Inspecting for Lead-based Paint Chapter 1 Course Overview Lead - - PDF document

Inspecting for Lead-based Paint Chapter 1 • Course Overview

Lead Inspector

Chapter 1 – Course Overview

2

Course Purpose

◼ To train inspectors to identify lead in

◼ paint (lead-based paint inspections) ◼ dust and soil (clearance inspections)

3

Other Training Courses

◼ Lead Abatement Supervisors ◼ Abatement Project Designers ◼ Risk Assessors ◼ Abatement Workers ◼ Operations and Maintenance Workers

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Inspecting for Lead-based Paint Chapter 1 • Course Overview

4

Certified Lead Inspectors

◼ Conduct lead-based paint inspections

◼ lead-based paint inspection: a surface-by-surface

investigation to determine the presence of lead- based paint.

◼ certify results

◼ A report is then issued that identifies if there is lead-

based paint present and where it is located.

◼ Conduct post-hazard control clearance

sampling

5

Required Training

◼ Initial

◼3-day inspector course

◼ Refresher

◼1-day ◼every three years

◼ Check state or tribal refresher training requirements

as some require annual or biannual refresher training.

6

Statistics on Lead Pollution

◼ LBP found in 83% of private housing and 86%

• f public housing (EPA 1995)

◼ Existence of LBP crosses all boundaries

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Inspecting for Lead-based Paint Chapter 1 • Course Overview

7

Statistics on Lead Pollution

◼ Elevated blood-lead levels more common in

children that are

◼minority ◼lower income status ◼living in urban areas

◼ Almost one million children under the age of

six have blood lead levels above the CDC threshold of 10 µg/dL.

8

Laws, Regulations and Guidance

◼ This course is based, in large part, on the following

documents:

◼Residential Lead-based Paint Hazard Reduction Act (Title X) ◼Section 404 of TSCA ◼Guidelines for the Evaluation and Control of Lead-based Paint Hazards in Housing ◼Section 302 of LBPPPA

9

Units of Measure

◼ cm

centimeter 1/100 meter

◼ cm2

square centimeter

◼ dL

deciliter 1/10 liter

◼ ft

foot 12 inches

◼ ft2

square foot144 sq. inches Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Inspecting for Lead-based Paint Chapter 1 • Course Overview

10

Units of Measure

◼ m

meter (39.37 in.)

◼ m3

cubic meter

◼ g

gram (0.035 ounces)

◼ mg

milligram (1/1000 g)

◼ µg

microgram (1/1,000,000 g)

◼ ppm

parts per million

◼ %

percent (1% = 10,000 ppm)

11

Understanding Units

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

1

Background Information for Lead Inspectors

Chapter 2

• Provide an understanding of the history of poisoning
• Acquaint inspectors with the uses of lead
• Describe the sources of lead exposure
• Help inspectors recognize the

extent of the lead hazard issue

Objectives

• Introduced to the environment by man
• Chronology
• 6500 BC -

earliest known object made of lead

• 2000 BC -

180 tons per year

• 700 BC - 10,000 tons year
• Roman Times: 80,000 tons per year produced extensively for vessels,

aqueducts, glazes. Hypothesized to be a factor in Roman Empire decline

• Industrial Age: occupational exposure accelerated
• Up to 1980: because of plasticity & softness it was

commonly used in paint pigments, construction materials, water and sewer pipes and chemical additives

History

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

2

• Metallic Element (PB): dense, soft, low melting,

corrosion resistant, conducts electricity, shield radiation

• Atomic Weight: 207
• Density:

11.4

• Melting Point:

327C

• Combines to form alloys or other compounds
• Inorganic Lead Particulate:
• Dust & Fume
• Organic Lead Compounds (e.g.. TEL) :
• Vapor

Lead Identification

• Man-made processes & products
• Major past industrial uses
• Paint additives
• Gasoline additives
• Solder/Pipe
• Major current industrial uses
• Manufacturers of electrical batteries
• Chemicals
• Pathways
• Adults: Occupational Exposures
• Children: household dust & soil

Sources of Environmental Lead Contamination

• Lead Based Paint (LPB)
• Urban Dust & Soil
• Lead Based Paint
• Gasoline
• Industrial Sources
• Drinking Water
• Solder
• Brass fittings & fixtures
• Service lines
• Air, Food & Other Sources of Lead

Major Sources

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

3

• Lead based paint
• Deteriorated paint/paint chips & dust
• Dust & Soil are major routes of exposure:
• Enters soil though deterioration
• Young children ingest through normal hand to mouth activity
• Poor/Fatty Diets increase absorption

Major Sources

• Association between the presence of dust,

lead and elevated blood levels (EBLs) has been scientifically documented

• Types of dust
• Surface dust both household & street
• Soil: both topsoil & below top layer of soil

Lead in Surface Dust & Soil

• Weathering & chipping of LBP
• Scraping & sanding LBP for refinishing
• Renovations that disturb LBP surfaces
• Abrasion on doors & windows
• Atmospheric fallout from leaded gasoline & factory

emissions

• Dust carried home by workers with occupational

exposures or by pets

Dust & Soil Contamination

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

4

• Once released into environment by use of leaded

gasoline (4-5 millions used)

• Other sources:
• Smelters/battery factories
• Combustion of oil, coal, waste oil & municipal waste
• Impact of EPA phase down of leaded gasoline:
• Total atmospheric lead emissions dropped 94%
• Reduction in childhood blood lead levels (50%)
• Occupational exposures still a problem
• Lead hazard control
• Bridge repair & steel structures

Lead in Air

• Lead solder in cans phased out in domestically

manufactured cans in 1970’s

• Lead glazes on ceramic cookware & dishes may be

problem on imported items

• Lead in crops or water
• Some home remedies

Lead in Food

• Certain Industries
• Battery manufacturing
• Smelting
• Auto body repair
• Printing
• Construction
• Hobbyists:
• Stained glass
• Pottery
• Candle making
• Sportsmen

Other Sources of Lead

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Health Effects of Lead Exposure

1

Health Effects

• f

Lead Exposure Lead Inspector Objectives

• Present the causes of lead poisoning
• Explain how lead enters the body
• Provide an understanding of health

hazards associated with lead exposure and the “level of concern” for lead in blood.

2

Learning Tasks

• Describe health effects of lead
• Recognize symptoms of lead poisoning
• Explain routes of entry of lead into the

body

• Understand the extent of lead poisoning

3

1 2 3

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Health Effects of Lead Exposure

2

Body Systems Effected

Almost all systems within in the body may be affected by lead exposure!

4

Problems Caused by Lead Exposure

5

Brain Disorders Hematological Problems Nerve Disorders Reproductive Problems Slower Reflexes Decreased Red Blood Cells

Kidney Problems

Body Systems Most Affected

6

Cardiovascular system (heart) Central nervous system (CNS) Kidneys (renal) Hematopoietic (Blood forming) system

4 5 6

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Health Effects of Lead Exposure

3

High Concentrations Can Cause

• Retardation (children)
• Convulsions
• Coma
• Death

7

Children

• More susceptible to effects of lead
• High levels of lead in the blood may cause

– permanent CNS damage

• Low levels of lead in the blood may cause

– delayed development – behavioral problems

• May not exhibit any obvious

symptoms!

8

NHANES, 1976- 1991

• Significant decrease in blood lead levels of

children

– lead gasoline 0.05 grams/gallon – soldered cans banned – lead-based paint reduced to 0.06 % by weight

• Average blood lead levels decreased 77%

– from 13.7 g/dL to 3.2 g/dL

9

7 8 9

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Health Effects of Lead Exposure

4

Children most at risk for lead poisoning

• Poor
• Mexican American
• Non-Hispanic Black
• Living in large metropolitan areas
• Living in older housing

10

How Lead Enters the Body

• Ingestion

– children are more likely to ingest lead – normal hand-to-mouth activity

• Inhalation

– adults are more likely to inhale lead – usually occupational exposures Note: Importance of take home lead, especially from construction activities

11

Protection for Inspectors

• Good personal hygiene practices

– during inspections – after inspections

• Do not eat, drink, or smoke
• Thoroughly clean face and hands
• Appropriate personal protective

equipment (PPE) when working in restricted areas

12

10 11 12

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Health Effects of Lead Exposure

5

High Risk Jobs— Construction

• Lead abatement

workers

• Carpenters
• Remodelers
• Renovators
• Demolition workers
• Iron workers
• Steel welders and

cutters

• Sheet metal workers
• Painters
• Plumbers
• Pipe fitters
• Cable splicers

13

High Risk Jobs- Industry

• Lead miners
• Lead smelter

workers

• Lead refinery

workers

• Lead crystal makers
• Ceramic glaze

manufacturers

• Plastic

manufacturers

• Wire and cable

manufacturers

• Electronics makers
• Others

14

High Risk Jobs— Others

• Firing range

employees

• Police officers
• Artists
• Radiator repair

workers

• Car mechanics
• Printers
• Scrap yard workers
• Recyclers

15

13 14 15

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Health Effects of Lead Exposure

6

What Happens to Lead in the Body?

• Absorbed
• Distributed

– red blood cells – soft tissue – bone

• Eliminated

– kidneys – gastrointestinal system (GI tract) – perspiration

16

Distribution

17 Blood

Blood Kidneys Colon Sweat Hair Nails Urine Feces BoneTissue Soft Tissue Liver GI Tract Lungs Upper Respiratory Ways Pharynx INHALATION INGESTION

Deposition

Where is lead stored in the body? For how long?

• Blood

5-10%, half-life ~ 1 month

• Kidney

5-10%, half-life ~ 1 month

• Bone

80-90%, half-life ~ 25 years

18

16 17 18

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Health Effects of Lead Exposure

7

Symptoms—Acute

• Colicky abdominal

pain

• Constipation
• Diarrhea
• Brain damage
• CNS
• Irritability
• Fatigue
• Weakness
• Muscle pain
• Vomiting
• Tremors
• Drowsiness
• Restlessness
• Destruction of red

blood cells

19

Affects of Chronic Exposure

• Impaired blood

formation

• Central nervous

system

• Peripheral nervous

system

• High blood pressure
• Reproductive

system

• Damage to

developing fetus

20

Adult Reactions to Lead

• 15 µg/dL

– increase blood pressure – effects on fetus – joint and muscle aches

• 25 µg/dL

– reproductive problems

• 40 µg/dL

– kidney – blood formation

21

19 20 21

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Health Effects of Lead Exposure

8

Adult Reactions to Lead

• 60 g/dL

– anemia – nerve damage – constipation – stomach pains – irritability – fatigue – memory and concentration problems – clumsiness – drowsiness – sleep problems 22

Adult Reactions to Lead

• 80 g/dL and above

– blue line on gums – shaking of hands and wrist – wrist and foot drop – hallucinations – brain damage – coma – death 23

Biological Evaluation

• The blood lead level is the best initial

measurement for evaluating lead exposure.

• The blood lead level

– indicates the amount of lead circulating in the blood stream – may be a measure of recent exposure

24

22 23 24

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Health Effects of Lead Exposure

9

Level of Concern in Children

• CDC

– 1970 60 g/dL – 1971 40 g/dL – 1975 30 g/dL – 1985 25 g/dL – 1991 10 g/dL

25

Treatment

• First step: remove person from

exposure

– parent education – nutrition counseling – child evaluation – medication

• chelating agents

26

Understand the Health Hazards

• Help prevent lead poisoning
• Encourage inspectors to protect

themselves and their families from lead exposure

• Enable inspectors to educate property
• wners and residents

27

Lead

25 26 27

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Medical Surveillance

Objective: To present information about medical surveillance programs

• n lead abatement projects.

Medical Surveillance

Medical Surveillance Program

• usually provided by a physician
• must be in writing
• designed to assess and monitor

workers’ health and fitness (before, during and after)

• provides for regular and emergency

medical treatment

• explains how to keep accurate records

Medical Surveillance

Two Levels of Medical Surveillance

• Initial medical surveillance if an

employee is exposed at or above the Action Level for at least one day per year.

• Full medical surveillance program if the

employee is exposed at or above the Action Level for more than 30 days in a year.

Medical Surveillance

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Initial Medical Surveillance

• consists of testing blood for lead and

zinc protoporphyrin (ZPP) levels.

• OSHA accepts the free erythrocyte

protoporphyrin (FEP) test as equivalent to ZPP for determining lead poisoning.

Medical Surveillance

Full Medical Surveillance

• blood check every 2 months for first 6 months
• n job; twice a year after that
• monitoring work history and symptoms, and

performing a physical examination

• documentation of the medical surveillance

program

• assessing base blood-lead levels
• monitoring changes with time
• assessing occupational Vs other sources of

lead

Medical Surveillance

Who Participates?

• all employees exposed to lead at or

above the action level (30 ug/m3 >30 days per year)

• all potentially exposed employees if the

employer has reason to believe they will be exposed at or above the Action Level for more than 30 days per year

• recommended for all workers on LBP

abatement sites

Medical Surveillance

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Medical Examination

To be performed:

• as soon as employer has reason to

believe the employee will be exposed > AL for >30 days/year

• at least annually if blood tests have

been > 40 ug/dl within preceding 12 months

• as soon as employee exhibits symptoms
• for employees medically removed

Medical Surveillance

Medical Exam Consists Of:

detailed work and medical history thorough physical examination blood pressure measurement blood sample and analysis routine urinalysis pregnancy or male fertility testing (if requested by the employee)

Medical Surveillance

Second Opinion

Employees may consult another physician for a second opinion, to review initial results, or conduct an examination and laboratory testing.

Medical Surveillance

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Information for Examining Physician

 copy of OSHA Construction Lead Standard including appendices  job description of affected employee relative to lead exposure  employee’s present or anticipated exposure level  description of any PPE to be used by employee  blood-lead levels recorded in the past  all written medical opinions in employer’s possession

Medical Surveillance

Written Medical Opinions

• Work-related exam results are given to the

employer by the physician.

• Employees have a right to see all test results
• f their examinations within five days of

employer receipt.

• Information contained on exam report:
• medical conditions likely to increase risk
• special protective measures needed
• limitations on the use of a respirator
• results of blood tests (lead-level, ZPP, etc.)

Medical Surveillance

Medical Removal

• Employee can be removed either

because of BLL test results [2 blood tests >

50 ug Pb/dl], or by recommendation of the

physician.

• Employee receives same pay & benefits

for at least 18 months.

• Employee can be assigned other duties

in areas where exposure is <AL.

Medical Surveillance

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Medical Surveillance Record Keeping

Employers must retain the following employee information for at least 30 years after the employee leaves the job:

• Name, social security number and job description
• Copy of physician’s medical opinion.
• Results of airborne exposure monitoring done for that

employee and representative values provided to the physician.

• Any employee complaints related to lead exposure.

Medical Surveillance

Conclusion

• Medical surveillance is an important part of

the employer’s health and safety program.

• This description of the medical

surveillance program is the minimum requirement for the employer.

• Some health professionals recommend

more frequent BLL monitoring and lower allowable BLLs.

Medical Surveillance

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

1 Re Respir spiratory y Pro Protection

Objective:

• To present information on various

types of respirators: how to use and maintain them, and their limitations.

Definition: Definition:

“A respirator is a personal device designed to protect the wearer from the inhalation of hazardous atmospheres.” (ANSI Z88.2, 1992)

Re Respir spiratory y Pro Protection

• Respirators are the last option after:

–engineering controls –administrative controls –work practices –alternative materials –other methods

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

2 Exp Exposur sure Asse Assessmen ssment

• know potential airborne hazards
• assume a hazard is present until

assessment is complete

• testing to be performed by

competent person

Employe Employer Re Respo sponsi sibilities

• employees must have proper

protection

• employees must be medically fit
• employees must be trained
• required fit testing
• written respiratory protection

program

Selec Selection of f Re Respir spirators

• use only approved respirators
• what you need to know when

selecting respirators

• other important factors

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

3 Ty Types s of f Re Respir spirators

• air-purifying respirators

–negative-pressure air purifying respirators –powered air-purifying respirators

• supplied-air respirators
• self-contained breathing apparatus

Table J-1 Respirator Cartridge Color Codes

Atmospheric Contaminants to Be Protected Against Color Assigned1 Acid Gases White Hydrocyanic acid gas White with ½ inch green stripe completely around the canister near the bottom Organic vapors Black Ammonia gas Green Acid gases and ammonia gas Green with ½ inch white stripe around the canister near the bottom Carbon monoxide Blue Acid gases and organic vapors Yellow Hydrocyanic acid gas and chloropicrin vapor Yellow with ½ inch blue stripe completely around the canister near the bottom Acid gases, organic vapors, and ammonia gases Brown Radioactive particles, asbestos, lead Purple (Magenta) (High Efficiency Particulate Filter) Particles (dusts, fumes, mist, fogs, or smoke) Canister color for contaminant as designated above, in combination with any of the above gases with ½ inch gray stripe completely around the canister

• r vapors

near the top All of the above atmospheric contaminants Red with ½ inch gray stripe completely around the canister near the top

1Gray shall not be assigned as the main color for a canister designed to remove acids or vapors.

Note: Orange shall be used as a complete body, or stripe color to represent gases not included in this table. The user will need to refer to the canister label to determine the degree of protection the canister will afford. For LEAD particles or fume the cartridge for PARTICLES is needed. It has a high-efficiency HEPA filter which is purple (magenta).

Pro Protection Factors

• contaminants inside the respirator
• ratio of contaminant inside to outside
• who determines protection factor

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

4

Table J-2 RESPIRATORY PROTECTION FOR LEAD AEROSOLS (OSHA)

Airborne Concentration of Lead

• r Condition of Use

Required Respirator1 Not in excess of 500 µg/m3

• ½ mask air purifying respirator with high efficiency filters2,3.

Not in excess of 1,250 µg/m3

• Loose fitting hood or helmet powered air purifying respirator with high

efficiency filters3.

• Hood or helmet supplied air respirator operated in a continuous-flow mode.

Not in excess of 2,500 µg/m3

• Full facepiece air purifying respirator with high efficiency filters3.
• Tight fitting powered air purifying respirator with high efficiency filters3.
• ½ mask or full facepiece supplied air respirator operated in a continuous-

flow mode. Not in excess of 50,000 µg/m3

• ½ mask supplied air respirator operated in pressure demand or other positive-

pressure mode. Not in excess of 100,000 µg/m3

• Full facepiece supplied air respirator operated in pressure demand mode.

Greater than 100,000 µg/m3

• Full facepiece SCBA operated in pressure demand

unknown concentration, or fire

• r other positive-pressure mode.

fighting...

1Respirators specified for higher concentrations can be used at lower concentrations of lead. 2Full facepiece is required if the lead aerosols cause eye or skin irritation at the use concentrations. 3A high efficiency particulate filter (HEPA) means a filter that is a 99.97 percent efficient against particles of 0.3 micron size or larger.

Table J-3 Type of Respirator APF* ½ mask air-purifying (HEPA filter) 10 loose-fitting hood or helmet powered air-purifying (HEPA filter) 25 hood or helmet supplied-air - continuous flow mode 25 tight-fitting powered air-purifying (HEPA) 50 full facepiece air-purifying (HEPA) 50 ½ mask or full facepiece supplied air - continuous flow mode 50 ½ mask supplied air in pressure-demand mode 1,000 full facepiece supplied air in pressure-demand mode 2,000 full facepiece SCBA in pressure-demand mode >2,000

*Assigned Protection Factor

Respirator Respirator Fit Fit

• initial fit test and re-testing

requirement

• types of fit tests

–qualitative

• depends upon ability of wearer to

detect irritant inside respirator

–quantitative

• substance measured inside & outside
• f respirator

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

5

Fit Checks Fit Checks

• rationale for the fit check
• negative pressure check

–why - how - when

• positive pressure check

–why - how - when

Other Imp Important Issue Issues

• Medical fitness to wear a respirator
• Facial hair & respiratory protection
• Care & cleaning of respirators
• Inspection of respirators
• Cleaning & disinfection
• Repairs
• Storage

Re Respir spiratory y Pro Program

• Minimum

Requirements:

– written SOP – MSHA/NIOSH certified respirators – appropriate for hazard – training of wearer – individual respirators – cleaning & disinfection – respirator storage – inspection & repair – work area monitoring – medical review – annual evaluation

• f respiratory

program

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

6

"Respiratory protection may be necessary for certain operations or methods such as paint removal by chemicals, heat gun, or abrasive techniques, and some set-up, and cleaning operations. However, respirators are the least preferred method of controlling airborne lead exposure, and they should not be used as the only means of preventing or minimizing exposures. Respiratory protection requirements are not an acceptable substitute for adequate training, supervision, appropriate engineering controls, and environmental or medical

• monitoring. Initial respiratory protection requirements for abatement work (which

may be based on conservative assumptions) should be modified with appropriate job-specific requirements based on air monitoring results. Respirator selection for each job category at every worksite should be determined by an industrial hygienist or other qualified individual, based on maximum airborne exposures measured."

NIOS IOSH Re Recomme mmendation

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

1 Pro Protective ve Clot Clothing & Eq Equipme ment

Objective:

• To present information on

various types of protective equipment: how to use and maintain them, and their limitations.

Imp Important Ag Agencies

• NIOSH - National Institute for

Occupational Safety and Health – research & recommendations

• ANSI - American National Standards

Institute – research & recommendations

• OSHA - Occupational Safety and Health

Administration – sets and enforces standards

Protective Clothing & Equipment

Imp Important PP PPE E Sta Standards

Protective Clothing & Equipment

1926.62(g) Protective work clothing and equipment 1910.132 & 1926.95 General requirements for full-body protection 1910.133 & 1926.102 Eye and face protection 1910.135 & 1926.1001 Head protection 1910.136 & 1926.96 Foot protection 1926.101 & 1926.101 Hearing protection 1910.95 (c) Noise and hearing conservation 1910.120(g)(3), 120(g)(5) PPE Program 1910.120 Appendix B Levels of protection and protective gear 1910.1200 Hazard communication 1926.59 Hazard comm. in construction

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

2 PP PPE E Spe Specified fied in OSH SHA A 1926.62

• Provision and use of PPE

– when PPE is required – who pays for PPE?

• Cleaning and replacement of PPE

–replacement dependent on exposure –who cleans clothing? –how can clothing be cleaned?

Protective Clothing & Equipment

Wa Warning fo for Clot Clothing Clea Cleaner

• Caution: Clothing contaminated

with lead: do not remove dust by blowing or shaking. Dispose of lead contaminated wash water in accordance with applicable local, state, or federal regulations.

Protective Clothing & Equipment

Per Person sonal Pro Protective ve Equ Equipme ment (PP (PPE) E)

• Full Body Protection
• Head Protection
• Eye Protection
• Hand Protection
• Foot Protection
• Hearing Protection
• Donning/Doffing Protective Clothing

Protective Clothing & Equipment

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

3 NIOSH Recommendations

Protective Clothing & Equipment

"Facilities for worker personal hygiene should be improved to minimize workers' exposure to lead through ingestion, and carry-home of lead contamination. Adequate washing facilities including running hot and cold water. Wherever feasible, showers, should be provided at the work site so that workers can remove lead particles from skin and hair. Contractors should arrange for collection and disposal of the wastewater in accordance with local and state

• requirements. Wherever feasible, contractors should supply a portable trailer to

contain storage, washing facilities, and clean areas. "All workers exposed to lead should wash their hands and faces before eating, drinking, or smoking, and they should not eat, drink, or use tobacco products in the work area, or other potentially contaminated areas on site. Tobacco and food products should never be permitted in the work area. Contaminated work clothes should be removed before eating."

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

1

Chapter 4 Inspecting for Lead-based Paint Regulatory Background

Learning Objectives

• Provide LBP inspectors with a regulatory history and

summary of current lead regulations and guidance;

• Explain how to comply with the laws regulating lead

inspections and environmental sampling

2

History

• Over the last three decades the federal government has

reduced the risk of lead exposure with the following actions: –banned the use of lead in drinking water systems –banned the use of lead solder in food cans –virtually removed lead from gasoline –issued guidance on lead in dust and soil –established work practice standards –implemented a lead in construction standard

3

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

2

Title X

• The Residential LBP Hazard Reduction Act of 1992

– switched the federal government’s focus from LBP to LBP hazards; – affects a number of other federal laws by amending their statutory language

4

Title X

– Defines lead-based paint hazard as

• “any condition that causes exposure to lead from

–lead-contaminated dust, –lead-contaminated soil, or –lead-contaminated paint that is deteriorated or present on accessible surfaces, friction surfaces, or impact surfaces

that would result in adverse human health effects as established by the appropriate Federal agency.”

5

What is LBP?

• Federal definition of LBP (pre-1978)

– > 1.0 mg/cm2—XRF or laboratory analysis – > 0.5% or 5,000 ppm —laboratory analysis

• CPSC’s definition of lead-containing paint

– > 0.06% or 600 ppm (1978-2016)

• CPSC’s NEW definition of lead-containing paint

– > 0.009% or 9000 ppm (current)

6

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

3

Environmental Protection Agency (EPA) Toxic Substances Control Act (TSCA)

• Amended to include Title IV which addresses:

–training and certification of lead-based paint detection and hazard control professionals; –training provider and laboratory accreditation; –health-based standards for dust, soil and lead-based paint; –real estate disclosure (most pre-1978 housing); –actions to reduce risks during renovation and remodeling

7

Notification, Evaluation and Reduction of Lead- Based Paint Hazards

• Section 1012/1013 of Title X
• Effective 15 September 2000
• Key Factors

– Covers pre-1978 housing receiving Federal assistance and Federally-owned housing being sold – Revises and consolidates existing HUD regulations

8

Housing & Urban Development (HUD) HUD’s 1012/1013 Regulation

• Requirements

– lead hazard evaluation and control based on program – required activities vary by

• type of assistance
• amount of assistance or cost of rehabilitation

– <$5,000 – $5,000-25,000 – >$25,000 9

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

4

HUD’s 1012/1013 Regulation

• Strategies vary in stringency, cost, and durability,

considering the statute, and

– amount, type and duration of HUD assistance – age of housing – occupants (rental or owner-occupied)

10

As s HUD involveme ment increase ses s with a resi sidential property, the resp sponsi sibilities s to protect children and fami milies s increase se.

Lead Hazard Evaluations

• Three types of methods:

– Visual assessment – Paint testing – Risk assessment (or lead hazard screen)

11

Lead Hazard Reduction Methods

• Three types of methods:

– Paint stabilization – Interim controls (or standard treatments) – Abatement of hazards

• Clearance examination required

– HUD dust lead hazard standards

• floors

10 µg/ft2

• sills

100 µg/ft2

• window troughs/wells

100 µg/ft2

12

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

5

HUD’s Prohibited Work Practices

13

Prohibited Methods of Paint Removal



• pen flame burning or torching

 machine sanding or grinding without a high-efficiency particulate air (HEPA) local exhaust control  abrasive blasting or sandblasting without HEPA local exhaust control  heat guns operating above 1,100 degrees Fahrenheit, or those that operate high enough to char the paint  dry sanding or dry scraping*  paint stripping in a poorly ventilated space using a volatile stripper that is a hazardous substance or chemical

Lead Disclosure Rule

• Joint EPA and HUD regulation
• Requires the following before a

purchaser or lessee of target housing becomes obligated under contract: –Provide a copy of Protect Your Family From Lead in Your Home; –Disclose the presence of any known lead-based paint

• r LBP hazards;

14

Lead Disclosure Rule

–Sales/rental contract shall include a lead warning statement; –Purchaser shall be given at least 10 days to conduct a risk assessment or inspection

• Lead-based paint free exemption:

–Owners of rental properties that are found to have no surfaces coated with LBP are exempted from the lead disclosure requirements.

15

For Sale

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

6

Training and Certification

• Rules issued by EPA (40 CFR part 745)
• Governs training and certification of lead

professionals working in target housing or child-occupied facilities

– Pre-1978, visited by the same child (age six or under), on at least two days per week, three hours per day, 60 hours per year.

• Effective in all states and Indian Nations on

1 March 2000.

16

Certification of Individuals

• Rule recognizes five disciplines:

– Lead-based paint inspector – Risk assessor – Contractor/supervisor – Abatement worker – Project designer

• Check with your state or tribe to determine if their

regulations differ from the federal!

17

Certification of Firms

• Firms that perform or offer to perform any of the LBP

activities must

– be certified – employ appropriately certified employees to conduct LBP activities – ensure that its employees follow the work practice standards for conducting LBP activities.

18

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

7

Re-certification

• To maintain certification, individuals must

– Apply to state, Indian tribe, or EPA, as applicable – Successfully complete a refresher course and exam from an accredited training provider

• EPA and most states and tribes require refresher training every

three years.

19

Work Practice Standards

• All lead-based paint activities in target housing and

child-occupied facilities

– must use certified individuals – must follow documented methodologies

• HUD Guidelines
• EPA Guidance
• other equivalent methods and guidelines (e.g., ASTM)

– clearance levels established by EPA

20

Renovation, Repair & Painting Rule (RRP)

• All renovations in target housings must use

lead safe work practices (LSWP)

– Renovators must be trained & certified – Renovation firms must be certified by EPA – LBP is presumed on building materials – Notification to Owner/Occupants required – Containment & Cleanup procedures – Cleaning verification – Recordkeeping

21

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

8

RRP Rule Summary:

• In 2008, EPA issued a final rule

under the authority of § 402(c)(3) of the Toxic Substances Control Act (TSCA) to address lead-based paint hazards created by renovation, repair, and painting activities that disturb lead-based paint in “target housing” and “child-occupied facilities.”

• Effective April 21, 2010

Abatements vs. Renovations

2 3

• Renovations are performed for many reasons, most

having nothing to do with lead-based paint.

• Renovations involve activities designed to update,

maintain, or modify all or part of a building.

• Renovations are covered by this rule.

RRP Rule Scope

2 4

• Covers renovation, repair and painting

activities that disturb lead-based paint in:

– Target housing, which is housing constructed before 1978 except:

• housing for the elderly or persons with disabilities

(unless any child who is less than 6 years of age resides or is expected to reside in such housing); or

• any 0-bedroom dwelling.

– Child-occupied facilities

• Includes kindergartens and child care centers

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

9

RRP Rule Scope

2 5

• Under this rule, a child-occupied facility is a

building, or a portion of a building:

– Constructed prior to 1978 and – Visited regularly by the same child, under 6 years of age on at least two different days within any week (Sunday through Saturday period), provided that each day’s visit lasts at least 3 hours and the combined weekly visits last at least 6 hours, and the combined annual visits last at least 60 hours. – Child-occupied facilities may be located in public

• r commercial buildings or in target housing.

RRP Rule Scope

2 6 Excludes:

• Renovations that affect only components that have

been determined to be free of lead-based paint.

• Minor repairs & maintenance

– Under 6 square feet interior or 20’ exterior

Opt-out provision:

• Homeowners may choose to opt out of the rule’s

requirements if they occupy the housing to be renovated, the housing is not a child-occupied facility, and no child under age 6 or pregnant woman resides there.

Training and Certification Requirements

2 7

• To become certified, the following persons

must take an 8-hour accredited training course:

– “renovators”—individuals who perform and direct renovation activities, and – “dust sampling technicians”—individuals who perform dust sampling not in connection with an abatement.

• The course completion certificate serves as

certification for these individuals.

• Refresher training is required every 5 years.

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

10

Training and Certification Requirements

2 8

• Renovations must be performed by certified

renovation firms using certified renovators and other workers that have received on- the-job training from certified renovators.

• To become certified, renovation firms must

submit an application to EPA and pay a fee (to be determined).

• Firm re-certification is required every 5

years.

Work Practice Requirements

2 9

• The certified renovator must direct the posting of

signs outside the work area to warn occupants and

• thers not involved in the renovation to remain

clear of the area.

• In addition, the certified renovator must also direct

the containment of the work area so that dust or debris does not leave the area while the work is being performed.

• Objects left in the work area, HVAC ducts, and

floors must be covered with taped-down plastic, or

• ther impermeable sheeting.

Work Practice Requirements

3

• Specific cleaning steps (which must be

directed by a certified renovator):

– All paint chips and debris must be picked up. – Protective sheeting must be misted, folded dirty- side inward, and disposed of as waste. – Walls in the work area must be vacuumed with a HEPA vacuum or wiped with a damp cloth. – All other surfaces in the work area must be vacuumed with a HEPA vacuum and wiped with a damp cloth. Floors must be wet mopped, using the 2-bucket method or a wet mopping system.

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

11

Work Practice Requirements

3 1

• A certified renovator must use wet disposable white

cleaning cloths to wipe the windowsills, countertops, and uncarpeted floors in the work area.

• These cloths must then be compared to a cleaning

verification card.

• If the cloth matches or is lighter than the cleaning

verification card, that surface has passed the cleaning verification.

• Surfaces that do not pass the first attempt must be

re-cleaned.

• Surfaces that do not pass on the second attempt

must be allowed to dry and wiped with a white electrostatic cleaning cloth.

Recordkeeping Requirements

3 2

• Recordkeeping: All documents must be retained

for 3 years following the completion of a renovation.

• Require post-renovation notification
• Enforcement:

– Lead-based paint is assumed to be present at renovations covered by this rule. – EPA may conduct inspections and issue subpoenas pursuant to the provisions of TSCA § 11 (15 U.S.C. 2610)

Enforcement

3 3

• Consolidated Enforcement Response and Penalty

Policy – August 2010

– Determines level of reponse

• Civil
• Criminal

– Assessing Penalties

• Gravity based
• History of violations
• $150 (minor)- $37,500 (major)

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

12

EPA Leaded Dust & Soil Hazards

• Dust

–Floors 10 µg/ft2 –Window Sills 100 µg/ft2

• Soil

–Interim controls - play areas 400 µg/g (ppm)

• non-play

1,200 µg/g (ppm) –Abatement 5,000 µg/g (ppm)

34

HUD Guidelines

• Guidelines for the Evaluation and Control of Lead-

based Paint Hazards in Housing

– published in 1995 – Chapter 7 revised in 1997 & 2012

• Chapter 7 provides a protocol for conducting LBP

inspections

35

OSHA

• Lead in Construction Standard (29 CRF 1926.62)

– regulates lead exposure in the construction industry

• permissible exposure level—50 µg/m3, 8-hour time weighted

average (TWA)

• action level—30 µg/m3, 8-hour TWA
• Check with your state to see if they have a state

OSHA plan.

36

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

13

OSHA

• Respiratory Protection Standard

(29 CFR 1910.134)

–must be complied with if a respirator is provided to an employee –employers must have a written respiratory protection program –Inspectors must be

• medically qualified
• fit tested, and
• trained

in order to wear a respirator

37

Respiratory Protection

• Situations during which an inspector may need a

respirator

– using a heat gun to collect paint-chip samples – conducting post-abatement clearance examinations – serving as a project monitor for the owner during an abatement project – others??

38

EPA Regulations/Laws

• Resource Conservation and Recovery Act (RCRA) -

1978

– governs federal hazardous waste disposal regulations – defines type of hazardous waste and generators – provides information on required procedures before, during and after disposal – many states and some localities are more stringent than federal – distinguishes between solid and hazardous waste

• LBP debris is hazardous waste if Toxicity Characteristic

Leachate Procedure (TCLP) determines leachable lead content > 5 ppm

39

POISON Hazardous

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

14

EPA’s Drinking Water Regulations

• Promulgated “National Primary Drinking Water

Regulation for Lead” in 1986

– level of concern for Pb in drinking water—15 ppb – requires 79,000 public water suppliers to monitor lead levels and apply treatment if necessary

• requirements affect public water systems (PWS), not individual

property owners

40

Differences in Regulations

• State, tribal, or local regulations may conflict with the

federal

• The most stringent applicable regulations apply

41

NYC Local Law 1

• f 2004

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

15

• Comprehensive law on lead paint in New York

City housing

• Replaces Local Law 38 of 1999 and Local Law

1 of 1982

• Effective Date – August 2, 2004

– Passed by Council December 15, 2003 – Vetoed by the Mayor – Council Override of Mayor’s Veto on February 4, 2004

Local Law 1 of 2004 Issues Addressed

• Owner’s responsibility to maintain
• HPD Enforcement
• J51
• Day Care Centers
• Other

Owner Responsibilities

• Remediate Lead Hazards
• Notify Tenants and Investigate
• Correct Lead Hazards Using Safe Work

Practices

• Make Apartments Lead Safe on Turnover
• Do All Repairs and Renovations Using

Safe work Practices

• Provide information to HPD and tenants

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

16

Owner Responsibilities to Remediate Lead Hazards

• Owners must prevent the reasonably

foreseeable occurrence of lead hazards and remediate them, and the underlying defects that may cause lead hazards, using safe work practices

– In apartments – In common areas

• In pre-1960 building, paint is presumed

to be lead paint Owner Responsibilities to Remediate Lead Hazards

• A Lead Hazard is any condition that

causes exposure to lead contaminated dust from:

– Peeling lead based paint – Deteriorated sub-surfaces – Friction surfaces – Impact surfaces – Chewable surfaces

Owner Responsibilities Remediate Lead Hazards

• Friction Surface

– Lead painted surfaces that abrade, scrape or

bind

• Chewable Surface

– Any window sill reachable by a child whether

intact or deteriorated

– Any other edge or protrusion that:

• Shows evidence of being chewed, or
• Tenant has notified owner that it has been chewed

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

17

• Obligation applies to

– Pre-1960 multiple dwellings – Post-1960 to pre-1978 buildings where the owner

knows that there is lead based paint

• Must investigate dwelling units where children

under 6 reside, and common areas, to find peeling paint, chewable surfaces, deteriorated sub surfaces, friction and impact surfaces

• The investigation must be conducted annually,

and more often if the owner knows of a condition that may cause a lead hazard, or the

• ccupant complains about such a condition

Owner Responsibilities Notify Tenants and Investigate Owner Responsibilities Notify Tenants and Investigate

• At Lease up and Renewal

– Must inquire if child under 6 will live there – Lease must contain notice of owner’s responsibilities – Must provide pamphlet on lead paint hazards

Owner Responsibilities Notify Tenants and Investigate

• Annual Notice

– Must send notice between January 1 and January 16

each year inquiring as to presence of child

– Tenant must respond by February 15 – If no response, owner must inspect between February

16 and March 1 to determine presence of child

– If no access must notify DOHMH – If there is a child, then must inspect to determine lead

hazards

– Must inform tenant of results of investigation

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

18

Owner Responsibilities Correct Lead Hazards

• Owner must correct lead hazards that are

found

– Must use workers trained in lead safe practices – Must use third party for clearance dust test – Must provide clearance dust test results to tenants

• Within 21 days, owner must correct any HPD

violation issued

– Must use EPA trained workers – Must use third party for clearance dust test – Must provide clearance dust test results to HPD

Owner Responsibilities Lead Safe on Turnover

• In all pre-1960 multiple dwelling units

and pre-1960 private dwelling units that are not owner-occupied:

– Remediate lead hazards – Make floors, sills and wells cleanable – Remove or permanently cover all lead on

friction surfaces of doors, door frames and windows

– Use safe work practices

Owner Responsibilities Repair and Renovation

• For any work of more than 2 sq ft in a

pre-1960 multiple dwelling or 1960-78 multiple dwelling where the owner has actual knowledge of lead paint:

– In a unit with a child or – In the common areas of building with a child

• Must use workers trained in lead safe practices
• Must use third party for clearance dust test
• Must provide clearance dust test results to tenants
• Must relocate if necessary

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

19

HPD Enforcement Inspections

 HPD may not remove any violations

from its records unless it has conducted a final inspection verifying remediation, and has copies of relevant dust tests.

 HPD must mail a copy of the final

inspection report and status to the

• ccupant and owner

Owner Responsibilities Repair and Renovation

• For any work of more than 100 sq ft or the

removal of two or more windows in a pre-1960 multiple dwelling or 1960-78 multiple dwelling where the owner has actual knowledge of lead paint:

– In a unit with a child or – In common areas where there is a child in the building

• Must use EPA certified firm
• Clearance dust test must be done by third party
• Must provide clearance dust test results to tenants
• Must relocate if necessary
• Must file with DOHMH 10 days prior to commencement

Owner Responsibilities Repair and Renovation

• Emergencies

– The law specifically exempts from coverage

work immediately necessary to safeguard against danger to life, health or safety

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

20

HPD Enforcement Inspections

• Complaints from tenants

– Must ask if there is child – Must inspect within 10 days

HPD Enforcement Inspections

• When doing inspection, HPD

– Must ask tenant for acknowledgment of child – Must perform room by room inspection – Must record for each room whether surfaces are intact – Where peeling paint is found must record condition of

underlying surface

– Must record any underlying defect – Need not move furniture – Must send Notice of Violation within 10 days – Must leave lead pamphlet

HPD Enforcement Inspections

• Complaint-driven Inspections

– Must XRF test conditions simultaneously with

inspection

• Line of Sight Inspections

– Must XRF test within 10 days of noting

peeling paint

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

21

Other

Record Keeping

• Owners who perform work pursuant to

Local Law 1/2004 must

– Retain all records relating to such work for

ten years from the completion of the work

– Make records available to HPD upon demand – Transfer records to the owner’s successor in

title

HPD Enforcement Inspections

• Timeframes

– Owner has 21 days to correct – Owner may seek two postponements of 14

days each

• May grant longer postponement if pending capital

work

– Certifications must be submitted within 5

days of correction

– HPD must re-inspect all violations within 14

days

– ERP must correct within 45 days

HPD Enforcement DOHMH Order to Abate

• If DOHMH issues a COTA for a lead poisoned child in a

multiple dwelling, within 15 days HPD must require the

• wner to submit to HPD all records of notification and

investigation within 45 days.

• If records show there may be lead hazards in other units

with children under age 7, HPD will inspect all such units within 10 days

• If the owner does not provide the records, HPD must

inspect child occupied units in 45 days to determine if there are any lead violations.

• The actions required of HPD are not applicable if HPD

has inspected the building within the twelve months preceding the issuance of the COTA

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

22

J-51 Expanded Benefit

• J-51 is available for abatement of lead

hazards

– In units occupied by children

• Including the costs of

– Permanent abatement – Inspection and risk assessment needed to do

the abatement

• Except that work performed to comply

with a Notice of Violation under the new lead law is not eligible for benefits Day Care DOHMH Program for Day Care

• Peeling lead paint is prohibited.
• Lead hazards must be remediated.
• Equipment must have lead free paint.
• If a non-complying condition is found, DOHMH must

serve the operator with an order to remediate.

• If the order is not complied within 45 days, DOHMH

must request an “agency of the City” to execute the

• rder. That agency must execute the order in 45 days.
• Lead hazards must be remediated in compliance with

DOHMH safe work practices

• Coop – Condo Exception

– Local Law 1/2004 does not apply to multiple

dwelling units where title is held by a coop

• r condo and the unit is occupied by the

shareholder of record or his or her family

• Tenants and subtenants retain protection of law

– Validates agreements made between coop

tenant shareholders and condo owners and coop and condo boards regarding allocation

• f responsibility for compliance with the lead

law

Other Coop-Condo Exception Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

23

Owner’s Form

– Annual notice – Apartment number – Application for exemption – Notice of commencement – Acceptable encapsulation products – Dismissal request

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

1

X-ray Fluorescence Theory

Inspecting for Lead-based Paint Chapter 5 (Part I)

Learning Objectives

• Provide inspectors with a working knowledge of X-ray

fluorescence technology;

• Describe the basic operating principles of portable

XRF analyzers;

• Introduce how XRF analyzers are used to conduct

LBP inspections;

• Introduce the principles of radiation safety;
• Explain registration and licensing requirements of

XRF instruments.

Introduction

• There are several methods used to test for lead in

– Paint – Soil – Dust

• All analytical methods are subject to some degree of

error

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

2

Introduction (continued)

• Two basic types of error in lead-based paint testing:

– False negative

• Failure to detect lead > the federal standard (1.0 mg/cm2 or

0.5 % by weight) – False positive

• Concluding that lead is present > federal standard, when it

is not.

X-ray Fluorescence (XRF)

• Most common analytical technique used for detecting

lead in paint

• XRF exposes a paint surface to radiation (X rays and

gamma rays) emitted from a source inside the instrument

– Cobalt-57 isotope – Cadmium-109 isotope – 4 W X-ray tube, 200µA

Basic graphic of X-ray fluorescence

radioactive source detector

Substrate LBP Non LBP

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

3

Basic Atomic Theory

• Atoms are the basic building blocks of all things
• Atoms have electrons that rotate in orbits or shells

around a nucleus

Basic Atomic Theory

• The closer the orbit of the electron is to the nucleus,

the more tightly bound those electrons are to the atom

• Nucleus is made up of positively charged particles

(protons) and, except for hydrogen, neutrons (carry no electrical charge)

• Orbiting electrons carry a negative charge.

– Like magnets—positive attracts negative

Basic Atomic Theory

• Different orbits (called “shells”) in the atom labeled

sequentially starting with K, L, M... K shell L shell M shell N shell

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

4

Basic Atomic Theory

• Gamma or X rays with sufficient energy can knock an

atoms electrons out of orbit

• When this happens, an electron from a higher shell

“drops down” to fill the vacancy

Basic Atomic Theory

• Each time a vacancy is filled by an electron from

another shell, a different energy X ray is emitted.

• Portable XRF analyzers generate gamma rays of

sufficient energy to knock out the K shell electrons

– The atom generates characteristic K X rays

Basic Atomic Theory

• X rays from each element have a different frequency.

– XRF analyzers can detect X rays of other elements in the paint or substrate, such as zinc and chromium – X rays emerge from the sample (paint) and enter the detector in the XRF analyzer

• The more lead X rays “counted” by the detector, the

more lead in the paint.

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

5

Basic Atomic Theory

• Some XRF analyzers display a spectrum or graph

containing peaks at the energy levels of the most abundant elements in a sample.

Basic Atomic Theory

• Other XRF analyzers use the energy levels of

characteristic lead X rays to filter and process only those pulses corresponding to lead

– This method is employed by direct reading XRF analyzers. – Only a number is shown to the reader, no spectrum of lead

• r other elements.

Half-life

• Half-life—the time it takes half of the material to decay

into another radionuclide or element.

• All radioactive isotopes decay over time, whether in use
• r not.

– This decay rate results in the intensity of the emission decreasing over time.

• Half-life for 57Co is approximately 9 months
• Half-life for 109Cd is approximately 15 months

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

6

Half-life

• The cost of re-sourcing an XRF varies by

manufacturer:

– $1,000 to 3,500 per source, including factory calibration

• Contact the manufacturer before shipping the

instrument back for re-sourcing to ensure that a source is available.

Radiation Safety

Inspecting for Lead-based Paint Chapter 5 (Part 2)

Health Effects of XRF Radiation

• X rays and gamma rays are forms of ionizing

radiation.

• Ionizing radiation can be classified into two groups:

– Photons (e.g., gamma and X rays) – Particles (e.g., beta particles, alpha particles)

• All types of ionizing radiation can remove electrons.

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

7

Health Effects of XRF Radiation

• Human exposure to ionizing radiation can lead to

damage depending on:

–type of radiation involved –chemical form of the radiation –intensity of the radiation (amount of radiation and distance from the source) –energy –duration of exposure

• The amount of radiation involved with any of the XRF

analyzers is small if used properly!!

Radiation Safety

• Inspectors must handle the XRF analyzer with care.
• The emission from the radioactive source is shielded to

minimize the operator’s exposure.

Radiation Safety

• Use common sense and follow these rules:

– Do not operate an XRF without thorough training; – Always handle the analyzer carefully; – NEVER point the shutter of an XRF at yourself or any other person; – Never open the shutter unless testing a surface; – The inspector is responsible for the security of the radioactive source.

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

8

Radiation Safety

• If an XRF is lost, report it immediately to state

authorities!!

Measuring Radiation Exposure

• Ionizing radiation exposure is measured in roentgens.
• The units of dosage are measured in roentgen

equivalent man (rem) or one-one thousandths (1/1,000) of a rem (millirem or mrem)

• The higher the dosage the greater the potential for

adverse health effects.

Natural Background Sources of Radiation

• The largest contributor (~300 mrem/year) to an

individual’s total radiation dose.

• Main sources are:

– radon, a naturally occurring gas – cosmic radiation – radioactive elements present in the earth’s crust – radioactive elements, present in the human body and building materials

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

9

Human-made Sources

• f Radiation
• Contribute the remainder of the annual average

radiation dose (~60 mrem)

• Examples include

– Medical X rays and nuclear medicine – Consumer products (e.g., smoke detectors, lantern mantles, tobacco) – Fallout from nuclear weapons testing – Nuclear reactors for power generation

Radiation Exposure Limits

• Two separate agencies have established exposure

limits:

– Nuclear Regulatory Commission (NRC) – OSHA

• Which levels apply to the inspector depends upon

whether the firm or agency is covered by federal or state OSHA

Radiation Exposure Limits*

Limits established by NRC Limits established by OSHA Whole body 5 rem/year (5,000 mrem/year) 1.25 rem/quarter Extremities 50 rem/year (50,000 mrem/year) 18.75 rem/quarter Eye 15 rem/year (15,000 mrem/year) Fetus 0.5 rem for the gestation period (500 mrem)

* Maximum allowable dosages for occupationally exposed employees!

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

10

Average annual radiation dose

Occupation Dose (m rem/ yr) Air line flight crew mem ber About 1,000 Nuclear power plant wor ker 700 Grand Centr al S tation worker 120 Medical personnel 70 University radi ation worker <10 Lead inspector using XR F 20

ALARA

• As
• Low
• As
• Reasonably
• Achievable

Factors Affecting Radiation Exposure

• Time

– The longer the exposure, the more chance of damage to human tissues.

• Distance

– Intensity diminishes very quickly with the distance between the person and the radiation source.

• Shielding

– A dense substance, (e.g., concrete) is placed between the source and an exposed individual.

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

11

Radiation Monitoring

• There is always the possibility of radiation exposure.
• Inspectors should wear dosimeters to measure their

exposure.

– Dosimeters are small devices that measure and record the amount of radiation to which the device is exposed. – Never store a dosimeter with an XRF analyzer or expose it to heat (e.g., on the dashboard of a car)

Radiation Monitoring

• Two basic types of dosimeters

– Ring dosimeters – Badge dosimeters

• Should be worn by the inspector whenever carrying or

using the XRF analyzer.

• Any overexposure recorded should be reported to the

Radiation Safety Officer (RSO) and the XRF manufacturer.

Dosimeters

Ring dosimeter Badge dosimeter

Graphics courtesy of Landauer, Inc.

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

12

Leak Testing

• Qualified personnel (usually the RSO) should monitor

the XRF analyzer periodically for radiation leakage.

– Use a radiation survey meter – Every six months wipe the surface of the XRF and analyze for radioactive levels.

• Maintain leak test results with the XRF analyzer at all
• times. Keep a copy in the office too!

Using an XRF

Inspecting for Lead-based Paint Chapter 5 (Part 3)

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

13

Performance Characteristics Sheets (PCS)

• Provides detailed information necessary to conduct a

LBP inspection using specific XRF instruments.

• Only XRF instruments for which a PCS has been

developed should be used!!

• Standardize the way each instrument is used and how

readings are corrected for substrate effect.

Example of a PCS

Substrate Bias and Correction

• Measurement of lead in paint by any XRF is affected

by scattering of X rays and gamma rays from the substrate.

– X rays generated within an atom are emitted in all directions

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

14

Substrate Bias and Correction

• Only X rays emitted in the direction of the XRF’s

detector will be detected.

• Additionally, the incoming rays can bounce off other

electrons and scatter.

– These scattered rays from other elements (within the paint

• r substrate) can lose energy and be detected as having

the same energy as lead X rays.

Scattering of Source Gamma Rays

Substrate Bias and Correction

• Interference from the substrate can bias the

measurement

– High (overestimates the true lead level) – Low (underestimates the true lead level)

• Most current generation XRF analyzers include

internal software to minimize or eliminate the substrate effect on readings.

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

15

Substrate Correction Procedure

• The need for substrate correction depends upon:

– specific instrument used – substrate type – initial reading level – specifications within the instrument’s PCS

Field Quality Control Procedures

• Evaluate whether an instrument is working properly.
• Used in XRF testing to protect against

– drift

• instability of the instrument’s electronics or by an aging battery

(i.e., failure to charge properly)

• drift cannot be corrected in the field!

– high variability in the measurements

Field Quality Control Procedures

• Accuracy

– the agreement of a reading or measurement or average of measurements with the true value.

• Precision

– degree of agreement of repeated measurements (using the same instrument and methods)

• Bias

– systematic difference between precise measurements and accurate measurements (i.e., the “true value”)

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

16

Accuracy, Precision and Bias

A B C D

Precision and Bias

• Precision may be affected by

– the length of measurement – random source decay variation – substrate/matrix effects

• Bias may be caused by

– calibration errors – systematic hardware problems related to the electronics of the XRF – system software problems related to internal compensation fore the substrate/matrix effect

Calibration Checks

• A series of measurements on a film or coupon with a

known amount of LBP applied to it (i.e., standard reference material [SRM]).

• Check must be done, at a minimum

– beginning of each inspection – every four hours – end of each inspection

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

17

Calibration Checks

• Inspector will need the following items:

– XRF analyzer – PCS – calibration check test result form (Appendix A) – SRM closest to 1.0 mg/cm2 (usually NIST 1.02 SRM film is used) – piece of solid wood, Styrofoam, or other nonmetal rigid substrate

Calibration Checks

• Before beginning testing, the inspector:

 attaches the SRM to the piece of nonmetal substrate;  takes three XRF measurements on the SRM;  records each of the three readings on the calibration check test results form;  averages the three readings (round to the same number of decimal places as the instrument displays);  Compares average with the calibration check limits on the PCS.

Standard Reference Materials

• NIST has developed a set of standard reference paint

films:

– yellow 3.53 mg/cm2 – orange 1.63 mg/cm2 – red 1.02 mg/cm2 – green 0.29 mg/cm2 – white <0.0001 mg/cm2

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

18

Licensing and Registration

• f XRF Analyzers
• Responsibility for registering an XRF analyzer rests

with the owner of the inspection company.

• Not usually regulated by NRC
• Regulated by state authorities

– registration or certification states – licensing states

• agreement
• nonagreement

Licensing and Registration

• f XRF Analyzers
• Specific Licenses

– Inspector cannot legally take possession of an XRF in a licensing state without this license. – Most require on-site visit from state radiation department inspector; they will look for:

• safe storage of the XRF;
• safe transportation of the XRF;
• safe use of the XRF;
• safe emergencies for the XRF.

Reciprocity

• The ability to bring an XRF analyzer from one state

into another without having to get another license.

• Agreement states agree to honor another state’s

license to possess radioactive materials.

– Possible conditions to reciprocity

• fee
• additional paperwork

– Must submit a copy of current license

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

19

General License

• A general license allows the user (e.g., a

lead inspection company) to take possession of the radioactive source under the manufacturer’s specific license.

• Advantages

– usually less paperwork involved – much smaller or no fees to the state

• Disadvantages

– the inspector cannot use reciprocity – many states do not accept general licenses

XRF Training

• Factory training (by the XRF manufacturer) is often a

requirement and always recommended!!

• Employer is responsible for maintaining a radiation

safety program that

– trains inspectors – informs them of the specific state(s) regulations

Transportation

• DOT regulates transportation of radioactive materials.
• DOT’s “exclusive use” category applies to most

portable XRF analyzers.

• XRFs cannot be shipped by the US Postal Service!!

– other package carriers will accept them if properly packaged and labeled.

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

20

Transportation

• Packaging
• Labeling

– Radionuclide – Physical form – Activity – Max radiation level, package surface: 0.5 mR/hr, no contamination – Radiation level, 10 inches from device: 10 mR/hr

Transportation

• Motor vehicle regulations

– Secure package against movement – Set handbrake during loading, unloading – Documentation with driver

• Shipping

– Airline – Common carrier

Scenarios

• Describe your organization’s plan for controlling:

– Storage – Access – Usage – Training – Transport – Shipping – Emergency response

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

21

Record Keeping

• Maintain a detailed log of use including:

– date checked out – date(s), times, and locations of each use – date, mode, and destinations for transport – dates and extent of all maintenance operations (including replacement of sealed radioactive source) – records of regular survey meter measurements and wipe tests

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Legal Liability and Insurance Issues

Liability and Insurance Issues

Chapter 6

Objectives

• To provide inspectors with knowledge of

potential legal liabilities

• To provide an understanding or criminal

penalties and administrative sanctions

• To provide an overview of the need for

contracts

• To provide an awareness of insurance

issues

Learning Tasks

• Legal responsibilities
• Sources of civil legal liability
• Contract language
• Purpose, limitations, and

availability of insurance

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Legal Liability and Insurance Issues

Sources of Legal Liability

• Statutory Law
• Administrative Law
• Common (or Civil) Law

Statutory Law

• Federal statutes—Lead-Based Paint

Poisoning Prevention Act (LBPPPA)

• Title X—Residential LBP Hazard

Reduction Act

• State statutes—specific lead poisoning

prevention laws, building codes, etc.

• Local, county or city ordinances
• Consumer protection laws

Administrative Law

• Federal regulations

– EPA training, certification, work practice standards – Department of Housing and Urban Development

• State regulations

– Department of Public Health – Department of Labor

• Health, sanitary or building codes

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Legal Liability and Insurance Issues

Common (or Civil) Law

• Decisions by state and federal courts

interpreting statutes, regulations, responsibilities

Criminal Penalties and Administrative Sanctions

• Fines
• Loss of License
• Criminal Prosecution
• Injunctions
• Cease work orders

Civil Lawsuits

• Compensation for harm done by the

legally responsible party.

• Common law

– Tort Law – Contract Law Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Legal Liability and Insurance Issues

Tort Law

• A civil “wrong” or breach of a

standard behavior or failure to use reasonable care

Tort Law

• Lead inspectors may be liable under tort

law for:

– negligence – vicarious liability

Negligence

• A lead professional could be found

“negligent” under Tort Law if he/she fails to exercise the standard of care to which a reasonable lead professional would adhere.

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Legal Liability and Insurance Issues

Elements of a Negligence Claim

• The plaintiff must prove four “elements”

in order to hold a defendant legally liable:

– that the defendant committed an act or

• mission which

– violated a duty which the defendant owed to the plaintiff and which act or omission – was the cause of – an injury to the plaintiff.

Vicarious Liability

• An employer is legally responsible for

the acts, omissions, and wrongful behaviors (“torts”) of his/her employees.

Duties of Lead Inspectors

• To do a complete, thorough and

accurate inspection, be knowledgeable

• f:

– statutes – regulations – industry practices and procedures – industry standards Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Legal Liability and Insurance Issues

Avoidance of Liability

• Tort liability

– be familiar with and follow laws, regulations, and industry standards – keep abreast of new developments – keep a comprehensive paper trail – provide close supervision – do not take short cuts

Contract Law

• A person is liable under contract law if

he/she breaks or “breaches” a legally enforceable written or oral agreement

• r contract.

Contract Liability

• Based on legally enforceable

agreements or contracts

– credibility – default – remedies

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Legal Liability and Insurance Issues

Avoidance of Liability

• Contract liability

– use written contracts – confirm all oral agreements, change

• rders, disputes in writing

– written forms

Avoidance of Liability

• Contract liability

– have clients sign “satisfaction” form upon completion of work – promise only what can be delivered – have a lawyer review forms and contracts

Insurance Considerations

• Obtain professional liability insurance to

secure protection from litigation arising from professional activities

– Errors & Omissions – General Liability Insurance

• Occurrence Insurance
• Claims-Made Insurance

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Legal Liability and Insurance Issues

Errors & Omissions

• Insurance to protect a lead professional

against misjudgments made during an inspection/risk assessment/abatement project

• Examples

– misclassification of testing combinations – not enough testing locations tested

General Liability Insurance

• Coverage suitable for situations arising

in the normal course of business and not related to the inspector’s delivery of professional opinions

Occurrence Insurance

• If an incident “occurs” while the policy is

in force, coverage is afforded even if the actual claim is made some years later and even if the insured is no longer insured by the same carrier

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Legal Liability and Insurance Issues

Claims-Made Insurance

• Coverage exists if a claim is made

(filed) while the policy is in force

Summary

• Liability

– Statutory – Administrative – Common (or Civil)

• Tort
• Contract
• Insurance

– Errors & Omissions – General Comprehensive Liability

• Occurrence
• Claims-Made

Regulations generally establish the minimum (the floor)!

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

1

Lead-based Paint Testing Operations

Part One: Inspecting for Lead-based Paint

Chapter 7 Chapter Objectives

• To provide instructions on how to do a

lead based paint inspection including:

– selecting surfaces to test; – understanding the technology required; – choosing applicable analysis method(s); – evaluating the results; – documenting the inspection; and – providing a complete, readable report.

Learning Tasks

• Explain obligations of all parties
• Describe standards/protocols for

inspections

• Understand construction components
• Identify all testing combinations
• Systematically document testing

conducted

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

2

Learning Tasks

• Describe how and when to conduct

paint-chip sampling

• List differences

between inspections in single- and multifamily housing.

Responsible Groups

• State, Indian tribe, and local

governments

• HUD
• EPA
• Housing authorities
• Homeowners and landlords
• LBP inspectors, risks assessors, and

hazard control contractors

Why is the use of a protocol important?

• Protection against potential liability
• Derived from inspection experience and

technical base of knowledge

• Report structure
• Competitive base

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

3 Preparing for the Inspection

• Hold a pre-inspection

conference between the inspector and client to discuss all aspects of the project

• Develop a confidential contract that

includes a scope of work, schedule, cost estimate, and payment terms

Designing the Inspection Plan–Single-Family

• The plan must include provisions for:

– scheduling the inspection – accessing the property – determining painting histories – selecting a primary testing method – planning quality assurance tests – identifying a laboratory – documenting the results of inspection

Designing the Inspection Plan–Multifamily

• Additional considerations included in

plan:

– randomly selecting units to be tested – randomly selecting common areas to be tested – analyzing results to determine if there is a pattern of LBP on specific components – developing a development-wide summary

• f component types coated with LBP

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

4 Terms and Definitions

• Lead-based paint inspection
• Room equivalent
• Building component type
• Substrate
• Testing combination
• Test location

Testing Hints

• Test surfaces representative of each

testing combination

• Certain adjacent components can be

grouped together if they have the same painting history

• Never group interior and exterior

components together

Types of Housing

• Single-family

– Any housing with fewer units than a multifamily development – Results cannot be applied to other dwellings Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

5 Types of Housing

• Multifamily

– Include dwellings with:

• 21 or more units if built before 1960; or
• 10 or more units if built from 1960 through 1978

– Use of random sampling

Inspection Steps

1 List all painted testing combinations by room equivalent 2 Select testing combinations 3 Perform XRF testing (including calibration check readings) 4 Collect and analyze paint-chip samples 5 Classify XRF and paint-chip samples 6 Evaluate the work and results 7 Document all findings in a report

Inventory & Selection of Painted Surfaces

• Make a rough sketch of property

– Label sides of dwelling clockwise with letters – Label room equivalents by use and number clockwise – ID like components by numbering left to right – ID closets by room and wall side

• Test all room equivalents inside and out as

distinct areas

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

6

Living room Dining room Kitchen Bathroom Pantry Play area Garage Driveway Foyer Enclosed Porch Stairs up Basement stairs

Room Equivalents & Side ID Testing Combinations

• Room Equivalents
• Building Components
• Substrates
• Other issues:

– Paint color & history? – Clear coatings – Furniture – Grouping components with multiple parts

Room Equivalent Building Component Substrate Kitchen (Room 4 ) Window B-1, Casing Wood Kitchen (Room 4 ) Window B-2, Apron Wood Kitchen (Room 4 ) Wall A, upper, center Plaster Kitchen (Room 4 ) Wall B, middl e, left Plaster House Exterior Window B-1, Casing Wood House Exterior Window B-3, Sill Wood

Testing Combinations

Examples:

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

7 Inspections in Single-Family Housing

• The Performance Characteristics Sheet

(PCS) for each XRF instrument provides important details for the following:

– Step 1: Calibration Checks – Step 2: Testing – Step 3: Substrate Corrections – Step 4: Classifying Results 30-second Readings Warp Drive 0.7 to 1.3 mg/cm2 (inclusive) 0.8 to 1.2 mg/cm2 (inclusive)

Step 1: Calibration Checks

• Refer to the XRF Calibration Check Limits on

your instrument’s PCS

– Example: Make: Gamma-Blast, Inc. Model:Techno-Xtra Special 601 XRF Calibration Check Limits

• Remember, the limits depend upon the operating mode

Calibration Checks

• Take three readings on 1.0 mg/cm2 NIST

SRM and average.

• Example: Calibration Readings

1.2 mg/cm2 0.9 mg/ cm2 1.3 mg/ cm2

– What is the average? – Is the average within the Calibration Check Limits for the instrument? Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

8 Calibration Checks

• Perform Calibration Check at least at

beginning and end of each inspection and every four hours.

• What if instrument is out
• f calibration

– At the beginning ? – At the end ?

Step 2: Testing

• Test all room equivalents
• One location per testing combination

– Exception: Four readings; one on each wall

• Test locations—representative
• Testing on non-flat surfaces
• Conditions for abbreviation of

testing

Step 3: Substrate Corrections

• Refer to PCS Substrate Correction

Section

• Example:

– For XRF results below 4.0 mg/cm2, substrate correction is recommended for: Metal and Wood – Substrate correction is not needed for: Brick, Concrete, Drywall and Plaster Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

9 Substrate Corrections

• How to do substrate corrections, if needed:

– Find two areas for each substrate (metal and wood in this example) where readings were less than 2.5 mg/cm2

• Take three readings on each area using NIST 1.02

mg/cm2 standard

• Average the six readings to get substrate

correction value

– Apply substrate correction value where needed

Substrate Correction Values Collected in the Field

Metal Wood Area 1 Area 2 Area 1 Area 2 1.1 0.3 1.5 1.9 0.7 0.6 1.3 1.6 0.5 0.8 1.4 1.7

Substrate Corrections

• Example:

What is the substrate correction value for metal? for wood?

Substrate corrections

• What is the corrected value for these

readings on: Metal doors Wood doors

0.8 mg/cm2 4.1 mg/cm2 4.2 mg/cm2 1.5 mg/cm2 0.1 mg/cm2 1.0 mg/cm2 Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

10

Inconclusive Range or Threshold 30-second Reading Description Substrate Inconclusive Range (mg/cm2)

Results corrected for substrate bias on metal & wood substrates only

Brick 0.5 to 1.5 Concrete 0.5 to 1.5 Drywall 0.7 to 1.3 Metal 0.6 to 1.2 Plaster 0.8 to 1.2 Wood 0.8 to 1.0

Step 4: Classification

• f Results
• Classify all results as positive, negative, or inconclusive by

referring to the PCS for your instrument:

Inconclusive Range or T hreshold Warp Drive Reading Description Substrate Threshold Inconclusive Range (mg/cm2) Brick None 0.9 to 1.1 Concrete None 0.9 to 1.1 Drywall None 0.9 to 1.1 Metal 0.9 None Plaster 0.9 None Results corrected for substrate bias on metal & wood substrates only Wood 1.0 None

Classification

• f Results
• Refer to PCS for your instrument:

Classification

• f Results
• How would you classify the components

used as an example on the previous slides:

– in the 30-second mode? – in Quickmode? Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

11

Other Issues

• Paint chip sampling and confirmatory

testing (mg/cm2)

• QA/QC
• Re-testing
• Time-and-Motion analysis
• Final Report

Lead-based Paint Testing Operations

Part 2: Multifamily Housing

Chapter 7 Inspections in Multifamily Housing

• Multifamily have the following differences
• vs. single-family inspections:

– additional interior and exterior areas must be inspected – not every unit is inspected – classification of XRF results by component is required to determine development-wide patterns – substrate correction procedures differ – testing of additional common areas Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

12 Inspections in Multifamily Housing

• Step 1: Compute Sample Size
• Step 2: Group Housing Units, Common

Areas, Exterior Sites

• Step 3: Select the Specific Units,

Common Areas, Exterior Sites

• Step 4: Select Testing Combinations
• Step 5: Compile Results by Component
• Step 6: Multifamily Decision Flowchart

Step 1: Compute Sample Size

• Number of units, common areas, and

exterior sites to be tested is based upon:

– total number of units – similar common areas, or exterior sites in the building(s) or on the property, and – the date of the construction.

• Refer to Table 7-3.

Number of Similar Units, Similar Common Areas or Exterior Sites in a Building or Development Pre-1960 or Unknown-Age Building or Development: Number to Test 1960-1977 Building or Development: Number to Test 1-9 All All 10-13 All 10 14 All 11 15 All 12 16-17 All 13 18 All 14 19 All 15 20 All 16 21-26 20 16 27 21 17 28 22 18 29 23 18 30 23 19 31 24 19 32 25 19 33-34 26 19 35 27 19 36 28 19 37 29 19 38-39 30 20 40-48 31 21 49-50 31 22 51 32 22 52-53 33 22 54 34 22 55-56 35 22 57-58 36 22 59 37 23 60-69 38 23 70-73 38 24 74-75 39 24

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

13 Step 1: Compute Sample Size

• Example: How many units, common

areas, or exterior sites should be tested for the following buildings? Year Built # of Units # to Test 1962 16 ________ 1970 30 ________ 1950 100 ________ 1940 1000 ________

Step 2: Group Housing Units

• Complete visual inspection to verify

accuracy of available information

• Identify buildings with a common

construction and painting history so they can be grouped together

Step 2: Group Housing Units

• Two options:

1 Sample each unit as a single-family dwelling; or 2 Sample some of the units and apply the results to the whole multifamily housing development.

• If the inspector chooses option two, a

“positive” finding must be applied to that component type in all unsampled units

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

14 Step 3: Select the Specific Units

• Use table to help in selection process (similar

to Table 7-4a)

• Use statistics table, calculator, or computer

program to generate random numbers

• Generate list of unit numbers equal to needed

sample number using the following formula: – Unit number = Round up from (random number X total # of units)

Select Specific Units

• Example:

Year Built # of Units # to Test 1965 20 16

• Generate at least 16 random numbers

and multiply each by total # of units (20 in this example). Round up to next whole number to get ID#. (See next slide)

Select Specific Units

.218 x ___ = ____ .533 x ___ = ____ .153 x ___ = ____ .412 x ___ = ____ .342 x ___ = ____ .120 x ___ = ____ .981 x ___ = ____ .300 x ___ = ____ .024 x ___ = ____ .267 x ___ = ____ .539 x ___ = ____ .493 x ___ = ____ .878 x ___ = ____ .607 x ___ = ____ .578 x ___ = ____ .829 x ___ = ____ .371 x ___ = ____ .799 x ___ = ____

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

15 Select Specific Units

Match selected ID #s to housing unit #:

ID# Unit # ID# Unit # ID# Unit # 1 101 9 204 17 402 2 102 10 205 18 403 3 103 11 301 19 404 4 104 12 302 20 405 5 105 13 303 6 201 14 304 7 202 15 305 8 203 16 401

Step 4: Select Testing Combinations

• Choose testing combinations as in

single-family dwellings with the addition

• f:

– common areas – additional exterior sites

• Select common areas and exterior sites

to be tested using random sampling method

Step 5: Compile results by component type

• Record measurement for each testing

combination and classify as:

– Positive – Negative – Inconclusive with XRF reading < midpoint

• f the XRF’s inconclusive range

– Inconclusive with XRF reading > midpoint

• f the XRF’s inconclusive range

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

16 Step 5: Compile the results by component type

• Use Component Type Report form to

– add descriptions; – group component types; – record number and percent of testing combinations classified for each component

Compile the results by component type

Example: Component % Pos % Neg % Inc Int win sashes 20 75 5 Int win trim 12 83 5 Int doors 95 5 Int door trim 2 97 1

Step 6: Multifamily Decision Flowchart

• Apply the Multifamily Decision Flowchart separately to each

component type

• Result for component type is:

– Positive if 15% or more of the components are positive – Negative if:

• 100% of tested component types are negative (OR)
• 100% of the tested component types are either

negative or inconclusive AND all the inconclusive samples have XRF readings < 1.0 mg/cm2

• Perform confirmatory testing as required

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

17

Other issues

• Testing evaluation
• Substrate correction
• Unsampled housing units
• Fewer than five percent positive results

Quality Assurance and Control Measures

• HUD Guidelines recommend the

housing owner or client evaluate the quality of the LBP inspection in one of the following ways:

– Direct observation – On-site results – Repeated testing – Time-and-motion analysis

Lead-Based Paint Testing Operations

Part III: Paint Sampling

Chapter 7

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

18 Preparation of Laboratory Samples

• Paint chip sample collection may be

necessary in some instances

• This section discusses

– ASTM standards – proper area for analysis – sampling materials needed – requirement to sample all layers

Collecting the Sample

• Prepare the sample container
• Use a containment method to avoid

contamination during sample collection

• Select method of sample collection

– Measure carefully the dimensions of the surface area of paint removed (2-4 square inches)

• Minimize the amount of substrate removed
• Cleanup and repair

Steps to Obtain Paint Chip Samples

1. Record test location information 2. Mark collection area 3. Set up a paint collection tray 4. Remove the paint 5. Clean all cutting tools 6. Transfer sample to the collection container 7. Check documentation for completeness on the Paint Chip Sample Collection Form

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

19 Laboratory Paint Chip Analysis

• Only one location of each testing

combination needs to be sampled

• Contact lab to determine required

sample size prior to sample collection

• Analysis completed by either:

– FAAS or GFAAS – ICP-AES

Laboratory Paint Chip Analysis

• Results are in one of the following units:

– mg/cm2; or – ppm, weight percent, µg/g, or mg/kg.

• Laboratory must be NLLAP-recognized
• Inexpensive test method, requiring little

disturbance of paint

• Rely on color change of swab or paint

– sodium sulfide (black) – sodium rhodizonate (red)

• HUD/EPA do not consider spot test kits

acceptable for

– Drywall/Sheetrock – Plaster – Dark paints

• May be considered good field check

Spot Test Kits

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

20

Spot Test Kits

• Only use EPA-recognized test kits on

substrates approved for the kit.

• Used by EPA Renovators to rebut

presumption of LBP per Renovation, Repair & Painting (RRP)

• RRP testing results must be provided to

the client as soon as possible, but no later than 30 days after completing the renovation.

Spot Test Kits Record Keeping

• Keep detailed records
• Methods of data documentation:

– Handwritten forms (Chapter 7 of HUD Guidelines) – Electronic storage

• Final summary report to client
• Additional information on the final report

is in Chapter 13

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

21 What you should understand

• Testing combinations and identification
• Number of XRF tests to perform
• How to perform calibration checks
• How and when to do substrate

corrections

• How to classify readings
• How and when to take paint chip

samples

What you should understand

• Number and selection of units, common

and exterior areas to test in multifamily housing

• Quality control options
• What to include in your reports

Environmental Education Associates, Inc. USEPA Lead Inspection 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 Inspection Initial Course Presentation

2

Building Components

Door

Building Components Building Components

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

3

Stairs

Building Components Building Components

Wall

Building Components

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

4

Building Components

Porch

Building Components

Porch

Building Components

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

5

Building Components

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Clearance Sampling

1

Clearance Sampling

Clearance Examinations

Chapter 8

Clearance

• Two main phases

– visual examination

• interior
• exterior

– environmental sampling

• dust
• soil (if exterior work was completed [optional])

Visual Examination

• Determines whether the lead hazard control work was

completed as specified

• Examiner must

– understand the scope of the job – have a keen eye for detail – be independent from the contractor

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Clearance Sampling

2

Visual Examination

• Paint removal and repainting

– All surfaces where paint has been removed examined before repainting – Commonly overlooked areas include:

• underside of interior window sills and handrails;
• backside or radiator ribs;
• bottom edge of doors;
• top of doorframes

Visual Examination

• Building component removal and replacement

– examiner should know the scope of the replacement activities

• Enclosures

– mechanical fastening system adequate – all seams and edges “dust-tight”

Visual Examination

• Soil Treatments

– all bare areas covered by sod or asphalt, as specified – no visible LBP chips

• Encapsulants

– determine if the encapsulant is present

• Interim Controls

– confirm all LBP is stabilized – friction and impact surfaces have been properly treated

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Clearance Sampling

3

Visual Examination

• If the work site fails the visual exam

– contractor corrects deficiency(ies) – contractor repeats cleaning

• HEPA vacuum/wet wash/HEPA vacuum cycle

– review visual examination reports – repeat visual examination – conduct clearance sampling

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Clearance Sampling

4

Wipe Sampling

• To determine if:

– the work area was cleaned up adequately; – the area is safe for unprotected workers to enter; – the area is a safe place for residents and young children to live.

EPA Dust Lead Hazard Criteria

• Surface Dust Lead Levels (µg/ft2)

– Floors 10 – Interior window sills (stools) 100

Effective January 6,2020

Note: Some states, tribes, localities may have different levels; evaluate results based on local, state, or federal standard—whichever is most stringent.

EPA Clearance Criteria

• Surface Dust Lead Levels (µg/ft2)

– Floors 40 – Interior window sills (stools) 250 – Window troughs (wells) 400 Subject to revision per EPA Proposed Rulemaking Note: Some states, tribes, localities may have different levels; evaluate results based on local, state, or federal standard—whichever is most stringent.

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Clearance Sampling

5

HUD Clearance Criteria

• Applicable to federally-owned or assisted target

housing

• Surface Dust Lead Levels (µg/ft2)

– Floors 10 – Interior window sills (stools) 100 Note: Some states, tribes, localities may have different levels; evaluate results based on local, state, or federal standard—whichever is most stringent.

HUD Clearance Criteria

• Applicable to OLHCHH Grantees
• Surface Dust Lead Levels (µg/ft2)

– Floors 10 – Porch Floors 40 – Interior window sills (stools) 100 – Window troughs (wells) 100 Note: Some states, tribes, localities may have different levels; evaluate results based on local, state, or federal standard—whichever is most stringent.

NYC Clearance Criteria

• Applicable to Local Law 1 requirements
• Surface Dust Lead Levels (µg/ft2)

– Floors 10 – Interior window sills (stools) 50 – Window troughs (wells) 100

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Clearance Sampling

6

Wipe Sampling Protocols

• HUD

–HUD Guidelines

• EPA

–Residential Sampling for Lead: Protocols for Dust and Soil Sampling

• American Society for

Testing and Materials (ASTM)

–ASTM 1728

When to Conduct Clearance Sampling

• Should be performed no sooner than

1 hour after final cleanup.

• Multifamily versus single-family sampling

– Multifamily Housing

• 21 or more units if constructed before 1960
• ten or more units if constructed from 1960-1977

– Use Table 7.3 to randomly select adequate number of units

Single-family Clearance Sampling

• Single-family housing and smaller multifamily

developments

– smaller multifamily developments

• 20 units or less if constructed before 1960
• nine units or less if constructed from 1960-1977

– sampling should be conducted in each dwelling unit

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Clearance Sampling

7

Number of Dust Samples (Table 9-1)

• Based on:

–interior or exterior treatments –number of rooms treated

• containment between

treated and untreated areas

–size of common area

• HUD rule requires

clearance after many rehab activities

Number of Dust Samples

• Random Clearance Sampling;

– When inspector or RA is 95% confident that no more than 5% of units may fail clearance. – Dust sampling represents concentrations of lead dust at specific locations taken to represent concentrations throughout the unit.

Location of Dust Samples (Table 9-1)

• Locations include:
• near the area where the lead hazard control treatment was done
• nearby high-traffic areas
• other areas selected by inspector
• Abatement contractor must not know where the

samples will be collected.

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Clearance Sampling

8

Wipe Sampling Materials and Supplies

• Disposable wipes

– background levels < 5 g/wipe – single thickness – durable – contains no aloe – can be digested by laboratory – yields 80 -120 % recovery rates from spiked samples – remains moist during sampling process

Wipe Sampling Materials and Supplies

• Gloves

– disposable – nonsterilized – nonpowdered

• Centrifuge tubes* (50 ml size)

– nonsterilized – polyethylene with sealable lid *Or equivalent hard-shell container

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Clearance Sampling

9

Wipe Sampling Materials and Supplies

• Sample collection forms

– Single-surface or composite sampling forms

• Defining sampling area

– hard, smooth reusable template – masking tape

• Additional supplies

– labels, permanent marker, trash bag, measuring tape, disposable shoe coverings (optional)

Single-surface Wipe Sampling Procedure

• Outline wipe area
• Preliminary inspection of wipe
• Preparation of container
• Gloves
• Initial placement of wipe

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Clearance Sampling

10

Single-surface Wipe Sampling Procedure (continued)

• First wipe pass

– side-to-side (fold wipe in half, dust-side in)

• Second wipe pass*

– top-to-bottom

* The ASTM and EPA methods adds a third pass around the perimeter of the area wiped.

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Clearance Sampling

11

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Clearance Sampling

12

Single-surface Wipe Sampling Procedure (continued)

• Rectangular areas (e.g., window sills)

– two side-to-side passes

• avoid touching other portions of the window
• Paint chips

– If visible paint chips, should have failed visual examination! – If present, attempt to include any chips that adhere to the wipe

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Clearance Sampling

13

Single-surface Wipe Sampling Procedure

• Package wipe/Label container
• Area measurement—to within 1/8th of an inch

– at least 4" x 4" should be wiped (0.10 ft2) – no more than 2 ft2 should be wiped

• Fill out sampling form
• Dispose of trash

Composite Sampling

• Set up all areas to be wiped before sampling (roughly

equivalent)

• Use a separate wipe for each subsampling location

(no more than four wipes per composite)

• Gloves do not need to be changed between

subsamples

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Clearance Sampling

14

Composite Sampling

• Rules for compositing

– separate composite samples required:

• from carpeted and hard surfaces
• from each different component sampled
• for each dwelling

– floor surface areas should be approximately the same (1 ft2

• r 929 cm2)

– sill and trough sampling sizes should be as similar as possible

Composite Sampling

• Rules for compositing (continued)

– do not use the same wipe to sample two different spots – do not insert more than four wipes into a single container – submit blank and spiked QA/QC samples

Quality Control/ Quality Assurance

• Field blank samples

– obtain after sampling, but before decontamination – label with unique identifier similar to other samples (blind) – collection procedure

• remove wipe with new glove
• shake open
• refold as if actual sample
• insert into sample container

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Clearance Sampling

15

Quality Control/ Quality Assurance

• Field blank samples

– one blank/dwelling unit sampled or one blank/50 field samples – collect one blank for every wipe lot used (record lot # on sampling form) – if more than 50 µg/wipe detected in blank, samples taken are invalid

Quality Control/ Quality Assurance

• Inspector decontamination

– do not have any hand to mouth contact during sampling (eat, drink, smoke, etc.) – after sampling, wash hands thoroughly

Quality Control/ Quality Assurance

• Spiked samples

– wipe is spiked with a known amount of lead dust (use same wipe lot # as used in field) – insert into the sample stream randomly (blind) – determines if there is adequate QC of digestion process at laboratory

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Clearance Sampling

16

Quality Control/ Quality Assurance

• Spiked Samples

– use spiked wipe sampling procedure found in Appendix 14.3 of the HUD Guidelines – use NIST Standard 1579a Powdered Lead-based Paint or equivalent – spike wipes with between 20 to 1000 µg of lead-containing dust

Quality Control/ Quality Assurance

• Spiked Samples

– blind analysis must fall within 80 to 120% of the true value. – if laboratory fails to obtain readings within error limits

• two more spikes should be sent to lab immediately
• if these two spikes fail, sample batch should be considered invalid

Composite Sampling

• Advantages

–lower cost per surface sampled –increased surface area wiped for the same cost

• Disadvantages

–information on specific sampling location lost –laboratories will have to adopt special handling and digestion procedures If composite sampling is used, a minimum of 3 separate composite dust samples should be collected (bare floors, sills and troughs).

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Clearance Sampling

17

Single-surface or Composite Sampling?

• Single-surface sampling

should be used: – leaded dust level information needed in a specific location – areas where leaded dust levels expected to be high (target cleaning efforts)

• Composite sampling should

be used: – controlling costs is essential – dust levels from same types of surfaces probably similar – cost of multiple-room cleanup will not greatly exceed single room cleanup

Avoiding Cross-sample Contamination

• Inspector should

– always change gloves for each sample – not touch anything but the wipe once glove is donned – discard wipe if

• dropped
• accidentally wipes an area outside the marked area

Avoiding Cross-sample Contamination (cont.)

• Inspector should

– discard the first wipe from the dispenser at the start of each dwelling – fold the wipe completely before inserting the wipe into the sample container

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Clearance Sampling

18

Evaluate the results

• Laboratory results often reported in micrograms of lead

– To evaluate, results must be converted to micrograms/square foot using the formula

Total micrograms of lead Total area wiped ( in square feet)

Example

Lab results for a wipe on a window sill has 226 µg of

• lead. The inspector wiped an area measuring

2.5 inches x 17 inches. What is the result in µg/ft2? Step one: Multiply 2.5 inches x 17 inches = 42.5 in2 Step two: Convert square inches into square feet, divide 42.5 in2 by 144 in2/ ft2. Result = 0.2951333; round up to 0.3 ft2 Step three: Divide the total amount of lead in µg by the area wiped in square feet: 226 µg  0.3 ft2 = 753.3 µg/ft2

Dust Results: If a surface fails

• Single surface sampling:

– clean that surface in the room(s) that failed – clean that surface in rooms not sampled – repeat dust sampling

• Composite sampling

– clean that surface in the entire dwelling – repeat dust sampling

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

Clearance Sampling

19

Dust Results: If a surface fails

• Multifamily dust sampling

– same as single-family housing except:

• reclean that surface in all units or common areas the failed sample

represents

• repeat random dust sampling of that surface

Record Keeping Responsibilities

• Three parties should maintain records of all

abatement, interim control, risk assessment, inspection and clearance results:

– Property owner – Contractor – Clearance examiner

Records should be kept for the duration of the life of the building.

Record Content

• All laboratory results
• Quality control/quality

assurance procedures

• Date(s) of visual

examination

• Date(s) of

environmental sampling

• Completed forms
• Appropriate

identifiers for property:

–owner; –job contractor; and –resident(s)

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

1

Lead Haza zard rd Red educ ucti tion

• n Str

trateg ategies es

• This chapter is presented in three

sub-sections:

– Lead-Based Paint Abatement – Soil Lead Abatement – Interim Control

Lead Lead-Ba Based sed Paint Paint Ab Abateme ment

Objective: To explain how a lead-based paint abatement project is organized and the different methods used on those projects.

Major Ab Abateme ment Co Consi siderations

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

1 2 3

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

2 Minimu mum m Levels vels

• f

f Pr Protection

• To what level should the abatement

contractor protect the family, workers, and the environment?

• What is meant by “standard of

care”?

• Why should a contractor practice the

“standard of care”?

Lead-Based Paint Abatement

Occupant Pro 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.

In 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

4 5 6

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

3 Ext 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-Base sed Paint Abateme tement t Strate trategies

• Removing lead-based paint

– replace component or structure – remove paint from substrate

• Covering lead-based paint

– enclosing the paint – encapsulating the paint

• Enclosure

– hard barrier – 3/8”

• Encapsulation

– liquid applied – must be approved by HUD/EPA

Lead Lead-Ba Based sed Paint Paint Re Remo moval val

• Component/structure removal

– advantages – disadvantages

• Paint removal

– off-site removal

• advantages
• disadvantages

– on-site removal

• advantages
• disadvantages

7 8 9

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

4

Encapsula Encapsulants nts

• Reasons for encapsulant failure
• Encapsulant test patches
• Encapsulant systems

– fiberglass polymer systems – flexible polymer coatings

Abatement Abatement Tasks Tasks

• Final cleanup

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

• Record keeping

– records to be retained – who keeps the records

Soil Soil Lead Ab Abateme ment

Objective: To present the current methods for abating lead-contaminated soil

10 11 12

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

5 Soil Soil Lead Abateme ment

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

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

Inte Interim C rim Con

• ntrols

trols

Objective: To present information regarding proper and appropriate interim controls for the control of lead-based paint, dust, and soil hazards.

Interim Controls Interim Controls

HUD Definition: 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.

13 14 15

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

6

Interim Controls Interim Controls

• 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

Interim Controls Interim Controls

• When are interim controls

appropriate?

• Combinations of interim

controls and abatement

• Clearance
• Protecting residents during

interim control work.

• Waste

Paint Stabilization Paint Stabilization

• Causes of paint failure

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

16 17 18

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

7 Sub Subst strate Co Condition and and Repairs

• Water penetration from outside
• Interior leaks from heating and

plumbing

• Water vapor problems
• Substrate repairs

Co Comp mpleting Paint Painting Wo Work

• Worksite preparation
• Paint removal methods
• Surface cleaning
• Priming
• Topcoats
• Cleaning and clearance
• Reevaluations and monitoring

Friction & Impa & Impact Sur Surfa face Tre 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

19 20 21

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

8 Soil Soil In Interim m Co Control Pr 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

22

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

1 Chapters 9, 10 & 11

Dust, Soil & Water Sampling

Dust, Soil & Water Sampling

• Other sources of lead which can be a

major contributor to lead exposure (especially children), include:

• Dust
• Soil
• Water
• Miscellaneous items

Objectives of Section

• Understand different sources of lead in

a dwelling

• Learn how to conduct & interpret post

abatement clearance dust sampling

• Learn how to conduct results of testing
• Learn how to conduct & interpret

drinking water testing

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

2

Background

• Major rote of exposure in children is

leaded dust on hands, fingers, not ingestion of paint chips

• Much of leaded dust comes from soil

through deterioration and weathering of exterior LBP

• Level of lead dust is best indicator of

lead in the household

Sources of Lead in Interior Dust

• LBP is the primary source of leaded

dust

• HUD private housing survey showed

that houses with LBP were much more likely to have levels of lead in dust

• Other sources: dust & dirt tracked into

a house from outdoors by pets & people

Most Likely Place to Find Leaded Dust

• Interior window sills (stools), window

wells (troughs)

• Why?

– LBP was often used on wood & metal windows – Repeated opening/closing of window damages paint and produces dust – Those area cleaned infrequently Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

3 Other Places Where Lead Dust Likely to be Found

• Floors near windows & doors
• Near baseboards painted w/LBP
• Attic dust, esp. in houses near smelters, battery

plants or other industrial sources

• Near exterior doorways due to track-in from
• soil below exterior LBP (which was designed to

chalk as it weathered

• sidewalks near other houses w/LBP
• historically: from air borne lead in fuel, deposited in

exterior dust

How to control Lead Dust Levels in the Home

• Conscientious housecleaning. Especially

wet cleaning of:

• floors
• window sills
• window wells
• Regular mopping and wiping
• Lead dust reaccumulation rates are

more rapid when paint is in poor condition or under renovation

Post-Abatement Lead Dust Hazard is Substantial

• Historically: little attention paid to post-

abatement cleanup

• Substantial amounts of lead dust can be

released due to some abatement strategies

• Typical construction standard of “broom

clean” totally inadequate following abatement

• Tragic result: Actually causing poisoning in

children because of inadequate cleanup Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

4 HUD Proposed Post-Abatement Cleanup Guidelines

• Concern with post-abatement dust lead

levels caused HUD to propose stringent guidelines for cleanup and clearance testing after abatement

• Cleanup procedure involves:
• HEPA vacuuming
• Use of abrasive detergents

Inspector Responsibilities

• Visual inspection (preliminary &

final)

• Clearance testing of dust

Preliminary Visual Inspection

• Occurs after preliminary clean-up is completed.

Preliminary clean-up includes: – removal of plastic sheeting from floors – HEPA Vacuuming (VWV) – Washing with abrasive cleaners (VWV)

• Inspector ensures abatement has been

completed and that visible dust/debris have been removed

• Unsatisfactory inspection results in further

abatement and recleaning until passing preliminary visual inspection Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

5

Final Visual Inspection

• Completed after final cleanup, which includes:
• possible sealing of abated surfaces
• VWV (HEPA) 2X
• Goal is to ensure that abatement work is
• complete. Special attention to:
• boundary between abated and unabated area must be

sound

• windows should be checked for paint in hard-to-reach

places

• consider painting/sealing all abated areas

Last Step in Inspection Clearance Testing for Dust

• Goal of surface dust sampling: to ensure that

lead levels in surface dust in dwelling are reduces

• New Federal Clearance Standards (1/22/01)

– Floors 40 ug/f2 – Window Sills 250 ug/f2 – Window Wells 400 ug/f2

• Recommended sampling method: wipe

samples

Clearance Wipe Sampling

• Surfaces should be checked for dust &

cleaned, if necessary

• Sampling conducted at least 1 hour after final

cleaning

• Use non-aloe pre-packaged wipes moistened

with non-alcohol wetting agent and template (or measure after sampling)

• Supplies include: wipes, template, measuring

tape, marker, 50 ml centrifuge tubes, latex gloves and sampling bags (for transport) Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

6

Sampling Procedure for Floors

• Put on disposable shoe covers and latex

gloves before entering containment

• Position clean 1 x 1 foot template on floor

surface to be wiped

• Open wipe package
• Place wipe on surface within template and

wipe the surface using overlapping S pattern covering entire area

• Fold wipe in half and repeat sampling

procedure

Sampling Procedure for Floors

• Fold wipe again with area wiped on the inside
• Place wipe in new sealable 50 ml centrifuge

tube and seal

• Remove gloves
• Clean template
• Label sample

– site location – date & time – wipe area (1x1) – record similar info on chain of custody & field log

Sampling for Window Sills & Wells

• Sampling procedures are the same with the

exception of the use of the template

• Instead of using a template:

– Wipe an area at least 1/10 of a square foot (16

• sq. inches)

– Measure both length and width of the area sampled after sampling – Record measurements on chain of custody and field log

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

7 Field Quality Control Procedures - Field Blanks

• Field blank samples are collected for each

sampling batch or at least one per fifty (50) samples

• Field blank samples handled exactly like other

samples, but no area is wiped

• Field blanks collected at the end of sampling
• Record field blanks as such on logs/chain of

custody's

Field Quality Control Procedures - Spike Samples

• Spike samples are submitted at least one per

fifty (50) samples

• Spike samples are prepared in advance of

sampling by lab or qualified firm.

• Sampler knows concentration of lead on spike

sample

• Sampler records fictitious dimensions for

spike sample

• Record spikes as “blind” on chain of

custodians

Selecting Sample Locations

• Sample location should represent “worst case

scenario”, surfaces most likely to contain lead dust

• Sample one type (floor,sill, well) per room or

containment

• Clearance, Single Family

– 4 windows IWA – 4 floors IWA – 1 floor OWA (if containment used) Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

8

Selecting Sample Locations

• Clearance, Multi-unit Buildings

– 95% level of confidence that no more than 5% or 50 units, whichever smaller, exceed clearance levels

• Applicable only when abatement
• ccurring in multi-units at the same

time

Interpretation of Results

• Scattered-site cases (I.e. single family

dwellings) If any surface fails than all surfaces if that type should be recleaned

• Multi-unit project

If any surface fails in the unit, then all surfaces of the same type (e.g. floors) in all units should recleaned

Lead in Soil

• Soil sampling typically conducted by Risk

Assessor during hazard evaluation process

• Inspector may collect samples to establish

“baseline” levels of lead in soil, especially when exterior abatement or hazard control seems imminent (Manual p.10.6) Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

9

Lead in Soil

• Possible sources of contamination in soil

– weathering or “chalking” of exterior LBP on building (especially in colder Eastern & Middle West) – airborne contamination form leaded gasoline (until mid-70’s)

• Exposure to children

– playing in yard: dirt on hands put into their mouth – vegetables grown in lead contaminated soil (also source of adult exposure)

Soil Sample Collection Techniques

• Collected used a variety of devices:

– 12 inch stainless steel core sampler – hypodermic plunger (no needle) – plastic spoon

• Hammer or screw driver may be needed for

hard or frozen soils

• Composite sampling the rule:

– Collect between 3 - 10 sub-samples per use-area

Equipment for Soil Sampling

• Collected used a variety of devices:

– 12 inch stainless steel core sampler – hypodermic plunger (no needle) – plastic spoon

• Hammer or screw driver may be needed for

hard or frozen soils

• Latex gloves, wipes (for cleaning equipment)
• Wide mouth hard shell sample containers
• Labels, markers, chain of custody, log

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

10

Soil Sampling Procedures

• Identify sub-sample

locations

• Put on gloves
• Clean sampling tools
• Agitate sample location
• Collect top 1/2 inch of

soil

• Place sample in

collection container

• Collect similar sized

samples for each subsample

• Not necessary to clean

sampling equipment or change glove between sub-samples

• Label sample as

composite sample and identify location

• Complete chain of

custody

Location of Soil Samples

• Prepare a detailed drawing of the site which

includes:

– lot boundaries – position of main buildings and paved area – position of play areas – position of areas with exposed soil, roof drain spouts and other drainage – drip line of buildings – areas of heavy traffic

Location of Soil Samples

• Include the following in the description of the

property:

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

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

11 Number of Soil Samples

• Determine number of samples to take by the

area of bare soil

• One composite should be collected for each

area used for separate purpose, including:

– play area – foundation drip line – gardens – paths

Interpreting Soil Sampling Results

• Analysis by AAS (XRF possible)
• Results reported in parts lead per million

parts soil (ppm)

• Because of compositing, the results represent

average soil lead concentrations over the area where sample was collected

• Federal Standards:

– Child's Play Area: 400 ppm – Other Areas: 1200 ppm

Lead in Drinking Water

• Sources of lead contamination in drinking

water include:

– copper plumbing & lead/tin solder – lead services lines or interior lead plumbing – lead in main supply (1% of water supply system)

• Lead tends to build up in water stagnant in

pipes overnight so highest lead levels usually encountered in the “first draw” Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

12

Drinking Water Sampling Equipment

• Always obtain sampling containers from lab
• Containers must have preservative (nitric

acid) to ensure quality of water after deliver to lab

• Delivery must not exceed one week
• Complete chain of custody

Sampling Procedures*

• 1st draw:

One liter from the cold water tap used most often

• 2nd draw:

Immediately after 1st draw

• 3rd draw:

2 minutes after 2nd draw

• 4th draw:

3 minutes after 3rd draw

* devised for municipal water systems

Interpretation of Water Sample Results

• Samples sent to lab for AAS
• Results reported in parts per billion (ppb)
• EPA regulations set action level at 15 ppb for

water in dwellings

• In general levels of the four samples will

decrease in lead concentrations Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

13

Situations of Concern

• 1st & 2nd samples exceed the action level but

the third sample is much lower. Lead contamination is internal to the dwelling. Take the following steps:

– run water before using – use cold tap when cooking – never use first draw or warm water when making formula

Water Sampling in a Multi-unit Project

• The situation is more complicated in a multi-

unit project but useful information can be

• btained by using the process previously

described

• For additional information, call EPA Safe

Drinking Water Hotline:

800 426 4791

Spot Test Kits

• Inexpensive test method, requiring little

disturbance of paint

• Rely on color change of swab or paint

– sodium sulfide (black) – sodium rhodizonate (red)

• HUD/EPA do not consider spot test kits

acceptable for inspections

– not quantifiable – difficult to distinguish colors – other metals may be misidentified

• May be considered good field check

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

14

Chain of Custody

• Necessary to demonstrate transfer of sample

to laboratory

• Legally acceptable evidence that samples

went to the lab and were not interrupted during delivery

• Must be signed by sampler and lab (on

deliver)

• May include information to aid in reporting

results (i.e sample size)

• Try to retain original signatures

Sample Analysis

Most common techniques for lead determination in environmental matrices such as blood, air, soil, water and paint:

• Laboratory or transportable use:

– Flame Atomic Absorption (AAS) – Graphite Furnace Atomic Absorption (GFAA) – Inductively Coupled Plasma- Optical Emission Spectrometry (ICP-OES) – Inductively Coupled Plasma- Mass Spectrometry (ICP- MS)

• Portable use

– X-ray fluorescence (XRF)

Lead Determination by Atomic Spectroscopy Techniques

• Can detect low levels of lead in a variety of

matrices

• Accurate & precise lead determination

(precision better than 1%)

• Small sample sizes can be analyzed
• Sample preparation may be extensive

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

15 Sample Analysis Process

• Step 1

Representative & homogeneous sample collection

• Step 2

Delivery to Lab with Chain of Custody

• Step 3

Sample Preparation: solubilized, digested or leached (TCLP)

• Step 4

Analytical Instrument quality control/assurance

• Step 5

Samples analyzed

• Step 6

Report

Sample Preparation

• Ashing

paint film is ashed to destroy

• rganic content. Ash is

dissolved in acid

• Digestion

many matrices can be digested using acid & hotplate or microwave heating

• TCLP

material is agitated for 18-24 hours with an acetic acid buffered solution. Extract is filtered and digested

Other Analysis

• Anodic Stripping Voltammetry

– electrode used to charge lead and obtain measurement

• Laser Technology

– under development

• New Methods Request -EPA website

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

1

Chapter 13

Inspecting for Lead-based Paint Data Analysis

Objectives

• Learn the types of data generated during a LBP

inspection and how to evaluate

• Discuss possible sources of error in data
• Explain the function of the final report
• Describe the five major sections of the report
• Emphasize the importance of

writing reports in a standard format 2

Common Error & Deficiencies

• Did not test at least one of each of the testing

combinations per room equivalent

• Did not provide enough specific information on exact

testing locations

• Produced high rate of false negatives
• Provided incomplete reporting of the results of the

inspection 3

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

2

Reasons for Data Analysis

• Evaluated to ensure inspection

was completed in accordance with protocols

• Determine which components

are coated with LBP and which do not 4

Data Evaluation–Single Family

• Test one of each testing combination

– Determine if additional testing is required

• Classify all data as positive or negative
• Develop list of positive testing combinations
• All inconclusive results should be confirmed by lab

analysis or assume positive

• Review data for errors and omissions

5

Definition of Multifamily Housing

• Defined as any group of units that are similar in

construction from unit to unit with:

– 21 or more similar units, common areas or exterior sites if built before 1960 or are of unknown age – 10 or more similar units, common areas or exterior sites if they were all built from 1960 to 1977

6

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

3

Data Evaluation— Multifamily

• At least 40 of each component type must be tested
• Verify the number of each component type
• Use Multifamily Housing: Component Type Report to

classify component types as

➢positive ➢negative ➢inconclusive

7

Data Evaluation— Multifamily

• Generate development-wide summary
• Abbreviation of testing is allowed

– confirm with client first

8

Report Content

• Cover letter or summary page
• Scope of service, including limitations or exclusions
• Supporting documents and appendices
• Disclaimer and standard of care

9

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

4

Summary Page

• Should answer two basic questions:

–Is LBP present in the unit or dwelling? –If LBP is present, where is it located?

• Must include basic information such as:

–who conducted the inspection –when it was conducted –for whom it was conducted –how it was conducted

10

LBP Inspection for Janet Doe 123 Heart Way Anywhere, US Conducted by Joe Inspector Leadheads, Inc.

Summary Page

• List of positive component types including

– room equivalent (name and number) – component type – substrate type – color of paint, stain or other surface coating (optional)

• EPA/HUD lead disclosure statement

11

Scope of Service

• Outlines what work was contracted to be done

– Include any exceptions to the scope of service (what was not done and why)

• Briefly describe the assumptions used in conducting

the LBP inspection and in making the conclusions of the report

• Discuss any procedures not utilized

12

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

5

Supporting Documents/Appendices

• All raw XRF data
• Laboratory results from a laboratory that is recognized

by NLLAP

• Completed calibration check form(s)
• Completed substrate correction form(s)
• A sketch or detailed description

illustrating sampling locations

• Multifamily component and unit

selection forms (if applicable) 13

Disclaimer and Standard of Care

• Include brief narrative about the site and the type of

inspection conducted

• List protocols used and any other information relied

upon to generate report

• Provide statements about surfaces below

federal/local standards and OSHA regulations

• Results are only applicable to the dwelling inspected
• n specific date and time

14

Other Issues

• Record Keeping

– Handwritten or electronic

• Data Management

– Spreadsheet software programs

• Records Retention

– EPA requirement is three years – Seek legal advice to determine appropriate time period of retention for your company

15

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation

6

For More Information

• Publications

– EPA, state and/or Indian tribe lead rules – HUD Guidelines – EPA model curriculum for inspectors

• Federal Agencies

– EPA www.epa.gov/lead – HUD www.hud.gov/lea – OSHA www.osha.gov

• Non-Governmental Organizations

16

Environmental Education Associates, Inc. USEPA Lead Inspection Initial Course Presentation