-------
Lead Abatement for Workers
Lead poisoning
was recognized
2,000 years ago.
Lead causes health problems
The health problems associated with lead have been known for a very long time. Ancient
Egyptians knew that lead could kill people if they swallowed too much of it. In the
Middle Ages, doctors realized that some of the health problems of painters, miners, and
artists were caused by exposure to lead on the job. In 1786, Ben Franklin wrote to a
friend about work-related lead poisoning cases.
In the early 1900s, doctors found that lead-based paint caused reproductive problems for
workers and their families. Doctors from all over the world began to study lead-based
paint as a cause of childhood diseases. Many doctors in the United States studied and
wrote articles about childhood lead poisoning. In 1913, Dr. Alice Hamilton—an
American occupational health doctor—wrote about painters and the hazards of their
work. She documented their exposure to lead and their health problems.
1-8
-------
What is lead? Where is it found?
Where is lead found?
Lead can be found almost anywhere today. Some of the places where we may find lead
include the following:
Paint
WHITE-LEAD
-leasts!
o
"Lead-based paint" is defined in the Residential Lead-
Based Paint Hazard Reduction Act (also known as Title
X) as "paint, varnish, shellac, or other coating on
surfaces that contain 1.0 mg/cm2 or more oflead or 0.5
percent or more lead by weight." Chapter 3 will cover
ways to identify lead-based paint.
Lead was used in paints for color and durability. When
lead was added to paint, the paint was better able to
stand up to wear and tear and weather changes. Lead
was also added to paints to speed up the drying process.
In many ways, lead-based paint was an ideal product. However, as lead-based paint ages
or becomes damaged, dust and chips are created.
Lead dust pollutes the air, soil, household dust, and any surface it settles on. It
contaminates floors, counter tops, furniture, toys, shelves, books, pets, and people. It can
get on children's hands when they play on the floor. When lead-based paint gets old or
damaged, it creates lead dust and chips. Lead dust can be a health hazard. Many lead-
poisoned children are exposed to and poisoned by lead dust. Even when the floor looks
clean, there may be harmful amounts oflead dust. Lead dust and lead-contaminated soil
can be tracked indoors (e.g., by pets or on shoes) where it becomes another source of
exposure for children. It is normal for children to put their hands and toys in their
mouths and then swallow lead dust. The action called "hand-to-mouth contact" is the
most common way for children to ingest lead.
House paint
Lead-based paint is believed to be a major
source oflead poisoning. Any home built
before 1978 may contain lead-based paint.
Homes built before 1950 are more likely to
contain higher levels oflead because the use
of latex paints became more common
during the 1950s.
m
When lead-based
paint gets old or
damaged, it
creates lead dust
and chips.
Lead dust is a
health hazard.
Most children are
exposed to lead
by ingesting lead
dust.
Lead-based
paint can be
found on any
painted
surface—inside
or outside.
1-9
-------
Lead Abatement for Workers
Sand blasting
paint off a bridge
can pollute the
community.
Exhaust from
leaded gas
polluted the air
and soil.
Lead-based paint was used inside homes on woodwork, walls, floors, windows, doors,
and stairs because it resisted wear and tear. It was also used on the outside of homes,
porches, windows, and doors because it can withstand extreme weather changes.
Lead-based paint kills mold and mildew. Because mold and mildew typically grow in
high moisture areas, lead-based paint was often used in places where moisture is found
(such as kitchen and bathroom walls and on windows and doors).
Industrial use of lead-based paint
Lead-based paint is still used on bridges and on steel structures
to prevent rust and corrosion. These are "industrial uses" of lead-
based paint. There are no restrictions on the use of lead-based
paint for industrial purposes.
About 90,000 bridges in the United States are coated with lead-
based paint. Blasting or grinding lead-based paint off steel
structures and even performing routine repairs creates huge
amounts of lead dust. Doing this type of work can be harmful to
workers and the surrounding community. The lead dust gets
into the air and nearby soil, plants, and water.
Leaded gasoline
Until the late 1970s, lead was added to gasoline as an antiknock
agent. The car exhaust released the lead into the air and because
lead is heavy, this lead polluted not only the air but also the soil.
In 1978, the Environmental Protection Agency reduced the
amount of lead that could be added to gasoline. By 1982, the U.S.
national average level of lead found in the typical person's blood
dropped by 37 percent. Today the amount of lead permitted in
automobile gasoline is limited to 0.05 grams per gallon of
gasoline. A higher amount of lead is still allowed for farm vehicles and equipment. Leaded
gas is still used in other countries including Mexico, Korea, and Ireland.
Industrial releases
Many industries use lead in their products.
For example, lead is used in batteries,
ceramics, lead crystal, and bullets. When these
items are produced, lead can be released into
the air. The production and use of these
materials can pollute soil, water, and air.
1-10
-------
What is lead? Where is it found?
SOURCES OF LEAD EXPOSURE
LEAD FROM GAS
Jf
LEAD FROM INDUSTRY
LEAD SOLDER
.IN CANS LEAD IN PIPES
LEAD IN
WATER
)
LEAD I NY
AIR X
LEAD N AIR
LEAD I
FOOD
S
LEAD IN
\ ^ RAINT
A
LEAD DUST
ON TOYS
LEAD DUST
ON PETS
JJ
LEAD DUST ON FLOOR
Adapted from "Preventing Lead Poisoning In Young Children," Centers for Disease Control January 1985
-------
Lead Abatement for Workers
Soil can have
high levels of
lead.
Food and
drinking water
can be sources
of lead.
Some hobbies
can expose you
to lead.
Soil
High levels of lead in soil may come from paint dust, leaded gas
exhaust, and industrial releases. Naturally-occurring traces of
lead are found in most soil.
Some playgrounds may have soil that contains very high levels
of lead. Such playgrounds are very dangerous to children who
play there because of the risk of ingesting the lead during
normal hand-to-mouth contact.
Food
Food grown in soil that has lead can also contain lead.
Ceramic ware, pottery and glassware may contain lead
which can leach into foods cooked in or eaten from
these items.
Lead-soldered cans are no longer produced in the
United States, but lead-soldered cans are permitted in
some countries that export food to the United States.
Food cans imported from other countries may contain lead in the solder holding the
cans together. Any can containing lead must have a label on the can which states the
amount of lead used in the solder.
Drinking water
Lead was used in pipes and solder—even in water
coolers! Because lead can easily expand without cracking,
it was ideal for use in plumbing systems where freezing is
possible. The Safe Drinking Water Act (1986 and 1988)
made it illegal to use lead in household plumbing.
However, old lead pipes and lead soldering can still
contaminate drinking water. Lead is rarely a naturally
occurring contaminant in water.
Hobbies
Many people can be exposed to lead in their hobbies.
Activities that may expose you to lead are
home remodeling
glazed pottery making
target shooting at firing ranges
electronics
car and boat repair
u
1-12
-------
What is lead? Where is it found?
m
• refinishing furniture
• painting—some art paints have lead pigments
• making lead fishing sinkers or lures
• stained-glass window making
Occupational exposure
Many jobs or occupations can expose people to lead. These
workers are in danger of lead poisoning and may also
contaminate their cars and homes by bringing lead dust home
on their clothes, shoes, hair, or skin.
If workers don't clean up properly before leaving a worksite,
they could poison their own families.
Some jobs that have a high risk of lead exposure include
Many workers are
exposed to lead
on the job.
Construction trades
«
Lead abatement workers
• Ironworkers
«
Carpenters
• Steel welders and cutters
«
Remodelers
• Sheet metal workers
«
Renovators
• Painters
«
Demolition workers
• Plumbers and pipe fitters
Industry
«
Lead miners
• Ceramic glaze manufacturers
«
Lead smelter workers
• Plastic manufacturers
«
Lead refinery workers
• Wire and cable manufacturers
«
Lead crystal makers
• Electronics makers
Others
«
Firing range employees
• Car mechanics
«
Police officers
• Printers
«
Artists
• Scrap yard workers and
«
Radiator repair workers
recyclers
1-13
-------
Lead Abatement for Workers
In 1978, the U.S.
banned the use
of lead-based
paint in homes.
Millions of homes
in the U.S. have
lead-based paint.
The lead-based paint problem in the United States
Lead is a known poison. Other countries limited the use of lead-based paint as early as
1840. The United States did not act until the 1970s. The U.S. Government banned the
use of lead-based paint in houses, hospitals, schools, parks, playgrounds, and public
buildings in 1978. Although the government banned the use of lead-based paint in
1978, it allowed stores to sell-out their existing stock until 1980. Typically, we do not
expect to find lead-based paint in houses built after 1980.
Lead-based paint can still be used on cars, boats, metal furniture, industrial steel, farm
equipment, and on roads as traffic paint.
Today about 38 million U.S. homes contain lead-based paint. This number includes
houses and apartments in the cities, in suburbs, and in the country. It includes the
homes of wealthy people as well as the homes of middle-class and lower-income people.
Homes built prior to the 1950s are more likely to contain lead-based paint. After the
1950s, latex paints became more popular, and many people chose them instead of lead-
based paints.
There have been some reports of childhood lead poisoning that occurred during or
after renovation in homes with lead-based paint. Many homes with lead-based paint
are occupied by families with children under age six. Children under six are easily hurt
by lead because their nervous systems are still developing. How children get poisoned by
lead and what lead does to their bodies is discussed in the next chapter.
~ ~
s
—
s
o
87 percent of homes built before 24 percent of homes built between
1940 have lead-based paint. I960 and 1979 have lead-based
paint.
Adapted from
U.S. HUD. 2001. The National Survey of Lead and Allergens in Housing.
1-14
-------
What is lead? Where is it found?
Key facts for Chapter 1
What is lead?
Lead is a heavy metal.
Lead has been used for thousands of years. It prevents corrosion and kills mold
and mildew. It is durable and easy to shape.
Lead is a poison. It can make you sick if you breathe or swallow it.
Lead-based paint is "paint, varnish, shellac, or other coating on surfaces that
contain 1.0 mg/cm2 or more of lead or 0.5 percent or more lead by weight."
Sources of lead exposure
lead-based paint
leaded gasoline
industrial releases
soil, food, and water
pottery, crystal, glassware
some jobs and hobbies
Lead dust
Lead-based paint is a health hazard when it chips or becomes dust or fumes.
Lead dust is created when
lead-based paint gets old and deteriorates;
lead-painted surfaces are broken, damaged, or disturbed;
lead-painted surfaces are sanded or scraped;
household dust becomes contaminated by other sources of lead (e.g., soil).
Lead dust and particles tend to stick to surfaces.
Lead dust particles can be so small, you can't see them.
Lead-based paint in the home
Lead-based paint in the home is a major cause of childhood lead poisoning.
The United States banned the use of lead-based paint in homes in 1978.
An estimated 38 million American homes still contain lead-based paint.
-------
Lead Abatement for Workers
For more information
These publications have more information on the topics covered in this chapter. Your
instructor has a copy of the publications marked with a star (*). You can order your own
copy by calling 1-800-424-LEAD.
* Environmental Defense Fund, The Hour ofLead: A Brief History of Lead Poisoning in
the United States over the Past Century and of Efforts by the Lead Industry to Delay
Regulation (June 1992).
* EPA, Lead: Identification of Dangerous Levels of Lead; Final Rule, 40 CFR Part 745
(January 2001)
* EPA, Reducing Lead Hazards When Remodeling Your Home (September 1997).
* EPA, Lead in Your Drinking Water (April 1993).
* EPA, Home Water Treatment Units: Filtering Fact from Fiction (September 1990).
* EPA, Toxics Information Series on Lead (Pamphlet TS-793).
* EPA, HUD, and CPSC, Protect Your Family From Lead in Your Home (June 2003).
National Lead Information Center, Lead: Some Questions and Answers (April 1993).
National Lead Information Center Hotline: 1-800-424-LEAD
-------
®=
CHAPTER 2
Health Effects: How Lead Affects The Body
Learning objectives 2-3
Skit: Lunchtime on the job site 2-4
Discussion questions 2-5
Lead poisoning affects you 2-6
How much lead is dangerous? 2-7
How does lead get into your body? 2-8
How can lead harm your body? 2-9
Children are at high risk 2-13
Protect yourself and your family from lead poisoning! 2-14
Health effects of lead poisoning 2-15
Short-term or long-term effects 2-16
Reversible or permanent damage 2-16
Testing for lead in your body 2-17
Blood lead level test 2-17
ZPP test (Zinc Protoporphyrin) 2-17
Blood lead levels 2-18
Preventing lead poisoning 2-20
Making sure that you do not get sick 2-20
Good nutrition 2-21
Key facts for Chapter 2 2-22
For more information 2-24
-------
Lead Abatement for Workers
-------
Health Effects: How Lead Affects the Body
Learning objectives
In this chapter you will learn
• how lead enters and affects the body
• why lead is especially dangerous to children
• how lead levels in the body are measured
• how lead poisoning can be prevented
-------
Lead Abatement for Workers
Skit: Lunchtime on the job site
Tanja, Al, Joe, and Walt are eating lunch on the back porch of a home they are
renovating. They live in the community where the home is located. They have been
renovating the houses in this community for nearly a month. Let's listen to them while
they eat lunch:
Al: This porch is feeling like home. We've worked on these houses for a
month now. We'll be done by next week.
Tanja: It'd feel more like home if we had a table and a few chairs to sit on. I'll be
glad when this job is over. I'm tired. My body aches from all this work.
Joe: Women weren't made to work construction—that's why your body
aches. I don't want a table or chairs. I want a clean bathroom and some
cold water to drink. This porch is dirty. Maybe we could get some of
that poly plastic and lay it on the porch . . . man, I'm dizzy.
Al: Tanja, I've seen you do twice as much work as Joe in a day. Are you sick?
Walt: Hey, Joe, too much partying last night? We've worked on these houses
for almost a month. I won't miss this porch at all. I used to get real
hungry by lunch time. I was eating two or three sandwiches. I'm working
just as hard now, but I don't even want to finish one sandwich anymore.
Al: Walt, you usually eat like a horse. Ask your wife to fix your lunches again.
Walt: My wife made my favorite pot roast last night. I couldn't eat it. It tasted
so good, but I wasn't hungry. My stomach hurt. All I wanted to do was
go to sleep.
Joe: I wish I could get some sleep. The past week I got these headaches and
people just bothered me. You know, people are getting on my nerves. The
doctor says it's because I'm constipated.
Al: You all sound like you got the flu or some kind of bug. Stay away from
me. I'm feeling just fine and I want to stay that way.
-------
Health Effects: How Lead Affects the Body
Discussion questions
1. What is going on in this conversation?
2. What were the workers' complaints?
Circle them in the script. Is everyone feeling sick?
3- Do any of the workers share the same problems?
4. List some things that could be causing these complaints.
5. What suggestions were made to fix the problems?
What would you suggest?
What do
you think?
-------
Lead Abatement for Workers
Lead poisoning affects you
Lead is poisoning many children and adults around the country. As a lead abatement
worker, you can also be poisoned by lead. It can make you very sick and can even kill
you. At low levels of exposure, you can feel fine, but lead is still harming you. When you
work with lead, you must work carefully. Lead poisoning can be prevented by working
with lead-based paint safely. You are in this class to learn how to protect yourself, others,
and the environment from lead.
As a construction worker—especially if you do remodeling, demolition, or lead-based
paint abatement work—you may be exposed to lead. Without proper protection, you
can get sick from lead in the workplace. You should wear a respirator and protective
clothing when you work with lead. Clean up, shower, and put on clean street clothes
before going home. If you forget to shower before leaving the job site or you wear dirty
work clothes home, you could expose your family to lead.
-------
Health Effects: How Lead Affects the Body
How much lead is dangerous?
Even a small amount of lead can make you sick. Lead can remain in the body for a long
time. It stays in the blood for several months and can be stored in the bones for 30 years
or more.
The more lead you are exposed to, the more likely you are to get lead poisoned. Many
small doses of lead over a long time can cause lead poisoning. One large dose of lead in
less than a day can also make you lead poisoned. A low dose of lead can make you feel
tired and irritable. A high dose of lead can cause permanent damage to your brain,
nervous system, and kidneys. Avery high dose of lead can cause death.
Even a small
amount of lead
can harm you.
-------
Lead Abatement for Workers
You can breathe or
swallow lead.
You may swallow
lead if you don't
wash before you eat
or smoke.
How does lead get into your body?
Lead can get into our bodies in two ways: breathing (or inhalation) and eating (or
ingestion).
Breathing lead
When lead is in the air, you can breathe tiny
lead particles into your lungs. Once in your
lungs, lead is absorbed into your blood stream.
Eating lead
You can swallow lead particles by eating,
drinking, smoking, or chewing your fingernails
without washing your hands after working with
lead. If you swallow lead particles, the lead
eventually goes through your digestive system
and then slowly gets into your blood.
Up to 50 percent of the lead that children and
pregnant women ingest is absorbed into their
bodies. About 10 to 15 percent of the lead that
nonpregnant adults ingest is absorbed into their
bodies. People who do not get enough calcium
or iron in their diets will absorb more lead into
their bodies.
2-8
-------
Health Effects: How Lead Affects the Body
How can lead harm your body?
Blood
syste
Heart-
Bone
Marrow
Heart and blood system
When lead reaches your blood, it attaches to red blood
cells in the area where iron and oxygen are. If your
body does not get enough iron, lead will attach to the
red blood cells more quickly. Then, the red blood cells
cannot carry oxygen, and you cannot get oxygen to the
rest of your body. Without enough iron or red blood
cells in the blood, a condition called anemia can
develop. Anemia can make you very tired.
Lead can damage red blood cells by shortening the life
of the cells. Lead also reduces your body's ability to
make more red blood cells in the bone marrow.
Lead poisoning may cause high blood pressure.
When you have high blood pressure your heart muscles cannot relax. This increases
your risk of heart attack and stroke.
Kidneys
Your blood is cleaned and filtered in your kidneys.
Most (65 percent) of the lead that is in the blood gets
filtered in the kidneys, where it can cause damage.
Kidney damage can be very serious. Often this damage
cannot be detected until much of the kidneys' function
is lost. This damage requires serious medical treatment
to prevent the kidneys from failing. Kidney failure can
cause death.
Nervous system
Kidneys
The nervous system is the system in your body most
affected by lead. The nervous system includes your
rain, spinal cord, and nerves. The damage lead
causes to the nervous system can be permanent. Brair
Lead damages the brain and can even kill brain
cells. Lead damage to your brain can make you
depressed, irritable, forgetful, clumsy, and affect
your ability to learn. At very high doses, lead
poisoning can cause hallucinations, swelling of the
brain, coma, and even death.
Lead damages the ability of your nerves to give and
receive messages. Lead can damage the nerves that
go to your hands and feet. This nerve damage can
cause your hands to shake; and in severe cases, it
can cause your hand or foot to become weak and
drop. If wrist drop or foot drop develops, you may
never have full use of your hand or foot again.
Spinal Cord
Nerves^,
Lead attaches to
your red blood cells.
Lead can cause
high blood pressure.
Lead can damage
your kidneys.
Lead can damage
your brain and nerves.
2-9
-------
Lead Abatement for Workers
The nervous system of a fetus, infant, or child is affected by even small amounts of lead.
Lead poisoning can decrease the intelligence of children. Lead can cause behavior
problems in children. Some studies have linked learning disabilities, such as attention
deficit disorder (ADD), and delinquent behavior to childhood lead poisoning.
pregnancy, or during times of anxiety. If the lead goes from the bone back into the
blood, then other body systems are exposed, and problems can begin all over again.
Lead that stays in your body is called a "body burden." The more lead you are exposed
to, the higher your lead body burden is. The lead body burden is not easy to measure
because it is mostly found in your bone tissue. Samples of bone tissue are difficult to get.
A child's tooth can be tested for lead when it falls out. The tested tooth can tell you how
much lead is in the child's bones—that is, the child's lead body burden. A special X-ray
machine can measure shin bone lead to tell us body burden, but these machines are used
for research only.
Lead v
deposits
Bone tissue
As blood travels through the bones, lead from the
blood is deposited into the bone tissue. Lead
blocks your body's natural process of making new
blood cells.
Lead also competes with calcium in the bone.
Calcium is released from bone tissue as our
bodies need it. If lead is there instead of
calcium, then lead is released into the blood.
The bones and teeth store 95 percent of the
lead in the body. Lead can be stored in bone
tissue for more than 30 years. Lead can be
cycled from bone to blood to body organs.
When the body is under stress, lead is released
from the bone tissue into the blood. A body is
under stress during illness, overactivity,
-------
Health Effects: How Lead Affects the Body
Female reproductive health and
Pregnancy
Lead poisoning is very dangerous to the female
reproductive system. It can make women less
fertile and can cause abnormal menstrual
cycles and affect menopause.
During pregnancy, current or past exposure to
lead by the mother could present a risk to the
fetus. When a woman is pregnant, the fetus
gets blood from the mother. If the mother has
been exposed to lead, the lead absorbed by her
body could be released and passed on to the
fetus through the blood. This lead could cause
brain damage and even death to the fetus. It
could also cause miscarriages and premature
(early) births.
Even a small amount
of lead can make a
pregnant woman sick.
Lead can cause
miscarriages and
birth defects.
Reproductive Health Effects of Lead
Women
Decreased sex drive
Decreased fertility
Abnormal menstrual cycles
Premature births
Miscarriages
Children
Birth defects
Lower birth weight
Learning problems
Behavioral problems
Men
Decreased sex drive
Problems having an erection
Decreased fertility
Miscarriages in female partner
2-11
-------
Lead Abatement for Workers
Lead can cause men to
have difficulty having
an erection.
Male reproductive system
Lead is very dangerous to the male reproductive
system. Lead can make men lose interest in sex,
and it can cause men to have problems having an
erection. Lead can cause infertility. It damages
sperm. Lead causes the sperm to have an odd
shape. It makes sperm move slowly. Wives of
leadpoisoned workers have more miscarriages and
premature births, and their children have more
birth defects.
Fetal protection policies
In the past, many companies developed policies with the stated purpose of
protecting the fetus. They were called fetal protection policies. Fetal
protection policies may really have been developed to protect the
companies against lawsuits.
To keep their jobs, women were forced to prove they could not have
children. Women who wanted to have children in their lifetime were fired
or given lower paying jobs. In some cases, women had to be sterilized to
keep their jobs.
In 1991, the Supreme Court decided that fetal protection policies
discriminated against women. Fetal protection policies are now illegal.
Lead affects both male and female reproductive systems. Both men and
women need to be protected from harmful levels of lead to have healthy
babies. The employer must provide a safe workplace for both male and
female workers.
2-12
-------
Health Effects: How Lead Affects the Body
Children are at high risk
Children can get lead poisoned very quickly. Even a small dose of lead can poison a
young child. A child's rapidly developing brain, central nervous system, and entire body
are affected by lead. Toddlers (age one to three) are at a very high risk of lead poisoning,
because they typically crawl on floors and put things in their mouths and therefore can
swallow a lot of lead dust. Children absorb up to 50 percent of the lead that they take in.
Recent medical research indicates that lead may affect a child's intelligence even at blood
lead levels below 10 micrograms per deciliter (pg/dL). Lead-poisoned children have a
higher high school dropout rate than non-lead-poisoned children. Lead poisoning can
reduce a child's ability to learn. It can also cause
• poor muscle and bone growth
• poor hearing
• speech and language problems
• coordination problems
Lead is the most significant environmental health hazard for children in the United
States. Some research has suggested that children exposed to lead may be hyperactive.
Other studies have found evidence that lead can make a child react very slowly. Still
other research studies indicate that lead can make it hard for a child to pay attention
(Attention Deficit Disorder). Lead can make a child very clumsy. Lead kills brain cells
and disrupts nerve signals. The effects of childhood lead poisoning can last a lifetime.
Even low levels of lead
can cause permanent
damage to a child.
Children's developing
bodies and brains
are easily damaged
by lead.
Lead is the most
significant
environmental
health hazardfor
children in the U.S.
2-13
-------
Lead Abatement for Workers
Protect yourself and your family from lead
poisoning!
Julia's husband Mike is an auto mechanic and machinist. He is exposed to
lead on the job. Julia was exposed to lead on the job for three months
while she worked in a shipyard as a burner. Two years later, Julia became
pregnant with their son. The parents' lead exposure may have affected
their son's health.
"As my son grew up," says Julia, "he developed learning disabilities. He
had a lot of trouble paying attention and following directions. He has
really poor organization skills. We had to send him to a special education
program for several years. My son is 14 years old now. He's doing better,
but he still needs help organizing. He still needs special care."
From interview with a worker. (The names have been changed.)
-------
Health Effects: How Lead Affects the Body
Health effects of lead poisoning
Lead poisoning can affect you in many different ways. A large amount of lead can make
you sick right away. A small amount of lead day after day can make you sick over a long
period of time.
The health effects of lead poisoning are often difficult to recognize. There are many
different signs and symptoms of lead poisoning that can also be caused by a number of
other things, like the flu or a cold. Because the symptoms are so similar, lead poisoning
can easily be mistaken for a cold or the flu.
Sometimes the signs of lead poisoning come and go. You have them one day and then
they disappear. Then the signs come back again. This can happen for several months.
Lead can cause damage without symptoms. Lead poisoning often goes unnoticed, and
you may not know you have lead poisoning. Children with lead poisoning may seem
healthy while damage is being done to their bodies. Signs and symptoms of the damage
usually do not develop until the condition is serious.
Signs and symptoms of lead poisoning
• Tiredness (fatigue)
• Wrist or foot drop
• Sleep problems
• Weakness
• Dizziness
• Clumsiness
• Irritability
• Joint and muscle pain
• Nervousness
• Vomiting
• Headaches
• Loss of appetite
• Difficulty concentrating
• Stomach aches
• Depression
• Constipation
• Forgetfulness
• Metal taste in the mouth
• Hyperactivity (children)
• Problems having healthy children
• Numbness
Some health effects of lead poisoning
Anemia
High blood pressure
Damage to blood cell formation
Kidney disease
Brain damage
Nerve damage
Decreased fertility
Premature births
Miscarriages
You may not know
that you have lead
poisoning.
Lead can cause
damage without
signs or symptoms.
Lead poisoning is
sometimes mistaken
for the flu.
The health effects
of lead poisoning
are often difficult to
recognize.
2-15
-------
Lead Abatement for Workers
Short-term or long-term effects
Sometimes the effects of lead poisoning are short term. This means they do not last a
long time—maybe a few weeks or months. Sometimes the symptoms of lead poisoning
are long term. This means the symptoms stay with you a long time—sometimes for
years or even permanently. Long-term effects can be caused by repeated small doses of
lead or by a very high dose at one time.
Lead can cause
permanent damage.
Reversible or permanent damage
Some effects of lead poisoning can be reversed. This means the effects may go away.
High blood pressure is an effect of lead poisoning that is reversible. High blood pressure
can return to normal when the lead in your body decreases.
Lead poisoning can cause permanent damage. This means that the damage is always
there. An example of permanent damage caused by lead is wrist drop. Wrist drop is when
your wrist hangs limp at the end of your arm. You may never be able to use that hand
again. Wrist drop is caused when lead damages your nervous system. When lead damages
the development of the electrical connections in a child's brain, the effect is permanent.
Lead can cause permanent damage to your
• brain
• digestive system
• learning ability
• heart
• coordination
• blood cell formation
• hearing
• kidneys
• nerves
• reproductive system
2-16
-------
Health Effects: How Lead Affects the Body
Testing for lead in your body
The only way to determine the amount of lead in your body is to get a blood test. When
lead enters your body, it gets into your blood. The amount of lead in your blood is called
your blood lead level.
There are two kinds of tests to monitor blood lead levels—the blood lead level test and
the ZPP test (zinc protoporphyrin). Both tests can be done from blood taken from either
your arm or your finger. Both can be done from the same sample of blood.
Blood lead level test
This test measures the amount of lead in your blood. Blood lead levels are only a
snapshot of lead exposure. The test shows how much lead you have been exposed to in
the last 6 to 8 weeks. The blood lead test is the more accurate test. Your blood lead level
is measured in micrograms of lead per deciliter of blood (pg/dL).
ZPP test (Zinc Protoporphyrin)
ZPP is produced when lead stops one of the body's building blocks from making blood.
Your ZPP level becomes abnormal when a lot of lead has entered your body over the last
few months. It tells how much lead your body has absorbed by looking at some of your
body's building blocks. It does not measure the amount of lead in your blood. Results
are measured in micrograms per deciliter (pg/dL). Normal results for the ZPP test are
35-50 pg/dl. The ZPP test is not as accurate as the blood lead level test for early or low-
level lead exposures. ZPP results can vary because of diet, anemia, and other factors.
Understanding Units
A microgram is a measure of weight. There are 1 million micrograms in a gram.
The abbreviation for microgram is pg.
Blood tests find out
how much lead is in
your blood.
A penny weighs about two grams. Imagine cutting a penny into 2
million pieces. A microgram would weigh the same as one of those
2 million pieces.
A deciliter is a measure of volume. It is equal to a little less
than half a cup. A person weighing 165 pounds has about 60
deciliters of blood. The abbreviation for deciliter is dL.
2-17
-------
Lead Abatement for Workers
You may not know
that lead is harming
you.
People have
different reactions
to the same blood
lead level.
Blood lead levels
Recent studies claim that lead can be harmful at blood levels below 10 pg/dL. Imagine
that penny broken up into 2 million pieces again. Now picture 10 of those pieces
dissolved in a half cup of liquid. That tiny amount of lead in your blood can cause
health problems!
Lead is dangerous because it builds up in your body. It can stay there for years. It is
difficult to say exactly what happens to your body with specific lead levels because each
person is different. Different people have different reactions to lead in their bodies. You
may not know that lead is harming your body. Some people do not even know that they
are having problems with lead poisoning when their blood levels are 60 pg/ dL. Other
people suffer obvious signs of lead poisoning at 30 pg/dL.
ADULT REACTIONS TO LEAD
Blood Lead
Level
Possible Health Effects
15 pg/dL
Increase in blood pressure; harmful effects on fetus;
joint and muscle aches
25 pg/dL
Reproductive problems
40 pg/dL
Kidney damage; damage to blood formation
60 pg/dL
Anemia; nerve damage; constipation; stomach pains;
irritability and fatigue; memory and concentration
problems; clumsiness; drowsiness and sleep problems
80 pg/dL
and above
Blue line on gums; uncontrollable shaking of hands; wrist
and foot drop; hallucinations; brain damage; coma; death
ATSDR 1989; California Health Department 1993
2-18
-------
Health Effects: How Lead Affects the Body
Every child is also different in his or her reaction to lead. A lead poisoned child may not
look or act sick but his or her body is being damaged. Researchers have known for a
long time that children are especially sensitive to lead exposures. Scientists have
discovered that even very low exposures to lead can cause serious health effects in
children.
In 1991, the Centers for Disease Control and Prevention (CDC) lowered the level of
concern for children's blood lead levels from 25 (ig/dL to 10 (ig/dL. About 2 percent of
all children aged 1 to 5 years (about 400,000 children) are estimated to have blood lead
levels at or above 10 (ig/dL. Lead dust from deteriorating lead-based paint is the major
source of lead exposure for children.
CHILD REACTIONS TO LEAD
Blood Lead
Level
Possible Health Effects
10 (ig/dL
Slight loss in IQ; hearing and growth problems
20 (ig/dL
Moderate loss in IQ; hyperactivity; poor attention span;
difficulty learning; language and speech problems; slower
reflexes
40 (ig/dL
Poor bone and muscle development; clumsiness; lack of
coordination; early anemia; fewer red blood cells to carry
oxygen and iron; tiredness; drowsiness
50 (ig/dL
Stomach aches and cramps; anemia; destruction of red blood
cells; brain damage
100 (ig/dL
Swelling of the brain; seizures; coma; death
and above
The effects of lead
can be different for
each child.
A child who has
lead poisoning may
not look or act sick.
2-19
-------
Lead Abatement for Workers
Lead poisoning can
be prevented.
Preventing lead poisoning
One way of reducing the chance of lead poisoning is to properly abate lead-based paint
hazards in homes that are occupied by children. Leadbased paint abatement eliminates the
lead hazard permanently. Abatement can be expensive and often cannot happen right
away. In that case interim controls may be used to control the lead hazard. "Interim"
means temporary. Interim controls reduce the amount of lead that children are exposed to
without permanently removing the source. Depending on the extent of the lead hazard,
interim controls may not take the place of abatement. By doing lead abatement and using
interim controls, you are helping prevent lead poisoning. (Chapter 6 will cover
abatement and interim controls.)
Making sure that you do not get sick
When you work with lead, you have a higher risk of getting lead poisoned. As much as
possible should be done to reduce that risk. Some things that you can do are
make sure your employer provides a safe workplace;
know your rights as a worker;
wear protective gear;
use safe work practices;
make sure you don't create a lead hazard while you work;
use good personal hygiene;
do not take lead home on your clothes or in your car;
get the medical exams that your employer provides;
inform your employer if you develop any signs of lead poisoning;
avoid lead-related work if your blood lead level is too high;
eat a balanced diet.
2-20
-------
Health Effects: How Lead Affects the Body
Good nutrition
Good nutrition is important for anyone exposed to lead. A diet with enough iron and
calcium prevents worse lead poisoning. When you eat a diet high in iron and calcium you
can reduce lead absorption. People with low amounts of iron and calcium absorb more
lead than those with normal amounts of iron and calcium. If you have enough iron and
calcium in your body, lead will be absorbed less quickly. Research shows that vitamin C,
zinc, and protein—found in a well-balanced diet—appear to decrease lead absorption.
Foods with a lot of fat, such as fried foods, appear to increase lead absorption. When
choosing dairy products, try to eat low-, non-, or reduced-fat varieties.
Eat foods high in iron—cheese, fish, seafood, meat (especially liver), eggs, spinach,
beans, raisins, apricots, seeds (pumpkin, squash, sunflower), black walnuts, almonds,
barley, wheat germ.
Eat foods high in calcium—milk, cheese, ice cream, yogurt, bread, fish, seafood, meat,
beans, broccoli, leafy green vegetables (spinach, etc.), cherries, blackberries, raisins, fruit
juice (orange, prune, grapefruit, pineapple), peaches, apricots, dates, sunflower seeds,
almonds, hazelnuts, pecans.
Eat a balanced diet
with foods high in
iron and calcium.
2-21
-------
Lead Abatement for Workers
Key facts for Chapter 2
Lead can poison you and make you very sick.
Even a small amount of lead can make you sick.
Lead is dangerous when you breathe or swallow it.
Lead can cause permanent damage.
Children's developing brains and bodies are easily damaged by lead.
Even low levels of lead can cause permanent damage to a child.
Pregnant women and children are most easily lead poisoned.
Lead in your body
Lead can damage your body without your feeling any symptoms.
Lead poisoning can easily be mistaken for the flu.
Lead attaches to your red blood cells and travels through your body.
Lead can be stored in your body for more than 30 years.
Body burden is the amount of lead stored in your body.
Lead can be released from your bones and poison you.
Lead can harm many parts of your body—blood cells, heart, kidneys, nervous
system, bone tissue, and reproductive organs.
Lead can cause men to have problems having an erection.
Lead can cause women to have stillbirths or miscarriages.
Blood tests
Blood tests find out how much lead is in your blood.
The tests used are: blood lead level test and zinc protoporphyrin (ZPP) test. The
blood lead level test is the more accurate test.
Blood lead levels are measured in micrograms of lead per deciliter (pg/dL) of blood.
People can have different reactions to the same blood lead level.
Lead poisoning can be prevented.
Your work as a lead abatement worker will prevent future lead poisoning.
You can protect yourself against lead poisoning.
-------
Health Effects: How Lead Affects the Body
Make sure your employer provides a safe workplace.
Wash your hands and face carefully when you leave the work area.
Use safe work practices that you will learn in this class.
Eat a balanced diet that has enough iron and calcium.
-------
Lead Abatement for Workers
For more information
These publications have more information on the topics covered in this chapter. Your
instructor may have a copy of the publications marked with a star (*). You can order
your own copy by calling 1-800-424-LEAD.
* CDC, Preventing Lead Poisoning in Young Children (October 1991).
* Environmental Defense Fund, Legacy of Lead: America's Continuing Epidemic of
Childhood Lead Poisoning (March 1990).
* EPA, HUD, and CPSC, Protect Your Family from Lead in Your Home (June 2003).
Murphy, J. "Fetal Protection v. Women's Jobs: Case Is Before the Supreme Court," The
Nation's Health: Official Newspaper of the American Public Health Association (November 1990).
National Lead Information Center, "Lead Poisoning and Your Children."
-------
CHAPTER 3
Laws, Regulations, Standards
Learning objectives 3-3
Laws 3-4
Other worker rights under OSHA 3-5
OSHA Interim Final
Lead in Construction Standard
fact sheet 3-7
Airborne lead exposure 3-7
Respirators and protective clothing 3-11
Your workplace 3-14
Training 3-15
Recordkeeping 3-16
Medical surveillance 3-16
Medical removal 3-19
Medical treatment 3-20
Title X fact sheet 3-22
Why was Title X passed? 3-22
The federal government is a "model landlord." 3-23
Who has to be trained? 3-23
How should abatement work be done? 3-24
Does each state or tribe have its own certification program? 3-24
Are workers doing lead-abatement jobs protected? 3-25
When does lead-based paint become a hazard? 3-25
How is the government educating the public? 3-26
Who is making sure the laws really help solve the problem? 3-26
Have these laws been effective? 3-27
Your state or tribal laws 3-28
Key facts for Chapter 3 3-29
For more information 3-32
-------
Lead Abatement for Workers
-------
Laws, Regulations, and Standards
Learning objectives
In this chapter you will learn about
• the federal guidelines on lead
• the federal laws and regulations that protect workers and the environment
• your state, tribal, and local laws and regulations for lead.
-------
Lead Abatement for Workers
The law is one
tool for a safer
and healthier job.
Laws
There are many laws and regulations on the books. Not everyone observes them. But
laws give you many rights. You can't fight for your rights unless you know what they
are. The law is one tool that can be used to secure a safer and healthier job.
The Occupational Safety and Health Administration (OSHA)—an agency of the
Department of Labor—writes and enforces rules protecting workers on the job. OSHA
issued an Interim Final Standard for Lead in Construction (29 CFR 1926.62) in May
1993. You will find a fact sheet that summarizes all the need-to-know information about
the lead standard in this chapter. Other OSHA regulations may apply to the hazards of
lead on construction sites. Your employer is required to provide additional training on
the OSHA requirements.
Other OSHA rules you should know about are the Hazard Communication Standard
("Right-to-Know") and the 11-C ("Nondiscrimination") clause of the Occupational
Safety and Health Act standards.
The Environmental Protection Agency (EPA) has issued rules protecting lead abatement
workers, the public, and the environment. EPA's training and work practices rules (what
you can and cannot do when working on a lead abatement job) form the model most
states/Indian tribes have used to write their lead program.
Some state and local governments have written laws protecting lead-abatement workers.
The laws in your state/Indian tribe will be reviewed at the end of this section.
The Department of Housing and Urban Development (HUD) is responsible for setting
requirements for federally owned or assisted housing and operating the Lead Hazard
Control Grant Program for privately owned low-income housing. Most pre-1978
properties receiving HUD funds are subject to HUD requirements for lead-based paint.
HUD has established guidelines for the evaluation and control of lead-based paint
hazards in housing. For some projects, the guidelines are requirements. For other
projects, they are recommendations only (not requirements). HUD has issued rules
requiring training of rehab, renovation, and maintenance workers who do work on older
homes or apartments on how to do their work lead-safely. These rules require clearance
examinations of the worksite(s) to prove that the workers cleaned up properly.
HUD and EPA have issued rule to make sure the public is informed about lead-based
paint and lead-based paint hazards in housing built before 1978.
3-4
-------
Laws, Regulations, and Standards
Other worker rights under OSHA
As a construction worker, you have other OSHA rights that are contained in the Code
of Federal Regulations (CFR). Below is a list of these rights and where to find them.
Right to a workplace free of recognized hazards (OSH Act, Public Law 91-596)
OSHA uses Section 5 in the Occupational Safety and Health Act to stop an employer from
endangering a worker's health. It is sometimes called the "General Duty Clause." It can be
applied when OSHA does not have a specific standard for a chemical or safety hazard.
Right to file a complaint (OSH Act, Public Law 91-596)
Under Section 11 (C) of the Occupational Safety and Health Act, you have a right to
file a complaint with OSHA whenever you feel your health and safety rights are violated.
You must file your complaint with OSHA within 30 days of the incident. You may
request that OSHA keep your identity secret from your employer.
It is best not to file a complaint alone. Work through your union or co-workers. Contact
your local area Committee on Occupational Safety and Health (COSH group) for
assistance. A COSH group is a coalition of unions, workers, and professionals working
together for safer and healthier working conditions.
Right to safety training (29 CFR 1926.21)
Your employer must train each worker on how to recognize and avoid unsafe conditions.
Training must cover methods on how to work safely with hazardous substances—like
lead—and in dangerous situations. You must be taught about personal hygiene
procedures and about the use and limits of personal protective equipment.
Right to sanitation (29 CFR 1926.51)
Your employer must provide drinking water, toilet facilities, and adequate washing
facilities for any work site where there is a contaminant, such as lead.
OSHA has many
regulations to
protect you.
3-5
-------
Lead Abatement for Workers
Right to respirator program (29 CFR 1910.134*)
Before your employer hands you a respirator, he or she must have a respirator program.
This program includes written procedures for choosing and using respirators and
training all employees how to use and maintain respirators. Your employer must
monitor the area to make sure all workers have the correct respirators. And your
employer must make sure your respirator fits you properly.
The lead standard requires medical exams. You should not be assigned to tasks requiring
use of respirators unless it has been determined that you are physically able to perform the
work and use the equipment. The local physician shall determine what health and physical
conditions are pertinent in order for you to wear a respirator. [29 CFR 1910.134(e)]
*You will receive more information on the requirements of the respiratory protection
standard in the OSHA training provided by your employer.
-------
Laws, Regulations, and Standards
OSHA Interim Final
Lead in Construction Standard
fact sheet
The OSHA Interim Final Lead in Construction Standard (1926.62) went into effect
June 3, 1993- It applies to all workers doing construction work who may be exposed to
lead on the job.
OSHA has developed a compliance document that will clarify the standard. You can
obtain a copy of the compliance document by contacting the OSHA office in your area
or by accessing the OSHA web site (www.osha.gov). Contact your state or regional
OSHA office for an interpretation of the Construction Standard if necessary. (See the
Glossary and Resources Section, Chapter 10, for a listing of OSHA offices.)
The sections of the standard which apply to the different parts of this fact sheet are listed
in parentheses ().
Airborne lead exposure
How much lead am I allowed to breathe?
There are two legal limits for the amount of lead you are allowed to breathe. These
limits are for the average amount of lead in the air over an 8-hour day:
Action Level—If you work in an area that contains lead at or above 30 micrograms
per cubic meter (|ig/m3) of air, your employer must give you medical surveillance
and training in the hazards of working with lead. The limit of 30 |ig/m3 is called the
Action Level (AL).
Permissible Exposure Limit—Your employer is not allowed to let you breathe in
more than 50 micrograms of lead per cubic meter of air. It is called the Permissible
Exposure Limit (PEL). If you work in an area with more lead in the air than the
PEL, your employer must reduce your exposure.
If you are exposed to lead for more than 8 hours a day, the PEL must be adjusted.
Divide 400 by the hours worked per day to get the new exposure limit.
How does my employer know how much lead is in the air?
Your employer must do an exposure assessment to determine the amount of lead in the
air you are breathing. Exposure assessment can be air sampling, past exposure data from
the same job or a similar job, or objective data (Section (d)(3) Basis of initial
determination). Examples of objective data are product information and insurance
information. Objective data are not often used. Conditions for each job, each day, and
even each hour, are constantly changing. When conditions change, you cannot rely on
objective data.
3-7
OSHA lead in air
levels are:
AL = 30 |jg/nn3;
PEL = 50 |jg/m3.
-------
QP
Lead Abatement for Workers
Your employer must determine how much lead is in the air for each job type. For
example, your employer may do exposure assessment on one scraper, one cleaner, and
one person using a heat gun. When your employer does air sampling, your employer
must do air sampling on each shift or the shift with the highest exposure. Your employer
must also sample the air if any of the employees on the job think they are getting sick
because of exposure to lead on the job.
How often does my employer need to sample the air?
Your employer must determine if you are breathing air at or above the Action Level (30
(ig/m3). If your exposure to lead is below the Action Level, your employer does not need
to sample again unless the conditions of your job change. If your exposure to lead is at or
above the Action Level but below the PEL (50 pg/m3), then sampling must be done
every six months. If the amount is above the PEL, then sampling must be done every
three months.
Your employer must also sample every time the conditions of your job change. For
example, your employer needs to sample each time you do an abatement job on a
different type of building. (Section (d)(6) Frequency and (d)(7) Additional exposure
assessments)
How can I find out the results of air sampling?
Your employer is required to give you the results of air sampling within five working
days after receiving the results. (Section (d)(8) Employee notification)
Am I protected before air sampling is done?
YES! Certain tasks on construction jobs where lead-based paint is present are known to
create large amounts of lead in the air. These tasks are called lead-related tasks. The
OSHA Standard splits these lead-related task into three different classes. (Section (d)(2)
Protection of employees during exposure assessment)
• using a heat gun
• power tool cleaning with dust collection systems
• spray painting with lead-based paint
When you do Class 1 tasks, your employer must protect you as if your lead exposure
is above the PEL (50 |ig/m3) but not in excess of 500 |ig/m3. Your employer must
give you this protection until exposure assessment shows the exposure is less than
the PEL. Even when the exposure is lower than 50 pg/m3, you can request a
respirator. Your employer must give you one.
Certain tasks on
construction jobs
create large
Class 1 tasks
• manual demolition of structures (for example, removing a wall)
• manual scraping (includes chemical stripping) or sanding
amounts of lead
in the air.
3-8
-------
Laws, Regulations, and Standards
Class 2 tasks
• using lead-based mortar
• burning lead
• rivet busting
• power tool cleaning without dust collection systems
• cleanup activities where dry expendable abrasives are used
• moving or tearing down the enclosure used for abrasive blasting
Your employer must protect you when you do Class 2 tasks as if your lead exposure
is between 10 times the PEL (500 pg/m3) and 2,500 pg/m3. He or she must give
you higher protection until exposure assessment shows that your exposure is less
than 500 |ig/m3. If your exposure is lower, you must still be protected. Your
employer must provide you with a respirator that protects you from the lead level to
which you are being exposed. You can use the chart on page 3-10 and the exposure
assessment to find the right respirator for the job.
Class 3 tasks
• abrasive blasting
• welding
• cutting
• torch burning
Your employer must protect you when you do Class 3 tasks as if your lead exposure is
above 50 times the PEL (2,500 |ig/m3). Your employer must give you this higher
protection until exposure assessment shows that your exposure is below this level. If your
exposure is lower, you must still be protected. Your employer must provide you with a
respirator that protects you from the lead level to which you are being exposed. You can
use the chart on page 3-10 to find the right respirator for the job.
What does my employer have to do?
If you will be exposed at or above the AL or you will do any of the lead-related tasks in
Classes 1, 2, or 3, your employer must provide the following for workers: (Section
(d)(2)(v)(A)-(F))
• training on the hazards of working with lead
• a place for hand and face washing
• blood tests reviewed by a doctor
• HEPA vacuums
Your employer
must provide you
with a respirator
that protects you
from the lead
level to which you
are being
exposed.
3-9
-------
Lead Abatement for Workers
SOME RESPIRATORS LEGAL FOR LEAD WORK
Task Class
MUC*
Respirator Types
Class 1
500 |ig/m3
• Half-mask, air-purifying with HEPA** filters
Class 2
1,250 |ig/m3
• Loose-fitting hood or helmet PAPR with HEPA filters
• Hood or helmet with supplied air continuous flow
• Type CE continuous flow
Class 2
2,500 |ig/m3
• Full-face, air-purifying with HEPA filters
• Tight-fitting PAPR with HEPA filters
• Full-face, supplied air, pressure demand
• Half-mask or full-face, supplied air, continuous flow
Class 3
50,000 |ig/m3
• Half-mask, supplied air, pressure demand
Class 3
100,000 |ig/m3
• Full-face, supplied air, pressure demand
• Type CE pressure demand
Class 3
100,000+ |ig/m3
• Full-face, SCBA, pressure demand
*MUC stands for "Maximum Use Concentration," which means the highest amount of lead in the air for which the
respirator can be used.
**HEPA: high efficiency particulate filter means a filter that is 99-97 percent efficient against particles of 0.3 micron
size or larger.
Remember: Some specific tasks require minimum respiratory protection until your employer determines your actual
exposure level (i.e., the amount of lead in the air you are breathing). However, the appropriate level of respiratory
protection provided for any lead activity should be based upon the airborne concentration present in the workplace.
3-10
-------
Laws, Regulations, and Standards
If you will be exposed above the PEL or you will do any of the lead-related tasks in
Classes 1, 2, or 3, your employer must provide the following for workers,
(in addition to those required if you exceed the AL): (Section (d)(2)(v)(A)-(F))
the correct respirator (see the table on page 3-10)
personal protective clothing and equipment
an area to change into and out of your work clothes
a place for hand and face washing
a place where you can shower at the end of the day, if feasible
blood tests reviewed by a doctor
training on the hazards of working with lead
a lead-safe area for eating and drinking
warning signs around the work area
Does my employer have to reduce my exposure to the lead in the air?
YES! Your employer must do everything possible to reduce your exposure, for example:
• Use materials or tools which make less lead dust or fumes.
• Change the way you do a job so you create less dust and fumes.
• Rotate schedules so worker exposure to lead is less than a few hours a day.
• Provide you with a respirator.
Your employer must list in writing all the
ways he or she is trying to reduce your
exposure to lead. This is called a compliance
program. (Section (e)(2) Compliance
program)
Respirators and protective clothing
When must I wear a respirator?
According to the OSHA Standard, you are
only required to wear a respirator if you are
doing a Class 1, 2, or 3 task or if air sampling
shows you are exposed above the PEL (50 pg/ m3). But if you are exposed to any amount
of lead, the regulations say you can request a respirator from your employer, and your
employer is required to give you a respirator. This means you can still get a respirator even
if you are not exposed to lead above the PEL or doing any of the lead-related tasks.
Respirators and
protective
clothing will
reduce your lead
exposure.
3-11
-------
Lead Abatement for Workers
Your employer must provide a respirator for any employee exposed to lead who asks for
one. You may want to have this extra protection, especially if you are planning to have
children. OSHA recommends that both males and females that are of childbearing age
not exceed a blood lead level of 30 (ig/dL (Appendix C, Section II).
Whenever you are exposed above the PEL, you can always ask your employer for a
Powered Air Purifying Respirator (PAPR). If you are exposed above the PEL, your
employer must, by law, provide you with a PAPR—if you ask for it and if it protects
you enough. If a PAPR is not protective enough for the job—for example, abrasive
blasting—then your employer must provide you with a better respirator that is suitable
for this type of work. (Section (f)(l)(iv) Respiratory protection)
What type of respirator can I use?
The respirator you use will depend on the amount of lead in the air and the job you are
doing. The standard says you must have a respirator at least as protective as those listed
in the table on page 3-10. You can always ask your employer for a Powered Air Purifying
Respirator (PAPR). By law, your employer must give you a PAPR if you are exposed
above the PEL and you ask for one—and if it provides enough protection. Sometimes a
PAPR will not protect you enough—for example, if you were doing abrasive blasting. In
that case, your employer must give you a better respirator, such as a full-face, supplied
air, pressure demand respirator. Any respirator you use must have a stamp of approval
by National Institute of Occupational Safety and Health (NIOSH) or the Mine Safety
and Health Administration (MSHA). (Section (f), Table 1 Respiratory Protection for
Lead Aerosols)
What do I need to do before I wear a respirator?
A physician or other licensed health care professional (PLHCP) (e.g., registered nurse)
must determine who can and cannot use or wear a respirator safely. This medical
evaluation consists of the written or verbal completion of Appendix C of the lead in
construction standard (29 CFR 1926.62) by the PLHCP. Your employer must pay for
the medical evaluation and any testing recommended by the PLHCP. You also need fit
testing and training on how to use your respirator.
What personal protective equipment do I need other than a respirator?
If you are working in an area with lead above the PEL, or if you are doing any of the
tasks listed under Class 1, 2, or 3, your employer must give you protective work
clothing. (Section (g) Protective work clothing and equipment) This clothing should
include
The respirator you
use will depend
on the amount of
lead in the air and
the job you are
doing.
A physician or
PLHCP must
determine who can
and cannot use or
wear a respirator
safely.
• coveralls
• gloves
• disposable shoe coverings
• face shield or vented goggles
• hat (adequate head protection based on the hazards present in the work area)
3-12
-------
Laws, Regulations, and Standards
Who is responsible for providing and cleaning my
protective clothing ?
If you are exposed at or below the PEL (50 |ig/m3), your
employer is not required to provide you with protective
clothing. If you are exposed above the PEL but below 200
|ig/m3 —or you are doing a Class 1 task and no exposure
assessment has been completed—your employer must
wash and dry protective clothing or give you new clothing
every week. If you are exposed at or above 200 |ig/m3,
your employer must provide clean or new protective
clothing every day. If you are doing a Class 2 or 3 task,
and an exposure assessment for the task has not been
completed, your employer must assume that you are being exposed at the higher levels
associated with these tasks. The employer must provide clean or new protective clothing
every day until the exposure assessment determines that your exposure is less than 200
|ig/ m3.
Many employers provide disposable suits. These suits are easily torn. You should
inspect your protective clothing regularly for tears or rips. If your suit tears or rips and
you cannot repair it, you must get a new protective suit. Some employers provide
reusable, non-disposable protective clothing. This clothing is usually more durable
than the disposable suits, but if it does rip or tear, have it repaired immediately to
minimize your chances of being contaminated. If you are given non-disposable
protective clothing, your employer is responsible for cleaning, drying, and repairing it.
(Section (g)(2) Cleaning and replacement)
Where should I put my used protective clothing?
Your employer must have a closed container in the change area for used protective
clothing. The container must be labeled as follows:
CAUTION: Clothing contaminated with lead.
DO NOT REMOVE DUST BY BLOWING OR SHAKING.
Dispose of lead-contaminated wash water in accordance
with applicable local, state, or federal regulations.
This helps to prevent your family and other people living in the community from being
exposed to lead. The standard says your employer cannot let you leave the work area
with protective clothing on.
-------
Lead Abatement for Workers
Use only a HEPA
vacuum when
cleaning up lead
dust.
Your workplace
How clean must we keep our job site?
The standard says you must keep all surfaces as free of lead as possible. You must clean
up floors and other surfaces with a vacuum or other method that minimizes the
likelihood of lead getting into the air. This vacuum must have a High Efficiency
Particulate Air (HEPA) filter. Only use shoveling, dry-sweeping, wet-sweeping, or
brushing if your employer shows that vacuuming, or other equally effective method,
does not work to pick up the dust on your job site.
Compressed air shall not be used to remove lead from any surface unless used in
conjunction with proper ventilation and air filtration. (Section (h) Housekeeping)
Can we eat or drink on the job?
NO! Your employer must not allow you to eat, drink, smoke, chew tobacco, or apply
cosmetics in the work area where your exposure to lead is above the PEL. Your employer
must have a place where anyone exposed above the PEL can eat and drink safely, away from
lead. Your employer must make sure that you wash your hands and face before eating,
drinking, smoking, or applying cosmetics. (Section (i) Hygiene facilities and practices)
Where can we change our clothes and wash?
Whenever you work with lead, your employer must have a place for you to wash your
hands and face. Your employer must make sure that you wash your hands and face at the
end of each work shift.
The standard says your employer must have places where anyone exposed above the PEL
or doing any of the lead-related tasks (Class 1, 2, or 3) can change in and out of their
work clothes. Your employer must have a place where anyone exposed above the PEL
can shower, if feasible. OSHA officials have said that if your employer decides having a
shower is not feasible, he or she must be able to explain his or her reasoning to any
OSHA inspector who comes on the site. (Section (i)(2) Change areas)
Never eat, drink,
smoke, chew, or
apply cosmetics
in a lead work
area!!
3-14
-------
Laws, Regulations, and Standards
Does my employer have to post warning signs in the work area?
Your employer must post warning signs in the work area where employees are exposed
above the PEL. (Section (m) Signs) The signs must say
WARNING
LEAD WORK AREA
POISON
NO SMOKING OR EATING
Your employer
must train you on
the hazards of
lead and how to
protect yourself.
Training
How can workers find out about the hazards of lead?
The OSHA standard says that employers must provide training to anyone
• working with lead at or above the Action Level (30 |ig/m3);
• doing any of the tasks listed under Class 1, 2, or 3;
• using any lead compounds that cause eye or skin irritation.
(Section (1) Employee information and training)
What does the training about lead have to include?
The annual training must include information on
• OSHA's hazard communication standard (29 CFR 1926.59) including requirements
for warning signs and labels, MSDS, and employee information and training;
• OSHA Interim Final Lead in Construction Standard;
• jobs that expose workers to lead above the Action Level;
• respirators: their use and limitations, the different types, and the importance of a
proper fit;
• medical surveillance and medical removal protection programs;
• ways your employer can reduce your exposure to lead;
• what your employer is doing to reduce your exposure to lead;
• contents of employer's compliance program (if > 50 |ig/m3);
• instructions not to use chelating agents.
3-15
-------
Lead Abatement for Workers
Recordkeeping
What records does my employer have to keep?
Your employer must keep records of
• all exposure assessments done on your job site;
• the types of respiratory protection worn on your job site;
• names and social security numbers of all employees;
• all medical surveillance done on employees;
• all training done for employees;
• all cases of employees being "medically-removed" from the workplace.
OSHA says that
you have a right
to see your
records:
• medical;
• air sampling.
All records must be kept for at least 30 years (except training records—they must be kept
for at least one year after you leave that employer). (Section (n) Recordkeeping).
Do I have the right to see any of these records?
YES! You have the right to see any of the air sampling results or any other types of
exposure assessments done on your job site. You have the right to have a copy of your
medical exam and blood test results. Your employer is required to send a copy of your
medical records to anyone you choose. Any requests to send your medical records to
someone else should be in writing.
Medical surveillance
Special medical exams called medical surveillance are required when you work with lead.
(Section (j) Medical surveillance) There are two types of medical surveillance:
• initial medical surveillance
• medical surveillance program
Initial medical surveillance
Initial medical surveillance consists of blood tests that check the amount of lead in
your blood. This test is also called biological monitoring. The two blood tests used in
the biological monitoring are the blood lead level test and the zinc protoporphyrin
(ZPP) test. You need medical surveillance if you do any of the tasks in class 1, 2 or 3
listed in this standard or if you are exposed to lead on the job any one day at or above
the Action Level.
3-16
-------
Laws, Regulations, and Standards
On-going medical surveillance program
You need a medical surveillance program if you are or may be exposed to lead on the job
at or above the Action Level for more than 30 days in any continuous 12-month
period. If you are a lead-abatement worker, you can be exposed to lead above the Action
Level for 30 or more days in a year. When you expect to do lead-abatement work for at
least 30 days, you should take part in a medical surveillance program.
The ongoing medical surveillance program has three types of exams. The doctor must
follow the standard and provide
• blood tests for biological monitoring;
• a six-part medical exam;
• a medical exam and consultation.
Blood tests for biological monitoring
The blood lead level and ZPP tests are required when
1. you begin working with lead and every two months for the first six months, and
then every six months as long as you are working with lead at or above the Action
Level for 30 or more days within a year's time period;
2. your blood lead level results are at or above 40 (ig/dL—you must be tested at least
every two months until two consecutive blood lead level results are below 40 (ig/dL;
3. your blood lead level results are at or above 50 (ig/dL—you must be tested again
within two weeks. If the second test result is at or above 50 (ig/dL, you must be
medically removed (defined on page 3-19) and tested at least every month until you
reach a blood lead level of 40 (ig/dL or less on two separate testing dates. The tests
must be taken at least 30 days apart.
Six-part medical exam
Your employer must make available to you the required six-part medical exam in the
medical surveillance program whenever you will be working with lead at or above the
Action Level for 30 or more days and your blood lead level results are 40 (ig/dL or above.
(Section (j) (3) (ii) Content) This exam consists of the following:
1. interview about your work and medical history covering:
a. past lead exposures
b. personal habits like smoking and hygiene
c. previous medical problems with the kidneys, heart, nerves, blood, stomach,
intestines, and reproductive organs
2. complete physical exam to look at your
Blood tests are
the best way of
knowing if you've
been exposed to
lead.
3-17
-------
Lead Abatement for Workers
a. blood
b. teeth and gums
c. stomach and intestines
d. kidneys
e. nerves
f. brain
g. heart
h. lungs
3- blood pressure check
4. blood tests which will show
a. blood lead level
b. ZPP
c. hemoglobin & hematocrit (anemia test)
d. blood urea nitrogen
e. serum creatinine (kidney test)
5. routine urinalysis (kidney and protein check)
6. any additional test that the doctor needs to do to determine how lead has affected or
could affect you. Pregnancy testing and male fertility testing must be provided if you
request them.
Medical exam and consultation
You have the right to a medical exam and consultation whenever you will be working
with lead at or above the Action Level for 30 days or more and
• anytime you are working with lead and you feel sick with any of the signs and
symptoms of lead poisoning;
• yearly when you have a blood lead level at or above 40 |ig/dL;
• whenever you are concerned about having a healthy baby;
• if you have difficulty breathing while wearing a respirator.
You need to notify your employer that you want the medical exam and consultation.
The content of this medical exam and consultation is determined by the doctor. (Section
(j)(3) Medical exam and consultation)
Who must provide medical surveillance?
Medical surveillance must be provided by your employer.
Your employer must provide medical surveillance for you at no cost to you, the
worker—and at a reasonable time and place.
-------
Laws, Regulations, and Standards
All medical examinations and procedures must be supervised or performed by a licensed
physician. Your employer must notify you of the results of the exam within five working
days. This is called "notification." You may have another doctor review the findings and
provide a second exam. The employer must pay for the second review. This is called
"multiple physician review."
What does multiple physician review mean?
If you are not comfortable with the available doctor or do not agree with the doctor's
findings, you can request a second medical exam with a doctor of your choice. This
request must be made within 15 days after you receive your copy of the initial medical
exam results. Your employer must pay for the second exam.
If the doctors do not agree, they are asked to talk with each other. If there is still no
agreement, then a third doctor selected by the two previous doctors will review the
findings and conduct any necessary exams. The third doctor gives a written
recommendation to the employer. The third opinion is followed unless you and your
employer jointly agree to follow the recommendation of either of the previous doctors.
(Section (j)(3)(iii) Multiple physician review mechanism)
Medical removal
What is medical removal?
Medical removal means that you are removed from the lead exposure on your job. The
standard states you must be removed if your blood lead levels get too high. Medical
removal can prevent you from getting severe lead poisoning. Removing you from the
lead exposure gives your body time to get rid of the lead. Sometimes this is enough to
bring the blood lead level down. Medical removal is a way to protect you from becoming
lead poisoned. There are two times that you may be medically removed:
• elevated blood lead level
If your blood lead level reaches 50 pg/dL, for the periodic blood test and the follow-
up blood test, you must be removed from exposure to lead at or above the Action
Level. It is dangerous for you to work with lead when your blood lead level is so
high. You cannot wear a respirator to lower your exposure when your blood lead
level is so high. If you get more lead into your body, you could become lead
poisoned. Your employer must provide you with a job with no lead exposure at or
above the Action Level. If your employer cannot, he/she must pay you your normal
wages until your blood lead level is at 40 (ig/dL on two separate tests. You then
return to your former job. If your blood lead level remains above 40 pg/dL, your
wages must be paid as long as the job exists or up to 18 months. This is called
medical removal protection.
If the lead level in
your blood gets
too high, you
should not work
in a lead work
area until your
doctor says it's
okay.
3-19
-------
Lead Abatement for Workers
• final medical determination
Final medical determination means the doctor has given a written medical opinion
to remove you from lead exposure. The doctor believes that you have a medical
problem that will be affected by lead exposure. The doctor believes that the risk to
your health is high. The doctor must inform the employer of the medical
recommendation regarding working with lead.
The doctor does not tell the employer what the medical problem is, but states that you
are at high risk of ill health with lead exposure.
You may return to work with lead when the doctor determines that you no longer have a
medical problem that puts you at high risk of ill health with lead exposure. The doctor
must put the medical opinion in writing. You then return to your former job. While you
are unable to work with lead, your employer must provide you with another job where
your lead exposure is not at or above the Action Level. If another job is not available,
your employer must pay your wages for as long as the job exists or up to 18 months.
A doctor may use a final medical determination if you say you want to have children
and your blood lead level is 30 pg/dL or higher. You will then be placed on medical
removal protection. OSHA recommends that a Maximum Permissible blood lead level
of 30 (ig/dL should not be exceeded in males and females who wish to have children.
(Section (k)(l) Temporary medical removal and return of an employee)
What is medical removal protection?
Medical removal protection means that your job will be protected if you must be
medically removed from your lead abatement job. Under the OSHA Lead Standard,
your employer must pay your salary and benefits and maintain your seniority while you
are medically removed. This medical removal protection will last as long as the job exists
or up to 18 months. (Section (k)(2) Medical removal protection benefits)
Medical treatment
What is the treatment for lead poisoning?
Chelation therapy is the medical treatment for severe lead poisoning. Chelation
therapy is when a drug that is attracted to metals (such as lead) is given to someone with
high levels of lead in their blood. Most chelating drugs are now given orally (they used
to be given by injection). The drug then gets into the blood stream. It binds to the metal
in the blood; the metal and the drug are then passed out of the body through the
kidneys in the urine. It is a risky treatment.
Whenever
possible, get a
second medical
opinion to
determine
whether you
need chelation
treatment.
3-20
-------
Laws, Regulations, and Standards
Chelation can get rid of some of the lead in your body, but it can be harmful to your
health. Chelation is a serious medical treatment. The drug not only removes the lead
from your blood, but also other metals that the body needs, such as iron and zinc. When
possible, you want to know that at least two doctors think it is necessary for you to have
it. The second doctor should be a doctor that you know and trust. This second opinion
is paid for by your employer, when you request it. This is when the multiple physician
review is most helpful.
Prophylactic chelation means giving chelating drugs to someone to try and prevent lead
poisoning. Chelating drugs will only help remove lead from your body after you have
been poisoned. Chelating drugs will not protect anyone from lead poisoning. It is illegal
for your employer or anyone employed by your employer to give you chelating drugs.
Chelating drugs are dangerous to your health. They can hide lead poisoning that may be
happening to you. The chelating drugs may also make your body take in lead more
easily. (Section (j)(4) Chelation)
Taking chelating
drugs as a
preventative
treatment is
prohibited and
illegal.
3-21
-------
Lead Abatement for Workers
Title X was
designed to
reduce lead-
based paint
hazards and lead
poisoning.
Title X fact sheet
The Residential Lead-Based Paint Hazard Reduction Act of 1992 (Title X ["ten"]) was
established by Congress to reduce the risk of lead poisoning in Federal Housing stock.
Some of the general purposes of this law were to
• prevent lead poisoning;
• insure that Federal policies incorporate lead hazard reduction measures;
• educate the public;
• develop an infrastructure capable of dealing with lead in housing (e.g., trained and
certified professionals such as lead abatement contractors and workers).
Most of the lead regulations from federal agencies such as the Environmental Protection
Agency (EPA), the Department of Housing and Urban Development (HUD), and the
Occupational Safety and Health Administration (OSHA) were developed based on
direction found in Title X. This law is the cornerstone of the national lead program.
Title X required different government agencies (such as HUD and EPA) to help reduce
the amount of lead poisoning in this country. This fact sheet lists some of the important
parts of Title X.
Why was Title X passed?
The United State Congress received information that
• an estimated three million American children under the age of six had at least low-
level lead poisoning (that number has been reduced to less than one million in part
due to the laws and practices instituted since the passage of Title X);
• lead poisoning in children may cause reading and learning disabilities, hyperactivity,
and behavior problems;
• ingesting lead dust from deteriorating lead-based paint is the most common cause of
lead poisoning;
• homes built before 1980 contained more than 3 million tons of lead in the form of
lead-based paint;
• as many as 3,800,000 American homes had chipping or peeling
lead-based paint;
• the dangers of lead-based paint hazards can be reduced by permanently abating
those hazards or by using interim controls to prevent paint deterioration;
3-22
-------
Laws, Regulations, and Standards
Since Title X was passed, the government has taken many steps to reduce lead-based paint
hazards (the regulations and an explanation of what each requires are listed in this chapter).
Title X was designed to eliminate lead-based paint hazards before they poison children. In
the past, many agencies only got rid of lead-based paint after a child had been poisoned.
What was the law designed to do?
The law was designed to
• develop a system of trained people (including lead inspectors, risk assessors,
supervisors, contractors, project designers, and abatement workers) to evaluate and
reduce lead hazards;
• reduce childhood lead poisoning;
• use government funds in the most cost-effective way to eliminate lead-based paint
hazards-,
• educate the public concerning the hazards and sources of lead poisoning.
The federal government is a "model landlord."
The federal Lead Safe Housing Rule (which became effective September 15, 2000)
requires that actions be taken to address lead hazards in all housing receiving HUD
assistance. The actions required depend upon the nature and amount of the assistance
provided by HUD. For example, housing receiving funds for rehabilitation are subject
to different requirements than housing receiving project-based rental assistance (i.e., the
financial assistance is tied to a specific residential property with a specific location).
Anyone purchasing or renting a housing unit built before 1978 must be given a lead
hazard information pamphlet: Protect Your Family from Lead in Your Home. They must
also be notified by the owner of any known information on lead-based paint or lead-
based paint hazards inside or outside of the house or apartment.
Who has to be trained?
Title X required EPA to issue specific requirements for how contractors, workers,
supervisors, inspectors, risk assessors, and project designers will be trained in lead-based
paint activities. These requirements also say how abatement contractors, workers,
supervisors, and paint inspectors and risk assessors will be certified. EPA has developed
model course curricula for each of the disciplines listed. Most training providers use EPA's
curricula. As part of the EPA program, lead training programs must also be accredited.
Only EPA- or state/Indian Tribe-approved training will qualify for certification.
3-23
HUD's Lead Safe
Housing Rule
requires that lead
hazards be
addressed in all
housing receiving
HUD assistance.
-------
Lead Abatement for Workers
HUD's Lead Safe Housing Rule requires renovation, rehab, and maintenance workers
who will disturb lead-based paint during jobs done in housing receiving HUD assistance
to be trained in lead-safe work practices. HUD and EPA have developed several courses
to train these workers in lead-safe work practices.
How should abatement work be done?
Many renovation
and maintenance
workers must be
trained in lead-
safe work
practices.
There are
established work
practices that
you must
followed on a
lead abatement
job.
Certification and
licensing
requirements for
lead workers
apply in all states
and tribes.
EPA established work practice standards which must be followed when doing abatement
(and lead-based paint inspections, or risk assessments):
• Companies and individuals doing the work must be certified or licensed by the
state, Indian tribe, or EPA.
• abatement must be performed according to the following procedures:
a certified supervisor is required for each abatement project and must be on-site
during all work site preparation and during the post-abatement cleanup of work
areas and available by telephone, pager or answering service and to be present at
the work site within two hours (some states require the supervisor to be on-site
at all times during the project).
the supervisor and firm must be sure that all abatement activities are conducted
according to the requirements of all Federal, State/Tribal, or local requirements.
EPA and the state/tribes require notification of the beginning of lead-based
paint abatement activities in a residential dwelling or child-occupied facility.
a written occupant protection plan must be prepared for all abatement projects
specific work practices are prohibited;
soil must be either removed and replaced or permanently covered;
there are specific post-abatement procedures required (including a visual
inspection and clearance dust sampling) that must be done by a certified lead-
based paint inspector or risk assessor.
Does each state or tribe have its own certification program?
Many states have their own certification or licensing program which is approved by
EPA. EPA runs the certification program in states and Indian tribes that do not have
their own programs. Because all state programs must be based on EPA's model plan,
each state's program should be the same or very similar. However, some states' rules are
different. The course instructor will address the differences that may exist between your
state's or tribe's rules and EPA's rules. Make sure this course and any others you take are
approved by the state(s)/Indian tribe(s) in which you work.
3-24
-------
Laws, Regulations, and Standards
Are workers doing lead-abatement jobs protected?
The OSHA Interim Final Lead in Construction Standard became law on June 3, 1993.
This standard includes specific requirements for protecting workers doing lead-
abatement jobs.
When does lead-based paint become a hazard1?
EPA has issued standards on
• the conditions of lead-based paint that are a hazard;
• the level of lead in dust allowed on the floors or windows before it is considered
a hazard;
• the level of lead allowed in bare residential soil before it is considered a hazard.
Paint-lead hazards
EPA has defined under what conditions lead-based paint in a dwelling becomes
hazardous:
• lead-based paint on friction surfaces that are subjected to abrasion (rubbing of
painted surface against painted surface as with double-hung window sashes) and
where dust-lead hazards (see below) are present;
• lead-based paint on impact surfaces (e.g., floors, door stops, chair rails) that is
damaged or deteriorated;
• any chewable lead-based painted surface on which there is evidence of teeth marks;
• any other deteriorated lead-based paint.
Dust-lead hazards
EPA has defined what dust levels would indicate a dust-lead hazard. These levels are:
Location Amount of Lead
Bare or carpeted floors 40pg/ft2
Interior window 250pg/ft2
sills (stools)
Damaged or
deteriorated
lead-based paint
is a hazard.
EPA has defined
dangerous levels
of lead in dust
and bare soil.
1 Lead-based paint hazards are usually identified during a lead risk assessment. More information on lead
risk assessments and other lead hazard evaluations is found in Chapter 4.)
3-25
-------
EPA and HUD are
educating the
public about
lead-based paint
hazards.
Lead Abatement for Workers
In addition, EPA has established clearance lead-dust levels. The clearance levels must be
met after abatement or federally-assisted rehab or renovation activities have been
performed:
Location
Bare or carpeted floors
Interior window
sills (stools)
Window troughs
Amount of Lead
40 pg/ft2
250 pg/ft2
400 pg/ft2
Soil-lead hazards
Finally, EPA issued standards on the levels of lead in residential bare soils that
constitute a soil-lead hazard.
The two different levels established are
Location
play areas
other areas of the yard
Amount of Lead
400 pg/g(ppm)
average of 1,200 (ig/g (ppm)
Your supervisor or employer is required to make sure the project is in compliance with
the applicable standards.
How is the government educating the public?
Title X required EPA and HUD to issue regulations which require property owners to
give each person buying or renting a property built before 1978:
• an EPA lead hazard information pamphlet: Protect Your Family From Lead in Your
Home-,
• any information about lead-based paint hazards in the property;
• for homes built before 1978, a statement in the sales/lease contract warning about
the hazards of lead-based paint.
In addition, before a home built before 1978 is sold, the buyer must be given at least ten
days to conduct an inspection or risk assessment for lead-based paint hazards. This
requirement became effective for everyone in December 1996.
Before starting renovation that will disturb more than two square feet of paint in
housing built before 1978, home remodeling or renovation contractors are required by
EPA to give a lead hazard information pamphlet to the owner and occupant.
Who is making sure the laws really help solve the problem?
Title X required the HUD Secretary and the EPA Administrator to set up a task force of
federal agencies and other organizations with knowledge about lead-based paint
activities. This task force has made recommendations to EPA and HUD on developing
standards and dealing with the concerns of property owners.
3-26
-------
Laws, Regulations, and Standards
Have these laws been effective?
Yes! Since the passage of Title X and the implementation of these laws, there have been
many successes in reducing lead poisoning in children and lead-based paint hazards in
housing. These include:
• a significant reduction in the number of residences with lead-based paint and lead-
based paint hazards;
• fewer children have too much lead in their blood;
• thirty-seven states now have lead certification or licensing laws (approved by EPA);
• there are thousands of trained and certified lead inspectors, risk assessors,
contractors, and workers;
• HUD lead hazard control grants are now active in over 200 cities;
• thousands of maintenance, renovation, and remodeling workers have been trained
in lead-safe work practices;
• HUD published the Guidelines for the Evaluation and Control of Lead-based Paint
Hazards in Housing and modernized lead hazard control requirements in all
federally-assisted housing;
• there is overall increased public awareness of lead hazards in housing and how to
prevent them.
Since Title X was
passed by
Congress, there
have been many
successes in
reducing lead-
based paint
hazards in
housing and lead
poisoning of
children and
workers.
3-27
-------
Lead Abatement for Workers
Your state or tribal laws
Your instructor should provide you with lead-based paint information that applies to the
state or tribe in which you work or live. Some cities and counties have lead laws that
may apply to the job you are doing. This information may be inserted here. Or, you
may take some notes on this page.
Your state or
tribe may have
lead regulations
that are different
from the federal.
3-28
-------
Laws, Regulations, and Standards
Key facts for Chapter 3
The law is one tool that can be used to secure a safer and healthier job.
The Occupational Safety and Health Administration (OSHA), an agency of the
Department of Labor, writes and enforces rules protecting workers on the job.
The Environmental Protection Agency has issued rules protecting lead
abatement workers, the public, and the environment.
The Department of Housing and Urban Development (HUD) has established
guidelines for lead-based paint abatement projects in housing. They have also
issued rules to protect workers and occupants during and after rehab,
renovation, and maintenance in federally-assisted housing.
OSHA has set legal limits for airborne lead exposure.
There are two legal limits for the amount of lead you are allowed to breathe: the
Action Level, at or above 30 pg/m3; the Permissible Exposure Limit, more than
50 pg/m3 per cubic meter of air.
Your employer must do an exposure assessment to determine the amount of
lead in the air you are breathing.
Your employer must determine how much lead is in the air for each job type.
Certain tasks on construction jobs where lead-based paint is present are known to
cause large amounts of lead in the air. These tasks are called "lead-related tasks."
If you will be exposed above the PEL or you will do any of the lead-related tasks
in Classes 1, 2, or 3, your employer must provide the following for workers:
• the correct respirator;
• personal protective clothing and equipment;
• an area to change into and out of your work clothes;
• a place for hand and face washing;
• a place where you can shower at the end of the day, if feasible;
• blood tests reviewed by a doctor;
• training on the hazards of working with lead;
• a lead-safe area for eating and drinking;
• warning signs around the work area.
-------
Lead Abatement for Workers
When must I wear a respirator?
According to the OSHA Standard, you are only required to wear a respirator if
you are doing a Class 1, 2, or 3 task or if air sampling shows you are exposed
above the PEL (50 pg/m3).
You can request a respirator from your employer, and your employer is required
to give you a respirator.
If you are exposed above the PEL, your employer must provide you with a
Powered Air Purifying Respirator (PAPR)—if you ask for it and if it provides
enough protection for the lead levels to which you are exposed.
The respirator you use will depend on the amount of lead in the air and the job
you are doing.
What personal protective equipment do I need other than a respirator?
coveralls
disposable shoe coverings
face shield or vented goggles
hat (adequate head protection based on the hazards present in
the work area)
You must clean up floors and other surfaces equipped with a vacuum with a
High Efficiency Particulate Air (HEPA) filter.
You must not eat, drink, smoke, chew tobacco, or apply cosmetics in the
work area.
Whenever you work with lead, your employer must have a place for you to
wash your hands and face.
Your employer must train you on the hazards of lead and how to protect
yourself. Employers must provide training to anyone
• working with lead at or above the Action Level (30 pg/m3);
• doing any of the tasks listed under Class 1, 2, or 3;
• using any lead compounds that cause eye or skin irritation.
Your employer must keep records of
• all exposure assessments done on your job site;
• the types of respiratory protection worn on your job site;
• names and social security numbers of all employees;
• all medical surveillance done on employees;
-------
Laws, Regulations, and Standards
• all training done for employees;
• all cases of medical removal of employees.
You have a right to see your records.
Special medical exams are required when you work with lead. These exams
are called medical surveillance. There are two types: initial medical
surveillance and medical surveillance program.
Initial medical surveillance is blood tests that check the amount of lead in your
blood.
You need a medical surveillance program if you are or may be exposed to lead
on the job at or above the Action Level for more than 30 days in any
continuous 12-month period.
Your employer must provide medical surveillance for you at no cost to you, the
worker—and at a reasonable time and place.
Medical removal is a way to protect you from becoming lead poisoned.
There are two times that you may be medically removed: if your blood lead level
reaches 50 (ig/dL or if the doctor has given a written medical opinion to remove
you from lead exposure.
Medical removal protection means that your job will be protected if you must
be medically removed from your lead abatement job.
Chelation is the medical treatment for severe lead poisoning. Chelating
drugs are dangerous to your health.
"Residential Lead-Based Paint Hazard Reduction Act of 1992" is also known
as Title X (Title "Ten").
Title X was designed to reduce lead-based paint hazards and lead poisoning.
Training is required for nationwide for lead workers. Check to see whether
EPA or the state/tribe in which you work is running the program.
There are work practice standards which must be followed when doing
abatement.
The public is being educated about the dangers of lead-based paint hazards.
EPA has set levels of dangerous levels of lead in dust and bare soil and
defined lead-based paint hazards.
You must clean up carefully after each job and pass clearance dust-wipe testing.
Your state/Indian tribe may have lead regulations that are more stringent
than EPA's.
-------
Lead Abatement for Workers
For more information
These publications have more information on the topics covered in this chapter. Your
instructor has a copy of the publications marked with a star (*). You can order your own
copies by calling 1-800-424-LEAD.
*EPA, Lead: Identification of Dangerous Levels ofLead; Final Rule; 40 CFR Part 745
(January 2001).
EPA, Regulatory Status of Waste Generated by Contractors and Residents from Lead-based
Paint Activities Conducted in Households, Interpretive Memorandum (July 2000).
EPA, Lead: Requirements for Hazard Education Before Renovation of Target Housing;
Final Rule; 40 CFR Part 745 (June 1998).
*EPA, Lead: Requirements for Lead-Based Paint Activities in Target Housing and Child-
Occupied Facilities-, 40 CFR Part 745 (August 1996).
EPA and HUD, Lead: Requirements for Disclosure of Known Lead-Based Paint and/or
Lead-Based Paint Hazards in Housing; Final Rule; 40 CFR Part 745 and 24 CFR Part 35
(March 1996).
*HUD, Requirements for Notification, Evaluation and Reduction of Lead-Based Paint
Hazards in Federally Owned Residential Property and Housing Receiving Federal
Assistance; Final Rule (September 1999).
*HUD, Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in
Housing (June 1995).
*OSHA, Interim Final Lead in Construction Standard, 29 CFR 1926.62 (May 1993).
National Lead Information Center: 1-800-424-LEAD.
-------
CHAPTER 4
Identifying Lead-based Paint Hazards
Learning objectives 4-3
Skit: Recognizing lead-based paint 4-4
Discussion questions 4-4
Lead dust 4-5
Where is lead-based paint? 4-6
Inspections 4-7
What surfaces need to be tested? 4-8
What a lead inspector does 4-9
Risk assessment 4-10
Tests for lead in paint, dust, and soil 4-12
Paint chip lab analysis 4-13
X-ray fluorescence (XRF) analysis 4-14
Dust wipe test 4-16
Anodic stripping voltametry 4-18
Wet chemical field tests 4-19
Soil sampling 4-20
Key facts for Chapter 4 4-21
For more information 4-22
-------
Lead Abatement for Workers
4-2
-------
Identifying Lead-based Paint Hazards
Learning objectives
In this chapter you will learn about
• lead dust
• lead inspections
• when lead-based paint inspections are required
• risk assessments
• how inspectors and risk assessors test for lead-based paint and lead-based paint
hazards using
paint chip analysis
X-ray fluorescence analysis
dust wipe tests
anodic stripping voltametry
wet chemical field tests
soil sampling
4-3
-------
Lead Abatement for Workers
Skit: Recognizing lead-based paint
Spiker and Vinnie are getting ready to set up for a rehab job. Let's listen in on their
conversation.
Spiker: Let's get the windows and doors out before we set up. It will save us some
time, and we're already behind schedule.
Vinnie: Is that safe? How do you know there isn't any lead-based paint on them?
Spiker: The owner said replace all the windows and doors. You know, combine
rehab with the lead abatement job.
Vinnie: Yeah, I know. But what if there's lead-based paint on them?
Spiker: Look, they were painted just last year. What are you worried about? If the
windows had lead-based paint, don't you think the owner would know?
Come on, stop trying to stall. Grab a tool and let's get started!
Vinnie: OK, you're the boss. Or at least you act like him.
Discussion questions
1. Is there a chance that the windows and doors would have lead-
based paint on them? Why or why not?
2. Are lead-based paint and dust dangerous if they get on
your clothes?
3. Can you tell if paint contains lead by looking at it?
4. What would you do if you were Vinnie?
What do
you think?
-------
Identifying Lead-based Paint Hazards
Lead dust is
poisonous when
you breathe or
swallow it.
Lead dust
Lead dust is poisonous when you breathe or swallow it.
Lead dust comes from lead-based paint. The dust is so small that you may not even see
it. Lead dust is easy to breathe and swallow. Lead-based paint turns into lead dust when
• it peels, chips, or flakes.
This may occur when paint gets old, moisture-damaged, or damaged by weather
changes.
• surfaces covered with lead-based paint break or get disturbed.
This happens during abatement, renovation, or demolition. When you saw or drill
into a lead-painted surface, you create lead dust.
• surfaces covered with lead-based paint rub against something.
This is called friction. Windows and doors have friction surfaces. When you open a
window, painted edges get rubbed together and create dust. When you walk on
lead-painted floors, lead dust gets kicked up. The friction wears through the top
layers of paint and exposes the older lead-based paint. When you sand or scrape
lead-based paint, you create friction and lead dust.
• surfaces covered with lead-based paint get hit with force.
This is called impact. Impact surfaces include floors, stairs, parts of walls, and doors.
When you bang a lead-painted wall with the back of a chair, lead dust is released.
When you close a door, there is an impact. If the door is painted or hits surfaces
painted with lead-based paint, lead dust can be released.
Whenever you create dust from a lead-painted surface, lead is released into the air.
Lead dust particles in the air can be inhaled into your lungs. When lead dust falls, it
sticks to anything it lands on—floors and other surfaces, people, pets, and even food. If
you get lead dust on your hands and put your fingers in your mouth, you will swallow
lead particles.
Young children are most at risk for lead poisoning. They play on the floor. They put
their hands and toys in their mouths. If lead dust is on the floor and toys, children are
likely to get lead dust in their mouths and swallow lead particles. Sometimes children eat
paint chips. Sometimes they chew on lead-painted surfaces, like window sills. Even if
the lead-based paint is in good condition, a child may still chew the paint and swallow
lead particles.
Lead dust comes
from lead-based
paint.
4-5
-------
Lead Abatement for Workers
Test paint or
assume it has
lead.
Where is lead-based paint?
Any home built before 1978 may contain lead-based paint. Outside surfaces, kitchens,
bathrooms, and windows are the areas most likely to have lead-based paint. However,
lead-based paint can be found on any painted surface of a home. Sometimes the lead-
based paint is buried under layers of latex paint.
You cannot tell if paint has lead in it by looking at it. Painted surfaces must be tested
for lead content. Remember, only certified lead-based paint inspectors or risk assessors
can conduct lead-based paint inspections! Your employer is required to find out if the
paint you will be working on could expose you to dangerous levels of lead in the air. To
be safe, make sure the paint has been tested before you disturb it. If the painted surfaces
have not been tested for lead, assume they contain lead-based paint.
HUD Requirements
Public and Indian housing units, common areas, and exteriors of family housing
must be inspected for lead-based paint if
• built before 1978 (must have been inspected by December 1994) and
• children younger than six years old live or may live there.
Most pre-1978 residential properties receiving HUD funds are subject to HUD
requirements for lead-based paint (24 CFR 35). These regulations include
requirements for notification, lead hazard evaluations, and lead hazard reduction.
The lead hazard evaluation category includes the following activities
• visual assessment;
• paint testing;
• risk assessment.
Title X
As of December 1996, Title X requires that all known information about lead-based
paint and lead-based paint hazards be provided at the time of sale or rental of any
pre-1978 housing unit. It also allows home buyers ten days to arrange for a risk
assessment to identify lead hazards or an inspection to identify the presence of lead-
based paint.
4-6
-------
Identifying Lead-based Paint Hazards
Inspections
identify surfaces
containing lead-
based paint.
Inspections
Checking for lead-based paint is called an inspection. Inspections must be done by a
certified lead inspector or risk assessor. The inspector tests the paint with an X-ray
fluorescence analyzer (XRF) to see if it contains lead. An inspector may also collect paint
chip samples and send them to a lab for testing. Inspections are often done before a lead
hazard control project begins so the owner and contractor know which surfaces are
painted with lead-based paint. Inspections identify the location of lead-based paint.
States have different rules about how and when to test for lead-based paint. (Find out
what your state laws say.) The Department of Housing and Urban Development
(HUD) has developed final guidelines for lead-based paint-related activities, including
inspections. The HUD Guidelines are applicable to inspections of any residential
housing, including private, public, or Indian housing.
The 1992 Residential Lead-Based Paint Hazard Reduction Act (Title X) required EPA
to develop regulations related to lead-based paint inspections in housing built before
1978. EPA issued training and certification regulations for inspectors, risk assessors,
supervisors, project designers, and workers on August 29, 1996. These regulations went
into effect in March 2000 in all states and Indian tribes that did not already have their
own EPA-approved lead certification program established.
4-7
-------
HOUSE
|i PUNT j
Any painted
surface can have
lead-based
paint.
Lead Abatement for Workers
What surfaces need to be tested?
The HUD Guidelines recommend testing all types of painted, stained, shellacked, and
varnished surfaces. (Your state may require testing all painted surfaces or just some.)
Anything painted is a painted surface. Any painted, stained, shellacked, or varnished
surface may contain lead. Painted, stained, shellacked, or varnished surfaces are found
both inside and outside the home. They include, but are not limited to,
ceilings
doors
floors
molding
radiators
cabinets
shelves
staircases
walls
windows
porches
baseboards
siding and trim
gutters
roofs
sheds
interior trim
and more
4-8
-------
Identifying Lead-based Paint Hazards
What a lead inspector does
Lead inspectors must have special training and certification. To start an inspection, the
lead inspector will find out when the home was built and get or make a sketch of the
home. The inspector will number the rooms to be tested and label the sides of the house
starting with the street or address side as "A." The windows and doors can be numbered
and labeled according to the side of the house on which it is located (e.g., CI, C2). (See
Figure 4-1.) Inspectors will test any surface that is painted or varnished to find out if any
lead is on that surface and how much lead is present.
The inspector records the following information about each sample:
• what room the sample or reading was taken in;
• which part of the room the sample or reading was taken from (i.e., left window apron);
• where on the painted surface the reading or sample was taken (i.e., upper middle
sash or lower left door frame).
An inspector or risk assessor also does clearance inspections at the end of an abatement
project or some federally-assisted rehabilitation/renovation projects. For these clearance
inspections, the inspector will take dust and soil samples (optional) to find out if the
cleanup was done carefully. The inspector will identify each type of sample (i.e., dust
wipes, soil samples) on specific data forms. XRF readings are also listed on specific data
forms.
Lead inspectors
must have
special training.
t
NORTH
Kitchen
Dining
B-l 1|
B-l
11 Dan
11 (3)
Bath /
/
D SIDE
B SIDE
B-2 I Stair Hall
Living Room
Bedroom
B-l— (2) (1)
II
/
Exterior Porch
ASIDE
Figure 4-1. Example inspector's sketch of a home.
4-9
-------
Lead Abatement for Workers
Risk
assessments
look at:
• lead hazards;
• who lives in
the home;
• how to control
hazards.
Lead dust is a
health hazard.
Friction and
impact cause
lead dust.
Risk assessment
An inspection tells you where the lead-based paint is in a home. A risk assessment tells
you if the lead-based paint could be a health hazard to the people who live in the home.
A risk assessment looks at
• lead-based paint hazards;
• the people who live in the home;
• how these hazards can be controlled.
The person who does a risk assessment is called a risk assessor. A risk assessor has to get
special training and certification.
Lead hazards
The risk assessor first looks at the places where lead-based paint is in the home. This is
the information that the inspector collected. If no inspection has been done, the risk
assessor looks at the condition of the home and of the paint. Then the risk assessor
figures out which surfaces might be creating lead hazards.
Any exposure to lead from contaminated dust, soil, or paint that could make you ill is a
lead-based paint hazard. Lead is a hazard when you breathe or swallow it. Dust from
lead-based paint is a major hazard. Risk assessors look for sources of lead dust in the
home, such as
Deteriorating lead-based paint—Painted surfaces deteriorate for a number of
reasons. The primary reason is moisture. Rain, leaks, condensation, and spills can
cause paint to break down. Sun, heat, cold, and wind can wear down paint on
exterior surfaces. Paint will also deteriorate if it is not put on properly. Putting paint
on glossy or greasy surfaces or on rotting or termite-damaged wood is not proper
application. Sometimes the new layer of paint is incompatible with the old paint
layer. This can also cause deterioration.
Friction surfaces—Paint dust also forms any place where a painted surface rubs
against another surface. When two surfaces rub against each other, the movement
causes friction. Friction causes paint to flake, chip, and form dust. Lead-painted
windows are the places where friction most often causes lead dust. Whenever a
window goes up or down, it causes friction.
Impact surfaces—Paint can be weakened by impact or forceful contact. This
happens when doors and windows close. Doors and windows have many impact
points where paint can flake and chip.
Lead dust buildup—Lead dust is made of tiny lead particles. Lead particles are
heavy and they stick to surfaces. They land close to the surface they came from.
When a lead-painted wall is flaking and peeling, the lead dust particles fall close to
the wall. Lead dust tends to build up in spaces close to friction surfaces, such as
window troughs.
Deteriorating
lead-based paint
causes lead
dust.
4-10
-------
Identifying Lead-based Paint Hazards
Lead dust can also build up in areas that are not cleaned properly. Lead dust gathers
in cracks. It builds up behind cabinets, between floor boards, and behind
baseboards. The dust may come out of the cracks over time due to air movement,
impact, pressure, or even a child picking at the floor.
People who live in houses with lead-based paint
Besides looking at possible lead-based paint hazards, the risk assessor looks at the people
who live in the home. These are the people who
may get lead poisoning. If there is a lot of lead
dust, the risk increases that someone will get
lead poisoning.
Children and pregnant women are at highest
risk for lead poisoning. A home with
deteriorating lead-based paint where a young
child and a pregnant woman live would be a
very high-risk home.
Lead hazard controls
After the risk assessor has identified the lead-
based paint hazards, he or she will put together a
plan to control the lead-based paint hazards.
Then a contractor and his or her workers
implement the hazard control plan.
Children and
pregnant women
are at highest risk
for lead
poisoning.
4-11
-------
Lead Abatement for Workers
Tests for lead in paint, dust, and soil
An inspector can use a number of methods to test for lead in different sources such as
paint, dust, or soil. Each test has advantages and disadvantages. The results are all
measured differently. We'll take a look at the following tests in this chapter:
• paint chip lab analysis
• X-ray fluorescence (XRF) analysis
• dust wipe test
• anodic stripping voltametry
• wet chemical field tests
soil sampling
-------
Identifying Lead-based Paint Hazards
Samples must be
clearly labeled.
Paint chip lab analysis
The inspector takes paint samples from painted surfaces and sends them to a lab for lead
tests. The test, called paint chip lab analysis, shows how much lead is in the paint. The
inspector should wear safety goggles or glasses and gloves when taking samples. Gloves
must be changed after each sample is collected.
Advantages
Paint chip analysis can be very accurate when the inspector correctly collects the sample.
The paint chip sample must include all the paint layers of the tested surface but no
wood, plaster, or other material underneath the paint. (This is not always easy to do.)
Disadvantages
Paint chip analysis costs $5 to $20 per sample. It takes two days to two weeks to get the
results, sometimes longer. To get a sample, the inspector has to disturb the painted
surface. Patches of paint in the area scraped (for the sample) may get left behind. The
inspector or owner will have the added expense of repairing and repainting the surface.
Results
Paint chip analysis most often measures the amount of lead in the paint by weight. The
weight of lead in the sample is compared to the weight of the entire sample. The lead in
the sample is reported as a percentage by weight. If the sample is 0.5 percent lead or
higher, HUD says that the surface tested should be considered a lead-based paint
surface. Lead in paint chips can also be measured in milligrams per square centimeter
(mg/cm2), but only if the exact area of the paint chip is measured. The 1995 HUD
Guidelines recommend getting paint-chip results reported in mg/cm2 if at all possible.
Paint chip
samples must
include all paint
layers.
Sometimes paint
chip lab analysis
is used to back
up XRF tests.
4-13
-------
Lead Abatement for Workers
XRFs can be
used on site.
X-ray fluorescence (XRF) analysis
The inspector can also use a machine called an X-ray fluorescence analyzer, or XRF. An
XRF works similar to an X-ray machine at the doctor's office, but the process is
different. Radioactive waves are used to find the lead in paint. But, instead of taking a
picture, the XRF tells us how much lead is in the paint. This test is called XRF analysis.
XRF machines must be used very carefully because they produce radiation. Inspec
need special training to prevent radiation exposure.
Advantages
The XRF machine is portable and can be used on site. For most painted surfaces, it can
determine whether or not lead-based paint is present. Usually, it does not damage the
painted surface as paint chip sampling does.
Disadvantages
XRFs cost from $8,000 to $20,000. XRF inspectors must have radiation safety training.
They also need special training to operate the machine. After this training, they must get
a permit to use an XRF machine. Permits, training, and replacement parts can also be
expensive—about $3,000 to 4,000 per year.
Many things can interfere with XRF readings and result in inaccurate results. Brick, metal,
and other building materials that the lead-based paint is on can affect the XRF readings.
Temperature, humidity, radio waves, and vibration can also cause false readings. Some
surfaces—like corners and narrow edges—cannot be measured by an XRF.
Results
XRF readings tell how much lead is in the tested surface area. Results are reported in
milligrams (mg) per square centimeter (cm2). A milligram is one-thousandth of a gram.
A square centimeter is about the size of your thumbnail.
In single-family housing XRF readings will be taken of each painted or stained surface
type (e.g., baseboard, floor, door) present in each room. In multifamily housing (large
developments with a lot of apartments or units) an inspector doesn't have to inspect
every unit. The number of units that must be inspected depends upon the year the
housing was build and how many total units or apartments there are in the
development. If the XRF readings are equal to or greater than 1.0 mg/cm2, those surfaces
are coated with lead-based paint. Some states or localities have rules or regulations that
set a lower (or higher) level of lead in paint for it to be called lead-based paint. If a state
or local rule or regulation sets a different level of lead in paint, the more stringent (i.e.,
lower) regulation should be used. Check your state, tribal, and local laws.
4-14
-------
Identifying Lead-based Paint Hazards
Laboratory testing method
Sometimes, an inspector will take a paint chip test sample from the same surface area to
confirm the XRF readings. The paint chip lab results will be compared with the XRF
results. Paint chip analysis performed by an accredited laboratory is more accurate than
XRF testing.
-------
Lead Abatement for Workers
Dust wipe tests
tell you if there is
lead dust.
Dust wipe test
Dust wipe tests measure lead dust on surfaces.
High levels of surface lead dust are an immediate
danger. Dust tests do not determine the presence
of lead-based paint that is several layers down.
They show whether there is lead in the dust.
The inspector or risk assessor collects dust from
surfaces with commercial wipes. Inspectors must
wear disposable gloves when collecting samples. Most dust wipes are taken during a
clearance inspection or a risk assessment (see page 4-20). Inspectors can take single dust
wipe samples from one surface and have it analyzed, or they can wipe several of the same
surfaces (e.g., floors) and have them analyzed together. The latter is called composite
sampling. When doing composite sampling, inspectors do not have to change gloves
between dust wipes until they are going to wipe a different surface (e.g., the inspector
takes dust wipe samples from several floors in a dwelling and then changes gloves and
takes several dust wipe samples from window sills). The dust wipe samples are sent to an
accredited laboratory to find out how much lead dust each sample contains.
Advantages
The dust wipe test is easy to do and costs about $5 to $20 per test. The results tell you
whether lead is in the dust. It gives you a good indication if there is a lead dust hazard
on the surface wiped.
Disadvantages
The dust wipe test cannot tell you exactly how much lead is in the paint. It cannot tell
you which surfaces will need to be abated. It can tell you only if lead dust is present and
give you an idea of how much. Lead dust may be coming from sources other than lead-
based paint.
Results
Results are measured in micrograms of lead per square foot (pg/ft2). A microgram is one-
millionth of a gram.
Dust wipe tests are taken at two times. First, they are used to test homes to see if dust-
lead hazards exist. These dust tests are crucial in preventing lead poisoning.
Some homes cannot be abated right away. While the family waits, they can do things to
reduce the amount of lead dust. These actions are called "interim controls." When lead
dust is reduced, the source of lead poisoning is reduced. (For more information on interim
controls, see Chapter 5.) Dust wipe tests can show if interim controls are helping.
4-16
-------
Identifying Lead-based Paint Hazards
Second, dust wipe tests are used at the end of an abatement project or some federally-
assisted rehabilitation/renovation projects. The dust samples show whether the cleanup
of these jobs was done well enough. They tell you if the house is ready for the occupants
to return.
EPA has established levels of lead in dust that should be considered a hazard. These
levels only apply to dust wipe samples collected on floors and window sills. The average
of the dust test results for each type of surface must be below the levels presented in
Chapter 3. If the dust levels are equal to or higher than this, there is a dust-level hazard.
For clearance, all samples must be below the clearance standards. If any sample is equal
to or higher than the clearance standards, then the type of surface represented by that
sample must be recleaned. For example, if a window sill sample fails clearance, the
workers only have to reclean the sills.
The Baltimore City Department of Health used a wipe sampling to do a study of 20
houses that were abated of lead-based paint. The average results are below.
During the abatement, work practices were carefully monitored. The use of heat guns
and dry scraping was not allowed. After abatement, wet cleaning and HEPA vacuums
were used to thoroughly clean the houses.
I IIU
house
Ii. PUNT j
trjiJL
DUST LEVELS BEFORE AND AFTER ABATEMENT
Surface
Before
Abatement
After
Chemical
Stripping*
After Replacement,
Encapsulation,
and Enclosures*
Floors
1,300 pg/ft2
59 pg/ft2
44 pg/ft2
Window sills
7,634 pg/ft2
125 pg/ft2
17 pg/ft2
Window troughs
59,202 pg/ft2
252 pg/ft2
49 pg/ft2
* The clearance dust levels for floors, sills, and troughs were higher when this study was
conducted than the levels in effect today.
4-17
-------
Lead Abatement for Workers
Anodic stripping voltametry
Anodic stripping voltametry (ASV) is another analytical method for identifying small
amounts of metals within paint chip, soil, dust, or water samples. The ASV equipment
is small and portable so that analysis can be at the job site. Depending on where the job
site is located, ASV may provide quicker results from sample analysis than if the samples
had to be sent off to a laboratory.
Advantages
The ASV allows samples to be analyzed at the job site. It is relatively easy to use and
provides a quicker turnaround time for results than laboratory analysis.
Disadvantages
ASV requires training in chemical handling. The per sample price is about the same as
for a fixed-site laboratory analysis. The equipment requires a source of electricity. Firms
using the equipment need to be accredited as a laboratory.
ASV allows
sample analysis
at the job site.
4-18
-------
Identifying Lead-based Paint Hazards
Wet chemical field tests
Some inspectors use wet chemical field
tests (spot tests) to find out if paint
contains lead. The sodium sulfide test
and the sodium rhodizonate test are two
examples. EPA, CPSC (the agency that
established the legal limit of lead in
paint), and HUD currently do not
recommend chemical field tests, because
research has not proven their effectiveness.
Top layer of paint
Next layer of paint
Third layer of paint
underneath
The chemical test solutions are clear (sodium sulfide) or yellow (sodium rhodizonate)
liquids. To do the test, the inspector scrapes the painted surface down to the wall surface
or substrate. All the layers of paint must be exposed. Then the inspector puts a drop of
test solution on the painted surface.
Results
If lead is in the paint, sodium sulfide turns gray, brown, or even black. Sodium
rhodizonate turns pink or red when lead is present.
Advantages
This is a quick, easy test to do. It is done on site. It is inexpensive.
Disadvantages
Sodium sulfide works well only with white paint. Colored paints are hard to read.
The changes in color can be missed.
Other metals can cause the same color change that lead does.
These tests do not tell how much lead is in the paint.
These tests only test exposed layers of paint. These tests will not tell you if coats of
paint that are not exposed have lead in them.
Sometimes these tests say lead is present when it is not.
Dirt or plaster can hide a color change.
EPA, CPSC, and HUD currently do not recommend chemical field tests, because
research has not proven their effectiveness.
Wet chemical
field tests may
not be reliable.
4-19
-------
I )
Lead Abatement for Workers
Soil can contain
hazardous
amounts of lead.
Lead soil levels
are sometimes
highest close to
the house and
the street.
Soil sampling
Soil can have high levels of lead. You usually find the highest levels of lead in soil close to
the surface (top 2.5 cm or 1 inch). Lead in soil can be a major hazard. Children play
outside in the soil. They can get lead-containing dust or dirt on their hands, clothes, and
toys. Children can get lead poisoned by playing in soil that contains lead.
Soil sampling and analysis tells how much lead is in the soil. Soil samples are most often
collected as part of a lead risk assessment. The risk assessor doing the test needs special
training. He or she will dig into the soil with a special tool called a coring tool. The
coring tool takes samples from the top 1/2 inch of soil. An inspector may also use a
disposable syringe, spoon, or other tool to scoop up the soil. Soil on all sides of the
building should be tested. Play areas with bare soil will also be sampled.
The test results compare the amount of lead to the amount of soil in the sample. Results
are reported in parts per million, or ppm. High levels of lead are usually found close to a
house with lead-based paint on the exterior. High levels of lead are often found in the soil
close to the street. Lead in the soil close to the street often comes from leaded gasoline.
EPA has established hazardous levels of lead in soil. A soil-lead hazard is present if the
level of lead in bare residential soil is at or above 400 parts per million in a play area or
an average of 1,200 ppm or higher lead in other bare areas of a yard.
Neither EPA nor HUD require soil sampling after abatement or rehab work. However,
inspectors may test for lead in soil when lead-related work was done on the outside of a
house or building or if lead-painted debris was stored on the property. These tests may
be part of a clearance inspection.
Lead close to
the house
4-20
-------
Identifying Lead-based Paint Hazards
Key facts for Chapter 4
A lead-based paint hazard is any exposure to lead from contaminated dust,
soil, or paint that makes you sick.
Lead dust is a hazard when you breathe or swallow it.
Any painted surface can have lead-based paint.
HUD Guidelines recommend testing all painted surfaces.
Test paint or assume it has lead.
Inspections show which paint has lead.
Lead-based paint inspectors must have special training and certification.
Risk assessments look at whether a home contains lead hazards.
Lead risk assessors must have special training and certification.
Lead-based paint dust is a health hazard.
Sources of lead-based paint dust include
• deteriorating lead-based paint
• friction on a lead-based painted surface
• impact on a lead-based painted surface
• places where lead dust builds up
Children and pregnant women are at highest risk for lead poisoning.
Testing for lead in paint and lead hazards
XRFs are used on site.
Paint chip analysis is used on its own and to back up XRF tests.
Paint chip samples must include all paint layers.
Dust wipe tests tell you where there are lead dust hazards.
Dust wipe tests are also done after every abatement job as the final clearance test
for the job. The test results show if the post-abatement cleanup was adequate.
Soil tests tell you how much lead is in the soil and if soil-lead hazards exist.
Soil may also be tested for lead after lead work is done on the outside of a
home or building.
4-21
-------
Lead Abatement for Workers
For more information
These publications have more information on the topics covered in this chapter. Your
instructor has a copy of the publications marked with a star (*). You can order your own
copy by calling 1-800-424-LEAD.
Alliance to End Childhood Lead Poisoning, Guide to State Lead Screening Laws
(October 1991) -
Alliance to End Childhood Lead Poisoning, Resource Guide for Financing Lead-Based
Paint Cleanup (October 1991) -
Environmental Defense Fund, At a Crossroads: State and Local Lead Poisoning Prevention
Programs in Transition.
* EPA, Lead: Identification of Dangerous Levels of Lead; Final Rule-, 40 CFR Part 745
(January 2001)
* EPA, Reducing Lead Hazards When Remodeling Your Home (September 1997).
* EPA, HUD, and CPSC, Protect Your Family From Lead in Your Home (June 2003).
* HUD, Guidelines for the Evaluation and Control ofLead-Based Paint Hazards in
Housing (June 1995).
* National Lead Information Center, Testing Your Home for Lead, Fact Sheet (1993).
National Lead Information Center Hotline: 1-800-424-LEAD.
-------
CHAPTER 5
Controlling Lead-based Paint Hazards
Learning objectives 5-3
Skit: What do you need to know about lead? 5-4
Discussion questions 5-4
Reducing lead-based paint hazards 5-5
When does lead-based paint become a hazard? 5-5
Where is lead-based paint found? 5-7
Who will reduce the lead hazards? 5-8
How will lead hazards be reduced? 5-9
Title X's two-step plan for reducing lead hazards 5-10
Abatement 5-11
Interim controls 5-12
Education programs 5-12
Special cleaning methods 5-12
Repairs, repainting, and maintenance 5-13
An interim control plan for a house 5-14
In-place management 5-15
Holistic approach to lead-hazard control 5-16
Special cleaning methods 5-17
HEPA vacuum 5-18
How to use a HEPA vacuum 5-19
Wet cleaning 5-22
Key facts for Chapter 5 5-25
For more information 5-27
-------
Lead Abatement for Workers
-------
Controlling Lead-based Paint Hazards
Learning objectives
In this chapter you will learn about
• Title X
• six situations where lead is a hazard
• who will reduce lead hazards
• lead-paint abatement
• interim controls
• special cleaning
• how to use interim controls for a home
• operations and maintenance programs
• the parts of a HEPA vacuum
• how to use a HEPA vacuum
• how to use the four-step system
-------
Lead Abatement for Workers
Skit: What do you need to know about lead?
Sandy and Tim are maintenance workers at a local elementary school. The school was
built in I960 and needs repair. Since summer is coming and school will be out, Sandy
and Tim are told to take care of the lead-based paint in the building. The school district
can not afford complete abatement.
Sandy: I'm a little concerned about this lead-based paint. That's all you read about
in the papers.
Tim: Well, it should not be such a big problem. I hear the main thing to deal
with is the windows.
Sandy: I don't know. I wish I knew more about it.
Tim: Don't make such a big deal. Look, we'll scrape the peeling paint, vacuum
everywhere and then paint over it. That should take care of it.
Sandy: I'm not sure.
Discussion questions
1. Do Sandy and Tim seem to know enough about lead-based
paint to take on the job?
2. What should Sandy and Tim do before they begin any work?
3. What surfaces should be a high priority for Sandy and Tim?
4. What type of interim controls can they use on these surfaces?
5. What items are essential to a good Operations and
Maintenance program?
f 'N
What do
you think?
-------
Controlling Lead-based Paint Hazards
Reducing lead-based paint hazards
Children most often get poisoned by lead because they swallow lead dust. In the early
1990s the Congress of the United States found that
• more than 3 million children were estimated to be affected by low-level lead exposure;
• the most common cause of lead poisoning in children is swallowing lead in
household dust;
• there were more than 3 million tons of lead in lead-based paint in the total number
of houses built before 1980.
In October 1992, Congress passed a law called the Housing and Community
Development Act. This Act includes Title X of the Residential Lead Based Paint Hazard
Reduction Act of 1992 (Public Law 102-550). The purpose of this act is to reduce lead-
based paint hazards.
Since the passage of Title X, EPA, HUD, and OSHA, have implemented several
regulations aimed at reducing worker's and the public's exposure to lead-based paint
hazards. The number of homes with lead-based paint and lead-based paint hazards has
been reduced. Additionally, CDC estimates the number of children with too much lead
in their blood has also been reduced (from more than three million to just over
400,000). While these reductions are impressive, there is still a lot of work to be done to
reduce lead-based paint hazards in housing and lead poisoning of children and workers.
You play an important role in that effort!
When does lead-based paint become a hazard?
EPA has defined the conditions under which lead-based paint in a dwelling or child-
occupied facility becomes a hazard:
• lead-based paint on any friction surface that rubs against another surface and
creates a lead-dust hazard
A friction surface is any surface that rubs against another surface. Windows and
floors are friction surfaces.
• lead-based paint that is damaged or deteriorated on any impact surface
An impact surface is any surface that receives forceful contact over and over again.
Windows and doors have impact surfaces; floors and stairways are impact surfaces.
• any chewable lead-painted surface on which there is evidence of teeth marks
The child chews on the surface and swallows the lead particles. These surfaces are also
called accessible surfaces. An interior window sill is an example of a chewable surface.
As a lead
abatement
worker, you play
an important role
in reducing lead-
based paint
hazards in
housing.
5-5
-------
Lead Abatement for Workers
• damaged lead-based paint
All building materials get damaged and deteriorate. All building materials with lead-
based paint can create lead dust.
• dust-lead hazard
Dust anywhere in the home that is at or above the standards for floors and window
sills that have been established by EPA. There are two sets of dust standards—dust-
lead hazards and clearance lead-dust levels. The clearance levels must be met after
abatement or federally-assisted rehabilitation/renovation activities have been
performed (these levels were discussed in Chapters 3 and 4).
• soil-lead hazard
Lead-contaminated soil is bare soil with lead at or above the levels set by EPA (these
levels were discussed in Chapters 3 and 4).
A lead-based paint hazard is possible wherever lead dust can be created. When lead dust
is created, you can breathe or swallow it. It is a hazard to your health.
Your supervisor or employer is required to make sure the project is in compliance with
the applicable standards.
-------
Controlling Lead-based Paint Hazards
Where is lead-based paint found?
Lead-based paint may be found in buildings built before 1978. That includes our
homes, schools, community centers, libraries, hospitals, and other public and
commercial buildings built before 1978. Today, it can still be used on bridges and steel
structures. Lead-based paint is almost always found on bridges and steel structures
because it prevents corrosion. Any time there is bridge repair, lead dust is likely to be
created. Any time an older house is renovated there is a potential lead hazard. Any time
demolition is done on an older building, there is a potential lead hazard.
Lead-based paint
may be found in
any building built
before 1978.
5-7
-------
Lead Abatement for Workers
Many different
people will work
to reduce lead
hazards.
Who will reduce the lead hazards?
Reducing the lead-based paint hazards in the United States is a huge job. It will take
many years and a lot of resources. Many different people will work to help reduce the
lead hazards:
Certified small contractors will abate homes using trained certified workers.
Certified large contractors with trained certified workers will abate large building
complexes, facilities, and steel structures.
Community organizations and tenant associations will have members trained to
reduce lead hazards in the homes, playgrounds, and community facilities.
Public employees of schools, housing, and state and municipal agencies will be
trained to provide lead-safe facility maintenance and custodial care.
Homeowners who get training often work in their own homes.
Contractors, supervisors, and workers should also be licensed to conduct lead-
related jobs.
Trained renovation, rehabilitation, and maintenance workers using lead-safe
work practices.
5-8
-------
Controlling Lead-based Paint Hazards
How will lead hazards be reduced?
Title X gives a detailed plan to reduce lead hazards. Here are some of the important parts
of Title X's plan:
• EPA, OSHA, and HUD are working together and have developed standards,
regulations, and funding to reduce lead hazards.
• The federal government is educating the public about lead hazards.
• If a property seller or landlord knows about lead hazards on the property, he or she
must inform potential buyers or renters about them.
• Home buyers have the right to get a lead inspection or risk assessment of that home.
• There are state, tribal, and federal rules which require training and certification/
licensing for lead abatement contractors and workers.
• There are minimum work practices which must be followed when doing lead-based
paint abatement.
• There are specific work practices which are prohibited when working on lead-based
paint in housing or child-occupied facilities.
• Renovators and remodelers must give out a lead information pamphlet to
consumers before renovation or remodeling begins.
-------
Lead Abatement for Workers
Title X has a
two-step plan:
• evaluate for
lead hazards;
• reduce lead
hazards.
Title X's two-step plan for reducing lead hazards
• Evaluate the lead hazards.
Evaluating lead hazards will help answer very important questions:
• Which homes need to be taken care of first?
• Who in the home might get poisoned?
• What actions will reduce lead hazards?
The information gathered in the inspections and risk assessments (Chapter 4) will
help answer these questions.
• Reduce the lead hazards.
Once the lead hazards are identified they need to be reduced. Reducing lead hazards
means getting rid of the lead that is dangerous to an individual's health. Title X states
two ways of reducing lead hazards. They are called abatement and interim controls.
5-10
-------
Controlling Lead-based Paint Hazards
Abatement
Lead-based paint abatement is a set of actions that permanently eliminate lead-based
paint hazards. HUD has defined "permanent" as lasting at least 20 years. Some of these
actions are permanent as long as the protective material stays intact. These actions are
sometimes called abatement strategies. Abatement includes, but is not limited to:
• replacement
• removal
• enclosure
• encapsulation; and
• the removal or permanent covering of soil.
EPA's definition of abatement also includes all preparation, cleanup, disposal, and post-
abatement clearance testing activities associated with these measures.
Enclosure and encapsulation of lead-based paint are included as abatement methods.
However, enclosure and encapsulation do not remove the lead-based paint; they abate
the lead-based paint hazard by covering it.
Lead abatement must be done with special work practices, skill, and care. This training
provides you with the basic information you need to know for lead abatement. You will
read more about abatement actions in Chapters 7, 8, 9 and Appendix A of this manual.
-------
Lead Abatement for Workers
Interim controls
only remove the
lead hazard
temporarily.
Interim controls
keep the lead
dust levels down.
Community
members,
building
occupants, and
workers need to
know about lead
hazards.
You must use
special cleaning
methods.
Interim controls
Interim controls are actions that reduce the lead hazard temporarily. They are a temporary
solution. They can be very helpful. They keep the lead dust levels down and can prevent
lead poisoning. Areas where interim controls are being used need to be regularly inspected
to make sure the controls are still working. HUD has developed a schedule for monitoring
each interim control activity. Interim controls include the following:
• education programs
• special cleaning
• repairs, repainting, and maintenance.
Education programs
Anyone who uses interim
controls should have special
training. You create lead dust
when you use interim controls.
You will move lead dust
around. This creates a hazard.
You need to know how to work
safely with lead. This course is
an example of such training.
Other education programs
would be lead hazard awareness
training for building occupants
and workers who will not be
doing lead work. Both groups
need to be aware of lead hazards. They need to know where the lead-based paint surfaces
are and what is being done to control them.
Special cleaning methods
Special cleaning can be used by itself to control lead dust. Special cleaning must be used
with all abatement methods. Research shows that there are two cleaning methods that
work well to reduce lead dust:
• HEPA vacuuming
• washing with an all-purpose cleaner or a cleaner made just for lead cleanup
These cleaning methods work best when they are used together, one right after the
other. You will learn more about special cleaning methods later in this chapter.
LEAD
5-12
-------
Controlling Lead-based Paint Hazards
Repairs, repainting, and maintenance
The purpose of interim controls is to reduce the lead hazard until the hazard can be
abated. Repairing lead-painted surfaces and repainting them with a non-lead-based
paint combine to reduce lead dust until those surfaces can be abated. You must monitor
and maintain any surface that you repair or repaint. Many actions are included in the
repair and maintenance of lead-painted surfaces.
A small repair job at home
A heavy mirror was hung on the wall of your bathroom. The weight of the
mirror caused the hook and nail to pull out of the wall. The mirror fell onto
the sink. Fortunately, it did not break. The wall now has a hole as wide as a
penny and an inch deep where the nail use to be. The paint around the hole
is chipped.
This small and simple repair could include
• wet washing the paint dust and chips
• wet scraping the chipped paint
• repairing the hole with caulk or putty
• repainting the surface
• wrapping and disposing of debris
Monitor any
surface you
repair or repaint.
Make sure the
surface remains
in good
condition.
5-13
-------
Lead Abatement for Workers
An interim control plan for a house
Here is a set of actions that can be used as interim controls for a home. Combined, these
actions can reduce lead exposure. Make sure interim controls are allowed by state and
city laws before using them.
Before you begin, make sure you contain the area. Set up signs and barrier tape to keep
nonworkers out of the area. Wear appropriate protective gear until you are ready to repaint.
• Do a special cleaning.
Vacuum the whole house with a HEPA vacuum. Then use an all-purpose cleaner or
a cleaner made just for lead cleanup to wash the entire house. Pay special attention
to the areas that are not frequently cleaned (e.g., window troughs, above doors and
windows, etc.).
• Do small repairs to the windows to reduce lead dust.
Cut a piece of sheet metal or plastic the same size as the window trough. Back caulk
the piece and nail it in place. This repair will enclose the trough and create a
cleanable surface. It will reduce the lead dust the paint on the window creates and
make the window easier to clean later on.
• Wet scrape edges and loose paint.
Wet scrape the leading edge of the interior window sill. Wet scrape any other loose,
peeling paint.
• Wash the entire house with the cleaning solution again. Then HEPA vacuum the
entire house again.
• Have an inspector or risk assessor do clearance dust wipe tests.
• Repaint the wet-scraped surfaces with non-lead-based paint.
These actions will reduce the amount of lead dust in the home and make it a safer
environment for both children and adults. The home will still need to be monitored for
lead hazards on a regular basis. Step-by-step instructions for doing interim controls and
abatement in housing are located in Appendix A at the end of this manual.
Make sure the
interim controls
you use are legal
in your city and
state.
Look in Appendix
A for step-by-
step instructions
on interim
controls and
abatement in
housing.
5-14
-------
Controlling Lead-based Paint Hazards
In-place management
In-place management is necessary whenever you use interim controls. Keeping a lead-based
paint surface in good condition prevents damage and dust. Controlling lead dust and paint
chips during routine cleanup and maintenance activity also helps reduce lead hazards.
Custodians and maintenance personnel clean and repair schools, hospitals, and other
public and commercial buildings. Any facility that has lead-painted surfaces should have
an in-place management program.
A good in-place management program can help prevent lead poisoning. It can help make and
keep a building lead safe. A good program should include at a minimum the following:
• an education program for workers and building occupants to make them aware of
lead-based paint hazards, where the lead-painted surfaces are located, and what
actions are being taken to make the building lead-safe;
• safe work practices training for the custodians and maintenance workers;
• a written program for each building that identifies all sources of lead exposure;
• a lead program manager who is in charge of all activities related to lead and who
communicates with workers, outside contractors, and occupants regularly;
• ongoing monitoring and checking of the condition of lead-painted surfaces;
• records of all inspections, work activities, maintenance, ongoing monitoring, worker
medical exams, exposure monitoring, waste disposal, and other activities.
EPA and HUD have developed courses on how to reduce lead-based paint hazards
during maintenance and renovation or remodelling. These courses presents the steps
maintenance or renovation workers can take to minimize lead dust generation and soil
contamination during activities which affect lead-based painted surfaces.
Everyone in the building is involved in preventing lead hazards when an in-place
management program is working.
A good in-place
management
program can help
prevent lead
poisoning.
5-15
-------
Lead Abatement for Workers
Holistic approach to lead-hazard control
The goal of planning and doing lead-hazard control is to create a safe environment
at an affordable price.
Lead work should always be a part of a maintenance approach. Maintenance work
should always be done as part of lead in-place management or abatement work. Lead-
based paint work should never be done without looking at long-term maintenance
issues. Consider the following issues:
• It makes no sense to replace windows if the replacement does not benefit energy
conservation. Energy-efficient replacement windows will increase the value and
efficiency of the building.
• Moisture problems can cause lead-based paint failure and may result in termite damage
or structural problems. Repair all sources of moisture before or during abatement.
• Carpets can store lead dust as well as bacteria and mold that cause respiratory
disease. Bacteria, mold, and lead dust are almost impossible to clean out of carpets.
Whenever possible, carpets should be removed and replaced. If that is not possible,
the best cleaning methods include steam cleaning (with beater bar attachment) off-
site or dry cleaning area rugs.
-------
Controlling Lead-based Paint Hazards
Special cleaning methods
Special cleaning can be used by itself to control lead dust. Special cleaning must be used
with all abatement methods.
Research shows that HEPA vacuuming and washing with an all-purpose cleaner or a
cleaner made just for lead cleanup are the methods that work well to reduce lead dust.
They work best when used together, one right after the other:
• HEPA vacuum all surfaces.
• Wash all surfaces with an all-purpose cleaner or a cleaner made just for lead cleanup.
• HEPA vacuum all surfaces again.
For best results:
1 .HEPA vacuum;
2. Wet wash;
3. HEPA vacuum
again.
5-17
-------
HEPA vacuum
Lead Abatement for Workers
Always use a HEPA vacuum on a lead job. A HEPA vacuum is an industrial strength
vacuum cleaner with a HEPA filter. HEPA stands for "High Efficiency Particulate Air."
HEPA filters can catch lead dust. A regular shop vacuum will not filter out the lead
dust. A shop vacuum just blows the lead back out into the room.
Mr. B. and his wife stripped all the lead-based paint from their home in New
York. The family lived in two rooms of the house while work was done on
the rest of the home.
Mr. B. wanted to protect his infant daughter, Mary, from lead. He vacuumed
the entire house every day. He used a regular vacuum. The regular vacuum
blew the lead dust back into the area where his family was living every time
he vacuumed. As a result, Mary's blood lead level went up to 37 (ig/dL. She
had to receive chelation therapy. Two years later her blood lead level returned
to normal.
Blakelee, S. "Lead-Calcium Time Bomb." American Health. November 1990.
Always use a
HEPA vacuum on
lead jobs.
True story:
What can happen if you don't use a HEPA-vacuum
5-18
-------
Controlling Lead-based Paint Hazards
How to use a HEPA vacuum
1. Lightly mist area with water to keep dust levels down.
Some HEPA vacuums can combine a wet wash with the vacuum. Read the
manufacturer's instructions on how to use it.
2. Move slowly.
Remember, lead dust sticks to surfaces. Vacuum slowly so the HEPA vacuum can
pick up all the lead dust.
How a HEPA vacuum works
Most HEPA vacuums have three filters: a pre-filter, a secondary filter, and a
HEPA filter.
1. Debris gets sucked in through the hose into the vacuum bag.
2. The air and dust get filtered through the pre-filter, the secondary filter, and
the HEPA filter.
3. The HEPA filter captures the lead dust before the air is released into the work
area again.
HEPA filter
secondary filter
vacuum bag
Most HEPA
vacuums have
three filters.
5-19
-------
3.
Lead Abatement for Workers
HEPA vacuum all surfaces.
Start at the end farthest from the main entrance/exit. As you vacuum, move towards
the main exit and finish there.
HEPA vacuum
every surface.
Begin at the top of each room and work down. For example, start with the top
shelves, the top of the woodwork, and so on, and work down to the floor. Do every
inch of the windows, especially the window troughs.
5-20
-------
Controlling Lead-based Paint Hazards
4. Use special attachments.
Use the rubber cone where the floor meets the baseboard and along all the cracks in
the floor boards. Use the brush tool for walls and woodwork. Use the wheeled floor
nozzle for bare floors and the carpet beater for rugs.
rubber cone
powered
carpet beater
wheeled
floor nozzle
5. Maintain the HEPA vacuum.
Every now and then, you should check the HEPA vacuum for
• damaged wires
• worn gaskets and switches
• torn vacuum bag
• damaged and clogged filters
Whenever you repair the HEPA vacuum, wear protective clothing and your
respirator. Repair and replace parts for HEPA vacuums in a contained work area.
Replace parts as needed. Check the pre-filter often for dust and debris. Change the
pre-filter when appropriate. This keeps the HEPA vacuum working properly. Use
parts and filters that are the same make as the originals. Never use shop vacuum
parts on a HEPA vacuum.
Wear protective clothing and your respirator. When checking the HEPA vacuum,
clean it off using a second HEPA vacuum. Remember to clean up the area when you
are done.
Wear protective
clothing and a
respirator when
you repair or
clean the HEPA
vacuum.
5-21
-------
Lead Abatement for Workers
Wet cleaning
Some cleaners
can burn your
skin and eyes!
Wear eye
protection.
Recent studies have shown that cleaning with an all-purpose cleaner or a cleaner made just
for lead cleanup is very effective in removing lead dust from contaminated surfaces.
Washing with these cleaners helps get dust particles out of cracks and crevices. Remember
to rinse surfaces well after washing them with any cleaner if the directions tell you to.
Some detergents contain trisodium phosphate (TSP). Cleaners such as TSP should not
be used on certain surfaces, such as finished furniture. Use a tack cloth (a soft, lintless
cloth that has a sticky feel to it) on such surfaces.
Phosphates such as TSP are harmful to the environment. A number of other lead cleaners
may be used instead of TSP. Some states and local governments do not allow the use of
TSP. Be sure to check your state and local laws.
1. Use an all-purpose cleaner or a cleaner made just for lead cleanup.
You can buy all-purpose cleaners in most hardware or janitor supply stores. Cleaners
made just for lead cleanup will likely come from a safety or abatement supply
warehouse.
2. Wear gloves and eye protection, if appropriate.
Some cleaning products are skin and eye irritants.
Always wear gloves and protective eye gear when you use
them. Refer to the MSDS for appropriate personal
protective equipment. A portable eye wash should also
be on site.
3. Mix the cleaner with water.
Follow directions on the package to make the solution.
Do not use it at concentrations stronger than the
instructions say.
4. Wash the area in the same order you HEPA vacuumed it.
Wipe from the far end of the area to the entrance and from the top of each room to
the floor. Wash and rinse each room one at a time.
5. Use the "four-step system."
When you wipe down surfaces with the cleaner, you will need three containers: one to
hold the wash, one to squeeze the rag or mophead into, and one with clean rinse water.
There are four steps in washing with a cleaning solution. (See next page.) Go
through these steps for each room in the work area. Wash and rinse each room one
at a time. Rinse carefully and thoroughly. Some cleaners leave behind a film. If you
do not rinse it off once it dries, the cleaner can damage surfaces. It can also prevent
new paint from bonding to the surface.
5-22
-------
Controlling Lead-based Paint Hazards
The four-step system
Step 1: Spray or pour on the cleaning
solution.
Use a plastic jug or a garden sprayer to hold
the lead cleaner. Pour out the lead cleaner
onto the rag or mophead. This will help avoid
contaminating the cleaning solution.
Step 3: Squeeze out the dirty rag or
mophead.
Squeeze out the dirty rag or mophead into an
empty container.
Replace the wash rag or mophead whenever it
gets loaded with dust and debris.
Repeat Steps 1 through 3 until you finish
washing one room.
LEAD
CLEANER
Step 2: Wash surfaces with
cleaning solution.
Use rags for woodwork and a
string mop for floors.
Sometimes a sponge mop is
used for walls. Cloth rags may
be used for all surfaces.
Steps for
washing with
lead cleaner:
1. Spray or pour
on cleaning
solution;
2. Wash surfaces;
3. Squeeze out
rag or mop
into empty
container;
4. Rinse surfaces
with clean
water.
5-23
-------
Lead Abatement for Workers
Rinse with a
clean mophead
or rag and clean
water.
Rinse carefully
and thoroughly.
Step 4: Rinse the surfaces.
Fill a container with clean water. Use a
clean rag or mophead, and rinse all the
surfaces you washed.
Squeeze the rinse rag or mophead into
an empty container. Replace
it when you need to.
Repeat Step 4 until you finish rinsing
the room you washed. Replace rinse
water as often as necessary to keep it
clean. Repeat all four steps for each
room in the work area.
Check your state and local laws for
instructions on how to dispose of the
cleanup waste water, rags, mopheads,
and debris.
Remember to repeat the HEPA vacuum process.
5-24
-------
Controlling Lead-based Paint Hazards
Key facts for Chapter 5
Lead-based paint hazards
Lead-based paint-dust exposure is the major cause of childhood lead poisoning.
Lead dust can be found any place where lead-based paint is flaking or damaged.
Lead-based paint can be found in many buildings built before 1978.
Title X (Residential Lead-Based Paint Hazard Reduction Act)
U.S. Congress passed Title X in 1992 to reduce the hazard of lead-based paint.
Title X has a two-step plan for reducing lead hazards: evaluating and controlling
lead hazards.
Abatement means controlling the hazard.
Title X states that abatement means "removing lead-based paint hazards
permanently."
Anyone doing lead abatement must be trained and certified.
Interim controls reduce lead-based paint hazards temporarily.
Interim controls keep lead dust levels down and may prevent poisoning.
Careful cleaning is important in abatement and interim controls.
A good in-place management program can help prevent lead poisoning.
Monitor any area that you repair to make sure it stays in good condition.
Make sure the interim controls you use are legal in your area.
Anyone using interim controls should be trained and certified.
Community members, building occupants, and workers need to know about
lead hazards in the building.
They need to know what is being done to make a building lead-safe.
Special cleaning requires HEPA vacuuming and washing with an all-purpose
cleaner or a cleaner made just for lead cleanup.
1. HEPA vacuum all surfaces in the work area.
2. Wash all surfaces with cleaning solution.
3. HEPA vacuum all surfaces again.
-------
Lead Abatement for Workers
Use a HEPA vacuum on lead jobs.
HEPA vacuum all surfaces from top to bottom.
Wear protective clothing and a respirator whenever you use, repair, or clean the
HEPA vacuum.
Special cleaning methods must be used when abating lead.
Special cleaning removes lead dust.
Special cleaning is one of the most important jobs in abatement.
Use a cleaner on all surfaces.
Use an all-purpose cleaner or a cleaner made just for lead to wash surfaces.
Check what your state and local laws require.
Some cleaners can burn your skin and eyes, so wear gloves and eye protection
when you use it and have an eye wash nearby.
Use three containers: (1) cleaner; (2) empty; (3) rinse water.
Use four-step system:
1. Pour or spray the cleaner from a jug or garden sprayer onto the rag or
mophead.
2. Wash all the surfaces in a room with lead cleaner. Move from top to bottom,
starting from the point farthest from the exit.
3. Squeeze out the dirty rag or mophead into empty bucket.
4. Rinse all surfaces very carefully. Use clean water, rags, and mopheads.
Wash and rinse each room—one at a time.
Check your state and local laws for instructions on how to dispose of the
cleanup waste water, rags, mopheads, and debris.
Special cleaning methods can be used as an interim control.
-------
Controlling Lead-based Paint Hazards
For more information
These publications have more information on the topics covered in this chapter. Your
instructor will have a copy of some of the publications. You can order your own copies
by calling 1-800-424-LEAD.
Residential Lead-Based Paint Hazard Reduction Act of1992 (Title X of the Housing and
Community Development Act of 1992).
EPA, Minimizing Lead-Based Paint Hazards During Renovation, Remodeling and
Repainting (September 2000).
EPA and HUD, Addressing Lead-Based-Paint Hazards During Renovation, Remodeling
and Rehabilitation in Federally Owned and Assisted Housing (February 2001).
EPA and HUD, Lead-Based Paint Maintenance Training Program (1997).
EPA, HUD, and CDC, Lead Paint Safety: A Field Guide for Painting, Home
Maintenance, and Renovation Work (June 1999).
EPA, HUD, and CPSC, Protect Your Family From Lead in Your Home (June 2003).
HUD, Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing
(July 1995).
NIBS, Lead-Based Paint Operations and Maintenance Work Practices Manual for Homes
and Buildings (May 1995).
Society for Occupational and Environmental Health, Protecting Workers and Their
Communities from Lead Hazards: A Guide for Protective Work Practices and Effective
Worker Training (1993).
-------
Lead Abatement for Workers
-------
CAUTION
LEAD
HAZARD
KEEP
OUT!
CHAPTER 6
Setup
Learning objectives 6-3
Skit: Starting a new job 6-4
Discussion questions 6-4
Working with lead 6-5
Rules for lead work 6-6
Setup 6-8
Setup check list 6-8
Entering the work area 6-13
Exiting the work area 6-13
Setup for outside work 6-19
Checklist for outside setup 6-19
Setup checklist for interim controls 6-21
Key facts for Chapter 6 6-22
For more information 6-23
-------
CAUTION
LEAD
HAZARD
KEEP
OUT!
Lead Abatement for Workers
6-2
-------
CAUTION
Setup
LEAD
HAZARD
KEEP
OUT!
Learning objectives
In this chapter you will learn
• how to keep lead out of the air
• how to protect yourself from lead while you work
• how to clean the work room
• how to set up the work room
• how to set up a decontamination area
• how to use the decontamination area
6-3
-------
CAUTION
LEAD
HAZARD
KEEP
OUT!
Lead Abatement for Workers
Skit: Starting a new job
Juan and Ed are getting ready to start on an abatement job in one of the houses in their
neighborhood.
Juan: We need to replace this window here. Let's get into our suits and masks and
start laying out the poly.
Ed: I don't need a suit and respirator. It's too hot in here.
Juan: But there's lead-based paint in this room. You need to protect yourself from
the dust.
Ed: All the lead-based paint is on the woodwork. We're not going to disturb it.
A respirator and a suit are just going to slow me down in this heat.
Juan: I know it's really hot in here, but you need to protect yourself so you don't
get lead poisoned.
Ed: I don't want to get in trouble for working too slowly. This is the first work
I've had in three months. It's hot in here.
Discussion questions
1. Do you agree or disagree with the following? Why or why not?
Ed and Juan don't really need to wear a suit and respirator
if they are just setting up.
It's none of Juan's business if Ed doesn't want to wear a
suit and respirator.
The foreman should install a fan or provide PAPRs to help
keep the workers cool during setup.
It would be better for Ed to work without a respirator than
to risk losing his job.
If Ed explained things to the foreman, Ed wouldn't get in trouble with him.
2. Why is Ed in such a hurry?
3. What could Juan do to convince Ed to wear a respirator and suit?
4. What could the foreman do to make it easier for Ed to wear his respirator and suit?
What do
you think?
6-4
-------
Setup
Working with lead
All lead paint abatement methods create lead dust.
• Lead dust is poisonous if breathed or swallowed.
• Lead dust is made up of very small particles of lead.
• Lead dust is often too small to see.
• Lead dust is heavy. Most lead particles will fall to the floor within one hour.
• Lead dust usually falls within six feet from its source.
• Lead dust settles on whatever surface it lands on.
• You can get lead dust on your hands if you touch any surface that has lead dust.
Burning lead creates lead fumes.
• Lead fumes are very dangerous.
• Lead fumes contain many tiny lead particles.
• Lead fumes stay in the air a long time.
• Lead fumes are very easy to breathe.
• Lead fumes easily go through a dust mask.
CAUTION
LEAD
HAZARD
KEEP
OUT!
Lead dust is
poisonous when
you breathe or
swallow it.
Lead fumes are
very dangerous.
They are very
easy to breathe.
6-5
-------
CAUTION
LEAD
HAZARD
KEEP
OUT!
Lead Abatement for Workers
Rules for lead work
The following steps will keep lead from spreading outside of the work area. It will also
make final cleanup of the work area much easier.
1. Keep dust levels down
2. Contain the work area
3. Follow good hygiene practices
4. Use personal protective gear and clothing
5. Clean up
Each of these steps will be discussed in the remainder of this chapter. Some of these steps
will also be included in hands-on activities during this class.
1. Keep dust levels down
The purpose of lead abatement is to reduce a hazard. But, during the abatement you will
stir up and even create new lead dust. It is very important to keep lead dust levels
down. According to OSHAyour employer must use methods and tools which create the
least amount of lead dust. This program must be in writing and is called a compliance
program. As a worker, you can control lead dust levels by
avoiding methods that create a lot of dust and waste
using a HEPA vacuum
using wet methods
cleaning up as you work
never dry sweeping
2. Contain the work area
The OSHA Lead in Construction standard says that the work area must be separated
from the non-work area. HUD says the work area must be sealed off. The work area can
be contained with sheets of 6-mil polyethylene, called "poly."
Containing the work area
• protects non-lead-based painted
surfaces from lead dust
Contain the work
area with poly.
• keeps lead dust from spreading
outside the work area
• keeps everyone but workers away
from the lead
• makes cleanup easier
It is important to look for rips in the poly every day before you begin work. Repair any
rips with duct tape as soon as you see them.
6-6
-------
Setup
3. Use personal protective gear and clothing
Your supervisor or employer is required to tell you what equipment you need to use to
protect yourself from hazards on the job site. Sometimes you will have to wear a
respirator and protective clothing; sometimes you will need protective eye gear, too.
What protective gear you need to wear is determined by the job you are doing and the
air levels of lead to which you are exposed. Always take off your disposable coveralls and
booties whenever you leave the work area. Throw them away in the container labelled
"LEAD CONTAMINATED WASTE" at the end of each workday. Do not take lead
dust home on work clothes.
4. Wash up, shower, change
Wash you hands and face each time you
leave the work area. Lead dust will get on
you while you work. Washing up each
time you leave the work area prevents you
from getting lead dust in your mouth.
Washing prevents you from poisoning
yourself. Never eat, drink, smoke or put
on makeup in the work area.
Don't take lead dust home! When your
exposure to lead is above 50 |ig/m3, your
employer is required to provide showers
whenever feasible. When showers are
available, take a shower at the end of the work day. Do not wear contaminated work
clothes or shoes home.
5. Cleanup
Cleanup is very important. It prevents future exposures to lead. It protects you while you
work. It keeps harmful lead dust levels down. It prevents you from spreading lead dust
outside the work area. Good cleanup is required for the abatement job to pass the final
clearance inspection.
! WASH
L£AP
0ff*~
CAUTION
LEAD
HAZARD
KEEP
OUT!
Washing up
prevents you
from poisoning
yourself.
Do not wear
contaminated
work clothes or
shoes home.
6-7
-------
CAUTION
LEAD
HAZARD
KEEP
OUT!
Lead Abatement for Workers
Setup
A good setup is very important on an abatement job. There are many different parts of
the setup job. You have to turn off and seal off the ventilation system. You have to clean
and protect the room. You may have to bring in extension cords. A good setup makes
the rest of your job much easier. It also prevents many safety problems. The exact type of
setup that you do will depend on your job. Your supervisor or employer will tell you
what setup is needed for each job area.
It is important to think about how to set up without creating a bigger lead dust hazard.
Identify the contaminated areas. Identify where the shower or wash area will be set up
and how you will move in and out of the contaminated area. Before you do any work,
find out if and when you will need to put on a suit and respirator. Check your state
regulations for work area preparation.
Setup check list
Put up warning signs
Identify work site safety hazards
Clean and remove anything you can move
Shut off and seal off ventilation system
Provide airflow for workers
Do necessary repair work
Shut off and lock out electricity
Set up the decontamination area
Clean, cover, and seal everything left in the work area
Put up critical barriers
Mop and seal the floor
Bring in equipment and tools
Seal off the work site
Separate "dirty work" area from the rest of the work area
Set up locked storage space for waste
Secure the work site
6-8
-------
Setup
Put up warning signs
Only the people working on the lead-based paint abatement job should enter the job
site. People who live in homes where work is done should pack up their belongings and
stay somewhere else until the abatement job passes the final clearance inspection. Even
on jobs where interim controls are being used, occupants should
be out of the house during work.
The building owner needs to warn everyone in advance that lead
work will be done. Warning signs need to be put up at the exits
and entrances of the area to be abated. Many state and local
governments say you must post warning signs. Make sure you
check your state and local laws.
Some states say the contractor performing the abatement must put
up warning signs on the doors leading to the work area. They must say:
CAUTION
LEAD
HAZARD
WARNING
LEAD WORK AREA
POISON
NO SMOKING, EATING,
DRINKING
These signs prevent anyone from wandering onto the work site. The signs tell everyone
there is a lead hazard. The OSHA lead standard says these signs must be posted if you
are working above the PEL. Warning signs should be written in the language of the
occupants and the workers.
CAUTION
LEAD
HAZARD
KEEP
OUT!
Only the people
working on the
lead-based paint
abatement
should enter the
job site.
Warning signs let
everyone know
there is a lead
hazard.
6-9
-------
CAUTION
LEAD
HAZARD
KEEP
OUT!
Lead Abatement for Workers
Identify work site safety hazards
It is important to identify work site safety hazards before starting the job. You and your co-
workers need to map all the safety hazards on the job site. You will look for problems like
exposed electrical wires and switches
water damage
water leaks
collapsed or damaged ceilings, walls, floors, stairs
any other structural damage
You will need to put up warning signs that say "DANGER" until you repair the problems.
Clean and remove anything you can move
Clean and move anything you can out of the room. Large appliances such as stoves,
refrigerators, washers, and dryers may be left. But gas stoves and refrigerators must be
Identify safety
hazards and do
repair work
before you start
the abatement.
disconnected. You will move
• chairs • office supplies
• desks • machines
computers
bookcases
paintings
cooking pans
books
lamps
tables
and so on
Clean everything off with rags and an all-purpose cleaner or a cleaner made just for lead
cleanup. Immediately rinse off the cleaner with clear water. Read the manufacturer's
instructions and check for surfaces on which the cleaner should not be used. If you can't
use the cleaner because it may damage the surface of the item, use a tack cloth instead.
Put the used rags in 6-mil poly bags and label the bags "LEAD CONTAMINATED."
Dispose of them with other waste. The wash water must be stored in noncorrosive
containers. It may be hazardous waste. In some states it is illegal to pour wash water
down the drain.
All cloth items must be removed and cleaned. These include clothes, curtains, carpets,
and upholstered furniture. (This may not be part of the lead-based paint abatement job;
it may be the owner's or tenant's responsibility.) Removing carpet kicks up a lot of dust.
You might need to wear protective gear, including respirators and disposable suits.
Rugs and fabric on furniture should be cleaned. It is very difficult to clean cloth and
carpets. If they cannot be cleaned, they may need to be removed. Your supervisor or
employer should warn the owner about the things you cannot clean.
Do not throw anything away without the owner's permission.
6-10
-------
Setup
If the owner agrees to throw contaminated items away, wrap them in two layers of 6-mil
poly. Seal them up with duct tape. Label the items "LEAD-CONTAMINATED
WASTE." Dispose of them with other abatement waste. (See Chapter 8 on Cleanup
and Disposal.)
Shut off and seal off ventilation system
The ventilation air system carries air through the building. It can carry lead dust through
the building. Lead dust goes where air goes. The ventilation system for the work area
must be shut off at the electrical box. Lock the box and label it with a tag that says
CAUTION
LEAD
HAZARD
KEEP
OUT!
DANGER
DO NOT
OPERATE
The ventilation system is often called the HVAC system. HVAC stands for heating,
ventilating, and air conditioning. Cover and seal the air vents with poly and duct tape.
Since the heat is turned off, in cold weather it is necessary to bring in other heat sources.
Also be sure to protect water pipes and fixtures from freezing. If necessary, drain the
pipes and wrap the water entrance from the street with electrical tape.
Provide ventilation (airflow) for workers
There are times when extra ventilation is necessary. Your employer might use a negative
air machine to both ventilate the work area and clean the air. A negative air machine is
like an exhaust fan with a HEPA filter. When you use a negative air machine, there
must be an opening for fresh air to come in. This is called "make up air." The OSHA
lead standard says you must have extra ventilation if you are working above the PEL.
Do necessary repair work
Some of the structural problems you identified at the crew's pre-job meeting have to be
fixed. Collapsed stairways, ceilings, and floors can make the work area too dangerous to
start the job. You will have to fix these problems before you can start the abatement work.
Check for moisture damage. If you find any moisture damage, determine the source of
the moisture or water damage. Fix the source problem or inform the owner of the need
to have it fixed. Roof leaks, poor flashing, bad plumbing and other water leaks must be
repaired. Uncorrected water leaks will cause the abatement to fail. Walls must be allowed
to dry out. Moisture in a wall can cause abatement to fail.
6-11
-------
CAUTION
LEAD
HAZARD
KEEP
OUT!
Lead Abatement for Workers
Any damaged plaster will need repair if it is going to be abated. Otherwise, the method
will fail. Remember to contain the area before you do this repair work.
Moisture can
cause abatement
to fail.
Fix the problems
or tell the owner
of the need to
repair.
Shut off the
electricity and
lock the box.
Use Ground
Fault Circuit
Interrupters to
protect against
electric shock.
You also need to make sure the water system is working. You will need on-site running
water to wash up. You will need water for some abatement methods and for cleanup
procedures. If the water service is shut off, you will have to bring water to the site.
Shut off and lockout the electrical
system
Lead abatement jobs use water. This is an electrical
hazard. Water can leak into an electrical outlet and
kill you. For small residential jobs, you can cut off
the electricity at the fuse or breaker box for the
rooms that you are working on.
For large jobs, the electrical system should be shut
off at the electrical box. Lock the box and label it
with a tag that says
"DANGER—DO NOT OPERATE."
Turning off wall switches is not enough. Someone
who does not know about lead abatement work
could electrocute you by mistake.
Machines also have to be shut off. A machine with moving parts could hurt someone. It
has to be turned off and locked so that people can work safely around it.
Ventilation machines, safety lights, HEPA vacuums, and hand tools all need power.
Bring in extension cords for all the equipment. Extension cords are sometimes called
temporary wiring. Tape the cords onto the walls so that workers will not trip on them.
Do not hang cords with metal wire. This could
cause a shock.
Cords should be hooked up to sensitive switches.
These are called Ground Fault Circuit
Interrupters (GFCIs).
DO Nut
6-12
-------
Setup
Set up the decontamination area (decon)
You go into and out of the work area through a special area. It is called the
"decontamination unit" or "decon." This is where you decontaminate or get clean.
Your employer needs to set up a decon. Set up the decon in a clean area. The kind of
decon you use depends on the size of the job. Some contractors build their own decons.
Some use hard plastic decons. Others use decon trailers that go outside the building.
For a large-scale job, the decon may be separate rooms. These rooms should be lined
with two layers of poly (hung with duct tape) and have poly flaps between them. The
decon should be sealed to the work room. For small-scale work, like single unit
abatement or interim control, you may not need or be able to construct a full decon.
You employer is still required to provide an area to decontaminate, a wash area, and a
clean changing area that are separate from the work area.
The decon has three rooms. They have to be in this order (starting from the work room)
DIRTY AREA—WASH AREA—CLEAN AREA
1. Dirty area
The dirty area must have a container to put your dirty protective clothing and used respirator
filters in. This container has to have a lid that closes. The container should be labeled.
2. Wash area
The wash area must have an eye wash station, running warm water, clean towels, and soap.
When possible there should be a shower. Your employer must also provide on-site toilets.
3. Clean area
The clean area must have a clean place to store your street clothes and respirator. Your
street clothes should never be in contact with your dirty work clothes.
Entering the work area
Before you begin to work, you should change into your protective work clothes and shoe
covers in the clean area. Store your street clothes in the clean area. Inspect, put on, and
fit check your respirator. Put your hood over your respirator straps and secure with duct
tape. Walk through the wash area into the equipment or dirty room. Take whatever
equipment you need and go into the work area.
Exiting the work area
Every time you leave the work area, you must exit through the decon. Before stepping
into the decon, HEPA vacuum the protective suit that you are wearing. Remove your
booties and leave them in the work area. Then enter the dirty area of the decon. Take
off your protective clothing by rolling the inside out. At the end of the day, you need to
put your contaminated protective clothing in the labeled laundry container. Your
CAUTION
LEAD
HAZARD
KEEP
OUT!
Enter and exit
the work area
through the
decon.
Set up the decon
in a clean area.
The decon area
has a dirty room,
shower, and
clean change
room.
6-13
-------
CAUTION
LEAD
HAZARD
KEEP
OUT!
Everyone must
enter and exit
the work area
through the
decon.
Lead Abatement for Workers
employer must give you clean protective clothing either every day or once a week,
depending on the levels of lead in the air.
Move into the wash area. Wash your face with your respirator on. Remove your
respirator and wash your hands and face.
Clean your respirator. When you leave at the end of the day, you need to shower and wash
your hair as well as wash your hands and face. Don't take lead out of the work area on your
body. If showers are not available, shower and wash your hair as soon as you get home.
Move into the clean area with your clean respirator. Put on your clean clothes and
shoes. Never wear contaminated work clothes home or bring them home to wash. They
are contaminated with lead. If you take your work clothes home, you could expose
yourself and your family to lead.
WORKER ENTERS
DECON FROM
WORK AREA.
WORKER EXITS
DECON AFTER
WASHING AND
CHANGING.
On small jobs, the doorway to the work area may be covered with overlapped poly
"flap" doorways. These doorways separate the dirty area from the rest of the house or
building. (See Figure 1 on the next page for two examples of these door flaps.) Check
often to make sure the flaps are still stuck to the door frame.
6-14
-------
Setup
FIGURE 1. EXAMPLES OF DOOR FLAPS WHICH SEAL OFF THE WORK AREA
FROM THE REST OF THE DWELLING.
CAUTION
LEAD
HAZARD
KEEP
OUT!
6-15
-------
CAUTION
LEAD
HAZARD
KEEP
OUT!
Lead Abatement for Workers
Clean, cover, and seal everything left in the room
HEPA-vacuum and wipe off with a damp rag anything that you cannot remove (like a
refrigerator, oven, piano, etc.). Wet mop all surfaces. Wait until the surfaces dry. Then
cover and seal them with 6-mil poly and duct tape. This seal may not be broken until
the final inspection. Remember to duct tape the poly to the floor.
Clean and seal
everything left in
the work area.
Repair tears in
poly as you work!
Cover floors with
two layers of 6-
mil poly sheeting.
Put up critical barriers
Duct tape poly on air vents, heat ducts, windows, and any other openings. This helps
prevent lead dust from escaping the work area.
Mop and seal the floor
Wet-mop the floor, particularly where the floor meets each wall. Let it dry. Cover the floor
with 6-mil poly, taping it around the outside edges with duct tape. Staple the corners.
When the surfaces are dry, cover the first sheet of poly with a second sheet of poly where
demolition or removal will create high dust levels. Tack this layer down with small pieces
of duct tape so the second layer can be taken up without pulling up the first layer.
It's important to look for tears in the poly every day before you begin working. Repair
any rips as soon as you notice them.
Bring in equipment and tools
Be sure that all the tools you need are in the workroom before abatement begins. Make
sure you bring all the tools and cleaning equipment that you will need for abatement.
You should bring in cleaning equipment, negative air machines (if required), scaffolding,
and ladders before the decon area is built and before the area is sealed.
6-16
-------
Setup
Seal off the work site (from the rest of the building)
If you're only abating lead-based paint from one room or one part of a building and
another part of the building is occupied, seal off the work area from the rest of the
building. The barrier must prevent people from passing through accidentally. Examples of
this kind of barrier are a locked door or plywood nailed to a frame. The edges must be sealed
on all sides with duct tape to make them dust tight. This seal may not be broken until the
work is complete in this area, the area is cleaned, and the area passes final clearance.
Workers should enter and exit from the work area through a door. If this is not possible
(for example, the work area is more than three floors up), a full decon system must be
used between the work area and the rest of the occupied building.
Separate "dirty work" area from rest of work area
Demolition, chemical stripping, and any other work that will generate a lot of lead dust
or waste is called "dirty work." It is a good idea to separate "dirty work" area from the
rest of the work area. Doing so helps control the transfer of dust.
• Put up two layers of 6-mil poly over the dirty area exit (air lock)
• Seal off ventilation registers (vents)
• (If possible) do not remove debris through other areas
• Avoid tracking dust from the dirty area when you move to other parts of the work area.
CAUTION
LEAD
HAZARD
KEEP
OUT!
6-17
-------
CAUTION
LEAD
HAZARD
KEEP
OUT!
Lead Abatement for Workers
Set up a locked storage space for waste
Use a locked dumpster or an area that can be locked. The waste storage area must not be
accessible to children or animals. Put up a warning sign that says: "DANGER! LEAD
WASTE." If you use a rented dumpster, be sure the rental company knows you will be
storing lead waste in it. Lay out a path of poly to the storage space. Do not track lead
dust or chips from the work area to the storage area.
Store waste in a
locked storage
area.
Secure the work site
Secure the building at the end of each work day. This prevents vandalism and loss of
property. It also keeps people from entering the contaminated area. Take particular care
to lock doors and windows.
6-18
-------
Setup
Setup for outside work
Checklist for outside setup
Put up warning signs
Rope off the area
Put down the poly
Put up temporary fencing or barrier tape at a 20-foot perimeter around the surfaces on
which you will be working (or less if distance to next building or sidewalk is less than 20
feet). Put up warning signs on the building and at the same distance from the working
surfaces as you put the barrier tape or fencing.
Put 6-mil poly on the ground and seal it to the wall with duct tape or wood trim and
masonry nails. There should be no gaps between poly and the building. You need to
extend 10 feet of poly in every direction from the surface on which you are working. A
disposable tarp may be laid loosely over plants. Put weights around the edge of the tarp
to keep it down. Keep all windows within 20 feet of the working surfaces closed,
including windows of houses or buildings nearby.
If the outside work includes window treatment or replacement, then one layer of poly
should be placed on the ground and extend at least five feet beyond the perimeter of the
window being treated/replaced. Two layers of poly should be taped to the interior wall
around the window(s) to prevent dust and debris from getting inside the house.
Good setup will prevent soil from getting
contaminated. When water is used to remove the
lead-based paint, you need to collect all of the
water. You can use 2 x 4s to build drains. Turn up
the edge of the poly and attach the boards. Water
must be contained and disposed of properly.
Do not do outside abatement work if wind speeds
are more than 20 miles per hour. If it looks like it
is going to rain, work must stop and cleanup must
be done before the rain begins. At the end of each
day, wrap up the poly, seal it with duct tape, and store it with other waste.
1
CAUTION
LEAD
HAZARD
KEEP
OUT!
Put up warning
signs around the
perimeter of the
exterior work
area.
6-19
-------
CAUTION
LEAD
HAZARD
KEEP
OUT!
Lead Abatement for Workers
Lead tracking
When you walk on lead dust it can stick to your shoes or boots. It then falls in another
area. This is called "lead tracking." Set up a path of poly to prevent lead tracking. Areas
of heavy traffic should be covered with a layer of plywood.
Tracking lead dust is a big problem on lead abatement jobs. Lead dust can be tracked on
your shoes from the work to outside. Sometimes lead dust from the outside soil is
tracked into the work area. Lead dust from a porch or nonwork area can get tracked into
a clean area. When this happens, the whole area must be cleaned again.
Don't track lead
dust or debris
out of the work
area!
6-20
-------
Setup
Setup for interim controls
Anytime you disturb lead-based painted surfaces you will create lead dust. Even small
jobs require appropriate set up. When performing an interim control or a maintenance
repair activity, it is possible to create lead dust.
Setup checklist for interim controls
Put up warning signs and mark off work area with tape. Keep people out of the
work area
Wear protective gear, as appropriate
Clean and remove nearby objects. Send rugs out to be cleaned, after labeling
Clean and seal what remains in the area
Turn off HVAC (or turn off HVAC to that room)
Seal air vents and other openings
Set up dirty area, wash area, and clean area
Place layers of poly at least six feet in every direction from the area where you
will be working
Bring all work tools and equipment into the work area
Seal off the work site from the rest of the building
The following activities are not interim controls
• stripping
• demolition
• paint removal (scraping, sanding, etc.)
• component replacement
You must use a full abatement setup when you do any of them.
CAUTION
LEAD
HAZARD
KEEP
OUT!
Even small jobs
require appropriate
set up.
Place poly at
least six feet in
every direction
from the area
where you will be
working.
6-21
-------
CAUTION
LEAD
HAZARD
KEEP
OUT!
Lead Abatement for Workers
Key facts for Chapter 6
Good setup makes cleaning up at the end of the job easier
When working with lead, you must
keep dust levels down
seal off the work area
repair tears in poly as you work
wear disposable suits and booties while in the work area
wash your hands and face each time you leave the work area
shower at the end of each shift
clean up as you work and at the end of each shift
secure the work site
To set up you will use the following materials
disposable coveralls and booties
poly and duct tape
HEPA vacuum
all-purpose cleaner or a cleaner made just for lead, buckets, rags, and sponges
Before doing the abatement
1. Clean and remove everything that you can from the work area
(such as furniture, appliances, etc.)
2. Clean and cover anything that you cannot remove with poly.
3. Remove all carpeting.
4. Cover all floors with poly.
5. If you're only removing paint from one room or one part of a building,
then seal off the work area from the rest of the building with poly.
When doing outside abatement, keep lead from getting into the soil
Good setup can prevent lead contamination
During interim controls, setup is important to contain any lead dust that
gets created
6-22
-------
CAUTION
Setup
LEAD
HAZARD
KEEP
OUT!
For more information
These publications or resources have more information on the topics covered in this
chapter. Your instructor has a copy of the publications marked with a star (*). You can
order your own copy by calling 1-800-424-LEAD.
EPA, Reducing Lead Hazards When Remodeling Your Home (April 1994).
EPA, HUD, and CDC, Lead Paint Safety: A Field Guide for Painting Home
Maintenance, and Renovation Work (June 1999).
* EPA, HUD, and CPSC, Protect Your Family From Lead in Your Home (June 2003).
* HUD, Guidelines for the Evaluation and Control ofLead-Based Paint Hazards in
Housing (June 1995).
NIBS, Lead-Based Paint: Operations & Maintenance Work Practices Manual for Homes
and Buildings (May 1995).
National Lead Information Center Hotline: 1-800-424-LEAD.
6-23
-------
CAUTION
LEAD
HAZARD
KEEP
OUT!
Lead Abatement for Workers
6-24
-------
CHAPTER 7
Abatement Methods
Learning Objectives 7-3
Skit: On the job 7-4
Discussion Questions 7-4
Lead-based paint abatement 7-5
Replacement 7-6
Enclosure 7-7
Encapsulation 7-9
Paint removal 7-11
Prohibited methods 7-18
Key facts for Chapter 7 7-19
For more information 7-21
-------
f
I
Lead Abatement for Workers
7-2
-------
Abatement Methods
Learning Objectives
In this chapter you will learn about
• replacement
• enclosure
• encapsulation
• paint removal by
— wet scraping and planing
— electric heat guns
— HEPA sanders
— HEPA needle guns
— chemical strippers
-------
Lead Abatement for Workers
Skit: On the job
Abdul and Ed have been working on a house in an older neighborhood for the last two
weeks. Their boss told them that the job should not take more than three weeks.
Abdul: Hey! Slow down buddy. What are you doing dry scraping that trim? You
know the specs say no dry scraping.
Ed: Don't worry about it. You can just clean up underneath me as I go. I'll help
you clean up once I'm done.
Abdul: Yeah, but dry scraping creates a lot of dust.
Ed: No problem. You're wearing your respirator, right?
Abdul: Respirators will only protect you so much. We're going to have a tougher
time doing clean-up. You really need to slow down and cut out the dry
scraping.
Ed: And you need to quit talking and start cleaning. If you can't keep up with
me, that's your problem, not mine.
What do
you think?
Discussion questions
1. Who is right, Abdul or Ed?
2. Is there anything wrong with dry scraping if you clean it up
immediately?
3. Why is Abdul concerned about the dry scraping if he is
wearing a respirator?
4. Do you agree or disagree with the following statements?
Abdul should work faster and clean up after Ed.
Ed should slow down and stop dry scraping.
5. Why do you think Ed is in such a hurry?
6. What could the supervisor do to ensure that no dry scraping occurs at the site?
$
-------
Abatement Methods
Lead-based paint abatement
The Lead-Based Paint Hazard Reduction Act of 1992 states "abatement" refers to the
methods used to permanently get rid of lead-based paint hazards. HUD has defined
permanent as lasting at least 20 years. Getting rid of lead-based paint hazards means
making lead-based paint unavailable, so that it is no longer a hazard. Remember, EPA
defines a "paint-lead hazard" as
• lead-based paint on any friction surface that rubs against another surface and creates
a dust-lead hazard
• lead-based paint that is damaged or deteriorated on any impact surface
• any chewable lead-painted surface on which there is evidence of teeth marks
• any other deteriorated lead-based paint on the inside or outside of any residential
building or child-occupied facility.
There are four basic methods of lead abatement:
• replacement—removing the building part with lead-based paint on it and replacing
it with a new one;
• enclosure—covering the lead-based paint with a solid barrier;
• encapsulation—coating the lead-based painted surface so that it is not accessible;
• paint removal.
Enclosure and encapsulation are permanent solutions, but these methods do not remove
the lead-based paint; they abate the lead-based paint hazard.
Four methods of
lead abatement
• replace;
• enclose;
• encapsulate;
• remove.
7-5
-------
f
I
Lead Abatement for Workers
Replacement is a
permanent
solution.
Replacement can
create a lot of
dust.
Replacement
Replacement means removing the lead-painted building part (such as a window) and
replacing it with a new one that is not painted with lead-based paint. This method is
mostly recommended for windows, doors, and other woodwork that are painted with
lead-based paint.
Advantages
Replacement is the easiest and quickest way to get rid of lead-based paint. Replacement
removes lead-based paint forever. It is a permanent solution. When combined with
overall modernization, replacing windows can upgrade the building itself. Replacement
can lower heating bills and maintenance costs.
Disadvantages
Replacement is expensive. It takes a lot of work. Skilled carpenters are often needed to
put in the new parts—especially windows and doors. Surfaces next to the part being
removed may get damaged. The replacement part may not be as good as the original.
Replacement can involve demolition work. It can create a lot of dust. To keep lead
levels down, wet mist and HEPA (High Efficiency Particulate Air)-vacuum the old
building part before removing it.
Replacement often requires manual
demolition. Old building parts must be
torn out and removed. Manual
demolition is a Class 1 task under OSHA.
You must wear an appropriate respirator
and protective clothing unless your
employer has sampled the air for lead and
this job does not release a lot of lead dust
into the air. Lead abatement tasks are
identified in OSHA's Lead in
Construction Standard and defined in
Chapter 3 of this manual. After removing
the building part, wet mist the part again,
wrap it in poly, and seal it with duct tape.
Store it until it can be disposed of
properly. Wet down and clean up debris
as you work. This helps keep lead dust
levels down. You will learn more about
cleanup and waste disposal in Chapter 8.
a—
7-6
-------
Abatement Methods
An enclosure is a
dust-tight, solid
barrier.
Enclosure
Enclosure means covering the lead-based paint with a solid, dust-tight barrier. The lead-
based paint is enclosed behind the barrier. An enclosure keeps the lead-based paint away
from the rest of the building. It keeps lead away from the building occupants.
The materials used to enclose the lead-painted surface must be durable. Common
materials used to build enclosures include:
underlayment
aluminum
panelling
fiber board
vinyl
plywood
drywall
tile
acrylic sheets
Wall paper and contact paper are not enclosure materials. They are not dust-tight.
Before you enclose a surface, remove all peeling and chipping paint. Also fix any "source
problems" such as water leaks or moisture sources. If source problems are not fixed, the
enclosure that you build will get damaged and fail. After fixing the source problem,
HEPA vacuum the area to be enclosed. This will collect any loose lead dust.
AN ENCLOSURE KEEPS LEAD-BASED PAINT AWAY FROM OCCUPANTS
AND THE REST OF THE BUILDING.
7-7
-------
f
I
An enclosure
prevents lead
dust from
leaking out.
An enclosure
does not
permanently
remove lead-
based paint.
Lead Abatement for Workers
Label the surface "LEAD-BASED PAINT"
before you enclose it. Use spray paint or
something similar.
When you enclose a surface, make sure that the
lead dust will not leak out of the edges or seams.
Seal all seams with caulk. Back-caulk the
perimeter of the enclosure material before you
install it. Then mechanically attach the enclosure
material to the lead-painted surface. Use nails or
screws. You need to use both adhesive and
physical fasteners to create a dust-tight seal. A
dust-tight seal prevents lead-dust leaks.
The new surface must stay in place. The
enclosure must be made so that no one,
especially not a small child, can remove it. The
enclosure material must be strong and durable. If
there are building plans, the areas where enclosures cover lead-based paint need to be
marked and identified in the plan. This will show workers who work in the building in
the future that lead is located there.
$
Advantages
Enclosures are made using locally available construction materials. Enclosures are
durable and, if done right, don't create much waste or dust.
Disadvantages
Enclosure does not permanently remove the lead-based paint. The lead source still
remains underneath the covering. Renovation or repair work to enclosed surfaces will
disturb the lead-based paint. It will release lead dust that has collected behind the
enclosure barrier. Enclosed surfaces and joints of the enclosures must be monitored for
damage and deterioration.
7-8
-------
Abatement Methods
Encapsulant
It is best to use
encapsulants on
building materials
that are in good
condition.
Encapsulation
Encapsulation means coating the lead-painted surface with a thick, durable sealing
material. Surface preparation is critical when encapsulants are used. Some systems
include a mesh as well. The coating prevents lead dust from being released. Encapsulants
are best used on building materials that are in good condition. You need an encapsulant
with mesh for surfaces that have some chipping or peeling.
Encapsulants must be strong enough so you can not easily break or chip the surface.
They must completely cover the lead surface and have a dust-tight seal. Encapsulants
must be flexible and strong. You should not be able to damage the encapsulated surface
with impact. Make sure that the encapsulant you use is not toxic and that it is flame
resistant. Read the MSDS (Material Safety Data Sheet). Wallpaper, contact paper, and
new paint are not encapsulants.
There are many different kinds of encapsulants on the market. The quality and
reliability of encapsulants vary greatly. ASTM has developed three standards for
encapsulants. Only encapsulants that meet these standards should be used. Check your
state and local laws. In some areas of the country, encapsulants must be approved by
state or local government on a case-by-case basis.
Preparing the surface
You must follow all of the manufacturer's instructions on how to prepare the surface.
The wall or surface must be in good condition to use encapsulants. Encapsulation will
not work if the wall is separating from the wood or lath. It will not work if the plaster is
separating. It will not work if the surface is very damaged or deteriorated.
The surface to be covered needs to be prepared first. Moisture sources must be removed
and the surface allowed to dry. Peeling paint should be wet scraped. The surface should
be wet cleaned and allowed to dry. (You can use a HEPA vacuum to clean the surface if
a wet cleaning is not recommended by the
manufacturer.) If these steps are skipped, the
encapsulant will fail.
Applying the encapsulant
You must follow all of the manufacturer's
instructions on how to apply the encapsulant.
Encapsulants are usually easy to apply. Often they
can be applied like you apply paint. If the
encapsulant is improperly applied, it will fail. It
can separate from the paint. This will cause the paint
to peel and create lead dust.
Make sure it is
legal to use the
encapsulant in
your local area.
You must prepare
the surface.
Follow directions
when you
use an
encapsulant.
7-9
-------
f
I
Always do a "test
patch."
Encapsulation
does not remove
the lead-based
paint.
Lead Abatement for Workers
Doing a test patch
Not all encapsulants can be used on all surfaces. Some encapsulants will not work on
certain surfaces. For this reason, you must do a "test patch" of the encapsulant on the
surface to be covered. Read and follow the manufacturer's instructions. If the test patch
bubbles or cracks, then it has failed. If the test fails, do not use this encapsulant on this
surface. Test other encapsulants or use another abatement method.
Using the right personal protective equipment
The type of personal protective equipment you need depends on the type of encapsulant
you use. Suits and respirators should be worn when you do any repair work before
applying the encapsulant. For some chemical encapsulants, you will need special filters,
and chemical-resistant gloves and suits. When using some encapsulants you will need to
use an organic vapor filter as well as a HEPA filter on your respirator.
Make sure the area has a good flow of air. You might need extra ventilation. Good
ventilation is very important when using an encapsulant. Be sure to check the product's
MSDS for specific safety measures.
Advantages
Encapsulation usually does not generate a lot of dust. It may be less costly than other
abatement options. A wide range of products meeting the ASTM standards is available.
Disadvantages
Encapsulation does not permanently remove the lead-based paint. The lead source still
remains underneath the covering. Any renovation or repair work to encapsulated
surfaces will disturb the lead-based paint. Encapsulants do not work on all surfaces.
They need to be tested. "Patch testing" the encapsulant takes time.
Encapsulated surfaces need to be inspected regularly for damage and deterioration.
Encapsulants can fail, especially if the underlying surface was not properly prepared or
the encapsulant was not applied correctly. Sometimes encapsulants separate from the
surface. This is called encapsulant failure. Encapsulants should not be used on impact or
friction surfaces.
Using some encapsulant products may create hazardous waste. Hazardous waste has to
be disposed of properly. You will learn about disposal of hazardous waste in Chapter 8.
7-10
-------
Abatement Methods
SCRAPERS
Removal
methods create a
lot of lead dust.
Paint removal
Removal means taking off lead-based paint. Removal methods create a lot of lead dust
and waste. To begin, wet mist and HEPA vacuum old building parts. Clean up debris as
you work. Keep lead-dust levels down. Paint can be removed by using one or more of
the following methods:
wet scraping down to the substrate
wet planing
using electric heat guns
using local-exhaust hand tools
chemical stripping
vacuum and water blasting (exterior only)
Wet scraping
Wet scraping means misting loose paint before scraping it. Dry scraping paint creates a
huge amount of dust. Avoid dry scraping lead-based paint. Mist the loose paint before you
scrape it. Continue to wet it while you scrape. Doing this keeps lead dust levels down.
Wet scraping is often used to prepare a surface for painting. It does not mean removing
all of the paint—only the loose paint. Wet scraping and painting can be used as an
interim control.
WARNING: Never wet surfaces near
electrical outlets even if the circuit is
turned off. You could get an electric shock.
A scraper is a blade-like tool used to
remove paint. They come in different
sizes. Scrapers should be kept sharp at all
times. A mill file is good for keeping
scrapers sharp.
Clean up the paint scrapings and dust as
you work. Wet and bag the debris as you
go. This keeps lead-dust levels down.
Manual scraping is a Class 1 task. To be
safe, wear appropriate respiratory protection and disposable suit, gloves, and goggles
when you wet scrape. You will get a lot of paint chips and lead dust on your disposable
suit. HEPA vacuum the outside of your suit as you exit the work area.
Wet the paint
before you
scrape it.
Clean up as you
work.
7-11
-------
f
I
Wet the paint
before you plane
it.
Do not use a
heat gun above
1,100° F.
Heat guns can
burn you and the
building.
Heat guns can
create dangerous
lead fumes.
Lead Abatement for Workers
Wet planing
Wet planing is much like wet
scraping. It means misting
the surface before you plane
it. Wet planing creates dust.
Wear a respirator and
protective clothing to be safe.
A plane is a carpenter's tool
for shaving a wooden surface.
You can use a plane to
remove lead-based paint
from impact surfaces such as
the edges of a door. You can use a plane on friction
surfaces such as the edges of windows that rub
together when you open or close the window.
Electric heat guns
Heat guns that generate heat of 1,100° F or more are
prohibited. Electric heat guns may be used to force
warmed air onto a painted surface. The heat softens the paint. The loosened paint is
then scraped off with hand tools.
Use heat guns very carefully. Heat guns can cause serious burns on your skin. They
can damage the building material from which you are removing paint. They can even
cause a fire. Before using a heat gun, check the building material and the other side of
the wall. Heat guns can ignite a fire on the
other side of the surface material. Have an
ABC (multiuse) fire extinguisher on hand.
Heat guns that operate at 1,100° F or more
can cause lead-based paint to produce toxic
fumes. Fumes are created when a metal is
heated. Lead fumes contain many tiny
particles of lead. These tiny particles are
very easy to breathe. The lead fumes quickly
travel deep into your lungs and then cross
into the blood. Heat can also cause the
paint to release organic vapors. Organic
vapors come from chemicals used to make
paint. High heat can turn the chemicals
into dangerous vapors.
7-12
-------
Abatement Methods
HEPA SANDER
HEPA NEEDLE GUN
Local exhaust
tools have a
HEPA vacuum
attached to them.
You should wear a Powered Air Purifying Respirator (PAPR) when you use a heat gun
to protect yourself against dust and fumes. The PAPR should have both a HEPA filter
and an organic vapor cartridge. Some states say you must wear a PAPR when using a
heat gun. You are dry scraping when you use a heat gun. This could create a lot of dust.
Using a heat gun is a Class 1 task. The OSHA Lead Standard says you can ask your
employer for a PAPR. If you ask for a PAPR, your employer must provide you one if
you are working above the PEL and it is protective against the contaminants in your
work area.
Local exhaust hand tools
Local exhaust hand tools are power tools that you can hold in your hand. They have a
hose that attaches to a vacuum, which has a HEPA filter. This system is called a local
HEPA exhaust system. There are a number of local exhaust hand tools for lead-
abatement work. Using local exhaust hand tools is a Class 1 task.
Follow the manufacturer's instructions for proper use of local exhaust hand tools. Never
remove or pull back the shroud or cover. The cover is needed for the vacuum to work.
Shrouded tools are difficult to use. Sometimes you cannot see what you are doing. You
must move the tool very slowly to keep the shroud in place. The tool must be used
flat against the surface. If you work too fast, the shroud seal will break and lead dust will
get into the air.
• HEPA sanders
Sanding generates huge amounts of dust. A HEPA
sander is a power sander fitted with a HEPA vacuum to
catch and filter lead dust as it is created. Always use a
HEPA sander when you sand lead-based paint. Limit
the use of HEPA sanding to flat surfaces for feathering
or finishing only.
• Needle gun with HEPA filter
A needle gun has many metal rods. The rods are contained
inside a shroud (cover). The rods loosen and break
the surface paint. The shroud catches most of the
lead dust. The local exhaust pulls them into the
HEPA filter.
Needle guns are best used on metal or masonry
surfaces. They are useful on pipes and structural
steel. They will damage wood surfaces. Wear
hearing protection when you use a needle gun.
Sanding
generates large
amounts of dust.
7-13
-------
f
I
Do not use
sanders, saws,
drills, or needle
guns without a
HEPA
attachment.
Chemical
stripping strips
paint with
solvents or
caustic paste.
Lead Abatement for Workers
HEPA saws and drills
Other hand tools, such as saws and
drills, can be fitted with HEPA
exhaust systems. The HEPA system
catches and filters most of the lead
dust as it is created. The drill, like the
needle gun, has a cover. Wear hearing
protection when you use a HEPA
saw or drill.
HEPA SAW
HEPA DRILL
J,s'al-
chemical stripping
The use of chemicals in the form of
solvents or caustic paste to strip off paint is
called chemical stripping. Chemical solvents
dissolve the paint. Caustic paste melts paint
into a goo that is scraped off with hand
tools. Chemical stripping always involves
manual scraping. Wear eye protection, a
respirator, and protective clothing to be safe
from the chemicals and from lead. Chemical
strippers give off harmful chemical vapors.
You will need to wear combination filters on
your respirator.
After the paint is removed, carefully clean the surface. Then use a special rinse to
neutralize the surface. The rinse balances the acid or base of the stripping chemicals.
Check with pH indicators to make sure the neutralizer worked. Repainted surfaces will
fail if the caustic paint stripper is not completely removed and the surface is not
neutralized. The surface may need to be smoothed and reglued before it is repainted.
Chemical stripping can be done on- or off-site. When chemical stripping is done off-site
or when you send painted material off-site to be stripped, you should wet down and
clean up any debris generated when you remove the component. Mark the component
in order to identify the place that it was removed from. Place such markings in an out-
of-the-way place. Be sure to use markings that will not be removed by stripping products
(i.e., engraving). Mist the building part with water and remove it. Wrap it in poly. You
may need to wear a respirator and protective clothing when you do this.
Send the component to a professional stripping shop. At the shop it will be dipped in a
tank full of chemical stripping agents. The paint will dissolve right off the surface.
7-14
-------
Abatement Methods
When the component is returned, be sure to wash it before you reinstall it. Make sure it
is properly neutralized. You may also need to refinish and reglue it. Remember to wear a
respirator if you sand the surface—chemical stripping always leaves some lead behind.
Advantages
Chemical paint strippers are useful to preserve the detail on decorative doors, molding,
and trims. They are used on old antique trims or molding that can not be replaced.
Sending the work somewhere else keeps hazardous chemical strippers out of your work area.
Disadvantages
Chemical strippers may create hazardous waste. Strippers are often made of hazardous
materials and may have to be disposed of as hazardous waste. The liquid waste generated
through rinsing and cleaning may also be hazardous waste. Hazardous waste has to be
contained and disposed of in a special way. It must be handled correctly, or it can hurt
workers and the environment. Sending the work off-site protects you and your work site.
It does not protect the work site or workers where the stripping takes place. Your
employer is required to find out if each job generates hazardous waste.
Chemical stripping leaves some lead behind. This leftover lead soaks into the pores
and cracks of a surface, especially wood, where it hardens. Wear a respirator if you sand
the surface. Clean the stripped surface carefully, or the leftover lead will mix with the
new non-lead-based paint. When the new paint chalks, chips, or peels, the lead will get
into the dust all over again. Clean up any dust or debris using wet cleaning methods and
HEPA vacuuming.
Caustic strippers can damage the building material.
Leftover stripper will cause the new paint coat to fail. It will damage the building
material. This can happen if the surface was not cleaned properly. Cleaning is an
important job that takes a lot of time. Another reason the new paint might fail is that
the neutralizer did not work properly. It is very important to test the surface to see if the
neutralizer has worked. If the surface is not neutral, you must clean and neutralize it
again. Do this process over and over until the surface is neutral. This could take days.
Removing a building component for ofF-site stripping will create dust. An old
building component may break when you try to remove it. To keep dust levels down,
mist the component with water before you remove it. Wet down and clean up any debris
generated. Wear the right protective gear and follow proper hygiene practices.
Chemical strippers are dangerous!
Material Safety Data Sheets (MSDSs) give you safety instructions about using chemical
products.
Chemical
stripping creates
hazardous
waste—both on
site and off site.
7-15
-------
f
I
Read your
Material Safety
Data Sheets.
Lead Abatement for Workers
Any chemical that call remove paint will harm you if it touches your skin or gets in
your eyes.
Caustic strippers will burn your skin. When you scrape a caustic, it can create a dust or
mist that can get into your eyes, nose, mouth, and throat. Solvent strippers can be very
dangerous. Some solvents can damage your skin, others pass through your skin into your
blood. Solvents can damage your brain, nervous system, blood, liver, kidney, and heart.
• Find out where the eye-wash station is so you know where to find it if you need it.
• Never do chemical stripping above your head.
• Keep chemicals off your skin and out of your eyes.
• Wear chemical-resistant, rubber gloves and suits. Wear eye goggles and gloves that
extend up your arm towards your elbows.
Some stripping chemicals have toxic vapors which you should not breathe.
Do not use strippers that contain methylene chloride. Methylene chloride is
extremely toxic. It can cause cancer and
other major health problems.
Only use chemical strippers in well-
ventilated areas.
Use the right respirator filters. Make sure
your respirator cartridges will protect you
from the chemicals in the stripper. You may
need a combination filter when you are
removing lead with a chemical stripper.
YLENE
CHLORIDE
7-16
-------
Abatement Methods
Some strippers can cause a fire. The vapors they give off create a fire hazard.
• Do not use them around electric heaters, heat guns, or any electrical equipment.
• Have an ABC fire extinguisher on hand.
• Have a plan in case of a fire.
• Mark and know where the emergency exits are.
• Post the emergency phone numbers.
• Know where the phone is and how to use it.
• Have a designated meeting place outside the work area.
Vacuum and water blasting (exterior methods)
Paint can be removed by vacuum blasting and water blasting. These methods are to be
used for exterior work only. Vacuum blasting requires a HEPA vacuum. Both methods
are very expensive. They create a lot of waste. They can damage the treated surface,
especially wood. Neither method is used very often. Vacuum blasting can be used on a
variety of surfaces, but it works best on flat surfaces. Water blasting creates waste water
that is considered hazardous. It must be contained and disposed of properly.
After the lead-based paint is removed, the bare surface must be cleaned and smoothed.
Then, the surface must be inspected. If it passes inspection, it can be repainted with
non-lead-based paint or covered with other materials.
Only use vacuum
and contained
water blasting for
outside work.
7-17
-------
f
I
Lead Abatement for Workers
Torching and
flame burning
lead-based paint
are not allowed in
residential
abatement.
HUD does not
allow the use of
paint strippers in
poorly ventilated
work spaces.
Prohibited methods
HUD and EPA do not allow some methods on residential lead abatement jobs
(including child-occupied facilities). These methods are not allowed because they are
hazardous. They include
torch or flame burning;
machine sanding or grinding (unless equipped with a
HEPA filter);
abrasive blasting or sandblasting (unless equipped
with a HEPA filter);
dry scraping of lead-based paint*;
using a heat gun above 1100 degrees Fahrenheit.
*Dry scraping of lead-based paint is only allowed in the
following situations:
when scraping while using a heat gun or around
electrical outlets;
when scraping defective paint spots totaling no
more than two square feet in any one room,
hallway or stairwell or totaling no more than 20
square feet on exterior surfaces.
NO TORCH BURNING!
NO DRY SANDING!
Additionally, HUD prohibits the use of methylene chloride paint strippers, as well as
the use of other paint strippers in poorly ventilated work spaces.
Some states or localities may prohibit the use of methylene chloride paint strippers.
Methylene chloride paint strippers may cause cancer.
Remember, wallpapering or repainting are not lead-based paint abatement methods.
Wall papering
and painting are
not lead-based
paint abatement
methods.
7-18
-------
Abatement Methods
Wall papering
and painting are
not lead-based
paint abatement
methods.
Key facts for Chapter 7
Always wear a respirator and protective clothing when doing abatement
work.
Clean up as you work.
There are four methods to abate lead-based paint:
• Replacement
• Enclosure
• Encapsulation
• Paint removal
Replacement permanently removes the lead-based paint.
Replacement can increase the value of the building.
It can create a lot of dust.
Wet mist before removing the old part.
Clean up as you work.
An enclosure is a dust-tight solid barrier.
A dust-tight enclosure prevents lead dust from leaking out.
Lead-based paint remains.
The surface must be HEPA vacuumed before enclosure.
The enclosure must be strong and durable.
Encapsulation means coating the lead-painted surface with a thick, durable
sealing material.
Encapsulation is best used on building parts in good condition.
Whenever you encapsulate, you must prepare the surface first.
Always do a "test patch."
Lead-based paint remains.
Encapsulants may fail.
Make sure the encapsulant you use is legal in your area.
Paint removal methods create a lot of lead dust.
Mist the paint before you scrape or plane it.
Heat guns may create dangerous lead fumes and toxic vapors.
Do not use a heat gun that heats above 1,100° F.
Heat guns can burn you and the building.
7-19
-------
Lead Abatement for Workers
Use only local exhaust tools that have a HEPA vacuum attached to them to
remove lead-based paint.
Mechanical hand tools create large amounts of dust.
Only use sanders, saws, needle guns or drills that have a HEPA attachment.
Chemical stripping removes paint by means of solvents or caustic paste.
Chemical strippers are dangerous!
Chemical stripping may create hazardous waste—on site and off.
Wear chemical-resistant coveralls, gloves and booties.
Always wear eye protection.
Do not use strippers that contain methylene chloride.
Some strippers can create a fire hazard.
Make sure you have an ABC fire extinguisher on site.
Vacuuming and water blasting should only be used for outside work.
HUD and EPA do not allow these lead-abatement methods for residential work:
torch or flame burning;
machine sanding or grinding (unless equipped with a HEPA filter);
abrasive blasting or sandblasting (unless equipped with a HEPA filter);
dry scraping of lead-based paint (with a few exceptions);
using a heat gun above 1,100 degrees Fahrenheit.
HUD does not allow the use of paint strippers in poorly ventilated
work spaces.
-------
Abatement Methods
For more information
These publications have more information on the topics covered in this chapter. Your
instructor has a copy of the publications marked with a star (*). You can order your own
copies by calling 1-800-424-LEAD.
*EPA, Lead: Identification of Dangerous Levels ofLead; Final Rule; 40 CFR Part 745
(January 2001).
*EPA, Lead: Requirement for Lead-Based Paint Activities in Target Housing and Child-
occupied Facilities-, 40 CFR Part 745 (August 1996).
*HUD, Requirements for Notification, Evaluation and Reduction of Lead-Based Paint
Hazards in Federally Owned Residential Property and Housing Receiving Federal
Assistance; Final Rule (September 1999).
*HUD, Guidance for the Evaluation and Control ofLead-Based Paint Hazards in Housing
(July 1995).
*NIOSH, Preventing Lead Poisoning in Construction Workers, NIOSH Document No.
91-116A (April 1992).
*OSHA, Interim Final Lead in Construction Standard, 29 CFR 1926.62 (May 1993).
OSHA, Lead in Construction, OSHA 3142 (1993).
*Society for Occupational and Environmental Health, Protecting Workers and Their
Communities from Lead Hazards: A Guide for Protective Work Practices and Effective
Worker Training (1993).
-------
f
I
Lead Abatement for Workers
7-22
-------
CHAPTER 8
Cleanup, Disposal, and Clearance
Learning objectives 8-3
Skit: A home abatement job 8-4
Discussion questions 8-4
Cleanup of lead dust 8-5
Cleanup materials 8-6
Daily cleanup 8-7
Final cleanup 8-9
Clearance Inspection 8-12
Visual examination 8-12
Stage 2: Painting and sealing 8-12
Stage 3: Repeat special cleaning 8-12
Final inspection—Environmental sampling 8-13
Clearance dust levels 8-13
Why measure lead in house dust? 8-14
Waste from a lead abatement job 8-15
Handling waste on the job 8-17
Liquid waste 8-18
Testing and disposing of waste 8-19
Nonhazardous waste disposal 8-20
Hazardous waste disposal 8-21
EPA studies of paint abatement waste 8-23
Key facts for Chapter 8 8-24
For more information 8-26
Addendum A 8-27
-------
Lead Abatement for Workers
-------
Cleanup, Disposal, & Clearance
Learning objectives
In this chapter you will learn
• the importance of good cleanup
• what cleanup materials to use
• how to do daily cleanup
• how to do final cleanup
• what the clearance levels are
• how to handle waste
• how to dispose of hazardous waste
-------
Lead Abatement for Workers
Skit: A home abatement job
It's 4:30 in the afternoon, and Paul and Pam are just finishing cleaning up for the day.
Pam: Hey, I can see a little bit of dust left on the floor. I'll bring in the shop
vacuum and clean it up.
Paul: Don't do that. Use the HEPA vacuum.
Pam: Didn't you hear that the HEPA vacuum broke this morning? Besides, we
already did a thorough vacuuming yesterday.
Paul: Why don't we spray it down and then sweep it up?
Pam: That will take too much time. I've got a date tonight and I want to get out
of here before the next shift comes in and removes the poly. Don't worry
about it. I'm gonna vacuum and when I'm done it'll look really good.
Discussion questions
1. Is it okay to use a regular shop vacuum to clean up the lead
dust as long as you're inside the contained area?
2. If you are inside of the enclosed area, do you need to worry
about kicking up the lead dust?
3. What makes lead-paint dust and chips so hard to clean up?
4. If Pam uses the shop vacuum, how could it affect the people
on the next shift? How could it affect the next person who
uses the shop vacuum?
f \
What do
you think?
-------
Cleanup, Disposal, & Clearance
Cleanup of lead dust
Cleanup is the most important step.
If you do not clean up, lead dust levels will increase! Careful cleaning prevents future
exposures to lead. Careful cleaning protects the family who will move back into the
homes you work on. Any lead dust that remains can poison them. Careful cleaning also
protects you while you work.
Lead dust is difficult to remove because
• lead dust is very fine
• it may not be visible
• it sticks to surfaces
• it has to be rubbed off
• it collects and packs into cracks
Careful cleanup
keeps lead dust
down.
8
-------
Lead Abatement for Workers
Cleanup materials
• Protective suit and respirator
• Work gloves and eye protection
• Hand-pumped water sprayer
• Water
• Labelled heavy-duty plastic bags (6-mil poly)
• Plastic shovels and/or dust pans
• HEPA-vacuum cleaner (with special attachments)
• All-purpose cleaner or a cleaner just for lead cleanup
• Buckets (at least 3 mop buckets, one with a wringer)
• Sponges and rags
• String mops, sponge mops, and extra mop heads for both
• Clean step ladder
• Special containers for hazardous waste (if needed)
-------
Cleanup, Disposal, & Clearance
Daily cleanup
Cleaning the work site every day helps to keep lead dust levels down. It keeps the work
area as clean as possible. The OSHA Lead Standard says all surfaces must be kept as free
from lead dust as is practical. This keeps lead out of the air. Cleaning the work site
prevents you from spreading lead dust around. It also helps make final cleanup—and
passing the final inspection—much easier. You may be exposed to high levels of lead in
cleanup. You must wear a respirator and protective clothing during cleanup. Daily
cleanup takes place at the end of each work day.
1. Wrap up and label large debris.
Wrap large debris (like doors and windows) in 6-mil poly. Seal the wrapped debris
with duct tape. Put a label on it that says "LEAD CONTAMINATED." Store
waste in a secure area until it can be tested and disposed of properly.
o,;
/ s / / —f \ i
Wrap large debris in 6-mil poly.
Clean up the
work site every
day.
Wrap large
debris in poly.
8
-------
Lead Abatement for Workers
2 Wet mop the floor. Bag and label small debris.
Mist dust and small debris with water. Wet mop or wet sweep it all up. Do not dry
sweep! This stirs up lead dust. Put the debris into 6-mil plastic bags and seal the
bags. Bag, tape, and throw away the mopheads with the debris. Put labels on the
bags that say "LEAD CONTAMINATED." Store waste in a secure area until it can
be tested and disposed of properly.
Wet mop the
floors.
Do not dry
sweep!
3. HEPA vacuum all surfaces in the work area.
The OSHA Lead Standard says that you should not allow lead dust to build up. It
says wherever possible use the HEPA vacuum. Do not use a regular shop
vacuum—it cannot filter lead dust. Start at the far end of the work area and move
towards the exit through the decontamination area.
4. Check poly and repair any tears or rips.
Check for tears in the poly throughout the day. Repair any rips as you find them. At
the end of each day, inspect the whole containment for holes, rips, and tears in the
poly. Make sure you check the poly covering the air vents and heat registers.
WET MOP FLOORS
DON'T DRY SWEEP!
HEPA vacuum all
surfaces at the
end of each day.
-------
Cleanup, Disposal, & Clearance
Every step in
final cleanup is
very important.
Final cleanup
The cleanup done at the end of the abatement job is called final cleanup. Final cleanup
must be done slowly and carefully. Final cleanup might even take longer than the
abatement itself. There are three stages of final cleanup. Each stage is very important
and must be done thoroughly.
Many abatement jobs fail the final inspection because the final cleanup was not done
properly. If an abatement job fails, you will have to do cleanup over again as many times
as it takes for the job to pass. Redoing cleanup is expensive and takes a lot of work time.
It is better to do it right the first time.
Wait at least one hour after you finish the abatement before you start final cleanup (even
longer [e.g. overnight] if it's practical). (Check with your state and local laws.) This
allows the lead dust that is in the air to settle. The time that it takes for the lead dust to
settle depends on the type of work methods you used. Dust may settle onto surfaces
within a few hours of encapsulation or enclosure. Smaller particles created with a needle
gun or heat gun will take much longer to settle
out of the air.
Stage 1: Special cleaning
1. Wear protective gear.
Put on plastic gloves to protect your hands
from the lead cleaner. Wear protective
goggles or other eye gear to shield your eyes.
You will also wear your respirator,
disposable suit, and booties or rubber boots.
2. HEPA vacuum all surfaces.
HEPA vacuum all surfaces in the work
area, including areas that had been
covered with plastic.
Start at the far end and then work
towards the decontamination area.
Begin with ceilings or the top of the
walls and work down, cleaning the
floors last. Do every inch of the
windows, especially the troughs. Use
the corner tool to clean where the floor
meets the baseboard and all cracks in
the floor boards. Use the brush tool for
the walls. Move slowly and carefully to
get all the dust.
1|
Final cleanup
may take longer
than the
abatement.
For all surfaces
in the work area:
• HEPA vacuum;
• wash with
cleaner;
• HEPA vacuum
again.
8-9
-------
Lead Abatement for Workers
Collect waste in sealed plastic bags or wrap in poly.
Place any remaining disposable items in 6-mil plastic bags and tie the bags shut. If
waste items are too large, wrap them in 6-mil poly. Seal them with duct tape. Put
labels on them that say "LEAD CONTAMINATED."
Wet mop and bag dust.
Use the spray bottle to wet down all dust and debris with a fine mist of water. This
will help control the dust during cleanup. Wet mop the entire work area. Bag and
seal the debris. Label the waste "LEAD CONTAMINATED."
Take off first layer of poly.
If you did not do any demolition or replacement, you may have used only one layer.
If so, do not remove that layer, and skip to step #6.
If you used two layers of poly, now is the time to remove only the first layer. Wet
mist the poly before removing it. This contaminated plastic must be removed
carefully. Remove the upper plastic that covers cabinets and counters first. Then
carefully remove the poly on the floor. Do not remove floor poly until all other poly
has been removed. Fold top layer of poly onto itself from the edges into the center
in order to trap any remaining dust inside. Seal with duct tape and put into plastic
bags for disposal.
6. Wash all surfaces with cleaner.
Wash all surfaces in the work area
with an all-purpose cleaner or a
cleaner made just for lead cleanup,
including areas that had been covered
with plastic. Some wallpaper should
only be HEPA vacuumed and not
washed.
Use the 4-Step System you learned
about in Chapter 5.
Start from the top and work down.
Start with the ceiling and work down
to the floors.
Mix up a new solution of lead cleaner
often so it stays clean. Change the
rinse water, rags, and mop heads at
least once every 500 square feet. The number of times you must change both the
wash water and the rinse water will depend on how dirty the area is. After washing
each room, go back over the surfaces with a clean water rinse.
Dispose of washwater waste according to state and local laws.
Don't remove the
first layer of poly
until all other poly
has been
removed.
8-10
-------
Cleanup, Disposal, & Clearance
7- Remove the bottom layer of poly. Clean the floor.
After all the work above the floor has been cleaned, carefully remove the bottom
layer of poly from the floor. Fold the contaminated side of the poly into itself. This
will contain the lead dust and moisture. Seal the bundle with duct tape and place it
in a 6-mil bag or wrap it in 6-mil poly. Label it "LEAD CONTAMINATED."
HEPA vacuum the floor. Use the lead cleaner to wash it. Rinse it with clean water.
8. HEPA vacuum all surfaces again.
After all surfaces have dried, HEPA vacuum a second time. Vacuum until no dust or
residue can be seen. Move slowly and carefully.
9. Collect used cleaning items in sealed plastic
bags.
label them "LEAD CONTAMINATED."
Discard all items used for cleaning (towels,
sponges, rags, mop heads) in 6-mil plastic
bags. Seal the plastic bags, making sure to
"gooseneck" the opening to the bags, and
Seal all items
used for cleaning
in plastic bags.
8-11
-------
Lead Abatement for Workers
Clearance Inspection
The final clearance inspection occurs in two main phases:
• visual examination
• environmental sampling
Visual examination
The work area should be visually inspected before you repaint or seal surfaces where the paint
has been removed. The inspector will come in and look at the surfaces chosen for abatement
to see if visible paint residue remains. The inspector will also look for signs of dust. This
visual inspection should be done no sooner than one hour after cleanup is finished.
If all the abatement work is done and no dust can be seen, the job passes the visual
inspection. If the job does not pass visual inspection, you will have to reclean the area
until no dust can be seen.
In some states there is no requirement for visual inspection before repainting or sealing
the abated surfaces, but it is often a part of the specifications. It is always a good idea to
make sure you don't see any signs of lead dust before repainting an abated surface.
Stage 2: Painting and sealing
All abated surfaces should be primed with the correct type of primer for the surface.
Repaint all abated surfaces. A final coat of gloss or semi-gloss is recommended.
Enclosures or encapsulants may not need to be painted. Wooden floors should be sealed
with clear polyurethane-based sealer or coating. Other floors such as tile or linoleum
should be sealed with wax. Concrete floors need to be sealed with a concrete sealer.
Stage 3: Repeat special cleaning
Allow at least 24 hours between stage 2 and stage 3 for the paint and sealers to dry, or
follow the manufacturer's specifications. Then HEPA vacuum all surfaces. Wash all
surfaces with a lead cleaner (some latex paints can be damaged by cleaning solutions; use
a warm water rinse instead). Then HEPA vacuum all surfaces again.
-------
Cleanup, Disposal, & Clearance
Surface
EPA Clearance Levels
Level of lead in dust
Floors
Window sills
Window troughs
40 pg/ft2
250 pg/ft2
400 pg/ft2
If the dust sample results are below these levels, then the job passes final inspection.
If they are at or above these levels, you will have to redo cleanup. You will have to redo
cleanup as many times as it takes for the job to pass the final clearance inspection.
The job must
pass final
inspection.
Final inspection—Environmental sampling
Once the area has been cleaned and repainted, an inspector will take dust samples for
the final inspection. These samples are called clearance dust samples. Clearance dust
samples are taken no sooner than one hour after final cleanup is finished. (Review
Chapter 4 for more information on collecting dust samples.) The job must pass final
inspection before occupants can move back into the building.
The inspector will take samples from several rooms within the work area. The inspector
will sample three surfaces: floors, window sills, and window troughs. The actual number
of samples will depend on
• whether there was containment (at least an airlock between the abated rooms and
the rest of the dwelling or building);
• whether the abatement was done on the inside or outside of the house;
• whether the inspector does single-surface or composite dust sampling.
Common areas (such as hallways and stairwells) are also sampled. The number of
samples taken in common areas depends on the size (in square feet) of the common area.
The purpose of the final inspection is to make sure that dust levels are as low as they
can be.
Clearance dust levels
The lead dust levels from these samples must be acceptable for clearance. Passing
clearance means that the area has been cleaned adequately. Remember, lead in dust is
measured in micrograms (pg) of lead per square foot (ft2) of area tested.
The final
inspection makes
sure that dust
levels are as low
as they can be.
If lead dust levels
are too high, you
must redo
cleanup.
Dust tests show
if cleanup was
adequate.
8-13
-------
Lead Abatement for Workers
Why measure lead in house dust?
All abatement methods create lead dust. Dust tests show if dangerous levels of lead
dust still exist in a home. Lead dust is a major source of lead exposure for young
children. Children have been poisoned after abatement jobs because cleanup was
not done well. If lead dust gets left behind, the families who return to their homes or
children who return to the child-occupied facility (for example, a daycare center) can
be poisoned. This is why cleanup is so important. This is why passing final inspection
is so important.
Children have
been poisoned
after abatement
jobs because
cleanup was not
done well.
Protect the families whose homes you work on.
Do cleanup right!!
8-14
-------
Cleanup, Disposal, & Clearance
What is the purpose of this interpretation?
This memorandum clarifies the regulatory status of waste generated as a result of lead-
based paint activities (including abatement, renovation, and remodeling) in homes and
other residences.
Since 1980, EPA has excluded "household waste" from the universe of RCRA hazardous
wastes under 40 CFR 261.4(b)(1). In the 1998 temporary toxicity characteristic (TC)
suspension proposal, EPA explained that the household waste exclusion applies to all
lead-based paint waste generated as a result of actions by residents of households to
renovate, remodel or abate their homes on their own. In the 2000 memorandum, EPA
stated that they believe lead paint debris generated by contractors in households is also
"household waste" and thus excluded from the RCRA Subtitle C hazardous waste
regulations. Thus, the household exclusion applies to waste generated by either residents
or contractors conducting lead-based paint activities in residences.
Residents and contractors managing lead-based paint waste from households, although
excluded from the hazardous waste regulations, should take common sense measures to
• minimize the generation of lead dust,
• limit access to stored lead-based paint wastes including debris, and
• maintain the integrity of waste packaging material when moving or transporting the
lead-based paint waste.
Separate each
type of waste on
the job.
Waste from a lead abatement job
There are many waste materials from lead abatement jobs:
• lead-based paint chips
• lead-based paint dust
• large components that were removed (windows, doors, etc.)
• poly and duct tape
• sludge from paint removers
• solvents from paint stripping
• liquid waste (from cleanup, neutralizing surfaces, water blasting)
• used cleaning supplies
• disposable work clothes and respirator filters
Before the project begins, your employer must find out the federal, state, and local rules
on how to dispose of each type of waste likely to be created. The building owner will
need to know that all of the waste was disposed of legally.
In July 2000, EPA issued a memorandum clarifying how waste generated as a result of
lead-based paint activities should be handled (Regulatory Status of Waste Generated by
Contractors and Residents from Lead-Based Paint Activities Conducted in Households). A
copy of the memo is included as Addendum A of this chapter.
Your employer
must check with
the state, locality,
or tribe to see
how they
regulate LBP
abatement
waste.
8-15
-------
Lead Abatement for Workers
Follow best
management
practices when
handling and
disposing of LBP
waste.
In particular, EPA endorses the basic steps outlined in the 1998 proposals for the proper
handling and disposal of lead-based paint waste as the best management practices
(BMPs). These include:
• Collect paint chips, dust, and dirt and rubble in plastic trash bags for disposal.
• Store larger lead-based paint architectural debris pieces in containers until ready for
disposal (wrap in poly before storing).
• Consider using a covered mobile dumpster (such as a roll-off container) to store
lead-based paint debris until the job is done.
• Contact local municipalities or county solid waste offices to determine where and
how lead-based paint debris can be disposed.
In addition, contractors working in residential dwellings are subject to either one or both
of the following:
• The HUD guidance for contractors doing publicly-funded rehabilitation/renovation
projects in public housing.
• EPA (or state or tribal) training and certification requirements and the proposed
EPA onsite management standards.
These best management practices for households are similar to those included in the
HUD Guidelines for individuals controlling lead-based paint hazards in housing. HUD
requires that contractors using HUD funding follow the lead-based paint hazard control
guidelines. Not following these guidelines can potentially result in the loss of funding.
Contractors should contact their state, local and/or tribal government to determine
whether any restrictions apply to the disposal of residential lead-based paint waste. This
verification is necessary since, under RCRA, States, local and tribal governments can
enforce regulations that are more stringent or broader in scope than the federal EPA
requirements. In those cases, lead-based paint waste from households may still be
regulated as a hazardous waste as matter of State regulations. In states or tribes that do
not have an exemption for residential lead abatement waste and for commercial
(nonresidential) structures, the following information applies.
State, localities,
and Indian Tribes
may not have an
exemption for
residential LBP
waste.
8-16
-------
Cleanup, Disposal, & Clearance
Handling waste on the job
Your employer is responsible for determining what types of waste and how much waste
is generated on an abatement project.
If the state, tribe, or city in which you are working treats lead abatement waste as
possibly hazardous and if your job is creating more than 220 pounds of waste per
month, your employer will need to take a small sample from each type of waste and have
it tested. If your employer is creating less than 220 pounds of waste per month, you
may be able to dispose of the waste as nonhazardous waste after checking with the state
and solid waste disposal facility. Dispose of the waste according to state and local laws.
Separate each type of waste on a job. Your employer or supervisor will take a sample
from each type of waste to see if it is hazardous. Hazardous waste is waste that can
poison people and the environment if it is not handled carefully. Your supervisor or
employer is responsible for telling you what waste is hazardous and what is
nonhazardous. All waste should be kept within the contained area on the job until it
is tested to determine if it is hazardous. Even if the waste you create is nonhazardous,
it may still pose an exposure hazard to you and to the occupants.
Warning! Sometimes regulations call all waste "solid waste" until it is tested. Sometimes
the regulations call all nonhazardous waste "solid waste," including nonhazardous liquid
waste. In this manual, "solid waste" means solid material and "liquid waste" means
liquid material.
Your employer
is responsible
for determining
what types of
waste are
generated on
the project.
8-17
-------
Lead Abatement for Workers
Liquid waste
The contract specifications for larger jobs will often tell your supervisor how to handle
liquid waste. On small jobs you may not have any specifications. Liquid waste includes
wash water from cleanup, the neutralizing solution used for paint strippers, and waste
from water blasting. Liquid waste should be filtered before disposal to remove as much
of the lead and other particles as possible. Store liquid waste in noncorrosive containers.
Contact the local sewage treatment center and the state department of the environment
for directions on how to dispose of liquid waste properly. Never pour it down toilets,
drains, storm sewers, or onto the ground. (Note: In some cases, liquid debris from dust
abatement or renovation/remodeling may be disposed of down the toilet. You should
check with the state or local waste water agencies to check before doing so.)
Liquid waste from lead abatement is often hazardous waste. It must be treated by a
liquid waste treatment facility before disposal. If you are generating lots of liquid waste,
store the waste in 55-gallon steel or plastic drums until it is tested.
Do not pour
liquid waste
down a drain or
onto the ground.
8-18
-------
Cleanup, Disposal, & Clearance
Testing and disposing of waste
If you are working in a state/area where local regulations require that lead abatement
wastes be treated as hazardous, all waste from lead abatement jobs must be tested to see
if it is hazardous waste. Hazardous waste is liquid or solid waste that could poison
people if it is not disposed of correctly.
Your employer will test different types of waste to see if they are hazardous. This is done
with a special test called a "Toxicity Characteristic Leachate Procedure" test. This test is
often called a "TCLP" test. The TCLP test looks at how the waste material will break
down. It checks to see if the waste material will leak or release a hazard.
Lead waste—including paint chips, sludge from chemical strippers, and water from
water blasting—are some of the types of waste that must be tested. Once your employer
has tested the waste, you will be responsible for keeping the hazardous and
nonhazardous wastes separated.
Your employer
may have to take
a sample of each
type of waste to
see if it is
hazardous.
8-19
-------
Use a secure
space to store
wastes.
Never burn lead
waste!
Lead Abatement for Workers
Nonhazardous waste disposal
These steps are appropriate for all waste if you are working in a state which follows EPA
guidance stating that lead abatement waste from residential structures is exempt from
hazardous waste requirements.
1. Bag or wrap solid waste in 6-mil poly.
Seal with duct tape. Do this as part of cleanup
every day and at the end of the job. Do not use a
bag labelled "asbestos" when you are bagging lead.
Label the bag "LEAD CONTAMINATED."
2. Store waste in a secure space.
Store waste in an area closed off to people other
than workers. Protect waste from children, animals, the weather, and anything else
that can disturb it. Sometimes you can use a locked dumpster. Put signs that say
"DANGER! CONTAINS LEAD WASTE" on the storage space.
3. Take waste to a landfill in a covered vehicle.
Transport solid waste to a
municipal or lined landfill
(your employer should check
to determine what your state
or local laws require) . Always
transport waste from a lead-
abatement job in a covered
truck. This keeps lead dust
from getting into the
environment.
- i
iuLar
WARNING: Do not take waste from a lead-abatement job to an incinerator.
Burning lead waste creates lead fumes that get into the air. Lead fumes are very easy
to inhale and are very dangerous to health.
8-20
-------
Cleanup, Disposal, & Clearance
Hazardous waste disposal
If the state, tribe, or city in which you are working treats lead abatement waste as
possibly hazardous, avoid abatement methods which generate hazardous waste, such as
chemical stripping. If you use such methods, your employer must plan how to contain,
transport, and dispose of the hazardous waste before the project begins. Hazardous waste
is much more expensive to dispose of than nonhazardous waste.
The federal law that covers hazardous waste is the Resource Conservation and Recovery
Act. It is called RCRA for short.
If your employer or supervisor has determined that some or all of the waste you are
handling is hazardous, then he or she must have you do the following:
1. Store all hazardous waste in special containers.
Store hazardous waste in 55-gallon drums, tanks, or other containers that match the
type of waste. The Department of Transportation or state waste management
agency will give you the information you need to choose the right container. All
containers must be marked "HAZARDOUS WASTE" in bright red and yellow
colors. All containers must have a label that lists their contents.
55-GALLON DRUM
D.O.T. SHIPPING NAME
UN OR NA #
EPA NAME
EPA #
GENERATOR INFORMATION:
NAME
ADDRESS
CITY
DATE OF GENERATION/ACCUMULATION
FEDERAL LAW PROHIBITS IMPROPER DISPOSAL
IF FOUND, CONTACT THE NEAREST POLICE,
OR PUBLIC SAFETY AUTHORITY, OR THE
U.S. ENVIRONMENTAL PROTECTION AGENCY.
HANDLE WITH CARE!
HAZARDOUS WASTE
STATE
MANIFEST #
ZIP
Hazardous waste
is dangerous to
human health
and the
environment.
Store hazardous
waste in special
containers.
Label the
containers.
8-21
-------
Lead Abatement for Workers
Hazardous waste
must go to a
licensed disposal
site.
2. Store hazardous waste in a secure area.
Store waste in an area closed off to people other than workers. Protect waste from
anything else that can disturb it. Regularly inspect containers for leaks or corrosion.
Hazardous waste can be stored at the company's facility for up to 90 days.
3. Use a licensed transporter.
The person or company that transports hazardous waste must be approved by the
EPA. Be careful when you move hazardous waste containers. Use hand trucks,
dollies, pull carts, and ramps whenever you can. This will help prevent containers
from breaking and help protect everyone from exposure to hazardous waste.
4. The hazardous waste must be brought to a licensed disposal site.
The transporter must take the hazardous waste to a disposal facility that is licensed
to accept this type of hazardous waste. The site must be approved by EPA. All
hazardous waste must be disposed of within 90-180 days of the start of collection.
5. Use a Hazardous Waste Manifest.
An EPA form called a "Hazardous Waste Manifest" must be with every shipment.
Your employer or supervisor, the transporter, and the receiver at the disposal site
must all sign the manifest.
Other requirements:
Some contractors have to follow even more requirements for hazardous waste. They
include contractors who
• generate more than 2,200 pounds of hazardous waste per month;
• abate more than one housing unit at a time;
• abate commercial, public, and industrial buildings.
8-22
-------
Cleanup, Disposal, & Clearance
EPA studies of paint abatement waste
EPA sponsored two studies of lead abatement waste. They used jobs from the HUD
demonstration project in 1991.
After the first study, EPA found that certain types of waste generally were hazardous or
not hazardous. For some kinds of waste they did not have enough data to draw
conclusions. So, they did a second study.
The results from the second study are in the following chart. These results only give you
an idea of what might happen on your project. You can separate the waste into these two
groups before the TCLP tests are done. The following results from the second study are
not conclusive.
Current federal EPA guidance does not require TCLP testing of lead abatement wastes.
However, some states, tribes, or localities may require that any contractor generating
more than 220 pounds of waste per month sort and test waste from each project or use
knowledge from prior similar projects. Local and state or tribal regulations may require
that even waste from small jobs be tested.
ABATEMENT WASTE
Hazardous
Usually not hazardous
• Paint chips
• Filtered wash water
• Paint dust (from HEPA vacuums
• Disposable work clothes and
and air filters)
respirator filters (HEPA vacuumed
before disposal)
• Rags, sponges, mops, HEPA filters,
other cleaning materials
• Solid waste, such as window frames,
with lead level less than 4 mg/cm2
• Air monitoring cartridges
(measured at lab)
• Scrapers
• Poly and tape from encapsulation
• Unfiltered wash water
and enclosure jobs (HEPA
vacuumed before disposal)
• Solid waste with lead level higher
than 4 mg/cm2
• Poly and tape from jobs where heat
guns used
Tests results
from previous
similar jobs may
be used to
determine if
waste is
hazardous or not.
8-23
-------
Lead Abatement for Workers
Key facts for Chapter 8
Cleanup is the most important part of the abatement job.
Cleanup must be done slowly and thoroughly.
It may take longer than doing the abatement.
Daily cleanup
1. Wrap large debris in poly.
2. Wet mop or wet sweep small debris and bag it.
3. Check the poly and repair any tears or rips.
4. HEPA vacuum all surfaces.
Wait one hour after finishing abatement before you begin final clean up.
(Check your state and local laws)
Final cleanup must be done slowly and thoroughly
Final cleanup—Stage 1
Every step of final cleanup is important:
1. Wear protective clothing, including a respirator and goggles.
2. Wet mop the entire area and bag all dust.
3. Take up the first layer of poly.
4. HEPA vacuum all surfaces.
5. Wash all surfaces with a cleaning solution and then rinse. Follow state and
local laws about disposal of wash water.
6. HEPA vacuum all surfaces again.
7. Dispose of all cleaning items in sealed 6-mil plastic bags.
Some states require a visual inspection of the abatement job after the first
stage of final cleanup. Wait one hour after finishing final cleanup before
letting the inspector go in.
Final cleanup—Stage 2
Paint and seal all the abated surfaces.
Final cleanup—Stage 3
HEPA vacuum all surfaces. Wash all surfaces with a cleaning solution and rinse
well. HEPA vacuum all surfaces again.
-------
Cleanup, Disposal, & Clearance
Clearance inspection
Two phases: visual inspection and environmental sampling.
Do this no sooner than one hour after final cleanup is done.
Every lead abatement job must pass a final inspection.
Dust wipe tests measure the amount of lead in the house.
If lead dust levels are too high, you must redo cleanup.
EPA allows states and tribes to treat lead-based paint abatement waste as
nonhazardous waste.
Your employer must check with the state or tribe in which the job is being done
to determine whether any restrictions apply to the disposal of residential lead-
based paint waste.
Waste from a lead abatement job
1. Store waste in a locked place until it can be disposed of.
2. Waste should not be removed from the contained area on the job site until
your employer knows if it is hazardous or not.
3. Liquid waste should be filtered before disposal.
4. Hazardous waste can be stored for a limited time (depending on your
employer's generator status) at the company's facility.
Handling nonhazardous waste
Wrap or bag solid waste in 6-mil poly.
Label waste "Lead-Contaminated."
Transport solid waste to a lined dump in a covered truck.
Never burn lead waste.
Do not pour liquid waste down a drain, storm sewer, or onto the ground.
Handling hazardous waste
Store hazardous waste in special, labelled containers.
Use a licensed transporter to take the hazardous waste away.
Hazardous waste must go to a licensed disposal site.
A manifest must go with every shipment of hazardous waste.
-------
Lead Abatement for Workers
For more information
These publications have more information on the topics covered in this chapter. Your
instructor has a copy of the publications marked with a star (*). You can order your own
copies by calling 1-800-424-LEAD.
*EPA, Lead: Identification of Dangerous Levels ofLead; Final Rule-, 40 CFR Part 745
(January 2001).
*EPA, Regulatory Status of Waste Generated by Contractors and Residents from Lead-Based
Paint Activities Conducted in Households, Interpretive Memorandum (July 2000).
EPA, Temporary Suspension of Toxicity Characteristic Rule for Specified Lead-Based Paint
Debris-, 40 CFR Part 745, Subpart P (December 1998).
*HUD, Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in
Housing (June 1995).
RCRA Hotline for information on waste disposal: 1-800-424-9346.
-------
Cleanup, Disposal, & Clearance
Addendum A
EPA Memorandum:
Regulatory Status of Waste Generated by Contractors and
Residents from Lead-Based Paint Activities Conducted in
Households
-------
Lead Abatement for Workers
MEMORANDUM
From: Elizabeth A. Cotsworth, Director
Office of Solid Waste
To: RCRA Senior Policy Advisors
EPA Regions 1-10
Subject: Regulatory Status of Waste Generated by Contractors and
Residents from Lead-Based Paint Activities Conducted in
Households
What is the purpose of this interpretation?
This memorandum clarifies the regulatory status of waste generated as a result of
lead-based paint (LBP) activities (including abatement, renovation and remodeling)
in homes and other residences. Since 1980, EPA has excluded "household waste"
from the universe of RCRA hazardous wastes under 40 CFR 261.4(b)(1). In the
1998 temporary toxicity characteristic (TC) suspension proposal, we clarified that
the household waste exclusion applies to all LBP waste generated as a result of
actions by residents of households (hereinafter referred to as "residents") to
renovate, remodel or abate their homes on their own. (At 63 FR 70233, 70241,
Dec. 18, 1998). In this memorandum, EPA is explaining that we believe lead paint
debris generated by contractors in households is also "household waste" and thus
excluded from the RCRA Subtitle C hazardous waste regulations. Thus, the
household exclusion applies to waste generated by either residents or contractors
conducting LBP activities in residences.
What is the practical significance of classifying LBP waste as a household waste?
As a result of this clarification, contractors may dispose of hazardous-LBP wastes from
residential lead paint abatements as household garbage subject to applicable State
regulations. This practice will simplify many lead abatement activities and reduce their
costs. In this way, the clarification in today's memorandum will facilitate additional
residential abatement, renovation and remodeling, and rehabilitation activities, thus
protecting children from continued exposure to lead paint in homes and making
residential dwellings lead safe for children and adults.
LBP debris (such as architectural building components — doors, window frames,
painted wood work) that do not exhibit the TC for lead need not be managed as
hazardous waste. However, LBP waste such as debris, paint chips, dust, and sludges
generated from abatement and deleading activities that exhibit the TC for lead (that
is, exceed the TC regulatory limit of 5 mg/L lead in the waste leachate), are hazardous
wastes and must be managed and disposed of in accordance with the applicable RCRA
subtitle C requirements (including land disposal restrictions) except when it is
"household waste." Under 40 CFR 261.4(b)(1), household wastes are excluded from
-------
Cleanup, Disposal, & Clearance
the hazardous waste management requirements. Today, EPA is clarifying that waste
generated as part of LBP activities conducted at residences (which include single
family homes, apartment buildings, public housing, and military barracks) is also
household waste, that such wastes are no longer hazardous wastes and that such wastes
thus are excluded from RCRA's hazardous waste management and disposal
regulations. Generators of residential LBP waste do not have to make a RCRA
hazardous waste determination. This interpretation holds regardless of whether the
waste exhibits the toxicity characteristic or whether the LBP activities were performed
by the residents themselves or by a contractor.
Where can I dispose of my household LBP waste?
LBP waste from residences can be discarded in a municipal solid waste landfill
(MSWLF) or a municipal solid waste combustor. Dumping and open burning of
residential LBP waste is not allowed. Certain LBP waste (such as large quantities of
concentrated lead paint waste—paint chips, dust, or sludges) from residential
deleading activities may be subject to more stringent requirements of State, local, and/
or tribal authorities.
What is the basis for this interpretation?
The household waste exclusion implements Congress's intent that the hazardous waste
regulations are "not to be used either to control the disposal of substances used in
households or to extend control over general municipal wastes based on the presence
of such substances." S. Rep. No. 94-988, 94th Cong., 2nd Sess., at 16. EPA
regulations define "household waste" to include "any waste material (including
garbage, trash, and sanitary wastes in septic tanks) derived from households (including
single and multiple residences, hotels and motels, bunkhouses, ranger stations, crew
quarters, campgrounds, picnic grounds and day-use recreation areas)." 40 CFR
261.4(b)(1). The Agency has applied two criteria to define the scope of the exclusion:
(1) the waste must be generated by individuals on the premises of a household, and
(2) the waste must be composed primarily of materials found in the wastes generated
by consumers in their homes (49 FR 44978 and 63 FR 70241).
In 1998, EPA concluded that LBP waste resulting from renovation and remodeling
efforts by residents of households met these criteria. (63 FR 70241-42, Dec. 18,
1998). In short, the Agency found that more and more residents are engaged in
these activities and thus the waste can be considered to be generated by individuals
in a household and of the type that consumers generate routinely in their homes.
Wastes from LBP abatements performed by residents were also considered
household wastes.
EPA clarifies that this interpretation also applies to contractor-generated LBP waste
from renovations, remodeling and abatements in residences. Both the definition of
household waste in section 261.4(b)(1) and the Agency's criteria for determining the
scope of the exclusion focus on the type of waste generated and the place of generation
-------
Lead Abatement for Workers
rather than who generated the waste (e.g., a resident or a contractor). This approach
is consistent with prior Agency policy.1 Since contractor-generated LBP waste from
residential renovations, remodeling, rehabilitation, and abatements are of the type
generated by consumers in their homes, it is appropriate to conclude that such waste,
whether generated by a resident or contractor, falls within the household waste
exclusion. This clarification will facilitate lead abatements and deleading activities
in target housing by reducing the costs of managing and disposing of LBP waste
from residences.
What is the relationship of this interpretation to the on-going LBP debris
rulemaking?
On December 18, 1998, EPA proposed new TSCA standards for management and
disposal of LBP debris (63 FR 70190) and simultaneously proposed to suspend
temporarily the applicability of the RCRA hazardous waste regulations that currently
apply to LBP debris (63 FR 70233). This memorandum responds to stakeholders
requests that EPA clarify whether the existing household waste exclusion applies to both
homeowners and contractors conducting LBP activities in residences. While the Agency
still intends to finalize aspects of the two proposals, we are making this clarification in
advance of the final rule to facilitate LBP abatement in residences without unnecessary
delay.
How does this interpretation affect EPA's enforcement authorities?
Under this clarification, LBP wastes generated by residents or contractors from the
renovation, remodeling, rehabilitation, and/or abatement of residences are household
wastes that are excluded from EPA's hazardous waste requirements in 40 CFR Parts
124, and 262 through 271. The household waste provision of 40 CFR 261.4(b)(1) only
excludes such wastes from the RCRA regulatory requirements. However, it does not
affect EPA's ability to reach those wastes under its statutory authorities, such as RCRA
§3007 (inspection) and §7003 (imminent hazard). See 40 CFR §261.1(b).
1 In the final rule establishing standards for the tracking and management of medical waste, EPA concluded
that waste generated by health care providers (e.g., contractors) in private homes would be covered by the
household waste exclusion (54 FR 12326, 12339, March 24, 1989). In the specific context of LBP, the
Agency stated in a March 1990 "EPA Hotline Report" (RCRA Question 6) that lead paint chips and dust
resulting from stripping and re-painting of residential walls by homeowner or contractors (as part of routine
household maintenance) would be part of the household waste stream and not subject to RCRA Subtitle C
regulations. Similarly, in a March 1995 memorandum on the "Applicability of the Household Waste
Exclusion to Lead-Contaminated Soils, " we found that if the source of the lead contamination was as a result
of either routine residential maintenance or the weathering or chalking of lead-based paint from the residence,
the hazardous waste regulations do not apply so long as the lead-contaminated soil is managed onsite or
disposed offsite according to applicable solid waste regulations and/or state law mandated by RCRA.
-------
Cleanup, Disposal, & Clearance
What are the "best management practices" for handling residential LBP waste?
Although excluded from the hazardous waste regulations, EPA encourages residents and
contractors managing LBP waste from households to take common sense measures to
minimize the generation of lead dust, limit access to stored LBP wastes including debris,
and maintain the integrity of waste packaging material during transfer of LBP waste. In
particular, we continue to endorse the basic steps outlined in the 1998 proposals for the
proper handling and disposal of LBP waste (63 FR 70242) as the best management
practices (BMPs) including:
• Collect paint chips and dust, and dirt and rubble in plastic trash bags for disposal.
• Store larger LBP architectural debris pieces in containers until ready for disposal.
• Consider using a covered mobile dumpster (such as a roll-off container) for storage
of LBP debris until the job is done.
• Contact local municipalities or county solid waste offices to determine where and
how LBP debris can be disposed.
In addition, contractors working in residential dwellings are subject to either one or both
of the following:
• The HUD Guidance for contractors doing publicly-funded rehabilitation/
renovation projects in public housing. (See Guidelines for the Evaluation and Control
of Lead-Based Paint Hazards in Housing. U.S. Department of Housing and Urban
Development, June 1995.) The HUD Guidelines can be accessed via the Internet at:
http: //www. hud. gov/ office/lead
• TSCA 402/404 training and certification requirements. (See 40 CFR Part 745; 61
FR 45778, August 29, 1996) and the proposed TSCA onsite management standards
(See 40 CFR Part 745, Subpart P; 63 FR 70227 - 70230, Dec. 18, 1998). [EPA
expects to issue the final rule next year.]
The above-mentioned BMPs for households are similar to those included in the HUD
Guidelines for individuals controlling LBP hazards in housing. HUD requires that
contractors using HUD funding adhere to LBP hazard control guidelines. Non-
adherence to these guidelines can potentially result in the loss of funding.
Does this interpretation apply in my State and/or locality?
We encourage contractors and residents to contact their state, local and/or tribal
government to determine whether any restrictions apply to the disposal of residential
LBP waste. This verification is necessary since, under RCRA, States, local and tribal
governments can enforce regulations that are more stringent or broader in scope than
the federal requirements. Thus, under such circumstances, LBP waste from households
may still be regulated as a hazardous waste as a matter of State regulations.
-------
Lead Abatement for Workers
We are distributing this memorandum to all 56 States and Territories, and Tribal
Programs and various trade associations. We encourage States to arrange for
implementation of the interpretation discussed in this memo in their States to facilitate
residential LBP abatements making residential dwellings lead-safe. We encourage trade
associations to inform their memberships about this memo and instruct them about
ways to manage residential LBP waste.
Whom should I contact for more information?
If you have additional questions concerning the regulatory status of waste generated
from lead-based paint activities in residences, please contact Ms. Rajani D. Joglekar of
my staff at 703/308-8806 or Mr. Malcolm Woolf of the EPA General Counsel's Office
at 202/564-5526.
cc: Key RCRA Contacts, Regions 1-10
RCRA Regional Council Contacts, Regions 1-10
RCRA Enforcement Council Contacts, Regions 1-10
Association of State and Territorial Solid Waste Management Officials
(ASTSWMO)
-------
CHAPTER 9
Soil Abatement and Exterior Dust Cleanup
Learning objectives 9-3
Soil abatement and exterior dust cleanup 9-4
Soil-lead hazards 9-4
Soil abatement 9-5
Exterior dust cleanup 9-7
Key facts for Chapter 9 9-8
For more information 9-9
-------
Lead Abatement for Workers
-------
Soil Abatement and Exterior Dust Cleanup
Learning objectives
In this chapter you will learn
• why lead in soil is a health hazard
• what levels of lead in residential bare soil are considered hazards
• how lead exposure from soil can be controlled
-------
Lead Abatement for Workers
Soil abatement and exterior dust cleanup
Bare soil with high lead levels is a major health hazard, especially to children. Lead-
contaminated soil could be a hazard because children may play in or near it, and dirt
tracked into a home can lead to increased lead dust levels in the home. Government
agencies used to recommend removing and replacing six to 24 inches of soil that
contained high lead levels. However, studies have shown this process to be very costly
and not to be a very effective way to reduce the blood lead levels of children living in
these areas. Often, the best approach is to remove two to three inches, and then test the
new lead levels of remaining soil. If the levels of lead are still high, more soil may need to
be removed. Some states require abated soil to be tested to see if it is a hazardous waste.
If the soil has low levels of lead, the best method is to reduce access to the bare soil. This
can be done by planting grass, laying sod, or covering the area with mulch. Activities
such as these are called interim controls, because they are temporary methods of
minimizing exposure to the lead in the soil.
Gardens grown in soil contaminated with lead can also be a health risk. Leafy vegetables
and vegetables that grow under ground (such as carrots and potatoes) can absorb lead.
These vegetables can then be eaten by people.
Soil abatement and exterior dust cleanup are considered together because they will likely
occur together in abatement projects. Since soil abatement will tend to contaminate
immediately adjacent paved areas, these paved areas should then be cleaned.
Soil-lead hazards
A soil-lead hazard is present in bare residential soil:
• in a play area when the soil-lead concentration is equal to or greater than 400 parts
per million;
• from the rest of the yard (i.e., non-play areas) when the average soil-lead concentration
of samples collected is equal to or greater than 1,200 parts per million.
It is important to remember that your state/Indian tribe may establish different levels of
lead in soil which are considered a soil-lead hazard. Your supervisor or employer is
responsible for following the applicable standards!
Removal and
replacement of
soil can be
expensive.
Interim controls
for soil-lead
hazards include
planting grass,
laying sod, or
using mulch.
A soil-lead
hazard in bare
soil is:
• 400 ppm in a play
area;
• average of
1,200 ppm in the
rest of the yard.
9-4
-------
Soil Abatement and Exterior Dust Cleanup
Soil abatement
Lead-contaminated soil in residential areas can be treated in two main ways:
• abatement by
removing and replacing the contaminated soil with clean soil, or
permanently covering the contaminated soil with concrete or asphalt;
• interim controls such as
covering with several inches of clean soil or mulch, or planting sod or grass.
The depth of soil removed during an abatement project is an important issue. In projects
where there are extremely hazardous materials or chemicals which may contaminate the
ground water, all contaminated soil is generally removed or physically isolated at the site.
Soil contaminated with less hazardous materials, such as lead from lead-based paint, may
either be removed or partially removed and topped with "clean" soil.
Removal and replacement is the
most common abatement
strategy for lead-contaminated
soil. Before beginning a soil
removal project, make sure your
supervisor has shown you where
any buried utility lines are
located. Your employer is
required to find out if and where
any buried cable, telephone,
water, or electrical lines are
located before you start digging.
Removal and replacement of soil in residential abatement situations may involve
working in both large and small sites. Some urban yards are very small, consisting of
only a few square yards in some cases. Other urban yards
are larger but they are sometimes surrounded by
buildings. Because of this, residential soil abatement will
often require extensive hand labor in addition to
mechanical soil removal. When soil is removed by hand,
it can be loaded into wheelbarrows. The soil in the
wheelbarrows must then be taken to other vehicles to be
transported to the disposal site.
-------
Lead Abatement for Workers
EPA requires that if soil removal and replacement is done, then the replacement soil
must have a lead concentration as close to the local soil background levels as possible,
but cannot be more than 400 ppm lead. The soil that is removed cannot be used as top
soil at another residential property or child-occupied facility. Your employer or
supervisor is required to properly dispose of the contaminated soil.
Contaminated
soil removed
from a soil
abatement
project cannot be
used as top soil
at another
residential
property or child-
occupied facility!
Sometimes it is difficult to locate large amounts of soil with low enough levels of lead. In
those situations, or in cases when removal and replacement is too costly, the lead-
contaminated soil may be permanently covered by concrete or asphalt. Concrete or
asphalt is an approved method of abatement for lead-contaminated soil.
9-6
-------
Soil Abatement and Exterior Dust Cleanup
Exterior dust cleanup
Exterior dust cleanup would be more likely to occur alone, whereas, soil abatement is
always followed by exterior dust cleanup. It could possibly be performed for a
neighborhood area as part of a cleanup after an improper lead-based paint abatement in
which a neighborhood was contaminated. This could result from a contractor or owner
burning, sand blasting, or dry sanding lead-based paint from a structure. It could also be
performed periodically where the exterior dust was contaminated by industrial or
mining-related operations.
Exterior dust cleanup is an important abatement strategy because of the amount of lead
in some street dust, and because contaminated dust is considered to be the primary
exposure source. Just as children can be directly exposed to soil lead, they can also be
exposed to exterior dust lead. Exterior dust can enter homes in several ways. Exterior
dust lead concentrations over 100,000 ppm (equal to 10 percent lead in dust) have been
measured in urban areas.
Cleaning up exterior dust consists of removing as much dust and dirt as possible from all
paved surfaces within the abatement area. Lead-contaminated dust can be found on
paved surfaces such as streets, street gutters, sidewalks, alleys, patios, and parking lots.
The paved surfaces exist in a variety of materials. Commonly used paving materials are
asphalt, concrete, and paving bricks. Surfaces such as old brick-paved alleys present the
biggest challenge in removing street dust.
Cleaning up
exterior dust
consists of
removing as
much dust and
dirt as possible
from all paved
surfaces within
the abatement
area.
9-7
-------
Lead Abatement for Workers
Key facts for Chapter 9
High levels of lead in soil can be a major health hazard, especially to
children.
Children may play in or near lead-contaminated soil and track it back into the
home.
Pets can also track it into the home.
Gardens grown in lead-contaminated soil can also be a health risk.
Soil-lead hazard levels are set by EPA or your state or Indian tribe.
A soil-lead hazard* is present in bare soil:
in a play area when the soil-lead concentration is equal to or greater than
400 parts per million;
from the rest of the yard (i.e., non-play areas) when the average of samples
collected is equal to or greater than 1,200 parts per million.
* Your employer must check with the state or Indian Tribe in which the work is
being done to see if they have set different soil-lead hazard levels.
Lead-contaminated soil in residential areas can be treated in two main ways:
Abatement—either removal and replacement or covering the soil with concrete
or asphalt.
Replacement soil must have lead levels close to the local background levels,
but not more than 400 ppm.
Make sure all underground utilities have been marked before you dig!
Interim controls—laying sod, planting grass, and mulching.
Exterior dust cleanup is usually done after soil abatement because soil
abatement typically causes surrounding concrete areas to become
contaminated.
-------
Soil Abatement and Exterior Dust Cleanup
For more information
These publications have more information on the topics covered in this chapter. Your
instructor has a copy of the publications marked with a star (*). You can order your own
copies by calling 1-800-424-LEAD.
*EPA, Lead: Identification of Dangerous Levels ofLead; Final Rule; 40 CFR Part 745
Qan 2001).
*EPA, Lead: Requirements for Lead-Based Paint Activities in Target Housing and Child-
Occupied Facilities-, 40 CFR Part 745 (August 1996).
EPA, Applicability ofRCRA Disposal Requirements to Lead-Based Paint Abatement Wastes
(March 1993).
*HUD, Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in
Housing (June 1995).
*OSHA, Interim Final Lead in Construction Standard, 29 CFR 1926.62 (May 1993).
-------
Lead Abatement for Workers
-------
CHAPTER 10
Glossary and Resources
-------
Lead Abatement Worker
Abatement Any measure or set of measures designed to permanently
eliminate lead-based paint hazards.
ABC-rated fire Fire extinguishers are rated according to the type of fire
extinguisher they are used on: Class A for paper and wood, Class B for
more flammable materials such as liquids or greases, and Class
C for electrical fires. An ABC-rated fire extinguisher puts out
all of these kinds of fires. An ABC-rated fire extinguisher is
recommended for work sites.
Accessible surface An interior or exterior surface that a young child can reach—
such as a window sill—to chew or put its mouth on.
Accreditation A formal recognition that an organization, such as a
laboratory, is qualified to carry out specific tasks or types of
tests.
Action level The level at which an employer must begin certain compliance
activities outlined in the OSHA lead standard. The action
level, regardless of respirator use, for the lead in construction
standard is an airborne concentration of 30 |ig/m3 calculated as
an 8-hour time-weighted average (TWA).
Acute effect Severe or immediate reaction, usually to a single large exposure
to a toxin or substance.
Adequate quality Means a plan or design which ensures the
control authenticity, integrity, and accuracy of samples, including
dust, soil, and paint chip or paint film samples. Adequate
quality control also includes provisions for representative
sampling.
AIHA American Industrial Hygiene Association.
Anemia A condition where there is not enough iron in your blood.
Anemia makes people very tired.
Anodic stripping An analytical method for identifying small amounts of metals
voltametry (ASV) within a substance. The charged atoms of the metal (e.g., lead) in
a solution are attracted to an electric probe. After the charged
atoms collect upon the probe, they are stripped off and measured.
-------
Glossary
Atomic absorption
spectroscopy (AAS)
A method of measuring elements such as lead. The lead
is turned into a gas at high temperatures, usually several
thousand degrees, and light of a very specific wave length is
passed through the vapor. The instrument measures how
concentrated the lead is in the test material.
Biological The analysis of a person's blood and/or urine to determine
monitoring the level of a contaminant, such as lead, in the body.
Blank
Blind sample
Body burden
Building
component
An unused sample of the medium being used for testing (i.e.,
wipe or filter) that is tested to determine if the medium has
been contaminated with lead (e.g., at the factory or during
transport).
A sample submitted for analysis when the sample and its
elements are known to the submitter but not to the analyst.
This is done to test the laboratory analyst's accuracy and skill
in analyzing samples. (See also "spiked sample").
The total amount of a substance that is deposited in the entire
body. Metal substances, such as lead and mercury, tend to
accumulate in the kidneys, the liver, and especially the bones.
Any part of a building that may be painted or
have dust on its surface, e.g. walls, stair treads, floors, railings,
doors, window sills, etc.
Calcium A nutrient that helps make bones strong. If you do not have
enough calcium in your diet, your body will absorb more lead.
Carcinogen A substance that can cause cancer.
Certified Describes people who have completed training and other
requirements to allow them to safely perform risk assessments,
inspections, or abatement work.
Certified firm A company, partnership, corporation, sole proprietorship,
association, or other business entity that performs lead-based
paint activities to which a state agency or EPA has issued a
certificate of approval.
-------
Lead Abatement Worker
Certified inspector An individual who has been trained by an accredited training
program and certified by a state agency or by EPA to conduct
inspections. A certified inspector also samples for the presence
of lead in dust and soil for the purposes of clearance testing
after abatement has been performed.
Certified An individual who has been trained by an accredited training
abatement worker program and certified by a state agency or by EPA to perform
abatements.
Certified project
designer
An individual who has been trained by an accredited training
program and certified by a state agency or by EPA to prepare
abatement project designs, occupant protection plans, and
abatement reports.
Certified risk
assessor
An individual who has been trained by an accredited training
program and certified by a state agency or by EPA to conduct
risk assessments. A risk assessor also samples for the presence of
lead in dust and soil for the purposes of abatement clearance
testing.
Certified An individual who has been trained by an accredited training
supervisor program and certified by a state agency or by EPA to supervise
and conduct abatement projects, and to prepare occupant
protection plans and abatement reports.
CFR—The Code of
Federal
Regulations
The regulations of the various federal agencies arranged into a
numbered sequence for easy referral
Chalking The effect of light and oxygen on paint binders—usually due to
weathering—that causes a powder to form on the film surface.
Characteristics EPA has identified four characteristics of a hazardous waste:
ignitable; corrosive; reactive; and toxic. Any solid waste that
exhibits one or more of these characteristics is classified as a
hazardous waste under RCRA.
Chelation therapy The medical treatment in which a drug that is attracted to
metals (such as lead) is infused into a patient's vein. The drug
binds to the metal in the blood, and both are passed by the
kidney in urine.
-------
Glossary
Chemical stripping The use of chemicals to strip off paint. Chemical stripping is
usually done with solvents or corrosive pastes.
Chewable surface An interior or exterior surface painted with lead-based paint
that a young child can mouth or chew. A chewable surface is
the same as an "accessible surface" as defined in 42 U.S.C.
4851b(2)). Hard metal substrates and other materials that
cannot be dented by the bite of a young child are not
considered chewable.
Child-occupied A building, or portion of a building, constructed before 1978
facility that is visited regularly by the same child, 6 years of age or
under, 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 total at least 6
hours, and the combined annual visits total at least 60 hours.
Child-occupied facilities may include, but are not limited to,
day-care centers, preschools and kindergarten classrooms.
Chronic effect A response to exposure which may take days, months or years
to develop.
Clearance Visual examination and collection of environmental
examination samples by an inspector or risk assessor and analysis by an
accredited laboratory upon completion of an abatement
project, interim control intervention, rehabilitation, or
maintenance job that disturbs lead-based paint.
Clearance levels Values that indicate the maximum amount of lead permitted
in dust on a surface following completion of an abatement
activity.
cm Centimeter; 1/100 of a meter. There are about 2.5 cm in one
inch.
Code of Federal
Regulations (CFR)
Same as CFR.
-------
Lead Abatement Worker
Common area A portion of a building that is generally accessible to all
occupants. Such an area may include, but is not limited to,
hallways, stairways, laundry and recreational rooms,
playgrounds, community centers, garages, and boundary
fences.
Competent person One who is capable of identifying existing and possible lead
hazards in the surroundings or working conditions and who
has the authority to take prompt corrective measures to
eliminate them.
Component or Specific design or structural elements or fixtures of
building a building, residential dwelling, or child-occupied
component facility that are distinguished from each other by form,
function, and location. These include, but are not limited to,
interior components such as: ceilings, crown molding, walls,
chair rails, doors, door trim, floors, fireplaces, radiators and
other heating units, shelves, shelf supports, stair treads, stair
risers, stair stringers, newel posts, railing caps, balustrades,
windows and trim (including sashes, window heads, jambs,
sills or stools and troughs), built-in cabinets, columns, beams,
bathroom vanities, counter tops, and air conditioners; and
exterior components such as: painted roofing, chimneys,
flashing, gutters and downspouts, ceilings, soffits, fasciae
boards, rake boards, cornerboards, bulkheads, doors and door
trim, fences, floors, joists, lattice work, railings and railing
caps, siding, handrails, stair risers and treads, stair stringers,
columns, balustrades, window sills or stools and troughs,
casings, sashes and troughs, and air conditioners.
Compliance The written program that is required under
program the OSHA Lead Standard for your employer to have before
beginning a job where lead is present.
Composite sample
A single sample made up of individual subsamples. Analysis of
a composite sample produces the average data for all
subsamples.
Containment A process to protect workers and the environment by
controlling exposures to the lead-contaminated dust and debris
created during an abatement project.
-------
Glossary
COSH Short for "Committee (or Coalition) on Occupational Safety
and Health." A COSH group is a group of unions, workers,
and professionals working together for safer and healthier
working conditions.
Deciliter (dL) The unit of measure for blood lead levels. The prefix "deci-"
means "one-tenth." One deciliter is roughly the same as about
one-tenth of a quart, or about 3.4 fluid ounces.
Demolition The removal of walls (plaster or gypsum) or building
components (windows or doors) by sledge hammer or similar
tool. If the surfaces are covered with lead-based paint,
demolition will create high levels of lead dust. This is a Class 1
Task under the OSHA lead standard.
Detection limit The minimum amount of a substance that can be reliably
measured by a particular method.
Deteriorated paint any interior or exterior paint or other coating that is peeling,
chipping, chalking or cracking, or any paint or coating located
on an interior or exterior surface or fixture that is otherwise
damaged or separated from the substrate.
Direct-reading An analyzer that displays lead concentrations as
XRF calculated from the lead K X-ray intensity without a picture of
the spectrum. Usually expressed in mg/cm2.
Dripline Dripline means the area within three feet surrounding the
perimeter of a building.
Dust-lead hazard A dust-lead hazard is surface dust in a residential dwelling or
child-occupied facility that contains a mass-per-area
concentration of lead equal to or exceeding 40 (ig/ft2 on floors
or 250 (ig/ft2 on interior window sills based on wipe samples.
Dust removal A form of interim control that involves initial cleaning
followed by periodic monitoring and recleaning, as needed.
Dwelling unit The room or group of rooms within a residential premises used
or intended for use by one family or household for living,
sleeping, cooking and eating.
-------
Lead Abatement Worker
EBL child See Elevated blood lead level (EBL).
Efflorescence When salt rises to the surface of a material, such as masonry,
plaster, or cement, caused by the movement of water through
the material. Paint or encapsulants may not adhere to a surface
contaminated with efflorescence.
Environmental
intervention blood
lead level (EIBLL)
A confirmed concentration of lead in whole blood
equal to or greater than 20 |ig/dL (micrograms
of lead per deciliter) for a single test or 15—19 pg/dL in two
tests taken at least three months apart.
Elevated blood
lead level (EBL)
An excessive absorption of lead in a child.
Determined by a confirmed concentration of lead in whole
blood of 20 (ig/dL (micrograms of lead per deciliter of whole
blood) for a single venous test or of 15-19 pg/dL in two
consecutive tests taken three to four months apart.
Encapsulant A substance that forms a barrier between lead-based paint and
the environment. Usually a liquid-applied coating (with or
without reinforcement materials) or a covering material
applied with an adhesive.
Encapsulation The application of an encapsulant. One method of abatement.
Enclosure Rigid, durable construction materials that are mechanically
fastened to the substrate in order to act as a dust-tight barrier
between lead-based paint and the environment. One method
of abatement.
Engineering Changes that can be made in the work environment
controls to reduce hazards on the job. OSHA requires employers to
make changes in the workplace environment whenever
possible to protect worker health and safety.
EPA—
Environmental
Protection Agency
A federal agency that studies environmental
problems and develops regulations to protect
human health and the environment.
Evaluation
Risk assessment, paint inspection, reevaluation, investigation,
clearance examination, or lead hazard screen.
-------
Glossary
Exposure Air monitoring within an employee's breathing
monitoring zone to determine the amount of contaminant (e.g., lead) to
which he/she is exposed.
Exterior work area An exterior paved area, soil area, outdoor porch, stairway or
other element of trim or walls on the exterior of a building.
A document published daily by the federal
(FR) government that contains either proposed or final regulations
or notices.
Fetus An unborn baby from 7 to 8 weeks after fertilization up until birth.
Field blank A clean sample of the medium used for testing (e.g., filter or
wipe) that has been exposed to the sampling conditions,
returned to the laboratory, and analyzed as an environmental
sample.
Final medical The written opinion given by a doctor that a worker
determination be removed from lead exposure.
Friction surface An interior or exterior building surface subject to abrasion or
friction, such as a window or stair tread.
Generator Any person whose act or operation produces hazardous waste
identified or listed in 40 CFR Part 261 or whose act causes a
hazardous waste to come under regulation (40 CFR 260.10).
GFCI Short for "ground fault circuit interrupter." This is a very
sensitive switch which your employer can use to prevent
workers from getting an electrical shock. Each extension cord
should have its own GFCI.
Gram A metric unit of weight. A penny weighs about two grams.
The abbreviation for gram is "g."
Hazardous waste Any waste as defined in 40 CFR 261.3 (RCRA). RCRA's
definition means a solid waste, or combination of solid wastes,
which because of its quantity, concentration, or physical,
chemical, or infectious characteristics may (a) cause, or
significantly contribute to, an increase in mortality or an
increase in serious irreversible, or incapacitating reversible,
illness; or (b) pose a substantial present or potential hazard to
human health or the environment or when improperly treated,
stored, transported, or disposed of, or otherwise managed.
-------
Lead Abatement Worker
Heat gun
HEPA or High
Efficiency
Particulate
Air Filter
HEPA vacuum
Housing receiving
Federal assistance
HUD—
Department of
Housing and
Urban Development
HVAC system
Impact surface
Indian Housing
Authority (IHA)
Industrial
hygienist
Initial medical
surveillance
A device capable of heating lead-based paint, causing it to
separate from the substrate.
A filter that is 99-97% efficient at filtering out particles of
0.3 microns or greater from a body of air.
A vacuum cleaner which filters air through a HEPA filter.
Housing which is covered by an application for
HUD mortgage insurance, receives housing assistance
payments under a program administered by HUD, or
otherwise receives more than $5,000 in project-based
assistance under a Federal housing program administered by
an agency other than HUD.
This federal agency regulates public and some federal assisted
housing. HUD published the Guidelines for the Evaluation
and Control of Lead-based Paint Hazards in Housing which
provide guidance on all aspects of lead-based paint detection
and abatement.
The heating, ventilating, and air-conditioning system in any
building. The HVAC system should always to turned off
before lead abatement work begins.
An interior or exterior building surface that is subject to
damage by repeated sudden force, such as certain parts of door
or window frames.
A public housing agency established (a) by exercise
of a tribe's powers of self-government independent of state law,
or (b) by operation of state law providing specifically for
housing authorities of Native Americans.
A person who is trained and experienced in looking
for safety and health hazards in the workplace and determining
the impact of those hazards on the community and workers.
A set of special blood tests required by OSHA's Interim Final
Lead in Construction standard when working with lead. This
is also referred to as biological monitoring.
-------
Glossary
Inspection
In-place
management
Interim controls
Interior window
sill
Laboratory
analysis
Latex paint
Lead (inorganic)
Lead-accredited
laboratory
Lead-based paint
A surface-by-surface investigation to determine the presence of
lead-based paint. A report is then issued that identifies if there
is lead-based paint present and where it is located.
See interim controls.
A set of measures designed to temporarily reduce human
exposure or likely exposure to lead-based paint hazards. They
may include specialized cleaning, repairs, maintenance, painting,
temporary containment, ongoing monitoring of lead-based
paint hazards or potential hazards, and the establishment and
operation of management and resident education programs.
The portion of the horizontal window ledge that protrudes
into the interior of the room, adjacent to the window sash
when the window is closed; often called the window stool.
A determination of the lead content in a sample by
specific laboratory equipment and methods.
A waterborne emulsion paint made with synthetic binders such
as 100-percent acrylic, vinyl acrylic, terpolymer, or styrene
acrylic; a stable emulsion of polymers and pigment in water.
An element, represented by the symbol Pb. Its atomic structure
is permanently arranged and is not changed by chemical
reactions. Lead can combine chemically with other atoms or
molecules to make new compounds. Lead is considered a
heavy metal; "heavy" because lead weighs more that the same
volume of water, and "metal," because when it is refined from
raw ore into its pure form, lead can be hammered or drawn
into shapes.
A laboratory that has been evaluated and received
accreditation through EPA's National Lead Laboratory
Accreditation Program (NLLAP) to perform lead measurement
or analysis, usually over a specified period of time.
Paint or other surface coatings that contain lead equal to or in
excess of 1.0 milligrams per square centimeter or more than
0.5 percent by weight.
-------
Lead Abatement Worker
Lead-based paint In the case of target housing and child-occupied facilities:
activities inspection, risk assessment, and abatement.
Lead-based paint
hazard
hazardous lead-based paint, dust-lead hazard or soil-lead
hazard as identified in §745-65- (See also paint-lead hazard,
dust-lead hazard and soil-lead hazard.)
Lead-based paint Activities to control and eliminate lead-based paint hazards,
hazard control including interim controls and abatement.
Lead-based paint- Describes a rental dwelling certified by a certified lead-based
free certification paint inspector to contain no lead at or above 1.0 mg/cm2.
Lead-based paint
hazard-free
dwelling
A dwelling that contains no lead-based paint and has interior
dust and exterior soil lead levels below the applicable EPA or
state/Indian Country standards.
Lead-hazard A limited risk assessment activity that involves limited paint
screen and dust sampling.
Lead-specific A cleaning agent manufactured specifically for cleaning and
detergent removing leaded dust or other lead contamination.
m3 Short for "cubic meter." It is a metric unit of volume. You
breathe between 1 and 2 cubic meters of air every hour when
you are working. A cubic meter is about the size of a blue U.S.
Post Office box.
Manifest The shipping document—EPA form 8700-22— your
employer will use for identifying the quantity, composition,
origin, routing, and destination of hazardous waste during its
transport from the point of generation to the point of
treatment, storage, or disposal.
Medical removal
Medical removal
protection
The temporary removal of workers due to elevated blood lead levels
as defined in the OSHA Lead Standard (currently 50 |ig/dL).
Your employer must pay your salary if you are
medically removed from a lead abatement job. Your employer
must pay you as long as the job exists or up to 18 months.
-------
Glossary
Medical
surveillance
program
mg
mg/ cm2
Micrograms
Multifamily
dwelling
NIOSH
Occupational
Off-site paint
removal
On-site paint
removal
OS HA—
Occupational
Health and Safety
Administration
A special program of medical exams an employer must make
available to workers under the OSHA lead standard.
Milligram. There are one thousand milligrams in a gram.
Milligrams (mg) per square centimeter (cm2). When surfaces
are tested for lead using an XRF analyzer, the amount of lead is
measured in milligrams of lead per square centimeter (mg/
cm2). When a paint chip sample is taken from a measured
area, the results may also be provided in mg/cm2.
One millionth of a gram: |ig; the prefix "micro-" means "1/
1,000,000 of' (one millionth of).
A building that contains more than four separate
residential dwelling units. One or more persons may live in
each unit.
National Institute for Occupational Safety and Health. A
federal agency which does research and suggests new laws on
occupational health and safety to OSHA. NIOSH tests and
certifies respirators.
Having to do with the workplace and working.
The removal of paint at a site away from the
abatement project, such as stripping lead-based paint from the
surface of a component (e.g., a door) at the facilities of a
commercial paint-stripping operation. Such procedures are
often performed in chemical tanks.
The removal of lead-based paint down to the bare
substrate usually through heat, chemical or mechanical means.
The affected surface/component usually remains in place on
the premises during this removal process.
The main federal agency that issues and enforces
safety and health standards in the workplace.
Paint chip sample
A sample of paint that is removed from a surface (down to the
substrate) and analyzed for lead content.
-------
Lead Abatement Worker
Paint-lead hazard
A paint-lead hazard is any of the following: (1) Any lead-based
paint on a friction surface that is subject to abrasion and where
the lead dust levels on the nearest horizontal surface
underneath the friction surface (e.g., the window sill, or floor)
are equal to or greater than the dust-lead hazard levels
identified in paragraph (b) of this section. (2) Any damaged or
otherwise deteriorated lead-based paint on an impact surface
that is caused by impact from a related building component
(such as a door knob that knocks into a wall or a door that
knocks against its door frame. (3) Any chewable lead-based
painted surface on which there is evidence of teeth marks. (4)
Any other deteriorated lead-based paint in any residential
building or child-occupied facility or on the exterior of any
residential building or child-occupied facility.
Paint testing The determination of the presence or the absence of lead-based
paint on deteriorated paint surfaces or painted surfaces to be
disturbed. Paint testing must be done by certified lead-based
paint inspector or risk assessor.
Performance A document developed by EPA and HUD that
characteristic provides information on portable XRF instruments,
sheet (PCS) The PCS describes how to calibrate the XRF, tells when test
results may not provide a valid analysis, and gives other
important information about the XRF.
Permanently Soil that has been separated from human contact
covered soil by the placement of a barrier consisting of solid, relatively
impermeable materials, such as pavement or concrete. Grass,
mulch, and other landscaping materials are not considered
permanent covering.
Permissible
exposure
limit
(PEL)
The maximum worker exposure to lead under the
OSHA lead in construction standard. No employee
may be exposed to lead at airborne concentrations
greater than 50 |ig/m3 averaged over an 8 hour period.
Personal Equipment for protecting the eyes, face, head,
protective and/or arms and legs. Includes protective clothing,
equipment respiratory devices, and protective shields: PPE is
(PPE) used when hazards are encountered that may cause bodily
injury or impairment.
-------
Glossary
Personal samples Air samples collected from within the breathing zone of a
worker, but outside the respirator. The samples are collected
with a personal sampling pump, pulling one to four liters/
minute of air.
Physician or other
licensed health
care provider
(PLHCP)
Pigments
an individual whose legally permitted scope of
practice (i.e., license, registration, or certification)
allows him or her to independently provide, or
be delegated the responsibility to provide some or all of the
health care services required by the medical evaluation section
of OSHA's respiratory protection standard [1910.134(e)].
Chemicals that have color or properties which affect color.
Usually, a small amount of these chemicals is mixed with
another material to color all of the material. Lead carbonate
and lead oxide are chemical forms of lead used as pigments.
Play area An area of frequent soil contact by children of less than six
years of age, as indicated by the presence of play equipment or
toys or other children's possessions, observations of play
patterns, or information provided by parents, residents or
property owners.
Poly Short for polyethylene sheet plastic. This is a plastic sheet that
is used to protect surfaces while lead-based paint abatement or
interim controls are being done.
ppm "Parts per million," meaning the weight of one part per weight of
the total amount of material. For example, a lead concentration of
1 ppm expresses the ratio of one gram of lead dissolved into one
million (1,000,000) grams of water.
Primary The process of controlling lead hazards to prevent
prevention exposure before a child is poisoned.
Public Housing
Agency (PHA)
Quality assurance
(QA)
Any state, county, municipality, or other governmental
entity or public body (or agency or instrumentality thereof)
which is authorized to engage or assist in the development or
operation of housing for low income families.
A system of activities involving planning, quality control,
quality assessment, reporting, and quality improvement to
ensure that a product or service meets defined standards of
quality within a stated level of confidence.
-------
Lead Abatement Worker
Quality control
(QC)
Random sample
RCRA
Reevaluation
Regulation or Rule
Renovation
Representative
sample
Residential
dwelling
The overall system of technical activities whose purpose is
to measure and control the quality of a product or service so that it
meets the needs of users. The aim is to provide a level of quality
that is satisfactory, adequate, dependable, and economical.
A sample drawn from a population in a way that allows each
member of the population to have an equal chance of being
selected. Random sampling is a process used to identify locations
for the lead-based paint inspections in multifamily dwellings.
Resource Conservation and Recovery Act of 1976. What we
commonly refer to as RCRA is an amendment to the Solid
Waste Disposal Act of 1965. RCRA was amended in 1980
and 1984 by the Hazardous and Solid Waste Amendments.
In lead hazard control work, the combination of a visual
assessment and collection of environmental samples performed
by a certified risk assessor to determine if a previously
implemented lead-based paint hazard control measure is still
effective and if the dwelling remains lead-safe.
All or part of any federal statement of general or particular
applicability and future effect designed to: (1) implement,
interpret, or prescribe law or policy or (2) describe the federal
Department's organization or its procedure or practice
requirements.
Work that involves construction tasks such as window replacement,
weatherization, remodeling, or modification of any existing
structure that results in the disturbance of painted surfaces.
A sample of a material to be disposed of (e.g., painted
components, waste sample pile, or waste stream) which can be
expected to exhibit the average properties of that type of debris.
(1) A detached single family dwelling unit, including
attached structures such as porches and stoops; or (2) a single
family dwelling unit in a structure that contains more than one
separate residential dwelling unit in which one or more people
may live.
Resident
A person who lives in a dwelling.
-------
Glossary
Risk assessment An on-site investigation to determine the existence, nature,
severity, and location of lead-based paint hazards. The risk
assessor will provide a report explaining the results of the
investigation and how to reduce the lead-based paint hazards.
Room equivalent An identifiable part of a residence, such as a room, a house
exterior, a foyer, staircase, hallway, or an exterior area (exterior
areas contain items such as play areas, painted swing sets,
painted sandboxes, etc.). Closets or other areas adjoining room
equivalents should be designated room equivalents only if large.
Sample site A specific spot on a surface being tested for lead concentration
or contamination.
Screening The process of testing children to determine if they have
elevated blood lead levels.
Secondary The process of identifying children who have
prevention elevated blood lead levels through screening, and then
controlling or eliminating the sources of further exposure.
Sodium A chemical used to test a paint sample for the
rhodizonate presence of lead. A positive test is characterized by
a pink or red discoloration of the paint film cross section or of
the applicator tip.
Sodium sulfide A chemical used to test a paint sample for the presence of lead.
A positive test is characterized by a gray or black discoloration
of the paint film cross section.
Soil-lead hazard A soil-lead hazard is bare soil on residential real property or on
the property of a child-occupied facility that contains total lead
equal to or exceeding 400 parts per million ((ig/g) in a play
area or average of 1,200 parts per million of bare soil in the
rest of the yard based on soil samples.
Solid waste As defined in RCRA means any garbage, refuse, sludge from a
waste treatment plant, water supply treatment plant, or air
pollution control facility and other discarded material,
including solid, liquid, semisolid, or contained gaseous
material resulting from industrial, commercial, mining, and
agricultural operations, and from community activities. Does
not include solid or dissolved material in domestic sewage, or
solid or dissolved materials in irrigation return flows or
industrial discharges which are point sources subject to permits
under the Clean Water Act, or special nuclear or by-product
material as defined by the Atomic Energy Act of 1954.
-------
Lead Abatement Worker
Spectrum A type of XRF analyzer which provides the operator
analyzer with a plot of the energy and intensity of both "K"
XRF and "L" X-rays, as well as a calculated lead concentration.
Spiked sample A sample prepared by adding a known mass of the substance
to be analyzed (e.g., leaded dust) to a specific amount of matrix
sample (e.g., one dust wipe). The known concentration of the
substance to be analyzed is compared against the laboratory's
results to check for accuracy.
Standard Used in two ways in this manual: (a) levels established by law
or regulation, such as 1.0 mg/cm2; (b) materials to which
known quantities of lead have been applied; used to evaluate
the accuracy and performance of the XRF analyzer, usually
called Standard Reference Materials.
Storage The holding of hazardous waste for a temporary period, after
which the hazardous waste is treated, disposed of, or stored
elsewhere.
Subsample A representative portion of a sample. A subsample may be either a
field sample or a laboratory sample. A subsample is often
combined with other subsamples to produce a composite sample.
Substrate A surface upon which paint or varnish has been or may be
applied. Examples included in the HUD Guidelines are: wood,
plaster, metal, brick, drywall, and concrete. Substrates can
contain lead absorbed from paint or from other sources.
Substrate Reducing the apparent lead reading by the level
correction attributable to the substrate. The substrate correction level is
determined by taking a total of 6 readings on two different
locations of each bare substrate. The Performance
Characteristic Sheet must be consulted to determine if
substrate correction is needed for the analyzer being used.
Substrate effect The returning of backscattered radiation from the paint,
substrate or underlying material to the XRF analyzer. When
counted as lead X-rays by an XRF, this radiation contributes to
the bias. The inspector may have to adjust for this effect when
using some XRF analyzers.
Tack cloth
A soft, sticky, lint-free cloth used to clean dust off of surfaces
that cannot be washed.
-------
Glossary
Target housing
Tertiary
prevention
Testing
combination
Title X (10)
T oxicity
characteristic
leachate
procedure (TCLP)
Trisodium
phosphate (TSP)
detergent
Trough
re
Visual assessment
Visual inspection
Visual
examination
Any housing constructed prior to 1978, except housing for the
elderly or persons with disabilities (unless any one or more
children age 6 years or under resides or is expected to reside in
such housing for the elderly or persons with disabilities) or any
0-bedroom dwelling (e.g. dormitory, studio apartment).
Providing medical treatment to children with elevated blood
lead levels to prevent more serious injury or death.
A unique surface to be tested that is characterized
by the room equivalent, component, and substrate type.
The Residential Lead Hazard Reduction Act of 1992. It
requires the government to regulate people's exposure to lead
much more closely than had been done in previous years.
One of the tests for the determination of whether a
solid waste is classified as a hazardous substance.
A detergent that contains trisodium phosphate.
See window trough.
Microgram. The prefix "micro-" means 1/1,000,000 (or one
millionth); a microgram is 1/1,000,000 of a gram and 1/1,000
of a milligram; equal to about 35 billionths of an ounce.
Looking for (1) deteriorated paint; (2) visible surface dust,
debris and residue as part of a risk assessment or clearance
examination; or (3) the completion or failure of a hazard
reduction measure.
The visual examination of a residential dwelling or a child-
occupied facility following an abatement to determine whether
or not the abatement has been successfully completed.
The examination of a residential dwelling or a child-
occupied facility to determine the existence of deteriorated lead-
based paint or other potential sources of lead-based paint hazards.
-------
Lead Abatement Worker
Wet sanding or A process of removing loose paint in which the
wet scraping painted surface to be sanded or scraped is kept wet to
minimize the spread of paint chips and airborne dust.
Window trough For a typical double-hung window, the portion of the exterior
window sill between the interior window sill (or stool) and the
frame of the storm window. If there is no storm window, the
window trough is the area that receives both the upper and
lower window sashes when both are lowered. Sometimes
inaccurately called the window "well."
Window well the space that provides exterior access and/or light to a window
that is below grade, i.e., below the level of the surrounding
earth or pavement.
X-ray the emission of X-rays from excited atoms produced
fluorescence by the impact of high-energy electron, other particles, or
primary beam of other X-rays.
X-ray An instrument which estimates lead concentration
fluorescence in milligrams per square centimeter (mg/cm2) using
analyzer (XRF) X-ray fluorescence.
ZPP test
Zinc protoporphyrin test. It is a type of blood test which can
show a person's lead exposure over the previous two to three
months.
-------
Resources
Resources
U.S. EPA Regional Offices
USEPA Region I
Lead Coordinator
John F. Kennedy Federal Building
One Congress Street
Boston, MA 02203
617-565-3471
USEPA Region II
Lead Coordinator
290 Broadway
New York, NY 10007-1866
732-321-6671
USEPA Region III
Lead Coordinator
1650 Arch St.
Philadelphia, PA 19103
215-814-2084
USEPA Region IV
Lead Coordinator
61 Forsyth St
Atlanta, GA 30303-3104
404-562-8998
USEPA Region V
Lead Coordinator
77 West Jackson Boulevard
Chicago, IL 60604
312-886-7836
USEPA Region VI
Lead Coordinator
1445 Ross Avenue, 12th Floor
Dallas, TX 75202-2733
214-665-7577
USEPA Region VII
Lead Coordinator
726 Minnesota Ave.
Kansas City, KS 66101
913-551-7518
USEPA Region VIII
Lead Coordinator
999 18th St.-Suite 500
Denver, CO 80202-2466
303-312-6021
USEPA Region IX
Lead Coordinator
75 Hawthorne St.
San Francisco, CA 94105-3901
415-744-1094
USEPA Region X
Lead Coordinator
1200 Sixth Ave.
Seattle, WA 98101
206-553-1985
OSHA Regional Offices
OSHA Region I
133 Portland Street, 1st Floor
Boston, MA 02114
617-565-7164
OSHA Region II
201 Varick St.
New York, NY 10014
212-337-2378
OSHA Region III
Gateway Building, Suite 2100
3535 Market Street
Philadelphia, PA 19104
215-596-1201
OSHA Region IV
1375 Peachtree St., NE, Suite 587
Atlanta, GA 30367
404-347-3573
OSHA Region V
230 South Dearborn St.
Room 3244
Chicago, IL 60604
312-353-2220
OSHA Region VI
525 Griffin St., Room 602
Dallas, TX 75202
214-767-4731
-------
Lead Abatement Worker
OSHA Region VII
City Center Square
1100 Main St., Suite 800
Kansas City, MO 64105
816-426-5861
OSHA Region VIII
1999 Broadway, Suite 1690
Denver, CO 80202-5716
303-391-5858
OSHA Region IX
71 Stevenson St. Room 420
San Francisco, CA 94105
415-744-6670
OSHA Region X
1111 Third Avenue, Suite 715
Seattle, WA 98101-3212
206-553-5930
Federal Agencies
Agency for Toxic Substances and Disease
Registry (ATSDR)
Office of Policy and External Affairs
404-639-0501
atsdrl .atsdr.cdc.gov
Centers for Disease Control and Prevention
(CDC)
Lead Poisoning Prevention
404-639-3311
www.cdc.gov
Environmental Protection Agency
TSCA assistance hotline
202-554-1404
www.epa.gov/lead
Private Organizations
Alliance to End Childhood Lead Poisoning
227 Massachusetts Ave., NE
Suite 200
Washington, DC 20002
202-543-1147
www.aeclp.org
Association of Occupational and
Environmental Clinics
1010 Vermont Ave, NW #513
Washington, DC 20005
202-347-4976
Environmental Defense Fund
1875 Connecticut Ave., NW
Suite 1016
Washington, DC 20009
202-387-3500
www.edf.org
National Institute for Environmental Health
Science (NIEHS)
919-541-0752
www.niehs.nih.gov
National Institute for Occupational Safety and
Health (NIOSH)
800-35-NIOSH
www.cdc.gov/niosh
Department of Housing and Urban
Development
Office of Health Homes and Lead Hazard
Control
202-755-1785
www.hud.gov/offices/lead
HUD USER 800-245-2691
National Center for Healthy Housing
10227 Wincopin Circle, Suite 205
Columbia, Maryland 21044
410-992-0712
www.enterprisefoundation.org/howwork/
housing/leadsafe.htm
National Lead Information Center
800-424-LEAD
www.epa.gov/lead/nlic.htm
Society for Occupational and Environmental
Health
6728 Old McLean Village Dr.
McLean, VA 22101
703-556-9222
-------
Resources
The Environmental Information Asso.
4915 Auburn Ave., Suite 303
Bethesda, MD 20814
301-961-4999
www.eia-usa.org
National Lead Abatement Council
P.O. Box 535
Olney, MD 20832
301-924-5490
-------
SB
Lead Abatement Worker
10-24
-------
APPENDIX A
Lead Abatement in Housing
Learning objectives A-3
Skit: A home abatement job A-4
Discussion questions A-4
Doing the abatement A-5
Windows A-6
Doors A-10
Woodwork (not including doors and windows) A-12
Walls A-13
Ceilings A-17
Floors A-18
Staircases A-20
Porches A-22
Outside brick and cement A-23
Key facts for Appendix A A-25
For more information A-26
-------
Lead Abatement for Workers
-------
Lead Abatement in Housing
Learning objectives
In this appendix you will learn how to treat lead-based paint on
• windows
• doors
• woodwork
• walls
• ceilings
• floors
• staircases
• porches
You will also review the differences between abatement and interim controls.
-------
Lead Abatement for Workers
Skit: A home abatement job
Sam has worked in a lot of trades. He was recently trained in lead abatement because he
heard there was some work available. Later, Sam and his buddy, George, got a job doing
home abatement for a neighbor. They needed to get some experience, so they bid low in
Sam: We should've looked over the inspection report before
submitting that bid. There's lead-based paint everywhere!
George: You're telling me. We're going to have to cut corners
somehow. How about the windows?
Sam: No, let's not skimp there. They're a big hazard. Let's go ahead and replace
them, but get cheaper windows.
George: How about if we just repaint the doors and replace the stop?
Sam: Not a bad idea, and we can just repaint the ceiling where it needs it.
George: All right, good plan! Boy, could I use a smoke. It's going to be tough
smoking only outside.
Discussion questions
order to get the job.
1. What do you think of Sam's and George's plan?
2. Can you manage the hazard of lead-based paint on a surface
r
What do
you think?
such as a window by just repainting it? Why or why not?
3. Does it make sense to repaint the doors and replace the stops?
4. Why do lead abatement workers who smoke have a harder
time keeping their lead exposure down?
-------
Lead Abatement in Housing
Doing the abatement
Abatement means getting rid of lead-based paint hazards. Abatement methods are
discussed in Chapter 6.
Whenever you do abatement you must use the personal protection that is appropriate
for the job. You can find this information in the HUD Guidelines. OSHAsays you must
be trained on PPE and the hazards of working with lead. The following chart shows
which methods are used for different parts of a home.
Method Where can you best use it?
REPLACEMENT • Windows, doors, moldings
• Any easily removed component
ENCAPSULATION • Walls, ceilings, trim
ENCLOSURE
• Floors, pipes, ceilings, exterior trim
PAINT REMOVAL
Wet Scraping
As an interim control for loose paint
Not as a removal method for large areas
Heat Gun
Flat surfaces
Thick layers of paint (softens them)
Caustic Paste
Decorative molding
Soft woods, brick, cement
Solvents
Metal substrates
To clean residue left by other methods
Restoration work
Doors, mantels, metal railing, trim
Off-site Chemical
Stripping
-------
Lead Abatement for Workers
Windows
Lead-painted windows are often the greatest source of lead dust.
Opening and closing windows causes friction between painted surfaces. This friction
creates dust. Windows are exposed to water, sun, wind, and temperature changes. These
all cause paint to deteriorate and create dust.
Put extra poly up when you work on windows. Attach the poly to the wall underneath
the window and extend the poly out at least 6 feet. Do this both inside and outside the
window.
The greatest
levels of lead
dust are often
found in the
window troughs.
Replace window
units.
Side casing
Head casing
Top sash
il
Bottom
Jamb
Trough
Sill (stool)
Apron
Window abatement
Replacing lead-painted windows is a good choice because
• raising and lowering the windows may produce lead dust;
• children like to play in and near windows;
• old windows are expensive to maintain;
• new windows can save energy;
• new windows may increase property value.
If you must keep the old sashes, you can
• Remove the sashes and have them stripped off site whenever possible. Clean, reglue,
refinish, and paint them before reinstalling.
• Replace the stops and the parting bead.
• Enclose or chemically strip the jamb.
A-6
-------
Lead Abatement in Housing
• Replace the casing and the apron.
• Replace the sill (stool) or enclose it.
• Enclose the outside of the window with wood or coil stock. WARNING: Enclosing
wood with coil stock may cause exterior wood to rot.
Interim controls
If you are not going to abate lead-painted windows right away, you can still treat them so
they create less lead dust. (Make sure these options are legal in your state and local area!)
The sashes
The goal is to eliminate friction against leaded surfaces.
• Fix the top sash in place.
Nail or screw in wood blocks under
the top sash to hold it in place.
(Make sure this is legal to do in your
area.) This way you will only have to
work the bottom sash.
• Remove and dispose of inside stop.
Do the same with the parting bead i
you are treating the top sash as well
as the bottom.
• Remove the bottom sash. If the
counter-weight ropes or chains are in
place, do not let them drop into the
weight compartment.
• Remove the paint from edges that
rub against stop, sill (stool), and
parting bead. Wet planing is a good
method.
Inside stop
Parting bead
-------
Lead Abatement for Workers
• Rehang the sash(es) in a
compression track. If there is no
counter weight or spring system,
install one.
^^Compression
/ track
The trough and the sill (stool)
When a window sash is lowered, the opening the sash fits into is called a trough.
This area is typically one of the highest dust areas.
• HEPA vacuum the trough.
• Create a cleanable surface. Enclose
trough with vinyl or metal coil stock.
Back caulk the material and nail it
down. Caulk the edges from the top.
• Open or drill out weep holes. (Weep
holes are drain holes in the bottom of
storm windows.)
• The sill (most window makers and
carpenters call this the "stool") is at
the base of the window, inside the
house. Children often look out the
window and may put their mouths
on the sill. Wet plane or enclose the
edge facing the room. You may also
need to enclose or remove the paint
from the top surface.
Leading edge of sill
Sash
Trough
-------
Lead Abatement in Housing
The casing, apron, jamb
• If the paint on the casing, apron,
and jamb is in good shape, you
may be able to just wet scrape
and repaint. Remember, paint is
not an encapsulant. Repainting is
only a temporary solution!
• If the outside jamb is still exposed
and the outside casing is
damaged, wet scraping and
painting may not be enough.
Seal any exposed wood with
boiled linseed oil (or equivalent)
and paint. Enclosing the trim
with coil stock will also work, but
may cause exterior wood to rot.
Head casing «.
Side casing —
¦wT'h
K jf | 1 t ' m
'ill1; ' I
i f i iH
Jambv
II sll
Apron —
4Ibtl
-------
Lead Abatement for Workers
Replace doors.
Doors
Opening and closing doors creates an impact. When you impact a lead-based painted
surface again and again, lead dust is created. Outside doors are exposed to water, sun,
wind, and temperature changes. These cause paint to deteriorate and create lead dust.
Lead-painted
doors are a
source of lead
dust.
Head jamb
Latch jamb
Casing
Hinge jamb
Door abatement
Replacement is often the easiest, most cost-effective method. There are a number of
ways to do this:
• Replace door and door stop.
• Install a pre-hung door and keep old jamb.
• Install a pre-hung door and new casing.
Taking out old casing can damage the surrounding wall. New casing should be wide
enough to cover any damage. It should also cover the jamb edge and the area where the
old casing meets the wall.
Remove the paint off site.
If you must preserve the door and casing, send them to be stripped off site. Clean them
when they come back. Reglue, fill in any holes or cracks, and wet sand them. Reinstall
and paint after inspection.
A-10
-------
Lead Abatement in Housing
Remove the paint on site.
You can remove the lead-based paint on site with chemical stripping, wet scraping, or
by using a heat gun. Needle guns equipped with HEPA filters may be used for metal
doors. These methods require time and patience.
Interim Controls
If you are not going to abate lead-painted door systems, you can still treat them so they
create less lead dust. (Make sure these options are legal in your state and local area!)
1. Replace the stop—or wet plane it.
2. Wet plane the corner edges of the door on the latch side where it contacts the stop.
3. Re-set the hinge screws if necessary.
The door should not make any wood-to-wood contact, except against the latch
(knob) side stop. If it does, rehang the door or plane the hinge side of the door until
there is about 1/8-inch space.
-------
Lead Abatement for Workers
Woodwork (not including doors and windows)
Lead-painted woodwork can be a source of lead dust, especially impact points such as
chair rails, baseboards, and jamb edges.
Crown
Replace or
encapsulate
woodwork.
WALL
Chair rail
Wainscot
Base Cap
Baseboard
Shoe molding
Woodwork abatement
• Replace
Woodwork can be replaced. Remember to back caulk and nail down replacement
parts when you install them.
• Encapsulate
Encapsulate if the paint is in good shape.
Interim controls
If you are not going to abate lead-painted woodwork, you can still treat it so that it
creates less lead dust. (Make sure these options are legal in your state and local area!)
• Wet plane and enclose any edges on surfaces where children may put their mouths.
• Where paint is intact, paint over with a high-grade paint. Paint is not an
encapsulant. Repainting is only a temporary measure!
• Cover impact points (chair rails, baseboards, jamb edges) with a strip of solid lattice
or corner protector.
A-12
-------
Lead Abatement in Housing
Walls
Kitchen, bathroom, and basement walls were often painted with lead-based paint. Other
walls in a home can have lead-based paint, too. Encapsulation and enclosure are the
methods most often used to abate lead-painted walls. Regardless of the type of
abatement chosen, the cause of the damage (e.g., leaking roof, leaking chimney,
termites, etc.) to the wall(s) must be fixed first.
Wall abatement
• Encapsulating walls
The wall must be sound. Plaster or plaster board must be in good shape. There
cannot be any major peeling of the existing paint layers. If the wall is not sound, the
encapsulant could pull right off the wall. If the wall is sound, but has minor cracks
or chips, a mesh system works well. It will seal the cracks and chips. Old wallpaper
should be removed because it can cause the encapsulant to fail.
• Prepare the wall. Wet scrape any loose paint. Clean off any oil, dirt, and grease
with a solvent or detergent.
• Wear the right protective gear. You may need to use chemical-resistant
protective gear. Wear your respirator and goggles. Check the encapsulant
MSDS. Make sure you have the right filters for your respirator. You may need a
combination filter.
• Mix the encapsulant. Follow the manufacturer's directions.
• Do a "test patch."
• Ventilate the area. Some products need extra ventilation.
• Enclosing walls
Before you enclose a wall, label the wall surface "lead-based paint." This will alert
anyone who works on the wall later on that they are disturbing lead-based paint.
Both sound walls and damaged walls can be enclosed. Enclosure is recommended
where the substrate (wall material) is damaged. Before you install an enclosure, you
have to get rid of all moisture sources and let the walls dry out.
Fur out the wall.
When plaster is damaged, you must install enclosure material to studs or furring
strips. Furring strips are thin strips of wood you fasten to the studs. This way, even
if the plaster fails, the enclosure will stand. Furring strips should be attached with
adhesive and screws into the studs. Putting up furring strips is called "furring out
the wall."
Encapsulate or
enclose walls.
Prepare the wall
with wet
scraping and
clean.
Label the old wall
"LEAD-BASED
PAINT" before
you enclose it.
A-13
-------
Lead Abatement for Workers
First lay out a horizontal furring
strip along the base of the wall.
Then put up vertical furring
strips. Line them up with the
studs.
Fasten the enclosure material.
Fasten the enclosure material to the
studs. If you furred out the wall,
fasten the enclosure material to the
furring strips. Use both adhesive and
screws. If the wall is plaster on
masonry and the plaster is sound, the
enclosure material can be attached
with a combination of mastic and
masonry fasteners.
Create a dust
tight seal.
Create a dust-tight seal.
Paint deteriorates more quickly behind
an enclosure. All edges of an
enclosure—especially the bottom—
must be sealed well. If you don't create
a good seal, lead dust will leak out.
Vertical furring
strip
^-Horizontal
-furring strip
Enclosure
material
Screws
Mastic or
adhesive
AAA
-------
Lead Abatement in Housing
Seal the bottom edge.
• Caulk the enclosure material at
the bottom.
• Back-caulk and nail the
baseboard in place.
• Back-caulk, bottom-caulk, and
nail the shoe molding in place.
Enclosure
material
Baseboard
Shoe
molding
2w=i!L 'i
Furring stiji
Wall
Furring
strip
P
Seal the edges-
especially the
bottom.
Seal the seams and other edges.
• Back-caulk all the seams that
aren't taped and spackled. Use a
high quality adhesive caulk.
• Use a "J-channel" where drywall
meets a finished surface. A J-
channel is a final strip you attach
to the rough edge of drywall to
make a finished edge. It's called a
"J-channel" because of its shape.
Caulk the outside edge so it seals
with the finished surface. Screw tl
• Replacing walls
Replacing drywall and plaster is extremely messy and expensive. Sometimes it is the
most practical solution—for example, when partition walls will be built or new
electric, plumbing, or heating systems will be installed within a wall.
Taking out the old walls or wall substrate (plaster) is demolition work. Follow
all worker and environmental protection rules.
• Remove all furniture and personal items.
• Seal off the area.
• Put down a second layer of poly on the floor for added protection.
• Keep area misted to lower dust levels.
• Clean up often and dispose of waste.
• Wear protective suits and respirators and use extra ventilation.
l— J-Channel
1 I Drywall
1
Screw
Caulk
drywall in place.
A-15
-------
Lead Abatement for Workers
Interim controls
If the lead-painted walls are not damaged, flaking, or peeling, you might just wet scrape
and repaint them. Remember, paint is not an encapsulant. Repainting is not an
abatement method, it is only a temporary solution. When the new paint does chip and
peel, the old paint may chip with it. Then it will create lead dust.
-------
Lead Abatement in Housing
Ceilings
If a lead-painted ceiling is damaged, it should be enclosed. Replacement is also an
option, but it will create large amounts of dust and debris in addition to being much
more expensive and difficult to do. Regardless of the type of abatement chosen, the cause
of the damage to the ceiling (e.g., leaking plumbing, poor painting preparation,
unvented bathroom) must be fixed first. Ceilings can be enclosed with drywall—or any
other type of covering that seals the seams and edges. An enclosure must be dust-tight. It
must be sealed along all edges, joints, and seams. A drop ceiling is not an enclosure.
Ceiling abatement
Never attach the new ceiling to the old ceiling itself. New drywall must be attached to
the ceiling beams—called "joists"—with drywall screws. To find the joists, use a drywall
dagger and do the following:
1. Cut to the joists on both sides.
2. Mark the center of each joist on the wall.
3. Draw a chalk line across the ceiling
from center mark to center mark.
4. Screw the new drywall into the joists
along these lines.
5. Tape and spackle all edges.
6. Where new drywall meets a finished
surface, use a
J-channel.
Interim controls
If the ceiling is not damaged, flaking, or peeling, you might repaint it to take care of the
lead hazard in the short run. Remember, paint is not an encapsulant. Repainting is not
an abatement method. It is only a temporary solution. When the old paint does chip
and peel, it will create lead dust.
Enclose ceilings.
A-17
-------
Lead Abatement for Workers
Enclose or
replace floors.
Back caulk and
nail in subfloor.
Carpets collect
more lead dust
than bare floors.
Floors
Lead-painted floors are a major source of lead dust. They are impact and friction
surfaces. People walk on them. Children and pets play on them. Things get dropped on
and dragged around on them. These activities create lead dust.
Floors should be abated last. Ceilings, walls, and windows need to be done first. This
will reduce the amount of lead dust that gets on the new lead-free floor. The less dust
that gets on the floor, the easier it will be to clean at the end of the job.
Floor abatement
1. Clean the floor to remove lead dust with an all-purpose cleaner or some other
cleaner made especially for lead.
2. Install a subfloor before installing the finished floor (unless you are installing a
new tongue-and-groove floor). Use 1/2-inch or thicker plywood or tempered
underlayment. Do not use masonite. Back caulk the edges, especially the borders.
Nail the subfloor down. HEPA vacuum the floor and all cracks. Fill large cracks
with a filler that will not turn brittle or break.
3. Install the finished floor. You can use vinyl, tile, or wood. (If you use urethane, use
extra ventilation and follow instructions carefully.) You can also place carpeting on
top of the newly installed floor, but wait until final cleanup is complete before
installing. Carpeting alone is not an enclosure. Wall-to-wall carpeting is discouraged
in homes with lead-based paint because it is not cleanable.
A-18
-------
Lead Abatement in Housing
Carpet removal
Lead dust falls on and sticks to carpet fibers. Lead dust settles under the carpet. Taking
out lead-contaminated carpets can be dangerous. You will be exposed to high levels of
lead dust.
1. Seal the area from other parts of the house.
2. Wear a respirator and protective clothing.
3. Ventilate the area.
4. Dampen rug and any dust underneath to keep the dust levels down.
5. Wrap up the carpet in 6-mil poly and seal it with duct tape.
6. HEPA vacuum the area and wash over it with an all-purpose cleaning solution.
Carpets contaminated with lead are very difficult to clean. You or your employer should
advise the owner of this difficulty. Do not remove the carpet without the owner's written
permission. If the carpet is not removed, it must be HEPA vacuumed very slowly.
After the abatement
Lead-free floors will collect lead dust.
Floors should be abated at the end of the job—after windows, doors, walls, and ceilings.
It is very difficult to clean floors of lead dust. Once you finish abating the floor, seal off
the area until the final cleanup and a clearance can be done.
Carpet removal
can cause high
levels of lead
dust to be
released.
A-19
-------
Lead Abatement for Workers
Staircases
Staircase abatement can be done in a number of ways. The entire staircase can be
replaced—but this is extremely expensive and is generally not recommended. Parts of
the staircase can be replaced, while other parts can be enclosed or encapsulated.
Rail
Tread
Riser
Balusters
Newel
Stringer
Staircase abatement
• Stringers and newels
Stringers and newels cannot be removed without taking out the whole staircase.
This is very expensive. It is better to remove the lead-based paint on site or use an
encapsulant that will hold up against impact.
• Railings, newels, and balusters
Railings, newels, and balusters can be treated with some encapsulants. However, the
rail is a high friction area. An encapsulant may not work on the rail. The outside
corners of the newel post and the top edge of the railing may need to be enclosed,
wet planed, or chemically stripped.
In some cases, the balusters and rails can be removed and stripped off-site or
replaced. The paint in between balusters must be removed on-site. As an interim
control for square railing caps, you could wet-plane them across the top side.
-------
Lead Abatement in Housing
• Enclose treads and risers.
A rubber tread with metal nosing
works well. Rubber nosing may
work, if it fits snugly on the nose of
the stair and the stairs are not used
very often.
Plywood
Metal nosing
Caulk back of
rubber tread
• Enclose risers with thin plywood
(such as luan plywood) or some
other hard material. Whatever
you use must fit snugly.
• Back caulk the edges of treads.
Place treads, and nail or screw
them down. Screw or nail the
metal nosing on.
• Enclose the whole railing system.
You can enclose the railing cap, balusters, and newels with plywood or drywall.
Then, cap the new system with a wooden rail. This solution changes the design of
the room a lot. It also takes a long time, is a lot of work, and is expensive.
After abating the staircase
Once the staircase is abated, cover it with 6-mil poly. Staple down some type of non-slip
material on top of the poly for worker safety. You can use cardboard stapled to the treads.
-------
Lead Abatement for Workers
Lead-painted
wooden porches
are a serious
lead hazard.
Porches
Wooden porches with lead-based paint are serious lead hazards because
• surfaces get worn down from weather changes;
• children spend a lot of time there;
• railings are at the right height for kids to put their mouths on.
Column
Railing
Baluster
Porch floors should be replaced or enclosed. Use treated planks, treated tongue-and-
groove, or exterior or marine-grade plywood. Make sure the floor slants down away from
the house. The slant allows water to drain properly.
Balusters may be on-site stripped or encapsulated. They are often in such bad shape that
they need to be replaced.
Rails can be replaced, stripped, or wet planed.
Structural columns can be wet scraped, encapsulated, or stripped.
Lattice (crisscrossed strips of wood or metal) should be replaced.
Ceilings may be enclosed with exterior grade plywood. Remember to back caulk around
the edges.
A-22
-------
Lead Abatement in Housing
Outside brick and cement
Abatement
Enclosing outside surfaces with a dust-tight material and vinyl or aluminum siding is often
the method of choice. This method provides protection against weathering and increases
the efficiency of the house. It also creates less waste than other abatement methods.
Vacuum blasting and contained water blasting may be allowed for outdoor work (your
employer must check with the state or tribal agency responsible for regulating residential
lead-based paint abatement). Chemical stripping can also be used. These methods are
very costly and generate a lot of waste. Waste from water blasting and chemical stripping
may be considered hazardous and must be disposed of properly.
When working on outside structures, setup is very important. You need to protect the
soil, bushes, and plants, and the surrounding environment. Put 6-mil poly on the
ground and seal it to the wall with duct tape or wood trim and masonry nails. There
should be no gaps between poly and the building. You need to extend 10 feet of poly in
every direction from the surface on which you are working. Place boards under the edge
of the poly to create a curb. The curb directs the waste water into a low spot, where it
can be pumped into a 55-gallon drum. A disposable tarp may be laid loosely over plants.
Put weights around the edge of the tarp to keep it down. Keep all windows within 20
feet of the working surfaces closed, including windows of houses or buildings nearby.
If the outside work includes window treatment or replacement, then one layer of poly
should be placed on the ground and extend at least 5 feet beyond the perimeter of the
window being treated/replaced. Two layers of poly should be taped to the interior wall
around the window(s) to prevent dust and debris from getting inside the house.
Clean and take down the entire outside setup at the end of each day. Lock up waste
before leaving the work site.
-------
Lead Abatement for Workers
Interim controls
Wet scraping is sometimes used to remove loose lead-based paint from outside brick and
cement structures. This is a very labor-intensive method. Masonry wet scraping should
be done with maximum pressure to remove all paint that has separated from the
substrate. Repaint with a high-grade masonry paint, or use an encapsulant
recommended for masonry application.
-------
Lead Abatement in Housing
Key facts for Appendix A
The four abatement methods used in a home are
• replacement
• enclosure
• encapsulation
• paint removal
Replacing lead-painted windows, doors and woodwork is a good way to
reduce lead hazards.
Back-caulk and nail (or screw in) replacement parts when you install them.
Do not use encapsulants on structurally damaged walls or walls that are
separating from the substrate.
Enclosure is often used for lead-painted floors and ceilings.
Create a dust-tight seal when you enclose a surface.
Back-caulk and nail (or screw in) enclosure materials.
When working on outside structures, setup is very important.
Interim controls are only temporary solutions.
They are actions you can take to reduce lead dust levels until you do an
abatement.
Interim controls should not take the place of abatement.
Interim controls may not be allowed in your state or local area. Check your state
and local laws.
-------
Lead Abatement for Workers
For more information
These publications have more information on the topics covered in this appendix. Your
instructor will have a copy of some of the publications. You can order your own copies
by calling 1-800-424-LEAD.
EPA, Regulatory Status of Waste Generated by Contractors and Residents from Lead-Based
Paint Activities Conducted in Households, Interpretive Memorandum (July 2000).
EPA, Lead: Requirements for Hazard Education Before Renovation of Target Housing;
Final Rule-, 40 CFRPart 745 (June 1998).
*EPA, Lead: Requirements for Lead-Based Paint Activities in Target Housing and Child-
Occupied Facilities-, 40 CFRPart 745 (August 1996).
EPA, HUD, and CDC, Lead Paint Safety: A Field Guide for Painting Home
Maintenance, and Renovation Work (June 1999).
EPA, HUD, and CPSC, Protect Your Family From Lead in Your Home (June 2003).
*HUD, Requirements for Notification, Evaluation and Reduction of Lead-Based Paint
Hazards in Federally Owned Residential Property and Housing Receiving Federal
Assistance; Final Rule (September 1999).
*HUD, Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in
Housing (June 1995).
*OSHA, Interim Final Lead in Construction Standard, 29 CFR 1926.62 (May 1993).
Society for Occupational and Environmental Health, Protecting Workers and Their
Communities from Lead Hazards: A Guide for Protective Work Practices and Effective
Worker Training (1993).
-------