Model Certified Renovator
Refresher Training Course
Student Manual
EPA-740-R-09-004
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Repair and
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ule 1: Regulations
Module 2: Testing for
Lead-based Paint
Module 3: Review of Setup
Praotioes
Module 4: Review of
Prohibited Practices, Personal
Protective Equipment, and Dust
Control
Module 5: Cleaning Activities
and Checking Your Work
Module 6: Recordkeeping
Module 7: Training
Non-Certified Renovators
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Introduction
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Lead Safety for Renovation, Repair, and Painting Refresher
Lead Safety for Renovation, Repair
and Painting
Welcome and Introductions
Please tell the class:
Your name, the company you work for, and what you do.
Module Overview:
Course agenda
Course manual
&EPA fM
United States
Environmental Protection
Agency
October 2011
Why Are You Here?
Traditional renovation work, without lead safe work practices, creates significant dust-lead hazards if
lead-based paint is disturbed.
The leaded dust generated by traditional renovation work can cause lead poisoning in children. It can
also poison pregnant women, yourself and other workers and even pets. Practical changes in work
practices can minimize and contain dust. The use of lead-safe work practices makes the job safer
and reduces your liability exposure.
EPA's Renovation, Repair and Painting Final Rule (40 CFR 745) requires that renovations conducted
for compensation, must be performed by Certified Firms using Certified Renovators. Renovation firms
that wish to work in pre-1978 homes and child-occupied facilities must apply to EPA and pay a fee in
order to become certified. Renovators seeking to become Certified Renovators must successfully
complete an EPA-accredited renovator course or a course accredited by an EPA authorized State or
Tribe. This course is the EPA model course for Certified Renovators and as such meets all
requirements in 40 CFR 745.90.
This course will teach you how to comply with the EPA Renovation, Repair and Painting Rule and the
HUD Lead Safe Housing Rule, and how to perform lead-safe work practices safely and effectively.
Once you have successfully complete this Certified Renovator refresher course, delivered by an EPA-
accredited training provider, you will be an EPA Certified Renovator. EPA Certified Renovator status
will allow you to do lead safe renovation, repair, and painting work in pre-1978 housing and in child-
occupied facilities where work will disturb lead-based paint. Your certification is valid for five years
from the date of completion of the course. To renew certification after five years, you must
successfully complete another EPA-accredited Certified Renovator Refresher Course before your
initial certification expires. Refresher training must be taken every five years to maintain certification.
If the certified renovator training is not refreshed within five years of the previous training, you must
retake the initial course to become certified again.
1 October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
Course Agenda
Introduction and welcome
Module 1: Federal Regulations
Module 2: Testing for Lead-
based Paint
Module 3: Review of Setup
Practices
Break
Module 4: Review of Prohibited
Practices, Personal Protective
Equipment and Dust Control
Module 5: Review of
Cleanup Practices,
Cleaning Verification
Procedure and Hands-on
Module 6: Recordkeeping
Module 7: Training Non-
Certified Renovation
Workers
Test
October 2011
SEPA
United States
Environmental Protection
Agency
2
October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
Training Manual Overview
Seven modules
Key appendices
Appendix 2 - U.S. Department of Housing and Urban
Development (HUD) Requirements
Appendix 3 - Renovate Right: Important Lead Hazard
Information for Families, Child Care Providers and Schools
Appendix 4 - Small Entity Compliance Guide to Renovate Right
Appendix 5 - Steps to LEAD SAFE Renovation, Repair, and
Painting
Appendix 6 - Hands-on Exercises
Appendix 9 - Paint Chip Sample Collection Guide
v>EPA /li!!?
United States
Environmental Protection
Agency
October 2011
Modules - In addition to this introduction, there are eight modules in this course:
Module 1: Regulations
Module 2: Testing for Lead-based Paint
Module 3: Review of Setup Practices
Module 4: Review of Prohibited Practices, Personal Protective Equipment and Dust Control
Module 5: Cleaning Activities and Checking Your Work
Module 6: Recordkeeping
Module 7: Training Non-Certified Renovators
Appendices - This manual has nine appendices that provide extra information that will help
contractors.
Appendix 1 - [Intentionally Blank]
Appendix 2 - U.S. Department of Housing and Urban Development (HUD) Requirements
Appendix 3 - Renovate Right: Important Lead Hazard Information for Families, Child Care Providers
and Schools
Appendix 4 - Small Entity Compliance Guide to Renovate Right
Appendix 5 - Steps to LEAD SAFE Renovation, Repair, and Painting
Appendix 6 - Hands-on Exercises
Appendix 7 - State and Local Regulatory Requirements
Appendix 8 - Regulatory Status of Waste Generated by Contractors and Residents from Lead-
Based Paint Activities Conducted in Households
Appendix 9 - Paint Chip Sample Collection Guide
Appendix 10 - More information
Test - Renovators must pass the test administered at the end of the course in order to earn
certification. Failure to pass the test means you must retake the course.
3
October 2011
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Module 1: Regulations
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Lead Safety for Renovation, Repair, and Painting Refresher
Module 1: Regulations - The RRP
Rule
Addresses activities that disturb lead-based paint in
target housing and child-occupied facilities. It requires:
Renovators to be certified through training.
Firms to be certified.
Training providers to be accredited.
Lead-safe work practices during renovations.
Pre-renovation education in target housing and child-occupied
facilities.
Firms working in pre-1978 homes and child-occupied
facilities must be certified and use lead-safe work
practices during renovations.
EPA may authorize states, territories and tribes to
enforce the Rule. ซ,EpA |
October 2011
EPA's Renovation, Repair and Painting Final Rule:
Published April 22, 2008, under the authority of the Toxic Substances Control Act (section 402(c)(3)
ofTSCA).
The final rule addresses lead-based paint hazards created by renovation, repair and painting
activities that disturb lead-based paint in "target housing" and "child-occupied facilities."
Target Housing is a home or residential unit built on or before December 31, 1977, except:
Housing designated for the elderly or persons with disabilities (unless any child who is less
than 6 years of age resides or is expected to reside in such housing).
Any zero-bedroom dwelling (e.g. studio apartments, hospitals, hotels, dormitories, etc).
A Child-Occupied Facility is a pre-1978 building that meets all three of the criteria below:
Visited regularly by the same child, under 6 years of age.
The visits are on at least two different days within any week (Sunday through Saturday
period), provided that each day's visit lasts at least 3 hours.
Combined weekly visits last at least 6 hours, and the combined annual visits last at least 60
hours.
Child-occupied facilities may be located in a public or commercial building or in target housing.
These facilities include schools, child care facilities, and daycare centers.
State Authorization: EPA may authorize states, territories and tribes to enforce all aspects of the
RRP Rule. Such states are called "authorized states." EPA enforces the Rule in non-authorized
states.
The Rule Requires:
Training providers must be accredited.
Renovation firms must be certified.
Renovators and dust sampling technicians must be trained and certified.
Non-certified workers must work under and be trained on-the-job by a Certified Renovator.
Work practices must be followed for renovations covered by the rule.
Renovators must educate owners/occupants.
1-1
October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
The RRP Rule: Exclusions
Renovation activities where affected
components do not contain lead-based paint.
Emergency renovations (requires cleanup and
cleaning verification).
Minor repair and maintenance activities. Note:
This does not apply to window replacement,
demolition or activities involving prohibited
practices.
Renovations performed by homeowners in
their own homes.
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October 2011 1-2
The Renovation, Repair, and Painting rule does not apply to renovation work that meets the
following exclusions.
If the renovation only affects components that do not contain lead-based paint, the rule does not
apply to renovation of these components.
EPA has established limits (see below) for minor repairs or maintenance. Work that does not
exceed these limits is exempt from the work practice requirements in the Rule. The EPA limits for
minor repairs and maintenance are larger than the HUD limits (see the HUD box below).
Minor repair and maintenance activities have been defined in the Rule.
EPA has defined minor repair and maintenance activities as below.
Interior work disturbing less than 6 square feet (6 ft2) per room of painted surface is exempt
from the work practices requirements in the Rule. Cleanup and cleaning verification are not
required after minor repair and maintenance activities, unless they involve window
replacement, demolition, or prohibited practices.
Exterior work disturbing less than 20 square feet (20 ft2) of painted surface is exempt from the
work practices requirements in the Rule. Cleanup and cleaning verification are not required
after minor repair and maintenance activities, unless they involve window replacement,
demolition, or prohibited practices.
Minor repair and maintenance activities do not include window replacement, demolition or
activities involving prohibited practices.
When removing painted components, the entire surface area removed is the amount of
painted surface disturbed. Work, other than emergency renovations, performed within a 30-
day period must be considered the same job when determining the amount of paint disturbed.
r
The HUD Lead Safe Housing Rule applies to every home built prior to 1978 that
receives Federal housing assistance, where greater than HUD's de minimis
amounts of painted surfaces will be disturbed. HUD's de minimis amounts are:
2 square feet of interior lead-based paint, 20 square feet of exterior lead-based
paint or 10% of the total surface area on an interior or exterior type of
component with a small surface area that contains lead-based paint. Examples
include window sills, baseboards, and trim.
1-2
October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
The RRP Rule: Firm Certification
To become certified, firms must submit an
application and fee to EPA.
Certifications will be good for 5 years.
Certification allows the firm to perform
renovations in any non-authorized state or Indian
tribal area.
>>EPA
October 2011
No firm working in target housing or child-occupied facilities, where lead-based paint will be affected
by the work, may perform, offer or claim to perform renovations without Firm Certification from EPA,
an EPA-authorized agreement state, territory, or Indian tribe.
One EPA renovation firm certification is all that is needed for a renovation firm to work in any non-
authorized state/territory/tribal area. Firm certification is not the same as the personal certification
attained by each renovator's successful completion of this course.
1-3 October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
The RRP Rule:
Firm Responsibilities
Ensure overall compliance with the RRP Rule.
Ensure that all renovation personnel are Certified
Renovators or have been trained on-the-job by
Certified Renovators.
Assign a Certified Renovator to all jobs.
Meet Pre-Renovation Education Requirements.
Meet recordkeeping requirements.
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October 2011 1-4
The Certified firm must ensure that everyone on the renovation, repair or painting job is trained to
perform lead-safe work practices during the job. EPA requires all persons on the job to be trained in
the RRP Rule-required work practices that will apply to their assigned tasks on that job. The person
responsible for lead-safe work practices must be a Certified Renovator. Other firm employees (non-
certified renovation workers), working on the job, must be trained on-the-job by Certified Renovators,
or must be Certified Renovators themselves. This could be accomplished by:
Having all employees trained as Certified Renovators; or,
Having at least one person trained as a Certified Renovator, who will then train the rest of the
employees in lead-safe work practices. Note that this training must be performed by a Certified
Renovator.
The Certified Firm must designate a Certified Renovator: to conduct setup activities; to insure that the
renovation is performed in accordance with work practice standards; to verify work and cleanup
activities using the cleaning verification procedure; and, to train non-certified renovation personnel on-
the-job in lead-safe work practices.
The Certified Firm must ensure that the renovation is performed in accordance with the work practice
requirements in the Rule.
The Certified Firm is responsible for complying with pre-renovation education requirements.
The Certified Firm is also responsible for keeping all records including:
Pre-renovation education documentation (proof of receipt, proof of delivery, waivers, etc.);
Documentation of lead-based paint;
Training and certification records; and,
Cleaning verification records.
Note: Recordkeeping is covered in detail in Module 6.
1-4
October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
The RRP Rule:
Individual Certification
To become a Certified Renovator, an individual must either
take an EPA-approved 8-hour training course, or for those
with previous training an EPA-approved 4-hour training
course, from an EPA-accredited training provider.
The course completion certificate serves to certify
renovators (no application to EPA is required).
Refresher training is required every 5 years.
Workers do not need certification so long as on-the-job
training is received from a Certified Renovator and the
work is not HUD-regulated.
>>EPA
October 2011
All renovations must be directed by Certified Renovators. Individuals may become Certified Renovators
by completing either:
1) An EPA-approved 8-hour training course in lead-safe work practices taught by an EPA-accredited
training provider, or
2) Renovators and Dust Sampling Technicians who take the appropriate prerequisite course (see
www.epa.gov/lead/pubs/trainerinstructions.htm for list of courses) before the effective date of October 4,
2011 may take an accredited refresher course in lieu of the initial training.
Successful completion of the appropriate course will result in a 5 year certification as a Certified
Renovator. To maintain certification, Certified Renovators must take an EPA-approved 4-hour refresher
course taught by an EPA-accredited training provider, before their certification expires.
No application or fee is required to become a Certified Renovator. Instead, the course completion
certificate serves as the renovator certification. A "copy" of the initial and/or refresher course completion
certificate must be available on-site during the work.
States, territories and tribes may establish requirements for individual renovators working within their
jurisdictions. Be sure to determine if your state, territorial or tribal government has additional regulations
that may affect what you must do and where you may work.
HUD requires instructor-led training for all workers unless they are supervised
by a certified abatement supervisor (who, under the RRP Rule, must also be a
Certified Renovator).
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October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
The RRP Rule: Certified Renovator
Responsibilities
Perform work and direct lead-safe work practices.
Provide applicable on-the-job training to non-certified workers.
Keep a copy of initial and/or refresher training certificates onsite.
When requested, conduct testing for lead-based paint using EPA-
recognized test kits or collect paint chip samples for lab analysis
and report findings.
Be physically present while posting signs, containing work areas,
and cleaning work areas.
Be available by telephone when off-site.
Maintain the containment to keep dust and debris within the work
area.
Implement the cleaning verification procedure.
Prepare and maintain required records. <>EPA w
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October 2011 1-6
The RRP Rule requires that an individual Certified Renovator be responsible for the renovation job
regardless of the level of training and certification of the other persons working on the job. This
individual Certified Renovator has the following responsibilities.
1. Perform work and direct the work of non-certified renovation workers.
2. Train all non-certified workers on-the-job in lead-safe work practices applicable to their duties.
3. Maintain copies of initial and/or refresher training certifications onsite.
4. When requested, conduct testing for lead-based paint using EPA-recognized test kits or collect paint
chip samples for lab analysis and report findings.
5. Remain onsite during the sign posting, work area setup, and cleanup phases of work.
6. When not on site, be available by telephone or pager.
7. Make sure that the containment is maintained in a way that prevents the escape of dust and debris.
This responsibility implies a need to determine which work practices should be used to minimize dust.
8. Conduct the cleaning verification procedure to make sure that the work is complete and that the work
area is ready to reoccupy.
9. Prepare a summary of the work, on-the-job training records, and certify that all work was done in a
lead safe manner.
1-6 October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
Pre-Renovation Education
Requirements
The RRP Rule updated the Pre-
Renovation Education Rule. This slide
summarizes the changes.
Renovation firms must provide the new Renovate
Right pamphlet (Appendix 3) to owners and
occupants of target housing before renovation starts.
In a child-occupied facility, Renovate Right must be
provided to the owner or an adult representative
before renovation.
For work in common areas of multifamily housing or
child-occupied facilities, firms must notify tenants or
parents/guardians of the children, or post
informational signs about the renovation or repair.
See the Compliance Guide (Appendix 4) for more ,
information.
October 2011
Exclusions: The Pre-Renovation Education Rule covers the same renovation activities that are covered
by the Renovation, Repair, and Painting Rule. The same exclusions apply. (Refer to Module 2 for more
information on exclusions.)
Work in Homes: No more than 60 days before beginning a renovation, Certified Renovation Firms must
distribute the Renovate Right pamphlet to the owners and residents of the pre-1978 housing to be
renovated. Firms must either obtain the owner's written acknowledgment or proof that the pamphlet was
sent by certified mail, return receipt requested, at least 7 days before the renovation began. For tenants,
Certified Firms must either obtain a written acknowledgment of receipt, or document that the firm
delivered the pamphlet and was unable to obtain a written acknowledgment. All proof of
receipt/mailing/delivery records must be kept for 3 years after completion of the renovation. Sample forms
to document confirmation of receipt are included in the Renovate Right pamphlet.
Work in Common Areas: No more than 60 days before beginning a renovation, Certified Renovation
Firms must provide the Renovate Right pamphlet to the owner of pre-1978 housing being renovated.
Firms must provide written notification to all residents in the affected units of the property being
renovated, must notify affected residents about where information is posted if work in nearby common
areas will affect them. The following information should be posted about work in common areas:
Describing the nature and location of the work;
Listing the work start and end dates; and,
Providing the Renovate Right pamphlet or information on how to obtain a free copy of the pamphlet.
This information may be provided to tenants by mail, hand-delivery, or by posting signs containing
this information where they are likely to be seen by the residents of all affected units.
Work in Child-Occupied Facilities: No more than 60 days before beginning a renovation, Certified
Renovation Firms must distribute the Renovate Right pamphlet to the owner of the building and to an
adult representative of the child-occupied facility, following the same documentation requirements as for
homes. Firms must also provide notification to parents and guardians of children using the child-occupied
facility, following the same requirements as for tenants affected by renovations in common areas.
To obtain copies of the Renovate Right pamphlet visit the EPA website at www.epa.gov/lead, or contact
the National Lead Information Center at 1-800-424-LEAD (5323). The pamphlet may be copied for
distribution as needed to comply with pre-renovation education requirements.
1-7
October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
The RRP Rule:
Work Practice Standards
The Renovation, Repair, and Painting Final Rule
covers setup of the work area, prohibited work
practices, cleanup and the cleaning verification
procedures.
Setup practices, such as posting signs and containing
the work area, will be covered in Module 3.
Prohibited practices and dust control will be covered
in Module 4.
Cleanup practices and cleaning verification
procedures will be covered in Module 5.
Recordkeeping will be covered in Module 6;ฎ!|PA
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October 2011 1-8
Work practice standards found in the Renovation, Repair, and Painting Rule are required during all
renovations in target housing and child-occupied facilities if lead-based paint is disturbed.
HUD has additional work practice requirements. See Slide 1-11.
1-8
October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
The RRP Rule: Enforcement
EPA may suspend, revoke, or modify a
firm's certification if the Certified Firm or
Certified Renovator is found to be in non-
compliance.
Those firms found to be non-compliant
may be liable for civil penalties for each
violation.
Those firms who knowingly or willfully
violate this regulation may be subject to
additional fines per violation, or
imprisonment, or both. aepa
October 2011
Enforcement:
EPA has the authority to seek civil fines for each violation and an additional criminal fine plus jail time
for knowing and willful violations of the Renovation, Repair, and Painting Rule requirements.
EPA can also revoke certification for of a Certified Firm or a Certified Renovator who violates
Renovation, Repair, and Painting Rule requirements.
Note that violators may be both Certified Renovation Firms and non-certified contractors who are not
aware of or have ignored the requirement to become a Certified Renovation Firm.
1-9
October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
HUD's Lead Safe Housing Rule
(LSHR)
Covers target HOUSING that is
Federally-owned or assisted.
Does not cover child-occupied facilities.
Key differences between the LSHR and
the RRP Rule are shown in text boxes
with the HUD logo.
See Appendix 2 for a complete
discussion of additional requirements
imposed by the LSHR on Certified
Renovators working in Federally-
assisted target housing.
>>EPA
October 2011
Renovators must determine if a property is Federally-assisted by asking the owner or a designated party.
When conducting renovation activities in Federally-assisted target housing, renovators must follow all
requirements of the RRP Rule as well as LSHR. The major differences are as follows:
Training: EPA requires that Certified Renovators be responsible for renovation projects. Because of
this requirement, there are now two major training options for renovation work under the LSHR:
All renovation workers on the job are trained as Certified Renovators; or,
The designated Certified Renovator is also a Certified Lead Abatement Supervisor, and all workers
who are not certified renovators have on-the-job training in lead-safe work practices (see Module 7).
Determination that Lead-Based Paint is present: EPA-recognized test kits may not be used to test
for lead-based paint (LBP); only a Certified Lead Inspector or Risk Assessor may determine whether
or not LBP is present.
Prohibited Practices: HUD prohibits the same practices as the EPA RRP Rule, plus three more:
Heat guns that char paint;
Dry scraping or sanding except within 1 ft. of electrical outlets; and,
Use of a volatile paint stripper in a poorly ventilated space.
De minimis levels: In Federally-assisted target housing, all areas of deteriorated paint in the work area
must be repaired. Work affecting less than "de minimis" amounts of LBP is not required to follow the
lead safe work practices and clearance requirements in the LSHR. HUD's "de minimis" limits are
smaller than the limits for minor repair and maintenance activities in the EPA's RRP Rule.
Clearance Testing: HUD requires a clearance examination after renovation work above the de minimis
level, in homes regulated by the LSHR. HUD requires a clearance examination by a party
independent of the renovator, and, therefore, does not allow acceptance of the Certified Renovator's
visual inspection or use of the cleaning verification procedure. When the HUD LSHR applies to your
work (see Appendix 2), a clearance examination must be performed by a certified professional such
as a Lead Inspector, Lead Risk Assessor, or Dust Sampling Technician. Some state and local
authorities have different clearance requirements and standards.
Occupant Notification: HUD requires notices to be distributed to occupants within 15 days after lead
hazard evaluation and control activities in their unit (or common areas, if applicable).
1-10
October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
State and Local Regulations
States and localities may have different
regulations than EPA and HUD for
renovations in target housing.
Check with your state and local housing and
environmental agencies to obtain
information about such requirements.
Appendix 7 is reserved for copies or
summaries of state and local regulations.
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October 2011 1-11
States, territories and tribes may seek authorization from EPA to operate their own programs. Also,
states, territories and tribes, whether authorized by EPA or not, can establish additional requirements for
firms working within their jurisdictions. Be sure to determine if your state, territorial or tribal government
has additional regulations that may affect renovation in your community.
1-11
October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
Know the Rules!
To obtain a copy of the EPA or HUD regulations contact the
National Lead Information Center at 1-800-424-LEAD or
download them from the following websites:
http://www.epa.gov/lead
http://www.hud.gov/offices/lead
U.S. Occupational Safety and Health Administration
(OSHA):
Establishes worker protection standards.
For more information, on the OSHA Lead in
Construction Standard, see
http://www.osha.qov/Publications/osha3142.pdf.
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State and local regulations:
Renovators must follow all applicable state and local
regulations during renovations. yyEPA
October 2011
EPA Renovation, Repair, and Painting Rule:
Individuals and firms performing renovation, repair, and painting in pre-1978 dwellings and child-occupied
facilities should understand the EPA Renovation, Repair, and Painting Final Rule.
HUD's Lead Safe Housing Rule:
Individuals performing renovation, remodeling, and rehabilitation in pre-1978 housing that is Federally-
assisted, need to understand the HUD Lead Safe Housing Rule. Appendix 2 contains more information
on the HUD Lead Safe Housing Rule.
U. S. Occupational Safety and Health Administration (OSHA):
OSHA has a Lead in Construction Standard which outlines worker protection requirements. Your
employer should be aware of these. For more information, on the OSHA Lead in Construction Rule, see
www.osha.gov/Publications/osha3142.pdf. Another helpful OSHA publication addresses general safety
and health hazards in construction, OSHA 3252 Construction Pocket Guide, it's available at
https://www.osha.gov/Publications/osha3252.pdf.
State and Local Regulations:
State and local regulations may also apply to the renovation work you do. Where applicable, these
requirements will be covered at this point in this module.
1-12
October 2011
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Module 2: Testing for Lead-based Paint
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Lead Safety for Renovation, Repair, and Painting Refresher
Module 2: Testing for Lead-based
Paint
Overview
This module teaches you:
To test for lead-based paint.
To use EPA-recognized test kits to check for
lead-based paint.
To collect a paint chip sample for lead
analysis at a NLLAP-recognized entity.
&EPA fM
United States
Environmental Protection
Agency
October 2011
Module Overview
This module teaches how and when to use EPA-recognized test kits to determine if lead-based paint
affects renovation activities.
This module also teaches the procedure for collecting paint chip samples for lead analysis at a NLLAP-
recognized entity.
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October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
How to Test for Lead-Based Paint
Paint testing must be performed prior to renovation on
all surfaces to be affected by the work, or you must
presume the paint is lead-based. Any testing must be
performed by the approprial
te qualified professional.
Type of Paint Testing for
Renovations
Who can do the testing?
EPA-recognized test kits
Certified renovators
X-Ray Fluorescence instruments
Certified lead-based paint
inspectors or risk assessors
Paint chip sampling
Certified renovators, inspector
or risk assessor
&EPA /jfil.
United States
Environmental Protection
Agency
October 2011
Lead-based paint can only be identified by testing paint. Results of testing only apply to the work if the
surfaces covered by the renovation are covered by the testing report. A property owner may provide a
report from a Certified Lead Inspector/Risk Assessor that proves no lead-based paint is present, in lieu of
testing affected surfaces. If no testing result is available, test the paint or presume lead-based paint is
present.
EPA-Recoqnized Test Kits: Check the EPA website at www.epa.gov/lead for information on EPA-
recognized test kits and how to use them. EPA is currently reviewing more sensitive test kits which may
come on the market. All test kits currently on the market are colorimetric tests for lead; that is, they
change color when lead is present. Different test kit chemicals produce different colors when lead is
present. All paint layers must be tested when using test kits. Make sure to follow the manufacturer's
instructions when using this testing method. If there is no color change on the paint film tested, lead-
based paint is not present and lead-safe work practices are not required on that surface. Test kit sampling
is intrusive and damages each surface tested. Common kit types include:
Rhodizonate-based test kits that produce a pink to red color when lead is present; and,
Sulfide-based test kits that produce a dark grey to black color when lead is present.
X-Rav Fluorescence Testing: Requires a special instrument and a specially-trained Certified Lead
Inspector or Certified Lead Risk Assessor. The instrument tests by bombarding the paint film with gamma
radiation that causes the lead in the paint to emit x-rays that can be read by a sensor in the instrument.
The amount of lead in the paint is directly related to the x-rays read by the sensor. A computer program in
the instrument calculates how much lead is in the paint film. This testing method is non-intrusive and is
the most used.
Paint-Chip Collection for Laboratory Analysis: Paint-chip testing requires intrusive sampling. All paint
layers are removed from the surface being tested. The resulting sample is sent to an EPA-recognized
laboratory where it is analyzed to determine how much lead is present. Paint chips can be collected by
Certified Renovators, Certified Inspectors or Certified Risk Assessors. Laboratory charges are based on
turnaround time, and it usually requires a day or two to get results. Intrusive sampling makes repair of
tested surfaces necessary.
2-2
October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
Using EPA-Recognized Test Kits
to Check for Lead-Based Paint
Only use EPA-recognized test kits on
substrates approved for the kit.
Submit a testing report of results from use of
an EPA-recognized test kit to the client as
soon as possible, but no later than 30 days
after completing the renovation.
&EPA fM
United States
Environmental Protection
Agency
October 2011
it test kits are used, you must use an EPA-recognized test kit.
Presently, EPA is only requiring the use of test kits that determine that lead-based paint is not
present on the surfaces tested. Refer to test kit instructions to determine if lead is absent. If lead is
not determined to be absent using the test kit the surface must be presumed to be coated with
lead-based paint.
A negative test result will mean that lead safe-work practices are not required.
Alternatively, sampling may be performed by a Certified Lead Inspector or Risk Assessor to
determine whether or not lead-based paint is present.
If test kits are used, Certified Renovators must use an EPA-recognized test kit in order to test
affected surfaces. EPA-recognized test kits will be listed on the EPA website at www.epa.gov/lead.
What should be tested?
Each building component to be renovated or disturbed by renovation must be tested, unless the
component is a part of a larger component system and is representative of the whole system. In
this case, a single component may represent the larger system. For instance, a stair tread may
represent the whole stair system if the painting history of both is similar. If the painting histories are
similar and the tested tread shows a negative test for lead-based paint, then the RRP Rule does
not apply to the stair system.
What substrates can be tested?
Recognized test kits should only be used to test for lead in paint on substrates for which they are
approved. Where testing is needed on a non-approved substrate, or a surface coating other than
paint, a certified risk assessor or lead inspector would be required to do such sampling.
Reporting
When EPA-recognized test kits are used, the Certified Firm must provide a report to the client
within 30 days after completion of the renovation. The date of testing, identification of and contact
information for the Certified Firm and Certified Renovator performing the testing, test kit
manufacturer's name and kit identification, locations of surfaces tested, descriptions of the surfaces
tested, and the results of testing must be included in the report to the owner.
2-3 October 2011
-------
Lead Safety for Renovation, Repair, and Painting Refresher
Paint Chip Sample Collection
Method
This practice is used to collect samples for the
determination of lead on an area basis
(milligrams of lead) or concentration basis
(mass percent)
This is an alternative method for Certified
Renovators to check for lead-based paint.
Once collected, all paint chip samples must be
submitted to an entity recognized by NLLAP
for lead analysis. A .
y &EPA jiil.
United States
Environmental Protection
Agency
October 2011
If paint chip sampling is used, you must follow appropriate procedures.
Paint chip analysis result of lead greater than or equal to 1.0 mg/cm2 or 0.5% by weight indicates a
surface containing lead-based paint.
A paint chip analysis result of <1.0 mg/cm2 or 0.5% by weight will mean that lead safe-work
practices are not required.
Owners may choose to have sampling or XRF testing performed by a Certified Lead Inspector or
Risk Assessor to determine whether or not lead-based paint is present.
If paint chip samples are collected by the Certified Renovator, Certified Renovators must follow and
document appropriate procedures.
What components should be tested?
Each building component to be renovated or disturbed by renovation must be tested, unless the
component is a part of a larger component system and is representative of the whole system. In
this case, a single component may represent the larger system. For instance, a stair tread may
represent the whole stair system if the painting history of both is similar. If the painting histories are
similar and the tested tread shows a negative test for lead-based paint, then the RRP Rule does not
apply to the stair system.
What substrates can be tested?
Paint chip samples may be obtained from all painted substrates. Scrape and collect all paint down
to the substrate. Because of their porous nature or texture, sample collection is more difficult from
substrates such as brick, concrete, and wood.
Reporting
When paint chip samples are obtained by a Certified Renovator, the Certified Firm must provide a
report to the client within 30 days after completion of the renovation. The date of testing,
identification of and contact information for the Certified Firm and Certified Renovator performing
the testing, laboratory name, locations of surfaces tested, descriptions of the surfaces tested, and
the results of testing must be included in the report to the owner.
Note: If lead is reported below the regulatory level it is still advisable to use lead-safe work practices
because lead-hazards can be created at those paint lead levels.
2-4
October 2011
-------
Lead Safety for Renovation, Repair, and Painting Refresher
Steps to Obtain Paint Chip
Samples
1. Record test location information
2. Mark collection area
3. Set up a paint collection tray
4. Remove the paint
5. Clean all cutting tools
6. Transfer sample to the collection container
7. Check documentation for completeness on
the Paint Chip Sample Collection Form
SEPA
United States
Environmental Protection
Agency
October 2011
Overview of paint chip sample collection (see Appendix 9 for detailed instructions):
Step 1: Write required information and observations about the test location on the Paint Chip
Sample Collection Form and Paint Chip Sample Container.
Step 2: Mark the Collection Area using a template or freehand.
Step 3: Set up a Paint Collection Tray
Step 4: Remove the Paint
Step 5: Clean all cutting tools used during paint sample collection.
Step 6: Transfer the Collected Sample to the Paint Collection Container.
Step 7: Check documentation for completeness on the Paint Chip Sample Collection Form
2-5
October 2011
-------
Lead Safety for Renovation, Repair, and Painting Refresher
Test Kit Hands-on
Purpose: The purpose of this hands-on exercise
is to teach Certified Renovators how to correctly
use EPA-recognized test kits to determine if
lead-based paint is present on components and
surfaces affected by renovation work.
SEPA
United States
Environmental Protection
Agency
October 2011
2-6
October 2011
-------
Lead Safety for Renovation, Repair, and Painting Refresher
Paint Chip Sample Collection
Hands-on
Purpose: The purpose of this hands-on exercise is
to teach Certified Renovators how to correctly
collect paint chip samples from components
affected by renovation.
SEPA
United States
Environmental Protection
Agency
October 2011
2-7
October 2011
-------
LEAD SAFETY for Remodeling, Repair and Painting
Skill Set #1: Using EPA-Recognized Test Kits and Collecting Paint Chip Samples -
Continued
Skills Practice:
Paint Chip Collection Procedure
Step 1: Read Paint Chip Sample Collection Guide (see Appendix 9) Step 2: Write
required information and observations about the test location on the Paint Chip
Sample Collection Form.
Step 3: Mark the Collection Area either using a template or freehand.
Step 4: Set up a paint collection tray using a sheet of letter-sized white paper for making
a paper funnel for paint sample collection.
Step 5: Remove the paint using a cold scraping method (see step 5-1 below). Don plastic
gloves as appropriate
Step 5-1: Cold Scraping Method. Using the appropriate cutting tool, begin removing the
paint from the substrate. Carefully scrape away all paint within the marked area
down to the substrate and ensure that all the scraped paint lands in or is pushed
into the paint collection tray
Step 6: Cleaning all cutting tools used during paint sample collection.
Step 7: Check documentation for completeness on the Paint Chip Sample Collection
Form
Step 8: Transfer the Collected Sample to the Paint Collection Container.
Step 9: Label the container with sufficient information to uniquely identify the sample. Be
sure to record the dimensions of the sample surface, including the measurement
units.
Step 10: Submit the paint chip sample for lead analysis to a NLI_AP-recognized laboratory.
Record all results reported from the laboratory.
Documenting Paint Chip Sample Lead Analysis Results:
A report of the findings from the submitted paint chip samples to a NLLAP-recognized entity
must be given to the person contracting the work within 30 days following the completion of the
renovation work. The Certified Firm should keep the completed Paint Chip Sample Collection
Form for 3 years after the work is completed.
Hands-on Exercises
October 2011
A6-10
-------
LEAD SAFETY for Remodeling, Repair and Painting
Paint Chip Sample Collection Form Page 1 of
Client/Project Information
Name of Owner/Proiect:
Address:
Citv:
State:
Zip code:
Contact # ( )
Email:
Renovation Information
Fill out all of the following information that is available about the Renovation Site, Firm and Certified
Renovator.
Renovation Address: Unit #:
City: State: Zip code:
Certified Firm Name:
Address:
City: State: Zip code: Contact #: ( ) -
Email:
Certified Renovator Name:
Date Certified / /
Paint Chip Sample Information
For each sample collected, fill out all of the following information
Sample Identifier:
Sample Collector Name:
Sampling Location:
Sampling site description:
Sample Dimensions (cm):
NLLAP-recognized entity and location
Submission date: / / Results: Result Date: / /
Date of Collection: / /
Calculate Sample Area (cm2) :
Hands-on Exercises
October 2011
A6-11
-------
LEAD SAFETY for Remodeling, Repair and Painting
Paint Chip Sample Collection Form
Page of
Renovation Address:
City:
State:
Zip code:
Unit #:
For each sample collected, fill out all of the following information
Sample Identifier:
Sample Collector Name:
Sampling Location:
Sampling site description:.
Sample Dimensions (cm):
Date of Collection: / /
_Calculate Sample Area (cm ):_
NLLAP-recognized entity and location:
Submission date: / / Results:
Result Date: /
For each sample collected, fill out all of the following information
Sample Identifier:
Sample Collector Name:
Sampling Location:
Sampling site description:.
Sample Dimensions (cm):
Date of Collection: /
_Calculate Sample Area (cm2):
NLLAP-recognized entity and location:
Submission date: / / Results:
Result Date:
/ /
Hands-on Exercises
October 2011
A6-12
-------
LEAD SAFETY for Remodeling, Repair and Painting
Skill Set #1: Using EPA-Recognized Test Kits and Collecting Paint Chip Samples for
Laboratory Lead Analysis
Time: 25 minutes
October 2011
Test Kit Supplies needed:
EPA-recognized test kit(s) w/ manufacturer's instructions
Kit-specific supplies as required in the manufacturer's instructions
Disposable plastic drop cloth 2' by 2'
Tape (duct, painters, and masking)
Disposable, non-latex gloves
Disposable shoe covers
Manufacturer provided test verification card with lead-based paint layer
Disposable wet cleaning wipes
Heavy duty garbage bags
Painted wood surface with no lead-based paint layer
Test Kit Documentation Form
Participant Progress Log
Pen or pencil
Digital camera (Optional)
Numbered index cards (Optional)
EPA vacuum with attachments (for cleanup after sampling)
Paint Chip Sample Collection Supplies needed:
Resealable Rigid Walled Container, for use as paint collection containers, e.g. screw-top
plastic centrifuge tube
Steel or Plastic Measuring Ruler-Metric Only
Cloths
White Paper
Indelible Marking Pen
Personal Safety Gear
Cutting and Scraping Tools
Flashlight
Plastic gloves
Painted wood surface with lead-based paint layer
Trash bags
Paint Chip Sample Collection Form
Note to Instructor: It is strongly suggested that instructors prepare plastic bags
containing all materials needed for the hands-on exercises, prior to the exercise, in
order to meet the time limits allocated to Skill Set #1.
Purpose: The purpose of this hands-on exercise is to teach students how to correctly
use EPA-recognized test kits to determine if lead-based paint is present on components
and surfaces affected by renovation work. In addition, students will learn an alternative method
for determining the presence of lead-based paint by collecting paint chip samples that are
submitted to a NLLAP-recognized laboratory for analysis.
Hands-on Exercises
October 2011
A6-5
-------
LEAD SAFETY for Remodeling, Repair and Painting
Note to Instructor: Read the purpose of this activity to students and remind them to
document all areas where the paint color or substrate reactions may cause an
incorrect result. These surfaces should not be tested with a test kit, but should either
be tested by Certified Inspectors or Certified Risk Assessors; or must be assumed to
contain lead-based paint.
Demonstration: The course instructor must show and explain all of the steps involved in
the use of EPA-recognized test kits as well as the collection of paint chip samples for lead
analysis. The demonstration should not take longer than 5 minutes for each method including
the time needed to hand out materials.
Evaluating the Students: Allow students to practice the required steps on the following
pages. Watch each student follow the steps. Make corrections and suggestions as the
exercise proceeds and determine if additional practice is necessary. This should take no
longer than 10 minutes. Students must complete all required steps to be "Proficient".
Evaluate the work of each student and once the student can use a test kit and sample paint
chips correctly, the instructor should write the word "Proficient" in the field on the Participant
Progress Log that corresponds to Skills Set #1 and that particular student's name.
Hands-on Exercises
October 2011
A6-6
-------
LEAD SAFETY for Remodeling, Repair and Painting
Skill Set #1: Using EPA-Recognized Test Kits and Collecting Paint Chip Samples -
Continued
Skills Practice:
Test Kit Procedure
Step 1: Read the manufacturer's instructions
Step 2: Write required information and observations about the test location on the Test
Kit Documentation Form*
Step 3: (Optional) Secure a small disposable plastic drop cloth (2ft x 2 ft) on the floor
beneath the test location with masking tape.
Step 4: Put on disposable non-latex gloves and shoe covers.
Step 5: Follow the manufacturer's instructions for use of the test kit to conduct the
test.* If possible, perform one test where a positive test result can be observed;
and conduct one test of a painted wood surface with no lead-based paint layer
to observe a negative test result.*
Step 6: Use one wet cleaning wipe to remove residual chemicals left on the surface
tested. Use a second cleaning wipe to remove any visible debris or dust on the
floor beneath the sample collection area and place the used cleaning wipe in
the trash bag*
Step 7: Check documentation for completeness and note the result of the testing on
the Test Kit Documentation Form*
Step 8: (Optional) Number the test location in sequence on the Test Kit Documentation
Form, then select the corresponding numbered index card and tape it next to
the test location with masking tape and take a picture of the numbered test
location to photo-document conduct and possibly the result of the test.
indicates required skills that must be accomplished for a "Proficient" rating.
Interpreting the Results of Test Kit Sampling:
The manufacturer's instructions will indicate how to determine the absence of lead
in paint. Once the test is conducted, note the result and refer to the manufacturer's
guidelines for interpreting the result. All painted surfaces where lead is not determined
to be absent must be treated as lead-based paint until additional testing performed
by a Certified Lead Inspector or Risk Assessor proves it is not.
Documenting Test Kit Results:
A report of the findings from use of the test kit must be submitted to the person
contracting the work within 30 days following the completion of the renovation work. The
completed Test Kit Documentation Form should be kept by the Certified Firm for 3 years
after the work is completed.
Hands-on Exercises
October 2011
A6-7
-------
LEAD SAFETY for Remodeling, Repair and Painting
Test Kit Documentation Form Page 1 of
Owner Information
Name of Owner/Occupant:
Address:
City: State: Zip code: Contact #: ( )
Email:
Renovation Information
Fill out all of the following information that is available about the Renovation Site, Firm, and
Certified Renovator.
Renovation Address:
Unit#
Citv: State:
Zip code:
Certified Firm Name:
Address:
Citv: State:
Zip code: Contact #: ( )
Email:
Certified Renovator Name:
Date Certified: / /
Test Kit Information
Use the following blanks to identify the test kit or test kits used in testing components.
Test Kit #1
Manufacturer: Manufacture Date:
/ /
Model:
Serial #:
Expiration Date:
Test Kit #2
Manufacturer:
Manufacture Date:
/ /
Model:
Serial #:
Expiration Date:
Test Kit #3
Manufacturer:
Manufacture Date:
/ /
Model:
Serial #:
Expiration Date:
Hands-on Exercises
October 2011
A6-8
-------
LEAD SAFETY for Remodeling, Repair and Painting
Test Kit Documentation Form
Page of
Renovation Address: Unit#.
City: State: Zip code:
Test Location # Test Kit Used: (Circle only one) Test Kit #1 Test Kit #2 Test Kit #3
Description of component tested including location:
Result: Is lead present? (Circle only one) YES NO Presumed
Test Location # Test Kit Used: (Circle only one) Test Kit #1 Test Kit #2 Test Kit #3
Description of component tested including location:
Result: Is lead present? (Circle only one) YES NO Presumed
Test Location # Test Kit Used: (Circle only one) Test Kit #1 Test Kit #2 Test Kit #3
Description of component tested including location:
Result: Is lead present? (Circle only one) YES NO Presumed
Test Location # Test Kit Used: (Circle only one) Test Kit #1 Test Kit #2 Test Kit #3
Description of component tested including location:
Result: Is lead present? (Circle only one) YES NO Presumed
Test Location # Test Kit Used: (Circle onlv one) Test Kit # 1
Description of component tested including location:
Test Kit # 2
Test Kit # 3
Result: Is lead present? (Circle only one)
YES
NO
Presumed
Test Location # Test Kit Used: (Circle onlv one)
Description of component tested including location:
Test Kit # 1
Test Kit # 2
Test Kit # 3
Result: Is lead present? (Circle only one)
YES
NO
Presumed
Test Location # Test Kit Used: (Circle onlv one)
Description of component tested including location:
Test Kit # 1
Test Kit # 2
Test Kit # 3
Result: Is lead present? (Circle only one)
YES
NO
Presumed
Hands-on Exercises
October 2011
A6-9
-------
Module 3: Review of Setup Practices
-------
Lead Safety for Renovation,
Module 3:
Repair, and Painting Refresher
Review of Setup Practices
Overview
Containing dust for interior activities.
Containing dust for exterior activities.
&EPA fM
United States
Environmental Protection
Agency
October 2011
Upon completion of this module you will be able to:
Establish containment systems that will keep dust inside of the work area to allow you to clean more
efficiently at the end of the day and at completion of the job;
Identify containment requirements for interior renovations; and,
Identify containment requirements for exterior renovations.
In general, there are many degrees of containment, ranging from simple plastic sheeting on the
floor surrounding a small work area to a fully enclosed space. Some types of containment are
more effective than other types.
For purposes of this training, "containment" is what is required under the RRP Rule to prevent dust
and debris from spreading beyond the work area to non-work areas.
Containment is required by the RRP Rule because it:
Reduces the risk to you and residents. Following the work area setup requirements of this module
will protect you, your co-workers and residents by confining lead-contained dust and debris to a
defined and demarcated area. Confining the lead is an important consideration in avoiding exposure.
Reducing the risk to you and co-workers is also dependent upon use of personal protective
equipment.
Facilitates efficient cleaning of the work area. The pre-work setup process is essential to keeping
lead-contaminated dust confined to the work area where it can be easily cleaned. Proper containment
of the work area helps to limit the area you need to clean after the job is complete. Knowing exactly
where to clean is an important factor in saving time (and money) spent on cleanup.
Containing the work area includes:
Removing objects and furniture from the work area, or covering them with plastic sheeting.
Covering floors (or the ground) with plastic sheeting a minimum distance beyond the surfaces being
renovated (6 feet for interior jobs and 10 feet for exterior jobs).
Vertical containment is required for any exterior renovation within 10 feet of the property line.
Larger areas of disposable plastic sheeting may also be necessary to prevent the spread of dust.
Smaller areas of containment may be used if additional precautions such as vertical containment
are used to stop the spread of dust and minimize the area of cleanup.
Closing windows and doors, and using plastic sheeting to seal doors and air ducts in the work area.
Covering doors used to enter the work area with plastic sheeting in a manner that allows workers to
pass through but contains dust and debris within the work area.
3-1 October 2011
-------
Lead Safety for Renovation, Repair, and Painting Refresher
Keep Dust Within the Containment
Containment is required.
You are responsible for making sure dust
does not migrate out of containment.
Consider how much dust the renovation will
generate.
Plan the size and configuration of containment
to keep the generated dust within
containment.
v>EPA ,
United States
Environmental Protection
Agency
October 2011
If you do not plan and contain the work area correctly, the dust and debris created by renovation
can spread beyond the minimum contained area required by the RRP Rule. This means that:
For interior locations, dust may migrate more than 6 feet from the surface being renovated; or,
For exterior locations dust may migrate more than 10 feet from the surface being renovated.
Controlling dust and debris may require more extensive containment than is specified in the rule if the job
is particularly dusty. Plan accordingly.
In general, renovations that involve only a small amount of paint disturbance create less dust than jobs
that involve larger areas of paint disturbance. However, in addition to the size of the area of paint
disturbed, the work practices (e.g., sanding) and equipment used will also affect how much dust is
created and how the dust migrates. The location of the work activity also has a bearing on the amount of
dust that is distributed. For example, small areas of ceiling work can spread dust over the entire room and
are very difficult to control.
Required containment is similar for all jobs, but jobs that generate more dust and debris may require
protection of larger areas. While the RRP Rule does not require vertical containment, except for exterior
projects within 10 feet of a property line, such systems may be helpful in limiting the size of the area
affected by the work and may reduce the area that must be cleaned at the end of the job. Pre-engineered
containment systems (purchased and home-made) are very helpful in cutting time spent on the job
erecting containment and are easier to install than hanging plastic sheeting with tape. These systems
also allow the contractor to create a sealed area within a room where the dust can be completely
contained to a limited and controlled area.
Examples of dusty jobs include:
Hand scraping large areas.
Removing paint with a low temperature heat gun and scraper.
Removing dry residue and paint after using chemical strippers.
Demolishing painted surfaces.
Removing building components with painted surfaces that are in poor condition.
Remember, you are responsible for making sure that dust and debris remain inside of the
contained work area. When planning containment, keep in mind how, how much, and where the
work practices to be used will create dust, and plan accordingly.
3-2
October 2011
-------
Lead Safety for Renovation, Repair, and Painting Refresher
Vertical Containment
Vertical barrier of plastic
sheeting over a rigid
frame.
Required for exterior
jobs close to property
lines.
Can be used to minimize
floor or ground
containment needed.
October 2011
What is vertical containment?
Vertical containment means a vertical barrier consisting of plastic sheeting or other impermeable material
over scaffolding or a rigid frame, or an equivalent system of containing the work area. Vertical
containment is required for some exterior renovations but it may be used on any renovation.
Is vertical containment required for interior jobs?
No, the use of vertical containment is not required for interior jobs, but you can minimize the amount of
floor containment needed by making use of vertical containment for interior projects. Floor containment
measures may stop at the edge of the vertical barrier when using a vertical containment system
consisting of impermeable barriers that extend from the floor to the ceiling and are tightly sealed at joints
with the floor, ceiling and walls.
Is vertical containment required for exterior jobs?
Yes, vertical containment is required for exterior jobs where the property line is within 10 feet of the area
of paint disturbance. In addition, vertical containment can also be used to minimize the amount of ground
containment needed for a project. Ground containment measures may stop at the edge of the vertical
barrier when using a vertical containment system.
United States
Environmental Protection
Agency
3-3
October 2011
-------
Lead Safety for Renovation, Repair, and Painting Refresher
Overview of Interior Setup Steps
The goal of these interior setup practices
is to prevent dust and debris from
escaping the work area.
Limit access and post signs.
Remove or cover belongings
Cover floors.
Close windows, close and seal
doors and HVAC system.
Work area entry.
wmm
LEAD WORK AREA
POISON
NO SMOKING OR EATING
&EPA fM
United States
Environmental Protection
Agency
October 2011
RRP Rule: Interior Containment General Requirements:
Posted signs: These must be posted on all sides of the work area to define the work area, must be in
the primary language of occupants, must be posted before the beginning of the renovation, and must
remain until cleaning verification (or clearance) is achieved.
Contain the work area: Before renovation, isolate the work area to prevent the escape of dust. During
work, maintain the containment integrity and ensure that containment does not interfere with
occupant and worker egress from the home or work area.
Remove or cover furniture/objects: Remove (preferred) objects like furniture, rugs, window coverings;
or, cover them with plastic sheeting with all seams and edges taped.
Cover floors: Cover floors including carpets in the work area with taped down plastic sheeting or other
impermeable material to 6 feet beyond the perimeter of surfaces undergoing renovation or to a
distance sufficient to contain dust, whichever is greater. Note: Where vertical containment is used
floor containment measures may stop at the edge of the vertical containment.
Close windows, close and seal doors: Close windows, close and seal doors in the work area with
plastic sheeting or other impermeable material. Doors used as entrances to the work area must be
covered with plastic sheeting that allows workers to pass through while confining dust to the work
area.
Cover duct openings: Close and cover all HVAC vents in the work area with taped down plastic
sheeting or other impermeable materials (e.g., magnetic covers).
3-4
October 2011
-------
Lead Safety for Renovation, Repair, and Painting Refresher
Overview of Exterior Containment
Steps
Establish the work area.
Close all windows and doors.
Establish, as necessary, additional
containment to prevent spread of dust to
adjacent properties.
Erect Vertical Containment for any exterior
renovations within 10 feet of the property line.
&EPA rjfil.
United States
Environmental Protection
Agency
October 2011
RRP Rule: Exterior Containment General Requirements:
Posted signs: Signs must be placed on all sides of the work area to define the area, must be posted
in the primary language of occupants, and must be posted before the beginning of the renovation and
remain until cleaning verification is achieved.
Close doors and windows: Close all doors and windows within 20 feet of the work area. For multi-
story buildings close all windows and doors on the same floor within 20 feet of the work area and all
windows on all floors below that are the same horizontal distance from the renovation.
Doors used as entrances to the work area: Cover doorway openings with plastic sheeting that allows
workers to pass through while confining dust to the work area.
Cover the ground: Cover the ground with plastic sheeting or other impermeable material extending 10
feet beyond the perimeter of surfaces undergoing renovation or to a sufficient distance to contain
dust, whichever is greater, unless the property line prevents 10 feet of such ground cover in which
case the firm must erect vertical containment.
Ensure that dust and debris do not contaminate or migrate to adjacent areas or properties: In other
situations, the renovation will require extra precautions for containing the exterior work area to ensure
that dust and debris does not contaminate other properties, such as when working on multi-story
buildings. The RRP Rule establishes performance standards that the contractor must meet, but does
not specify how the contractor must meet them. This allows the contractor flexibility in how to comply
with the requirement to ensure that no dust or debris leaves the work area.
3-5
October 2011
-------
Module 4: Review of Prohibited Practices,
Personal Protective Equipment and Dust
Control
-------
Lead Safety for Renovation, Repair, and Painting Refresher
Module 4: Review of Prohibited
Practices, Personal Protective
Equipment and Dust Control
Overview:
Prohibited practices.
Protect yourself
Control the spread of dust.
&EPA fM
United States
Environmental Protection
Agency
October 2011
Requirements in the EPA RRP Rule:
The RRP Rule prohibits the use of certain practices. These prohibited practices are discussed in
this module. This module also contains recommendations regarding how to reduce dust during
work activities that are not specifically required or addressed in the RRP Rule. The practices you
choose to use in the contained work area must not include prohibited practices. Beyond this you are free
to use whatever practices get the job done, provided that all dust and debris you generate stays in the
work area and does not migrate to other areas or properties. The recommendations in this section will
assist you by reducing the amount of dust released during work. Dust reduction in the work area will
make the workplace safer for employees, and will make cleaning easier.
Upon completion of this module, you will know:
What work practices are prohibited under the RRP Rule because they create dangerous amounts of
dust and paint chips;
What practices to use to control dust, debris or paint chips; and,
What personal protection you need to work safely.
4-1 October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
Prohibited Practices
Open-flame burning or
torching.
Heat gun above 1100ฐ F.
Power sanding, power
grinding, power planing,
needle guns, abrasive
blasting and sandblasting,
without a shroud or
containment system
equipped with a HEPA
vacuum. ฃERA /j;
United States
Environmental Protection 'IIIIIH /
Agency
October 2011 4-2
The EPA Renovation. Repair, and Painting Rule does not specifically address what measures
must be taken to reduce the amount of dust generated on the job. Rather, the rule lists three
Prohibited Practices that must not be used on the job.
ฎ Open-flame burning or torching of painted surfaces
ฎ Heat gun above 1,100ฐ F (degrees Fahrenheit).
ฎ The use of machines designed to remove paint or other surface coatings through high-speed
operation such as sanding, grinding, power planing, needle gun, abrasive blasting, or sandblasting
unless such machines have shrouds or containment systems and are equipped with a HEPA
vacuum attachment to collect dust and debris at the point of generation. Machines must be
operated so that no visible dust release of air occurs outside the shroud or containment system.
A key to minimizing the spread of dust and paint chips is not to use certain traditional work practices
known to create large amounts of dust and debris.
Open-flame burning or torching of paint and using a heat gun above 1,100ฐ F create very fine
leaded dust particulates ("fume") that are dangerous for workers to breathe. The small leaded dust
particles created by burning and heating also settle on surrounding surfaces and are very hard to
clean up.
Power sanding, power grinding, power planning, needle guns, abrasive blasting, and
sandblasting create a large amount of dust that floats in the air and then settles on surfaces inside
and outside of the work area.
See Appendix 5 Steps to LEAD SAFE Renovation, Repair and Painting for more information.
The practices listed on the slide are also prohibited in pre-1978 properties with
lead-based paint that receive Federal housing assistance. The HUD Rule also
prohibits extensive dry scraping and sanding by hand, and paint stripping in a poorly
ventilated space using a volatile paint stripper. States, localities, or tribes may also
prohibit these practices.
4-2
October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
Dust Reducing Techniques
Wet scraping and sanding
Heat gun below 1,100 degrees F
Use of power tools with shrouds or
containment systems equipped with a HEPA
vacuum attachment
Chemical stripping
&EPA fM
United States
Environmental Protection
Agency
October 2011
Wet Methods:
Wet methods are a major part of dust reducing practices under the HUD Lead Safe Housing Rule.
While they are neither prohibited nor required under the EPA RRP rule, they are a very good work
practice and should be considered as a good way to control dust in the work area. They can also help
meet requirements of the OSHA lead in construction standard (29 CFR 1926.62). OSHA also requires
the use of ground fault circuit interruption (GFCI) protection on circuits in wet areas to prevent electric
shock.
Also keep in mind:
Chemical strippers can be dangerous. Some can cause burns. Methylene chloride is suspected to
cause cancer. The spectrum of chemical strippers ranges from citrus-based (safer) to more dangerous
caustic strippers. Follow the manufacturer's directions when using any chemical stripper. OSHA
requires hazardous materials communications.
If building components to be stripped can be removed, such as doors, consider having them stripped
off-site at a paint stripping facility.
Negative pressure respirators do not provide sufficient breathing protection when using methylene
chloride strippers. The OSHA standard for methylene chloride is 29 CFR 1910.1052.
4-3 October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
Specialized Tools
Large jobs may require special
considerations to get the job done,
like:
Power tools designed to remove paint or
other surface coatings must have a
shroud or containment system equipped
with a HEPA vacuum attachment.
Pneumatic and battery powered tools to
protect against shock hazards.
Specialized planning and containment.
October 2011
SEPA
United States
Environmental Protection
Agency
Only power tools designed to remove paint or other surface coatings equipped with shrouds or
containment systems with a HEPA vacuum attachment to collect dust and debris at the point of
generation may be used when lead-based paint is present or presumed to be present.
Electric power tools such as sanders, grinders, circular saws, reciprocating saws, planers and drills
produce dust and debris. Because they are electric, wet methods are not safe. Pneumatic and battery
powered tools prevent shock hazards. Such tools must have shrouds or containment systems
equipped with a HEPA vacuum attachment to contain the dangerous leaded dust and paint chips that
are generated by their use.
Tools with attached HEPA-filtered capture ventilation collect and filter dust and debris as it is created.
A shroud at the head of the tool helps to contain the dust and paint chips as the vacuum draws away
dust and debris for safe storage in the vacuum canister. This makes the job cleaner and safer.
Abrasive blasting is very effective at removing large areas of paint quickly, but these practices require
special HEPA filtration equipment that contains the blast medium, dust and paint chips without
releasing dust into the air or into the containment.
Containment is even more important when using specialized tools.
Proper containment and cleaning are crucial even when using HEPA-filtered specialized tools. These
tools generate a lot of dust inside a localized negative pressure (vacuum) environment. If the vacuum
fails or if the vacuum seal created by the shroud is broken, large volumes of dust can be released.
Nonetheless, HEPA-filtered specialized tools can reduce dust levels when used properly, and can aid
work production by shortening the cleaning time and lowering cost.
See the Shopping List of tools and supplies found in Appendix 5 Steps to LEAD SAFE Renovation,
Repair and Painting for more information.
4-4
October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
Protect Yourself
Workers should wear:
Disposable painter's hat.
Disposable coveralls.
Repair tears with duct tape.
Dispose of in plastic bag.
Disposable N-100, R-100 or P-100 respirator.
Wash face and hands frequently and at
the end of each shift.
Washing helps to reduce hand-to-mouth
ingestion of leaded dust.
OSHA may require more protection A EPA
depending on what work is done
October 2011
United States
Environmental Protection
Agency
Workers should protect themselves.
Painter's hats are an inexpensive way to keep dust and paint chips out of workers' hair. Painter's
hats can be easily disposed of, and should be disposed of at the end of each day or at the end of the
job.
Disposable coveralls are a good way to keep dust off workers' street clothes and reduce the chance
of carrying dust away as they come and go. Remember to use a HEPA vacuum to remove dust and
debris from coveralls or other outerwear (a "dry decon") before exiting the work area. Some coveralls
have a hood to keep dust out of hair.
Respiratory protection. Employers should consider that workers should wear respiratory
protection, such as a disposable N-100, R-100 or P-100 respirator and follow OSHA's Respiratory
Protection standard (29 CFR 1910.134) to prevent them from inhaling leaded dust. These respirators
are particulate-filtering respirators and would not be appropriate as protection from chemical stripping
compounds. To further protect workers, wet sanding and scraping will reduce airborne dust.
You should wash your hands and face at the end of each shift. Workers should wash their
hands and faces periodically to avoid ingesting leaded dust. You should also wash well before eating,
drinking or smoking. You should not eat, drink, or smoke in the work area. Some of the dust that
settles on the face around the mouth invariably finds its way into the mouth. Workers should also
wash at the end of the day before getting in their car or going home. They shouldn't take leaded dust
home to their families.
Personal protection is especially important on high dust generating jobs when lead-based paint or
lead-contaminated dust is disturbed, and while cleaning is being performed. However, the same level
of protection is not necessary during the planning, testing or setup phases of the work when lead is
not being disturbed.
The protective equipment listed above is meant to show what is needed during activities that disturb
lead-based paint and lead-contaminated dust. Depending upon work practices used, OSHA rules
may require employers to take further steps to protect the health of workers on the job.
OSHA provides additional information on working with lead in their Safety and Health Regulations for
Lead in the Construction Industry (29 CFR 1926.62).
4-5
October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
Control the Spread of Dust
When you leave the work site, clean yourself and your tools.
Remove shoe coverings and HEPA vacuum or wipe shoes.
Walk on disposable tack pads to remove dust from your soles.
HEPA vacuum and remove coveralls, and HEPA vacuum your
clothes.
Remove gloves if used, and carefully wash your hands and face.
At the end of the day don't take lead home to your family on your
clothes or in your car.
HEPA vacuum clothes, shoes, etc.
Change your clothes, and dispose of disposable clothing or place
dusty work cloths in a plastic bag to wash separately from
household laundry.
Don't hug your family until you get clean!
Wash your hands and face.
Shower as soon as you get home. &EPA (M.
United States
Environmental Protection
Agency
October 2011
Precautions to take when leaving the work site
When you leave the work site (the area covered by protective sheeting or the work room), take
precautions to prevent spreading dust and paint chips on your clothes and shoes to other parts of
the residence.
Every time you leave the plastic sheeting around the surfaces being renovated, remove the
disposable shoe covers and wipe or vacuum your shoes before you step off the plastic sheeting. A
large disposable tack pad on the floor can help to clean the soles of your shoes.
Every time you leave containment, HEPA vacuum and remove your disposable coveralls and
disposable shoe covers. Clean/vacuum your shoes, and wash your hands and face.
At the end of the day:
Change your clothes and wash yourself to reduce the risk of contaminating your car and
taking leaded dust home to your family.
Before leaving the worksite, remove any protective clothing, HEPA vacuum dust from non-
protective clothing, and thoroughly wash your hands and face. Throw away disposable
clothing or place clothing in a plastic bag to stop dust from getting on other clothes at home.
As soon as you arrive home, take a shower and be sure to thoroughly wash your hair,
especially before playing with children. Wash your work clothes separately from regular
household laundry to stop lead from getting on your other clothes.
Be clean before you come in contact with family members, especially children. Remember
the video about the contractor who lead-poisoned his own kids.
HUD requires wet scraping and wet sanding to stabilize defective paint surfaces,
except within 1 ft. of electrical outlets, or for very small projects (under 2 sq. ft. in
a room or 20 sq. ft. on exterior surfaces).
4-6
October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
Cleaning During the Job
A clean work site reduces the spread of dust
and paint chips.
Clean as you work.
HEPA vacuum horizontal surfaces.
Remove debris frequently.
Remove paint chips as they are created.
As building components are removed, wrap and
dispose of them immediately.
Clean frequently (in stages, at least daily).
v>EPA A
United States
Environmental Protection
Agency
October 2011
Clean the work site frequently.
Cleaning the work site frequently as the job progresses will reduce the spread of dust and paint chips.
Daily cleaning need not be as thorough as the final cleaning. It should, however, keep debris, dust
and paint chips from piling up and spreading beyond the immediate work site.
Daily cleaning during the job includes:
Removing debris frequently. Seal and dispose of construction debris as it is created.
Vacuuming horizontal surfaces frequently. HEPA vacuum dust and paint chips that settle on
surfaces, including protective sheeting. As workers come and go during the work day, this debris is
easily spread. Periodic cleaning throughout the work day helps minimize the spread of dust.
Collect paint chips as they are created. When removing paint, paint chips can spread outside the
immediate work area as workers come and go from the work site. To keep paint chips from spreading
beyond the work site, make sure that they are collected as they are created. Periodically HEPA
vacuum and dispose of paint chips.
Wrapping and disposing of removed components. When removing painted components such as
windows, trim and cabinets, wrap them in plastic sheeting and dispose of them in stages. This will
prevent the spread of debris and keep residents, especially children, from coming into contact with
leaded dust created by the work.
Safe Waste Disposal. All renovation waste from the work area must be contained prior to its
removal, storage, or disposal to prevent releases of dust and debris. Chutes for removing waste from
the work area must be covered. At the conclusion of each work day, collect waste and store it in
containment, in an enclosure, or behind a barrier that prevents the release of, and access to, dust
and debris. When transporting waste from the renovation work area it must be contained to prevent
the release of dust and debris.
How often should cleaning during the job take place?
The goal is to keep dust and debris under control, not to maintain a completely spotless site at all
times. Every job is different; so clean when it makes sense to, without hindering progress. Remove
large amounts of dust, paint chips, and debris frequently, at least daily.
4-7
October 2011
-------
Module 5: Cleaning Activities and Checking
your Work
-------
Lead Safety for Renovation, Repair, and Painting Refresher
Module 5: Cleaning Activities and
Checking Your Work
Overview
Interior cleaning techniques.
Exterior cleaning techniques.
How to check your work.
Cleaning verification procedure.
Clearance testing.
Safe disposal practices.
v>EPA rjfii;
United States
Environmental Protection
Agency
October 2011
What you will learn in this module:
This module will cover all the topics listed on the slide above.
The goal of cleaning is to leave the work area as clean as or cleaner than when you arrived so that, as
a result of your work, leaded dust is not left behind to poison the residents.
At the end of this module, you will know how to check your work to ensure the work area is clean
enough to pass the visual inspection and cleaning verification procedure, or pass a clearance
examination.
By using the techniques described in this module, you will be able to clean a work area quickly and
efficiently. Remember, approaching a cleanup is similar to approaching a job. Proper preparation and
planning will help make your cleaning efforts more effective and efficient.
Always schedule time at the end of each day to thoroughly clean the work area.
5-1 October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
Interior Cleaning
Requirements
Collect all paint chips and debris; seal in heavy duty plastic bags.
Mist, remove, fold (dirty side in) and tape or seal protective
sheeting. Dispose of sheeting as waste.
Plastic sheeting between non-contaminated rooms and work areas
must remain in place until after cleaning and removal of other
sheeting.
HEPA vacuum (operated following manufacturer's instructions) or
wet wipe walls from high to low, then HEPA vacuum remaining
surfaces and wipe with a damp cloth.
Clean 2 feet beyond the contained work area.
Use disposable wipes or change cloths frequently.
For carpet or rug, use HEPA vacuum with beater bar.
HEPA vacuum and wet mop uncarpeted floors. SEPA C\
Always begin cleaning activities by picking up paint chips and debris with a wet disposable cloth without
dispersing any of it, and sealing this material in a heavy-duty bag.
When the job is complete, mist the sheeting, fold it (dirty side in), and either seal it with tape, or seal it
in a heavy-duty bag. Always fold dirty side inwards, and seal with tape or place in a heavy duty plastic
bag. If it is placed in a heavy-duty bag, "gooseneck-seal" the bag and dispose of the bag with the rest of
your waste. Dispose of all sheeting as waste by using the correct folding and disposal procedure, after
it has been vacuumed.
Clean with a Plan
Start cleaning at the far end of the work area and work back to the exit.
Clean walls with a HEPA vacuum or by wiping with a damp disposable cloth: Start with the tops of the
walls, tops of doors and door frames and work down to the floor.
Thoroughly vacuum all remaining surfaces and objects, including furniture and fixtures, in the work
area. The HEPA vacuum must be equipped with a beater bar when vacuuming carpeting or rugs.
Wipe all surfaces and objects that remained in the work area, except carpeted or upholstered surfaces,
with a damp cloth.
Clean the floor last
Clean with a wet mopping system or a two-sided bucket and mop.
Clean the entire work area and the area within 2 feet of the work area.
If using the two-bucket mopping system, repeat the process using a new mop head and clean water.
Remember, always keep one bucket for cleaning solution and the other bucket for wringing out the
cloth or mop head. You must keep wash and rinse water separate. Change the rinse water often.
Check your work
Before a Certified Renovator visually inspects the work area, check your work to determine whether
dust, debris or residue is still present. If dust, debris or residue is still present, these conditions must be
corrected before the visual inspection is performed.
United States
Environmental Protection
Agency
October 2011
5-2
Pick up
5-2
October 2011
-------
Lead Safety for Renovation, Repair, and Painting Refresher
Visual Inspection Procedure
1. Conducted by Certified Renovator.
2. Put on disposable foot covers before entering the work area.
3. Make sure there is adequate lighting in the work area.
Turn on all of the lights or use a bright, white-light flashlight.
4. Systematically look for dust, debris or residue on every
horizontal surface in the work area and 2 feet beyond.
Work from the farthest area from the entry to the entry.
Closely examine each surface.
5. If you find visible dust, debris or residue then re-clean the work
area and repeat step 4.
6. Once you have carefully looked at all of the surfaces and found
no dust, debris or residue proceed to the cleaning verification
procedure or clearance.
v>EPA fM.
United States
Environmental Protection
Agency
October 2011
Visual inspection after cleaning is required by the RRP Rule.
A visual inspection must be conducted by a Certified Renovator once cleaning is complete, and prior to
the cleaning verification or clearance examination of the work area.
In a visual inspection, the Certified Renovator looks for dust, debris and residue.
Make sure that adequate lighting is provided during the cleaning and visual inspection of the work area.
You cannot see dust and small paint chips without adequate lighting.
Inspect the entire work area and the area 2 feet beyond the work area on all sides of the containment.
Visual inspection of the work area alone will not verify that the work area has been cleaned adequately
- visual inspection is only the first step. In many instances, leaded dust is not visible to the naked eye
and will not be detected during a visual inspection.
Once the visual inspection has been completed and no dust, debris or residue is present, the work area
must pass either the cleaning verification procedure or a clearance examination in order for the project
to be completed in compliance with the RRP Rule.
Whether the cleaning verification procedure or clearance examination is conducted will be based on
regulatory requirements or terms in the renovation contract.
5-3
October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
Cleaning Verification (CV)
Procedure
Wipe each window sill within the work area. Use a single wet
disposable cleaning cloth per window sill.
Wipe uncarpeted floors and all countertops with wet disposable
cleaning cloths. Wipe up to a maximum of 40 ft2 per cloth.
Compare each wipe to the CV card. If the cloth matches or is lighter
than the CV card, the surface has passed cleaning verification and
no further action is required.
If the cloth is darker than the CV card, re-clean and repeat the CV
process.
If the second wet cloth fails, wait 1 hour or until surfaces are dry,
and then wipe with an electrostatically-charged white disposable
cleaning cloth designed to be used for cleaning hard surfaces. This
completes the cleaning verification. ฃ ERA
United States
Environmental Protection
Agency
October 2011
After visual inspection, one of two activities must be conducted. A Certified Renovator must perform
cleaning verification or other certified professionals must conduct a clearance examination. The steps for
the cleaning verification procedure are explained below.
Window Sills
Using a single, wet, disposable cleaning cloth, wipe the entire surface of each window sill in the work
area.
Wipe Countertops and Floors
Wipe the entire surface of each countertop and uncarpeted floor within the work area with wet
disposable cleaning cloths. Floors must be wiped using a wet cleaning system, including a long
handle device with a head to which a wet disposable cleaning cloth is attached. The cloth must
remain damp at all times while being used to wipe the floor.
If the surface of a countertop or floor within the work area is greater than 40 square feet, the surface
within the work area must be divided into roughly equal sections that are each less than 40 square
feet. Wipe each surface section separately using a new wet disposable cleaning cloth.
Interpret the Cleaning Verification Procedure.
Compare each wipe representing a specific surface section to the cleaning verification card. If the
cloth used to wipe each surface section within the work area matches or is lighter than the cleaning
verification card, that surface section has been adequately cleaned.
If the cloth is darker than the cleaning verification card, re-clean that surface section, then use a new
wet disposable cleaning cloth to wipe the surface section. If the cloth matches or is lighter than the
cleaning verification card, that surface section has been adequately cleaned.
If the second cloth does not match and is not lighter than the cleaning verification card, wait for 1
hour or until the surface section has dried completely, whichever is longer. Then wipe the surface
section with an electrostatically charged white disposable cleaning cloth designed to be used for
cleaning hard surfaces. The cleaning verification procedure is now complete and the surface is
considered clean.
When cleaning verification has been completed for all of the surfaces in the work area (including
window sills), warning signs may be removed.
5-4
October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
Dust Clearance Examination
A dust clearance examination may be performed
instead of cleaning verification.
A clearance examination must be a conducted by a
Certified Lead Inspector. Risk Assessor, or Dust
Sampling Technician.
If clearance fails, the renovation firm must re-clean the
work area until dust clearance standards and any
state, territorial, tribal and local standards are met.
&EPA fM
United States
Environmental Protection
Agency
October 2011
Clearance Examination (Dust Clearance Testing) - Optional under the RRP Rule
Dust clearance testing may be performed to check the effectiveness of the cleaning efforts.
Clearance is an option under the EPA Renovation, Repair, and Painting Rule and is required by the
HUD Rule in many cases.
Dust clearance testing is performed to check the effectiveness of cleaning efforts.
In some cases, dust clearance testing may be required as part of "clearance" (a regulation-defined
process to ensure that a work area is not contaminated with leaded dust after work is completed).
Cleaning verification need not be performed if dust clearance testing is required at the conclusion of a
renovation. In such cases, dust clearance testing may only be performed by a Certified Lead
Inspector, Risk Assessor, or Dust Sampling Technician. The Certified Renovation Firm is required to
re-clean the work area until dust-lead levels in the work area meet the clearance standards. Some
state, local, and tribal laws may require a clearance examination following renovation and remodeling
work, to levels that differ from the Federal clearance standards. The selection of a CV or a clearance
examination will be based on regulatory requirements or the renovation contract.
^ENTQfr
Clearance is required by HUD's Lead-Safe Housing Rule in many pre-1978
properties receiving Federal housing assistance. The clearance examination may
be scheduled by the agency administering the assistance. A clearance examination is
performed by a trained person independent of the renovation firm performing the
work. Ask your client or contact the agency administering the assistance to the
property to find out if a clearance examination is required at the end of the job and to
find out who will schedule it. Remember, if the property fails clearance, the unit must
be re-cleaned and another clearance examination performed. Sometimes the cost of
re-cleaning and the additional clearance examination will be the responsibility of the
contractor. Cleaning well the first time will saves both time and money.
5-5
October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
Exterior Cleanup Requirements
Clean all surfaces in the work area until no visible
dust, debris, or residue remains.
Collect all paint chips and debris without dispersal,
and seal in heavy plastic bags.
Remove protective plastic sheeting and mist before
folding it dirty side inward.
Check your work.
Focus on areas such as window sills, bare soil, and
children's play areas.
Look for dust, debris and residue.
&EPA rjfil.
United States
Environmental Protection
Agency
October 2011
Specific exterior jobs
If work takes place on an exterior porch or stairwell, HEPA vacuuming, wet cleaning and mopping, in
addition to a thorough visual inspection, should be used to clean the work area. For such jobs, the
cleanup should be similar to cleanup after interior jobs. Collect and dispose of any dust and debris with
the rest of your waste.
Remember
Lead contaminated soil can poison children.
Avoid dry raking and shoveling, and spreading dust. However, raking and shoveling the soil is
appropriate if it is misted first.
Protective sheeting
Collect all paint chips and debris and, without dispersing any of it, seal this material in a heavy-duty
bag.
Remove the protective sheeting. Mist the sheeting before folding it, fold the dirty side inward, and
either tape shut to seal or seal in heavy-duty bags. Dispose of the sheeting as waste.
Check your work
Before a Certified Renovator visually inspects the work area, check your work to determine whether
dust, debris or residue is still present. If dust, debris or residue is still present, these conditions must be
corrected before the visual inspection is performed.
5-6
October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
Exterior - Check Effectiveness of
Cleaning
Visual inspection
A Certified Renovator conducts a visual inspection
after cleaning.
Determines if any dust, debris or residue is still
present on surfaces in and below the work area.
Including windows sills and the ground.
If dust, debris or residue is present, these conditions
must be eliminated by re-cleaning.
After re-cleaning, the Certified Renovator conducts
another visual inspection.
When all areas pass, warning signs may be removed.
&epa a
United States
Environmental Protection
Agency
October 2011
Checking your work
A thorough visual inspection is the main part of checking your cleanup after an exterior job.
A visual inspection is conducted after completing cleanup, to check your work.
The Certified Renovator must perform the visual inspection to determine whether dust, debris or
residue is still present on surfaces in or below the work area, including window sills and on the ground.
If dust or residue is present, clean again, and then repeat the visual inspection.
Warning signs may be removed after passing visual inspection.
Clearance on exterior jobs. For exterior jobs, HUD requires only a visual
assessment of the work area to pass clearance. No dust or soil testing is
required. If you follow procedures taught in this course you will satisfy HUD
requirements.
5-7
October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
Disposal
What should I do with waste generated on the job?
At the work site:
Place waste in heavy duty plastic bag.
"Gooseneck seal" the bag.
HEPA vacuum the exterior of the waste bag before
removing it from the work area.
Store waste in a secure area.
Carefully dispose of waste in accordance with
Federal and other regulations.
Always check local waste A
requirements. 'O'iEA
Environmental Protection
Agency
October 2011
At the Work Site
Waste from renovation activities must be contained to prevent releases of dust and debris before the
waste is removed from the work area for storage or disposal. Architectural components that are too big
to fit into bags must be wrapped in plastic and sealed with tape prior to removal from the work area. If
needed, "double-bag" your waste to help prevent the waste from escaping if the bag is cut or ripped. If
a chute is used to remove waste from the work area, it must be covered. Some examples of waste
include protective sheeting, HEPA filters, paint chips, dust, dirty water, used cloths, used wipes, used
mop heads, used protective clothing, used respirators, used gloves, and architectural components.
At the conclusion of each work day and at the conclusion of the renovation, waste that has been
collected from renovation activities must be stored under containment, in an enclosure, or behind a
barrier that prevents release of dust and debris out of the work area and prevents access to dust and
debris.
When the firm transports waste from renovation activities, the firm must contain the waste to prevent
release of dust and debris.
Federal, State, and Local Waste Requirements
Because EPA considers most renovation and remodeling as "routine residential maintenance", most
waste generated during these activities is classified as solid, non-hazardous waste, and should be
taken to a licensed solid waste landfill (see Appendix 8 and www.epa.gov/lead/pubs/fslbp.htm). This
does not apply to commercial, public or other non-residential child-occupied facilities.
Always check state and local requirements before disposing of waste. Some are more stringent than
Federal regulations.
Waste Water
Water used for cleanup might be able to be filtered and dumped in a toilet if local rules allow. Never
dump this water down a sink or tub, down a storm drain or on the ground. Always dispose of waste
water in accordance with Federal, state and local regulations.
EPA's website has links to state information on solid and hazardous waste disposal at
htt p ://www. e pa. g o v/e pawaste/wy l/state prog ra ms. htm.
HUD recommends that when building components are recycled or sold, painted
building components should be stripped before re-installation. If components are not
stripped, they should never be reinstalled in housing.
5-8
October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
Exercise: Cleaning Verification
Procedure
Work in groups of 2-6.
Assignment:
Skill Set #2: Cleaning Verification Procedure
You have 20 minutes.
&EPA fM
United States
Environmental Protection
Agency
October 2011
Exercise: Cleaning Verification Procedure
This exercise gives you a chance to learn the cleaning verification procedure in the RRP Rule. The slide
provides basic instruction. Stay in your groups of 2 to 6 students, in your work area.
5-9 October 2011
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LEAD SAFETY for Remodeling, Repair and Painting
Skill Set #2: Cleaning Verification Procedure
Time: 15 minutes
October 2011
Supplies needed:
Baby powder or corn starch
Disposable foot covers
Flashlight
Disposable non-latex gloves
Disposable wet cleaning wipes
Cleaning verification card, one per student to take away and retain
Electrostatically charged, white, disposable cleaning cloths designed for cleaning
hard surfaces
Long-handled mop designed for wet cleaning wipes
Tape measure
Watch or clock
Purpose: The purpose of this hands-on exercise is to show the students the proper
steps for conducting the cleaning verification procedure.
The course instructor should explain all of the steps involved in performing the
cleaning verification procedure.
Evaluating the Students: Watch each student conduct the cleaning verification
procedure and listen as they point out problems that must be fixed. Students must
complete all required steps to be "Proficient". Evaluate the work of each student and
once the student has completed all required elements of the exercise correctly, record
the performance as "Proficient" in the field on the Participant Progress Log that
corresponds to Skills Set #2 and that particular student's name.
Hands-on Exercises
October 2011
A6-13
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LEAD SAFETY for Remodeling, Repair and Painting
Skill Set #2: Cleaning Verification Procedure - Continued
Skills Practice:
Step 1: As you enter the work area put on disposable foot covers so that you do not
track dust and debris into the work area.*
Step 2: Turn on all of the lights that are available in the work area. Make sure there is
adequate lighting.*
For window sills:
Step 3: While wearing gloves, wipe each window sill in the work area with a clean,
white, damp cleaning wipe.*
Step 4: Compare the cleaning wipe to the cleaning verification card. If the first wipe is
the same as or whiter (lighter) than the cleaning verification card, the window
sill is clean; continue to Step 6. If the first cleaning wipe is not the same as or
whiter (lighter) than the cleaning verification card, re-clean the window sill,
and, repeat Step 3 and then proceed to Step 5 (skip this step).*
Step 5: Compare the second cleaning wipe to the cleaning verification card. If the
second wipe is the same as or whiter (lighter) than the cleaning verification
card, the window sill is clean; continue to Step 6. If the second cleaning wipe
is not the same as and not whiter (not lighter) than the cleaning verification
card, wait one hour or until the wet surface is dry (for the purposes of this
exercise you do not wait). Then re-clean the surface with a dry,
electrostatically charged, white, disposable cleaning cloth designed for use
on hard surfaces. The window sill is now clean and has completed the
cleaning verification procedure.*
For Floors and Countertops:
Step 6: While wearing gloves, wipe each floor or countertop in the work area with a
clean, white, damp cleaning wipe. For floors, use a long handled mop
designed to hold a wet cleaning wipe. For floors, wipe no more than 40
square feet per wipe. For countertops wipe the whole surface of the
countertop up to 40 square feet per wipe.*
Step 7: Compare each floor and countertop cleaning wipe to the cleaning verification
card. If the first wipe is the same as or whiter (lighter) than the cleaning
verification card, the floor or countertop is clean. If the first cleaning wipe is
not the same as and not whiter (not lighter) than the cleaning verification
card, re-clean the floor section or countertop section, wipe the floor or
countertop section with a wet cleaning wipe, and repeat Step 6 for that
section and proceed to Step 8 (skip this step).*
Hands-on Exercises
October 2011
A6-
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LEAD SAFETY for Remodeling, Repair and Painting
Step 8: Compare the second floor or countertop cleaning wipe to the cleaning
verification card. If the second wipe is the same as or whiter (lighter) than the
cleaning verification card, the floor or countertop section has been adequately
cleaned. If the second cleaning wipe is not the same as and not whiter (not
lighter) than the cleaning verification card, wait one hour or until the wet
surface is dry (for the purposes of this exercise you do not wait). Then reclean
the surface with a dry, electrostatically charged, white, disposable
cleaning cloth designed for use on hard surfaces. The floor or countertop
section is now clean and has completed the cleaning verification procedure.*
Step 9: Once the cleaning verification shows that all areas have been
adequately cleaned, remove the signs and critical barriers around the
work area.*
indicates required skills that must be accomplished for a "Proficient" rating
Hands-on Exercises
October 2011
A6-15
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Module 6: Recordkeeping
-------
Lead Safety for Renovation, Repair, and Painting Refresher
Module 6: Recordkeeping
Overview:
In this section, you will learn about
records required for each job.
Records must be retained and made
available to EPA, upon request, for 3
years following completion of
renovation.
v>EPA
United Stales
Environmental Protection
Agency
October 2011
Language of the RRP Rule is:
"Firms performing renovations must retain and, if requested, make available to EPA, all records
necessary to demonstrate compliance...for a period of three years following completion of the
renovation."
HUD also has a three year record retention requirement for notices,
evaluations, and clearance or abatement reports (24 CFR 35.175).
6-1
October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
On-The-Job Records
Copies of Certified Firm and Certified Renovator
certifications (must be kept on site).
Lead-based paint testing results when using an EPA-
recognized test kit or paint chip sample
Laboratory results when a paint chip sample is
obtained by a Certified Renovator
Proof of owner/occupant pre-renovation education,
including receipt of Renovate Right pamphlet.
Non-certified renovation worker training
documentation.
v>EPA
United Stales
Environmental Protection
Agency
October 2011
The Certified Firm must designate (in writing) a Certified Renovator to be responsible for each
renovation job in target housing or a child-occupied facility. This is the logical person to organize
and maintain on-the-job records during the work. On the jobsite, the records should be kept in a safe,
secure, clean and dry place. Once the project is complete, some records can be filed with other firm
records while others may need to be moved to the next job site.
Records to be maintained on site include:
Copy of Certified Firm and Certified Renovator(s) certifications.
Records to be maintained to document the job:
Copy of Certified Firm and Certified Renovator(s) certifications.
Non-certified worker training documentation.
Designation of a Certified Renovator to the job.
Information on and results of use of EPA-recognized test kits or paint chip sample collection
provided by a Certified Renovator who acted as the representative of the Certified Firm at the job
site and who conducted testing for the presence of lead-based paint on surfaces to be affected by
the renovation.
Lead-based paint inspection reports provided by a Certified Lead Inspector or Certified Lead Risk
Assessor, if applicable.
Proof of owner/occupant pre-renovation education, including receipt of the pamphlet Renovate
Right: Important Lead Hazard Information for Families, Child Care Providers and Schools.
Any other signed and dated documents from the owner(s) and/or residents regarding conduct of
the renovation and requirements in the EPA RRP Rule.
All reports required from the Certified Firm and the Certified Renovator by the EPA RRP Rule.
6-2
October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
Non-Certified Renovator Training
Records
Name and Signature of the Certified Renovator.
Description of the lead safe work practices the
non-certified renovation worker is trained to
perform.
Completed and signed skills evaluation
checklists.
Date(s) of training.
Name and signature of the Certified Renovator
who conducted the training.
v>EPA
United Stales
Environmental Protection
Agency
October 2011
Documentation of Non-Certified Renovator Training
The Certified Renovator who conducted the non-certified renovator worker training must document the
information taught to, and skill set proficiencies achieved by, each individual trainee. This training can be
conducted in a classroom setting with simulated hands-on or on the job. Documentation may vary for
each trainee as not all trainees may be assigned to conduct all lead-safe work practices and the training
is only required to be task specific.
To simplify this documentation, your training manual includes a form that can be adapted for documenting
hands-on and topical training for non-certified renovation workers (See Appendix 6).
6-3
October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
Post-Renovation Reporting
Following a renovation, firms must document and share
the following information
Project information documenting compliance with
renovation training, certification, and work practice
requirements.
If performed, documentation of dust clearance sampling.
This information must be prepared, retained by the firm
and shared with owners and occupants of housing and
child-occupied facilities.
v>EPA
United Stales
Environmental Protection
Agency
October 2011
Documentation of project information (compliance with renovation training, certification, and work practice
requirements). This can accomplished by completing the sample form titled "Sample Renovation
Recordkeeping Checklist", or a similar form.
The project information documentation must also be distributed when the final invoice is delivered or
within 30 days of the completion, whichever is earlier, to the following :
The owner of the building; and, if different,
An adult occupant, or an adult representative of the child-occupied facility
If dust clearance sampling is performed the firm must provide, when the final invoice for the renovation is
delivered or within 30 days of the completion of the renovation, whichever is earlier, a copy of the dust
sampling report to:
The owner of the building; and, if different,
An adult occupant, or an adult representative of a child-occupied facility.
Note: When work is done in common areas of multi-unit housing, firms must post project information and
dust sampling reports on how interested occupants of the housing being renovated can obtain a copy of
the report. This information must be posted in areas where they are likely to be seen by all affected
occupants.
6-4
October 2011
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Sample Renovation Recordkeeping Checklist
Name of Firm:
Date and Location of Renovation: ____________________________________________________
Brief Description of Renovation:
Name of Assigned Renovator:
Name(s) of Trained Worker(s), if used:
Name of Dust Sampling Technician,
Inspector, or Risk Assessor, if used: __________________________________________________
Copies of renovator and dust sampling technician qualifications (training certificates, certifications) on file.
Certified renovator provided training to workers on (check all that apply):
Test kit or test results from an EPA-recognized laboratory on collected paint chip sample, used by certified
renovator to determine whether lead was present on components affected by renovation (identify method
used, type of test kit used (if applicable), laboratory used to conduct paint chip analysis, describe sampling
locations and results):
Warning signs posted at entrance to work area.
Work area contained to prevent spread of dust and debris
All objects in the work area removed or covered (interiors)
HVAC ducts in the work area closed and covered (interiors)
Windows in the work area closed (interiors)
Windows in and within 20 feet of the work area closed (exteriors)
Doors in the work area closed and sealed (interiors)
Doors in and within 20 feet of the work area closed and sealed (exteriors)
Doors that must be used in the work area covered to allow passage but prevent spread of dust
Floors in the work area covered with taped-down plastic (interiors)
Ground covered by plastic extending 10 feet from work areaplastic anchored to building and
weighed down by heavy objects (exteriors)
Vertical containment installed if property line prevents 10 feet of ground covering, or if necessary to prevent
migration of dust and debris to adjacent property (exteriors)
Waste contained on-site and while being transported off-site.
Work site properly cleaned after renovation
All chips and debris picked up, protective sheeting misted, folded dirty side inward, and taped for removal
Work area surfaces and objects cleaned using HEPA vacuum and/or wet cloths or mops (interiors)
Certified renovator performed post-renovation cleaning verification (describe results, including the
number of wet and dry cloths used): __________________________________________________
If dust clearance testing was performed instead, attach a copy of report
I certify under penalty of law that the above information is true and complete.
Name and title Date
Posting warning signs
Maintaining containment
Waste handling
Setting up plastic containment barriers
Avoiding spread of dust to adjacent areas
Post-renovation cleaning
27
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Module 7: Training Non-Certified
Renovators Workers
-------
Lead Safety for Renovation, Repair, and Painting Refresher
Module 7: Training Non-Certified
Renovators
Certified Renovators are responsible for
teaching lead-safe work practices to non-
certified renovators.
&EPA fM
United States
Environmental Protection
Agency
October 2011
The RRP Rule requires that you, the Certified Renovator, be responsible for instruction of non-
certified renovation workers.
Note: See Slide 2-11 and HUD regulations for more information on the training required for workers
on HUD funded renovations.
7-1
October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
Teaching Lead Safe Work
Practices Means
Training non-certified renovators to properly use
signs, dust barriers, dust minimizing work practices,
and dust cleanup practices during the course of
renovation, repair, and painting activities to prevent
and/or reduce potentially dangerous dust-lead
contamination in the home.
To effectively train non-certified renovators you need
to:
Know lead safety yourself.
Show non-certified renovators what you know.
Review "shopping list" and have materials at hand.
v>EPA (M.
United States
Environmental Protection
Agency
October 2011
Remember all the skills you mastered during the Skill Set exercises? You will be teaching non-
certified renovators to master them.
All that follows are presented to aid you in conduct of the training.
The Steps to LEAD SAFE Renovation, Repair, and Painting contains a shopping list of
materials and supplies needed for setting up containment, clean the work area, protect yourself
during work, and verify that the work area is clean. These shopping lists or another similar list
must be reviewed prior to on-the-job training to make sure all of the materials needed for work
are available. Failure to gather all supplies and equipment will delay on-the-job training and
related work.
7-2
October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
The Role of the Certified
Renovator
Certified Renovators:
Perform lead safe work as described in the RRP Rule
(Sections 40 CFR 745.85 (a) and (b)).
Train all non-certified renovators in lead safe
practices.
Provide onsite and regular direction for all non-
certified workers during setup and cleanup.
Are available by phone when not physically present at
the work site during work.
Maintain onsite proof of certification as a Certified
Renovator.
&EPA
United States
Environmental Protection
Agency
October 2011
What Are the Responsibilities of a Certified Renovator? Certified Renovators are responsible for
ensuring overall compliance with Renovation, Repair, and Painting Program requirements for lead-
safe work practices at renovations to which they are assigned.
A Certified Renovator:
1. Must use an EPA-recognized test kit or, alternatively, collect a paint chip sample for analysis
when requested by the party contracting for renovation services, to determine whether
components to be affected by the renovation contain lead-based paint.
2. Must provide lead-safe work practices training to non-certified workers so those workers can
perform assigned tasks safely. This training can be provided by the Certified Renovator on-the-job
or in the classroom, provided adequate hands-on practice is available. This training could also be
conducted by a third party although the instructor must be a Certified Renovator.
3. Must be physically present at the work site when warning signs are posted, while the work area
containment is being established, and while the work area cleaning is performed. (Note: Use the
terms Setup and Cleanup to describe this work).
4. Must monitor work being performed by non-certified individuals to ensure that lead-safe work
practices are being followed. This includes maintaining the integrity of the containment barriers
and ensuring that no dust or debris migrates from the work area.
5. Must be available, either on-site or by telephone, at all times during performance of the
renovation.
6. Must perform project cleaning verification.
7. Must have copies of their initial course completion certificate and their most recent refresher
course completion certificate at the work site. Certification as a Certified Renovator lasts for 5
years. The Certified Renovator must take a refresher course every 5 years in order to maintain
certification.
8. Must prepare required records.
EPA RRP Rule requirements are found at 40 CFR 745.85 (a) and (b).
7-3
October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
Role of Trained, Non-Certified
Renovators
Trained, non-certified renovators are persons, working
on renovation, repair and painting jobs who have had
on-the-job training or similar classroom training from
a Certified Renovator to perform tasks in conformance
to the EPA RRP Rule.
They must perform lead-safe work practices as
described in the RRP rule.
Protect the home by "setting up" the work area.
Protect themselves.
Perform renovation work safely.
Prohibited Practices must not be used.
Clean the work area.
Control dust and debris.
&EPA fM.
United States
Environmental Protection
Agency
October 2011
On-the-job training must be provided for each non-certified renovator and for each job to the extent that
each non-certified renovator is adequately trained for the tasks he or she will be performing. This training
may occur while the non-certified renovator is engaged in productive work, which provides knowledge
and skills essential to the full and adequate performance of the job. However, work conducted during
training must be in full compliance with the RRP Rule.
Trainees will benefit by seeing the "Steps" to lead safety found in Steps to LEAD SAFE Renovation,
Repair and Painting in Appendix 5 (this document is also referred to as the "Steps Guide"). It contains a
seven step primer on lead safety and can be used as a field text to hand out to non-certified renovator in
the field. In the "Steps Guide", steps 2 through 6 contain information specific to work performed by non-
certified personnel, while step 1 and step 7 contain information on testing painted surfaces and cleaning
verification which are Certified Renovator responsibilities. Step 7 also discusses clearance examination
which is performed only by Certified Lead Inspectors, Certified Lead Risk Assessors, and Certified Dust
Sampling Technicians.
The information in the "Steps Guide" can be covered in about 5 minutes per Step and then reinforced by
on-the-job practical exercises such as setting up barriers and signs, demonstrations of cleaning
procedures, etc. It is recommended that the material in the "Steps Guide" be covered in a toolbox (on-
site) meeting format with handouts on the specific information to be covered.
It is very important that non-certified renovators be allowed to participate in hands-on learning as work
progresses and that skill sets that are learned by each non-certified renovator are documented.
Documentation is required by the RRP Rule to assure that non-certified renovators are trained to perform
renovation activities to which they are assigned. Remember that the RRP Rule requires all non-certified
renovators on the job to be given skills training specific to the tasks that they will perform on the job and
that each non-certified renovator's training must be documented by topic area covered in the on-the-job
training that is performed. The required documentation will be discussed in more detail later.
7-4
October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
Teaching Lead Safety During
Renovations - Use the Steps
Steps to LEAD SAFE Renovation,
Repair and Painting covers basic
lead safe practices and can be
used as a training guide outside of
the classroom in conjunction with
on-the-job demonstrations and
hands-on training.
It is strongly recommended that
you use this guide as a basis for
LEAD SAFE-
^Renovation, Repair*
training.
VSrEPA fM]
United States
Environmental Protection
Agency
October 2011
Training for non-certified renovators can be delivered in one session covering all 7 Steps or the
information can be covered in a series of "toolbox" meetings over the course of several days. You should
spend about 5-10 minutes on the information contained in each "Step" and then conduct on-the-job
training to teach the skills needed to renovate lead safely.
If this training is offered in the classroom, Slides 8-5 through 8-12 could be used to teach the material
found in the Steps to LEAD SAFE Renovation, Repair, and Painting. This document is included as
Appendix 5 of your student manual. Use the Steps to LEAD SAFE Renovation, Repair, and Painting
as a student handout for training non-certified renovators. The handout should also include write-ups of
demonstrations and practical hands-on exercises, and a checklist of desired skills to reinforce the
"toolbox" talks or classroom training. During either "toolbox" talks or classroom instruction, have non-
certified renovators refer to the training handout while you teach the information.
Before You Train: Print copies of Steps to LEAD SAFE Renovation, Repair, and Painting and give
one copy to each non-certified renovator.
7-5
October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
Step 1: Determine If the Job
Involves Lead-Based Paint
Lead-based paint (LBP) is found many older homes:
1960-1978 homes - 1 in 4 have LBP.
1940-1960 homes - 7 in 10 have LBP.
Pre-1940 homes - 9 in 10 have LBP.
Renovation, repair or painting that disturbs lead-based paint can
create significant lead-based paint hazards in homes.
Just a little lead-based paint can poison kids and their parents,
poison pets, and cause problems for pregnant women and their
unborn children.
The Certified Renovator will determine if lead-based paint is
present on work surfaces.
If information about lead-based paint is not available for a pre-1978
homes or a child-occupied facility, assume that lead-based paint is
present and use lead-safe work practices. q ERA
United States
Environmental Protection
Agency
October 2011
During Training:
Review the information on this slide with the non-certified renovators as they follow along on pages 4 & 5
of the Steps to LEAD SAFE Renovation, Repair, and Painting.
Notes to the On-The-Job Instructor:
This information is included in the on-the-job training so non-certified renovators will understand why they
need to use lead-safe work practices. Non-certified renovators are not allowed to determine whether lead-
based paint is present, but they should understand that when it is identified as present, generating dust
can cause significant problems if not properly and safely controlled.
More information:
Review pages 4 and 5 of the Steps to LEAD SAFE Renovation, Repair and Painting.
7-6
October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
Step 2: Set It Up Safely
Containment is used to keep dust IN the work
area and non-workers OUT!
Signs and barriers are used to limit access.
Inside versus outside jobs:
Review all procedures and differences in setup.
&EPA fM
United States
Environmental Protection
Agency
October 2011
What To Do
To keep the dust in, and people out, of your work area, you will need to take slightly different steps for
inside or outside jobs.
For Inside Jobs
Place signs, barrier tape, and/or cones to keep all non-workers, especially children, out of the work
area. Keep pets out of the work area for their safety and to prevent them from tracking dust and
debris throughout the home.
Remove furniture and belongings from the work area. If an item is too large or too heavy to move,
cover it with heavy plastic sheeting and tape the sheeting securely in place.
Use heavy plastic sheeting to cover floors in the work area 6 ft. or more our from the surface being
renovated. Close and seal doors, close windows.
Close and cover air vents in the work area. This will keep dust from getting into the system and
moving through the home.
For Outside Jobs
Keep non-workers away from the work area by marking it off with signs, tape and/or cones. Have
owners keep pets out of the work area.
Cover the ground and plants with heavy plastic sheeting to catch debris. The covering should
extend at least 10 feet out from the building, unless a property line prevents 10 feet of such ground
cover ,in which case the firm must erect vertical containment. Secure the covering to the exterior.
Close windows and doors within 20 feet of the work area to keep dust and debris from going into
the home.
Move (if possible) or cover play areas and equipment within 20 feet of the work area.
7-7
October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
Step 3: Protect Yourself
Without the right personal protective equipment (PPE)
workers can swallow and inhale lead from the job, and
can carry lead on their skin and work clothes home to
their families.
Review the "shopping list."
Advise workers to:
Keep clothes clean or use disposable clothing.
Wear a respirator. The appropriate respirator keeps
lead out of your lungs and stomach.
Wash-up each time you leave the work
area and especially at the end of the
day- aepa
United States
Environmental Protection
Agency
October 2011
Wear protective clothing
Protective clothing and shoe covers are very important in preventing "take home" lead and to prevent
you from tracking lead out of the work area. They can also help prevent contamination of areas that
have already been cleaned during final cleanup.
Keep clothes clean. At the end of the work day, vacuum off dust or change out of dusty clothes. Do
not use compressed air to blow dust off clothing. Wash dirty work clothes separately from household
laundry.
Wear a painter's hat to protect your head from dust and debris.
Wear respiratory protection
When work creates dust or paint chips, employers should consider respiratory protection, such as a
N-100 disposable respirator, to prevent workers from breathing leaded dust.
Wash up
Workers should wash their hands and faces each time they stop work. It is especially important to
wash up before eating and at the end of the day.
Note: OSHA rules may require employers to take further steps to protect the health of workers on the job.
7-8
October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
Step 4: Control the Spread of
Dust
The goal is to control the spread of dust that
is created.
Review the "shopping list."
Use the right tools.
If possible, work wet.
Disposable plastic drop cloths control the
spread of dust and debris.
Avoid prohibited practices. aEPA
United States
Environmental Protection
Agency
October 2011
Control the spread of dust
Keep the work area closed off from the rest of the home.
Don't track dust and debris out of the work area.
Stay in the contained work area and on the contained paths.
Vacuum off suits when exiting the work area so the dust stays inside containment.
Remove disposable shoe covers and make sure your shoes are clean by using tack pads or damp
paper towels to wipe off your shoes each time you step off the protective sheeting.
Keep components in the work area until they are wrapped securely in heavy plastic sheeting or
bagged in heavy duty plastic bags. Once wrapped or bagged, HEPA vacuum the exterior and
remove them from the work area and store them in a safe area away from residents.
Launder non-disposable protective clothing separate from family laundry.
Do not use Prohibited Practices, including:
Open-flame burning or high heat removal of paint; and
Power tools such as sanders without HEPA attachments.
The practices prohibited by EPA's RRP Rule are also prohibited in pre-1978
properties with lead-based paint that receive Federal housing assistance. The
HUD Rule also prohibits extensive dry scraping and sanding by hand, use of heat
guns that char paint and paint stripping in a poorly ventilated space using a volatile
paint stripper. States, localities, or tribes may also prohibit these practices.
^ENTQo
AN DEV^V
7-9
October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
Step 5: Leave the Work Area
Clean
The goal should be to leave the work area
completely free of dust, debris and residue.
Review the "shopping list."
Discuss daily cleaning procedures.
Discuss end of job cleaning procedures.
&EPA fM
United States
Environmental Protection
Agency
October 2011
On a daily basis, pick up the work area (recommended)
Pick up as you go. Put trash in heavy-duty plastic bags.
Vacuum the work area with a HEPA vacuum several times during the day and for sure at the end of
the day. Use only HEPA vacuums. Do not use standard household or shop vacuum cleaners.
Clean tools at the end of the day.
Wash your hands each time you leave the work area and especially well before you go home.
Dispose of all disposable personal protective clothing daily.
When the job is complete, clean the work area (required)
Make sure all paint chips, dust, trash and debris, including building components, are removed from
the area to be cleaned and disposed of properly.
Carefully remove plastic sheeting on the floor, fold it with the dirty side in, tape the edges shut or
seal it in a heavy duty plastic bag, and dispose of it. Keep plastic sheeting in doorways and
openings that separate the work area from non-work areas in place until the work area is released
as clean.
HEPA vacuum or wet wipe all wall surfaces. HEPA vacuum all other surfaces in the work area. Use
a beater bar attachment on carpets.
Wet wipe all remaining surfaces in the work area and wet mop all uncarpeted floors until dust,
debris and residue are removed.
Visually inspect your work. Look around the work area and pathways where debris was carried,
both inside and out. You should see no dust, debris or residue.
Re-clean the area thoroughly if you find dust, debris or residue.
7-10
October 2011
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Lead Safety for Renovation, Repair, and Painting Refresher
Step 6: Control the Waste
Discuss the waste bagging procedure.
Demonstrate folding a small section of plastic
with the dirty side turned in.
Discuss temporary storage of waste.
Discuss how to deal with waste water
appropriately.
Discuss waste disposal rules that apply to the
specific job.
v>EPA fM.
United States
Environmental Protection
Agency
October 2011
Bag or wrap your waste at the work site and in the work area.
Collect and control all your waste. This includes dust, debris, paint chips, protective sheeting, HEPA
filters, dirty water, clothes, mop heads, wipes, protective clothing, respirators, gloves, architectural
components, and other waste. Use heavy plastic sheeting or bags to collect waste. Gooseneck seal the
bag with duct tape. Consider double bagging waste to prevent tears. Large components should be
wrapped in protective sheeting and sealed with tape. Bag and seal all waste before removing it from the
work area. HEPA vacuum the exterior of waste bags and bundles before removing them from the work
area. Store all waste that has been collected from renovation activities preventing access to and release
of dust and debris.
Dispose of waste water appropriately.
Water used in the work area to remove paint or to clean surfaces should be filtered. Never dump this
water down a sink or tub, in a storm drain, or on the ground. It may be dumped in a toilet if local rules
allow. If local regulations do not allow this, you may be required to contain and test the water, and contact
a waste disposal company to assist you with disposal. Check with your local water treatment
authority, and in Federal and state regulations for more information.
Be aware of waste disposal rules.
EPA considers most renovation, repair and painting activities in residential housing to be "routine
residential maintenance." The waste generated by these activities is classified as solid, non-hazardous
waste and can be disposed of in an ordinary waste landfill (see Appendix 8 and
www.epa.gov/lead/pubs/fslbp.htm). Some states and localities have more stringent waste disposal
requirements that must be followed.
7-11
October 2011
-------
Lead Safety for Renovation, Repair, and Painting Refresher
Step 7: Cleaning Verification or
Clearance Testing
Cleaning verification will be performed by a
Certified Renovator after most renovations.
A clearance examination may be requested in
place of cleaning verification by the owner.
A clearance examination is required in many
pre-1978 properties receiving Federal housing
assistance.
Discuss what happens when cleaning
verification and/or clearance is not passed.
v>EPA fM
United States
Environmental Protection
Agency
October 2011
When all the cleaning is complete, and before the space is reoccupied, a cleaning verification procedure
or clearance examination must be conducted to make sure leaded dust is not left behind. If the HUD Rule
applies, a clearance examination is required in place of the cleaning verification procedure. Before
conducting either cleaning verification or clearance examination, the Certified Renovator performs a
visual inspection of the work area. The HUD regulations also require a person trained in visual inspection,
who is independent of the renovation firm, to perform a visual inspection as part of a clearance
examination. If dust, debris or residue are present in the work area, cleaning must be repeated and the
visual inspection repeated until the work area is free of dust, debris and residue. After the project passes
visual inspection by the Certified Renovator (and, for HUD-regulated projects, by the independent trained
person), either the cleaning verification procedure or clearance examination can proceed.
7-12 October 2011
-------
Appendix 1:
This Appendix is Intentionally Left Blank
-------
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This Page Intentionally Left Blank
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Appendix 2:
U.S. Department of Housing and Urban
Development (HUD) Requirements
-------
EPA Certified Renovation Firms and Certified Renovators
Additional Requirements of HUD's Lead Safe Housing Rule
The U.S. Department of Housing and Urban Development's Lead Safe Housing Rule (HUD's
Lead Safe Housing Rule (LSHR), which is found in HUD's regulations at 24 CFR Part 35,
Subparts B through M), generally applies to work performed in target housing units receiving
HUD housing assistance, such as rehabilitation or acquisition assistance.
Under the LSHR, the program participant (governmental jurisdiction, non-profit, community
organization or the property owner who accepts HUD funds) becomes responsible for
compliance with the LSHR and is referred to as the designated party (or DP). Renovation firms
may include, for example, for-profit contractors, non-profit organizations, or a designated party
using its own employees for renovation. In the spirit of maintaining good customer relations,
certified renovation firms should ask their client if:
1) The work involves lead hazard control (including abatement, interim control of lead hazards
or ongoing lead-based paint maintenance); and
2) The housing receives financial assistance. If so, the renovator should ask the client to find
out if the assistance is federal assistance.
Most clients would appreciate these questions so they may avoid violating HUD or EPA rules.
See www.hud.gov/offices/lead/enforcement/lshr.cfm for more information.
The information below and in the table explain the basic requirements of HUD's regulation for
renovators who have not yet had experience with HUD-funded work. The term "rehabilitation" is
used by HUD to describe residential renovation work. When HUD funds pay for this work,
funding often flows from HUD through cities, states or other program participants, and
addressing lead-based painted surfaces becomes a routine part of the job. HUD's specific
requirements depend on the amount of Federal rehabilitation assistance the project is receiving:
1) Up to $5,000 per unit: "Do no harm" approach. Lead safety requirements cover only the
surfaces being disturbed. Program participants can either test these surfaces to determine if
they contain lead-based paint or presume they contain lead-based paint. Work which
disturbs painted surfaces known or presumed to contain lead-based paint is done using lead
safe work practices, and clearance of the worksite is performed at the end of the job (unless
it is a very small "de minimis" scale project) to ensure that no lead dust hazards remain in
the work area. Training that meets the EPA's RRP Rule requirements is sufficient for this
work.
2) Greater than $5,000 and up to $25,000 per unit: Identify and control lead hazards. Identify
all lead hazards at the affected units and common areas servicing those units by performing
a lead-based paint risk assessment. Control the hazards using interim controls. Participants
may skip the risk assessment and presume that all potential lead hazards are present, and
then must use standard treatments to address them. In addition to training that meets the
EPA's RRP Rule requirements, HUD-approved interim control training (such as the HUD-
EPA RRP curriculum) is required for renovators and workers.
3) Greater than $25,000 per unit: Identify and abate lead hazards. Identify all lead hazards at
the property by performing a risk assessment and then abate all the hazards. Participants
may skip the risk assessment and presume that all potential lead hazards are present and
1
-------
EPA Certified Renovation Firms and Certified Renovators
Additional Requirements of HUD's Lead Safe Housing Rule
abate them. This approach requires certified abatement contractors perform the abatement
part of the job.
These approaches also include all the basic HUD requirements describe in the slide
presentations in Module 2. They clearly demonstrate the importance to the renovator of asking
the client whether federal housing assistance is provided for the project.
The differences between HUD's LSHR and the Environmental Protection Agency's (EPA's)
Renovation, Repair and Painting (RRP) regulation, part of EPA's regulations at 40 CFR
Part 745, and the changes for HUD LSHR projects, are summarized in the following table and
explained in the narrative after the table:
Differences between HUD LSHR and EPA RRP regulations
Stage of
Job
Requirement
HUD LSHR
EPA RRP
Changes to
LSHR Projects
to Comply with
RRP.
Planning
and Set-
up
Determination
that lead-based
paint (LBP) is
present.
EPA-recognized test
kits cannot be used to
say paint is not LBP.
Only a certified LBP
inspector or risk
assessor may
determine whether
LBP is present.
Certified renovators
use an EPA-
recognized test kit
to determine if RRP
rule applies or not.
None.
Training
HUD does not certify
renovators or firms.
HUD does not
require that all
workers be certified
renovators. All
workers and
supervisors must
complete a HUD-
approved curriculum in
lead safe work
practices, of which
RRP is one. All
workers need this
training except they
only need on-the-job
training for EPA if they
are supervised by a
certified LBP
abatement supervisor
who is also a Certified
Renovator.
EPA or EPA-
authorized States
certify renovation
firms and accredit
training providers
that certify
renovators. Only
the certified
renovator is
required to have
classroom training.
Workers must
receive on-the-job
training from the
certified renovator.
Renovation firms
must be certified.
At least one
certified renovator
must be at the job
or available when
work is being
done. (The
certified renovator
may be a certified
LBP abatement
supervisor who
has completed
the 4-hour RRP
refresher course.)
2
-------
EPA Certified Renovation Firms and Certified Renovators
Additional Requirements of HUD's Lead Safe Housing Rule
Stage of
Job
Requirement
HUD LSHR
EPA RRP
Changes to
LSHR Projects
to Comply with
RRP.
Pre-Renovation
Education
HUD requires
conformance with EPA
regulations, including
EPA's Pre-Renovation
Education Rule. EPA
had required
renovators to hand out
the EPA / HUD/
CPSC Protect Your
Family from Lead in
Your Home (Lead
Disclosure Rule)
pamphlet.
Renovators must
hand out the EPA/
HUD Renovate
Right: Important
Lead Hazard
Information for
Families, Child Care
Providers and
Schools pamphlet.
(This requirement
went into effect on
December 22,
2008.)
None.
During
the Job
Treating LBP
hazards
Depending on type
and amount of HUD
assistance, HUD
requires that lead
hazards be treated
using "interim controls"
or "ongoing lead-
based paint
maintenance."
EPA generally
requires that
renovations in
target housing be
performed using
lead-safe work
practices.
None.
Prohibited Work
Practices
HUD's prohibited work
practices include
EPA's prohibited work
practices plus: dry
scraping or sanding
farther than 1 ft. of
electrical outlets, and
use of a volatile
stripper in poorly
ventilated space.
EPA prohibits work
practices (open
flame burning or
torching, heat guns
above
1100 degrees F,
machine removal
without HEPA
vacuum
attachment).
None.
Threshold
minimum
amounts of
interior paint
disturbance
which trigger
lead activities.
HUD has a lower
interior "de minimis"
threshold (2 sq. ft. per
room, or 10% of a
small component type)
than EPA for lead-safe
work practices. HUD
also uses this lower
threshold for clearance
and occupant
notification.
EPA's interior
threshold (6 sq. ft.
per room) for minor
repair and
maintenance
activities is higher
than HUD's de
minimis threshold.
None.
3
-------
EPA Certified Renovation Firms and Certified Renovators
Additional Requirements of HUD's Lead Safe Housing Rule
Stage of
Job
Requirement
HUD LSHR
EPA RRP
Changes to
LSHR Projects
to Comply with
RRP.
End of
Job
Confirmatory
Testing
HUD requires a
clearance examination
done by an
independent party.
EPA allows
cleaning verification
by the renovator or
clearance
examination. The
cleaning verification
does not involve
sampling and
laboratory analysis
of the dust.
None.
Notification to
Occupants
(non-owner-
occupied
housing)
HUD requires the
designated party to
distribute notices to
occupants within 15
days after lead hazard
evaluation and control
activities in their unit
(and common areas, if
applicable).
EPA requires that
owners receive
documentation after
the renovation.
Contractor
notifies owner as
well as
occupants.
4
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EPA Certified Renovation Firms and Certified Renovators
Additional Requirements of HUD's Lead Safe Housing Rule
A. Responsibilities Shifted from the Renovator to the Designated Party under
HUD's LSHR:
1. Under the LSHR, the designated party is generally responsible to either have the paint
tested by a certified lead inspector or risk assessor or presume the presence of lead-
based paint. Therefore, when HUD's rule applies, the Certified Renovator may not use a
paint test kit to determine that the paint is not lead-based paint. Note: Some states may
have conflict-of-interest regulations prohibiting renovators from testing paint on which
they will be working.
2. When the HUD LSHR applies, the designated party must have a qualified person,
independent of the renovation firm, conduct a lead clearance examination. The Certified
Renovator does not conduct a cleaning verification. See below for more information on
clearance testing.
B. Additional HUD Requirements for the Renovator:
1. Training requirements for workers and supervisors performing interim controls.
To meet the requirements of both rules:
a. If the supervisor (in HUD terms) or Certified Renovator (in EPA terms) is certified as
a lead-based paint abatement supervisor or has successfully completed an
accredited abatement supervision or abatement worker course, that person must
complete a 4-hour RRP refresher course.
b. For workers who are not themselves supervisors / Certified Renovators:
If their supervisor on this project is a certified lead-based paint abatement
supervisor who has completed a 4-hour RRP refresher course, the workers must
obtain on-the-job training in lead-safe work practices from the supervisor.
Otherwise, the workers must successfully complete either a one-day RRP
course, or another lead-safe work practices course approved by HUD for this
purpose after consultation with the EPA. HUD has approved the one-day RRP
course, the previously-published HUD/EPA one-day Renovation, Remodeling
and Repair course, and other one-day courses listed on HUD's website, at
www.hud.gov/offices/lead.
c. Where the work is being done in a State or Tribal jurisdiction that has been
authorized by the EPA to operate an RRP training and certification program, the
one-day RRP course and half-day RRP refresher course must be accredited by the
State or Tribe. HUD will approve all one-day RRP courses accredited by EPA-
authorized States or Tribes.
d. The 4-hour RRP refresher course is not sufficient on its own to meet either the EPA
or HUD training requirements.
2. The certified renovation firm and the certified renovator must take additional
precautions to protect residents from lead poisoning beyond those in EPA's RRP
Rule.
a. Renovators must use lead-safe work practices in work exempt from the RRP
Rule that:
Disturbs between 2 and 6 ft2 of paint per room, the LSHR's de minimis threshold
and the RRP's minor repair and maintenance activities threshold, respectively.
5
-------
EPA Certified Renovation Firms and Certified Renovators
Additional Requirements of HUD's Lead Safe Housing Rule
Note: Window replacement, window sash replacement, and demolition of
painted surface areas disturb more paint than the LSHR's de minimis threshold.
Disturbs more than 10% of a component type with a small surface area (such as
window sills, baseboards, and trim).
b. Not using HUD's 3 additional prohibited work practices:
Heat guns that char the paint even if operating at below 1100 degrees F.
Dry sanding or dry scraping, except dry scraping in conjunction with heat guns or
within 1 ft of electrical outlets.
Paint stripping using a volatile stripper in a poorly ventilated space.
c. Taking additional measures to protect occupants during longer interior hazard
reduction activities: Temporarily relocating the occupant before and during longer
interior hazard reduction activities to a suitable, decent, safe, and similarly accessible
dwelling unit that does not have lead-based paint hazards. Temporary relocation is
not required for shorter projects, where:
The work is contained, completed in one period of 8-daytime hours, and does not
create other safety, health or environmental hazards; or
The work is completed within 5 calendar days, after each work day, the worksite
and the area within 10 feet of the containment area are cleaned of visible dust
and debris, and occupants have safe access to sleeping areas, and bathroom
and kitchen facilities.
C. Additional Designated Party Responsibilities that may Affect the Renovator
On jobs covered by the HUD LSHR, the certified renovation firm and the certified renovator
should know other requirements for the designated party that may affect their role on the
project.
1. Designated party must provide occupants with two notices, if the amount of work
is above HUD's de minimis threshold:
a. NOTICE OF EVALUATION OR PRESUMPTION: This notice informs the occupants
that paint has been evaluated to determine if it is LBP or that paint has been
presumed to be LBP. The designated party must notify the occupants within 15
calendar days of receiving the evaluation report or making the presumption. The
renovator should ask the client if he/she has made this notice. The owner may
provide a copy of this notice to the renovator so the renovator knows where LBP is
located.
b. NOTICE OF HAZARD REDUCTION ACTIVITY: This notice describes the hazard
reduction work that was completed and gives the contact for occupants to get more
information. The designated party must notify the occupants within 15 calendar days
of completion the hazard reduction work. The renovator may be given a copy of this
6
-------
EPA Certified Renovation Firms and Certified Renovators
Additional Requirements of HUD's Lead Safe Housing Rule
notice, or may be asked to prepare or distribute the notice for the owner at part of the
renovator's work for the owner.
2. Depending on the type and amount of housing assistance provided, HUD
generally requires that identified LBP hazards be treated. Treatments may include
LBP hazard abatement, interim controls or ongoing LBP maintenance. Renovators
should inquire if their contract with the owner requires them to perform lead hazard
treatment tasks listed below. If so, all workers and supervisors must have the proper
training and qualifications. Generally, interim controls include the following activities,
which are required if the amount of work is above HUD's de minimis threshold; for work
below the de minimis threshold, any deteriorated paint must be repaired, but the work
need not be done using lead-safe work practices, although HUD strongly encourages
their use:
a. Deteriorated LBP must be stabilized. This means that physical defects in the
substrate of a paint surface or component that is causing the deterioration of the
surface or component must also be repaired.
b. Friction surfaces that are abraded must be treated if there are lead dust hazards
nearby.
c. Friction points must be either eliminated or treated so the LBP is not subject to
abrasion.
d. Impact surfaces must be treated if the paint on an impact surface is damaged or
otherwise deteriorated and the damage is caused by impact from a related building
component (such as a door knob that knocks the wall or a door that rubs against its
door frame).
e. LBP must be protected from impact.
f. Chewable LBP surfaces must be made inaccessible for chewing by children of less
than six years of age if there is evidence that such a child has chewed on the painted
surface.
g. Horizontal surfaces that are rough, pitted, or porous must be covered with a smooth,
cleanable covering or coating.
3. For certain types of HUD assistance, when a child known to have an
environmental intervention blood lead level is present, the designated party must
take additional steps to assess the situation and respond to potential lead
hazards. An environmental intervention blood lead level is a reading in a child under 6
years old of 20 micrograms per deciliter of blood (20 |jg/dL), or two readings of 15 to 19
|jg/dL at least 3 months apart. For certain types of HUD assistance (tenant-based rental
assistance, project-based rental assistance, public housing, and HUD-owned multifamily
housing), the owner or designated party may ask the renovator to perform work in the
unit to address specific lead hazards identified by an environmental investigation risk
assessment. All persons participating in such work should have appropriate training and
qualifications.
4. The designated party must arrange for a party independent of the renovator to
conduct a clearance examination, if the amount of work is above HUD's de
minimis threshold:
a. A clearance examination includes a visual assessment at the end of the renovation
work for deteriorated paint, dust, debris, paint chips or other residue; sampling of dust
on interior floors, window sills and window troughs; submitting the dust samples to a
7
-------
EPA Certified Renovation Firms and Certified Renovators
Additional Requirements of HUD's Lead Safe Housing Rule
laboratory for analysis for lead; interpreting the lab results, and preparing a clearance
report. EPA also allows a clearance examination to be used instead of the post-
cleaning verification, if the clearance examination is required by federal, state or local
regulations or by the contract. The unit - or, where work is contained, just the work
area and an area just outside the containment - must pass clearance, and must not
have any remaining lead hazards. If clearance fails at either the visual assessment
step or the dust testing step, cleaning has to be redone in the failed part of the work
area. The failed part of the work area is the specific area that was tested, as well as
any areas that were not tested, and any other areas that are being represented by
the sampled area. For example:
Just one bedroom was tested, because it was to represent all bedrooms in the
housing unit; it failed. Therefore, all of the bedrooms in the unit have to be re-
cleaned and re-cleared.
In a large multifamily apartment building, if a percentage of units are tested in
accordance with the HUD Guidelines, if any fail, all of the units except those that
passed clearance have to be re-cleaned and re-cleared. (If there are patterns of
just certain component types failing, just those component types need to be re-
cleaned and re-cleared in the failed and untested units.)
b. The person conducting the clearance examination must be both:
A certified lead-based paint inspector, risk assessor, clearance examiner, or dust
sampling technician, depending on the type of activity being performed. (Either
the State or the EPA certifies this person, depending on whether or not the State
the housing is in is authorized by EPA to certify people in the lead discipline.)
Independent of the organization performing hazard reduction or maintenance
activities. There is one exception, which is that designated party may use a
qualified in-house employee to conduct clearance even if other in-house
employees did the renovation work, but an in-house employee may not do both
renovation and clearance.
D. How to Find Out About Lead-Based Paint Requirements that Apply to
Planned Work in Properties Receiving HUD Housing Assistance, such as
Rehabilitation or Acquisition Assistance:
Finding out whether the work is receiving federal housing assistance is important
because failing to meet lead-based paint requirements could affect the
continuation of the assistance. For each job, the renovation firm should find out
whether:
The housing receives financial assistance; and
Any lead-based paint requirements apply to the work because of the assistance
provided.
The renovation firm should take the following steps:
1. Ask the property owner if the property or the family receives any type of housing
assistance, including low-interest loans, from a local, State, or Federal agency. If so:
a. Find out the name of the agency, contact person, address and phone number. (See the
list of types of agencies below.)
8
-------
EPA Certified Renovation Firms and Certified Renovators
Additional Requirements of HUD's Lead Safe Housing Rule
b. Get a basic description of the type of assistance the property receives.
Note: You should be able to explain to the owner that there will be information about the
work that you will need, and that you also need to check if there are any special
requirements.
2. If you have any questions about the Federal or State lead-based paint requirements that
apply to the work, contact the public agency administering the assistance and discuss the
project with the program specialist or rehabilitation specialist working with the property. For
example:
a. Is the project considered lead abatement? If so, what are the agency's abatement
requirements?
b. If the project is not abatement, what are the agency's lead-based paint requirements for
the project, and how should they be incorporated into the work write-up?
Some types of public agencies administering housing assistance, such as rehabilitation or
acquisition assistance, include:
State Housing Agency, Corporation or Authority
State Community Development Agency, Corporation or Authority
State Housing Finance Agency
City or County Housing Authority, Corporation or Authority
City or County Community Development Agency, Corporation or Authority
USDA Service Center - Rural Housing Programs
9
-------
Appendix 3:
Renovate Right: Important Hazard
Information for Families, Child Care
Providers and Schools
-------
CAUTION CAUTION CAUTION
Ml
DE^V
vvEPA
1-800-424-LEAD (5323)
epa.gov/aetleadsafe
EPA-740-K-10-001
Revised September 2011
O
This document may be purchased through the U.S. Government Printing Office online at
hookstorP.apo.aov or by phone (toll-free): 1-866-512-1800.
CAUTION
Important lead hazard information for
families, child care providers and schools
-------
IT'S THE LAW!
Federal law requires contractors that disturb painted surfaces
in homes, child care facilities and schools built before 1978 to
be certified and follow specific work practices to prevent lead
contamination. Always ask to see your contractor's certification.
Federal law requires that individuals receive certain information
before renovating more than six square feet of painted surfaces
in a room for interior projects or more than twenty square feet
of painted surfaces for exterior projects or window replacement
or demolition in housing, child care facilities and schools built
before 1978.
Homeowners and tenants: renovators must give you this
pamphlet before starting work.
Child care facilities, including preschools and kindergarten
classrooms, and the families of children under six years of age
that attend those facilities: renovators must provide a copy
of this pamphlet to child care facilities and general renovation
information to families whose children attend those facilities.
-------
WHO SHOULD READ THIS PAMPHLET?
This pamphlet is for you if you:
Reside in a home built before 1978.
Own or operate a child care facility, including preschools and kindergarten
classrooms, built before 1978, or
Have a child under six years of age who attends a child care facility built before 1978.
You will learn:
Basic facts about lead and your health.
How to choose a contractor, if you are a property owner.
What tenants, and parents/guardians of a child in a child care facility or school
should consider.
How to prepare for the renovation or repair job.
What to look for during the job and after the job is done.
Where to get more information about lead.
This pamphlet is not for:
Abatement projects. Abatement is a set of activities aimed specifically at
eliminating lead or lead hazards. EPA has regulations for certification and training of
abatement professionals. If your goal is to eliminate lead or lead hazards, contact the
National Lead Information Center at 1-800-424-LEAD (5323) for more information.
Contractor education. Contractors
who want information about working
safely with lead should contact
the National Lead Information
Center at 1-800-424-LEAD (5323)
for information about courses and
resources on lead-safe work practices.
1
"Do-it-yourself" projects. If you plan to do renovation work yourself, this document
is a good start, but you will need more information to complete the work safely. Call
the National Lead Information Center at 1-800-424-LEAD (5323) and askfor more
information on how to work safely
in a home with lead-based paint.
-------
RENOVATING, REPAIRING, OR PAINTING?
Is your home, your building, or the child care facility
or school your children attend being renovated,
repaired, or painted?
Was your home, your building, or the child care facility
or school where yourchildren under six years ofage
attend built before 1978?
If the answerto these questions is YES, there are a
few important things you need to know about
lead-based paint.
This pamphlet provides basic facts about lead and
information about lead safety when work is being
done in your home,your building orthe child care
facility or school your children attend.
The Facts About Lead
Lead can affect children's brains and developing nervous systems, causing reduced
IQ, learning disabilities, and behavioral problems. Lead is also harmful to adults.
Lead in dust is the most common way people are exposed to lead. People can also
get lead in their bodies from lead in soil or paint chips. Lead dust is often invisible.
Lead-based paint was used in more than 38 million homes until it was banned for
residential use in 1978.
Projects that disturb painted surfaces can create dust and endanger you and your
family. Don't let this happen to you. Follow the practices described in this pamphlet
to protectyou and yourfamily.
2
LEAD AND YOUR HEALTH
Lead is especially dangerous to children
under six years ofage.
Lead can affect children's brains and developing
nervous systems, causing:
Reduced IQand learning disabilities.
Behavior problems.
Even children who appear healthy can have
dangerous levels of lead in their bodies.
Lead is also harmful to adults. In adults, low levels
of lead can pose many dangers, including:
High blood pressure and hypertension.
Pregnant women exposed to lead can transfer lead to their fetuses. Lead gets into
the body when it is swallowed or inhaled.
People, especially children, can swallow lead dust as they eat, play, and do other
normal hand-to-mouth activities.
People mayalso breathe in lead dustorfumes if they disturb lead-based paint.
People who sand, scrape, burn, brush, blast or otherwise disturb lead-based
paint risk unsafe exposure to lead.
What should I do if I am concerned about my family's exposure to lead?
A blood test is the only way to find out if you or a family member already has lead
poisoning. Call your doctor or local health department to arrange for a blood test.
Call your local health department for advice on reducing and eliminating
exposures to lead inside and outside your home, child care facility or school.
Always use lead-safe work practices when renovation or repair will disturb
painted surfaces.
For more information about the health effects of exposure to lead, visit the EPA lead
website at epa.gov/lead/pubs/leadinfo or call 1-800-424-LEAD (5323).
There are other things you can do to protect your family every day.
Regularly clean floors, window sills, and other surfaces.
Wash children's hands, bottles, pacifiers, and toys often.
Make sure children eat a healthy, nutritious diet consistent with the USDA's dietary
guidelines, that helps protect children from the effects of lead.
Wipe off shoes before entering the house.
3
-------
WHERE DOES THE LEAD COME FROM?
Dust is the main problem.
The most common way to get lead in the body is from dust. Lead dust comes from
deteriorating lead-based paint and lead-contaminated soil that gets tracked into
your home. This dust may accumulate to unsafe levels. Then, normal hand to-mouth
activities, like playing and eating (especially in young children), move that dust from
surfaces like floors and window sills into the body.
Home renovation creates dust.
Common renovation activities like sanding, cutting, and demolition can create
hazardous lead dust and chips.
Proper work practices protect you from the dust.
The key to protecting yourself and your family during a renovation, repair or painting
job is to use lead-safe work practices such as containing dust inside the workarea,
using dust-minimizing work methods, and conducting a careful cleanup, as described
in this pamphlet.
Other sources of lead.
Remember, lead can also come from outside soil, your water, or household items
(such as lead-glazed pottery and lead crystal). Contact the National Lead Information
Center at 1-800-424-LEAD (5323) for more information on these sources.
4
CHECKING YOUR HOME FOR LEAD-BASED PAINT
Percentage of Homes Likely to Contain Lead
i/j Between
^ 1960-1978
-9 Between
1940-1960
qj Before 1940
<
.a.fi.fi 24%
.ffi.fi.fi.ffil.ffi.fi.fi.fi.fi 69%
.fi.fi.fi.a,ffi.fi.fi.fi.ffi.fi.fi.fi 87%
1 1 1 1 1 1 1 1 1 r
10 20 30 40 50 60 70 80 90 100
Older homes, child care facilities, and schools are more likely to contain
lead-based paint.
Homes may be single-family homes or apartments. They may be private, government-
assisted, or public housing. Schools are preschools and kindergarten classrooms. They
may be urban, suburban, or rural.
You have the following options:
You may decide to assume your home, child care facility, or school contains lead.
Especially in older homes and buildings, you may simply want to assume lead-based
paint is present and follow the lead-safe work practices described in this brochure
during the renovation, repair, or painting job.
You can hire a certified professional to check for lead-based paint.
These professionals are certified risk assessors or inspectors, and can determine if
your home has lead or lead hazards.
A certified inspector or risk assessor can conduct an inspection telling you whether
your home, or a portion of your home, has lead-based paint and where it is located.
This will tell you the areas in your home where lead-safe work practices are needed.
Acertified risk assessor can conducta risk assessment telling you ifyourhome
currently has any lead hazards from lead in paint, dust, or soil. The risk assessor
can also tell you what actions to take to address any hazards.
For help finding a certified risk assessor or inspector, call the National Lead
Information Center at 1-800-424-LEAD (5323).
You may also have a certified renovator test the surfaces or components being
disturbed for lead by using a lead test kit or by taking paint chip samples and sending
them to an EPA-recognized testing laboratory. Test kits must be EPA-recognized and
are available at hardware stores. They include detailed instructions for their use.
5
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FOR PROPERTY OWNERS
You have the ultimate responsibility for the safety of your family, tenants, or children
in your care.
This means properly preparing for the renovation and keeping persons out of the work
area (see p. 8). It also means ensuring the contractor uses lead-safe work practices.
Federal law requires that contractors performing renovation, repair and painting projects
that disturb painted surfaces in homes, child care facilities, and schools built before 1978
be certified and follow specific work practices to prevent lead contamination.
Make sure your contractor is certified, and can explain clearly the details of the job
and how the contractor will minimize lead hazards during the work.
You can verify that a contractor is certified by checking EPA's website at
epa.gov/aetleadsafe or by calling the National Lead Information Center at
1-800-424-LEAD (5323). You can also ask to see a copy of the contractor's
firm certification.
Ask if the contractor is trained to perform lead-safe work practices and to see a
copy of their training certificate.
Ask them what lead-safe methods they will use to set up and perform the job in your
home, child care facility or school.
Ask for references from at least three recent jobs involving homes built before 1978,
and speak to each personally.
Always make sure the contract is clear about how the work will be set up,
performed, and cleaned.
Share the results of any previous lead tests with the contractor.
You should specify in the contract that they follow the work practices described on
pages 9 and 10 of this brochure.
The contract should specify which parts of your home are part of the work area and
specify which lead-safe work practices will be used in those areas. Remember, your
contractor should confine dust and debris to the work area and should minimize
spreading that dustto otherareas of the home.
The contract should also specify that the contractor will clean the work area, verify
that it was cleaned adequately, and re-clean it if necessary.
If you think a worker is not doing what he is supposed to do or is doing something
that is unsafe, you should:
- Direct the contractor to comply with regulatory and contract requirements.
Call your local health or building department, or
Call EPA's hotline 1-800-424-LEAD (5323).
If your property receives housing assistance from HUD (or a state or local agency that
uses HUD funds), you must follow the requirements of HUD's Lead-Safe Housing Rule
and the ones described in this pamphlet.
6
FOR TENANTS AND FAMILIES OF CHILDREN UNDER SIX
YEARS OF AGE IN CHILD CARE FACILITIES AND SCHOOLS
You play an important role ensuring the ultimate
safety of your family.
This means properly preparing for the renovation
and staying out of the work area (see p. 8).
Federal law requires that contractors performing
renovation, repair and painting projects that disturb
painted surfaces in homes built before 1978 and in
child care facilities and schools built before 1978, that
a child under sixyears of age visits regularly, to be
certified and follow specific work practices to prevent
lead contamination.
The law requires anyone hired to renovate, repair, or do
painting preparation work on a property built before
1978 to follow the steps described on pages 9 and 10 unless the area where the work
will be done contains no lead-based paint.
If you think a worker is not doing what he is supposed to do or is doing something
that is unsafe, you should:
Contact your landlord.
Call your local health or building department, or
Call EPA's hotline 1-800-424-LEAD (5323).
Ifyou are concerned about lead hazards left behind afterthe job is over, you can
check the work yourself (see page 10).
7
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PREPARING FOR A RENOVATION
The work areas should not be accessible to occupants while the work occurs.
The rooms or areas where work is being done may need to be blocked off or sealed
with plastic sheeting to contain any dust that is generated. Therefore, the contained
area may not be available to you until the work in that room or area is complete,
cleaned thoroughly, and the containment has been removed. Because you may not
have access to some areas during the renovation, you should plan accordingly.
You may need:
Alternative bedroom, bathroom, and kitchen arrangements if work is occurring in
those areas of your home.
A safe place for pets because they too can be poisoned by lead and can track lead
dust into other areas of the home.
A separate pathway for the contractor from the work area to the outside in order to
bring materials in and out of the home. Ideally, it should not be through the same
entrance that your family uses.
A place to store your furniture. All furniture and belongings may have to be moved
from the work area while the work is being done. Items that can't be moved, such as
cabinets, should be wrapped in plastic.
To turn off forced-air heating and air conditioning systems while the work is being
done. This prevents dust from spreading through vents from the work area to the
rest of your home. Consider how this may affect your living arrangements.
You may even want to move out of your home temporarily while all or part of the
work is being done.
Child care facilities and schools may want to consider alternative accommodations
for children and access to necessary facilities.
8
DURING THEWORK
Federal law requires contractors that are hired to perform renovation, repair and painting
projects in homes, child care facilities, and schools built before 1978 that disturb painted
surfaces to be certified and follow specific work practices to prevent lead contamination.
The work practices the contractor must follow include these three simple procedures,
described below:
1. Contain the work area. The area must be contained so that dust and debris do not escape
from that area. Warning signs must be put up and plastic or other impermeable material
and tape must be used as appropriate to:
Cover the floors and any furniture that cannot be moved.
Seal off doors and heating and cooling system vents.
For exterior renovations, cover the ground and, in some instances, erect vertical
containment or equivalent extra precautions in containing the workarea.
These work practices will help prevent dust or debris from getting outside the work area.
2. Avoid renovation methods that generate large amounts of lead-contaminated dust.
Some methods generate so much lead-contaminated dust that their use is prohibited.
They are:
Open flame burning or torching,
Sanding, grinding, planing, needle gunning,
or blasting with power tools and equipment
not equipped with a shroud and HEPA
vacuum attachment.
Using a heat gun at temperatures greater
than 1100ฐF.
There is no way to eliminate dust, but some renovation methods make less dust than others.
Contractors may choose to use various methods to minimize dust generation, including
using water to mist areas before sanding or scraping; scoring paint before separating
components; and prying and pulling apart components instead of breaking them.
3. Clean up thoroughly. The workarea should be cleaned up daily to keep it as clean as
possible. When all the work is done, the area must be cleaned up using special cleaning
methods before taking down any plastic that isolates the workarea from the rest of the
home. The special cleaning methods should include:
Using a HEPA vacuum to clean up dust and debris on all surfaces, followed by
Wet wiping and wet mopping with plenty of rinse water.
When the final cleaning is done, look around. There should be no dust, paint chips, or debris
in the workarea. If you see any dust, paint chips, or debris, the area must be re-cleaned.
9
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FOR PROPERTY OWNERS: AFTER THE WORK IS DONE
When all the work is finished, you will want to know if your home, child care facility, or
school where children under six attend has been cleaned up properly.
EPA Requires Cleaning Verification.
In addition to using allowable work practices and working in a lead-safe manner,
EPA's RRP rule requires contractors to follow a specific cleaning protocol. The protocol
requires the contractor to use disposable cleaning cloths to wipe the floor and other
surfaces of the work area and compare these cloths to an EPA-provided cleaning
verification card to determine if the work area was adequately cleaned. EPA research
has shown that following the use of lead-safe work practices with the cleaning
verification protocol will effectively reduce lead-dust hazards.
Lead-Dust Testing.
EPA believes that if you use a certified and trained renovation contractor who follows
the LRRP rule by using lead-safe work practices and the cleaning protocol after the
job is finished, lead-dust hazards will be effectively reduced. If, however, you are
interested in having lead-dust testing done at the completion of your job, outlined
below is some helpful information.
What is a lead-dust test?
Lead-dust tests are wipe samples sent to a laboratory for analysis. You will get a
report specifying the levels of lead found after your specific job.
How and when should I ask my contractor about lead-dust testing?
Contractors are not required by EPA to conduct lead-dust testing. However, if you
want testing, EPA recommends testing be conducted by a lead professional. To
locate a lead professional who will perform an evaluation near you, visit EPA's
website at epa.gov/lead/pubs/locate or contact the National Lead Information
Center at 1-800-424-LEAD (5323).
If you decide that you want lead-dust testing, it is a good idea to specify in your
contract, before the start of the job, that a lead-dust test is to be done for your job
and who will do the testing, as well as whether re-cleaning will be required based on
the results of the test.
You may do the testing yourself.
If you choose to do the testing,
some EPA-recognized lead
laboratories will send you a kit
that allows you to collect samples
and send them back to the
laboratory for analysis. Contact
the National Lead Information
Center for lists of EPA-recognized
testing laboratories.
FOR ADDITIONAL INFORMATION
You may need additional information on how to protect yourself and yourchildren
while a job is going on in your home, your building, or child care facility.
The National Lead Information Center at 1-800-424-LEAD (5323) or
epa.qov/lead/nlic can tell you how to contact your state, local, and/or tribal programs
or get general information about lead poisoning prevention.
Local building code officials can tell you the
regulations that apply to the renovation work that you
are planning.
State, county, and local health departments can
provide information about local programs, including
assistance for lead-poisoned children and advice on
ways to get your home checked for lead.
The National Lead Information Center can also provide
a variety of resource materials, including the following
guides to lead-safe work practices. Many of these
materials are also available at
epa.gov/lead/pubs/brochure
Steps to Lead Safe Renovation, Repair and Painting.
Protect Your Family from Lead in Your Home
Lead in Your Home: A Parent's Reference Guide
For the hearing impaired, call the Federal Information Relay Service at 1-800-877-8339
to access any of the phone numbers in this brochure.
11
ฆ State and tribal lead poisoning prevention or environmental protection programs
can provide information about lead regulations
and potential sources of financial aid for reducing
lead hazards. If your state or local government has
requirements more stringent than those described in
this pamphlet, you must follow those requirements.
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EPA CONTACTS
EPA Regional Offices
EPA addresses residential lead hazards through several different regulations.
EPA requires training and certification for conducting abatement and renovations,
education about hazards associated with renovations, disclosure about known lead
paint and lead hazards in housing, and sets lead-paint hazard standards.
Your Regional EPA Office can provide further information regarding lead safety and
lead protection programs at epa.gov/lead.
Region 1
(Connecticut, Massachusetts,
Maine, New Hampshire,
Rhode Island, Vermont)
Regional Lead Contact
U.S. EPA Region 1
Suite 1100
One Congress Street
Boston, MA 02114-2023
(888) 372-7341
Region 2
(New Jersey, New York,
Puerto Rico, Virgin Islands)
Regional Lead Contact
U.S. EPA Region 2
2890 Woodbridge Avenue
Building 205, Mail Stop 225
Edison, NJ 08837-3679
(732)321-6671
Region 3
(Delaware, Maryland,
Pennsylvania, Virginia,
Washington, DC, West
Virginia)
Regional Lead Contact
U.S. EPA Region 3
1650 Arch Street
Philadelphia, PA
19103-2029
(215)814-5000
Region 4
(Alabama, Florida, Georgia,
Kentucky, Mississippi, North
Carolina, South Carolina,
Tennessee)
Regional Lead Contact
U.S. EPA Region 4
61 Forsyth Street, SW
Atlanta, GA 30303-8960
(404) 562-9900
Region 5
(Illinois, Indiana, Michigan,
Minnesota, Ohio, Wisconsin)
Regional Lead Contact
U.S. EPA Region 5
77 West Jackson Boulevard
Chicago, IL 60604-3507
(312)886-6003
Region 6
(Arkansas, Louisiana, New
Mexico, Oklahoma, Texas)
Regional Lead Contact
U.S. EPA Region 6
1445 Ross Avenue,
12th Floor
Dallas, TX 75202-2733
(214) 665-7577
Region 7
(Iowa, Kansas, Missouri,
Nebraska)
Regional Lead Contact
U.S. EPA Region 7
901 N. 5th Street
Kansas City, KS 66101
(913)551-7003
Region 8
(Colorado, Montana,
North Dakota, South Dakota,
Utah, Wyoming)
Regional Lead Contact
U.S. EPA Region 8
1595 Wy n koop Street
Denver, CO 80202
(303)312-6312
Region 9
(Arizona, California, Hawaii,
Nevada)
Regional Lead Contact
U.S. Region 9
75 Hawthorne Street
San Francisco, CA 94105
(415) 947-8021
Region 10
(Alaska, Idaho,
Oregon, Washington)
Regional Lead Contact
U.S. EPA Region 10
1200 Sixth Avenue
Seattle, WA 98101-1128
(206) 553-1200
12
OTHER FEDERAL AGENCIES
CPSC
The Consumer Product Safety
Commission (CPSC) protects the public
from the unreasonable risk of injury or
death from 15,000 types of consumer
products under the agency's jurisdiction.
CPSC warns the public and private
sectors to reduce exposure to lead and
increase consumer awareness. Contact
CPSC for further information regarding
regulations and consumer product safety.
CPSC
4330 East West Highway
Bethesda, MD 20814
Hotline 1-(800) 638-2772
cpsc.gov
CDC Childhood Lead Poisoning
Prevention Branch
The Centers for Disease Control and
Prevention (CDC) assists state and local
childhood lead poisoning prevention
programs to provide a scientific basis
for policy decisions, and to ensure that
health issues are addressed in decisions
about housing and the environment.
Contact CDC Childhood Lead Poisoning
Prevention Program for additional
materials and links on the topic of lead.
CDC Childhood Lead Poisoning
Prevention Branch
4770 Buford Highway, MS F-40
Atlanta, GA 30341
(770) 488-3300
cdc.gov/nceh/lead
HUD Office of Healthy Homes and Lead
Hazard Control
The Department of Housing and Urban
Development (HUD) provides funds
to state and local governments to
develop cost-effective ways to reduce
lead-based paint hazards in America's
privately-owned low-income housing. In
addition, the office enforces the rule on
disclosure of known lead paint and lead
hazards in housing, and HUD's lead safety
regulations in HUD-assisted housing,
provides public outreach and technical
assistance, and conducts technical
studies to help protect children and their
families from health and safety hazards
in the home. Contact the HUD Office of
Healthy Homes and Lead Hazard Control
for information on lead regulations,
outreach efforts, and lead hazard control
research and outreach grant programs.
U.S. Department of Housing and Urban
Development
Office of Healthy Homes and
Lead Hazard Control
451 Seventh Street, SW, Room 8236
Washington, DC 20410-3000
HUD's Lead Regulations Hotline
(202) 402-7698
hud.gov/offices/lead/
13
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^eD
w
PrO^
SAMPLE PRE-RENOVATION FORM
This sample form may be used by renovation firms to document compliance with the Federal
pre-renovation education and renovation, repair, and painting regulations.
Occupant Confirmation
Pamphlet Receipt
~ I have received a copy of the lead hazard information pamphlet informing me of the
potential risk of the lead hazard exposure from renovation activity to be performed in my
dwelling unit. I received this pamphlet before the work began.
Printed Name of Owner-occupant
Signature of Owner-occupant Signature Date
Renovator's Self Certification Option (for tenant-occupied dwellings only)
Instructions to Renovator: If the lead hazard information pamphlet was delivered but a tenant
signature was not obtainable, you may check the appropriate box below.
~ Declined - I certify that I have made a good faith effort to deliver the lead hazard
information pamphlet to the rental dwelling unit listed below at the date and time indicated
and that the occupant declined to sign the confirmation of receipt. I further certify that I
have left a copy of the pamphlet at the unit with the occupant.
~ Unavailable for signature -1 certify that I have made a good faith effort to deliver the lead
hazard information pamphlet to the rental dwelling unit listed below and that the occupant
was unavailable to sign the confirmation of receipt. I further certify that I have left a copy of
the pamphlet at the unit by sliding it under the door or by (fill in how pamphlet was left).
Printed Name of Person Certifying Delivery Attempted Delivery Date
Signature of Person Certifying Lead Pamphlet Delivery
Unit Address
Note Regarding Mailing Option As an alternative to delivery in person,you may mail the
lead hazard information pamphlet to the owner and/or tenant. Pamphlet must be mailed at
least seven days before renovation. Mailing must be documented by a certificate of mailing
from the post office.
-------
Appendix 4:
Small Entity Compliance Guide to Renovate
Right
-------
XV EPA
United States
Environmental Protection
Agency
Office of Chemical Safety and
Pollution Prevention
EPA-740-K-10-003
September 2011
'/Ft ED
Small Entity Compliance
Guide to Renovate Right
EPA's Lead-Based Paint
Renovation, Repair, and
Painting Program
ON CAUTION CAUTION
IWARNINGI
LEAD WORK AREA
A handbook for contractors,
property managers and
maintenance personnel
working in homes and
child-occupied facilities
built before 1978.
-------
Who Should Read this Handbook?
Anyone who owns or manages housing or child-occupied facilities built before 1978.
Contractors who perforin activities that disturb painted surfaces in homes and child-occupied facilities
built before 1978 (including certain repairs and maintenance, and painting preparation activities).
About this Handbook
This handbook summarizes requirements of EPA's 2008 Lead-Based Paint Renovation, Repair and Painting
Program Rule (as amended in 2010 and 2011), aimed at protecting against lead-based paint hazards associ-
ated with renovation, repair and painting activities. The rule requires workers to be trained to use lead-safe
work practices and requires renovation firms to be EPA-certified; these requirements became fully effective
April 22, 2010.
To ensure compliance, you should also read the complete rule on which the program is based. While EPA has
summarized the provisions of the rule in this guide, the legal requirements that apply to renovation work are
governed by EPA's 2008 Lead Rule. A copy of the rule is available on EPA's website at
www, en a. go v/lead/nu 1) s/reno vation. htm.
A companion pamphlet, entitled The Lead-Safe Certified Guide to Renovate Right: Important Lead Hazard
Information for Families, Child Care Providers, and Schools (EPA-740-K-10-001), has been prepared in con-
junction with the rule for distribution to persons affected by work that disturbs lead-based paint. (See page 17
for information on how to get copies of the rule, the Renovate Right pamphlet, and other related materials.)
Other state or local requirements that are different from or more stringent than the federal requirements
may apply in your state. For example, federal law allows EPA to authorize states to administer their own pro-
gram in lieu of the federal lead program. Even in states without an authorized lead program, a state
may promulgate its own rules that may be different or go beyond the federal requirements. For more
information on the rules that apply in your state, please contact the National Lead Information Center
at 1-800-424-LEAD (5323).
Your feedback is important. Please review this guide and contact the National Lead Information Center
at 1-800-424-LEAD (5323) with any comments regarding its usefulness and readability, and improvements
you think are needed.
This document is published by the Environmental Protection Agency (EPA) as the official compliance
guide for small entities, as required by the Small Business Regulatory Enforcement Fairness Act of 1996
(SBREFA). Before you begin using the guide, you should know that the information in this guide was
originally published in June 2008, and was revised in July 2010 and September 2011 to address regula-
tory revisions. EPA is continually improving and upgrading its rules, policies, compliance programs, and
outreach efforts. To find out if EPA has revised or supplemented the information in this guide call the
National Lead Information Center at 1-800-424-LEAD (5323).
-------
What Is the Lead-Based Paint Renovation, Repair and
Painting Program (RRP)?
The Lead-Based Paint Renovation, Repair and Painting Program is a federal regulatory program affecting
contractors, property managers, and others who disturb painted surfaces.
It applies to residential houses, apartments, and child-occupied facilities such as schools and day-care
centers built before 1978.
It includes pre-renovation education requirements as well as training, certification, and work practice
requirements.
- Pre-renovation education requirements:
Contractors, property managers, and others who perform renovations for compensation
in residential houses, apartments, and child-occupied facilities built before 1978 are required
to distribute a lead pamphlet before starting renovation work.
- Training, certification, and work practice requirements:
Firms are required to be certified, their employees must be trained (either as a certified renovator or
on-the-job by a certified renovator) in use of lead-safe work practices, and lead-safe work practices hat
minimize occupants' exposure to lead hazards must be followed.
Renovation is broadly defined as any activity that disturbs painted surfaces and includes most repair,
remodeling, and maintenance activities, including window replacement.
The program includes requirements implementing both Section 402(c) and 406(b) of the Toxic
Substances Control Act (TSCA). (www, en a. gov/lcart/nuhs/titlctcn.htmh
EPA's lead renovation regulations can be found at 40 CFR Part 745, Subpart E.
How Can this Handbook Help Me?
Understanding the lead program's requirements can help you protect your customers from the hazards of
lead and can, therefore, mean more business for you.
This handbook presents simple steps to follow to comply with the EPA's lead program. It also lists ways
these steps can be easily incorporated into your work.
Distributing the lead pamphlet and incorporating required work practices into your job site will help protect
your customers and occupants from the hazards of lead-based paint.
1
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Who Must Follow the Renovation, Repair and Painting Rule's Re-
quirements?
In general, anyone who is paid to perform work that disturbs paint in housing and
child-occupied facilities built before 1978, this may include, but is not limited to:
- Residential rental property owners/managers
- General contractors
- Special trade contractors, including
Painters
Plumbers
Carpenters
Electricians
What Activities Are Subject to the Lead Renovation, Repair and
Painting Program?
In general, any activity that disturbs paint in pre-1978 housing and child-occupied facilities, including:
Remodeling and repair/maintenance
Electrical work
Plumbing
Painting preparation
Carpentry
Window replacement
What Housing or Activities Are Excluded and Not Subject
to the Rule?
Housing built in 1978 or later.
Housing for elderly or disabled persons, unless children under 6 reside or are expected to reside there.
Zero-bedroom dwellings (studio apartments, dormitories, etc.).
Housing or components that have been declared lead-free. Such a declaration can be made by a certified
inspector or risk assessor. Also, a certified renovator may declare specific components lead-free using an
EPA recognized test kit or by collecting paint chip samples and obtaining test results from an
EPA recognized laboratory showing the components do not contain lead-based paint.
Minor repair and maintenance activities that disturb 6 square feet or less of paint per room inside, or 20
square feet or less on the exterior of a home or building.
Note: minor repair and maintenance activities do not include window replacement and projects involving
demolition or prohibited practices.
2
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What Does the Program Require Me To Do?
Pre-renovation education requirements.
In housing built before 1978, you must:
Distribute EPA's lead pamphlet (www.ei)a.sov/lead/i)ubs/brochure.htm) to the owner and occupants
before renovation starts.
In a child-occupied facility, you must:
Distribute the lead pamphlet to the owner of the building or an adult representative of the child-occupied
facility before the renovation starts.
Either distribute renovation notices to parents/guardians of the children attending the child-occupied
facility, or post informational signs about the renovation or repair job.
For work in common areas of multi-family housing, you must:
Either distribute renovation notices to tenants or post informational signs about the renovation or
repair job.
Informational signs must:
Be posted where they will be seen;
Describe the nature, locations, and dates of the renovation; and
Be accompanied by the lead pamphlet or by information on how parents and guardians can get a free
copy (see page 29 for information on obtaining copies).
Obtain confirmation of receipt of the lead pamphlet (see page 23) from the owner, adult representative, or
occupants (as applicable), or a certificate of mailing from the post office.
Retain records for three years.
Note: Pre-renovation education requirements do not apply to emergency renovations.
Emergency renovations include interim controls performed in response to a resident child
with an elevated blood-lead level.
Training, Certification, and Work Practice Requirements.
All firms must be certified (even sole-proprietors).
All renovators must be trained.
Lead-safe work practices must be followed. Examples of these practices include:
Work-area containment to prevent dust and debris from leaving the work area.
Prohibition of certain work practices like open-flame burning and the use of power tools without HEPA
exhaust control.
Thorough clean up followed by a verification procedure to minimize exposure to lead-based
paint hazards.
3
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How Does a Firm Become Certified?
Firms must apply to EPA for certification to perform renovations or dust sampling. To apply, a firm must
submit to EPA a completed "Application for Firms," signed by an authorized agent of the firm, and pay the
correct amount of fees. To obtain a copy of the "Application for Firms" contact the NLIC at 1-800-424-LEAD
(5323) or visit www.ena.gov/getleadsafe
What Are the Responsibilities of a Certified Firm?
Firms performing renovations must ensure that:
1. All individuals performing activities that disturb painted surfaces on behalf of the firm are either certified
renovators or have been trained by a certified renovator.
2. A certified renovator is assigned to each renovation and performs all of the certified renovator
responsibilities.
3. All renovations performed by the firm are performed in accordance with the work practice standards of the
Lead-Based Paint Renovation, Repair, and Painting Program (see the flowchart on page 9 for details
about the work practice standards).
4. Pie-renovation education and lead pamphlet distribution requirements of the Lead-Based Paint Renovation,
Repair, and Painting Program are performed
5. The program's recordkeeping requirements are met.
4
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How Does a Renovator Become Certified?
To become a certified renovator an individual must successfully complete an eight-hour initial renovator
training course offered by an accredited training provider (training providers are accredited by EPA, or by an
authorized state or tribal program). The course completion certificate serves as proof of certification. To find
a trainer in your area contact the NLIC at 1-800-424-LEAD (5323) or visit www.ena.gov/getleadsafe.
Are There Streamlined Requirements for Contractors with
Previous Lead Training?
Yes. Individuals who have successfully completed an accredited lead abatement worker or supervisor course,
or individuals who have successfully completed certain EPA, Department of Housing and Urban
Development (HUD), or EPA/HUD model renovation training courses before October 4, 2011, need only
take a four-hour refresher renovator training course instead of the eight-hour initial renovator training course
to become certified. For a list of qualified previous training courses contact the NLIC at 1-800-424-LEAD
(5323) or visit www.ena.gov/lead/nuhs/trainerinstructions.htmtfrefresher.
What Are the Responsibilities of a Certified Renovator?
Certified renovators are responsible for ensuring overall compliance with the Lead-Based Paint Renovation,
Repair, and Painting Program's requirements for lead-safe work practices at renovations they are assigned
(see the flowchart on page 9 for details about the work practice standards). A certified renovator:
1. Must provide on-the-job training to other workers (who have not taken the certified renovator training
course) on the lead safe work practices to be used in performing their assigned tasks.
2. Must be physically present at the work site when warning signs are posted, while the work-area
containment is being established, and while the work-area cleaning is performed.
3. Must regularly direct work being performed by other individuals to ensure that the work practices are
being followed, including maintaining the integrity of the containment barriers and ensuring that dust or
debris does not spread beyond the work area.
4. When requested by the party contracting for renovation services, must use an EPA recognized test kit or
must collect paint chip samples, submit them to an EPA-recognized laboratory, and obtain test results
from the laboratory to determine whether components affected by the renovation contain lead-based paint.
(For more information regarding test kits call the National Lead Information Center at 1-800-424-LEAD
(5323), or check our web site at www.cna.gov/lcart/nuhs/rcnovation.htm). Note: you must assume lead-
based paint is present for housing and buildings covered by this rule, unless testing is done that determines
the components affected are lead-free.
5. Must be available, either on-site or by telephone, at all times renovations are being conducted.
6. Must perform project cleaning verification.
7. Must have with them at the work site copies of their initial course completion certificate and their most
recent refresher course completion certificate.
8. Must prepare required records.
5
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How Long Do Firm and Renovator Certifications Last?
To maintain their certification, individual renovators and firms must be re-certified by EPA every five years.
A firm must submit to EPA a completed "Application for Firms," signed by an authorized agent of the firm,
and pay the correct amount of fees. Individual renovators must successfully complete a refresher training
course provided by an accredited training provider.
What Are the Recordkeeping Requirements?
All documents must be retained for three years following the completion of a renovation.
Records that must be retained include:
Reports certifying that lead-based paint is not present.
Records relating to the distribution of the lead pamphlet.
Documentation of compliance with the requirements of the Lead-Based Paint Renovation,
Repair, and Painting Program. This information must also be given to the owner and, if different, the
occupant of the housing or unit that was renovated (EPA has prepared a sample form that is available at
www.cna.gov/lcart/nuhs/samnlcchccklist.iHlf')
What Are the Required Work Practices?
The flow charts on the following pages will help determine if your project is subject to the Lead-
Based Paint Renovation, Repair and Painting Program's requirements and, if so, the specific require-
ments for your particular project. The flowcharts, and other information included in this guide, are not
intended to be a replacement for official training.
6
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EPA's Lead Program Rule At-A-Glance
Do the Requirements Apply to the Renovation?
If you will be getting paid to do work that disturbs painted surfaces in a pre-1978 home, apartment
building, or child-occupied facility, answer the questions below to determine if the EPA lead program
requires you to distribute the lead pamphlet and/or if you will need to comply with training, certifica-
tion, and work practice requirements when conducting the work.
Does the job involve activities that disturb painted surfaces in a
home or child-occupied facility built before 1978?
m
Are ANY of the following conditions present?
The work is a lead abatement project.
Work consists of only minor repairs or maintenance that disturb 6
square feet or less of painted surfaces per room for interior activi-
ties or 20 square feet or less of painted surface for exterior activi-
ties. Note: this does not include window replacement, demolition,
and projects involving prohibited practices.
Housing has been determined to be free of lead-based paint either
by a certified inspector or risk assessor, or the components being
renovated have been determined to be free of lead-based paint by
a certified renovator using either an EPA recognized test kit or
laboratory analysis of collected paint chip samples.
Housing is a zero-bedroom dwelling (studio apartments, dormito-
ries, etc.).
Housing is for the elderly or disabled and no children under six
reside or are expected to reside there.
Is the project an emergency renovation?
Emergency renovations are:
1. Activities that were not planned and if not immediately
attended to present a safety hazard or threaten equipment
and/or property with significant damage.
OR
2. Interim controls performed in response to an elevated blood
lead level in a resident child.
~
You will need to provide the lead pamphlet.
See Flow Chart 2 for specific requirements.
EPA
lead-based
paint renovation,
repair, and
painting program
requirements
do not apply.
Pre-renovation
education
requirements
of the program
do not apply.
See Flow Chart 3
to determine which
specific renovation
training and work
practice requirements
apply to the job.
Flow Chart 1
7
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How Do I Comply with the Pre-Renovation Education Requirements?
Requirements to distribute pre-renovation educational materials vary based on the location of the
renovation. Select the location below that best describes the location of your project, and follow the
applicable procedure on the right.
Renovations
in Owner-
Occupied
Dwelling
Units
W
Renovations
J
in Tenant-
ฆ
Occupied
n
Dwelling
Units
Renovations
in Child-
Occupied
Facilities
Deliver lead pamphlet (www.ena.pov/lead/niihs/hrochiire.htin) to
owner before renovation begins and obtain confirmation of receipt.
OR
Mail lead pamphlet to owner 7 days before renovation begins and docu-
ment with certificate of mailing.
1. Provide lead pamphlet to owner using either procedure described in
the box at the top of this page.
2. Provide lead pamphlet to tenant by either method below:
(a) Deliver pamphlet to dwelling unit before renovation begins and
document delivery with either a confirmation of receipt of lead
pamphlet or a self-certification of delivery.
k
*
OR
(b)Mail lead pamphlet to tenant at least 7 days prior to renovation
and document with a certificate of mailing.
Renovations
L,
in Common
ฆ
Areas
n
of Multi-
Family
Housing Units
~
1. Provide owner with lead pamphlet using either procedure described
in the box at the top of this page.
2. Notify tenants and make pamphlet available, or post signs describing
the renovation. The signs must include the pamphlet or information
on how to review a copy.
3. Maintain written documentation describing notification procedures.
4. Provide supplemental renovation notice if changes occur in location,
timing, or scope of renovation occurring.
it
1. Provide the owner of the building with the lead pamphlet using either:
(a) The procedure described in the box at the top of this page.
OR
See
Flow
Chart 3
for
information
about
specific
training
and work
practice
requirements
for the job.
*
(b)If the child-occupied facility is not the building owner, provide the lead pamphlet by either
method below:
(i) Obtain a written acknowledgment that an adult representative received the pamphlet; or cer-
tify in writing that a pamphlet was delivered.
OR
(ii) Obtain a certificate of mailing at least 7 days before the renovation.
2. Provide the parents or guardians of children using the childoccupied facility with information by
either of these methods:
(a) Mail or hand-deliver the lead pamphlet and renovation information to each parent or guardian.
OR
(b)Post signs describing the renovation. The signs must include the pamphlet or information on
how to review a copy.
8
Flow Chart 2
-------
Do the Renovation Training and Work Practices Apply?
Is the project an emergency renovation?
Does the project include interim controls performed in
response to an elevated blood lead level of a resident
child?
Continue to
Flow Chart 4
for work
practice
requirements.
Emergency projects are exempt from the warning sign,
containment, waste handling, training, and certification
requirements to the extent necessary to respond to the
emergency. Emergency renovations are NOT exempt
from the cleaning and cleaning verification requirements.
See Flow Chart 5 for interior cleaning and cleaning
verification requirements, and Flow Chart 8 for exterior
cleaning and verification requirements.
Flow Chart 3
9
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Work Practice Requirements
General
(A) Renovations must be performed by certified firms using certified renovators.
(B) Finns must post signs clearly defining the work area and warning occupants and other persons
not involved in renovation activities to remain outside of the work area. These signs should be
in the language of the occupants.
(C) Prior to the renovation, the firm must contain the work area so that no dust or debris leaves
the work area while the renovation is being performed.
(D) Work practices listed below are prohibited during a renovation:
1. Open-flame burning or torching of painted surfaces;
2. Use of machines that remove paint or other surface coatings through high speed operation such
as sanding, grinding, power planing, needle gun, abrasive blasting, or sandblasting, unless such
machines have shrouds or contaimnent systems and are equipped with a HEPA vacuum attachment
to collect dust and debris at the point of generation. Machines must be operated so that no visible
dust or release of air occurs outside the shroud or contaimnent system; and
3. Operating a heat gun on painted surfaces at temperatures above 1100 degrees Fahrenheit.
(E) Waste from renovations:
1. Waste from renovation activities must be contained to prevent releases of dust and debris
before the waste is removed from the work area for storage or disposal.
2. At the conclusion of each work day and at the conclusion of the renovation waste that has
been collected from renovation activities must be stored to prevent access to and the release
of dust and debris.
3. Waste transported from renovation activities must be contained to prevent release of dust
and debris.
Interior Exterior
Renovation
Projects.
See Flow
Chart 5.
Renovation
Projects.
See Flow
Chart 8.
10
Flow Chart 4
-------
Work Practice Requirements Specific to Interior Renovations
The firm must:
(A) Remove all objects from the work area or cover them with plastic sheeting with all seams and
edges sealed.
(B) Close and cover all ducts opening in the work area with taped-down plastic sheeting.
(C) Close windows and doors in the work area. Doors must be covered with plastic sheeting.
(D) Cover the floor surface with taped-down plastic sheeting in the work area a minimum of six feet
beyond the perimeter of surfaces undergoing renovation or a sufficient distance to contain the dust,
whichever is greater. If a vertical containment system is employed, floor covering may stop at the
vertical barrier, providing it is impermeable, extends from floor to ceiling, and is tightly sealed at
floors, ceilings, and walls.
(E) Use precautions to ensure that all personnel, tools, and other items, including the exteriors of
containers of waste, are free of dust and debris when leaving the work area.
(F) After the renovation has been completed, the firm must clean the work area until no dust, debris or
residue remains. The firm must:
1. Collect all paint chips and debris, and seal it in a heavy-duty bag.
2. Remove and dispose of protective sheeting as waste.
3. Clean all objects and surfaces in the work area and within two feet of the work area in the
following manner:
a. Clean walls starting at the ceiling and working down to the floor by either vacuuming with a
HEPA vacuum or wiping with a damp cloth.
b. Thoroughly vacuum all remaining surfaces and objects in the work area, including furniture
and fixtures, with a HEPA vacuum.
c. Wipe all remaining surfaces and objects in the work area, except for carpeted or upholstered
surfaces, with a damp cloth. Mop uncarpeted floors thoroughly using a mopping method that
keeps the wash water separate from the rinse water, or using a wet mopping system.
I
Cleaning verification is required to ensure the work area
is adequately cleaned and ready for re-occupancy.
See Flow Chart 6 for instructions on performing cleaning
verification for interior projects.
Flow Chart 5
11
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Interior Cleaning Verification: Visual Inspection and Optional
Clearance Testing
Certified renovator must perform a visual inspection.
Is dust, debris or residue present?
Does the contract, or another federal, state, territorial, tribal, or
local regulation, require clearance testing at the conclusion of the
renovation?
Are the dust clearance samples required to be collected
by a certified inspector, risk assessor or dust sampling
technician, and is the renovation firm required to re-clean the
work area until the dust clearance sample results are below
applicable clearance standards?
When you meet the applicable clearance standards,
you're finished!
The area must be
re-cleaned and another
visual inspection must
be performed.
H
Continue to
cleaning
verification
procedure.
See Flow
Chart 7.
12
Flow Chart 6
-------
Interior Cleaning Verification: Floors, Countertops, and Window Sills
Note: For areas greater than 40 square feet, separate the area into sections and use a new disposable
cleaning cloth for each section.
Certified renovator must wipe all uncarpeted floors, countertops,
and windowsills within the work area with a wet disposable clean-
ing cloth. Is the cloth used for any area darker than the cleaning
verification card?
Re-clean the areas that failed using the procedures from Flow
Chart 5, then use a new wet disposable cleaning cloth to wipe
those areas again. Is the cloth used for any area darker than the
cleaning verification card?
Wait until either the area has dried completely or 1 hour has
passed, whichever is longer. Once dry, wipe that area with a dry
disposable cleaning cloth.
The
work area
has been
adequately
cleaned
and
warning
signs
may be
removed.
1
You're finished!
Flow Chart 7
13
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Work Practice Requirements Specific to Exterior Renovations
The firm must:
(A) Close all doors and windows within 20 feet of the renovation.
(B) Ensure that doors within the work area that will be used while the job is being performed are
covered with plastic sheeting in a manner that allows workers to pass through while confining
dust and debris.
(C) Cover the ground with plastic sheeting or other disposable impermeable material extending a
minimum of 10 feet beyond the perimeter or a sufficient distance to collect falling paint debris,
whichever is greater. If a property line prevents 10 feet of such ground covering, then erect verti-
cal containment or equivalent extra precautions to prevent contamination of adjacent buildings and
property.
(D) In situations such as where work areas are in close proximity to other buildings, windy conditions,
etc., the renovation firm must take extra precautions in containing the work area, like vertical
containment.
(E) After the renovation has been completed, the firm must clean the work area until no dust, debris or
residue remains. The firm must:
1. Collect all paint chips and debris, and seal it in a heavy-duty bag.
2. Remove and dispose of protective sheeting as waste.
3. Waste transported from renovation activities must be contained to prevent release of dust and
debris.
A certified renovator must perform a visual inspection.
Is dust, debris or residue present?
These conditions
must be eliminated and
another visual inspec-
tion must
be performed.
The area has
been adequately
cleaned; remove
the warning signs
You're finished!
14
Flow Chart 8
-------
How Is My Compliance Determined, and What Happens if the
Agency Discovers a Violation?
To maximize compliance, EPA implements a balanced program of compliance assistance, compliance incen-
tives, and traditional law enforcement. EPA knows that small businesses that must comply with complicated
new statutes or rules often want to do the right thing, but may lack the requisite knowledge, resources, or
skills. Compliance assistance information and technical advice helps small businesses to understand and
meet their environmental obligations. Compliance incentives, such as EPA's Small Business Policy, apply to
businesses with 100 or fewer employees and encourage persons to voluntarily discover, disclose, and correct
violations before they are identified by the govermnent (more information about EPA's Small Business Policy
is available at www.cna.gov/comnliancc/inccntivcs/smalIhusincss/indcx.html) EPA's enforcement program
is aimed at protecting the public by targeting persons or entities who neither comply nor cooperate to address
their legal obligations.
EPA uses a variety of methods to determine whether businesses are complying, including inspecting work
sites, reviewing records and reports, and responding to citizen tips and complaints. Under TSCA, EPA (or
a state, if this program has been delegated to it) may file an enforcement action against violators seeking
penalties of up to $37,500 per violation, per day. The proposed penalty in a given case will depend on many
factors, including the number, length, and severity of the violations, the economic benefit obtained by the vio-
lator, and its ability to pay. EPA has policies in place to ensure penalties are calculated fairly. These policies
are available to the public. In addition, any company charged with a violation has the right to contest EPA's
allegations and proposed penalty before an impartial judge or jury.
EPA encourages small businesses to work with the Agency to discover, disclose, and correct violations. The
Agency has developed self-disclosure, small business, and small community policies to modify penalties for
small and large entities that cooperate with EPA to address compliance problems. In addition, EPA has estab-
lished compliance assistance centers to serve over one million small businesses (see Construction Industry
Compliance Assistance Center for information regarding this rule at www.cicacenter.org). For more informa-
tion on compliance assistance and other EPA programs for small businesses, please contact EPA's Small Busi-
ness Ombudsman at 202-566-2075.
15
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Frequent Questions
What is the legal status of this guide?
This guide was prepared pursuant to section 212 of SBREFA. EPA has tried to help explain in this guide what
you must do to comply with the Toxic Substances Control Act (TSCA) and EPA's lead regulations. However,
this guide has no legal effect and does not create any legal rights. Compliance with the procedures described
in this guide does not establish compliance with the rule or establish a presumption or inference of compli-
ance. The legal requirements that apply to renovation work are governed by EPA's 2008 Lead Rule, which
controls if there is any inconsistency between the rule and the information in this guide.
Is painting considered renovation if no surface preparation activity occurs?
No. If the surface to be painted is not disturbed by sanding, scraping, or other activities that may cause dust,
the work is not considered renovation and EPA's lead program requirements do not apply. However, painting
projects that involve surface preparation that disturbs paint, such as sanding and scraping, would be covered.
What if I renovate my own home?
EPA's lead program rules apply only to renovations performed for compensation; therefore, if you work on
your own home, the rules do not apply. EPA encourages homeowners to use lead-safe work practices, none-
theless, in order to protect themselves, their families, and the value of their homes.
Is a renovation performed by a landlord or employees of a property management firm con-
sidered a compensated renovation under EPA's lead program rules?
Yes. The receipt of rent payments or salaries derived from rent payments is considered compensation under
EPA's lead program. Therefore, renovation activities performed by landlords or employees of landlords are
covered.
Do I have to give out the lead pamphlet seven days prior to beginning renovation activities?
The 7-day advance delivery requirement applies only when you deliver the lead pamphlet by mail;
otherwise, you may deliver the pamphlet anytime before the renovation begins so long as the renovation
begins within 60 days of the date that the pamphlet is delivered. For example, if your renovation is to begin
May 30, you may deliver the pamphlet in person anytime between April 1 and start of the project on May 30,
or you may deliver the pamphlet by mail anytime between April 1 and May 23.
Tips for Easy Compliance
1. For your convenience the sample form on page 23 of this handbook is included in the Renovate
Right lead pamphlet (see page 29 for information on how to get copies). Attach the form to the
back of your customer renovation or repair contracts. The completed form can be filed along with
your regular paperwork.
2. Plan ahead to obtain enough copies of the lead pamphlet (see page 29 for information on how to
get copies of the pamphlet).
16
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Where Can I Get More Information?
Further information is available from the National Lead Information Center (800-424-LEAD) and
the Internet at www.ena.gov/lead. Available resources include:
Full text version of the Lead-Based Paint Renovation, Repair, and Painting Program regulation.
Frequent Questions which provide more detailed information on the rule's requirements.
A downloadable version of the lead pamphlet.
Why Is Lead Paint Dangerous?
Lead gets into the body when it is swallowed or inhaled. People,
especially children, can swallow lead dust as they eat, play, and do
other normal hand-to-mouth activities. People may also breathe in ^4
lead dust or fumes if they disturb lead-based paint. People who
sand, scrape, burn, brush, blast or otherwise disturb lead-based
paint risk unsafe exposure to lead.
Lead is especially dangerous to children under 6 years of age.
Lead can affect children's brains and developing nervous
systems, causing:
Reduced IQ and learning disabilities.
Behavioral problems.
Even children who appear healthy can have dangerous levels of lead in their bodies.
Lead is also harmful to adults. In adults, low levels of
lead can pose many dangers, including:
High blood pressure and hypertension.
Pregnant women exposed to lead can transfer lead to
their fetus.
-------
Other Resources
For additional information on how to protect yourself and your customers from lead paint hazards,
visit www.ena.gov/lead or call the National Lead Information Center at 1-800-424-LEAD (5323).
Available documents include:
The Lead-Safe Certified Guide to Renovate Right: Important Lead Hazard Information for Families, Child
Care Providers and Schools
Joint EPA-HUD Curriculum: Lead Safety for Remodeling, Repair, and Painting
Steps to Lead Safe Renovation, Repair and Painting
Fight Lead Poisoning with a Healthy Diet
Protect Your Family From Lead in Your Home
Lead in Your Home: A Parent's Reference Guide
CAUTION
Important lead hazard information for
families, child care provtdcnt and schoofa.
18
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Key Terms
Certificate of Mailing A written verification from the Postal Service that you mailed the lead pamphlet
to an owner or a tenant. This is less expensive than certified mail, which is also acceptable for meeting the
Lead-Based Paint Renovation, Repair, and Painting Program requirements. (Note: If using this delivery
option, you must mail the pamphlet at least seven days prior to the start of renovation.)
Certified Inspector or Risk Assessor An individual who has been trained and is certified by EPA or an
authorized state or Indian Tribe to conduct lead-based paint inspections or risk assessments.
Child-occupied Facility May include, but is not limited to, day care centers, pre-schools and kindergarten
classrooms. Child-occupied facilities may be located in target housing or in public or commercial buildings.
The regulation defines a "child-occupied facility" as a building, or portion of a building, constructed prior to
1978, visited regularly by the same child, under 6 years of age, on at least two different days within any week
(Sunday through Saturday period), provided that each day's visit lasts at least three hours and the combined
weekly visits last at least six hours, and the combined annual visits last at least 60 hours. Child-occupied
facilities may be located in target housing, or in public or commercial buildings. With respect to common
areas in public or commercial buildings that contain child-occupied facilities, the child-occupied facility
encompasses only those common areas that are routinely used by children under age 6, such as restrooms
and cafeterias. Common areas that children under age 6 only pass through, such as hallways, stairways, and
garages are not included. In addition, with respect to exteriors of public or commercial buildings that contain
child-occupied facilities, the child-occupied facility encompasses only the exterior sides of the building that
are immediately adjacent to the child-occupied facility or the common areas routinely used by children under
age 6.
Cleaning Verification Card a card developed and distributed by EPA for the purpose of determining,
through comparison of wet and dry disposable cleaning cloths with the card, whether post-renovation
cleaning has been properly completed.
Common Area A portion of a building that is generally accessible to all residents or users. Common
areas include (but are not limited to) hallways, stairways, laundry rooms, recreational rooms, playgrounds,
community centers, and fenced areas. The term applies to both interiors and exteriors of the building.
Component A specific design or structural element or fixture distinguished by its form, function, and
location. A component can be located inside or outside the dwelling. Examples...
Interior Exterior
Ceilings Painted roofing
Crown molding
Walls
Doors and trim
Floors
Fireplaces
Radiators
Shelves
Stair treads
Windows and trim
Built-in cabinets
Beams
Bathroom vanities
Counter tops
Air conditioners
Flashing
Gutters and downspouts
Ceilings
Soffits
Doors and trim
Fences
Floors
Joists
Handrails
Window sills and sashes
Air conditioners
19
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Confirmation of Receipt of Lead Hazard Information Pamphlet A form that is signed by the owner or ten-
ant of the housing confirming that they received a copy of the lead pamphlet before the renovation began.
(See sample on page 23.)
Emergency Renovation Unplanned renovation activities done in response to a sudden, unexpected event
which, if not immediately attended to, presents a safety or public health hazard or threatens property with
significant damage.
Examples
Renovation to repair damage from a tree that fell on a house.
Renovation to repair a burst water pipe in an apartment complex.
Interim controls performed in response to an elevated blood lead level in a resident child.
Firm A company, partnership, corporation, sole proprietorship or individual doing business, association,
or other business entity; a Federal, State, Tribal, or local government agency; or a nonprofit organization.
General Contractor One who contracts for the construction of an entire building or project, rather than for
a portion of the work. The general contractor hires subcontractors (e.g. plumbing, electrical, etc.), coordinates
all work, and is responsible for payment to subcontractors.
Housing for the Elderly Retirement communities or similar types of housing specifically reserved for
households of one or more persons 62 years of age or older at the time the unit is first occupied.
Interim Controls Interim controls means a set of measures designed to temporarily reduce human exposure
or likely exposure to lead-based paint hazards, including specialized cleaning, repairs, maintenance, painting,
temporary containment, ongoing monitoring of lead-based paint hazards or potential hazards, and the estab-
lishment and operation of management and resident education programs.
Lead Abatement Work designed to permanently eliminate lead-based paint hazards. If you are hired to do
lead-abatement work only, the Lead-Based Paint Renovation, Repair, and Painting Program does not apply.
Abatement does not include renovation, remodeling, or other activities done to repair, restore, or redesign a
given building even if such renovation activities incidentally eliminate lead-based paint hazards. {Note:
Some states define this term differently than described above. Consult your state officials if you are not sure
how "lead abatement" is defined in your state.)
Lead Pamphlet The lead hazard information pamphlet for the purpose of pre-renovation education is The
LeadSafe Certified Guide to Renovate Right: Important Lead Hazard Information for Families, Child Care
Facilities and Schools, or an EPA-approved alternative pamphlet. (See page 29 for information on obtaining
copies.)
20
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Minor Repair and Maintenance Activities that disrupt 6 square feet or less of painted surface per room for
interior activities or 20 square feet or less of painted surface for exterior activities where none of the prohibit-
ed work practices is used and where the work does not involve window replacement or demolition of painted
surface areas. When removing painted components, or portions of painted components, the entire surface area
removed is the amount of painted surface disturbed. Jobs, other than emergency renovations, performed in the
same room within the same 30 days must be considered the same job for the purpose of determining whether
the job is a minor repair and maintenance activity.
Owner Any person or entity that has legal title to housing, including individuals, partnerships,
corporations, government agencies, Indian Tribes, and nonprofit organizations.
Painted Surface A component surface covered in whole or in part with paint or other surface coatings.
Prohibited Practices Work practices listed below are prohibited during a renovation:
Open-flame burning or torching of painted surfaces;
Use of machines that remove paint or other surface coatings through high speed operation such as sanding,
grinding, power planing, needle gun, abrasive blasting, or sandblasting, unless such machines have shrouds
or containment systems and are equipped with a HEPA vacuum attachment to collect dust and debris at the
point of generation. Machines must be operated so that no visible dust or release of air occurs outside the
shroud or containment system.
Operating a heat gun on painted surfaces at temperatures above 1100 degrees Fahrenheit.
Record of Notification A written statement documenting the steps taken to notify occupants of renovation
activities in common areas of multi-family housing. (See page 25 for sample.)
Renovation Modification of all or part of any existing structure that disturbs a painted surface, except for
some specifically exempted activities (e.g., minor repair and maintenance). Includes:
Removal/modification of painted surfaces, components, or structures
Surface preparation activities (sanding/scraping/other activities that may create paint dust)
Window replacement
Examples
1. Demolition of painted walls or ceilings
2. Replastering
3. Plumbing repairs or improvements
4. Any other activities which disturb painted surfaces
Renovation Notice Notice to tenants of renovations in common areas of multi-family housing. (See sample
form on page 25.) Notice must describe nature, location, and expected timing of renovation activity; and must
explain how the lead pamphlet may be obtained free of charge.
21
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Renovator A person who either performs or directs
workers who perform renovation. A certified renova-
tor is a renovator who has successfully completed a
renovator course accredited by EPA or an EPA autho-
rized State or Tribal program. (Note: Because the term
"renovation" is defined broadly by the Lead-Based
Paint Renovation, Repair, and Painting Program, many
contractors who are not generally considered "renova-
tors", as that term is commonly used, are considered to
be "renovators" under the program and must follow the
rule's requirements.)
Self-Certification of Delivery An alternative
method of documenting delivery of the lead hazard
information pamphlet to a tenant. This method may be
used whenever the tenant is unavailable or unwilling to
sign a confirmation of receipt of lead pamphlet. (See
sample form on page 23.) (Note: This method is not a
permissible substitute for delivery of the lead pamphlet
to an owner.)
Supplemental Renovation Notice additional
notification that is required when the scope, location,
or timing of project changes.
Vertical Containment A vertical barrier consisting
of plastic sheeting or other impermeable material over
scaffolding or a rigid frame, or an equivalent system
of containing the work area. Vertical containment is
required for some exterior renovations but it may be
used on any renovation.
Zero-Bedroom Dwelling Any residential
dwelling where the living area is not separated from
the sleeping area. This term includes efficiency and
studio apartments, dormitory housing, and military
barracks.
22
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Sample Pre-Renovation Form
This sample form may be used by firms to document compliance with the requirements of the Federal
Lead-Based Paint Renovation, Repair, and Painting Program.
Occupant Confirmation
Pamphlet Receipt
I have received a copy of the lead hazard information pamphlet informing me of the potential risk of the
lead hazard exposure from renovation activity to be performed in my dwelling unit. I received this
pamphlet before the work began.
Printed Name of Owner-occupant
Signature of Owner-occupant Signature Date
Renovator's Self Certification Option (for tenant-occupied dwellings only)
Instructions to Renovator: If the lead hazard information pamphlet was delivered but a tenant signature was not
obtainable, you may check the appropriate box below.
Declined -1 certify that I have made a good faith effort to deliver the lead hazard information pamphlet
to the rental dwelling unit listed below at the date and time indicated and that the occupant declined to
sign the confirmation of receipt. I further certify that I have left a copy of the pamphlet at the unit with
the occupant.
Unavailable for signature -1 certify that I have made a good faith effort to deliver the lead hazard
information pamphlet to the rental dwelling unit listed below and that the occupant was unavailable to
sign the confirmation of receipt. I further certify that I have left a copy of the pamphlet at the unit by
sliding it under the door or by (fill in how pamphlet was left).
Printed Name of Person Certifying Delivery Attempted Delivery Date
Signature of Person Certifying Lead Pamphlet Delivery
Unit Address
Note Regarding Mailing Option As an alternative to delivery in person, you may mail the lead
hazard information pamphlet to the owner and/or tenant. Pamphlet must be mailed at least 7 days
before renovation. Mailing must be documented by a certificate of mailing from the post office.
23
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^tD srx
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Sample Forms (continued)
Renovation Notice For use in notifying tenants of renovations in common areas of multi-family
housing.
The following renovation activities will take place in the following locations:
Activity (e.g., sanding, window replacement)
Location (e.g., lobby, recreation center)
The expected starting date is and the expected ending date is .
Because this is an older building built before 1978, some of the paint disturbed during the renovation
may contain lead. You may obtain a copy of the pamphlet Renovate Right, by telephoning me
at . Please leave a message and be sure to include your name, phone num-
ber and address. I will either mail you a pamphlet or slide one under your door.
Date Printed name of renovator
Signature of renovator
Record of Tenant Notification Procedures
Project Address
Street (apt. #)
City State Zip Code
Owner of multi-family housing
Number of dwelling units
Method of delivering notice forms (e.g
. delivery to units, delivery to mailboxes of units)
Name of person delivering notices
Signature of person delivering notices Date of Delivery
25
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^tD srx
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Sample Renovation Recordkeeping Checklist
Name of Finn:
Date and Location of Renovation:
Brief Description of Renovation:
Name of Assigned Renovator:
Name(s) of Trained Worker(s), if used:
Name of Dust Sampling Technician,
Inspector, or Risk Assessor, if used:
Copies of renovator and dust sampling technician qualifications (training certificates, certifications) on file.
Certified renovator provided training to workers on (check all that apply):
Test kit or test results from an EPA-recognized laboratory on collected paint chip sample, used by certified
renovator to determine whether lead was present on components affected by renovation (identify method
used, type of test kit used (if applicable), laboratory used to conduct paint chip analysis, describe sampling
locations and results):
Warning signs posted at entrance to work area.
Work area contained to prevent spread of dust and debris
All objects in the work area removed or covered (interiors)
HVAC ducts in the work area closed and covered (interiors)
Windows in the work area closed (interiors)
Windows in and within 20 feet of the work area closed (exteriors)
Doors in the work area closed and sealed (interiors)
Doors in and within 20 feet of the work area closed and sealed (exteriors)
Doors that must be used in the work area covered to allow passage but prevent spread of dust
Floors in the work area covered with taped-down plastic (interiors)
Ground covered by plastic extending 10 feet from work areaplastic anchored to building and
weighed down by heavy objects (exteriors)
Vertical contaimnent installed if property line prevents 10 feet of ground covering, or if necessary to prevent
migration of dust and debris to adjacent property (exteriors)
Waste contained on-site and while being transported off-site.
Work site properly cleaned after renovation
All chips and debris picked up, protective sheeting misted, folded dirty side inward, and taped for removal
Work area surfaces and objects cleaned using HEPA vacuum and/or wet cloths or mops (interiors)
Certified renovator performed post-renovation cleaning verification (describe results, including the
number of wet and dry cloths used):
If dust clearance testing was performed instead, attach a copy of report
I certify under penalty of law that the above information is true and complete.
Name and title Date
Posting warning signs
Maintaining contaimnent
Waste handling
Setting up plastic containment barriers
Avoiding spread of dust to adjacent areas
_ Post-renovation cleaning
27
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^tD sr%
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Where Can I Get Copies of the Lead Pamphlet?
For single copies, in Spanish or English, of The Lead-Safe Certified Guide to Renovate Right: Important
Lead Hazard Information for Families, Child Care Facilities and Schools (EPA-740-K-10-001), call the
National Lead Information Center (NLIC) at 1-800-424-LEAD. For any orders, be sure to use the appro-
priate stock reference number listed above.
There are four ways to get multiple copies:
1. Obtain downloadable copies (PDF) from the EPA website at
www.ei)a,gov/lead/i)ubs/brochure.htm.
2. Call the Government Printing Office (GPO) Order Desk at
(202) 512-1800.
3. Order from the GPO Bookstore at
httn:/7hookstore.gi)o.gov/cnvironment
4. Request copies in writing from:
U.S. GPO
P.O. Box 979050
St. Louis, MO 63197-9000
The pamphlet may be photocopied for distribution as long as the text
and graphics are readable.
Paperwork Reduction Act Notice: The incremental public burden for the collection of information contained in the Lead
Renovation, Painting and Repair Program, which are approved under OMB Control No. 2070-0155 and identified under
EPA ICR No. 1715, is estimated to average approximately 54 hours per year for training providers. For firms engaged in
regulated renovation, repair, and painting activities, the average incremental burden is estimated to be about 6.5 hours per
year. Comments regarding this burden estimate or any other aspect of this collection of information, including suggestions
for reducing the burden, may be sent to: Director, Collection Strategies Division, Office of Environmental Information,
U.S. Environmental Protection Agency (Mail Code 2822T), 1200 Pennsylvania Avenue, N.W., Washington, D.C. 20460.
Include the OMB number identified above in any correspondence. Do not send any completed form(s) to this address. The
actual information or fonn(s) should be submitted in accordance with the instructions accompanying the form(s), or as
specified in the corresponding regulations.
Important lead hazard information (or
families, child care providm and schoob.
29
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NOTICE
This guide was prepared pursuant to section 212 of the Small Business Regulatory
Enforcement Fairness Act of 1996 (SBREFA), Pub. L. 104-121. THIS DOCUMENT
IS NOT INTENDED, NOR CAN IT BE RELIED UPON, TO CREATE ANY RIGHTS
ENFORCEABLE BY ANY PARTY IN LITIGATION WITH THE UNITED STATES.
The statements in this document are intended solely as guidance to aid you in complying
with the Lead-Based Paint Renovation, Repair, and Painting Program requirements in 40
CFR 745, Subpart E. EPA may decide to revise this guide without public notice to reflect
changes in EPA's approach to implementing the Lead-Based Paint Renovation, Repair, and
Painting Program or to clarify and update text. To determine whether EPA has revised this
guide and/or to obtain copies, contact EPA's Small Business Ombudsman at 202-566-2075,
or contact the National Lead Information Center at l-800-424-LEAD(5323), or on the
web at www.ena.pov/leatl/nubs/nlic.htin.
SEPA
United States
Environmental Protection
www.en a. go v/lead
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Appendix 5:
Steps to LEAD SAFE Renovation, Repair,
and Painting
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Steps to
LEAD SAFE
Renovation, Repair 3
and Painting s.
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oEPA
United States
Environmental Protection
Agency
1-800-424-LEAD
www.epa.gov/lead
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Renovating, Repairing or Painting?
Do you renovate, repair or paint homes or child-occupied facilities built before
1978?
If so, you need to know how to work safely with lead-based paint. This guide is
designed to help plan for and complete a home renovation, repair or painting
project using lead safe work practices. Lead safe work practices are a group of
techniques that reduce the amount of dust produced by renovation activities.
When used correctly, they make the work area safer for workers and the home
safe for residents when renovation is complete.
Are you a professional renovator?
Contractors doing work for compensation in homes or child-occupied facilities
built before 1978 must be certified and follow certain work practices. This guide
describes those required work practices and provides additional helpful recom-
mendations.
Are you a do-it-yourselfer?
If you are doing work yourself you should follow the work practices described in
this brochure to ensure your home and family are protected from lead hazards the
project could generate.
Contractors, Painters, Landlords! If you are working in a
home or child-occupied facility built before 1978, you
are required to provide information about lead-based paint
to occupants and owners of homes, and owners and parents
of child-occupied facilities. For more information, see page
31.
"M~% enovation, repair and painting contractors must be certi-
J\.fied and use lead safe work practices when working in
homes built before 1978. For more information, see page 6.
2
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Table of Contents
Learn the Facts About Lead -Based Paint
The Renovation, Repair and Painting Program Rule
Other Federal and State Regulations
Step 1: Determine if the Job Involves.rlead
Step 2: Set It LJp Safely
Step 3: Protect Yourself
Step 4: Minimize the Dust
Step 5: Leave the Work Area Cleap
Step 6: Control the Waste
Step 7: Verify Work Completion with the Cjlanii
Verification Procedure or Cleararlfe
Learn More About Lead Safety
ฆ
Other Resources
Pre-Renovation Education Requirement:
3
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r
1
71
Learn the Facts about
Lead-Based Paint
About half of homes built before 1978 have lead-based paint. The likelihood
of finding lead-based paint increases with the age of the home:
ฆ Two out of three of homes built between 1940 and 1960 have
lead-based paint.
ฆ Nine out of ten homes built before 1940 have lead-based paint.
Older Homes are More Likely to
Contain Lead-Based Paint
3
CO
V)
flj
%
CI
ฃ
o
X
Betvreen 1960-1977
Between 1940-1959
Before 1940
'ฆ ฆ"lyj11 ฆ"lyj"
24%
69%
87%
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Percentage of Homes Containing Lead-Based Paint
Source: American Healthy Homes Survey: Lead and Arsenic Findings. April 2011.
Lead-based paint may be found on any surface in the homeinside or
outside. When lead-based paint is disturbed during renovation, repair or
painting activities, dangerous amounts of lead dust can be created. Jobs such
as demolition, window replacement, opening up walls, etc., can also release
accumulated lead dust into the home. Even after a typical renovation cleanup,
dangerous levels of lead dust can remain.
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Lead gets into the body when it is swallowed or breathed.
ฆ People, especially children, can swallow lead dust as they eat, play, and
perform other ordinary hand-to-mouth activities.
ฆ People may also breathe in lead dust or fumes while they work on jobs
that sand, scrape, brush, blast or otherwise disturb painted surfaces that
contain lead paint.
ฆ Additionally, pets may be poisoned by the same types of exposure to lead.
Once in the body, lead can have significant effects on
human health.
ฆ In children, lead poisoning damages the nervous system and causes
developmental and behavioral problems that can affect them for their
lifetime.
ซ In adults, lead poisoning causes health and reproductive problems.
Pregnant women are especially vulnerable to the effects of lead.
Research has shown that general residential renovation activities are
associated with an increased risk of elevated lead levels in children.
By working safely
you can help pre-
vent lead exposure
and poisoning.
This guide tells
you how.
5
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0 COA The Renovation, Repair
united states and Painting PvogyutH
Environmental Protection o o
Agency Rule
The RRP rule affects contractors, property managers and others who disturb
known or presumed lead-based paint during renovation. The term renova-
tion covers all activities done for compensation that disturb painted surfaces
including most repair, remodeling and maintenance activities, such as window
replacement, weatherization and demolition. The RRP rule applies to all
renovation work performed in residential houses, apartments and child-
occupied facilities such as schools and day-care centers built before 1978.
To assist those affected by the RRP rule, EPA developed the Small Entity
Compliance Guide to Renovate Right, which provides an overview of the
rules requirements. This guide, along with links to other related materials is
available on EPAs Web site at
www.epa.gov/lead/pubs/lscp-renov-materials.htm.
Requirements for Renovation Contractors Include:
Certification and Training Requirements
ฆ All firms paid to perform renovation, repair or painting work in pre-1978
housing and child-occupied facilities must be certified. This is accom-
plished by applying to EPA or to the State, if it has an EPA-authorized
renovation program, and paying a fee. For information about the autho-
rization status of your state, visit
www.epa.gov/lead/pubs/lscp-renovation_firm.htm or call the National
Lead Information Center at 1-800-424-LEAD (5323).
ฆ Firms must have a "Certified Renovator" assigned to each job where
lead-based paint is disturbed. To become certified, a renovator must
successfully complete an EPA or State-approved training course
conducted by a training program accredited by EPA or an EPA autho-
rized state program.
ฆ All renovation workers must be trained. Renovation workers can be
trained on-the-job by a Certified Renovator to use lead safe work
practices, or they can become Certified Renovators themselves.
6
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Pre-Renovation Education Requirements
ฆ Contractors, property managers and others who perform renovations
for compensation in residential houses, apartments, and child-occupied
facilities built before 1978 are required to distribute EPAs Renovate
Right lead hazard information pamphlet before starting renovation work
to occupants and owners of homes, and owners and parents of child-
occupied facilities. More information about pre renovation education
requirements can be found on page 31.
Work Practice Requirements
ฆ Renovators must use work-area containment to prevent dust
and debris from leaving the work area.
ฆ Certain work practices are prohibited. Open-flame burning,
using heat guns at greater than 1,100 degrees Fahrenheit and
the use of power tools without high-efficiency particulate
air (HEPA) exhaust control (to collect dust generated) are
prohibited.
ฆ Thorough cleaning followed by a cleaning verification procedure to
minimize exposure to lead-based paint hazards is required.
ฆ Minor repair and maintenance activities (6 square feet or less per interior
room or 20 square feet or less per exterior project) are exempt from the
work practices requirements. However, this exemption does not apply to
jobs involving window replacement or demolition, or that involve the use
of any of the prohibited practices listed above.
THE LEAt)>SAFE.CERTIFIED GUIDE TO
RENOVATE
7
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Other Federal and State
Regulations
The U.S. Department of Housing and Urban Development (HUD) Lead
Safe Housing Rule
HUDs Lead Safe Housing Rule (24 CFR Part 35) covers pre-1978 federally-
owned or assisted housing and federally-owned housing that is being sold. It
does not cover child-occupied facilities outside of residential housing. The
requirements of HUDs rule are similar to EPAs RRP rule, but there are some
differences in the details, including:
ฆ Training Requirements. To conduct lead hazard control in federally-
assisted housing there must be a Renovator certified by EPA or an EPA
authorized state and all workers must have completed a HUD-approved
course, or the crew must be supervised by a Renovator certified by EPA
or an EPA authorized state who is also a Certified Lead Abatement
Supervisor and untrained workers must receive on the job training from
the Certified Renovator.
ฆ Minor Repair and Maintenance. HUDs definition of minor repair and
maintenance that is exempt from its rule is different than EPAs (2 square
feet interior and 20 square feet exterior or 10 percent of the surface area
of a small building component type).
Other differences between the EPA and HUD rules (concerning paint testing,
prohibited practices, clearance testing and waste disposal) are pointed out in
the appropriate places throughout this document.
State and Local Regulations
Other state or local requirements that are different from or more stringent
than the federal requirements may apply. For example, federal law allows EPA
to authorize states to administer their own lead renovation program in place of
the federal lead program. (For a list of authorized states go to
www.epa.gov/lead/pubs/lscp-renovation_firm.htm). Even in states without
an authorized lead renovation program, a state may promulgate its own rules
that may be different or go beyond the federal requirements.
For more information on the rules that apply in your state, please contact the
National Lead Information Center at www.epa.gov/lead/nlic.htm or 1-800-
424-LEAD (5323).
8
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Determine If the Job
Involves Lead-Based Paint
Before you begin a job, consider whether lead-based paint will be an issue.
Find Out the Age of the Home or Child-Occupied Facility.
The age of a home can tell you a lot about whether lead-based paint is likely to
be present.
ฆ If it was built before 1978, it may have lead-based paint.
ฆ The older the home, the greater the likelihood that lead is present in the
paint and accumulated dust.
ฆ Lead-based paint may be found either inside or outside the home and is
most common in kitchens or bathrooms and in high gloss paint on trim,
such as on window sills, door frames, and railings.
Look for Information About Lead.
Information about lead-based paint in your home may be readily available.
Under a federal disclosure law, when a pre-1978 home is sold or leased, the
seller/landlord must provide information to the buyer/tenant about any known
lead-based paint. Homeowners should check their records to see if they have
information about lead-based paint and share this information with anyone
performing work on the home.
9
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Consider Lead Testing.
If a home or child-occupied facility was built before 1978, all surfaces affected
by a renovation covered by the Renovation, Repair and Painting Rule must
either be tested for lead-based paint or presumed to contain lead-based paint.
Testing must include all affected surfaces coated with paint, shellac, varnish,
stain, coating or even paint covered by wallpaper, if it will be disturbed during
the renovation work. A report documenting the testing must describe the test
used, the surfaces tested, and the results of the testing. If lead-based paint is
present on an affected surface, then the lead safe work practices described in
this pamphlet must be used on the job.
There are two options for testing paint under the Renovation, Repair and
Painting Rule:
1. Paint testing by a Certified Lead-based Paint Inspector or Lead-based
Paint Risk AssessorThese licensed professionals conduct a surface-by-
surface investigation for lead-based paint by collecting paint chips for
laboratory analysis or by testing painted surfaces with an machine called
an X-Ray Fluorescence Analyzer (XRF) which measures the amount of
lead in the paint.
2. Paint testing by a Certified RenovatorCertified Renovators, at the
request of the owner, can use EPA-recognized test kits or collect paint
chips for laboratory analysis to test all painted surfaces affected by the
renovation.
Note: HUD does not recognize testing by a Certified Renovator using test kits.
In housing covered by the HUD Lead Safe Housing Rule, only the first option
is allowed.
For a list of certified lead testing professionals in your area, go to
http://cfpub.epa.gov/flpp or contact the National Lead Information Center
at 1 -800-424-LEAD (5323).
Remember, if the home or child-occupied facility was built before 1978 and
there is no information available about the paint, renovators must presume
lead-based paint is present and use the lead safe work practices described in
this pamphlet. Make sure everyone involved on the job, including workers,
supervisors and residents, uses proper safety precautions.
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m
CAUTION
Set It Up Safely
When you work on a job with lead-based paint, you must contain the work
area to prevent the escape of dust and debris. The goal of proper setup of the
work area is to keep dust in the work area and non-workers out.
The work area is the area that may become contaminated during the work. The
size of the work area may vary depending on the method used to disturb lead-
based paint and the amount of dust and debris that is generated as a result.
Whenever lead-based paint is disturbed, the work area must be protected by
plastic sheeting applied to the floor, ground or other applicable surfaces to
prevent contamination of the home or exterior, from dust generated by the
work.
The Renovation, Repair and Painting Rule requires that the work area be
protected by plastic sheeting that extends a minimum of 6 feet for interior
projects and 10 feet for exterior projects in all directions from the location
where paint will be disturbed. For exterior renovations within 10 feet of the
property line, vertical contaiment or equivalent extra precautions are required.
The Rule further requires that protective plastic sheeting extend far enough
from the location of paint disturbance so that all dust or debris generated by
the work remains within the area protected by the plastic. The entire portion
of the home or exterior that is protected by plastic sheeting, however large, is
the work area.
Unauthorized persons and pets must be prevented from entering the work
area. This can be accomplished by posting warning signs and by establishing
barriers around the work area such as barrier tape, fencing, plastic barriers in
doorways, etc.
11
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Shopping List
Here is a list of supplies and tools you will need to set up the work area safely.
These items are available in hardware, paint or garden supply stores.
Materials to Restrict Access and Cover the Floor/Ground
~ Signs
~ Barrier tape, rope or fencing
~ Cones
~ Heavy duty plastic sheeting
~ Tape (masking, duct or painters)
~ Stapler
~ Utility knife or scissors
~ Rigid framing material for vertical containment
What To Do
To keep the dust in and people out of your work area, you must take the steps
below for inside or outside jobs.
Post Signs
You must post signs clearly defining the work area and warning occupants and
other persons not involved in renovation activities to remain outside of the work
area. These signs should be in the primary language of the occupants and should
say "Warning - Lead Work Area" and "Poison, No Smoking or Eating." Also
remember to keep pets out of the work area for their safety and to prevent them
from tracking dust and debris throughout the home.
12
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I
For Inside Jobs
ฆ Remove all objects from the work area, including furniture, rugs, and
window coverings, or cover them with plastic sheeting with all seams and
edges taped or otherwise sealed.
ซ Cover the floor surface, including installed carpet, with taped-down
plastic sheeting in the work area 6 feet from the area of paint distur-
bance or a sufficient distance to contain the dust, whichever is greater. If
a vertical containment system is employed, floor covering may stop at
the verticial barrier, providing it is impermeable, extends from floor to
ceiling, and is tighltly sealed at floors, ceilings, and walls.
Close windows and doors in the work area. Doors must be covered in
plastic sheeting. When the work area
boundary includes a door used to
access the work area it must be covered
in a way that allows workers to pass,
but also confines dust and debris to
the work area. One method is to cover
the door with two layers of protective
sheeting as described here:
Cut and secure one layer of
sheeting to the perimeter of
the door frame. Do not pull the
sheeting taut. Rather, leave slack
at the top and bottom of the door
before taping or stapling.
ซ Cut a vertical slit in the middle of the sheeting leaving 6" uncut at the
top and bottom. Reinforce with tape.
ฆ Cut and secure a second layer of sheeting to the top of the door.
ฆ Close and cover all ducts opening in the work area with taped-down
plastic sheeting.
ฆ Ensure that all personnel, tools, and other items, including the exteriors
of containers of waste, are free of dust and debris before leaving the work
area.
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For Outside Jobs
ฆ Cover the ground with plastic sheeting or other disposable impermeable
material extending 10 feet beyond the perimeter of surfaces undergo-
ing renovation or a sufficient distance to collect falling paint debris,
whichever is greater. If the renovation will affect surfaces within 10
feet of the property line, then vertical containment or equivalent extra
precautions must be erected to prevent contamination of adjacent
buildings and property
ฆ Close all doors and windows within 20 feet of the renovation. On
multi-story buildings, close all doors and windows within 20 feet of the
renovation on the same floor as the renovation, and close all doors and
windows on all floors below that are the same horizontal distance from
the renovation.
ฆ Ensure that doors within the work area that will be used while the job is
being performed are covered with plastic sheeting or other impermeable
material in a manner that allows workers to pass through while confining
dust and debris to the work area.
ฆ In certain situations, the renovation firm must take additional precau-
tions in containing the work area to ensure that dust and debris from the
renovation does not contaminate other buildings or other areas of the
property or migrate to adjacent properties.
ฆ When working on the 2nd story or above, you should extend the
sheeting farther out and to each side where paint is being disturbed.
ฆ It is also a good idea to use vertical containment if work is close to a
sidewalk, street, or property boundary, or the building is more than
three stories high.
ฆ Avoid working in high winds if possible. EPA's rule does not address
wind speed, but when the wind is strong enough to move dust and
debris, precautions need to be taken to keep the work area contained.
That may mean creating a wind screen of plastic at the edge of
the ground-cover plastic to keep dust and debris from migrating.
Ultimately, you are responsible for preventing dust and debris from
leaving the work area, so take appropriate precautions when wind is
a factor or consider rescheduling the renovation for a less windy day.
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Stel)3
L
r ' I JI
S 1
Protect Yourself
f Tl
Workers should protect themselves.
Without the right personal protective equipment, workers may ingest or inhale
lead from the job and may risk bringing lead from the worksite home to their
families. The following items are available through hardware, paint, garden
supply stores or other specialty suppliers.
Shopping List
~ Painters hat
~ Disposable coveralls
~ Disposable N 100 rated respirator
~ Disposable shoe covers
What to Do
Consider wearing:
ฆ Disposable protective clothing covers to limit contamination of your
clothing. They can be stored in a plastic bag and reused if they are fairly
clean and are not torn. Small tears can be repaired with duct tape.
ฆ Disposable shoe covers to prevent the tracking of dust from the work
area and to protect your shoes from exposure to dust.
ฆ A painters hat to protect your head from dust and debris. These are easy
to dispose of at the end of the day.
15
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Respiratory protection.
When work creates dust or paint chips, workers should wear respiratory
protection, such as an N-100 disposable respirator, to prevent them from
breathing leaded dust.
No smoking, drinking or eating in the work area.
You should not eat, drink or smoke in a lead work area because dust and
debris that comes in contact with these items can contaminate them and
cause the ingestion of lead when consumed.
Wash up.
Workers should wash their hands
and faces each time they stop
working. It is especially important
to wash up before eating and at the
end of the day.
Wash your work clothes separately
from family laundry.
Note: OSHA rules may require
employers to take further steps to protect the health of workers on the job.
See www.oslia.gov/SLI C/lead/iiidex.html.
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Minimize the Dust
As you work, your goal is to keep down the dust.
Remember that as you scrape, drill, cut, open walls, etc., you are creating dust.
You can keep dust down by using the right tools and following some simple
practices that minimize and control the spread of dust. The following items
are available through hardware, paint, garden supply stores or other specialty
suppliers.
Shopping List
Materials for all jobs:
~ Wet-dry sandpaper, sanding sponge
~ Misting bottle or pump sprayer
~ Heavy plastic sheeting
~ Utility knife or scissors
~ Masking tape, duct tape, or painters' tape
~ High Efficiency Particulate Air (HEPA) vacuum
~ Heavy duty plastic bags
~ Tack pads (large, sticky pads that help remove dust), paper towels, or
disposable wipes
Other tools that may be needed:
~ Low-temperature heat gun (under 1,100 degrees Fahrenheit)
~ Chemical strippers without methylene chloride
~ Power tools with HEPA filter equipped vacuum attachments
r mfS-"
17
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What To Do
Do Not Use Prohibited Practices.
The Renovation, Repair and Painting Rule prohibits the following dangerous
work practices by contractors:
ฆ Open-flame burning or torching of painted surfaces
ฆ The use of machines designed to remove paint or other surface coatings
through high speed operation such as sanding, grinding, power planing,
needle gun, abrasive blasting, or sandblasting, on painted surfaces unless
such machines have shrouds or containment systems and are equipped
with a HEPA vacuum attachment to collect dust and debris at the point
of generation. Machines must be operated so that no visible dust or
release of air occurs outside the shroud or containment system.
ฆ Operating a heat gun on painted surfaces at temperatures greater than
1,100 degrees Fahrenheit.
Control the spread of dust.
ฆ You must keep the work area closed off from the rest of the home. The
work area must be sufficiently isolated and maintained to prevent the
escape of dust or debris.
ฆ You must ensure that all personnel, tools, and all other items exiting the
work area are free of dust and debris. Don't track dust out of the work
area:
ฆ Vacuum all personnel leaving the work area, pay particular attention
to the soles of shoes. Consider disposable protective clothing and
shoe covers to minimize the contamination of work clothes and
shoes. Also, a large disposable tack pad on the floor can help to
clean the soles of your shoes.
ฆ Vacuum and/or wipe down, as necessary, all tools and other items
exiting the work area.
ฆ You should launder non-disposable protective clothing separately from
family laundry.
18
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Use the right tools.
ฆ You should use wet sanders and misters to keep down the dust created
during sanding, drilling and cutting.
ฆ You must use HEPA vacuum attachments on power sanders and grinders
to contain the dust created by these tools.
ฆ When a heat gun is needed to remove paint or other surface coatings,
you must use a temperature setting below 1,100 degrees Fahrenheit.
Use work practices that minimize dust.
ฆ You should mist areas before sanding, scraping, drilling and cutting to
keep the dust down (except within 1 foot of live electrical outlets).
ฆ You should score paint with a utility knife before separating components.
ฆ You should pry and pull apart components instead of pounding and
hammering.
ฆ You must keep components that are being disposed of in the work area until
they are wrapped securely in heavy plastic sheeting or bagged in heavy duty
plastic bags. Once wrapped or bagged, remove them from the work area and
store them in a safe area away from residents.
In federally-assisted housing, HUD's rule prohibits additional work
practices:
ฆ Extensive dry scraping and sanding by hand.
ฆ Heat guns that char paint.
ฆ Paint stripping in a poorly ventilated space using a volatile paint stripper.
Note: The EPA Renovation, Repair and Painting Rule does not apply to
homeowners who renovate their own property. However, because the practices
prohibited under the rules generate significant amounts of dust, EPA recom-
mends that they be avoided by the do-it-yourself homeowner also.
19
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/
Leave the Work
Area Clean
-i ,
i
11
The work area should be left clean at the end of every day and must be
cleaned thoroughly at the end of the job. The area must be completely free
of dust and debris. The following cleaning supplies, tools, and equipment are
available in hardware, paint or garden supply stores.
Shopping List
~ Heavy-duty plastic bags
~ HEPA vacuum with attachments and a powered beater bar
~ Masking tape, duct tape, or painters tape
~ Misting bottle or pump sprayer
~ Disposable wet-cleaning wipes or hand towels
~ General-purpose cleaner
~ Mop and disposable mop heads
~ Two buckets or one two-sided bucket with a wringer
~ Shovel and rake
~ Wet Mopping System
~ Electrostatically charged dry cleaning cloths
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What To Do
On a daily basis, you should:
ฆ Pick up as you go. Put trash in heavy-duty plastic bags.
ฆ Vacuum the work area with a HEPA vacuum cleaner frequently.
ฆ Clean tools at the end of the day.
ฆ Wash up each time you take a break and before you go home.
ฆ Dispose of or clean off your personal protective equipment.
ฆ Remind residents to stay out of the work area.
When the job is complete, yoa must clean the work area until no dust,
debris or residue remains:
Interior and exterior renovations
ฆ Collect all paint chips and debris and seal in a heavy-duty bag.
ฆ Remove the protective sheeting. Mist the sheeting before folding it dirty
side inward, and either tape shut or seal in heavy-duty bags. Sheeting
used to isolate contaminated rooms from non-contaminated rooms must
remain in place until after the cleaning and removal of other sheeting.
Dispose of the sheeting as waste.
Additional cleaning for interior renovations.
ฆ The firm must clean all objects and surfaces in the work area and within
2 feet of the work area, cleaning from higher to lower:
ฆ Walls. Clean walls with a HEPA vacuum or wiping with a damp cloth.
ฆ Remaining surfaces. Thoroughly vacuum all remaining surfaces and
objects in the work area, including furniture and fixtures, with a HEPA
vacuum. The HEPA vacuum must be equipped with a beater bar when
vacuuming carpets and rugs.
ฆ Wipe all remaining surfaces and objects in the work area, except carpet
or upholstery, with a damp cloth. Mop uncarpeted floors thoroughly.
21
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Step 6
4k
Control
the Waste
Waste from Renovations
ฆ Waste from renovation activities must be contained to prevent releases
of dust and debris before the waste is removed from the work area for
storage or disposal.
ป Collect and control all your waste. This includes dust, debris, paint
chips, protective sheeting, HEPA filters, dirty water, cloths, mop
heads, wipes, protective clothing, respirators, gloves, architectural
components and other waste.
ฆ Use heavy plastic sheeting or bags to collect waste. Seal the bag
securely with duct tape. Consider double bagging waste to prevent
tears. Large components must be wrapped in protective sheeting and
sealed with tape.
ฆฆ Bag and seal all waste before removing it from the work area.
ฆ At the conclusion of each work day and at the conclusion of the renova-
tion, waste that has been collected from renovation activities must be
stored to prevent access to and the release of dust and debris.
ฆ Waste transported from renovation activities must be contained to
prevent release of dust and debris.
22
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Dispose of waste water appropriately.
ฆ Water used for cleanup should be filtered and dumped in a toilet if local
rules allow. If not, collect it in a drum and take it with you. Never dump
this water down a storm drain, or on the ground. Always dispose of waste
water in accordance with federal, state and local regulations.
ฆ EPA's Web site has state information on solid and hazardous waste
disposal. See the following link for further information:
www.epa.gov/epawaste/wyl/stateprograms.htm.
Be aware of waste disposal rules.
ฆ Because EPA considers most residential renovation and remodeling as
"routine residential maintenance," most waste generated during these
activities is classified as solid, non-hazardous waste, and should be taken
to a licensed solid waste landfill. This is not the case for work done in
commercial, public or other nonresidential child-occupied facilities,
where waste may be considered hazardous and require special disposal
methods. See the following link for further information:
www.epa.gov/lead/pubs/fslbp.htm.
ฆ Always check state and local requirements before disposing of waste.
Some are more stringent than federal regulations.
23
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Step 7
T /if r
! ^ L ^ T
Verify Work Completion with the
Cleaning Verification Procedure or
Clearance
When all the work is complete, and before interior space is reoccupied, you
must determine whether it is a safe environment to live in.
To ensure work areas are safe for reoccupancy, cleaning verification is
required by the Renovation, Repair and Painting Rule. If the housing receives
federal assistance, clearance testing is required. When the cleaning verification
procedure is required, an EPA Certified Renovator must perform the cleaning
verification procedure. If clearance is required, a Certified Lead Inspector,
Certified Lead Risk Assessor, or Certified Lead Sampling Technician must
conduct clearance testing.
Cleaning Verification Procedure
After completion of cleaning, the Certified Renovator must visually inspect the
work area to confirm that it is free of dust, debris, or residue.
For exterior projects, when work areas have passed the visual inspection, the
project is complete and the area maybe turned over to the occupants.
For interior projects, when work areas have passed the visual inspection, the
cleaning verification procedure is performed by wiping all dust collection
surfaces in the work area with a wet, disposable cleaning cloth and comparing
that cloth visually to a cleaning verification card. Dust collection surfaces
include window sills, countertops and floors. Cleaning verification cards
are available by calling the National Lead Information Center at 1-800-
424-LEAD (5323). Cleaning verification may only be performed by an EPA
Certified Renovator if renovations covered by the Renovation, Repair and
Painting rule were performed.
24
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The cleaning verification procedure for window sills is described below:
ฆ Each window sill in the work area is wiped by the Certified Renovator
using a single, wet, disposable cleaning cloth.
ฆ Once the entire window sill surface is wiped, the cleaning cloth is
compared to the cleaning verification card. (See "Interpreting the
Cleaning Verification Procedure" on page 26).
The cleaning verification procedure for countertops and floors is described
below:
ฆ Each countertop is wiped by the Certified Renovator using a wet dispos-
able cleaning cloth:
ฆ For smaller countertops and floors with a total surface area less than
40 square feetwipe the entire surface with a single wet disposable
cleaning cloth and compare to the cleaning verification card.
ฆ Large area surfaces, such as large countertops and floors, have surface
areas larger than 40 square feeteach of these large countertops and
floors must be divided into roughly equal sections that are 40 square
feet or less. Wipe each section separately using a new wet dispos-
able cleaning cloth for each separate section. When conducting
cleaning verification on floors, the wet disposable cleaning cloth will
be attached to the handle of a wet mopping system. The use of the
wet mopping system handle allows the Certified Renovator to apply
uniform pressure on the cleaning cloth. Each cleaning cloth is then
compared to the cleaning verification card.
25
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Interpreting the Cleaning Verification
Procedure
ฆ The Certifed Renovator compares each cleaning cloth representing a
specific surface section to the cleaning verification card. If the cleaning
cloth used to wipe a surface section within the work area is cleaner than
the example cleaning cloth on the cleaning verification card, then that
surface section has been adequately cleaned.
ฆ If the cloth is not cleaner than the cleaning verification card, re-clean that
surface section. Then the Certified Renovator uses a new wet disposable
cleaning cloth to wipe the surface section again. If the second cloth is
cleaner than the cleaning verification card, that surface section has been
adequately cleaned.
ฆ If the second cloth is not cleaner than the cleaning verification card, wait
for 1 hour or until the surface section has dried completely, whichever is
longer.
ฆ Then the Certified Renovator wipes the surface section with a dry
electrostatic cleaning cloth. The cleaning verification procedure is now
complete and the surface is considered clean.
ฆ When all of the surfaces in the work area have passed comparison with
the cleaning verification card, or have completed the post-renovation
cleaning verification, the project is complete and the area can be turned
over to occupants unless the housing is receiving federal assistance, or
state or local laws require dust clearance testing, in which case the project
must pass dust clearance testing before the area can be turned over to
occupants.
26
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Dust Clearance Testing
Clearance testing is conducted by Certified Lead-based Paint
Inspectors, Certified Lead-based Paint Risk Assessors, or Certified
Lead Dust Sampling Technicians. For homes receiving federal assis-
tance, the clearance testing must be done by a person independent of
the renovation firm.
ฆ Although optional under the Renovation, Repair and Painting
Rule, some states and localities may require clearance testing. Also,
a homeowner may specifically request that a clearance test be
performed in the contract. In this case, clean up the work area and
check your work, then contact a Certified Lead-based Paint Inspector,
Risk Assessor or Lead Dust Sampling Technician to arrange for
clearance testing.
ฆ HUD requires clearance testing after renovation or repair work in
pre-1978 homes receiving federal assistance, which are regulated
under the Lead Safe Housing Rule. Contractors must determine
whether the home is federally-assisted. Federal assistance may be
channeled through a state or local government, community develop-
ment corporation or other similar entity.
ฆ Clearance sampling for interior jobs will consist of a floor sample
taken in each room where work was performed (to a maximum of
four samples) and an additional sample on the floor outside the entry
to the work area. Where window sills and window troughs were
present in the work area, a window sill or window trough sample will
be collected in each room where work was performed (to a maximum
of four samples).
ฆ All clearance samples must be sent to an EPA-recognized dust-lead
laboratory for analysis. You can view the list of laboratories at
www.epa.gov/lead/pubs/nllap.htm.
-------
Interpret the Clearance Testing Results
The laboratory will report the amount of lead in the dust. A dust sample at or
above the following limits means the area is not safe for reoccupancy:
ฆ Floors: 40 micrograms per square foot
ฆ Window sills: 250 micrograms per square foot
ฆ Window troughs: 400 micrograms per square foot
If the laboratory report shows lead levels at or above these thresholds, the
home fails the dust clearance test. The home must be cleaned and retested
until compliance with these clearance limits is achieved.
If a homowner decides they want dust clearance testing performed, it is a
good idea to specify in the initial contract, before the start of the job, that
that a dust clearance test is to be done and who will do the testing, as well as
whether re-cleaning will be required based on the results of the test. No one
besides the contractor and the person taking the dust samples should enter the
work area until the area has passed the dust clearance test.
28
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] v^i" -~yf
Learn More About Lead
Safety
To learn more about the Renovation, Repair and Painting Rule, and lead safe
work practices, go to www.epa.gov/lead or you may also contact the National
Lead Information Center at 1-800-424-LEAD (5323). The Center is the federal
governments leading source of quality information on lead poisoning preven-
tion and lead hazards.
Take a Course.
Get trained and certified in lead safety. Go to
http://cfpub.epa.gov/flpp/searchrrp_training.htm to find a training provider
in your area accredited by EPA.
Find Out About Local Rules and Resources.
To check whether a state is authorized to administer its own program in lieu
of the EPA Renovation, Repair and Painting Program, and for information on
EPA authorized state programs, visit
www.epa.gov/lead/pubs/lscp-renovation_firm.htm. In addition, the National
Lead Information Center can provide information on how to contact your
state, local and/or tribal programs to get general information about lead
poisoning prevention.
ฆ Local health departments can provide information about local programs,
including assistance for poisoned children.
ฆ State and tribal lead poisoning prevention or environmental protection
programs can provide information about the lead regulations that apply
in your community and can tell you about possible sources of financial
aid for reducing lead hazards. They also may be able to tell you about the
costs and availability of individuals certified to test lead paint and/or lead
dust.
ฆ Building code officials can tell you the regulations that apply to the
renovation and remodeling work that you are planning.
29
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Access Additional Resource Materials.
EPA's website provides the following general reference and how-to guidance
materials:
ฆ The Lead-Safe Certified Guide to Renovate Right: Important Lead
Hazard Information for Families, Child Care Providers and Schools
(EPA-740-K-10-001, Revised September 2011).
www.epa.gov/lead/pubs/renovaterightbrochure.pdf
ฆ Small Entity Compliance Guide to Renovate Right: A Llandbook for
Contractors, Property Managers and Maintenance Personnel Working in
Homes, Child Care Facilities and Schools Built Before 1978. (EPA-740-K-
10-003, Revised September 2011).
www.epa.gov/lead/pubs/sbcomplianceguide.pdf
ฆ Protect Your Family from Lead in Your Home (EPA 747-K-99-001,
Revised June 2003). This is a general information pamphlet on lead-
based paint, lead hazards, the effects of lead poisoning and steps you can
take to protect your family www.epa.gov/lead/pubs/leadpdfe.pdf
ฆ For a copy of these materials you may also contact the National Lead
Information Center at www.epa.gov/lead/nlic.htm or call 1-800-424-
LEAD (5323).
30
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Other Resources
For other resources on lead, visit the following Web sites:
www.epa.gov/lead/ EPA is playing a major role in addressing residential
lead hazards, including those associated with lead-based paint, lead contami-
nated dust and lead contaminated residential soil. This Web site provides
information about lead and lead hazards and provides some simple steps to
protect your family. It contains links to basic information, as well as more
detailed information and documents on lead in the news, rules and regula-
tions, education and outreach materials, training, and other lead links.
www.hud.gov/offices/lead/ The Department of Housing and Urban
Development (HUD) provides funds to state and local governments to develop
cost-effective ways to reduce lead-based paint hazards in Americas privately-
owned low-income housing. In addition, the office enforces HUD lead
regulations, provides public outreach and technical assistance, and conducts
technical studies to help protect children and their families from health and
safety hazards in the home. The site will direct you to resources on lead paint
regulations, training, guidance/technical guidelines and compliance and
enforcement.
www.osha.gov/SLTC/lead/index.html The mission of the U.S. Department
of Labors Occupational Safety and Health Administration (OSHA) is to assure
the safety and health of Americas workers by: setting and enforcing standards;
providing training, outreach, and education; establishing partnerships; and
encouraging continual improvements in workplace safety and health. OSHA
has established the reduction of lead exposure as a high strategic priority. This
site contains links to lead recognition, evaluation, compliance, and training
resources.
www.cdc.gov/lead The U.S. Department of Health and Human Services
Centers for Disease Control and Prevention (CDC) are committed to
achieving improvements in peoples health. This site provides CDC's compiled
information on lead and includes materials and links for parents, health
professionals, researchers, students and others interested in the topic of lead.
The key resources include fact sheets, guidelines and recommendations and
questions and answers.
31
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Pre-Renovation Education
Requirements
The pre- renovation education requirements of the Renovation, Repair and
Painting Rule ensure that owners and occupants of pre-1978 homes and child-
occupied facilities are provided information about potential hazards of lead-
based paint exposure before renovations are begun.
Who is affected? The requirements apply to any person paid to do work that
disturbs paint in residential housing or child-occupied facilities built before
1978. This includes residential rental property owners and managers, general
contractors and special trade contractors such as painters, plumbers, carpen-
ters and electricians.
What properties are affected? All residential properties and
child-occupied facilities built before 1978 are affected unless they meet one of
the exceptions listed below.
Are there any exceptions? The requirements do not apply to housing desig-
nated for elderly or disabled persons (unless children under age 6 live there),
zero-bedroom dwellings (studio apartments, dormitories, etc.), housing
determined to be free of lead-based paint by a lead-based paint inspection,
emergency renovations and repairs, and minor repairs that disturb 6 square
feet or less of paint on interior surfaces or 20 square feet or less of paint on
exterior surfaces. The minor repair exemption does not apply to projects
involving demolition, window replacement, or involve the use of any of the
practices prohibited by the Renovation, Repair and Painting rule.
What are the requirements? The Renovation, Repair and Painting Rule
requires the distribution of the lead pamphlet The Lead-Safe Certified Guide
to Renovate Right: Important Lead Hazard Information for Families, Child
Care Providers and Schools before the work starts.
ฆ In housing built before 1978, you must:
ฆ Distribute EPA's lead pamphlet to the owner and occupants before
renovation starts.
ฆฆ In a child-occupied facility, you must:
ฆ Distribute the lead pamphlet to the owner of the building and an
adult representative of the child-occupied facility before the renova-
tion starts.
ฆ Either distribute renovation notices to parents/guardians of the
children attending the child-occupied facility, or post informational
signs about the renovation or repair job.
-------
ฆ For work in common areas of multi-family housing, you must:
ป Either distribute renovation notices to tenants or you must post
informational signs about the renovation or repair job.
ฆ Obtain confirmation of receipt of the lead pamphlet from the owner or
a certificate of mailing from the post office.
ซ Obtain confirmation of receipt of the lead pamphlet from the housing
occupants or the adult representative of the child-occupied facility or a
certificate of mailing from the post office. For these persons, you may
also certify in writing that you delivered the lead pamphlet but were
unable to obtain written confirmation.
ฆ Retain records for three years.
How do I get the pamphlet? You can download the pamphlet from EPA's
website at www.epa.gov/lead/pubs/brocliure.htm. Single copies of the
pamphlet are available from the National Lead Information Center
at 1-800-424-LEAD (5323). Ask for the Lead-Safe Certified Guide to
Renovate Right: Important Lead Hazard Information for Families, Child Care
Providers, and Schools pamphlet. For multiple copies you may do the fol-
lowing:
1. Call the Government Printing Office
(GPO) Order Desk at (202) 512-1800.
2. Order from the GPO Bookstore
at h ttp: //b o okstor e. gpo.gov/environ ment.
3. Request copies in writing from:
U.S. GPO
P.O. Box 979050
St. Louis, MO 63197-9000
Note: In federally-assisted housing, HUD requires notification to be dis-
tributed to occupants within 15 days after lead-based paint or lead-based
paint hazards are identified in their unit (or common areas, if applicable),
and within 15 days after completion of hazard control work in their unit or
common areas.
33
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Prevent Lead Exposure During Renovation,
Repair, and Painting
L A Understand that Renovation, Repair and Painting Jobs Can Create
^ Hazards. People, especially children, may swallow the lead dust or paint
chips created during the job and get poisoned. Lead poisoning has serious health
effects.
Read EPA and HUD's Lead Hazard Information Pamphlet The
Lead-Safe Certified Guide to Renovate Right Important Information for
Families, Child Care Providers and Schools. Contractors are required by law to
give clients in pre 1978 homes and child-occupied facilities a copy of this
pamphlet. The pamphlet explains the hazards associated with lead-based paint.
You can get copies of the pamphlet by calling 1-800-424-LEAD (5323) or you can
download it at
www.epa.gov/lead/pubs/renovaterightbrochure.pdf.
14 Use Lead-Safe Work Practices. Follow practices that will protect you and
residents from exposure to lead. These practices may take a small amount of
additional time and money, but they are necessary to protect children, residents,
workers and workers' families from exposure to lead dust.
L A Conduct Lead Testing Before and/or After the Work is Performed.
^ Pre-job testing can identify any lead paint in the home and allow workers to
target lead safe work practices to the areas where there is lead paint. Using the
cleaning verification procedure or clearance testing at the end of the job ensures
that no dust has been left behind.
I A Learn More About Lead. To learn more about working safely with lead,
visit EPA's Web site at wvw.epa.gov/lead or HUDs Web site at
www.liud.gov/offices/lead. You may also contact the National Lead Information
Center at 1-800-424-LEAD (5323)
October 2011, EPA-740rK-l 1 -001
U.S. Environmental Protection Agency, Office of Chemical Safety and Pollution Prevention
U.S. Dept. of Housing and Urban Development, Office of Healthy Homes and Lead Hazard Control
Printed with Vegetable Oil-Based Inks, Recycled Paper
-------
Appendix 6:
Hands-on Exercises
-------
LEAD SAFETY for Remodeling, Repair and Painting
Appendix 6: Hands-on Exercises
The following exercises can be used in place of the hands-on exercises or as supplemental activities.
Exercise worksheets and answers are provided.
Skill Set #1: Using EPA-Recognized Test Kits and Paint Chip Sample Collection
Procedure
Skill Set #2: Cleaning Verification Procedure
Recommended Supplies for Hands-on Activities
Test Kits Supplies List
Disposable plastic drop cloth 2' by 2'
Disposable shoe covers
Disposable wet cleaning wipes
Disposable, non-latex gloves
HEPA vacuum with attachments (for cleanup after sampling)
EPA-recognized test kit(s) w/ manufacturer's instructions
Heavy duty garbage bags
Kit-specific supplies as required in the manufacturer's instructions
Manufacturer provided test verification card with lead-based paint layer
Painted wood surface with no lead-based paint layer
Participant Progress Log
Pen or pencil
Tape (duct, painters, and masking)
Test Kit Documentation Form
Digital camera (Optional)
Numbered index cards (Optional)
Paint Chip Sample Collection Supplies List
Resealable Rigid Walled Container, for use as paint collection containers, e.g. screw-top
plastic
centrifuge tube
Steel or Plastic Measuring Ruler-Metric Only
Cloths
White Paper
Indelible Marking Pen
Personal Safety Gear
Cutting and Scraping Tools
Flashlight
Trash bags
Plastic Gloves
Paint Chip Sample Collection Form
Painted wood surface
Hands-on Exercises
October 2011
A6-1
-------
LEAD SAFETY for Remodeling, Repair and Painting
Recommended Supplies for Hands-on Activities - Continued
Cleaning Verification Procedure Supplies List
Baby powder or corn starch
Cleaning verification card, one per student to take away and retain
Disposable foot covers
Disposable non-latex gloves
Disposable wet cleaning wipes
Electrostatically charged, white, disposable cleaning cloths designed for cleaning hard
surfaces
Flashlight
Long-handled mop designed for wet cleaning wipes
Tape measure
Watch or clock
Hands-on Exercises
October 2011
A6-2
-------
LEAD SAFETY for Remodeling, Repair and Painting
Participant Progress Log:
Module 3
(25 Min)
Module 6
(15 Min)
Name of Trainee
Skill Set 1: Using
EPA-Recognized Test
Kits and Paint Chip Sample Collection
Procedure
Skill Set 2: Cleaning
Verification Procedure
Date of Training:
Certified Renovator Name:
Hands-on Exercises October 2011 A6-3
-------
LEAD SAFETY for Remodeling, Repair and Painting
Certified Renovator Training Hands-On Skills Assessment
Date: Address: City & State
Student Name: Student Signature:
Skill
Set
Skill
Description
Student has demonstrated proficiency at the following skills
consistent with the requirements of the EPA RRP Rule.
Trainer's
Initials
#1
Using EPA
Recognized
Test Kits and
Paint Chip
Sample
Collection
Procedure
Using test kits and collecting paint chip samples for laboratory
lead analysis to properly test for lead-based paint and document
results.
#2
Cleaning
Verification
Procedure
Conducting cleaning verification procedure.
I am the trainer for the Certified Renovator course offered on the date and location described
above. I verify that the student has demonstrated the skills as described above.
Trainer Name: Trainer Signature:
Trainer Phone: Organization: Date:
Hands-on Exercises
October 2011
A6-4
-------
LEAD SAFETY for Remodeling, Repair and Painting
Skill Set #1: Using EPA-Recognized Test Kits and Collecting Paint Chip Samples for
Laboratory Lead Analysis
Time: 25 minutes
October 2011
Test Kit Supplies needed:
EPA-recognized test kit(s) w/ manufacturer's instructions
Kit-specific supplies as required in the manufacturer's instructions
Disposable plastic drop cloth 2' by 2'
Tape (duct, painters, and masking)
Disposable, non-latex gloves
Disposable shoe covers
Manufacturer provided test verification card with lead-based paint layer
Disposable wet cleaning wipes
Heavy duty garbage bags
Painted wood surface with no lead-based paint layer
Test Kit Documentation Form
Participant Progress Log
Pen or pencil
Digital camera (Optional)
Numbered index cards (Optional)
EPA vacuum with attachments (for cleanup after sampling)
Paint Chip Sample Collection Supplies needed:
Resealable Rigid Walled Container, for use as paint collection containers, e.g. screw-top
plastic centrifuge tube
Steel or Plastic Measuring Ruler-Metric Only
Cloths
White Paper
Indelible Marking Pen
Personal Safety Gear
Cutting and Scraping Tools
Flashlight
Plastic gloves
Painted wood surface
Trash bags
Paint Chip Sample Collection Form
Note to Instructor: It is strongly suggested that instructors prepare plastic bags
containing all materials needed for the hands-on exercises, prior to the exercise, in
order to meet the time limits allocated to Skill Set #1.
Purpose: The purpose of this hands-on exercise is to teach students how to correctly
use EPA-recognized test kits to determine if lead-based paint is present on components
and surfaces affected by renovation work. In addition, students will learn an alternative method
for determining the presence of lead-based paint by collecting paint chip samples that are
submitted to a NLLAP-recognized laboratory for analysis.
Hands-on Exercises
October 2011
A6-5
-------
LEAD SAFETY for Remodeling, Repair and Painting
Note to Instructor: Read the purpose of this activity to students and remind them to
document all areas where the paint color or substrate reactions may cause an
incorrect result. These surfaces should not be tested with a test kit, but should either
be tested by Certified Inspectors or Certified Risk Assessors; or must be assumed to
contain lead-based paint.
Demonstration: The course instructor must show and explain all of the steps involved in
the use of EPA-recognized test kits as well as the collection of paint chip samples for lead
analysis. The demonstration should not take longer than 5 minutes for each method including
the time needed to hand out materials.
Evaluating the Students: Allow students to practice the required steps on the following
pages. Watch each student follow the steps. Make corrections and suggestions as the
exercise proceeds and determine if additional practice is necessary. This should take no
longer than 10 minutes. Students must complete all required steps to be "Proficient".
Evaluate the work of each student and once the student can use a test kit and sample paint
chips correctly, the instructor should write the word "Proficient" in the field on the Participant
Progress Log that corresponds to Skills Set #1 and that particular student's name.
Hands-on Exercises
October 2011
A6-6
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LEAD SAFETY for Remodeling, Repair and Painting
Skill Set #1: Using EPA-Recognized Test Kits and Collecting Paint Chip Samples -
Continued
Skills Practice:
Test Kit Procedure
Step 1: Read the manufacturer's instructions
Step 2: Write required information and observations about the test location on the Test
Kit Documentation Form*
Step 3: (Optional) Secure a small disposable plastic drop cloth (2ft x 2 ft) on the floor
beneath the test location with masking tape.
Step 4: Put on disposable non-latex gloves and shoe covers.
Step 5: Follow the manufacturer's instructions for use of the test kit to conduct the
test.* If possible, perform one test where a positive test result can be observed;
and conduct one test of a painted wood surface with no lead-based paint layer
to observe a negative test result.*
Step 6: Use one wet cleaning wipe to remove residual chemicals left on the surface
tested. Use a second cleaning wipe to remove any visible debris or dust on the
floor beneath the sample collection area and place the used cleaning wipe in
the trash bag*
Step 7: Check documentation for completeness and note the result of the testing on
the Test Kit Documentation Form*
Step 8: (Optional) Number the test location in sequence on the Test Kit Documentation
Form, then select the corresponding numbered index card and tape it next to
the test location with masking tape and take a picture of the numbered test
location to photo-document conduct and possibly the result of the test.
indicates required skills that must be accomplished for a "Proficient" rating.
Interpreting the Results of Test Kit Sampling:
The manufacturer's instructions will indicate how to determine the absence of lead
in paint. Once the test is conducted, note the result and refer to the manufacturer's
guidelines for interpreting the result. All painted surfaces where lead is not determined
to be absent must be treated as lead-based paint until additional testing performed
by a Certified Lead Inspector or Risk Assessor proves it is not.
Documenting Test Kit Results:
A report of the findings from use of the test kit must be submitted to the person
contracting the work within 30 days following the completion of the renovation work. The
completed Test Kit Documentation Form should be kept by the Certified Firm for 3 years
after the work is completed.
Hands-on Exercises
October 2011
A6-7
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LEAD SAFETY for Remodeling, Repair and Painting
Test Kit Documentation Form Page 1 of
Owner Information
Name of Owner/Occupant:
Address:
City: State: Zip code: Contact #: ( )
Email:
Renovation Information
Fill out all of the following information that is available about the Renovation Site, Firm, and
Certified Renovator.
Renovation Address:
Unit#
Citv: State:
Zip code:
Certified Firm Name:
Address:
Citv: State:
Zip code: Contact #: ( )
Email:
Certified Renovator Name:
Date Certified: / /
Test Kit Information
Use the following blanks to identify the test kit or test kits used in testing components.
Test Kit #1
Manufacturer: Manufacture Date:
/ /
Model:
Serial #:
Expiration Date:
Test Kit #2
Manufacturer:
Manufacture Date:
/ /
Model:
Serial #:
Expiration Date:
Test Kit #3
Manufacturer:
Manufacture Date:
/ /
Model:
Serial #:
Expiration Date:
Hands-on Exercises
October 2011
A6-8
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LEAD SAFETY for Remodeling, Repair and Painting
Test Kit Documentation Form
Page of
Renovation Address: Unit#.
City: State: Zip code:
Test Location # Test Kit Used: (Circle only one) Test Kit #1 Test Kit #2 Test Kit #3
Description of component tested including location:
Result: Is lead present? (Circle only one) YES NO Presumed
Test Location # Test Kit Used: (Circle only one) Test Kit #1 Test Kit #2 Test Kit #3
Description of component tested including location:
Result: Is lead present? (Circle only one) YES NO Presumed
Test Location # Test Kit Used: (Circle only one) Test Kit #1 Test Kit #2 Test Kit #3
Description of component tested including location:
Result: Is lead present? (Circle only one) YES NO Presumed
Test Location # Test Kit Used: (Circle only one) Test Kit #1 Test Kit #2 Test Kit #3
Description of component tested including location:
Result: Is lead present? (Circle only one) YES NO Presumed
Test Location # Test Kit Used: (Circle onlv one) Test Kit # 1
Description of component tested including location:
Test Kit # 2
Test Kit # 3
Result: Is lead present? (Circle only one)
YES
NO
Presumed
Test Location # Test Kit Used: (Circle onlv one)
Description of component tested including location:
Test Kit # 1
Test Kit # 2
Test Kit # 3
Result: Is lead present? (Circle only one)
YES
NO
Presumed
Test Location # Test Kit Used: (Circle onlv one)
Description of component tested including location:
Test Kit # 1
Test Kit # 2
Test Kit # 3
Result: Is lead present? (Circle only one)
YES
NO
Presumed
Hands-on Exercises
October 2011
A6-9
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LEAD SAFETY for Remodeling, Repair and Painting
Skill Set #1: Using EPA-Recognized Test Kits and Collecting Paint Chip Samples -
Continued
Skills Practice:
Paint Chip Collection Procedure
Step 1: Read Paint Chip Sample Collection Guide (see Appendix 9) Step 2: Write
required information and observations about the test location on the Paint Chip
Sample Collection Form.
Step 3: Mark the Collection Area either using a template or freehand.
Step 4: Set up a paint collection tray using a sheet of letter-sized white paper for making
a paper funnel for paint sample collection.
Step 5: Remove the paint using a cold scraping method (see step 5-1 below). Don plastic
gloves as appropriate
Step 5-1: Cold Scraping Method. Using the appropriate cutting tool, begin removing the
paint from the substrate. Carefully scrape away all paint within the marked area
down to the substrate and ensure that all the scraped paint lands in or is pushed
into the paint collection tray
Step 6: Cleaning all cutting tools used during paint sample collection.
Step 7: Check documentation for completeness on the Paint Chip Sample Collection
Form
Step 8: Transfer the Collected Sample to the Paint Collection Container.
Step 9: Label the container with sufficient information to uniquely identify the sample. Be
sure to record the dimensions of the sample surface, including the measurement
units.
Step 10: Submit the paint chip sample for lead analysis to a NLI_AP-recognized laboratory.
Record all results reported from the laboratory.
Documenting Paint Chip Sample Lead Analysis Results:
A report of the findings from the submitted paint chip samples to a NLLAP-recognized entity
must be given to the person contracting the work within 30 days following the completion of the
renovation work. The Certified Firm should keep the completed Paint Chip Sample Collection
Form for 3 years after the work is completed.
Hands-on Exercises
October 2011
A6-10
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LEAD SAFETY for Remodeling, Repair and Painting
Paint Chip Sample Collection Form Page 1 of
Client/Project Information
Name of Owner/Proiect:
Address:
Citv:
State:
Zip code:
Contact # ( )
Email:
Renovation Information
Fill out all of the following information that is available about the Renovation Site, Firm and Certified
Renovator.
Renovation Address: Unit #:
City: State: Zip code:
Certified Firm Name:
Address:
City: State: Zip code: Contact #: ( ) -
Email:
Certified Renovator Name:
Date Certified / /
Paint Chip Sample Information
For each sample collected, fill out all of the following information
Sample Identifier:
Sample Collector Name:
Sampling Location:
Sampling site description:
Sample Dimensions (cm):
NLLAP-recognized entity and location
Submission date: / / Results: Result Date: / /
Date of Collection: / /
Calculate Sample Area (cm2) :
Hands-on Exercises
October 2011
A6-11
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LEAD SAFETY for Remodeling, Repair and Painting
Paint Chip Sample Collection Form
Page of
Renovation Address:
City:
State:
Zip code:
Unit #:
For each sample collected, fill out all of the following information
Sample Identifier:
Sample Collector Name:
Sampling Location:
Sampling site description:.
Sample Dimensions (cm):
Date of Collection: / /
_Calculate Sample Area (cm ):_
NLLAP-recognized entity and location:
Submission date: / / Results:
Result Date: /
For each sample collected, fill out all of the following information
Sample Identifier:
Sample Collector Name:
Sampling Location:
Sampling site description:.
Sample Dimensions (cm):
Date of Collection: /
_Calculate Sample Area (cm2):
NLLAP-recognized entity and location:
Submission date: / / Results:
Result Date:
/ /
Hands-on Exercises
October 2011
A6-12
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LEAD SAFETY for Remodeling, Repair and Painting
Skill Set #2: Cleaning Verification Procedure
Time: 15 minutes
October 2011
Supplies needed:
Baby powder or corn starch
Disposable foot covers
Flashlight
Disposable non-latex gloves
Disposable wet cleaning wipes
Cleaning verification card, one per student to take away and retain
Electrostatically charged, white, disposable cleaning cloths designed for cleaning
hard surfaces
Long-handled mop designed for wet cleaning wipes
Tape measure
Watch or clock
Purpose: The purpose of this hands-on exercise is to show the students the proper
steps for conducting the cleaning verification procedure.
The course instructor should explain all of the steps involved in performing the
cleaning verification procedure.
Evaluating the Students: Watch each student conduct the cleaning verification
procedure and listen as they point out problems that must be fixed. Students must
complete all required steps to be "Proficient". Evaluate the work of each student and
once the student has completed all required elements of the exercise correctly, record
the performance as "Proficient" in the field on the Participant Progress Log that
corresponds to Skills Set #2 and that particular student's name.
Hands-on Exercises
October 2011
A6-13
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LEAD SAFETY for Remodeling, Repair and Painting
Skill Set #2: Cleaning Verification Procedure - Continued
Skills Practice:
Step 1: As you enter the work area put on disposable foot covers so that you do not
track dust and debris into the work area.*
Step 2: Turn on all of the lights that are available in the work area. Make sure there is
adequate lighting.*
For window sills:
Step 3: While wearing gloves, wipe each window sill in the work area with a clean,
white, damp cleaning wipe.*
Step 4: Compare the cleaning wipe to the cleaning verification card. If the first wipe is
the same as or whiter (lighter) than the cleaning verification card, the window
sill is clean; continue to Step 6. If the first cleaning wipe is not the same as or
whiter (lighter) than the cleaning verification card, re-clean the window sill,
and, repeat Step 3 and then proceed to Step 5 (skip this step).*
Step 5: Compare the second cleaning wipe to the cleaning verification card. If the
second wipe is the same as or whiter (lighter) than the cleaning verification
card, the window sill is clean; continue to Step 6. If the second cleaning wipe
is not the same as and not whiter (not lighter) than the cleaning verification
card, wait one hour or until the wet surface is dry (for the purposes of this
exercise you do not wait). Then re-clean the surface with a dry,
electrostatically charged, white, disposable cleaning cloth designed for use
on hard surfaces. The window sill is now clean and has completed the
cleaning verification procedure.*
For Floors and Countertops:
Step 6: While wearing gloves, wipe each floor or countertop in the work area with a
clean, white, damp cleaning wipe. For floors, use a long handled mop
designed to hold a wet cleaning wipe. For floors, wipe no more than 40
square feet per wipe. For countertops wipe the whole surface of the
countertop up to 40 square feet per wipe.*
Step 7: Compare each floor and countertop cleaning wipe to the cleaning verification
card. If the first wipe is the same as or whiter (lighter) than the cleaning
verification card, the floor or countertop is clean. If the first cleaning wipe is
not the same as and not whiter (not lighter) than the cleaning verification
card, re-clean the floor section or countertop section, wipe the floor or
countertop section with a wet cleaning wipe, and repeat Step 6 for that
section and proceed to Step 8 (skip this step).*
Hands-on Exercises
October 2011
A6-
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LEAD SAFETY for Remodeling, Repair and Painting
Step 8: Compare the second floor or countertop cleaning wipe to the cleaning
verification card. If the second wipe is the same as or whiter (lighter) than the
cleaning verification card, the floor or countertop section has been adequately
cleaned. If the second cleaning wipe is not the same as and not whiter (not
lighter) than the cleaning verification card, wait one hour or until the wet
surface is dry (for the purposes of this exercise you do not wait). Then reclean
the surface with a dry, electrostatically charged, white, disposable
cleaning cloth designed for use on hard surfaces. The floor or countertop
section is now clean and has completed the cleaning verification procedure.*
Step 9: Once the cleaning verification shows that all areas have been
adequately cleaned, remove the signs and critical barriers around the
work area.*
indicates required skills that must be accomplished for a "Proficient" rating
Hands-on Exercises
October 2011
A6-15
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Appendix 7:
State and Local Regulations
(Note: This Appendix is intentionally blank to allow training providers to add applicable
state and local regulations.)
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Appendix 7
State and Local Regulations
Appendix 7 is reserved for state and local regulations that apply to the Certified
Renovator and the Certified Firm. Instructors must determine what additional state and
local regulations apply to renovation work and include that information in Appendix 7.
Provide copies or summaries of applicable state and local regulations, web links and/or
copies of important pages, contact lists, training materials such as slides, brochures and
pamphlets, etc.
October 2011
A7-1
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Appendix 8:
Regulatory Status of Waste Generated by
Contractors and Residents from Lead-
Based Paint Activities Conducted in
Housing
-------
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 flhousehold wasteฎ 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 flail LBP waste generated as a
result of actions by residents of households (hereinafter referred to as "residents") to renovate,
remodel or abate their homes on their own.ฎ 63 FR 70233, 70241 (Dec. 18, 1998). In this
memorandum, EPA is explaining that we believe lead paint debris generated by contractors in
households is also "household waste" and thus excluded from the RCRA Subtitle C hazardous
waste regulations. Thus, the household exclusion applies to waste generated by either residents or
contractors conducting LBP activities in residences.
What is the practical significance of classifying LBP waste as a household waste?
As a result of this clarification, contractors may dispose of hazardous-LBP wastes from residential
lead paint abatements as household garbage subject to applicable State regulations. This practice
will simplify many lead abatement activities and reduce their costs. In this way, the clarification
in today's memorandum will facilitate additional residential abatement, renovation and
remodeling, and rehabilitation activities, thus protecting children from continued exposure to lead
paint in homes and making residential dwellings lead safe for children and adults.
1
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LBP debris (such as architectural building components doors, window frames, painted wood
work) that do not exhibit the TC for lead need not be managed as hazardous waste. However, LBP
waste such as debris, paint chips, dust, and sludges generated from abatement and deleading
activities that exhibit the TC for lead (that is, exceed the TC regulatory limit of 5 mg/L lead in the
waste leachate), are hazardous wastes and must be managed and disposed of in accordance with
the applicable RCRA subtitle C requirements (including land disposal restrictions) except when it
is "household waste." Under 40 CFR 261.4(b)(1), household wastes are excluded from the
hazardous waste management requirements. Today, EPA is clarifying that waste generated as part
of LBP activities conducted at residences (which include single family homes, apartment
buildings, public housing, and military barracks) is also household waste, that such wastes are no
longer hazardous wastes and that such wastes thus are excluded from RCRA's hazardous waste
management and disposal regulations. Generators of residential LBP waste do not have to make a
RCRA hazardous waste determination. This interpretation holds regardless of whether the waste
exhibits the toxicity characteristic or whether the LBP activities were performed by the residents
themselves or by a contractor.
Where can I dispose of my household LBP waste?
LBP waste from residences can be discarded in a municipal solid waste landfill (MSWLF) or a
municipal solid waste combustor. Dumping and open burning of residential LBP waste is not
allowed. Certain LBP waste (such as large quantities of concentrated lead paint waste paint
chips, dust, or sludges) from residential deleading activities may be subject to more stringent
requirements of State, local, and/or tribal authorities.
What is the basis for this interpretation?
The household waste exclusion implements Congress's intent that the hazardous waste regulations
are "not to be used either to control the disposal of substances used in households or to extend
control over general municipal wastes based on the presence of such substances." S. Rep. No. 94-
988, 94th Cong., 2nd Sess., at 16. EPA regulations define "household waste" to include "any
waste material (including garbage, trash, and sanitary wastes in septic tanks) derived from
households (including single and multiple residences, hotels and motels, bunkhouses, ranger
stations, crew quarters, campgrounds, picnic grounds and day-use recreation areas)." 40 CFR
261.4(b)(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.
2
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EPA clarifies that this interpretation also applies to contractor-generated LBP waste from
renovations, remodeling and abatements in residences. Both the definition of household waste in
section 261.4(b)(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 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 ง3007 (inspection) and ง7003 (imminent hazard). See 40 CFR
ง261.1(b).
What are the "best management practices" for handling residential LBP waste?
' 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 flEPA Hotline Reportฎ (RCRA Question 6) that lead paint chips and dust resulting from
stripping and re-painting of residential walls by homeowner or contractors (as part of routine household
maintenance) would be part of the household waste stream and not subject to RCRA Subtitle C regulations.
Similarly, in a March 1995 memorandum on the AApplicability of the Household Waste Exclusion to Lead-
Contaminated Soils,ฎ we found that if the source of the lead contamination was as a result of either routine
residential maintenance or the weathering or chalking of lead-based paint from the residence, the hazardous waste
regulations do not apply so long as the lead-contaminated soil is managed onsite or disposed offsite according to
applicable solid waste regulations and/or State law mandated by RCRA.
3
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Although excluded from the hazardous waste regulations, EPA encourages residents and
contractors managing LBP waste from households to take common sense measures to minimize the
generation of lead dust, limit access to stored LBP wastes including debris, and maintain the
integrity of waste packaging material during transfer of LBP waste. In particular, we continue to
endorse the basic steps outlined in the 1998 proposals for the proper handling and disposal of LBP
waste (63 FR 70242) as the best management practices (BMPs) including:
Collect paint chips and dust, and dirt and rubble in plastic trash bags for disposal.
Store larger LBP architectural debris pieces in containers until ready for disposal.
Consider using a covered mobile dumpster (such as a roll-off container) for storage of LBP
debris until the job is done.
Contact local municipalities or county solid waste offices to determine where and how
LBP debris can be disposed.
In addition, contractors working in residential dwellings are subject to either one or both of the
following:
The HUD Guidance for contractors doing publically-funded rehabilitation/renovation
projects in public housing. (See Guidelines for the Evaluation and Control of Lead-Based
Paint Hazards in Housing. U.S. Department of Housing and Urban Development, June
1995) The HUD guidelines can be accessed via the Internet at:
http://www.hud.gov/lea/learules.html
TSCA 402/404 training and certification requirements. (See 40 CFR Part 745; 61 FR
45778, August 29, 1996) and the proposed TSCA onsite management standards (See 40
CFR Part 745, Subpart P; 63 FR 70227 - 70230, Dec. 18, 1998). [EPA expects to issue the
final rule next year.]
The above-mentioned BMPs for households are similar to those included in the HUD Guidelines
for individuals controlling LBP hazards in housing. HUD requires that contractors using HUD
funding adhere to LBP hazard control guidelines. Non-adherence to these guidelines can
potentially result in the loss of funding.
Does this interpretation apply in my State and/or locality?
We encourage contractors and residents to contact their state, local and/or tribal government to
determine whether any restrictions apply to the disposal of residential LBP waste. This
verification is necessary since, under RCRA, States, local and tribal governments can enforce
regulations that are more stringent or broader in scope than the federal requirements. Thus, under
such circumstances, LBP waste from households may still be regulated as a hazardous waste as a
matter of State regulations.
We are distributing this memorandum to all 56 States and Territories, and Tribal Programs and
various trade associations. We encourage States to arrange for implementation of the
4
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interpretation discussed in this memo in their States to facilitate residential LBP abatements
making residential dwellings lead-safe. We encourage trade associations to inform their
memberships about this memo and instruct them about ways to manage residential LBP waste.
Whom should I contact for more information?
If you have additional questions concerning the regulatory status of waste generated from lead-
based paint activities in residences, please contact Ms. Rajani D. Joglekar of my staff at 703/308-
8806 or Mr. Malcolm Woolf of the EPA General Counsel's Office at 202/564-5526.
cc: Key RCRA Contacts, Regions 1-10
RCRA Regional Council Contacts, Regions 1-10
RCRA Enforcement Council Contacts, Regions 1-10
Association of State and Territorial Solid Waste Management Officials ( ASTSWMO)
5
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Appendix 9:
Paint Chip Sample Collection Guide
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Paint Chip Sample Collection Guide
Lead Renovation, Repair and Painting Program - October 2011
What is the Paint Chip Sample Collection Guide?
This document, the Paint Chip Sample Collection Guide, provides step-by-step instruction in how to
collect paint chip samples and submit them for analysis to a laboratory recognized by the National Lead
Laboratory Accreditation Program (NLLAP).
Whom does this guide apply to?
This guide applies to Certified Renovators who want to use paint chip sampling to determine whether
lead-based paint is present on components to be disturbed during a renovation.
When is it appropriate to use this guide?
EPA's Renovation, Repair, and Painting (RRP) Rule covers renovations in target housing and child-
occupied facilities built before 1978. The RRP rule does not require any paint testing. However, many
provisions of the RRP rule do not apply to renovations where a Certified Renovator determines that the
components that will be disturbed by the renovation are free of lead-based paint. Certified Renovators
must make this determination for each component either by using an EPA-recognized test kit or by
collecting a paint chip sample and submitting it to an NLLAP laboratory for analysis. Certified
Renovators should use this guide as they collect and submit paint chip samples for this purpose.
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Paint Chip Sample Collection Guide
October 2011
Recommended Materials and Equipment
Resealable rigid walled container for use as paint chip sample collection containers, e.g. screw-top
plastic centrifuge tube
Note: Resealable plastic bags are not suitable for holding and transporting dried paint chip samples
due to potential losses of paint chips during laboratory handling.
Steel or plastic measuring ruler - metric only with millimeter and centimeter divisions
Cloths for cleaning purposes
White paper for making paper funnels (paint chip sample collection trays)
Masking and duct tape
Permanent (indelible)marking pen
Personal safety gear
Cutting and scraping tools:
o Sharp-edged razor knife
o Single-edged safety razor blades
o Pocket knife with locking blade
o Rigid blade paint scraper with extra blades
o Flexible putty knife
o Chisels
o Hammer
Flashlight
Trash bags
Plastic gloves, powderless
Sample Paint Chip Sample Collection Form (www.epa.gov/lead/pubs/paintchip.pdf)
Note: Before you begin, take precautions to protect yourself and prevent the contamination of the area
with lead dust. This may include using protective sheeting in the sampling area and donning the
appropriate personal protective equipment (PPE). You should clean all tools used as well as the
sampling area after each sample collection.
Step 1: Write the required information about the test location and sample on a
paint chip sample collection form and paint chip sample container
The field collection report should include, at a minimum:
Project or client name
General sampling site description
The name of the person collecting the samples
The paint chip sample container should include, at a minimum:
A unique identifier
Dimensions of the sampled surface (include measuring units)
[2]
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Paint Chip Sample Collection Guide
October 2011
Step 2: Outline the collection area
Using a ruler, draw an outline of the sampling area on the painted surface with a permanent
marking pen.
Record the dimension of the outline.
Score the outlined area with a razor knife or equivalent cutting tool.
Use the cutting tool to retrace the outline area.
Clean the ruler with a cloth.
Note: Samples generally should be at least 1 in2, however, the minimum sample size needed may vary by
laboratory. Therefore, it is advisable to contact the NLLAP laboratory that will be analyzing the sample to
determine their minimum sample size requirement.
Step 3: Set up a paint chip sample collection tray
For Horizontal Surfaces
Use a sheet of letter-size white paper for making a paper funnel for paint chip sample collection.
In cases where the sampling location is too small to accommodate a funnel made with a sheet of
the letter-size paper, cut the paper to an appropriate smaller size.
For Vertical Surfaces
Center a piece of tape along one of the long edges of a clean sheet of white paper. The tape
should be slightly shorter than the paper and placed so that sufficient adhesive is available to
firmly stick the paper to the paint surface.
Stick the paper directly below the location to be sampled with the taped edge closest to the
scored location.
Pull the two lower corners of the paper together and overlap slightly to form a funnel.
Secure with a piece of tape.
Fold the bottom of the newly formed funnel up and use a piece of tape to close off the funnel
bottom. Be sure no sticky tape surfaces are exposed on the inside of the funnel.
For Overhead Horizontal Surfaces (Painted Surfaces Facing Down)
Make a closed-bottom funnel in the same manner as described in "For Vertical Surfaces."
Affix the funnel to the painted surface in a way so that it is directly under the location to be
sampled without impeding access to the surface, or attach the funnel to a ladder beneath the
sample location.
Step 4: Remove the paint chip sample
Using a cutting tool, begin removing the paint chip sample from the substrate.
Peel the paint chip sample from the substrate by sliding the blade along the score and
underneath the paint chip sample.
If problems are encountered in removing the paint chip sample, use a scraping tool or other
equivalent tool to aid in paint chip sample removal.
[3]
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Paint Chip Sample Collection Guide
October 2011
Step 5: Transfer the collected sample to the paint chip sample collection
container
Remove the paint chip sample collection tray from the sampling location. Avoid any sample
spillage.
Carefully tap all the collected paint chip sample into the paint chip sample collection container.
Seal the paint chip sample collection container.
Dispose of paint chip sampling trays made of paper in a trash bag.
If a reusable paint chip sample collection tray is used, clean it thoroughly with a cloth and allow
it to dry completely before reusing it at a new sampling location.
Note: Carefully clean the area of all dust using a wet wipe procedure.
Step 6: Clean all cutting tools used during paint chip sample collection
Clean all cutting tools used during paint chip sample collection with a cloth.
Step 7: Check documentation for completeness on the Paint Chip Sample
Collection Form
Ensure all required documents and paint chip sample collection containers are completely
labeled.
Step 8: Submit the paint chip sample for lead analysis to a NLLAP-recognized
laboratory
A list of NLLAP-accredited laboratories is available at www.epa.gov/lead/pubs/nllaplist.pdf.
Record all results reported from the laboratory.
Step 9: Document paint chip sample lead analysis results
A report of the findings from the submitted paint chip samples must be given to the person
contracting for the work within 30 days following the completion of the renovation work. The
Certified Firm should keep the completed Paint Chip Sample Collection Form for 3 years after
the work is completed.
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Paint Chip Sample Collection Guide
October 2011
Remodeling, Repair and Painting
Sample Paint Chip Collection Form Page 1 of
Name of Owner/Project:
Address:
City: State: Zip code: Contact # ( )
Email:
Renovation Information
Fill out all of the following information that is available about the Renovation Site, Firm and Certified Renovator.
Renovation Address: Unit #:
City: State: Zip code:
Certified Firm Name:
Address:
City: State: Zip code: Contact #: ( ) -
Email:
Certified Renovator Name:
Date Certified / /
Paint Chip Sample Information
For each sample collected, fill out all of the following information
Sample Identifier:
Sample Collector Name:
Sampling Location:
Sampling site description: Date of Collection: / /_
Sample Dimensions (cm): Calculate Sample Area (cm2):
NLLAP-recognized entity and location:
Submission date: / / Results: Result Date: / /
[5]
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Paint Chip Sample Collection Guide
October 2011
Renovation Address:
City:
Unit #:
State:
Zip code:
For each sample collected, fill out all of the following information
Sample Identifier:
Sample Collector Name:
Sampling Location:
Sampling site description:
Sample Dimensions (cm):
Date of Collection: / /_
Calculate Sample Area (cm2):
NLLAP-recognized entity and location:
Submission date: / / Results:
Result Date: / /
For each sample collected, fill out all of the following information
Sample Identifier:
Sample Collector Name:
Sampling Location:
Sampling site description:
Sample Dimensions (cm):
Date of Collection: / /
Calculate Sample Area (cm ):_
NLLAP-recognized entity and location:
Submission date: / / Results:
Result Date: / /
For each sample collected, fill out all of the following information
Sample Identifier:
Sample Collector Name:
Sampling Location:
Sampling site description:
Sample Dimensions (cm):
Date of Collection: / /_
Calculate Sample Area (cm2):
NLLAP-recognized entity and location:
Submission date: / / Results:
Result Date: / /
[6]
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Appendix 10:
For More Information
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APPENDIX 10: For More Information
If you are a hearing- or speech-impaired person, you may reach the telephone numbers
below via TTY by calling the Federal Information Relay Service at 1 -800-877-8339.
Where can I get copies of the Renovate Right: Important Lead Hazard Information for
Families, Child Care Providers and Schools pamphlet in English or Spanish?
S Download electronic copies at: http://www.epa.gov/lead/pubs/renovation.htm.
S Use camera-ready copies from the National Lead Information Center to
reproduce the pamphlet, providing that you reproduce the text and graphics in
full: 1 -800-424-LEAD (5323).
S Order bulk copies from the Government Printing Office (GPO) which cost $53.00
for a package of 50 pamphlets: 202-512-1800; refer to the pamphlet by name
order online at http://bookstore.gpo.gov.
Where can I get copies of Small Entity Compliance Guide to Renovate Right handbook?
S Download electronic copies in PDF format at
http://www.epa.gov/lead/pubs/renovation.htm.
S Contact the National Lead Information Center at: 1-800-424-LEAD (5323)
Where can I find additional information and resources related to lead-based paint?
ฆS Lead Information Center: 1-800-424-LEAD (5323)
S EPA's Office of Pollution Prevention and Toxics (OPPT): www.epa.gov/lead
S HUD's Office of Healthy Homes and Lead Hazard Control:
www.hud.gov/offices/lead or by email to lead.regulations@hud.gov.
October 2011
A10-1
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