Good Morning! Course Overview US EPA Lead Risk Assessor Course - - PDF document

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Good Morning!

Course Overview US EPA Lead Risk Assessor Course Overview

• At the end of this course, students

should be able to:

–define lead-based paint risk assessment –follow the steps in the EPA & HUD lead based paint risk assessment protocol

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

2 Course Overview

Key Definitions

–Risk Assessment: An on-site investigation of a residential dwelling for LBP hazards –Inspection: A surface by surface investigation for determining the presence of LBP (sometimes lead in dust/soil) and reporting the results

Course Overview

Key Definitions

–LBP Hazard: lead-contaminated dust, lead- contaminated soil, deteriorated LBP or from LBP present on accessible, friction or impact surfaces –Lead-based Paint (LBP): Any paint, varnish, shellac or other coating that contains lead >/= 1.0mg/cm2 or 0.5%by weight

Course Overview

Key Definitions

–Primary Prevention: LBP risk assessments and/or inspections followed by abatement and/or interim controls in housing before children are exposed –Secondary Prevention: Blood lead screening programs to identify children who already have elevated blood lead levels (EBLs) Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

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Introduction US EPA Lead Risk Assessor

Legislative Basis for LBP Risk Assessments

• Major Purposes of Title X

–Reduce Childhood Lead Poisoning –Re-orient national approach emphasizing LBP hazards –Build national infrastructure to eliminate LBP hazards in housing –Establish a workable framework for LBP hazard control

Title X: An Exposure- Oriented Mandate

• A risk assessor needs to know

–condition of paint –various exposure pathways (i.e. dust/soil) –likely sources of exposure –future plans for the dwelling

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

2 History of LBP Risk Assessment

• Emerged in response to an

insurance problem in the nations public housing

• Congress required all housing

authorities to inspect pre-1978 family dwellings by 12/94 –if LBP present, abatement req’d

History of LBP Risk Assessment

• However:

–No Deadline given for abatement –No abatement funds were available except through the modernization program So, PHAs & IHAs had reports identifying “hazards” but no ability to do anything

History of LBP Risk Assessment

• HARRG*provided LBP insurance but
• nly if housing authorities could

manage the immediate risk by controlling exposure

• required to complete risk assessments and

appropriate controls, thus any future EBLs were likely poisoned from another source

*Housing Authority Risk Retention Group

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

3 History of LBP Risk Assessment

• HARRGs response to LPB in

public housing meant that:

• the authority has substantive

defense against lawsuits

• lead-safe housing created in the

short-term

• LBP problem became manageable

History of LBP Risk Assessment

• Title X also indicates that risk

assessment and/or inspections will be carried out through a number of federally assisted housing programs (i.e. Section 1012) History of LBP Risk Assessment

• HUD published risk assessment

protocol in 1990 (derived in part from HARRGs)

• HUDs protocol has been modified

and updated (Ch.5 HUD Guidelines)

–provides more detailed guidance specific to the private sector

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

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Traditional Definition of Risk Assessment

• Typical definition of ”risk

assessment” is a quantification of the health effects of exposure to hazardous material of individuals or populations developed by conducting:

• Hazard

identification

• dose-response

assessment

• exposure

assessment

• risk

characterization

Title X Definition of Risk Assessment

• TSCA Title IV provides that the
• bjective of a risk assessment is to

determine and then report the:

• existence
• nature
• severity
• location of LBP hazards, and
• options to control the hazards

Risk Assessors work with Other Professionals

• Risk Assessors must also provide some

advice on:

• how an owner can solve problems

identified

• cost estimate of each solution
• There are several other professionals

the risk assessor may deal with while providing services to the owner

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

5 Different Forms of Hazard Evaluation

• Risk Assessments

–determine the immediately available sources of lead –help the owner design a mixture

• f long and/or short-term

responses

Different Forms of Hazard Evaluation

• LBP inspections

–do not identify hazards, measure exposure or suggest solutions –often performed by technicians, and –do not help owner design a hazard control plan

Different Forms of Hazard Evaluation

• Poisoned Child Investigation

(EBL/EIBLL)

–neither an inspection nor a risk assessment, is designed to investigate the causes of poisoning in the home of a child with an EBL

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

6 Different Forms of Hazard Evaluation

• Many health departments have

established EIBLL procedures so coordination is crucial to avoid:

–duplication of effort –confusion on the part of the residents and/or owner –interference with health department jurisdiction

Different Forms of Hazard Evaluation

• Inspections

– measure the concentration of lead in paint on a surface by surface basis – identify the presence

• f LBP on all

components – allow the owner to avoid treating paint that is not LBP

• Risk Assessments

– measure the level of lead in dust, soil & deteriorated paint – identify the location & severity of all hazards – consider information about past mgmt &

• maint. Practices

– allow owner to treat all lead hazards present

Special Approaches

• Lead Hazard Screen

–type of risk assessment applicable to housing in good condition –more limited sampling than full risk assessment –more stringent criteria

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

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Special Approaches

• Bypass Hazard Identification

– skip the initial hazard identification step & control suspected or assumed hazards – risk assessor may be asked to determine if all LBP hazards have been control;led after work is completed.

– Clearance sampling to check clean-up effectiveness

Special Approaches

• Reevaluations

–needed in dwellings where LBP remains or is suspected to remain –not needed in dwellings in which

• wners or managers have established

that hazards are unlikely to appear (more information in Section 12 “Ongoing Monitoring”

Special Approaches

• Combination Risk

Assessment/Inspection

–determines both presence of LBP and LBP hazards

• Clearance

–Performed after all hazard control activities

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

8 The Risk Assessment Process

Seven Major Steps

• 1. Determine the most appropriate evaluation tool
• 2. Obtain background information
• 3. Schedule the evaluation
• 4. Conduct the evaluation
• 5. Determine the actual hazards
• 6. Provide guidance for reducing/eliminating

hazards

• 7. Produce a written report

Why an Owner wants a LBP evaluation

• Regulations requires it
• Parents of lead-poisoned child
• Sale of building
• Owner is sued by a poisoned

resident

• Insurance company wants it

Good Practices

• Good Public Health Practices

– LBP hazards are a public health, housing and environmental problem – options should be based on owners’ needs & financial resources – LBP hazards more common in low- income housing

Do not suggest services that will raise the cost of housing

• r cause owners to abandon the effort to identify &

remedy LBP

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

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Good Practices

• Good Public Health Practices

–Tailor services offered to the client –Ultimately, owners bear the responsibility for the condition of a property

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

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Preliminary Contact with the Dwelling Owner

Preliminary Contact with the Dwelling Owner

• Initial Responsibility of the Risk Assessor

– Informing the Owner of the Evaluation Options

• Combination risk Assessment/inspection
• Full paint inspection
• Full risk assessment
• Lead Hazard Screen
• EBL Investigation

Preliminary Contact with the Dwelling Owner

• Primary Factors influencing decision

– Motivation for having a lead evaluation conducted – Likelihood of discovering a hazard – Likely hazard control options – Financial Resources – Future plans for the building

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

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Preliminary Contact with the Dwelling Owner

• Collect information about the property from the owner:

– Single-family, owner occupied

• resident use patterns, including child's play area

– Rental dwellings

• Management & maintenance practices
• Occupancy status of buildings

Preliminary Contact with the Dwelling Owner

• Onsite Data Collection Procedures

– Visual Assessment

• Condition of building
• Condition of common areas
• Condition of painted surfaces
• Areas of Bare Soil

– Dust Sampling – Paint Sampling – Soil Sampling – Water Sampling

Preliminary Contact with the Dwelling Owner

• Single-family, owner-occupied
• Resident Questionnaire
• Completed by Risk Assessor via interview

– Children(s) habits – Family use patterns

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

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Preliminary Contact with the Dwelling Owner

• Rental dwellings

– Part two: Management

• Staffing
• Lead Hazard Control Policy Statement
• Previous LBP Evaluations
• Previous Lead Hazard Control Activities
• Turnover Procedure
• Employee Health & Safety Plan

Preliminary Contact with the Dwelling Owner

• Rental dwellings

– Part two: Management

• On-site Day Care Facilities
• Management of EBLs
• Routine Inspections
• Code Violations
• Resident Notifications

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

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Visual Examination US EPA Lead Risk Assessor

Purpose & Goals

• To look at the interior & exterior
• f a dwelling unit to identify

possible LBP hazards, their causes and to select sampling locations

Initial Building Walkthrough Survey

• Risk Assessor should ask the

following questions:

–Is the house/apartment in generally good repair? –Are there large amounts of deteriorated paint and/or visible dust accumulations?

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

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Initial Building Walkthrough Survey

• Risk Assessor should ask the

following questions:

–Are the doors/windows old & possibly coated with LBP? –Is there an obvious, exterior sources of lead (ex. old house next door with lots

• f peeling paint or a battery recycling

shop nearby)?

Visual Examination Checklist

–What to look for:

• Deteriorated paint and visible causes of

such deterioration

• Visible dust accumulation
• Bare residential soil
• Painted impact & friction surfaces
• Painted surfaces that a child is

suspected of chewing

Visual Examination Steps

–Conduct initial building walk-through –Assess paint condition

• intact
• deteriorated

–Identify exterior problems that can lead to paint failure

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

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Visual Examination Steps (continued)

–Identify areas of bare soil –Identify interior problems that can lead to paint deterioration

Assessing Paint Condition

–What is the extent of deterioration? (how large an area is deteriorated) –What Type of deterioration is

• ccurring?

Exterior Examination

–Begin at the top of the building & move to the bottom

• Roof, gutters & downspouts
• Windows
• Porches
• Masonry & foundations
• Other painted surfaces (fences, garages)

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

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Exterior Examination (continued)

–Bare residential soil

• Ground underneath swing sets, play

equipment

• Sandboxes
• Foundation drip line
• Ground under porches (frequent play

areas)

• Discharge from downspouts

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

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Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

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Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

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Dust Sampling US EPA Lead Risk Assessor

Dust as exposure pathway

• Positive correlation between

LBP and lead in dust

• Strong positive correlation

between lead-in-dust and elevated blood levels (EBLs)

Units of measure

• Two ways to describe lead in dust

– loading (area concentration): measure of the total amount of lead present in area (ex.ug/ft2) – Mass Concentration: measure of the amount of lead contained in the dust (ppm/ug/g)

• These units are not interchangeable

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

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Surfaces sampled

• Interior window sills (stool)
• Window trough (well)*
• Bare floors
• Carpeted floors (if present)

* per HUD Guidelines, not USEPA standards

Wipe sampling

• Recommended method because:

– simple & inexpensive – has been correlated with children's blood lead levels – vacuum sampling methods not standardized – basis for EPA, HUD & state standards

Lead Dust Levels

Surface EPA & HUD Lead Hazard Level (ug/ft2) EPA Clearance Level (ug/ft2)

Floors 10 40 Sills 100 250 Wells No standard 400 Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

3 Wipe sampling materials & supplies

• Disposable Wipe

– background levels below 5 ug/wipe – single thickness – durable – contains no aloe – can be digested by lab – yields 80-120% recovery rates from spiked samples – remains moist during sampling process – individually packaged*

*per ASTM

Wipe sampling materials & supplies

– Sample collection forms/chain of Custody – Defining sampling area

• masking tape & tape measure
• hard, smooth reusable template
• “measured” tape
• Additional supplies
• labels, markers, trash bags, measuring

tape, disposable shoe coverings

Single-surface wipe sampling procedure

–First pass: side to side, “s” shaped motion

• fold wipe in half, dust side in

–Second pass: top to bottom, “s” shaped motion –Third pass*: perimeter

*per ASTM Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

4 Wipe sampling materials & supplies

• Gloves

– disposable – nonsterilized – nonpowdered

• Centrifuge Tubes (50ml)*

– nonsterilized – polyethylene w/sealable lid

*or equivalent hard-shell container

Single-surface wipe sampling procedure (continued)

– Rectangular areas (e.g. window sills)

• two side to side passes (avoid touching
• ther portions of window)

– Paint Chips

• attempt to include any chips that adhere

to the wipe

Composite Samples

• Multiple sub-samples from similar

surfaces analyzed as one sample and averaged

– Advantage – lower cost – Disadvantage – imprecise data

• Acceptable per EPA
• Not acceptable per ASTM & Labs

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

5 Composite Sample Rules

• Separate composite samples from

different surfaces (e.g. hard floors, carpets, sills, wells)

• Separate composites from different

dwellings

• Sub-sample sized should be the same
• Separate samples for each location
• Maximum 4 sub samples per sample

QC/QA Blanks

• Lot Blank – determine pre-existing

contamination

• Field Blank – determine sampler

introduced contamination

• Lab blank – used for AAS calibration
• Spike samples – evaluate laboratory

procedures

Composite Sample Locations

• Principle play room
• Kitchen
• Bedroom of youngest child (over 6

months )

• Bedroom of next youngest child

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

6 Single Surface Sample Locations

• Entry way
• Child’s principal play area
• Children’s bedrooms
• Kitchen
• Bathroom

Avoiding Cross Contamination

• Always change gloves between samples
• After donning glove don’t touch anything

else other than area being sampled

• If wipe touches anything else other than

sample area, discard and use a new wipe

• Discard first wipe in dispenser in every

new dwelling

• Fold wipe completely before putting in tube

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

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Soil Sampling US EPA Lead Risk Assessor Soil Sampling

• Sources of lead in soil

–Weathering & caulking of LBP on exterior –Airborne contamination from gasoline –Point sources of lead (e.g. smelters, battery manufacturing plants

Why is Lead in Soil a Problem

• Direct source of lead exposure to children playing in

yard

– get hands dirty – put fingers in mouth

• Source of lead in interior house dust

– easily tracked inside by residents or pets

• Vegetables grown in lead contaminated soil may

uptake lead

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

2 Soil Composite Sampling

• Take 3 - 10 soil (i.e. sub-samples)

from each designated area

• Mix sub-samples together to

achieve a representative sample of the area tested

Soil Sampling Protocol

• Start with clean tools
• Put on vinyl or latex gloves
• Push coring devise at least 1/2 inch

into bare soil

• Remove device from soil & push out

the top 1/2 inch of soil

• Place plug of soil into sample container

Soil Sampling Protocol

• Repeat for a total of 3 to 10 times,

placing each sub-sample into the same container

• Remove & discard gloves & clean

sampling device to prevent cross- contamination before collecting next composite

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

3 Soil Sampling Protocol

• Label sampling container with

sample ID, time, date and location

• f sample
• Record same information on field

sampling & chain of custody

Soil Collection Techniques

• Soil samples usually taken using a

soil

–Many types of probes available that are suited to different types of soil

• May use 5 cc disposable syringe or

plastic centrifuge tube for loose soil types

Soil Collection Techniques

• Soil samples usually taken using a

soil

–Many types of probes available that are suited to different types of soil

• May use 5 cc disposable syringe or

plastic centrifuge tube for loose soil types

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

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Location of Samples

• Prepare site description
• Make detailed drawing

– boundary of lot – position of main buildings – position of sidewalks, driveways & other paved areas – position of play areas – location of exposed (bare) soil – roof rain spouts, drainage patterns – drip lines & areas of heavy traffic

Location of Samples

• Describe property

–type of building construction –conditi0on of main building –condition of property –type & condition of adjacent property –fencing & animals on property –apparent use of property

Number of Samples

• Two composite samples per

dwelling

–one from play area –one from building foundation

• Other areas that may be sampled

–gardens –pet sleeping areas –parking areas (vehicle exhaust) –sandboxes

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

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Interpretation of Results

• Samples sent to lab & analyzed

either by laboratory XRF or AAS

• Results reported in ppm
• Results represent the average soil

lead concentration over a specific area

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

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Paint Testing

US EPA Lead Risk Assessor

Deteriorated Paint Sampling

• Deteriorated paint is a lead-based

paint hazard if both of the following apply:

–it meets the definition of “poor” –it contains lead above the applicable federal or local standard

Deteriorated Paint

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

2 Deteriorated Paint Applicable Federal Standards

• 1.0 mg/cm2

–laboratory analysis –portable XRF

• 5,000 ppm (ug/g) = 0.5% by weight

–measured by laboratory analysis

Applicable Standards

• If a locality has a more stringent

standard

–Risk assessors should always use the most stringent standard

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

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When to Measure Lead in Paint

• All deteriorated paint films

–2 - 10 paint films –composite paint films (optional)

When Not to Measure Lead in Intact Paint

• friction surfaces
• impact surfaces
• accessible or chewable surfaces

Methods & Protocols of Measuring Lead in Deteriorated Paint Films

• Portable XRF analysis
• Laboratory analysis
• Protocols available from EPA, HUD &

ASTM

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

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XRF Analysis

• Follow manufacturers instructions
• Technical Performance Sheets
• Chapter 7, HUD Guidelines

XRF Analysis

• Take 1 reading across any given surface &

average, minus any bias (substrate) correction

• Ensure that each spot selected has all

layers present

• All calibration checks & raw data should

be included in the report

Laboratory Results

• Laboratories report results in:

–mg/cm2

• area sampled must be measured exactly

–ug/g, ppm, weight percent or mg/kg

• area sampled does not need to be measured

exactly, but all paint layers must be included w/o any substrate

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

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Sample Size

• 2” x 2” for flame AA analysis
• smaller for graphite furnace AA or ICP

Other Methods of Paint Analysis

• Chemical Spot Test Kits

– Sodium Sulfate - black or grey – Sodium Rhodizonate – red or pink

Portable Laboratories

• Anodic Stripping Voltometry
• Laser Technology

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

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Tips for Proper Deteriorated Paint Film Sampling

• Avoid sampling only the deteriorated areas
• Use a use heat gun on intact paint film
• ASTM standard E-28
• Use hard-shelled sample container
• Measure area sampled

Review of Previous Paint Testing

• Always review previous paint testing

reports

• Determine reliability of data
• use checklist for reviewing previous

report data

Sources of Error

• Sampling where lead layer has fallen
• ff or been removed
• Substrate included in sample for

weight percent analysis

• Failing to measure surface exactly

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

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Sources of Error

• Failure to determine deterioration of all

paint surfaces

• Failure to include all layers in the sample
• Failure to notify the laboratory that results

must be reported in total lead ug of lead sample as well as in mg/cm2 or ug/g

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

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Water Sampling US EPA Lead Risk Assessor

Objective

• To Conduct & Evaluate testing
• f Drinking Water

Regulations That Govern the Amount of Lead in Drinking Water

• The Lead Ban (1986)
• The Lead Contamination

Control Act (1988)

• The Lead & Copper Rule (1992)

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

2 Sampling Strategy

• Most routine risk assessments will not

require water sampling

• If required, obtain 1 liter of water from cold

tap most often used for drinking water after at lest 6 hours of no water use (in lab approved bottle/preservative)

• This initial sampling or “morning first draw

represents worst case

Sampling Strategy

• Second sample

–Take immediately after first sample

• Third sample

–Take after 2 minutes of water flow

• Fourth sample

–take after another 3 minutes of water flow

Analysis Strategy

• Send samples to lab w/in seventh-

two hours

• Analysis by AAS/ICP
• Results reported in ppb (15)

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

3 Interpretation

• f Results
• #1>AL, #2>AL but #3<< AL

– Lead is coming from internal plumbing (I.e.pipes or connections)

• #3>AL

– Lead is coming from service line

• #4>AL

– Problem is due to the water supply itself

Possible Solutions

• Internal Plumbing
• Let water run about 30 sec. before

using; always use water from cold tap

• Service Line
• Contact water company about

replacement of service line. Use bottled water

• Water Supply: Contact water company

For Additional Info

• Call the Safe Drinking Water

Hotline

800 426 4791

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

Hazard Control

US EPA Lead Risk Assessor

Two-Step Plan for Reducing Lead Hazards

• Evaluate lead hazards

– Inspections – Risk Assessments – Clearance

• Reduce lead hazards

– Abatement – Interim Controls/Management – Renovations

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Abatement

… is a set of actions that permanently eliminate lead-based paint hazards

– Replacement – Removal – Enclosure and encapsulation – Cleanup of lead dust – Removal or permanent covering of lead- contaminated soil – Site preparation and cleanup – Waste disposal – Final inspections and clearance testing

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Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

Ma Major Ab Abateme ment Co Considerations

– Occupant protection – Worker protection – Worksite preparation – Containment – Lead-based paint abatement methods – Daily cleanup procedures – Controlling off-site contamination – Final cleanup procedures – Clearance

Oc Occupant Protection Plan

• A written occupant protection plan (OPP) shall be

developed for all abatement projects

• OPP shall be unique to each residential dwelling or

child-occupied facility and be developed prior to the abatement.

• OPP shall describe the measures and management

procedures that will be taken during the abatement to protect the building occupants from exposure to any lead-based paint hazards.

• A certified supervisor or project designer shall prepare

the OPP.

Oc Occupant Protection

• Relocation of residents is the norm.
• Relocation may not be necessary when:

– abatement work is very limited; – abatement & cleanup take less than 8 hours and the unit is still livable; – abatement is on the exterior of the building, containment is suitable, and safe access is assured.

• Resident notification requirements.

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

Interior Co Containme ment

• Clearing the work area of movable material
• Covering non-movable material with 6-mil plastic
• Separation of work from non-work areas
• Using barriers at work site entrances
• Covering non-movable objects
• Covering floors when necessary
• Shutting down HVAC and seal duct openings
• Checking containment periodically
• Using engineering controls to reduce worker exposure
• Working in common areas in apartment buildings

Exterior Co Containme ment

• Design surface containment to

capture all liquid runoff.

• Collect and store all liquid waste.
• Contain dry waste with the use of 6-

mil plastic on horizontal surfaces.

• Use vertical containment when

necessary.

• Protect the interior of the building.
• Provide safe corridors for residents.

Lead Lead-Ba Based Paint Ab Abateme ment Strategies

• Removing lead-based paint

– replace component or structure – remove paint from substrate

• Covering lead-based paint

– enclosing the paint – encapsulating the paint

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

Ab Abateme ment Tasks

• Controlling off-site dispersal
• Daily cleanup

– large debris – small debris – exterior cleanup

Ab Abat atemen ement Ta Tasks ks

• Final cleanup

– preliminary final cleanup – painting & sealing surfaces – final cleanup – clearance testing

• Record keeping

– records to be retained – who keeps the records

Soil Lead Ab Abateme ment

Objective: To present the current methods for abating lead- contaminated soil and the problems you may have doing this kind of abatement.

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

Soil Lead Ab Abateme ment

• Lead in soil can be a hazard
• Abatement as a solution
• Abatement strategies

– soil replacement – permanent barriers – mixing soil – alternative methods

• Interim controls

Soil Lead Ab Abateme ment Projects

• Scope of the work

– what must be done to accomplish the work

• Health & safety issues

– worker training programs

• Contamination control

– preventing the spread of contaminated soil

• Site control

– keeping unauthorized people off the site

Interim Controls

. . . are actions that reduce a lead hazard temporarily –Education programs –Special cleaning methods –Repairs, repainting, and maintenance

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Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

Interim m Co Controls

Defined: A set of measures designed to reduce temporarily, human exposure or likely exposure to lead-based paint hazards, including specialized cleaning, repairs, maintenance, painting, temporary containment, ongoing monitoring of lead-based paint hazards or potential hazards and the establishment and operation of management and resident education programs.

environmentaleducation.com

• Shall be prepared by a certified supervisor or

project designer. Start and completion dates of

abatement

– The name and address of each certified firm conducting the abatement and the name of each supervisor assigned to the abatement project – The occupant protection plan – The name, address, and signature of each certified risk assessor or inspector conducting clearance sampling and the date of clearance testing. – The results of clearance testing and all soil analyses (if applicable) and the name of each recognized laboratory that conducted the analyses.

Abatement Report

• A detailed written description of the abatement,

including abatement methods used, locations of rooms and/ or components where abatement

• ccurred, reason for selecting particular abatement

methods for each component, and any suggested monitoring of encapsulants or enclosures.

• All reports orplans required in this section shall be

maintained by the certified firm or individual who prepared the report for no fewer than 3 years. The certified firm or individual also shall provide copies of these reports to the building ownerwho contracted for its services.

Abatement Report

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

Interim Control Plan

• These actions can reduce lead

exposure in a home

–Do a special cleaning –Do small repairs to windows to reduce lead dust –Wet scrape edges and loose paint –Wash entire house with cleaning solution again –Have clearance dust wipe testing done by a certified inspector or risk assessor –Repaint wet-scraped surfaces with non- lead-based paint

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Interim m Co Control Me Measures

• Substrate repair
• Paint film stabilization
• Friction & impact surface treatment
• Treating accessible surfaces
• Treating exposed soil
• Dust removal and control
• Educating residents and maintenance workers
• Conducting reevaluations

Paint Stabilization

• Causes of paint failure

– moisture – aging – mechanical damage – chemical incompatibility – poor surface preparation

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

Substrate Co Condition & & Re Repairs

• Water penetration from outside
• Interior leaks from heating and plumbing
• Water vapor problems
• Substrate repairs

Friction & & Imp mpact Surface Treatme ment

• Definitions

–friction surfaces –impact surfaces

• Procedures

–window systems –door systems –stair systems –baseboards and corners –drawers and cabinets –porches, decks, and interior floors

Soil Interim m Co Control Procedures

• Soil interim control strategies:

– covering with thin layer of soil – ground cover – land use controls – drainage and dust control

• Controlling migration into buildings
• Reevaluating and monitoring

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

In-Place Management

• Needed whenever interim controls are used and lead-

based painted surfaces remain

• Can help prevent lead poisoning

20

In-place management should include:

Education Training Written program Lead program manager Ongoing monitoring Recordkeeping

Renovation, Repair & Painting Rule (RRP)

• Addresses activities that disturb lead-based paint in

target housing and child-occupied facilities. It requires:

– Renovators to be certified through training. – Firms to be certified. – Training providers to be accredited. – Lead-safe work practices during renovations. – Pre-renovation education in target housing and child-occupied facilities.

• Firms working in pre-1978 homes and child-occupied

facilities must be certified and use lead-safe work practices during renovations.

• EPA may authorize states, territories and tribes to

enforce the Rule.

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

The RRP Rule: Exclusions

• Renovation activities where affected

components do not contain lead-based paint.

• Emergency renovations (requires cleanup

and cleaning verification).

• Minor repair and maintenance activities.

Note: This exclusion does not apply to window replacement, demolition or activities involving prohibited practices.

• Renovations performed by homeowners in

their own homes.

The RRP Rule: Firm Certification

• All covered renovations must be performed by

Certified Firms, using Certified Renovators and

• ther trained workers.
• To become certified, firms must submit an

application, and pay a fee, to EPA.

• Certifications will be good for 5 years.
• Certification allows the firm to perform renovations

in any non-authorized state or Indian tribal area.

The RRP Rule: Firm Responsibilities

• Ensure overall compliance with the RRP Rule.
• Ensure that all renovation personnel are Certified

Renovators or have been trained on-the-job by Certified Renovators.

• Assign a Certified Renovator to all jobs.
• Meet pre-renovation education requirements.
• Meet recordkeeping requirements.

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

The RRP Rule: Individual Certification

• To become a Certified Renovator, an individual must take

an EPA-approved 8-hour training course from an EPA- accredited training provider.

• The course completion certificate serves to certify

renovators (no application to EPA is required).

• Refresher training is required every 5 years.
• Workers do not need certification so long as on-the-job

training is received from a Certified Renovator and the work is not HUD-regulated.

The RRP Rule: Certified Renovator Responsibilities

• Perform work and direct lead-safe work practices.
• Provide on-the-job training to non-certified workers.
• Keep copy of the initial and/or refresher training certificates onsite.
• When requested, use EPA-recognized test kits or, alternatively,

collect paint chip samples for laboratory lead analysis to identify lead-based paint.

• Be physically present while posting signs, containing work areas,

and cleaning work areas.

• Be available by telephone when off-site.
• Maintain the containment to keep dust and debris within the work

area.

• Implement the cleaning verification procedure.
• Prepare and maintain required records.

The RRP Rule: Enforcement

– EPA may suspend, revoke, or modify a firm’s certification if the Certified Firm or Certified Renovator is found to be in non-compliance. – Those firms found to be non-compliant may be liable for civil penalties of up to $37,500 for each violation. – Those firms who knowingly or willfully violate this regulation may be subject to fines of up to an additional $37,500 per violation, or imprisonment, or both.

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

HUD’s Lead Safe Housing Rule

– Covers federally-owned or -assisted target HOUSING and federally-owned target housing being sold. Renovators should ask if the housing receives financial assistance.

• If yes, the renovator should ask the owner to find out if the

assistance is federal assistance.

– HUD’s rule has evaluation and control requirements based on type of assistance:

• Visual assessment, lead paint inspection;
• Paint stabilization, interim control, abatement;
• Ongoing lead-based paint maintenance.

HUD’s Lead Safe Housing Rule: Safe Work Practices

• HUD’s rule requires lead safe work practices for:
• Paint stabilization
• Interim control of identified lead-based paint

hazards

• Rehabilitation (renovation)
• Standard treatments
• Ongoing lead-based paint maintenance

– HUD’s de minimis level is smaller than the RRP Rule’s minor repair and maintenance level

HUD’s Rule Addresses:

• Training (usually classroom training for workers)
• Occupant protection and worksite preparation
• Prohibited methods (3 in addition to RRP Rule’s)
• De minimis levels (smaller than RRP Rule’s)
• Lead safe work practices
• Specialized cleaning
• Clearance testing (covered in Module 6)
• Occupant notification (within 15 days)

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

October 2011 2-37

Know the EPA and HUD Rules!

To obtain a copy of the regulations contact the National Lead Information Center at 1- 800-424-LEAD. You may also download the rules and

• ther information from the following

websites:

• www.epa.gov/lead
• www.hud.gov/offices/lead

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

1

Assessing Multi-Family US EPA Lead Risk Assessor

Procedures for Assessing Multi-family Properties

• Many similar dwellings present,

therefore only a few need be sampled

• Cost per unit decreases, but proper

selection of units more crucial

Determining Similarity of Dwellings

• Gather info from
• wner about

– residents – management company – maintenance staff

• Similar dwellings will

have

– been built at the same time – have a common maintenance & management history – have a common painting history – be of similar construction

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

2

Assessments of 5 or More Dwellings

• Information on property condition

(from owner or his representative)

• Age & location of children in

residence

• Management & maintenance

practices

• Selection of targeted, worst-case or

random sampling

Targeted Assessments

• Advantages

– requires less sampling than random – does not require access to all units

• Disadvantages

– open to owner manipulation or bias – owner may not be able to provide

• ccupancy status &

physical condition of dwellings

Based on units selected using information supplied by the owner

Targeted Assessments

• Within targeted dwellings, should

conduct:

–visual assessment of the condition of building & painted surface –environmental sampling of deteriorated paint, dust* and soil

* including common areas

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

3 Selected Dwellings to be Sampled

• Targeted sampling

–units selected using information supplied by the owner

• Worst Case

–units selected on the basis of a walk- through visual examination by the risk assessor of all units w/in the development

Worst-Case Sampling

• Advantages

– requires less sampling than random – units selected will reflect the worst- case

• Disadvantages

– requires access to all dwelling units (could be a problem in large complexes) – open to risk assessor bias

Selected Dwellings to be Sampled

• Random Sampling

–A sample drawn from a population in away that allows each member of the population to have an equal chance

• f being selected

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

4

Random Sampling

• Advantages

– offers the strongest degree of statistical confidence* – least open to owner

• r assessor bias
• Disadvantages

– requires the most samples – most expensive * follows Inspection Unit Selection Process

Number of Dwellings to be Sampled

• Table 5.6 of Guidelines describes the

number of dwellings needed for Targeted or Worst-Case sampling

• At least 4 dwellings must be samples,

targeted & worst case cannot be used if fewer than 5 similar dwellings

Dwelling Selection Criteria

• Cited by housing or building code

violation within past year

• Owner believes are in poor condition
• Housing 2 or more children 6 months –

6 years

• Serve as day care facilities
• Prepared for reoccupancy w/in past

three months

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

5 Optional Management & Maintenance Practices

• Review information on how mgmt/maint

work is structured & suggest modifications

• A typical plan will consist of:

– Person responsible for LBP work – Written policy statement – Training – Work order forms

Additional Dust Sampling

• Common Areas*

–Low rise buildings (4 stories or less)

• Collect 2 additional dust samples

– Entry area floor – Floor of first story landing of hallway or stairwell

*in all common areas tested, note paint conditions

Additional Dust Sampling

• Common Areas*

–High rise buildings

• Collect 2 additional samples from

corridor of every fourth floor

– Floor & sills – Floor of first story landing of hallway or stairwell

• Collect 2 samples from stairwells

– Treads & landings

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

6 Additional Dust Sampling

• On-site Community Buildings

–Day care, recreational or other spaces frequented by children

• Spaces up to 2,000 square feet

– Floors: 2 samples from high traffic areas – Windows: two samples » Interior sill » well

Additional Dust Sampling

• On-site Community Buildings

–Day care, recreational or other spaces frequented by children

• Spaces over 2,000 square feet

– Floors: 1 addtl sample for ea. 2000 sq. feet – Windows: 1 addtl sample of sill or trough for ea. 2000 sq. ft

Interpreting Dust & Soil Sampling Results

• Calculate averages

– Floor dust lead – Well lead* – Sill dust lead – Play area soil lead – Perimeter soil lead

• If any of the

averages exceed the standards, a development or building wide LBP hazard exists

Inconsistent data & outliers require further evaluation by the risk assessor

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

7 Interpreting Dust & Soil Sampling Results

• If deteriorated paint on a given

component has lead in excess of the standard:

–All of that component type have lead levels above the standard; or –Further sampling can be completed (using the LBP inspection protocol)

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

1 Hazard Screen

US EPA Lead Risk Assessor Lead Hazard Screen

• Screen vs. Full Risk Assessment
• Employs more limited sampling

but more stringent hazard identification criteria

• Serves as a negative screen
• Should be used only when:

– dwelling in good condition

Lead Hazard Screen

• Step 1

–take a 5-15 minute tour of dwelling –note paint conditions –select locations for dust samples

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

2

Lead Hazard Screen

Step 2

–Collect 2 composite dust samples

• one from floors
• one from window sills*

–Each composite should include dust samples from:

• child's play area
• child's bedroom
• main entryway
• other location (high risk)

Lead Hazard Screen

Step 3

–Collect up to five paint samples, if deteriorated paint is present –Testing should be done by paint chip collection, unless intact area allows use of XRF

Lead Hazard Screen

• No soil, water or air sampling
• No data collected on property

management or property condition

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

3

Lead Hazard Screen

• Hazard Levels for Screen:

–Paint: 1.0 mg/cm2 –Dust (EPA Risk Assessment Levels divided in half)

• Floors:

50 ug/ft2 ????

• Sills:

5ug/ft2 ????

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

1

Ongoing Monitoring

Lead Risk Assessor

Key Elements of Ongoing Monitoring

• Reevaluations by certified risk

assessor

• Annual visual surveys by
• wner or representative

Reevaluations

• Visual examination
• Composite Dust sampling
• Soil Sampling
• Qualified Personnel
• Refer to Standard Reevaluation

Schedules (Guidelines Table 6.1)

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

2

Conditions Resulting in Reevaluation Failure

• Interior dust leads above

applicable standards

• Bare soil > 400 ppm, play areas
• Bare soil > 1200 ppm, other
• Breach in soil covering
• Hazard Control no longer intact
• Deterioration of known or suspect

LBP

Documentation

• Sample Reevaluation Report

Format

–Summary information –Visual Examination & Sampling Results –Recommended Actions

Units Exempt from Ongoing Monitoring

• Combined risk assessment and

inspection shows no LBP present & soil and dust levels below limits

• All building components w/LBP

were removed &/or LBP was removed & soil & dust levels below limits

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

7/28/2020 1

Report Preparation US EPA Lead Risk Assessor

Report Preparation

• Part 1: Identifying Information
• Part 2: Completed Management,

Maintenance & Environmental Results Forms & Analysis

• Part 3: Lead Hazard Control Plan

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

1

Building Comp mponents ts

Objective: To describe the architectural components of residential buildings

Bui uildi ding ng Comp mponents ts

• Inspectors and Risk Assessors

should know the names of building components for several reasons:

– Proper identification of building components during an inspection or risk assessment, which may lead to some type of response action – A contractor performing some response will have to know the names

• f such components as identified in the

inspection

Building Components

Window

Building Components

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

2

Building Components

Door

Building Components Building Components

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

3

Stairs

Building Components Building Components

Wall

Building Components

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

4

Building Components

Porch

Building Components

Porch

Building Components

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation

5

Building Components

Environmental Education Associates, Inc. USEPA Lead Risk Assessor Initial Course Presentation