Lead
Dust
Minimization
Work
Practices
for
Renovation,
Remodeling
and
Repainting
Draft
Technical
Manual
US
Environmental
Protection
Agency
Office
of
Pollution
Prevention
and
Toxics
Prepared
by
The
National
Center
for
Lead­
Safe
Housing
10227
Wincopin
Circle,
Suite
205
Columbia,
MD
21044
Under
Prime
Contract
#
68­
W7­
0070
Subcontract
#
EPAOPPT­
TNC­
001
For
ICF
Incorporated
8300
Lee
Highway
Fairfax,
VA
22031­
1207
September
29,
1998
NOTICE
This
manual
describes
lead
dust
minimization
work
practices
appropriate
for
common
residential
renovation,
remodeling
and
repainting
tasks.
It
is
an
internal
EPA
draft
technical
reference
tool
and
is
not
intended
for
use
by
the
general
public.
As
such,
the
manual
should
not
be
cited
or
circulated.

Mention
of
any
trade
name
products
in
this
manual
does
not
convey
and
should
not
be
interpreted
as
conveying
official
EPA
approval,
endorsement
or
recommendation.
TABLE
OF
CONTENTS
Page
I.
INTRODUCTION
AND
OVERVIEW
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1
Background
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1
Purpose
and
Guiding
Assumptions
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2
Relationship
to
Existing
EPA
Regulations
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2
Organization
of
the
Document
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3
II.
PRINCIPLES
FOR
LEAD
DUST
MINIMIZATION
WORK
PRACTICES
DURING
RENOVATION,
REMODELING
AND
REPAINTING
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4
III.
INTERIOR
RENOVATION,
REMODELING
AND
REPAINTING:
BASIC
CONSTRUCTION
TASKS
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7
Level
1:
Minimal
Lead
Dust­
Generating
Tasks
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11
Level
2:
Moderate
Lead
Dust­
Generating
Tasks
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12
Level
3:
Substantial
Lead
Dust­
Generating
Tasks
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13
Level
4:
Extreme
Lead
Dust­
Generating
Tasks
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15
Level
5:
Prohibited
Tasks
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17
IV.
EXTERIOR
RENOVATION,
REMODELING
AND
REPAINTING:
BASIC
CONSTRUCTION
TASKS
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21
Level
1:
Minimal
Lead
Dust­
Generating
Tasks
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25
Level
2:
Moderate
Lead
Dust­
Generating
Tasks
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26
Level
3:
Substantial
Lead
Dust­
Generating
Tasks
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27
Level
4:
Extreme
Lead
Dust­
Generating
Tasks
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28
Level
5:
Prohibited
Tasks
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29
REFERENCES
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33
GLOSSARY
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36
LIST
OF
EXHIBITS
Page
Exhibit
1:
Increasing
Steps
Of
Interior
Lead
Dust
Minimization
Work
Practices
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9
Exhibit
2:
Lead
Dust
Minimization
Work
Practices
For
Interior
Renovation
Tasks
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10
Exhibit
3:
Tools,
Supplies
And
Equipment
For
Interior
Renovation
Tasks
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18
Exhibit
4:
Interior
Set­
Up
Procedures
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19
Exhibit
5:
Interior
Final
Clean­
Up
And
Waste
Disposal
Procedures
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20
Exhibit
6:
Increasing
Steps
Of
Exterior
Lead
Dust
Minimization
Work
Practices
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23
Exhibit
7:
Lead­
Dust
Minimization
Work
Practices
For
Exterior
Renovation
Tasks
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24
Exhibit
8:
Tools,
Supplies
And
Equipment
For
Exterior
Renovation
Tasks
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30
Exhibit
9:
Exterior
Set­
Up
Procedures
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31
Exhibit
10:
Exterior
Final
Clean­
Up
And
Waste
Disposal
Procedures
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32
1
NIOSH,
January
1997,
"
Protecting
Workers
Exposed
to
Lead­
Based
Paint
Hazards,"
p.
1­
5.
2
U.
S.
Environmental
Protection
Agency
(
EPA),
May
1997,
"
Lead
Exposure
Associated
with
Renovation
and
Remodeling
Activities:
Summary
Report,"
pp.
19­
23.

Draft
1
September
29,
1998
I.
INTRODUCTION
AND
OVERVIEW
Background
Renovation,
remodeling
and
repainting
activities
conducted
in
older
homes
pose
a
considerable
lead
exposure
health
risk.
Both
the
workers
engaged
in
these
activities
as
well
as
the
occupants
of
the
building
undergoing
the
work
may
be
exposed
to
lead.
Lead­
based
paint
has
been
shown
to
be
one
source
of
lead
exposure.
It
is
found
in
more
than
half
the
US
housing
stock,
including
three
quarters
of
the
units
built
before
1978.
In
addition
to
paint,
the
fine
dust
that
has
accumulated
behind
the
woodwork,
walls,
and
trim
may
also
contain
lead
that
can
be
released
during
these
activities.

Even
a
simple
renovation
and
remodeling
task
can
create
lead­
contaminated
dust
and
debris
that
pose
health
risks
to
children
and
adults
living
in
the
building
and
to
project
workers.
If
small
children
ingest
this
lead
dust,
lead
poisoning
may
result.
Children,
particularly
those
under
age
six,
are
exposed
to
lead
dust
as
a
result
of
crawling
on
the
floor
or
playing
with
toys
and
then
engaging
in
normal
hand­
to­
mouth
activity
(
e.
g.,
eating
food
or
mouthing
a
toy).
Lead
poisoning
can
cause
learning
disabilities,
permanent
damage
to
the
nervous
system,
reductions
in
intelligence
and
attention
span,
stunted
growth
and
behavior
problems.
Lead
can
also
have
health
consequences
for
adults.
For
example,
breathing
or
ingesting
harmful
levels
of
lead
dust
can
cause
hypertension
and
infertility
in
men
and
miscarriages
in
pregnant
women.
Extreme
lead
poisoning
can
result
in
comas
and
death.
1
Although
specific
sources
and
mechanisms
of
lead
exposure
from
renovation,
remodeling
and
repainting
are
not
entirely
understood,
there
is
little
doubt
that
dust
control
is
the
key
to
reducing
this
exposure.
A
wide
variety
of
simple
tasks
can
create
lead­
contaminated
dust
and
debris
that
may
pose
a
serious
health
risk
to
building
occupants
and
project
workers.
Minimizing
the
dust
produced
and
released
by
this
work
will
almost
certainly
reduce
the
lead
exposure
potential.
Many
common
residential
renovation,
remodeling
and
repainting
projects
jobs
can
generate
dust.
For
example,
a
painting
job
that
requires
extensive
surface
preparation
before
repainting
can
involve
sanding
(
either
by
hand
or
with
a
power
tool),
scraping
or
removing
damaged
wood
trim.
Renovation
related
tasks
such
as
removing
cabinets,
sawing,
refinishing
painted
floors,
or
removing
paint
with
a
heat
gun
or
open
flame
torch
can
also
release
substantial
lead
dust
or
fumes
if
undertaken
in
a
residence
with
lead­
based
paint.
2
Because
lead
particles
in
dust
are
virtually
impossible
to
see,
even
a
work
area
or
room
that
appears
as
though
it
was
carefully
cleaned
can
have
harmful
levels
of
lead­
contaminated
dust.

Renovation,
remodeling
and
repainting
jobs
conducted
on
building
exteriors
can
release
leadcontaminated
dust
and
debris,
contaminating
the
soil
and
ground
cover.
If
young
children
play
in
these
areas,
their
normal
hand­
to­
mouth
behavior
can
result
in
lead
exposures.
Exterior
work
can
also
release
dust
that
moves
indoors
through
open
windows
or
doors
or
by
being
tracked
inside
on
shoes
and
clothing.
Draft
2
September
29,
1998
Renovation,
remodeling
and
repainting
contractors
can,
however,
take
precautions
to
minimize
and
contain
the
amount
of
lead­
contaminated
dust
created,
restrict
occupant
access
to
work
sites
when
dust
is
present,
and
clean­
up
the
site
using
methods
that
effectively
reduce
this
dust.
These
precautions
can
reduce
the
risk
of
lead
poisoning
among
children
and
adult
occupants
as
well
as
for
those
performing
the
work.

Purpose
and
Guiding
Assumptions
This
document
presents
a
set
of
draft
technical
specifications
for
renovation,
remodeling
and
repainting
activities
that
describe
the
precautions
needed
to
ensure
that
lead­
contaminated
dust
and
debris
are
minimized,
controlled
and
properly
cleaned­
up.
The
specifications
were
developed
to
be
applicable
to
both
contractors
and
homeowners
who
perform
these
activities
without
the
aid
of
a
contractor.
However,
the
document
in
its
current
form
is
not
intended
for
use
by
the
general
public
or
contractors.
Rather,
it
was
developed
to
provide
background
information
that
will
serve
as
a
reference
for
EPA
to
prepare
technical
materials,
including
training
materials.

To
help
focus
these
specifications,
residential
properties
are
assumed
to
be
reasonably
well
maintained.
Properties
with
extensive
deferred
maintenance,
or
abandoned
properties
with
severe
structural
problems,
were
not
considered
in
formulating
the
specifications.
Such
properties
often
have
severely
deteriorated
paint
on
many
surfaces
and
even
small­
scale
tasks
such
as
nailing
can
create
substantial
lead­
contaminated
dust
and
debris.
One
possible
rule
of
thumb
when
working
on
deferred
maintenance
properties
would
be
to
always
use
the
most
extensive
level
of
lead
dust
minimization
work
practice
precautions.

Relationship
to
Existing
EPA
Regulations
The
Residential
Lead­
Based
Paint
Hazard
Reduction
Act
of
1992
(
Title
X)
directs
EPA
to
develop
regulations
under
the
Toxic
Substances
Control
Act
(
TSCA)
Section
402(
a)
which
create
standards
for
conducting
lead­
based
paint
activities
that
include
abatement.
EPA
has
already
promulgated
final
regulations
for
lead­
based
paint
activities
in
target
housing
and
child­
occupied
facilities
(
40
CFR
Part
745).
These
regulations
require
that
individuals
conducting
lead­
based
paint
inspections,
risk
assessments
and
abatement
be
properly
trained
and
certified
and
that
the
work
be
performed
in
accordance
with
the
standards
set
forth
in
the
rule.
The
work
practice
standards
for
abatement
include:


providing
notice
of
the
commencement
of
work;


developing
an
occupant
protection
plan;


restricting
selected
work
practices
due
to
the
potential
risk
of
excessive
lead
contamination;


procedures
for
soil
abatement;
and

dust
and
soil
clearance
testing
requirements.

EPA's
regulations
also
establish
a
process
for
States
and
Indian
tribes
to
seek
authorization
to
administer
lead
programs.
The
Agency
will
administer
lead­
based
paint
training
and
certification
programs
and
enforce
work
practices
in
any
State
or
Indian
tribe
that
does
not
have
an
authorized
program
by
August
31,
1998
(
40
CFR
745.239).
Draft
3
September
29,
1998
TSCA
Section
402(
c)
directs
EPA
to
address
renovation
and
remodeling
activities
by
first
conducting
a
study
to
determine
the
extent
to
which
persons
engaged
in
various
types
of
renovation
and
remodeling
activities
in
target
housing
are
exposed
to
lead
in
the
conduct
of
such
activities
or
disturb
lead
and
create
a
lead­
based
paint
hazard.
Section
402(
c)
further
directs
the
Agency
to
use
the
results
of
the
study
and
consult
with
stakeholders
to
determine
which
renovation
and
remodeling
activities
should
be
subject
to
regulations
under
Section
402(
a).
EPA
must
then
revise
the
Section
402(
a)
regulations
for
abatement
activities
and
apply
them,
if
appropriate,
to
renovation
or
remodeling
activities.

Under
Section
403
of
TSCA,
EPA
has
proposed
a
rule
to
identify
conditions
that
constitute
a
lead­
based
paint
hazard
and
lead
levels
in
residential
dust
and
soil
that
should
be
considered
a
health
hazard
to
building
occupants.
Although
the
Agency
has
not
yet
promulgated
its
final
standards,
it
has
published
interim
guidance.
These
draft
technical
specifications
call
for
lead
dust
clearance
testing
and
soil
testing
under
several
circumstances.
The
forthcoming
TSCA
403
standards
will
establish
relevant
dust
clearance
levels
that
could
be
used
during
renovation,
remodeling
and
repainting
projects.

Organization
of
the
Document
This
document
presents
specifications
for
lead
dust
minimization
work
practices
during
renovation,
remodeling
and
repainting
from
a
task
perspective.
Tasks
are
specific
construction
activities
such
as
drilling,
sanding,
using
a
crow
bar
to
remove
a
component,
and
demolishing
walls
using
power
or
hand
tools.
Many
such
tasks
typically
make
up
a
project
like
removing
kitchen
cabinets
or
repainting
a
wall.

The
document
is
organized
into
four
chapters:


Chapter
I
(
this
chapter)
provides
the
rationale
for
developing
these
draft
specifications
and
highlights
each
of
the
remaining
chapters;


Chapter
II
outlines
the
key
principles
that
guided
the
development
of
the
draft
specifications
presented
in
Chapters
III
and
IV;


Chapter
III
addresses
lead
dust
minimization
work
practices
for
interior
renovation,
remodeling
and
repainting
tasks;
and

Chapter
IV
addresses
the
work
practices
for
exterior
renovation,
remodeling
and
repainting
tasks.

In
Chapters
III
and
IV,
renovation,
remodeling
and
repainting
tasks
are
grouped
into
five
potential
lead
dust­
generating
task
levels,
ranging
from
minimal
to
prohibited.
At
each
level,
the
specifications
identify
typical
tasks
and
specify
lead
dust
minimization
work
practices.
A
glossary
is
included
at
the
end
of
the
manual
to
help
define
commonly
used
terms.
Draft
4
September
29,
1998
II.
PRINCIPLES
FOR
LEAD
DUST
MINIMIZATION
WORK
PRACTICES
DURING
RENOVATION,
REMODELING
AND
REPAINTING
This
chapter
sets
forth
the
principles
for
lead
dust
minimization
work
practices
found
in
Chapters
III
and
IV.

Six
principles
guided
the
development
of
these
technical
specifications.
These
principles
are
presented
below
to
explicitly
identify
the
assumptions
used
in
formulating
the
specifications.

1.
In
residences
built
before
1978,
contractors
should
assume
that
all
paint
contains
lead
unless
analytic
tests
reveal
otherwise.

When
working
in
or
on
a
residential
property
built
prior
to
1978,
assume
that
all
painted
surfaces
and
building
components
are
coated
with
lead­
based
paint
unless
analytic
tests
(
e.
g.,
use
of
portable
XRF
lead­
in­
paint
analyzers
or
laboratory
analysis
of
paint
chip
samples)
demonstrate
that
the
paint
is
not
lead­
based.
In
post­
1949
housing
where
lead­
based
paint
may
be
less
prevalent,
paint
testing
is
encouraged
so
as
to
avoid
the
necessity
of
following
lead
dust
minimization
work
practices
when
lead­
based
paint
is
not
present.

2.
Contractors
must
minimize,
contain
and
clean­
up
any
dust
and
debris
created.

If
renovation,
remodeling
or
repainting
activities
will
disturb
painted
surfaces
or
create
dust:


choose
construction
tasks
that
generate
a
lower
amount
of
dust
and
debris;


contain
any
dust
and
debris
within
the
smallest
possible
area;


do
not
permit
non­
workers
to
enter
the
work
area;


wear
protective
clothing
while
working
and
use
a
HEPA
(
High
Efficiency
Particulate
Air)
filter­
equipped
vacuum
to
clean
the
clothing
and
work
shoes
or
discard
the
protective
clothing
before
leaving
the
work
area
to
minimize
the
potential
that
other
areas
or
rooms
will
be
contaminated
or
that
the
worker
will
bring
home
lead­
contaminated
dust;
and

promptly
clean­
up
dust
and
debris
using
a
suitable
dry
method
(
e.
g.,
HEPA­
filter
equipped
vacuum)
and
a
final
wet
washing
with
a
detergent­
based
solution
and
clean
water
rinse.

3.
Properly
staging
projects
and
jobs
can
isolate
tasks
that
generate
substantial
leadcontaminated
dust
and
debris,
thereby
limiting
the
need
for
lead
dust
minimization
work
practice
precautions.

One
of
the
keys
to
efficiently
integrating
lead
dust
minimization
work
practices
into
renovation,
remodeling
and
repainting
projects
is
proper
staging
of
the
work.
Construction
tasks
that
can
create
dust
and
debris,
such
as
demolition
and
surface
preparation
for
repainting,
often
occur
at
the
beginning
of
the
project.
Once
these
tasks
and
the
associated
clean­
up
are
completed,
the
remainder
of
the
tasks
can
be
conducted
with
less
extensive
precautions.
Draft
5
September
29,
1998
4.
Dust
testing
should
be
used
to
measure
whether
lead­
contaminated
dust
was
controlled.

Dust
testing
can
determine
whether
interior
renovation,
remodeling
or
repainting
activities
have
left
unacceptable
levels
of
lead­
contaminated
dust
that
could
be
hazardous
to
occupants.
Such
testing
should
be
considered
upon
completion
of
interior
projects
to
determine
whether
lead
dust
was
adequately
controlled
and/
or
eliminated.
For
projects
and
tasks
where
substantial
or
extreme
levels
of
lead
dust
are
likely
to
be
generated,
dust
testing
is
critical
to
ensure
that
the
unit
is
safe
to
reoccupy.
Dust
clearance
tests
can
also
serve
as
performance
standards
to
provide
contractors
with
an
alternative
to
following
specific
lead
dust
minimization
protocols,
provided
that
occupants
are
restricted
from
entering
work
rooms
or
areas
and
independent
testing
documents
that
the
work
area
is
safe
for
re­
occupancy
(
i.
e.,
dust
lead
levels
are
below
state
or
federal
standards).

5.
Certain
work
practices
should
be
prohibited
because
of
their
potential
to
create
harmful
lead
exposures.

EPA
regulations
restrict
the
use
of
the
following
work
practices
during
lead­
based
paint
abatement
in
target
housing
and
child­
occupied
facilities:


open
flame
burning
or
torching
of
lead­
based
paint
is
prohibited;


machine
sanding,
grinding,
abrasive
blasting
or
sandblasting
of
lead­
based
paint
is
prohibited
unless
used
with
a
HEPA
exhaust
control;


dry
scraping
of
lead­
based
paint
is
permitted
only
in
conjunction
with
heat
guns
or
around
electrical
outlets
or
when
treating
defective
paint
spots
totaling
no
more
than
two
square
feet
in
any
one
room,
hallway
or
stairwell
or
totaling
no
more
than
20
square
feet
on
exterior
surfaces;
and

operating
a
heat
gun
on
lead­
based
paint
is
permitted
only
at
temperatures
below
1100
degrees
Fahrenheit
(
40
CFR
745.227(
e)(
6)).

These
practices
are
either
restricted
or
prohibited
because
they
generate
excessive
levels
of
lead­
contaminated
dust.
The
resulting
lead
exposures
can
pose
a
very
dangerous
health
risk
to
residents,
particularly
young
children,
which
can
not
be
properly
controlled.
If
these
same
procedures
were
used
during
renovation,
remodeling
or
repainting
activities,
similarly
harmful
levels
of
lead
dust
would
likely
be
created.

6.
The
protection
of
workers
from
harmful
lead
exposures
is
more
properly
covered
by
OSHA's
Lead
Exposure
in
Construction
Standard.
(
29
CFR
1926.62)

This
manual
describes
work
practices
that
are
designed
to
protect
occupants
from
harmful
lead
exposure
and
minimize
lead
in
the
environment.
It
recommends
that
workers
use
protective
clothing
while
performing
many
interior
and
exterior
renovation,
remodeling
and
repainting
tasks,
and
that
the
protective
clothing
be
HEPA
vacuumed
and/
or
discarded
any
time
a
worker
leaves
the
work
area
or
room.
The
purpose
of
this
recommendation
is
to
minimize
the
potential
that
other
areas
or
rooms
of
the
building
could
be
contaminated
as
the
worker
moves
beyond
the
primary
work
area
or
room.
Additionally,
the
recommendation
is
Draft
6
September
29,
1998
intended
to
prevent
possible
worker
take­
home
lead
exposures
that
could
endanger
family
members.

The
Occupational
Safety
and
Health
Administration
(
OSHA)
has
promulgated
a
Lead
Exposure
in
Construction
Standard
(
29
CFR
1926.62)
which
applies
to
all
occupational
exposures
to
lead
in
the
course
of
construction
work.
Accordingly,
lead­
related
worker
safety
and
respiratory
protection
procedures
during
renovation,
remodeling
and
repainting
should
be
guided
by
this
standard.
Draft
7
September
29,
1998
III.
INTERIOR
RENOVATION,
REMODELING
AND
REPAINTING:
BASIC
CONSTRUCTION
TASKS
Renovation,
remodeling
and
painting
contractors
routinely
perform
many
construction
tasks
on
a
daily
basis.
When
these
tasks
occur
during
interior
projects
in
residential
properties
built
before
1978,
lead­
contaminated
dust
and
debris
could
be
created
if
lead­
based
paint
is
disturbed.
Depending
upon
the
extent
of
the
dust
and
debris,
lead
exposures
to
residential
occupants
range
from
minimal
to
extremely
dangerous.
Some
tasks
can
generate
such
excessive
levels
of
leadcontaminated
dust
and
debris
that
they
should
be
prohibited.

This
chapter
groups
interior­
based
construction
tasks
according
to
the
potential
for
generating
lead­
contaminated
dust
and
debris,
and
describes
the
work
practices
necessary
to
limit
and
control
occupant
exposures
and
building
contamination.
The
practices
described
herein
are
not
intended
to
apply
to
residential
properties
with
extensive
deferred
maintenance.
In
such
cases,
more
intense
dust
and
debris
containment
and
clean­
up
may
be
necessary.

These
specifications
define
five
levels
of
lead
dust­
generating
tasks:
minimal,
moderate,
substantial,
extreme
and
prohibited.
As
Exhibit
1
on
page
9
illustrates,
the
recommended
lead
dust
minimization
work
practices
for
each
task
level
increase
in
stringency
as
their
potential
for
creating
lead
dust
and
debris
increases.
The
additional
precautions
associated
with
each
task
level
are
highlighted
in
italics
and
supplement
the
specifications
that
apply
to
lower
level
tasks.
For
example,
Level
3
tasks
trigger
the
work
practices
of
Level
2
and
the
added
precautions
of
using
protective
sheeting
to
cover
the
work
room
floor
and
seal
doorways
to
restrict
access
to
the
room.
(
Protective
sheeting
means
non­
permeable,
puncture
resistant
disposable
sheeting.)
"
Prohibited
tasks"
are
not
included
in
Exhibit
1;
these
tasks
do
not
have
any
lead
dust
minimization
work
practice
recommendations
because
the
risk
of
lead
exposure
and
contamination
cannot
be
adequately
controlled.

Exhibit
2
on
page
10
identifies
the
common
renovation,
remodeling
and
repainting
tasks
that
fall
into
the
various
lead
dust­
generating
levels
and
also
briefly
describes
the
work
practice
specifications
appropriate
for
each.
This
table
thus
summarizes
the
chapter.
It
lists
the
common
tasks,
groups
those
tasks
by
their
likely
potential
to
create
lead­
contaminated
dust,
and
articulates
work
practices
designed
to
minimize
occupant
lead
exposures
and
limit
environmental
contamination
taking
into
account
cost
considerations.

For
example,
removing
paint
with
a
heat
gun
operating
under
1,100

F
is
considered
a
Level
3:
Substantial
Lead
Dust­
Generating
Task.
The
occupant
protection
measures
are:
restricting
access
to
the
room
after
work
begins;
requiring
workers
to
wear
protective
clothing;
and
covering
the
floor,
sealing
the
room
and
covering
all
windows
with
protective
sheeting.
Once
work
is
completed,
the
sheeting
should
be
wet­
misted,
rolled­
up
and
disposed
of
in
a
special
bag,
and
the
work
room
and
tools
should
be
HEPA­
vacuumed
and
wet
washed.
(
Special
bags
mean
nonpermeable
puncture
resistant
disposable
bags.)

Exhibit
2
also
does
not
include
Level
5:
Prohibited
Tasks
since
no
precautions
currently
can
be
recommended
to
enable
a
contractor
to
sufficiently
minimize,
control
and
clean­
up
dust
and
debris.
The
following
paint
removal
methods
are
classified
as
prohibited:
dry
scraping
unless
Draft
8
September
29,
1998
performed
in
conjunction
with
heat
guns
or
around
electrical
outlets
or
when
treating
defective
paint
spots
totaling
no
more
than
2
ft2
in
any
one
room,
hallway
or
stairwell;
use
of
an
open
flame
torch
or
other
burning
apparatus;
use
of
a
heat
gun
operating
in
excess
of
1,100

F;
uncontrolled
or
uncontained
abrasive
blasting;
and
machine
sanding
without
a
HEPA
vacuum
attachment.

In
the
pages
that
follow,
the
five
levels
of
dust
generating
tasks
are
presented.
The
tasks
associated
with
each
level
and
the
procedures
for
minimizing
and
controlling
such
dust
and
debris
are
discussed.
For
the
ease
of
the
reader,
several
exhibits
are
presented
to
streamline
the
text
and
facilitate
a
comparison
of
dust
minimization
procedures
among
the
various
levels.
Exhibit
3
identifies
the
tools,
supplies
and
equipment
needed
for
each
level.
Exhibit
4
describes
how
to
setup
the
work
area.
Exhibit
5
discusses
final
clean­
up
and
waste
disposal
procedures.
These
exhibits
are
consistent
with
the
overall
theme
of
this
manual:
increasing
the
amount
of
dust
generated
during
renovation,
remodeling
and
repainting
activities
triggers
added
dust
minimization
and
control
precautions.
Exhibits
3,
4,
and
5
depict
how
the
tools,
as
well
as
set­
up,
final
clean­
up,
and
waste
disposal
procedures
increase
in
complexity
and
stringency
concomitant
with
the
increase
in
likely
dust
generation.
These
exhibits
are
located
at
the
end
of
this
chapter
on
pages
18
through
20
for
easy
reference.
3Protective
sheeting
means
non­
permeable,
puncture
resistant
disposable
sheeting.

Draft
9
September
29,
1998
Exhibit
1:
Increasing
Steps
Of
Interior
Lead
Dust
Minimization
Work
Practices
(
This
exhibit
is
an
overview
and
does
not
contain
some
items.
See
the
text
for
a
complete
discussion
of
each
level.)

Level
4:
Extreme
Lead
Dust
Tasks

focus
on
residence

HEPA
vacuum
daily

take
2
dust
samples:
floor
of
work
room
and
outside
containment
area
Level
3:
Substantial
Lead
Dust
Tasks

focus
on
work
room

wear
protective
worker
clothing

contain
dust
in
work
room
with
protective
sheeting

wet
surfaces,
if
feasible

take
1
dust
sample:
floor
of
work
area
or
room


focus
on
work
room

wear
protective
worker
clothing

contain
dust
in
work
room
with
protective
sheeting

wet
surfaces,
if
feasible

take
1
dust
sample:
floor
of
work
area
or
room
Level
2:
Moderate
Lead
Dust
Tasks

focus
on
work
area

restrict
access

clean
worker
clothing

use
protective
sheeting
3

focus
on
work
area

restrict
access

clean
worker
clothing

use
protective
sheeting

focus
on
work
area

restrict
access

clean
worker
clothing

use
protective
sheeting
Level
1:
Minimal
Lead
Dust
Tasks

final
cleaning:
HEPA
vacuum
&
wet
wash

final
cleaning:
HEPA
vacuum
&
wet
wash

final
cleaning:
HEPA
vacuum
&
wet
wash

final
cleaning:
HEPA
vacuum
&
wet
wash
Draft
10
September
29,
1998
Exhibit
2:
Lead
Dust
Minimization
Work
Practices
For
Interior
Renovation
Tasks
(
This
exhibit
is
an
overview
and
does
not
contain
some
items.
See
the
text
for
a
complete
discussion
of
each
level.)

Tasks
Performed
On
Painted
Surfaces
Occupant
Protection
Dust
Minimization
and
Containment
Final
Clean­
up
and
Waste
Disposal
Level
1:
Minimal
Lead­
Dust
Generating
Tasks

wet
sanding
small
areas
(
less
than
2
ft2
per
room)


drilling
painted
surfaces

removing
paint
by
applying
and
removing
chemical
strippers

If
using
chemical
stripper,

place
protective
sheeting
directly
underneath
work
area
to
collect
effluent

HEPA
vacuum
&
wet
wash

dispose
of
protective
sheeting
in
special
bag
or
container
Level
2:
Moderate
Lead­
Dust
Generating
Tasks

dry
hand
sanding
less
than
2
ft2
per
room
or
around
electrical
outlets

dry
hand
scraping
less
than
2
ft2
per
room
or
around
electrical
outlets

removing
carpet
or
non­
painted
flooring

hand­
sawing

chiseling

prying
with
a
crow
or
pry
bar

wet
sanding
more
than
2
ft2
per
room

removing
whole
building
components
with
paint
in
good
condition

dry
machine
sanding
using
a
sander
with
HEPA­
filtered
vacuum

using
an
electric
planer
with
HEPA­
filtered
vacuum

focus
on
work
area

restrict
access

remove/
cover
belongings

clean
worker
clothing
with
HEPA
vacuum

close
&
cover
HVAC
vents
with
protective
sheeting

cover
floor
of
work
area
with
protective
sheeting

wrap
removed
components
with
deteriorated
paint
in
protective
sheeting
LEVEL
1
plus

wet
mist
protective
sheeting,
roll
up
&

dispose
in
special
bag
Level
3:
Substantial
Lead
Dust­
Generating
Tasks

using
an
electric
planer

cutting
using
an
electric
circular
or
reciprocating
saw

removing
paint
with
a
heat
gun
operating
under
1,100

F

dry
hand
sanding
or
hand
scraping
remaining
dry
residue
after
removing
paint
with
chemical
strippers

removing
window
systems
or
components
if
paint
is
in
very
poor
condition

demolishing
painted
surfaces
using
hand
or
power
tools
LEVEL
2
plus

focus
on
work
room

restricting
access
to
work
room
after
work
begins

wear
protective
worker
clothing
and
clean
with
HEPA
vacuum
before
leaving
work
room

collect
1
dust
clearance
sample
from
floor
of
work
area
or
room
LEVEL
2
plus

cover
floor
and
seal
door
to
work
room
with
protective
sheeting

close
&
cover
windows
with
protective
sheeting

wet
mist
affected
surfaces,
if
feasible

wrap
all
painted
components
removed
from
work
room
in
protective
sheeting
LEVEL
2
plus

clean
work
room
&

tools

HEPA
vacuum
and/
or
dispose
of
protective
worker
clothing
in
special
bag
Draft
11
September
29,
1998
Level
4:
Extreme
Lead
Dust
Generating
Tasks
No
activities
are
currently
considered
Level
4
tasks
LEVEL
3
plus

focus
on
entire
residence

collect
2
dust
clearance
samples:

1st
in
work
room,
2nd
outside
dust
containment
LEVEL
3
plus

clean
all
horizontal
surfaces
in
work
room
with
HEPA
vacuum
at
conclusion
of
work
day
LEVEL
3
plus

clean
protective
sheeting
&
protective
worker
clothing
before
disposal
Protective
sheeting
means
non­
permeable,
puncture
resistant
disposable
sheeting.
Special
bags
means
non­
permeable,
puncture
resistant
disposable
bags.
Draft
12
September
29,
1998
Minimal
Tasks

Wet
sanding
small
areas
(
less
than
2
ft2)
of
painted
surfaces
in
a
room;


Drilling
painted
surfaces;
and

Removing
paint
by
applying
and
removing
chemical
strippers.
Level
1:
Mini
These
tasks
are
unlikel
of
lead­
contaminated
dust
surface
areas
will
be
disturbe
beyond
clean­
up.

Lead
Dust
Minimization
Work
Pra
To
properly
limit
and
control
lead­
contamin
when
performing
these
tasks,
contractors
shou
specifications
below
using
the
tools
listed
in
Exhi
18.

Set­
Up
Procedures.
Restrict
occupant
access
to
the
imme
complete
(
see
Exhibit
4
on
page
19).

Dust
Minimization
and
Control
Procedures
During
The
Work.

needed
is
to
wet
mist
the
surface
before
sanding
or
drilling.
However
strippers
and
removing
the
wet
slurry
during
paint
removal,
place
protect
beneath
the
work
area
to
collect
and
contain
the
effluent.

Final
Clean­
Up
and
Waste
Disposal
Procedures.
Once
the
work
is
completed,

area
with
a
HEPA­
filtered
vacuum
and
wet
cleaning
solution,
and
dispose
of
all
debr
bags.
(
Exhibit
5
on
page
20
describes
these
procedures
in
more
detail.)
Draft
13
September
29,
1998
Moderate
Tasks

Dry
hand
sanding
less
than
2
ft
of
painted
surfaces
per
room,

hallway
or
stairwell,
or
dry
sanding
around
electrical
outlets;


Dry
hand
scraping
less
than
2
ft
2
of
painted
surfaces
per
room,

hallway
or
stairwell,
or
dry
scraping
around
electrical
outlets;


Removing
carpet
or
other
non­

painted
floor
materials;


Hand­
sawing
painted
surfaces;


Chiseling
painted
surfaces;


Prying
painted
surfaces
using
a
crow
bar
or
pry
bar;


Wet
sanding
more
than
2
ft
2
of
painted
surfaces
in
a
room,

hallway
or
stairwell;


Removing
whole
building
components,
both
painted,
if
the
paint
is
in
good
condition,
and
unpainted
(
i.
e.,
trim/
casement/

molding,
cabinets,
kitchen
and
bath
fixtures,
electrical
fixtures,

window
components);


Dry
sanding
using
an
electric
sander
with
a
HEPA­
filter
equipped
vacuum
attachment;

and

Using
an
electric
planer
on
painted
surfaces
with
a
HEPA­

filter
equipped
vacuum
attachment.
Level
2:
Mode
These
basic
tasks
are
p
some
power
tools
that
gen
impact,
and
may
disturb
larg
that
reason,
these
tasks
are
likel
amount
of
lead­
contaminated
dust
Lead
Dust
Minimization
Work
Practi
To
properly
limit
and
control
lead­
contaminate
debris
when
performing
these
tasks,
contractors
s
follow
the
specifications
below
using
the
tools
listed
Exhibit
3
on
page
18.

Set­
Up
Procedures.
These
include
restricting
occupant
access
to
the
work
area
until
final
clean­
up
occurs
and
containing
dust
to
the
work
area
through
the
use
of
protective
sheeting.
(
The
procedures
are
described
in
detail
in
Exhibit
4
on
page
19.)

Dust
Minimization
and
Control
Procedures
During
The
Work.


Use
a
razor
or
utility
knife
to
cut
all
painted
joints
prior
to
removing
whole
building
components
to
avoid
breaking
intact
painted
surfaces.


Wrap
all
removed
components
with
deteriorated
paint
in
protective
sheeting.


If
workers
leave
the
activity
area
before
completion
of
the
task
and/
or
prior
final
clean­
up,
use
a
HEPA­

filter
equipped
vacuum
to
remove
any
visible
dust
or
debris
from
their
shoes
or
clothing,
and
wet
wipe
shoes
with
a
disposable
hand
towel.


When
removing
carpet,
wet
mist
both
the
top
and
back
sides
before
rolling
it
inward.
Cut
the
carpet
into
smaller
pieces
so
that
it
can
either
be
placed
in
special
bags
or
wrapped
in
protective
sheeting.
Tape
it
shut
prior
to
disposal.

Final
Clean­
Up
and
Waste
Disposal
Procedures.
Once
the
work
is
completed,
clean
the
work
area
and
buffer
zone
with
a
HEPA­
filtered
vacuum
and
wet
cleaning
solution,
dispose
of
protective
sheeting
and
debris
in
special
bags,
and
clean
worker
clothing
before
leaving
the
work
area.
(
Exhibit
5
on
page
20
describes
these
procedures
in
more
detail.)
Draft
14
September
29,
1998
Substantial
Tasks

Using
an
electric
planer
on
painted
surfaces;


Cutting
using
an
electric
circular
or
reciprocating
saw;


Removing
paint
with
a
heat
gun
operating
under
1,100

F;


Dry
hand
sanding
and/
or
scraping
remaining
dry
residue
after
removal
of
paint
using
chemical
strippers;


Removing
entire
window
systems
or
window
components
when
the
paint
is
in
poor
condition;
and

Demolishing
painted
surfaces
using
hand
or
power
tools
(
e.
g.,

sledge
hammer,
crow
bar,
maul,

electric
circular
or
reciprocating
saw,
etc.).
Level
3:
Subs
Level
3
tasks
are
perfo
tools,
and
involve
signific
activities
intended
to
abrade,

surfaces.
The
potential
for
distu
high.
Therefore,
these
tasks
are
lik
substantial
lead­
contaminated
dust.

Lead
Dust
Minimization
Work
Practices
Specification
To
properly
limit
and
control
lead­
contaminated
dus
debris
when
performing
these
tasks,
contractors
should
follow
the
specifications
below
using
the
tools
listed
in
Exhibit
3
on
page
18.

Set­
Up
Procedures.
These
include
restricting
occupant
access
to
the
work
room
until
final
clean­
up
occurs,

containing
dust
in
the
work
room
through
the
use
of
protective
sheeting,
and
taking
additional
precautions
for
occupants.
(
These
procedures
are
described
in
detail
in
Exhibit
4
on
page
19.)

Dust
Minimization
and
Control
Procedures
During
The
Work.


If
feasible,
wet
mist
the
affected
surfaces
and/
or
building
components.
With
larger
compone
it
may
be
simpler
to
use
a
pressurized
garden
sprayer.


If
removing
building
components,
use
a
razor
or
utility
knife
to
score
all
painted
joints
to
avoid
breaking
intact
painted
surfaces.


If
large
scale
demolition
of
painted
surfaces
is
being
performed,
keep
as
much
of
the
surface
intact
as
possible.
Wrap
debris
in
protective
sheeting
tape
it
shut
before
removing
it
from
the
work
room
and
the
building.


If
chemical
stripping
of
painted
surfaces
and
components
(
a
Level
1
task)
can
not
be
performed
off­
site
or
away
from
the
building,
use
caution
when
dry
hand
sanding
and/
or
scraping
any
remaining
dry
residue
left
over
from
the
chemical
stripper.


If
workers
leave
the
work
area
or
room
before
completion
of
the
task
and/
or
prior
to
final
clean­
up,
use
a
HEPA­
filter
equipped
vacuum
to
remove
any
visible
dust
from
protective
clothing
and
work
shoes,
dispose
of
protective
clothing
if
not
re­
usable,
and
wet
wipe
shoes
with
a
disposable
hand
towel.


If
the
task
is
not
completed
prior
to
the
end
of
the
day,
use
a
HEPA­
filter
equipped
vacuum
to
clean­
up
any
visible
dust.
Place
construction
debris
in
special
bags,
goose­
necking
and
taping
the
bags
shut.
Block
entrances
to
the
work
room
with
suitable
barriers
in
addition
to
hanging
protective
sheeting
over
any
doorways.
Draft
15
September
29,
1998
Final
Clean­
Up
removed
building
c
HEPA­
filtered
vacuum
worker
clothing
(
if
not
re
these
procedures
in
more
de
Post
Activity
Testing
Procedure
at
least
one
dust
sample
from
the
floo
recognized
laboratory
for
analysis.
If
an
recommended
dust
clearance
level
for
floo
procedure
in
the
work
area
or
room.
Draft
16
September
29,
1998
Extreme
Tasks
This
category
is
reserved
for
those
Level
3
tasks
that
require
a
greater
level
of
protection.
(
EPA
invites
comments
and
supporting
data
to
justify
moving
certain
tasks
to
Level
4
or
eliminating
this
category.)
Level
4:
Extre
Level
4
construction
ac
lead­
contaminated
dust
T
dangerous
to
occupants.

Lead
Dust
Minimization
Work
P
To
properly
limit
and
control
lead­
conta
debris
when
performing
these
tasks,
contrac
follow
the
specifications
below
using
the
tools
Exhibit
3
on
page
18.

Set­
Up
Procedures.
These
include
restricting
occupan
cleaning
occurs
and
post­
activity
dust
testing
is
complete,

during
the
work
day.
(
These
procedures
are
described
in
deta
Dust
Minimization
and
Control
Procedures
During
The
Work.


If
feasible,
wet
mist
the
affected
surfaces
and/
or
building
components.

components,
it
may
be
simpler
to
use
a
pressurized
garden
sprayer.


If
workers
leave
before
final
clean­
up,
use
a
HEPA­
filter
equip
remove
any
visible
dust
and
debris
from
protective
clothing
and
work
shoes,
and
shoes
with
a
disposable
hand
towel.
If
protective
clothing
is
not
re­
usable,
dispose
o
special
bag
before
leaving
the
work
room
and
put
on
new
protective
clothing
before
ret
to
the
work
room.


If
the
task
is
not
completed
prior
to
the
end
of
each
day,
all
horizontal
surfaces
must
be
vacuumed
using
a
HEPA­
filter
equipped
vacuum
and
any
construction
debris
must
be
placed
in
special
bags
goose­
necking
and
taping
the
bags
shut.
Restrict
access
to
the
work
room
with
suitable
barriers
in
addition
to
hanging
protective
sheeting
over
any
doorways.

Final
Clean­
Up
and
Waste
Disposal
Procedures.
Once
the
work
is
completed,
HEPA­
vacuum
the
protective
sheeting
before
wet
misting
and
discarding
it
in
special
bags,
clean
the
work
room
with
a
HEPA­
filtered
vacuum
and
wet
cleaning
solution,
and
HEPA­
vacuum
and/
or
discard
protective
clothing
(
if
not
re­
usable)
and
HEPA­
vacuum
work
shoes.
(
Exhibit
5
on
page
20
describes
these
procedures
in
more
detail.)

Post­
Activity
Testing
Procedures.
Conduct
lead
dust
testing
in
and
immediately
outside
the
work
room.
Collect
at
least
two
lead
dust
samples:
the
first
from
the
floor
of
the
work
room
and
the
second
from
a
floor
just
beyond
the
dust
containment
established
for
the
work
room.
Submit
the
samples
to
an
EPA­
recognized
laboratory
for
analysis.
If
any
dust
sample
exceeds
the
EPA/
HUD
or
state
recommended
dust
clearance
level
for
floors
(
whichever
is
more
stringent),

repeat
the
cleaning
procedure
in
the
work
room
or
immediately
outside
the
work
room,
or
both.

Occupants
should
not
be
permitted
access
to
or
re­
occupancy
of
the
work
room
or
zone
outside
the
containment
area
until
the
sample
results
document
that
dust
levels
are
at
or
below
the
EPA/
HUD
guidance
or
state
levels.
4
NIOSH,
January
1997,
"
Protecting
Workers
Exposed
to
Lead­
Based
Paint
Hazards,"
p.
50.

Draft
17
September
29,
1998
Prohibited
Tasks

Removing
paint
using
an
open
flame
torch
or
other
burning
apparatus;


Removing
paint
by
machine
sanding,
grinding,
abrasive
blasting,
or
sandblasting
without
HEPA
exhaust
control;


Removing
paint
by
dry
scraping
unless
performed
in
conjunction
with
heat
guns
or
around
electrical
outlets
or
when
treating
defective
paint
spots
totaling
no
more
than
2
ft
2
in
any
one
room,
hallway
or
stairwell;
and

Removing
paint
by
using
a
heat
gun
operating
at
temperatures
above
1100

F.
Level
5:
Proh
Some
tasks
generate
su
contaminated
dust
and
de
they
must
be
prohibited.
Th
the
potential
for
exposures
that
occupants
and
leave
highly
contam
can
only
be
made
safe
after
an
exhaus
decontamination
regimen.
Therefore,
no
minimization
work
practices
specification
i
the
risk
from
these
tasks
can
not
be
adequately
The
HUD
Guidelines
and
EPA's
current
renovation
guidelines
identified
these
activities
as
"
prohibited
practices."
The
Toxic
Substances
Control
Act
(
TSCA)

Section
402(
a)
rules,
as
promulgated
by
EPA,
also
prohibit
these
activities
during
lead­
based
paint
abatement.

Additionally,
NIOSH
recommends
against
open
flame
burning
during
home
renovation.
4
Therefore,
these
activities
are
prohibited
due
to
the
extreme
health
and
safety
risk
to
workers
and
occupants
as
well
as
the
availability
of
alternative
methods.
Alternatives
to
these
prohibited
tasks
include,
but
are
not
limited
to,
the
following
paint
removal
techniques:
use
of
heat
guns
operating
below
1,100

F;
use
o
strippers;
mechanical
sanding
with
a
special
HEPA
filtered
vacuum
attachment;
wet
scr
sanding;
and
replacing
components.
5This
category
is
reserved
for
those
Level
3
tasks
that
require
a
greater
level
of
protection.
Appropriate
tools,
supplies,
and
equipment
will
be
marked
for
tasks
which
may
be
added
to
this
category
in
the
future.

6Used
to
collect
and
contain
effluent
when
removing
paint
with
chemical
strippers.

Draft
18
September
29,
1998
Exhibit
3:
Tool
(
This
exhibit
is
an
overvie
Tools
Level
1
Level
2
Level
3
Level
4
5
Wet/
dry
sandpaper
or
wet
sandin
X
X
X
HEPA
filter­
equipped
vacuum
X
X
X
Two­
sided
bucket
or
two
buckets
with
wr
X
X
X
Disposable
hand
towels
X
X
X
Special
­
non­
permeable,
puncture
resistant
disposable
bags
X
X
X
Hand­
held
misting
device
X
X
X
Squeegee
or
wringer
mop
X
X
X
General
purpose
household
detergent
or
cleaning
agent
X
X
X
Protective
sheeting
­
non­
permeable,
puncture
resistant
disposable
sheeting
X
6
X
X
Chemical
stripping
agent
(
the
use
of
methylene
chloride
is
not
recommended)

X
Duct
tape
X
X
Razor
or
utility
knife
X
X
Machine
sander
with
HEPA­
filter
equipped
vacuum
X
Machine
planer
with
HEPA­
filter
equipped
vacuum
X
Protective
X
Staple
gun
X
Lead­
dust
sampling
supplies
(
wipes,
wipe
containers,

gloves,
templates
or
tape
measure,
lab
transmittal
form)

X
Draft
19
September
29,
1998
Level
1
1.
Minimize
access
to
immediate
work
area.
Do
not
allow
occupants
in
the
immediate
work
area
until
final
clean­
up
is
completed.

Level
2:
Level
1
PLUS
1.
Restrict
access
to
work
area.
Do
not
allow
occupants
in
work
area
during
the
work
and
until
final
cleanup
is
completed.
Establish
barriers
that
restrict
access.
2.
Contain
dust
in
work
area.


Turn
off
HVAC
systems.
Close
and
cover
duct
vents
in
the
work
area
with
protective
sheeting.

Disconnect
the
power
source
for
room
air
conditioner
and
cover
unit
with
protective
sheeting.


Cover
the
following
areas
with
protective
sheeting:
floor
directly
beneath
the
work
area
and
extending
out
at
least
4
feet;
pathway
from
the
entrance
of
the
work
area
to
the
exterior
doorway
of
the
building.


Remove
occupant
belongings
from
the
work
area
or
cover
them
with
protective
sheeting.


Use
duct
tape
or
equivalent
to
secure
all
protective
sheeting
to
the
floor
or
other
horizontal
surfaces.

3.
Take
safety
precautions.
If
removing
electrical
fixtures,
shut
off
electrical
power
to
the
work
area.

Level
3:
Level
2
PLUS
1.
Restrict
access
to
work
room.
Do
not
allow
occupants
in
work
room
during
work
and
until
final
clean­
up
and
post­
activity
dust
testing
are
completed.


Contain
dust
in
the
work
room.


Cover
the
following
areas
in
the
work
room
with
protective
sheeting:
floor;
duct
vents;
windows
(
unless
work
will
occur
on
these
surfaces).
Hang
two
layers
of
protective
sheeting
from
all
doorways
into
the
work
room.
Attach
sheeting
with
duct
tape
and
cut
a
vertical
slit
in
both
pieces
to
permit
worker
access.
2.
Take
added
safety
precautions.


In
occupied
multifamily
buildings,
post
lead
hazard
caution/
warning
signs
outside
the
apartment
unit
and
in
common
areas
(
e.
g.,
hallways
and
entry
foyers).


Instruct
workers
to
wear
protective
clothing.
Exhibit
4:

Level
4:
Level
3
PLUS
1.
Restrict
access
to
work
room
and
building.


Do
not
allow
occupants
in
work
room
until
final
clean­
up
and
post­
activity
dust
testing
are
completed.


Restrict
access
to
the
building
during
the
work
day.
Post
lead
hazard
caution/
warning
signs
directly
outside
the
building
entryway
and
only
allow
workers
to
enter
the
building
(
e.
g.,
install
barrier
caution
tape,
lock
entryway
doors,
erect
plywood
barriers).
Protective
sheeting
means
non­
permeable,
puncture
resistant
disposable
sheeting.
Draft
20
September
29,
1998
Level
1
1.
HEPA
vacuum
and
wet
clean
work
area.


Use
a
HEPA­
filtered
vacuum
to
remove
any
visible
dust
and
debris.


Wet
clean
using
disposable
hand
towels
or
a
squeegee
or
wringer
mop.
Fill
a
two­
sided
bucket
with
detergent
water
solution
on
one
side
and
clean
water
on
the
other
side.
Dip
the
towel
or
mop
in
the
detergent
solution
side
of
the
bucket
and
clean
the
area.
Wring
out
the
mop
or
take
a
fresh
towel,
dip
it
in
the
clean
water
side
of
the
bucket
and
clean
the
area
again.
Empty
the
waste
water
in
the
toilet.
2.
Place
debris
in
special
bag.
Place
any
debris
in
a
special
bag
and
dispose
according
to
applicable
state
and
federal
standards.
Contain
effluent
generated
during
on­
site
chemical
stripping
in
a
suitable
container.
(
Such
effluent
is
likely
to
be
"
hazardous
waste.")

Level
2:
Level
1
PLUS
1.
Wrap
all
removed
components
with
deteriorated
paint
in
protective
sheeting.
2.
Dispose
of
protective
sheeting.
Wet
mist
all
protective
sheeting
before
rolling
inward
to
capture
debris.
Tape
the
edges
shut
and
place
in
a
special
bag.
Goose
neck
the
bag
and
tape
it
shut.
Remove
the
bag
from
the
building.
3.
HEPA
vacuum
and
wet
clean
the
work
area
and
buffer
zone.
Extend
cleaning
procedures
to
all
area
covered
by
protective
sheeting
and
two
additional
feet.
4.
Clean
worker
clothing
before
leaving
the
work
area.
Clean
worker
clothing
and
shoes
using
a
HEPAfiltered
vacuum
to
remove
visible
dust
and
debris.
Wet
wipe
shoes
with
disposable
hand
towels.

Level
3:
Level
2
PLUS
1.
Dispose
of
removed
building
components
and
construction
debris.


Place
building
components
with
deteriorated
paint
and
larger
construction
debris
in
special
bags
or
wrap
in
protective
sheeting.
Use
duct
tape
to
secure
and
close.
Remove
components
from
the
building.


Dispose
of
waste
in
accordance
with
applicable
state
or
federal
guidelines.

2.
HEPA
vacuum
and
wet
clean
the
work
room.
Extend
cleaning
procedures
to
work
room,
cleaning
all
horizontal
and
vertical
surfaces
in
the
room.
Clean
all
hand
and
electric
tools
before
removing
them
from
the
work
room
with
a
HEPA­
filtered
vacuum
and
wet
cleaning
solution.
3.
HEPA
vacuum
or
dispose
of
worker
protective
clothing
before
leaving
the
work
room.
Once
the
room
is
cleaned,
HEPA
vacuum
and
then
remove
worker
protective
clothing.
If
not
re­
usable,
dispose
of
protective
clothing
in
special
bags
and
HEPA
vacuum
the
floor
where
clothing
was
removed.
Goose
neck
and
tape
bags
shut.
Remove
bags
from
the
building.

Level
4:
Level
3
PLUS
1.
Dispose
of
protective
sheeting.
Vacuum
all
protective
sheeting
on
horizontal
surfaces
with
HEPA­
filtered
vacuum
before
misting
and
discarding
sheeting.
2.
HEPA
vacuum
and
dispose
of
worker
protective
clothing.
After
the
room
is
cleaned,
use
a
HEPAfiltered
vacuum
to
remove
dust
from
protective
clothing.
If
not
re­
usable,
dispose
in
special
bags.
Exhibit
5:

Protective
sheeting
means
non­
permeable,
puncture
resistant
disposable
sheeting.

Special
bag
means
a
non­
permeable,
puncture
resistant
disposable
bag.
Draft
21
September
29,
1998
IV.
EXTER
BASIC
CON
Renovation,
remodeli
a
residential
property
bu
contaminated
dust
and
debr
extent
of
the
dust
and
debris
an
minimal
to
extremely
hazardous.

contaminated
dust
and
debris
should
screws,
are
so
unlikely
to
create
lead
co
This
chapter
groups
exterior
renovation,
remo
according
to
the
likelihood
each
task
level
has
fo
Lead
dust
minimization
work
practices
that
limit
contamination
the
environment
are
then
identified.

intended
to
apply
to
residential
properties
with
extensive
more
intense
dust
and
debris
containment
clean­
up
may
These
specifications
define
five
levels
of
lead­
dust­
generating
task
substantial,
extreme
and
prohibited.
As
Exhibit
6
on
page
23
illustra
dust
minimization
work
practices
for
each
level
increase
according
to
th
and
debris.
The
additional
precautions
associated
with
each
task
level
are
and
supplement
the
specifications
that
apply
to
lower
level
tasks.
For
exampl
trigger
the
work
practices
of
Level
2,
plus
extend
precautions
to
a
wider
buffer
z
that
protective
sheeting
be
extended
out
further
from
the
building.
"
Prohibited
task
included
in
Exhibit
6;
these
tasks
do
not
have
any
lead
dust
minimization
work
practic
recommendations
because
the
risk
lead
exposure
and
contamination
cannot
be
adequat
controlled.

Exhibit
7
on
page
24
identifies
which
common
renovation,
remodeling
and
repainting
tasks
fall
into
the
various
lead
dust­
generating
levels
and
also
briefly
describes
the
work
practice
specifications
appropriate
for
each.
This
table
thus
summarizes
the
chapter.
It
lists
the
common
tasks,
groups
those
tasks
by
their
likely
potential
to
create
lead
dust,
and
articulates
work
practices
designed
to
minimize
occupant
lead
exposures
and
limit
environmental
contamination
taking
into
account
cost
considerations.

For
example,
removing
paint
with
a
heat
gun
operating
under
1,100

F
is
considered
a
Level
3:

Substantial
Lead
Dust­
Generating
Task.
To
protect
occupants
and
workers,
it
is
recommended
that
contractors:
remove
or
cover
play
equipment
in
the
work
area
or
buffer
zone;
cover
the
ground,
windows
and
HVAC
compressor/
condenser
box
with
protective
sheeting;
and
turn
off
the
HVAC
system.
Final
clean­
up
requires
that
all
sheeting
be
vacuumed
and
wet­
misted
before
being
rolled­
up
and
disposed
of
in
a
special
bag.

Exhibit
7
also
does
not
include
Level
5:
Prohibited
Tasks
since
no
precautions
currently
can
be
recommended
to
enable
a
contractor
to
sufficiently
minimize,
control
and
clean­
up
lead­

contaminated
dust
and
debris.
The
following
methods
are
classified
as
prohibited:
dry
scraping
more
than
20
ft
2
of
total
exterior
surfaces;
use
of
an
open
flame
torch
or
other
burning
apparatus;
Draft
22
September
29,
1998
use
of
a
hea
or
sandblasting
In
the
pages
that
foll
associated
with
each
lev
discussed.
For
the
ease
of
facilitate
a
comparison
of
dus
identifies
the
tools,
supplies
and
9
describes
how
to
set­
up
the
work
procedures.
These
exhibits
are
consist
amount
of
dust
generated
during
renovati
precautions.
Exhibits
8,
9,
and
10
depict
ho
waste
disposal
procedures
increase
in
complexi
likely
dust
generation.
These
exhibits
are
located
32
for
easy
reference.
7Protective
sheeting
means
non­
permeable,
puncture
resistant
disposable
sheeting.

Draft
23
September
29,
1998
Exhibit
6:

(
This
exhibit
is
a
Level
4:
Extreme
Lead
Dust
Tasks

focus
on
residence,
larger
buffer
zone

restrict
residence
access
during
workday

erect
temporary
barriers
to
buffer
zone

perform
daily
cleaning

perform
expanded
final
cleaning
Level
3:
Substantial
Lead
Dust
Tasks

focus
on
work
area
and
buffer
zone

focus
on
work
area
and
buffer
zone
Level
2:
Moderate
Lead
Dust
Tasks

focus
on
work
area

restrict
access

clean
worker
clothing

use
protective
sheeting
to
10
ft.
7

wet
mist
surfaces,

if
feasible

perform
final
cleaning

conduct
visual
examination

focus
on
work
area

restrict
access

clean
worker
clothing

use
protective
sheeting
to
10
ft.


wet
mist
surfaces,

if
feasible

perform
final
cleaning

conduct
visual
examination

focus
on
work
area

restrict
access

clean
worker
clothing

use
protective
sheeting
to
10
ft.


wet
mist
surfaces,

if
feasible

perform
final
cleaning

conduct
visual
examination
Level
1:
Minimal
Lead
Dust
Tasks
none
Draft
24
September
29,
1998
Exhibit
7:
Lead­
Dust
Minimization
Work
Practices
For
Exterior
Renovation
Tasks
(
This
exhibit
is
an
overview
and
does
not
contain
some
items.
See
the
text
for
a
complete
discussion
of
each
level.)

Tasks
Performed
On
Painted
Surfaces
Occupant
Protection
Dust
Minimization
and
Containment
Final
Clean­
up
and
Waste
Disposal
Level
1:
Minimal
Lead
Dust­
Generating
Tasks

nailing

screwing

drilling

wet
sanding/
scraping
small
areas
(
less
than
20
ft2)


removing
paint
by
applying
and
removing
chemical
strippers

If
using
chemical
stripper,
place
protective
sheeting
directly
underneath
to
collect
effluent

Dispose
of
protective
sheeting
in
special
bag
or
container
Level
2:
Moderate
Lead
Dust­
Generating
Tasks

sawing

chiseling

prying
with
a
crow
or
pry
bar

dry
scraping
less
than
20
ft2

dry
sanding
less
than
20
ft2

wet
sanding/
scraping
more
than
2
ft2

removing
painted
components

removing
paint
with
an
orbital
or
belt
sander
equipped
with
a
HEPA­
filtered
vacuum

removing
paint
using
abrasive
blasting
with
a
HEPA­
filtered
vacuum

power­
washing
painted
surfaces
with
low­
pressure
equipment

focus
on
work
area

restrict
access
to
work
area

clean
worker
clothing
when
leaving
work
area

perform
visual
examination
for
paint
chips,
dust
and
debris

protective
sheeting
in
work
area
&
extend
out
10
ft.


mist
work
surfaces,
if
feasible

barriers
to
contain
run­
off
from
power
washing

wet
mist
protective
sheeting
&
roll
up

collect
paint
chips/
debris

dispose
of
debris
in
protective
sheeting
or
special
bags
Level
3:
Substantial
Lead
Dust­
Generating
Tasks

electric
planing

removing
paint
with
a
heat
gun
operating
under
1,100

F

dry
hand
sanding
or
hand
scraping
remaining
dry
residue
after
removing
paint
with
chemical
strippers

demolishing
painted
surfaces
using
either
hand
or
power
tools
LEVEL
2
plus

focus
on
work
area
&
buffer
zone

remove/
cover
play
equipment
LEVEL
2
plus

cover
windows
within
6
ft.
of
the
work
area
with
plastic
sheeting

turn
off
HVAC
if
compressor/
condenser
is
in
work
area/
buffer
zone
&
cover
with
protective
sheeting
LEVEL
2
Level
4:
Extreme
Hazards

removing
paint
using
high­
pressure
water
or
hydroblasting
equipment
LEVEL
3
plus

focus
on
residence
&
larger
buffer
zone

restrict
resident
access
during
day

restrict
access
with
temporary
fencing/
barrier
LEVEL
3
plus

cover
windows
&
HVAC
system
with
protective
sheeting

control
water
run­
off
and
debris
from
hydroblasting
LEVEL
2
plus

with
multi­
day
jobs,
full
cleaning
procedures
daily

collect
paint
chips/
debris
with
HEPA
vacuum
Draft
25
September
29,
1998
Protective
sheeting
means
non­
permeable,
puncture
resistant
disposable
sheeting.
Special
bag
means
a
non­
permeable,
puncture
resistant
disposable
bag.
Draft
26
September
29,
1998
Minimal
Lead
Dust­
Generating
Tasks

Nailing
into
painted
surfaces;


Screwing
into
painted
surfaces;


Drilling
into
painted
surfaces;


Wet
sanding
small
areas
(
less
than
20
ft2)
of
total
exterior
painted
surfaces;
and

Removing
paint
by
applying
and
removing
chemical
strippers.
Level
1:
M
Level
1
tasks
invo
using
hand
tools.
Th
than
minimal
amounts
o
and
debris
because
the
task
damage
large
surface
areas
or
heavy
abrasion
to
painted
surface
Lead
Dust
Minimization
Work
Prac
Specification
To
properly
limit
and
control
lead­
contaminated
dust
and
debris
when
performing
these
tasks,

contractors
should
follow
the
specifications
below
usi
Set­
Up
Procedures.
Level
1
requires
no
special
procedure
Dust
Minimization
and
Control
Procedures
During
the
Work
strippers
and
removing
the
wet
slurry
during
paint
removal,
place
pr
beneath
the
work
area
to
collect
and
contain
the
effluent.

Final
Clean­
Up
and
Waste
Disposal
Procedures.
After
applying
and
remo
strippers
during
paint
removal,
dispose
of
protective
sheeting
in
special
bags
or
(
Exhibit
10
on
page
32
describes
these
procedures
in
more
detail.)
Draft
27
September
29,
1998
Moderate
Lead
Dust­
Generating
Tasks

Sawing
painted
surfaces;


Chiseling
painted
surfaces;


Prying
painted
surfaces
using
a
crow
bar;


Dry
hand
scraping
more
than
2
ft
2
but
less
than
20
ft
2
of
total
exterior
painted
surfaces;


Dry
hand
sanding
more
than
2
ft
2
but
less
than
20
ft
2
of
painted
surfaces;


Wet
sanding/
scraping
more
than
2
ft
2
of
painted
surfaces;


Removing
painted
components
(
e.
g.,
doors,
stairs
and
landing
systems);


Dry
machine
sanding
using
an
electric
sander
with
a
HEPA­
filter
equipped
vacuum
attachment;


Removing
paint
using
abrasive
blasting
equipment
with
a
HEPA­

filter
vacuum
attachment;
and

Power­
washing
painted
surfaces
using
equipment
operating
at
a
pressure
of
less
than
5,000
pounds
per
square
inch
(
PSI).
Level
2:
M
Level
2
tasks
invo
removing
or
power­
w
Typically,
the
activity
a
greater
surface
area
is
inv
performed
wet
or
by
using
a
s
HEPA­
filter
equipped
vacuum
at
the
dispersal
of
dust
and
debris.
Th
to
create
a
moderate
amount
of
lead­
co
dust.

Lead
Dust
Minimization
Work
Practices
Specification
To
properly
limit
and
control
lead­
contaminated
dust
and
debris
when
performing
these
tasks,
contractors
should
follow
the
specifications
below
using
the
tools
listed
in
Exhibit
8
on
page
30.

Set­
Up
Procedures.
These
include:
restricting
occupant
access
to
the
immediate
work
area;
placing
protective
sheeting
under
the
work
area
and
extending
out
10
feet;
and
adjusting
protective
sheeting
to
control
run­
off
during
power
washing.
(
These
procedures
are
described
in
detail
in
Exhibit
9
on
page
31.)

Dust
Minimization
and
Control
Procedures
During
the
Work.


To
the
extent
feasible,
wet
mist
affected
building
components
and
surfaces
with
either
a
hand­

held
wet
misting
bottle
or
a
pressurized
garden
sprayer.
Components
at
higher
elevations
may
be
more
effectively
misted
from
the
ground
using
a
pressurized
garden
sprayer.


Wipe
contractor
shoes
with
disposable
towels
moistened
with
a
wet
cleaner,
remove
visible
dust
from
clothing
before
walking
off
the
protective
sheeting,
and
vacuum
clothing
with
a
HEPA­
filter
equipped
vacuum.


Do
not
enter
the
residence
wearing
work
clothes,
unless
clothes
have
been
HEPA
vacuumed
and
shoes
wiped
clean.

Final
Clean­
Up
and
Waste
Disposal
Procedures.
Once
the
work
is
completed,
wet
mist
and
dispose
of
protective
sheeting,
dispose
of
debris
from
power
washing,
and
remove
any
visible
paint
chips
or
debris.
(
Exhibit
10
on
page
32
describes
these
procedures
in
more
detail.)

Post­
Activity
Testing.
Conduct
a
visual
examination
of
the
work
area
and
surrounding
area
to
check
for
any
remaining
visible
paint
chips
and
debris.
Draft
28
September
29,
1998
Substantial
Lead
Dust­
Generating
Tasks

Using
an
electric
planer
on
surfaces;


Removing
paint
with
a
heat
gun
operating
under
1,100
o
F;


Dry
hand
sanding
or
scraping
remaining
dry
residue
after
removing
paint
with
chemical
strippers;
and

Demolishing
painted
surfaces
using
either
hand
or
power
tools
(
e.
g.,
sledge
hammer,
maul,
circular
or
reciprocating
saw).
Level
3:
S
Level
3
tasks
invo
painted
surface
areas
work
wet)
or
heating
pa
activities
can
release
substa
contaminated
dust
or
create
le
sanding
or
scraping
any
remainin
from
chemical
stripping
to
remove
p
task)
can
also
create
lead­
contaminated
Lead
Dust
Minimization
Work
Practices
Specification
To
properly
limit
and
control
lead­
contaminated
dust
and
debris
when
performing
these
tasks,

contractors
should
follow
the
specifications
below
using
the
tools
listed
in
Exhibit
8
on
page
30.

Set­
Up
Procedures.
These
include:
restricting
access
to
the
work
si
household
items;
extending
protective
sheeting
out
10
feet;
and
coverin
outdoor
HVAC
system
elements.
(
These
procedures
are
described
in
detai
31.)

Dust
Minimization
and
Control
Procedures
During
the
Work.


To
the
extent
feasible,
wet
mist
the
affected
components
and
surfaces.
Components
at
l
elevations
can
be
misted
using
a
hand­
held
wet
misting
bottle
or
a
pressurized
garden
spraye
Components
at
higher
elevations
may
be
more
effectively
misted
from
the
ground
using
a
pressurized
garden
sprayer.
Such
misting
is
not
appropriate
before
using
a
heat
gun.


Vacuum
work
clothes
with
a
HEPA­
filter
equipped
vacuum
and
wipe
work
shoes
with
disposable
towels
moistened
with
a
wet
cleaner
before
walking
off
the
protective
sheeting.


Do
not
enter
residence
wearing
work
clothes,
unless
work
clothes
have
been
removed
or
HEPA
vacuumed
and
shoes
cleaned.

Final
Clean­
Up
and
Waste
Disposal
Procedures.
These
are
identical
to
those
for
Level
2.

Once
the
work
is
completed,
wet
mist
and
dispose
of
protective
sheeting
and
remove
any
visible
paint
chips
or
debris.
(
Exhibit
10
on
page
32
describes
these
procedures
in
more
detail.)

Post­
Activity
Testing.
Conduct
a
visual
examination
of
the
work
area
and
surrounding
area
to
check
for
any
remaining
visible
paint
chips
and
debris.
Draft
29
September
29,
1998
Extreme
Lead
Dust­
Generating
Tasks

Removing
paint
by
using
water
or
hydro­
blasting
equipment
operating
at
a
pressure
in
excess
of
5,000
pounds
per
square
inch
(
PSI);
and

This
category
is
also
reserved
for
those
Level
3
tasks
that
require
a
greater
level
of
protection.
(
EPA
invites
comments
and
supporting
data
to
justify
ceding
tasks
to
Level
4
or
for
eliminating
this
category.)
Level
4:
E
Level
4
constructi
amounts
of
lead­
cont
occupants
being
highly
d
Lead
Dust
Minimization
Wo
Specification
To
properly
limit
and
control
lead­
cont
and
debris
when
performing
these
tasks,
c
should
follow
the
specifications
below
using
listed
in
Exhibit
8
on
page
30.

Set­
Up
Procedures.
These
include:
placing
warning
signs
at
the
site;
restricting
access
to
the
work
site
and
entryways
near
the
work
area;
removing
nearby
occupant
b
to
control
water
run­
off
and
debris
from
hydroblasting;
and
co
components
within
20
feet
of
the
work
area.
(
These
procedures
a
9
on
page
31.)

Dust
Minimization
and
Control
Procedures
During
the
Work.


Wet
mist
affected
components
and
surfaces.
Components
at
lower
elevations
c
using
a
hand­
held
wet
misting
bottle
or
pressurized
garden
sprayer.
Components
a
elevations
may
be
more
effectively
misted
from
the
ground
using
the
garden
sprayer.


Vacuum
disposable
protective
clothing
with
a
HEPA­
filter
equipped
vacuum
and
wipe
s
with
disposable
hand
towels
moistened
with
a
wet
cleaner
before
walking
off
the
protective
sheeting.
If
not
re­
usable,
dispose
of
protective
clothing
in
special
bags.


Do
not
enter
the
residence
while
wearing
protective
clothing.


When
hydroblasting,
limit
the
volume
of
water
used
and
take
steps
to
control
water
run­
off
to
avoid
contamination
of
the
nearby
environment
and
possible
contamination
of
the
sewers
and
storm
drains.
For
example,
minimize
the
flow
of
water
over
collected
debris
(
e.
g.,
if
structure
is
on
a
grade
begin
on
the
uphill
side
and
work
down
grade).
Collect
any
wet
debris
promptly
and
dispose
of
it
in
special
bags.
Wastewater
should
be
controlled
in
accordance
with
applicable
Federal,
State,
and
local
standards.

Final
Clean­
Up
and
Waste
Disposal
Procedures.
Perform
extensive
daily
cleaning,
wet
mist
and
dispose
of
protective
sheeting
in
special
bags,
and
remove
any
visible
paint
chips
or
debris
with
a
HEPA­
filtered
vacuum.
(
Exhibit
10
on
page
32
describes
these
procedures
in
more
detail.)

Post­
Activity
Testing
Procedures.
Conduct
a
visual
examination
of
the
work
area
and
surrounding
area
to
check
for
any
remaining
visible
paint
chips
and
debris.
8
NIOSH,
January
1997,
"
Protecting
Workers
Exposed
to
Lead­
Based
Paint
Hazards,"
p.
50.

Draft
30
September
29,
1998
Prohibited
Construction
Tasks

Removing
paint
using
an
op
torch
or
other
burning
apparatu

Removing
paint
by
machine
sandi
grinding,
abrasive
blasting,
or
sandblasting
without
HEPA
exhaust
control;


Removing
paint
by
dry
scraping
unless
performed
in
conjunction
with
heat
guns
or
around
electrical
outlets
or
when
treating
defective
paint
spots
totaling
no
more
than
20
ft
2
on
exterior
surfaces;
and

Removing
paint
by
using
a
heat
gun
operating
at
temperatures
above
1100

F.
Level
5:
P
Some
tasks
genera
of
lead­
contaminated
occupants
that
they
mus
eliminate
the
potential
for
e
seriously
injure
occupants,
con
surrounding
the
building,
and
eve
to
enter
through
unguarded
interior
spaces.
Therefore,
no
lead­
related
wor
specification
is
provided
as
the
risk
can
no
adequately
controlled.

The
HUD
Guidelines
and
EPA's
current
renovation
guidelines
identified
these
activities
as
"
prohibited
practices."
The
TSCA
Section
402(
a)

rules,
as
promulgated
by
EPA,
also
prohibit
these
activities
during
lead­
based
paint
abatement.

Additionally,
NIOSH
recommends
against
open
flame
burning
during
home
renovation.
8
Therefore,

these
activities
are
prohibited
due
to
the
extreme
health
and
safety
risk
to
occupants.
9This
category
is
reserved
for
those
level
3
tasks
that
require
a
greater
level
of
protection
.
Appropriate
tools,
supplies,
and
equipment
will
be
marked
for
the
tasks
that
may
be
added
to
this
category
in
the
future.

10Used
to
collect
and
contain
effluent
when
removing
paint
with
chemical
strippers.

Draft
31
September
29,
1998
Exhibit
8:

(
This
exhibit
is
an
ov
Tools
Level
1
Level
2
Level
3
Level
4
9
Wet/
dry
sandpaper
or
wet
s
X
X
X
HEPA
filter­
equipped
vacuum
X
X
X
Disposable
hand
towels
X
X
X
Special
­
non­
permeable,
punctur
disposable
bags
X
X
X
Hand­
held
misting
device
and/
or
pressurized
sprayer
X
X
Protective
sheeting
­
non­
permeable,
puncture
resis
disposable
sheeting
X
10
X
X
X
Duct
tape
X
X
X
Two
by
four
planks/
boards
or
other
items
to
anchor
protective
sheeting
X
X
X
Machine
sander
with
HEPA­
filter
equipped
vacuum
X
Power
washing
equipment
(
including
run­
off
control
and
filtering
supplies)

X
Abrasive
blasting
equipment
with
a
HEPA­
filter
equipped
vacuum
X
Equipment
to
seal
off
the
work
area
(
e.
g.,
barrier
tape,

temporary
fencing)

X
X
Warning
signs
X
X
Hydro­
blasting
equipment
(
including
run­
off
control
and
filtering
supplies)

X
Protective
clothing
X
Chemical
stripping
agent
(
the
use
of
methylene
chloride
is
not
recommended)

X
Draft
32
September
29,
1998
Level
1
requires
no
special
procedures.
1
Level
2
1.
Minimize
access
to
immediate
work
area.
Do
not
allow
occupants
in
the
immediate
work
area
and
6
feet
beyond.
2.
Cover
ground
with
protective
sheeting.
Place
protective
sheeting
under
the
work
area
and
extend
out
at
least
10
feet.
Tape
sheeting
to
the
building
foundation.
Tape
outside
edges
to
hard
surfaces
or
weight
down
edges
with
2
by
4
planks/
boards
or
similar
objects
to
secure
to
the
ground.
If
a
ladder
is
used,
cut
slits
in
the
sheeting
to
allow
the
bottom
to
rest
on
the
ground.
3.
Adjust
protective
sheeting
to
control
run­
off
during
power
washing.
Raise
edges
of
protective
sheeting
to
create
a
basin
that
controls
run­
off.
Establish
procedures
to
capture
wet
debris
(
e.
g.,
filter
run­
off
with
cheesecloth).

Level
3:
Level
2
PLUS
1.
Restrict
access
to
the
work
site.
Restrict
access
to
the
work
site
from
non­
workers
by
installing
barrier
tape,
warning
signs,
and/
or
fencing.
If
feasible,
request
that
occupants
leave
the
building
when
work
occurs.
2.
Remove
nearby
occupant
belongings.
Remove
toys
and
play
equipment
and
cover
sandboxes
within
20
feet
of
the
work
area
with
protective
sheeting.
3.
Cover
some
windows
and
some
outdoor
HVAC
system
components.
Cover
windows
within
6
feet
of
the
work
area
with
protective
sheeting.
If
the
HVAC
compressor/
condenser
box
is
near
the
work
area
or
could
be
contaminated
with
dust
and
debris,
turn
off
the
HVAC
system
and
cover
the
compressor/
condenser
box
with
protective
sheeting.

Level
4:
Level
3
PLUS
1.
Place
warning
signs.
Place
signs
warning
of
potential
lead
hazards
on
the
building
and
along
the
20­
foot
perimeter
of
the
work
site.
2.
Restrict
access
to
work
site
and
entryways.
Erect
temporary
fencing
or
barrier
tape
along
a
20
foot
perimeter
from
the
work
area.
Do
not
allow
occupants
to
use
doorways
within
10
feet
of
the
work
area
and
provide
an
alternative
entryway.
Alternatively,
construct
an
enclosure
to
retain
lead
dust
and
debris.
3.
Cover
added
windows
and
outdoor
HVAC
system
components.
Cover
windows
within
20
feet
of
the
work
area.
Cover
any
compressor/
condenser
box
within
20
feet
of
the
work
area.
Exhibit
9:

Protective
sheeting
means
non­
permeable,
puncture
resistant
disposable
sheeting.
Draft
33
September
29,
1998
Level
1:
Application
and
removal
of
chemical
strippers
only.
1.
After
applying
and
removing
chemical
strippers
during
paint
removal,
dispose
of
protective
sheeting
in
special
bags
or
containers.

Level
2
1.
Dispose
of
wet
debris
from
power
washing
and
protective
sheeting.
Place
any
wet
debris
from
power
washing
in
a
special
bag.
Wet
mist
all
protective
sheeting
used
during
all
other
tasks
before
rolling
inward
to
capture
debris.
Tape
the
edges
shut
and
place
the
sheeting
in
a
special
bag.
Goose
neck
all
special
bags
and
tape
shut.
Remove
bags
from
the
work
area
and
dispose
according
to
applicable
state
and
federal
standards.
Use
a
durable
container
for
heavy
or
sharp
edged
debris.
2.
Remove
paint
chips
and
debris.
After
removing
protective
sheeting,
clean
up
any
remaining
visible
paint
chips
and
debris.
Place
all
debris
in
a
special
bag.
Remove
bag
from
work
area
and
dispose
according
to
applicable
state
and
federal
standards.

Level
3:
Same
as
Level
2
1
Level
4:
Level
3
PLUS
1.
Perform
daily
cleaning.
If
the
work
extends
beyond
one
day,
disposal
of
protective
sheeting
and
removal
of
paint
chips
and
debris
with
a
HEPA­
filtered
vacuum
must
occur
daily
as
well
as
at
the
end
of
the
job.
During
hydroblasting,
collect
run­
off
and
remove
wet
debris
daily.
2.
Dispose
of
debris
from
hydroblasting.
Collect
all
wet
debris
and
filtered
runoff.
Place
in
special
bags
and
dispose
according
to
state
and
federal
standards.
Exhibit
10:

Protective
sheeting
means
non­
permeable,
puncture
resistant
disposable
sheeting.

Special
bag
means
non­
permeable,
puncture
resident
disposable
bags.
Draft
34
September
29,
1998
REFEREN
Amitai,
Y.,
Brow
the
Blood
Lead
Leve
ARAMSCO
Products
Cata
Bates,
M.,
Wyatt
R,
et.
Al.,
"
Old
Medical
Journal
1997;
110(
1053):
3
Bellinger,
D.,
Leviton,
A.,
et
al.
"
Correla
years
of
age,"
Pediatrics
1986;
77:
826­
33.

Buchwald­
Fellis,
M.
November
1997.
"
Presentat
Conference."

California
Department
of
Health
Services,
Occupational
Le
March
1996.
Painting
Contractors
Guide
to
Lead
Safety.

California
Department
of
Health
Services,
Occupational
Lead
Poiso
February
1998.
California
Painters
Project:
Helping
Small
Business
W
Dixon,
S.,
Tohn,
E.
February
1998.
"
How
Much
Cleaning
is
Enough?"
(
sub
publication)

Farfel,
M.
R.
and
Chisolm,
J.
J.
Jr.
1990.
"
Health
and
Environmental
Outcomes
of
Tra
Modified
Practices
for
Abatement
of
Residential
Lead­
Based
Paint."
American
Journal
Health.
80(
10):
1240­
1245.

Marino,
P.
E.,
Landrigan,
P.
J.,
et
al.
"
A
Case
Report
of
Lead
Paint
Poisoning
During
Renovation
of
a
Victorian
Farmhouse,"
American
Journal
of
Public
Health,
October
1990,
80(
10):
1183­

1185.

Maryland
annotated
code,
26.16.03E(
2).

Minnesota
Department
of
Health,
"
Safely
Working
With
Lead
While
Remodeling
the
Older
Home:
Testing
the
Home
for
Lead;
Removing
Carpet;
Taking
Down
and
Wall;
Removing
Paint
From
Exterior
Surfaces;
Removing
and
Covering
Interior
Paint;
Replacing
Doors,
Windows
and
Trim;
Working
with
Soil;
Disposal
of
Lead­
Contaminated
Waste."

National
Association
of
the
Remodeling
Industry,
(
undated).
HUD/
NARI
Lead
Remodeler's
Training
Program.

National
Environmental
Training
Association,
1997.
Lead­
Based
Paint
Maintenance
Training
Program:
Work
Smart,
Work
Wet
and
Work
Clean
to
Work
Lead
Safe.

National
Institute
of
Building
Sciences,
May
1995.
Lead­
Based
Paint:
Operations
and
Maintenance
Work
Practices
Manual
for
Homes
and
Buildings.
Draft
35
September
29,
1998
National
Ins
University,
Ath
NIOSH,
July
1997.

Rabinowitz,
M.,
Leviton,
A
American
Journal
of
Public
H
Sussell,
A.
ed.,
January
1998.
"
Pro
Report
to
Congress."
(
NIOSH
Publica
Sussell,
A.,
March
1998.
"
Letter
to
Ms.
Lyn
Sussell,
A.
February
1998.
"
Presentation
at
New
E
Tohn,
E.,
October
1997.
"
A
Preliminary
Review
of
the
Maintenance
Practices
and
Lead
Disclosure."

U.
S.
Department
of
Housing
and
Urban
Development
(
HUD),
19
Paint
Abatement
Demonstration
(
Fair
Housing
Administration).
(
H
U.
S.
HUD,
June
1995.
Guidelines
For
The
Evaluation
and
Control
of
Le
Hazards
in
Housing.

U.
S.
HUD,
July
1995.
Lead­
Based
Paint
Hazard
Reduction
and
Financing
Task
F
the
Pieces
Together:
Controlling
Lead
Hazards
in
the
Nation's
Housing.

U.
S.
HUD,
July
1995.
Regulatory
Impact
Analysis
of
the
Proposed
Rule
on
Lead­
Based
Pa
Requirements
for
Notification,
Evaluation
and
Reduction
of
Lead­
Based
Paint
Hazards
in
Federally­
Owned
Residential
Property
and
Housing
Receiving
Federal
Assistance.

U.
S.
HUD,
June
1996.
HUD
Issues
Proposed
Rule
to
Revise
Its
Lead­
Based
Paint
Regulations
for
Federally
Owned
Residential
Property
and
Housing
Receiving
Federal
Assistance.

U.
S.
HUD,
March
1998.
Evaluation
of
the
HUD
Lead­
Based
Paint
Hazard
Control
Grant
Program:
Fifth
Interim
Report.

U.
S.
Environmental
Protection
Agency
(
EPA),
July
1994.
"
Guidance
on
Residential
Lead­
Based
Paint,
Lead
Contaminated
Dust,
and
Lead
Contaminated
Soil."
(
60
FR
47248)

U.
S.
EPA,
1995.
A
Review
of
Studies
Addressing
Lead
Abatement
Effectiveness.
(
EPA
747­
R­

95­
006)

U.
S.
EPA,
February
1995.
Comprehensive
Abatement
Performance
Pilot
Study:
Volume
1:

Results
of
Lead
Data
Analysis.
(
EPA
747­
R­
93­
007)

U.
S.
EPA,
March
1995.
Laboratory
Evaluation
of
Dust
and
Dust
Lead
Recoveries
for
Samplers
and
Vacuum
Cleaners:
Volume
1:
Objectives,
Methods
and
Results.
(
EPA
747­
R­
94­
004A)
Draft
36
September
29,
1998
U.
S.
EPA,
M
Summary;
Volu
008)

U.
S.
EPA,
September
1
K­
97­
001.

29
CFR
Part
1926,
Lead
Exposu
40
CFR
Part
745,
Requirements
for
Le
11
Many
of
these
definitions
are
excerpted
from
40
CFR
745.223
and
the
US
Department
of
Housing
and
Urban
Development,
Guidelines
for
the
Evaluation
and
Control
of
Lead­
Based
Paint
Hazards
in
Housing,
1995,
pp.
G
1
­
G­
14.

Draft
37
September
29,
1998
GLOSSAR
Abatement:
A
m
hazards
or
lead­
based
lead­
based
paint,
perma
painted
surfaces
or
fixtures
strategies
require
preparation,

Accreditation:
formal
recogniti
carry
out
specific
tasks
or
types
of
test
Accredited
laboratory:
A
laboratory
that
h
Laboratory
Accreditation
Program
(
NLLAP)
to
over
a
specified
period
of
time.

Bare
soil:
Soil
not
covered
with
grass,
sod,
some
other
the
sand
in
sandboxes.

Building
component:
Any
element
of
a
building
that
may
be
pa
(
e.
g.,
walls,
stair
treads,
floors,
railings,
doors,
window
sills,
etc.).

Certification:
The
process
of
testing
and
evaluating
against
certain
speci
competence
of
a
person,
organization
or
other
entity
in
performing
a
function
for
a
specified
period
of
time.

Certified:
The
designation
for
contractors
who
have
completed
training
and
other
req
to
allow
them
to
safely
undertake
risk
assessments,
inspections
or
abatement
work.
Risk
assessors,
inspectors
and
abatement
contractors
should
be
certified
by
the
appropriate
state
o
EPA
pursuant
to
§
745.226(
f).

Clearance
examination:
Visual
examination
and
collection
of
environmental
samples
by
an
inspector
or
risk
assessor
and
analysis
by
an
accredited
laboratory
upon
completion
of
an
abatement
project,
interim
control
intervention,
or
maintenance
job
that
disturbs
lead­
based
paint
(
or
paint
suspected
of
being
lead­
based).
The
clearance
examination
is
performed
to
ensure
that
lead
exposure
levels
do
not
exceed
standards
established
by
the
EPA
Administrator
pursuant
to
Title
IV
of
the
Toxic
Substances
Control
Act,
and
that
any
cleaning
following
such
work
adequately
meets
those
standards.

Code
of
Federal
Regulations
(
CFR):
The
codification
of
the
regulations
of
Federal
agencies.

The
regulations
are
published
in
the
Federal
Register.
Draft
38
September
29,
1998
Common
a
area
may
inclu
community
center
Containment:
A
proce
the
lead­
contaminated
dust
Deteriorated
paint:
Paint
that
i
from
the
substrate
of
building
com
Elevated
blood
lead
level
(
EBL)
child:

to
10
µ
g/
dl.

Hazardous
waste:
As
defined
in
EPA
regulations
waste
or
combination
of
solid
wastes
that
because
o
chemical
or
infectious
characteristics
may
cause
or
signi
mortality,
serious
and
irreversible
or
incapacitating
but
reve
present
or
potential
hazard
to
hum
health
or
the
environment
w
or
disposed.
As
defined
in
the
regulations,
solid
waste
is
hazardo
conditions:
(
1)
exhibits
a
characteristic
of
hazardous
waste
(
40
CFR
262.24);
(
2)
has
been
listed
as
hazardous
(
40
CFR
Section
261.31
throu
mixture
containing
a
listed
hazardous
waste
combined
with
a
non­

the
mixture
is
specifically
excluded
or
no
longer
exhibits
any
of
the
character
waste;
and
(
4)
not
excluded
from
regulation
as
hazardous
waste.
For
lead­
bas
abatement
waste,
hazardous
waste
is
waste
that
contains
more
than
5
ppm
of
leacha
determined
by
the
TCLP
test,
or
is
waste
that
is
corrosive,
ignitable,
or
reactive
and
n
excluded.

Heat
gun:
A
device
capable
of
heating
lead­
based
paint
causing
it
to
separate
from
the
substra
For
lead
hazard
control
work,
the
heat
stream
leaving
the
gun
should
not
exceed
1,100

F
(
some
authorities
may
use
a
different
temperature).

High­
Efficiency
Particulate
Air
(
HEPA)
filter:
A
filter
capable
of
removing
particles
of
0.3
microns
or
larger
from
air
at
99.97
percent
or
greater
efficiency.

Inspection
(
of
paint):
A
surface­
by­
surface
investigation
to
determine
the
presence
of
lead­

based
paint
and
a
report
explaining
the
results
of
the
investigation.

Inspector:
An
individual
who
has
completed
training
from
an
accredited
program
as
defined
by
40
CFR
Part
745
and
certified
by
EPA
pursuant
to
40
CFR
745.226
to
conduct
inspections.
A
certified
inspector
also
samples
for
the
presence
of
lead
in
dust
and
soil
for
the
purposes
of
abatement
clearance
testing.

Interim
controls:
A
set
of
measures
designed
to
temporarily
reduce
human
exposures
to
lead­

based
paint
hazards
including
specialized
cleaning,
repairs,
maintenance,
painting,
temporary
containment,
and
ongoing
monitoring
of
lead­
based
paint
hazards
or
potential
hazards,
and
the
establishment
and
operation
of
management
and
resident
education
programs.
Interim
controls
Draft
39
September
29,
1998
include,
but
impact
surface
Interior
window
sill
of
the
room,
adjacent
to
stool).
Laboratory
analysis:
A
determ
inductively
coupled
plasma
emissio
or
an
equivalent
method.

Lead:
Lead
includes
metallic
lead
and
inorg
Lead­
based
paint
or
lead
paint:
Paint
or
other
s
greater
than
1.0
mg/
cm
2
or
more
than
0.5
percent
by
mg/
kg).
(
Local
definitions
may
vary.)

Lead­
based
paint
hazard:
Any
condition
that
causes
exposu
dust,
lead­
contaminated
soil,
or
lead­
contaminated
paint
that
is
de
accessible
surfaces,
friction
surfaces,
or
impact
surfaces
that
would
effects
as
identified
by
the
Administrator
pursuant
to
TSCA
section
40
Lead­
based
paint
hazard
control:
Activities
to
control
and
eliminate
lead­

including
interim
controls,
abatement
and
complete
abatement.

Lead­
contaminated
dust
or
lead
dust:
Surface
dust
in
residential
dwellings
or
child
facilities
that
contain
an
area
or
mass
concentration
of
dust
in
excess
of
the
standard
esta
by
the
EPA
Administrator,
pursuant
to
Title
IV
of
the
Toxic
Substances
Control
Act.
Until
EPA
standards
are
set,
the
HUD­
and
EPA­
recommended
clearance
and
risk
assessment
standa
for
leaded
dust
are
100
µ
g/
ft
2
on
floors,
500
µ
g/
ft
2
on
interior
window
sills
and
800
µ
g/
ft
2
on
window
troughs.

Lead­
contaminated
soil:
Bare
soil
on
residential
real
property
on
the
property
of
a
child­

occupied
facility
that
contains
lead
in
excess
of
the
standard
published
by
the
EPA
Administrator,

pursuant
to
Title
IV
of
the
Toxic
Substances
Control
Act.
The
HUD­
recommended
standard
and
interim
EPA
guidance
is
400
µ
g/
g
for
high­
contact
play
areas
and
2,000
µ
g/
g
in
other
bare
areas
of
the
yard.
EPA
and
HUD
recommend
that
soil
contaminated
with
lead
at
levels
greater
than
or
equal
to
5,000
µ
g/
g
be
abated
by
removal
or
paving.

Lead­
free
dwelling:
A
lead­
free
dwelling
contains
no
lead­
based
paint
and
has
interior
dust
and
exterior
soil
lead
levels
below
the
applicable
HUD
and
EPA
standards.

Lead­
poisoned
child:
A
child
with
a
single
blood
lead
level
that
is
greater
than
or
equal
to
20
µ
g/
dl
or
consecutive
blood
lead
levels
greater
than
or
equal
to
15
µ
g/
dl.
Local
definitions
may
vary.
Multifamily
housing:
Housing
that
contains
more
than
one
dwelling
unit
per
location.
Draft
40
September
29,
1998
NLLAP
req
Accreditation
P
matrixes
by
an
EP
Off­
site
paint
removal
paint
from
the
component
Protective
sheeting:
Non­
perm
completely
containing
lead­
contami
sealed,
should
remain
tight
with
no
vis
Renovation:
Work
that
involves
constructio
such
as
window
replacement,
weatherization,
re
Replacement:
Removal
of
building
components
(
su
installation
of
new
components.

Risk
assessment:
(
1)
An
onsite
investigation
to
determine
to
location
of
lead­
based
paint
hazards,
and
(
2)
the
provision
of
a
re
conducting
the
risk
assessment.

Risk
assessor:
A
certified
individual
who
has
completed
training
by
an
a
program
as
defined
in
40
CFR
Part
745
and
certified
by
EPA
pursuant
to
40
conduct
risk
assessments.
A
risk
assessor
also
samples
for
the
presence
of
lead
for
the
purposes
of
abatement
clearance
testing.

Solid
waste:
As
defined
by
RCRA,
the
term
solid
waste
means:
garbage,
refuse,
sludge
waste
treatment
plant,
water
supply
treatment
plant,
or
air
pollution
control
facility;
or
other
discarded
materials,
including
solid,
liquid,
semi­
solid
or
contained
gaseous
material
resulting
from
industrial,
commercial,
mining,
and
agricultural
operations
or
from
community
activities.

The
term
does
not
include
solid
or
dissolved
material
in
irrigation
return
flows
or
industrial
discharges
(
which
are
point
sources
subject
to
permits
under
the
Clean
Water
Act),
nor
does
the
term
include
special
nuclear
or
by­
product
material
as
defined
by
the
Atomic
Energy
Act
of
1954.

Special
bags:
Non­
permeable,
puncture
resistant,
heavy­
duty
disposable
bags
that
are
capable
completely
containing
lead­
contaminated
dust
and
debris
or
other
waste
and,
after
being
properly
sealed,
should
remain
tight
with
no
visible
signs
of
discharge
during
movement
or
relocation.

Spectrum
analyzer:
A
type
of
XRF
analyzer
that
provides
the
operator
with
a
plot
of
the
energy
and
intensity,
or
counts
of
both
K
and
L
x­
ray
spectra,
as
well
as
a
calculated
lead
concentration.

Substrate:
A
surface
on
which
paint,
varnish,
or
other
coating
has
been
applied
or
may
be
applied.
Examples
of
substrates
include
wood,
plaster,
metal
and
drywall.

Toxicity
Characteristic
Leaching
Procedure
(
TCLP):
A
laboratory
test
to
determine
if
excessive
levels
of
lead
or
other
hazardous
materials
could
leach
from
a
sample
into
groundwater
(
usually
used
to
determine
if
waste
is
hazardous
based
on
its
toxicity
characteristics).
Draft
41
September
29,
1998
Trained:
S
control
work,
t
program,
pursuan
Window
trough:
For
a
between
the
interior
windo
storm
window,
the
window
tr
sashes
when
they
are
both
lower
Window
well:
The
space
that
provide
grade
(
i.
e.,
below
the
level
of
the
surroun
Work
area:
The
immediate
area
in
which
wor
extending
out
at
least
four
feet.

XRF
analyzer:
An
instrument
that
determines
lead
con
centimeter
(
mg/
cm
2
)
using
the
principle
of
x­
ray
fluorescen
analyzers
are
used
 
direct
readers
and
spectrum
analyzers.
Th
portable
instruments
manufactured
to
analyze
paint
and
does
not
portable
instruments
designed
to
analyze
soil.

µ
g:
Micrograms.
The
prefix
micro
means
1/
1,000,000
(
or
one­
millionth
1/
1,000,000
of
a
gram
and
1/
1,000
of
a
milligram,
equal
to
about
35/
1,000,00
of
an
ounce
(
an
ounce
is
equal
to
28,400,000
µ
g).
