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U.S. Department of Housing and Urban Development

GUIDELINES FOR THEEVALUATION AND CONTROLOF LEAD-BASED PAINTHAZARDS IN HOUSING

JUNE 1995

U.S. Department of Housing and Urban DevelopmentWashington, D.C. 20410

OFFICE OF LEAD-BASED PAINT ABATEMENTAND POISONING PREVENTION

TO THE READER:

The U.S. Department of Housing and Urban Development (HUD) has issued these Guidelines For the Evalua-tion and Control of Lead-Based Paint Hazards in Housing pursuant to Title X of the Housing and CommunityDevelopment Act of 1992. This document replaces the 1990 publication, Lead-Based Paint: Interim Gu/de//nesfor Hazard Identification and Abatement ;n Public and Indian Housing.

These new Guidelines are based on the most current scientific research. As ongoing studies are completed,HUD expects to issue revisions and updates that will incorporate advances in technology and more cost-effective methods validated by research and experience. For example, HUD and the U.S. EnvironmentalProtection Agency are sponsoring a statistical study to determine whether reliable paint inspections of multi-family properties can be conducted with fewer units than are recommended in Chapter 7. It is planned thatthe results of that study and any modifications to Chapter 7 will be available in the fall of 1995. HUD is alsopreparing a more compact version of the Guidelines—a field guide—that is planned for publication in 1996.

Your comments and suggestions on ways to improve the Guidelines would be very helpful to the Department inpreparing future revisions. Please send comments to: Director, Office of Lead-Based Paint Abatement and Poi-soning Prevention, HUD—Room B-133, 451 Seventh Street SW, Washington, DC 20410.

Additional copies of the Guidelines are available for a small handling fee from HUD USER at 1-800-245-2691. Revisions and updates will be available from the same source.

DisclaimerThis document was prepared under contract to an agency of the United States Government. Neither the United StatesGovernment nor any of its employees makes any warranty, expressed or implied, or assumes any legal liability for anythird party's use of, or the results of such use of, any information, product, or process discussed in this document. Men-tion or illustration of company or trade names or of commercial products does not constitute endorsement by the UnitedStates Government.

Acknowledgments

The U.S. Department of Housing and Urban Development and the National Center for Lead-Safe Housing wishes to thank

the many individuals who helped prepare this document. Experts from the housing, public health, and environmental disci-

plines volunteered countless hours to provide the Nation vtrh the best possible guidance. Due to their dedication and hard

work, this document will further the effort to provide safe affordable housing and reduce childhood lead poisoning.

Principal Author

David E Jacobs

Contributing Authors

Scon Clark

David Cox

Gar/ Dewalt

Mar* Farfel

Walter G Fan-

Norman Fay

Susan Guyaux

Ron Jones

Jin Keck

Barbara Lecrynski

Miles Mahoney

Andrew Nelson

Pat VkLaine

Sharon C Park

Brad Prenney

Don Ryan

Bob Santucci

John Scalera

DICK Schmehl

Aarcn Sussell

Elltn John

Steve WeiU

Jonathan Wilson

Federal Steenng Committee

Steve WeiQ. Chair HUD Arthur Newtourg HUD

Dave Jacobs, Secretary NCLSH Carolyn Newton HUD

Rick Brandes EPA Gary Noonan CDC

Bnon Cook EPA John Schwemberger EPA

NickFarr NCLSH Dianne Sheridan EPA

Mark Henshall EPA Linda Walker VA

Samuel Hodges III FmHA Bill Wisner HUD

Louts Lygon OSHA Hugh Wolfe DoD

Mary McKnight NIST

Acknowledgments(continued)

Technical EditorJudy La Kind

Copy EditorsCaroline S.A. Baker

Robin GurleyAspen Systems Corporation

Graphic DesignersDavid L. SchmidtStephanie L. Melis

Grant HutchinsAspen Systems Corporation

ReviewersVicki Ainslie

Jim August

Tracy Barlow

Sue Binder

Karen Blume

Lynn Boulay

Dave Burgoon

David Bussard

Bruce Buxton

Patrick Connor

John Dement

Gary Dewalt

Denny Dobbin

Pierre Erville

Charles Hartwig

Karen Florini

Michael Godfrey

Andrew Goodman

Jeanne Gorman

Sharon Harper

Steve M. Hays

Ron Jones

Fred Kalvelage

John Kinateder

Barbara Leczynski

Linda Lewis

Ben Lim

Bob Lordo

Tom Matte

John McCarthy

John McCauley

Ron Menton

John Menkedick

Beth Moore

John Moran

Rick Rinehart

John Rogers

Steve Rust

Joan Ryan

Mary Ann Russ

Joe Schirmer

Thomas J. Schruben

Brad Schultz

Steve Sides

Kenn White

Neil Wilson

John Zilka

Ralph Zumwalde

Finally, special thanks go to Evelyne Bloomer, who contributed many hours typing and formatting.

IV

TABLE OF CONTENTS

List of Tables vii

List of Figures viii

List of form ix

List of Appendixes xi

Executive Summary xiii

Chapter 1: Introduction 1-1

Chapter 2: Where To Go for Help—Qualifications and Roles 2-1

Chapter 3: Before You Begin—Planning To Control Lead Hazards 3-1

Chapter 4: Lead-Based Paint and Housing Renovation 4-1

Chapter 5: Lead-Based Paint Risk Assessment 5-1

Chapter 6: Ongoing Monitoring 6-1

Chapter 7: Lead-Based Paint Inspections 7-1

Chapter 8: Resident Protection and Worksite Preparation 8-1

Chapter 9: Worker Protection 9-1

Chapter 10: Hazardous and Nonhazardous Waste 10-1

Chapter 11: Interim Controls 11-1

Chapter 12: Abatement 12-1

Chapter 13: Encapsulation 13-1

Chapter 14: Cleaning 14-1

Chapter 15: Clearance 15-1

Chapter 16: Investigation and Treatment of Dwellings Housing ChildrenWith Elevated Blood Lead LeveK 16-1

Chapter 17: Routine Building Maintenance and Lead-Based Paint 17-1

Chapter 18: Lead Hazard Control and Historic Preservation 18-1

References R—1

Glossary G-1

Appendixes

* *LIST OF TABLES

2.1 Owner Responsibilities 2-3

3.1 Summary of Steps in Planning Lead Hazard Control Projects 3-7

3.2 Privately Owned Dwellings With Lead-Based Paint (by Age and Amount) 3-7

4.1 Similarities Between Lead Hazard Control and Renovation 4-5

4.2 Selected Renovation Jobs and Work Practices 4-9

5.1 Percentage of All Paint That Is Lead-Based, by Year and Component Type 5-6

5.2 Comparison of Risk Assessment and Paint Inspection 5-85.3 Categories of Paint Film Quality 5-12

5.4 Review of Previous Lead-Based Paint Inspections 5-22

5.5 Risk Assessment Approach for Different Size Evaluations 5-27

5.6 Minimum Number of Targeted Dwellings To Be Sampled AmongSimilar Dwellings 5-29

5.7 Hazard Levels for Lead-Based Paint Risk Assessments 5-34

5.8 Main Hazard Control Options That Could Be Identified in RiskAssessments 5-39

6.1 Standard Reevaluation Schedules 6-10

7.1 Examples of Interior and Exterior Components 7-107.2 Examples of Testing Combinations 7-11

7.3 Number of Units To Be Tested in Multifamily Developments 7-33

8.1 Interior Worksite Preparation Levels (Not Including Windows) 8-11

8.2 Exterior Worksite Preparation Levels (Not Including Windows) 8-138.3 Window Treatment or Replacement Worksite Preparation 8-15

9.1 Personal Breathing Zone Air Sampling for Lead by Method or Activity 9-99.2 Worker Exposure Limits and Guidelines 9-13

9.3 Required Action Under the OSHA Standard by Exposure Level 9-13

9.4 Residential Lead Hazard Control Assumed Exposures for OSHA'sTask-Related Triggers 9-17

10.1 Categories of Abatement Waste 10-9

10.2 Management of Abatement Waste 10-16

vii

List of Tables (continued)

11.1 Recommended Minimum Thickness of Dried Paint Film forLead-Based Paint Stabilization (in mil) 11-19

11.2 General Recommendations for Applying Paint 11-2311.3 Finish Coats for Lead-Based Paint Stabilization 11-2411.4 Sticky Tape Technique for Removing Loose Paint on Impact Surfaces

for Owner/Occupants or Residents 11-3211.5 Potential Sources of Lead-Contaminated House Dust 11-3611.6 Major Dust Reservoirs and Potential Dust Traps 11-3711.7 Carpet Cleaning Steps 11-4611.8 Grasses and Their Appropriate Applications 11-50

12.1 Prohibited Lead-Based Paint Abatement Methods 12-912.2 Comparison of Lead-Based Paint Abatement Methods 12-1112.3 Steps To Install Drywall and Fiberboard on Interior Walls 12-27

13.1 Advantages and Disadvantages of Using Encapsulants 13-713.2 Categories of Encapsulants 13-913.3 Steps for Obtaining Proper Application and Installation of an

Encapsulant System 13-21

14.1 Initial Cleaning Wipe-Test Failure Rates for Various AbatementStrategies 14-22

14.2 Mass Removal Efficiency for Extended Vacuuming Cycles 14-23

15.1 Recommended Minimum Number and Location of Single-SurfaceDust Samples 15-14

15.2 Interim HUD Clearance Dust Standards (Wipe Sampling Only) 15-1715.3 Hypothetical Example of Single-Surface Clearance Dust Sampling Data 15-1815.4 Hypothetical Example of Composite Clearance Dust Sampling Data 15-18

16.1 How To Interpret Blood Lead Levels in Children 16-716.2 Resident Questionnaire for Investigation of Children With

Elevated Blood Lead Levels 16-11

17.1 Summary of Low- and High-Risk Job Designations for SurfacesKnown or Suspected To Contain Lead-Based Paint 17-6

17.2 Summary of Protective Measures for Low- and High-Risk Jobs 17-7

VIII

LIST OF FIGURES

1.1 Title X's Lead Hazard Control Framework 1-9

1.2 Some Lead-Bawd Paints Had as Much as 50 Percent Lead 1-10

3.1 Risk Assessment vs. Inspection: Decisionmaking Logic 3—10

4.1 A Case Report: Renovation and Lead Poisoning 4—4

5.1 Lead Hazard Screen Decision Logic 5-7

5.2a Forms of Paint Deterioration: Chalking 5—13

5.2b Forms of Paint Deterioration: Scaling. Comflaking, and Peeling 5-13

5.2c Formsof Paint Deterioration: Checking 5-13

5.2d Forms of Paint Deterioration: Alligatoring 5-14

5.2e Formsof Paint Deterioration: Blistering 5-14

5.2f Formsof Paint Deterioration: Cracking. Peeling, and Blistering 5-15

5.2g Forms of Paint Deterioration: Cracking and Peeling on Plaster 5-15

5.3a Window Locations for Dust Sampling 5-17

5 3b Deteriorated Window Troughs Often Contain High Levels ofLead-Contaminated Dust 5-18

7.1 Single-Family Housing LBP Testing Example: "Single-Family HousingLBP Testing Data Sheet" testing combination inventory of the kitchen 7-20

7.2 Single-Family LBP Testing Example: "Calibration Check Test Results"form completed for the initial calibration check readings 7-21

7.3 Example of an XRF Performance Characteristics Sheet 7-22

7.4 Single-Family Housing LBP Testing Example: Single-Family HousingLBP Testing Data Sheet" completed through XRF reading 7-23

7.5 Single-Family LBP Testing Example: "Calibration Check Test Results"form completed through the second set of calibration check readings 7-24

7.6 Single-Family LBP Testing Example: "Substrate Correction Values" form 7-26

7.7 Single-Family LBP Testing Example: "Calibration Check Test Results"form for the back-up XRF completed through the second set of calibrationcheck readings 7-27

7.8 Single-Family Housing LBP Testing Example: ' Single-Family HousingLBP Testing Data Sheet* fully completed for the kitchen 7-28

7.9 Single-Family Housing LBP Testing Example: Single-Family HousingLBP Testing Data Sheet" fully completed for the bedroom 7-29

IX

* *List of Figures (continued)

7.10 Single-Family LBP Testing Example: Lead Inspection FinalSummary Report 7-30

7.11 Multifamily Decision Flowchart 7-357.12 Multifamily LBP Testing Example: "Selection of Units" form 7-397.13 Multifamily Housing LBP Testing Example: "Multifamily Housing LBP

Testing Data Sheet" form with completed testing combination inventoryof the bedroom 7-41

7.14 Multifamily LBP Testing Example: "Calibration Check Test Results"form completed through the initial calibration check readings 7-42

7.15 Example of an XRF Performance Character/sties Sheet 7-437.16 Multifamily Housing LBP Testing Example: "Multifamily Housing LBP

Testing Data Sheet" form completed through XRF Classification 7-447.17 Multifamily LBP Testing Example: "Calibration Check Test Results"

form completed through the second set of calibration check readings 7-467.18 Multifamily LBP Testing Example: "Component Type Report" form 7-477.19 Multifamily LBP Testing Example: "Multifamily Housing LBP Testing

Data Sheet" form completed through Laboratory Classification 7-497.20 Multifamily Housing LBP Testing Example: XRF Performance

Characteristics Sheet providing instructions for the evaluation ofthe inspection 7-50

7.21 Multifamily Housing LBP Testing Example: Lead Inspection FinalSummary Report 7-51

8.1 Repair Structural Deficiencies at the Beginning of Lead Hazard Control 8-68.2 Area Should Be Precleaned and Structural Deficiencies in Flooring

Repaired Before Lead Hazard Control Begins 8-78.3a Prepare the Worksite With Plastic Sheeting (interior) 8-78.3b Prepare the Worksite With Plastic Sheeting (exterior) 8-88.3c Prepare the Worksite (exterior) 8-88.4 Apply a Second Layer of Plastic 8-98.5 Cover the Air Vents With Plastic After Turning Off the HVAC System 8-108.6 Install a Simple Airlock Over a Doorway to Minimize Lead Dust

Migration 8-10

9.1 Adverse Health Effects of Lead in Adults and Children 9-79.2 Personal Breathing Zone Air Sampling 9-11

List of Figures (continued)

9.3 How To Inspect Your Respirator 9-18

94 Qualitative Respirator Fit Checks 9-19

9.5 Types of Respirators Used in Residential Lead Hazard Control Work 9-22

9.6a Worker Decontamination 9-24

9.6t> Decontamination of Tools 9-25

9.7 Portable Showers Make Worker Decontamination More Effective

and Feasible 9-25

9.8 Example of Required Sign 9-29

10.1 Waste Management Procedures 10-8

10.2 Seal Abatement Debris in Plastic Before Transporting Offsite 10-11

10.3 Hazardous Waste Container Label With Accumulation Start Date 10-17

10.4 Sample Emergency Plan 10-18

10.5 Sample Waste Manifest 10-20

11.1 Moisture-Related Causes of Paint Failure 11-16

11.2 Wet Scraping Tool 11-21

113 HEPA Vacuum Sanders 11-21

11.4 Use a Sponge To Wet Sand and Smooth New Patching Material 11-22

11.5 Use Litmus Paper To Determine the Surface pH Before Paint

Film Stabilization 11-22

11.6 Window Friction and Impact Points 11-28

11.7 Damaged Paint on an Impact Surface 11-29

11.8 Impact Surfaces 11-29

11.9 Enclose the Window Sill and Window Trough 11-30

11.10 Window Channel Guides That Reduce Friction 11-31

11.11 Covering Stairs With Tread Guards 11-31

11.12 Shoe Molding Is an Acceptable Impact Surface Treatment for

Baseboards 11-32

11.13 Comer Bead Coverings Can Be Used on Outside Corners of Walls 11-32

11 14a Turning an Exterior Window Sill Into a Smooth and Cleanable Surface

(before treatment) 11-38

11.14b Turning an Exterior Window Sill Into a Smooth and Cleanable Surface

(after treatment) 11-38

11.15 Sequence for Dust Removal 11-41

XI

* *List of Figures (continued)

11.16a Remove the HEPA Vacuum Filters 11-4311.16b Disconnect Vacuum Bag From Hose Inlet 11-43

11.16c Remove Bag 11-4311.16d Tape Bag Closed and Put Inside Plastic Bag 11-44

11.16e Service Coarse Prefilters if Necessary 11-44

11.16f Remove and Replace HEPA Filter Assembly 11-44

11.17 Clean Air Vent Registers 11-4511.18 Walk-Off Mats 11-46

11.19 Bark Used as an Interim Control 11-50

11.20 Thorny Bushes as a Land Use Control 11-5011.21 a Fencing as a Soil Interim Control 11-49

11.21b Fencing as an Interim Control for Bare Soil Hazards 11-50

12.1 Use a Pry Point Pad To Minimize Damage to Adjoining SurfacesDuring Component Removal 12-16

12.2 Bend Back All Nails on Removed Components 12-16

12.3a Remove and Replace Trim (interior) 12-17

12.3b Remove and Replace Trim (exterior) 12-1712.4 Window Frame Enclosure System 12-18

12.5 Window Replacement 12-1812.6 Exterior Siding Removal and Replacement 12-19

12.7a Line Walking Surfaces With Plastic 12-20

12.7b Line Pathways With Plastic 12-2012.8a Label Surfaces With a Stamp Before Enclosure 12-2412.8b Caulk the Seams of a Window Frame Enclosure System 12-24

12.9 Example of a Diagram Showing the Location of Lead-Based PaintEnclosures 12-25

12.10a Use of Tyvek on Building Exteriors Prior to Enclosure 12-2812.10b Install Underlayment and New Tile as a Suitable Lead-Based Paint

Enclosure Method 12-28

12.11 Seal All Seams for Enclosure 12-31

12.12a Open-Flame Burning Is Prohibited 12-3612.12b Open-Faced Power Sanding or Grinding Is Prohibited 12-36

XII


12.13 Traditional Abrasive Blasting Is Prohibited (note the visible dustsurrounding the worker) 12-37

12.14 Do Not Wet Painted Surfaces Near Electrical Circuits 12-37

12.15 Heat Guns Operating Below 1.100 CF Are Useful for Limited Areas 12-38

12.16 HEPA Vacuum Power Tools 12-39

12.17 Scraping Tools 12-40

12.18 Vacuum Blasting 12-40

12.19a Needle Gun With HEPA Exhaust Ventilation (without shroud) 12-41

12.19b Needle Gun With HEPA Exhaust Ventilation (with shroud) 12-41

12.20 Proper Protective Gear, Including Gloves. Faceshield. Goggles, andEyewash is Required When Working With Chemical Paint Removers 12—42

12.21 Use Punches To Identify the Location of Components Before SendingThem Offsrte for Paint Removal 12-42

12.22 Eye Wash Stations Are Required When Caustic or Chemical PaintRemovers Are Used 12-43

12 23a Neutralise Surfaces When Using Caustic Paint Removers 12-44

12.23b Neutralize Surfaces With a Glacial Acetic Acid Wash When UsingCaustic Paint Removers 12-44

12.24 Use Litmus Paper on a Bare Stripped Surface Before Repainting 12-45

12.25 Paving Bare Soil May Be the Best Option for High-Traffic Areas 12-55

13.1 Encapsulant Failure 13-17

14.1a Vacuum With a HEPA Filter 14-9

14.1b Pressure Gauge Indicator Shows When Filters Require Changing 14—9

142 HEPA Vacuum Sues and Tools 14-10

14.3 Goggles, Face Shields. Gloves, and Eye Wash Facilities Should BeAvailable When Used With Chemicals Such as TSP 14-11

14.4a-d The HEPA Vacuum. Wet Wash. HEPA Vacuum Cycle Helps inMeeting Clearance Standards 14—12

14.5 Single-Pass HEPA Vacuum/Wet Wash Technology 14-17

14.6 Precleaning Is Needed in Areas Where Contamination andDeterioration Are High 14-17

14.7 Plastic Sheeting Should Be Repaired as Part of Daily Cleanup 14-18

14.8a Pick Up Corners of Plastic Sheeting 14-20

14.8b FoldPlastic Inward 14-20

14.8c Dispose of Plastic Sheeting in a Plastic Trash Bag 14-21

XIII


15.1 Visible Dust Indicates Cleaning Should Be Repeated 15-915.2 Window Locations for Dust Sampling 15-12

17.1 Example of a Lead-Based Paint Inventory 17-1017.2 A Typical Work Order Form 17-12

18.1 Historic Property Before Lead-Based Paint Was ChemicallyRemoved From Exterior Masonry 18-7

18.2 Historic Property After Lead-Based Paint Was Chemically Removed 18-718.3 Historic Property Where the Interior Woodwork and Staircase Were

Wet Sanded and Recoated With Three Layers of Encapsulant ToPreserve the Carved Profiles 18-9

18.4 Deteriorated Window Sashes Were Replaced in This Historic PropertyWhile the Frames and Trim Were Wet Sanded and Repainted(vinyl liners were also installed as a friction reduction treatment) 18-10

XIV

* *LIST OF FORMS

5.0 Resident Questionnaire 5-43

5.1 Building Condition Form 5—44

5.2 Paint Conditions on Selected Surfaces (Single-Family, Owner-Occupied) 5—45

5.3 Field Sampling Form for Deteriorated Paint (Single-Surface Sampling) 5—46

5.3a Field Sampling Form for Deteriorated Paint (Composite Sampling) 5—47

5.4 Field Sampling Form for Dust (Single-Surface Sampling) 5—48

5.4a Field Sampling Form for Dust (Composite Sampling) 5-49

5.5 Field Sampling Form for Soil (Composite Sampling Only) 5-50

5.6 Management Data for Risk Assessment of Lead-Based Paint Hazardsin Rental Dwellings (optional) 5-53

5.7 Maintenance Data for Rental Dwellings 5-56

7.1 Single-Family Housing: LBP Testing Data Sheet 7-54

7.2 Calibration Check Test Results 7-57

7.3 Substrate Correction Values 7-58

7.4 Selection of Units 7-59

7.5 Multifamiry Housing: LBP Testing Data Sheet 7-60

7.6 Multifamiry Housing: Component Type Report 7-63

9.1 Model OSHA Written Compliance Plan 9-31

13.1 Encapsulant Patch Test Documentation 13-20

13.2 Lead-Based Paint Encapsulation Visual Monitoring Form 13—23

151 Lead Hazard Control Visual Clearance Form 15-20

15.2 Lead Hazard Control Clearance Dust Sampling Form(Single-Surface Sampling) 15-21

15.2a Lead Hazard Control Clearance Dust Sampling Form(Composite Sampling) 15-22

15.3 Lead Hazard Control Clearance Soil Sampling Form(Composite Sampling Only) 15-23

17.1 inventory Form 17-17

xv

* *LIST OF APPENDIXES

1. Units of Measure Used in the Lead-Based Paint Field 1-1

2. CDC's Childhood Lead Poisoning Prevention Program Offices 2-1

3. U.S. EPA Regional Offices 3-1

4. OSHA Regional Offices 4-1

5. EPA Sponsored Regional and Local Lead Training Centers 5-1

6. Other Organizations Providing the EPA Lead-Based Paint AbatementSupervisor and Inspector Course Curriculum 6-1

7.1 Elements of Inspection and Risk Assessment RFPs 7-1

7.2 Types of Lead-Based Paint Enclosure Systems 7.2-1

7.3 Lead-Based Paint Abatement Specification Example 7.3-1

8. Example of Risk Assessment Report 8-1

8.1 Example of a Risk Assessment Report for a Single-Family DwellingOperated by a Small-Scale Owner 8.1-1

8.2 Example of a Risk Assessment Report for a Large MultifamilyHousing Development 8.2-1

9. Insurance Companies Offering Lead Abatement General and Professional

Liability Coverage 9-1

10. Questions and Answers on Sampling Lead-Based Paint Hazardous Waste 10-1

10.1 State and Territorial Hazardous Waste Management Agencies 10.1-1

11. One-Hour Waiting Period Rationale for Clearance Sampling 11-1

12. Lead-Based Paint Testing: Sample Sizes for Multifamily Housing 12-1

13.1 Wipe Sampling for Settled Lead-Contaminated Dust 13.1-1

13.2 Paint Chip Sampling 13.2-1

13.3 Soil Sampling Protocol for Housing 13.3-1

13.4 Sampling Airborne Particulate for Lead (NIOSH Method 7082) 13.4-1

13.5 EPA Water Sampling Procedures 13.5-1

14.1 Laboratory Analytical Procedures 14.1-1

14.2 Procedure for the Digestion of Wipe Samples Using Diaper Wipes 14.2-1

14.3 Procedure for the Preparation of Field Spiked Wipe Samples 14.3-1

15. OSHA Interim Final Lead in Construction Standard Fact Sheet 15-1

16. Summary of CDC Lead Poisoning Statement 16-1

XVII

Executive Summary

The Guidelines for the Evaluation and Control ofLead-Based Paint Hazards in Housing, hereafter

referred to as the Guidelines, provide detailed,comprehensive, technical information on howto identify lead-based paint hazards in housing

and how to control such hazards safely and effi-ciently. The goal of this document is to helpproperty owners, private contractors, and Gov-ernment agencies sharply reduce children's ex-posure to lead without unnecessarily increasingthe cost of housing.

The Guidelines address lead hazards posed by

paint, dust, and soil in the residential environ-ment. Lead exposures from air emissions,Superfund sites, drinking water, ceramics, home(folk) remedies, cosmetics, food, or othersources are not the focus of this manual.

The Guidelines are issued pursuant to Section

1017 of the Residential Lead-Based Paint Haz-ard Reduction Act of 1992, which is often re-ferred to as Title X ("Title Ten") because it wasenacted as Title X of the Housing and Commu-nity Development Act of 1992 (Public Law102-550). The Guidelines are based on the con-cepts, definitions, and requirements set forth by

Congress in Title X.

Section 1017 requires the Secretary of the U.S.

Department of Housing and Urban Develop-ment (HUD) to issue "guidelines for the con-duct of federally supported work involving riskassessments, inspections, interim controls, andabatement of lead-based paint hazards" (em-

phasis added). Therefore, the primary purposeof this document is to provide guidance to

people involved in identifying and controllinglead-based paint hazards in housing that is asso-

ciated with the Federal Government. TheGuidelines may also be useful to individuals inhousing that has no connection with the Fed-

eral government, as well as day-care centers andpublic buildings that exhibit conditions similar

to those in residential structures.

This document replaces Lead-Based Paint: In-terim Guidelines for Hazard Identification andAbatement in Public and Indian Housing, whichwas issued by HUD in 1990. The Guidelines donot replace the Lead-Based Paint Risk Assessment

Protocol, which applies only to the public andIndian housing program and was published inJune 1992. The risk assessment procedures inthe Guidelines are similar to those of the 1992document, but the management systems of pub-lic and Indian housing authorities requireslightly different risk assessment tools.

The Guidelines complement regulations, otherdirectives, and other guidelines to be issued byHUD, the Environmental Protection Agency

(EPA), the Occupational Safety and HealthAdministration (OSHA) of the U.S. Depart-ment of Labor, and the Centers for Disease

Control and Prevention (CDC) of the U.S. De-

partment of Health and Human Services. OtherFederal agencies and State and local govern-ments may also issue regulations and directivespertaining to housing under theirjurisdictions.Regulations generally specify minimum require-ments for what work must be done, when thework must be done, and what training and cer-tification workers must have. Certain basicstandards as to how the work must be done arealso usually specified. The Guidelines providemore complete guidance than do regulations on

how activities related to lead-based paint shouldbe carried out and why certain measures are rec-ommended. The Guidelines are not enforceableby law unless a Federal, State, or local statute or

regulation requires adherence to certain parts ofthis document.

HUD prepared the Guidelines in close consulta-tion with EPA, CDC, OSHA, and several otherFederal agencies. Most of the writing was done

by the National Center for Lead-Safe Housing,with the help of numerous experts and practi-tioners who served as writers and reviewers.

XIX

Executive Summary

Readers should be aware that lead hazard con-trol is a rapidly changing field in which newproducts, methods, procedures, and standardsare introduced frequently. The Guidelines willtherefore be updated periodically, as researchand experience provide new information, astechnology advances, and as Federal regulationsare revised. HUD welcomes comments and sug-gestions on ways to improve these Guidelines.Please send written comments to:

Director, Office of Lead-Based PaintAbatement and Poisoning Prevention

U.S. Department of Housing andUrban Development

451 Seventh Street SW, Room B-133Washington, DC 20410

I. Childhood LeadPoisoning

Childhood lead poisoning has been labeled byCDC as "the number one environmental healthhazard facing American children." Current evi-dence shows that 8.9 percent of American chil-dren under age 6 have blood lead levels greaterthan 10 ng/dL, which is CDC's current thresh-old of concern (Brody, 1994; Perkle, 1994). Ofgreatest concern are changes in the brain thatcause reductions in IQ and attention span, read-ing and learning disabilities, hyperactivity, andbehavior problems. Adult workers who are ex-posed to lead also suffer a variety of healthproblems. Pregnant workers and their fetusesare at special risk.

Because lead has been successfully removedfrom gasoline and food, CDC believes the fore-most source of lead in the environments ofyoung children is house paint applied before the1978 ban on lead-based paint for residential andconsumer use. Closely associated sources of leadare lead-contaminated dust and soil.

II. The Title X Fram'ework

The most difficult question in lead-based painthazard control derives from resource limitations:How can the cost-effectiveness of lead hazard

control be maximized so children's lead expo-sure in housing can be sharply reduced withoutunnecessarily adding to the cost of housing?

In confronting this problem. Congress providedin Title X a framework to allow governmentalofficials, property owners, participants in thereal estate industry, and specialists in lead-basedpaint hazard control to tailor sensible and effec-tive lead hazard control programs to fit the fi-nancial and environmental conditions of spe-cific properties. In effect, the immediate goal isto make housing lead-safe rather than lead-free.

This framework, however, is not simple. Withthe flexibility needed for practicality and cost-effectiveness comes complexity. And with com-plexity comes the need to learn, share informa-tion, and continually improve methods.

III. Definition of "Lead-Based Paint Hazard"

Title X redefines the concept of "lead-basedpaint hazards." Under prior Federal legislation,a lead-based paint hazard was any paint con-taining 1 mg/cm2 of lead or more, regardless ofpaint condition or location. Title X states thata lead-based paint hazard is "any condition thatcauses exposure to lead . . . that would result inadverse human health effects" and that comesfrom:

+ Lead-contaminated dust.

4- Bare, lead-contaminated soil.

+ Lead-contaminated paint that is deterio-rated or present on accessible, friction, orimpact surfaces.

Thus, under this definition, intact lead-basedpaint on most walls and ceilings would notbe considered a "hazard," although the paintshould be maintained and its condition moni-tored to ensure that it does not deteriorate andbecome a hazard.

Title X acknowledges that some lead-basedpaint hazards are of more immediate concernthan others. In these Guidelines, the hazards

XX

Executive Summary

considered to be of greatest immediate concernare those to which children are most frequentlyexposed: lead-contaminated dust; deterioratedlead-based paint: and lead-contaminated soil ifit is bare, accessible to young children, and/or

likely to be blown or tracked into the dwelling.Also of concern are friction, chewable. and im-pact surfaces with intact lead-based paint. Fric-

tion surfaces are subject to abrasion and may

generate lead-contaminated dust in the dwell-ing chewable surfaces are protruding surfacesthat are easily chewed on by young children;and impact surfaces may become deteriorated

through forceful contact. Intact lead-basedpaint on flat surfaces not subject to abrasion,impact, or other disturbances, although of lessconcern, is still a potential hazard because the

paint could deteriorate over time, as a result ofage. disturbance (through renovation and re-pair), or major casualty (such as Tire, storms.

and water leaks).

Although most efforts to reduce lead hazards inhousing will now be aimed at controlling lead-

based paint hazards as defined by Title X. thereis one notable exception: in public and Indianhousing, all toad-based paint must be abated

when the housing is renovated or remodeled.

Lead-eased part is any paint, varnish, stain, orother applied coating that has 1 mg/crrr (or5.000 vglg by dry weight) or more of lead Forthe purposes of these Gudehnes. the terms'leaded paint* and 'toad-containing paint*are synonymous with 'lead-based paint.*

IV. Lead Hazard ControlProcess

The process of controlling toad hazards beginswith suggestions on how property owners cantailor lead poisoning prevention efforts to their

own unique dwellings.

A. Planning

In buildings constructed after 1978. it is very

unlikely that toad-based paint hazards arepresent. No further action is recommended.

unless a child with an elevated blood lead level

is identified The older the dwelling, the moreprevalent and concentrated the lead-based

paint. The prevalence of lead-based paint inhousing built before 1940 is especially high;

after 1943 the use of lead in paint declinedsteadily The condition of the building (i.e.. its

paint and substrates coated with that paint), itsprojected service life, and funding availabilityalso bear directly on the owner's decision about

a specif.c course of action.

B. Lead Hazard Evaluation

Most lead hazard control efforts begin with anevaluation of the nature and extent of the prob-

lem. Eva uations of lead hazards should be con-ducted through risk assessments, paint inspec-tions, or a combination risk assessment/paintinspection. A risk assessment is an onsite inves-tigation of a residential building to determine

the location, severity, and nature of toad-basedpaint hazards and includes (but may not be lim-ited to) i visual inspection to determine thecondition of painted surfaces, the need for

structural repairs, and locations for dust. soil,and pain: sampling; limited environmental sam-pling of dust, soil, and deteriorated paint; and a

report of the results that identifies acceptableabatement or interim control strategies for con-trolling any lead-based paint hazards. Risk as-sessments and inspections can be combined (seeChapters 3 and 5). A paint inspection "means a

surface-by-surf ace investigation of all paintedsurfaces—interior and exterior, in common ar-eas of mi Itifamily buildings as well as in dwell-ing units—using portable x-ray fluorescence

paint analyzers or laboratory analysis of paint

samples to determine the presence of lead-basedpaint, and the provision of a report on theresults.'

Inspections to identify the presence of toad-based paint should not be confused with clear-ance examinations risk assessments, or investi-

gations of homes with lead-poisoned children.These Guidelines also describe a lead hazardscreen ri<k assessment for dwellings in good

condition that are unlikely to contain lead haz-

ards (see Chapter 5). This flexibility reducesthe cost of evaluating lead hazards.

XXI

Executive Summary

Paint inspections are particularly useful in de-veloping plans to conduct abatement duringrenovation or remodeling activities, while riskassessments are often used to confirm that nolead hazards exist or to guide interim controlefforts if hazards are identified. Combiningthese approaches has the advantage of identify-ing both immediate and potential hazards soowners can understand what work must be doneimmediately and what work can be done atlater, more convenient times (for example,vacancy and rehabilitation).

The Guidelines provide detailed procedures andforms for completing both risk assessments andinspections. Slightly different procedures arerecommended for owner-occupants and ownersof large and small rental properties.

If an owner decides to bypass the evaluationprocess and correct suspected lead hazards, aclearance process is needed to ensure that alllead-based paint hazards were actually correctedand that leaded dust and soil levels remaining atthe conclusion of the project are acceptable.Somejurisdictions, HUD regulations, or EPAregulations may require risk assessments, inspec-tions, and/or clearance examinations. Successfulcompletion of the process may require a certifi-cate documenting the status of the dwelling.

C. Lead Hazard ControlIn the Title X framework, there are three typesof lead hazard control: interim controls, abate-ment of lead-based paint hazards, and completeabatement of all lead-based paint. Interim con-trols are designed to address hazards quickly,inexpensively, and temporarily, while abate-ment is intended to produce a permanent solu-tion. In the Guidelines, "permanent" meanshaving an expected life of at least 20 years.

Interim controls, according to Title X, "meansa set of measures designed to reduce temporarilyhuman exposure or likely exposure to lead-based paint hazards, including specialized clean-ing" (to reduce lead-contaminated dust), "re-pairs, maintenance, painting, temporary con-tainment, ongoing monitoring of lead-basedpaint hazards or potential hazards, and the

establishment and operation of managementand resident education programs." Interim con-trols include dust removal, paint film stabiliza-tion, and treatment of friction and impact sur-faces. Interim controls are appropriate forimplementation on a broad scale and may provecost effective in many cases. Whenever interimcontrols are employed, ongoing monitoring oflead hazards must be undertaken by the prop-erty owner because lead-based paint may still bepresent and may become hazardous in thefuture.

Abatement of lead-based paint hazards, accord-ing to Title X, "means any set of measures de-signed to permanently eliminate lead-basedpaint hazards . . ." Such measures may include"(A) the removal of lead-based paint andlead-contaminated dust, the permanent con-tainment or encapsulation of lead-based paint,the replacement of lead-painted surfaces or fix-tures, and the removal or covering of lead-contaminated soil; and (B) all preparation,cleanup, disposal, and post-abatement clearancetesting activities associated with such mea-sures." Consistent with its focus on lead-basedpaint hazards, Title X has redefined the term"abatement" to mean the elimination of "lead-based paint hazards," not necessarily all lead-based paint.

Complete abatement of lead-based paint meansthe permanent elimination of all lead-basedpaint, interior or exterior, intact or not intact,using the same methods as those included in thedefinition of abatement of lead-based paint haz-ards. Title X requires this for public and Indianhousing (leaving unchanged the statutory re-quirements that have been in place since 1987).Specifically, all pre-1978 public and Indianhousing must be inspected, and all lead-basedpaint identified must be abated (notjust lead-based paint hazards). While there is no explicitdeadline, abatement in public and Indian hous-ing usually occurs during rehabilitation.

The Guidelines take a performance-oriented ap-proach to lead hazard control work. Any con-struction material or method that meets theperformance criteria for interim control or

XXII

Executive Summary

abatement work n acceptable as long as resi-dents and workers are protected, clearance stan-

dards are met. the methods used are not ex-pressly prohibited, waste is properly managed.

and the effectiveness of the measure is eval-uated over time. This permits innovation andshould reduce costs.

All interim controls and some abatement meth-

ods require ongoing monitoring by owners andresidents as well as periodic reevaluation by acertified professional.

As with nsk assessment and inspection, a com-bination of approaches is often best to addresslead-based paint in the most cost-effective wayin a particular dwelling. For example, it may

make sense to stabilize the paint on trim (aninterim control), while replacing windows inthe same dwelling (an abatement measure).

The owner may decide to replace only parts ofthe windows, such as the sashes and/or interiorwindow sills (sometimes known as stools).

Since each case is different, owners are encour-aged to seek professional guidance from certifiednsk assessors and certified abatement supervi-

sors to determine which strategy is best. Riskassessments can target lead hazards and makecontrols more cost-effective.

Whenever building components such as doors

and windows are replaced, the Guidehnes rec-ommend that they be replaced with productsthat are more energy efficient. This will helpreduce eocigy consumption and also reduce thelength of tune it takes for new components topay for themselves.

1. Encapsulation

Encapsulants include coatings and rigid cover-ings that are bonded to the existing paint film

with an adhesive (they are not mechanically

fastened). Because encapsulants rely on adhe-sion to the existing paint film, their durabilitydepends on the properties of the existing sub-strate coating. The standards indicated in Title

X (Section 1051) defining encapsulant perfor-mance have not yet been promulgated Encap-sulants should not be confused with permanentenclosure systems, which are mechanically

fastened to the structural system (and not de-pendent on the substrate coating for their dura-

bility) ard can be expected to last at least 20years.

2. Prohibited Methods

Some pa nt removal methods are known to be

extremely dangerous in the residential settingand are prohibited. Prohibited methods includeopen-flame burning or torching, machine sand-

ing or grinding without a high-efficiency par-ticulate £\r (HEPA) vacuum exhaust tool.uncontained hydroblasting or high-pressurewashing, abrasive blasting or sandblasting with-out HEPA vacuum exhaust tools, and heat guns

that operate above 1,100 F. In addition, HUDdoes not recommend the on-site use of methyl-ene chloride chemical strippers or dry scraping(except far limited areas). Safer alternative

measures that make all these techniques unnec-essary an? available.

D. Preparation

Before control measures can actually be imple-mented a few other planning steps are neces-sary. The Guidelines specifically recommendhow to p-epare worksites to protect residents.

Under certain circumstances, occupants canremain inside the dwelling during the work (al-though they are never to be permitted within

the work area itself while work is under way). Awritten compliance plan needs to be developedby the lead hazard control contractor/supervisor

to comply with the worker protection require-ments of the OSH A Lead in ConstructionStandard

All abatement workers need to be properlytrained by an accredited training provider. Un-

trained workers can worsen conditions. EPA has

developed a training curriculum designed toteach wo-kers to conduct their trade in a lead-safe manner

The wast? that will be generated from the

project rray also need to be tested and evalu-ated to determine whether it is hazardous. Both

worker protection and hazardous waste require-ments a-c strictly enforced.

XXIII

Executive Summary

E. Cleaning and ClearanceAfter the work has been completed, thoroughcleaning is needed. For dust removal alone, allhorizontal surfaces should be vacuumed with aHEPA vacuum and then washed with a lead-specific cleaning agent, trisodium phosphatedetergent, or other suitable cleaner. For moreinvolved abatement work, cleaning should bedone by HEPA vacuuming all horizontal andvertical surfaces, wet washing, and a final HEPAvacuuming. Work should proceed from clean todirty areas to prevent recontamination. Aftercleaning, clearance examinations should alwaysbe conducted by certified risk assessors or certi-fied inspector technicians. The clearance ex-amination involves a confirmation that thework was completed, a visual assessment forvisible dust, and dust (and perhaps soil) sam-pling. HUD and EPA have established specificleaded dust standards for clearance purposes. Ifan owner chooses to bypass the evaluation (go-ing straight to hazard control), a certified riskassessor should perform the clearance examina-tion to ensure that all hazards were addressedand that remaining levels of leaded dust areacceptable.

F. Reevaluation

Some dwellings and control measures will re-quire periodic reevaluations by a certified riskassessor to ensure that hazards have not reap-peared. The Guidelines provide specific recom-mended schedules defining the frequency ofreevaluations.

V. Other Issues

The Guidelines also include information on thespecial procedures for investigating a lead-poisoned child. This type of investigation isvery different from the risk assessment or in-spection process described earlier, which are

related to the condition of a dwelling ratherthan the health of an individual child. Investi-gations of lead-poisoned children shouldinvolve close collaboration with the localhealth department, which may have primaryauthority over housing conditions and may re-quire sampling for many more sources of leadthan would be carried out in a routine risk as-sessment or paint inspection. Further guidanceon this issue will be provided by CDC.

Finally, the Guidelines interpret historic preser-vation requirements and suggest safe proceduresfor maintenance activities that may disturb sur-faces containing lead-based paint.

VI. Innovation and Cost-Effectiveness

Considerable research and innovation is underway. Future editions of these Guidelines willincorporate the results of these efforts. TheGuidelines are a report on state-of-the-art proce-dures for all aspects of lead-based paint hazardevaluation and control.

Within certain regulatory limits and programfunding requirements, the Guidelines are aperformance-oriented document. At the mostbasic level, owners can conduct lead hazardcontrol work any way they choose, as long asthey protect workers and occupants, complywith clearance standards, monitor over time theeffectiveness of the control measures imple-mented, and do not use prohibited methods. Inshort, these Guidelines describe the best knownways to perform lead hazard control work. TheGuidelines also permit the flexibility needed toaddress different kinds of housing and identifyspecific cost-saving measures to make primaryprevention of lead poisoning a reality in mil-lions of homes across the country.

XXIV

*CHAPTER 1: INTRODUCTIONI. Legislative Basis and Relationship to Federal

Programs and Regulations 1-4

A. Legislative Basis 1-4

B. Relationship to Earlier HUD Guidelines 1-4

C. Intended Audience 1-5

II. Background on Childhood Lead Poisoning, Sources of Leadin the Environment, and the Evolution of LeadPoisoning Prevention 1-5

A. Childhood Lead Poisoning 1-5

1. Health Hazards 1-5

2. Prevalence Rates 1-6

3. Highest Risk Populations 1-6

4. Health Screening 1-6

B. Causes of Childhood Lead Poisoning 1-6

1. Lead in Residential Paint 1-6

2. Lead-Based Paint in Housing 1-6

3. Lead in Surface Dust 1-7

4. Lead in Soil 1-7

5. Other Causes of Lead Poisoning 1-7

C. The Evolution of Prevention Approaches 1-7

1. Medical Treatment of Poisoned Children (Tertiary Treatment) 1-7

2. Screening and Case Management Programs (Secondary Prevention) 1-7

3. Primary Prevention 1-8

III. The Title X Framework 1-8

A. Definition of "Lead-Based Paint Hazard" 1-8

B. Strategic Framework for Lead Hazard Control 1-8

1, Evaluating Lead Hazards 1-8

2. Controlling Lead Hazards 1-9

C. Requirements to Ensure Quality Control 1-10

1. Training and Certification 1-10

2. Accreditation of Training Providers 1-11

3. Health-Based Standards 1-11

4. Performance Standards for Testing and Abatement Products 1-11

5. Laboratory Accreditation 1-11

D. State and Local Regulations 1-11

1-1

Chapter 1: Introduction

IV. Organization and Use of the Guidelines 1-11

A. Chapter Organization 1-11

1. Chapters 1-4: Backgrojnd Information 1-11

2. Chapters 5-7: Hazard Evaluation 1-12

3. Chapters 8-10: Preparation for the Project 1-12

4. Chapters 11-15: Hazard Control, Cleanup, and Clearance 1-12

5. Chapters 16-18: Other Issues 1-12

6. Glossary and Appendixes 1-13

B. Units of Measurement 1-13

C. Federal Lead Standards 1-13

1. Pamt 1-13

2. Leaded Dust Levels for Risk Assessments 1-13

3. Dust Levels for Lead Hazard Screen Only 1-13

4. Leaded Dust Clearance Levels (by wipe sampling) 1-13

5. Bare Residential Soil 1-13

6. Airborne Lead Particulate 1-13

7. Elevated Blood Lead Level 1-13

8. Waste 1-13

1-2


The Guidelines for the Evaluation and Control ofLead-Based Paint Hazards in Housing providedetailed, comprehensive technical informationon how to identify lead-based paint and relatedhazards in housing and how to control such haz-ards safely and efficiently. The purpose of thisdocument, hereafter referred to as the Guide-fines, is to help property owners, governmentagencies, and private contractors sharply reducechildhood exposure to lead without unnecessar-ily increasing the cost of housing.

The Guidelines address lead hazards posed bypaint, dust, and soil in the residential environ-ment. Lead exposures from air emissions,Superfund sites, drinking water, ceramics, homeremedies, cosmetics, or other sources of leadexposure are not covered in these Guidelines.

This document replaces Lead-Based Paint: In-terim Guidelines for Hazard Identification andAbatement in Public and Indian Housing, whichwas issued by the U.S. Department of Housingand Urban Development (HUD) in 1990. (Sec-tion I of this chapter includes a description ofthe differences between the Interim Guidelinesand the new Guidelines.) These new Guidelinesare applicable to lead hazard evaluation andcontrol in alf federally associated housing, notjust public and Indian housing. Of course, theGuidelines may also be useful in housing that hasno connection with the Federal Government,as well as day-care centers and public buildingsthat operate under conditions that are similar tothose in residential structures.

The Guidelines complement regulations andother directives and guidelines to be issued byHUD, the Environmental Protection Agency(EPA), the Occupational Safety and HealthAdministration (OSHA) of the U.S. Depart-ment of Labor, and the Centers for DiseaseControl and Prevention (CDC) of the U.S. De-partment of Health and Human Services. OtherFederal agencies, as well as State and local gov-ernments, may also issue regulations and otherdirectives pertaining to housing under their

jurisdictions. Regulations generally specifyminimum requirements for what must be doneand when, minimum training and certificationrequirements for those conducting the work,and certain basic standards as to how work mustbe done. The Guidelines generally provide moredetailed information than regulations on howactivities related to lead-based paint shouldbe carried out and why certain measures arerecommended.

The Guidelines are not enforceable by lawunless a Federal, State, or local statute orregulation requires that certain parts of thisdocument be followed.

HUD prepared the Guidelines in close consulta-tion with EPA, CDC, OSHA, and several otherinterested Federal agencies. The National Cen-ter for Lead-Safe Housing wrote the document,with the help of numerous experts and practi-tioners who served as writers and reviewers.

Readers should be aware that lead hazard con-trol is a rapidly changing field in which newproducts, methods, procedures, and standardsare being introduced frequently. Therefore, theGuidelines will be updated periodically as re-search and experience provide new information,as technology advances, and as Federal regula-tions are revised. HUD welcomes commentsand suggestions on ways to improve theseGuidelines. Please send written comments to:

Director, Office of Lead-Based PaintAbatement and Poisoning Prevention

U.S. Department of Housing andUrban Development

451 Seventh Street SW, Room B-133Washington, DC 20410

This introductory chapter expfains further thelegislative basis for the Guidelines, the intendedreadership, and the relationship of the Guide-lines to the 1990 Interim Guidelines and to Fed-eral regulations. The chapter also includes abrief summary of the problem of childhood lead

1-3


poisoning, an explanation of the basic concepts

that underlie the methods and procedjres set

forth in the Guidelines, and a description of how

the document is structured.

I. Legislative Basis andRelationship to FederalPrograms and Regulations

A. Legislative Basis

The Guidelines are issued pursuant to Section

1017 of the Residential Lead-Based Pemt Haz-

ard Reduction Act of 1992. which is often re-

ferred to as Title X ('Title Ten") because it was

enacted as Title X of the Housing and Commu-

nity Development Act of 1992 (Public Law

102-550) The Guidelines are based on the con-

cepts, definitions, and requirements set forth in

Title X. Section 111 of this chapter describes

the framework of concepts and definitions in

TrtteX.

As required by Section 1017. the Guidelines are

to be used as guidance for 'federally supported

work." which is defined in the Act as 'any lead

hazard evaluation or reduction activities in fed-

erally owned or assisted housing or funded in

whole or in part through any financial assis-

tance program of the Department of Housing

and Urban Development, the Farmers Home

Administration, or the Department of Veterans

Affairs." The term 'federally owned housing' is

defined in the Act as "residential dwellings

owned or managed by a Federal agency, or for

which a Federal agency is a trustee or conserva-

tor.* In this context, the term Tedera agency"

includes HUD. the Farmers Home Administra-

tion, the Resolution Trust Corporation, the

General Services Administration, the U.S De-

partment of Defense, the U.S. Department of

Veterans Affairs, the U.S. Department of the

Interior, the U S Department of Transporta-

tion, and any other Federal agency. The term

'federally assisted housing* is defined in the Act

as "residential dwellings receiving project-based

assistance under programs including—

(A) section 221 (d) (3) or 236 of the National

Housing Act"

(B) section 1 of the Housing and Urban Devel-

opment Act of 1965;

(C) section 8 of the United States Housing Act

of 1937; or

(D) sections 502(a). 504. 514. 515. 516 and 533

of the Housing Act of 1949."

B. Relationship to EarlierHUD GuidelinesThese Guidelines sup< e and replace HUD's

Lead-Based Paint: Interim Guidelines for Hazard

Identification and Abatement in PuMc and Indian

Housing (HUD, 1990a). For those familiar with

the 1990 Interim Guidelines, an appreciation of

the significant differences in context and scope

is important. HUD's 1990 Interim Guidelines

were based on the legislation at that time,

which, as explained in Section 111 of this chap-

ter, required the identification and abatement

of all lead-based paint regardless of condition or

location. Also, the Interim Guidelines were writ-

ten for use primarily in conventional public

housing settings, which are multifamity devel-

opments. The new Guidefines cover a broader

spectrum of housing types and categories of

ownership, and they address the full range of

activities involved in evaluating and control-

ling lead-based paint hazards, as introduced in

1992 by Title X. For example, these Guidelines.

• Cover risk assessment methods for evaluat-

ing current lead-based paint hazards in addi-

tion to inspection methods for identifying

the presence of lead-based paint. These risk

assessment procedures are similar to the risk

assessment protocol published by HUD in

June 1992 for use in public and Indian

housing, but they call for less data on man-

agement, maintenance, and occupancy;

therefore, the June 1992 protocol (or its

successor) will remain as a requirement for

the public and Indian housing program until

further notice.

1-4


4 Include a completely rewritten chapter

on paint inspection (Chapter 7) with new

procedures based on recent research.

4 Focus on correcting lead-based painthazards, as opposed to abatement of alllead-based paint (except in public andIndian housing where requirements toabate all lead-based paint still apply).

4- Describe new procedures for interim

controls to manage lead-based paintin place.

C. Intended Audience

These Guidelines have been developed to pro-vide technical guidance to the many individualsand groups involved with or affected by lead-based paint in residential housing units. Theaudience of these Guidelines includes thefollowing:

4- Lead-based paint abatement contractors.

+ Lead-based paint risk assessors and inspectortechnicians.

4- Lead-based paint training providers.

4- State contractor certifying or licensingagencies.

4 Residential building owners and managers,including public and Indian housing agen-cies; private, nonprofit housing develop-ment organizations; and private, for-profitlandlords, managers, and building owners.

+ State and local housing and communitydevelopment agencies.

4- State and local health agencies.

4 Building maintenance personnel.

4 Architects and designers.

4- Federal agency staff.

4 Environmental laboratory personnel.

4 Real estate agents and brokers.

4 Casualty and liability insurers.

4 Lenders and appraisers.

These Guidelines are not intended for use byuntrained persons attempting to control lead-

based paint hazards. Under proposed EPA regu-lations, contractors and individuals must betrained and certified to conduct inspections,risk assessments, and lead-based paint abate-ment activities.

II. Background on Child-hood Lead Poisoning,Sources of Lead in the En-vironment, and the Evolu-tion of Lead PoisoningPrevention

As understanding of lead's adverse health effectsand the sources and pathways of exposure tochildren has improved, so has recognition ofthe seriousness of lead-based paint hazards.

A. Childhood Lead Poisoning

Childhood lead poisoning is "the most commonenvironmental disease of young children,"

(CDC, 1991a) eclipsing all other environ-mental health hazards found in the residentialenvironment (ATSDR, 1988).

1. Health Hazards

Lead is highly toxic and affects virtually everysystem of the body. At high exposure levels,lead poisoning can cause coma, convulsions,and death. While adults can also suffer fromexcessive lead exposures (discussed in Chapter

9), the groups most at risk are fetuses, infants,and children under age 6. At low levels lead'sneurotoxic effects have the greatest impact on

children's developing brains and nervous sys-

tems, causing reductions in IQ and attentionspan, reading and learning disabilities, hyperac-tivity, and behavioral problems (Davis, 1993).

These effects have been identified in manycarefully controlled research studies (National

Academy of Sciences, 1993). However, the vastmajority of childhood lead-poisoning cases go

undiagnosed and untreated, since most poi-soned children have no obvious symptoms.

1-5


2. Prevalence Rates

In October 1991. CDC formally revised itsstatement on Preven«ng Lead Poisoning in Young

Cf«Jdren (CDC. 1991b). CDC reduced its in-tervention level* for childhood lead poisoningfrom the previous threshold of 25 ug'cL to 10

ug/dL (see Appendix 1 for a description of unitsof measure for lead in blood, paint, dust, soilair. and water) This change was based on scien-tific evidence indicating that adverse health

effects can occur at levels as low as 10 jg/dLFederal agencies estimate that nationwide 8.9

percent (1.7 million) of American children un-der age 6 have elevated blood lead levels (EBLs)(Brody. 1994: Perkle. 1994). (It should be noted

that the 1991 CDC statement did not recom-mend environmental or medical intervention at

the level of 10 ug/dL It recommendec medicalevaluation at or above 20 ug/dL and environ-mental intervention at or above 20 -o/dL ex ifMood lead levels of 15-19 persist. Varous coun-seling, monitoring and communitywice preven-

tion activities were recommended at levels be-i 10-19.g/dL)

3. Highest Risk Populations

Lead poisoning affects children across all socio-

economic strata and in all regions of tie coun-

try. However, because lead-based paint haiardsare most severe in older, dilapidated housingthe poor in inner cities are disproportionately

affected. In many such neighborhoods over halfof all young children are lead poisoned. Nation-wide. African-American children are twice as

likely to be lead poisoned as white childrenacross all income categories (ATSDR. 1988:

EPA1992b)

4. Health Screening

In 1990 CDC called for a phase-in of universalMood lead testing of all young children (unless

it can be shown that the community has nolead poisoning problem) because most poisonedchildren do not exhibit easily identifiable symp-

toms and virtually all children are at r sk (CDC.1991a). The 1992 Medrari Guidelines called forall children under age 6 to be tested I'HCFA,

1992). In 1993 the American Acaderry of

Pediatrics (AAP) also revised its policy to

recommend the routine screening of virtually

all young children under age 6 (AAP. 1993).

B. Causes of Childhood LeadPoisoning

Today, children in the United States are lead

poisoned primarily through ingestion by normalhand-to-mouth activity and. to a lesser extent,inhalation. Because lead is ubiquitous in indus-trial societies, there are many sources and path-

ways of lead exposure.

1. Lead in Residential Paint

The foremost cause of childhood lead poisoningin the United States today is lead-based paintand the accompanying contaminated dust and

soil found in older houses (CDC. 1991b;Rabinowitz. 1985b; Jacobs, 1994). As early as1897, lead-based paint was identified as a causeof childhood lead poisoning (Turner, 1897;Reich. 1992). Many countries prohibited the

use of lead in residential paints as far back as1922 (Rabin. 1989). Lead was a major ingredi-ent in most interior and exterior oil housepaints prior to 1950. with some paints contain-

ing as much as 50 percent lead by dry weight. Inthe early 1950s, other ingredients became morepopular, but some lead pigments, corrosion in-hibitors, and drying agents were still used. Leadwas first regulated in residential paint in 1972 at0.5 percent and "banned" in 1978, meaningthat paint could contain no more than 0.06 per-cent lead by dry weight (Reich, 1992; Rabin,1989).

2. Lead-Based Paint in Housing

HUD estimates that three-quarters of pre-1980housing units contain some lead-based paint.The likelihood, extent, and concentration of

lead-based paint all increase with the age of thebuilding. Fully 90 percent of privately ownedunits built before 1940, 80 percent of units built

between 1940 and 1959. and 62 percent of unitsbuilt between 1960 and 1979 contain some

lead-based paint (HUD, 1990b). Because thegreatest risk is in dwellings built before 1950,older housing generally commands a higher pri-ority for lead hazard controls. However, there is

1-6


evidence that significant amounts of lead-basedpaint were sold as late as 1971, when New YorkCity's Health Department tested 78 "new" resi-dential paints and found 8 of them to have leadranging from 2.6 percent to 10.8 percent (NYTimes, 1971). See Chapters 3 and 5 for leadprevalence data by year of construction and bybuilding component type.

3. Lead in Surface DustThe belief that in order to be poisoned childrenmust eat lead-based paint chips is unfounded.The most common cause of poisoning is theingestion—through hand-to-mouth transmis-sion—of lead-contaminated surface dust (Clark,1991; Bellinger, 1991; Roberts, 1991; Chisolm,1985; Farfel, 1990; Farfel, 1994). Lead-contami-nated dust may be so fine that it cannot be seenby the naked eye. In addition, lead-contami-nated dust is difficult to clean up. Leaded dust isgenerated as lead-based paint deteriorates overtime, is damaged by moisture, abraded on fric-tion and impact surfaces, or disturbed in thecourse of renovation, repair, or abatementprojects. Lead can also be tracked into homesfrom exterior dust and soil. These Guidelinesaddress lead in surface dust and soil as well as inpaint since Congress also defined lead found indust and soil to be lead-based paint hazards.

4. Lead in SoilChildren can also be exposed to lead in baresoil. The high levels of lead in soil typicallycome from deteriorating exterior lead-basedpaint around the foundation of a house (TerHarr, 1974; Linton, 1980). The fallout of leademissions from the combustion of leaded auto-mobile gasoline, lead-based paint, and industrialsources also contributes to lead levels in soil(ATSDR, 1988). In some areas high leaded soillevels result from factory and smelter emissionsor deteriorating lead-based paint on steel struc-tures, such as bridges. Bare soil that is contami-nated with lead poses a hazard to children whoplay in it. Lead in soil may also be tracked intoa home, increasing interior leaded dust levels.These Guidelines address lead-contaminatedsoil, as well as lead-based paint.

5. Other Causes of Lead PoisoningOther sources and pathways of lead poisoningin children can include drinking water, pointsources (such as smelters or industrial discharg-ers), ceramics, lead brought home from aparent's workplace, home and folk remedies,cosmetics, and hobbies (such as casting leadsinkers or toy soldiers, making stained glass,loading ammunition, and soldering). For somechildren these sources may account for theirexposure; however, for most children, paint,dust, and soil are the primary sources of leadpoisoning.

C. The Evolution of PreventionApproaches

The approach to identifying and responding tolead-based paint hazards in American housinghas evolved over the past several decades.

1. Medical Treatment of PoisonedChildren (Tertiary Treatment)During the 1940s and 1950s, deaths from child-hood lead poisoning were common. Using che-lation therapy (the use of drugs to excrete leadfrom the body), medical providers attempted totreat symptomatic cases to prevent death, withthe assumption that children who survived hadbeen cured. During the 1950s studies in Chi-cago (Williams, 1952), Boston (1954), NewYork City (McLaughlin, 1956), and Baltimore(Chisolm, 1956) demonstrated conclusivelythat children who survived serious lead poison-ing were often left mentally retarded or other-wise permanently impaired (Lin Fu, 1982).

2. Screening and Case ManagementPrograms (Secondary Prevention)Recognition of these neurological problemsgave rise to expanded screening and case man-agement programs in many cities and States.Traditionally, the approach to childhood lead-poisoning prevention has been reactive, relyingon the identification of a poisoned child to trig-ger investigation of lead hazards in the homeenvironment.

1-7


Based on the belief that children had to eat

lead-bated paint chips to be poisoned, the typi-cal response to a lead poisoning during the1970s and early 1980s consisted of removing

deteriorated lead-based paint by scrap ng. un-controlled sanding, or open-flame burling. Ap-proaches differed slightly from city to 3ity Somerequired removal of all lead-based paint to a

certain height, such as 5 feet: others requiredonly that deteriorating paint be removed. How-

ever, these traditional abatements had one com-mon characteristic: little attention was paid tocontrolling, containing, and cleaning up leadeddust. In many cases these paint removal meth-ods actually aggravated the problem and in-creased lead exposures, poisoning workers andchildren in the process. Several studies foundthat uncontrolled abatement and inadequate

cleanup caused increased blood lead levels(Farfel and Chisolm. 1990; RabinowiU. 1985a:Amitai. 1987)

3. Primary Prevention

In 1987 Congress concluded that responding tolead-based paint hazards on an indivicual basisonly after a poisoning was inappropriate. TheHousing Act of 1987 (PL 100-242) cirectedattention to finding and abating lead-basedpaint in housing to prevent lead poisoning (pri-

mary prevention). The presence of lead-basedpaint on any and all surfaces was cons dered tobe a hazard, and permanent abatement of all

lead-based paint was deemed the only appropri-ate response. Requirements for action were lim-ited primarily to conventional public and In-

dian housing, where full abatement of alllead-based paint is completed during substantialrehabilitation or if an EBL child is identifiedHDD's 1990 Interim GuxMines. which evolvedfrom this statute, properly emphasized the dan-ger of lead-contaminated dust and the need forworker protection and thorough cleanup.

III. The Title XFramework

Title X fundamentally reorganizes the nationalapproach to controlling lead-based paint haz-ards in housing by focusing attention on lead

hazards through the establishment of new re-quirements for property owners as well as Fed-

eral agencies and mandating action to improvethe safety and effectiveness of lead-based paintactivities.

A. Definition ofPaint Hazard"

Lead-Based

Most importantly Title X redefines the conceptof "lead-based paint hazards.* Under prior Fed-eral legislation, a lead-based paint hazard wasdefined as any paint containing 1 mg/crn2 ormore of lead regardless of its condition or loca-

tion. Title X states that a lead-based paint haz-ard is 'any condition that causes exposure to

lead from lead-contaminated dust; bare, lead-contaminated soil; or lead-based paint that isdeteriorated or intact lead-based paint presenton accessible surfaces, friction surfaces, or im-

pact surfaces that would result in adverse hu-man health effects." Thus, under this definition,

intact lead-based paint on most walls and ceil-ings is not considered a 'hazard," although thecondition of the paint should be monitored and

maintained to ensure that it does not becomedeteriorated.

While most efforts to reduce lead hazards inhousing will now be aimed at controlling lead-based paint hazards as defined by Title X, Fed-eral law makes one notable exception: in publicand Indian housing, all lead-based paint mustbe abated when the housing is modernized.

B. Strategic Framework forLead Hazard Control

As shown in Figure 1.1, Title X's objective of

reducing exposures from lead-based paint haz-ards is accomplished by evaluating and control-ling lead-based paint hazards.

1. Evaluating Lead Hazards

Lead hazard evaluation may be accomplished byrisk assessment or inspection, or by a combina-

tion of the two. The combination approach re-sults in an identification of all lead-based paintand lead-based paint hazards.

1-8


Figure 1.1 Title X's Lead Hazard Control Framework.

Evaluating Lead Hazards

Risk Assessmentor

Risk AssessmentScreen

CombinationRisk

Assessment/Inspection

Inspection

Controlling Lead Hazards

Interim Controls CombinationInterim

Controls/Abatement

Abatement

"Paint inspection" is a surface-by-surface inves-

tigation of all painted surfaces—interior andexterior, in common areas of multifamily build-ings, as well as in dwelling units—using por-table x-ray fluorescence (XRF) analyzers and/or

laboratory analysis of paint samples to deter-mine the presence of lead-based paint, and theprovision of a report on the results.

Inspections to identify the presence of lead-based paint should not be confused with clear-ance examinations, risk assessments, or investi-gations of homes with lead-poisoned children.

"Risk assessment" is an onsite investigation of

a residential dwelling for lead-based paint haz-ards and includes, but may not be limited to, avisual inspection; limited environmental sam-

plings of dust, soil, and deteriorated paint; and a

report of the results that identifies acceptable

abatement: and interim control strategies for

controlling any lead-based paint hazards identi-

fied. Risk assessments and paint inspections canbe combined (see Chapters 3, 5, and 7).

2. Controlling Lead Hazards

Title X provides for three types of lead hazardcontrol: interim controls, abatement of lead-based paint hazards, and complete abatementof all lead-based paint.

"Interim controls," according to Title X, are "a

set of measures designed to reduce temporarilyhuman exposure or likely exposure to lead-based paint hazards, including specialized clean-ing (to reduce lead-contaminated dust), repairs,

maintenance, painting, temporary containment,ongoing monitoring of lead-based paint hazards

or potential hazards, and the establishment and

operation of management and resident educa-

tion programs." Interim controls include dust

1-9


Figure 1.2 Some Lead-Based Paints Had as Much as50 Percent Lead.

removal, paint film stabilization, and frictionand impact surface treatments. Interim controlsare appropriate for implementation on a broadscale and may prove cost-effective in manycases. Whenever interim controls are employed,ongoing monitoring of lead hazards must be un-dertaken by the property owner, as some poten-tial hazards are still present.

"Abatement of lead-based paint hazards," ac-cording to Title X, is "any set of measures de-signed to permanently eliminate lead-basedpaint hazards . . ." Such measures may include"(A) the removal of lead-based paint and lead-contaminated dust, the permanent containmentor encapsulation of lead-based paint, the re-placement of lead-based painted surfaces orfixtures, and the removal or covering of lead-contaminated soil; and (B) all preparation,

cleanup, disposal, and post-abatement clearancetesting activities associated with such mea-sures." Consistent with its focus on lead-basedpaint hazards, Title X has redefined the term"abatement" to mean the elimination of "lead-based paint hazards," not necessarily all lead-based paint.

"Complete abatement of lead-based paint," isthe permanent control of all lead-based paint,interior or exterior, intact or deteriorated, usingthe same methods as those included in the defi-nition of abatement of lead-based paint hazards.Title X requires complete abatement for publicand Indian housing (according to the statutoryrequirements that have been in place since1987). Specifically, all pre-1978 public and In-dian housing must be inspected, and all lead-based paint identified must be abated (notjustlead-based paint hazards). Abatement usuallyoccurs during rehabilitation or modernization.

C. Requirements To EnsureQuality Control

To ensure that lead hazard control work is car-ried out safely and effectively, Title X imposesnew requirements for consistency and qualitycontrol.

1. Training and Certification

Title X requires EPA to promulgate regulationsto ensure that all risk assessors, inspector tech-nicians, and abatement supervisors meet mini-mum training requirements and are certified byan EPA-approved State program (or by EPA inthose States that have not sought approval fortheir lead control program within 2 years afterEPA has issued its regulations). All workers andproject planners must be properly trained by anaccredited training provider. The proposedregulation can be found in the Federal Register(Vol. 59, No. 170, P. 45871 September 2, 1994).In addition, it should be noted that the Na-tional Lead Abatement Council (NLAC) isestablishing the XRF Operators Registry forinspectors who use the XRF instrument.

1-10


2. Accreditation of TrainingProviders

Lead-based paint-related training must be pro-vided by a training program that has been for-mally accredited either by EPA or by an EPA-approved State program. EPA has developed oris developing model training courses for inspec-tor technicians, abatement supervisors, abate-ment workers, and risk assessors, and is estab-lishing minimum national criteria for trainingproviders. Also, in an effort to build a nationalnetwork of training providers, EPA has pro-vided "seed" money grants to five university-based training centers (see Chapter 2).

3. Health-Based Standards

Consistent criteria must be used for identifyinglead-based paint hazards and triggering lead haz-ard control action. Title X directs EPA to iden-tify dangerous levels of lead in soil, dust, andexisting paint films.

4. Performance Standards for Testingand Abatement Products

Title X also requires that appropriate criteria,testing protocols, and performance characteris-tics be developed for lead-based paint testingand abatement products. It is expected thatthese standards will be developed jointly byHUD and EPA, with technical support from theNational Institute for Standards and Technol-ogy (NIST). Private-sector organizations suchas the American Society for Testing and Mate-rials (ASTM) may also play a role in developingsuch standards.

5. Laboratory Accreditation

Laboratories analyzing environmental samplesof lead in paint film, dust, and soil must followestablished protocols and procedures and be ac-credited through the EPA National Lead Labo-ratory Accreditation Program (NLLAP). Suchlaboratories will become "EPA recognized."Property owners, risk assessors, inspector tech-nicians, and contractors should ensure thatlaboratory analyses are performed by an "EPA-recognized" laboratory.

D. State and Local Regulations

If there is a difference between Federal, State,or local regulations, the more stringentrequirements must be observed in any givenjurisdiction.

IV. Organization and Useof the Guidelines

Evaluation and control of lead-based paint haz-ards is an evolving field. For cases in which re-search has demonstrated that certain tech-niques are appropriate, references are cited. Insome cases, there has been no research donethat clearly describes the best approach to solv-ing a specific problem. Recognizing that prob-lems require answers, these Guidelines offer ad-vice based on the experience and consideredjudgment of the authors and reviewers. Forcases in which citations are not provided, thereader should assume that the source of the ad-vice is anecdotal and is the best advice thatHUD can provide at this time. Those referencesthat are unpublished are available through theEPA National Lead Information Center (seeChapter 2).

A. Chapter Organization

A short summary of steps is provided at the be-ginning of each technical chapter to alert thereader to especially critical points and actionsteps. In general, the material is presented ineach chapter in order of sequence in a typicalproject; however, a complete reading and un-derstanding of these Guidelines is essential be-fore any project is undertaken. Wherever pos-sible, the Guidelines explain the rationale forrecommendations and provide a technicaldescription of the action to be taken.

1. Chapters1-4: BackgroundInformation

Understanding the background material is criti-cal to the successful completion of any project.Chapter! ("Introduction") describes the pur-pose and application of the Guidelines; brieflyreviews the hazards of lead-based paint in

1-11


housing; summarizes major departures from pastapproaches; and provides context in terms ofFederal law, regulations, and agency programs.Chapter 2 ("Where to Go lor Help") introducesthe types of individuals involved in evaluatingand controlling lead-based paint hazards inhousing, explains their roles, and summarizestheir qualifications. Chapter 3 ("Before You Be-gin the Project") identifies the critical issuesthat must be examined to avoid problems andmistakes that can result in project delays andcost overruns. Chapter4 ("Renovation andLead-Based Paint") provides general advice onhow to carry out work in older housing so thatlead hazards are not inadvertently created (e.g.,by disturbing lead-based paint) and how tocombine renovation with abatement work.

2. Chapters 5-7: Hazard Evaluation

Hazard evaluation helps to ensure the selectionof the safest and most cost-effective hazard con-trol strategy for each situation. Chapter 5 ("RiskAssessment") provides detailed guidance onhow risk assessments are to be conducted invarious categories of housing, including proto-cols for environmental sample collection andinterpretation, evaluation of building and paintcondition, and methods for sampling a subset ofunits in multifamily buildings. Chapter 6 ("On-going Monitoring") describes how reevaluationsare to be performed and provides detailedschedules for when they are needed. Chapter 7("Paint Inspection") provides detailed informa-tion on methods for testing housing to deter-mine the presence of lead-based paint on asurface-by-surface basis, including the use ofportable XRF analyzers and paint-chip samplingfor laboratory analysis.

3. Chapters 8-10: Preparation forthe Project

The critical steps in preparing to control lead-based paint hazards are covered in Chapters 8-10. Chapter 8 ("Occupant Protection and Con-tainment") provides guidance on the stepsneeded to ensure that occupants are not endan-gered and that contamination is not spread.Chapter 9 ("Worker Protection") provides

detailed advice on how to comply with theOSHA Lead in Construction Standard whileperforming work in housing. Chapter 10 ("Haz-ardous and Nonhazardous Waste") provides de-tailed, practical advice on methods for segregat-ing, handling, and disposing various kinds ofdebris to protect the environment and meethazardous waste requirements at the lowest cost.

4. Chapters 11-15: Hazard Control,Cleanup, and Clearance

Detailed information on how to carry out allaspects of lead hazard control is provided inChapters 11-15. Chapter 11 ("Interim Con-trols") provides specific guidance on interimcontrols: general principles of interim controls,dust removal, paint film stabilization, frictionsurface treatments, and soil and exterior dusttreatments. Chapter12 ("Abatement") coversgeneral principles of abatement such as compo-nent replacement, enclosure, paint removalmethods, and soil abatement. Chapter 13 ("En-capsulation") describes how to use encapsulantsand the status of such products pending the de-velopment of performance standards pursuantto Title X. Chapter 14 ("Cleanup") detailscleanup procedures for lead hazard controlprojects. Chapter 15 ("Clearance") explainshow to conduct clearance tests after a lead haz-ard control project to ensure that a unit or areais safe for reoccupancy.

5. Chapters 16-18: Other IssuesInformation on addressing lead-based paint haz-ards in special situations is provided in the finalchapters of these Guide//nes. Chapter 16("Evaluation of Houses With Lead-PoisonedChildren") describes the special measures thatare usually taken by health department staff andothers to investigate environmental lead haz-ards once a child has been identified as poi-soned. Chapter 17 ("Maintenance") addressesthe range of issues related to lead-based paint asit is encountered in the course of routine main-tenance work. Chapter 18 ("Historic Preserva-tion") discusses the special situations and issuessurrounding lead-based paint in historicdwellings.

1-12


6. Glossary and Appendixes

The definitions of key terms are consolidated inthe glossary and deserve special attention be-cause the meanings of several key terms (such as"abatement") differ from common usage. Theappendixes provide detailed background infor-mation and technical materials.

B. Units of Measurement

4 ng/ft2—micrograms per square foot.

4- ppm—parts per million by weight (10,000ppm = 1 percent), equivalent to ng/g.

4- ppb—parts per billion by weight (1,000ppb = 1 ppm).

4 |jg/g—micrograms per gram of sample,equivalent to ppm by weight.

4 percent—percent by weight, used usually forpaint (1 percent = 10,000 ng/g).

4- mg/cm2—milligrams per square centimeter,used for paint.

4 ^g/m3—micrograms per cubic meter, usedfor air.

4- ng/dl_—micrograms per deciliter, used forblood.

C. Federal Lead Standards

If Federal standards differ from State and localstandards, the most stringent standards must beapplied.

1. Paint

4 1.0 mg/cm2 or 5,000 ng/g (0.5 percent).

2. Leaded Dust Levels for RiskAssessments (by wipe sampling)

4 100 ng/ft2—floors (carpeted anduncarpeted).

4 500 ng/ft2—interior window sills.

4 800 ng/ft2—window troughs (previouslycalled "window wells" in the literature).

3. Dust Levels for Lead HazardScreen Only

4 50 ng/ft2—floors.

4 400 ng/ft2—window troughs.

4. Leaded Dust Clearance Levels(by wipe sampling)

4- 100 ng/ft2—floors (includes carpeted anduncarpeted floors).

4 500 ng/ft2—interior window sills.

4 800 ng/ft2—window troughs (previouslycalled "window wells" in the literature).

4 800 ng/ft2—exterior concrete surfaces.

5. Bare Residential Soil

4 5,000 ng/g—paving or removal criteria.

4 2,000 ng/g—building perimeter and yard.

4- 400 ng/g—play areas and high-contact areasfor children.

6. Airborne Lead Paniculate

4 30 ng/m3—OSHA action level (8-hour,time-weighted average).

4 50 ̂ g/m3—OSHA permissible exposurelimit (8-hour, time-weighted average).

7. Elevated Blood Lead Level

4 20 (.ig/dL (or 15-19 ng/dl_ in two consecu-tive samples taken several months apart)—CDC environmental intervention level forindividual child.

8. Waste

4 5 ppb (parts per billion) by TCLP test.

1-13

* *CHAPTER 14: CLEANINGStep-by-Step Summary ' 14-3

I. Introduction 14-5

A. Performance Standard 14-5

B. Small Dust Particles 14-5

C. Difficulties in Cleaning 14-5

1. Low Clearance Standards 14-5

2. Worker Inexperience 14-6

3. High Dust-Producing Methods and/or Inadequate Containment 14-6

4. Deadlines 14-6

II. Coordination of Cleaning Activities 14-6

A. Checklist 14-6

B. Equipment Needed for Cleaning 14-6

C. Waste Disposal 14-7

III. Cleaning Methods and Procedures 14-7

A. Containment 14-7

B. Basic Cleaning Methods: Wet Wash and VacuumCleaning Techniques 14-7

1. HEPA Vacuuming 14-7

2. Wet-Detergent Wash 14-9

3. The HEPA/Wet Wash/HEPA Cycle 14-11

4. Sealing Floors 14-16

IV. Order of Cleaning Procedures During Lead Hazard Control 14-16

A. Precleaning Procedures 14-16

B. Ongoing Cleaning During the Job 14-18

C. Daily Cleaning Procedures 14-18

1. Large Debris 14-18

2. Small Debris 14-18

3. Exterior Cleaning 14-18

4. Worker Protection Measures 14-19

5. Maintaining Containment 14-19

14-1

Chapter 14: Cleaning

V. Order of Final Cleaning Procedures AfterLead Hazard Control 14-19

A. Final Cleaning 14-19

1. Decontamination of Workers, Supplies, and Equipment 14-19

B. Preliminary Visual Examination 14-20

C. Surface Painting or Sealing of Nonfloor Surfaces 14-20

D. Final Inspection 14-20

E. Recleaning After Clearance Failure 14-20

VI. Cleaning Cost Considerations 14-21

A. Initial Clearance' Test Failure Rates 14-21

B. Key Factors In Effective Cleaning 14-21

C. Special Problems 14-21

VII. Alternative Methods 14-22

A. Vacuums 14-22

B, Trisodium Phosphate and Other Detergents 14-22

14-2

Step-by-Step Summary

Cleaning; How To Do It1. Include step-by-step procedures for precleaning, cleaning during the job, and daily and final cleanings in

project design or specifications.

2. Assign responsibilities to specific workers for cleaning and for maintaining cleaning equipment.

3. Have sufficient cleaning equipment and supplies before beginning work.

4. If contamination is extensive, conduct precleaning of the dwelling unit. Move or cover all furnitureand other objects.

5. Conduct ongoing cleaning during the job, including regular removal of large and small debris and dust.Decontamination of all tools, equipment, and worker protection gear is required before it leaves contain-ment areas. Electrical equipment should be wiped and high-efficiency particulate air (HEPA) vacuumed,not wetted down, to minimize electrocution hazards.

6. Schedule sufficient time (usually 30 minutes to an hour) for a complete daily cleaning, starting at the sametime near the end of each workday after lead hazard control activity has ceased.

7. For final cleaning, wait at least 1 hour after active lead hazard control activity has ceased to let dustparticles settle.

8. Use a vacuum cleaner equipped with a HEPA exhaust filter. HEPA vacuum all surfaces in the room(ceilings, walls, trim, and floors). Start with the ceiling and work down, moving toward the entry door.Completely clean each room before moving on.

9. Wash all surfaces with a lead-specific detergent, high-phosphate detergent, or other suitable cleaningagent to dislodge any ground-in contamination, then rinse. Change the cleaning solution after everyroom is cleaned.

10. Repeat step 8. To meet clearance standards consistently, a HEPA vacuum, wet wash, and HEPA vacuumcycle is recommended. For interim control projects involving dust removal only, the final HEPA vacuum-ing step is usually not needed (see Chapter 11). Other cleaning methods are acceptable, as long as clear-ance criteria are met and workers are not overexposed.

11. After final cleaning, perform a visual examination to ensure that all surfaces requiring lead hazard controlhave been addressed and all visible dust and debris have been removed. Record findings and correct anyincomplete work. This visual examination should be performed by the owner or an owner's representativewho is independent of the lead hazard control contractor.

12. If other construction work will disturb the lead-based paint surfaces, it should be completed at this point.If those surfaces are disturbed, repeat the final cleaning step after the other construction work has beencompleted.

13. Paint or otherwise seal treated surfaces and interior floors.

14. Conduct a clearance examination (see Chapter 15).

15. If clearance is not achieved, repeat the final cleaning.

14-3

Step-by-Step Summary (continued)

16. Continue clearance testing and repeated cleaning until the dwelling achieves compliance with all clear-ance standards. As an incentive to conduct ongoing cleaning and a thorough final cleaning, the cost of repeatedcleaning after failing to achieve clearance should be borne by the contractor as a matter of the job specifica-tion, not the owner.

17. Do not allow residents to enter the work area until cleaning is completed and clearance is established.

18. Cleaning equipment list:

4- HEPA vacuums.

+ Detergent.

4- Waterproof gloves.

4- Rags.

+ Sponges.

4- Mops.

4 Buckets.

4^ HEPA vacuum attachments (crevice tools, beater bar for cleaning rugs).

4 6-mil plastic bags.

4 Debris containers.

4 Waste water containers.

4 Shovels.

4 Rakes.

4 Water-misting sprayers.

4 6-mil polyethylene sheeting (or equivalent).

14-4

Chapter 14: fI waningI. Introduction

This chapter describes cleaning procedures to

be employed following abatement and interim

control work. Dust removal as an interim con-

trol measure is covered in Chapter 11.

All lead hazard control activities can produce

dangerous quantities of leaded dust. Unless this

dust is properly removed, a dwelling unit will

be more hazardous after the work is completed

than it was originally. Once deposited, leaded

dust is difficult to clean effectively. Whenever

possible, ongoing and daily cleaning of leaded

dust during lead hazard control projects is rec-

ommended. Ongoing and daily cleaning is also

necessary to minimize worker exposures.

Cleaning is the process of removing visible de-

bris and dust particles too small to be seen by

the naked eye. Removal of lead-based paint

hazards in a dwelling unit will not make the

unit safe unless excessive levels of leaded dust

are also removed. This is true regardless of

whether the dust was present before or gener-

ated by the lead hazard control process itself.

Improper cleaning can increase the cost of a

project considerably because additional clean-

ing and clearance sampling will be necessary.

However, cleaning and clearance can be

achieved routinely if care and diligence

are exercised.

A. Performance Standard

Although the cleaning methods described in

this chapter are feasible and have been shown

to be effective in meeting clearance standards,

other methods may also be used if they are

safe and effective. This performance-oriented

approach should stimulate innovation, reduce

cost, and ensure safe conditions for both resi-

dents and workers.

B. Small Dust Particles

Dust particles that are invisible to the naked

eye remain on surfaces after ordinary cleaning

procedures. A visibly clean surface may contain

high and unacceptable levels of dust particles

and require special cleaning procedures.

C. Difficulties in Cleaning

While cleaning is an integral and essential com-

ponent of any lead hazard control activity, it is

also the most likely part of the activity to fail.

Several common reasons for this failure include

low clearance standards, worker inexperience,

high dust-producing methods, and deadlines.

1. Low Clearance Standards

Because very small particles of leaded dust are

easily absorbed by the body when ingested or

inhaled, a small amount can create a health haz-

ard for young children. Therefore, "clearance

standards" are extremely low for acceptable lev-

els of leaded dust particles on surfaces after haz-

ard control activities, and careful cleaning pro-

cedures are required. Although it is not possible

to remove all leaded dust from a dwelling, it is

possible to reduce it to a safe level.

Clearance standards are described more fully in

Chapter 15. The permissible amount of leaded

dust remaining on each of the following surfaces

following lead hazard work is as follows:

•*• 100 ng/ft2 on floors.

+ 500 ng/ft2 on interior window sills (stools).

+ 800 ng/ft2 on window troughs (the area

where the sash sits when closed).

+ 800 jig/ft2 on exterior concrete.

These levels are based on wipe sampling.

Clearance testing determines whether the pre-

mises or area are clean enough to be reoccu-

pied after the completion of a lead paint haz-

ard control project. A cleaned area may not

be reoccupied until compliance with clearance

standards has been established. To prevent de-

lays, final testing and final cleaning activities

should be coordinated.

14-5


2. Worker Inexperience

To understand the level of cleanliness required

to meet the established clesirance standards for

hazard control cleanup, new hazard control per-

sonnel often require a significant reorientation

to cleaning. Many construction workers are

used to cleaning up only dust that they can

see, not the invisible dust particles that are also

important to remove.

3. High Dust-Producing Methodsand/or Inadequate Containment

High dust-generating methods, inadequate con-

tainment during hazard control work, and poor

work practices can all make achievement of

clearance particularly difficult. Work practices

necessary to prevent spreading of dust through-

out a dwelling (e.g., by trac<ing dust out of

work areas) are essential but sometimes tedious.

Essential work practices are sometimes mis-

takenly considered to be "flexible guidelines"

rather than necessary standards that are de-

signed to ensure that thejoo is completed, not

only safely, but also on time and within budget.

4. Deadlines

Daily and final cleanings hcive sometimes

been compromised due to project deadlines,

since cleaning comes at the end of the job.

Hurried efforts often result n clearance fail-

ure. Delayed and over-budget hazard control

projects are often the result of repeated, un-

planned recleanings that ans necessitated by

inadequate containment and sloppy work

practices.

II. Coordination ofCleaning Activities

A. Checklist

The owner or contractor may use the following

cleaning checklist before any lead hazard con-

trol activity:

•/ Is the critical importance of cleaning in

a hazard control project understood?

•/ Have all workers been trained and certified

for hazard control work?

•J Have the precleaning, daily, and final

cleanings been scheduled properly and

coordinated with the other participants

in the hazard control process?

J Have cleaning equipment and materials

been obtained?

•/ Do the workers know how to operate and

maintain special cleaning equipment, and

do they have directions for the proper use

of all cleaning materials?

J Have all workers carefully studied the

step-by-step procedures for precleaning

(if needed), in-progress cleaning, and

daily and final cleanings?

•/ Are all workers properly protected during

the cleaning processes (see Chapter9)?

J Have provisions been made to properly

contain and store potentially hazardous

debris (see Chapter 10)?

J Have dust-clearance testing and related

visual inspections been arranged (see

Chapter 15)?

•/ Are the clearance criteria to be met fully

understood?

J Have all appropriate surfaces been properly

painted or otherwise sealed?

•/ Have appropriate records been maintained

that document participants' roles in the

hazard control project?

B. Equipment Needed forCleaning

The following equipment is needed to con-

duct cleaning: high-efficiency particulate air

(HEPA) vacuums and attachments (crevice

tools, beater bar for cleaning rugs), detergent,

waterproof gloves, rags, sponges, mops, buckets,

6-mil plastic bags, debris containers, waste wa-

ter containers, shovels, rakes, water-misting

sprayers, and 6-mil polyethylene plastic sheet-

ing (or equivalent).

14-6


C. Waste Disposal

Regulations governing hazardous and nonhaz-

ardous waste storage, transportation, and dis-

posal affect both the daily and final cleaning

procedures. The hazard control contractor and

the disposal contractor should work together to

establish formal written procedures, specifying

selected containers, storage areas, and debris

pickups, to ensure that all relevant regulations

are met.

III. Cleaning Methods andProcedures

Many of the special cleaning methods and

procedures detailed in this chapter are not

standard operating procedure for general home

improvement contractors. Therefore, project

designers, responsible agencies, or owners must

ensure that contractors follow the methods and

procedures recommended herein or specially

designed alternative procedures, even though

some may appear to be redundant and unneces-

sary. These methods have been shown to be

feasible and effective in many situations and

skipping steps in the cleaning procedures can

be counterproductive.

A. Containment

Because of the difficulty involved in the re-

moval of fine dust, dust generated by hazard

control work should be contained to the

extent possible to the inside of work areas.Inadequately constructed or maintained con-

tainment or poor work practices will result in

additional cleaning efforts, due to dust that

has leaked out or been tracked out of the work

area (see Chapter 8).

B. Basic Cleaning Methods:Wet Wash and VacuumCleaning Techniques

Because leaded dust adheres tenaciously, espe-

cially to such rough or porous materials as

weathered or worn wood surfaces and masonry

surfaces (particularly concrete), workers should

be trained in cleaning methods. As a motivator,

some contractors have awarded bonuses to

workers who pass clearance the first time.

Two basic cleaning methods have proven effec-

tive, when used concurrently, in lead-based

paint hazard control projects: a special vacuum

cleaner equipped with a HEPA exhaust filter,

followed by wet washing with special cleaning

agents and rinsing, followed by a final pass with

the HEPA vacuum.

Although HEPA filtered vacuums and triso-

dium phosphate (TSP) cleaners have been

considered the standard cleaning tools for lead

hazard control projects, new research, discussed

under the "Alternatives Methods" section in

this chapter, suggests that other tools and prod-

ucts may also be effective in efficiently cleaning

dust while providing adequate worker protec-

tion from airborne exposure risks. Some of these

innovations may even be superior.

1. HEPA VacuumingHEPA vacuums differ from conventional vacu-

ums in that they contain high-efficiency filters

that are capable of trapping extremely small,

micron-sized particles. These filters can remove

particles of 0.3 microns or greater from air at

99.97 percent efficiency or greater. (A micron

is 1 millionth of a meter, or about 0.00004

inches.) Some vacuums are equipped with an

ultra-low penetration air (ULPA) filter that is

capable of filtering out particles of 0.13 microns

or greater at 99.9995 percent efficiency. How-

ever, these ULPA filters are slightly more ex-

pensive, and may be less available than HEPA

filters.

Vacuuming with conventional vacuum ma-

chines is unlikely to be effective, because much

of the fine dust will be exhausted back into

the environment where it can settle on surfaces.

A recent Canadian study revealed that fine-

dust air levels were exceedingly high when a

standard portable vacuum with a new bag was

used, although partially filled bags were found

to be more efficient (CMHC, 1992). Consider-

ations for the proper use of a HEPA vacuum

are listed below.

14-7


Operating Instructions

There are a numerous manufacturers of HEPA

vacuums. Although all HEPA vacuums operate

on the same general principle, they may vary

considerably with respect to specific procedures,

such as how to change the filters. To ensure the

proper use of equipment, the manufacturer's

operating instructions should be carefully fol-

lowed and if possible, training sessions arranged

with the manufacturer's representative.

Although HEPA vacuums have the same "suc-

tion" capacity as ordinary vacuums that are

comparably sized, their filters are more efficient.

Improper cleaning or changing of HEPA filters

may reduce the vacuum's suction capability.

Special Attachments

Because the HEPA vacuum will be used to

vacuum surfaces other than floors, operators

should buy attachments and appropriate tool

kits for use on different surfaces—such as

brushes of various sizes, crevice tools, and

angular tools.

Selecting Appropriate Size(s)

HEPA vacuums are available in numerous sizes,

ranging from a small lunchbucket-sized unit

to track-mounted systems. Two criteria for size

selection are the size of the job and the type

of electrical power available. Manufacturer

recommendations should be followed.

Wet-Dry HEPA Vacuums

Some hazard control contractors have found

the wet-dry HEPA vacuums to be particularly

effective in meeting clearance standards. These

vacuums are equipped with a special shut-off

float switch to protect the electrical motor

from water contact.

Prefilters

HEPA filters are usually used in conjunction

with a prefilter or series of prefilters that trap

the bulk of the dust in the exhaust airstream,

particularly the larger particles. The HEPA fil-

ter traps most of the remaining small particles

that have passed through the prefilter(s). All

filters must be maintained and replaced or

cleaned as specified in the manufacturer's

instructions. Failure to do so may cause a re-

duction in suction power (thus reducing the

vacuum's efficiency and effectiveness). Failure

to change prefilters may damage the vacuum

motor and will also shorten the service life of

the HEPA filter, which is far more expensive

than the prefilters.

HEPA Vacuuming Procedures

Surfaces frequently vacuumed include ceilings,

walls, floors, windows, interior and exterior sills,

doors, heating, ventilation, and air conditioning

(HVAC) equipment (heating diffusers, radia-

tors, pipes, vents), fixtures of any kind (light,

bathroom, kitchen), built-in cabinets, and

appliances.

To aid in dislodging and collecting deep dust

and lead from carpets, the HEPA vacuum must

be equipped with a beater bar (agitator head)

that is fixed to the cleaning head. This bar

should be used on all passes on the carpet face

during dry vacuuming (see Chapter 11 for

details on carpet and furniture cleaning).

All rooms and surfaces should be included in

the HEPA vacuum process, except for those

that (1) were found not to have lead-paint

hazards and were properly separated from work

areas before the process began (see Chapter 8),

or (2) were never entered during the process.

Porches, sidewalks, driveways, and other exte-

rior surfaces should be vacuumed if exterior haz-

ard control work was conducted, or if debris was

stored or dropped outside. Vacuuming should

begin on the ceilings and end on the floors, se-

quenced to avoid passing through rooms already

cleaned, with the dwellings' entryway cleaned

last.

Emptying the HEPA Vacuum

Used filters and vacuumed debris are potentially

hazardous waste and should be treated accord-

ingly (see ChapterlO). Therefore, operators

should use extreme caution when opening the

HEPA vacuum for filter replacement or debris

removal to avoid accidental release of accumu-

lated dust into the environment. This may oc-

cur, for example, if the vacuum's seal has been

broken and the vacuum's bag is disturbed.

14-8


Figure 14.1 a Vacuum With a HEPA Filter.

1.HEPA filter

2. Main filter

3. Prefilter

Pressuregauge

Parts of a HEPA-vacuumMost HEPA-vacuums have threefilters: HEPA filter, main filter, and pre-filter. Debris gets sucked in throughthe hose into the vacuum bag. The airand dust get filtered through the pre-filter, the main filter, and the HEPAfilter. The HEPA filter captures the leaddust before the air is released into thework area again.

Operators should also wear a full set of protec-

tive clothing and equipment, including appro-priate respirators, when performing this mainte-nance function, which should be done in the

containment area or offsite.

2. Wet Detergent Wash

Several types of detergents have been usedto remove leaded dust. Those with a high-

phosphate content (containing at least 5percent trisodium phosphate, also known asTSP) have been found to be effective whenused as part of the final cleaning process(Milar, 1982). TSP detergents are thought towork by coating the surface of dusts with phos-phate or polyphosphate groups which reduceselectrostatic interactions with other surfaces

and thereby permits easier removal. Becauseof environmental concerns some States haverestricted the use of TSP, and some manufac-turers have eliminated phosphates from theirhousehold detergents. However, high-TSP

detergents can usually be found in hardwarestores and may be permitted for limited use,

such as lead hazard control.

Other non-TSP cleaning agents developed

specifically for removing leaded dust havealso been found to be effective (possibly more

effective than TSP) in limited trials by several

Pressuregauge

Figure 14.1b Pressure Gauge Indicator ShowsWhen Filters Require Changing.

14-9

Chcipter 14: Cleaning

Figure 14.2 HEPA Vacuum Sizes and Tools.

investigators (Grawe, 1993; Wilson, 1993) andmay also be safer, since TSP is a skin and eyeirritant. See section VII for more informationon non-TSP detergents. Proper procedures forusing high-phosphate detergents also apply tomost other types of detergents and include thefollowing steps:

Manufacturer's Dilution Instructions

Users of cleaning agents for leaded dust re-moval should follow manufacturer's instruc-tions for the proper use of a product, especiallythe recommended dilution ratio. Even diluted,trisodium phosphate is a skin irritant and usersshould wear waterproof gloves. Eye protectionshould also be worn, and portable eyewashfacilities should be located in or very near thework area. Consult manufacturer's directionsfor the use of other detergents.

Appropriate Cleaning Equipment

Because a detergent may be used to clean leadeddust from a variety of surfaces, several types ofapplication equipment are needed, includingcleaning solution spray bottles, wringer buckets,mops, variously sized hand sponges, brushes,

and rags. Using the proper equipment on eachsurface is essential to the quality of the wet-wash process.

Proper Wet-Cleaning Procedures

At the conclusion of the active lead hazard con-trol process and the initial HEPA vacuuming,all vacuumed surfaces should be thoroughly andcompletely washed with a high-phosphate solu-tion or other lead-specific cleaning agent (orequivalent) and rinsed. Select a detergent thatdoes not damage existing surface finishes (TSPmay damage some finishes). Work should pro-ceed from ceilings to floors and sequenced toavoid passing through rooms already cleaned.

Changing Cleaning Mixture

Many manufacturers of cleaners will indicatethe surface area that their cleaning mixture willcover. To avoid recontaminating an area bycleaning it with dirty water, users should followmanufacturer-specified surface-area limits.However, regardless of manufacturers' recom-mendations, the cleaning mixture should bechanged after its use for each room. As a ruleof thumb, 5 gallons should be used to clean no

14-10


Figure 14.3 Goggles, Face Shields, Gloves, and Eye Wash Facilities Should Be AvailableWhen Used With Chemicals Such as TSP.

EMERGENCY EYEWASH STATION

Latex Neoprene Nitrile

more than 1,000 square feet. Used cleaningmixture is potentially hazardous waste (seeChapter 10); consult with your local waterand sewage utility for directions on its properdisposal. Wash water should never be pouredonto the ground. The wash water is usuallyfiltered and then poured down a toilet (if thelocal water authority approves).

3. The H EPA/Wet Wash/HEPA Cycle

Typical Procedures

The usual cleaning cycle that follows leadhazard control activities is called the HEPAvacuum/wet wash/HEPA cycle and is appliedto an entire affected area as follows:

•*• First, the area is HEPA vacuumed.

14-11


Figure 14.4a The HEPA Vacuum, Wet Wash, HEPA VacuumCycle Helps in Meeting Clearance Standards.

HEPA vacuum all surfacesStart at the end farthest from themain entrance/exit. As you vacuum,move towards the main exit andfinish there.

Begin at the top of each room andwork down. For example, start withthe top shelves, the top of the wood-work, and so on, and work down tothe floor. Do every inch of the win-dows, especially the window troughs.

Courtesy: Alice Hamilton Occupational Health Center

14-12


+ Next, the area is washed down.

•*• After drying, the area is again HEPAvacuumed.

The rationale for this three-pass system is asfollows:

+ The first HEPA vacuum removes as muchdust and remaining debris as possible.

4- The wet wash further dislodges dust fromsurfaces.

+ The final HEPA cycle removes any remain-ing particles dislodged but not removed bythe wet wash.

Single-Pass Wet Wash/HEPA Vacuum

Some lead hazard control contractors havefound HEPA spray cleaner vacuums to be acost-effective alternative to the three-pass sys-tem. Similar to home carpet-cleaning machines,these vacuums simultaneously deliver a solutionto the surface and recover the dirty solution.Theoretically, this process combines two of thesteps in the HEPA vacuum/wet wash/HEPAcycle into one step. While anecdotal evidenceindicates that the spray cleaner wet wash/HEPAis effective for some uses, limitations have beennoted in its use for ceilings, vertical surfaces,and hard to reach areas. This device may beused as long as clearance standards are met.

Figure 14.4b (continued)

Use special attachmentsUse the rubber cone where the floormeets the baseboard and along allthe cracks in the floor boards. Usethe brush tool for walls and woodwork.

Use the wheeled floor nozzle for barefloors and the carpet beater for rugs.

Move slowlyVacuum slowly so the HEPA vacuumcan pick up all the lead dust.

Rubber Cone Dust Brush

Powered Carpet Beater

Wheeled Floor Nozzle

14-13


Figure 14.4c (continued)

Wash all surfaces with suitabledetergentsWash all surfaces in the work areawith suitable detergents, includingareas that had been covered withplastic. Some wallpaper should onlybe HEPA vacuumed, since it maybe damaged by the detergent.

Wipe All Surfaces

Wet Mop Floor Don't Dry Sweep

14-14


Figure 14.4c (continued)

Use the 3-Bucket System.

To wash: Use string mops and mopbuckets with wringers. (Some expertssay NEVER use a sponge mop on thefloor. Sponge mops may only push thelead around on the floor, not remove it.)

Dip the string mophead in the detergentwash in bucket #1. Mop the floor.

Squeeze out the mophead in emptybucket #2. Return to bucket #1 for moredetergent solution and continue moppingRepeat.

Use the third bucket for rinsing the floor.

14-15


Figure 14.4d (continued)

HEPA vacuum all surfaces a fina timeHEPA vacuum all surfaces in the workarea, including areas that had been cov-ered with plastic.

Starting at the far end, work towards thedecontamination area. Begin with ceilingsor the top of the walls and work down,cleaning the floors last. Do every inch ofthe windows, especially the troughs;. Usethe corner tool to clean where the floormeets the baseboard and all the cracks inthe floor boards. Use the brush tool for thewalls. Move slowly and carefully to getall the dust.

4. Sealing Floors

Before clearance, all floors without an intact,

nonporous coating should be coated. Sealed

surfaces are easier for residents to clean and

maintain over time than those that are notsealed. Wooden floors shou d be sealed with aclear polyurethane or painted with deck enamel

or durable paint. Vinyl tile, linoleum, and othersimilar floors should be sealad with an appropri-ate wax. Concrete floors should be sealed witha concrete sealer or other type of concrete deckenamel. However, if these floors are alreadycovered by an effective coal of sealant, it maybe possible to skip this step.

As an alternative to sealing, floors may be cov-

ered with new vinyl tile, sheet vinyl, linoleum

flooring, or the equivalent to create a more per-

manent cleanable surface. New surfaces should

be cleaned with a cleaning solution that is ap-

propriate for that type of surface.

IV. Order of CleaningProcedures During LeadHazard Control

The special cleaning procedures to be followedduring a lead-based paint hazard control projectare discussed in chronological order below.Skipping steps in the process may result in fail-ure to meet post-lead hazard control clearancestandards.

A. Precleaning Procedures

Precleaning (i.e., cleaning conducted beforelead hazard control is begun) is necessary only

in dwelling units that are heavily contaminated

with paint chips. Precleaning involves the re-

moval of large debris and paint chips, followed

by HEPA vacuuming. These steps may be fol-

lowed by removal of occupant personal posses-

sions, furniture, or carpeting, depending on the

14-16


Figure 14.5 Single-Pass HEPA Vacuum/Wet Wash Technology.

Wet HEPA Vacuum

Cleaning AgentContainer

Cleaning AgentDispenser andVacuum Nozzle

Worksite Preparation Level selected (see Chap-ter 8). If the furniture will not be cleaned, itshould be removed from the area or coveredwith plastic prior to beginning the precleaningprocedure. Carpeting should always be mistedbefore its removal to control the generation ofhazardous dust.

It is usually the resident's responsibility to re-move most of his or her personal possessions.However, if necessary, owners or project man-agement should be prepared to complete thisactivity before lead hazard control work begins.As a last resort, the contractor may pack anyremaining belongings and carefully seal andmove the boxes, supplying all necessary boxes,packing materials, and staff to complete thetask. Following cleaning and clearance, thecontractor should return all packed items totheir appropriate places. Leaving these tasksto the contractor may be expensive and ineffi-cient, since the contractor will need to beinsured for this function if the occupant's

Figure 14.6 Precleaning Is Needed in Areas WhereContamination and Deterioration Are High.

14-17

•I* Chapter 14: Cleaning

belongings are damaged. Additionally, moving

furniture, rugs, drapes, and other items owned

by the occupant could increase leaded dust lev-

els. Clearance should be conducted after clean-

ing but before resident items are moved back in.

B. Ongoing Cleaning Duringthe Job

Periodic HEPA vacuuming during the lead haz-

ard control work may be necessary to minimize

tracking of dust and paint chips from one area

to another (e.g., when a lanje amount of paint

chips or dust is being generated).

C. Daily Cleaning Procedures

Cleaning activity should be scheduled at the

end of each workday when all active lead haz-

ard control throughout the dwelling has ceased.

Sufficient time must be allowed for a thorough

and complete cleaning (usually about 30 min-

utes to an hour). Daily clea ling helps achieve

clearance dust levels by minimizing problems

that may otherwise occur during final cleaning

and limiting worker exposures. While daily

cleaning can be skipped in vacant dwelling

units, it is required when occupants will

Figure 14.7 Plastic Sheeting Should Be Repaired as Part ofDaily Cleanup.

return in the evening. Under no circumstances

should debris or plastic be left outside overnight

in an unsecured area, even if the dwelling is

vacant. Daily cleaning should consist of:

•*• Removing large debris.

+ Removing small debris.

+ HEPA vacuuming, wet clean, HEPA

vacuuming (horizontal surfaces only).

+ Cleaning exterior.

+ Patching and repairing plastic sheeting.

4- Securing debris/plastic.

1. Large Debris

Large demolition-type debris (e.g., doors, win-

dows, trim) should be wrapped in 6-mil plastic,

sealed with tape, and moved to a secure area on

the property designated for waste storage. All

sharp corners, edges, and nails should be ham-

mered down to prevent injury and minimize

the tearing of plastic. It is not necessary to wrap

each individual piece of debris in plastic if the

entire load can be wrapped. A secure area either

outside or inside the property must be desig-

nated as a temporary waste-storage area. Cov-

ered, secured, and labeled dumpsters placed on

or near the property may be used. Proper segre-

gation of waste should be enforced at this time

(see Chapter 10).

2. Small Debris

After being misted with water, small debris

should be swept up, collected, and disposed

of properly. The swept debris should be placed

in double 4-mil or single 6-mil polyethylene

(or equivalent) plastic bags, properly sealed,

and moved to the designated trash storage area.

Trash bags should not be overloaded; over-

loaded bags may rupture or puncture during

handling and transport.

3. Exterior Cleaning

Areas potentially affected by exterior lead haz-

ard control should be protected via a contain-

ment system (see Chapter 8). Because weather

can adversely affect the efficacy of exterior

14-18


containment, the surface plastic of the contain-ment system should be removed at the end ofeach workday. On a daily basis, as well as duringfinal cleaning, the immediate area should beexamined visually to ensure that no debris hasescaped containment. Any such debris shouldbe raked or vacuumed and placed in single 6-mil or double 4-mil plastic bags, which shouldthen be sealed and stored along with other con-taminated debris. HEPA vacuuming is appropri-ate for hard exterior surfaces, not soil.

4. Worker Protection Measures

General worker protection measures are dis-cussed in Chapter 9. Studies indicate that dur-ing daily cleaning activities, especially whilewet sweeping, workers may be exposed to highlevels of airborne dust. Therefore, workersshould wear protective clothing and equip-ment, especially appropriate respirators.

5. Maintaining Containment

The integrity of the plastic sheeting used in alead hazard control project must be maintained.During their daily cleaning activities, workersshould monitor the sheeting and immediatelyrepair any holes or rips with 6-mil plastic andduct tape.

V. Order of Final CleaningProcedures After LeadHazard Control

Before treated surfaces can be painted or sealed,final cleaning procedures must be completed.Because airborne dust requires time to settle,the final cleaning process should start no soonerthan 1 hour after active lead hazard control hasceased in the room. See Appendix 11 for detailsregarding dust settling.

A. Final Cleaning

As the first stage in the final cleaning, floorplastic should be misted and swept as detailedearlier in this chapter. Upper-level plastic,such as that on cabinets and counters, shouldbe removed first, after it has been misted withwater and cleaned. All plastic should be folded

carefully from the corners/ends to the middleto trap any remaining dust. Next, remove bothlayers of plastic from the floor.

Plastic sheets used to isolate contaminatedrooms from noncontaminated rooms shouldremain in place until after the cleaning andremoval of other plastic sheeting; these sheetsmay then be misted, cleaned, and removed last.

Removed plastic should be placed into double4-mil or single 6-mil plastic bags, or plastic bagswith equivalent'(or better) performance charac-teristics, which are sealed and removed from thepremises. As with daily cleanings, this plastic-removal process usually requires workers to useprotective clothing and respirators.

After the plastic has been removed from thecontaminated area, the entire area should becleaned using the HEPA/wet wash/HEPA cycle,starting with the ceiling and working down tothe floor. After surfaces are repainted or sealed,a final HEPA/wet wash/HEPA cycle may benecessary if accumulated dust caused by otherwork is visible.

1. Decontamination of Workers,Supplies, and Equipment

Decontamination is necessary to ensure thatworker's families, other workers, and subsequentproperties do not become contaminated. Spe-cific procedures for proper decontamination ofequipment, tools, and materials prior to theirremoval from lead hazard control containmentareas should be implemented, as described be-low and in Chapters 9 and 10.

Work clothing, work shoes, and tools shouldnot be placed in a worker's automobile unlessthey have been laundered or placed in sealedbags. All vacuums and tools that were usedshould be wiped down using sponges or ragswith detergent solutions.

Consumable/disposable supplies, such as mopheads, sponges, and rags, should be replaced,after each dwelling is completed. Soiled itemsshould be treated as contaminated debris (seeChapter 10).

14-19


Figure 14.8a Pick Up Corners of PlasticSheeting.

Figure 14.8b Fold Plastic Inward

Durable equipment, such as power and hand

tools, generators, and vehicles, should be

cleaned prior to their removal from the site;

the cleaning should consist of a thorough

HEPA vacuuming followed by washing.

B. Preliminary VisualExamination

After the preliminary final cleaning effort is

completed, the certified supervisor should visu-

ally evaluate the entire work area to ensure that

all work has been completed and all visible dust

and debris have been removed. While the pre-

liminary examination may be performed by the

lead hazard control supervisor, contractor, or

owner as a preparatory step before the final

clearance examination, it does not replace the

independent visual assessment conducted dur-

ing clearance.

If the visual examination results are unsatisfac-

tory, affected surfaces must be retreated and/or

recleaned. Therefore, it is more cost effective to

have the supervisor rather than the clearance

examiner perform this initial examination.

C. Surface Painting or Sealingof Nonfloor Surfaces

The next step of the cleaning process is paint-

ing or otherwise sealing all treated surfaces

except floors.

Surfaces, including walls, ceilings, and wood-

work, should be coated with an appropriate

primer and repainted. Surfaces enclosed with

vinyl, aluminum coil stock, and other materials

traditionally not repainted are exempt from the

painting provision.

D. Final Inspection

The final clearance evaluation should take

place at least 1 hour after the final cleaning.

Clearance has three purposes: 1) to ensure that

the lead hazard control work is complete, 2) to

detect the presence of leaded dust, and 3) to

make sure that all treated surfaces have been

repainted or otherwise sealed. Clearance is

usually performed after the sealant is applied

to the floor. See Chapter 15 for information

on clearance examination procedures.

E. Recleaning After ClearanceFailure

If after passing the final visual examination, the

dwelling unit fails the clearance wipe dust tests,

14-20


the HEPA/wet wash/HEPA cleaning cycle

should be carefully and methodically repeated.

Failure is an indication that the cleaning has

not been successful. Recleaning should be con-

ducted under the direct supervision of a certi-

fied supervisor. Care should be exercised during

the recleaning of "failed" surfaces or compo-

nents to avoid recontaminating "cleared"

surfaces or components.

VI. Cleaning CostConsiderations

An important consideration in determining

lead hazard control strategies and methods is

the cost and difficulty of required daily and final

cleanup operations and the ease with which

one can meet dust-clearance standards. A gen-

eral rule of thumb is that lead hazard control

strategies that generate the most dust will have

higher cleanup costs and higher initial clear-

ance test-failure rates.

A. Initial Clearance TestFailure Rates

The likelihood of passing final dust-clearance

tests is highly correlated with the chosen inter-

vention strategy, methods, and care exercised

by the contractor. For example, in one study

(HUD, 1991) initial wipe-test failure rates were

14 percent for interior window sills, 19 percent

for floors, and 33 percent for window troughs.

The pass/fail rates for each surface were strongly

associated with the dwelling unit abatement

strategy employed. Chemical removal and

hand-scraping strategies experi-enced higher

failure rates than replacement and encapsula-

tion/enclosure strategies (see Table 14.1).

However, results of the HUD demonstration

project indicated that clearance failure is not

solely related to abatement method. The report

stated that "the diligence and effectiveness of

an abatement contractor's cleaning process ...

had a major impact on ... the likelihood of the

dwelling unit to pass the final wipe test clear-

ance" (HUD, 1991).

Figure 14.8c Dispose of Plastic Sheeting in aPlastic Trash Bag.

B. Key Factors In EffectiveCleaning

Effective cleaning will be aided by adequate

sealing of surfaces with polyethylene sheeting

prior to lead hazard control, proper daily clean-

ing practices, good worker training, and atten-

tion to detail. Where poor worksite preparation

is employed, additional cleaning may be re-

quired to meet clearance.

C. Special Problems

Surfaces such as porous concrete, old porous

hardwood floors, and areas such as corners of

rooms and window troughs pose especially diffi-

cult cleaning challenges. Porous concrete and

corners of rooms normally require additional

vacuuming to achieve an acceptable level

of cleanliness.

The lead hazard control strategy of enclosure is

frequently chosen for window troughs and for

old porous hardwood floors due to the difficulty

of adequately cleaning these surfaces. This

14-21


option provides not only a clean surface buta more permanently cleanable surface fordwelling occupants to maintain.

VII. Alternative Methods

Alternatives to the recommended cleaningtools and practices discussed in this chapterare available, some having significant potentialfor increasing effectiveness and lowering costs.

A recent Canadian study (CMHC, 1992) eval-uated the effectiveness of contaminated dustcleanup activities using tools that would gener-ally be available to construction contractors andhomeowners. Vinyl flooring and carpeting werecleaned using several wet/dry vacuuming sys-tems, sweeping, and wet mopping. The studyfound that regular vacuums with empty bagssend a steady stream of fine particles into theair, while vacuums with partially filled bagswere more efficient. This finding suggests thenecessity for HEPA vacuums. Other vacuumsmay be used if workers do not experience in-creased exposures, if compliance with clearancestandards is achieved, and if a variance fromOSHA regulation (29 CFR 1926.62 (h)(4))is obtained by the contractor or employer (ifrequired).

Agitator heads on vacuums were demonstratedto significantly enhance vacuum effectivenesson carpets in cleaning up fine dust without

increasing airborne dust levels. Table 14.2 sug-gests that a central vacuum with an agitatorhead is most efficient at removing dust andminimizing recontamination, probably becausethe vacuum exhaust is blown away from livingareas. Because many houses do not have centralvacuuming systems, a portable HEPA vacuum isthe next best choice (see Table 14.2). Vacuumswithout agitator heads appeared to performrelatively poorly on carpets.

A. Vacuums

Regular (non-HEPA) dry vacuums potentiallyproduce hazardous levels of airborne dust andtherefore should be avoided. Externally ex-hausted vacuum units with adequate dust-retaining capability may be used. The OSHAlead standard requires the use of HEPA vacuumequipment (see 29 CFR 1926.62 (h)(4), whichstates, "where vacuuming methods are selected,the vacuums shall be equipped with HEPAfilters"). •

B. Trisodium Phosphate andOther Detergents

TSP detergents have been used successfully fora number of years in lead hazard control work.However, in recent years, other new cleaningagents have been developed specifically forleaded dust removal. The need for alternativeshas been fueled by the fact that TSP is an eye

Table 14.1 Initial Cleaning Wipe-Test Failure Rates for Various Abatement Strategies

Dust TestLocation

Floors

Sills

Wells

Hand Scrapew/Heat Gun

28.8%

24.4%

44.5%

ChemicalRemoval

22.7%

24.1%

45.7%

Enclosure

20.0%

8.2%

23.7%

Encapsulation

13.8%

4.8%

25.7%

Replacement

12.5%

17.4%

21 .0%

All Methods

19%

14%

33%

Source: U.S. Department of Housing and Urban Development (August 1991) The HUD Lead-Based PaintAbatement Demonstration (FHA)

14-22


and skin irritant and is increasingly restrictedfrom household use and unavailable in manylocal jurisdictions. TSP also damages some

finishes. Recently reported trials of two new

products suggest that alternative lead-specific

cleaning agents may be more effective and safer

than TSP (Grawe, 1993; Wilson, 1993).

These Guidelines do not prohibit the use ofnon-TSP cleaning agents. HUD encourages

further evaluation of alternative cleaningmethods. Use of any cleaning agent that re-

sults in compliance with clearance criteria

is encouraged.

Table 14.2 Mass Removal Efficiency for Extended Vacuuming Cycles

Cycle Number

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

Mass Removal Efficiency Percentages

Cleaning Method

CentralVacuum — Plain

Tool

34.7

47.0

51.9

56.0

59.3

61.6

63.8

67.5

67.5

67.2

CentralVacuum — Agitator

Head

71.0

80.2

85.9

87.8

88.9

91.2

93.1

95.4

97.7

100.0

102.3

104.6

104.6

103.8

HEPA Vacuum

55.4

61.2

66.3

67.0

72.1

74.4

76.4

77.5

78.7

80.2

80.2

84.1

84.5

84.5

PortableVacuum — Plain

Tool

17.5

23.0

26.6

29.4

32.5

34.9

36.5

38.1

40.1

41.7

41.7

44.8

46.8

48.4

49.6

50.8

52.4

53.6

54.4

55.2

Source: Canada Mortgage and Housing Corporation: Saskatchewan Research Council (December 1992) Effectiveness ofClean-up Techniques for Leaded Paint Dust

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us dept of hud - guidelines for evaluation & … similarities between lead hazard control and...

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