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October 2011 8ซ/oEซtv
Model Certified Lead Dust Sampling
    Technician Training Course
       INSTRUCTOR MANUAL
                             EPA-740-R-09-006

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                                                                         Instructor Overview
                                This Course Curriculum

The U.S. Environmental Protection Agency (US EPA) and Office of Housing and Urban
Development (HUD) have produced this course to teach individuals how to conduct non-
abatement lead dust clearance testing. This course is designed to be taught over an 8-hour time
period with 2 hours devoted to hands-on training. For certification purposes, the course can be
taught by either an EPA-accredited training provider, or a training provider accredited by an
authorized State, Tribe, or Territory.

Objectives for the Course
At the end of the course, students will be able to:

   •   Understand the Federal, State, and Indian Tribe regulatory requirements for lead dust
       clearance testing;

   •   Conduct a visual inspection and correctly identify visible dust, debris, and deteriorated
       paint;

   •   Appropriately determine where to take dust samples and how to develop a sampling
       strategy.

   •   Collect dust samples in accordance with standard acceptable procedures;

   •   Interpret the results of a laboratory analysis for lead in dust correctly;

   •   Apply these skills to conduct an appropriate lead dust clearance test in post-renovation
       and other circumstances;

   •   Write a complete, accurate, and understandable report of sampling results.

Audience for the Course
Organizations that will be interested in this course include:

   •   State and local public agencies that administer Federal funds for housing;

   •   Non-profit and community housing organizations, particularly those that assist public
       agencies in administering Federal housing funds;

   •   State and local health departments;

   •   Home inspection firms; and

   •   Lead and other environmental services firms.
Appropriate staff to take this course will include:

   •   Housing quality standards (HQS) inspectors;

   •   Rehabilitation specialists;

   •   Home inspectors; and

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                                                                        Instructor Overview
   •   Other staff who are involved in evaluating buildings.

              Overview of Lead Dust Sampling Technician Training Curriculum
This training course consists of three parts in the six chapters including:

Part 1: Introduction

   •   Chapter 1: Introduction provides an overview of the course, the role of a lead dust
       sampling technician, and the relevance of the EPA Renovation, Repair, and Painting
       (RRP) Rule and HUD's Lead Safe Housing Rule (LSHR).

Part 2: Skills

   •   Chapter 2: Visual Inspection explains how to perform a visual inspection for paint
       chips, dust and debris and, in some circumstances, deteriorated paint.

   •   Chapter 3: Lead Dust Wipe Sampling describes how to prepare for and collect dust
       wipe samples.

   •   Chapter 4: Selecting a Laboratory and Interpreting Results describes how to select a
       recognized lab, how to submit samples, and how to interpret the results.

Part 3: Application

   •   Chapter 5: Writing the Report covers how to prepare the report.

   •   Chapter 6: Putting the Skills Together gives the students an opportunity to put their
       new skills  to the test in a series of desktop and hands on exercises that cover the issues of
       sample location selection, dust wipe sampling, interpreting laboratory results and writing
       a dust lead clearance report
Course Materials

Course materials include slides, an instructor manual, a student manual, and a. Lead Dust
Sampling Technician Field Guide.

   •   Slides. Each chapter in this course has slides that highlight key points to be made during
       the presentation. The slides also include pictures, diagrams, and other visual aids.

   •   Instructor Manual. The instructor manual includes copies of the slides and explanatory
       text. At the front of each chapter, there are brief instructor notes that describe the chapter
       objectives, the activities, and additional information if necessary. The back of each
       chapter includes attachments such as sample documents, exercises, etc.  Finally, in the
       back of the manual there are 3 appendices that contain useful resources  for both
       instructors and students.

   •   Student Manual. The student manual includes everything in the instructor manual
       except this instructor overview and the instructor notes that appear at the front of every
       chapter in the instructor manual.

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                                                                         Instructor Overview
   •   Lead Dust Sampling Technician Field Guide. The Lead Dust Sampling Technician
       Field Guide provides protocols for conducting post-renovation clearance under EPA's
       RRP Rule and clearance examinations under HUD's LSHR in housing and child-
       occupied facilities built before  1978. This guide also provides Federal standards for lead
       in dust.  Refer students to the Lead Dust Sampling Technician Field Guide as appropriate.

   •   In presenting the course, instructors are encouraged to use the student materials in the
       following ways:

          - Recommend to the students that they follow along with the slides as they are
             presented and to take notes;

          - Refer students to the attachments and appendices and encourage them to mark
             pages with specific information, summaries, checklists, tables, or tools they can
             use; and

          - Refer students to the Lead Dust Sampling Technician Field Guide as appropriate.

Instructional Information
Instructor responsibilities. The success of each training session depends upon good preparation
and effective delivery of course materials. While this manual provides specific guidance about
presenting this course, instructors will  need to use their professional expertise and training
experience in preparing their lessons and adapting their deliveries to address the needs of
students in each session. The key responsibilities of each instructor are to:

   •   Understand the course material, the relevant EPA and HUD regulations and documented
       methodologies including Chapter - 15 of the HUD Guidelines for the Identification and
       Control  of Lead-based Paint Hazards in Housing.

   •   Prepare  for each lesson based on the guidance  and instructions in the instructor manual;

   •   Deliver  lessons and accomplish objectives within each chapter;

   •   Make sure that questions from  students are answered, or refer them to an appropriate
       resource; and

   •   Reinforce course objectives throughout the training session.
Instructional methods. This course is primarily discussion-based;  however, it is designed to be
interactive. Several of the chapters include exercises and activities.  Throughout the presentation,
instructors are encouraged to be conversational in tone and solicit student input. The instructor
notes highlight  some of the appropriate times to prompt students for input. Instructors may
modify lesson activities, as long as the learning objectives for the chapter are accomplished, the
key points are effectively covered, and the hands-on time is not reduced to less than 2 hours.
Preparing for a training session. Prior to each course delivery, instructors are responsible for
making the following preparations:

   •   Planning the delivery of their lessons;
                                                                                       in

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                                                                      Instructor Overview
•  Reviewing the participant registration forms to familiarize themselves with the students,
   their agencies/firms/organizations and positions, and any special issues they have
   identified;
•  Ensuring that the training room is properly set up; and
•  Confirming that all the necessary training supplies, materials, and equipment are
   available at the training site.
•  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 Lead Dust Sampling Technician. 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.
                              Instructor's Checklist

                       Supplies of Materials for the Course
Instructor manual - including notes and attachments
Student manuals - including copies of instructor slides and attachments
Lead Dust Sampling Technician Field Guide
Slides
Lead dust sampling materials
-  Disposable lead dust wipes (individually wrapped)
-  Disposable gloves
-  Disposable shoe covers
-  Sample tubes with caps
-  Reusable or disposable templates (can be made or purchased)*
-  Masking or painter's tape
-  Ruler (measurements must begin at ruler's edge)
-  Sample collection forms
-  Chain-of-custody forms
-  Markers, trash bags, labels, pens, re-sealable storage bags
-  Calculator
-  Sanitary wipes
Flipchart and/or blank transparencies for recording additional information
                                                                                    iv

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                                                                         Instructor Overview
*Instructors should provide samples of floor templates to the students during the course.

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.  In addition, knowing the layout of the training
   room in advance would be helpful in determining whether or not windowsills or troughs can
   be sampled during the training.  If the room does not have a window, then make certain there
   is a suitable prop resembling a windowsill or trough, like box tops, for example.

•  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 such as dirty templates, tubes, or gloves.

•  The use of actual lead-based paint for training purposes is not allowed. Participants are in
   your class to  learn the skills to be a successful lead dust sampling technician.  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 chapters 3, 4 and 6 list specific tasks that each participant must perform correctly

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                                                                       Instructor Overview
during that activity. Record achievement of these skills in a Participant Progress Log. See
page vii of this Instructor Overview for an example Participant Progress Log.
                                                                                     VI

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Instructor Overview
Sample Agenda
Registration and Introduction
(Includes Taking Pictures of Students)
Chapter 1: Introduction
Chapter 2: Visual Inspection
Break
Chapter 3: Lead Dust Wipe
Sampling
Lunch
Chapter 4: Selecting a Laboratory
and Interpreting Results
Chapter 5: Writing the Report
Break
Chapter 6: Putting the Skills
Together
Review
Test
15 -minute
lecture/discussion
30-minute lecture
45-minute lecture
15 minutes
60-minute lecture
60-minute hands-
on activity
1 hour
45-minute lecture
25-minute lecture
15 minutes
45-minute lecture
75- minute hands-
on activity
15 minutes
30 minutes

The objective of this chapter is
simply to introduce students to
the course and cover basic
information.
The major objective of this
chapter is to teach students to
perform visual inspections.

The major objective of this
chapter is to teach students how
to take a lead dust wipe sample.

The major objective of this
chapter is to teach students to
understand the role of the
laboratory and what to look for
when they select a laboratory.
This chapter will teach students
how to complete and deliver
reports of their lead dust
clearance tests.

This chapter is designed to help
students apply all of the
information they have been
given in a hands-on activity.
Take this time to review any
last minute questions before the
test.

                Vll

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                                          Instructor Overview
Sample - Participant Progress Log - Sample
            Hands-on Activities
Name of
Trainee








Chapter 3
Activity:
Let's Try It








Chapter 4
Activity:
Interpreting
Laboratory
Results








Chapter 6
Activity 1 :
Where To
Take
Samples








Chapter 6
Activity 2:
Dust Wipe
Sampling








Chapter 6
Activity 3:
Interpreting
the Results








Chapter 6
Activity 4:
Translating
Results into
a Written
Report








                                                  Vlll

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Chapter 1: Introduction

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INSTRUCTOR
NOTES
                            CHAPTER 1: INTRODUCTION
Objectives:
The objective of this chapter is to introduce students to the course
and cover basic information. At the end of this chapter students
will know:
   •   Course objectives
   •   Basic information on lead and lead in dust and debris
   •   The role of a lead dust sampling technician
   •   How this course relates to the lead-based paint inspector
       and risk assessor courses
   •   The EPA RRP Rule's requirements related to clearance
       sampling and cleaning verification
   •   HUD clearance requirements for non-abatement j obs
Introduction to this
chapter:
This is the first chapter of the course. It outlines the course
objectives, provides basic information about the class, and
provides an overview of the lead-dust sampling technician's role
and responsibilities.
Activities:
Introductions: On Slide 1-3, ask students to identify themselves
and the organization they work with and tell how their work
involves lead-based paint.
Review:
This chapter has no review.
Notes:
This chapter simply sets the stage for the rest of the course.  The
requirements for the HUD and EPA rule's can be complicated and
may require extra time.
Be sure to point out Attachment 1-A: Comparing Lead
Evaluation Professionals, which describes the differences in
capacity and responsibility of lead dust sampling technicians,
lead-based paint inspectors, and risk assessors.
Lead Dust Sampling Technician
                                                   Chapter 1

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Model Certified Lead Dust Sampling Technician Training Course
                                             1
Welcome to the Lead Dust Sampling Technician Training Course.
1-1                                 October 2011

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Model Certified Lead Dust Sampling Technician Training Course

                       Understand what a lead-dust clearance test is.
                       Identify steps in lead-dust clearance testing.
                       Learn how to:
                        •  Conduct a visual inspection
                        •  Collect lead dust samples
                        •  Interpret results
                        •  Write a report
                        •  Explain the results to the client
The EPA has provided this model curriculum to teach individuals how to conduct lead dust clearance
testing after renovation activities.
Lead dust clearance testing is often performed to find out whether lead dust remains after renovation,
repair, or painting. It is required by HDD's LSHR regulations for most renovations.  By the  end of the
course, students will be able to perform the actions listed above.
1-2                                   October 2011

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Model Certified Lead Dust Sampling Technician Training Course
                                                     1-3
               •  Name
               •  Occupation/organization
               •  How does your work involve lead-
                 based paint?
1-3                          October 2011

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Model Certified Lead Dust Sampling Technician Training Course
                                                                   1-4
                                of
                     Student Manual
                     Attachments
                     Appendices
                     Lead Dust Sampling  Technician
                     Field Guide
The student materials include a student manual, attachments, appendices, and a copy of the Lead Dust
Sampling Technician Field Guide.
  •    The student manual contains copies of the slides that are used by the instructor during the
      course.
  •    The attachments and appendices provide important summaries, checklists, tables, and tools you
      can use.
  •    The Lead Dust Sampling Technician Field Guide outlines key points and procedures in one easy-
      to-read reference tool that can be taken along on the job.
1-4                                 October 2011

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Model Certified Lead Dust Sampling Technician Training Course
                                                                        1-5
                                        of

                    •  In children:
                       - Damage to 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.
                    •  In pregnant women:
                       - Damage to the fetus
Children under 6 are most at risk from small amounts of lead.
Children are at a greater risk than adults. During normal and frequent playing or hand-to-mouth activity,
children may swallow or inhale lead dust from their hands, toys, food, or other objects.
In children, lead may cause:
       •  Nervous system and kidney damage
       •  Decreased intelligence, attention deficit disorder, and learning disabilities
       •  Speech, language, and behavioral 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:
       •  Miscarriage
       •  Premature birth
       •  Brain damage
       •  Low birth weight
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Model Certified Lead Dust Sampling Technician Training Course
                                                               1-6
                                  of         -
                  •  In workers:
                    -Elevated blood pressure
                    - Loss of sex drive and/or capability
                    -Physical fatigue
Health effects of lead in adults include:
      • Elevated blood pressure
      • Reproductive problems in men and women
      • Digestive problems
      • Nerve disorders
      • Memory and concentration problems
      • Sexual disorders
      • Muscle or joint pain
1-6                               October 2011

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Model Certified Lead Dust Sampling Technician Training Course
                                                                a


                     •  Renovations that disturb lead-based
                        paint create dust and debris.
                     •  Very small amounts of lead dust can
                        poison children.
                     •  Adults can swallow or breathe lead
                        dust during work activities.
                     •  Workers can bring lead dust home and
                        poison their families.
                                                                        1-7
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.
Common renovation activities like sanding, scraping, cutting, and demolition can create hazardous lead
dust and chips by disturbing lead-based paint.
Some tasks, such as power sanding, open flame burning, and the use of heat guns above 1100 degrees
Fahrenheit, create large amounts of extremely fine lead dust that is very difficult to clean up.
Small amounts of lead dust can poison children and adults.
A tiny amount of lead can be extremely harmful.
Lead dust particles are often so small that you cannot see them, yet you can breathe or swallow them.
These smaller, inhaled or swallowed lead dust particles are more easily absorbed by the body than larger
particles, and can therefore more easily cause poisoning.
Lead dust may be breathed or swallowed by children, residents, and workers.
Through normal hand-to-mouth activities, children may swallow or inhale lead dust on their hands, toys,
food, or other objects. Children may also ingest paint chips.
Adults can swallow or breathe lead 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 lead dust present.
1-7                                   October 2011

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Model Certified Lead Dust Sampling Technician Training Course
                                                                "
                          in

               To address the issue of lead hazards in housing, EPA
               and HUD have issued several regulations.
               EPA currently oversees the training and certification of
               abatement contractors, inspectors, and risk assessors.
               HUD's Lead Safe Housing Rule (LSHR) addresses lead
               hazards in  Federally owned and assisted housing.
               In April 2008, EPA issued the Renovation Repair and
               Painting (RRP) Rule to address lead hazards created
               during renovation.
1-8                               October 2011

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Model Certified Lead Dust Sampling Technician Training Course



                                    of the


                    • Lead Dust Sampling Technician
                    • Lead-Based Paint Inspector
                    • Risk Assessor
                       - All three disciplines can  conduct
                         dust clearance testing  after an
                         RRP project
1-9
There are three courses for professionals who wish to be certified to conduct evaluations for lead dust,
lead hazards and/or lead-based paint:
  •   Lead Dust Sampling Technician: This 8-hour training course teaches you how to become a lead
     dust sampling technician. You will learn how to conduct a visual inspection, collect dust wipe
     samples, interpret results, and write a lead dust clearance test report.
  •   Lead-Based Paint Inspector: To become a certified lead-based paint inspector, you must take a
     24-hour training course. In the lead-based paint inspector course, you will learn the skills and
     protocols for conducting a paint inspection. A lead-based paint inspection is a surface-by-surface
     investigation to locate all lead-based paint on a property. We will talk more about what a paint
     inspection is in the next chapter.
  •   Risk Assessor: To become a certified risk assessor, you must successfully complete a lead-based
     paint inspector course plus an additional 16-hour risk assessor course.  In the  risk assessor course,
     you will learn the skills and protocols necessary for conducting risk assessments. A risk
     assessment is an on-site investigation to identify all lead-based paint hazards on a property.

Today you are taking the LOST Training Course.

Refer to Attachment 1-A: Comparing Lead Evaluation Professionals for additional information.
1-9                                   October 2011

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Model Certified Lead Dust Sampling Technician Training Course
            • EPA's RRP rule also established the lead dust
              sampling technician discipline.
            • To work as a dust sampling technician, an
              individual must successfully complete this
              training course. The course completion
              certificate will serve as your certification.
            • Dust sampling technicians are used in both
              EPA's and HUD's regulations.
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Model Certified Lead Dust Sampling Technician Training Course

                   Perform post-renovation lead dust clearance
                   testing under EPA's RRP Rule
                   - Determines whether the work area has been
                      sufficiently cleaned of lead dust after
                      renovation, repair, or painting
                   Perform a clearance examination after hazard
                   reduction or maintenance activities in most
                   properties covered by HDD's LSHR
A lead dust sampling technician can perform lead dust clearance testing, but not if associated with an
abatement.

The purpose of lead dust clearance testing after renovation, repair, or painting activities that disturb lead-
based paint is to determine if a work area is safe for re-occupancy. These activities can create lead dust,
so proper cleanup is critical.
1-11                                 October 2011

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Model Certified Lead Dust Sampling Technician Training Course
                                                                          1-12
                A

                                     Is

                •  Perform clearance after an abatement
                    - Lead abatement jobs are designed to permanently
                      eliminate lead-based paint hazards.
                    - Clearance after an abatement must be done by a
                      certified risk assessor or lead-based paint inspector
                      and may not be done by a lead  dust sampling
                      technician.
                •  Sample paint for lead content
                •  Sample soil for lead
While lead dust sampling technicians can conduct post-re novation lead dust clearance testing, they are
not allowed to conduct post-abatement clearance. Clearance after abatement must be done by a certified
risk assessor or a lead-based paint inspector.

Abatements are projects designed to permanently remove or eliminate lead-based paint and lead-based
paint hazards.
Abatement does not include renovation, remodeling, landscaping, or other activities, when such activities
are not designed to permanently eliminate lead-based paint hazards, but, instead, 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.
So, if a renovation job involves abatement, the lead dust sampling technician cannot perform lead dust
clearance testing on the abatement part of the job. Make sure you understand what type of work was
done before conducting lead dust clearance testing.
In addition, a lead dust sampling technician is not trained to test paint for lead content. Paint sampling
must be done by a lead-based paint inspector, risk assessor or certified renovator.
Finally, a lead dust sampling technician is not trained  to sample soil. Soil sampling must be done by a
certified lead-based paint inspector or risk assessor.
              HUD NOTE: HUD does not allow sampling technicians to work on abatement projects.
              HUD also requires that a certified risk assessor or a certified lead-based paint inspector
              approve the work of the clearance sampling technician and sign the clearance report.
              Sampling technicians may work on single-family properties or individually-specified
              dwelling units and associated common areas in a multi-unit property as directed by a
              certified risk assessor or a certified lead-based paint inspector, but may not themselves
              select dwelling units or common areas for testing.
1-12                                   October 2011

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Model Certified Lead Dust Sampling Technician Training Course
                                                                   1-13
                        RRP  Rule

              •  Common renovation activities like sanding, cutting, and
                demolition can create hazardous lead dust and chips by
                disturbing lead-based paint.
              •  On April 22, EPA issued a rule requiring the use of lead-
                safe practices and other actions aimed at preventing
                lead poisoning.
              •  Beginning on April 22, 2010, all contractors performing
                renovation and all dust sampling technicians must be
                trained and certified.
Beginning April 22, 2010, contractors performing RRP projects that disturb lead-based paint in homes,
child care facilities, and schools built before 1978 must be certified and must follow specific work
practices to prevent lead contamination.
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                                                                       1-14
              EPA's RRP  Rule -  (cont.)

              •  Upon completion of renovation activity, the RRP Rule
                requires either:
                 -  cleaning verification by a certified renovator, or
                 -  lead dust clearance testing  by a certified LOST, lead-
                    based paint inspector, or risk assessor
                "Cleaning verification" need not be done if both lead dust
                clearance testing and achieving clearance is required by:
                 -  the contract between the renovator and the property
                    owner, or
                 -  another  Federal, State,  or local law
The cleaning verification process involves a visual inspection of the work area, followed by wiping of the
windowsills, floors, and countertops with wet disposable cleaning cloths and comparing the wipes to a
cleaning verification card.

Cleaning verification must be performed by a certified renovator; it cannot be done by the lead dust
sampling technician and sampling technicians are not allowed to perform clearance on abatement
projects or on abatement parts of renovation projects.

See Appendix A for a portion of the EPA RRP final rule.
              HUD Note:  A certified sampling technician may work on HUD-assisted single-family
              properties or individually-specified dwelling units and associated common areas in a
              multi-unit property.  The sampling technician may work on a random sampling of
              dwelling units or common areas in multifamily properties only as directed by a certified
              risk assessor or a certified lead-based paint inspector, but the sampling technician may
              not select dwelling units or common areas for testing, and the risk assessor or inspector
              must approve the sampling technician's work and sign the clearance report for the
              report to be  acceptable.
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Model Certified Lead Dust Sampling Technician Training Course
                           RRP Rule -

                •  You must be a certified LOST to perform
                  post-renovation clearance testing under
                  EPA's RRP Rule.
                  Successful completion of this course
                  completes the certification process.

                  You will be certified by either EPA,  or if they
                  are an authorized program, the State, Tribe,
                  or Territory in which you work.
To conduct a post-renovation clearance examination, the individual must be a certified lead dust sampling
technician, lead-based paint inspector, or risk assessor.

EPA LOST certification allows the certified individual to perform post-re novation lead dust clearance
testing in residential housing and child-occupied facilities.  Certified lead dust sampling technicians
cannot conduct post-abatement clearance testing.

When going to a worksite, lead dust sampling technicians must have a copy of their initial course
completion certificate and most recent refresher training course completion certificate.
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                                                                  1-16
                                         -


                   Before conducting dust clearance sampling after a
                   renovation, a visual inspection of the work area for
                   dust and debris is required.
                   Results of dust clearance testing must be interpreted
                   according to the EPA/HUD clearance standards and
                   provided to the client.


                   All surfaces represented by a failed clearance test
                   must be re-cleaned and re-tested until the clearance
                   level is met.
More details on all these topics are discussed later in the course.
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                                                              1-17
Model Certified Lead Dust Sampling Technician Training Course



            HUD's Lead Safe Housing Rule -

            (LSHR)

           •  HUD requires clearance testing on all but very small
              renovation or maintenance jobs.
           •  Clearance must be performed by a clearance examiner
              who is independent of those performing work (third party).
           •  This clearance must be performed by either a certified lead-
              based paint inspector, risk assessor, or sampling
              technician.
           •  HUD requires a visual inspection (assessment), dust
              sampling, laboratory analysis, and submission of a
              clearance report.
HDD's LSHR requires that lead hazards be corrected in target housing receiving Federal housing
assistance or being sold.  It also requires clearance dust sampling as a routine part of every such activity,
unless very small amounts of paint are disturbed.
1-17                              October 2011

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Model Certified Lead Dust Sampling Technician Training Course

                 HUD clearance generally covers an entire dwelling
                 unit, common areas, and exteriors.
                 Worksite-only clearance is permitted on certain
                 renovation or maintenance jobs.
                    -  For ongoing lead-based paint maintenance
                    -  Rehabilitation assistance up to and including
                       $5,000 per unit
                 Clearance report must include specifics of property,
                 results of visual inspection, laboratory information,
                 dates, written description of work performed, and dust
                 testing results.
Clearance must be on the entire unit unless the worksite has been properly contained or the LSHR
specifically permits worksite-only clearance. The LSHR permits worksite-only clearance for units receiving
rehabilitation assistance up to and including $5,000 and for ongoing lead-based paint maintenance
activities.

Sampling requirements will be discussed in later chapters.
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Model Certified Lead Dust Sampling Technician Training Course
                                                          1-19
           •  Use EPA/HUD clearance standards to interpret
              dust sampling results.
           •  HUD requires that all surfaces represented by a
              failed clearance test be re-cleaned and re-
              tested until the clearance level is met.
           •  If the work area fails the visual inspection, the
              sampling technician must stop and require the
              renovator to re-clean.
           •  The sampling technician must then re-inspect
              before dust testing.
Details on these topics are provided later in the course.
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           Attachment 1-A: Comparing Lead Evaluation Professionals

Is qualified to perform
the/allowing types of
evaluations




Is not qualified to
perform


Training/Certifieation
required to perform
evaluations



















LEAD DUST
SAMPLING
TECHNICIAN
Post-renovation
clearance testing
Clearance after
hazard reduction or
maintenance
activities in HUD-
covered properties
• Post-abatement
clearance
• Soil and paint
testing
• Certification
8 training hours



Perform:
• Visual inspection
Lead dust wipe
sampling


To identify dust lead
hazards after
renovation.








LEAD-BASED
PAINT INSPECTOR
Paint inspections
• All clearance





• Risk assessments



• Certification
24 training hours



Perform;
• Visual inspection
• Paint chip
sampling
• Paint testing by
XRF
• Lead dust wipe
sampling for
clearance

To identify the
existence and location
of lead-based paint.




LEAD-BASED
PAINT RISK
ASSESSOR
Risk assessments
• Paint inspections
All clearance








• Certification
40 training hours
(24 inspector hours
and 16 risk
assessor hours)
Perform:
• Interview of
residents
• Visual inspection
• Lead dust wipe
sampling
• Soil sampling
• Paint chip
sampling
• XRF testing

To assess a unit,
identify all lead
hazards, and
recommend methods
for lead hazard
reduction.
Chapter 1
Attachment 1-A

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Chapter 2: Visual Inspection

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INSTRUCTOR
NOTES
                       CHAPTER 2: VISUAL INSPECTION
Objectives:
The major objective of this chapter is to teach students to perform
visual inspections. Specific objectives include the following:
   •   List the items that should be identified in a visual
       inspection
   •   Identify:
          -   Visible dust or debris
          -   Paint chips
          -   Deteriorated paint
   •   Record results on a visual inspection form
Introduction to this
chapter:
This chapter is designed to give students the tools to perform
visual inspections and report their findings on standard forms in a
manner that is understandable to clients and future contractors.
This chapter will demonstrate what students should look for as
they perform visual inspections and where they should look for
potentially problematic areas within housing units.
Activities:
Photographs tell the story. Slides 2-8 through 2-16 have
photographs of deteriorated paint caused by different conditions.
The object here is to get students thinking about the many sources
of deteriorated paint and how they might be creating dust or paint
chips in the home. For each picture, discuss with the group the
likely source of the problem and why this  deteriorating paint
could be a problem.
Review:
See Slides 2-18 and 2-19 for this chapter's review topics. Ask
students if they have any questions about the material before
moving on to the next chapter.
Notes:
The pictures included in Slides 2-8 through 2-16 should be
"narrated" and explained to students so that they understand that
these images demonstrate problematic conditions in the units they
are assessing. Students should understand how to recognize each
of these conditions by the end of the chapter.

Be sure to point out Attachments 2-A and 2-B,  a blank and
completed sample visual inspection form, which students can use
to model their notetaking as they perform visual  inspections.
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                  •  Learn what a visual inspection is
                  •  Learn the steps for performing a visual
                     inspection under both EPA's and  HUD's
                     regulations
                  •  Learn when to look for deteriorated paint,
                     visible dust or debris, and paint chips
                  •  Record results on a visual inspection
                     form
This chapter will outline the steps a lead dust sampling technician must take to perform a visual
inspection. A visual inspection is the first activity to perform on site for any lead dust clearance testing.
This chapter will also highlight the differences in visual inspection between EPA's RRP Rule and HUD's
LSHR.
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Model Certified Lead Dust Sampling Technician Training Course

              Under both EPA's and
              HUD's rules, visual
              inspection is the first step
              in the clearance process.
              Under EPA's rule, the
              visual inspection is
              designed to determine if
              the area is free of visible
              dust and debris before
              lead dust clearance
              testing can begin.
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                                        -

               •  The visual inspection determines whether the
                  unit/work area (interior and exterior) is clear of visible
                  conditions that can result in exposure to lead-based
                  paint hazards:
                   - Chips or debris
                   - Visible dust
               •  In addition, HUD's rule requires identification of
                  deteriorated paint.
                   - Required before dust sampling can begin
                   - Whole-unit clearance generally required
The visual inspection determines whether the unit/work area is clear of conditions that can result in
exposure to lead-based paint hazards, such as paint chips, debris, visible dust, and deteriorated paint. If
these conditions are present, the unit does not meet EPA's and HUD's rules for lead dust clearance
testing. HUD generally requires visual inspection and clearance of an entire unit, with worksite-only
clearance allowable under certain conditions.
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                                          -


              1  At the conclusion of the renovation, the certified
                renovator may have conducted a visual inspection to
                look for paint chips,  dust, and debris.
              1  The LOST must conduct a separate visual inspection of
                the work area to ensure that the area is ready for lead
                dust sampling.
              1  If any paint chips, dust, or debris are found, the
                renovation firm should re-clean these areas before the
                dust sampling technician begins to collect dust wipe
                samples.
It is important for the lead dust sampling technician to understand that the renovation firm may perform
his or her own preliminary visual inspection. The lead dust sampling technician should also perform a
visual inspection of the work area. If the lead dust sampling technician observes paint chips, dust, or
debris in the work area, these conditions must be brought to the attention of the certified renovator for re-
cleaning.
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Model Certified Lead Dust Sampling Technician Training Course
                                        - HUD
             • Addresses entire unit unless worksite-only
               clearance is allowed.
               Do not perform lead dust clearance testing if
               unit/work area does not pass visual inspection.

               If deteriorated paint, dust, or debris is found, it
               must be eliminated before dust testing may begin.
                - See Attachment 2-A and 2-B
Why look for deteriorated paint?
In order to address lead dust in a housing unit, you need to address its sources, including deteriorated
lead-based paint. If paint contains lead, deteriorated paint can create chips and dust, which can cause
exposure to lead.

*  NOTE: The LSHR refers to this process as a "visual assessment," but for purposes of this
   curriculum, the term "visual inspection" is used.
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                                           -  HUD

                  •  Inspect exterior area if:
                     - Exterior painted surfaces have been disturbed
                       by renovation activity
                     - Openings to exterior were not sealed during
                       interior work
                  •  Inspect ground and outdoor living areas
                    close to affected surfaces
                  •  Visible dust or debris must be removed
                  •  Deteriorated paint must be eliminated
                  •  Dust sampling is not performed for exterior
                    work
EXTERIOR VISUAL INSPECTION IS NOT REQUIRED IF ONLY INTERIOR WORK IS PERFORMED.
An independent third party is needed to do an exterior visual inspection if the exterior work was done
under HDD's LSHR. A certified dust sampling technician is qualified to perform this inspection.

For more information, see Appendix B or 24 CFR 35.1340.
             HUD Note:  HUD requires sampling technicians to verify with renovator that openings
             to the exterior are closed during interior work. If not closed, exterior visual inspection is
             required for interior work.
             Dust sampling is not required for exterior work. There are no dust-lead clearance
             standards for porches, balconies, railings, or other horizontal exterior features.
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                                            -  HUD

              Identify any paint that is
              not intact:
               - Chipping
               - Peeling
               - Chalking
               - Cracking
               - Holes, moisture, and
                 friction damage
              Hairline cracks and nail
              holes are not considered
              deteriorated paint.
Deteriorated paint is any paint that is not intact.  It does not have to be peeling paint.
As seen in the following photographs, deteriorated paint can include:
• Chipping paint on door and window trim
• Peeling paint and flaking paint on walls and window sashes
• Paint with small bubbles that look like blisters
• Paint with lines and cracks that make it easy to peel the paint away
• Paint that is "chalking" or creating chalk-like dust

Note: Hairline cracks and nail holes are not considered deteriorated paint.
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Model Certified Lead Dust Sampling Technician Training Course
                                          - HUD
                 Dust
                 - Dust you can see
                 Debris
                 - Pieces of wood, bits of
                   plaster, and various
                   other building pieces
                   covered in paint
                 Paint chips
                 - Small  pieces of paint
What do visible dust, paint chips, and debris look like?
• Visible dust is dust you can see.
• Debris can be pieces of wood, bits of plaster, and various other building pieces covered with paint that
are left in the room or near where the work was done.
• Paint chips are little pieces of paint. Chips can be even smaller than your fingernail or larger than your
hand. Look for paint chips on floors and windows.
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                                     - HUD



                          Chipping Paint
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                                      - HUD
                           Holes in wall
                                                        2-12
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                                      - HUD
                       Deteriorated Paint
                          2-13
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Model Certified Lead Dust Sampling Technician Training Course

                                        - HUD
                          Cracking Paint
2-14
The arrow here points to a crack in the paint.
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                                                             2-15
                                    -





                          Moisture Damage
Moisture can be the cause of many paint problems. In this case, it is causing the paint to bubble.
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                                -




                       Friction Damage
                                                      2-16
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Model Certified Lead Dust Sampling Technician Training Course
                                                              2-17
                                         - HUD

                  •  Be precise about locations.
                  •  Write down results as you go.
                  •  Write down other information,
                    indicating source.
                  •  See sample visual inspection form.
                    (Attachment 2-B)
When recording the results of a visual inspection, take the following steps:
     Be precise about locations (e.g., room descriptions and/or specific areas in room) where visible
     dust, debris, paint chips, and deteriorated paint were found.
     Write down results as you go along.
     Write down other information the client provides about the surface in question.
See Completed Sample Visual Inspection Form in Attachment 2-B.
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Model Certified Lead Dust Sampling Technician Training Course
               •  Visual inspection is the first step to clearance.
               •  EPA's visual inspection determines that the
                  area is free of dust and debris before dust
                  clearance testing can begin.
               •  HDD's visual inspection also checks for
                  deteriorated paint and generally covers the
                  entire unit unless worksite-only clearance is
                  allowed.
   See Slides 2-3 through 2-16 for information and answers.
   See Slide 2-3 for information and answers.
   See Slides 2-3 through 2-9 for information and answers.
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Model Certified Lead Dust Sampling Technician Training Course
                      -
              Visual inspection as part of clearance is
              the responsibility of the dust sampling
              technician.
              Be methodical in your visual inspection,
              and record results.
                                                     2-19
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               Attachment 2-A: Sample Visual Inspection Form
                  SAMPLE VISUAL INSPECTION FORM
Date and Time of
Clearance
Lead Dust Sampling
Technician
Client
Property Address




Location









Identify visible areas of dust, paint chips, painted debris, and
deteriorated paint. (Note location: walls, ceiling, floors, doors,
windows, trim, cabinets, approximate square footage, etc.)









Chapter 2
Attachment

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          Attachment 2-B: Completed Sample Visual Inspection Form
                  SAMPLE VISUAL INSPECTION FORM
Date and Time of
Clearance
Lead Dust Sampling
Technician
Client
Property Address
8/5/09 1LOOAM
Jane White
The Smith Family
78 East Main Street
Hammond, IN 89898
Location
Entry Area
Living Room
Dining Room
Kitchen
Common Area
Bedroom #1
Small bedroom
(Street Side)
Bedroom #2
Small bedroom
(Back of the house)
Bath #1
Exterior
Identify visible areas of dust, paint chips, painted debris, and
deteriorated paint. (Note location: walls, ceiling, floors, doors,
windows, trim, cabinets, approximate square footage, etc.)



Window above sink; deteriorated paint on window sash. Client said
deteriorated paint was tested and is not lead-based paint.

East window; deteriorated paint on lower sash and dust and paint
chips in trough. Client said deteriorated paint was tested and is not
lead-based paint.
Dust and paint chips on floor.


Chapter 2
Attachment

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Chapter 3: Lead Dust Wipe Sampling

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INSTRUCTOR
NOTES
              CHAPTER 3: LEAD DUST WIPE SAMPLING
Objectives:
The major objective of this chapter is to teach students where and
how to take a lead dust wipe sample. Specific objectives are the
following:
    •   Learn when and where to take a dust wipe sample
    •   Learn how to take a dust wipe sample
    •   Sample 3 surfaces where dust is collected
    •   Learn the difference between single-surface and
	composite sampling	
Introduction to this
chapter:
This chapter is designed to teach students to collect single-surface
lead dust wipe samples and to understand the role of composite
samples. The chapter will cover this material in three ways:
    •  Images of lead dust wipe sampling techniques
    •  Description and demonstration of lead dust wipe sampling
       process
    •  Hands-on practice of lead dust wipe sampling

As you cover the material in this chapter, be careful to connect
these three pieces for students to understand how each of the
components fit together into a single skill set.	
Activities:
There are three activities in this chapter: two demonstrations and
one hands-on exercise.

Demonstration: Lead Dust Contamination Demonstration
The first demonstration takes place on Slide 3-3 and requires a
packet of artificial sweetener. Show the packet and explain that an
amount of lead dust equal to the amount of sweetener in this one
packet is enough to contaminate a large area.

(Note: Use artificial sweetener rather than sugar because it is
finer. Only do this demonstration if you have a non-carpeted
floor to work on.  If you only have carpeted surfaces, simply
empty the packet of sweetener into your hand, show it to the class
and explain that this is enough to contaminate 125 ft2 (about a 10'
by 12' room) to a level of 40 micrograms/ft2)

Do the following demonstration to emphasize the point:

1. Tear open a packet of artificial sweetener and sprinkle it on
   the floor.
2. Ask a few participants to walk through it.
3. Now give a participant a broom  and tell him or her to sweep
   up the sweetener.
4. Question to the class: Do you think all the sweetener has been
   cleaned up or removed? Ask them if there is any on the  soles
   of the shoes that walked through it. Where is that sweetener
Lead Dust Sampling Technician
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Chapter 3

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                         now?
                     5.   Explain that one way to test the amount of sweetener on the
                         floor is to do a dust wipe.
                     6.   Demonstrate the dust wipe sampling process.
                     7.   Question for the class: Do you think a lab analysis would
                         show sweetener on the wipe?
                     8.   Now tell the  class to imagine that the packet was actually full
                         of lead dust. It is possible that this small amount of lead dust
                         (1 gram) could contaminate several rooms.

                     If the packet contained a gram of crushed paint that contained just
                     enough lead to be defined as lead-based paint (0.5% lead by dry
                     weight), it would hold 5,000 micrograms of lead. Once crushed
                     into dust, this is enough to contaminate 125 ft2 (about a 10' by
                     12' room) to a level of 40 micrograms/ft2.

                     If the dust had a higher lead content, it could contaminate an even
                     larger area. At 1% lead, one gram could contaminate 250 ft2
                     (about a 16' by 16' room); at 5% lead, it could contaminate 1,250
                     ft  (about the size of a two-bedroom apartment).
                     Hands-On Exercise: Lead Dust Wipe Sampling

                     Description: In this exercise, starting on Slide 3-35, each student
                     will take a lead dust wipe sample following the protocol discussed
                     in the chapter.

                     Materials:
                         •   Disposable lead dust wipes (individually wrapped)
                         •   Disposable gloves
                         •   Disposable shoe covers
                         •   Sample tubes with caps
                         •   Reusable templates (can be made or purchased)
                         •   Masking  or painter's tape
                         •   Ruler
                         •   Sample collection forms
                         •   Chain-of-custody forms
                         •   Markers,  trash bags, labels, pens, re-sealable storage bags
                         •   Calculator
                         •   Sanitary wipes
                     Note: To be effective, at most, a 6:1 student-to-teacher ratio is
                     recommended. The instructor may want to bring in additional
                     qualified instructors to oversee this activity.

                     Steps:
                     1.  Distribute sampling materials and a blank sample collection
                         form to the students.
Lead Dust Sampling Technician
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                     2. Divide students into groups of three or four individuals,
                        depending on class size.
                     3. Using the templates and dust sampling materials, have each
                        student practice lead dust wipe sampling techniques and
                        complete the blank sample collection form. Have students
                        refer to Attachment 3-F: Lead Dust Wipe Checklist for
                        assistance.
                     4. Encourage students to take samples on a variety of surfaces -
                        windowsills, troughs, and uncarpeted floors.
                     5. Go to each of the groups and review the students' sampling,
                        measuring, and recording techniques. Correct any errors and
                        answer any questions students may have.
                     6. Have students briefly discuss  any problems they encountered
                        and ask any relevant questions. Use Slide 3-37 to guide the
                        discussion.
                     Use Slides 3-36 and 3-37 to kick off and debrief the exercise.
                     Demonstration of Inaccurate Measurement

                     In discussing common mistakes on Slide 3-36, consider this
                     scenario. Write it on a white board or flipchart to illustrate:
                     •  Suppose you record the interior sill sample area as 3 inches by
                        24 inches. That's 72 in2.
                     •  But suppose the sample area was really 3 1/8 inches by 24
                        inches. That gives you 75 in2. This is significantly more than
                        72 in2 and will affect the results.
                     •  Now suppose the results come back from the lab that there was
                        127 |j,g in the  sample. 127 jig over 72 in2 translates to 254
                        ng/ft2.
                     •  But 127 |ig over 75 in2 translates to 244 ng/ft2.
                     •  In the first case, the sample exceeds the standard clearance of
                                r\
                        250 ng/ft . In  the second case, the sample does not exceed the
                        standard.
                     •  We'll discuss the standards later in this course. For now, your
                        take-away message should be that a small measurement
                        mistake can mean the difference between passing and failing
                        clearance.
Review:
See Slide 3-42 for this chapter's review topics. Ask students if
they have any questions about the material before moving on to
the next chapter.	
Notes:
Be sure to point out Attachments 3-A and 3-B, blank and
completed sample collection forms, which students should use to
model their notetaking as they take lead dust wipe samples. Refer
students to Attachment 3-E: Worksheet for Performing
Mathematical Calculations from Fractions to Decimals for
Lead Dust Sampling Technician
                     3-iii
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                     assistance in performing mathematical calculations and
                     conversions as they complete their sampling forms.
Lead Dust Sampling Technician
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                                                               3-1
                                           3

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            •  Learn when and where to take a dust
              wipe sample
            •  Learn how to take a dust wipe sample
            •  Sample 3 surfaces where dust is
              collected
            •  Learn the difference between single-
              surface and composite sampling
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Model Certified Lead Dust Sampling Technician Training Course
                    •  You  cannot tell by looking at dust
                      whether it contains lead.
                    •   A small  amount of lead dust can
                      contaminate a  room.
Why collect samples?
       Not all dust contains lead.
       You cannot tell by looking whether dust is contaminated with lead. A laboratory test is needed.
Activity: Lead Dust Contamination Demonstration
It only takes a little lead to contaminate a room. For example, imagine that each granule of artificial
sweetener in a sweetener packet represents a tiny piece of lead. If only two or three of these "lead"
granules were placed in a 1 square-foot area of floor, enough lead would be present to exceed the EPA
clearance standard for lead dust. An individual granule is very small and would be nearly impossible to
find by simply  looking at an area, especially if the granule was ground up into smaller particles and
spread throughout the area.
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Model Certified Lead Dust Sampling Technician Training Course
                                                                     3-4
                  A

                 •  Total amount of lead dust on a specific
                    surface area (lead loading)
                    - The EPA lead dust clearance standards use
                      this type of measurement.
                 •  Lead present at the time and location of
                    sample collection
                    - Does not tell you about past or future levels
                    - Lead levels can change depending on the
                      activity in the house or in different locations
A dust wipe measures the total amount of lead dust on a specific surface area. This measurement is
called lead "loading." Lead loading is a good indicator of the amount of lead to which a child is exposed.

       Dust wipes measure lead dust at a particular point in time.
       Lead levels can change as the amount of lead dust on the surface changes.
       Lead levels also can change depending on the activity in the house, including activities that
       disturb lead-based paint and the frequency of cleaning.
       The measurement tells you how much lead existed when the sample was collected; it does not
       tell you about past or likely future lead levels.
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Model Certified Lead Dust Sampling Technician Training Course
                                                              3-5
                      of

             •  You must wait at least 1  hour after final
               cleanup is completed and visual inspection
               is passed before collecting samples.
             •  This allows time for dust to settle out of the
               air and onto surfaces.
             •  Be strategic about laying out sampling area
               to capture areas were the highest dust
               generating tasks occurred during the job.
You must wait a minimum of 1 hour after the final cleanup is completed before collecting dust wipe
samples. This allows time for the dust to settle out of the air and onto surfaces.
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Model Certified Lead Dust Sampling Technician Training Course
                                                                       3-6

                    A single surface dust wipe measures total lead
                    dust from a specific surface on component or area.
                    When choosing sampling locations, identify areas
                    where the most dust was generated during the job.
                    Whenever possible sample hard floors, not
                    carpets.
                    Make sure to follow the sampling requirements in
                    the next slides or the Field Guide to select your
                    final sample locations.
•  Single-surface dust wipe samples contain one wipe from one surface.
- They measure lead dust from a specific surface, such as a floor or an interior windowsill.
- They measure the total lead in the surface area.
- They do not tell you about dust lead levels in other places on the same surface. Dust lead levels can
vary substantially.

When planning a sampling strategy, consider your sample numbering scheme and prepare for the
number of samples you expect to take. Try to capture the sampling locations near dust-generating tasks
that occurred during the job.
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                    •   If there is more than 1 room, hallway, or stairwell within the work
                       area, take:
                        -  1 windowsill sample and 1 floor sample within each room,
                          hallway, or stairwell (no more than 4 rooms, hallways, or
                          stairwells need be sampled)
                        -  If the windows were not closed and covered with plastic during
                          the renovation, also take 1 window trough sample in each
                          room, hallway, or stairwell (no more than 4 need be sampled).
                        -  1 floor sample adjacent to the work area, but not in an area
                          that has been cleaned
                    •   For Federally-assisted housing, take these samples if the work
                       area is contained, otherwise, clear the whole unit, as discussed in
                       the previous slide.
                                                                               3-7
Although cleaning verification is not performed on carpeted floors, dust clearance sampling is.  LDSTs
should not avoid sampling carpeted floors.

If the work area includes more than 4 rooms, hallways, or stairwells, only 4 must be sampled. A
windowsill sample and a floor sample must be collected from each of 4 rooms, hallways, or stairways
within the work area.

The RRP Rule requires all objects and surfaces, including floors, within 2 feet of the work area to be
cleaned after the work has been completed.  Floor samples required to be collected outside of the work
area must be collected outside of the cleaned area surrounding the work area.

Window troughs may contain pre-existing dust lead hazards. If possible, LDSTs should discuss the
window trough sampling requirements with the certified renovator before the renovation begins. If the
windows in the work area remain closed and covered with plastic during the renovation, window trough
sampling will not be necessary.

The next few slides on sampling apply to HUD as well.
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                                                 -

                • If the work area is a single room, hallway, or
                  stairwell, or a smaller area, take:
                   - 1 windowsill sample and 1 floor sample
                   - If the windows were not closed and covered
                     with plastic during the renovation, also take 1
                     window trough sample.
                   - 1 floor sample adjacent to the work area, but
                     not in an area that has been cleaned.
                                                                3-8
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                                                                       3-9
                 HUD does not allow clearance to be performed on a
                 work area alone that has not been adequately contained
                 HUD clearance can be done in several ways
                  - Whole unit clearance in most cases
                  - Worksite-only clearance in some cases
                  - Clearance for interior work when containment is used
                 LOST should discuss sampling strategy with renovator
                 prior to start of work
                 See HUD Sampling Appendix and optional HUD
                 Sampling Exercise for detailed descriptions of HUD
                 sampling strategies.
HUD has different requirements than EPA for clearance.  Although EPA's post-re novation clearance
protocol is similar to HDD's allowed protocol for worksite-only clearance, HUD has additional
requirements to use this sampling strategy. Although the sampling requirements are very important for
Federally-funded renovation activity, these units will represent a relatively small percentage of all
renovation projects performed nationwide. Because most of the renovation jobs that are expected to
occur in U.S. housing will not be funded with Federal housing assistance, details on HUD sampling are
provided attached to the curriculum in the optional sampling exercise for HUD-assisted work and in the
HUD sampling appendix. All LDSTs should discuss sampling plans with the renovator before work
begins; with particular attention to whether the project is receiving Federal housing assistance, so the
proper sampling strategy can be used to comply with the Lead Safe Housing Rule.
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Model Certified Lead Dust Sampling Technician Training Course
                     To


              • Now that you know where and when to
                sample, the next section will cover the
                most important part of the course: How to
                take dust wipe samples.
              • Regardless of the rule you are working
                under, the methods for taking and later
                analyzing dust wipe samples are
                identical.
                                                        3-10
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                                                                        3-11
                  Wipes - Disposable individually packaged wipes.
                  Check with you laboratory, they often provide these
                  Disposable gloves - Should be non-sterilized and non-
                  powdered
                  Disposable shoe covers - Use of disposable shoe
                  covers helps to minimize the transfer of settled dust
                  from one location to another.
                  Containers - Centrifuge tubes or other hard plastic,
                  non-glass containers.  They should be non-sterilized,
                  plastic tubes equipped with a sealable lid.
                  Reusable template - A12" x 12" reusable template for
                  floors.
Key supplies are listed above. Check with your analytical lab, because they will often provide some of
these materials.
       Disposable lead dust wipes. Use individually packaged wipes (laboratories often provide
       these). The wipes should meet ASTM Standard E1792-03. Do not use any wipes that contain
       aloe or lanolin.
       Disposable gloves. Gloves should be disposable. Non-sterilized and non-powdered gloves are
       recommended because powder on gloves may contaminate the sample (laboratories often
       provide them).
       Disposable shoe covers. Use of disposable shoe covers between buildings and the removal of
       shoe covers before entering your vehicle can be helpful in minimizing the inadvertent transfer of
       settled dust from one location to another.
       Centrifuge tubes or other hard plastic, non-glass container. They should be non-sterilized,
       plastic tubes equipped with a sealable lid.
       Reusable templates. A 12"x12" reusable plastic or disposable cardboard template is best.
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                                                                         3-12
                                                              -



                   Tape - Painter's or masking tape works well

                   Ruler -To measure sampling areas if templates are not
                   available

                   Sample collection forms and chain-of -custody forms

                   Labeling and cleanup supplies. Permanent markers, trash
                   bags,  labels, re-sealable storage bags, and sanitary wipes

                   Pen -To complete the sample collection form, label tubes,
                   and write down notes

                   Calculator - To assist in the calculation of sampling area
                   dimensions

Key supplies are listed above. Check with your analytical lab, because they will often provide some of
these materials.

Tape. Painter's or masking tape works well. Tape is used to secure templates while taking dust samples
and to outline sample areas when templates are not available.
Ruler. To measure sampling areas if templates are not available.
Sample collection forms and chain-of-custody forms. Laboratories will generally provide their own
forms.
Labeling and cleanup supplies. Permanent markers, trash bags, labels, re-sealable storage bags, and
sanitary wipes for face and hands if no access to warm and soapy water.
Pen. A  pen should be used to complete the sample collection form, label tubes, and write down notes.
Calculator.  A calculator should be used to assist in the calculation of sampling area dimensions.
Sanitary Wipes. To be used for cleanup if no access to warm, soapy water.
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Model Certified Lead Dust Sampling Technician Training Course
                                                                          3-13

                  A new, unused wipe that is tested at the laboratory to
                  determine whether the sampling medium is contaminated.
                  Laboratory should not know they are blanks
                   •  Blanks should be assigned sample numbers and
                      locations.
                   •  Only your copy of the sample collection form should
                      identify which samples are blanks.
                  One blank sample should be submitted
                   •  For each job tested
                   •  From each wipe lot
Blank samples are new, unused wipes that are sent to the laboratory to determine whether the sampling
media are contaminated by providing a "clean" (assumed lead-free) wipe for comparison. Because you
should prepare blank samples on every job, you should factor the costs associated with these samples
into your fee. Submitting blank samples is important to test the accuracy of your sampling techniques, the
sampling media, and the laboratory's analysis.
Preparing blank samples. You should prepare blank samples in the same manner as other dust wipes.
            Prepare blank samples at the end of a job - after collecting all of your dust wipe samples.
            Remove a new wipe from the container with a new glove, shake the wipe open, and refold it
            as you  would if you were taking a dust sample.
            Insert the unused wipe into a sampling container without touching any surfaces.
Labeling and submitting blank samples. Blank samples should be labeled so you can identify them,
but the lab cannot. Do not label blank samples as "blank."
            Give the sample a fictitious number that looks like your other sample numbers and provide a
            fictitious sample location and measurements to the lab.
            Keep notes in your records identifying the blank sample number.
            Submit one blank sample for each unit sampled. Additionally, one blank should be included
            from each wipe lot  used to ensure that the lots are not contaminated. The wipe lot number is
            usually found on the bottom of the wipe container.
            It is improper to label blanks as such because of the unavoidable potential for biasing the
            laboratory analysts; it is poor practice to have all blanks at the same portion of each unit's
            (and each wipe lot's) samples.
Interpreting blank samples. If the laboratory detects more than 10 ug/wipe, one of three errors may
have occurred:
            The dust wipes were contaminated  before you began using them;
            You contaminated the wipes during your sampling; or
            The laboratory contaminated them during the analysis.
If the blank sample is contaminated, then the data should not be used and the unit in question should be
re-sampled.
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Model Certified Lead Dust Sampling Technician Training Course
                                                                       3-14
                           To

             Step 1:  Put on disposable shoe covers and lay out the sample
             area.

             Step 2:  Prepare the tubes.

             Step 3:  Put on clean gloves.

             Step 4:  Sample the selected area and place wipe in tube.

             Step 5:  Measure the sample area.

             Step 6:  Record sample area (dimensions) on forms.

             Step 7:  Clean up.
This slide presents an overview of the dust sample collection process, which has seven key steps. Each
of these steps is presented here and in more detail later in this training.
Step 1: Put on disposable shoe covers and lay out the sample area. Carefully outline the area you
will sample using a template or tape.
Step 2: Prepare the tubes. Label the tubes and place partially opened tubes near the spot you will
sample.
Step 3: Put on clean gloves. Put on clean gloves before collecting each sample. This helps minimize
contamination.
Step 4: Wipe sample area. Wipe the entire area you laid out with disposable wipe for the sample. Fold
the wipe and place it in the appropriate tube.
Step 5: Measure the sample area. Measure the area sampled.
Step 6: Record sample area on forms. Record measurement on sample collection form and chain-of-
custody form.
Step 7: Clean up. Sampling materials must be cleaned or removed from the site because they may be
contaminated.
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Model Certified Lead Dust Sampling Technician Training Course
                          1:  Put on
                                    Lay       the

                  •  Put on shoe covers.
                  •  Outline sample area with tape or a template.
                  •  Templates should be durable material.
                     - Floor  sample is generally 12" x 12"
                     - Make sure you clean the template with a new
                        wipe.
                  •  Tape can also be used to outline the sample
                     area.
                  •  Lay out tape squarely so you can accurately
                     measure the sample area later.
                  •  Do NOT  touch area inside the sample area.
3-15
Step 1: Put on Disposable Shoe Covers and Lay Out the Sample Area
The following describes how to lay out the sample area using a template. Whenever possible, use a
template to avoid measurement errors. (*Make sure you clean the template before following sampling
protocol.)
The templates will vary in their dimensions:
  •   The floor template should have a 144-square inch or 1-square foot opening (12 inches = 1 foot) or
     an alternative area that has accurately known dimensions. A square foot is the basic measurement
     used by EPA-recommended guidance for lead dust clearance testing.
  •   The interior windowsill or window trough template should have an opening of at least 16 square
     inches (approximately 2" x 8").  Interior sills can vary in width.
  •   Tape the template to the appropriate surface (floor, interior sill, or interior trough) using  masking or
     painter's tape. Be careful to avoid placing your hands in the sample area, as this might remove or
     add lead dust and give you a misleading  result.
  •   If using tape, ensure that the tape is laid out squarely so that an accurate area can be determined
     for the sample size.  It is very difficult to measure the area if the tape is not laid out in a square or
     rectangle.
Do not touch  or otherwise disturb the area inside the measured sample area. This could remove or add
lead dust and give you a misleading  result. (You will measure the exact area of the sample area after
collecting the dust sample.)
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Model Certified Lead Dust Sampling Technician Training Course
                       Taping  Template to Floor
Here is an example of how the sampling area is laid out when you have a template. Note how it is taped
to the floor.
*Be sure to clean reusable templates. Tape corners at 45 degree angle away from the corner.
*Be sure not to touch the inside of the sample area.
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                                                                        3-17
Here is an example of using tape to outline the sample area on a floor when a template is not available.
Make sure that the tape is laid at right angle to ensure a that the area outlined as close to a perfect
square as possible. Doing so will make measure the area of the sample much easier and more accurate.
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Model Certified Lead Dust Sampling Technician Training Course
                             Taping Window Sill
If a template for a sill or trough is not available, lay out the sampling area with painter's tape. Place tape
perpendicular to the edge of the sill or trough. The sample area will be calculated after taking the sample
to avoid contaminating the area.

If the sill or trough is not taped, the width of the sample area varies from front-to-back when the ends of
the sill or trough are not parallel straight lines, so the area of the sample will be difficult to determine.

Make sure the area you are sampling is at least 16 square inches. Try to sample at least 8" of sill width.
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Model Certified Lead Dust Sampling Technician Training Course
                                                                   3-19
                         2:              the

                 • Use clean,  hard-sided tubes.
                 • Make sure  tube is labeled with an ID
                   number.
                 • Record ID number on sample collection
                   form and chain-of-custody form.
                 • Partially  unscrew tube cap.
                 • Place tube  near sample area.
Step 2: Prepare the Tubes
Tubes must be prepared so that they are properly labeled and are accessible to you when you are ready
to put your samples in them.
     Label each tube with an identification number.
     Record the identification number on the sample collection form and chain-of-custody form.
     Partially unscrew the cap on the tube to be sure you can open it easily.
     Place the tube near the area you plan to sample. This avoids possible contamination of the wipe
     and loss of sampled dust between the time you collect the sample and place it in the tube.
     Organizing tubes in a portable test tube rack may be helpful.
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Model Certified Lead Dust Sampling Technician Training Course
                                                               3-20
                        3: Put on

                • Use disposable gloves.
                • Use new gloves for each sample.
                • After putting on the gloves, do NOT
                  touch anything else before you pick
                  up the wipe.
Step 3: Put on Clean Gloves
Wearing clean gloves avoids transferring lead dust from your hands to the wipe.
     Use disposable gloves.
     Use new gloves for each sample collected.
     Do not put on the gloves until you are ready to take the sample. You can contaminate the gloves if
     you touch other surfaces, such as when measuring the sample area.
     After putting on the gloves, do NOT touch anything else before you pick up the wipe.
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Model Certified Lead Dust Sampling Technician Training Course
                                                                3-21
                        4:

                 •  The procedures for taking dust wipe samples
                   from floors, windowsills, and troughs are listed
                   on the following slides.
                 •  The procedure for sampling floors is different
                   than the procedure for sampling windowsills and
                   troughs.
                 •  Step 4 of lead dust wipe sampling is also
                   described in the Lead Dust Sampling
                   Technician Field Guide.
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Model Certified Lead Dust Sampling Technician Training Course
                            4:                                -


                   Do not touch other objects. They can contaminate the
                   wipe.
                   Press the wipe down firmly (with fingers, not the palm of the
                   hand) at an upper corner of the sample area.
                   Make as many "S" like motions as needed to wipe the
                   entire sample area, moving from side to side.  Do not cross
                   the outer border of the tape or template.
                   Fold the wipe in half, keeping the dirty side in, and repeat
                   the wiping procedure ("S" like motion). Folding wipe
                   carefully helps to prevent the loss of any collected dust.
Step 4: Sampling Procedure for Floors
     Do not touch other objects. They can contaminate the wipe.
     Press the wipe down firmly (with fingers, not the palm of the hand) at an upper corner of the sample
     area.
     Make as many "S"-like motions as needed to wipe the entire sample area, moving from side to
     side. Do not cross the outer border of the tape or template.
     Fold the wipe in half, keeping the dirty side in, and repeat the wiping procedure ("S" motion). This
     helps to prevent the loss of any collected dust.
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Model Certified Lead Dust Sampling Technician Training Course
                          4:                              -


                  • Fold the wipe in half again, keeping all the
                    dust in the wipe, and repeat the wiping
                    procedure one more time, concentrating on
                    collecting dust from the corners within the
                    selected surface area.
                  • Wipes are folded to keep the collected dust
                    within the wipe, avoid dust losses, and to
                    expose a clean wipe surface for further
                    collection.
                                                                     3-23
Step 4: Sampling Procedure for Floors
     Fold the wipe in half again, keeping all the dust in the wipe, and repeat the wiping procedure one
     more time, concentrating on collecting dust from the corners within the selected surface area.
     Wipes are folded to keep the collected dust within the wipe, avoid dust losses, and to expose a
     clean wipe surface for further collection.

Students should refer to Attachment 3-A: Sample Collection Form and Attachment 3-B: Completed
Sample Collection Form. A checklist of the key steps involved in taking a dust sample can be found in
Attachment 3-D: Lead Dust Wipe Checklist and the Lead Dust Sampling Technician Field Guide.
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Model Certified Lead Dust Sampling Technician Training Course
                          4:                              -


                  •  Fold the wipe again with the sample side
                     folded in, and place the folded wipe into
                     the sample tube. Avoid contact with
                     other surfaces.


                  •  Cap the container.  Discard the gloves
                     into a trash bag.
                                                                      3-24
Step 4: Sampling Procedure for Floors
     Fold the wipe again with the sample side folded in, and place the folded wipe into the sample tube.
     Avoid contact with other surfaces. Wipes should be stored only in their original container or in the
     tube. Do not use plastic bags or other items to hold wipes. Blank wipes should also be used.
     Blanks should be assigned sample numbers and locations so that the laboratory does not know
     they are blanks. Only your copy of the sample collection form should identify which samples are
     blanks
     Cap the container.  Discard the gloves into a trash bag.

Students should refer to Attachment 3-A: Sample Collection Form and Attachment 3-B: Completed
Sample Collection Form. A checklist of the key steps involved in taking a dust sample can be found in
Attachment 3-D: Lead Dust Wipe Checklist and the Lead Dust Sampling Technician Field Guide.
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                                                              3-25
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                                                              3-27
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Model Certified Lead Dust Sampling Technician Training Course
                           4:                                -


                   •  Sampling interior windowsills and troughs
                      - Hold fingers together and flat against surface.
                      - Wipe surface in a single pass while applying
                        constant pressure.
                      - Fold wipe  in half with wiped side in and wipe
                        in both directions.
                      - Fold wipe  in half again with wiped side in and
                        concentrate on corners and edges.
                      - Place the folded wipe in the tube.
Special Considerations for Interior Windowsills and Troughs
Window troughs may contain pre-existing dust lead hazards. If possible, LDSTs should discuss the
window trough sampling requirements with the certified renovator before the renovation begins. If the
windows in the work area remain closed and covered with plastic during the renovation, window trough
sampling will not be necessary.

Sampling Procedure for Windowsills and Troughs:
•  Holding the fingers together and flat against the selected surface area, wipe the measured surface in
one direction in a single pass. Apply pressure to the fingers while wiping the surface.  This will avoid
overloading the wipe on the first pass.
•  Fold the wipe in half with the sample side folded in, and repeat the preceding wiping procedure in both
directions within the selected surface area on one side of the folded wipe.
•  Fold the wipe in half with the sample side folded in, and repeat the preceding wiping procedure one
more time, concentrating  on collecting settled dust from the corners within the selected surface area.
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Model Certified Lead Dust Sampling Technician Training Course



                         4:                              -
                                                         -


                  •  Sampling interior windowsills and troughs
                     - Cap the tube
                     - Label the tube properly.
                     - Measure and record the dimensions of the
                       selected sampling area.  Discard the gloves
                       into a trash bag then close the bag.
3-29
Special Considerations for Interior Windowsills and Troughs
Sampling Procedure for Windowsills and Troughs:
•Fold the wipe again with the sample side folded in, and insert the folded wipe into the tube and cap it.
•Label the tube with sufficient information to uniguely identify the sample.
•Measure and record the dimensions of the selected sampling area (the area actually wiped during
sample collection). Discard the gloves into a trash bag.
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Model Certified Lead Dust Sampling Technician Training Course
                                   a
                                                                    3-30
Note how the lead dust sampling technician is holding the wipe and moving across the windowsill.
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Model Certified Lead Dust Sampling Technician Training Course
                                     a
                                                                       3-31
Here is an example of how to sample a window trough. The trough is not taped because its area is less
than 16 inches, so sample the entire trough and determine its area. Measure carefully and down to 1/8 of
an inch.  Make sure the window trough has been adequately cleaned before sampling.
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Model Certified Lead Dust Sampling Technician Training Course
                                                                 3-32
                         5:              the


               Measure width and length (unless template was
               used). Area must be at least 16 square inches
               (2 inches by 8 inches). Measure to 1/8 inch.
               Measure exact area after sample is taken.
               - Length of sill or trough between inside edges of tape
               - Tape across width of sill or trough (front to back)
               Do not remove tape until after measurements
               are taken.
Step 5: Measure the Sample Area
If a template was used, record the dimensions of the template on the lab collection form. If a template
was not used, you must measure the sample area.
     Measure the exact length and width of the sample area with a tape measure after the dust sample
     has been taken. This allows you to get an accurate measurement without contaminating the
     sample area.
     Make sure you measure the area inside the tape, not the outside border.
     Always measure to an eighth of an inch (1/8"). Sloppy measurement can produce inaccurate
     results.
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Model Certified Lead Dust Sampling Technician Training Course
                         Measuring Window Sill
                                33
When the wiping is done, measure the area wiped, unless you used a template and know the dimensions
already. Measure the length and width of the area wiped.

Note: The ruler does not have additional space between where the measurements begin and the edge of
the ruler.
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Model Certified Lead Dust Sampling Technician Training Course
                                                                   3-34
                       6:                             on



               •  Record measurement on sample collection form and
                  lab chain-of-custody form.
               •  Calculate area outlined by the tape and record on
                  the sample collection form and lab chain-of-custody
                  form.
               •  In some cases, conversion from inches to feet will
                  be necessary. To make these calculations easier,
                  measurements should always be converted from
                  fractions to decimals (e.g., 0.5 rather than 1/2).
               •  Check with analytical laboratory for additional
                  recording requirements.
•See Attachment 3-A: Sample Collection Form and Attachment 3-B: Completed Sample Collection
Form.
•Instructors should pull out Attachment 3-C: Worksheet for Performing Mathematical Calculations
from Fractions to Decimals and review with the class.  A few simple calculations for the class may be
very useful.
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                                                                       3-35
                           7:           Up

                  •  Clean template with a clean sampling wipe;
                     place template in a plastic bag for storage.
                  •  Remove materials from site:
                      - Gloves, tape from floors and windows, used shoe
                        covers
                      - Put items in plastic bag, NOT in client's containers
                  •  Clean clothing and remove shoe covers before
                     leaving the work area.
                  •  Clean face and hands with warm,  soapy water
                      - Use sanitary wipes if no access to warm, soapy water
Step 7: Clean Up
Sampling materials may be contaminated and therefore must be cleaned or removed from the site.
     Clean the template with a clean wipe and place it in a re-sealable plastic bag for storage. This
     decontaminates the template between uses and helps avoid contamination when it is not being
     used. Throw wipe away in trash bag.
     Be sure you have recorded the location and dimensions of the sample area before removing tape.
     Remove gloves, tape, and shoe covers. Throw them away in trash bag.
     Clean face and hands with warm, soapy water. (Use sanitary wipes if no access to warm, soapy
     water.)
Refer to the Lead Dust Sampling Technician Field Guide and Attachment 3-D: Lead Dust Wipe
Checklist, which summarizes all the steps just described.
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Model Certified Lead Dust Sampling Technician Training Course
                                                         3-36
                                            Try It
             •  You are now going to practice taking dust
               wipe samples.
             •  Each individual must demonstrate
               proficiency.
             •  Follow your instructor's directions for
               taking samples.
             •  You can refer to your Field Guide or
               Attachment 3-D for a list of key steps.
Activity: Take samples on a variety of surfaces - window/sills, troughs, and floors.
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                                                                        3-37
                  •   These common mistakes can give
                      incorrect results:
                       - Incorrect measurement
                       - Contaminated wipe
                       - Contaminated gloves
                       - Sample area is disturbed
                       - Sloppy recording
If the lead dust sampling technician makes any of the following common mistakes, the technician could
get incorrect results:
Incorrect measurement. Small mistakes in reading the tape measure can produce misleading results.
Being off by half an inch can make the difference between passing or failing the EPA/HUD standards for
lead in dust.
Wipe is contaminated. It is important that the wipe is clean before you collect the sample and that you
do not lose any dust before putting the wipe in the tube. Common sources of contamination include the
following:
  •  Wipe touches the floor or window before you place it in the tube.
  •  Wipe falls to the floor before wiping and you do not get a new one.
  •  Wiping motions go beyond the template outline or taped area, collecting added dust or debris.
  •  Wipe is placed on the floor or interior sill while unscrewing the tube cap, collecting dust.
Gloves are contaminated. The gloves can contaminate the sample  if they are not clean.
  •  Gloves are put on too early and you touch dust on other surfaces.
  •  Gloves are not changed for each sample. Previously used gloves can carry lead dust from the
    previous sample.
Sample area is disturbed. Contamination may remove or add lead dust to sample area before you wipe
the area. The lead dust sampling technician should  select a new area to sample.
  •  Place hand or tape measure inside sample area before you wipe it.
  •  Place hand inside sample area while taping down template to the floor.
  •  Slide template across sample area as you tape it down.
  •  Use template that has not been cleaned.
Sample area is recorded incorrectly. To avoid errors:
  •  Record measurements for interior sills and troughs immediately after measuring the area.
  •  Review forms before you submit them to double-check measurements.
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                                                       3-38
               How Did It Go?

              • Would you  like to review and
                practice any of these steps again?
              • Are you ready to do this on your
                own?
When you are done sampling, discuss these questions with the large group.
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                                                                       3-39

                     In composite sampling, samples are collected
                     from common components in different rooms
                     and analyzed as one.
                     You may receive a request to take a composite
                     sample during lead dust clearance testing.
                     Analytical laboratories often have difficulty
                     processing composite samples. Contact your
                     laboratory before taking any composite samples.
EPA allows composite samples during lead dust clearance testing. You may receive a request to take a
composite sample during lead dust clearance testing. HUD discourages composite sampling for
clearance. Analytical laboratories often have difficulty processing composite samples.  Contact your
laboratory before taking any composite samples.

A composite is a sample that holds up to four dust wipes in one container. Each wipe is called a
subsample.
A composite tells you the average amount of lead dust across all the areas you sampled. This provides a
measure of average exposure. Subsamples need to be collected from areas of equal size for the results
to be an average.
In contrast to single wipe samples, composite samples do not define the location of lead dust, if it exists.
Rather, they simply identify that lead dust exists somewhere in the sampled area.
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                                                                         3-40
                             for a
                    Measures average amount of lead dust on several
                    surfaces (up to 4) of the same type.
                    -  Sample container holds up to 4 dust wipes
                    -  Do not use more than 4 wipes.
                    -  Do not mix samples from different types of surfaces.
                    Sample equal areas with each wipe, and use
                    tern plates where possible.
                    Interior sills or troughs: use smallest sill or trough
                    to set area
Make sure the areas sampled for each of the subsamples are the same size. If you include wipes that
    collected dust from areas with varying sizes, you will not get an accurate reading of the average
    levels. This should not be a problem if templates are used.
          Floors. Use a 12" x 12" sample area. Use a template or tape outline.
          Interior windowsills and window troughs. Identify the smallest interior windowsill and/or
          trough you plan to sample. Measure the length and width after you lay down the template or
          tape and take the dust sample. Use these measurements to outline the same sample area for
          all of the other interior sills and/or troughs. This will guarantee that all the interior sills or
          troughs sampled are the same size.
Do not combine subsamples  across units. A composite sample can only include dust wipes from a single
    unit. Do not use more than four wipes in a composite sample. It is difficult for labs to analyze
    composites holding more than four wipes.  Check that your lab has experience analyzing composite
    wipes.
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Model Certified Lead Dust Sampling Technician Training Course
                                                                     3-41
               •  Outline all areas to wipe for composite before
                  collecting sample.
               •  Use a new wipe for each subsample.
               •  Follow single wipe sampling procedures.
               •  Use a separate chain of custody form for each
                  composite sample.
               •  It is not necessary to change gloves between
                  subsamples.
•Whenever possible, use a template when collecting composite samples. If a template is not available,
outline the areas you plan to wipe before collecting the subsamples. Remember that the sample size
must be the same for all subsamples included in a composite sample.
•Use a separate wipe for each subsample area wiped.
•Follow the single-wipe sampling procedures.
•You can use one set of gloves for all subsamples in the composite. However, if your glove touches an
area outside the sample area, put on a new one.
•After wiping each subsample area, carefully place the wipe into the tube.
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Model Certified Lead Dust Sampling Technician Training Course
                                                     3-42
              •  Hand washing
              •  Face washing
              •  Check your clothing and shoes
                (especially soles) before leaving
                work site
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Model Certified Lead Dust Sampling Technician Training Course
              • Planning sampling locations and supplies
              • Where and when to take dust wipe
                samples
              • Steps in taking a dust wipe sample
              • Single-surface and composite sampling
              • Clean up after sampling
                                                        3-43
3-43                          October 2011

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                   Attachment 3-A: Sample Collection Form
                        Field Dust Wipe Sampling Form
Name of Sampling Technician:

Name of Property Owner: 	

Property Address: 	
Apt. #:
Sample
Number









Room and Location
(name of room used by owner)









Surface
Type*
(circle one)
FL WS WT
FL WS WT
FL WS WT
FL WS WT
FL WS WT
FL WS WT
FL WS WT
FL WS WT
FL WS WT
Dimensions
of Sample
Area
(in x in)









Area
(ft2)









* Surface types FL = Floor; WS = Windowsill; WT = Window Trough

Total number of samples on this page:	
Chapter 3
              Attachments

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              Attachment 3-B: Completed Sample Collection Form
                        Field Dust Wipe Sampling Form
Name of Sampling Technician:   Jane White
Name of Property Owner:   Smith Family
Property Address: 78 East Main St., Hammond, IN 89898
Apt. #:  25
Sample
Number
98-1
98-2
98-3
98-4
98-5
98-6



Room and Location
(name of room used by owner)
Upstairs Ig bedroom - near
doorway
Upstairs Ig bedroom - selected
window in room on west side of
room
Upstairs sm bedroom - in center
of room
Upstairs sm bedroom - only
window in room
Kitchen - near stove
Kitchen - above sink



Surface
Type*
(circle one)
FLWSWT
FLWSWT
FLWSWT
FLWSWT
FLWSWT
FL WS WT

FL WS WT
FL WS WT
FL WS WT
Dimensions of
Sample Area
(in x in)
11V x 12V
2315/16" x 2 V
nu/16"xi2V
24V x 3V
n3/4" x 11 V
239/16" x 3"



Area
(ft2)
.979
.478
1.025
.544
.928
.491



* Surface types FL = Floor; WS = Windowsill; WT = Window Trough

Total number of samples on this page:	6_
Chapter 3
              Attachments

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       Attachment 3-C: Worksheet for Performing Mathematical Calculations
                             from Fractions to Decimals

When recording the sample area on the dust wipe collection form, you may need to perform one
or both of the following conversions: converting fractions to decimals and converting inches to
square feet. To facilitate the mathematical calculations, fractions should always be converted to
decimals first. Refer to the following Table of Common Conversions for assistance.

1.     Converting Fractions to Decimals: Table of Common Conversions
Fraction
1/8
2/8
3/8
4/8
5/8
6/8
7/8
Decimal
0.125
0.250
0.375
0.500
0.625
0.750
0.875
Fraction
1/4
2/4
3/4
Decimal
0.250
0.500
0.750
2.     Converting inches to square feet (ft2)
If the area you sampled was not a square foot, you will need to convert it to this dimension. One
foot equals 12 inches, and 1 square foot equals 144 square inches.
*     Record the sample area in inches (in) as opposed to feet (ft).
*     Convert the sample area to square inches (in2). Round the number to a maximum of three
       decimal places.
*     Divide the square inches by 144 to get square feet (ft2). Round the number to a maximum
       of three decimal places.
Dimensions of sample area in inches (in)

Multiply length times width to calculate the area in
square inches (in2)

Divide the area in square inches (in2) by 144 to
calculate the area in square feet (ft2)

Length: in Width: in

in x in = in2

in2 -144 = ft2

3.     Example: Convert an area with length of 20 !/2 inches and a width of 5 % inches to
square feet.
*     Convert fractions to decimals:         20 !/> in —ป 20.500 in 5 % in —ป  5.250 in
*     Calculate the area in square inches:     20.500 in x 5.250 in = 107.625 in2
*     Calculate the area in square feet:       107.625 in2 - 144 = 0.747 ft2
Chapter 3
Attachments

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             Attachment 3-D: EPA Lead Dust Wipe Checklist
These are the steps involved in taking a lead dust wipe sample. When you are collecting dust
samples, you should follow each of these steps.  Note: The procedure for sampling floors is
different than the procedure for sampling windowsills and troughs.
Step
1.


2.



3.
4.
4a.



4b.



4c.





4d.





5.

Criteria
Put on disposable shoe covers and lay out the sample area
• Clean the template and properly dispose of wipe
• Tape down template; or lay out sample area using tape
Prepare the tubes
• Label tube with identification number
• Record identification number on sample collection and chain-of-custody forms
• Partially unscrew cap of tube and place tube near the area planned for sampling
Put on clean gloves
Wipe sample area and place wipe in centrifuge tube
First swipe (floors):
• Press wipe down firmly
• Make overlapping "S"-like motions on the sample surface while moving side-to-
Side
• Do not cross outer boundary tape or template
Second swipe (floors):
• Fold wipe in half, keeping dust inside, and press wipe down firmly
• Make top-to-bottom overlapping "S"-like motions
• Do not cross outer boundary tape or template
Third swipe (floors):
• Fold wipe in half, keeping dust inside, and press wipe down firmly
• Repeat the wiping procedure one more time (focusing in on corners)
• Do not cross outer boundary tape or template
• Fold wipe again, keeping all dust inside wipe
• Place wipe in sample container tube
Windowsills and troughs (side-to-side)
• Hold fingers together, wipe surface in one direction, and press wipe down firmly
• Fold wipe in half and repeat wiping procedure, using a reverse direction
• Fold wipe in half again and repeat wiping procedure concentrating on corners
• Fold wipe in again and insert into a rigid-walled container
• Label the rigid-walled container to identify sample
Measure the sample area
• Measure the area inside the tape, not the outside border
V































Chapter 3
Attachments

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6.



7.




• Measure to V8 inch
Record sample area
• Calculate sample area
• Record measurements on the sample collection form
• Fill in chain-of-custody form
Clean up
• Clean template with new wipe, place template in a plastic bag for storage, and then
discard wipe
• Put gloves, used shoe covers, and tape from floors and windows into trash bags
• Check your clothing and shoes (especially soles) before leaving work site
• Wash your face and hands with warm, soapy water or sanitary wipe










Chapter 3
Attachments

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Chapter 4: Selecting a Laboratory

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INSTRUCTOR
NOTES
CHAPTER 4: SELECTING A LABORATORY
          AND INTERPRETING RESULTS
Objectives:
Introduction to this
chapter:
Activities:
Review:
The major objective of this chapter is to teach students to understand
the role of the laboratory and what to look for when they select a
laboratory. Specific objectives are the following:
• Selecting a laboratory recognized by EPA for analysis of lead
in dust
• Maintaining a chain of custody
• Reviewing lab results
This chapter is designed to demonstrate to students how to select the
appropriate lab for their projects and what they should do with
laboratory results.
There is one activity in this chapter, an exercise on interpreting lab
results.
Exercise: Interpreting Lab Results
Description: This exercise provides sample lab results and asks
students to check the math in the lab results and determine whether the
sample passed or failed the lead dust clearance testing.
Materials: The exercise is in the student manual as Attachment 4-D.
The answer sheet for this exercise is provided as an attachment to
these notes.
Steps:
1 . Slide 4-11 instructs students to turn to Attachment 4-D:
Activity — Interpreting Laboratory Results.
2. Instruct the students to answer the questions on the worksheet.
Give them time to complete the activity. They can work
individually or in small groups.
3. Go through the questions one at a time, demonstrating the
calculations and reasoning required to answer each question.
4. Ask students what mistakes led to incorrect answers and what
they think are the most important lessons to learn from the
worksheet.
See Slide 4-13 for this chapter's review topics. Be sure to answer all
student questions about the material before moving on to the next
chapter.

  Lead Dust Sampling Technician
    4-i
Chapter 4

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Notes:
The chapter also includes resources for students to use in performing
measurement conversions, which many students may find difficult.
Direct them to Attachment 4-C: Worksheet for Performing
Mathematical Conversions for Dust Samples for additional
resources to help with these potential problems.
  Lead Dust Sampling Technician
                       4-ii
Chapter 4

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ANSWERS—ACTIVITY: INTERPRETING LABORATORY RESULTS
(ATTACHMENT 4-D)

Instructions: The purpose of this activity is to test your ability to verify the results received from
the laboratory, compare these results to EPA dust clearance standards, and interpret the results.
Using the following excerpt from a lead dust clearance test results form, check the laboratory's
calculation of the dust lead loading.
Sample #
92-1
92-2
92-3
92-4
Location
Upstairs
bedroom
Upstairs
bedroom
Kitchen, front
window
Kitchen, side
window
Surface
Floor
Interior
windowsill
Interior
windowsill
Window
trough
Dimensions
of Sample
Area (ft2)
1.025
0.478
0.544
0.928
Total Lead
(us)
23
150
260
97
Jig/ft2
22.4
71.7
477.9
90.0
1.     Check the results (|ig lead/ft2) for each sample.  If the results are incorrect, provide the
       correct results in (ig lead/ft2.

               92-1: 23/1.025 = 22.4 jig/ft2 is correct
               92-2: 150/0.478 = 71.7 jig/ft2 is incorrect (313.8 jig/ft2 is the correct result)
               92-3: 260/0.544 = 477.9 jig/ft2 is correct
               92-4: 97/0.928 = 90.0 jig/ft2 is incorrect (104.5 jig/ft2 is the correct result)
2.     After verifying the laboratory's results, compare these results to the appropriate EPA
       recommended guidance. Did the individual samples pass or fail the lead dust clearance
       test?
92-1: Result 22.4 us/ft2

92-2: Result 313.8 ne/fi2

92-3: Result 477.9 ug/ft2

92-4: Result 104.5 fig/ft2

Clearance Standard: 40 fig/ft2

Clearance Standard: 250 fig/ft2

Clearance Standard: 250 fig/ft2

Clearance Standard: 400 ^/ft2

Pass or Fail? Pass

Pass or Fail? Fail

Pass or Fail? Fail

Pass or Fail? Pass

Lead Dust Sampling Technician
4-iii
Chapter 4

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Model Certified Lead Dust Sampling Technician Training Course
                                                             4-1
                                          4

                                    a
                        and
4-1                              October 2011

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Model Certified Lead Dust Sampling Technician Training Course
                    •  Select an  EPA-recognized lab
                    •  Maintain a chain of custody
                    •  Review and  interpret lab results
After performing lead dust wipe sampling, you will need to submit the samples to a laboratory for analysis
and interpret the laboratory results to determine the levels of lead dust in a unit. This chapter describes
the steps you will need to take.
At the end of this chapter, you will be able to do the following:
     Select an EPA-recognized laboratory and explain why proper selection is important
     List the important steps to ensure samples are not tampered with or lost, maintaining a chain of
     custody
     Review and interpret the laboratory results
4-2                                  October 2011

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Model Certified Lead Dust Sampling Technician Training Course
                                                                        4-3
                                    a
                    •  Submit samples to a lab recognized by
                       EPA's National Lead Laboratory
                       Accreditation Program (NLLAP)
                    •  To locate a lab
                       - Call the National Lead Information Center
                          (NLIC)at1-800-424-LEAD
                       - Visit the EPA Web site at
                          www.epa.gov/lead/pubs/nllap.htm
                    •  See the fact sheet "Selecting a Lead
                       Laboratory" at  the end of this chapter.
All samples must be submitted to a laboratory recognized by the EPA's National Lead Laboratory
Accreditation Program (NLLAP) to be proficient in lead in dust analysis.
     The NLLAP provides the public with a list of recognized laboratories for analyzing lead in dust
     samples. You can contact the National Lead Information Center (NLIC) Clearinghouse at 1-800-
     424-LEAD, or visit the EPA Web site at www.epa.gov/lead/pubs/nllap.htm for an up-to-date list of
     NLLAP-recognized laboratories. A technical bulletin entitled Selecting a Laboratory for Lead
     Analysis: The EPA NLLAP, EPA 747-G-99-002, April 1999, is also on the EPA Web site.
     For a laboratory to become EPA-NLLAP recognized, it must participate in the Environmental Lead
     Proficiency Analytical Testing (ELPAT) Program and undergo a quality system audit, including an
     onsite assessment by a laboratory outside accreditation body participating in the NLLAP, such as
     the American Industrial Hygiene Association.
It is important to recognize that not every recognized laboratory will  meet your needs. Taking the time to
select a good laboratory will save you time and effort in the long run. Knowing the costs associated with
laboratory supplies and the analysis will also help you calculate the  fees you will charge customers. Even
if your company has selected a laboratory for you to work with, it is a good idea to ask a few simple,
straightforward questions so you can find out whether the laboratory meets some basic quality criteria.

See Attachment 4-A: Questions to Ask Laboratory
4-3                                   October 2011

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Model Certified Lead Dust Sampling Technician Training Course
                              To

               • Tell the lab you will be collecting dust wipe
                 samples for lead.
               • Ask:
                  - Is the laboratory recognized to analyze for lead
                    in dust by NLLAP?
                  - Will sampling materials be provided?
                  - What is the turnaround time for analysis?
                  - Can the laboratory analyze composite samples?
                    (If the client wants composite samples)
                  - What is the cost per sample?
Review Attachment 4-A: Questions To Ask Laboratory.
4-4                               October 2011

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Model Certified Lead Dust Sampling Technician Training Course
                                      in the

                 •  Submit blank wipe samples.
                 •  Duplicate, or side by side sampling
                   can be used to check  lab
                   consistency.
                 •  Review all of your sample collection
                   and chain-of-custody forms.
                 •  Carefully review all lab results.
Lead dust clearance testing and analysis require a great deal of care and precision by both you and the
laboratory. Follow the steps above to help control the quality of the lab results. Each step is discussed in
further detail on the following slides.
4-5                             October 2011

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Model Certified Lead Dust Sampling Technician Training Course
                   •  Confirm all information is recorded
                      clearly and correctly.
                      - Sample numbers
                      - Sample locations
                      - Sample dimensions
                   •  Keep a copy for your records and
                      note blanks.
                                                                    4-6
In Chapter 3, we described how to record sample information on the sample collection form clearly and
accurately. Before you send the samples to the laboratory, you should check your sample collection form
to confirm that all of the following information is recorded clearly and correctly.
     Sample numbers - Samples should be numbered sequentially, in the order you took them. (This
     information must be included accurately on the laboratory chain-of-custody form.)
     Sample locations - These should be precise. For example, "left window on back wall in master
     bedroom" is better than "bedroom window."
     Sample dimensions for dust wipe samples - As discussed in Chapter 3, these dimensions are
     extremely important and should be recorded to the nearest 1/8 of an inch.
After completing the form, it is essential that you keep a copy for your records and to note the ID numbers
of your blank samples.
4-6                                  October 2011

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Model Certified Lead Dust Sampling Technician Training Course
                                                                        4-7
                               of
                       A record of each person who handles the
                       sample from the time it is collected until it is sent
                       to the lab.
                       The lead dust sampling technician is
                       responsible for maintaining chain of custody
                       until he or she transfers custody of the samples.
                       Include information on sampling form
                       A sample Chain of Custody form is shown on
                       the next page, and as an attachment to this
                       chapter.
It is important that samples are not lost before or during the analysis process. To trace the path of the
sample, you should establish a "chain of custody." This simply means that every person who handles the
sample must sign and date a form.
Who is in the chain of custody? People in the chain of custody may include:
     Lead dust sampling technician
     Technician's supervisor
     Person packing the samples for shipment
     Person picking up and shipping the samples
     Person receiving the shipment at the laboratory
Maintaining the chain of custody - Ensure that the chain of custody is maintained from when you take
the samples until you transfer custody of the samples.
     Space for documenting the chain of custody may be included as part of the sample collection form
     or you may use a separate form. There should be enough space for each individual handling the
     sample to sign and date the form - 5 to 7 lines should be sufficient.
     You should also keep a copy of any shipping or mailing forms documenting when the samples were
     sent to the laboratory.
     You should send the package with delivery confirmation and return receipt requested, or the
     equivalent shipping record.
4-7                                   October 2011

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Model Certified Lead Dust Sampling Technician Training Course
This form appears at the end of this chapter.
4-8
October 2011

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Model Certified Lead Dust Sampling Technician Training Course
                                                                      4-9
                                                               for


                    •  Check for appropriate units (ing/ft2)
                    •  Compare results to the EPA/HUD
                      clearance standards for lead dust:
                       - Floors < 40 |jg/ft2 passes
                       - Sills < 250 |jg/ft2 passes
                       - Troughs < 400 ug/ft2 passes
When you receive the results from the laboratory, you must interpret them to determine whether they
pass or fail clearance. This section describes dust lead hazards and the process used to evaluate the
sample results. Specifically, you will need to evaluate the laboratory results, converting them if necessary,
and comparing them to the Federal or State standards.
To evaluate the laboratory results, you may need to take the steps listed below. These steps should be
implemented as follows:
  Step 1: Check the units. If results are not reported in ng/ft2, use the conversion table (see
  Attachment 4-C: Worksheet for Performing Mathematical Conversions for Dust Samples).

  Step 2: Compare the results to the EPA clearance standard for lead dust. Once you have  made
  the necessary conversion, you can compare the laboratory results to the appropriate EPA clearance
  standard for lead dust. EPA clearance standards have been developed for lead dust on floors,  interior
  windowsills, and window troughs. It is important to recognize that the levels for lead dust are different
  for each of these three surfaces. If test results equal or exceed the standards, the unit, worksite, or
  common area represented by the sample fails the dust clearance test.
4-9                                   October 2011

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Model Certified Lead Dust Sampling Technician Training Course
               •  Turn to Attachment 4-D

               •  Answer the questions.

               •  Be prepared to explain your
                 answers.
                                                    4-10
4-10                         October 2011

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Model Certified Lead Dust Sampling Technician Training Course
                                                                       4-11
                                                                for
                 Location
2 Subsamples  3 Subsamples  4 Subsamples
Floors
Sills
Troughs
40 |jg/ft2
250 |jg/ft2
400 |jg/ft2
27 |jg/ft2
167 |jg/ft2
267 |jg/ft2
20 |jg/ft2
125|jg/ft2
200 |jg/ft2
Composite samples determine the average of the dust lead levels on the surfaces that make up the
composite.
To minimize the chance that any individual surface included in the composite does not fail clearance,
composite samples that contain more than two Subsamples are compared to more stringent standards
than are single-surface samples.
4-11
       October 2011

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Model Certified Lead Dust Sampling Technician Training Course
                                                                    4-12
               •  Mistaking weight (mass) for surface
                 loading by  using incorrect units  (u.g for
                 ng/ft2)

               •  Not submitting blank samples
                  - Labeling or recording in the sample log blank
                    samples as blanks

               •  Not maintaining a chain of custody
Listed above are some common mistakes you might make while performing any of the activities listed on
the previous slide.
     Mistaking the units. One common mistake is not understanding the units of measurement
     provided in the lab report. When the results come from the laboratory, check whether they are
     provided in ng or ng/ft2. If they are in ng, you must convert them to ng/ft2 before recording them on
     your report and interpreting results. Discuss with your laboratory how results are reported.

     Failing to submit blank samples. Another common mistake is not submitting  blank samples.
     Without this mechanism, you have no way of verifying if the laboratory results were
     uncontaminated, or that you used good sampling techniques. Submit one blank sample for every
     unit sampled.

     Failing to maintain the chain of custody. This is your only mechanism to track the handling of the
     sample. The chain-of-custody form must  be maintained from the time you take the dust wipe
     sample until you transfer custody. Re-sampling is recommended if this document is not maintained.
4-12                                 October 2011

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Model Certified Lead Dust Sampling Technician Training Course
                                                       4-13
                •  Select an EPA-recognized lab.
                  -Call 1-800-424-LEAD
                  - Visit www.epa.gov/lead/pubs/nllap.htm
                  - Ensure that the lab is EPA-recognized
                    for the analysis of lead in dust.
                •  Maintain a chain of custody.
                •  Interpret lab results.
4-13                          October 2011

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                       Attachment 4-A: Questions to Ask Laboratory
Is the laboratory recognized
by NLLAP?
All samples must be analyzed by an NLLAP laboratory. You can
contact the NLIC Clearinghouse at 1-8QO-424-LEAD for an up-to-date
list of NLLAP-recognized laboratories. Even after selecting a laboratory,
you should check the laboratory's accreditation every 6 months.
What is the turnaround
time for sample analysis?
The laboratory turnaround time is an important factor; labs usually
provide results within 1 to 3 days. A faster turnaround time allows you to
be more responsive to your client but may cost more money.
What is the cost per sample?
Prices can vary depending on how quickly you want the results. A 6-
hour turnaround will cost more than samples analyzed over a few days.
Will the laboratory provide
sampling materials?
Some laboratories will provide you with the materials necessary to
perform sampling. You may want to select a laboratory that provides
these materials because laboratory-supplied materials and forms can help
minimize potential errors in the analysis and recordkeeping.
Can the laboratory analyze
composite samples?
It is good practice to check in advance the laboratory's capabilities in
analyzing composite samples, if your client wants you to collect
composite samples. Some laboratories do not offer this service.
Does the laboratory perform
all the necessary
mathematical calculations?
The Federal guidance is provided in (ig/ft2. Depending on the size of the
sample or sample area, some mathematical calculations may need to be
performed to convert the sample area to 1 square foot. Selecting a
laboratory that will perform this calculation for you can reduce the
possibility of mathematical errors.
Chapter 4
                                                     Attachments

-------
Blank Chain of Custody Form

-------

Project Name
Submitting Co,
Special Instructions (include requests for special reporting or data packages]
Project Location:
Project Nymber:
Pyrehase Order No,; STATE SAMPLES COLLECTED

Turn Amtmd Time
; day"
; 1 business day*
[ '2 business days8
I 3 business days'
[ STANDARD 18 bus- days]
( Standard Full TCLP \ 10d)
* not avai/aiwe fot a// t&sts
Jป.t,lซ S ปซซปซป<ป*ป lr> .->ปป,•ป,ปซ.

Sample tf










Date
Sampled











Matrix / Sample Type {Select ONE) Testa 1 Ana ytes (Select ALL that Aooly)
All samples on form should be of SAME Asbestos Air 1 Fibei Counts As >estos Bulk •' Ash ID
matih type . Use additional foims a-s n&xteo' PCM (NIGSH 7400: [ ]PLW>ฃrA6CQ 19g'2;
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) Aqueous f [Waste TEM (EPA Level fit [ ] Pt-M (Qualitative only!
] Bulk ( ] \Atestewater I ] NT E LAP 19S M 4' &
' ) HI-Vol Finer (PM10I ( ] Water.Drinking Miscellaneous Tests [ ] CAEtAP ..EPA Interim >
') HI-Vol Filter (TSP) ( ] Compliance To al Dust (MIOSK 0500) [ ] TEM (Chatfies.Ji
|OII I ]Vylpe Resp DtiStjNIOSHOSOO) | I
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1] Silica - XRD (N)OSh /500; TYPE OF RESPIRATOR
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Mefate-Extraet
TCLP ,' Lead
TCLP / RCRA Metals
TCLP / Full i'.v/orgaracs:

Organic^ Wipes Information lor Air Samples Organicฎ
Time
Sampled










Sample Identifica! on
(e.g. Employee. SSN, Bldg. Material)










Sample Collection & Custody Information
Sampled by
Relinquished
Received in Is
( ]FX [ ]DHL
Unusual Sample
[NAME] [SIGNATURE)
to lab by[N/
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Type'
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Start










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OR6ANICS TESTS and other Analyses
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-------
Attachment 4-C: Worksheet for Performing Mathematical Conversions for Dust Samples
Unit of Measurement
Inches
Square inches
Feet
Square feet
Symbol
in
in2
ft
ft2
Unit of Weight
Micrograms
Micrograms per square foot
Symbol
US
ng/ft2


     1. Convert the sample area to square feet (ft2)
     If the area you sampled was not a square foot, you will need to convert it to this dimension.
     One foot equals 12 inches, and 1 square foot equals 144 square inches.

     •   Record the sample area in inches (in) as opposed to feet (ft).

     •   Convert the sample area to square inches (in2). If you have a decimal, round the number to
         three decimal places.

     •   Divide the square inches by 144 to get square feet (ft2). If you have a decimal, round the
         number to three decimal places.
Dimensions of sample area in inches (in)
Multiply length times width to calculate the area
in square inches (in2)
Divide the area in square inches (in2) by 144 to
calculate the area in square feet (ft2)
Length: in Width:

in x in = in2

in2 -144= ft2

in



     2. Convert the results to micrograms per square foot (ug/ft2)

     After you have converted the sample area to square feet, you need to find the amount of lead dust
     contained in that area. The micrograms per square foot (|ig/ft2) describe the quantity of lead dust
     contained in a 1 square-foot area.
                                                 r\
     •   Divide the amount of lead (jig) by the area (ft).
Dimensions of sample area in square feet (ft2)
Quantity of lead in micrograms (jig)
Divide micrograms (jig) by square feet (ft2) to
Area = ft2
Lead = jig

Ug - ft2 =

ng/ft2

-------
               Attachment 4-D: Activity — Interpreting Laboratory Results

Instructions: The purpose of this activity is to test your ability to verify the results received
from the laboratory, compare these results to the EPA dust clearance standards, and interpret the
results. Using the following excerpt from a lead dust clearance test results form, check the
laboratory's calculation of the weighted lead dust sample.
Sample #
92-1
92-2
92-3
92-4
Location
Upstairs
bedroom
Upstairs
bedroom
Kitchen, front
window
Kitchen, side
window
Surface
Floor
Interior
windowsill
Interior
windowsill
Window
trough
Dimensions
of sample
area (ft2)
1.025
0.478
0.544
0.928
Total lead
fog)
23
150
260
97
Hi/ ft2
22.4
71.7
477.9
90.0
1.      Check the results (|ig lead/ft2) for each sample. If the results are incorrect, provide the correct
       results in (ig lead/ft2.

2.      After verifying the laboratory's results, compare these results to the appropriate EPA lead dust
       clearance standard. Did the individual samples pass or fail the lead dust clearance test?

                           EPA Clearance Standards for Lead Dust

                                      Floors: < 40 ug/ft2
                               Interior windowsills: < 250 ug/ft2
                                Window troughs: < 400 ug/ft2
92-1: Result

92-2: Result

92-3: Result

92-4: Result

Clearance Standard:

Clearance Standard:

Clearance Standard:

Clearance Standard:

Pass or Fail?

Pass or Fail?

Pass or Fail?

Pass or Fail?

Chapter 4
Attachments

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Chapter 5: Writing and Delivering the
              Report

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INSTRUCTOR
NOTES
               CHAPTER 5: WRITING AND DELIVERING
                                             THE REPORT
Objectives:
This chapter will teach students how to complete reports of their
lead dust clearance tests. By the end of the chapter, students will
be trained to:
    •  List the key contents of a lead dust clearance test report
Introduction to this
chapter:
In this chapter, students will learn to present their findings from
lead dust clearance tests to clients in a manner that is clear,
concise, and easy for untrained homeowners to understand.
Activities:
There is one exercise in this chapter.

Activity: Review a Blank and Sample Report (Attachment 5-
A and B)

Description: In this activity, take several minutes to review the
attached blank and completed dust sampling reports. Walk
through each section of the completed report and answer
questions as appropriate.
Review:
The review information for this chapter is included on Slide 5-7.
Notes:
Point out the handout Renovate Right: Important Lead Hazard
Information for Families, Child Care Providers and Schools in
Appendix B. Lead dust sampling technicians can refer clients to
this information.
Lead Dust Sampling Technician
                                                  Chapter 5

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Model Certified Lead Dust Sampling Technician Training Course
                                          5
                                   the
5-1                              October 2011

-------
Model Certified Lead Dust Sampling Technician Training Course
                 •  List the items that make up a
                    complete lead dust clearance test
                    report.


                 •  Make the report easy for the client
                    to understand.
At the end of the chapter, students will be able to:
     List the key contents of a complete lead dust clearance test report
     Describe ways to make the report easy to read
     Respond appropriately to questions that clients may ask upon receiving their report
5-2                               October 2011

-------
Model Certified Lead Dust Sampling Technician Training Course
                               Of

                 •  Cover Page
                 •  Summary of Sampling Results
                 •  Visual Inspection Results
                 •  Laboratory Analytical Results
                 •  Renovate Right Pamphlet
                    -  (Appendix B)
These are the six elements of the Lead Dust Clearance Test Report.
Blank forms that can be used for the Cover Page, Summary of Sampling Results, and Visual Inspection
Results are provided in Appendix B of this course.
A copy of the Renovate Right: Important Lead Hazard Information for Families, Child Care Providers and
Schools pamphlet is also included in Appendix B.
5-3                               October 2011

-------
Model Certified Lead Dust Sampling Technician Training Course
                       Of
            • Address of property and if multifamily,
             specific units and common areas affected
            • Date of clearance exam
            • Name, address and signature of person
             performing clearance including certification
             number
            • Visual inspection results
Because HUD has more extensive visual inspections requirements, than does the EPA rule, HUD
requires more information regarding the details of a lead dust clearance test report.
5-4                            October 2011

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Model Certified Lead Dust Sampling Technician Training Course
                        Of
            •  Dust sampling results
            •  Name and address of each laboratory that
               analyzed samples
            •  Start and completion dates of work performed
            •  Detailed written description of methods used
               during work and specific, detailed locations
               where work occurred
            •  If soil hazards are corrected, description of
               location.
Because HUD has more extensive visual inspections requirements, than does the EPA rule, HUD
requires more information regarding the details of a lead dust clearance test report.
5-5                              October 2011

-------
Model Certified Lead Dust Sampling Technician Training Course
                                  the

              • Refer to Attachment 5-A and 5-B

              • Review the blank and completed
                Lead Dust Clearance reports
5-6                         October 2011

-------
Model Certified Lead Dust Sampling Technician Training Course
               • The items that make up a complete
                lead dust clearance test report

               • How to make a report easy for a
                client to understand
5-7                         October 2011

-------
          Attachment 5-A:  Sample Lead Dust Clearance Test Report

The following report is a sample lead dust clearance test report from a small HUD
funded rehabilitation job (less than $5,000/unit) in a unit that involved window
replacements in the small bedroom and kitchen of a single-family home that is
available for rent. The lead dust clearance test report covers lead dust clearance
testing of the worksite.
                   LEAD DUST CLEARANCE TEST REPORT
                             General Information
Date of Lead Dust
Clearance Test:
Lead Dust Sampling
Technician:
Property Address:
Client Name and
Address:
Laboratory Name and
Address:
Telephone Number:
NLLAP Number:
8/5/09
Jane White
80 East Main St.
Hammond, IN 89898
Smith Family
80 East Main St.
Hammond, IN 89898
Analysis Services, Inc.
990 45th St., Suite 500
Gary, IN 44444
222-222-2222
IN 999999
                Summary of Lead Dust Clearance Test Results

 This unit failed the lead dust clearance testing portion of the lead dust sampling
 examination. Areas represented by the failed samples should be re-cleaned.

 Lead dust above HUD/EPA clearance standards was found in the following areas:
Location
Small bedroom
Small bedroom
Kitchen
Surface
Side facing window
(C- 1 ) — windo wsill
Floor
Window above sink
(A-l)~ windo wsill
ug lead/ft2
600
200
525
 Signature:
                             Date:

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                  Summary of Hazard Reduction Activities
Name of Firm
Address of Firm
Supervisor Name
Supervisor Certification Number
Start and Completion Date of
Hazard Reduction or Completion
Activity
ABC Renovations
123 Main Street
East Chicago, IN 12345
John Brown #1634
1634
8/4/09 to 8/5/09
      Description of Hazard Reduction Activities and Areas Addressed:
Location
Kitchen
2nd floor small
bedroom
Activity
Replaced A-l window with new, vinyl-clad window
Replaced C-l and C-2 windows with new, vinyl-clad
windows
Description of
work
The supervisor was present on the job site when work was
being performed. Workers used lead-safe work practices.
Plastic sheeting covered a 5-foot area on the ground outside
under the windows being replaced and on the floor inside.
Signs were posted at the doors to the bedroom and kitchen.
Occupants were not allowed in the kitchen and bedroom and
the outside work area during this activity. The window
frame was misted prior to tear-out. After removal, workers
wrapped the old windows in plastic sheeting and picked up
debris on the plastic immediately and bagged it. The plastic
sheeting was carefully gathered up and bagged for disposal.
Workers replaced their disposable booties when leaving the
work area for lunch and breaks. Respirators were not
necessary. The new windows were installed and a clearance
examination was requested.	

-------
                Part I. VISUAL INSPECTION RESULTS FORM
Date of Lead Dust
Sampling:
Lead Dust Sampling
Technician:
Client:
Property Address:
tlsw
fateTVfate
Swtit& ^amily
%0 StutTKciut St.
??wซw, IHIWM?
                     Visual Inspection of the Work Area
   Work Area
Deteriorated
   Paint
Debris
Visible
 Dust
Notes
Pass/
 Fail
Sxteiun
Sxteiun

-------
             LEAD DUST CLEARANCE TEST RESULTS FORM
Date of Lead Dust
Clearance Test:
Lead Dust Sampling
Technician:
Client:
Property Address:
XISIM
fateTVfate
St*ttf& "^tuftity
XO SattWal* St.
VfauHotul. tfltZWW
 Sample #
   Location
Surface
Dimensions
 of sample
   area
                                                     Lead/ft
                                                        2
Pass/Fail
1-2
                              4" % 1%"
                         wutdow&tfl
                         17
1-3
                              12"
                         200
1-4
                              4" % 1%"
                         wutdow&tfl
                         600
2-1
Second floon.

fatlCway, 3

fyiom newel fco4t
            12"
            35
3-1
                              12" %12
                        30
4-1
                              12"
                         12
4-2
                           '-/)-
                              4" % 1%"
                        525
5-1
                   ctoon.
                              12"
                        30

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     Exterior
     soil
FIRST FLOOR
     Kitchen/
     DR
1st floor
Bedroom
             Hall-
             way
              X Foyer
             Living
             Room
                                               X = sample
                                               locations

Large
Bedroom

/
Hall /
X
/
/
Bathroom



Small
Bedroom


•—
X X
                                          SECOND
                                          FLOOR
                                       Window
                                       C-l
                        Window
                        C-2

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                         Understanding Your Report

1.  The Summary Results section lists all of the areas that failed the lead dust
   clearance test. The areas represented by the sample needs to be re-cleaned to
   see if the cleaning removed the contaminated dust. Deteriorated painted
   surfaces should be repaired using interim controls or abatement techniques.
   For written information on how to address lead hazards, call the National Lead
   Information Center Clearinghouse at 1-800-424-Lead (1-800-424-5323). You
   may consider hiring a risk assessor to evaluate lead hazards in your home and
   recommend a lead hazard control plan. Risk assessors can be located through
   the Lead listing at 1-888-Leadlist (1-888-532-3547).
2.  The laboratory result forms attached to the report list the analyst, all of the areas
   sampled inside and outside the building and the laboratory analysis results for
   each sample.
3.  The lead dust clearance test results are expressed in  micrograms per square foot
   (fig/ft2); soil samples are expressed in micrograms per gram (fig/g).
4.  Areas that failed the lead dust clearance test showed dust lead levels above EPA
   clearance standards for lead dust. The guidance that was used during this lead
   dust clearance test is as follows:
                  EPA Clearance Standards for Lead Dust
                                                     i~t
              Carpeted and uncarpeted floors: < 40 ug/ft
              Interior window sill (stool): < 250 fig/ft2
              Window trough: < 400 ug/ft2

-------
Chapter 6: Putting the Skills Together

-------
INSTRUCTOR
NOTES
                    CHAPTER 6: PUTTING THE SKILLS TOGETHER
Objectives:
This chapter is designed to help students apply all of the information they have
been given in a hands-on activity. The objectives are as follows:
-  Demonstrate an understanding of the skills and information taught in the
   class:
   •   Choosing appropriate sampling location
   •   Taking lead dust samples
   •   Interpreting results
Introduction to
this chapter:
In this chapter, students will learn to put all the skills they have learned
throughout the day into practice.
Activities:
                    NOTE: HUD has different requirements than EPA for clearance.  Although
                    EPA's post-renovation clearance protocol is similar to HUD's allowed protocol
                    for worksite-only clearance, HUD has additional requirements to use this
                    sampling strategy. Although the sampling requirements are very important for
                    Federally-funded renovation activity, these units will represent a relatively
                    small percentage of all renovation projects performed nationwide.  Because
                    most of the renovation jobs that are expected to occur in U.S. housing will not
                    be funded with Federal housing assistance, details on HUD sampling are
                    provided in the HUD sampling appendix. In addition, the course includes a
                    HUD-specific Activity 1 and 3. Activity 2, Dust Wipe Sampling, is the same
                    regardless of the regulation. The HUD-specific Activities can be found at
                    Attachment 6-A and 6-B and the answer key is included at the end of these
                    notes.  All LDSTs should discuss sampling plans with the renovator before
                    work begins; with particular attention to whether the project is receiving
                    Federal housing assistance, so the proper sampling strategy can be used to
                    comply with the Lead Safe Housing Rule.

                    The activities outlined below are specific to the EPA RRP and will be
                    applicable for most training classes.

                    Activity 1: Where To Take Samples for Renovated Areas
                    Description: This exercise provides details of a home renovation and asks
                    students to determine which areas of the home need to be sampled as a result.
                    The answers to the four questions posed are included at the end of these
                    Instructor Notes. Students should take no more than 15 minutes to complete
                    this exercise. The next 10 minutes should be spent discussing the correct
                    answers with the class.

                    Materials: Home renovation description sheet with questions and home
                    diagram. These documents are provided in Attachment 6-A.

                    Activity 2: Dust Wipe Sampling
                    Description: In this exercise, each student will take a lead dust wipe sample
 Lead Dust Sampling Technician
                       6-i
Chapter 6

-------
                    following the protocol discussed in Chapter 3.

                    Put students into different groups than they were in the first time this activity
                    was performed in Chapter 3.  If a student was only able to sample a floor during
                    the first hands-on activity, make certain that he or she is put into a group that
                    will not be sampling floors again. It is imperative that the Instructor ensures
                    every student has become proficient at all areas of sampling, from Step 1:
                    Layout through Step 7: Cleanup. If any student is unclear on any step of the
                    sampling process or on a particular sampling area, such as a window trough,
                    this exercise is the time to remedy all concerns.

                    Materials:
                       •   Disposable lead dust wipes (individually wrapped)
                       •   Disposable gloves
                       •   Disposable shoe covers
                       •   Sample tubes with caps
                       •   Reusable templates (can be made or purchased)
                       •   Masking or painter's tape
                       •   Ruler
                       •   Sample collection forms
                       •   Chain-of-custody forms
                       •   Markers, trash bags, labels, pens, re-sealable storage bags
                       •   Calculator
                       •   Sanitary wipes

                    Note: To be effective, at most, a 6:1 student-to-teacher ratio is recommended.
                    The instructor may want to bring in additional qualified instructors to oversee
                    this activity.

                    Steps:
                    1.  Distribute sampling materials and a blank sample collection form to the
                       students.
                    2.  Divide students into groups of three or four individuals, depending on class
                       size.
                    3.  Using the templates and dust sampling materials, have each student practice
                       lead dust wipe sampling techniques and complete the blank sample
                       collection form.
                    4.  Encourage  students to take samples on a variety of surfaces - windowsills,
                       troughs, and uncarpeted floors.
                    5.  Go  to each of the groups and review the students' sampling, measuring, and
                       recording techniques. Correct any errors and answer any questions students
                       may have.
                    6.  Have students briefly discuss any problems they encountered and ask any
                       relevant questions.

                    Activity 3: Interpreting Laboratory Results
                    Description: This exercise provides sample lab results and asks students to
                    check the math in the lab results and determine whether the sample passed or
Lead Dust Sampling Technician
6-ii
Chapter 6

-------
                    failed the lead dust clearance testing.

                    Materials: The exercise is provided as Attachment 6-B. The answer sheet for
                    this exercise is provided as an attachment to these notes.
                    Steps:
                        1.
                       4.
       Turn to Attachment 6-B: Activity — Interpreting Laboratory
       Results.
       Instruct the students to answer the questions on the worksheet. Give
       them time to complete the activity. They can work individually or in
       small groups.
       Go through the questions one at a time, demonstrating the calculations
       and reasoning required to answer each question.
       Ask students what mistakes led to incorrect answers and what they think
       are the most important lessons to learn from the worksheet.
                    Activity 4: Translating Results into a Written Report
                    Description: This exercise uses the sample lab results from the previous activity
                    and translates the findings into a written report introduced in Chapter 5
                    (Writing the Report).

                    Materials: The exercise is provided as Attachment 6-C. An example of the
                    completed report is provided below.
                    Steps:
                        1.
                       4.
       Review Chapter 5 and the six elements of the written report, if
       necessary.
       Turn to Attachment 6-C: Activity — Translating Results into a
       Written Report
       Instruct the students to use the results from the previous activity
       (Interpreting Laboratory Results) and complete the report as shown
       in Chapter 5.
       Review the completed report and address any issues.	
Review:
Review Chapter 5 (Writing the Report) in order to re-familiarize yourself with
the requirements of the written report.
Notes:
There are a number of useful resources included in Appendices B and C.
Encourage students to look over these—a completed clearance report and a
clearance report template—and familiarize themselves with the types of
information they will need to provide to their clients as they assess properties.
Take questions from students about the format and content of these forms.
 Lead Dust Sampling Technician
                      6-iii
Chapter 6

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           Answers to Activity 1: Where to Take Samples for Renovated Areas

A homeowner renovated her house and she chose, under the EPA RRP regulation, to have
clearance conducted in her home, instead of cleaning verification. This language was inserted in
the contract at the beginning of the project. After reading the description about each type of
renovation performed, decide where and whether or not samples should be taken inside the house
by marking an "X" on the floor plan (see floor plan on following page).

   1.  The kitchen cabinets were replaced. Next to the cabinets, a stove and the 18-inch-square
       metal wall plate that held the exhaust vent for the stove were removed. A plastic barrier
       was hung between the kitchen and the hallway during this project.
   2.  In an effort to have a more energy-efficient house, both windows in bedroom 2 were
       replaced with triple-paned, argon-gas windows.  The contractor erected a barrier at the
       existing doorway to the bedroom.
   3.  The homeowner's  company decided its employees could reduce both fuel costs and
       pollution by allowing them  to work from home more often. As a result, the homeowner
       needed to create an office space. She decided to split her spacious upstairs bedroom into a
       smaller bedroom and an office. She had a wall constructed in the middle to divide the
       room. The original bedroom door was removed and two new doors were installed to
       allow access into each room. A window was installed in the office. The renovator
       considered both new rooms as a single work area and only erected a barrier between the
       bedroom/office and the hall.
   4.  The bathroom floor, original since the house was built in the 1960s, was replaced with
       new ceramic tile. Both the existing floor and the existing walls were ceramic tile.

Answers:

   1.  The work area consists of the kitchen. You should take a floor sample from  the kitchen
       floor near where the cabinets were removed (X-l), because that is where the most lead
       dust was created.  Because there is only one window in the work area, you should take
       the windowsill (X-2) and the window trough (X-3) samples from this window. The
       "outside the work area" sample should be taken from the hallway (X-4), since the barrier
       was constructed between  the kitchen and the hallway.  The removal of the wall plate does
       not affect the analysis; the work in the kitchen was within that one room and conducted
       as part of a single project.

       If the owner had not included the removal of the stove and the wall plate, how would that
       have affected clearance?  Answer: It would not have any effect; the cabinet replacement
       would still require clearance. Follow-up question: If the owner decided a month later to
       remove the stove and the  wall plate, what would be required for clearance of that project?
       Answer:  The plate is 18 inches on a side; with paint a few inches around it to be
       disturbed during removal. The paint to be removed would be a square about 2 feet on a
       side, or about 4 square feet. Under the EPA RRP regulation, there would be no need for
       clearance, because the amount of paint disturbed is within the EPA regulation's 6 square
       feet limit for minor repair and maintenance activities. Note that,  if the work is done
       under the HUD rule, this  project would need to be cleared, because the paint disturbance
       of 4 square feet is above HUD's de minimis threshold of 2 square feet.
Lead Dust Sampling Technician                6-iv                          Chapter 6

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   2.  The work area consists of Bedroom 2.  You should take the floor sample from the
       bedroom floor near the windows (X-5). Since the barrier was constructed at the existing
       doorway, the "outside the work area" sample should be taken from the Hall near the door
       (X-6). In this room, even though the windows are new, samples should be taken from
       both the sill and the trough of each window (X-14, X-15), because wall paint and lead-
       contaminated dust could be disturbed during installation of the windows. As a point of
       discussion, to keep the exercise within the class time available, just the first 13 samples
       are shown in the answer key and the lab report.

   3.  In this example, work area is Bedroom 3 and the Office.  Since there is more than one
       room, but fewer than four rooms, within the work area, both rooms must be sampled.
       X-7 is the floor sample in the Bedroom and X-8 is the floor sample from the Office. A
       windowsill sample (X-9) and window trough sample (X-10) should be collected from the
       Bedroom window.  Since a window was installed in the office, two window samples, a
       windowsill sample (X-12) and a window trough sample (X-13), are required.  On this
       job, the barrier was constructed between the  original bedroom (now Bedroom 3  and the
       Office) and the Hall, so the "outside the work area" sample should be taken from the Hall
       (X-ll).

   4.  No samples required since no lead-based paint was disturbed.
Lead Dust Sampling Technician               6-v                         Chapter 6

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                 Exterior
                 soil
             First Floor
                 Kitchen    Hallway
                            X-4
                       DR
         Bedroom 1
                              Foyer
                                       Living Room
Mark "X" for
sample locations
     Bedroom 3

     X-7
              X-8
     Office
Hall
x-n
                       X-6
                                  Bathroom
                                    Bedroom 2
                                              X-5
                                     Second
                                     Floor
Lead Dust Sampling Technician
              6-vi
    Chapter 6

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                 Answers to Activity 3: Interpreting Laboratory Results

Instructions: The purpose of this activity is to test your ability to verify the results received
from the laboratory, compare these results to EPA dust clearance standards, and interpret the
results. Using the following excerpt from a lead dust clearance test results form, check the
laboratory's calculation of the dust lead loading.  (Note: To keep the exercise within the class
time available, just the first 13 samples in the lab report are shown.)
Sample #
X-l
X-2
X-3
X-4
X-5
X-6
X-7
X-8
X-9
X-10
X-ll
X-12
X-13
Location
Kitchen
Kitchen
Kitchen
Hallway
Bedroom 2
Hall
Bedroom 3
Office
Bedroom 3
Bedroom 3
Hall
Office
Office
Surface
Floor
Interior
windowsill
Window
trough
Floor
Floor
Floor
Floor
Floor
Interior
windowsill
Window
trough
Floor
Interior
windowsill
Window
trough
Dimensions
of Sample
Area (ft2)
1.070
0.969
0.525
1.107
0.988
1.107
1.094
1.094
0.88
0.67
1.107
0.88
0.76
Total Lead
Gig)
40
323
210
30
50
26
47
192
412
111
900
70
12
ug/ft2
42.8
333.3
400.0
27.1
50.6
23.5
43.0
17.5
468.1
165.7
813.0
795.5
15.8
Lead Dust Sampling Technician
6-vii
Chapter 6

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1.       Check the results (|ig lead/ft2) for each sample. If the results are incorrect, provide the correct
        results in (ig lead/ft2.

               X-l: 40/1.070 = 42.8 ug/ft2 is incorrect (37.4 jig/ft2 is the correct result)
               X-2: 323/0.969 = 333.3 ug/ft2 is correct
               X-3: 210/0.525 = 400.0 ug/ft2 is correct
               X-4: 30/1.107 = 27.1 ug/ft2 is correct
               X-5: 50/0.988 = 50.6 ug/ft2 is correct
               X-6: 26/1.107 = 23.5 ug/ft2 is correct
               X-7: 47/1.094 = 43.0 ug/ft2 is correct
               X-8 192/1.094= 17.5 ug/ft2 is incorrect (175.5 ug/ft2 is the correct result)
               X-9: 412/0.88= 468.1ug/ft2 is correct
               X-10: 111/0.67= 165.7 ug/ft2 is correct
               X-ll: 900/1.107= 813.0 ug/ft2 is correct
               X-12: 70/0.88= 795.5 ug/ft2 is incorrect (79.5 ug/ft2 is the correct result)
               X-13: 12/0.76= 15.8 jig/ft2 is correct
Lead Dust Sampling Technician                 6-viii                             Chapter 6

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2.      After verifying the laboratory's results, compare these results to the appropriate EPA
       recommended guidance. Did the individual samples pass or fail the lead dust clearance test?
X-l: Result 37.4 us/ft2

X-2: Result 333.3 ^/ft2

X-3: Result 400.0 us/ft2

X-4: Result 27.1 us/ft2

X-5: Result 50.6 us/ft2

X-6: Result 23.5 ^/ft2

X-7: Result 43.0 us/ft2

X-8: Result 175.5 ug/ft2

X-9: Result 468.1 us/ft2


X-10: Result 165.7 ^/ft2


X-ll: Result 813.0^/ft2


X-12: Result 79.5 us/ft2


X-13: Result 15.8 us/ft2


Clearance Standard: 40 fig/ft2

Clearance Standard: 250 fig/ft2

Clearance Standard: 400 fig/ft2

Clearance Standard: 40 fig/ft2

Clearance Standard: 40 fig/ft2

Clearance Standard: 40 fig/ft2

Clearance Standard: 40 fig/ft2

Clearance Standard: 40 fig/ft2


Clearance Standard: 250 fig/ft2


Clearance Standard: 400 fig/it


Clearance Standard: 40 fig/ft


Clearance Standard: 250 fig/rt


Clearance Standard: 400 fig/tt

Pass or Fail? Pass

Pass or Fail? Fail

Pass or Fail? Fail

Pass or Fail? Pass

Pass or Fail? Fail

Pass or Fail? Pass

Pass or Fail? Pass

Pass or Fail? Fail


Pass or Fail? Fail


Pass or Fail;' Pass


Pass or Fail/ Fail


Pass or Fail? Pass


Pass or Fail? Pass

Lead Dust Sampling Technician
6-ix
Chapter 6

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   Answers to Activity 1: Where to Take Samples for Renovated Areas in HUD-Funded
                                        Projects

Scenario:  A homeowner received Federal rehabilitation assistance (less than $5,000) to renovate
specific areas of her house. After reading the description about each type of renovation
performed, decide where and whether or not samples should be taken inside the house by
marking an "X" on the floor plan (see floor plan on following page).

    1.  The kitchen cabinets were replaced. Next to the cabinets, a stove and the 18-inch-square
       metal wall plate that held the exhaust vent for the stove were removed. A plastic barrier
       was hung between the kitchen and the hallway during this project.

   2.  The two windows in Bedroom 2 had their sashes replaced with triple-paned, argon-gas-
       filled sashes. The sashes were replaced from the inside and plastic was hung on the
       outside of the windows. The contractor erected a barrier over the existing doorway to the
       bedroom. (Note that this work scope differs from the scope in the EPA example.)

   3.  The homeowner's company decided its employees could reduce both fuel costs and
       pollution by allowing them to work from home more often. As a result, the homeowner
       needed to create an office space. She decided to split her spacious upstairs bedroom into a
       smaller bedroom and an office. She had a wall constructed in the middle to divide the
       room. The original bedroom door was removed and two new doors were installed to
       allow access into each room. A window was installed in the office. The renovator
       considered both new rooms as a single work area and only erected a barrier between the
       bedroom/office and the hall.

   4.  The bathroom floor, original since the house was built in the 1960s, was replaced with
       new ceramic tile. Both the existing  floor and the existing walls were ceramic tile.

HUD Answers:

Either a worksite-only clearance strategy or a whole-unit clearance strategy may be used.

Sampling Strategy A - Worksite-Only Clearance in Multiple Areas (See diagram): In this
scenario, multiple work areas are created in the dwelling unit; one on the first floor and two on
the second floor.  This strategy clears these areas is by considering them to be individual work
areas. This sampling strategy will require a minimum of 13 samples to be taken. Under HUD's
Lead Safe Housing Rule, this project qualifies for worksite-only clearance because each work
area was contained and  the level of housing rehabilitation assistance is below $5,000.

    1.  Work Area #1 consists of the kitchen.  You should take a floor sample from the kitchen
       floor near where the cabinets were hung (X-l).  Because there is only one window in the
       work area, you should take the windowsill (X-2) and the window trough (X-3) samples
       from  this window. The "outside the work area" sample should be taken from the hallway
       (X-4), since the barrier was constructed between the kitchen and the hallway. A visual
       inspection is not needed on the exterior because the barrier was hung on the outside of the
       window.  A total of 4 samples are required for this work area.
Lead Dust Sampling Technician                6-x                          Chapter 6

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       Question for class discussion: If the owner had not included the removal of the stove and
       the wall plate, how would that have affected clearance?  Answer: It would not have any
       effect; the cabinet replacement would still require clearance. Follow-up question:  If the
       owner decided a month later to remove the stove and the wall plate, what would be
       required for clearance of that project? Answer: The plate is 18 inches on a side; with
       paint a few inches around it to be disturbed during removal. The paint to be removed
       would be a square about 2 feet on a side, or about 4 square feet. Under the HUD Lead
       Safe Housing Rule, this project would need to be cleared, because the paint disturbance
       of 4 square feet is above HUD's de minimis threshold of 2 square feet.  Note that, under
       the EPA RRP  regulation, there would be no need for clearance, because the amount of
       paint disturbed by removing the metal plate is within the EPA regulation's 6 square feet
       limit for minor repair and maintenance activities.

   2.  Work Area #2 is Bedroom 2. Only the sashes of the windows were replaced and the
       frames and sills were not affected.  You should take the floor sample from the bedroom
       floor within 5  feet of the windows  (X-5).  One window sill (X-6) and one trough sample
       (X-7) should be taken. You may take the sill sample from one of the windows and the
       trough sample from the other. Because the barrier was constructed at the existing
       doorway, the "outside the work area" sample should be taken from the Hall near the door
       (X-8). An exterior visual inspection should be performed under the windows. A total of
       4 samples are required for this work area plus the exterior visual inspection.

   3.  The work area is Bedroom 3 and the Office.  Since there is more than one room, but
       fewer than four rooms, within the work area, both rooms must be sampled. X-9 is the
       floor sample in the Bedroom and X-10 is the floor sample from the Office. For window
       sampling, the windows in Bedroom 3 and the Office, both within this work area, are
       matched up. A windowsill sample (X-l 1) should be collected from the Bedroom
       window, and a window trough sample (X-l2) should be  collected from the Office
       window. On this job, the barrier was constructed between the original bedroom (now
       Bedroom 3 and the Office) and the Hall, so the "outside  the work area" sample should be
       taken from the Hall (X-l3).  A total of 5 samples are required for this work area.

   4.  No samples are required because no lead-based paint was disturbed.

Sampling Strategy B:  Whole Unit Clearance for Interior Work with No Dust Containment:  In
this scenario, the Lead Dust Sampling Technician elects to treat the entire unit as the work area,
ignoring the  containment barriers erected in the unit.  There are  more than four rooms in the unit,
so the LOST plans to  sample the following four rooms where work was done:  Kitchen,
Bedroom 2, Bedroom 3  and Office. Each  room requires a minimum of two samples, one from
the floor and one from an interior window sill or trough, alternating from sill to trough between
rooms. A total of 11 samples are required for whole-unit clearance.

   1.  In the kitchen, one floor sample (X-l), one window sill (X-2) and one window trough
       (X-3) sample are required. A total of 3 samples in this room should be taken.
   2.  In Bedroom 2, one floor sample (X-5), one window sill (X-6) and one window trough
       (X-7) sample are required. A total of 3 samples in this room should be taken.
Lead Dust Sampling Technician               6-xi                          Chapter 6

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   3.  In Bedroom 3, one floor sample (X-9), and one window sill (X-l 1) are required. The
       window in this room is matched up with the window in the office.  A total of 3 samples in
       this room should be taken.
   4.  In the Office, one floor sample (X-10), and one window trough sample (X-12) are
       required.  The window in this room is matched up with the window in Bedroom 3.  A
       total of 2 samples in this room should be taken.
   5.  No samples are required in the bathroom, because no lead-based paint was disturbed.
Note that an alternative strategy is to treat the whole unit as the work area, and also to consider
the containment barriers erected in the unit.  A total of up to 20 samples are required in this
scenario. Because fewer samples are required in this unit for clearing the unit as a whole without
considering the containment barriers, that approach, Strategy B, would be the choice between the
whole-unit sampling strategies.
Lead Dust Sampling Technician               6-xii                          Chapter 6

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                  Exterior
                  soil
             First Floor
                            Hallway
                     DR
                             X-4
         Bedroom 1
                  Living Room
                               Foyer
                                   HUD Clearance
                                   Sampling Strategy A
                                   Worksite-Only: Mark
                                   "X" for sample locations
      x-n
     Bedroom 3

     X-9
              x-io
     Office
       X-12
Hall
X-13
                       X-8
                                  Bathroom
              Bedroom 2

                        X-5
                                        Exterior
                                        soil
                                     Second
                                     Floor
Lead Dust Sampling Technician
             6-xiii
Chapter 6

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     Answers to Activity 3: Interpreting Laboratory Results In HUD-Funded Project
Instructions: The purpose of this activity is to test your ability to verify the results received from the
laboratory, compare these results to EPA/HUD dust clearance standards, and interpret the results. Using
the following excerpt from a lead dust clearance test results form, check the laboratory's calculation of
the dust lead loading. (Note: To keep the exercise within the class time available, just the first 13
samples in the lab report are shown.)
Sample #
X-l
X-2
X-3
X-4
X-5
X-6
X-7
X-8
X-9
X-10
X-ll
X-12
X-13
Location
Kitchen
Kitchen
Kitchen
Hallway
Bedroom 2
Bedroom 2
Bedroom 2
Hall
Bedroom 3
Office
Bedroom 3
Bedroom 3
Hall
Surface
Floor
Interior
windowsill
Window
trough
Floor
Floor
Interior
Windowsill
Interior trough
Floor
Floor
Floor
Interior
windowsill
Interior trough
Floor
Dimensions
of Sample
Area (ft2)
1.070
0.969
0.526
1.107
0.988
0.898
0.775
1.107
1.094
1.094
0.88
0.67
1.107
Total Lead
fog)
40
323
156
30
50
289
154
26
47
192
412
111
900
ug/ft2
42.8
333.3
296.6
27.1
50.6
321.82
198.7
23.5
43.0
17.5
468.1
165.7
813.0
Lead Dust Sampling Technician
6-xiv
Chapter 6

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       Check the results (|ig lead/ft2) for each sample. If the results are incorrect, provide the correct
       results in (ig lead/ft2. (Note: To keep the exercise within the class time available, just the
       first 13 samples in the lab report are shown.)

               X-l: 40/1.070 = 42.8 ug/ft2 is incorrect (37.4 jig/ft2 is the correct result)
               X-2: 323/0.969 = 333.3 jig/ft2 is correct
               X-3: 156/0.526 = 296.6 jig/ft2 is correct
               X-4: 30/1.107 = 27.1 ug/ft2 is correct
               X-5: 50/0.988 = 50.6 ug/ft2 is correct
               X-6: 289/.89S = 321.82 jig/ft2 is correct
               X-7: 154/885 = 198.7ug/ft2 is correct
               X-8: 26/1.107 = 23.5 ug/ft2 is correct
               X-9: 47/1.094 = 43.0 ug/ft2 is correct
               X-10: 192/1.094= 17.5 ug/ft2 is incorrect (175.5 ug/ft2 is the correct result)
               X-ll: 412/0.88 = 468.1 jig/ft2 is correct
               X-12: 111/0.67 = 165.7 ug/ft2 is correct
               X-13: 900/1.107= 813.0 ug/ft2 is correct

       After verifying the laboratory's results, compare these results to the appropriate EPA
       recommended guidance. Did the individual samples pass or fail the lead dust clearance test?
       (Note: To keep the exercise within the class time available, just the first 13 samples in the
       lab report are shown.)
X-l: Result 37.4 ug/ft2

X-2: Result 333.3 fig/ft2

X-3: Result 296.6 us/ft2

X-4: Result 27.1 us/ft2

X-5: Result 50.6 ne/ft2

X-6: Result 333.3 us/ft2

X-7: Result 296.6 fig/ft2

X-8: Result 23.5 us/ft2

X-9: Result 43.0 us/ft2

X-10: Result 175.5 us/ft2

X-ll: Result 468.1 us/ft2

X-12: Result 165.7 ne/ft2

X-13: Result 813.0ug/ft2

Clearance Standard: 40 fig/ft2

Clearance Standard: 250 fig/ft2

Clearance Standard: 250 fig/ft2

Clearance Standard: 40 fig/ft2

Clearance Standard: 40 fig/ft2

Clearance Standard: 250 fig/ft2

Clearance Standard: 250 fig/ft2

Clearance Standard: 40 fig/ft2

Clearance Standard: 40 fig/ft2

Clearance Standard: 40 fig/ft2

Clearance Standard: 250 fig/ft2

Clearance Standard: 400 fia/ft2

Clearance Standard: 40 fig/ft2

Pass or Fail? Pass

Pass or Fail? Fail

Pass or Fail? Fail

Pass or Fail? Pass

Pass or Fail? Fail

Pass or Fail? Fail

Pass or Fail? Fail

Pass or Fail? Pass

Pass or Fail? Pass

Pass or Fail? Fail

Pass or Fail? Fail

Pass or Fail? Pass

Pass or Fail? Fail

Lead Dust Sampling Technician
6-xv
Chapter 6

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                                    Attachment 6-C

                  Activity 4 — Translating Results into a Written Report

Instructions: The purpose of this activity is to test your ability to translate the results from the previous
activity (Interpreting Laboratory Results In HUD-Funded  Project) into a written report
which is easy for the client to understand. Using the results from the previous activity and the report
format from Chapter 5 (Writing the Report), complete a lead dust clearance test report.
                      LEAD DUST CLEARANCE TEST REPORT
                                  General Information
Date of Lead Dust
Clearance Test:
Lead Dust Sampling
Technician:
Property Address:
Client Name and
Address:
Laboratory Name and
Address:
Telephone Number:
NLLAP Number:
8/5/09
Jane White
80 East Main St.
Hammond, IN 89898
Smith Family
80 East Main St.
Hammond, IN 89898
Analysis Services, Inc.
990 45th St., Suite 500
Gary, IN 44444
222-222-2222
IN 999999
                     Summary of Lead Dust Clearance Test Results

This unit failed the lead dust clearance testing portion of the lead dust sampling examination.
Areas represented by the failed samples should be re-cleaned.

Lead dust above HUD/EPA clearance standards was found in the following areas:
Location
Kitchen
Kitchen
Bedroom 2
Bedroom 2
Bedroom 2
Office
Bedroom 3
Hall
Surface
Interior windowsill
Window trough
Floor
Interior Windowsill
Interior trough
Floor
Interior windowsill
Floor
jig lead/ft2
333.3
296.6
50.6
321.82
198.7
175.5
468.1
813.0
             Signature:
                    Date: Xlt8lQ9
Lead Dust Sampling Technician
6-xvi
Chapter 6

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                        Summary of Hazard Reduction Activities
Name of Firm
Address of Firm
Supervisor Name
Supervisor Certification Number
Start and Completion Date of Hazard
Reduction or Completion Activity
ABC Renovations
123 Main Street
East Chicago, IN 12345
John Brown #163 4
1634
8/4/09 to 8/5/09
            Description of Hazard Reduction Activities and Areas Addressed:
Location
Kitchen
Bedroom 2










Activity
Replaced A-l window with new, vinyl-clad window
Replaced C-l and C-2 windows with new, vinyl-clad windows










Description of work
The supervisor was present on the job site when work was being
performed. Workers used lead-safe work practices. Plastic sheeting
covered a 5-foot area on the ground outside under the windows being
replaced and on the floor inside. Signs were posted at the doors to the
bedroom and kitchen.  Occupants were not allowed in the kitchen and
bedroom and the outside work area during this activity.  The window
frame was misted prior to tear-out. After removal, workers wrapped
the old windows in plastic sheeting and picked up debris on the plastic
immediately and bagged it.  The plastic sheeting was carefully gathered
up and bagged for disposal.  Workers replaced their disposable booties
when leaving the work area for lunch and breaks. Respirators were not
necessary. The  new windows were installed and a clearance
examination was requested.	
Lead Dust Sampling Technician
                  6-xvii
Chapter 6

-------
                    Part I.  VISUAL INSPECTION RESULTS FORM
Date of Lead Dust
Sampling:
Lead Dust Sampling
Technician:
Client:
Property Address:
tlsw
fateWfate
SM&& "potttilfy
80 Stuffffae* St.
VfauKOtul. 1H 89898
                          Visual Inspection of the Work Area
Work Area
StwxM fiedMom-
"Kitcfa*
Jintt {fan faMway
SfaVUXMC
Second $oo>i faMuKiy
Sxteiun tout uttde>i &&c&eti
wifidoui
Sxteiun tout uttde>i
fiednoom cvutdacv
Deteriorated
Paint







Debris







Visible Dust







Notes







Pass/Fail
POM
"P
-------
Model Certified Lead Dust Sampling Technician Training Course

                               the
6-1                              October 2011
                                                              6-1

-------
Model Certified Lead Dust Sampling Technician Training Course
                                                                   6-2
               •  Practice the skills taught in the class:
                  - Choosing appropriate sampling locations
                  -Taking lead dust samples
                  - Interpreting Results
                  -Translating Result into a Report
This chapter will outline the steps a lead dust sampling technician must take from start to finish when
conducting an examination. This chapter includes five activities to help practice implementing the
protocols.
By the end of this chapter, students will be able to demonstrate that they can:
  •   Choose appropriate sampling locations
  •   Take lead dust samples
  •   Interpret Results
  •   Translating Results into a Report
6-2                                 October 2011

-------
Model Certified Lead Dust Sampling Technician Training Course
                                                          6-3
                      1:           To

            •  You are now going to practice sampling area
              strategies.
            •  Your instructor will provide you with a
              hypothetical renovation scenario and diagram.
            •  Read the scenario and mark the location(s) of
              where you think dust wipe samples should be
              taken.
6-3                            October 2011

-------
Model Certified Lead Dust Sampling Technician Training Course
                                                    6-4
          •  Be strategic about laying out sampling area
            to capture areas were the highest dust
            generating tasks occurred during the job.


          •  Refer to the Field Guide or Chapter 3 to
            determine the appropriate places to take
            your samples.
6-4                         October 2011

-------
Model Certified Lead Dust Sampling Technician Training Course
                                                               6-5
                       2:

             •  You are now going to practice taking dust wipe
               samples again.

             •  Each individual must demonstrate proficiency.

             •  Follow your instructor's directions for taking
               samples.
Activity 2: Now that the sampling locations have been determined, you will take samples on a variety of
surfaces - windowsills, troughs, and floors.
6-5                               October 2011

-------
Model Certified Lead Dust Sampling Technician Training Course
                                                                6-6
                        3:                  the

             •  Analyze the results
               -Your instructor will provide you with
                 laboratory results to interpret.
               - Use EPA lead dust clearance standards for
                 guidance:
                  o Floors: < 40 |jg/ft2
                  o Interior window sills: < 250 ug/ft2
                  o Window troughs:  < 400 ug/ft2
Results
When analyzing the data, follow the guidelines provided in Chapter 4.
Use the EPA/HUD lead dust clearance standards when evaluating sample results.
6-6                                October 2011

-------
Model Certified Lead Dust Sampling Technician Training Course


                        4:                                    a


             •Translate analyzed results into a written report
                -Using the result from the previous activity
                (Interpreting the Results), write up a report that
                can be easily understood by the client

                -Use the format introduced in Chapter 5 (Writing
                the Report) as a guide.
6-7
Report Writing
Use the information in Chapter 5 (Writing the Report) as a guideline to translate the results into an easy
to understand report.
6-7                                October 2011

-------
                                   Attachment 6-A
                 Activity 1: Where to Take Samples for Renovated Areas

A homeowner renovated her house and she chose, under the EPA RRP regulation, to have
clearance conducted in her home, instead of cleaning verification. This language was inserted in
the contract at the beginning of the project. After reading the description about each type of
renovation performed, decide where and whether or not samples should be taken inside the house
by marking an "X" on the floor plan (see floor plan on following page).

   1.  The kitchen cabinets were replaced. Next to the cabinets, a stove and the 18-inch-square
       metal wall plate that held the exhaust vent for the stove were removed. A plastic barrier
       was hung between the kitchen and the hallway during this project.
   2.  In an effort to have a more energy-efficient house, both windows in bedroom 2 were
       replaced with triple-paned, argon-gas windows.  The contractor erected a barrier at the
       existing doorway to the bedroom.
   3.  The homeowner's  company decided its employees could reduce both fuel costs and
       pollution by allowing them  to work from home more often. As a result, the homeowner
       needed to create an office space. She decided to split her spacious upstairs bedroom into a
       smaller bedroom and an office. She had a wall constructed in the middle to divide the
       room. The original bedroom door was removed and two new doors were installed to
       allow access into each room. A window was installed in the office. The renovator
       considered both new rooms as a single work area and  only erected a barrier between the
       bedroom/office and the hall.
   4.  The bathroom floor, original since the house was built in the 1960s, was replaced with
       new ceramic tile. Both the existing floor and the existing walls were ceramic tile.
Lead Dust Sampling Technician                6-i                           Chapter 6

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    Activity 1: Where to Take Samples for Renovated Areas in HUD-Funded Projects

Scenario: A homeowner received Federal rehabilitation assistance (less than $5,000) to renovate
specific areas of her house. After reading the description about each type of renovation
performed, decide where and whether or not samples should be taken inside the house by
marking an "X" on the floor plan (see floor plan on following page).

    1.   The kitchen cabinets were replaced. Next to the cabinets, a stove and the 18-inch-square
       metal wall plate that held the exhaust vent for the stove were removed. A plastic barrier
       was hung between the kitchen and the hallway during this project.

    2.   The two windows in Bedroom 2 had their sashes replaced with triple-paned, argon-gas-
       filled sashes. The sashes were replaced from the inside and plastic was hung on the
       outside of the windows. The contractor erected a barrier over the existing doorway to the
       bedroom. (Note that this work scope differs from the scope in the EPA example.)

    3.   The homeowner's company decided its employees could reduce both fuel costs and
       pollution by allowing them to work from home more often. As  a result, the homeowner
       needed to create an office space. She decided to split her spacious upstairs bedroom into a
       smaller bedroom and an office. She had a wall constructed in the middle to divide the
       room. The original bedroom door was removed and two new doors were installed to
       allow access into each room.  A window was installed in the office. The renovator
       considered both new rooms as a single work area and only erected a barrier between the
       bedroom/office and the hall.

    4.   The bathroom floor, original since the house was built in the 1960s, was replaced with
       new ceramic tile. Both the existing floor and the existing walls were ceramic tile.
Lead Dust Sampling Technician                6-ii                           Chapter 6

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                 Exterior
                 soil
             First Floor
Mark "X" for
sample locations
         Kitchen
                          Hallway
                 DR
         Bedroom 1
                                      Living Room
                             Foyer
     Bedroom 3
     Office
Hall
                                Bathroom
                                           \
                                   Bedroom 2
                                    Second
                                    Floor
Lead Dust Sampling Technician
              6-iii
     Chapter 6

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                                     Attachment 6-B
                       Activity 3 — Interpreting Laboratory Results


Instructions: The purpose of this activity is to test your ability to verify the results received
from the laboratory, compare these results to the EPA/HUD dust clearance standards, and
interpret the results. Using the following excerpt from a lead dust clearance test results form,
check the laboratory's calculation of the weighted lead dust sample.
Sample #
X-l
X-2
X-3
X-4
X-5
X-6
X-7
X-8
X-9
X-10
X-ll
X-12
X-13
Location
Kitchen
Kitchen
Kitchen
Hallway
Bedroom 2
Hall
Bedroom 3
Office
Bedroom 3
Bedroom 3
Hall
Office
Office
Surface
Floor
Interior
windowsill
Window
trough
Floor
Floor
Floor
Floor
Floor
Interior
windowsill
Interior
trough
Floor
Interior
windowsill
Interior
trough
Dimensions
of Sample
Area (ft2)
1.070
0.969
0.526
1.107
0.988
1.107
1.094
1.094
0.88
0.67
1.107
0.88
0.76
Total Lead
(^g)
40
323
210
30
50
26
47
192
412
111
900
70
12
Hg/ft2
42.8
333.3
400
27.1
50.6
23.5
43.0
17.5
468.1
165.7
813.0
795.5
15.8
Lead Dust Sampling Technician
6-iv
Chapter 6

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1.      Check the results (jig lead/ft2) for each sample. If the results are incorrect, provide the
       correct results in jig lead/ft2.
2.      After verifying the laboratory's results, compare these results to the appropriate EPA lead
       dust clearance standard. Did the individual samples pass or fail the lead dust clearance
       test?
                    EPA/HUD Clearance Standards for Lead Dust
                                   Floors: 40 ug/ft2
                           Interior windowsills: 250 ug/ft2
                             Window troughs: 400 ug/ft2
Sample
X-l: Result
X-2: Result
X-3: Result
X-4: Result
X-5: Result
X-6: Result
X-7: Result
X-8: Result
X-9: Result
X-10: Result
X-ll: Result
X-12: Result
X-13: Result
Clearance Standard:













Pass or Fail?













Lead Dust Sampling Technician
6-v
Chapter 6

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           Activity 3: Interpreting Laboratory Results In HUD-Funded Project
Instructions: The purpose of this activity is to test your ability to verify the results received
from the laboratory, compare these results to EPA/HUD dust clearance standards, and interpret
the results. Using the following excerpt from a lead dust clearance test results form, check the
laboratory's calculation of the dust lead loading. (Note: To keep the exercise within the class
time available, just the first 13  samples in the lab report are shown.)
Sample #
X-l
X-2
X-3
X-4
X-5
X-6
X-7
X-8
X-9
X-10
X-ll
X-12
X-13
Location
Kitchen
Kitchen
Kitchen
Hallway
Bedroom 2
Bedroom 2
Bedroom 2
Hall
Bedroom 3
Office
Bedroom 3
Bedroom 3
Hall
Surface
Floor
Interior
windowsill
Window
trough
Floor
Floor
Interior
Windowsill
Interior
trough
Floor
Floor
Floor
Interior
windowsill
Interior
trough
Floor
Dimensions
of Sample
Area (ft2)
1.070
0.969
0.525
1.107
0.988
0.898
0.775
1.107
1.094
1.094
0.88
0.67
1.107
Total Lead
(m)
40
323
210
30
50
289
154
26
47
192
412
111
900
ug/ft2
42.8
333.3
400.0
27.1
50.6
321.82
198.7
23.5
43.0
17.5
468.1
165.7
813.0
Lead Dust Sampling Technician
6-vi
Chapter 6

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1.      Check the results (jig lead/ft2) for each sample.  If the results are incorrect, provide the
       correct results in jig lead/ft2.
2.      After verifying the laboratory's results, compare these results to the appropriate EPA
       recommended guidance. Did the individual samples pass or fail the lead dust clearance
       test?
                    EPA/HUD Clearance Standards for Lead Dust
                                   Floors: 40 ug/ft2
                           Interior windowsills: 250 ug/ft2
                            Window troughs: 400 ug/ft2
X-l: Result:
X-2: Result:
X-3: Result:
X-4: Result:
X-5: Result:
X-6: Result:
X-7: Result:
X-8: Result:
X-9: Result:
X-10: Result:
X-ll:Result:
X-12: Result:
X-13: Result:
Clearance Standard:
Clearance Standard:
Clearance Standard:
Clearance Standard:
Clearance Standard:
Clearance Standard:
Clearance Standard:
Clearance Standard:
Clearance Standard:
Clearance Standard:
Clearance Standard:
Clearance Standard:
Clearance Standard:
Pass or Fail?
Pass or Fail?
Pass or Fail?
Pass or Fail?
Pass or Fail?
Pass or Fail?
Pass or Fail?
Pass or Fail?
Pass or Fail?
Pass or Fail?
Pass or Fail?
Pass or Fail?
Pass or Fail?
Lead Dust Sampling Technician
6-vii
Chapter 6

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                                    Attachment 6-C
                 Activity 4 — Translating Results into a Written Report

Instructions: The purpose of this activity is to test your ability to translate the results from the
previous activity (Interpreting Laboratory Results In HUD-Funded Project) into a written
report which is easy for the client to understand. Using the results from the previous activity and
the report format from Chapter 5 (Writing the Report), complete a lead dust clearance test
report.
                      LEAD DUST CLEARANCE TEST REPORT
                                 General Information
Date of Lead Dust
Clearance Test:
Lead Dust Sampling
Technician:
Property Address:
Client Name and
Address:
Laboratory Name and
Address:
Telephone Number:
NLLAP Number:







                     Summary of Lead Dust Clearance Test Results

This unit failed the lead dust clearance testing portion of the lead dust sampling examination.
Areas represented by the failed samples should be re-cleaned.

Lead dust above HUD/EPA clearance standards was found in the following areas:
Location







Surface







jig lead/ft2







    Signature:
            Date:
Lead Dust Sampling Technician
6-viii
Chapter 6

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                       Summary of Hazard Reduction Activities
Name of Firm
Address of Firm
Supervisor Name
Supervisor Certification Number
Start and Completion Date of Hazard
Reduction or Completion Activity





            Description of Hazard Reduction Activities and Areas Addressed:
      Location
         Activity
Description of work
Lead Dust Sampling Technician
6-ix
Chapter 6

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                  Part I.  VISUAL INSPECTION RESULTS FORM
Date of Lead Dust
Sampling:
Lead Dust Sampling
Technician:
Client:
Property Address:




                        Visual Inspection of the Work Area
Work Area







Deteriorated
Paint







Debris







Visible Dust







Notes







Pass/Fail







Lead Dust Sampling Technician
6-x
Chapter 6

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          Appendix A:

Excerpt from EPA Final Renovation,
     Repair, and Painting Rule

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Appendix A:  Excerpt from EPA Final Rule: Renovation, Repair, and Painting Rule

To see the entire rule go to http://www.epa.gov/fedrgstr/EPA-TOX/2008/April/Day-
227t8141.pdf.
ENVIRONMENTAL PROTECTION AGENCY
40 CFR Part 745 [EPA-HQ-OPPT-2005-0049; FRL-8355-7] RIN 2070-AC83
Lead; Renovation, Repair, and Painting Program
AGENCY: Environmental Protection Agency (EPA).
ACTION: Final rule.
SUMMARY: EPA is issuing a final rule under the authority of section 402(c)(3) of the
Toxic Substances Control Act (TSCA) to address 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 defined in TSCA section 401 as any
housing constructed before 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. Under this rule, a child-occupied facility is 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 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 be located in public or commercial buildings or in target housing.
This rule establishes requirements for training renovators, other renovation workers, and
dust sampling technicians; for certifying renovators,  dust sampling technicians, and
renovation firms; for accrediting providers of renovation and dust sampling technician
training; for renovation work practices; and for recordkeeping. Interested States,
Territories, and Indian Tribes may apply for and receive authorization to administer and
enforce all of the elements of these new renovation requirements.

ง 745.85 Work practice standards.

(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:

(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 ง745.227(e)(8) or any applicable
State, Territorial, Tribal, or local standard.
Appendix A

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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:

(1) 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.
Appendix A

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(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.
Appendix A

-------
         Appendix B:

 Renovate Right: Important Lead
 Hazard Information for Families,
Child Care Providers, and Schools

-------
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This document may be purchased through the U.S.             Office online at
                    or by    (toll-free): 1-866-512-1800,

-------
Federal law requires contractors that disturb painted surfaces
in homes, child care facilities and schools built before 1978 to
be certified and follow specific work practices to prevent lead
contamination. Always ask to see your contractor's certification.
Federal law requires that individuals receive certain information
before renovating more than six square feet of painted surfaces
in a room for interior projects or more than twenty square feet
of painted surfaces for exterior projects or window replacement
or demolition in housing, child care facilities and schools built
before 1978.
• Homeowners and tenants: renovators must give you this
 pamphlet before starting work.
ซ Child care facilities, including preschools and kindergarten
 classrooms, and the families of children under six years of age
 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.

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• 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 years of age who attends a child care facility built before 1978.
• Basic facts about lead and your health.
• How to choose a contractor, if you area 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.
• 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, butyou will need more information to complete the work safely. Call
 the National Lead Information Center at 1-800-424-LEAD (5323) and askfor 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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                             • 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 where your children under six years of age
                               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 orthe child care
                             facility or school your children attend.
                            The            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 painted surfaces 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.
Lead is                    to
under sii years of age.
Lead can affect children's brains and developing
nervous systems, causing:
• Reduced IQand 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 fetuses. 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.


                                      my                 to
• 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.
• 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
 painted surfaces.


For more information about the health effects of exposure to lead, visit the EPA lead
website at epa.gov/lead/pubs/leadinfo or call 1-800-424-LEAD (5323).
                                                                                             i iwi'e life otner tnsncis you can cio to protect you?" tasinif every ciay,
                                                                                             • 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 the house.


-------
     is the
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.


Common renovation activities  like sanding, cutting,and demolition can create
hazardous lead dust and chips.

                                    the
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 workarea,
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.
ซ  Between
g  1960-1978

.5  Between
M_  1940-1960  —
O
Si  Before 1940 —
                         Percentatje of Homes Likely to Contain
                                                        69%
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                 care          and        are            to

Homes may be single-family homes or apartments. They maybe private, government-
assisted, or public housing. Schools are preschools and kindergarten classrooms. They
may be urban, suburban, or rural.

You      the
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 can hire a certified professional to check for lead-based paint.
These professionals are certified riskassessors 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).

You may also have a certified renovator test the surfaces or components being
disturbed for lead by using a lead test kit or by taking paint chip samples and sending
them to an EPA-recognized testing laboratory. Test kits must be EPA-recognized and
are available at hardware stores. They include detailed instructions for their use.


-------

in pur care.
This means properly preparing forthe renovation and keeping persons out of the work
area (see p. 8). It also means ensuring the contractor uses lead-safe work practices.
Federal law requires that contractors performing renovation, repair and painting projects
that disturb painted surfaces in homes, child care facilities, and schools built before 1978
be certified and follow specific work practices to prevent lead contamination.
Make sure your contractor is certified, and can explain clearly the details of the job
and how the contractor will minimize lead hazards during the work.
• You can verify that a contractor is certified by checking EPA's website at
                    or by calling the National Lead Information Center at
 1-800-424-LEAD (5323). You can also ask to see a copy of the contractor's
 firm certification.
• 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 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.
• 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 will be used  in those areas. Remember, your
 contractor should confine dust and debris to the work area and should minimize
 spreading that dustto otherareas of the home.
• The contract should also specify that the contractor will clean the work area, verify
 that it was cleaned adequately, and re-clean it if necessary.

                    is not            he is          to do or is
that is        you
• Direct the contractor to comply with regulatory and contract requirements.
• Call your local health or building department, or
• Call EPA's hotline 1-800-424-LEAD (5323).
If your property receives housing assistance from HUD (or a state or local agency that
uses HUD funds), you must follow the requirements of HUD's Lead-Safe Housing Rule
and the ones described in this pamphlet.
You play an           role          the

This means properly preparing for the renovation
and staying out of the work area (see p. 8).

Federal law requires that contractors performing
renovation, repair and painting projects that disturb
painted surfaces in homes built before 1978 and in
child care facilities and schools built before 1978, that
a child under sixyears of age visits regularly, to be
certified and follow specific work practices to prevent
lead contamination.

The law requires 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.

           a        is not            he is         to do or is
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 afterthe job is over, you can
check the work yourself (see page 10).


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The                  not be           to                the
The rooms or areas where work is being done may need to be blocked off or sealed
with plastic sheeting to contain any dust that is generated. Therefore, the contained
area may not be available to you until the work in that room or area is complete,
cleaned thoroughly, and the containment has been removed. Because you may not
have access to some areas during the renovation, you should plan accordingly.

You may
• 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 being done. Items that can't be moved, such as
 cabinets, should be wrapped in plastic.

• To turn off forced-air heating and air conditioning systems while the work is being
 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 part of the
work is being done.

Child care facilities and schools may want to consider alternative accommodations
for children and access to necessary facilities.
Federal law requires contractors that are hired to perform renovation, repair and painting
projects in homes, child care facilities, and schools built before 1978 that disturb painted
surfaces to be certified and follow specific work practices to prevent lead contamination.

The work practices the contractor must follow include these three simple procedures,
described below:

1. Contain the work area. The area must be contained so that dust and debris do not escape
  from that area. Warning signs must be put up and plastic or other impermeable material
  and tape must be used as appropriate to:

   • Cover the floors and any furniture that cannot be moved.

   • Seal off doors and heating and cooling system vents.

   • For exterior renovations, cover the ground and, in some instances, erect vertical
    containment or equivalent extra precautions in containing the work area.

These work practices will help prevent dust or debris from getting outside the work area.

2. Avoid renovation methods that generate large amounts of lead-contaminated dust.
  Some methods generate so much lead-contaminated dust that their use is prohibited.
  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.

There is no way to eliminate dust, but some renovation  methods make less dust than others.
Contractors may choose to use various methods to minimize dust generation, including
using water to mist areas before sanding or scraping; scoring paint before separating
components; and prying and pulling apart components instead of breaking them.

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 must 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 wiping and 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 must be re-cleaned.


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                                                                        *i IT
   When all the work is finished, you will want to know if your home, child care facility, or
   school where children under six attend has been cleaned up properly.

   EPA
   In addition to using allowable work practices and working in a lead-safe manner,
   EPA's RRP rule requires contractors to follow a specific cleaning protocol. The protocol
   requires the contractor to use disposable cleaning cloths to wipe the floor and other
   surfaces of the workarea and compare these cloths to an EPA-provided cleaning
   verification card to determine if the workarea was adequately cleaned. EPA research
   has shown that following the use of lead-safe work practices with the cleaning
   verification protocol will effectively reduce lead-dust hazards.

   Lead-Dust Testing.
   EPA believes that if you use a certified and trained renovation contractor who follows
   the LRRP rule by using lead-safe work practices and the cleaning protocol after the
   job is finished, lead-dust hazards will be effectively reduced. If, however, you are
   interested in having lead-dust testing done at the completion of your job, outlined
   below is some helpful information.

   What is a lead-dust test?
   • Lead-dust tests are wipe samples sent to a laboratory for analysis. You will get a
    report specifying the levels of lead found after your specific job.

   How and when should I ask my contractor about lead-dust testing?
   • Contractors are not required by EPA to conduct lead-dust testing. However, if you
    want testing, EPA recommends testing be conducted by a  lead professional. To
    locate a lead professional who will perform an evaluation near you, visit EPA's
    website at epAiQov/leAd/QMbs/jgcate. or contact the National Lead Information
    Center at 1-800-424-LEAD (5323).

   • If you decide that you want lead-dust testing, it is a good idea to specify in your
    contract, before the start of the job, that a lead-dust test is to be done for your job
    and who will do the testing, as well as whether re-cleaning will be required based on
    the results of the test.

   • You may do the testing yourself.
    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
    laboratory for analysis. Contact
    the National Lead Information
    Center for lists of EPA-recognized
    testing laboratories.
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 child care facility.

The National Lead Information Center at 1-800-424-LEAD (5323) or
epa.qov/lead/nlic 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
epa.gov/lead/pubs/brochure

• Steps to Lead Safe Renovation, Repair and  Painting.

• 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.
10
                                                                                                                                                                             11

-------
   EPA addresses residential lead hazards through several different regulations.
   EPA requires training and certification for conducting abatement and renovations,
   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 atepa.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
   (888) 372-7341

   Region 2
   (New Jersey, New York,
   Puerto Rico, Virgin Islands)
   Regional Lead Contact
   U.S. EPA Region 2
   2890 Woodbridge Avenue
   Building 205, Mail Stop 225
   Edison, NJ 08837-3679
   (732)321-6671

   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) 665-7577
Region 7
(Iowa, Kansas, Missouri,
Nebraska)
Regional Lead Contact
U.S. EPA Region 7
901 N. 5th Street
Kansas City, KS 66101
(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, CA 94105
(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
12
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,MD 20814
Hotline 1-(800) 638-2772
CDC           Lead

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
cdc.qov/nceh/lead
HUD      of               and Lead

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,
outreach 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
hyd.gov/offices/lead/
                                                                                                                                                                            13

                                                                                                                                                                        pT'-ซ'ฅ-"5'=%__

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This sample form may be used by renovation firms to document compliance with the Federal
pre-renovation education and renovation, repair, and painting regulations.


Pamphlet Receipt
QI 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.
Printed Name of Owner-occupant
Signature of Owner-occupant                Signature Date


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         - 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           for          -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

                      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.

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           Appendix C:

Lead Dust Sampling Technician Field
              Guide

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            Is the
 This guide will help determine that a recently-renovated area has
 been cleaned sufficiently. The Lead Dust Sampling Technician
 Field Guide should be used by lead dust sampling technicians.
 The guide provides protocols for conducting post-renovation
 clearance under EPA's Renovation, Repair, and Painting Rule
 (RRP) covering housing and child-occupied facilities built before
 1978, and clearance examinations under HUD's Lead Safe
 Housing Rule (LSHR) in federally-assisted housing built before
 1978. This guide also provides federal standards for maximum
 allowable contamination levels of residual      dust.
Take this guide with you on site when you perform clearance, including
visual inspections. It serves as a quick reminder of:
   ป  When and where to take lead dust clearance samples;
   ซ  The step-by-step instructions for taking a dust wipe sample; and
   ป  EPA/HUD clearance standards for lead dust.
Renovation activities that disturb lead-based paint can create lead dust so
proper cleanup after these jobs is critical. The purpose of lead dust
clearance is to determine if the area is safe for re-occupancy.
                    is
   ซ After renovation, repair, painting, and cleaning activities are
    finished in property built before 1978 and where children are
    assumed to spend time.
   ป After hazard reduction or maintenance activities in most federally-
    assisted  properties built before 1978 that are covered by HUD's
    LSHR,
Lead dust sampling technicians should NEVER  perform post-abatement
clearance. (Abatement—as opposed  to renovation, repair and painting —
is a term used for the complete removal of lead.) When performing
clearance, the lead dust sampling technician is required to bring  a copy of
his or her certificate of initial training to the worksite.
 ? :[--?f•? •-: r--:--'i ': "an                   or

   ป  One windowsil! sample and one floor sample within each room, hall
     way, or stairwell (no more than four rooms, hallways, or stairwells
     need be sampled).
   ซ  If the windows were not closed and covered with plastic during the
     renovation, also take one window trough sample in each  room, hall
     way, or stairwell (no more than four need be sampled).
   ป  One floor sample adjacent to the work area, but not in an area that
     has been cleaned.
For federally-assisted housing, take these samples if the work area is
contained, otherwise, clear the whole unit.
If          (-.i-:.'> i:. .•: :.                    or         or a

   ซ  One windowsill sample and one floor sample.
   ซ  If the windows were not closed and covered with plastic during the
     renovation, also take one window trough sample.
   ป  One floor sample adjacent  to the work area, but not in an area that
     has been cleaned.
  -  Disposable lead dust wipes
     (individually wrapped)         <'3/f" -I-.
  ป  Disposable gloves           *:;/;.-/  •            ^
  ป  Disposable shoe covers       w. ,   :.         rf;
  ป  Sample tubes with caps        *'ฑ  ' '^-..-^^'"'•f >
  ป  Re-usable templates         _ ^'''""""fe^^SS"1-*!;' "'''***!
  ป  Masking or painter's tape     ~'^ป^:^^^^%--*"rf^"~*~i:.
  ป  Ruler                        -f^Uvffi.a^""         .,f~-
  *  Sample collection forms      - "''^>^'-i->-----.,,,.,^ '  - ..  _.,.-;::&*":
  ป  Chain-of-custody forms
  ป  Markers, trash bags, labels, pens, re-sealable storage bags
  ป  Calculator
  ป  Sanitary wipes
Check with your laboratory for their sampling  requirements
                       Lead dust clearance testing for both
                       EPA's RRP Rule and HUD's LSHR requires a
                       visual inspection as a first step in the clearance
                       process:
                       -  Under both HUD and EPA rules,
                          the visual inspection is designed to
                          determine if the area is free of visible
                          dust and debris before lead dust
                          clearance testing can begin.
                       In addition, under HUD's rule the visual
                       inspection determines whether the  unit/work
                       area (interior and exterior) is clear of visible
conditions that can result in exposure to lead-based paint hazards:
  ป  Deteriorated paint
  ป  Chips or debris
  ป  Visible dust
Single or composite samples can be taken; however, single-surface
sampling is recommended to get results for specific surfaces. Use
durable, re-usable 12" x 12" sampling templates, a disposable template,
or use tape to lay out the sampling area.

                    on                               lay
               |
  ป  Clean template with a new wipe,
  ป  Tape template to surface.
  ป  If no template, outline with tape.
  ป  Using tape to lay out  the sample area, make sure that on floors
     the tape is laid in a square. On sills and troughs, the tape should
     be laid perpendicular to the sill.
  ป  DO NOT touch the area inside the template.
Note: Use disposable shoe covers when walking between buildings and
remove shoe covers before entering your vehicle to help minimize the
spreading of settled lead dust from one location to another.

     Use clean tubes.
     Label tube with ID number.
     Record ID number on sample collection form
     and chain-of-custody form.
     Partially unscrew tube cap.
     Place tube near sample area.

                    on

     Use disposable gloves.
     Use new gloves for each sample.
     DO NOT touch anything except the wipe after
     putting on the gloves.

               I                                    in
                tube
                                                                                                                                                                                        Start at corner and wipe sideways.
     Do not touch other objects.
     Press the wipe down firmly
     at an upper corner of the
     sample area.
     Make as many "S"-like
     motions as needed to wipe
     the entire sample area,
     moving from side to side.
     Do not cross the outer border
     of the tape or template,         I        •      .  -• •
     Fold the wipe in half, keeping    j  •••;  '  "•- ฃ  ,.:---?'„ -  - -'!"'''_,,__--
     the dirty side in, and repeat      I      "l'-.--- •'.'". -.:...-.'. .-,j;*--~--
     the wiping procedure in the      I      ..       - ".",""""''>!'" "r ••"' " •
     original direction in a forward    \   •••—ฃ• ,.:,  .     -'-- .  '  „--'"'"
     and back motion.              I        '      -.   _..^~"
     Fold the wipe again and  repeat    "ฐw w'Pe'" a fฐrw^ and back motion.
     the wiping procedure, concetrating on collecting dust from the
     edges and corners of the sample area.

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    Fold the wipe again with the sample side folded in, and place the
    folded wipe into the sample tube.
    Cap the container. Discard the gloves into a trash bag.
    Label the centrifuge tube and record the dimensions of the
    sampling area.

    Measure width and length (unless template was used),
    - Length of sill or trough between edges of tape
    	Width of sill or trough, measure at tape
    Measure to 1/8 inch.
    Do not remove tape until after measurements are taken.

                                                 on
    Calculate the sample area and record on sample collection
    form and laboratory chain-of-custody form.

                      up
    Clean template with a clean wipe; place in a plastic bag for storage.
    Remove materials from site:
    - Gloves,  tape from floors and windows, and used shoe covers
    	 Put items in trash bag, NOT in client's trash containers
    Clean face and hands with warm, soapy water.
    	 Use sanitary wipes if you do not have access to warm, soapy water
    Send the samples to a laboratory recognized by the National Lead
    Laboratory Accreditation Program (NLLAP) as being proficient in
    lead in dust analysis. For information on locating EPA-accredited labs,
    visit http://www.epa.gov/lead/pubs/nllaplist.pdf.
   ป Compare the laboratory results to the EPA clearance standards for
    maximum allowable residual lead dust provided below:
    - Floors: 40 micrograms per square foot ((.ig/ft2)
    - Interior windowsills: 250 |J.g/ft2
    - Window troughs: 400 |-ig/ft2
These standards are for single-surface samples. The clearance standards
for composite samples will be different depending on how many sub-
samples are collected. Before collecting composite samples, check with
your laboratory. Note that HUD discourages composite sampling when
clearing federally-assisted housing.
    Use the standard report format.
    Sign the report.
1-800-424-LEAD (1-800-424-5323)
http://www.epa.gov/lead/pubs/nlic.htm

For a wide range of lead information—from outreach brochures to
technical reports—on lead-based paint in the home,

National      Laboratory              Program
http://www.epa.gov/lead/pubs/nllaplist.pdf

For information on locating EPA-accredited labs.

      of
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW (7404T)
Washington, DC 20460
202-566-0500
http://www.epa.gov/lead

For information on EPA lead-based paint regulations.

Office of                                Control
U.S. Department of Housing and Urban Development (HUD)
451 Seventh Street, SW
Washington, DC 20410
202-755-1785
http://www.hud.gov/offices/lead

For information on the HUD lead-based paint regulations and technical
assistance in complying with the HUD regulations for HUD-funded work.
                                                                           United States
                                                                           Environmental
                                                                           Protection Agency
                        Office of
                        Pollution Prevention
                        and Toxics
                                                                                                                                                                                                  EPA-W-04-022
                                                                                                                                                                                                  May 2009
a


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