- 1- a tieavy
soft, malleable, bluish-gray
metallic chemical element.
Video Clip of Parent of a Child Poisoned by
Renovation
S-EPA
ff.'f.T,;'
Feb09
1-8
Parent Discusses Child Poisoned by Renovation Undergoing Treatment.
The video shown at this point in the course shows Maurci Jackson, a parent whose child
became lead poisoned, discussing how hard it was to watch her daughter undergo "chelation"
treatments to remove lead from her body. Maurci shares her fears about her child's future
health after being lead poisoned and her frustration that lead poisoning is completely
preventable if those who disturb lead-based paint would just considered the consequences of
working with lead improperly. She emphasizes the need for lead safety precautions and
planning to prevent lead poisoning.
Note: Chelation treatment is a series of medical procedures that remove lead from the body.
1-8
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Lead Safety for Remodeling, Repair, and Painting
Module 1 Instructor Notes
Feb09
Slide 1-9: Now You Know...
Quickly use this slide to close out the module and make the transition to the next module
(Module 2: Regulations).
1-9
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Lead Safety for Renovation, Repair, and Painting
Now You Know...
What lead-based paint is and the adverse
health effects of lead.
Dust is the problem.
Lead poisoning is hard to spot and the effects
can be permanent.
Kids are most at risk for lead poisoning.
Lead poisoning is preventable.
Feb09
1-9
1-9
Feb09
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Module 2: Regulations
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Lead Safety for Renovation, Repair, and Painting
Module 2 Instructor Notes
Feb09
Module 2: Regulations
Purpose: To give the renovators in the training course knowledge of the regulatory
requirements that affect renovation work, and to make them familiar with resources that
they can use to help understand the EPA and HUD Rules.
Review the purpose of this module with the students
Overview of this module: For your reference the table below summarizes the content
and teaching methods for this module. Do not cover this with the participants.
Module 2: Regulations
45 Minutes
2-1: Module 2: Regulations
2-2: The RRP Rule
2-3: The RRP Rule: Exclusions
2-4: The RRP Rule: "Opt-Out" Provision
2-5: The RRP Rule: Firm Certification
2-6: The RRP Rule: Firm Responsibilities
2-7: The RRP Rule: Individual Certification
2-8: The RRP Rule: Certified Renovator
Responsibilities
2-9: The RRP Rule: Work Practice Standards
2-10: The RRP Rule: Enforcement
2-11: HUD's Lead Safe Housing Rule
2-12: HUD's Lead Safe Housing Rule: Safe
Work Practices
2-13: HUD's Rule Addresses:
2-14: Know the EPA and HUD Rules!
2-15: State and Local Regulations
2-16: Now You Know...
Key message: Know the EPA
and HUD Rules. These rules set
forth specific and performance-
based requirements that must be
mastered to achieve compliance.
Notes: Know your audience. All
contractors must know all the
regulations.
Preparing for this module: Review
materials in advance. Read all
federal, state and local
regulations.
Slide 2-1: Module 2: Regulations
Mention that Title X (spoken as "Title Ten") is the enabling law for both EPA and HUD in which
Congress assigned them the authority to regulate various parts of the lead industry.
EPA was tasked to develop training and certification regulations for renovators to follow when
working with lead in pre-1978 housing and child-occupied facilities.
HUD was tasked with establishing guidance for work practices used in lead abatement and lead
hazard control work. HUD is also responsible for regulations governing renovation and lead
hazard control work in Federally-assisted target housing. OSHA is responsible for developing
safety regulations for lead in the construction and general industries.
State and Local Regulations:
Cover applicable state and local regulations at the end of this module.
The EPA Renovation, Repair, and Painting Program Final Rule allows EPA-authorized states
to administer the RRP Rule requirements for EPA. In these states, EPA certification and
accreditation is provided from the authorized state.
In non-authorized states, EPA and state requirements must both be satisfied.
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Lead Safety for Renovation, Repair, and Painting
Module 2: Regulations
U.S. Environmental Protection Agency (EPA):
Established accredited training and certification programs for
workers, supervisors, inspectors and risk assessors conducting
evaluation or abatement of lead-based paint.
Established requirements for pre-renovation education.
Promulgated the Renovation, Repair, and Painting Program Final
Rule (RRP Rule).
U.S. Department of Housing and Urban Development
(HUD):
Established actions in Federally-assisted target housing.
Established Federal grant programs.
Established guidelines for lead-based paint evaluation and
control; established the Lead Safe Housing Rule.
U.S. Occupational Safety and Health Administration
(OSHA):
Established worker protection standards.
Feb09
2-1
U. S. Environmental Protection Agency (EPA):
EPA has established training requirements for people involved in lead abatement (the permanent removal
of lead). Certified Renovators may not perform lead-based paint abatement unless they are Certified
Lead Abatement Workers or Certified Lead Abatement Supervisors.
Lead abatement is defined as any measure or set of measures designed to permanently remove or cover
lead-based paint or lead-based paint hazards. Abatement includes, but is not limited to: (1) The removal of
paint and dust, the permanent enclosure or encapsulation of lead-based paint, the replacement of painted
surfaces or fixtures, or the removal or permanent covering of soil, when lead-based paint hazards are
present in such paint, dust or soil; and (2) All preparation, cleanup, disposal, and post-abatement clearance
testing activities associated with such measures. (40 CFR 745.223).
Abatement does not include renovation, remodeling, landscaping or other activities, when such activities
are not designed to permanently eliminate lead-based paint hazards, but are designed to repair, restore, or
remodel a given structure or dwelling, even though these activities may incidentally result in a reduction or
elimination of lead-based paint hazards. Furthermore, abatement does not include interim controls,
operations and maintenance activities, or other measures and activities designed to temporarily, but not
permanently, reduce lead-based paint hazards. (40 CFR 745.223).
Module 3 has information on the pre-renovation education requirements.
Details on the RRP Rule are in the slides following.
U. S. Dept. of Housing and Urban Development (HUD):
If you work in Federally-assisted target housing, certain actions are required to address lead hazards. In
these cases, the workers must have proper training. See Appendix 2 for more information on the HUD
requirements for worker training and lead hazard reduction in Federally-assisted housing.
HUD has a grant program to state and local governments for funding lead hazard reduction activities.
Check with nearby states and localities to find out if there are any local programs (which may be state or
Federally funded) that are designed to address lead hazards.
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 29 CFR 1926.62 (http://www.osha.gov/Publications/osha3142).
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 the end of this module.
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Lead Safety for Renovation, Repair, and Painting
Module 2 Instructor Notes
Feb09
Slide 2-2: The RRP Rule
When covering this slide make sure to define the terms below.
Target Housing is a home or residential unit built on or before December 31, 1977,
except:
o Housing built for the elderly or persons with disabilities (unless a child less than 6
years old lives there or is expected to live there); or,
o Zero-bedroom dwellings (studio apartments, hospitals, hotels, dormitories, etc).
Note: Target Housing may also be referred to as "Pre-1978 housing".
A Child-Occupied Facility is any pre-1978 building or portion of a building that is
visited by the same child, under 6 years old; the visits are at least two different days
within any week, for at least 3 hours each day and where the combined weekly visits
exceed 6 hours and combined annual visits exceed 60 hours. Child-occupied
facilities include: schools, child-care facilities, and daycare centers.
Note that EPA may authorize states, territories and tribes to enforce all aspects of the
RRP Rule. Such states are called "Agreement states." EPA enforces the Rule in non-
Agreement states.
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Lead Safety for Renovation, Repair, and Painting
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.
On or 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.
Feb09
2-2
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).
After April 22, 2010, 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 "Agreement states." EPA enforces the Rule in non-
Agreement states.
The Rule is effective April 22, 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 work covered by the rule.
Renovators must educate owners/occupants (Module 3).
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Lead Safety for Renovation, Repair, and Painting
Module 2 Instructor Notes
Feb09
Slide 2-3: The RRP Rule: Exclusions
Explain to students that there are several situations in which the rule will not apply to
their work, such as:
When a lead inspection report prepared by a Certified Lead Inspector or Risk
Assessor finds that no lead-based paint is present in the target home or child-
occupied facility on surfaces that will be disturbed during the work.
When an EPA-recognized test kit used by a Certified Renovator to test surfaces that
will be disturbed by renovation, repair or painting work identified no lead-based paint
during testing.
When interior renovation, repair, or painting work disturbs less than 6 square feet of
paint per room. Window replacement and demolition do not qualify for exclusions,
even if the amount of disturbed known or presumed lead-based paint is below this
limit.
When exterior renovation, repair or painting work disturbs less than 20 square feet of
paint per side of the building.
When the homeowner conducts renovation, repair and painting in the home they
occupy.
When the work is not conducted for compensation of any kind.
When an emergency renovation is performed, the pre-renovation education and set-
up requirements are waived to the extent necessary to respond to the emergency.
Other requirements are waived if necessary to respond to the emergency; otherwise
they are in effect. The renovation firm must still clean the home and conduct either
cleaning verification or clearance prior to re-occupancy. It would be common for
there to be no residents in this case. Personal protective measures and prohibitions
on work practices still apply to this work.
Note that prohibited practices must not be used even if exclusions apply to the work.
2-3
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Lead Safety for Renovation, Repair, and Painting
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 exclusion does not apply to window
replacement, demolition or activities involving
prohibited practices.
Renovations performed by homeowners in
their own homes.
Feb09
2-3
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.
1. 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.
2. 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.
3. Minor repair and maintenance activities do not include window replacement, demolition
or activities involving prohibited practices.
4. The entire surface area of a removed component 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.
2-3
The HUD Lead Safe Housing Rule applies to every home built prior to 1978
that receives Federal housing assistance, typically provided through state
and local governments, 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.
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 2 Instructor Notes
Feb09
Slide 2-4: The RRP Rule: "Opt-Out" Provision
The Opt-Out exemption applies when the homeowner chooses not to use lead-safe work
practices and certifies in writing, that:
The homeowner and their family reside in the home;
There is no child under 6 years residing in the home;
There is no pregnant female residing in the home;
There is no child-occupied facility in the home;
The owner and residents have been educated about the dangers of lead during
renovations and have received the Renovate Right pamphlet; and, the Owner
signs a written acknowledgement that the Certified Firm is not required to use the
work practices found in the Rule.
Notes:
Make sure that whatever form you use to record this information allows the owner to
document how they meet all requirements of the Opt-Out Provision in the Rule.
2-4
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Lead Safety for Renovation, Repair, and Painting
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 and
the house is not a child-occupied facility;
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. vsrEPA
Feb09
2-4
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 live 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 or 20 square feet of exterior lead-
based paint will be disturbed during renovation, repair or painting.
2-4
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 2 Instructor Notes
Feb09
Slide 2-5: The RRP Rule: Firm Certification
Cite the October 22, 2009 as the date when renovation firms may first apply for
certification under the rule.
Allude to the April 22, 2010 as the date when all renovation firms must be certified to
continue doing renovation, repair or painting work.
Remind students that firm certification requires an application and a fee to be paid to
EPA. Firm certification is a different certification from the individual certification
received by renovators after successful completion of this course.
Tell students that certification of a firm lasts for 5 years after it is issued by EPA and
gives the firm the ability to operate as renovators in any non-EPA-authorized states.
Explain that firm certification may also be required by state and local governments,
and that they need to check with the appropriate agencies to determine what
requirements apply.
2-5
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Lead Safety for Renovation, Repair, and Painting
The RRP Rule: Firm Certification
On or after April 22, 2010, all covered renovations
must be performed by Certified Firms, using
Certified Renovators and other trained workers.
To become certified, firms must submit an
application, and pay a 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.
x>EPA
Feb09
2-5
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, or 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.
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.
2-5
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 2 Instructor Notes
Feb09
Slide 2-6: The RRP Rule: Firm Responsibilities
Review the information on the slide and in the student text.
2-6
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Lead Safety for Renovation, Repair, and Painting
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.
x>EPA
Feb09
2-6
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 set-up 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 7.
2-6
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 2 Instructor Notes
Feb09
Slide 2-7: The RRP Rule: Individual Certification
Cite April 22, 2010 as the date when at least one individual renovator on-the-job
must be certified to oversee renovation, repair or painting work.
Certification as a Certified Renovator only requires successful completion of an EPA-
approved training course conducted by an EPA-accredited training provider.
State to the students that certification will last for 5 years from the date of successful
course completion and gives them the ability to operate as Certified Renovators in
any non-EPA-authorized state.
Remind students that they will have to carry a copy of their training information with
them on the job.
Explain that state, local and tribal entities may also require certification in some
areas, and that they need to check with the appropriate agencies to determine what
requirements apply.
To maintain their certification, Certified Renovators must take refresher training from
an EPA-accredited Renovator Refresher Training Provider before the 5-year
anniversary of their initial certification course date.
2-7
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Lead Safety for Renovation, Repair, and Painting
The RRP Rule:
Individual Certification
To become a Certified Renovator, an individual
must take an EPA-approved 8-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.
Feb09
2-7
On or after April 22, 2010, all renovations must be directed by Certified Renovators.
Individuals may become Certified Renovators by completing an EPA-approved 8-hour
training course in lead-safe work practices taught by an EPA-accredited training provider.
Successful completion of that 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).
2-7
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 2 Instructor Notes
Feb09
Slide 2-8: The RRP Rule: Certified Renovator Responsibilities
Review the slide and student text with students.
2-8
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Lead Safety for Renovation, Repair, and Painting
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.
x>EPA
Feb09
2-8
The RRP Rule requires that an individual Certified Renovator be responsible for
the renovation job regardless of the level of training and certification of the other
persons working on the job. This individual Certified Renovator has the following
responsibilities.
1. Perform work and direct the work of non-certified renovation workers.
2. Train all non-certified workers on-the-job in lead-safe work practices.
3. Maintain copies of initial and/or refresher training certifications onsite.
4. Conduct testing for lead-based paint using EPA-recognized test kits and report
findings.
5. Remain onsite during the sign posting, work area setup, and cleanup phases of
work.
6. When not on site, be available by telephone or pager.
7. Make sure that the containment is maintained in a way that prevents the escape of
dust and debris. This responsibility implies a need to determine which work
practices should be used to minimize dust.
8. Conduct the cleaning verification procedure to make sure that the work is
complete and that the work area is ready to reoccupy.
9. Prepare a summary of the work, maintain training and certification records, and
certify that all work was done in a lead safe manner.
2-8
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 2 Instructor Notes
Feb09
Slide 2-9: The RRP Rule: Work Practice Standards
Quickly review the topics on the slide.
Emphasize that the steps involved in lead safe work practices: Setup, Prohibited
Practices and Dust Reduction Practices, Cleanup and Cleaning
Verification/Clearance and, Recordkeeping, will be addressed in Modules 4, 5, 6 and
7, respectively.
2-9
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Lead Safety for Renovation, Repair, and Painting
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
procedure.
Setup practices, such as posting signs and containing
the work area, will be covered in Module 4.
Prohibited practices and dust reduction suggestions
will be covered in Module 5.
Cleanup practices and cleaning verification
procedures will be covered in Module 6.
Recordkeeping will be covered in Module
its?
Feb09
2-9
HUD has additional work practice requirements. See Slide 2-13.
2-9
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 2 Instructor Notes
Feb09
Slide 2-10: The RRP Rule: Enforcement
Documentation: Inform the students of the following:
Documentation of renovations, testing and training related to renovations must be
kept for 3 years after the end of the job.
Enforcement: Inform the students of the following:
EPA has the authority to seek a civil fine of $32,500 per offense and an additional
criminal fine of $32,500 plus jail time for a firm that knowingly and willfully violates
the Renovation, Repair, and Painting Rule requirements.
EPA can also revoke certifications for firms and individuals who violate Renovation,
Repair, and Painting Rule requirements.
2-10
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Lead Safety for Renovation, Repair, and Painting
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 of up to
$32.500 for each violation.
Those firms who knowingly or willfully
violate this regulation may be subject to
fines of up to an additional $32.500 per
violation, or imprisonment, or both. vปEPA
Feb09
2-10
Enforcement:
EPA has the authority to seek civil fines of $32,500 per offense and an additional
criminal fine of $32,500 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.
2-10
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 2 Instructor Notes
Feb09
Slide 2-11: HUD's Lead Safe Housing Rule
Trainer's Note: This slide introduces the HUD rule and outlines the general target
audience for that regulation.
Discuss the types of affected housing, the program-based nature of the Lead Safe
Housing Rule requirements, and effective dates.
Emphasize that in order to determine if a property receives Federal financial
assistance, you should ask the questions found in Appendix 2 under "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".
Point out that, as they are renovated, the numerous pre-1978 homes in foreclosure
(as of early 2009) may be subject to the EPA RRP rule or HUD regulations, or both,
as applicable.
2-11
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Lead Safety for Renovation, Repair, and Painting
HUD's Lead Safe Housing Rule
Covers federally-owned or -assisted target
11OUSING and federally-owned target
housing being sold. Renovators should ask
if the housing receives financial assistance.
If yes, the renovator should ask the owner to
find out if the assistance is federal assistance.
HUD's rule has evaluation and control
requirements based on type of assistance:
Visual assessment, lead paint inspection;
Paint stabilization, interim control, abatement;
Ongoing lead-based paint maintenance.
FebOQ
HUD requirements for federally assisted housing are similar to those in the EPA rules with
some exceptions. In this curriculum the differences between the HUD rules and the RRP
Rules will be highlighted when they occur by special text boxes containing the HUD logo.
These boxes are located at the bottom of pages on which an EPA requirement and a HUD
requirement differ. Appendix 2, contains an overview of the HUD requirements, and a table
detailing differences between the rules.
The HUD "Lead Safe Housing Rule" covers pre-1978 Federally-owned or assisted housing
and Federally-owned housing which is being sold. Housing owned and operated by a Federal
agency other than HUD may be covered by this regulation.
HUD's rule does not cover "Child-Occupied Facilities" unless they are part of a residential
property covered by the rule. This differs from the EPA Renovation, Repair and Painting Rule,
which covers housing and child occupied facilities, whether or not they are federally-assisted.
Wherever the EPA regulations and HUD regulations differ, the more protective standard must
be followed.
HUD has many programs that provide financial assistance, for example: rehabilitation,
community development, acquisition assistance, etc. HUD requires addressing lead-based
paint hazards (such as peeling paint, friction and impact surfaces, and high lead dust levels)
by linking those activities to the HUD financial assistance. When asking clients if the housing
is receiving federal assistance, renovators should recognize that the assistance may come
through a state or local government, community development corporation or other local entity,
so they may have to ask the client to check into the ultimate source of the assistance funds.
HUD does not recognize on-the-job worker training alone, and generally requires all
individuals performing interim controls (see Slide 2-12) of lead hazards in Federally-owned
and Federally-assisted housing to complete a HUD-approved training course. HUD's training
requirements for work other than abatement are satisfied by successful completion of this
EPA/HUD jointly approved Certified Renovator Course.
2-11
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 2 Instructor Notes
Feb09
Slide 2-12: HDD's Lead Safe Housing Rule: Safe Work Practices
Remind students of the components of interim controls.
Advise students to check with their state to find out if state law or regulation allows
interim controls to be done by trained but uncertified individuals. If they do,
renovation contractors may perform these activities.
Explain the four activities where HUD requires Lead-Safe Work Practices:
Paint stabilization - This activity returns non-intact paint to an intact condition.
Rehabilitation (receiving <$5,000 per unit) - These are small scale activities that
upgrade existing structures. These include activities such as the replacement of
one or two windows. Rehabilitation is defined in the Lead Safe Housing Rule as
the improvement of an existing structure through alterations, incidental additions,
or enhancements. Rehabilitation includes repairs necessary to correct the results
of deferred maintenance, the replacement of principal fixtures and components,
improvements to increase the efficient use of energy, and installation of security
devices.
Standard Treatments - These are a group of activities, such as treating doors
and windows so they do not rub and generate dust, that are conducted to
address the potential generation of lead hazards. These treatments are usually
done if lead is assumed to be present.
Ongoing lead-based paint maintenance - These are tasks that are done over
and over again, and include all maintenance activities that disturb lead-based
paint.
Contrast the "de minimi's" limits in the HUD rule with the minor repair and
maintenance limits in the RRP Rule.
2-12
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Lead Safety for Renovation, Repair, and Painting
HUD's Lead Safe Housing Rule:
Safe Work Practices
HUD's rule requires lead safe work practices for:
Paint stabilization
Interim control of identified lead-based paint
hazards
Rehabilitation (renovation)
Standard treatments
Ongoing lead-based paint maintenance
HUD's de minimis level is smaller than the
RRP Rule's minor repair and maintenance level
FebOQ
The HUD Lead Safe Housing Rule requires lead safe work for the activities listed on the slide. It
specifies prohibited practices, requirements for protecting occupants, and preparing the work site.
Special cleaning techniques must be used and clearance achieved.
Lead safe work practices are required during:
Paint Stabilization - Renovation to repair non-intact painted surfaces (flaking, peeling, or
otherwise damaged) by performing substrate repair (if needed), surface preparation and
repainting. The result is an intact painted surface.
Interim Controls - Interim controls are defined by HUD to include repairs, painting, temporary
containment, specialized cleaning, clearance, ongoing lead-based paint maintenance activities,
and the establishment and operation of management and occupant education programs.
Rehabilitation - This is HUD's term for the renovation of properties.
Standard Treatments - a set of measures that reduce all potential lead-based paint hazards in
a dwelling unit when lead-based paint is presumed to be present (no lead-based paint
evaluation is performed); all deteriorated paint is treated as a lead-based paint hazard.
Ongoing Maintenance - Normal maintenance activities.
In Federallv-owned/assisted target housing, all areas of deteriorated paint in the work area must be
repaired. Work affecting less than the small - "de minimis" - amounts listed below is not required to
follow the lead safe work practices and clearance requirements in the HUD Rule. HUD's "de minimis"
limits are smaller than the limits for minor repair and maintenance activities in the EPA's Renovation,
Repair and Painting Rule. HUD's "de minimis" amounts are:
2 square feet in any one interior room or space.
20 square feet on exterior surfaces.
10% of the total surface area of small interior or exterior component type.
HUD's clearance requirements are covered in Module 6. In general, clearance is required after all
work above HUD's de minimis amounts, and is performed by a certified professional, such as a Lead
Inspector, Lead Risk Assessor, or Dust Sampling Technician, who is independent of the Certified
Renovation Firm. State and local jurisdictions may have different clearance requirements than HUD's
and EPA's; the most stringent requirements must be used.
2-12
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 2 Instructor Notes
Feb09
Slide 2-13: HUD's Rule Addresses:
Review the slide and student notes with the class. Point out the differences between
the EPA and HUD Rules.
The notes under the slide mirror information found in the Appendix 2 table:
Differences between HUD LSHR and EPA RRP regulations.
2-13
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Lead Safety for Renovation, Repair, and Painting
HUD's Rule Addresses:
Training (usually classroom training for workers)
Occupant protection and worksite preparation
Prohibited methods (3 in addition to RRP Rule's)
De minimis levels (smaller than RRP Rule's)
Lead safe work practices
Specialized cleaning
Clearance testing (covered in Module 6)
Occupant notification (within 15 days)
x>EPA
JfiMSS
Ewianii
Feb09
2-13
The HUD Lead Safe Housing Rule (LSHR) covers renovation work in Federally-assisted crowned target
housing, and specifically addresses the following lead safe activities.
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 8).
Occupant Protection and Worksite Preparation: Occupants have to be kept out of the work area
during the renovation work, and must be relocated from the unit during longer renovation projects.
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 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 stripper in poorly ventilated space.
De minimis levels: HUD has a smaller cte minimis threshold for interior work than EPA's limit for minor
repair and maintenance activities. See the notes on the previous slide for details.
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 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 LBP
or LBP hazards in their unit (and common areas, if applicable) are identified, and within 15 days after
completion of the hazard control work in their unit or common areas.
2-13 Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 2 Instructor Notes
Feb09
Slide 2-14: Know the EPA and HUD Rules!
Quickly present this for informational purposes.
2-14
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Lead Safety for Renovation, Repair, and Painting
Know the EPA and HUD Rules!
To obtain a copy of the regulations
contact the National Lead Information
Center at 1-800-424-LEAD.
You may also download the rules and
other information from the following
websites:
www.epa.gov/lead
www.hud.gov/offices/lead
FebOQ
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.
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.
2-14
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 2 Instructor Notes
Feb09
Slide 2-15: State and Local Regulations
This slide is reserved for state and local regulations that apply to the Certified
Renovator and the Certified Firm. If state or local requirements for renovations differ
from EPA and HUD requirements, they must be included in the course information at
this point in the presentation.
Instructors must determine what additional state and local regulations apply to
renovation work and add that information to this page and to the accompanying slide
and student notes.
Copies or summaries of applicable state and local or tribal regulations must be
included in Appendix 7, which has been reserved for that purpose.
2-15
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Lead Safety for Renovation, Repair, and Painting
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.
xvEPA
Feb09
2-15
Reserved for student notes on state and local regulations for renovation that differ from
the EPA and HUD regulations.
2-15
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 2 Instructor Notes
Feb09
Slide 2-16: Now You Know...
Quickly read through the slide and use it as a bridge to the next topic (Module 3:
Before Beginning Work).
2-16
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Lead Safety for Renovation, Repair, and Painting
Now You Know...
That the EPA Renovation, Repair, and Painting
Program Final Rule (RRP Rule) applies to renovation
in housing and child-occupied facilities built before
1978 that contain lead-based paint.
To always take into account the requirements and
responsibilities of certification for Certified Firms and
Certified Renovators, and to re-certify every 5 years.
To comply with setup of the work area, prohibited
work practices, cleanup and the cleaning verification
procedure requirements in the Rule.
To determine whether your renovation job is regulated
by EPA, HUD, both, or neither.
Feb09
2-16
2-16
Feb09
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Module 3: Before Beginning Work
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Lead Safety for Renovation, Repair, and Painting
Module 3 Instructor Notes
Feb09
Overview of this module: The table below summarizes the content and teaching
methods for this module. This is for your reference. Do not cover this with the
participants.
Module 3: Before Beginning Work
40 minutes
3-1: ModuleS: Before
Beginning Work
3-2: Educate Owners and
Residents
3-3: How Widespread is Lead-
Based Paint in Housing?
3-4: How to Determine if Lead-
Based Paint is Present
3-5: Using EPA-Recognized
Test Kits to Check for Lead-
Based Paint
3-6: Test Kit Hands-on
3-7: Using Decision Logic
Charts
3-8: Now You Know...
Key message: Plan before you start the work.
Notes: This module contains two exercises: a
hands-on exercise using EPA-recognized test kits
and a paint chip; and, a paper-based exercise
using the decision-making flow charts from the
Compliance Guide to determine what EPA and
HUD requirements apply to the work.
Preparing for this module: Review materials in
advance so you are familiar with the scenarios and
the checklist.
Hands-On Exercise with Test Kits: Participants will
learn when and how to use lead test kits. Review
materials in advance so you are familiar with Skill
Set#1.
Slide 3-1: Module 3: Before Beginning Work
The purpose of this module is to help the Certified Renovator to ask the right
questions to plan a job and to emphasize the importance of planning. The module
walks through a brief, simple scenario. Following that, participants will fill out a
planning checklist and then discuss it.
Announce the module and move quickly to the next slide.
3-1
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Lead Safety for Renovation, Repair, and Painting
Module 3: Before Beginning Work
Overview
This module teaches you:
To educate owners and residents.
That the use of lead-based paint was
widespread.
To determine if lead-based paint is present.
To use EPA-recognized test kits to check for
lead-based paint.
How to decide which rule(s) apply.
&EPA
Feb09
3-1
Module Overview
The module also considers the important questions that must be asked at the beginning of
a job to establish whether a job is covered by the RRP Rule and/or the HUD Rules, and
what requirements apply.
3-1
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 3 Instructor Notes
Feb09
Slide 3-2: Educate Owners and Residents
Review requirements for pre-renovation education.
Ask students if they have any questions concerning their obligations under EPA
regulations regarding educating owners and residents. Make sure to review the
requirements for dwelling units, common areas, and child-occupied facilities.
Remind students to check with state and local authorities to find out if they have any
additional rules, regulations and/or requirements for working with lead-based paint.
Walk the class through the pamphlet Renovate Right: Important Lead Hazard
Information for Families, Child Care Providers, and Schools, in Appendix 3.
Emphasize that the Renovate Right pamphlet may be copied to use to comply with
pre-renovation education requirements.
3-2
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Lead Safety for Renovation, Repair, and Painting
Educate Owners and Residents
The Pre-Renovation Education Rule:
Requires Renovation Firms to provide the Renovate Right pamphlet to
owners/residents prior to renovation activities in pre-1978 housing and
child-occupied facilities.
Specifies requirements for educating residents/occupants and
delivering the Renovate Right pamphlet that vary by type of property
and the area being renovated.
Under the RRP Rule, Certified Firms MUST:
Give homeowners/residents and child-occupied facility owners/adult
representatives copies of the Renovate Right pamphlet.
Let parents/guardians of children using a child-occupied facility know
about the renovation and how to get a copy of the Renovate Right
pamphlet.
Get confirmation of receipt of the Renovate Right pamphlet from
owners, or evidence that the pamphlet was delivered to
tenants/residents.
Keep all records for at least 3 years.
vvEPA
Feb09
3-2
Exclusions: The Pre-Renovatipn 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.
3-2
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 3 Instructor Notes
Feb09
Slide 3-3: How Widespread is Lead-Based Paint in Housing?
Key message of this slide: A high percentage of pre-1960 housing contains lead-
based paint. Homes built between 1960 and 1978 also contain substantial amounts of
lead-based paint on surfaces, but the percentage of homes with lead-based paint
declines as the date of construction approaches 1978.
Highlight that approximately 34 million homes contained some lead-based paint
according to HUD's American Healthy Homes Survey (2006). Additionally, note that
lead-based paint under new paint is still a problem and will create lead-contaminated
dust and debris when disturbed or allowed to deteriorate.
Homes built before 1950 may contain significant levels of lead-based paint. Explain
that many homes built before 1978 may contain some lead-based paint. Participants
should assume that any house built in 1978 or earlier contains lead-based paint
unless the house has been tested for lead-based paint by an EPA Certified
Renovator, or a Certified Lead Inspector or Risk Assessor, and the results indicate
that the house does not contain lead-based paint.
Emphasize that pre-1950 housing is likely to have lead-based paint on the exterior
and interior. After 1950 and up through 1978, there was a decline in the use of lead-
based paint in the interior of housing; however, it is likely that it will be present on the
exterior. Lead-based paint on the exterior of housing could result in soil
contaminated with lead, making it likely that lead-contaminated dirt and dust from
around the house has blown in or has been tracked into the home. Children also are
more likely to play in the dirt near the house and thus be exposed to lead-
contaminated soil, dirt and dust. After 1978, lead-based paint is not likely to be found
in the interior or exterior of housing.
3-3
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Lead Safety for Renovation, Repair, and Painting
How Widespread is Lead-Based
Paint in Housing?
Year House Was Built
Before 1940
1940-1959
1960-1978
All Housing
Percent of Houses with
Lead Based Paint
86 percent
66 percent
25 percent
35 percent
Feb09
3-3
Source of data in table above: American Healthy Homes Survey: Draft Final Report for Peer Review: Lead
and Arsenic Findings, October 7, 2008.
Homes built in 1978 and earlier
Approximately 34 million pre-1978 housing units contain paint that meets the Federal definition of
"lead-based paint" (Source: American Healthy Homes Survey: Draft Final Report for Peer Review:
Lead and Arsenic Findings, October 7, 2008).
EPA's RRP Rule assumes that any house built before 1978 contains lead-based paint, unless the
house has been tested for lead-based paint and the results indicate that the house does not
contain lead-based paint.
Components most likely to be coated with lead-based paint include windows and doors (interior
and exterior), as well as exterior walls and porches.
Homes built before 1960
Homes built before 1960 are more likely than homes built after 1960 to contain lead-based paint and
are also more likely to have deteriorated paint surfaces due to age. In addition, concentrations of
lead in paint were higher prior to the 1950's when paint companies began to use less lead in paint
they manufactured.
Consider:
86% of pre-1940 homes contain lead-based paint on at least one surface.
66% of homes built from 1940 to 1959 contain lead-based paint on at least one surface.
Note: Determining the age of the property may require some investigation. If the owner does not
know or have access to records, property information in many localities can be accessed from review
of court registration or tax records held by the office of the tax assessor in the community or county
where the property is located. If you don't know the age of the building, assume it was built before
1978.
3-3
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 3 Instructor Notes
Feb09
Slide 3-4: How to Determine If Lead-Based Paint is Present
Review the slide and discuss the three methods of paint testing.
Emphasize the pros and cons of each type of testing.
Emphasize that Certified Renovators are only allowed to use EPA-recognized test kits.
Discussion: When should testing be conducted? (Note that there may be no good
conclusion for all cases.)
The specific time to conduct paint testing is not specified in the RRP Rule, except
that it must be done prior to any decision not to use lead-safe work practices.
Testing prior to the bid will allow the bid to contain all costs and information
necessary for a complete price, but requires access to surfaces being renovated and
an agreement to allow for intrusive sampling. This also adds extra cost to the
preparation of the proposal.
Testing after the contract is awarded does not provide the information needed to bid
and could result in price changes and contract cancellation, but solves the access
issues.
3-4
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Lead Safety for Renovation, Repair, and Painting
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
v>EPA
Feb09
3-4
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-Recoqnized 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-Rav 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.
3-4
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 3 Instructor Notes
Feb09
Slide 3-5: Using EPA-Recognized Test Kits to Check For Lead-Based Paint
Use this slide to discuss how Certified Renovators can check for lead-based paint
using EPA-recognized test kits. If unable or not allowed to test surfaces subject to
disturbance, the renovator should use previous lead inspection data, if available, or
assume that lead-based paint is present.
Check EPA's website regularly for updated information on test kits and for a list of
EPA-recognized test kits (visitwww.epa.gov/lead and search keywords: EPA-
Recognized Test Kit).
Demonstration: Instructor demonstrates use of an approved lead test kit on a surface
coated with lead-based paint. Note that there are two commonly available test kit
types that utilize chemicals that give different colors when lead is present.
Demonstrate an example of each chemical kit type (rhodizonate and sulfide).
Note: Some state and local regulations may not allow Certified Renovators to test paint.
In these states and localities presume that lead-based paint is present or rely on
appropriately certified individuals to conduct testing.
3-5
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Lead Safety for Renovation, Repair, and Painting
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.
Submit 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.
Feb09
3-5
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 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.
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.
If the test kit gives a positive result on any of the tested surfaces, lead-safe work practices must be
used. Alternatively, sampling may be performed by a Certified Lead Inspector or Risk Assessor to
determine whether or not lead-based paint is present.
If test kits are used, Certified Renovators must use an EPA-recognized test kit in order to test
affected surfaces. EPA-recognized test kits will be listed on the EPA website at www.epa.gov/lead.
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.
3-5
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 3 Instructor Notes
Feb09
Slide 3-6: Test Kit Hands-on
Read this slide then review the instructor notes on Skill Set #1 and conduct the practical
exercise.
3-6
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Lead Safety for Renovation, Repair, and Painting
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.
SEPA
Feb09
3-6
3-6
Feb09
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Skill Set #1: Using EPA-Recognized Test Kits
Time: 15 minutes
Feb09
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)
EPA 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 submitted 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:
Add ress:
City: State: Zip code: Contact #: ( ) -.
Email:
Renovation Information
Fill out all of the following information that is available about the Renovation Site, Firm, and
Certified Renovator.
Renovation Address: Unit#
City: State: Zip code:
Certified Firm Name:
Add ress:
City: State: Zip code: Contact #: ( ) - _
Email:
Certified Renovator Name: 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:
Skill Set #1: Using EPA-Recognized 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
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Lead Safety for Renovation, Repair, and Painting
Module 3 Instructor Notes
Feb09
Slide 3-7: Using Decision Logic Charts
Read this slide and review the flow charts on the following pages.
Emphasize that by following these flow charts you can determine what regulatory
requirements apply to your job.
Review the general way the flow charts work as described in the student notes.
Make sure students also understand where in Appendix 2 to find the decision logic
on how to determine if a home receives Federal assistance.
Review the following examples to work through the decision logic in the flow charts.
Read each example to the students and lead them through the decision logic in the
flow charts. Review at least two of the three examples with the students.
1. 18 Cherry Tree Lane, Everytown, USA: This Victorian era home receives $6000
per year in rental assistance from the HUD Section 8 Voucher Program. This
house will have the exterior siding scraped and repainted.
Note: You will start with Flow Chart 1, then HUD Guidance in Appendix 2, then
Flow Chart 2, Flow Chart 3, Flow Chart 4, and finally Flow Chart 8.
2. 4 Autumn Maple St, Alltown, USA: This 1976 ranch style home is having all of
the windows replaced. The house is occupied by the owners and they really want
to find some way to avoid using lead-safe work practices. Lead-based paint is
present on the windows. The 70-year-old owner has no children, but does
provide after school childcare for his grandkids in the home until their parents get
home from work (Approximately 2.5 hours per day).
Note: You will use Flow Chart 1, Flow Chart 2, Flow Chart 3, Flow Chart 4, Flow
Charts 5, Flow Chart 6, Flow Chart 7, and Flow Chart 8. Make sure to point out
that work affects both interior and exterior areas of the home.
3-7
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Lead Safety for Renovation, Repair, and Painting
Using Decision Logic Charts
Using the following pages, you will
practice use of the decision logic charts
found in the Small Entity Compliance
Guide to Renovate Right.
The decision logic charts will assist you in
making decisions regarding how the EPA
RRP Rule applies to your work.
Determine if the property is Federally-
assisted and if it is, then determine what
to do next.
Feb09
3-7
The information presented in the Small Entity Compliance Guide to Renovate Right flow charts is
intended to assist you in understanding what RRP Rule requirements apply to the renovation you
are about to perform and whether the HUD Rule also applies to the project. You will find the
Small Entity Compliance Guide to Renovate Right flow charts on the following pages in this
module. For a complete copy of the Small Entity Compliance Guide to Renovate Right see
Appendix 4.
The Small Entity Compliance Guide to Renovate Right flow charts walk you step-by-step through
a decision tree which asks you a series of ordered yes-or-no questions. To use the flow charts,
begin at the top of flow chart 1, ask yourself each question. Following the yes-or-no answer
arrows to the next appropriate question box. At some point you will come to an arrow with
directions about continuing to another flow chart. Follow the direction to whichever flow chart the
pathway takes you to, skipping flow charts that do not apply. Whenever a text box gives direction
about what to do, write it down to develop a list of actions that must be taken for RRP Rule
compliance.
Appendix 2 provides a summary of HUD requirements that apply to work done in homes that
receive Federal assistance. Information found in Appendix 2 provides assistance in determining
whether the property receives Federal housing assistance and what requirements apply if it does.
If the property is pre-1978 and does receive Federal housing assistance, both the HUD Lead
Safe Housing Rule and the EPA RRP Rule apply to your renovation work.
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Feb09
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EPA's Lead Program Rule At-A-Glance
FLOW CHART 1: 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 build-
ing, 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 property receive
Federal housing assistance?
Additional HUD requirements
apply. See Appendix 2.
Does the job involve activities that disturb painted surfaces in a
home or child-occupied facility built before 1978?
Are ANY of the following conditions present?
The work is a lead abatement project.
Work consists of only minor repairs or maintenance that dis-
turbs 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.
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.
^^^^^
EPA
lead-based
paint renovation,
repair, and
painting program
requirements
do not apply.
^^^^^k
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.
Decision Logic Chart - Flow Chart 1 - following page 3-7
Page 1 of 8
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FLOW CHART 2: How Do I Comply with the Pre-Renovation Education Re-
quirements?
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 |
(COFs)
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
(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.
OR
(ii) Obtain a certificate of mailing at least 7 days before the
renovation.
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
(b)Post signs describing the renovation. The signs must
include the pamphlet or information on how to review
a copy.
See
Flow
Charts
for
information
about
specific
training
and work
practice
requirements
for the job.
Page 2 of 8
Decision Logic Chart - Flow Chart 2 - following page 3-7
-------
FLOW CHART 3: 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.
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.
Decision Logic Chart - Flow Chart 3 - following page 3-7
Page 3 of 8
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FLOW CHART 4: 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.
Page 4 of 8
Decision Logic Chart - Flow Chart 4 - following page 3-7
-------
FLOW CHART 5: 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.
Decision Logic Chart - Flow Chart 5 - following page 3-7
Page 5 of 8
-------
FLOW CHART 6: 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're finished!
Continue to
cleaning
verification
procedure.
See Flow
Chart 7.
Page 6 of 8
Decision Logic Chart - Flow Chart 6 - following page 3-7
-------
FLOW CHART 7: 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
cleaning 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
electrostatically charged, white, disposable cloth designed to be
used for cleaning hard surfaces.
Decision Logic Chart - Flow Chart 7 - following page 3-7
Page 7 of 8
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FLOW CHART 8: 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?
~^^^^r
~^^^^r
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!
Page 8 of 8
Decision Logic Chart - Flow Chart 8 - following page 3-7
-------
Lead Safety for Renovation, Repair, and Painting
Module 3 Instructor Notes
Feb09
Slide 3-8: Now You Know...
Use this slide to reinforce lessons learned and address any outstanding questions.
Highlight the resources available in the appendices.
3-8
-------
Lead Safety for Renovation, Repair, and Painting
Now You Know...
To properly plan a renovation, you must:
Educate owners and residents.
Determine if lead-based paint is present.
Determine what requirements from the EPA
and HUD Rules apply to your renovation
activities.
ซEPA
Feb09
3-8
3-8
Feb09
-------
-------
Module 4: Contain Dust During Work
-------
Lead Safety for Renovation, Repair, and Painting
Module 4 Instructor Notes
Feb09
Overview of this module: The list below summarizes the content and teaching methods
for this module. This is for your reference. Do not cover this with the participants.
Module 4: Contain Dust During Work
90 Minutes
4-1: Module 4: Contain Dust During Work
4-2: What is Containment?
4-3: Keep Dust Within the Containment
4-4: Interior Containment: Limit Access and
Post Signs
4-5: Interior Containment: Remove or Cover
Belongings
4-6: Interior Containment: Cover Floors
4-7: Interior Containment: Close Windows,
Doors, HVAC
4-8: Interior Containment: Work Area Entry
Doorway
4-9: Overview of Interior Containment Steps
4-10: Exterior Containment: Establish the
Work Area
4-11: Exterior Containment: Close Windows
and Doors
4-12: Exterior Containment: Extra Precautions
4-13: Overview of Exterior Containment Steps
4-14: Hands-on Exercise: Interior and Exterior
Containment (Skill Sets #2-#5)
4-15: Debrief of Hands-on Exercise
4-16: Now You Know...
Key message: Keep the dust in the
work area and make it easier to
cleanup.
Notes: Slides are followed by an
exercise.
Slides: (45 minutes)
Hands-On Exercise: Students
set up containment in a small
area. They lay plastic and
secure it. Trainer demonstrates
how to do a door flap. (45
minutes)
Preparing for this module: Prepare
materials for hands-on exercise
and identify appropriate locations
for groups to work in. Review
materials in advance so you are
familiar with Skill Set #2, #3, #4,
#5.
Materials needed: See the Setup
Supplies List for materials needed.
Option: Trainer can follow Lesson
Plan 2 and defer hands-on
exercises until the end of the day,
when hands-on exercises are
combined and conducted all at
once.
Slide 4-1: Module 4: Contain Dust During Work
Module objective: The purpose of this module is to learn how to follow a few simple
setup techniques that will stop the spread of lead-contaminated dust to non-work
areas during both interior and exterior work.
This module covers the bulleted list of topics on the slide. Review this list with the
class participants. Do not spend a lot of time on this slide, as the slides in the rest of
the module will answer many questions that arise.
4-1
-------
Lead Safety for Renovation, Repair, and Painting
Module 4: Contain Dust During Work
Overview
What is containment?
Containing dust for interior activities.
Containing dust for exterior activities.
Feb09
4-1
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.
4-1
Feb09
-------
Lead Safety for Renovation, Repair, and Painting
Module 4 Instructor Notes
Feb09
Slide 4-2: What is Containment?
This slide may best be covered using a question and answer format. The slides
following in the module identify equipment needed for and how to do containment
setup. Don't try to cover everything in the module on this slide.
Questions for class discussion:
How does containment protect co-workers and residents? [Answer: Containment
keeps dust isolated to the work area where workers who are protected by and
trained in the use of special equipment can work safely. It also keeps residents
out of the work area until the job and cleanup are complete.]
How does containment make cleanup easier at the end of a job? [Answer: By
limiting the cleanup area to approximately the work area plus 2 feet beyond the
work area.]
Highlights:
As explained in the student notes, highlight the requirements under the RRP Rule for
containment in target housing and child-occupied facilities as well as the HUD
requirement for containment in pre-1978 properties that receive Federal housing
assistance.
See slides 4-6 though 4-9 for additional information on setting up the interior
containment. See slides 4-10 though 4-13 for additional information on setting up the
exterior containment.
Discuss the fact that the work area can be a small area within a room requiring only
plastic sheeting (taped to the floor), barrier tape, and signs; or, it can be area
including a group of rooms that have been closed off from the rest of the home. The
scale of the work area is determined by the Certified Firm based on their experience
and on the size of the area which must be protected to prevent the migration of dust
and debris from the work area. The work area is the area that is contained. As the
scale of the work area is increased it may include windows, doors and HVAC vents.
All affected windows must be closed; all affected doors must be closed and sealed;
and, all affected HVAC vents must be sealed.
Mention that all carpet in the work area must be covered with plastic sheeting. Also
explain that a piece of disposable plastic sheeting used as a drop cloth at the work
location is very helpful when cleaning up at the end of the day and during final
cleanup. Encourage the use of disposable plastic drop cloths, but noting that they
must be disposed of as waste according to the RRP Rule. Show students how to
apply plastic drop clothes during the hands-on exercises.
4-2
-------
Lead Safety for Renovation, Repair, and Painting
What Is Containment?
"Containment" is a system of temporary
barriers used to isolate a work area so that no
dust or debris escapes while the renovation
is being performed.
Benefits of containment.
Protects residents and workers.
Prevents spread of dust to rest of house/building
or neighboring properties.
Easier cleaning at the end of the job.
Containment is required. V>EPA
Feb09
4-2
What is containment?
In general, there are many degrees of containment, ranging from simple plastic sheeting
on the floor surrounding a small work area to a fully 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.
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 (10 feet for
exterior work) 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.
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.
4-2
Feb09
-------
Lead Safety for Renovation, Repair, and Painting
Module 4 Instructor Notes
Feb09
Slide 4-3: Keep Dust Within the Containment
Review the information on the slide.
Ask the participants for examples of dusty jobs. Ask them about the reasoning
behind their examples - why one particular job creates and/or spreads more dust
than another. Jobs that generate more dust will require larger areas of floor or
ground to be covered during work. Discussion about the amount of dust generated
by jobs in this module should lead into thinking about how best to design
containment to guard against the spread of that dust (and debris) from the work area
to other areas of a building or property.
Emphasize to the participants that the work practices and equipment used on a job,
as well as the size of the job are all factors that affect the amount of dust generated
and, therefore, the size and placement of containment. For example, vigorous hand
sanding can create enough dust to migrate farther than 6 feet from the work surface.
Emphasize that minimizing dust generation through work practice modification and
containment planning is helpful in controlling dust produced by high-dust renovation
activities.
4-3
-------
Lead Safety for Renovation, Repair, and Painting
Keep Dust Within the Containment
Consider how much dust the renovation will
generate.
Containment design is a function of the work
practices to be used and the expected amount
of dust to be generated during the renovation.
Plan the size and configuration of containment
to keep the generated dust within
containment.
You are responsible for making sure dust
does not migrate out of containment.
&EPA
Feb 09
4-3
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 Rule does 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 room 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.
4-3 Feb 09
-------
Lead Safety for Renovation, Repair, and Painting
Module 4 Instructor Notes
Feb09
Slide 4-4: Interior Containment: Limit Access and Post Signs
Review the information on the slide and in the student notes.
4-4
-------
Lead Safety for Renovation, Repair, and Painting
Interior Containment: Limit
Access and Post Signs
Notify residents to stay away
from the work area.
Do not allow residents or pets
near the work area.
Do not allow eating, drinking,
or smoking in the work area.
Post warning signs.
CAUTION
RENOVATION WORK
DO NOT ENTER WORK AREA
UNLESS AUTHORIZED
NO SMOKING, EATING, OR
DRINKING
&EPA
Restrict access to the work area and notify residents to stay away while
work is underway.
Restricting access to the work area will protect residents, especially children and pregnant
women, from unnecessary exposures to leaded dust and will minimize the spread of dust to
non-work areas.
Before the job starts, notify the residents not to enter the work area and to stay away from the
vicinity of the entrance to the work area as much as possible. Residents and pets coming and
going can easily track lead-contaminated dust into non-work areas throughout the home. Non-
work areas will likely not be cleaned up promptly or properly.
Restricting exposure is especially important for small children under 6 years old and for
pregnant women. Be sure to explain to residents that restricting access is for their own
protection, and that small children and pregnant women are most at risk of health problems
from exposure to lead.
You must provide an indication of how long you will be working in a particular area so that
residents can plan ahead to obtain items that they may need from the work area before you
begin working.
Do not allow eating, drinking, or smoking in the work area.
This is primarily for worker protection, but is also important if residents are living near the work
area. Post signs that prohibit eating, drinking and smoking in the work area. Dust in the air can
land on food or be inhaled when smoking. If food is set on a dust-contaminated surface, it can
easily pick up the lead-contaminated dust, which is then ingested when the food is consumed.
Post warning signs.
Before beginning the renovation, post a sign in the residents' native language to warn them and
other persons not involved in renovation activities to remain outside of the work area. Signs
must remain in place and be readable through completion of the renovation and the post-
renovation cleaning verification.
A warning sign must be posted: at each entry to a work area; or, at each main and secondary
entryway to a building from which occupants have been relocated; or, for exterior work, where
it is easily read 20 feet (6 meters) from the edge of the worksite.
4-4
Feb09
-------
Lead Safety for Renovation, Repair, and Painting
Module 4 Instructor Notes
Feb09
Slide 4-5: Interior Containment: Remove or Cover Belongings
Highlight the desirability of removing furniture and other objects from the work area,
where practicable. Covering them to prevent dust from settling on them can add to
the project workload, as these objects are usually quite hard to clean once they get
dust on them. Note that when objects are covered, edges and seams need to be
taped or otherwise sealed.
Describe the illustration. Point out how all fixtures and pieces of furniture in view are
covered and that other pieces (unseen) have been moved.
Distribute pieces of plastic sheeting to the class to allow them to get a feel for what
they will be working with.
It may be helpful to know names of local hardware stores and suppliers that sell
protective sheeting, and the typical price per foot of common types or sizes.
4-5
-------
Lead Safety for Renovation, Repair, and Painting
Interior Containment: Remove or
Cover Belongings
Remove belongings.
Cover immovable
objects in protective
sheeting, including:
Furniture;
Carpet; and,
Lamps and other
fixtures.
Seal edges and seams.
Feb09
Where Practicable Remove Belongings and Furniture from the
Work Area.
It is desirable to remove all objects from the work area including furniture, rugs and
window coverings. Removal is the best option for protecting occupant items from
contamination and for reducing post-renovation cleanup time (and cost).
If It Can't Be Moved Out of the Work Area, Cover It.
Cover all objects that were not removed from the work area in protective sheeting.
Seal the seams and edges with tape. Completely cover all immovable fixtures,
furniture, carpets and other personal items with protective sheeting.
Secure protective sheeting to the floor with tape so that no dust can get onto the
covered items.
Protective sheeting such as disposable heavy-duty plastic sheeting is commonly
used in many remodeling jobs. Protective sheeting can be bought at most hardware
stores.
4-5
Feb09
-------
Lead Safety for Renovation, Repair, and Painting
Module 4 Instructor Notes
Feb09
Slide 4-6: Interior Containment: Cover Floors
Highlight the importance of covering the floor for easier cleanup of dust and debris.
Emphasize that this activity is similar to the current practice of covering the floor with
a drop cloth but instead they will use plastic protective sheeting.
Floors should be covered at least 6 feet out from the surfaces being disturbed or
further if necessary to contain the dust.
Highlight the importance of using a disposable tack pad, removing shoe coverings
(sometimes called "booties"), wiping shoes, and/or laying plastic on common traffic
areas to prevent lead-contaminated dust from being carried to other areas of the
building. It is quite common to find high lead-contaminated dust levels along the path
from the work area to the bathroom.
A disposable tack pad acts like flypaper. It is a sticky paper or cloth that removes
dust or debris from a worker's shoes when he walks on it. Disposable tack pads are
available from specialty construction catalogs and many hardware stores.
It may be helpful to know names of local hardware stores and suppliers that sell tack
pads, wipes and shoe coverings, and the typical cost of each. If possible bring in
samples of these items to show to the class.
Advise participants of the importance of cleaning shoes each time they step off the
sheeting. Demonstrate using disposable tack pads if available.
4-6
-------
Lead Safety for Renovation, Repair, and Painting
Interior Containment: Cover Floors
Required:
Cover all work area floors with plastic
sheeting.
Cover floors a minimum of 6 feet in all
directions around the paint being
disturbed.
Recommended:
Lay plastic sheeting in high traffic areas.
Take special precautions for carpets.
Use a disposable tack pad at the edge of
protective sheeting.
If using chemical stripper, add 2nd
plastic layer.
t: -ซ
Feb09
4-6
Cover Floors
Use protective sheeting to cover all work area floors including installed carpet. The
protective sheeting must extend a minimum of 6 feet to the left, right and front - and in
some cases to the back - of the area where work will be performed. It should be tightly
secured to baseboard or flooring using duct tape (where appropriate), painters tape or
masking tape. The corner edge of the protective sheeting should be reinforced using duct
tape or a staple.
Take special precautions with carpets in the work area. Carpets are a major dust
collection medium and it is very difficult to clean the dust out of them once contaminated.
When the work area includes carpets, you must cover all carpeted areas that are in the
work area with at least one layer of sealed plastic sheeting.
Consider covering shoes with removable shoe covers, wiping off the tops and soles of
shoes with a damp paper towel each time you step off the sheeting, and/or using a
disposable tack pad that removes dust from the soles of shoes. Immediately place used
paper towels in a covered garbage bin. Disposable tack pads can be found at many
hardware stores or bought through a supply catalog. A tack pad is a sticky pad that you
walk on to remove dust from the soles of your shoes. The disposable tack pad can be
taped to an outer corner of the sheeting. Replace disposable tack pads at least daily.
You may find that using a HEPA vacuum to clean off shoes and clothing is necessary in
controlling carry-away dust when personnel leave the work area. This is called a "dry
decon" and works well.
A second smaller layer of protective sheeting should be used with chemical strippers. This
second layer should be taped to the top of the first layer. Place the second layer
immediately below the work area. This layer will capture splashes and waste, and allows
the mess made by chemical strippers to be cleaned up immediately after use.
Use precautions to ensure that all personnel, tools and other items, including the exteriors
of waste containers, are free of dust and debris before removing them from the work area.
A container of cheap hand or baby wipes is quite useful for such cleaning.
4-6
Feb09
-------
Lead Safety for Renovation, Repair, and Painting
Module 4 Instructor Notes
Feb09
Slide 4-7: Interior Containment: Close Windows, Doors, HVAC
Close and seal HVAC (IHeating, Ventilation, and Air Conditioning) vents to prevent
dust from leaving the work area. This is especially important for return (intake) vents
as they could easily spread contamination to other areas.
Depending on what work is being done and what is required for access to the work
area and for construction waste handling, close and seal all doors and windows in
the work area. If doors and windows are left open, air may flow freely through the
work area and into non-work areas. Because dust particles are so small, they can
easily spread to other areas of the house. Less air flowing through the work area
means that there is less chance that lead-contaminated dust will be blown out of the
work area.
4-7
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Lead Safety for Renovation, Repair, and Painting
Interior Containment: Close
Windows, Doors, HVAC
Depending on what work is to be done:
Close all windows in the work area.
Close and seal all doors in the work area.
Close and seal all HVAC vents in the work
area.
Turn off the HVAC unit (recommended).
&EPA
Feb09
4-7
Close Windows
Close all windows within the work area.
When conducting window replacements from the inside, consider attaching plastic sheeting
to the exterior of the window to prevent spread of dust and debris to the ground and other
surfaces under the window. If window replacement affects both interior and exterior
surfaces, then setup containment for both the interior and exterior work areas.
For dusty jobs, it is strongly recommended that you seal work area windows with protective
sheeting to prevent dust from getting into the trough or on the sill, making it harder to clean.
When sealing windows, cut plastic sheeting layer slightly larger than the window that you
are covering.
Attach the plastic sheeting with tape over the window to completely seal it.
Make sure that the tape or the sheeting does not cover part of the area on which you are
working.
Close and Seal Doors
Close all doors including closet and cabinet doors in the work area, and cover with plastic
sheeting.
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.
As an alternative to putting up plastic, doors may be shut and then sealed closed with
painter's tape.
Close and Seal HVAC Vents
Heating ventilating and air conditioning (HVAC) systems distribute air throughout the
building and thus can also carry dust to other rooms. If possible, turn off the HVAC system
for the work area. Close the HVAC supply and return vents in the work area and then cover
them tightly with plastic sheeting to prevent air from blowing the dust out of the contained
work area and to prevent dust from getting into the HVAC system.
4-7
Feb09
-------
Lead Safety for Renovation, Repair, and Painting
Module 4 Instructor Notes
Feb09
Slide 4-8: Interior Containment: Work Area Entry Doorway
Ask participants: Have you ever limited access to your work area? If so, how?
How successful was this? Would you have done this differently?
Ask participants: Can you think of any other ways to limit access to the work
area?
Be sure to highlight all of the points on these two slides if the class discussion has not
addressed all of them.
4-8
-------
Lead Safety for Renovation, Repair, and Painting
Interior Containment: Work Area
Entry Doorway
^ngrr7^-
>'. .'",/
Cover work area
entry doors with two
layers of protective
sheeting.
Feb09
4-8
A physical barrier, such as a cone or warning tape, can be placed outside the entry to remind
residents to stay away from the work area, especially in buildings where more than one family
lives. The double layers of plastic on the entry door and other barriers serve as a reminder to
residents that people and pets should not enter the work area, and also signals that the area
has not yet been cleaned up.
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 below.
Set up a two-layer entry barrier with closable flaps at the entry to the work area so that
workers can pass through but dust and debris stay in the work area. Covering the door with
this two-layer system will help contain the dust within the work area. Follow the steps below.
1) Cut the first plastic sheeting layer slightly wider and longer (three inches) than the door
frame.
2) Make a small "S" fold at the top of the sheeting and tape it to the top of the door frame.
Make a similar "S" fold at the bottom of the sheeting and tape it to the floor. This will
ensure that the plastic is not taut.
3) Secure the top corners to the door frame for reinforcement.
4) For exiting and entering the room, tape a vertical line about the size of a man from floor
to header on both sides of the plastic. Cut a long vertical slit through the tape, in the
middle of the protective sheeting. Leave about 6 inches at the top and bottom uncut.
Reinforce the top and bottom of the slit with tape to prevent the plastic from tearing.
5) Tape a second layer of protective sheeting to the top of the door frame. This layer is cut
slightly shorter than the door frame so that it will hang down flat against the first sheet
of plastic.
6) Tape and secure the top corners of the second layer to the door frame and the first
layer. Leave it to hang over the first layer. Weight the bottom of the flap with a dowel to
keep it in place. If needed, another weighted flap can be added to the other side of the
door to provide a third layer of plastic sheeting.
See Appendix 5 Steps to LEAD SAFE Renovation, Repair and Painting for more
information on how to put the two layer system in place.
4-8
Feb09
-------
Lead Safety for Renovation, Repair, and Painting
Module 4 Instructor Notes
Feb09
Slide 4-9: Overview of Interior Containment Steps
Use this slide to review the previous four steps. Do not go into detail about the steps
here. This is meant to provide reinforcement of the four steps to interior containment
so that participants will have a structure to organize the information.
4-9
-------
Lead Safety for Renovation, Repair, and Painting
Overview of Interior Containment
Steps
The goal of these interior containment practices
is to prevent dust and debris from escaping the
work area.
Limit access and post signs.
Remove (preferred) or cover belongings.
Cover floors.
Close and seal windows, doors and HVAC system.
Construct a work area entry doorway.
&EPA
Feb09
4-9
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 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 opening: Close and cover all HVAC vents in the work area with taped
down plastic sheeting or other impermeable materials (e.g., magnetic covers).
Remove dust and debris from everything leaving the work area: Use precautions to
ensure that all personnel, tools and all other items are free from dust and debris
before being removed from the work area.
4-9
Feb09
-------
Lead Safety for Renovation, Repair, and Painting
Module 4 Instructor Notes
Feb09
Slide 4-10: Exterior Containment: Establish the Work Area
Review the importance of protecting the ground and gardens from lead-contaminated
dust. Tomatoes are a common homegrown foodstuff. Tomato plants concentrate
heavy metals from the soil in the fruit. Lead is a heavy metal.
The extra length of the protective sheeting required by the Rule is necessary
because exterior winds can blow dust a significant distance.
The sheeting can be taped to the house or a 2x4 can be wrapped in protective
sheeting and placed next to the house if tape will not stick. At the loose edges the
sheeting can be weighted down with stones, rocks or any heavy object to prevent the
sheeting from flapping or lifting off the ground.
Saw horses, tape or orange cones remind residents and alert passersby to stay
away from the work area.
All toys and belongings should be removed from exterior work areas as part of the
pre-work setup.
Note that putting a ladder on the plastic sheeting may cause a slip hazard. By putting
a piece of plywood between the ladder and the sheeting, that hazard can be
avoided. In some cases, you should consider having someone hold the ladder from
below.
Avoid obscuring tripping hazards with plastic.
4-10
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Lead Safety for Renovation, Repair, and Painting
Exterior Containment: Establish
the Work Area
-i -#
.*.**
*>*,
Feb09
Cover the ground with
protective sheeting.
If space permits, extend a
minimum of 10 feet from the
work area.
Play special attention and
cover nearby vegetable
gardens and children's play
areas.
Limit access, place signs.
Establish a 20 foot perimeter
around the work area if space
permits' &EPA .
4-10
Cover the ground with protective sheeting
If space permits, lay protective sheeting on the ground below the work area to at least 10 feet
from the house. This creates a visible work area and helps remind residents and passers-by
that they should not enter the work area unless they have a compelling need. Extend the
work area farther if needed to collect dust and debris; for example, when paint on the second
story of a building is being disturbed. Note: Black and clear disposable plastic sheeting can
kill plants by making them too hot. Consider using white plastic sheeting instead.
Remember children often play in the dirt and may put their hands in their mouths while
playing. Dirt, dust or debris on their hands will go into their mouths and may be swallowed.
Remove toys and other items from the work area and cover all play areas including
sandboxes. Protect items that cannot be moved with plastic sheeting.
Staple or tape the protective sheeting to the wall of the building, or use a 2x4 wrapped in
protective sheeting to hold the material next to the wall. Use heavy objects (e.g., rocks) to
weight the other edges of the protective sheeting to the ground so that it won't blow in the
wind.
When using ladders on plastic sheeting consider placing a sturdy piece of plywood on the
plastic and then set the ladder on the plywood. This will prevent the ladder from puncturing
the plastic and will provide a stable surface for the ladder. If plywood is used, take special
care to secure it to the ground so that it does not move. This could be done by staking the
plywood and later sealing the holes in the plastic with duct tape.
Limit work area access
Limit access to the work area by placing orange cones or saw horses and warning tape
around a 20 foot perimeter of the work area. Ropes with signs at regular intervals could also
be used instead of barrier tape. This will help to discourage residents and passersby from
entering the work area. Keep pets out of the work area.
Exterior work area daily cleaning
Cleaning the exterior work area is crucial to prevent the spread of dust and debris. Picking up
all debris throughout the day and the use of temporary, plastic-sheeting drop cloths can
facilitate easy cleanup. Note that the plastic drop cloths do not take the place of protective
sheeting on the ground.
4-10
Feb09
-------
Lead Safety for Renovation, Repair, and Painting
Module 4 Instructor Notes
Feb09
Slide 4-11: Exterior Containment: Close Windows and Doors
Describe the illustration. State the importance of closing windows and doors to
prevent dust from blowing into the building. Close all windows and doors within 20
feet of renovation.
4-11
-------
Lead Safety for Renovation, Repair, and Painting
Exterior Containment: Close Windows
and Doors
Close all nearby doors
and windows that are
within 20 feet of the
work area.
Use two layers of plastic
sheeting on doors in the
work area that are being
used during the job.
Feb09
4-11
Close and cover all nearby windows and doors.
All windows and doors within 20 feet of the work area should be closed to prevent dust
from entering the home. Renovators have an obligation to keep the dust and debris
from the renovation contained within the work area and contained within the boundaries
of the property on which they are working. If the windows and doors of apartments or
condominiums are within 20 feet of the work area, consider requesting that the owners
or residents of those affected units close the affected windows and doors in order to
comply with the RRP Rule. If this is an unavailable option, other methods of restricting
dust and debris to the work area and the work-site property must be considered. These
other methods include construction of a vertical containment wall at the property line.
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 directly
below the area designated as the work area.
Establish two layers of plastic sheeting on the doors in work areas
being used during the job.
In the exterior work area, there will be times when a door into the house needs to be
used to access interior work areas. When this occurs, cover this door with disposable
plastic sheeting or other impermeable material in a manner that allows workers to pass
through while confining dust and debris to the work area. The steps for placing two
layers of plastic sheeting in a doorway are covered in the student notes on page 4-8.
4-11
Feb09
-------
Lead Safety for Renovation, Repair, and Painting
Module 4 Instructor Notes
Feb09
Slide 4-12: Exterior Containment: Extra Precautions
Describe the illustration of a vertical containment system.
In certain situations, such as high winds or use of a pressure washer when adjacent
units are close, vertical containment is necessary to prevent the spread of dust out of
the work area.
4-12
-------
Lead Safety for Renovation, Repair, and Painting
Exterior Containment: Extra
Precautions
Extra precautions
taken to prevent the
spread of dust.
Extending work area.
Vertical containment.
Avoid working in
windy conditions,
where possible.
Bft.
IgMMM
Feb09
I"
4-12
Situations Requiring Extra Precautions
Some situations may require extra precautions to avoid the spread of dust to the rest of a
property or to adjacent properties. These situations might include work in high winds that
can carry dust out of the work area and work conducted on upper levels of a building
during which even light winds can spread dust beyond the containment as it falls.
Extend the Work Area
The simplest solution may be to extend the area of ground covered by plastic sheeting.
Vertical Containment
If conditions are windy, if space is limited or if adjacent properties are relatively close to the
work area, vertical containment systems may need to be constructed. Examples of
vertical containment systems include plastic sheeting attached to scaffolding and plastic
sheeting attached to vertical wood boards.
Avoid High Winds Where Possible
Be wary of windy conditions. On days with high winds, it is not advisable to perform dust
creating activities. The HUD Rule restricts exterior work in winds in excess of 20 miles per
hour. The EPA RRP 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. More frequent cleanup of
exterior work areas is also not addressed specifically, but frequent cleanup will help the
renovator comply with the requirements to contain the work area and prevent dust and
debris from getting outside of the work area. Ultimately, you are responsible for preventing
dust and debris from leaving the work area, so take appropriate precautions to make that
happen when wind is a factor.
4-12
Feb09
-------
Lead Safety for Renovation, Repair, and Painting
Module 4 Instructor Notes
Feb09
Slide 4-13: Overview of Exterior Containment Steps
Use this slide to highlight the three setup practices. Do not go into detail about the
steps here.
4-13
-------
Lead Safety for Renovation, Repair, and Painting
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.
&EPA
Feb09
4-13
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.
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 building or work area.
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 may 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.
4-13
Feb09
-------
Lead Safety for Renovation, Repair, and Painting
Module 4 Instructor Notes
Feb09
Slide 4-14: Hands-On Exercise: Interior and Exterior Containment
Prepare this exercise in advance:
Have appropriate tools available. Refer to Skill Sets #2 - #5 in Appendix 6 for needed
tools and materials.
Have work areas ready. Ideally, each work area will require the participants to move
some furniture and cover other furniture, lay plastic on the floor, create a work area
entrance, and put up barrier tape or plastic in a doorway. If possible, leave these
work areas set up to allow for more realistic exercises as hands-on activities are
conducted throughout the day.
When conducting the exercise:
1. Instruct participants to break into groups of 2 to 6 students.
2. Assign each group a work area.
3. Circulate while they work to ensure they are doing the work properly. Consult
Skill Sets #2 - #5 list of skills they should demonstrate.
4. Coach them to stay on task to achieve the training goal.
5. Give them a 5-minute warning.
6. At the end of each skill set, tell them to stop. Times for each activity are listed on
each skill set.
7. Debrief at the end of each skill set (#2 - #5).
Options for the Trainer: You may also consider performing Skill Sets #2 - #5 later
in the course as part of a larger, comprehensive, hands-on module as described in
Lesson Plan 2 in the Note to Instructors on How to Use This Curriculum in the
introduction. The comprehensive hands-on module combines the hands-on
components from Modules 4, 5 and 6.
4-14
-------
Lead Safety for Renovation, Repair, and Painting
Hands-on Exercises: Interior and
Exterior Containment
Practice the following Skills:
Skill Set #2: Setting up Barriers, Signs and Flapped
Entry Doors.
Skill Set #3: Cover and Move Furniture.
Skill Set #4: Establish Interior Containment.
Skill Set #5: Establish Exterior Containment.
Work in groups of 2 to 6.
Choose the right tools and materials.
Feb09
4-14
Setting Up
This exercise gives you a chance to practice setting up the work area signs, barriers and
containments. The slide provides basic instruction.
Follow the instructions in each skill set. Your instructor may choose to also
demonstrate skills.
Form into groups of 2 to 6 students.
Your instructor will assign your group to an area to perform setup activities as if
for a job.
Choose the right tools and set up the work area to provide proper containment.
4-14
Feb09
-------
Skill Set #2: Setting up Barriers, Signs and Flapped Entry Doors
Time: 10 minutes
Feb09
Supplies needed:
Barrier tape
Warning signs
Doorway to use for work area entry setup
Utility knife and razor blades, or scissors
Heavy duty plastic sheeting
Duct tape, masking tape, and/or painter's tape
Stapler and staples
Broom handle, or dowels, or 1" x 1" x 30" wood or metal stock
Optional: Pre-engineered containment systems may also be used for this
exercise.
Note to Instructor: It is strongly suggested that instructors prepare plastic bags
containing all materials needed for the skills practice prior to the exercise in order to
meet the time limits allocated to Skill Set #2.
Purpose: The purpose of this hands-on exercise is to show students the proper steps in
determining where to place critical barriers, and to give them practice in erecting barriers
and posting signs to isolate the work area from access by unauthorized personnel.
Note to Instructor: Read the purpose of this activity to students. Remind them that
these setup steps must be completed before the disturbance of more than 6 ft2 per
room of lead-based paint, or, whenever window replacement or demolition is to be
accomplished.
Demonstration: The course instructor must show and explain all of the steps involved in
establishing a critical barrier and in placement of signage. Critical barriers are plastic
sheeting barriers secured over openings, doors, and windows that must remain in place
until cleaning verification or clearance is achieved in order to keep dust inside of the
work area. While they are not always required, they can assist with controlling the
spread of dust to other areas of the home. Use students to assist in the erection of the
demonstration critical barriers. Note: In the interest of time, use precut barriers for
installation in the doorway. Velcro attached barriers may be used for demonstration and
practice. Velcro sign attachments may also be used.
Evaluating the Students: The instructor should allow students to practice the steps on
the following page while watching each student follow the steps. Make corrections and
suggestions as the exercise proceeds and determine if additional practice is necessary.
Option: Have students say the steps as they work. 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 Skill Set #2
and that particular student's name.
Skill Set #2: Setting up Barriers, Signs, and Flapped Entry Doors
1 of 2
-------
Skill Set #2: Setting up Barriers, Signs, and Flapped Entry Doors
- Continued
Skills Practice:
Step 1: Ask occupants to leave and remain out of the room where work will be done.
Step 2: Have them stay out until the cleaning verification procedure is complete or
until clearance is passed. Install barrier tape to establish a controlled
perimeter.
Step 3: Post a "Do Not Enter" sign at the doorway to the work area.* Also post a sign
that states that no eating, drinking, or smoking is allowed the doorway to the
work area.*
Step 4: Cover the work area entry doorway with 2 layers of plastic sheeting, by doing
the following:*
Step 5: Cut first plastic sheeting layer slightly wider and longer than (about 3 inches
longer) than the doorframe.*
Step 6: Make a small "S" fold at the top of the plastic sheeting and tape so that all
layers are secured to the top of the door frame.* Make a similar "S" fold at the
bottom of the plastic sheeting and tape so that all layers are secured to the
floor.* This will ensure that the plastic sheeting is not tight and allows it to
give instead of tearing when people move through it. Secure both sides of the
plastic sheeting to the door frame with tape.
Step 7: Staple top corners to the door frame for reinforcement*
Step 8: For exiting and entering the room, use duct tape to create a vertical line about
the size of a man from floor to header in the middle of the plastic sheeting on
both sides.* Cut a long vertical slit through the duct tape; leave about 6
inches at the top and the bottom uncut.* Reinforce the top and bottom of the
slit with horizontal duct tape to prevent the plastic sheeting from tearing.*
Step 9: Tape a second layer of plastic sheeting to the top of the door frame.* This
layer is cut slightly shorter than the door frame so that it will hang down flat
against the first sheet of plastic sheeting.
Step 10: Weight the bottom of the second layer of plastic sheeting by taping a dowel
rod to the bottom of the second layer of plastic sheeting with duct tape. This
creates a self-sealing flap over the doorway and seals the opening that was
cut in the plastic sheeting during step 8.
*lndicates required skills that must be accomplished for a "Proficient" rating.
Skill Set #2: Setting up Barriers, Signs, and Flapped Entry Doors
2 of 2
-------
Skill Set #3: Cover or Remove Furniture
Time: 10 minutes
Feb09
Supplies needed:
Heavy duty plastic sheeting
Cutting tool (e.g., razor knife, box cutter or scissors)
Tape (duct, painters, and masking)
Purpose: The purpose of this hands-on exercise is to show students the proper steps
for determining when and how to cover or remove furniture and belongings from a work
area.
Note to Instructor: Read the purpose of this activity to students. Remind them that
these setup steps must be completed before the disturbance of more than 6 ffper
room of lead-based paint, or, whenever window replacement or demolition is to be
accomplished. Also remind them that the best solution to the problem of moving
furniture and belongings is to notify residents to remove them prior to the work.
Remind them also that it is better to remove personal property than to cover it.
Provide students with the opportunity to observe/practice both methods (covering
and removal).
Demonstration: The course instructor should explain all of the steps involved in
covering and/or removing furniture and belongings from the work area. Use students to
demonstrate moving chairs out of the work area. Then cover a table with plastic sheeting
and secure the plastic sheeting with tape so that no part of the table is exposed. Discuss
placing other items under the table for maximized efficiency in preparing the work area.
The demonstration should not take longer than 3 minutes including the time needed to
hand out materials.
Evaluating the Students: The instructor should allow students to practice the steps on
the following page while watching each student follow the steps. Make corrections and
suggestions as the exercise proceeds and determine if additional practice is necessary.
Option: Have students say the steps as they work. 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 Skill Set #3
and that particular student's name.
Skill Set #3: Cover or Remove Furniture
1 of 2
-------
Skill Set #3: Cover or Remove Furniture - Continued
Skills Practice:
Step 1: Move all the furniture out of the work area.
Note: If the training area is small, designate an area against one wall that is
"out of the work area", where furniture removed from the work area can be
placed. In a classroom setting, move the chairs and most of the tables to the
designated area, and cover the tables.
Step 2: Have the students team into groups of 2 to 6 per group. Cover several of the
tables where students were sitting. This is done as follows:
Step 3: Cut a piece of plastic sheeting large enough to cover the table and to overlap
the floor by 3-6 inches.*
Step 4: Secure the plastic sheeting to the table and/or the floor with tape.*
Step 5: If the table will not need to be moved during the work, the plastic sheeting
can be secured to the floor using duct tape or masking tape as is appropriate
to the surface.*
Step 6: If the table will need to be moved during the work, wrap the table with plastic
sheeting including the legs and secure the plastic sheeting to the table with
tape. Take care when applying tape so that there is no damage to the
finished surfaces of the furniture.*
Note: Students should understand that they are to remove or cover all
window treatments, furniture and rugs within 6 feet of surfaces that will be
renovated, repaired or painted. Removal of furniture is recommended
whenever possible.
*lndicates required skills that must be accomplished for a "Proficient" rating.
Skill Set #3: Cover or Remove Furniture
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Skill Set #4: Establish Interior Containment
Time: 10 minutes
Feb09
Supplies needed:
Orange cones
Rope and/or barrier tape (bright color preferable)
Warning signs
Tape measure
Tape (duct, painters, and masking)
Heavy duty plastic sheeting
Cutting tool (e.g., razor knife, box cutter or scissors)
Magnetic covers
Disposable tack pad
Purpose: The purpose of this hands-on exercise is to show students the proper steps in
covering floors, and closing and sealing the doors, windows and HVAC in the work area.
Note to Instructor: Read the purpose of this activity to students. Remind them that
these setup steps must be completed before the disturbance of more than 6 ffper
room of lead-based paint, or, whenever window replacement or demolition is to be
accomplished.
Demonstration: The course instructor should explain all of the steps involved in
covering and sealing floors and other horizontal surfaces in the work area, and in closing
and sealing doors and windows between the work area and non-work areas. Use
students to demonstrate closing and taping the windows and doors with masking tape.
Remind them that they are trying to keep dust from escaping the work area.
Evaluating the Students: Allow students to practice the steps for covering the floors,
closing and sealing windows, and closing and sealing doors. Watch each student follow
the steps on the following page. Make corrections and suggestions as the exercise
proceeds and determine if additional practice is necessary. Option: Have students say
the steps as they work. 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 Skill Set #4 and that particular
student's name.
Skill Set #4: Establish Interior Containment
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Skill Set #4: Establish Interior Containment - Continued
Skills Practice:
Step 1: At each non-entry doorway leading from the work area, place an orange
cone, barrier tape, and a "Do Not Enter" sign.*
Step 2: Close all doors and windows leading to/from the work area.*
Step 3: Tape the seams around each door and window casing with painter's tape,
masking tape, or duct tape.*
Step 4: Cut plastic sheeting so that it covers all exposed surfaces within 6 feet of the
component(s) that are to be affected by the work.*
Step 5: Secure the plastic sheeting to the floor and walls as appropriate with tape.*
Step 6: Use plastic sheeting floor runners to avoid stepping on the carpet or floors
when walking out of the work area. Secure them to the floor with tape.*
Step 7: Close and cover all air and heat diffusers and intakes with magnetic covers,
tape, or plastic sheeting and tape.* Also, if possible, turn off the HVAC
system while working.* HVAC units may be turned on after cleaning
verification or clearance has been achieved.
Step 8: Stage all of the tools, supplies and equipment you will need to conduct the
renovation, repair or painting work on the plastic sheeting in the work area to
avoid contaminating the work area.*
Step 9: Place a disposable tack pad at the corner of the plastic sheeting nearest the
entry door to control tracking dust off of the plastic sheeting.*
*lndicates required skills that must be accomplished for a "Proficient" rating.
Skill Set #4: Establish Interior Containment
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Skill Set #5: Establish Exterior Containment
Time: 15 minutes
Feb09
Supplies needed:
Orange cones
Rope and/or barrier tape (bright color preferable) and fencing stakes
Warning signs
Heavy duty plastic sheeting
Tape (duct, painters, and masking)
Cutting tool (e.g., razor knife, box cutter or scissors)
Tape measure
Disposable tack pad
Purpose: The purpose of this hands-on exercise is to show students the proper steps
for restricting entry to the exterior work area, and to protect the ground under and around
the work area from becoming contaminated.
Note to Instructor: Read the purpose of this activity to students. Remind them that
these setup steps must be completed before the disturbance of more than 20 ft2 of
paint on components that have been determined to be lead-based paint, or,
whenever window replacement or demolition is to be accomplished.
Demonstration: The course instructor should explain all of the steps involved in
restricting access to and containing dust within the work area. Emphasize to students
that proper setup will restrict access, and will keep dust and debris from escaping the
work area.
Evaluating the Students: Allow students to cover the ground and establish barriers to
prevent unauthorized access to the work area. Watch each student follow the steps on
the following page. Make corrections and suggestions as the exercise proceeds and
determine if additional practice is necessary. Option: Have students say the steps as
they work. 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 Skill Set #5 and that particular student's name.
Skill Set #5: Establish Exterior Containment
1 of 2
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Skill Set #5: Establish Exterior Containment - Continued
Skills Practice:
Step 1: At each non-entry doorway leading into the work area, place an orange cone,
barrier tape, and a "Do Not Enter"sign.*
Step 2: Close all doors and windows within 20 feet of the work area.*
Step 3: Place plastic sheeting as ground cover a minimum of 10 feet in all directions
from the actual location of a paint disturbance.*
Step 4: Weigh down the edges of the plastic sheeting with 2x4s or bricks or stake
down the edges of the plastic sheeting.*
Step 5: Secure the plastic sheeting to the floor and walls with tape or furring strips
and tacks.*
Step 6: Place barrier fencing or a rope around the perimeter of the work area 20 feet
from the work area and on all exposed sides.*
Step 7: Establish an entry point to the work area and place a "Do Not Enter, No Food
or Drinks or Smoking Allowed"sign.*.
Step 8: Curb the edges of the plastic sheeting to prevent dust from blowing off.*
Curbs can be made by running a low rope near the ground and draping the
plastic sheeting over the top of the rope. The rope should be only a few
inches above the ground. A staked 2x4 may also be used to raise the edges
of the plastic sheeting instead of the rope method.
Step 9: Stage all of the tools, supplies, and equipment you will need to conduct the
renovation, repair, or painting work on the plastic sheeting in the work area to
avoid contaminating the work area.*
Step 10: Place a disposable tack pad at the corner of the plastic sheeting nearest the
entry door to control tracking dust off of the plastic sheeting.*
*lndicates required skills that must be accomplished for a "Proficient" rating.
Skill Set #5: Establish Exterior Containment
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Lead Safety for Renovation, Repair, and Painting
Module 4 Instructor Notes
Feb09
Slide 4-15: Debrief of Hands-on Exercise
Use this slide to debrief the exercise.
Ask participants what was difficult about containing the work area.
Point out what the participants did well and where there were difficulties.
Demonstrate how to do some of the more difficult parts; for example, joining two pieces
of plastic, or create an S-fold in the door.
4-15
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Lead Safety for Renovation, Repair, and Painting
Debrief of Hands-on Exercise
How did it go?
What were some of the hard parts?
Feb09
4-15
Debrief of Hands-on Exercises.
Consider the questions above. Discuss as a class.
4-15
FebOQ
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Lead Safety for Renovation, Repair, and Painting
Module 4 Instructor Notes
Feb09
Slide 4-16: Now You Know...
Use this slide to close out the module and make the transition to the next module
(Module 5: During the Work).
Emphasize that proper containment of the work area will make the rest of the job
easier, as they will see in Modules 5 and 6.
4-16
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Lead Safety for Renovation, Repair, and Painting
Now You Know..
How to setup for a job
Interior containment
Exterior containment
vvEPA
Feb09
4-16
Now you know how to set up for a job. The next module will discuss
the conduct of lead-safe work practices during the job.
4-16
Feb09
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Module 5: During the Work
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Lead Safety for Renovation, Repair, and Painting
Module 5 Instructor Notes
Feb09
Overview of this module: The list below summarizes the content and teaching methods
for this module. This is for your reference. Do not cover this with the participants.
Module 5: During the Work
50 Minutes
5-1: Module 5: During the
Work
5-2: Traditional Renovations
Create Airborne Leaded Dust
5-3: Prohibited Practices
5-4: Specialized Tools
5-5: Protect Yourself
5-6: Control the Spread of
Dust
5-7: Cleaning During the Job
5-8: Exercise: Personal
Protective Equipment (Skill
Set #6)
5-9: Now You Know...
Key Message: Traditional renovation practices
produce dust, while lead safe practices will reduce
dust making the renovation, repair or painting work
safer.
Notes: Slides are followed by an exercise
Slides: (40 minutes)
Hands-on Exercise: (10 minutes)
Preparing for this module: Prepare a list of tasks for
participants to work on and assemble the materials
needed for the hands-on exercise.
Materials needed: See the Personal Protective
Equipment (PPE) Supplies List.
Options: Hands-on exercises are required. However,
the trainer may choose to conduct the hands-on
exercise in this section as part of a comprehensive
hands-on exercise (as shown in Lesson Plan 2).
Slide 5-1: Module 5: During the Work
This module presents lead safe work practices that minimize dust, the second of the
three major steps to lead safety. Setup was the first; the third, cleanup, is covered in
the next module.
This module covers the bulleted list of topics on the slide. Review this list with the
class.
Module objective: The purpose of this module is to teach work practices that reduce
the amount of dust that is produced by renovation and to show how to apply them on
the job.
Mention that you will first explain what dust reducing work practices are and then
conduct an exercise where the participants can think about how they can apply lead-
safe work practices on the job.
Emphasize that dust reducing work practices are specific practices that have been
shown to minimize the creation and spread of leaded dust. Many of these practices
are not required under EPA's RRP Rule. Make the point that EPA prohibits certain
practices and that the Certified Firm is responsible to ensure that no dust or debris
leaves the containment or contaminates adjacent areas or properties. The student
notes have more detail on this issue, and it may be helpful to read the first
paragraph.
5-1
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Lead Safety for Renovation, Repair, and Painting
Module 5: During the Work
Overview:
Traditional renovations create airborne dust.
Prohibited practices.
Protect yourself and make a personal
protective equipment toolkit.
Control the spread of dust.
Hands-on exercise (Skill Set #6).
&EPA
Feb09
5-1
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 tools you will need.
5-1
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 5 Instructor Notes
Feb09
Slide 5-2: Traditional Renovations Create Airborne Leaded Dust
This chart illustrates that traditional work practices create large amounts of dust.
Point out that the chart shows amounts of dust in the air measured for three common
work practices.
The source of the data for this chart is a study that measured amounts of leaded dust
in the air caused by each type of work. The dust was measured in micrograms per
cubic meter (ug/m3).
The OSHA trigger level at which special worker protection measures are required
(known as the permissible exposure limit or PEL) is 50 ug/m3 (50 micrograms per
cubic meter; time-weighted average over an 8-hour workday). As shown in the chart,
the amount of leaded dust created by power and hand sanding and demolition is
much greater than the PEL. OSHA requires special worker protection measures
during conduct of these activities.
5-2
-------
Lead Safety for Renovation, Repair, and Painting
Traditional Renovations Create
Airborne Leaded Dust
600 -i
<> ^00
.2
ฎ 400
ฃ 300
TO
k.
o>
O9OO
o
S 1 no
*
A
Hand Sanding Power Sanding Interior Demolition
Traditional Work Practices
Feb09
* OSHA Permissible Exposure
Limit (PEL) = 50 A/g/m3
5-2
The data above are from Lead Exposure Associated with Renovation and Remodeling Activities:
Summary Report, Prepared by Battelle for the U.S. Environmental Protection Agency, May 1997, EPA
747-R-96-005.
Traditional work practices create large amounts of dust!
This chart shows amounts of lead dust created by three common construction practices: hand sanding,
power sanding, and interior demolition. The RRP Rule prohibits the use of power sanding, grinding.
planing and cutting without attached HEPA-filtered local capture ventilation because these
practices produce so much dust.
By using safe work practices, you can control and significantly reduce the amount of dust created on the
job. Controlling leaded dust at the source of generation is important because dust released into the air will
eventually become settled dust on the ground. Later in this chapter, you will learn safe work practices that
can replace these prohibited work practices. In this section you will also find best practice
recommendations for reducing dust in the work area.
5-2
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 5 Instructor Notes
Feb09
Slide 5-3: Prohibited Practices
This slide lists several practices that are known to create large amounts of dust and
create exposure risks for occupants and workers. These practices are:
1. Open flame burning or torching.
2. Heat gun paint removal above 1,100 degrees F.
NOTE: The student notes on the facing page discuss the fact that minute leaded-
dust particulates ("fume") may be generated by high temperature heating and
burning of paint. These particulates are very, very small and are easy to breathe
into the lungs. They are therefore more dangerous than dust, which is generally
ingested to the stomach. The lungs transfer lead to the blood stream much more
efficiently than does the stomach. Because of this, fume is much more dangerous
than ordinary leaded dust. For this reason heat gun removal above 1,100
degrees F, open flame burning, and torching for removal of lead-based paint are
prohibited.
3. The use of machines that disturb paint through high-speed operations such as
power sanding, grinding, or abrasive blasting without a HEPA vacuum attachment
is prohibited.
Note: The term "abrasive blasting" includes special tools that use high-pressure
air mixed with another medium such as sand, walnut shells, chemical salts, or dry
ice to remove paint from surfaces.
Highlight that the HUD Rule prohibits additional activities in properties receiving Federal
housing assistance. For example, the HUD Rule prohibits extensive dry scraping or
sanding by hand (not prohibited in the EPA RRP Rule). See Slide 2-13 and Appendix 2
for more information.
5-3
-------
Lead Safety for Renovation, Repair, and Painting
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.
Feb09
5-3
The EPA Renovation. Repair, and Painting Rule does not specifically address
what measures must be taken to reduce the amount of dust generated on the
job. Rather, the 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.
5-3
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 5 Instructor Notes
Feb09
Slide 5-4: Specialized Tools
Because many contractors use electric power tools on the job, it is often not possible
to mist surfaces with water due to the possibility of electric shock. Use battery-
powered or pneumatic tools with HEPA filtration, and provide ground fault circuit
interrupters (GFCIs) when working near electrical outlets and wiring, in wet areas, or
on wetted surfaces to prevent electric shock hazards.
Contractors should consider investing in specialized power tools with attached
HEPA-filtered local capture ventilation, or buying attachments that fit their current
power tools. This investment will pay off in the long run because workers will work
quicker and contain dust better with these tools than without them. It may also be
possible to rent such tools locally. Point out that the attachments do not capture all
the dust created by the work, so the other precautions, especially containment
systems, are still important.
5-4
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Lead Safety for Renovation, Repair, and Painting
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.
Feb09
5-4
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.
5-4
Feb09
-------
Lead Safety for Renovation, Repair, and Painting
Module 5 Instructor Notes
Feb09
Slide 5-5: Protect Yourself
Workers should take precautions to protect themselves from dust hazards on the job.
Note: These are minimal precautions. Employers must comply with OSHA
regulations which may require more extensive worker protection measures,
especially for high dust jobs.
As you talk about the specific worker protection precautions, refer to the following
slide:
Worker protection. Personal protective equipment: a painter's hat, coveralls, and
N-100 disposable respirator. N-100 is a NIOSH rating for respirators that can be
used around leaded dust. N-100 means that the respirator has HEPA filtering
capability. The disposable N-100 respirator is acceptable for small jobs but under
other work conditions, OSHA may require another type of respirator.
Workers don't need to wear gloves but should wash their hands frequently,
especially before eating, smoking, and leaving at the end of the day. Lead from
leaded dust does not pass through the skin.
Supervisors can buy extra-large disposable coveralls and re-size them with duct
tape. Some coveralls also have hoods to keep dust out of hair. The coveralls can
be used over again at the same job site but should be laundered by a commercial
service equipped to handle lead-contaminated clothing or disposed of at the end
of the job.
OSHA rules may specify that more involved worker protection measures be taken
at a specific job or for specific work activities. Some work activities, by their
nature, trigger OSHA requirements.
5-5
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Lead Safety for Renovation, Repair, and Painting
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
Feb09
5-5
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.
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).
5-5
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 5 Instructor Notes
Feb09
Slide 5-6: Control the Spread of Dust
This slide presents steps that workers should take to control the spread of dust from
the work site.
Dust can be spread when workers leave the work site to get tools, carry away debris,
take a break, leave at the end of the day, etc. The boundaries of the work site
depend on the containment area. For example, it may be only the area covered by
protective sheeting or it may be an entire room.
Workers can carry dust outside the work area on their shoes and clothes. They
should always wipe the tops and bottoms of their shoes, and vacuum their clothes
before stepping off the protective sheeting. Prior to leaving the work area renovators
must change out of disposable clothing (such as shoe covers, protective suits,
overalls, hats and gloves).
Workers should take extra precautions when cleaning themselves before leaving for
home, because they can carry dust home to their families on their clothes, in their
hair, on their bodies, and in their car. Studies have been conducted that measure the
blood lead levels of worker families. These studies confirm that the children of
construction workers do get poisoned by leaded dust carried home from work sites.
Remember the video seen earlier about the contractor who lead-poisoned his own
kids.
5-6
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Lead Safety for Renovation, Repair, and Painting
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. VJfEPA ! < <
Feb09
5-6
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 and/or 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.
5-6
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 5 Instructor Notes
Feb09
Slide 5-7: Cleaning During the Job
By nature, renovation, repair and paint jobs create debris which can pile up in the
work area. Debris should be removed periodically to keep it from being a source of
dust that can be easily spread by work activity, and the comings and goings from the
work site. For example, paint chips are quite easily tracked to other parts of the
residence (remember the sweetener demonstration you saw this morning). It is
important to clean your shoes before stepping off the protective sheeting.
Cleaning to keep debris and dust under control can be done in stages, but should be
done at least daily.
Waste containment, removal and disposal are critical for keeping dust and debris in
the work area to a minimum.
5-7
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Lead Safety for Renovation, Repair, and Painting
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).
Feb09
5-7
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.
5-7
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 5 Instructor Notes
Feb09
Slide 5-8: Exercise: Personal Protective Equipment
In this exercise, students will learn how to put on and take off personal protective
equipment, and how to decontaminate themselves and dispose of used equipment.
Prepare this exercise in advance:
Have appropriate supplies ready (See the list in Skill Set #6 following slide 5-8, and
in Appendix 6).
Review Skill Set #6.
Option
You may choose to perform this exercise as part of a larger comprehensive hands-on
exercise after Module 8, as described in Lesson Plan 2.
5-8
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Lead Safety for Renovation, Repair, and Painting
Exercise: Personal Protective
Equipment
Watch the instructor dress a volunteer in
personal protective equipment.
Skill Set #6-Protective Equipment (10 Min).
Practice putting on and taking off personal
protective equipment.
Dispose of used equipment properly and clean
up.
Feb09
5-8
Personal Protective Equipment
This exercise gives you a chance to learn and practice the proper steps for putting on and taking
off personal protective equipment, disposing of used equipment, and decontaminating yourself.
The slide provides basic instruction.
5-8
Feb09
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Skill Set #6: Personal Protective Equipment
Time: 10 minutes
Feb09
Supplies needed:
Disposable coveralls
Disposable non-latex gloves
Disposable foot covers
Eye protection
Leather or canvas work gloves
N-100 respirators
Disposable waste bags
Duct tape
Hand washing facilities and hand soap
Purpose: The purpose of this hands-on exercise is to show students the proper steps
for putting on (donning) and taking off (doffing) personal protective equipment, and the
steps for decontaminating and disposing of used equipment.
Note to Instructor: Read the purpose of this activity to students.
Demonstration: The course instructor should explain all of the steps involved in putting
on personal protective equipment while actually dressing a volunteer student in personal
protective equipment. Emphasize to students that this equipment prevents their
exposure to lead as well as prevents the contamination of areas outside of the work
area.
Evaluating the Students: Watch each student as they follow the steps on the next
page. Make corrections and suggestions as the exercise proceeds and determine if
additional practice is necessary. Option: Have students say the steps as they work.
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 #6 and that particular student's name.
Skill Set #6: Personal Protective Equipment
1 of 2
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Skill Set #6: Personal Protective Equipment - Continued
Skills Practice:
Step 1: Put on (don) a set of protective coveralls.*
Step 2: Put on disposable gloves.*
Step 3: Put on boot covers over shoes.*
Step 4: Put on safety glasses.*
Step 5: Put on work gloves.*
Step 6: When dressed in this Personal Protective Equipment, discuss the use of
respirators and show the proper method for putting on and securing the
respirator in place.
Note: Students should not wear a respirator if they are not currently enrolled
in the training firm's respiratory protection program. Watch the demonstration
but do not try on a respirator if this note applies you.
Step 7: Remove the work gloves and place them in a marked waste bag.*
Step 8: Remove the boot covers by pulling them off from the heel and rolling the
cover inside out as it is rolled toward the toes. Once removed, place them in
a marked waste bag.*
Step 9: Remove your suit by unzipping it and rolling it dirty side in to prevent
releasing dust. Once removed, place the suit in a marked waste bag.*
Step 10: Remove your disposable non-latex gloves by grasping the cuff of one glove
and peeling the glove inside out off of the hand. Hold the glove that was
removed in the palm of the gloved hand. Place one finger under the cuff of
the gloved hand and remove this glove by peeling it off of the gloved hand
inside out and over the balled up glove you had already removed. Once
removed, you should have one glove inside the other, with the dirty side
contained. Dispose of the gloves in the marked waste bag.*
Step 11: Wash your hands, face and shoes with soap and water. Dry your hands and
face with a disposable towel.*
*lndicates required skills that must be accomplished for a "Proficient" rating.
Skill Set #6: Personal Protective Equipment
2 of 2
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Lead Safety for Renovation, Repair, and Painting
Module 5 Instructor Notes
Feb09
Slide 5-9: Now You Know...
Use this slide to close out this module and transition to the next module.
5-9
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Lead Safety for Renovation, Repair, and Painting
Now You Know...
What work practices produce dust.
What work practices are prohibited by EPA
and HUD.
How to work safely around lead-based paint
and leaded dust.
Proper use of personal protective equipment.
Feb09
5-9
The practices you learned in this module will help you make less dust as you
work.
In the next module, we'll talk about how to conduct final cleaning of the work area,
and how to verify that the cleaning is complete.
5-9
Feb09
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Module 6: Cleaning Activities and
Checking Your Work
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Lead Safety for Renovation, Repair, and Painting
Module 6 Instructor Notes
Feb09
Overview of this module: The table below summarizes the content of and teaching methods
for this module. This is for your reference. Do not cover this with the participants.
Module 6: Cleaning Activities and Checking Your Work
90 minutes
6-1: Module 6: Cleaning Activities and
Checking Your Work
6-2: What is Effective Cleanup?
6-3: Interior Cleaning Requirements
6-4: Visual Inspection Procedure
6-5: Cleaning Verification (CV) Procedure
6-6: Dust Clearance Examination
6-7: Exterior Cleanup Requirements
6-8: Exterior - Check Effectiveness of
Cleaning
6-9: Disposal
6-10: Disposal - Federal, State and Local
Information
6-11: Exercise: Cleaning and the Cleaning
Verification Procedure
6-12: Now You Know...
Key message: Cleanup right. Use wet
mops and HEPA vacuums. Traditional
methods don't do the job.
Notes: Slides followed by an exercise
Slides: (40 minutes)
Hands-on Exercise: (50 minutes)
Preparing for this module: Prepare
materials for hands-on exercise and
the cleaning verification and clearance
demonstrations.
Materials needed: Cleaning verification
materials and tools listed on the
Cleanup Supplies List.
Options: The hands-on exercises in
this module are not optional, but the
trainer may choose when to use the
exercises. You may opt to use the
exercises during delivery of this module
(as shown in Lesson Plan 1), or, as
part of a comprehensive hands-on
exercise (as shown in Lesson Plan 2).
Slide 6-1: Module 6: Cleaning Activities and Checking Your Work
This module focuses on how to clean the work area in order to pass both a visual check and
either a verification check or clearance. A visual check means that an area has been cleaned to
the point that no dust, debris or paint chips can be seen with the naked eye. The verification
check involves comparing a disposable cleaning cloth used following cleaning to a standard
verification card to determine cleanliness. Clearance involves taking dust samples and having
them analyzed and compared with applicable dust standards to determine if the area is
adequately clean.
Effective cleaning includes using specific techniques and following the proper order when
cleaning. In this section, participants will learn:
How to conduct an effective cleaning;
The tools to always keep in your truck and at the work site;
Effective techniques to clean up after both interior and exterior jobs;
Safe disposal methods; and,
How to check your work.
6-1
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Lead Safety for Renovation, Repair, and Painting
Module 6: Cleaning Activities and
Checking Your Work
Overview
What is effective cleanup?
Interior cleaning techniques.
Exterior cleaning techniques.
How to check your work.
Cleaning verification procedure.
Clearance testing.
Safe disposal practices.
&EPA
Feb09
6-1
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.
6-1
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 6 Instructor Notes
Feb09
Slide 6-2: What is Effective Cleanup?
Discuss the similarities between planning for cleanup and approaching a job. Explain that,
just as you approach a job by planning the work to effectively contain dust and debris, you
must approach cleaning by first having effective containment, then carefully following
specific procedures to best clean the work area. The techniques outlined in this section
should make your cleanup faster, more efficient, and more effective.
Remember:
Always conduct a visual check of the work area to make sure all work is complete.
Proper waste disposal and checking your work are essential to the process of cleaning.
The most effective cleaning will follow this sequence:
1. Pick up all visible paint chips and debris.
2. Clean and dispose of protective sheeting.
For interior renovations:
3. Walls - slowly HEPA vacuum or wipe with a damp cloth, working from high to low.
4. Other surfaces - thoroughly HEPA vacuum all surfaces including furniture and fixtures.
Wipe any remaining surfaces with a damp cloth. The HEPA vacuum must have a beater
bar for use on carpeting.
5. Mop uncarpeted floors using the two-bucket mopping method.
6. Visually inspect your work.
7. Bag all waste in heavy-duty plastic bags, "gooseneck" seal, and dispose of them
according to Federal, state and local regulations.
8. Perform cleaning verification on windowsills, countertops and uncarpeted floors.
9. Remove warning signs.
Demonstrate how to "gooseneck seal" a heavy duty plastic bag and note that this will
be covered again in the disposal section.
Discuss why this cleanup sequence should work well.
Picking up all visible debris and paint chips prepares a work area prior to the first
HEPA vacuuming.
Clean and dispose of protective sheeting. This step should come before HEPA
vacuuming in order to collect any dust that may escape from the protective sheeting.
HEPA vacuum the area from high to low. This first HEPA vacuuming will collect dust
and debris not visible to the naked eye.
Wet cleaning and mopping the area will further dislodge any lead-contaminated dust or
debris not collected by the first HEPA vacuum. Wet cleaning also gets dust and debris
that is "stuck" to surfaces.
If necessary, a final pass with the HEPA vacuum or wet cleaning cloth will capture
any remaining dust or debris left after the wet cleaning.
The last step should be to check your work to make sure that visual check inspection
can be passed, and all waste is bagged, sealed and disposed of in accordance with
Federal, state and local laws.
A dust clearance examination may be required by Federal, state, tribal or local law, or
it may be requested by the homeowner. If so, the clearance examination will replace the
cleaning verification process. Clearance is required by HUD in many homes receiving
Federal housing assistance. For more information about clearance see Slide 6-6.
6-2
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Lead Safety for Renovation, Repair, and Painting
What is Effective Cleanup?
Keeping dust from getting back into areas
already cleaned.
Using proper cleaning techniques.
Cleaning all surfaces, tools and clothing.
Checking your work.
Usually will involve performing cleaning
verification.
Could include a clearance examination.
Safe and secure disposal of waste.
Feb09
6-2
Containment
Effective cleaning begins with proper preparation and containment. Cleaning will be much
easier and efficient if proper containment has kept all dust and debris confined to the work area.
While cleaning, keeping dust in the area that is being cleaned is also important. You don't want
to have cleaned areas become re-contaminated after cleaning.
Proper cleaning techniques
Follow a "top to bottom, back your way out" approach so that you don't have to re-enter an area
that has already been cleaned. Start cleaning high to low. You should be careful not to spread
dust to other areas while cleaning. Follow an ordered sequence of cleaning to ensure that you
do not contaminate other areas. For example, if floors are cleaned before the countertops you
must walk on the floors to get to the countertops and this risks re-contaminating the floors.
Never re-enter areas already cleaned. Also, countertops are higher than floors and can drop
dust onto the floors.
Cleaning all surfaces
The term "all surfaces" includes all vertical surfaces such as walls and windows, and all
horizontal surfaces such as floors, door tops and moldings, window troughs, and window sills.
Cleaning should proceed from high to low, i.e., from top of wall to window to floor.
Checking your work
Conduct a visual inspection after cleaning is completed. Look for paint chips, dust and debris.
Perform cleaning verification until all areas pass when compared to the cleaning verification
card.
A dust clearance examination may replace cleaning verification when required by Federal,
state, tribal, or local law, or by the owner.
Safe and secure disposal of waste
Bag and "gooseneck seal" all waste in heavy duty plastic bags. Safely dispose of all waste in
accordance with Federal, state and local regulations. See slides 6-9 and 6-10 for information on
disposal.
6-2
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 6 Instructor Notes
Feb09
Slide 6-3: Interior Cleaning Requirements
Review the material on the slide by reading the actual requirements as they appear in the
student text under the slide.
Ask: Why should you pick up paint chips and other debris before picking up the protective
sheeting? Why should you mist down and wet wipe the protective sheeting before picking it
up?
[Answer to both questions: To prevent accidental spreading of lead-contaminated paint
chips and dust off of the protective sheeting].
After the first visual inspection of the work area, cleaning, folding and disposing of the
protective sheeting is the next step. Clean your protective sheeting with a HEPA vacuum
and wet wipe if necessary. Once cleaned, fold (dirty side in) and seal the sheeting and
dispose with the rest of your waste. When you pick up and fold the protective sheeting (dirty
side in), be careful not to spread any dust that may remain on the sheeting.
This process is followed by HEPA vacuuming and wet mopping (discussed in the next slide)
to clean up any dust that escaped the protective sheeting.
Note that the sheeting covering the entry to the work area should stay in place until after the
cleaning and removal of other sheeting.
Emphasize that workers must always clean at least 2 feet beyond the work area.
Also, discuss why cleaning should always proceed from high to low.
[Answer: Cleaning from high to low is more efficient and effective because any dust or
debris dislodged will fall down to the floor. Just as one would clean steps working from the
top down, cleaning a work area should proceed from high to low to "push" all dust not
collected down to the floor, which should be cleaned last.]
6-3
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Lead Safety for Renovation, Repair, and Painting
Interior Cleaning
Requirements
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 -two-bucket mopping
method or wet mopping system.
x>EPA
Feb09
6-3
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.
6-3 Feb 09
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Lead Safety for Renovation, Repair, and Painting
Module 6 Instructor Notes
Feb09
Slide 6-4: Visual Inspection Procedure
Always conduct a visual check after cleaning is completed. If you find any dust or debris,
make another pass with the HEPA vacuum and, if necessary, wet clean again. You should
continue these steps until the site passes a visual check. Slide 6-11 contains an exercise
demonstrating cleaning, visual inspection and cleaning verification. This exercise is
mandatory.
After passing a visual check, you can perform the cleaning verification procedure or have a
clearance examination performed to check your work. In some instances, other dust
sampling may be required.
Emphasize that cleanup should always be performed as if a clearance examination is
to be conducted after cleaning.
6-4
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Lead Safety for Renovation, Repair, and Painting
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.
SERA
Feb09
6-4
Visual inspection after cleaning is required by the RRP Rule. Visual inspection is just the
first step.
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.
6-4
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 6 Instructor Notes
Feb09
Slide 6-5: Cleaning Verification (CV) Procedure
This slide describes the cleaning verification procedure in detail. The instructor should walk
students through the procedure.
Tell the students they may keep the cleaning verification card if they successfully complete
this course. These cards are provided by EPA to accredited training providers for distribution
to Certified Renovators.
Demonstration: Depending on the time available, the instructor should demonstrate the
cleaning verification process either during the lecture or as a part of the hands-on exercise. The
demonstration should include attaching a wet disposable cleaning cloth to an application device,
cleaning a known area of the floor, removal of the cloth, and comparing it to the cleaning
verification card.
Whether or not you do the demonstration here, you should show the students the cleaning
verification card and make sure that they understand how to conduct and interpret the results of
the comparison process.
Discuss the carpet cleaning procedure and emphasize that the cleaning verification procedure
does not apply to carpets; therefore, extra care must be taken in carpeted areas to not get dust
on the carpet. This may require extra layers of plastic as a good work practice to prevent dust
from getting in the carpet during conduct of the work.
The hands-on exercises in this module are mandatory.
6-5
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Lead Safety for Renovation, Repair, and Painting
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.
Feb09
6-5
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.
6-5
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 6 Instructor Notes
Feb09
Slide 6-6: Dust Clearance Examination
Discuss the following instances, where a dust clearance examination (40 CFR 745.227(e)(8))
may be required or requested instead of the cleaning verification procedure:
HUD requires a dust clearance examination after certain kinds of jobs in target housing
receiving Federal housing assistance. Ask if the property receives Federal assistance. If
so, ask if a clearance examination is required.
In some states, a clearance examination conducted by a certified or trained person may
be required by law. You should be aware of laws regarding clearance examinations and
renovation work in your state and locality.
In some instances, the owner may request that dust wipe samples be taken to locate
lead hazards and to ensure cleaning has been effective. If you follow the cleaning
techniques described earlier, you should pass be able to pass clearance testing.
Emphasize that once you begin a clearance examination, if the clearance fails you must
continue the cycle of re-cleaning, visual inspection, and dust wipe testing until the dust wipe
results comply with the clearance standards governing the work.
6-6
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Lead Safety for Renovation, Repair, and Painting
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 standards
comply with applicable state, territorial, tribal
and local standards. ^
Feb09
6-6
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.
6-6
Clearance is required 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.
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 6 Instructor Notes
Feb09
Slide 6-7: Exterior Cleanup Requirements
The main point of cleaning after an exterior renovation job is not to let dust spread beyond
the work area. The focus is to be specifically on the areas accessible to children. This
includes bare soil, play areas, exterior porches and exterior window sills.
Always visually inspect beyond the work area. Collect and dispose of all paint chips, dust
and debris found.
6-7
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Lead Safety for Renovation, Repair, and Painting
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.
ฉEPA
Feb09
6-7
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.
6-7
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 6 Instructor Notes
Feb09
Slide 6-8: Exterior - Check the Effectiveness of Cleaning
Discuss why a visual inspection for checking the cleaning is necessary.
The visual inspection checks for visible dust and debris and includes all parts of the work
area, areas not covered by the protective sheeting, and areas 2 feet outside the
containment.
6-8
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Lead Safety for Renovation, Repair, and Painting
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.
Feb09
6-8
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.
6-8
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 6 Instructor Notes
Feb09
Slide 6-9: Disposal
Have bags and tape ready for the demonstration, if you choose to perform it, and for the
required hands-on activity.
Waste should be stored in a secure area to prevent children from getting into it and being
exposed to leaded dust.
Discuss methods to handle waste water.
Waste water produced during the job from mopping, wet cleaning, or misting should not be
poured down the sink or tub (because it will contaminate the sink or tub), into the yard or
down a storm drain.
Before disposal, waste water may need to be filtered through a filter capable of filtering out
particles 5 microns or larger, depending on state and local wastewater regulations.
If local regulations allow, waste water may be poured down the toilet. 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. Your local water authority can assist you with
this decision.
Always be aware of Federal, state and local regulations regarding waste water disposal.
All waste should be handled carefully and sealed in heavy duty plastic bags.
Do not overfill the bags. Renovation debris is heavy, and, if overfilled, will split the bags and
could injure workers.
Certified Firms must be aware of all components of the waste produced at the job site and of
the proper method of disposal. Again, always be aware of Federal, state and local waste
disposal regulations.
6-9
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Lead Safety for Renovation, Repair, and Painting
Disposal
What should I do with my waste?
At the work site:
Place waste in heavy duty plastic bag.
"Gooseneck seal" the bag with duct
tape.
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.
Feb09
6-9
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 or dumpster 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.
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. Filtering waste
water through a 5-micron filter may be necessary when lead-contamination such as paint
chips and dust may be present in the water. Check with your local water treatment
authority, and in Federal and state regulations for more information.
Always dispose of waste water in accordance with Federal, state and local regulations.
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.
6-9
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 6 Instructor Notes
Feb09
Slide 6-10: Disposal - Federal, State and Local Information
Waste disposal is regulated under the Resource Conservation and Recovery Act (RCRA),
and various associated state and local laws and regulations.
Some waste generated from lead work may meet the definition of "hazardous waste"
because it is toxic, corrosive, ignitable or explosive. Therefore, it is important for contractors
to segregate waste into categories that are likely to be hazardous and non-hazardous.
Examples of hazardous waste may include paint chips, vacuum debris, sludge or chemical
waste from stripper, and HEPA filters.
Generators of less than 220 pounds of waste per job site per month are exempt from
Federal waste disposal regulations and most state regulations.
Many states have more stringent regulations than Federal requirements. It is, therefore,
important for contractors to understand their obligations under these laws and regulations.
You should always be aware of how much waste you are generating per job site per month.
EPA's website has links to state information on solid and hazardous waste disposal at
http://www.epa.gov/epawaste/wyl/stateprograms.htm.
In a memorandum to RCRA Senior Policy Advisors and EPA Regions 1 -10, dated July 31,
2000, EPA's Office of Solid Waste stated that lead-based paint waste from households may
be disposed of as household garbage subject to applicable state regulations. For more
information, see Appendix 8 and the EPA website at www.epa.gov/lead/pubs/fslbp.htm.
Although EPA considers lead-based paint waste commonly generated during residential
renovation and painting to be household waste, some states have not yet adopted this
interpretation. Until states do adopt EPA's interpretation, they may continue to regulate lead-
based paint waste as potentially hazardous if generated in large enough quantities.
6-10
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Lead Safety for Renovation, Repair, and Painting
Disposal - Federal, State and
Local Information
According to Federal law:
In housing: Waste must be disposed of as normal
household waste.
In non-residential child-occupied facilities: If waste
exceeds 220 Ibs, treat all debris as hazardous.
Always check local requirements!
Feb09
6-10
Waste Disposal Issues
Because EPA considers most residential renovation and remodeling as "routine
residential maintenance", the waste generated during these activities is classified as
solid, non-hazardous waste, and should be taken to a licensed solid waste landfill.
This does not apply to commercial, public or other non-residential child-occupied
facilities.
If you generate any hazardous waste, you should determine whether you generate
more than 220 pounds of hazardous waste per job site per month. If you have less
than 220 pounds per location per month, manage the waste as solid, non-hazardous
waste. If you generate more than 220 pounds of hazardous waste, you should contact
your state and local regulators to find out how to properly dispose of it.
Some possible examples of hazardous waste include: paint chips; vacuum debris;
sludge or chemical waste from strippers; and, HEPA filters.
Some possible examples of non-hazardous waste may include: disposable clothing;
respirator filters; rugs and carpets; protective sheeting; and, solid components with no
peeling paint.
All waste should be sealed in heavy duty heavy duty plastic bags and handled
carefully.
Large architectural components should be wrapped and sealed in plastic sheeting, and
disposed of along with other waste.
Always check Federal, state and local requirements before disposing of waste.
Some states have enacted more stringent waste management and disposal
requirements than Federal regulations. You need to become aware of how
Federal, state and local requirements affect the management and disposal of
renovation waste in your area.
6-10
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 6 Instructor Notes
Feb09
Slide 6-11: Exercise: Cleaning and the Cleaning Verification Procedure
Prepare this exercise in advance:
Have appropriate tools and supplies ready. Necessary tools and supplies include buckets,
mops, water, detergent, a HEPA vacuum, wipes, plastic sheeting, plastic bags, tape, disposable
cleaning cloths and cleaning verification cards. See Skill Sets #7 - #11 for a complete list of
materials and supplies.
You will need access to water.
Sprinkle each work area with corn starch or baby powder to simulate dust.
Refer to the Skill Sets #7 - #11 following and in Appendix 6 for a list of skills that participants
should practice.
Vary the color and type of work area surfaces if possible.
When conducting the exercise:
Instruct participants to stay in their groups.
Circulate while they work to ensure they are doing the work properly.
Coach them as necessary to correct any incorrect behaviors.
Give them a 5-minute warning.
When the time for each skill set is up, tell them to stop. Keep to the schedule.
Option
You may also perform this cleanup exercise later in the course as part of a larger
comprehensive hands-on module as described in Lesson Plan 2 in the Note to the Instructor on
How to Use This Curriculum in the introduction. The comprehensive hands-on module combines
the hands-on components from Modules 4, 5, and 6.
Note: In some training facilities, such as hotels, you may not have access to water in the
training room. In such cases, instruct participants to walk through the process - practicing the
order of the steps: HEPA vacuum, two bucket wash, cleaning from high to low, etc. As a
demonstration of how hard it is to clean up dust, consider sprinkling corn starch or baby powder
on a tabletop and experimenting with different methods for cleaning it up - broom and dust pan,
HEPA vacuum, wet wipe, etc.
6-11
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Lead Safety for Renovation, Repair, and Painting
Exercise: Cleaning and the
Cleaning Verification Procedure
Work in groups of 2-6.
Assignments:
Skill Set #7: Interior Final Cleaning
Skill Set #8: Exterior Final Cleaning
Skill Set #9: Bagging Waste
Skill Set #10: Visual Inspection
Skill Set #11: Cleaning Verification Procedure
Choose the tools and supplies you need to clean
the work area.
Clean your work area.
You have 40 minutes.
Feb09
6-11
Exercise: Cleanup and Cleaning Verification
This exercise gives you a chance to demonstrate cleanup, visual clearance, cleaning
verification, and proper waste-bagging techniques. The slide provides basic
instruction.
Stay in your groups of 2 to 6 students, in your work area.
Choose the right tools. Tools available include buckets, mops, water, detergent,
HEPA vacuum, wipes, plastic sheeting, plastic bags, tape, etc.
Clean up the dust.
Bag the waste.
Check your work.
Verify cleaning.
6-11
Feb09
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Skill Set #7: Interior Final Cleaning
Time: 10 minutes
Feb09
Supplies needed:
Heavy duty plastic sheeting
Duct tape
HEPA vacuum with attachments and a powered beater bar
Garden sprayer
Cutting tool (e.g., razor knife, box cutter or scissors)
Disposable wet cleaning wipes
Heavy duty plastic bags
Two-sided mop bucket with wringer (or equivalent), disposable mop heads, long handled
mop to which disposable cleaning cloths can be attached; or, a wet mopping system.
Purpose: The purpose of this hands-on exercise is to show students the proper steps for
cleaning the interior work area after the completion of the work and prior to the visual inspection
and cleaning verification procedure, or a clearance examination.
Note to Instructor: Read the purpose of this activity to students. Remind them that they are
trying to completely clean all visible dust and debris in the work area, and that their work will
be checked. Remind them that this level of cleanliness is achievable, but does require
attention and careful execution.
The course instructor should explain all of the steps involved in cleaning the work area.
Emphasize to students that there are no short cuts to passing the visual inspection.
Recommended personal protective equipment during final cleaning activities is a set of
disposable coveralls, disposable gloves, and shoe covers.
If plastic sheeting is not already in place from previous exercises, have plastic sheeting
for the floor or carpets put down.
Evaluating the Students: Watch each student follow the steps on the following page. Make
corrections and suggestions as the exercise proceeds and determine if additional practice is
necessary. 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 #7 and that particular student's name.
Skill Set #7: Interior Final Cleaning
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Skill Set #7: Interior Final Cleaning - Continued
Skills Practice:
Step 1: Wrap and seal, or bag all components and other large materials and then remove
them from the work area.*
Step 2: Clean off the plastic sheeting using a HEPA vacuum (this procedure is not required,
but it is faster than wiping up dust and debris by hand). Mist the plastic sheeting and
fold dirty side inward. Either seal the edges of the folded plastic sheeting with tape or
place it in a heavy-duty plastic bag. Dispose of the protective sheeting.*
Step 3: Remove all waste from the work area and place in appropriate waste containers.*
Step 4: Clean all surfaces within the work area and in the area 2 feet beyond the work area
until no dust or debris remains. Start cleaning at the top of the walls and work down
toward the floor, HEPA vacuum or wet wipe all wall surfaces in the work area. HEPA
vacuum all remaining surfaces in the work area, including furniture and fixtures. Use
the upholstery attachment for the window surfaces and the crevice tool along the
edge of the walls. Use the HEPA vacuum with a beater bar for carpeting. Work from
the end farthest from the work area entrance back to the entrance, making sure
never to step back into areas that have already been cleaned.*
Step 5: Next, wipe all remaining surfaces and objects in the work area except for carpeted
and upholstered surfaces, with a disposable wet cleaning wipe. Also mop uncarpeted
floors using a two-bucket method or wet mopping system. Work from the end farthest
from the work area entrance back to the entrance, making sure never to step back
into areas that have already been cleaned. For carpeted areas, conduct a second
pass with the HEPA vacuum using the beater bar attachment instead of wiping with a
wet cleaning cloth.*
Step 6: If the property is HUD-regulated, repeat Step 4 for walls, countertops and floors, and
then continue to Step 7. Otherwise, continue to Step 7.
Step 7: After completion of cleaning procedures, check your work. Conduct a careful visual
inspection of the work area for visible dust and debris. If visible dust or debris is
found, repeat Steps 4 and 5 as needed to make sure no visible dust or debris is
present, and then re-check your work with a thorough visual inspection of the work
area. When there is no visible dust or debris present, proceed to step 8.*
Step 8: Notify the Certified Renovator in charge of the project that the work area is ready for
visual inspection.*
*lndicates required skills that must be accomplished for a "Proficient" rating.
Skill Set #7: Interior Final Cleaning
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Skill Set #8: Exterior Final Cleaning
Time: 10 minutes
Feb09
Supplies needed:
Heavy duty plastic sheeting
Heavy duty plastic bags
Tape (duct, painters, and masking)
Cutting tool (e.g., razor knife, box cutter or scissors)
Flashlight.
Disposable wet cleaning wipes
HEPA vacuum with attachments
Two-sided mop bucket with wringer (or equivalent), disposable mop heads, long handled
mop to which disposable cleaning cloths can be attached; or, a wet mopping system.
Purpose: The purpose of this hands-on exercise is to show students the proper steps for
cleaning an exterior work area after the completion of the work and prior to the visual inspection
and (if required) the cleaning verification procedure or a clearance examination.
Note to Instructor: Read the purpose of this activity to students. Remind them that they are
trying to clean all visible dust and debris within the work area, and that their work will be
checked. Remind them that this level of cleanliness is achievable, but does require attention
and careful execution.
The course instructor should explain all of the steps involved in cleaning the work area.
Emphasize to students that there are no short cuts to passing the visual inspection.
Recommended personal protective equipment during cleaning activities is a set of
disposable coveralls, disposable gloves, and shoe covers.
If plastic sheeting is not already in place from previous exercises, have plastic sheeting
for the floor or carpets put down.
Evaluating the Students: Watch each student follow the steps on the following page. Make
corrections and suggestions as the exercise proceeds and determine if additional practice is
necessary. Option: Have students say the steps as they work. 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 #8 and that particular
student's name.
Skill Set #8: Exterior Final Cleaning
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Skill Set #8: Exterior Final Cleaning - Continued
Skills Practice:
Step 1: Wrap and seal or bag all components and other large materials and then remove
them from the work area.*
Step 2: Clean off the plastic sheeting using a HEPA vacuum (this procedure is not required,
but it sure is faster than wiping up dust and debris by hand). Mist the plastic sheeting
and fold dirty side inward. Either seal the edges of the plastic sheeting with tape or
place it in a heavy-duty plastic bag. Dispose of plastic sheeting.*
Step 3: Remove all waste from the work area and place in appropriate waste containers.*
Step 4: Clean all surfaces in the work area and areas within 2 feet beyond the work area
until no visible dust, debris, or paint chips remain.*
Suggested Cleaning Procedure For Exterior Cleanable Surfaces: Start cleaning
at the top of the walls and work down to the floor, HEPA vacuum or wet wipe all
cleanable surfaces in the work area, including furniture and fixtures. Use the HEPA
vacuum with the upholstery attachment for windows and use the crevice tool along
the walls. Work from the end farthest from the work area entrance back to the
entrance, making sure never to step back into areas that have already been cleaned.
Step 5: After completion of cleaning, check your work. This is done by conducting a careful
visual inspection of the work area for visible dust, debris, or paint chips on hard
surfaces, and for visible dust, debris, or paint chips in the soil areas under the work
area protective sheeting. If dust or debris is found, re-clean, and then re-check your
work with a thorough visual inspection of the work area. Once there is no visible
dust, debris, or paint chips present, proceed to step 6.*
Step 6: Notify the Certified Renovator in charge of the project that the work area is ready for
visual inspection.*
*lndicates required skills that must be accomplished for a "Proficient" rating.
Skill Set #8: Exterior Final Cleaning
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Skill Set #9: Bagging Waste
Time: 10 minutes
Feb09
Supplies needed:
Used plastic sheeting and used personal protective equipment (from previous
exercises)
Dust and debris (from previous exercises)
Heavy duty plastic sheeting
Heavy duty plastic bags
Cutting tool (e.g., razor knife, box cutter or scissors)
HEPA vacuum with attachments
Duct tape
Purpose: The purpose of this hands-on exercise is to show the students the proper
steps to bag and gooseneck waste, wrap large pieces of debris, and remove waste from
the work area.
Note to Instructor: Read the purpose of this activity to students.
Demonstration: The course instructor should demonstrate the proper
gooseneck technique for sealing waste bags.
Optional Bagging Relay Race: This exercise can be conducted as a relay race.
Divide students into teams and have each team member select a waste bag,
load it with simulated waste material, make a gooseneck in the waste bag,
vacuum the bag and submit it as complete in the simulated waste storage area.
This will allow the instructors to observe proficiency in the method of closing the
bags and making goosenecks and provides a fun way to learn for the students.
Evaluating the Students: Watch each student make a gooseneck closure on a waste
bag. Students must complete all required Steps to be "Proficient". 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 #9
and that particular student's name.
Skill Set #9: Bagging Waste
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Skill Set #9: Bagging Waste - Continued
Skills Practice:
Note: This exercise requires that the waste materials generated throughout the
exercises be stored in unsealed bags or in sheets of plastic.
Gooseneck Procedure for Waste Bags:
Step 1: Each student should get a waste bag and place some material in it that will
be discarded as simulate waste. Do not overfill bags.
Step 2: Gather the open end of the bag just below the opening into one hand.*
Step 3: Twist the bag so that the neck of the bag twists in the same direction and
forms an 8"-10" column.*
Step 4: Fold the twisted column over on itself, in a similar manner to how you would
fold a hose over onto itself to cut off the flow of water.*
Step 5: Grasp the folded neck of the bag in one hand and wrap tape around the
folded neck to secure the fold in place.*
Step 6: Now wrap the tape about 2 or 3 inches from the top of the fold, several times
so that the bag cannot come open. The resulting bags neck looks like the
neck of a goose folded back on itself (a goose neck seal).*
Step 7: Use the HEPA vacuum to remove any dust from the exterior of the bags.
Carry the bags out of the work area to the appropriate waste container.*
Wrapping large pieces of debris:
Step 1: Cut a piece of plastic so that it can be wrapped around the debris to be
disposed of.*
Step 2: Once wrapped in plastic, tape the seams of the package.*
Step 3: Wrap tape around the width of the package in three spots to keep the
package from unraveling.*
Step 4: Use the HEPA vacuum to remove any dust from the exterior of the package
and carry the wrapped debris out of the work area to the appropriate waste
container.*
*lndicates required skills that must be accomplished for a "Proficient" rating.
Skill Set #9: Bagging Waste
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Skill Set #10: Visual Inspection
Time: 5 minutes
Feb09
Supplies needed:
Disposable foot covers
Flashlight
Purpose: The purpose of this hands-on exercise is to show the students the proper
steps for conducting a visual inspection of the work area prior to conduct of the cleaning
verification procedure.
Note to Instructor: Read the purpose of this activity to students. Remind them that
they are trying to verify that all visible dust and debris has been cleaned from the
work area. Remind them that this level of cleanliness is achievable, but does require
attention and careful execution. Also read the note to the students below.
Note to Students: If a clearance examination is to be performed, the Certified
Renovator should still conduct a visual inspection before submitting to the two-part
clearance examination. A clearance examination consists of a separate visual
inspection and dust wipe testing. The two-part clearance examination is conducted
by a Certified Lead Inspector, Certified Lead Risk Assessor, or Certified Sampling
Technician.
Demonstration: The course instructor should explain all of the steps involved in
performing a visual clearance in the work area. Emphasize to students that there are no
short cuts to passing the visual inspection.
Evaluating the Students: Watch each student conduct a visual inspection 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 #10 and that
particular student's name.
Skill Set # 10: Visual Inspection
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Skill Set #10: Visual Inspection - Continued
Skills Practice:
Step 1: Put on disposable foot covers so that you do not track dust and debris into
the work area, then enter the work area.*
Step 2: Turn on all of the lights that are available in the work area. Bring a bright,
white-light flashlight to make sure there is adequate lighting.*
Step 3: Systematically look at every horizontal surface in the work area, working from
the farthest area from the entry to the entry without recovering your tracks.
Get close to the surfaces you are inspecting.*
Note: Remember this is a visual inspection, but the cleaning verification is
going to wipe dust up to compare with the cleaning verification card. If you
suspect a surface to be dirty, have it re-cleaned with a wet cleaning cloth.
Step 4: If you find visible dust or debris, re-clean the work area and repeat step 3.*
Step 5: Once you have carefully inspected all of the surfaces and have found no dust
or debris, proceed to the cleaning verification procedure in Skill Set #11 .*
*lndicates required skills that must be accomplished for a "Proficient" rating.
Skill Set # 10: Visual Inspection
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Skill Set #11: Cleaning Verification Procedure
Time: 15 minutes
Feb09
Supplies needed:
Baby powder or corn starch
Disposable foot covers
Flashlight
Disposable non-latex gloves
Disposable wet cleaning wipes
Cleaning verification card, one per student to take away and retain
Electrostatically charged, white, disposable cleaning cloths designed for cleaning hard
surfaces
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 #11: Cleaning Verification Procedure
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Skill Set #11: 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 window sill 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 window sill 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 window
sill 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 window sill 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.*
Step 9: Once the cleaning verification shows that all areas have been adequately
cleaned, remove the signs and critical barriers around the work area.*
*lndicates required skills that must be accomplished for a "Proficient" rating
Skill Set #11: Cleaning Verification Procedure
2 of 2
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Lead Safety for Renovation, Repair, and Painting
Module 6 Instructor Notes
Feb09
Slide 6-12: Now You Know...
Review the following slide with students to remind them about what they learned during this
module.
6-12
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Lead Safety for Renovation, Repair, and Painting
Now You Know...
How to clean the work area systematically.
How to check the effectiveness of cleaning.
How to perform a visual inspection of the work
area.
How to perform the cleaning verification
procedure.
How to release the work area for clearance
testing.
How to properly dispose of
Feb09
6-12
The information on the slide above summarizes the topics covered in this module.
6-12
Feb09
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Module 7: Recordkeeping
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Lead Safety for Renovation, Repair, and Painting
Module 7 Instructor Notes
Feb09
Overview of this module: The list below summarizes the content and teaching methods
for this module. This is for your reference. Do not cover this with the participants.
Module 7: Recordkeeping
20 minutes
7-1: Module 7: Recordkeeping
7-2: On-The-Job Records
7-3: Recordkeeping: Pre-Renovation Education
Records
7-4: Sample Confirmation of Receipt of Renovate
Right
7-5: Recordkeeping: Non-Certified Worker
Training
7-6: Recordkeeping: Test Kit Reporting
7-7: Recordkeeping: Post-Re novation Reporting
7-8: Now You Know...
Key message: Records must
be complete, accurate and
organized.
Notes: This module is all
lecture. Participants learn
what records they should
keep.
Preparing for this module:
Review materials in advance
so you are familiar with them.
Slide 7-1: Module 7: Recordkeeping
The purpose of this module is to teach the Certified Renovator and Certified Firm
managers how to keep required records of the job and to determine what records
they must retain.
Announce the module and move quickly to the next slide.
7-1
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Lead Safety for Renovation, Repair, and Painting
Module 7: 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.
Feb09
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 3-year record retention requirement for
notices, evaluations, and clearance or abatement reports (24
CFR35.175).
7-1
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 7 Instructor Notes
Feb09
Slide 7-2: On-The-Job Records
Talk briefly through the topics to be covered.
Emphasize that copies of the Certified Renovator training certificate and Certified
Firm certification, as well as documentation of training of non-certified workers (if
applicable), must be kept on-site when you work in target housing or child-
occupied facilities, where lead-based paint or assumed lead-based paint is
disturbed. Make sure students understand that the other documents listed here
must be maintained, but do not have to be kept on site.
7-2
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Lead Safety for Renovation, Repair, and Painting
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 pre-renovation education.
Opt out certification by owner/occupant, when they
qualify to and decide to opt out of the lead-safe work
practice requirements.
Non-certified worker training documentation (must be
kept on site).
Feb09
7-2
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
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.
7-2
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 7 Instructor Notes
Feb09
Slide 7-3: Recordkeeping: Pre-Renovation Education Records
Talk briefly through the topics to be covered.
7-3
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Lead Safety for Renovation, Repair, and Painting
Recordkeeping: Pre-Renovation
Education Records
In Target Housing - Individual units:
Must acquire either written proof of receipt by an adult occupant
or proof of delivery/unsuccessful delivery of Renovate Right, or:
Written proof of receipt of Renovate Right by owner or proof of
mailing (if mailing, send 7 days prior to renovation).
In Target Housing - Common Areas (Two Options):
Provide written notification to each affected unit and make
Renovate Right pamphlet available on request; or:
Keep copies or pictures of the signs and notices posted.
In Child-Occupied Facilities
Written proof of receipt of Renovate Right by owner or proof of
mailing required (If mailing, send 7 days prior to renovation).
Maintain proof of receipt by owner or adult representative, or
certify in writing that the Renovate Right pamphlet has been
delivered to facility. A PDA
Keep copies or pictures of the signs and notices
Feb09
7-3
In addition to the requirements above, maintain all records for pre-renovation
education activities that contain information about the following:
In Target Housing - Individual Units:
When contacts with the owner and occupants were attempted.
Written proof of when contacts were made.
In Target Housing - Common Areas:
Documentation of when and to whom written notification was delivered for each unit
affected.
What notices were posted, and when and where they were posted.
In Child-Occupied Facilities:
When contacts with the owner and occupants were attempted.
Written proof of when contacts were made.
Whether and when contact was made with the owner or adult representative of the
child-occupied facility.
What notices were posted, and when and where they were posted.
7-3
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 7 Instructor Notes
Feb09
Slide 7-4: Sample Confirmation of Receipt of Renovate Right
Review the slide and the handouts on the next three pages.
7-4
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Lead Safety for Renovation, Repair, and Painting
Sample Confirmation of Receipt of
Renovate Right
U I have received a copy of the pamphlet, Renovate Right: Important
Lead Hazard Information for Families, Child Care Providers and
Schools.
Recipient Signature: Printed Name: Date: / /
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.
a Refusal to sign.
a Unavailable for signature.
Gather the following information:
Printed name and signature of person certifying lead pamphlet delivery.
Date and time of lead pamphlet delivery. f^ __..
Unit address. OtPA .''lil!
Feb09
7-4
7-4
Feb09
-------
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 - 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 7 days before
renovation. Mailing must be documented by a certificate of mailing from the post office.
25
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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, Protect Your Family From Lead in Your
Home, 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 Procedures Used For Delivering Notices to Tenants of
Renovations in Common Areas
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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Lead Safety for Renovation, Repair, and Painting
Module 7 Instructor Notes
Feb09
Slide 7-5: Recordkeeping: Non-Certified Worker Training
Talk briefly through the topics to be covered.
7-5
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Lead Safety for Renovation, Repair, and Painting
Recordkeeping: Non-Certified Worker
Training
Worker's name.
Description of lead safe work practices the
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.
&EPA
Feb09
Documentation of Non-Certified Renovation Worker Training
The Certified Renovator who conducted the non-certified 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 workers (See Appendix 6).
7-5
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 7 Instructor Notes
Feb09
Slide 7-6: Recordkeeping: Test Kit Reporting
Talk briefly through the topics to be covered.
7-6
-------
Lead Safety for Renovation, Repair, and Painting
Recordkeeping: Test Kit Reporting
If an EPA-recognized test kit is used to test
surfaces in the work area, the firm must:
Submit a report to the person contracting for the work
within 30 days after the end of the renovation,
containing:
Manufacturer and model of the EPA-recognized test kit.
A description of of the components tested.
The location of components tested.
Results of the testing.
Retain a copy of the test kit
documentation form. <>EPA h1
Feb09
7-6
Checking for Lead-Based Paint With EPA-Recognized Test Kits:
Check www.epa.gov for a list of EPA-recognized test kits.
Each component to be renovated or impacted by renovation must be tested. If all surfaces are
found to be free of lead-based paint, the RRP Rule does not apply.
If a set of affected components make up an integrated whole (such as a stair tread or riser
within a single staircase; or, a window casing, apron, stool, header or trough in a window case
system), then only one of the individual components from that set needs to be tested.
EPA-Recognized Test Kits:
Until September 1, 2010, EPA is only requiring the use of test kits that determine that lead-
based paint 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, while the change does not with
certainty mean that lead-based paint is present, the surface must be presumed to be coated
with lead-based paint.
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.
If the test kit positive indicator is present on any of the tested surfaces, lead-safe work
practices must be used. Alternatively, sampling may be performed by a Certified Lead
Inspector or Risk Assessor to prove by laboratory analysis that lead-based paint is not present.
Certified Renovators must use an EPA-recognized test kit to test affected surfaces. EPA-
recognized test kits are listed on the EPA website at www.epa.gov.
Reporting:
When test kits are used, within 30 days of completing the renovation, the Certified Renovation
firm must provide information on test kit manufacturers and models used for testing, a
description of components tested including locations, and the results of testing, to the client
who contracted for the renovation.
Retain a copy of the test kit documentation form.
7-6
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 7 Instructor Notes
Feb09
Slide 7-7: Recordkeeping: Post-Renovation Reporting
Talk briefly through the topics to be covered.
The "Future Sample Renovation Recordkeeping Checklist" is included in
Appendix 4 and can also be accessed online at:
http://epa.gov/lead/pubs/renovation.htmtfcontractors.
7-7
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Lead Safety for Renovation, Repair, and Painting
Recordkeeping: 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 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. ^ CDA
Feb09
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;
Records of inspections and/or risk assessments conducted by Certified Lead Inspectors
or Risk Assessors, if applicable.
Proof of successful cleaning verification.
If dust clearance sampling is performed in lieu of cleaning verification, provide a copy of
the dust sampling report to the person who contracted for the renovation within 30 days of
the completion of the renovation (see 40 CFR 745.86(d)).
7-7
Feb09
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This Page Intentionally Left Blank
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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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Lead Safety for Renovation, Repair, and Painting
Module 7 Instructor Notes
Feb09
Slide 7-8: Now You Know...
Quickly discuss the slide.
-------
Lead Safety for Renovation, Repair, and Painting
Now You Know...
To have records available at the work site of:
Training of Certified Renovators and non-certified renovation
workers.
Certifications for the Certified Firm and Certified Renovators.
To retain all records for at least 3 years after completion of the
renovation.
To keep records of:
Training and certifications for all renovation personnel, and
for certification of the firm.
Distribution of required information.
Communications with and certifications from owners and
residents.
Work activities in compliance to the Rule.
Post-renovation reports.
Feb09
7-8
7-?
Feb09
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Module 8: Training Non-Certified
Renovation Workers
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Lead Safety for Renovation, Repair, and Painting
Module 8 Instructor Notes
Feb09
Overview of this module: For your reference the table below summarizes the content
and teaching methods for this module. Do not cover this with the participants.
Module 8: Training Non-Certified Renovation Workers
40 Minutes
8-1: Module 8: Training Non-Certified
Renovation Workers
8-2: Teaching Lead-Safe Work Practices
Means:
8-3:The Role of the Certified Renovator
8-4: Role of Trained, Non-Certified
Renovation Workers
8-5: Steps for Teaching Lead Safety
During Renovations
8-6: Use the "Steps" Guide
8-7: Step 1: Determine if the Job Involves
Lead-Based Paint
8-8: Step 2: Set It Up Safely
8-9: Step 2: Set It Up Safely - Continued
8-10: Step 3: Protect Yourself
8-11: Step 4: Control the Spread of Dust
8-12: Step 5: Leave The Work Area Clean
8-13: Step 6: Control the Waste
8-14: Step 7: Cleaning Verification or
Clearance Testing
8-15: Training Documentation
8-16: Now You Know...
Key message: Certified Renovators
are responsible for teaching lead-safe
work practices to non-certified
renovation workers.
Notes: Emphasize that this training is
to give Certified Renovators the tools
and skills necessary to conduct either
on-site "toolbox" training or classroom
training for non-certified renovation
workers. All training should focus
mainly on teaching students to
perform the tasks necessary to work
as non-Certified Renovators on the
job. Special emphasis should be
placed on the practical skills and
activities of lead safe work practice
using as much hands-on instruction
as possible.
Preparing for This Module: Review so
you are familiar with the materials.
Slide 8-1: Module 8: Training Non-Certified Renovation Workers
Notes to the Instructor:
Announce the module and move quickly to the next slide.
Review the goal of this module:
To enable Certified Renovators to effectively teach non-certified workers how to use
lead safe practices during renovation, repair and painting work in target housing and
child-occupied facilities.
8-1
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Lead Safety for Renovation, Repair, and Painting
Module 8: Training Non-Certified
Renovation Workers
Certified Renovators are
responsible for teaching lead-safe
work practices to non-certified
renovation workers.
Feb09
The RRP Rule requires that you, the Certified Renovator, be responsible for
instruction of non-certified renovation workers.
8-1
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 8 Instructor Notes
Feb09
Slide 8-2: Teaching Lead Safe Work Practices Means:
Review the slide and student notes with the class.
8-2
-------
Lead Safety for Renovation, Repair, and Painting
Teaching Lead Safe Work
Practices Means:
' Training workers 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 workers you need to:
Know lead safety yourself.
Show students what you know.
Review the shopping list in Steps to LEAD SAFE Renovation,
Repair, and Painting and have appropriate materials at hand.
Feb09
8-2
Remember all the skills you mastered during the Skill Set exercises? You
will be teaching non-certified workers to master them.
The shopping list at the end of Steps to LEAD SAFE Renovation, Repair
and Painting details all of the equipment and supplies you may need to
conduct hands-on exercises during on-the-job training of non-certified
renovators.
All that follows is presented to aid you in conduct of the training.
8-2
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 8 Instructor Notes
Feb09
Slide 8-3: The Role of the Certified Renovator
The information on this slide is provided to remind Certified Renovator students
that Certified Renovators are named in the RRP Rule as responsible for teaching
lead safe practices to non-certified renovation workers.
Review the slide and student notes with the class.
8-3
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Lead Safety for Renovation, Repair, and Painting
The Role of the Certified
Renovator
Certified Renovators:
Perform lead safe work as described in the RRP Rule.
Train all non-certified workers 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
renovation workers.
Feb09
8-3
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.
The EPA Renovation, Repair, and Painting Rule is found at 40 CFR 745.85 (a) and (b).
8-3
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 8 Instructor Notes
Feb09
Slide 8-4: Role of Trained, Non-Certified Renovation Workers
Review the slide and student notes with the class.
8-4
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Lead Safety for Renovation, Repair, and Painting
Role of Trained, Non-Certified
Renovation Workers
Trained, non-certified renovation workers 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.
Control dust and debris.
Clean the work area.
Feb09
On-the-job training must be provided for each worker and for each job to the extent that each worker is
adequately trained for the tasks he or she will be performing. This training may occur while the worker
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 worker
trainees 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 personnel be allowed to participate in hands-on learning as work
progresses and that skill sets that are learned by each student are documented. Documentation is
required by the RRP Rule to assure that non-certified workers are trained to perform renovation
activities to which they are assigned. Remember that the RRP Rule requires all non-certified
personnel on the job to be given skills training specific to the tasks that they will perform on the job
and that each person'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.
8-4
Feb09
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Lead Safety for Renovation, Repair, and Painting
Module 8 Instructor Notes
Feb09
Slide 8-5: Steps for Teaching Lead Safety During Renovations
Review the slide and student notes with the class.
8-5
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Lead Safety for Renovation, Repair, and Painting
Steps for Teaching Lead Safety
During Renovations
Approach to training non-certified renovators
Feb09
8-5
Training for non-certified renovation workers 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 8-6 through 8-15 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 renovation workers. 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 renovator trainees refer to the training handout while you teach the
information.
8-5
Feb09
-------
Lead Safety for Renovation, Repair, and Painting
Module 8 Instructor Notes
Feb09
Slide 8-6: Use the "Steps" Guide
Review the slide and student notes with the class.
8-6
-------
Lead Safety for Renovation, Repair, and Painting
Use the "Steps" Guide
Stops to
LEAD SAFt
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.
1
Feb09
Before You Train: Print copies of Steps to LEAD SAFE Renovation, Repair, and Painting and
give one copy to each non-certified renovator trainee.
8-6
Feb09
-------
Lead Safety for Renovation, Repair, and Painting
Module 8 Instructor Notes
Feb09
Slide 8-7: Step 1: Determine If the Job Involves Lead-Based Paint
Review the slide and student notes with the class.
8-7
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Lead Safety for Renovation, Repair, and Painting
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 dust can poison kids, their parents
and pets, and can 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.
Feb09
8-7
During Training:
Review the information on this slide with the non-certified renovator students 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.
3-7
Feb09
-------
Lead Safety for Renovation, Repair, and Painting
Module 8 Instructor Notes
Feb09
Slide 8-8: Step 2: Set It Up Safely
Review the slide and student notes with the class.
8-8
-------
Lead Safety for Renovation, Repair, and Painting
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
Feb09
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 to a minimum of 6 feet from
the area of paint disturbance. 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 owner 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.
8-8
Feb09
-------
Lead Safety for Renovation, Repair, and Painting
Module 8 Instructor Notes
Feb09
Slide 8-9: Step 2: Set It Up Safely - Continued
Review the slide and student notes with the class.
8-9
-------
Lead Safety for Renovation, Repair, and Painting
Step 2: Set It Up Safely-
Continued
Review special setup for "dustier" jobs,
including:
Demolition.
Opening up wall cavities.
Removing old drop ceilings.
Paint scraping/dry hand sanding.
oEPA
Feb09
Some jobs create more dust than can be contained by the methods described on the
previous page. Certified Renovators should exercise their judgment as to whether those
methods provide sufficient containment or if additional precautions are necessary. Jobs that
typically require additional precautions include:
Demolition.
Opening up wall cavities.
Removing old drop ceilings.
Paint scraping/dry hand sanding.
These jobs call for additional steps to contain dust inside the work area. In addition to the
practices reviewed so far, consider the following:
Turning off forced-air heating and air-conditioning systems. This will keep dust from
circulating through the house.
Interior vertical containment to limit the size of the work area.
8-9
Feb09
-------
Lead Safety for Renovation, Repair, and Painting
Module 8 Instructor Notes
Feb09
Lead Safety for Renovation, Repair, and Painting
Module 8 Instructor Notes
6FEB09
Slide 8-10: Step 3: Protect Yourself
Review the slide and student notes with the class.
8-10
-------
Lead Safety for Renovation, Repair, and Painting
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 eyes.
Keep clothes clean or use disposable clothing.
Wear a respirator. The appropriate respirator keeps
lead out of the lungs and stomach.
Wash-up each time they leave the work area and
especially at the end of the day.
Feb09
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 work day, 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.
Post warning signs.
Post a warning sign at each work area entrance.
Signs should read: "Warning, Lead Work Area, Poison, No Smoking or Eating" to remind
workers that eating, drinking and smoking in the work area is prohibited.
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.
8-10
Feb09
-------
Lead Safety for Renovation, Repair, and Painting
Module 8 Instructor Notes
Feb09
Slide 8-11: Step 4: Control the Spread of Dust
Review the slide and student notes with the class.
8-11
-------
Lead Safety for Renovation, Repair, and Painting
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.
Disposable plastic drop cloths control the
spread of dust and debris.
Avoid prohibited practices.
wEPA
Feb09
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, and,
Power tools such as sanders without HEPA attachments.
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 prohibit additional work
practices.
8-11
Feb09
-------
Lead Safety for Renovation, Repair, and Painting
Module 8 Instructor Notes
Feb09
Slide 8-12: Step 5: Leave the Work Area Clean
Review the slide and student notes with the class.
8-12
-------
Lead Safety for Renovation, Repair, and Painting
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
Feb09
8-12
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. Do not clean with standard household or shop vacuum cleaners.
Use only HEPA vacuums.
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 two feet beyond, and on
paths where debris was carried. You should see no dust, paint chips or debris.
Re-clean the area thoroughly if you find dust or debris.
8-12
Feb09
-------
Lead Safety for Renovation, Repair, and Painting
Module 8 Instructor Notes
Feb09
Slide 8-13: Step 6: Control the Waste
Review the slide and student notes with the class.
8-13
-------
Lead Safety for Renovation, Repair, and Painting
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
Feb09
8-13
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 or dumpster 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 through a
0.5 micron filter. 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 residential renovation, repair and painting activities "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. Some states and localities have
more stringent waste disposal requirements that must be followed.
8-13
Feb09
-------
Lead Safety for Renovation, Repair, and Painting
Module 8 Instructor Notes
Feb09
Slide 8-14: Step 7: Cleaning Verification or Clearance Testing
Review the slide and student notes with the class.
8-14
-------
Lead Safety for Renovation, Repair, and Painting
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,
and is required in some cases.
Discuss what happens when cleaning
verification and/or clearance is not passed.
Feb09
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. The first step to both cleaning verification and a clearance examination is a visual
inspection of the work area to determine if dust or debris was left behind. 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. Once the visual inspection by the Certified Renovator is
complete, either the cleaning verification procedure or clearance examination can proceed.
8-14
Feb09
-------
Lead Safety for Renovation, Repair, and Painting
Module 8 Instructor Notes
Feb09
Slide 8-15: Training Documentation
Review the slide and student notes with the class.
8-15
-------
Lead Safety for Renovation, Repair, and Painting
Training Documentation
The Certified Renovator assigned to the job
must maintain at the job site the following
records for on-the-job training :
Written certification of worker training:
Must show which workers have what training;
Must list all training topics covered for each worker; and,
Must be signed by the Certified Renovator who did the
training.
All training documentation must be kept for 3 years following
completion of the renovation.
oEPA
Feb09
8-15
When you give this "toolbox training", use of a training guide, such as Steps to LEAD SAFE
Renovation, Repair and Painting, will make documentation easier. You should keep a copy
of the training guide used at the "toolbox" training you conduct on-site. Make a list of each
lead safe practical skill covered for each individual non-certified worker. A list of the
practical skills taught to each non-certified worker with the material covered in the toolbox
meetings will provide adequate documentation to meet RRP Rule requirements.
8-15
Feb09
-------
Lead Safety for Renovation, Repair, and Painting
Module 8 Instructor Notes
Feb09
Slide 8-16: Now You Know...
Read the information on the slide and close the course.
8-16
-------
Lead Safety for Renovation, Repair, and Painting
Now You Know...
That Certified Renovators are responsible for
training non-certified renovation workers.
The roles of Certified Renovators and trained,
non-certified workers during conduct of a
renovation.
How to use Steps to LEAD SAFE Renovation,
Repair and Painting to train non-certified
renovation workers.
SEPA
Feb09
8-16
8-16
Feb09
-------
-------
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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21758
Federal Register/Vol. 73, No. 78/Tuesday, April 22, 2008/Rules and Regulations
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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Federal Register/Vol. 73, No. 78/Tuesday, April 22, 2008/Rules and Regulations
21759
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.
(1) 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 Feb 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 Feb 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 Feb 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 Feb 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 Feb 09 A2-5
-------
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 Feb 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 Feb 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 Feb 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 Feb 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
-------
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.
-------
- -> -
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.
-------
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/
-------
-------
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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-------
-------
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
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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.
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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
-------
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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Appendix 5:
Steps to LEAD SAFE
Renovation, Repair and Painting
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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.
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&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.
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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.
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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.
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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.
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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.
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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.
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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."
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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.
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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.
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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.
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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
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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.
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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.
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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.
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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.
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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.
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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-
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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
-------
-------
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: Setting up Barriers, Signs, and Flapped Entry Doors
Skill Set #3: Cover or Remove Furniture
Skill Set #4: Establish Interior Containment
Skill Set #5: Establish Exterior Containment
Skill Set #6: Personal Protective Equipment
Skill Set #7: Interior Final Cleaning
Skill Set #8: Exterior Final Cleaning
Skill Set #9: Bagging Waste
Skill Set #10: Visual Inspection
Skill Set #11: 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)
Setup Supplies List
Barrier tape
Broom handle, or dowels, or 1" x 1" x 30" wood or metal stock
Cutting tool (e.g., razor knife, box cutter or scissors)
Disposable tack pad
Doorway to use for work area entry setup
Fencing stakes
Heavy duty plastic sheeting
Magnetic covers
Orange cones
Rope and/or barrier tape (bright color preferable)
Stapler and Staples
Tape (duct, painters, and masking)
Hands-on Exercises Feb 09 A6-1
-------
LEADSAFETY for Remodeling, Repair and Painting
Recommended Supplies for Hands-on Activities - Continued
Setup Supplies List - Continued
Tape measure
Warning signs
Pre-engineered containment systems (Optional for Skill Set 2)
Personal Protective Equipment (PPE) Supplies List
Disposable coveralls
Disposable non-latex gloves
Disposable foot covers
Eye protection
Leather or canvas work gloves
N-100 respirators
Disposable waste bags
Duct tape
Hand washing facilities and hand soap
Cleanup Supplies List
Baby powder or corn starch
Cleaning verification card, one per student to take away and retain
Cutting tool (e.g., razor knife, box cutter or scissors)
Disposable foot covers
Disposable non-latex gloves
Disposable wet cleaning wipes
Electrostatically charged, white, disposable cleaning cloths designed for cleaning hard
surfaces
Flashlight
Garden sprayer
Heavy duty plastic bags
Heavy duty plastic sheeting
HEPA vacuum with attachments and a powered beater bar
Long-handled mop designed for wet cleaning wipes
Tape (duct, painters, and masking)
Tape measure
Two-sided mop bucket with wringer (or equivalent), disposable mop heads, long handled
mop to which disposable cleaning cloths can be attached; or, a wet mopping system.
Watch or clock
Hands-on Exercises Feb 09 A6-2
-------
LEADSAFETY for Remodeling, Repair and Painting
Participant Progress Log
Name of Trainee
Module 3
(15 Min)
Skill Set 1: Using
EPA-Recognized Test
Kits
Module 4
(45 Min)
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Skill Set 3: Cover or
Remove Furniture
Skill Set 4: Establish
Interior Containment
Skill Set 5: Establish
Exterior Containment
Module 5
(10Min)
Skill Set 6: Personal
Protective Equipment
Module 6
(50 Min)
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Skill Set 10: Visual
Inspection
Skill Set 11: Cleaning
Verification Procedure
Date of Training:
Certified Renovator Name:
Hands-on Exercises
Feb09
A6-3
-------
LEADSAFETY for Remodeling, Repair and Painting
Participant Progress Log
Name of Trainee
Module 3
(15 Min)
Skill Set 1: Using
EPA-Recognized Test
Kits
Module 4
(45 Min)
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Skill Set 3: Cover or
Remove Furniture
Skill Set 4: Establish
Interior Containment
Skill Set 5: Establish
Exterior Containment
Module 5
(10Min)
Skill Set 6: Personal
Protective Equipment
Module 6
(50 Min)
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Skill Set 10: Visual
Inspection
Skill Set 11: Cleaning
Verification Procedure
Date of Training:
Certified Renovator Name:
Hands-on Exercises
Feb09
A6-4
-------
LEADSAFETY for Remodeling, Repair and Painting
Certified Renovator Training Hands-On Skills Assessment
Date: Address:
Student Name:
City & State
Student Signature:
Skill
Set
#1
#2
#3
#4
#5
#6
#7
#8
#9
#10
#11
Skill
Description
Using EPA-
Recognized
Test Kits
Setting up
Barriers,
Signs, and
Flapped
Entry Doors
Cover or
Remove
Furniture
Establish
Interior
Containment
Establish
Exterior
Containment
Personal
Protective
Equipment
Interior Final
Cleaning
Exterior Final
Cleaning
Bagging
Waste
Visual
Inspection
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.
Placing critical barriers and posting signs to isolate work area
from access by unauthorized individuals.
Identifying the proper steps in determining when and how to
cover or remove furniture and belongings from the work area.
Using the proper steps to cover floors and close and seal
doors and windows in the work area.
Taking proper steps to restrict entry to the exterior work area
and to protect the ground under and around the work area
from becoming contaminated.
Using dust reduction techniques while performing common
renovation, repair, and painting work activities.
Cleaning the interior work area after the completion of work
and prior to the visual inspection and cleaning verification
procedure or dust clearance examination.
Cleaning the exterior work area after the completion of the
work and prior to visual inspection and (if required) cleaning
verification or dust clearance examination.
Taking steps to bag and gooseneck waste, wrap large pieces
of debris, and to carry them out of the work area.
Conducting a visual inspection of the work area prior to the
cleaning verification procedure.
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 Signature:
Trainer Phone: Organization:
Date:
Hands-on Exercises
Feb09
A6-5
-------
LEADSAFETY for Remodeling, Repair and Painting
Skill Set #1: Using EPA-Recognized Test Kits
Time: 15 minutes
Feb09
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)
EPA 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 Feb 09 A6-6
-------
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 submitted 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 Feb 09 A6-7
-------
LEADSAFETY for Remodeling, Repair and Painting
Test Kit Documentation Form Page 1 of
Owner Information
Name of Owner/Occupant:
Add ress:
City: State: Zip code: Contact #: ( )
Email:
Renovation Information
Fill out all of the following information that is available about the Renovation Site, Firm, and
Certified Renovator.
Renovation Address: Unit#
City: State: Zip code:
Certified Firm Name:
Add ress:
City: State: Zip code: Contact #: ( ) - _
Email:
Certified Renovator Name: 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 Feb 09 A6-8
-------
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 Feb 09 A6-9
-------
LEADSAFETY for Remodeling, Repair and Painting
Skill Set #2: Setting Up Barriers, Signs and Flapped Entry Doors
Time: 10 minutes
Feb09
Supplies needed:
Barrier tape
Warning signs
Doorway to use for work area entry setup
Cutting tool (e.g., razor knife, box cutter or scissors)
Heavy duty plastic sheeting
Tape (duct, painters, and masking)
Stapler and staples
Broom handle, or dowels, or 1" x 1" x 30" wood or metal stock
Optional: Pre-engineered containment systems may also be used for this
exercise.
Note to Instructor: It is strongly suggested that instructors prepare plastic bags
containing all materials needed for the skills practice prior to the exercise in order to
meet the time limits allocated to Skill Set #2.
Purpose: The purpose of this hands-on exercise is to show students the proper steps in
determining where to place critical barriers, and to give them practice in erecting barriers
and posting signs to isolate the work area from access by unauthorized personnel.
Note to Instructor: Read the purpose of this activity to students. Remind them that
these setup steps must be completed before the disturbance of more than 6 ft2 per
room of lead-based paint, or, whenever window replacement or demolition is to be
accomplished.
Demonstration: The course instructor must show and explain all of the steps involved in
establishing a critical barrier and in placement of signage. Critical barriers are plastic
sheeting barriers secured over openings, doors, and windows that must remain in place
until cleaning verification or clearance is achieved in order to keep dust inside of the
work area. While they are not always required, they can assist with controlling the
spread of dust to other areas of the home. Use students to assist in the erection of the
demonstration critical barriers. Note: In the interest of time, use precut barriers for
installation in the doorway. Velcro attached barriers may be used for demonstration and
practice. Velcro sign attachments may also be used.
Evaluating the Students: The instructor should allow students to practice the steps on
the following page while watching each student follow the steps. Make corrections and
suggestions as the exercise proceeds and determine if additional practice is necessary.
Option: Have students say the steps as they work. 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 Skill Set #2
and that particular student's name.
Hands-on Exercises Feb 09 A6-10
-------
LEADSAFETY for Remodeling, Repair and Painting
Skill Set #2: Setting up Barriers, Signs, and Flapped Entry Doors
- Continued
Skills Practice:
Step 1: Ask occupants to leave and remain out of the room where work will be done.
Step 2: Have them stay out until the cleaning verification procedure is complete or
until clearance is passed. Install barrier tape to establish a controlled
perimeter.
Step 3: Post a "Do Not Enter" sign at the doorway to the work area.* Also post a sign
that states that no eating, drinking, or smoking is allowed the doorway to the
work area.*
Step 4: Cover the work area entry doorway with 2 layers of plastic sheeting, by doing
the following:*
Step 5: Cut first plastic sheeting layer slightly wider and longer than (about 3 inches
longer) than the doorframe.*
Step 6: Make a small "S" fold at the top of plastic sheeting and tape so that all layers
are secured to the top of the door frame.* Make a similar "S" fold at the
bottom of the plastic sheeting and tape so that all layers are secured to the
floor.* This will ensure that the plastic sheeting is not tight and allows it to
give instead of tearing when people move through it. Secure both sides of the
plastic sheeting to the door frame with tape.
Step 7: Staple top corners to the door frame for reinforcement*
Step 8: For exiting and entering the room, use duct tape to create a vertical line about
the size of a man from floor to header in the middle of the plastic sheeting on
both sides.* Cut a long vertical slit through the duct tape; leave about 6
inches at the top and the bottom uncut.* Reinforce the top and bottom of the
slit with horizontal duct tape to prevent the plastic sheeting from tearing.*
Step 9: Tape a second layer of plastic sheeting to the top of the door frame.* This
layer is cut slightly shorter than the door frame so that it will hang down flat
against the first sheet of plastic sheeting.
Step 10: Weight the bottom of the second layer of plastic sheeting by taping a dowel
rod to the bottom of the second layer of plastic sheeting with duct tape. This
creates a self-sealing flap over the doorway and seals the opening that was
cut in the plastic sheeting during step 8.
*lndicates required skills that must be accomplished for a "Proficient" rating.
Hands-on Exercises Feb 09 A6-11
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LEADSAFETY for Remodeling, Repair and Painting
Skill Set #3: Cover or Remove Furniture
Time: 10 minutes
FebOQ
Supplies needed:
Heavy duty plastic sheeting
Cutting tool (e.g., razor knife, box cutter or scissors)
Tape (duct, painters, and masking)
Purpose: The purpose of this hands-on exercise is to show students the proper steps
for determining when and how to cover or remove furniture and belongings from a work
area.
Note to Instructor: Read the purpose of this activity to students. Remind them that
these setup steps must be completed before the disturbance of more than 6 ffper
room of lead-based paint, or, whenever window replacement or demolition is to be
accomplished. Also remind them that the best solution to the problem of moving
furniture and belongings is to notify residents to remove them prior to the work.
Remind them also that it is better to remove personal property than to cover it.
Provide students with the opportunity to observe/practice both methods (covering
and removal).
Demonstration: The course instructor should explain all of the steps involved in
covering and/or removing furniture and belongings from the work area. Use students to
demonstrate moving chairs out of the work area. Then cover a table with plastic sheeting
and secure the plastic sheeting with tape so that no part of the table is exposed. Discuss
placing other items under the table for maximized efficiency in preparing the work area.
The demonstration should not take longer than 3 minutes including the time needed to
hand out materials.
Evaluating the Students: The instructor should allow students to practice the steps on
the following page while watching each student follow the steps. Make corrections and
suggestions as the exercise proceeds and determine if additional practice is necessary.
Option: Have students say the steps as they work. 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 Skill Set #3
and that particular student's name.
Hands-on Exercises Feb 09 A6-12
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LEADSAFETY for Remodeling, Repair and Painting
Skill Set #3: Cover or Remove Furniture - Continued
Skills Practice:
Step 1: Move all the furniture out of the work area.
Note: If the training area is small, designate an area against one wall that is
"out of the work area", where furniture removed from the work area can be
placed. In a classroom setting, move the chairs and most of the tables to the
designated area, and cover the tables.
Step 2: Have the students team into groups of 2 to 6 per group. Cover several of the
tables where students were sitting. This is done as follows:
Step 3: Cut a piece of plastic sheeting large enough to cover the table and to overlap
the floor by 3-6 inches.*
Step 4: Secure the plastic sheeting to the table and/or the floor with tape.*
Step 5: If the table will not need to be moved during the work, the plastic sheeting
can be secured to the floor using duct tape or masking tape as is appropriate
to the surface.*
Step 6: If the table will need to be moved during the work, wrap the table with plastic
sheeting including the legs and secure the plastic sheeting to the table with
tape. Take care when applying tape so that there is no damage to the
finished surfaces of the furniture.*
Note: Students should understand that they are to remove or cover all
window treatments, furniture and rugs within 6 feet of surfaces that will be
renovated, repaired or painted. Removal of furniture is recommended
whenever possible.
*lndicates required skills that must be accomplished for a "Proficient" rating.
Hands-on Exercises Feb 09 A6-13
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LEADSAFETY for Remodeling, Repair and Painting
Skill Set #4: Establish Interior Containment
Time: 10 minutes
Feb09
Supplies needed:
Orange cones
Rope and/or barrier tape (bright color preferable)
Warning signs
Tape measure
Tape (duct, painters, and masking)
Heavy duty plastic sheeting
Cutting tool (e.g., razor knife, box cutter or scissors)
Magnetic covers
Disposable tack pad
Purpose: The purpose of this hands-on exercise is to show students the proper steps in
covering floors, and closing and sealing the doors, windows and HVAC in the work area.
Note to Instructor: Read the purpose of this activity to students. Remind them that
these setup steps must be completed before the disturbance of more than 6 ffper
room of lead-based paint, or, whenever window replacement or demolition is to be
accomplished.
Demonstration: The course instructor should explain all of the steps involved in
covering and sealing floors and other horizontal surfaces in the work area, and in closing
and sealing doors and windows between the work area and non-work areas. Use
students to demonstrate closing and taping the windows and doors with masking tape.
Remind them that they are trying to keep dust from escaping the work area.
Evaluating the Students: Allow students to practice the steps for covering the floors,
closing and sealing windows, and closing and sealing doors. Watch each student follow
the steps on the following page. Make corrections and suggestions as the exercise
proceeds and determine if additional practice is necessary. Option: Have students say
the steps as they work. 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 Skill Set #4 and that particular
student's name.
Hands-on Exercises Feb 09 A6-14
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LEADSAFETY for Remodeling, Repair and Painting
Skill Set #4: Establish Interior Containment - Continued
Skills Practice:
Step 1: At each non-entry doorway leading from the work area, place an orange
cone, barrier tape, and a "Do Not Enter" sign.*
Step 2: Close all doors and windows leading to/from the work area.*
Step 3: Tape the seams around each door and window casing with painter's tape,
masking tape, or duct tape.*
Step 4: Cut plastic sheeting so that it covers all exposed surfaces within 6 feet of the
component(s) that are to be affected by the work.*
Step 5: Secure the plastic sheeting to the floor and walls as appropriate with tape.*
Step 6: Use plastic sheeting floor runners to avoid stepping on the carpet or floors
when walking out of the work area. Secure them to the floor with tape.*
Step 7: Close and cover all air and heat diffusers and intakes with magnetic covers,
tape, or plastic sheeting and tape.* Also, if possible, turn off the HVAC
system while working.* HVAC units may be turned on after cleaning
verification or clearance has been achieved.
Step 8: Stage all of the tools, supplies and equipment you will need to conduct the
renovation, repair or painting work on the plastic sheeting in the work area to
avoid contaminating the work area.*
Step 9: Place a disposable tack pad at the corner of the plastic sheeting nearest the
entry door to control tracking dust off of the plastic sheeting.*
*lndicates required skills that must be accomplished for a "Proficient" rating.
Hands-on Exercises Feb 09 A6-15
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LEADSAFETY for Remodeling, Repair and Painting
Skill Set #5: Establish Exterior Containment
Time: 15 minutes
Feb09
Supplies needed:
Orange cones
Rope and/or barrier tape (bright color preferable) and fencing stakes
Warning signs
Heavy duty plastic sheeting
Tape (duct, painters, and masking)
Cutting tool (e.g., razor knife, box cutter or scissors)
Tape measure
Disposable tack pad
Purpose: The purpose of this hands-on exercise is to show students the proper steps
for restricting entry to the exterior work area, and to protect the ground under and around
the work area from becoming contaminated.
Note to Instructor: Read the purpose of this activity to students. Remind them that
these setup steps must be completed before the disturbance of more than 20 ft2 of
paint on components that have been determined to be lead-based paint, or,
whenever window replacement or demolition is to be accomplished.
Demonstration: The course instructor should explain all of the steps involved in
restricting access to and containing dust within the work area. Emphasize to students
that proper setup will restrict access, and will keep dust and debris from escaping the
work area.
Evaluating the Students: Allow students to cover the ground and establish barriers to
prevent unauthorized access to the work area. Watch each student follow the steps on
the following page. Make corrections and suggestions as the exercise proceeds and
determine if additional practice is necessary. Option: Have students say the steps as
they work. 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 Skill Set #5 and that particular student's name.
Hands-on Exercises Feb 09 A6-16
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LEADSAFETY for Remodeling, Repair and Painting
Skill Set #5: Establish Exterior Containment - Continued
Skills Practice:
Step 1: At each non-entry doorway leading into the work area, place an orange cone,
barrier tape, and a "Do Not Enter"sign.*
Step 2: Close all doors and windows within 20 feet of the work area.*
Step 3: Place plastic sheeting as ground cover a minimum of 10 feet in all directions
from the actual location of a paint disturbance.*
Step 4: Weigh down the edges of the plastic sheeting with 2x4s or bricks or stake
down the edges of the plastic sheeting.*
Step 5: Secure the plastic sheeting to the floor and walls with tape or furring strips
and tacks.*
Step 6: Place barrier fencing or a rope around the perimeter of the work area 20 feet
from the work area and on all exposed sides.*
Step 7: Establish an entry point to the work area and place a "Do Not Enter, No Food
or Drinks or Smoking Allowed"sign.*.
Step 8: Curb the edges of the plastic sheeting to prevent dust from blowing off.*
Curbs can be made by running a low rope near the ground and draping the
plastic sheeting over the top of the rope. The rope should be only a few
inches above the ground. A staked 2x4 may also be used to raise the edges
of the plastic sheeting instead of the rope method.
Step 9: Stage all of the tools, supplies, and equipment you will need to conduct the
renovation, repair, or painting work on the plastic sheeting in the work area to
avoid contaminating the work area.*
Step 10: Place a disposable tack pad at the corner of the plastic sheeting nearest the
entry door to control tracking dust off of the plastic sheeting.*
*lndicates required skills that must be accomplished for a "Proficient" rating.
Hands-on Exercises Feb 09 A6-17
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LEADSAFETY for Remodeling, Repair and Painting
Skill Set #6: Personal Protective Equipment
Time: 10 minutes
Feb09
Supplies needed:
Disposable coveralls
Disposable non-latex gloves
Disposable foot covers
Eye protection
Leather or canvas work gloves
N-100 respirators
Disposable waste bags
Duct tape
Hand washing facilities and hand soap
Purpose: The purpose of this hands-on exercise is to show students the proper steps
for putting on (donning) and taking off (doffing) personal protective equipment, and the
steps for decontaminating and disposing of used equipment.
Note to Instructor: Read the purpose of this activity to students.
Demonstration: The course instructor should explain all of the steps involved in putting
on personal protective equipment while actually dressing a volunteer student in personal
protective equipment. Emphasize to students that this equipment prevents their
exposure to lead as well as prevents the contamination of areas outside of the work
area.
Evaluating the Students: Watch each student as they follow the steps on the next
page. Make corrections and suggestions as the exercise proceeds and determine if
additional practice is necessary. Option: Have students say the steps as they work.
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 #6 and that particular student's name.
Hands-on Exercises Feb 09 A6-18
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LEADSAFETY for Remodeling, Repair and Painting
Skill Set #6: Personal Protective Equipment - Continued
Skills Practice:
Step 1: Put on (don) a set of protective coveralls.*
Step 2: Put on disposable gloves.*
Step 3: Put on boot covers over shoes.*
Step 4: Put on safety glasses.*
Step 5: Put on work gloves.*
Step 6: When dressed in this Personal Protective Equipment, discuss the use of
respirators and show the proper method for putting on and securing the
respirator in place.
Note: Students should not wear a respirator if they are not currently enrolled
in the training firm's respiratory protection program. Watch the demonstration
but do not try on a respirator if this note applies you.
Step 7: Remove the work gloves and place them in a marked waste bag.*
Step 8: Remove the boot covers by pulling them off from the heel and rolling the
cover inside out as it is rolled toward the toes. Once removed, place them in
a marked waste bag.*
Step 9: Remove your suit by unzipping it and rolling it dirty side in to prevent
releasing dust. Once removed, place the suit in a marked waste bag.*
Step 10: Remove your disposable non-latex gloves by grasping the cuff of one glove
and peeling the glove inside out off of the hand. Hold the glove that was
removed in the palm of the gloved hand. Place one finger under the cuff of
the gloved hand and remove this glove by peeling it off of the gloved hand
inside out and over the balled up glove you had already removed. Once
removed, you should have one glove inside the other, with the dirty side
contained. Dispose of the gloves in the marked waste bag.*
Step 11: Wash your hands, face and shoes with soap and water. Dry your hands and
face with a disposable towel.*
*lndicates required skills that must be accomplished for a "Proficient" rating.
Hands-on Exercises Feb 09 A6-19
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LEADSAFETY for Remodeling, Repair and Painting
Skill Set #7: Interior Final Cleaning
Time: 10 minutes
Feb09
Supplies needed:
Heavy duty plastic sheeting
Duct tape
HEPA vacuum with attachments and a powered beater bar
Garden sprayer
Cutting tool (e.g., razor knife, box cutter or scissors)
Disposable wet cleaning wipes
Heavy duty plastic bags
Two-sided mop bucket with wringer (or equivalent), disposable mop heads, long
handled mop to which disposable cleaning cloths can be attached; or, a wet
mopping system.
Purpose: The purpose of this hands-on exercise is to show students the proper steps
for cleaning the interior work area after the completion of the work and prior to the visual
inspection and cleaning verification procedure, or a clearance examination.
Note to Instructor: Read the purpose of this activity to students. Remind them that
they are trying to completely clean all visible dust and debris in the work area, and
that their work will be checked. Remind them that this level of cleanliness is
achievable, but does require attention and careful execution.
The course instructor should explain all of the steps involved in cleaning the work
area. Emphasize to students that there are no short cuts to passing the visual
inspection.
Recommended personal protective equipment during final cleaning activities is a
set of disposable coveralls, disposable gloves, and shoe covers.
If plastic sheeting is not already in place from previous exercises, have plastic
sheeting for the floor or carpets put down.
Evaluating the Students: Watch each student follow the steps on the following page.
Make corrections and suggestions as the exercise proceeds and determine if additional
practice is necessary. 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 #7 and that particular
student's name.
Hands-on Exercises Feb 09 A6-20
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LEADSAFETY for Remodeling, Repair and Painting
Skill Set #7: Interior Final Cleaning - Continued
Skills Practice:
Step 1: Wrap and seal, or bag all components and other large materials and then
remove them from the work area.*
Step 2: Clean off the plastic sheeting using a HEPA vacuum (this procedure is not
required, but it is faster than wiping up dust and debris by hand). Mist the
plastic sheeting and fold dirty side inward. Either seal the edges of the folded
plastic sheeting with tape or place it in a heavy-duty plastic bag. Dispose of
the protective sheeting.*
Step 3: Remove all waste from the work area and place in appropriate waste
containers.*
Step 4: Clean all surfaces within the work area and in the area 2 feet beyond the
work area until no dust or debris remains. Start cleaning at the top of the
walls and work down toward the floor, HEPA vacuum or wet wipe all wall
surfaces in the work area. HEPA vacuum all remaining surfaces in the work
area, including furniture and fixtures. Use the upholstery attachment for the
window surfaces and the crevice tool along the edge of the walls. Use the
HEPA vacuum with a beater bar for carpeting. Work from the end farthest
from the work area entrance back to the entrance, making sure never to step
back into areas that have already been cleaned.*
Step 5: Next, wipe all remaining surfaces and objects in the work area except for
carpeted and upholstered surfaces, with a disposable wet cleaning wipes.
Also mop uncarpeted floors using a two-bucket method or wet mopping
system. Work from the end farthest from the work area entrance back to the
entrance, making sure never to step back into areas that have already been
cleaned. For carpeted areas, conduct a second pass with the HEPA vacuum
using the beater bar attachment instead of wiping with a wet cleaning cloth.*
Step 6: If the property is HUD-regulated, repeat Step 4 for walls, countertops and
floors, and then continue to Step 7. Otherwise, continue to Step 7.
Step 7: After completion of cleaning procedures, check your work. Conduct a careful
visual inspection of the work area for visible dust and debris. If visible dust or
debris is found, repeat Steps 4 and 5 as needed to make sure no visible dust
or debris is present, and then re-check your work with a thorough visual
inspection of the work area. When there is no visible dust or debris present,
proceed to step 8.*
Step 8: Notify the Certified Renovator in charge of the project that the work area is
ready for visual inspection.*
*lndicates required skills that must be accomplished for a "Proficient" rating.
Hands-on Exercises Feb 09 A6-21
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LEADSAFETY for Remodeling, Repair and Painting
Skill Set #8: Exterior Final Cleaning
Time: 10 minutes
Feb09
Supplies needed:
Heavy duty plastic sheeting
Heavy duty plastic bags
Tape (duct, painters, and masking)
Cutting tool (e.g., razor knife, box cutter or scissors)
Flashlight.
Disposable wet cleaning wipes
HEPA vacuum with attachments
Two-sided mop bucket with wringer (or equivalent), disposable mop heads, long
handled mop to which disposable cleaning cloths can be attached, or, a wet
mopping system.
Purpose: The purpose of this hands-on exercise is to show students the proper steps
for cleaning an exterior work area after the completion of the work and prior to the visual
inspection and (if required) the cleaning verification procedure or a clearance
examination.
Note to Instructor: Read the purpose of this activity to students. Remind them that
they are trying to clean all visible dust and debris within the work area, and that their
work will be checked. Remind them that this level of cleanliness is achievable, but
does require attention and careful execution.
The course instructor should explain all of the steps involved in cleaning the work
area. Emphasize to students that there are no short cuts to passing the visual
inspection.
Recommended personal protective equipment during cleaning activities is a set
of disposable coveralls, disposable gloves, and shoe covers.
If plastic sheeting is not already in place from previous exercises, have plastic
sheeting for the floor or carpets put down.
Evaluating the Students: Watch each student follow the steps on the following page.
Make corrections and suggestions as the exercise proceeds and determine if additional
practice is necessary. Option: Have students say the steps as they work. 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 #8 and that particular student's name.
Hands-on Exercises Feb 09 A6-22
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LEADSAFETY for Remodeling, Repair and Painting
Skill Set #8: Exterior Final Cleaning - Continued
Skills Practice:
Step 1: Wrap and seal, or bag all components and other large materials and then
remove them from the work area.*
Step 2: Clean off the plastic sheeting using a HEPA vacuum (this procedure is not
required, but it sure is faster than wiping up dust and debris by hand). Mist
the plastic sheeting and fold dirty side inward. Either seal the edges of the
plastic sheeting with tape or place it in a heavy-duty plastic bag. Dispose of
plastic sheeting.*
Step 3: Remove all waste from the work area and place in appropriate waste
containers.*
Step 4: Clean all surfaces in the work area and areas within 2 feet beyond the work
area until no visible dust, debris, or paint chips remain.*
Suggested Cleaning Procedure For Exterior Cleanable Surfaces: Start
cleaning at the top of the walls and work down to the floor, HEPA vacuum or
wet wipe all cleanable surfaces in the work area, including furniture and
fixtures. Use the HEPA vacuum with the upholstery attachment for windows
and use the crevice tool along the walls. Work from the end farthest from the
work area entrance back to the entrance, making sure never to step back into
areas that have already been cleaned.
Step 5: After completion of cleaning, check your work. This is done by conducting a
careful visual inspection of the work area for visible dust, debris, or paint
chips on hard surfaces, and for visible dust, debris, or paint chips in the soil
areas under the work area protective sheeting. If dust or debris is found, re-
clean, and then re-check your work with a thorough visual inspection of the
work area. Once there is no visible dust, debris, or paint chips present,
proceed to step 6.*
Step 6: Notify the Certified Renovator in charge of the project that the work area is
ready for visual inspection.*
*lndicates required skills that must be accomplished for a "Proficient" rating.
Hands-on Exercises Feb 09 A6-23
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LEADSAFETY for Remodeling, Repair and Painting
Skill Set #9: Bagging Waste
Time: 10 minutes
Feb09
Supplies needed:
Used plastic sheeting and used personal protective equipment (from previous
exercises)
Dust and debris (from previous exercises)
Heavy duty plastic sheeting
Heavy duty plastic bags
Cutting tool (e.g., razor knife, box cutter or scissors)
HEPA vacuum with attachments
Duct tape
Purpose: The purpose of this hands-on exercise is to show the students the proper
steps to bag and gooseneck waste, wrap large pieces of debris, and remove waste from
the work area.
Note to Instructor: Read the purpose of this activity to students.
Demonstration: The course instructor should demonstrate the proper
gooseneck technique for sealing waste bags.
Optional Bagging Relay Race: This exercise can be conducted as a relay race.
Divide students into teams and have each team member select a waste bag,
load it with simulated waste material, make a gooseneck in the waste bag,
vacuum the bag and submit it as complete in the simulated waste storage area.
This will allow the instructors to observe proficiency in the method of closing the
bags and making goosenecks and provides a fun way to learn for the students.
Evaluating the Students: Watch each student make a gooseneck closure on a waste
bag. Students must complete all required Steps to be "Proficient". 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 #9
and that particular student's name.
Hands-on Exercises Feb 09 A6-24
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LEADSAFETY for Remodeling, Repair and Painting
Skill Set #9: Bagging Waste - Continued
Skills Practice:
Note: This exercise requires that the waste materials generated throughout the
exercises be stored in unsealed bags or in sheets of plastic.
Gooseneck Procedure for Waste Bags:
Step 1: Each student should get a waste bag and place some material in it that will
be discarded as simulate waste. Do not overfill bags.
Step 2: Gather the open end of the bag just below the opening into one hand.*
Step 3: Twist the bag so that the neck of the bag twists in the same direction and
forms an 8"-10" column.*
Step 4: Fold the twisted column over on itself, in a similar manner to how you would
fold a hose over onto itself to cut off the flow of water.*
Step 5: Grasp the folded neck of the bag in one hand and wrap tape around the
folded neck to secure the fold in place.*
Step 6: Now wrap the tape about 2 or 3 inches from the top of the fold, several times
so that the bag cannot come open. The resulting bags neck looks like the
neck of a goose folded back on itself (a goose neck seal).*
Step 7: Use the HEPA vacuum to remove any dust from the exterior of the bags.
Carry the bags out of the work area to the appropriate waste container.*
Wrapping large pieces of debris:
Step 1: Cut a piece of plastic so that it can be wrapped around the debris to be
disposed of.*
Step 2: Once wrapped in plastic, tape the seams of the package.*
Step 3: Wrap tape around the width of the package in three spots to keep the
package from unraveling.*
Step 4: Use the HEPA vacuum to remove any dust from the exterior of the package
and carry the wrapped debris out of the work area to the appropriate waste
container.*
*lndicates required skills that must be accomplished for a "Proficient" rating.
Hands-on Exercises Feb 09 A6-25
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LEADSAFETY for Remodeling, Repair and Painting
Skill Set #10: Visual Inspection
Time: 5 minutes
Feb09
Supplies needed:
Disposable foot covers
Flashlight
Purpose: The purpose of this hands-on exercise is to show the students the proper
steps for conducting a visual inspection of the work area prior to conduct of the cleaning
verification procedure.
Note to Instructor: Read the purpose of this activity to students. Remind them that
they are trying to verify that all visible dust and debris has been cleaned from the
work area. Remind them that this level of cleanliness is achievable, but does require
attention and careful execution. Also read the note to the students below.
Note to Students: If a clearance examination is to be performed, the Certified
Renovator should still conduct a visual inspection before submitting to the two-part
clearance examination. A clearance examination consists of a separate visual
inspection and dust wipe testing. The two-part clearance examination is conducted
by a Certified Lead Inspector, Certified Lead Risk Assessor, or Certified Sampling
Technician.
Demonstration: The course instructor should explain all of the steps involved in
performing a visual clearance in the work area. Emphasize to students that there are no
short cuts to passing the visual inspection.
Evaluating the Students: Watch each student conduct a visual inspection 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 #10 and that
particular student's name.
Hands-on Exercises Feb 09 A6-26
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LEADSAFETY for Remodeling, Repair and Painting
Skill Set #10: Visual Inspection - Continued
Skills Practice:
Step 1: Put on disposable foot covers so that you do not track dust and debris into
the work area, then enter the work area.*
Step 2: Turn on all of the lights that are available in the work area. Bring a bright,
white-light flashlight to make sure there is adequate lighting.*
Step 3: Systematically look at every horizontal surface in the work area, working from
the farthest area from the entry to the entry without recovering your tracks.
Get close to the surfaces you are inspecting.*
Note: Remember this is a visual inspection, but the cleaning verification is
going to wipe dust up to compare with the cleaning verification card. If you
suspect a surface to be dirty, have it re-cleaned with a wet cleaning cloth.
Step 4: If you find visible dust or debris, re-clean the work area and repeat step 3.*
Step 5: Once you have carefully inspected all of the surfaces and have found no dust
or debris, proceed to the cleaning verification procedure in Skill Set #11 .*
*lndicates required skills that must be accomplished for a "Proficient" rating.
Hands-on Exercises Feb 09 A6-27
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LEADSAFETY for Remodeling, Repair and Painting
Skill Set #11: Cleaning Verification Procedure
Time: 15 minutes
Feb09
Supplies needed:
Baby powder or corn starch
Disposable foot covers
Flashlight
Disposable non-latex gloves
Disposable wet cleaning wipes
Cleaning verification card, one per student to take away and retain
Electrostatically charged, white, disposable cleaning cloths designed for cleaning
hard surfaces
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 Feb 09 A6-28
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LEADSAFETY for Remodeling, Repair and Painting
Skill Set #11: 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 window sill 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 window
sill 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 window sill 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 window sill 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 Feb 09 A6-29
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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.*
*lndicates required skills that must be accomplished for a "Proficient" rating
Hands-on Exercises Feb 09 A6-30
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Appendix 7:
State and Local Regulations
(Note: This Appendix is intentionally blank to allow training providers to add applicable
state and local regulations.)
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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.
Feb 09 A7-1
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Appendix 8:
Regulatory Status of Waste
Generated by Contractors and
Residents from Lead-Based Paint
Activities Conducted in Housing
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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.
A8-1
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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.
A8-2
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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.
A8-3
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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
A8-4
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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)
A8-5
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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?
v' 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
fora 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?
v' 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.qov/offices/lead or by email to lead.requlations(S)hud.qov.
Feb 09 A9-1
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