Lead Safety for Renovation, Repair, SAMPLE PPT.pdfTSITSI TSI - 16 Module 2: Regulations U.S. Environmental Protection Agency (EPA): • Established accredited training and certification

Lead Safety for Renovation, Repair, and

Painting

Jul 11

TSI Rev. 1 -- July 2011 1

Welcome to the Welcome to the

USEPA Lead Safety USEPA Lead Safety forfor

Renovation, Repair Renovation, Repair & Painting& Painting

Presented by:Presented by:

Wayne IngramWayne Ingram

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Lead Safety for Renovation, Repair, Lead Safety for Renovation, Repair, and Paintingand Painting

��Welcome and IntroductionsWelcome and Introductions

��Module Overview:Module Overview:

•• Course agenda Course agenda

•• Course Course manualsmanuals

•• You will learn…You will learn…

•• This course…This course…

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Course AgendaCourse Agenda

�� Introduction and welcomeIntroduction and welcome�� Module 1: Module 1: Why Should I Why Should I

Be Concerned About Be Concerned About Lead Paint?Lead Paint?

�� Module 2: Regulations Module 2: Regulations �� BreakBreak�� Module 3: Module 3: Before Before

Beginning WorkBeginning Work�� Module 4: Contain Dust Module 4: Contain Dust

During WorkDuring Work�� LunchLunch�� Module 5: During the Module 5: During the

WorkWork

�� BreakBreak�� Module 6: Cleaning Module 6: Cleaning

Activities and Activities and Checking Your WorkChecking Your Work

�� Module 7: Module 7: RecordkeepingRecordkeeping

�� BreakBreak�� Module 8: Training Module 8: Training

NonNon--Certified Certified Renovation WorkersRenovation Workers

�� ReviewReview�� TestTest

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Training Manual OverviewTraining Manual Overview

��Eight modulesEight modules�� Interactive and handsInteractive and hands--on exercises, in 11 Skill on exercises, in 11 Skill

SetsSets��Key appendicesKey appendices

�� Appendix 1 Appendix 1 -- EPA’s Renovation, Repair, and Maintenance EPA’s Renovation, Repair, and Maintenance Program Final Rule (40 CFR Part 745)Program Final Rule (40 CFR Part 745)

�� Appendix 2 Appendix 2 -- U.S. Department of Housing and Urban U.S. Department of Housing and Urban Development (HUD) RequirementsDevelopment (HUD) Requirements

�� Appendix 3 Appendix 3 -- Renovate Right: Important Lead Hazard Renovate Right: Important Lead Hazard Information for Families, Child Care Providers and SchoolsInformation for Families, Child Care Providers and Schools

�� Appendix 4 Appendix 4 -- Small Entity Compliance Guide to Renovate RightSmall Entity Compliance Guide to Renovate Right�� Appendix 5 Appendix 5 -- Steps to LEAD SAFE Renovation, Repair, and Steps to LEAD SAFE Renovation, Repair, and

PaintingPainting�� Appendix 6 Appendix 6 -- HandsHands--on Exerciseson Exercises

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You Will Learn…You Will Learn…

�� Why leadWhy lead--based paint is a problem during based paint is a problem during renovations.renovations.

�� What the EPA and HUD regulations require of Certified What the EPA and HUD regulations require of Certified Firms and Certified Renovators.Firms and Certified Renovators.

�� How to determine if leadHow to determine if lead--based paint affects work. based paint affects work.

�� How to begin the work.How to begin the work.

�� How to set up the work area to contain dust.How to set up the work area to contain dust.

�� How to work in a leadHow to work in a lead--safe manner. safe manner.

�� How to clean the work area and verify cleanliness.How to clean the work area and verify cleanliness.

�� How to dispose of waste safely.How to dispose of waste safely.

�� How to document your work. How to document your work.

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This Course...This Course...

�� Meets EPA and HUD requirements.Meets EPA and HUD requirements.

�� Produces EPA Certified Renovators.Produces EPA Certified Renovators.

�� Demonstrates your commitment to safety. Demonstrates your commitment to safety.

BUT, BUT,

�� Is not an abatement course.Is not an abatement course.

�� Does not satisfy OSHA training requirements.Does not satisfy OSHA training requirements.

�� May not satisfy state, local or tribal training May not satisfy state, local or tribal training requirements.requirements.

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Module 1: Why Should I be Module 1: Why Should I be Concerned about Lead Paint?Concerned about Lead Paint?

OverviewOverview

•• What is leadWhat is lead--based paint?based paint?

•• What health risks and health effects are related to What health risks and health effects are related to lead exposure? lead exposure?

•• Why is leadWhy is lead--contaminated dust a problem?contaminated dust a problem?

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What Is LeadWhat Is Lead--Based Paint?Based Paint?

•• Federal standards define leadFederal standards define lead--based paint as:based paint as:•• Any paint or surface coatings that contain lead equal to or in Any paint or surface coatings that contain lead equal to or in

excess of 1.0 milligram per square centimeter or more than 0.5 excess of 1.0 milligram per square centimeter or more than 0.5 percent by weight. percent by weight.

•• Some states and localities regulate paint with lower Some states and localities regulate paint with lower concentrations of lead.concentrations of lead.

•• It is the primary source of leadIt is the primary source of lead--contaminated dust in housing.contaminated dust in housing.

•• Why was lead used in paint?Why was lead used in paint?•• Lead was added for color and durability.Lead was added for color and durability.

•• LeadLead--based paint was banned in 1978.based paint was banned in 1978.

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Where is LBP found?Where is LBP found?

Paint

Gasoline

Piping

Food cans

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Health Risks of LeadHealth Risks of Lead

•• Very hazardous to children.Very hazardous to children.•• Damages the brain and central nervous system; can cause Damages the brain and central nervous system; can cause

decreased intelligence, reading and learning difficulties, decreased intelligence, reading and learning difficulties, behavioral problems, and hyperactivity.behavioral problems, and hyperactivity.

•• Damage can be irreversible, affecting children throughout their Damage can be irreversible, affecting children throughout their lives.lives.

•• Hazardous to pregnant women.Hazardous to pregnant women.•• Damage to the fetus.Damage to the fetus.

•• Also hazardous to workers and other adults.Also hazardous to workers and other adults.•• High blood pressure.High blood pressure.•• Loss of sex drive and/or capability.Loss of sex drive and/or capability.•• Physical fatigue.Physical fatigue.

•• Lead exposure causes permanent damage.Lead exposure causes permanent damage.•• *Primary way poisoned*Primary way poisoned

•• Breathing or ingestingBreathing or ingesting

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Health EffectsHealth Effects

��Heart & blood systemHeart & blood system

��KidneysKidneys

��Nervous system*Nervous system*

��Memory*Memory*

��Concentration*Concentration*

��Bone tissueBone tissue

��Female reproductionFemale reproduction

��Male reproductionMale reproduction

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Health Effects Health Effects -- AdultsAdults

�� Increased chance of illness during Increased chance of illness during pregnancy.pregnancy.

�� Harm to a fetus, including brain Harm to a fetus, including brain damage or death.damage or death.

�� Fertility problems (in men and Fertility problems (in men and women).women).

�� High blood pressure.High blood pressure.

�� Digestive problems.Digestive problems.

�� Nerve disorders*Nerve disorders*

�� Memory and concentration problems*Memory and concentration problems*

�� Muscle and joint pain.Muscle and joint pain.

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Health Effects Health Effects -- ChildrenChildren

Low Levels of ExposureLow Levels of Exposure��Persistent tiredness or Persistent tiredness or

hyperactivity.hyperactivity.

�� Irritability.Irritability.

��Loss of appetite.Loss of appetite.

��Weight loss.Weight loss.

��Reduced attention span.Reduced attention span.

��Difficulty sleeping.Difficulty sleeping.

��Constipation.Constipation.

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Health Effects Health Effects -- ChildrenChildren

Higher Levels of ExposureHigher Levels of Exposure

��Nervous system and kidney damage.Nervous system and kidney damage.

��Learning disabilities, attention deficit Learning disabilities, attention deficit disorder, and decreased intelligence.disorder, and decreased intelligence.

��Speech, language, and behavior problems*Speech, language, and behavior problems*

��Decreased muscle and bone growth.Decreased muscle and bone growth.

��Poor muscle coordinationPoor muscle coordination

��Hearing damage.Hearing damage.

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Symptoms Of Lead Poisoning are Symptoms Of Lead Poisoning are Not Always ObviousNot Always Obvious

•• Symptoms are easily misinterpreted by Symptoms are easily misinterpreted by medical personnel, thus delaying effective medical personnel, thus delaying effective treatment and increasing the likelihood of treatment and increasing the likelihood of permanent physical and mental damage.permanent physical and mental damage.

•• Only sure way to determine lead poisoning Only sure way to determine lead poisoning is to take a blood lead level (BLL) test.is to take a blood lead level (BLL) test.

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Why are Dust and Debris a Why are Dust and Debris a Problem?Problem?

•• Renovation activities that disturb leadRenovation activities that disturb lead--based paint based paint create dust and debris. Debris becomes dust.create dust and debris. Debris becomes dust.

•• LeadLead--contaminated dust is poisonous.contaminated dust is poisonous.

•• Very small amounts of leadVery small amounts of lead--contaminated dust can contaminated dust can poison children and adults.poison children and adults.

•• Children swallow dust during ordinary play Children swallow dust during ordinary play activities. activities.

•• Adults swallow or breathe dust during work Adults swallow or breathe dust during work activities. activities.

•• Workers can bring leadWorkers can bring lead--contaminated dust home contaminated dust home and poison their families.and poison their families.

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A Little Dust Goes a Long WayA Little Dust Goes a Long Way

•• You can’t see it.You can’t see it.

•• It’s hard to sweep up.It’s hard to sweep up.

•• And, it travels.And, it travels.

One gram of lead-based paint can contaminate a large area!

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Video Clip of a Contractor Who Poisoned His Own Kids

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Video Clip of Parent of a Child Poisoned by Renovation

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Now You Know…Now You Know…

•• What leadWhat lead--based paint is and the adverse based paint is and the adverse health effects of lead.health effects of lead.

•• Dust is the problem.Dust is the problem.

•• Lead poisoning is hard to spot and the effects Lead poisoning is hard to spot and the effects can be permanent.can be permanent.

•• Kids are most at risk for lead poisoning.Kids are most at risk for lead poisoning.

•• Lead poisoning is preventable.Lead poisoning is preventable.

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Module 2: Regulations Module 2: Regulations ��U.S. Environmental Protection Agency (EPA):U.S. Environmental Protection Agency (EPA):•• Established accredited training and certification programs for Established accredited training and certification programs for

workers, supervisors, inspectors and risk assessors conducting workers, supervisors, inspectors and risk assessors conducting evaluation or abatement of leadevaluation or abatement of lead--based paint.based paint.

•• Established requirements for preEstablished requirements for pre--renovation education.renovation education.•• Promulgated the Renovation, Repair, and Painting Program Final Promulgated the Renovation, Repair, and Painting Program Final

Rule (RRP Rule). Rule (RRP Rule).

��U.S. Department of Housing and Urban Development U.S. Department of Housing and Urban Development (HUD):(HUD):•• Established actions in FederallyEstablished actions in Federally--assisted target housing.assisted target housing.•• Established Federal grant programs.Established Federal grant programs.•• Established guidelines for leadEstablished guidelines for lead--based paint evaluation and based paint evaluation and

control; established the Lead Safe Housing Rule. control; established the Lead Safe Housing Rule.

��U.S. Occupational Safety and Health Administration U.S. Occupational Safety and Health Administration (OSHA):(OSHA):•• Established worker protection standards.Established worker protection standards.

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The RRP RuleThe RRP Rule

��Addresses activities that disturb leadAddresses activities that disturb lead--based paint in based paint in target housingtarget housing and and childchild--occupied facilitiesoccupied facilities. It requires:. It requires:•• Renovators to be certified through training.Renovators to be certified through training.

•• Firms to be certified.Firms to be certified.

•• Training providers to be accredited.Training providers to be accredited.

•• LeadLead--safe work practices during renovations.safe work practices during renovations.

•• PrePre--renovation education in renovation education in target housingtarget housing and and childchild--occupied occupied facilitiesfacilities..

•• On or after April 22, 2010, firms working in preOn or after April 22, 2010, firms working in pre--1978 1978 homes and childhomes and child--occupied facilities must be certified and occupied facilities must be certified and use leaduse lead--safe work practices during renovations.safe work practices during renovations.

•• EPA may authorize states, territories and tribes to EPA may authorize states, territories and tribes to enforce the Rule.enforce the Rule.

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The RRP Rule: ExclusionsThe RRP Rule: Exclusions

•• Renovation activities where affected Renovation activities where affected components do not contain leadcomponents do not contain lead--based paint.based paint.

•• Emergency renovations (requires cleanup and Emergency renovations (requires cleanup and cleaning verification).cleaning verification).

•• Minor repair and maintenance activities. Minor repair and maintenance activities. Note: Note: This exclusion does not apply to window This exclusion does not apply to window replacement, demolition or activities involving replacement, demolition or activities involving prohibited practices.prohibited practices.

•• Renovations performed by homeowners in Renovations performed by homeowners in their own homes.their own homes.

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The RRP Rule: Firm CertificationThe RRP Rule: Firm Certification

•• On or after April 22, 2010, all covered On or after April 22, 2010, all covered renovations must be performed by renovations must be performed by Certified Firms, using Certified Certified Firms, using Certified Renovators and other trained workers. Renovators and other trained workers.

•• To become certified, firms must To become certified, firms must submit submit an application, and pay a feean application, and pay a fee, to EPA. , to EPA. Firms may begin to apply for Firms may begin to apply for certification on October 22, 2009.certification on October 22, 2009.

•• Certifications will be good for Certifications will be good for 5 years5 years..

•• Certification allows the firm to perform Certification allows the firm to perform renovations in any nonrenovations in any non--authorized state authorized state or Indian tribal area.or Indian tribal area.

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The RRP Rule: The RRP Rule: Firm ResponsibilitiesFirm Responsibilities

•• Ensure overall compliance with the RRP Rule.Ensure overall compliance with the RRP Rule.

•• Ensure that all renovation personnel are Ensure that all renovation personnel are Certified Renovators or have been trained onCertified Renovators or have been trained on--thethe--job by Certified Renovators.job by Certified Renovators.

•• Assign a Certified Renovator to all jobs.Assign a Certified Renovator to all jobs.

•• Meet preMeet pre--renovation education requirements.renovation education requirements.

•• Meet recordkeeping requirements.Meet recordkeeping requirements.

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The RRP Rule: The RRP Rule: Individual CertificationIndividual Certification

•• To become a Certified Renovator, an individual To become a Certified Renovator, an individual must take an EPAmust take an EPA--approved approved 88--hour training coursehour training coursefrom an EPAfrom an EPA--accredited training provideraccredited training provider..

•• The course completion certificate serves to certify The course completion certificate serves to certify renovators (no application to EPA is required). renovators (no application to EPA is required).

•• Refresher training is required every Refresher training is required every 5 years5 years..

•• Workers do not need certificationWorkers do not need certification so long as onso long as on--thethe--job training is received from a Certified job training is received from a Certified Renovator and the work is not HUDRenovator and the work is not HUD--regulated.regulated.

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The RRP Rule: Certified Renovator The RRP Rule: Certified Renovator ResponsibilitiesResponsibilities•• Perform work and direct leadPerform work and direct lead--safe work practices.safe work practices.

•• Provide onProvide on--thethe--job training to nonjob training to non--certified workers.certified workers.

•• Keep a copy of the initial and/or refresher training certificates Keep a copy of the initial and/or refresher training certificates onsite. onsite.

•• Use EPAUse EPA--recognized test kits to identify leadrecognized test kits to identify lead--based paint.based paint.

•• Be physically present while posting signs, containing work Be physically present while posting signs, containing work areas, and cleaning work areas.areas, and cleaning work areas.

•• Be available by telephone when offBe available by telephone when off--site.site.

•• Maintain the containment to keep dust and debris within the Maintain the containment to keep dust and debris within the work area.work area.

•• Implement the cleaning verification procedure.Implement the cleaning verification procedure.

•• Prepare and maintain required recordsPrepare and maintain required records..

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The RRP Rule: The RRP Rule: Work Practice StandardsWork Practice Standards

The Renovation, Repair, and Painting Final Rule covers The Renovation, Repair, and Painting Final Rule covers setup of the work area, prohibited work practices, setup of the work area, prohibited work practices, cleanup and the cleaning verification procedure. cleanup and the cleaning verification procedure.

•• Setup practices,Setup practices, such as posting signs and containing such as posting signs and containing the work area, will be covered in Module 4.the work area, will be covered in Module 4.

•• Prohibited practicesProhibited practices and dust reduction suggestions and dust reduction suggestions will be covered in Module 5.will be covered in Module 5.

•• Cleanup practices and cleaning verification Cleanup practices and cleaning verification proceduresprocedures will be covered in Module 6.will be covered in Module 6.

•• RecordkeepingRecordkeeping will be covered in Module 7.will be covered in Module 7.

•• HUD requirements on page TSIHUD requirements on page TSI--154154

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The RRP Rule: EnforcementThe RRP Rule: Enforcement

•• EPA may EPA may suspend, revoke, or modify a firm’s suspend, revoke, or modify a firm’s certificationcertification if the Certified Firm or Certified if the Certified Firm or Certified Renovator is found to be in nonRenovator is found to be in non--compliance. compliance.

•• Those firms found to be nonThose firms found to be non--compliant may compliant may be liable for civil penalties of up to be liable for civil penalties of up to $37,500$37,500 for for each violationeach violation..

•• Those firms who knowingly or willfully violate Those firms who knowingly or willfully violate this regulation may be subject to fines of up this regulation may be subject to fines of up to an to an additional additional $37,500$37,500 per violation, or per violation, or imprisonment, or bothimprisonment, or both..

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HUD’s Lead Safe Housing RuleHUD’s Lead Safe Housing Rule

•• Covers federallyCovers federally--owned or owned or --assisted target assisted target HOUSINGHOUSING and federallyand federally--owned target housing being owned target housing being sold. Renovators should ask if the housing sold. Renovators should ask if the housing receives financial assistance.receives financial assistance.

–– If yes, the renovator should ask the owner to find If yes, the renovator should ask the owner to find out if the assistance is federal assistance.out if the assistance is federal assistance.

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

–– Visual assessment, lead paint inspection;Visual assessment, lead paint inspection;

–– Paint stabilization, interim control, abatement;Paint stabilization, interim control, abatement;

–– Ongoing leadOngoing lead--based paint maintenance.based paint maintenance.

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HUD’s Lead Safe Housing Rule: HUD’s Lead Safe Housing Rule: Safe Work PracticesSafe Work Practices

•• HUD’s rule requires lead safe work practices for:HUD’s rule requires lead safe work practices for:

–– Paint stabilizationPaint stabilization

–– Interim control of identified leadInterim control of identified lead--based paint based paint hazardshazards

–– Rehabilitation (renovation)Rehabilitation (renovation)

–– Standard treatmentsStandard treatments

–– Ongoing leadOngoing lead--based paint maintenancebased paint maintenance

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

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HUD’s Rule Addresses:HUD’s Rule Addresses:

•• Training (usually classroom training for workers)Training (usually classroom training for workers)

•• Occupant protection and worksite preparationOccupant protection and worksite preparation

•• Prohibited methods (3 in addition to RRP Rule’s)Prohibited methods (3 in addition to RRP Rule’s)

•• De minimis levels (smaller than RRP Rule’s)De minimis levels (smaller than RRP Rule’s)

•• Lead safe work practicesLead safe work practices

•• Specialized cleaningSpecialized cleaning

•• Clearance testing (covered in Module 6)Clearance testing (covered in Module 6)

•• Occupant notification (within 15 daysOccupant notification (within 15 days))

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Know the EPA and HUD Rules!Know the EPA and HUD Rules!

To obtain a copy of the regulations To obtain a copy of the regulations contact the National Lead Information contact the National Lead Information Center at 1Center at 1--800800--424424--LEAD.LEAD.

You may also download the rules and You may also download the rules and other information from the following other information from the following websites:websites:

–– www.epa.gov/leadwww.epa.gov/lead

–– www.hud.gov/offices/leadwww.hud.gov/offices/lead

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State and Local RegulationsState and Local Regulations

•• States and localities may have different States and localities may have different regulations than EPA and HUD for renovations regulations than EPA and HUD for renovations in target housing. in target housing.

•• Check with your state and local housing and Check with your state and local housing and environmental agencies to obtain information environmental agencies to obtain information about such requirements.about such requirements.

•• Appendix 7 is reserved for copies or Appendix 7 is reserved for copies or summaries of state and local regulations.summaries of state and local regulations.

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•• That the EPA Renovation, Repair, and Painting That the EPA Renovation, Repair, and Painting Program Final Rule (RRP Rule) applies to renovation Program Final Rule (RRP Rule) applies to renovation in housing and childin housing and child--occupied facilities built before occupied facilities built before 1978 that contain lead1978 that contain lead--based paint.based paint.

•• To always take into account the requirements and To always take into account the requirements and responsibilities of certification for Certified Firms and responsibilities of certification for Certified Firms and Certified Renovators, and to reCertified Renovators, and to re--certify every 5 years.certify every 5 years.

•• To comply with setup of the work area, prohibited To comply with setup of the work area, prohibited work practices, cleanup and the cleaning verification work practices, cleanup and the cleaning verification procedure requirements in the Rule.procedure requirements in the Rule.

•• To determine whether your renovation job is regulated To determine whether your renovation job is regulated by EPA, HUD, both, or neither.by EPA, HUD, both, or neither.

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Module 3: Before Beginning WorkModule 3: Before Beginning Work

OverviewOverview

This module teaches you:This module teaches you:

��To educate owners and residents.To educate owners and residents.

��That the use of leadThat the use of lead--based paint was based paint was widespread.widespread.

��To determine if leadTo determine if lead--based paint is present. based paint is present.

��To use EPATo use EPA--recognized test kits to check for recognized test kits to check for leadlead--basbased paint. ed paint.

��How to decide which rule(s) apply.How to decide which rule(s) apply.

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Educate Owners and ResidentsEducate Owners and Residents

The PreThe Pre--Renovation Education Rule:Renovation Education Rule:•• Requires Renovation Firms to provide the Requires Renovation Firms to provide the Renovate RightRenovate Right

pamphlet to owners/residents prior to renovation activities in pamphlet to owners/residents prior to renovation activities in prepre--1978 housing and child1978 housing and child--occupied facilities.occupied facilities.

•• Specifies requirements for educating residents/occupants and Specifies requirements for educating residents/occupants and delivering the delivering the Renovate RightRenovate Right pamphlet that vary by type of pamphlet that vary by type of property and the area being renovated.property and the area being renovated.

Under the RRP Rule, Certified Firms MUST: Under the RRP Rule, Certified Firms MUST: •• Give homeowners/residents and childGive homeowners/residents and child--occupied facility occupied facility

owners/adult representatives copies of the owners/adult representatives copies of the Renovate RightRenovate Rightpamphlet.pamphlet.

•• Let parents/guardians of children using a childLet parents/guardians of children using a child--occupied facility occupied facility know about the renovation and how to get a copy of the know about the renovation and how to get a copy of the Renovate RightRenovate Right pamphlet.pamphlet.

•• Get confirmation of receipt of the Get confirmation of receipt of the Renovate RightRenovate Right pamphlet from pamphlet from owners, or evidence that the pamphlet was delivered to owners, or evidence that the pamphlet was delivered to tenants/residents.tenants/residents.

•• Keep all records for at least 3 years. Keep all records for at least 3 years.

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How Widespread is LeadHow Widespread is Lead--Based Based Paint in Housing?Paint in Housing?

Year House Was Built Percent of Houses with

Lead Based Paint

Before 1940 86 percent

1940-1959 66 percent

1960-1978 25 percent

All Housing 35 percent

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How to Determine if LeadHow to Determine if Lead--Based Paint Based Paint is Presentis Present

�� Paint testing must be performed prior to renovation on all Paint testing must be performed prior to renovation on all surfaces to be affected by the work, or you must presume the surfaces to be affected by the work, or you must presume the paint is leadpaint is lead--based. Any testing must be performed by the based. Any testing must be performed by the appropriate qualified professional.appropriate qualified professional.

Type of Paint Testing for Renovations

Who can do the testing?

EPA-recognized test kits Certified Renovators

X-Ray Fluorescence instruments (surface-by-surface)

Certified lead-based paint inspectors or risk assessors

Paint chip sampling and laboratory testing

Certified lead-based paint inspectors or risk assessors

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Using EPAUsing EPA--Recognized Test Kits Recognized Test Kits to Check for Leadto Check for Lead--BasBased Painted Paint

��Only use EPAOnly use EPA--recognized test kits on recognized test kits on substrates approved for the kit.substrates approved for the kit.

��Submit a testing report of results from use of Submit a testing report of results from use of an EPAan EPA--recognized test kit to the client as recognized test kit to the client as soon as possible, but no later than 30 days soon as possible, but no later than 30 days after completing the renovation.after completing the renovation.

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Test Kit HandsTest Kit Hands--onon

�� The purpose of this handsThe purpose of this hands--on exercise is to on exercise is to teach Certified Renovators how to correctly teach Certified Renovators how to correctly use EPAuse EPA--recognized test kits to determine if recognized test kits to determine if leadlead--based paint is present on components based paint is present on components and surfaces affected by renovation work.and surfaces affected by renovation work.

�� Review example testing documentation on Review example testing documentation on pages TSIpages TSI--46 and TSI46 and TSI--4747

�� Review example paint chip collection Review example paint chip collection documentation on TSIdocumentation on TSI--49 & TSI49 & TSI--5050

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Using Decision Logic ChartsUsing Decision Logic Charts

��Using the following pages, you will Using the following pages, you will practice use of the decision logic charts practice use of the decision logic charts found in the found in the Small Entity Compliance Small Entity Compliance Guide to Renovate Right. Guide to Renovate Right. (TSI(TSI--184)184)

��The decision logic charts will assist you in The decision logic charts will assist you in making decisions regarding how the EPA making decisions regarding how the EPA RRP Rule applies to your work. RRP Rule applies to your work.

��Determine if the property is FederallyDetermine if the property is Federally--assisted and if it is, then determine what assisted and if it is, then determine what to do next.to do next.

TSI – 51-59TSITSI


To properly plan a To properly plan a renovation, you must:renovation, you must:

��Educate owners and Educate owners and residents.residents.

��Determine if leadDetermine if lead--based based paint is present.paint is present.

��Determine what Determine what requirements from the EPA requirements from the EPA and HUD Rules apply to and HUD Rules apply to your renovation activities.your renovation activities.

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See Appendix 4 See Appendix 4 –– TSITSI--184184

TSITSI

Module 4: Contain Dust During WorkModule 4: Contain Dust During Work

Overview Overview

��What is containment?What is containment?

��Containing dust for interior activities.Containing dust for interior activities.

��Containing dust for exterior activities.Containing dust for exterior activities.

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What Is Containment?What Is Containment?

��“Containment” is a system of temporary “Containment” is a system of temporary barriers used to isolate a work area so that no barriers used to isolate a work area so that no dust or debris escapes while the renovation dust or debris escapes while the renovation is being performed.is being performed.

��Benefits of containment.Benefits of containment.

•• Protects residents and workers.Protects residents and workers.

•• Prevents spread of dust to rest of house/building Prevents spread of dust to rest of house/building or neighboring properties.or neighboring properties.

•• Easier cleaning at the end of the job.Easier cleaning at the end of the job.

��Containment is required. Containment is required.

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Keep Dust Within the ContainmentKeep Dust Within the Containment

��Consider how much dust the renovation will Consider how much dust the renovation will generate.generate.

��Containment design is a function of the work Containment design is a function of the work practices to be used and the expected amount practices to be used and the expected amount of dust to be generated during the renovation.of dust to be generated during the renovation.

��Plan the size and configuration of containment Plan the size and configuration of containment to keep the generated dust within to keep the generated dust within containment.containment.

��You are responsible for making sure dust You are responsible for making sure dust does not migrate out of containment.does not migrate out of containment.

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Vertical ContainmentVertical Containment

��Vertical barrier of plastic Vertical barrier of plastic sheeting over a rigid frame.sheeting over a rigid frame.

��Required for exterior jobs Required for exterior jobs close to property lines.close to property lines.

��Can be used to minimize the Can be used to minimize the floor or ground containment floor or ground containment neededneeded

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SAMPLE


Painting

Jul 11


Interior Containment: Limit Interior Containment: Limit Access and Post SignsAccess and Post Signs

��Notify residents to stay away Notify residents to stay away from the work area.from the work area.

��Do not allow residents or pets Do not allow residents or pets near the work area.near the work area.

��Do not allow eating, drinking, Do not allow eating, drinking, or smoking in the work area.or smoking in the work area.

��Post warning signs.Post warning signs.

WARNINGLEAD WORK AREALEAD WORK AREALEAD WORK AREALEAD WORK AREA

POISONPOISONPOISONPOISONNO SMOKING, EATING, OR

DRINKING

TSI - 66TSITSI

Insert illustration here

Interior Containment: Remove or Interior Containment: Remove or Cover BelongingsCover Belongings

�� RemoveRemove belongings.belongings.

�� Cover immovable Cover immovable objectsobjects in protective in protective sheeting, including:sheeting, including:

•• Furniture;Furniture;

•• Carpet; and,Carpet; and,

•• Lamps and other Lamps and other fixtures.fixtures.

�� Seal edges and seams.Seal edges and seams.

TSI - 67TSITSI

Interior Containment: Cover FloorsInterior Containment: Cover FloorsRequiredRequired::

�� Cover all work area floors with Cover all work area floors with plastic sheeting. plastic sheeting.

�� Cover floors a minimum of 6 feet Cover floors a minimum of 6 feet in all directions around the paint in all directions around the paint being disturbed. being disturbed.

�� RecommendedRecommended::

�� Lay plastic sheeting in high traffic Lay plastic sheeting in high traffic areas.areas.

�� Take special precautions for Take special precautions for carpets.carpets.

�� Use a disposable tack pad at the Use a disposable tack pad at the edge of protective sheeting. edge of protective sheeting.

�� If using chemical stripper, add 2nd If using chemical stripper, add 2nd plastic layer.plastic layer.

6’6’

TSI - 68TSITSI

Interior Containment: Close Interior Containment: Close Windows, Doors, HVACWindows, Doors, HVAC

Depending on what work is to be done:Depending on what work is to be done:

��Close all windows in the work area. Close all windows in the work area.

��Close and seal all doors in the work area.Close and seal all doors in the work area.

��Close and seal all HVAC vents in the work Close and seal all HVAC vents in the work area. area.

��Turn off the HVAC unit (recommended).Turn off the HVAC unit (recommended).

TSI - 69TSITSI

Interior Containment: Interior Containment: Work Area Work Area Entry DoorwayEntry Doorway

��Cover work area Cover work area entry doors with two entry doors with two layers of protective layers of protective sheeting.sheeting.

TSI - 70TSITSI

SAMPLE


Painting

Jul 11

TSI Rev. 1 -- July 2011 10

Overview of Interior Containment Overview of Interior Containment StepsSteps

The goal of these interior containment practices The goal of these interior containment practices is to prevent dust and debris from escaping the is to prevent dust and debris from escaping the work area.work area.

•• Limit access and post signs.Limit access and post signs.

•• Remove (preferred) or cover belongings. Remove (preferred) or cover belongings.

•• Cover floors.Cover floors.

•• Close and seal windows, doors and HVAC system.Close and seal windows, doors and HVAC system.

•• Construct a work area entry doorway.Construct a work area entry doorway.

TSI - 71TSITSI

Exterior Containment: Establish Exterior Containment: Establish the Work Areathe Work Area

��Cover the ground with Cover the ground with protective sheeting.protective sheeting.•• If space permits, extend a If space permits, extend a

minimum of 10 feet from the minimum of 10 feet from the work area.work area.

•• Pay special attention and Pay special attention and cover nearby vegetable cover nearby vegetable gardens and children's play gardens and children's play areas.areas.

��Limit access, place signs.Limit access, place signs.•• Establish a 20 foot perimeter Establish a 20 foot perimeter

around the work area if space around the work area if space permits.permits.

TSI - 72TSITSI

Exterior Containment: Exterior Containment: Close Windows Close Windows and Doorsand Doors

��Close all nearby doors Close all nearby doors and windows that are and windows that are within 20 feet of the within 20 feet of the work area.work area.

��Use two layers of plastic Use two layers of plastic sheeting on doors in the sheeting on doors in the work area that are work area that are being being used during the jobused during the job..

TSI - 73TSITSI

Exterior Containment: Things to Exterior Containment: Things to consider…consider…

�� Extending work area.Extending work area.

�� Avoid working in Avoid working in windy conditions, windy conditions, where possible.where possible.

�� More frequent More frequent cleanup of work cleanup of work area.area.

�� Repair any damage Repair any damage to containment to containment promptlypromptly

TSI - 74TSITSI

Overview of Exterior Containment Overview of Exterior Containment StepsSteps

��Establish the work area.Establish the work area.

��Close all windows and doors.Close all windows and doors.

��Establish, as necessary, additional. Establish, as necessary, additional. containment to prevent spread of dust to containment to prevent spread of dust to adjacent properties.adjacent properties.

��Erect Vertical Containment for any exterior Erect Vertical Containment for any exterior renovation within 10 feet of the property line.renovation within 10 feet of the property line.

TSI - 75TSITSI


��How to setup for a jobHow to setup for a job

•• Interior containmentInterior containment

•• Exterior containmentExterior containment

TSI - 86TSITSI

SAMPLE


Painting

Jul 11

TSI Rev. 1 -- July 2011 11

Module 5: During the WorkModule 5: During the Work

Overview:Overview:

��Traditional renovations create airborne dust.Traditional renovations create airborne dust.

��Prohibited practices.Prohibited practices.

��Protect yourself and make a personal Protect yourself and make a personal protective equipment toolkit.protective equipment toolkit.

��Control the spread of dust. Control the spread of dust.

��HandsHands--on exercise (Skill Set #6).on exercise (Skill Set #6).

TSI - 88TSITSI

Traditional Renovations Create Traditional Renovations Create Airborne Leaded DustAirborne Leaded Dust

0

100

200

300

400

500

600

Hand Sanding Power Sanding Interior Demolition

Traditional Work Practices

Mic

rog

ram

s/M

ete

r3

*

* OSHA Permissible Exposure Limit (PEL) = 50 µg/m3

TSI - 89TSITSI

Prohibited PracticesProhibited Practices

��OpenOpen--flame burning or flame burning or torching.torching.

��Heat gun above 1100º F.Heat gun above 1100º F.

��Power sanding, power Power sanding, power grinding, power planing, grinding, power planing, needle guns, abrasive needle guns, abrasive blasting and blasting and sandblasting, without sandblasting, without HEPA vacuum HEPA vacuum attachment.attachment.

TSI - 90TSITSI

Specialized ToolsSpecialized Tools

�� Large jobs may require Large jobs may require special considerations to get special considerations to get the job done, like:the job done, like:•• Power sanders, grinders and Power sanders, grinders and

planers, needle guns, and planers, needle guns, and abrasive and sand blasters, abrasive and sand blasters, each with required HEPAeach with required HEPA--filtered capture attachments.filtered capture attachments.

•• Pneumatic and battery powered Pneumatic and battery powered tools to protect against shock tools to protect against shock hazards.hazards.

•• Specialized planning and Specialized planning and containment.containment.

TSI - 91TSITSI

Protect YourselfProtect Yourself

�� Workers should wear:Workers should wear:•• Disposable painter’s hat.Disposable painter’s hat.

•• Disposable coveralls.Disposable coveralls.

–– Repair tears with duct tape.Repair tears with duct tape.

–– Dispose of in plastic bag.Dispose of in plastic bag.

•• Disposable NDisposable N--100, R100, R--100 or P100 or P--100 100 respirator.respirator.

�� Wash face and hands frequently and Wash face and hands frequently and at the end of each shift.at the end of each shift.•• Washing helps to reduce handWashing helps to reduce hand--toto--mouth mouth

ingestion of leaded dust.ingestion of leaded dust.

�� OSHA may require more protection OSHA may require more protection depending on what work is done.depending on what work is done.

TSI - 92TSITSI

Control the Spread of DustControl the Spread of Dust

�� When you leave the work site, clean yourself and your tools.When you leave the work site, clean yourself and your tools.•• Remove shoe coverings and HEPA vacuum or wipe shoes.Remove shoe coverings and HEPA vacuum or wipe shoes.•• Walk on disposable tack pads to remove dust from your soles.Walk on disposable tack pads to remove dust from your soles.•• HEPA vacuum and remove coveralls, and HEPA vacuum your HEPA vacuum and remove coveralls, and HEPA vacuum your

clothes.clothes.•• Remove gloves if used, and carefully wash your hands and face.Remove gloves if used, and carefully wash your hands and face.•• Dispose of all used disposable clothing in plastic bags.Dispose of all used disposable clothing in plastic bags.

�� At the end of the day don’t take lead home to your family on your At the end of the day don’t take lead home to your family on your clothes or in your car.clothes or in your car.•• HEPA vacuum clothes, shoes, etc.HEPA vacuum clothes, shoes, etc.•• Change your clothes, and dispose of or place dusty work cloths Change your clothes, and dispose of or place dusty work cloths

in a plastic bag to wash separately from household laundry.in a plastic bag to wash separately from household laundry.Don’t hug your family until you get clean!Don’t hug your family until you get clean!

•• Wash your hands and face.Wash your hands and face.•• Shower as soon as you get home.Shower as soon as you get home.

TSI - 93TSITSI

SAMPLE


Painting

Jul 11

TSI Rev. 1 -- July 2011 12

Cleaning During the JobCleaning During the Job

��A clean work site reduces the spread of dust A clean work site reduces the spread of dust and paint chips.and paint chips.

��Clean as you work.Clean as you work.•• HEPA vacuum horizontal surfaces.HEPA vacuum horizontal surfaces.

•• Remove debris frequently.Remove debris frequently.

•• Remove paint chips as they are created.Remove paint chips as they are created.

•• As building components are removed, wrap and As building components are removed, wrap and dispose of them immediately.dispose of them immediately.

��Clean frequently (in stages, at least daily).Clean frequently (in stages, at least daily).

TSI - 94TSITSI


��What work practices produce dust.What work practices produce dust.

��What work practices are prohibited by EPA What work practices are prohibited by EPA and HUD.and HUD.

��How to work safely around leadHow to work safely around lead--based paint based paint and leaded dust.and leaded dust.

��Proper use of personal protective equipment.Proper use of personal protective equipment.

TSI - 98TSITSI

Module 6: Cleaning Activities and Module 6: Cleaning Activities and Checking Your WorkChecking Your Work

OverviewOverview��What is effective cleanup?What is effective cleanup?

�� Interior cleaning techniques.Interior cleaning techniques.

��Exterior cleaning techniques.Exterior cleaning techniques.

��How to check your work.How to check your work.

��Cleaning verification procedure.Cleaning verification procedure.

��Clearance testing.Clearance testing.

��Safe disposal practices.Safe disposal practices.

TSI - 100TSITSI

What is Effective Cleanup?What is Effective Cleanup?

��Keeping dust from getting back into areas Keeping dust from getting back into areas already cleaned.already cleaned.

��Using proper cleaning techniques.Using proper cleaning techniques.

��Cleaning all surfaces, tools and clothing.Cleaning all surfaces, tools and clothing.

��Checking your work. Checking your work. •• Usually will involve performing cleaning Usually will involve performing cleaning

verificationverification..

•• Could include a clearance examination.Could include a clearance examination.

��Safe and secure disposal of waste.Safe and secure disposal of waste.

TSI - 101TSITSI

Interior Cleaning Interior Cleaning RequirementsRequirements

��Collect all paint chips and debris, and seal in heavy duty plastic bags.Collect all paint chips and debris, and seal in heavy duty plastic bags.

��Mist, remove, fold (dirty side in) and tape or seal protective sheeting. Mist, remove, fold (dirty side in) and tape or seal protective sheeting. Dispose of sheeting as waste. Dispose of sheeting as waste.

��Plastic sheeting between nonPlastic sheeting between non--contaminated rooms and work areas contaminated rooms and work areas must remain in place until after cleaning and removal of other must remain in place until after cleaning and removal of other sheeting.sheeting.

��HEPA vacuum or wet wipe walls from high to low, then HEPA vacuum HEPA vacuum or wet wipe walls from high to low, then HEPA vacuum remaining surfaces and wipe with a damp cloth.remaining surfaces and wipe with a damp cloth.

��Clean 2 feet beyond the contained work area.Clean 2 feet beyond the contained work area.

��Use disposable wipes or change cloths frequently.Use disposable wipes or change cloths frequently.

��For carpet or rug, use HEPA vacuum with beater bar.For carpet or rug, use HEPA vacuum with beater bar.

��HEPA vacuum and wet mop uncarpeted floors HEPA vacuum and wet mop uncarpeted floors -- twotwo--bucket mopping bucket mopping method or wet mopping system.method or wet mopping system.

TSI - 102TSITSI

Visual Inspection ProcedureVisual Inspection Procedure

1.1. Conducted by Certified Renovator.Conducted by Certified Renovator.2.2. Put on disposable foot covers before entering the work area.Put on disposable foot covers before entering the work area.3.3. Make sure there is adequate lighting in the work area. Make sure there is adequate lighting in the work area.

•• TurnTurn--on all of the lights or use a bright, whiteon all of the lights or use a bright, white--light light flashlight.flashlight.

4.4. Systematically look for dust and debris on every horizontal Systematically look for dust and debris on every horizontal surface in the work area and 2 feet beyond.surface in the work area and 2 feet beyond.•• Work from the farthest area from the entry to the entry.Work from the farthest area from the entry to the entry.•• Closely examine each surface. Closely examine each surface.

5.5. If you find visible dust or debris, then reIf you find visible dust or debris, then re--clean the work area clean the work area and repeat step 4.and repeat step 4.

6.6. Once you have carefully looked at all of the surfaces and Once you have carefully looked at all of the surfaces and found no dust or debris, proceed to the cleaning verification found no dust or debris, proceed to the cleaning verification procedure or clearance.procedure or clearance.

TSI -103TSITSI

SAMPLE


Painting

Jul 11

TSI Rev. 1 -- July 2011 13

Cleaning Verification (CV) Cleaning Verification (CV) ProcedureProcedure

��Wipe each window sill within the work area. Use a single wet Wipe each window sill within the work area. Use a single wet disposable cleaning cloth per window sill.disposable cleaning cloth per window sill.

��Wipe uncarpeted floors and all countertops with wet disposable Wipe uncarpeted floors and all countertops with wet disposable cleaning cloths. Wipe up to a maximum of 40 ftcleaning cloths. Wipe up to a maximum of 40 ft22 per cloth. per cloth.

��Compare each wipe to the CV card. If the cloth matches or is lighter Compare each wipe to the CV card. If the cloth matches or is lighter than the CV card, the surface has passed cleaning verification and than the CV card, the surface has passed cleaning verification and no further action is required. no further action is required.

��If the cloth is darker than the CV card, reIf the cloth is darker than the CV card, re--clean and repeat the CV clean and repeat the CV process.process.

��If the second wet cloth fails, wait 1 hour or until surfaces are dry, If the second wet cloth fails, wait 1 hour or until surfaces are dry, and then wipe with an electrostaticallyand then wipe with an electrostatically--charged white disposable charged white disposable cleaning cloth designed to be used for cleaning hard surfacescleaning cloth designed to be used for cleaning hard surfaces. This . This completes the cleaning verification.completes the cleaning verification.

TSI - 104TSITSI

Dust Clearance ExaminationDust Clearance Examination

A dust clearance examination may be performed A dust clearance examination may be performed instead of cleaning verification.instead of cleaning verification.

•• A clearance examination must be a conducted A clearance examination must be a conducted by a Certified Lead Inspector, Risk Assessor, by a Certified Lead Inspector, Risk Assessor, or Dust Sampling Technician.or Dust Sampling Technician.

•• If clearance fails, the renovation firm must reIf clearance fails, the renovation firm must re--clean the work area until dust standards clean the work area until dust standards comply with applicable state, territorial, tribal comply with applicable state, territorial, tribal and local standards. and local standards.

TSI - 105TSITSI

Exterior Cleanup RequirementsExterior Cleanup Requirements

��Clean all surfaces in the work area until no visible Clean all surfaces in the work area until no visible dust, debris, or residue remains.dust, debris, or residue remains.

��Remove all dust and debris without dispersal, and Remove all dust and debris without dispersal, and seal in heavy plastic bags.seal in heavy plastic bags.

��Remove protective plastic sheeting and mist before Remove protective plastic sheeting and mist before folding it dirty side inward. folding it dirty side inward.

��Check your work.Check your work.

•• Focus on areas such as window sills, bare soil, and Focus on areas such as window sills, bare soil, and children’s play areas.children’s play areas.

•• Look for dust, debris and paint chips.Look for dust, debris and paint chips.

TSI - 106TSITSI

Exterior Exterior –– Check Effectiveness of Check Effectiveness of CleaningCleaning

�� Visual inspectionVisual inspection

•• A Certified Renovator conducts a visual inspection after A Certified Renovator conducts a visual inspection after any cleaning.any cleaning.

•• Determines if any visible dust and debris are present in Determines if any visible dust and debris are present in and beyond the boundaries of the work area.and beyond the boundaries of the work area.

�� If visible dust or debris are found, collect and dispose of all If visible dust or debris are found, collect and dispose of all paint chips, dust, and debris identified during the visual paint chips, dust, and debris identified during the visual inspection. inspection.

�� After reAfter re--cleaning, the Certified Renovator conducts another cleaning, the Certified Renovator conducts another visual inspection.visual inspection.

�� When all areas pass, warning signs may be removedWhen all areas pass, warning signs may be removed..

TSI - 108TSITSI

DisposalDisposal

��What should I do with my waste?What should I do with my waste?

��At the work site:At the work site:•• Place waste in heavy duty plastic bag.Place waste in heavy duty plastic bag.

•• “Gooseneck seal” the bag with duct “Gooseneck seal” the bag with duct tape.tape.

•• Carefully dispose of waste in Carefully dispose of waste in accordance with Federal and other accordance with Federal and other regulations.regulations.

•• HEPA vacuum the exterior of the HEPA vacuum the exterior of the waste bag before removing it from the waste bag before removing it from the work area. work area.

•• Store waste in a secure area.Store waste in a secure area.

TSI - 107TSITSI

Disposal Disposal –– Federal, State and Federal, State and Local InformationLocal Information

��According to Federal law:According to Federal law:

•• In housing: Waste must be disposed of as normal In housing: Waste must be disposed of as normal household waste.household waste.

•• In nonIn non--residential childresidential child--occupied facilities: If waste occupied facilities: If waste exceeds 220 lbs, treat all debris as hazardous.exceeds 220 lbs, treat all debris as hazardous.

��Always check local requirements!Always check local requirements!

TSI - 109TSITSI

SAMPLE


Painting

Jul 11

TSI Rev. 1 -- July 2011 14


��How to clean the work area systematically.How to clean the work area systematically.

��How to check the effectiveness of cleaning.How to check the effectiveness of cleaning.

��How to perform a visual inspection of the work How to perform a visual inspection of the work area. area.

��How to perform the cleaning verification How to perform the cleaning verification procedure.procedure.

��How to release the work area for clearance How to release the work area for clearance testing.testing.

��How to properly dispose of waste.How to properly dispose of waste.

TSI - 122TSITSI

Module 7: RecordkeepingModule 7: Recordkeeping

Overview:Overview:

��In this section, you will In this section, you will learn about records learn about records required for each job.required for each job.

��Records must be Records must be retained and made retained and made available to EPA, upon available to EPA, upon request, for 3 years request, for 3 years following completion of following completion of renovation.renovation.

TSI - 124TSITSI

OnOn--TheThe--Job RecordsJob Records

�� Copies of Certified Firm and Certified Renovator Copies of Certified Firm and Certified Renovator certifications (must be kept on site).certifications (must be kept on site).

�� LeadLead--based paint testing results when an EPAbased paint testing results when an EPA--recognized test kit is used.recognized test kit is used.

�� Proof of owner/occupant preProof of owner/occupant pre--renovation education.renovation education.

�� Opt out certification by owner/occupant, when they Opt out certification by owner/occupant, when they qualify to and decide to opt out of the leadqualify to and decide to opt out of the lead--safe work safe work practice requirements.practice requirements.

�� NonNon--certified worker training documentation (must be certified worker training documentation (must be kept on site).kept on site).

TSI - 125TSITSI

Recordkeeping: PreRecordkeeping: Pre--Renovation Renovation Education RecordsEducation Records

In Target Housing In Target Housing –– Individual units:Individual units:•• Must acquire either written proof of receipt by an adult occupant Must acquire either written proof of receipt by an adult occupant

or proof of delivery/unsuccessful delivery of or proof of delivery/unsuccessful delivery of Renovate Right, Renovate Right, oror::•• Written proof of receipt of Written proof of receipt of Renovate RightRenovate Right by owner or proof of by owner or proof of

mailing (if mailing, send 7 days prior to renovation).mailing (if mailing, send 7 days prior to renovation).In Target Housing In Target Housing -- Common Areas (Two Options):Common Areas (Two Options):•• Provide written notification to each affected unit and make Provide written notification to each affected unit and make

Renovate RightRenovate Right pamphlet available on request; pamphlet available on request; oror::•• Keep copies or pictures of the signs and notices posted.Keep copies or pictures of the signs and notices posted.

In ChildIn Child--Occupied FacilitiesOccupied Facilities•• Written proof of receipt of Written proof of receipt of Renovate RightRenovate Right by owner or proof of by owner or proof of

mailing required (If mailing, send 7 days prior to renovation).mailing required (If mailing, send 7 days prior to renovation).•• Maintain proof of receipt by owner or adult representative, or Maintain proof of receipt by owner or adult representative, or

certify in writing that the certify in writing that the Renovate RightRenovate Right pamphlet has been pamphlet has been delivered to facility.delivered to facility.

•• Keep copies or pictures of the signs and notices Keep copies or pictures of the signs and notices posted.posted.

TSI - 126TSITSI

Sample Confirmation of Receipt of Sample Confirmation of Receipt of Renovate RightRenovate Right

�� I have received a copy of the pamphlet, I have received a copy of the pamphlet, Renovate Right: Important Renovate Right: Important Lead Hazard Information for Families, Child Care Providers and Lead Hazard Information for Families, Child Care Providers and Schools.Schools.

Recipient Signature:__________ Printed Name: __________ Date:__/__/__Recipient Signature:__________ Printed Name: __________ Date:__/__/__

SelfSelf--Certification Option (for tenantCertification Option (for tenant--occupied dwellings only)occupied dwellings only) -- If the lead If the lead pamphlet was delivered but a tenant signature was not obtainable, you may check pamphlet was delivered but a tenant signature was not obtainable, you may check the appropriate box below.the appropriate box below.

�� Refusal to sign. Refusal to sign.

�� Unavailable for signature.Unavailable for signature.

Gather the following information:Gather the following information:�� Printed name and signature of person Printed name and signature of person

certifying lead pamphlet delivery. certifying lead pamphlet delivery. �� Date and time of lead pamphlet delivery. Date and time of lead pamphlet delivery. �� Unit address. Unit address.

TSI – 128 - 129TSITSI

Recordkeeping: NonRecordkeeping: Non--Certified Worker Certified Worker TrainingTraining

��Worker’s name.Worker’s name.

��Description of lead safe work practices the Description of lead safe work practices the worker is trained to perform.worker is trained to perform.

��Completed and signed skills evaluation Completed and signed skills evaluation checklists. checklists.

��Date(s) of training.Date(s) of training.

��Name and signature of the Certified Renovator Name and signature of the Certified Renovator who conducted the training.who conducted the training.

TSI – 130TSITSI

SAMPLE


Painting

Jul 11

TSI Rev. 1 -- July 2011 15

Recordkeeping: Test Kit ReportingRecordkeeping: Test Kit Reporting

If an EPAIf an EPA--recognized test kit is used to test recognized test kit is used to test surfaces in the work area, the firm must:surfaces in the work area, the firm must:

•• Submit a report to the person contracting for the work Submit a report to the person contracting for the work within 30 days after the end of the renovation, within 30 days after the end of the renovation, containing:containing:

–– Manufacturer and model of the EPAManufacturer and model of the EPA--recognized test kit.recognized test kit.

–– A description of A description of ofof the components tested.the components tested.

–– The location of components tested.The location of components tested.

–– Results of the testing.Results of the testing.

•• Retain a copy of the test kit Retain a copy of the test kit documentation form.documentation form.

TSI - 131TSITSI

Recordkeeping: Paint Chip Sample Recordkeeping: Paint Chip Sample

Results ReportingResults Reporting

Paint chip sampling records must be maintained Paint chip sampling records must be maintained similarly to test kit results similarly to test kit results

��Submit a report to the person contracting for Submit a report to the person contracting for the work within 30 days after the end of the the work within 30 days after the end of the renovation, containing:renovation, containing:–– A description and location of the components tested.A description and location of the components tested.

–– Dimensions of the area tested in cm and area in cmDimensions of the area tested in cm and area in cm22..

–– Laboratory analysis results.Laboratory analysis results.

•• Retain a copy of the lab results and client report.Retain a copy of the lab results and client report.

TSI - 132TSITSI

Recordkeeping: PostRecordkeeping: Post--Renovation Renovation ReportingReporting

�� Following a renovation, firms must document and Following a renovation, firms must document and share the following information:share the following information:•• Project information documenting compliance with renovation Project information documenting compliance with renovation

training and work practice requirements;training and work practice requirements;

•• If performed, documentation of dust clearance sampling;If performed, documentation of dust clearance sampling;

•• This information must be prepared, retained by the firm and This information must be prepared, retained by the firm and shared with owners and occupants of housing and child shared with owners and occupants of housing and child occupied facilitiesoccupied facilities..

•• SEE FORM ON PAGE TSISEE FORM ON PAGE TSI--134134

TSI – 133-134TSITSI


�� To have records available at the work site of: To have records available at the work site of:

•• Training of Certified Renovators and nonTraining of Certified Renovators and non--certified renovation certified renovation workers.workers.

•• Certifications for the Certified Firm and Certified Renovators.Certifications for the Certified Firm and Certified Renovators.

�� To retain all records for at least 3 years after completion of the To retain all records for at least 3 years after completion of the renovation.renovation.

�� To keep records of:To keep records of:

•• Training and certifications for all renovation personnel, and Training and certifications for all renovation personnel, and for certification of the firm.for certification of the firm.

•• Distribution of required information.Distribution of required information.

•• Communications with and certifications from owners and Communications with and certifications from owners and residents.residents.

•• Work activities in compliance to the Rule.Work activities in compliance to the Rule.

•• PostPost--renovation reports.renovation reports.

TSI - 135TSITSI

Module 8: Training NonModule 8: Training Non--Certified Certified Renovation WorkersRenovation Workers

Certified Renovators are Certified Renovators are responsible for teaching leadresponsible for teaching lead--safe safe work practices to nonwork practices to non--certified certified renovation workers.renovation workers.

TSI - 137TSITSI

Teaching Lead Safe Work Teaching Lead Safe Work Practices Means:Practices Means:

�� Training workers to properly use signs, dust barriers, Training workers to properly use signs, dust barriers, dust minimizing work practices, and dust cleanup dust minimizing work practices, and dust cleanup practices during the course of renovation, repair, and practices during the course of renovation, repair, and painting activities to prevent and/or reduce potentially painting activities to prevent and/or reduce potentially dangerous dustdangerous dust--lead contamination in the home. lead contamination in the home.

�� To effectively train workers you need to:To effectively train workers you need to:•• Know lead safety yourself.Know lead safety yourself.

•• Show students what you know.Show students what you know.

•• Review the shopping list in Review the shopping list in Steps to LEAD SAFE Renovation, Steps to LEAD SAFE Renovation,

Repair, and PaintingRepair, and Painting and have appropriate materials at hand.and have appropriate materials at hand.

TSI - 138TSITSI

SAMPLE


Painting

Jul 11

TSI Rev. 1 -- July 2011 16

The Role of the Certified The Role of the Certified RenovatorRenovator

Certified Renovators:Certified Renovators:

�� Perform lead safe work as described in the RRP Rule.Perform lead safe work as described in the RRP Rule.

�� Train all nonTrain all non--certified workers in lead safe practices.certified workers in lead safe practices.

�� Provide onsite and regular direction for all nonProvide onsite and regular direction for all non--certified workers during setup and cleanup.certified workers during setup and cleanup.

�� Are available by phone when not physically present at Are available by phone when not physically present at the work site during work.the work site during work.

�� Maintain onsite proof of certification as a Certified Maintain onsite proof of certification as a Certified Renovator and training records for all nonRenovator and training records for all non--certified certified renovation workers.renovation workers.

TSI - 139TSITSI

Role of Trained, NonRole of Trained, Non--Certified Certified Renovation WorkersRenovation Workers

�� Trained, nonTrained, non--certified renovation workers are persons, certified renovation workers are persons, working on renovation, repair and painting jobs who working on renovation, repair and painting jobs who have had onhave had on--thethe--job training or similar classroom job training or similar classroom training from a Certified Renovator to perform tasks in training from a Certified Renovator to perform tasks in conformance to the EPA RRP Rule.conformance to the EPA RRP Rule.

�� They must perform leadThey must perform lead--safe work practices as safe work practices as described in the RRP rule:described in the RRP rule:•• Protect the home by “setting up” the work area.Protect the home by “setting up” the work area.

•• Protect themselves.Protect themselves.

•• Perform renovation work safely.Perform renovation work safely.

–– Prohibited Practices must not be used.Prohibited Practices must not be used.–– Control dust and debris.Control dust and debris.

•• Clean the work area.Clean the work area.

TSI - 140TSITSI

Use the “Steps” GuideUse the “Steps” Guide

��Steps to LEAD SAFE Renovation, Steps to LEAD SAFE Renovation, Repair and PaintingRepair and Painting covers basic covers basic lead safe practices and can be used lead safe practices and can be used as a training guide outside of the as a training guide outside of the classroom in conjunction with onclassroom in conjunction with on--thethe--job demonstrations and handsjob demonstrations and hands--on training.on training.

�� It is strongly recommended that you It is strongly recommended that you use this guide as a basis for use this guide as a basis for training.training.

��See Appendix 5See Appendix 5

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Step 1: Determine If the Job Step 1: Determine If the Job Involves LeadInvolves Lead--Based PaintBased Paint

�� LeadLead--based paint (LBP) is found many older homes:based paint (LBP) is found many older homes:–– 19601960--1978 homes 1978 homes –– 1 in 4 have LBP. 1 in 4 have LBP.

–– 19401940--1960 homes 1960 homes –– 7 in 10 have LBP.7 in 10 have LBP.

–– PrePre--1940 homes 1940 homes –– 9 in 10 have LBP.9 in 10 have LBP.

�� Renovation, repair or painting that disturbs leadRenovation, repair or painting that disturbs lead--based paint can based paint can create significant leadcreate significant lead--based paint hazards in homes.based paint hazards in homes.

�� Just a little leadJust a little lead--based paint dust can poison kids, their parents based paint dust can poison kids, their parents and pets, and can cause problems for pregnant women and their and pets, and can cause problems for pregnant women and their unborn children.unborn children.

�� The Certified Renovator will determine if leadThe Certified Renovator will determine if lead--based paint is based paint is present on work surfaces.present on work surfaces.

�� If information about leadIf information about lead--based paint is not available for a prebased paint is not available for a pre--1978 1978 homes or a childhomes or a child--occupied facility,occupied facility, assume that leadassume that lead--based paint is based paint is present and use leadpresent and use lead--safe work practices.safe work practices.

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Step 2: Set It Up SafelyStep 2: Set It Up Safely

��Containment is used to keep dust IN the work Containment is used to keep dust IN the work area and nonarea and non--workers OUT!workers OUT!

��Signs and barriers are used to limit access.Signs and barriers are used to limit access.

�� Inside versus outside jobsInside versus outside jobs

•• Review all procedures and differences in setup.Review all procedures and differences in setup.

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Step 2: Set It Up Safely Step 2: Set It Up Safely ––ContinuedContinued

Review special setup for “dustier” jobs, Review special setup for “dustier” jobs, including:including:

•• Demolition.Demolition.

•• Opening up wall cavities.Opening up wall cavities.

•• Removing old drop ceilings. Removing old drop ceilings.

•• Paint scraping/dry hand sanding.Paint scraping/dry hand sanding.

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Step 3: Protect YourselfStep 3: Protect Yourself

�� Without the right personal protective equipment (PPE) Without the right personal protective equipment (PPE) workers can swallow and inhale lead from the job, and workers can swallow and inhale lead from the job, and can carry lead on their skin and work clothes home to can carry lead on their skin and work clothes home to their families.their families.

�� Review the “shopping list.”Review the “shopping list.”

�� Advise workers to: Advise workers to:

•• Protect eyes.Protect eyes.

•• Keep clothes clean or use disposable clothing.Keep clothes clean or use disposable clothing.

•• Wear a respirator. The appropriate respirator keeps Wear a respirator. The appropriate respirator keeps lead out of the lungs and stomach.lead out of the lungs and stomach.

•• WashWash--up each time they leave the work area and up each time they leave the work area and especially at the end of the day.especially at the end of the day.

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Step 4: Control the Spread of Step 4: Control the Spread of DustDust

��The goal is to control the spread of dust that The goal is to control the spread of dust that is created.is created.

��Review the “shopping list.”Review the “shopping list.”

��Use the right tools.Use the right tools.

��Disposable plastic drop cloths control the Disposable plastic drop cloths control the spread of dust and debris.spread of dust and debris.

��Avoid prohibited practices.Avoid prohibited practices.

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Step 5: Leave the Work Area Step 5: Leave the Work Area CleanClean

��The goal should be to leave the work area The goal should be to leave the work area completely free of dust and debris.completely free of dust and debris.

��Review the “shopping list.”Review the “shopping list.”

��Discuss daily cleaning procedures.Discuss daily cleaning procedures.

��Discuss end of job cleaning procedures.Discuss end of job cleaning procedures.

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Step 6: Control the WasteStep 6: Control the Waste

��Discuss the waste bagging procedure.Discuss the waste bagging procedure.

��Demonstrate folding a small section of plastic Demonstrate folding a small section of plastic with the dirty side turned in.with the dirty side turned in.

��Discuss temporary storage of waste.Discuss temporary storage of waste.

��Discuss how to deal with waste water Discuss how to deal with waste water appropriately.appropriately.

��Discuss waste disposal rules that apply to the Discuss waste disposal rules that apply to the specific job.specific job.

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Step 7: Cleaning Verification or Step 7: Cleaning Verification or Clearance TestingClearance Testing

��Cleaning verification will be performed by a Cleaning verification will be performed by a Certified Renovator after most renovations.Certified Renovator after most renovations.

��A clearance examination may be requested in A clearance examination may be requested in place of cleaning verification by the owner, place of cleaning verification by the owner, and is required in some cases.and is required in some cases.

��Discuss what happens when cleaning Discuss what happens when cleaning verification and/or clearance is not passed.verification and/or clearance is not passed.

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Training DocumentationTraining Documentation

��The Certified Renovator assigned to the job The Certified Renovator assigned to the job must maintain at the job site the following must maintain at the job site the following records for onrecords for on--thethe--job training :job training :•• Written certification of worker training:Written certification of worker training:

–– Must show which workers have what training;Must show which workers have what training;

–– Must list all training topics covered for each worker; and,Must list all training topics covered for each worker; and,

–– Must be signed by the Certified Renovator who did the Must be signed by the Certified Renovator who did the training.training.

•• All training documentation must be kept for 3 years following All training documentation must be kept for 3 years following completion of the renovation.completion of the renovation.

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��That Certified Renovators are responsible for That Certified Renovators are responsible for training nontraining non--certified renovation workers.certified renovation workers.

��The roles of Certified Renovators and trained, The roles of Certified Renovators and trained, nonnon--certified workers during conduct of a certified workers during conduct of a renovation.renovation.

��How to use How to use Steps to LEAD SAFE Renovation, Steps to LEAD SAFE Renovation, Repair and Painting Repair and Painting to train nonto train non--certified certified renovation workers.renovation workers.

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Close your books for the test…Close your books for the test…

SAMPLE

Documents

Lead Safety for Renovation, Repair, SAMPLE PPT.pdfTSITSI TSI - 16 Module 2: Regulations U.S. Environmental Protection Agency (EPA): • Established accredited training and certification