JOINT EPA- HUD CURRICULUM

        June 2013
                                1
                                    s
Model Certified Lead Dust Sampling
    Technician Training Course
         STUDENT MANUAL
                              EPA-740-R-13-001

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                                                                           Student 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 refresh previously trained individuals how to
conduct non-abatement lead dust clearance testing. This course is designed to be taught over
approximately an 4.5-hour time period with at least 30 minutes 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; and

   •   Explain the results to the client.

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

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

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

   •   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;

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                                                                          Student Overview
   •   Rehabilitation specialists;

   •   Home inspectors; and

   •   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
       an accredited lab, how to submit samples, and how to interpret the results and determine
       if they are acceptable.

Part 3: Application

   •   Chapter 5: Writing the Report covers how to prepare the report and explain the results
       to the client.

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.

   •   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.

   •   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 to the Lead Dust Sampling Technician Field Guide as appropriate.

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Chapter 1: Introduction

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Chapter 1: Introduction
                                      Chapter 1



                                      Introduction
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         Welcome to the Lead Dust Sampling Technician Training Course.
Lead Dust Sampling Technician Training Course
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Chapter 1: Introduction
                                                                            1-2
                      Course Objectives
                         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
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          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 HUD's LSHR regulations for most
          renovations. By the end of the course, students will be able to perform the actions listed
          above.
Lead Dust Sampling Technician Training Course
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Chapter 1: Introduction
                     Overview of Student Materials
                        Student Manual

                        Attachments

                        Appendices

                        Lead Dust Sampling Technician
                        Field Guide
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         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.
Lead Dust Sampling Technician Training Course
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Chapter 1: Introduction
                                                                            1-4
                      Health Risks of Lead

                       •  In children:
                          - Damage to the brain and central nervous system;
                            can cause developmental and behavioral
                            problems.
                       •  In pregnant women:
                          -  Damage to the fetus
                       •  In workers:
                          - Elevated blood pressure
                          - Loss of sex drive and/or capability
                          - Physical fatigue
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          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
          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
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Chapter 1: Introduction
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                      Why Are Dust and Debris a Problem?
                          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.
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          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.
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Chapter 1: Introduction
                     Regulations Addressing Lead
                     Hazards in Housing

                     •  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.
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Chapter 1: Introduction
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                      Overview of the Lead  Hazard
                      Evaluation Courses


                       •  Lead Dust Sampling Technician
                       •  Lead-Based  Paint Inspector
                       •  Risk Assessor
                          - All three disciplines can conduct dust
                            clearance testing after an RRP project
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          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.
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Chapter 1: Introduction
                    Lead Dust Sampling Technician
                       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 HDD's regulations.
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Chapter 1: Introduction
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                        A Lead Dust Sampling Technician
                         Can...

                         •  Perform post-renovation lead dust clearance
                            testing under EPA's RRP Rule
                         •  Perform a clearance examination after hazard
                            reduction or maintenance activities in  most
                            properties covered by HUD's LSHR
                         Is Not Allowed To...
                         •  Perform clearance after an abatement
                         •  Sample paint for lead content
                         •  Sample soil for lead
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           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.
           While lead dust sampling technicians can conduct post-renovation 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 or risk assessor.
           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.
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Chapter 1: Introduction
                     EPA's 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, 2008 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.
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          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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Chapter 1: Introduction
                        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
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             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 muttifamily 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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Chapter 1: Introduction
                                                                            1-12
                      EPA's RRP Rule - (cont.)

                       • You must be a certified LOST to perform post-
                         renovation clearance testing  under EPA's RRP
                         Rule.
                       • Certified LDSTs must complete a refresher course
                         within 5 years of their previous certification.
                       • Successful completion of this course completes
                         the re-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.
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          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-renovation 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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Chapter 1: Introduction
                                                                        1-13
                     EPA's RRP Rule - (cont.)
                        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.
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         More details on all these topics are discussed later in the course.
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Chapter 1: Introduction
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                      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.
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          HUD'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.
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Chapter 1: Introduction
                                                                             1-15
                       HUD's LSHR-(cont.)
                          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.
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          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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Chapter 1: Introduction
                     HUD's LSHR-(cont-)

                      •  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.
                                                                       1-16
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         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 following types of
evaluations




Is not qualified to
perform


Training/Certification
required to perform
evaluations


Skills
















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.
1-17
Attachment

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Chapter 2: Visual Inspection

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Chapter 2: Visual Inspection
                                    Chapter 2



                                 Visual Inspection
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Chapter 2: Visual Inspection
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                    Objectives

                     • 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
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            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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Chapter 2: Visual Inspection
                                                                             2-3
                      Visual Inspection
                         Under both EPA's and
                         inspection is the first st
                         process.
                         The visual inspection d
                         unit/work area (interior
                         visible conditions that c
                         lead-based paint hazar
                          - Chips or debris
                          - Visible dust
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             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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Chapter 2: Visual Inspection
                     Visual Inspection - EPA RRP Lead
                     Dust Clearance Testing

                      •  At the conclusion of the renovation, the certified
                        renovator may have conducted a visual inspection
                        to look for paint chips, dust, and debris.
                      •  The LOST must conduct a separate visual
                        inspection of the work area to ensure that the area
                        is free of debris and ready for lead dust sampling.
                      •  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.
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                                                                         2-4
             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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Chapter 2: Visual Inspection
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                     Visual Inspection - HUD LSHR

                      •  HUD's rule requires identification of deteriorated
                        paint
                      •  Whole-unit clearance generally required 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 sampling may
                        begin.
                         - See Attachment 2-A and 2-B
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III
             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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Chapter 2: Visual Inspection
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                     Visual Inspection - HUD LSHR
                         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
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             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 HUD'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.
               -•WV OfV^"
                      Dust sampling is not required for exterior work. There are no dust-lead
              clearance standards for porches, balconies, railings, or other horizontal exterior
              features.
Lead Dust Sampling Technician Training Course
                                                                       2-6

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Chapter 2: Visual Inspection
                                 Exterior Debris
                                                                      2-7
                     PDA     Lead Dust Sampling Technician
                     CriT^                 -inn
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Chapter 2: Visual Inspection
                      Visual Inspection - HUD LSHR

                       •  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.
                        PDA     Lead Dust Sampling Technician
                        dlf\                   -inn
                                             June 20 13
29 12:25PM
              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.
Lead Dust Sampling Technician Training Course
                           2-8

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Chapter 2: Visual Inspection
                                                                             2-9
                      Visual  Inspection - HUD LSHR
                         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
** PDA
 fdlf\
                                  Lead Dust Sampling Technician
                                                -inn
                                            June 20 13
             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.
Lead Dust Sampling Technician Training Course
                                                                         2-9

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Chapter 2: Visual Inspection
                   Visual Inspection - HUD LSHR



                                  Chipping Paint
                    PDA    Lead Dust Sampling Technician

                    dlf\                -inn
                                     June 2013
                                                                 2-10
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Chapter 2: Visual Inspection
                   Visual Inspection - HUD LSHR
                                   Holes in wall
                    PDA    Lead Dust Sampling Technician

                    dlf\                -inn
                                     June 2013
                                                                 2-11
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Chapter 2: Visual Inspection
                   Visual Inspection - HUD LSHR
                                Deteriorated Paint
                    PDA    Lead Dust Sampling Technician

                    dlf\                -inn
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                                                                 2-12
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Chapter 2: Visual Inspection
                   Visual Inspection - HUD LSHR



                                   Cracking Paint
                     PDA    Lead Dust Sampling Technician

                     dlf\                 -inn
                                       June 2013
                                                                   2-13
            The arrow here points to a crack in the paint.
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Chapter 2: Visual Inspection
                    Visual Inspection - HUD  LSHR
                                  Moisture Damage
                     PDA    Lead Dust Sampling Technician

                     dlf\                 -inn
                                       June 2013
                                                                    2-14
            Moisture can be the cause of many paint problems. In this case, it is causing the

            paint to bubble.
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Chapter 2: Visual Inspection
                                                                2-15
                  Visual Inspection - HUD LSHR



                                 Friction Damage
                    PDA     Lead Dust Sampling Technician

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Chapter 2: Visual Inspection
                                                                      2-16
                    Visual Inspection - HUD LSHR


                     • Be precise about locations.
                     • Write down results as you go.
                     • Write down other information, indicating
                       source.
                     • See sample visual inspection form.
                       (Attachment 2-B)
                      PDA    Lead Dust Sampling Technician
                      Cr^\                 ™n
                                        June 2013
            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.
Lead Dust Sampling Technician Training Course
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Chapter 2: Visual Inspection
                                                                         2-17
                     Review

                      •  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.
                      •  Visual inspection as part of clearance is the
                        responsibility of the dust sampling technician.
                      •   Recordkeeping should be methodical.
** PDA
 XCr^\
                                 Lead Dust Sampling Technician
                                              ™n
                                          June 20 13

                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.
Lead Dust Sampling Technician Training Course
                                                                     2-17

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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.)









2-18
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.


2-19
Attachment

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Chapter 3: Lead Dust Wipe Sampling

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Chapters: Lead Dust Wipe Sampling
                                                                3-1
                                  Chapter 3
                           Lead Dust Wipe Sampling
                    PP/V    Lead Dust Sampling Technician
                    tliTA                ™n
                                     June 2013
Lead Dust Sampling Technician Training Course
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Chapters: Lead Dust Wipe Sampling
                 Objectives

                  • 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
£L PP/V
 ^ClJTA
                           Lead Dust Sampling Technician
                                      ->rvi->
                                  June 20 1 3
                                                            3-2
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                                                         3-2

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Chapters: Lead Dust Wipe Sampling
                     A Lead Dust Wipe Measures:

                      •  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
£L PP/V
 ^ClJTA
                                Lead Dust Sampling Technician
                                              ->rvi->
                                         June 20 1 3
                                                                        3-3
         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.
Lead Dust Sampling Technician Training Course
                                                                     3-3

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Chapters: Lead Dust Wipe Sampling
                                                                             3-4
                      Sampling Strategy
                         You must wait at least 1 hour after final cleanup is
                         completed and visual inspection is passed before
                         collecting samples to allow time for dust to settle out of
                         the air and onto surfaces.
                         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.
£L PP/V
 ^ClJTA
                                  Lead Dust Sampling Technician
                                                 ->rvi->
                                            June 20 1 3
          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.

          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.
Lead Dust Sampling Technician Training Course
                                                                         3-4

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Chapter 3: Lead Dust Wipe Sampling
                                                                                 3-5
                        Lead  Dust Wipe Sampling
                        Locations:  EPA RRP Rule
                        •  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.
£L PDA
 ^ClJTA
                                    Lead Dust Sampling Technician
                                                   ->rvi->
                                              June 20 1 3
          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.
Lead Dust Sampling Technician Training Course
                                                                             3-5

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Chapters: Lead Dust Wipe Sampling
                   Lead Dust Wipe Sampling
                   Locations:  EPA RRP Rule - (cont.)

                    •  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.
                                                                  3-6
£L PP/V
 ^ClJTA
                              Lead Dust Sampling Technician
                                          ->rvi->
                                      June 20 1 3
Lead Dust Sampling Technician Training Course
                                                               3-6

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Chapters: Lead Dust Wipe Sampling
                                                                              3-7
                       HUD  Clearance

                       •  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.
£L PDA
 ^ClJTA
                                   Lead Dust Sampling Technician
                                                 ->rvi->
                                            June 20 1 3
          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 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.
Lead Dust Sampling Technician Training Course
                                                                          3-7

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Chapters: Lead Dust Wipe Sampling
                  Activity: Where To Take Samples

                   • 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.
                                                               3-8
£L PP/V
 ^ClJTA
                            Lead Dust Sampling Technician
                                        ->rvi->
                                    June 20 1 3
Lead Dust Sampling Technician Training Course
                                                            3-8

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Chapters: Lead Dust Wipe Sampling
                 Remember...

                  • 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.
                                                            3-9
£L PP/V
 ^ClJTA
                           Lead Dust Sampling Technician
                                      ->rvi->
                                  June 20 1 3
Lead Dust Sampling Technician Training Course
                                                         3-9

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Chapters: Lead Dust Wipe Sampling
                                                            3-10
                  How To Take Dust Wipe Samples
                    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.
£L PP/V
 ^ClJTA
                           Lead Dust Sampling Technician
                                      ->rvi->
                                   June 20 1 3
Lead Dust Sampling Technician Training Course
                                                         3-10

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Chapters: Lead Dust Wipe Sampling
                       Dust Wipe Sampling  Materials

                        •  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 scalable lid.
                        •  Reusable template - A 12" x 12" reusable template for
                          floors.
                                                                               3-11
^^^^
                                    Lead Dust Sampling Technician
                                                  ^ f\ 1 •*!
                                              June 20 1 3
          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.
Lead Dust Sampling Technician Training Course
                                                                           3-11

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Chapters: Lead Dust Wipe Sampling
                                                                              3-12
                       Dust Wipe Sampling Materials -  (cont.)
                          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
£L PP/V
 ^ClJTA
                                   Lead Dust Sampling Technician
                                                  ->rvi->
                                             June 20 1 3
          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.
Lead Dust Sampling Technician Training Course
                                                                          3-12

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Chapters: Lead Dust Wipe Sampling
                                                                                         3-13
                          Blank Samples
                              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

                                        Lead Dust  Sampling Technician
                                                    June 2013
            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.
Lead Dust Sampling Technician Training Course
3-13

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Chapters: Lead Dust Wipe Sampling
                                                                             3-14
                       How To Collect Samples
                       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.
G PP/V
 ^tliTA
                                   Lead Dust Sampling Technician
                                                 ™n
                                            June 20 13
          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.
Lead Dust Sampling Technician Training Course
                                                                         3-14

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Chapters: Lead Dust Wipe Sampling
                                                                            3-15
                      Step 1:  Put on Disposable Shoe
                      Covers and Lay  Out the Sample Area

                       •  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.
£L PP/V
 ^ClJTA
                                  Lead Dust Sampling Technician
                                                ->rvi->
                                            June 20 1 3
          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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                                                                        3-15

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Chapters: Lead Dust Wipe Sampling
                                                                       3-16
                     Taping Template to Floor
£L PDA
 ^ClJTA
                                Lead Dust Sampling Technician
                                             ->rvi->
                                         June 20 1 3
         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.
Lead Dust Sampling Technician Training Course
                                                                   3-16

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Chapters: Lead Dust Wipe Sampling
                                                                        3-17
                     Outlining Sample Area with Tape
£L PP/V
 ^ClJTA
                                Lead Dust Sampling Technician
                                             ->rvi->
                                         June 20 1 3
         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.
Lead Dust Sampling Technician Training Course
                                                                    3-17

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Chapters: Lead Dust Wipe Sampling
                                                                              3-18
                       Taping Window Sill
£L PDA
 ^ClJTA
                                   Lead Dust Sampling Technician
                                                  ->rvi->
                                             June 20 1 3
          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.
Lead Dust Sampling Technician Training Course
                                                                          3-18

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Chapters: Lead Dust Wipe Sampling
                                                                      3-19
                     Step 2:  Prepare the Tubes

                     •  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.
                      PP/V     Lead Dust Sampling Technician
                      ClJTA                  ->rvi->
                                         June 2013
         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.
Lead Dust Sampling Technician Training Course
3-19

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Chapters: Lead Dust Wipe Sampling
                                                                     3-20
                    Step 3: Put on Clean Gloves

                     •  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.
£L PP/V
 ^ClJTA
                               Lead Dust Sampling Technician
                                            ->rvi->
                                        June 20 1 3
         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.
Lead Dust Sampling Technician Training Course
                                                                 3-20

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Chapters: Lead Dust Wipe Sampling
                    Step 4: Wipe Sample Areas

                     •  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.
                                                                    3-21
£L PP/V
 ^ClJTA
                               Lead Dust Sampling Technician
                                           ->rvi->
                                       June 20 1 3
Lead Dust Sampling Technician Training Course
                                                                3-21

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Chapters: Lead Dust Wipe Sampling
                      Step 4: Wipe Sample Area - 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" like motion). Folding
                          wipe carefully helps to prevent the loss of any collected
                          dust.

                                  Lead Dust Sampling Technician         j
                                            June 2013
          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.
Lead Dust Sampling Technician Training Course
3-22

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Chapters: Lead Dust Wipe Sampling
                      Step 4: Wipe Sample Area - Floors
                      (cont.)


                       •  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
£L PP/V
 ^ClJTA
                                  Lead Dust Sampling Technician
                                               ->rvi->
                                           June 20 1 3
          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.
Lead Dust Sampling Technician Training Course
                                                                      3-23

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Chapter 3: Lead Dust Wipe Sampling
                                                                         3-24
                     Step 4: Wipe Sample Area - Floors
                     (cont.)


                      • 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.
£L PP/V
 ^ClJTA
                                 Lead Dust Sampling Technician
                                              ->rvi->
                                          June 20 1 3
          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.
Lead Dust Sampling Technician Training Course
                                                                     3-24

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Chapters: Lead Dust Wipe Sampling
                    Floor Sampling
                   £L PDA    Lead Dust Sampling Technician
                   ^ClJTA                ->rvi->
                                       June 2013
                                                                   3-25
Lead Dust Sampling Technician Training Course
3-25

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Chapters: Lead Dust Wipe Sampling
                    Floor Sampling
                                                                   3-26
                   £L PDA    Lead Dust Sampling Technician
                   ^ClJTA                ->rvi->
                                       June 2013
Lead Dust Sampling Technician Training Course
3-26

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Chapters: Lead Dust Wipe Sampling
                    Floor Sampling
                                                                   3-27
                   £L PP/V    Lead Dust Sampling Technician
                   ^ClJTA                ->rvi->
                                       June 2013
Lead Dust Sampling Technician Training Course
3-27

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Chapters: Lead Dust Wipe Sampling
                                                                            3-28
                      Step 4: Wipe Sample Area -
                      Windowsills and Troughs

                       • 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.
£L PP/V
 ^ClJTA
                                  Lead Dust Sampling Technician
                                                ->rvi->
                                            June 20 1 3
          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.
Lead Dust Sampling Technician Training Course
                                                                        3-28

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Chapters: Lead Dust Wipe Sampling
                                                                       3-29
                     Step 4: Wipe Sample Area -
                     Windowsills and Troughs - (cont.)

                      •  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.
£L PP/V
 ^ClJTA
                                Lead Dust Sampling Technician
                                             ->rvi->
                                         June 20 1 3
         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 uniquely 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.
Lead Dust Sampling Technician Training Course
                                                                   3-29

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Chapters: Lead Dust Wipe Sampling
                    Sampling a Windowsill
                   G PP/V     Lead Dust Sampling Technician
                    ^ClJTA                ->rvi->
                                       June 2013
                                                                    3-30
         Note how the lead dust sampling technician is holding the wipe and moving across the

         windowsill.
Lead Dust Sampling Technician Training Course
3-30

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Chapters: Lead Dust Wipe Sampling
                                                                      3-31
                     Sampling a Window Trough
                                Lead Dust Sampling Technician
                                        June 2013
         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.
Lead Dust Sampling Technician Training Course
3-31

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Chapters: Lead Dust Wipe Sampling
                     Step 5: Measure the Sample Area

                      •  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.
                                                                       3-32
£L PP/V
 ^ClJTA
                                Lead Dust Sampling Technician
                                             ->rvi->
                                         June 20 1 3
         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.
Lead Dust Sampling Technician Training Course
                                                                    3-32

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Chapters: Lead Dust Wipe Sampling
                                                                        3-33
                     Measuring Window Sill
£L PP/V
 ^ClJTA
                                Lead Dust Sampling Technician
                                              ->rvi->
                                          June 20 1 3
         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.
Lead Dust Sampling Technician Training Course
                                                                    3-33

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Chapter 3: Lead Dust Wipe Sampling
                                                                          3-34
                      Step 6: Record Sample Area on
                      Forms

                      •  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.
£L PP/V
 ^ClJTA
                                 Lead Dust Sampling Technician
                                               ->rvi->
                                           June 20 1 3
            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.
Lead Dust Sampling Technician Training Course
                                                                      3-34

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Chapters: Lead Dust Wipe Sampling
                      Step 7: Clean  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
£L PP/V
 ^ClJTA
                                  Lead Dust Sampling Technician
                                                ->rvi->
                                            June 20 1 3
                                                                            3-35
          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.
Lead Dust Sampling Technician Training Course
                                                                        3-35

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Chapters: Lead Dust Wipe Sampling
                   Hands-on Activity: Let's 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.
                                                                 3-36
£L PP/V
 ^ClJTA
                             Lead Dust Sampling Technician
                                         ->rvi->
                                     June 20 1 3
        Activity: Take samples on a variety of surfaces - windowsills, troughs, and floors.
Lead Dust Sampling Technician Training Course
                                                              3-36

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Chapters: Lead Dust Wipe Sampling
                                                                                3-37
                       Avoiding Common  Mistakes

                        •  These common mistakes can give
                           incorrect results:
                           - Incorrect measurement
                           - Contaminated wipe
                           - Contaminated gloves
                           - Sample area is disturbed
                           - Sloppy recording
                         PP/V     Lead Dust Sampling Technician
                         tliTA                    ™n
                                              June 2013
           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.
Lead Dust Sampling Technician Training Course
3-37

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Chapters: Lead Dust Wipe Sampling
                                                                         3-38
                     Composite  Dust Wipe  Sampling
                        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.
£L PP/V
 ^ClJTA
                                 Lead Dust Sampling Technician
                                              ->rvi->
                                          June 20 1 3
          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.
Lead Dust Sampling Technician Training Course
                                                                     3-38

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Chapters: Lead Dust Wipe Sampling
                                                                           3-39
                      Rules for a Composite Sample


                       •  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
                         templates where possible.
                       •  Interior sills or troughs:  use smallest sill or trough
                         to set area
£L PP/V
 ^ClJTA
                                  Lead Dust Sampling Technician
                                                ->rvi->
                                           June 20 1 3
          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.
Lead Dust Sampling Technician Training Course
                                                                       3-39

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Chapters: Lead Dust Wipe Sampling
                                                                       3-40
                     Composite Sampling Procedures

                      •  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.
£L PP/V
 ^ClJTA
                                Lead Dust Sampling Technician
                                             ->rvi->
                                         June 20 1 3
               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.
Lead Dust Sampling Technician Training Course
                                                                   3-40

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Chapters: Lead Dust Wipe Sampling
                                                          3-41
                 Proper Hygiene After Completing
                 Sampling Job

                  •  Hand washing
                  •  Face washing
                  •  Check your clothing and shoes
                    (especially soles) before leaving
                    work site
                £L PP/V    Lead Dust Sampling Technician
                 ^ClJTA               ->rvi->
                                 June 2013
Lead Dust Sampling Technician Training Course
3-41

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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:	
3-42
              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)
11%" x 12V
231 V x 27/8"
n'V'xnV
24V x 3V4"
H3/4" 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_
3-43
              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
                                                       1/3
                                                       2/3
                                                       1/2
Decimal
 0.250
 0.500
 0.750
 0.333
 0.667
 0.500
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 !/> inches and a width of 5 % inches to
square feet.
*     Convert fractions to decimals:         20 !/> in —> 20.500 in  5 % in —> 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
3-44
         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































3-45
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










3-46
Attachments

-------
Chapter 4: Selecting a Laboratory

-------
Chapter 4: Selecting a Laboratory and Interpreting Results
                                     Chapter 4



                               Selecting a Laboratory

                               and  Interpreting Results
                       PPA     Lead Dust Sampling Technician
                       CljTA                 inn
                                        June 2013
                                                                    4-1
Lead Dust Sampling Technician Training Course
4-1

-------
Chapter 4: Selecting a Laboratory and Interpreting Results
                       Objectives


                        • Select an EPA-recognized lab
                        • Maintain a chain of custody

                        • Review and interpret lab results
                      ij PDA    Lead Dust Sampling Technician
                      V^CriTA                 onn
                                           June 2013
             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
Lead Dust Sampling Technician Training Course
4-2

-------
Chapter 4: Selecting a Laboratory and Interpreting Results
                        Selecting a  Laboratory
                         •  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) at
                              1-800-424-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.
                       ij PDA    Lead Dust Sampling Technician
                      V^CriTA                  onn
                                             June 2013
             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 atwww.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
Lead Dust Sampling Technician Training Course
4-3

-------
Chapter 4: Selecting a Laboratory and Interpreting Results
                                                                       4-4
                       Questions To Ask Laboratories

                       •  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?

                     G PDA    Lead Dust Sampling Technician
                     XX CriTA             .    . A. _
                                          June 2013
!|
 *
             Review Attachment 4-A: Questions To Ask Laboratory.
Lead Dust Sampling Technician Training Course
                    4-4

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Chapter 4: Selecting a Laboratory and Interpreting Results
                                                                    4-5
                      Quality Control in the Field


                      • 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.
                     Q PP/V    Lead Dust Sampling Technician
                    X/QjTA                -IAI~>
                                        June 2013
            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.
Lead Dust Sampling Technician Training Course
4-5

-------
Chapter 4: Selecting a Laboratory and Interpreting Results
                       Review Your Sample Collection Form


                        •  Confirm all information is recorded clearly
                          and correctly.
                          -Sample numbers
                          - Sample locations
                          - Sample dimensions
                        •  Keep a copy for your records and note
                          blanks.
                        PDA     Lead Dust Sampling Technician
                        CriTA                 onn
                                           June 2013
             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.
Lead Dust Sampling Technician Training Course
4-6

-------
Chapter 4: Selecting a Laboratory and Interpreting Results
                        Chain of Custody
                           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.
                       ij PDA    Lead Dust Sampling Technician
                      V^CriTA                  onn
                                            June 2013
          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.
Lead Dust Sampling Technician Training Course
4-7

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Chapter 4: Selecting a Laboratory and Interpreting Results



















Project Name
Project Locat
Project Numb.
on:

erNo.:

Weekend'
nciat^WeforaNKsts

Samples










Date











Oil
Sludge
g. Vses<io'iaHonnsBsneei
Iter(PNMO) i ] Water.Drlnking
«er(TSP) 1 ] Compliance
i IWipe
[ jWipe.Composi
1 1












Sample Identifies!
(eg Employee, SSN, Bldg

*"*

Subr
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ittingC^.

rrUeStSft'rSPeC/a'reP

siting D
	

data packages]

STATE WHERE SAMPLES WERE COLLECTED


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Resp Dust (KIOSH 0600

Silita-XRD|NtO£H?5OO)

-4,1










Sin.'.',- C'.il'rii.-,i«.C,i=vtr. !V Inf-mistinn
Sampled by
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Received in 1
JFX 1 ]DHL
ME |S
o lab by[N
b by (NAME
[ JUPS [





Alped










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P
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FOR ASBESTOS AIR:

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Metals^itract
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ORGANICS TESTS and otliw Analyses
£T!^£££^S£























































o: --3--:; :=•;-.- ->=, : ,--. !T=;':j ::• '==.;; ir:-,.O. ('i,.-if..; '« - j -,-, . C: 1 3- ,r ,'i i. ' i':,i-.; ->'-lj(i» i- _^-i [:i.-i: ir n - ••(:•• i LT
JREL



ICWE/TIMEl

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ed WAYBILL* Stota '-•:./• ..
n
[i
Sample return re
Ambient temp [
pH ]C1
quested
[ 1RI

IS


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

-------
Chapter 4: Selecting a Laboratory and Interpreting Results
                       Evaluating Laboratory Results for
                       Single Samples

                        •  Check for appropriate units (uxg/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
                      ij PDA     Lead Dust Sampling Technician
                     V^CriTA                 onn
                                           June 2013
             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 ug/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.
Lead Dust Sampling Technician Training Course
4-9

-------
Chapter 4: Selecting a Laboratory and Interpreting Results
                                                              4-10
                    Activity: Interpreting Laboratory

                    Results



                    • Turn to Attachment 4-D



                    • Answer the questions.



                    • Be prepared to explain your answers.
                   O PPA    Lead Dust Sampling Technician
                    XCljTA               inn
                                     June 2013
Lead Dust Sampling Technician Training Course
4-10

-------
Chapter 4: Selecting a Laboratory and Interpreting Results
4-11
Evaluating Laboratory Results for
Composite Samples
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
,J*J"T»V
O PPA Lead Dust Sampling Technician / ||l|j|| \
'CrM June 20 13 <•>

              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.
Lead Dust Sampling Technician Training Course
4-11

-------
Chapter 4: Selecting a Laboratory and Interpreting Results
                                                                       4-12
                       Avoiding Common Mistakes

                       •  Mistaking weight (mass) for surface
                          loading by  using incorrect units (jag for
                          Not submitting blank samples
                          -Labeling or recording in the sample
                            log blank samples as blanks
                          Not maintaining a chain of custody
                      ij PDA    Lead Dust Sampling Technician
                     V^CriTA                 onn
                                          June 2013
            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 ug or ug/ft2. If they are in ug, you
                 must convert them to ug/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.
Lead Dust Sampling Technician Training Course
4-12

-------
Chapter 4: Selecting a Laboratory and Interpreting Results
                                                                4-13
                    Summary

                     •  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.
                   Q PP/V    Lead Dust Sampling Technician
                   X/QjTA               -IAI~>
                                      June 2013
Lead Dust Sampling Technician Training Course
4-13

-------
                       Attachment 4-A: Questions to Ask Laboratory
Is the laboratory recognized
by NLLAP?
All samples must be analyzed by an NLLAP laboratory. You can
contact the NLIC Clearinghouse at 1-800-424-LEAD for an up-to-date
list of NLLAP-recognized laboratories. Even after selecting a laboratory,
you should check the laboratory's accreditation every 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.
4-14
                                                     Attachments

-------
   Blank Chain of Custody Form
4-15                                 Attachments

-------

Project Name
Submitting Co.




Special Instructions [include requests for special reporting or data packages]
Project Location :
Project Number:
Purchase Order No.:
Turn Around Time
] Same day*
] 1 business day*
] 2 business days*
] 3 business days*
[ ] STANDARD (5 bus. days)
] Standard Full TCLP(10d)
] Weekend*
I
* not available tor all tests
Schedule rush organics, multi-
metals & weekend tests in advance.

Sample #










Date
Sampled










STATE WHERE SAMPLES WERE COLLECTED



Matrix / Sample Type (Select ONE) Tests / Analytes (Select ALL that Apply)
All samples on form should be of SAME j Asbestos Air / Fiber Counts Asbestos Bulk /Asb ID
matrix type . Use additional forms as needed. [] PCM (NIOSH 7400) [] PLM (EPA 600, 1982)
[ ]Air [] Solid ]TEM(AHERA) [] PLM (EPA Point Count)
] Aqueous [] Waste [] TEM (EPA Level II) [] PLM (Qualitative only)
[]Bulk [ ]Wastewater [] [ ] NYELAP 198.1/.4/.6
] Hi-Vol Filter (PM10) [ ] Water.Drinking Miscellaneous Tests [] CAELAP (EPA Interim)
] Hi-Vol Filter (TSP) [] Compliance [] Total Dust (NIOSH 0500) [ ] TEM (Chatfield)
[Oil [ [Wipe [ IResp. Dust (NIOSH 0600) [ ]
] Paint
] Sludge
]Soil
[ ] Wipe, Composite [ ] Sil
[] MSil
1 1 [ 1
ca - FTIR (NIOSH 7602) FOR ASBESTOS AIR:
ca - XRD (NIOSH 7500) TYPE OF RESPIRATOR
USED:
Metals-Total Cone.
]Lead
] RCRA Metals
1
1
Metals-Extract
] TCLP / Lead
] TCLP /RCRA Metals
] TCLP/ Full (w/ organics)
1
1
Organics Wipes Information for Air Samples Organics
Time
Sampled










Sample Identification
(e.g. Employee, SSN, Bldg, Material)










Sample Collection & Custody Information
Sampled by
Relinquished
Received in It
[ ]FX [ ]DHL
Unusual Sample
Wiped
Area (ft2)










Type1
A,B,P,E










Time2
Start










Stop










Flow Rate3
Start










Stop










Total4
AirVol










# con-
tainers










.ab Use-WO*
<\cct#
3hone $
-AX#
ORGANICS TESTS and other Analyses
JOTE: All samples for organics should be kept at 4°C
rom collection until testing. Schedule rush analyses in
advance. Indicate preservatives added & media type.
Indicate analysis method for organics tests.























































pe: A=area B=blank P=persona E=excursion 2Beginning/End of Sample Period 3Pump Calibration in Liters/Minute "Volume in Liters [time in min *flowinLVrr
[NAME] [SIGNATURE] [DATE/TIME]
to lab by[N/
ib by [NAME
[ ]UPS [
Condition Not
ri
\MEl [SIGNATURE] [DATE/TIME] F 1
1 [SIGNATUREl
]USM [ ]
ed:
HD [ 1DB f 1COURIER
WAYBILL #

DATE/TIME
]
F 1
Sample return re
Ambient temp [
pH 1CI
quested
] Cool °C
F 1RF
Chain-of-Custody documentation continued internally within 1
]S
ab.

-------
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

in x in = in2

in2 -144= ft2

     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
calculate micrograms per square foot (|ig/ft2)
Area = ft2
Lead = jig

Hg -H ft2 = ng/ft2

     4-17
Attachments

-------
               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
Gig)
23
150
260
97
ug/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?

4-18
Attachments

-------
Chapter 5: Writing and Delivering the
              Report

-------
Chapter 5: Writing and Delivering the Report
                                                                    5-1
                                    Chapter 5
                                Writing the  Report
                     CDA     Lead Dust Sampling Technician
                     CliTA                 onn
                                       June 2013

Lead Dust Sampling Technician Training Course
5-1

-------
Chapter 5: Writing and Delivering the Report
                    Objectives
                       List the items that make up a complete
                       lead dust clearance test report.

                       Make the report easy for the client to
                       understand.
                  &EPA
Lead Dust Sampling Technician
         June 2013
            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
Lead Dust Sampling Technician Training Course
                                                     5-2

-------
Chapter 5: Writing and Delivering the Report
                   Contents of Report - EPA RRP

                   •  Cover Page
                   •  Summary of Sampling Results
                   •  Visual Inspection Results
                   •  Laboratory Analytical Results
                   •  Renovate Right Pamphlet
                      -  (Appendix B)
                 SEPA
Lead Dust Sampling Technician
        June 2013
m
           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.
Lead Dust Sampling Technician Training Course
                                                   5-3

-------
Chapter 5: Writing and Delivering the Report
                  Contents of Report - HUD LSHR

                  • 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

                4>EPA
Lead Dust Sampling Technician
        June 2013
           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.
Lead Dust Sampling Technician Training Course
                                                5-4

-------
Chapter 5: Writing and Delivering the Report
                   Contents of Report - HUD LSHR (Cont.)

                    •  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.
                              Lead Dust Sampling Technician
                                       June 2013
            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.
Lead Dust Sampling Technician Training Course
5-5

-------
Chapter 5: Writing and Delivering the Report
                Activity: Writing the Report


                 •  Refer to Attachment 5-A and 5-B

                 •  Review the blank and completed
                   Lead Dust Clearance reports
               SEPA
Lead Dust Sampling Technician
       June 2013
m
Lead Dust Sampling Technician Training Course
                                            5-6

-------
Chapter 5: Writing and Delivering the Report
                Summary
                   The items that make up a complete
                   lead dust clearance test report

                   How to make a report easy for a
                   client to understand
               SEPA
Lead Dust Sampling Technician
       June 2013
m
Lead Dust Sampling Technician Training Course
                                             5-7

-------
          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.
99045*81,811116500
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:
 5-8
Attachment

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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.	
5-9
                                                 Attachment

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                 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.
»ft*ww««£ IHIWM?
                     Visual Inspection of the Work Area
   Work Area
Deteriorated
   Paint
Debris
Visible
 Dust
Notes
Pass/
 Fail
Sxteiun tout uttde>i
5-10
                                                   Attachment

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               LEAD DUST CLEARANCE TEST RESULTS FORM
Date of Lead Dust
Clearance Test:
Lead Dust Sampling
Technician:
Client:
Property Address:
XISIM
fateTVfate
Smith "^tuftity
%0 S
-------
                  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
5-12
                                   Attachment

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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
5-13
Attachment

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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. To view updates to the RRP Rule since the 2008 Final Rule, go to
http://www2.epa.gov/lead/lead-renovation-repair-and-painting-program-rulestf2011.
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.

§ 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 §745.227(e)(8) or any applicable
State, Territorial, Tribal, or local standard.


Appendix A                                                                      1

-------
§ 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 § 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 § 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 § 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 § 745.85 at all renovations to which they are assigned. A certified
renovator:

(1) Must perform all of the tasks  described in § 745.85(b) and must either perform or
direct workers who perform all of the tasks described  in § 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 § 745.85(a)(l)
are posted, while the work area containment required by § 745.85(a)(2) is being
established, and while the work area cleaning required by § 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 § 745.86(b)(7).

(c) Dust sampling technician responsibilities. When performing optional dust clearance
sampling under § 745.85(c), a certified dust sampling technician:

(1) Must collect dust samples in accordance with § 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 § 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

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         Appendix B:

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

-------
                                                                            n
                                                                LEAD WORK AR
                                                                   POISON
                                                                 NO SMOKING^
                                                                  OR EATING
AUTION         CAUTION         CAUTION          CAUTION
                           1-800-424-LEAD (5323)
                         www.epa.gov/getleadsafe
                              EPA-740-K-10-001
                              Revised July 2011
        This document may be purchased through the U.S. Cover nmentPrirting.Office online at
               http://bookstore.gpo.gov or by phone (toll-free): 1-86b-5U-i»uu.
CAUTION
                                                                                      Important lead hazard information for
                                                                                     families, child care providers and schools.

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              IT'S THE LAW!
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.

• 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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WHO SHOULD READ THIS PAMPHLET?
This pamphlet is for you if you:
• Reside in a home built before 1978.
• Own or operate a child care facility, including preschools and kindergarten
 classrooms, built before 1978, or
• Have a child under six years of age who attends a child care facility built before 1978.
You will learn:

• Basic facts about lead and your health.

• How to choose a contractor, if you 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.


This pamphlet is not for:

• Abatement projects. Abatement is a set of activities aimed specifically at
 eliminating  lead or lead hazards. EPA has regulations for certification and training of
 abatement professionals. If your goal is to eliminate lead or lead hazards, contact the
 National Lead Information Center at 1-800-424-LEAD (5323) for more information.

• "Do-it-yourself" projects. If you plan to do renovation work yourself, this document
 is a good start, 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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RENOVATING, REPAIRING, OR PAINTING?
LEAD AND YOUR HEALTH
                             • 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 Facts About Lead

• Lead can affect children's brains and developing nervous systems, causing reduced
 IQ, learning disabilities, and behavioral problems. Lead is also harmful to adults.

• Lead in dust is the most common way people are exposed to lead. People can also
 get lead in their bodies from lead in soil or paint chips. Lead dust is often invisible.

• Lead-based paint was used in more than 38 million homes until it was banned for
 residential use in 1978.

• Projects that disturb 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 protectyou and yourfamily.
Lead is especially dangerous to children
under six 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 or blast or otherwise disturb lead-based
 paint risk unsafe exposure to lead.


What should I do if I am concerned about my family's exposure to lead?
• Call your local health department for advice on reducing and eliminating
 exposures to lead inside and outside your home, child care facility or school.
• Always use lead-safe work practices when renovation or repair will disturb
 painted surfaces.
• A blood test is the only way to find out if you or a family member already has lead
 poisoning. Call your doctor or local health department to arrange for a blood test.


For more information about the health effects of exposure to lead, visit the EPA lead
website at www.epa.gov/lead/pubs/leadinfo.htm or call 1-800-424-LEAD (5323).
                                                                                          There are other things you can do to protect your family every day.
                                                                                          • Regularly clean floors, window sills, and other surfaces.
                                                                                          • Wash children's hands, bottles, pacifiers, and toys often.
                                                                                          • Make sure children eat a healthy, nutritious diet consistent with the USDA's dietary
                                                                                           guidelines, that helps protect children from the effects of lead.
                                                                                          • Wipe off shoes before entering house.

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WHERE DOES THE LEAD COME FROM?
    CHECKING YOUR HOME FOR LEAD-BASED PAINT
Dust is the main problem.
The most common way to get lead in the body is from dust. Lead dust comes from
deteriorating lead-based paint and lead-contaminated soil that gets tracked into
your home. This dust may accumulate to unsafe levels. Then, normal hand to-mouth
activities, like playing and eating (especially in young children), move that dust from
surfaces like floors and window sills into the body.

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

Proper work practices protect you from the dust.
The key to  protecting yourself and your family during a renovation, repair or painting
job is to use lead-safe work practices such as containing dust inside the 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.
                         Percentage  of Homes  Likely  to Contain Lead
G
O
K
M-l
O
0)
Between
1940-1960
    BefoE 1940-
                           24
} ^ '
    Older homes, child care facilities, and schools are more likely to contain
    lead-based paint.
    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 have the following options:
    You may decide to assume your home, child care facility, or school contains lead.
    Especially in older homes and buildings, you may simply want to assume lead-based
    paint is present and follow the lead-safe work practices described in this brochure
    during the renovation, repair, or painting job.

    You can hire a certified professional to check for lead-based paint.
    These professionals are certified risk assessors or inspectors, and can determine if
    your home has lead or lead hazards.

    • A certified inspector or risk assessor can conduct an inspection telling you whether
     your home, or a portion of your home, has lead-based paint and where it is located.
     This will tell you the areas in your home where lead-safe work practices are needed.

    • A certified risk assessor can conduct a risk assessment telling you if your home
     currently has any lead hazards from lead in paint, dust, or soil. The risk assessor
     can also tell you what actions to take to address any hazards.

    • For help finding a certified risk assessor or inspector, call the National Lead
     Information Center at 1-800-424-LEAD (5323).

    You may also have a certified renovator test the surfaces or components being
    disturbed for lead using a  lead test kit. Test kits must be EPA-recognized and are
    available at hardware stores. They  include detailed instructions for their use.

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FOR PROPERTY OWNERS
You have the ultimate responsibility for the safety of your family, tenants, or children
in your care.
This means properly preparing 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
 epa.gov/getleadsafe 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.

If you think a worker is not doing what he is supposed to do or is doing something
that is unsafe, you should:
• 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.
FOR TENANTS AND FAMILIES OF CHILDREN UNDER SIX
YEARS OF AGE  IN CHILD CARE FACILITIES AND SCHOOLS
You play an important role ensuring the ultimate
safety of your family.
This means properly preparing for the renovation
and staying out of the work area (see p. 8).
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.

If you think a worker is not doing what he is supposed to do or is doing something
that is unsafe, you should:
• Contact your landlord.
• Call your local health or building department, or
• Call EPA's hotline 1-800-424-LEAD (5323).
If you are concerned about lead  hazards left behind afterthe job is over, you can
check the workyourself (see page 10).

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PREPARING FOR A RENOVATION
DURINGTHEWORK
The work areas should not be accessible to occupants while the work occurs.
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 need:
• Alternative bedroom, bathroom, and kitchen arrangements if work is occurring in
 those areas of your home.

• A safe place for pets because they too can be poisoned by lead and can track lead
 dust into other areas of the home.

• A separate pathway for the contractor from  the work area to the outside in order to
 bring materials in and out of the home. Ideally, it should not be through the same
 entrance that your family uses.

• A place to store your furniture. All furniture and belongings may have to be moved
 from the work area while the work is 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 workarea 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.

These will help prevent dust or debris from getting outside the workarea.

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 a re:

   • 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
    than1100°F.

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 workarea 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 workarea 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 workarea. If you see any dust, paint chips, or debris, the area must be re-cleaned.

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   FOR PROPERTY OWNERS: AFTER THE WORK IS DONE
   When all the work is finished, you will want to know if your home, child care facility, or
   school where children under six attend has been cleaned up properly.

   EPA Requires Cleaning Verification.
   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
    websiteatwww.epa.gov/lead/pubs/locate.htm 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.
10
FOR ADDITIONAL INFORMATION
You may need additional information on how to protect yourself and your children
while a job is going on in your home, your building, or child care facility.

The National Lead Information Center at 1-800-424-LEAD (5323) or
www.epa.gov/lead/nlic.htm can tell you how to contact your state, local, and/or
tribal programs or get general information about lead poisoning prevention.
• State and tribal lead poisoning prevention or environmental protection
 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   jr
a variety of resource materials, including the following
guides to lead-safe work practices. Many of these
materials are also available at
www.epa.gov/lead/pubs/brochure.htm.

• 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
programs
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.
                                                                                                                                                                       11

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   EPA CONTACTS
   EPA Regional Offices
   EPA addresses residential lead hazards through several different regulations.
   EPA requires training and certification for conducting abatement 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 programsatepa.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
                                                                OTHER FEDERAL AGENCIES
CPSC
The Consumer Product Safety
Commission (CPSC) protects the public
from the unreasonable risk of injury or
death from  15,000 types of consumer
products under the agency's jurisdiction.
CPSC warns the public and private
sectors to reduce exposure to lead and
increase consumer awareness. Contact
CPSC for further information regarding
regulations  and consumer product safety.

CPSC
4330 East West Highway
Bethesda.MD 20814
Hotline 1-(800) 638-2772
www.cpsc.gov


CDC Childhood Lead Poisoning
Prevention  Branch
The Centers for Disease Control and
Prevention (CDC) assists state and local
childhood lead poisoning prevention
programs to provide a scientific basis
for policy decisions, and to ensure that
health issues are addressed in decisions
about housing and the environment.
Contact CDC Childhood Lead Poisoning
Prevention Program for additional
materials and  links on the topic of lead.

CDC Childhood Lead Poisoning
Prevention  Branch
4770 Buford Highway, MS F-40
Atlanta, GA  30341
(770) 488-3300
www.cdc.gov/nceh/lead
HUD Office of Healthy Homes and Lead
Hazard Control
The Department of Housing and Urban
Development (HUD) provides funds
to state and local governments to
develop cost-effective ways to reduce
lead-based paint hazards in America's
privately-owned low-income housing. In
addition, the office enforces the rule on
disclosure of known lead paint and lead
hazards in housing, and HUD's lead safety
regulations in HUD-assisted housing,
provides public outreach and technical
assistance, and conducts technical
studies to help protect children and their
families from health and safety hazards
in the home. Contact the HUD Office of
Healthy Homes and Lead Hazard Control
for information on lead regulations,
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
www.hud.gov/offices/lead/
                                                                                                                                                                          13

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

Occupant Confirmation
Pamphlet Receipt
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
Renovator's Self Certification Option (for tenant-occupied dwellings only)
Instructions to Renovator: If the lead hazard information pamphlet was delivered but a tenant
signature was not obtainable, you may check the appropriate box below.


Q Declined - I certify that I have made a good faith effort to deliver the lead hazard
   information pamphlet to the rental dwelling unit listed below at the date and time indicated
   and that the occupant declined to sign the confirmation of receipt. I further certify that I
   have left a copy of the pamphlet at the unit with the occupant.

Q Unavailable for Signature -1 certify that I have made a good faith effort to deliver the lead
   hazard information pamphlet to the rental dwelling unit listed below and that the occupant
   was unavailable to sign the confirmation of receipt. I further certify that I have left a copy of
   the pamphlet at the unit by sliding it under the door or by (fill in how pamphlet was left).
Printed Name of Person Certifying Delivery     Attempted Delivery Date
Signature of Person Certifying Lead Pamphlet Delivery
Unit Address

Note Regarding Mailing Option —As an alternative to delivery in person,you may mail the
lead hazard information pamphlet to the owner and/or tenant. Pamphlet must be mailed at
least 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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 What Is the Field  Guide?
 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 lead dust.

How To Use This Guide
Take this guide with you on site when you perform clearance, including
visual inspections. It serves as a quick reminder of:
   • When and where to take lead dust clearance samples;
   • The step-by-step instructions for taking a dust wipe sample; and
   • EPA/HUD  clearance standards for lead dust.
 When To Perform Lead Dust Clearance Tests
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.
Lead dust clearance is performed:
   • After renovation, repair, painting, and cleaning activities are
    finished in property built before 1978 and where children are
    assumed to spend time.
   • 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.
 Where To Collect Samples for Lead Dust Clearance Tests
If there is more than one room, hallway, or stairwell within the work
area, take:
   • One windowsill sample and one floor sample within each room, hall
    way, or stairwell (no more than four rooms, hallways, or stairwells
    need be sampled).
   • 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).
   • 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 the work area is a single room, hallway, or stairwell, or a smaller
area, take:
  •  One windowsill sample and one floor sample.
  •  If the windows were not closed and covered with plastic during the
     renovation, also take one window trough sample.
  •  One floor sample adjacent to the work area, but not in an area that
     has been cleaned.
 Equipment List
  •  Disposable lead dust wipes
     (individually wrapped)
  •  Disposable gloves
  •  Disposable shoe covers
  •  Sample tubes with caps
  •  Re-usable templates
  •  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
Check with your laboratory for their sampling requirements
 Visual Inspections
                      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:
  •  Deteriorated paint
  •  Chips or debris
  •  Visible dust
 Lead Dust Wipe Sampling
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.
Step One:
               I Put on disposable shoe covers and lay out
               I the sample area
  • Clean template with a new wipe.
  • Tape template to surface.
  • If no template, outline  with tape.
  • 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.
  • 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.
Step Two:
               Prepare the sample tubes

  • 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.

               Put on clean gloves

    Use disposable gloves.
    Use new  gloves for  each sample.
    DO NOT  touch anything except the wipe after
    putting on the gloves.
Step Four:
               I Wipe sample area and place wipe in sample
               I tube
   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.
   Fold the wipe in half, keeping
   the dirty side in, and repeat
   the wiping procedure in the
   original direction in a forward
   and back motion.
                                                                                                                                                                                  Start at corner and wipe sideways.
 •  Fold the wipe again and repeat    Now w'Pe'" a forward and back motion.
   the wiping procedure, concetrating on collecting dust from the
   edges and corners of the sample area.

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 Step Four:
            (Continued)
  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.
 Step Five:
            Measure the sample 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.
 Step Six:
            Record sample area dimensions on forms
    Calculate the sample area and record on sample collection
    form and laboratory chain-of-custody form.
 Step Seven:
            Clean 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.
Evaluate the Results
  • Compare the laboratory results to the EPA clearance standards for
    maximum allowable residual lead dust provided below:
    - Floors: 40 micrograms per square foot (|ag/ft2)
    - Interior windowsills: 250 |_ig/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.
Write the Report
  • Use the standard report format.
  • Sign the report.
 Useful Resources
National Lead Information Center
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 Lead Laboratory Accreditation Program
http://www.epa.gov/lead/pubs/nllaplist.pdf

For information on locating EPA-accredited labs.

Office of Pollution Prevention and Toxics
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 Healthy Homes and Lead Hazard 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
Lead Dust  Sampling
Technician Field Guide
                                                                                                                                     SERA

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