Chapter 11: Interim Controls, Guidelines for the Evaluation and

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Chapter 11: Interim Controls

CHAPTER 11: INTERIM CONTROLS

Step-by-Step Summary for Interim Control ................................................... 11–5

I. Principles of Interim Control ........................................................................ 11–7

A. Introduction ....................................................................................................... 11–7

B. When Interim Controls Are Appropriate and When They Are Not ............ 11–8

C. Determining the Scope of Interim Controls .................................................... 11–8

D. Preparing a Lead Hazard Control Plan for Multifamily Housing .................. 11–9

E. Combinations of Interim Controls and Abatement of CertainHazards ............................................................................................................. 11–10

F. Qualifications of Interim Control Contractors ............................................. 11–10

G. Cleanup and Clearance ................................................................................... 11–10

H. Education ......................................................................................................... 11–10

I. Maintenance, Monitoring, and Reevaluation ................................................ 11–11

J. Resident Protection During Control Activities ............................................ 11–11

K. Waste ................................................................................................................ 11–11

L. Statements of Lead-Based Paint Compliance ................................................ 11–11

M. Documentation ................................................................................................ 11–12

1. Risk Assessment and/or Inspection Report ................................................ 11–12

2. Lead Hazard Control Plan .......................................................................... 11–12

3. Clearance Examination Report .................................................................. 11–12

4. Reevaluation Reports .................................................................................. 11–12

5. Maintenance and Monitoring Log ............................................................. 11–12

6. Statement of Lead-Based Paint Compliance .............................................. 11–12

Step-by-Step Summary for Paint Film Stabilization ................................. 11–13

II. Paint Film Stabilization ................................................................................. 11–15

A. Typical Lead Coatings and Their Failures ..................................................... 11–15

1. Moisture ...................................................................................................... 11–15

2. Aging ........................................................................................................... 11–15

3. Mechanical Damage ................................................................................... 11–15

4. Chemical Incompatibility ........................................................................... 11–15

5. Poor Surface Preparation ............................................................................ 11–16

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B. Substrate Condition and Repairs ................................................................... 11–17

1. Building Envelope Leaks............................................................................. 11–17

2. Interior Repairs and Water ......................................................................... 11–17

3. Water Vapor Management.......................................................................... 11–18

4. Substrate Repairs......................................................................................... 11–18

C. General Paint Application Guidelines ........................................................... 11–18

1. Appropriate Conditions .............................................................................. 11–18

2. When Paint Film Stabilization Will Not Last Very Long .......................... 11–18

D. Worksite Preparation ...................................................................................... 11–19

E. Paint Removal Methods .................................................................................. 11–19

1. Wet Scraping .............................................................................................. 11–20

2. Wet Sanding ............................................................................................... 11–20

F. Surface Cleaning ............................................................................................. 11–20

1. Dust and Chips ........................................................................................... 11–20

2. Oils, Waxes, and Mold ................................................................................ 11–20

G. Priming ............................................................................................................. 11–20

1. Oil- and Alkyd-Based Primers .................................................................... 11–21

2. Waterborne Primers .................................................................................... 11–21

H. Topcoats ........................................................................................................... 11–21

I. Cleaning and Clearance .................................................................................. 11–22

J. Reevaluation and Monitoring of Lead-Based Paint Stabilization ............... 11–23

Step-by-Step Summary for Friction and Impact SurfaceTreatment .................................................................................................................. 11–25

III. Friction and Impact Surface Treatment .................................................. 11–27

A. Definition of Terms ......................................................................................... 11–27

1. Friction Surfaces ......................................................................................... 11–27

2. Impact Surfaces ........................................................................................... 11–27

B. Lead Hazard Control Measures ...................................................................... 11–27

1. Window Systems ......................................................................................... 11–27

2. Door Systems............................................................................................... 11–28

3. Stair Systems ............................................................................................... 11–29

4. Baseboards and Outside Wall Corners ........................................................ 11–29

5. Drawers and Cabinets ................................................................................. 11–30

6. Porches, Decks, and Interior Floors ............................................................ 11–30

C. Lead Hazard Control Measures Performed by Residents ............................. 11–32

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Step-by-Step Summary for Dust Removal and Control ........................... 11–33

IV. Dust Removal and Control .......................................................................... 11–35

A. Introduction ..................................................................................................... 11–35

1. Sources and Locations of Leaded Dust ....................................................... 11–35

2. Removing Leaded Dust From a Dwelling ................................................... 11–35

3. Creating Cleanable Surfaces and Determining Whether DustRemoval Alone Is Adequate ....................................................................... 11–37

4. Planning and Preparations .......................................................................... 11–38

5. Responsibilities of Owners .......................................................................... 11–39

6. Responsibilities of Contractors ................................................................... 11–39

B. Methods of Dust Removal .............................................................................. 11–39

1. Cleaning Hard Surfaces .............................................................................. 11–40

2. Removal or Cleaning of Carpets or Rugs ................................................... 11–42

3. Cleaning Upholstered Furniture ................................................................. 11–44

4. Forced Air Systems and Drop Ceilings ....................................................... 11–44

5. Resident Protection .................................................................................... 11–45

C. Followup to Dust Removal ............................................................................. 11–45

Step-by-Step Summary for Soil Interim Control ......................................... 11–47

V. Soil Interim Controls ...................................................................................... 11–49

A. Temporary and Permanent Soil Treatments .................................................. 11–49

B. Types of Interim Control Measures for Soil ................................................. 11–49

1. Altering Contaminated Soil ....................................................................... 11–49

2. Soil Surface Cover ...................................................................................... 11–49

3. Land Use Controls ...................................................................................... 11–51

4. Drainage and Dust Controls ....................................................................... 11–52

C. Controls To Minimize Migration of Soil Lead Into Dwellings ..................... 11–52

D. Monitoring and Reevaluating Soil Interim Controls .................................... 11–52

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Chapter 11: Interim ControlsStep-by-Step Summary

Interim Control: How To Do It1. Owners of properties in good condition may decide to proceed directly to interim control without a risk

assessment. This involves stabilizing any deteriorated paint (see Section II), on the assumption that all de-teriorated paint contains lead-based paint, thoroughly cleaning all surfaces (see Section IV), and coveringall bare soil (see Section V). These measures should be followed by a risk assessment (not a risk assessmentscreen) to determine if the property meets clearance standards and if any hazards were left uncorrected.All interim control activities should be carried out in accordance with the procedures describedin these Guidelines.

2. Alternatively, an owner may first have an independent risk assessment performed by a certified profes-sional to determine if lead-based paint hazards exist and to minimize hazard control activities.

3. Together with a certified risk assessor, planner, or other designer, develop a site-specific lead hazard controlplan based on the hazards identified, the feasibility of the control measures, occupant protection, and fi-nancing. For interim controls and some abatement techniques, the plan should include how and whenongoing monitoring by the owner and reevaluation by a certified risk assessor or certified inspector willbe performed. (See Chapter 6 for standard reevaluation schedules.)

4. For building components, determine which hazards will be addressed with interim controls (dust removal,paint stabilization, and/or control of friction/abrasion points). For lead-contaminated soil, decide whichinterim control measure is appropriate for the climate and the planned use of the area.

5. Develop specifications (if appropriate). The amount of detail provided should be commensurate with thesize of the job. The specifications should state how any abatement activities and other construction work(e.g., weatherization) will coincide with the interim control work. It may be preferable to combine interimcontrols with abatement in many cases.

6. Although interim controls are not expected to generate hazardous waste, the planner or risk assessorshould make this assessment for each project and notify local authorities if the local jurisdiction requiresit.

7. Select a qualified, trained contractor to complete the hazard control work. For some small jobs, onsitemaintenance workers may be able to perform the work. In either case, Occupational Safety and HealthAdministration (OSHA) regulations require all interim control workers to be trained.

8. Select the appropriate interior and/or exterior Worksite Preparation Level (from Chapter␣8) to protectresidents.

9. Notify residents of the dwelling and nearby dwellings of the work and when it will begin. Distributeeducational materials furnished by the U.S. Environmental Protection Agency (EPA) and/or the Stateor local government to residents about lead poisoning and lead-safe practices.

10. Correct any existing conditions that could undermine the success of the interim controls (e.g., structuraldeficiencies, moisture problems, uncleanable surfaces).

11. For exterior work, preinterim control soil samples should be collected but not necessarily analyzed untilclearance soil samples have been collected, analyzed, and compared to clearance standards. If soil levelsare below applicable limits, the baseline samples need not be analyzed (see Chapter 15).

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12. Execute interim control work. See the Step-by-Step Summaries in each section of this chapter for informa-tion about dust removal, paint film stabilization, friction and impact surface treatments, and interim soilcontrols.

13. Store all waste in a secure area and make sure that it is properly labeled (see Chapter 10). Dispose of allwaste properly.

14. Conduct daily and final cleanups (see Chapter 14).

15. Have an independent, certified inspector technician or risk assessor conduct a clearance examination 1 hourafter cleanup to let dust settle (see Chapter 15). If no preliminary risk assessment was performed, only a certi-fied risk assessor can conduct the clearance examination/risk assessment. If clearance is not achieved, com-plete interim controls and/or reclean. Following a successful clearance examination, the property ownershould receive documentation to that effect, including a schedule for required reevaluation (if applicable).Local authorities may also require a Statement of Lead-Based Paint Compliance.

16. Pay contractor and clearance examiner.

17. The owner should conduct ongoing maintenance and monitoring of interim controls to ensure that theyremain in place. Periodic reevaluations by a certified risk assessor should be completed according to thereevaluation schedule in the hazard control plan of the property.

18. Maintain records of all lead hazard control, reevaluation, and monitoring activities and turn them overto any new owner upon sale of the property.

Step-by-Step Summary (continued)

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Section I

I. Principles of InterimControl

A. Introduction

While interim controls have been carried outin some public housing developments underthe name of “in-place management,” the con-cept is relatively new in the field of lead hazardcontrol. Interim controls are intended to makedwellings lead-safe by temporarily controllinglead-based paint hazards, as opposed to abate-ment, which is intended to permanently con-trol lead hazards. See Chapter 12 for a moredetailed discussion of the difference betweenabatement and interim controls. In Title X ofthe Housing and Community DevelopmentAct of 1992, interim controls are defined as“. . . a set of measures designed to reduce tem-porarily human exposure or likely exposure tolead-based paint hazards, including specializedcleaning, repairs, maintenance, painting, tem-porary containment, ongoing monitoring oflead-based paint hazards or potential hazardsand the establishment and operation of man-agement and resident education programs.” In-terim control measures are fully effective onlyas long as they are carefully monitored, main-tained, and periodically professionally reevalu-ated. If interim controls are properly main-tained, they can be effective indefinitely. Aslong as surfaces are covered with lead-basedpaint, however, they constitute potentialhazards.

Basic elements include planning, implementa-tion of interim controls, cleanup and clearance,education of residents and maintenance staff,ongoing maintenance and monitoring by theowner, and periodic reevaluation by a certifiedprofessional. The term “certified professional”means a certified risk assessor or certifiedinspector.

Interim lead hazard control measures include:

✦ Repairing all rotted or defective substratesthat could lead to rapid paint deterioration(repairing defective building systems thatcause substrate damage may be a prerequisitefor effective interim control but is outsidethe scope of interim control per se).

✦ Paint film stabilization (see Section II)—stabilizing all deteriorated lead-based paintsurfaces by removing deteriorating paint andrepainting.

✦ Friction and impact surface treatments (seeSection III)—treating floors and interiorwindow sills and window troughs so thatthey are smooth and cleanable.

✦ Treating friction and impact surfaces, suchas windows, doors, stair treads, and floors,when they are generating lead-based paintchips or excessive levels of leaded dustthat cannot be controlled with ordinarycleaning.

✦ Treating protruding, accessible surfaces, suchas interior window sills, where lead-basedpaint may be present and there is either vi-sual or reported evidence that children aremouthing or chewing them.

✦ Treating all bare soil containing excessivelevels of lead.

✦ Dust removal and control (see SectionIV)—cleaning surfaces to reduce levels ofleaded dust to acceptable levels, includingcleaning carpets, if they are contaminated.

✦ Educating residents and maintenanceworkers on how to avoid lead poisoning.

✦ Conducting reevaluations by certified indi-viduals, ongoing monitoring by owners, andobservation by residents.

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After completion of lead hazard control mea-sures, an independent, certified inspector tech-nician or risk assessor should carry out a clear-ance examination, which includes a visualinspection to determine whether all necessarylead hazard control measures were completedand collecting dust samples to determinewhether floors, interior window sills, andwindow troughs meet clearance levels.

The property owner should implement an ac-tive maintenance regime to ensure that theproperty continues to be free of hazards. Such amaintenance regime should consider the likeli-hood that leaded dust may be tracked into thehousing unit from the outside. Periodic visualmonitoring and reevaluation according to asite-specific schedule prescribed in the risk as-sessment report should be carried out to deter-mine whether the dwelling unit continues tobe free of hazards.

B. When Interim Controls AreAppropriate and When TheyAre Not

Unless precluded by regulation, interim controlsare most easily implemented when most surfaceswith lead-based paint are intact and structurallysound and lead exposure comes primarily fromdeteriorating paint and excessive levels of leadin household dust and/or soil. Interim controlsare also appropriate if the housing unit is slatedfor demolition or renovation within a few years.In many cases resources will not be available tofinance permanent abatement, making interimcontrols the only feasible approach.

If the housing unit has substantial structuraldefects or if interior or exterior walls or majorcomponents, such as windows and porches, areseriously deteriorated or subject to excessivemoisture, interim controls are unlikely to bevery effective. Paint cannot be effectively stabi-lized unless substrates are dry, structurallysound, and waterproof. Other interim controlmeasures, such as window repair, would also notbe very effective if structural problems are likelyto result in rapid treatment failure. Any struc-tural problems should be repaired before interimcontrols can be implemented. If these problems

cannot be repaired, then more frequent reevalu-ation will be necessary in case of prematurefailure.

Federal, State, and local legislation or regula-tions may require that certain lead hazards bepermanently abated rather than controlled onan interim basis. For example, HUD requiresthat public housing authorities abate all lead-based paint in dwelling units undergoing com-prehensive modernization. Title X requires thatlead hazards be abated in the course of substan-tial rehabilitation projects that use more than$25,000 of Federal funds per dwelling unit.Some State and local governments haveenacted laws and regulations requiring thatcer-tain lead hazards be abated.

Whenever building components are replaced,energy-efficient products should be used. Thiswill help reduce energy consumption and alsoreduce the length of time it takes for new com-ponents (energy-efficient doors and windows)to pay for themselves.

C. Determining the Scope ofInterim Controls

The property owner may decide to rely on a riskassessor to determine whether interim controlsare appropriate, identify treatment options, andestimate the long-term costs of the variousavailable options. (See Chapter 5 for a discus-sion of risk assessments.) In some cases in whichHUD funding will be used, a risk assessment ora paint inspection will be required. Some Stateor local laws may also strongly recommendor even require a risk assessment before leadhazard controls can be carried out.

Unless prohibited by local law, the propertyowner may elect to proceed with lead hazardcontrol measures without a risk assessment ora paint inspection. When no evaluation is con-ducted, the property owner must assume thatall surfaces have lead-based paint, all floorsand dust traps are contaminated, and all baresoil is also contaminated. In this case, the prop-erty owner could waste money if surfaces aretreated that do not contain lead-based paint.When there is a substantial likelihood that

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some treatable surfaces do not contain lead-based paint, the cost of risk assessment may wellbe recovered by a more focused effort on con-firmed hazards.

Some State and local laws prescribe certaintreatments in order for the housing unit toqualify as lead-safe. Insurance companies orlenders may also prescribe certain treatmentsif a property is to qualify for insurance coverageor a loan. In all cases, the property ownershould ensure, at a minimum, that requiredlead hazard control measures are carried out.

Whenever a housing unit is to be weatherizedor rehabilitated, it is usually cost effective tocontrol lead hazards at the same time. Usually,normal weatherization or rehabilitation activi-ties can also eliminate some lead hazards if thework is modified so that it can be performedsafely. However, if not carried out properly,these efforts will increase the risk of lead poi-soning. In those situations, abatement is usuallythe most appropriate intervention since win-dows and other components are often replaced.It will usually be more expensive and disruptiveto carry out weatherization or rehabilitationand lead hazard control separately.

D. Preparing a Lead HazardControl Plan for MultifamilyHousing

Conducting interim controls of lead-based painthazards in multifamily housing presents issuesnot generally found in single-family housing. Inmost occupied multifamily developments, it isnot feasible, financially or logistically, to carryout hazard control activity in all dwelling unitsat once. In properties with a relatively smallnumber of dwelling units, it may be possible toproceed unit by unit and complete the hazardcontrol work quickly. In larger properties, how-ever, decisions must be made as to the order ofthe work in dwelling units and common areas,and perhaps, in rooms or components withindwelling units and common areas. Even whenan entire building is vacant and undergoingrenovation, hazard control elements of thework must be identified and scheduled. There-fore, it is usually advisable that there be a lead

hazard control plan for properties with morethan approximately 10 units.

Owners should have an independent certifiedrisk assessor prepare a lead hazard control planto address lead-based paint hazards identifiedby the risk assessment or, if no risk assessmenthas been conducted, the specific hazards thatare assumed to be present. The plan should pri-oritize and schedule control measures and anyadditional hazard evaluations so that availableresources are targeted for maximum benefit.Lead hazard control planners or designers mayalso be helpful in preparing such a plan. In de-veloping the plan, the risk assessor should con-sult with the property owner to gain insightsabout the property to determine which strate-gies will be most appropriate. The goal of thisconsultation is to combine in the plan the riskassessor’s knowledge of lead-based paint hazardswith the property owner/manager’s knowledgeof the particular property—its maintenancehistory, persistent problems, occupancy profile,capital improvement program, etc.

In developing a lead hazard control plan, it isreasonable to consider treating units occupiedby children under age 6 or pregnant womenfirst. Common play areas, day-care centers, ordwelling units serving as day-care centers mayalso be candidates for early treatment. It is rea-sonable to consider the fact that it is less expen-sive to conduct hazard controls effectively andsafely in vacant units than in occupied units;thus, it may be appropriate to postpone somehazard control treatments until unit turnover.It is reasonable to consider the possibility of re-locating families with young children from un-controlled units to hazard-controlled vacantunits in order to more quickly and cost effec-tively reduce childhood exposure to lead inthe environment.

At a minimum, a lead hazard control planshould include the following elements:

✦ A schedule for hazard control, usuallyin units with young children or pregnantwomen first, followed by other units. Theschedule should show how lead-based painthazards will eventually be controlled in allunits.

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✦ A commitment on the part of the ownerand manager to control lead-based painthazards that are generated during routinemaintenance work or normal building aging,what those controls consist of, and howthose controls will be implemented.

✦ Specific measures that will be taken duringunit turnover (often paint stabilization, spe-cialized dust removal, and perhaps the pro-vision of cleanable surfaces on floors, sills,and troughs and some minor building com-ponent replacement).

✦ A schedule for performing risk assessments,lead hazard control screens, and inspectionsand/or clearance examinations in all unitsor a representative sample of units.

✦ A schedule for hazard control actions tobe completed in common areas.

✦ A schedule for reevaluations and visualmonitoring by certified risk assessors andowners or their representatives, respectively.

✦ A description of how maintenance workersand other staff will be trained to handlelead-based paint hazards safely.

✦ Designation of an individual, preferablyon the staff of the owner or the propertymanager, who is responsible for mattersassociated with lead-based paint hazards.

E. Combinations of InterimControls and Abatement ofCertain Hazards

In many dwellings owners will choose a combi-nation of interim controls and abatement. Thisdecision is best made by consulting a certifiedrisk assessor. For example, it is possible to stabi-lize deteriorated lead-based paint and removeexcess levels of leaded dust (interim controls),but at the same time enclose some lead-basedpainted surfaces, replace some lead-basedpainted components, or remove lead-basedpaint from some surfaces (abatement). Suchcombinations of interim control and abate-ment treatments might well be the most cost-effective response to a property owner’s lead

hazard problem, particularly if carried out whenthe dwelling unit is vacant.

F. Qualifications of InterimControl Contractors

Title X does not require certification of contrac-tors who carry out interim controls. However,OSHA requires that all interim control workersbe trained under 29 CFR 1926.21(b)(2), evenif lead exposures are below the action level (seeChapter 9). Interim control activities frequentlydisturb lead-based paint and typically take placein areas with excessive levels of leaded dust.Therefore, while not required by EPA, it is rec-ommended that interim control workers andsupervisors, whether employed by the propertyowner or an independent contractor, be trained,preferably through an accredited abatementcourse.

G. Cleanup and Clearance

Section IV of this chapter describes how leadeddust can be removed as an interim control mea-sure. In some dwellings dust removal from a fewsurfaces may be sufficient. Chapter 14 describescleanup after abatement or a more comprehen-sive set of interim control measures. Whetherleaded dust is removed as the primary elementof interim control or as final cleanup after morecomprehensive control activity, the objective isthe same—providing residents with a clean andeasily cleanable unit.

Like abatement, interim controls are intendedto make a dwelling unit safe for children; there-fore, interim controls are subject to the sameclearance testing requirements and documenta-tion as abatement. Clearance examinationsmust always be conducted following interimcontrol work (Chapter 15 describes clearanceexaminations).

H. Education

While education of the residents, particularlythe children’s caregivers, is not in itself suffi-cient to prevent childhood lead poisoning, itcan assist residents in reducing the risk thattheir children will be seriously poisoned.

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Therefore, education is an important adjunctto any lead hazard control system.

The property owner is responsible for the con-dition of the dwelling unit and for advising oc-cupants to report any deteriorating paint. Theowner should also distribute to the occupantsany educational materials furnished by theState or local government or by a local lead-poisoning prevention organization.

The educational materials should advise oc-cupants of all the potential sources of lead poi-soning. This includes lead-based paint, lead-contaminated dust and soil, and also lead inwater, pottery glazes, glass, some imported cos-metics, and home remedies. Materials shouldsuggest simple preventive measures, such aswashing children’s hands before eating and afterplay, and washing toys. Children’s nutrition isalso important. Foods high in iron and calciumreduce absorption of lead into children’s bodieswhile fatty foods increase the rate of absorp-tion. The EPA Lead Hazard Information Pam-phlet is a useful resource that can be obtainedby calling 1–800–LEAD–FYI. Property owners,managing partners, and remodelers should alsoobtain these educational materials.

I. Maintenance, Monitoring,and Reevaluation

See Chapter 6 for a complete discussion of re-evaluation and Chapter 17 for information onmaintenance. The success of interim controlmeasures depends not only on the adequacy oftheir initial application, but also on whetherthey remain effective over time. To remain ef-fective they must be maintained and monitored.Property owners or their agents should routinely(e.g., annually) visit the property and visuallyensure that interim controls remain in place.They should also respond promptly wheneveran occupant reports any deteriorating paint.Any failure of interim controls that is identifiedshould be corrected promptly.

An important component of maintenance isensuring that leaded dust levels remain belowacceptable levels. This can best be achievedthrough regular cleaning of areas where leadeddust is likely to accumulate. Property owners

should, therefore, undertake thorough cleaningof the unit upon vacancy if, during ongoingmonitoring, they find that excessive levelsof leaded dust have accumulated.

To ensure a reasonably lead-safe environmentfor young children, dwelling units that continueto contain lead-based paint and potential leadhazards should be reevaluated by a certified in-spector or risk assessor. The schedule should bedeveloped on a site-specific basis.

J. Resident Protection DuringControl Activities

Any activity that disturbs lead-based paintcan generate leaded dust. While interim con-trol activities are less likely to generate leadeddust than abatement activities, any scrapingor sanding without high-efficiency particulateair (HEPA) attachments can generate danger-ous levels of dust. Whenever dust-generatingactivities are carried out, residents and par-ticularly young children should stay out ofthe rooms (preferably the entire house) andshould not return until all dust and debrisare removed and the dwelling unit has beenthoroughly cleaned (see Chapter 8).

K. Waste

Most interim control activities are not ex-pected to generate hazardous waste since in-terim controls will generate less than 100 kilo-grams of lead per month, exempting them fromhazardous waste regulations. See Chapter 10(Hazardous and Nonhazardous Waste) forfurther guidance.

L. Statements of Lead-BasedPaint Compliance

State or local governments may require in-spectors or risk assessors who carry out clear-ance examinations to provide a Statement ofLead-Based Paint Compliance. The Statementwould provide evidence that described interimcontrols have been completed and that leadeddust levels are at or below applicable standards.Insurance companies and lenders could relyon the Statement in framing their under-writing criteria. Such a system would provide

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an inducement for property owners to con-trol lead hazards and give them hard proof ofcompliance.

The Statement of Lead-Based Paint Compli-ance would be valid for a limited period of timebased on the standard reevaluation schedule forthe property. The Statement could be extendedwhen a reevaluation demonstrates that the con-ditions of lead safety continue to be met. SomeStates may limit the number of recertifications.Others may permit recertification until someevent such as substantial rehabilitation takesplace. Insurance companies or lenders mayimpose their own requirements.

M. Documentation

Lead hazard evaluation, lead hazard control,and maintenance and monitoring activitiesassociated with interim controls should bedocumented. Several specific documents areof particular importance. These include:

1. Risk Assessment and/or Inspection Report.This document records the findings of any riskassessment or inspection, including any inspec-tion of painted surfaces and the collection andanalysis of samples for determination of the leadcontent in dust, soil, and/or water. A risk assess-ment that finds no lead-based paint hazardswould also justify issuance of a certificate.

2. Lead Hazard Control Plan. This documentexplains the schedule of hazard control actionsin multifamily housing (see section I.D. of thischapter).

3. Clearance Examination Report. Thisdocument records the basis for clearance ofthe property so that it is ready for occupancy(see Chapter 15).

4. Reevaluation Reports. These reports indi-cate that the hazard control measures are stillin satisfactory condition and that the dwellingis still in a lead-safe condition. Reevaluationsare performed on a schedule discussed inChapter 6.

5. Maintenance and Monitoring Log. Thislog records the results of the property owner’sor property manager’s monitoring visits. Anyrepairs made as a result of these visits or no-tices of defects from occupants should also berecorded.

6. Statement of Lead-Based Paint Compliance.This document states that on a particular datethe inspector or risk assessor confirmed throughan onsite investigation that the dwelling metapplicable requirements. The Statement ofLead-Based Paint Compliance is issued to theproperty owner, with copies provided to theresidents and to the State or local code enforce-ment authority, if required under State or locallaw or regulation. The Statement of Lead-BasedPaint Compliance is valid for a limited periodof time based on the site-specific reevaluationschedule contained in the risk assessmentreport.

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Paint Film Stabilization: How To Do It1. Eliminate any exterior leaks in the building envelope (e.g., roofing leaks, gutter or downspout problems,

missing or damaged doors, roof flashing, missing opening trim, missing glass in windows, defective or missingcaulk and glazing, loose fasteners).

2. Eliminate any interior water leaks (e.g., plumbing leaks; clogged condensate drip lines for air conditioners;missing water pans for hot water heaters; inadequately ventilated attic spaces; clogged bathtub drains;missing tile, grout, or caulking in bathtubs; windows that won’t close completely).

3. Select and implement an appropriate Worksite Preparation Level (see Chapter 8).

4. For exterior work, collect soil samples before the work begins (unless soil sampling has already been com-pleted for a risk assessment). These samples need not be analyzed unless clearance samples show soil leadlevels are above applicable clearance standards.

5. Repair all rotted structural, siding, or railing components; defective plaster; missing door hardware; loosesiding or trim; and loose wallpaper.

6. Prepare surface by wet scraping or wet sanding. Do not remove paint by burning or torching, power sandingwithout HEPA attachments, or abrasive blasting. Dry scraping and chemical strippers with methylene chlo-ride are not recommended.

7. Clean, degloss, neutralize, and rinse surfaces. Surfaces should be dry before priming or repainting.

8. Select primer and topcoat by considering longevity, moisture resistance, and organic compound contentwith low volatility. Paint film stabilization involves the application of at least two coats (the primer andthe topcoat). Use a primer/topcoat system from the same manufacturer to ensure compatibility.

9. Apply all paints at appropriate thickness (see Table 11.1) or according to manufacturer’s directions. Applypaint only during proper temperature, wind, and humidity conditions. Allow sufficient time for each coatto dry fully.

10. Conduct final cleanup (see Chapter 14).

11. At the end of the lead hazard control project, have a certified inspector technician or risk assessor con-duct a clearance examination and provide appropriate documentation or statements of lead-based paintcompliance.

12. Conduct reevaluations annually as indicated in the site-specific schedule (Table 6.1). Perform ongoingmaintenance of paint and restabilize paint whenever deterioration is discovered.

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Section II

II. Paint Film Stabilization

A. Typical Lead Coatings andTheir Failures

The lead in lead-based paint may be found aswhite pigments (lead carbonate, sulfate, or sili-cate), or colored pigments (chrome yellow, redlead, gray, and other orange, green, and red pig-ments). These pigments were mixed with othercomponents in an oil vehicle, and traditionallythinned with volatile organic solvents and adrying agent. Driers containing lead were usedto accelerate the conversion of the liquid coat-ing to a dry film. Paint films can fail ratherquickly under real-life conditions, makingongoing monitoring important. Paint filmsshould be quickly but carefully stabilizedwhenever a resident or owner reports thatpaint is deteriorating.

1. MoistureOil paints (virtually all lead-based paints areoil paints) form a hard, usually glossy, low-permeable and inflexible coating. Water,either in the form of water vapor or liquid, isthe single greatest cause of premature paintcoating failures. Once a substrate gets wet, theimpermeable paint coating is pushed away fromthe substrate due to vapor formed by heat fromthe sun or other sources. Repeated soaking/warming cycles result in microscopic failureof the paint and then an accelerated failure asmore and more openings become available, al-lowing the substrate to become increasinglywet. Expansion and contraction caused by smallice crystals during the wet winter months alsocause paint deterioration.

A significant number of homes are poorly con-structed, ventilated, or maintained, and allowmoisture to be trapped. The 26 main causesof premature paint failure from moisture aredescribed in Figure␣11.1.

2. AgingAll binders age and some cure over time. Thiscontinued curing causes the paint to becometoo brittle to accommodate the normal expan-sion and contraction of the substrate, resultingin cracking and peeling. Exterior paints are alsoattacked by sunlight, which can cause chalking.These slow aging processes mean that even awell-managed and protected surface will dete-riorate eventually.

3. Mechanical DamageThe two basic kinds of mechanical damage(abrasion and impact) can be minimizedonly by careful management. Paints exhibittremendous variability in hardness, impactresistance, and abrasion resistance. High-performance coatings (e.g., polyamide epoxy,urethane-reinforced alkyds, and epoxy-modified enamels) can withstand over 10,000more scrubbing cycles than inexpensive flatvinyl paints (Banov, 1978), although some ofthese paints may not be appropriate for resi-dential use. Failure from impact or friction isoften accelerated by the selection of a low-performance coating.

4. Chemical IncompatibilitySince oil and water do not mix, oil paints ap-plied over wet substrates will not adhere. Thefailure may occur within a week, and may causethe paint film to be pulled directly from thesubstrate. Although oil paints stick relativelywell on surfaces slightly contaminated with or-ganic material, dirt, and oil, they do not adherewell to fatty or heavily greased surfaces.

Most latex paints do not adhere to chalky orsmooth and glossy paint films. Epoxies will failprematurely when applied over latex coatingsand some oil coatings. Some chemical-basedstrippers contain such large amounts of wax andother stabilizers that almost no subsequent coat-ing will maintain good adhesion. If the substratehas been stripped with a caustic paste and notneutralized properly, the highly alkaline pH will

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cause deterioration of the subsequent paint. Onthe exterior, salts may build up on the surfaceof paint films in eaves and soffits and preventpaint adhesion. These salts must be removedwith water to allow good adhesion.

Portland cement and older plaster substrates areextremely alkaline and should be aged or etchedwith mild acid solutions prior to spot sealingwith a primer.

125 224

23

222120

26

19

18

17

16

15

14

1312 11

10 9 87

6

5

4

3

Fig 11.1

(1) siding exceeds 14-percent water content; (2) no cricket where chimney meets roof; (3) no step flashing atside of chimney; (4) corner rim not caulked; (5) exposed nailheads rusting; (6) no window wash at windowsill; (7) wood contacts earth; (8) no drip or gutter at eaves; (9) poorly fitted window and door trims; (10) water-proof paper not installed behind trim; (11) damp, wet cellar unventilated at opposite sides; (12) no ventilationof unexcavated space; (13) no blocking between unexcavated space and stud wall space; (14) no water-proofing or drainage tile around cellar walls; (15) no foundation water and termite sill; (16) plaster not dryenough to paint; (17) sheathing paper that is not waterproof; (18) vapor barrier omitted—needed for presentor future insulation; (19) roof built during wet, rainy season without taking due precaution or ventilating on drydays; (20) roof leaks; (21) inadequate flashing at breaks, corners, roof; (22) poorly matched joints; (23) nochimney cap; (24) no flashing over openings; (25) full of openings, loosely built; (26) no or inadequate venti-lation of attic space.

5. Poor Surface PreparationA 100-year-old house, repainted every 8 years,may have at least 12 coats of paint. If surfacepreparation for only one of those coats was in-sufficient, localized failures will occur. Becauseof the slow erosion of the binder in exteriorpaints, chalking can cause poor adhesion ofnew coatings. Chalk must be removed and

Figure 11.1 Moisture-Related Causes of Paint Failure.

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appropriate primers applied to prevent subse-quent failures. Surfaces must be free from oil,grease, and dirt. Paint stripper residue must beremoved, either with solvents or alkali cleanerssuch as trisodium phosphate. Hard, glossy oilfilms require deglossing to allow waterbornecoatings to adhere properly.

B. Substrate Condition andRepairs

1. Building Envelope LeaksThe quality and endurance of a paint coating isdependent on the quality of the substrate overwhich it is applied. The substrate must be dry,structurally sound, and waterproof. Roofingleaks, including porches, gutters, and down-spouts, must be fully repaired prior to stabilizingthe lead-based paint film. Temporary roofingrepairs like asphalt patching material, piecing indownspouts and gutters, and short-term paint-on coatings are not recommended. Within 4months, these quick fixes may fail and resultin subsequent failure of the lead-based paint.

The purpose of painting is to protect the sub-strate and improve its appearance. In lead-basedpaint stabilization, the main goal is to make in-tact a dangerous, poisonous coating to preventexcessive lead exposures. Paint stabilization ismost effectively and economically completedafter the following defects have been fullycorrected:

✦ Damaged or missing roof flashing.

✦ Damaged or missing door and windowflashings.

✦ Siding in contact with soil.

✦ Water running down siding.

✦ Missing or deteriorated opening trim.

✦ Missing glass in windows.

✦ Missing, damaged, or deteriorated caulking.

✦ Loose and rusty fasteners.

2. Interior Repairs and WaterThe major type of repair that must be com-pleted prior to paint film stabilization involveseliminating moisture sources. Plumbing leaks,especially in bathrooms and kitchens, are oftenthe cause of paint film failure on the ceilingsand walls below. A few major soak/dry cyclescan bring the lead-based paint or leach leadsalts to the surface. The following interiordefects should be corrected permanently inconjunction with interior lead-based paintstabilization projects:

✦ Visual leaks in waste lines, traps, supplylines, or fixtures above or in rooms under-going stabilization or where suspectedlead-based paint is present.

✦ Clogged condensate drip lines for airconditioners.

✦ Water heaters and washers without pansand overflows above or in rooms undergoingstabilization or where suspected lead-basedpaint is present.

✦ Inadequately ventilated attic spaces.

✦ Inadequately ventilated bathrooms,kitchens, and laundry areas.

✦ Clogged bathtub drains.

✦ Interior windows that are loose or do notclose completely.

✦ Broken or missing glass in windows.

✦ Improper or deteriorated caulking inbathrooms or kitchens.

✦ Plugged or blocked weep holes in stormwindows.

Needless friction and abrasion points on lead-contaminated surfaces should also be repaired.As structures age, sag, and adjust, componentscan bind or abrade each other. The followingfriction points should be eliminated whendiscovered on lead-contaminated surfaces(see Section␣III):

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✦ Doors and doorjambs, heads, and thresholds.

✦ Cabinet doors and drawers.

✦ Window sashes, jambs, heads, and partingbeads.

3. Water Vapor ManagementPaint exposed to excess water vapor can failwithin hours of initial application. Almost allexterior trim flashing and caulking serves afunctional purpose by covering seams and jointsand keeping out air and water. All missing ordeteriorated trim, flashing, and caulking shouldbe replaced prior to stabilization. Open cracksin bathrooms and kitchens should be taped withfiberglass mesh wall tape, spackled, and thensealed to eliminate water penetration. Minorrepairs to the plaster substrate should be com-pleted, allowed to dry, and sealed with whiteshellac or an acrylic latex. Exterior cladding andattic spaces should be ventilated to allow theescape of water vapor. Small wedges can bedriven between clapboards, circle vents can beinstalled, or the walls may be sealed from theinside using caulking and a very low-permeableprimer. Soffit and ridge ventilation of at least1 square inch of vent per 300 square inches ofceiling area is recommended. The following va-por maintenance defects should be permanentlycorrected prior to stabilizing lead-based paint:

✦ Deteriorated or missing caulking or groutat tub and shower surrounds.

✦ Painted-over vents on siding or roof.

✦ Deteriorated or missing caulking that allowsair infiltration (e.g., at trim, outlets, lightfixtures, pipe penetrations).

✦ Crawl space not covered with low-permeable barrier (vapor barrier).

4. Substrate RepairsPrior to stabilizing lead-based paint, the follow-ing defects must be permanently corrected:

✦ Dry rotted or rusty structural, siding, orrailing components.

✦ Wall and ceiling plaster that is loosefrom the underlying lath (sagging plaster).

✦ Missing door hardware (e.g., hinges orknobs).

✦ Loose siding or trim.

✦ Loose wallpaper.

C. General Paint ApplicationGuidelines

1. Appropriate ConditionsBecause the guidelines in this chapter havebeen developed primarily to stabilize and seallead-based paint, the general requirements forrepainting should be rigorously followed. Thepainters should be professional, skilled, andwilling to guarantee their work. Strict adher-ence to the paint manufacturers’ recommenda-tions for air and substrate temperatures, re-quired primers, relative humidity, and recoatingtime should be conscientiously enforced. Thecompleted primer and topcoat must be appliedat the manufacturers’ coverage rate and shouldnever be thinner than 2.5 mil. Table 11.1 con-tains other recommended procedures for paintfilm stabilization.

2. When Paint Film StabilizationWill Not Last Very LongUnder certain conditions, paint stabilizationwill not last very long. These are:

✦ Prerequisite repairs not possible.

✦ High probability of future physical damage.

✦ Stairwell walls with visual and likely physi-cal damage (enclosure with wood wain-scot is an acceptable alternative to paintstabilization).

✦ Children’s play equipment (removal of paintor disposal of equipment are better options).

✦ Wall surfaces that are structurally unsound.

✦ Walls with a layer of wallpaper over orunder lead-based paint.

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Table 11.1 Recommended Minimum Thickness of Dried Paint Film for Lead-Based PaintStabilization (in mil)

Topcoat Primer Topcoat Total CoatingThickness Thickness Thickness

Acrylic enamels 1.0 1.5 2.5

Alkyd enamel 1.0 1.5 2.5

Water-reducible epoxy 1.0 2.0 3.0

Urethane-modified alkyd/porch 1.0 2.0 3.0and deck enamel

Epoxy-modifier enamel 1.0 2.0 3.0

✦ Weep holes in storm windows not clearedto allow ventilation and drainage of water.

Paint film stabilization will yield the best resultswhen the surface and building system have beenproperly prepared. If prerequisite repairs cannotbe completed before paint film stabilization, thereevaluation period should be shortened sub-stantially. The owner’s monitoring frequencyshould also be increased.

D. Worksite Preparation

Choice of Worksite Preparation Level dependsupon the size of the area to be stabilized andother factors (see Chapter 8). Occupants shouldnever be present in the work area. Plastic sheet-ing should be used to capture falling paint chipsand make the cleanup process more efficient.

For exterior work, soil samples should be col-lected before the work begins. These samplesneed not be analyzed until postabatement soilsamples have been collected, analyzed, andcompared to clearance standards. If soil samplescollected after the work has been completed arebelow applicable limits, the preinterim controlsamples need not be analyzed (see Chapter 15).

E. Paint Removal Methods

The recommended approaches to surfacepreparation are as follows:

✦ All loose surface material should beremoved by hand treatments (i.e.,wet scraping, wet sanding).

✦ Surface contaminants that prevent adhesionshould be eliminated by cleaning (e.g.,chemical degreasing, trisodium phosphatewashing, or other equivalent detergentfollowed by thorough rinsing).

✦ Surface gloss should be eliminated bychemical etching or HEPA vacuum-assistedsanding.

✦ Adhesion to the substrate should be en-hanced by chemical etching, applying rustinhibitors, spot sealing, and/or wet sanding.

Certain paint removal practices are prohibited,including open-flame burning or torching,machine sanding or grinding without using aHEPA vacuum local exhaust system, uncon-tained hydroblasting or high-pressure wash,open abrasive blasting or sandblasting withoutusing a HEPA vacuum, and use of heat gunsabove 1,100 °F.

Other paint removal practices are not recom-mended, including dry scraping (except forlimited areas) and use of chemical stripperscontaining methylene chloride.

Further information on these prohibited meth-ods is provided in Chapter 12, Section␣IV.

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Rather than sanding to get a grip on an oldgloss coat of paint, the painter should chemi-cally treat the surface with specialized productssuch as Liquid Sandpaper™, taking care to pro-vide adequate ventilation if volatile substancesare released.

F. Surface Cleaning

1. Dust and ChipsGood surface preparation will remove damaged,oxidizing, and deteriorated paint surfaces, butwill also create leaded dust and chips. There-fore, after the surface has been allowed to dry,it should be HEPA vacuumed to collect surfacedust. Prior to applying primer, the surfaceshould be tested for its pH by placing litmuspaper against the wet surface (see Figure 11.5).The surface must be rinsed with clear wateror a weak acid solution until it reaches a pHbetween 6 and 8 for most new paints.

2. Oils, Waxes, and MoldWhile oil and alkyd paints have some tolerancefor oil in the substrate, acrylic latex paints willfail prematurely if applied over greasy or oilysurfaces. For waxes like crayons and some pol-ishes, a combination of household ammoniaand water should be used for cleaning, followedby a thorough rinse. Surfaces in baths andkitchens that may be prone to contaminationby airborne grease and oils, fatty soap films, ormold can be cleaned with a 5- to 6-percent so-lution of trisodium phosphate or other suitablecleaner and rinsed thoroughly. On some var-nished kitchen cabinets, the finished surfacemay become coated with organic films afterextended use. The surface should be cleanedwith a nonflammable solvent before painting.

G. Priming

To maximize the life of a paint job, a systemof compatible coatings is necessary. Primersare designed to adhere tightly to the old paintwhile leaving a rough, bondable surface on theoutside. Prior to priming wood and plaster, sub-strates should have a moisture content of nomore than 15-percent relative humidity on the

1. Wet ScrapingThe goal of safe scraping is to minimize the cre-ation of dust while removing loose paint. Thebest tool for this work is a scraper attached to aHEPA vacuum, which very efficiently removessmall dust particles generated during scraping.

The large chips that fall to the floor will be cap-tured by the 6-mil plastic floor containment.Continuously misting the surface with waterfrom a small atomizer or garden-type sprayerwill minimize dust generation. A small amountof detergent can be used as a wetting agent.This procedure is best completed by two peo-ple—one scraping, the other wetting the sur-face. Simple dust-gathering devices, like a damprag wrapped around the head of a draw scraper,capture the smallest dust particles while direct-ing the larger paint chips onto the floor con-tainment area (see Figure 11.2).

2. Wet SandingWhen preparing a surface by sanding (especiallywith fine-finishing grits), it is quite possible tocontaminate an entire household with fine par-ticles of lead-contaminated dust. Traditionalorbital sanding devices may be used only in con-junction with a HEPA vacuum filter attach-ment (see Figure 11.3). Dry sanding should bereplaced by wet sanding except near electricalcircuits.

Any liquid that does not interfere with subse-quent paint adherence may be used (e.g., water,Varsol, phosphoric acid etch for iron, andtrisodium phosphate).

Patching material for drywall, plaster, and woodcan be wet sanded using sponges (see Figure11.4).

Wood, metal, and painted surfaces that requirea fine cosmetic finish may be sanded using wet-dry sandpaper and water or an oil paint solvent.Relatively rough surfaces may be finished usingwet foam sanding blocks created by dipping asponge in an aluminum oxide grit. Thesesponge sanders are ideally suited for wet sandingand can be easily cleaned by immersing in abucket of trisodium phosphate or other cleaner.

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exterior and 10-percent relative humidity onthe interior. Top-quality primers work better,last longer, and treat more substrate types.Consider the following factors when selectinga primer:

✦ Type of substrate (e.g., wood, metal, gypsum,masonry).

✦ Type of existing substrate coating (e.g.,acrylic latex paint, varnish, oil enamel).

✦ Interior or exterior application.

✦ Topcoat (only use manufacturers’ recom-mended primers; use a single manufacturerfor both primer and topcoat).

1. Oil- and Alkyd-Based PrimersOil primers are compatible with a system ofmultiple coats of oil paint over a wood or plas-ter substrate. The similar solvents used in theold and new paints have a tendency to softenthe surface of paint, creating a better bond. Oilprimers are also effective vapor barriers. On theother hand, oil primers contain volatile organicchemicals that can cause adverse health effectsand may cost more than waterborne paints.Many States regulate the amount of volatileorganic chemicals in paint.

2. Waterborne PrimersThe most durable waterborne paints are madewith an acrylic or acrylic-containing binder.While acrylic latex primers and topcoats are anexcellent combination for new wood, they maynot be compatible with the lead-based oil paintsthat cover the substrate. Waterborne paints usu-ally emit less volatile organic compounds andmay be less expensive than oil paints.

H. Topcoats

To maximize cost-effectiveness and prolongthe efficiency of a coating used as a lead hazardcontrol method, it is important to purchasepaint with a long lifespan. Inexpensive, low-grade paint or special mixes should not be usedin lead-based paint stabilization programs.Paints and clear finishes used for paint stabiliza-tion jobs require outstanding adhesion, durabil-

Figure 11.2 Wet Scraping Tool.

HEPA Sanders

Sanding generates huge amountsof dust. HEPA sanders are sandersfitted with a HEPA vacuum to catchand filter lead dust as it is created.Use a HEPA sander when sandinglead paint. Limit the use of HEPAsanding to flat surfaces for feather-ing or finishing only.

To HEPAVacuum

Figure 11.3 HEPA Vacuum Sanders.

ity, chemical resistance, and flexibility. There-fore, the owner should request the most durableand the highest grade of paint.

Marine paints free of lead and mercury andvarnishes (used on boats, docks, etc.) are espe-cially durable and abrasive-resistant, because

HEPA Sander

To HEPAVacuum

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gloss, the more durable, impact-resistant, andmoisture-resistant the coating. Among typesof paint finishes, gloss, semigloss, and eggshellcoatings are much more resistant to abrasivecleaners and the detergents used in followupmaintenance procedures than flat finishes.

A satisfactory service life of 4 to 10 years maybe achieved with latex and alkyd-based paints,although much more rapid deterioration canoccur under adverse conditions. High-perfor-mance coatings applied properly to ideal sub-strates may offer a service life of 10 to 25 years.High-performance coatings include epoxy-modified alkyds, epoxies, urethanes, epoxy-polyesters, and polyesters. However, these typesof coatings should only be selected after con-sulting the manufacturer as to the specificintended use(s) and after considering thefollowing factors:

✦ Possible presence in the new coating of lead,chromate, mercury, and other heavy metals(and other toxic substances).

✦ Compatibility with existing paint film.

✦ Ability to be repainted in future mainte-nance operations (epoxies and urethanesare difficult to repaint).

Some lead-based paint encapsulants are madeout of similar materials and may last longer thanpaints on some surfaces (see Chapter␣13).

A 100-percent acrylic latex product could last10 years on the average exterior under optimalconditions (Cassens and Feist, 1991). A low-cost nonacrylic latex may last less than 4 years.The additional material costs (126 percent to200 percent) of high-priced paints and any spe-cial primers are minimal when compared to thecost of performing more frequent paint film sta-bilization. (See Table 11.3 for finishes typicallyused for lead-based paint stabilization.)

I. Cleaning and Clearance

Containment removal, extensive cleaning, andclearance testing is required following stabiliza-tion and recoating. (See Chapters 14 and 15 fordiscussion of cleaning and clearance.)

Figure 11.4 Use a Sponge To Wet Sand and Smooth NewPatching Material.

Figure 11.5 Use Litmus Paper To Determine the Surface pHBefore Applying New Paint.

they are formulated with more resin thanhouse paints and the resin is of the highestquality. However, some marine paints are notappropriate for residential use (e.g., bottompaints or mildew-resistant paints contain poi-sons and must be avoided, so that lead is notreplaced by another toxic substance). High-gloss floor and deck enamels offer the next bestlevel of protection. In general, the higher the

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J. Reevaluation andMonitoring of Lead-BasedPaint Stabilization

Immediately after completion of any paintstabilization job, the paint begins the slow pro-cess of deterioration from mechanical damage,ultraviolet rays, rain, snow, and wind. A well-prepared substrate, which is sealed, primed, andtopcoated with premium house paints, canwithstand between 4 and 10 years of weatheringin temperate climates. At the other extreme, asmall scratch in a metal railing located in acoastal town may lead to extensive corrosionand major paint failure within a much shortertime. Assuming a proper paint job, paint life isdirectly related to the environment to which it

is exposed. Cyclical changes in the environ-ment are responsible for the greatest rate ofpaint destabilization. Rapid changes in tempera-ture, moisture content, and relative humiditycause small stress cracks at joints and betweendissimilar materials. Exterior paint life can beextended considerably by annual inspectionsand maintenance (spot scraping, spot priming,and topcoating deteriorated areas). While anew paint job on interior plaster and wood canlast 5 to 10 years with only minor fading, re-painting will be required much more frequentlyin dwellings with more wear and tear. Spotpriming and spot topcoating as soon as a dete-rioration is noticed can extend the life of theinterior surfaces.

Table 11.2 General Recommendations for Applying Paint

✦ Paint only when surface and ambient temperatures are between 50 °F and 90 °F when using awater-thinned coating, and between 45°F and 95°F for other types of coatings.

✦ Maintain coatings in container at a temperature range of 65 °F to 85 °F at all times on the job.

✦ Paint only when the temperature is expected to stay above freezing.

✦ Paint only when wind velocity is below 15 mph.

✦ Paint only when relative humidity is below 80 percent.

✦ Observe the recommended spread rate for each kind of coating.

✦ Tint each coat differently if the same paint is to be used for successive coats to ensure complete coverage.

✦ Allow sufficient time for each coat to dry before applying another. Use the same brand for each coat.

✦ Allow adequate time for the topcoat to dry before permitting service to be resumed.

✦ Do not put doors back into use until they have dried completely.

✦ Do not paint over weep holes in the bottom of storm window systems; if the weep holes are blocked orplugged, drill a hole to permit proper ventilation and drainage of rainwater. Failure to clear weep holeswill cause premature paint failure in window troughs.

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Table 11.3 Finish Coats for Lead-Based Paint Stabilization

Options Base Cost per Difficulty Level Comments andGallon Recommendations

Varnish Oil alkyd resin, $18–$36 Can be touched up veryclear finish easily.

Acrylic latex Water $12–$18 Safest and May not adhere to alkydeasiest to use. enamels.

Polyurethaneresins:

Alkyd Oil-volatile $20–$36 Easy to apply. Cannot be touched uporganic solvent Very durable. without sanding off gloss.

Moisture-cured Volatile organic $32–$38 Harder to apply. Needs adequate relativesolvent humidity to cure.

Waterborne Polyurethane $35–$60 Can be hard to Safer to apply thanclear finish water apply. organic solvent-

containing coatings.

Source: Adapted from A Consumer’s Guide to Renovation, Repair and Home Improvement, J. Wiley & Sons, 1991.

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Friction and Impact SurfaceTreatment: How To Do It

1. Select and implement the appropriate Worksite Preparation Level (see Chapter 8).

2. For windows, remove stop bead and parting strip and dispose of properly. Wet scrape deteriorated paint. Ifthe window trough is badly weathered, cap with back-caulked, aluminum coil stock. If necessary repair win-dow weight and pulley system. Install new window channel or slide system and replace stop bead (and part-ing strip if required).

3. For doors, remove doorstop and dispose of properly. Remove door by pulling out hinge pins. Mist and planedoor to eliminate friction points. Reinstall door and install new doorstop.

4. For stairs, install a hard, cleanable covering on treads (i.e., rubber tread guards). Carpeting may be usedinstead, but it must be securely fastened so that it does not cause abrasion. Stabilize paint on banisters,balusters, and newel posts.

5. For baseboards, remove and dispose of shoe molding and replace.

6. For abraded outside wall corners, install new plastic or wood corner bead.

7. For drawers and cabinets, remove and replace cabinet doors or remove paint by offsite stripping. Strip paintfrom drawers and drawer guides or plane impact points and repaint. As an alternative, install rubber or feltbumpers at points of friction or impact.

8. Repaint porches, decks, and interior floors.

9. Have a certified risk assessor or certified inspector conduct a clearance examination.

10. Perform ongoing maintenance and monitoring of treatments. Reevaluations should be conducted bycertified risk assessors based on the reevaluation schedule for the specific property (see Chapter 6).

11. Provide educational materials to residents. Information should include proper cleaning routines andthe sticky tape method of removing loose paint.

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Section III

III. Friction and ImpactSurface Treatment

A. Definition of Terms

1. Friction SurfacesFriction surfaces are those surfaces covered withlead-based paint that are subject to abrasion,which may generate leaded dust. The most criti-cal friction surfaces are generally those portionsof a window that are rubbed when the windowis opened and closed (see Figure 11.6). The ac-tual area(s) of adjacent surfaces that rub to-gether should not be painted. This includes thejamb, stop bead, and parting strip, and some-times the sash. Other common friction surfacesinclude tight-fitting or rubbing doors, cabinetdoors and drawers, stairway treads and railings,and floors painted with lead-based paint, in-cluding exterior decks and porches.

Friction surfaces on doors and windows willgenerate less leaded dust when they are kept ingood operating condition and in a state of goodrepair. Friction surfaces can also often be cov-ered with a temporary or permanent coveringto eliminate the friction. The covering itself,however, must be abrasion-resistant.

However, if the component is deteriorated, itmay be more cost effective to simply replace itthan to attempt to treat friction surfaces (seeChapter 12).

2. Impact SurfacesImpact surfaces are generally protruding surfacesthat tend to be bumped or banged. These im-pacts can cause small chips of paint to becomedislodged and fall to the floor, thus coveringthe floor with small amounts of loose lead-contaminated dust and chips (see Figure 11.7).The most common impact surfaces are doorsand doorjambs, door trim, doorstops, outsidecorners of a wall, baseboards, and shoe moldingsalong the baseboard, stair risers, and chair rails(see Figure 11.8).

Impact surface problems can be lessened byplacing barriers in front of the impact surface,such as new shoe molding in front of base-boards, or a new chair rail to protect lead-basedpainted walls from jolts by the backs of chairs.Impact surfaces can also be covered with animpact-resistant material (e.g., placing cornerbeads over outside corners of walls).

B. Lead Hazard ControlMeasures

The control measures described in this sectioninvolve a combination of both interim controland abatement treatments of windows, doors,stairs, baseboards, drawers, cabinets, porches,decks, and interior floors. These treatments arelikely to control lead hazards more effectivelyand for longer periods than stabilizing paintedsurfaces.

The treatments described below require specialconstruction and cleanup skills that should beimplemented by trained personnel only.

1. Window SystemsWindow systems may be the largest source ofleaded dust and chips in the home and are alsothe most complex to treat. Window paint tendsto deteriorate more rapidly than other paintedsurfaces due to moisture, variations in tempera-ture, and exposure to the elements. In addition,painted friction surfaces, including the jamb,stop bead, and parting bead are abraded or“sanded” each time windows are opened andclosed. If the wood becomes weathered, dustis trapped and is difficult to remove.

Before beginning any window treatment, theWorksite Preparation Level for windows shouldbe implemented (see Chapter 8).

The stop bead holding in the lower sash shouldbe misted with water and scored with a razorknife along the edges to facilitate its removal.The stop bead should be pried off, wrapped inplastic, and sealed with tape for disposal. Next,the lower sash should be removed. The jamb,parting bead, sash, window trough, and peelingtrim should be misted with water, and loose andflaking paint should be carefully scraped away.

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Figure 11.6 Window Friction and Impact Points.any additional paint loosened by the hammer-ing should be wet scraped. All surfaces shouldbe HEPA vacuumed one more time and thenew stop bead should be primed and painted.The plastic used to protect the surrounding areamust be misted, folded with the dirty surfaceinside, and placed in a double 4-mil or single6-mil plastic bag. The bag should be sealed andlabeled to identify the contents for later dis-posal. Floor surfaces should be HEPA vacuumedbeneath the plastic and several feet aroundthe plastic on each side. The floor should bemopped with the cleaning solution, rinsed withclean water, and HEPA vacuumed a final time.

For further protection it is possible to installreplacement window channels or slides.Aluminum, vinyl, and polyvinyl chloride(PVC) plastic channels are available (seeFigure 11.10).

In this case, both the stop and parting beadsshould be removed, both sashes taken out, thechain and pulley system disconnected, and thepulleys removed. All other surfaces should re-ceive the same treatment as described above.The jambs should be repainted and the windowchannels installed with the old sashes and anew interior stop bead.

Covering painted surfaces with coil stock orchannel systems is technically an enclosureabatement measure combined with interim con-trols since the whole window system is not en-closed. This combination of abatement and in-terim controls provides a great deal of flexibilityto the property owner. In many cases it will per-mit the most cost-effective strategy to be used.

If windows are badly deteriorated, it may bemore cost effective to replace them, particularlyin young children’s bedrooms or in rooms inwhich young children frequently play.

2. Door SystemsDoors present a problem when the doorframebecomes misaligned due to settlement or whenmultiple coats of paint reduce frame clearanceto the point where the door sticks, rubs, oreven chips paint on the door or doorstop whenopened and closed. The simplest approach is to

SashJambSill/StoolParting Bead

Trough (well)

Jamb

All surfaces should be HEPA vacuumed, payingparticular attention to the window trough. Ifbadly weathered, the window trough shouldbe capped with aluminum coil stock (or equiva-lent), which is back caulked and nailed intoplace (see Figure 11.9).

All surfaces should be thoroughly scrubbedwith a cleaning agent suitable for leaded dustremoval and rinsed with clean water. Anynecessary repairs to the weight and pulleysystem should be made at this time. The sashshould be reinstalled with a new stop bead and

Head

Sash

Sill/Stool

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rehang the door so that it no longer rubsagainst the doorjamb.

To accomplish this, the area should be pro-tected with plastic taped to the floor, as de-scribed in Chapter 8. Heavily painted door-stops can be misted, scored with a razor, andpried loose. The stop should be wrapped inplastic and sealed with tape for disposal. Fric-tion points on the door should be noted. Hingepins should be removed and the door carefullyplaned (preferably outside the unit) to elimi-nate the friction points. (Note: Planing ofdoors will generate considerable leaded dustand paint-chip contamination and may bemore easily completed offsite in a controlledenvironment.) The minimum Worksite Prepa-ration Level that should be used is InteriorLevel 2. A new doorstop, if necessary, shouldbe installed and any paint loosened by the ham-mering should be wet scraped. The new stopand planed areas should be primed and all sur-faces repainted, as described in Section II ofthis chapter. The floor beneath the plastic andseveral feet around the plastic should be thor-oughly HEPA vacuumed and mopped with asuitable cleaning solution.

3. Stair SystemsThere are a number of treatments that will con-trol lead hazards on stairs. Installation of rubbertread guards will lessen or eliminate friction onthe tread (see Figure 11.11). The tread guardsshould cover the entire width of the stairs.

Covering the treads and risers with carpetingcan be useful in lessening friction and impact. Itis important that carpeting be securely installedand cover the entire width of the stairs, sinceloose-fitting carpeting can cause abrasion andsubsequent dust releases. However, since carpet-ing is difficult to clean effectively, installationof hard, cleanable surfaces (for example, tile)is generally preferable to carpet.

4. Baseboards and Outside WallCornersDamage to baseboards subject to frequent im-pact can be lessened by the replacement of theshoe molding at the bottom of the baseboard

Figure 11.7 Damaged Paint on an ImpactSurface.

Figure 11.8 Impact Surfaces.

Damagedpaint hasfallen offthis impactsurface

Head

Latch Jamb

Casing

Door

Hinge

Hinge Jamb

Stop

Fig 11.9

Transom

Threshold

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Figure 11.9 Enclose the Window Sill and Window Trough.

Sash

Apron

Storm Window Frame

Weep Hole

CasingInside Stop

Outside StopParting Bead

Jamb

No

Yes

(see Figure 11.12). This relatively inexpensivetreatment provides a barrier that preventschair and table legs from actually striking thelead-based painted surface. Shoe moldingshould be removed by misting the surface, scor-ing with a razor, and prying the molding loose.The molding should be wrapped in plastic andsealed with tape for disposal. Since the base-board is not necessarily removed, installation ofnew molding is a combined abatement/interimcontrol measure. New shoe molding shouldthen be back caulked.

Impact or abrasion of outside corners of wallscan be reduced by the installation of a woodenor plastic corner bead (see Figure 11.13).

5. Drawers and CabinetsDrawers and cabinets coated with lead-basedpaint present a potential risk when doorsor drawer facings do not fit properly. Thisis especially important when the cabinet ordrawer is used for storing food, eating utensils,or bathroom articles, such as toothbrushes.

Cabinet doors can be carefully removed anddiscarded, or can be stripped offsite and planedwhere necessary to fit properly, and repainted.These activities should only be performed afterall articles are removed from the cabinet andthe immediate area is contained. The exteriorand interior of the cabinets should be thor-oughly cleaned before articles are returned.

Drawers can also be removed and strippedoffsite. Drawer covers can be planed at impactpoints and repainted. Installation of rubber orfelt bumpers will also reduce impact with thepainted surface of the cabinet.

6. Porches, Decks, and Interior FloorsPorches, decks, and interior floors with lead-based paint can be significant generators ofpaint chips and leaded dust particles throughabrasion or impact. At a minimum, the paintshould be carefully stabilized and covered withpolyurethane or high-quality paint. Decks andfloors must be smooth enough so that dust canbe removed by normal cleaning without special

Interior Sill (stool)

Exterior Sill

Aluminim Coil Stock

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Figure 11.10 Window Channel Guides That Reduce Friction.

A rubber tread with metal nosing works well. Rubber nosing that fits snugly on the nose may work if the stairsare not used very often.

Figure 11.11 Covering Stairs With Tread Guards.

Compressiontrack

✦ Remove the bottom sash. If thecounter-weight ropes or chains arein place, do not let them drop intothe weight compartment.

✦ Remove the paint from edges that rubagainst stop, stool, and parting bead.Wet planing is a good method.

✦ Rehang the sash(es) in a compressiontrack. If there is no counter weight orspring system, install one to keep thesash in place.

✦ Enclose risers with thin plywood(like luan plywood) or someother hard material. Whateveryou use must fit snugly.

✦ Back caulk the edges of treads.Place them and nail or screwthem down. Screw or nail themetal nosing on.

Caulk back ofrubber tread

Nails

Wood

Metal nosing

Fig 11.15

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equipment. If funds are available, abatement offloors is strongly recommended, usually throughenclosure with new flooring or covering.

C. Lead Hazard ControlMeasures Performed byResidents

There are also a number of lead hazard controlmeasures that owner-occupants or residentsof rental dwellings can carry out. Owners ofrental properties should provide residentswith educational materials furnished by Stateor local agencies or lead-poisoning preventionorganizations that include the following basicinformation:

✦ Children’s toys should not be placed be-neath windows or near surfaces subject tofrequent friction or impact.

✦ If there is a sudden loosening of paint mate-rial through friction, impact, or any otherreason, occupants should use the sticky tapemethod to remove loose paint described inTable 11.4.

✦ Porch decks, interior floors, and otherhorizontal surfaces should be wet moppedat least twice a month.

Figure 11.12 Shoe Molding Is an Acceptable ImpactSurface Treatment for Baseboards.

Crown

Chair Rail

Wainscot

Base Cap

Baseboard

Shoe Molding

WALL

Fig 11.14

Figure 11.13 Corner Bead Coverings Can Be Used onOutside Corners of Walls.

1. Place a piece of plastic or paper beneath the area in question.

2. Press a piece of wide sticky tape firmly over the area of loose/chipping paint.

3. Wait a few seconds and then carefully remove the tape, taking the small chips of paint with it.

4. Place the tape in a plastic bag.

5. Carefully fold the piece of plastic or paper that was beneath the area and place it in the bag.

6. Seal the bag and clean the area.

7. Dispose of all waste materials in a secure manner; do not use the resident’s trash cans for thispurpose.

Table 11.4 Sticky Tape Technique for Removing Loose Paint on Impact Surfaces for Owner/Occupants or Residents

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Dust Removal and Control:How To Do It

1. If the level of lead-contaminated dust exceeds the following levels, the dust should be removed. The presentstandards for wipe sampling are:

✦ Window troughs, 800 µg/ft2.

✦ Interior window sills, 500 µg/ft2.

✦ Floors, 100 µg/ft2.

Bare floors and window components should also be made smooth and cleanable.

2. Correct any known or suspected lead-based paint hazards before dust removal.

3. Visually inspect other dust traps, such as radiators and floor grates. If visible dust is found, the componentshould be cleaned.

4. Distribute educational materials prepared by EPA or State or local government agencies to residents. Thesematerials should warn residents that carpets, drapes, and upholstered furniture may be contaminated andshould be cleaned or replaced.

5. Prepare the work area with Interior Worksite Preparation Level 1 or other proven containment method(see Chapter 8). If contaminated carpet is to be removed, the work area should be contained with InteriorWorksite Preparation Level 3 or 4 (do not put down plastic sheeting on floors for carpet removal).

6. Clean all horizontal surfaces, beginning with HEPA vacuuming, followed by wet washing with a cleaningagent suitable for lead removal, such as a lead-specific cleaner or trisodium phosphate detergent. Test thecleaning solution before using to determine if it will discolor or damage surfaces to be cleaned.

7. Begin dust removal at the top rear room in the dwelling, working forward and down. Within rooms, startwith the highest horizontal surface and work down. Clean windows, other dust traps, and finally the floors.When practical, clean dirty areas last within rooms to avoid spreading dust.

8. Place the HEPA vacuum on a smooth, hard surface or on a sheet of plastic during operation. Remove HEPAfilters and bags offsite (not inside the dwelling) in a controlled environment.

9. During wet cleaning, replace rags, sponges, and mops frequently (at least once per dwelling). Use a two-bucket system for floors: one for the cleaning solution and the other for rinsing. Change the wash waterat least once in each room.

10. Clean until no surface dust is visible. After cleaning rinse with clean water and a new sponge or cloth.

11. The owners of carpets and upholstered furnishings are responsible for their care. Recommend to the ownersthat highly contaminated or badly worn items should be discarded. To discard a carpet, mist the surface withwater; seal in plastic sheeting, bags, or containers; and discard properly.

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12. To clean area rugs, HEPA vacuum the top side with a beater bar or agitator attachment at a rate of 1 minutefor each 10-square-foot area. Fold the rug in half and HEPA vacuum the backing of half the carpet withoutusing the beater bar at a rate of 1 minute per 10 square feet. HEPA vacuum the exposed floor beneath thecarpet, the bottom of the carpet, and the pad (if there is one), and fold the rug back into its original posi-tion. Repeat the process for the other half of the rug. Finally, HEPA vacuum the top side again with thebeater bar at a rate of at least 2 minutes per 10 square feet. To summarize:

✦ Vacuum the top side for 1 minute per 10 square feet.

✦ Vacuum the bottom for 1 minute per 10 square feet.

✦ Vacuum the top again for a final 2 minutes per 10 square feet.

This is a total of 4 minutes for every 10 square feet of carpeting. Also vacuum the bare floor under thecarpet.

13. For wall-to-wall carpeting that cannot be folded over, HEPA vacuum at a rate no faster than 2 minutes per10 square feet in a side-to-side direction, followed by another pass at the same rate in a direction perpen-dicular to the direction of the first vacuuming, for a total of 4 minutes per 10 square feet. For wall-to-wallcarpeting, it is not feasible to clean the floor underneath the carpeting.

14. To attain an even higher level of cleanliness, steam clean the carpet using a regular commercial cleaningsystem after performing the HEPA vacuuming in step 12 or 13.

15. Conduct clearance dust wipe sampling on rugs or furnishings that were cleaned to determine if the cleaningwas effective.

16. To clean other upholstered furnishings, HEPA vacuum each surface three to five times. Steam cleaning isnot recommended because it may damage the fabric.

17. Clean drop ceilings or the ductwork for forced air systems only when they are expected to be disturbed.HEPA vacuum and wet clean air vents or registers. Replace air filters in the forced air systems at the timeof cleaning.

18. Have a certified inspector technician or risk assessor conduct a clearance examination (see Chapter 15).Repeat cleaning, if necessary. Conduct periodic reevaluations as explained in Chapter 6.


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Section IV

IV. Dust Removal andControl

A. Introduction

Dust removal is a type of interim control thatinvolves an initial treatment followed by re-cleaning as needed. This section provides infor-mation on when the removal of leaded dust(alone) is an appropriate interim control andhow to accomplish it. Some dust removalwill always be an element of interim controlmeasures, either as a stand-alone treatment oras part of cleanup following other work.

1. Sources and Locations of LeadedDustLead in settled house dust is a major source oflead exposure in young children. Leaded dustcan come from deteriorating lead-based painton interior and exterior surfaces, abrasion oflead-based paint on friction and impact sur-faces, and the disturbance of lead-based paintduring maintenance, renovation, or remod-eling activities. Leaded dust can also originatefrom exterior soil or dust. Sources of lead-contaminated soil include weathering or scrap-ing of exterior lead-based paint, past use of leadadditives in gasoline, industrial point sources,and demolition and paint removal from build-ings and steel structures. Lead-contaminatedsoil and exterior dust can be tracked inside byhumans and pets or carried indoors by wind.Leaded dust can be produced by activities re-lated to hobbies and can be carried home onthe clothing of workers exposed to lead. Table11.5 provides a summary of potential sourcesof lead in settled house dust.

Leaded dust can be found on surfaces and increvices throughout a dwelling. Certain surfacescan act as major reservoirs of lead-contaminateddust, including windows, worn floors, carpets,and upholstered furnishings (see Table 11.6).Cleaning carpets, upholstered items, and wornfloor surfaces can be difficult due to embedded

dust and dirt. Furthermore, lead-contaminateddust can rapidly reaccumulate on householdsurfaces following dust removal (Charney,1983).

Lead-contaminated dust in carpets and rugs,window coverings (drapes and curtains), mats,and upholstered furnishings is a hazard whetherthose items are supplied by the owner of thedwelling or by residents. Owners of rental unitsare responsible for cleaning such items or re-moving and replacing them only if they belongto the owners. However, the owner should pro-vide residents with educational material fur-nished by a government agency or a qualifiedlead-poisoning prevention organization. Suchmaterial should include a warning that carpetsand rugs, window coverings, mats, and uphol-stered furnishings may contain dangerous levelsof leaded dust and that those items should bethoroughly cleaned or (preferably) removedand replaced if they are hazardous.

2. Removing Leaded Dust From aDwellingBoth large, visible particles and small parti-cles not visible to the naked eye need to be re-moved (see Figure 11.14 a and b). Leaded dustcan be difficult to remove with ordinary house-cleaning measures such as non-HEPA vacuum-ing, particularly in poorly maintained housingwith rough and deteriorated surfaces (Charney,1983; Farfel and Chisolm, 1987a). A HEPAvacuum is equipped with a special filter thatremoves nearly all small lead particles from thevacuum’s exhaust airstream that would other-wise be redistributed throughout the dwelling.

A combination of HEPA vacuuming and wetcleaning is recommended for leaded dust re-moval. Wet cleaning is conducted with a solu-tion such as a lead-specific cleaner or trisodiumphosphate detergent. Even with special equip-ment and procedures, leaded dust can be diffi-cult to remove from dust traps, carpets, non-smooth surfaces, and surfaces abated by paintremoval methods such as caustic chemicals(Ewers, 1993; Farfel and Chisolm, 1991; Farfeland Chisolm, 1987b).

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Table 11.5 Potential Sources of Lead-Contaminated House Dust

Source Process That Contributes to Lead in Key SitesHouse Dust

Interior lead-based Deteriorating paint. All surfaces.paint

Friction/abrasion. Windows, doors, stairs, and floors.

Impact. Door systems, openings,baseboards, corner edges,chair rails, and stair risers.

Water damage. Walls, trim, and ceilings.

Planned disturbances: All surfaces coated with(maintenance activities, repainting, lead-based paint.remodeling, abatement).

Exterior lead-based Tracking (by humans and pets) and blowing All exterior lead-based paintedpaint of leaded dust from weathered, chalked, or components, including porches

deteriorated exterior lead-based paint; also and window sills.direct contact with such paint.

Demolition and other disturbances of Exposed soil, sandboxes, sidelead-based paint on buildings and nearby walks, and window troughs.steel structures.

Soil and exterior dust Tracking (by humans and pets) and blowing of Exposed soil, sandboxes, sideexterior soil/dirt contaminated with lead from walks, streets, and windowdeteriorating exterior lead-based paint; past troughs.deposition of lead in gasoline.

Point sources Releases from lead-related industries Location of point sources.(i.e., smelters, battery recycling, incinerators).

Hobby activities Cutting, molding, and melting of lead for Rooms in which hobbies arebullets, fishing sinkers, toys, and joining pursued.stained glass. Use of lead-containingglazes and paints. Restoration oflead-based painted items.

Occupational sources Transport of lead-contaminated dust from Vehicles and laundry rooms,the job to home on clothing, tools, hair, and changing areas, furniture, andvehicles. entryway rugs.

environment. Enhanced routine cleaning pro-cedures and practices as described in this chap-ter are recommended for use by property ownersover ordinary cleaning practices and procedures.This is not to imply that routine housecleaningis totally ineffective. However, in certain cases,

Workers and residents removing leaded dustshould not spread lead from one householdsurface to another (cross-contamination).Avoiding cross-contamination requires specialknowledge, equipment, procedures, and precau-tions to protect residents, workers, and the

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Table 11.6 Major Dust Reservoirs and Potential Dust Traps

Interior Exterior

Window sills Porch systemsFloors/steps Window troughsCracks and crevices StepsCarpets and rugs Exposed soilMats SandboxesUpholstered furnishingsWindow coveringsRadiatorsGrates and registersHeating, ventilation, air

conditioning filters

The rest of this section will describe howrisk assessors and owners should check floorsand floor coverings to plan for dust removalactivities.

✦ Check condition of floors. Smooth and in-tact floor surfaces, such as vinyl or linoleumsheet goods that still have a smooth finishand wooden floors that have a good finishof sealant (e.g., polyurethane or deck paint)can be effectively cleaned. If a floor surfaceis not smooth or intact, it will require theapplication of an appropriate sealer orcovering and/or repair in order to make itsmooth and cleanable. Examples of non-smooth floor surfaces include floors withworn areas or tears; wood floors with gaps,cracks, splinters, and areas with no sealantcoating; unsealed concrete floors; andreplacement flooring with no finishtreatment (e.g., plywood).

✦ Check carpets, rugs, entryways, and mats.Items such as area rugs or mats should bemachine washed. Wall-to-wall carpets andlarge area rugs in fair to good condition canbe cleaned, removed, and discarded or re-placed (see section on carpets/rugs below).Consideration should be given to discardingrugs, carpets, and mats that are at the end oftheir useful lives, since cleaning may not beeffective (see below for precautions on re-moval of carpets) (Ewers, 1993; IDHW,1991).

routine housecleaning may need to be aug-mented by the special procedures detailed inthis chapter.

The cleaning protocol contained in this chapteris different from that used following lead-basedpaint abatement and other interim controlwork. Postabatement cleaning is described inChapter 14. The main differences are as follows:

✦ Only horizontal surfaces (and these verticalsurfaces undergoing paint film stabilization,as explained in Section II of this chapter)are cleaned for dust removal; for cleanupfollowing abatement, all surfaces arecleaned.

✦ A single pass with a HEPA vacuum and wetwash is used for dust removal; for cleanupfollowing abatement, the cycle is HEPAvacuum, wet wash, HEPA vacuum again.

3. Creating Cleanable Surfaces andDetermining Whether Dust RemovalAlone Is AdequateA risk assessment is recommended to determinewhether the removal of leaded dust alone is anappropriate interim control, or whether otherinterim controls are needed in addition to dustremoval. If no environmental testing or riskassessment has been performed, the propertyowner should assume that lead-based paint ispresent on all painted surfaces and that all hori-zontal surfaces have excessive dust lead levels.

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✦ Check for other potential dust traps. Inaddition to carpets, rugs, and mats, potentialdust traps include radiators, floor grates andregisters, drapes, blinds, and upholsteredfurnishings. These items should be includedin the plan for dust removal. In rental prop-erties some of these items may not belong tothe building owner. Owners are responsiblefor the items they own, while residents areresponsible for their own property. However,it may be in everyone’s best interests to in-clude all of these items in the dust removalplan.

4. Planning and PreparationsOnce it has been determined that dust removalis an appropriate approach, the owner shoulddetermine if the dwelling unit will be occupiedor vacant while the dust removal is occurring.Dust removal work may be performed by con-tractors, maintenance staff, or homeowners.Individuals performing the work should beproperly equipped and trained in dust removal.

If dwelling units are occupied, the ownershould coordinate with residents to ensurethat the roles of all involved in the processare clear. The job should be organized so thatdust removal work is performed in 1 day tominimize inconvenience to residents. An In-terior Worksite Preparation Level 1 is almostalways appropriate (see Chapter 8). Additionalpersonnel and equipment may be required toperform simultaneous work in multiple rooms.

Role of residents. Owners should provideresidents with educational materials preparedby public agencies that indicate how residentscan help in removing leaded dust. The materi-als should indicate that residents perform thefollowing tasks before the professional dustremoval occurs:

✦ Wet wash all cleanable toys.

✦ Store all loose personal belongings in boxes,closets, or drawers to provide easy accessto floors and other surfaces during dustremoval.

Figure 11.14a Turning a Window Sill and Trough Into aSmooth and Cleanable Surface (before treatment).

WeepHole

Figure 11.14b Turning an Exterior Window SillInto a Smooth and Cleanable Surface (after treat-ment).

Notice Weep Holes Are Left Open to AllowProper Drainage and Ventilation.

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✦ Remove drapes and curtains and collectany washable area rugs for cleaning. Cleanor arrange for cleaning of these items andstore them in sealed plastic bags. Washblankets known to have been unprotectedduring renovation or remodeling activitythat disturbed lead-based paint.

✦ Wash or dust unupholstered furniture usingdisposable cloths and spray polish.

✦ Change filters in heating and air condition-ing units, except where routinely performedby the property manager.

5. Responsibilities of OwnersOwners should perform the following tasksprior to dust removal:

✦ Attempt to schedule dust removal whenthe dwelling is vacant (such as during unitturnover).

✦ If the unit will be occupied, notify residentsof the date dust removal will occur.

✦ Provide a written notice/flyer from thelocal health agency with information onresident responsibilities for preparationand cleaning.

✦ Provide for the safety of occupants.

✦ Arrange for dust removal of wood or metalcomponents of windows, built-in shelving,radiators, floors, porches, owner-suppliedcarpets and rugs, window coverings, mats,upholstered furnishings, and other dusttraps.

✦ Provide and install cleanable “walk-off”mats at interior entryways. This will helpresidents control exterior leaded dust thatmay be tracked into the home (Roberts,1991).

✦ Ensure that dust removal contractors com-ply with contract specifications. Largemultiunit contracts may require an onsitemonitor.

✦ Obtain written authorization from residentsfor dust removal where legal authority doesnot exist for such activity.

✦ Arrange for clearance examination.

6. Responsibilities of ContractorsContractors or maintenance staff should per-form the following tasks prior to and duringdust removal (City of Toronto, 1990):

✦ Coordinate with residents and owners ormanagers of property.

✦ Cooperate with any independent, onsiteinspector or risk assessor or project monitorwho may be present on large, multiunit dustremoval projects.

✦ Perform work according to contract/workspecifications.

In the case where the owner’s maintenance staffare performing the work, the owner is respon-sible for the following (otherwise the contractoris responsible):

✦ Ensuring that workers are properly trainedand protected (see Chapter 9).

✦ Providing all safety and special cleaningequipment and supplies.

✦ Taking precautions to minimize damageto residents’ belongings.

✦ Moving major furnishings within roomsto facilitate thorough cleaning.

✦ Responding to residents’ questions, com-plaints, and concerns.

B. Methods of Dust Removal

The objective of any dust removal strategy isto provide a dwelling unit or common area inwhich the leaded dust levels on all horizontalsurfaces are less than the clearance levels. Anycleaning method carried out by a propertyowner is satisfactory if it meets this performancestandard and if workers and occupants are fully

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protected. The procedures in the followingpages describe how best to meet that perfor-mance standard.

The dust removal strategy presented in thissection focuses effort on horizontal surfacesand dust traps that can have accumulationsof surface dust and embedded dust. Embeddeddust is dust that is trapped within a fiber matrix(such as carpeting), in cracks and crevices (ofwooden floors), under carpets, on greasy sur-faces, or ground into surfaces. A combinationof vacuuming with a HEPA vacuum and wetcleaning is recommended to remove both sur-face and embedded leaded dust from householdsurfaces. For upholstered furnishings HEPAvacuuming alone is recommended.

1. Cleaning Hard SurfacesThe standard dust removal procedure for hardsurfaces and components (e.g., hardwood floorsand window components) is HEPA vacuumingfollowed by wet cleaning with trisodium phos-phate (Milar and Mushak, 1982), or a cleanerdesigned specifically for lead removal or anequally effective cleaner. One study found thatHEPA vacuuming hard surfaces at a rate slowerthan 1 minute per square meter (approximately10 square feet) did not remove substantiallymore leaded dust from hard surfaces than fastermethods (Ewers, 1993).Therefore, no speed ortime restrictions are necessary for hard surfaces(although such restrictions are appropriate forcarpeted surfaces, as detailed below).

On hard surfaces HEPA vacuums should bepassed over the entire surface with overlappingstrokes using normal speed. Trisodium phos-phate has been shown to aid in the removal oflead in dust. There is also strong anecdotal evi-dence that a lead-specific, strippable coating(Grawe, 1993) and a lead-specific detergent(Wilson, 1993) are at least as effective as triso-dium phosphate in removing lead. These newproducts may in fact be more effective thantrisodium phosphate, which is now banned insome areas. Any cleaning product may be used,as long as the cleaner’s performance is evaluatedby determining compliance with clearance

criteria and lead-specific cleaning agents. Triso-dium phosphate is most likely to permit easycompliance with clearance criteria, avoidingthe need for repeated cleaning. Whenever a wetcleaner is used, a small area of the surfaceshould be tested to make sure that it does notdamage the surface or its coloring. If so, anotherwet cleaner should be used.

General work practices

✦ Clean from top to bottom and vacuum be-fore wet cleaning. On multistory dwellings,start at the top level in the rear room andwork in one direction toward the front (seeFigure 11.15). Then repeat the process onthe remaining floors in sequence. Within aroom start with the highest horizontal sur-faces and work down. This would typicallyresult in the following cleaning sequence:tops of window heads, tops of sashes, mul-lions, and interior and exterior window sillsand troughs. Clean dust traps such as radia-tors, followed by baseboards, and finallyfloors, vents/registers, and horizontal com-ponents of the ventilation ducts that can beeasily reached. When practical, work fromclean areas to dirty areas to minimize thespread of leaded dust to clean areas. It isusually not necessary to clean walls andceilings for dust removal unless those sur-faces have undergone paint removal orstabilization.

✦ When vacuuming, use crevice and brushtools where appropriate.

✦ If possible, place the vacuum unit on asmooth, hard surface that has been cleanedor on a clean sheet of 6-mil plastic ratherthan on a carpet. Vacuum exhaust, even onHEPA vacuums, can disperse dust when theexhaust airstream disturbs settled dust on asurface. A HEPA vacuum that exhausts airfrom the top or side rather than the bottomhelps to minimize dust dispersal, making itunnecessary to use a sheet of plastic.

✦ Use disposable cleaning cloths or sponges.Be prepared to dispose of them during thecleaning process and replace with new ones.

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Figure 11.15 Sequence for Dust Removal.

How to use a HEPA vacuum

1. Lightly mist area with water to keepdust levels down.

2. HEPA vacuum all horizontal surfaces.

Start at the end farthest from the mainentrance/exit. As you vacuum, movetowards the main exit and finish there.

Begin at the top of each room and work down.For example, start with the top shelves, thetop of the woodwork, and so on, and workdown to the floor. Do every inch of the win-dows, especially the window troughs.

✦ When cleaning household surfaces otherthan floors, the cleaning solution may bemixed in a plastic jug and poured directlyonto sponges or cloths (EPA, 1992a). Thisprocedure is designed to minimize the con-tamination of the cleaning solution withleaded dust. Frequently rinse the sponge/cloth in a bucket of clean water.

✦ For floors a two-bucket system is stronglyrecommended to minimize the potential forspreading leaded dust from one location toanother. The cleaning solution should bemixed in one bucket; a second bucketshould contain rinse water for the mophead.Frequently, at least once per room, changethe rinse water in the bucket. A disposable

sponge mophead with a built-in wringer(rather than a string mop) is recommended.A final cosmetic rinse is recommended us-ing clean water or a commercial cleaningsolution.

✦ Clean until surface dust is no longer visible.After cleaning a window or a floor, rinsewith clean water using a new sponge orcloth.

✦ To make a cleaning solution with trisodiumphosphate or other suitable detergent, mixwith water according to the manufacturer’sinstructions for recommended concentra-tions. When using the cleaner (especiallytrisodium phosphate), wear gloves and eye

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protection gear and follow all manufac-turer’s instructions and precautions. OSHAregulations require an onsite eyewash sta-tion when using trisodium phosphate (29CFR 1910.151). Also, concentrated triso-dium phosphate solutions can damage anddiscolor some surfaces.

✦ Where possible, clean floors underneathrugs and carpets.

✦ For dust removal projects in multifamilyhousing, a truck-mounted vacuum unit witha HEPA filter exhaust may be preferablesince the exhaust stream is located outsidethe dwelling and therefore is not likely todisturb dust inside the dwelling.

✦ Remove and dispose of HEPA vacuumcleaner bags and filters offsite, according tothe manufacturer’s instructions, in a con-trolled environment capable of capturingany dust released by the procedure. If thefilters need to be changed in the middle ofthe job, take the vacuum unit outside thehouse, place it on a sheet of plastic, and re-move the old filter carefully. Do not changefilters inside the dwelling if possible (seeFigure 11.16 a–f).

2. Removal or Cleaning of Carpetsor RugsCarpeting and large area rugs can be major trapsand reservoirs of leaded dust. Dirt embedded infibers of carpets and rugs is not easily removedby cleaning. The procedures described in thissection have been shown to reduce lead levelsto a limited degree. Highly effective lead re-moval methods have yet to be identified (Ewers,1993; IDHW, 1991). It is not likely that anycleaning process will remove all leaded dustembedded in carpets.

The first step in carpet dust removal is to decideif the carpet is going to be cleaned onsite, re-moved for disposal, or removed for professionaloffsite cleaning. It may be preferable to disposeof carpets that are in poor condition or thoseknown to be highly contaminated with lead.

In fact it may be more costly to clean a lead-contaminated carpet or rug than to replace it.When carpets are removed, the precautionsdescribed below should be followed to minimizethe exposure of workers and residents to leadeddust.

Removal of carpets or rugs. When a carpet orrug is going to be removed from a dwelling foreither disposal or offsite cleaning, the followingprocedure is recommended:

Mist the entire surface of the carpet to keepdust from spreading. Carefully roll up the carpetalong with any padding. (If the padding is notgoing to be removed, clean it like an area rug.)Wrap the carpet in a sheet of plastic, seal itwith tape, and remove it from the dwelling.

Because the removal of a carpet may gener-ate significant amounts of airborne lead-contaminated dust, Interior Worksite Prepara-tion Level 3 or 4 is recommended. If the areain which the carpet is located is not fully con-tained, HEPA vacuum the floor after removingthe carpet so leaded dust is not tracked to otherparts of the dwelling.

Cleaning area rugs. If cleaning of large arearugs is done onsite, the following steps arerecommended:

✦ First, vacuum the pile side (the top side)with a HEPA vacuum equipped with abeater bar or agitator attachment on thevacuum head at a rate no faster than 1minute for every 10 square feet. Thepurpose of the beater bar is to dislodgeembedded dust (CMHC, 1992; Ewers,1993; IDHW, 1991).

✦ Fold the rug in half, exposing the backing ofhalf of the carpet. The backing of the carpetshould be HEPA vacuumed without usingthe beater bar attachment (City of Toronto,1990) at a rate of 1 minute per 10 squarefeet.

✦ Vacuum the exposed floor beneath the rugat normal speed and unfold the rug.

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✦ Fold the rug in half again, exposing thebacking of the other half of the carpet, andrepeat the HEPA vacuuming of the bottomof the rug and the floor underneath.

✦ Unfold the rug.

✦ HEPA vacuum the pile side of the rug againusing the beater bar attachment. Vacuum ata rate no faster than 2 minutes per 10 squarefeet.

Consideration should be given to a final clean-ing step consisting of a steam cleaning of thepile side of the rug. Steam cleaning can removeadditional, but limited, amounts of lead fromrugs (IDHW, 1991). This cleaning can be doneby the contractor, owner, or resident using com-mercially available equipment. For multiunitbuildings consideration should be given to theuse of truck-mounted cleaning equipment sinceit may be significantly more powerful than typi-cal rental equipment for residential use.

Phosphate-containing detergents may bemore effective than nonphosphate-containing,regular detergents when cleaning rugs (Milarand Mushak, 1982), although the new lead-specific cleaners have not yet been evaluatedfor carpets. If using a commercial cleaningdetergent that does not contain phosphate ora lead-specific removal agent, considerationshould be given to substituting a mild trisodiumphosphate or lead-specific solution (less thanhalf the recommended strength). It may benecessary to clean a small, inconspicuous areafirst to determine if the material is colorfast.In all cases a second cleaning with the regularcommercial cleaner is recommended. Newcleaners advertised as lead-specific can alsobe used since preliminary evidence indicatesthat they are successful (Grawe, 1993; Wilson,1993).

Cleaning wall-to-wall carpeting. For cleaningwall-to-wall carpeting, the following procedureis recommended:

Vacuum carpeting with a HEPA vacuumequipped with a beater bar or agitator attach-ment on the vacuum head. The beater bar helps

Figure 11.16a Remove the HEPA VacuumFilters and Disassemble the Vacuum Witha Plastic Sheet Underneath.

Figure 11.16b Disconnect Vacuum BagFrom Hose Inlet.

Figure 11.16c Remove Bag.

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to dislodge embedded dust. The total vacuum-ing time recommended is at least 4 minutes per10 square feet of carpeting (Ewers et al., 1993),divided into two segments of at least 2 minutesfor each 10 square feet. The two vacuumingsegments are performed in perpendiculardirections. For example, the first segment maybe done in an east-west direction, while thesecond is done in a north-south direction.

The provisions regarding steam cleaning andsuitable detergents for area rugs also apply towall-to-wall carpeting.

3. Cleaning Upholstered FurnitureThe first step in dealing with upholstered fur-nishings is to determine if the item is going tobe discarded or cleaned. It may be preferable todispose of items that are in poor condition orknown to be highly contaminated with lead.

The recommended dust removal procedure forupholstered furniture is HEPA vacuuming with-out steam cleaning or other wet cleaning proce-dures that could damage fabrics. Cloth throwcovers, slipcovers, or fitted vinyl covers shouldbe provided for all cleaned, upholstered items.This is particularly important for items at theend of their useful lives that would not hold upwell under an aggressive vacuuming. A clothcover material that can be easily removed andwashed should be selected.

Upholstery surfaces should be HEPA vacuumedwith three to five passes over each surface at atotal rate of 2 minutes per 10 square feet.

4. Forced Air Systems and DropCeilingsThis section provides a practical approach todealing with these potential dust reservoirs.At the present time, it is not known whetherleaded dust in forced air ducts and drop ceilingsis a hazard to residents. Although one studyhas measured leaded dust in air ducts (city ofToronto, 1990), the results do not provide evi-dence that the lead is leaking out of the ductsand posing a hazard to children. If the ceilingsor forced air systems contain leaded dust, theymay present a hazard to maintenance or renova-tion workers who access them.

Figure 11.16d Tape Vacuum Bag Closedand Put Inside Plastic Trash Bag.

Figure 11.16e Wash or Replace CoarsePrefilters if Necessary.

Figure 11.16f Remove and ReplaceHEPA Filter Assembly.

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Where possible, return and supply air ventregisters that can be easily removed should betaken out, vacuumed, and wet cleaned (seeFigure 11.17). If the vent registers are sealed tothe wall or floor with paint, the edges should bemisted and scored to help free the vent registerwith a minimum of leaded-dust generation.

Air vent registers that cannot be easily removedshould be vacuumed and wet cleaned in place.The horizontal surfaces in the ductwork thatcan be easily reached with the vacuum attach-ment can be cleaned. Water should not bepoured down the air duct to clean the ventregister; wiping with a damp sponge or mopis adequate.

Replace the air filters on heating units and airconditioners with new filters at the time of dustremoval. Used filters should be placed in plasticbags and sealed prior to disposal to minimize thepotential spread of leaded dust.

Leaded dust in nonforced air systems and dropceilings is not considered a hazard to residentsunless major disturbances of the ducts or ceil-ings are planned, such as repairs or relocationsof ducts. When major disturbances of any typeof duct or ceiling work are anticipated, cleaningwill probably be warranted. This includes in-stances when forced air systems have the direc-tion of airflow reversed during maintenance.

5. Resident ProtectionTo facilitate dust removal work and provideprotection for occupants, only workers shouldbe in the work area during the dust removalprocess. This will also help ensure that workcan be completed in 1 day. The work area is de-fined as the room in which dust removal is oc-curring or where preparations are being madefor dust removal. Interior Worksite PreparationLevel 1 is usually adequate for dust removalunless lead-contaminated carpets or area rugsare being removed.

C. Followup to Dust Removal

Inspectors or risk assessors performing clearanceexaminations should check to see that all vis-ible dust and dirt have been removed from the

Figure 11.17 Clean Air Vents Registers.

a. Vacuum and Remove Register Covers.

b. Vacuum Accessible Parts of DuctOpening.

c. Wet Wash Register Covers and Replace.

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Table 11.7 Carpet Cleaning Steps

Step Description Time/10 ft 2

1 HEPA vacuum with beater bar at a 1 minuterate no faster than 1 minute forevery 10 square feet.

2 Fold rug in half and HEPA vacuum 1 minutebottom of rug without beater barat a rate no faster than 1 minute per10 square feet.

3 HEPA vacuum bare floor and any Approximatelypadding (no rate restriction or 10–30 secondsbeater bar).

4 Fold other half of rug over and Approximatelyrepeat steps 2 and 3 (no rate 10–30 secondsrestriction and no beater bar).

5 Fold rug back over so it is in its Approximatelyoriginal position. 10–30 seconds

6 HEPA vacuum top side of rug a final 2 minutestime with the beater bar. The rateis no faster than 2 minutes per 10square feet.

Total Time 4.5–5.5minutes

dwelling, followed by dust sampling. (See Chap-ter 15 for information on clearance.) The clear-ance test results will provide a means of check-ing that lead levels have been reduced by thedust removal work and will serve as a baselinefor comparison to future test results.

Since it has been shown that lead-contami-nated dust can reaccumulate on householdsurfaces following lead-based paint abatementand dust removal alone (Charney et al., 1983;Farfel and Chisolm, 1987b; Jacobs, 1992; Clark,1993), ongoing monitoring and professionalreevaluation of the dwelling, resident educa-tion, and continued cleaning are importantelements of a dust removal plan.

Educational materials prepared by State or localgovernment agencies or lead-poisoning preven-tion organizations should explain the need forperiodic wet cleaning of household surfaces,with particular attention to dust traps and reser-voirs, and the importance of promptly inform-ing property owners or managers of needed re-pairs. Those materials should include instruc-tions for proper replacement and disposal of airconditioning and heating unit filters. Someowners and municipalities provide cleaning kitsto residents to encourage and support their on-going dust removal efforts. (See Chapter 2 andSection I of this chapter for information onresident education.)

In addition, easily cleaned walk-off mats shouldbe placed at entryways to control the trackingof leaded dust into the dwelling (see Figure11.18).

Figure 11.18 Walk-Off Mats.

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Soil Interim Control: How To Do It1. Determine if lead contamination exists by taking samples of bare soil. The soil should be considered con-

taminated if lead levels exceed 2,000 µg/g (pending an Environmental Protection Agency standard) in theyard or the building perimeter, or 400 µg/g in high-contact play areas. If bare soil levels are high (greaterthan 5,000 µg/g), interim controls are not appropriate. At least a total of 9 square feet of contaminatedbare soil must exist in each yard or building perimeter for a hazard to be identified.

2. Use water to contain dust and clean equipment to prevent dispersion of lead.

3. Select an appropriate soil interim control, which may include impermanent surface coverings or land usecontrols.

4. Impermanent surface coverings, including grass (as seed or sod), other ground covers (e.g., ivy), artificialturf, bark, mulch, and gravel, may not be permanent. If the area to be controlled is heavily traveled, surfacecoverings such as grass are not appropriate.

5. If grass is selected, consult with the local agriculture extension service or a reputable local nursery to deter-mine what grasses are appropriate for the locale, soil type, and sun/shade characteristics. Properly preparethe soil prior to seeding or sodding.

6. If bark or gravel is selected, apply the covering at least 6 to 12 inches deep. New bark, gravel, or othermaterials should not contain more than 200 µg/g of lead. These materials should be tested before use unlessprevious testing data are available.

7. If the soil is in a public recreation area, comply with Consumer Product Safety Commission standards onacceptable surface coverings in play areas.

8. Land use controls include fencing, warning signs, creation of alternative play areas (such as decking), andthorny bushes.

9. Install surface coverings and/or land use controls. For live ground covers (including grass), it is imperativethat they are properly watered during the first 3 months and adequately maintained thereafter. Automaticsprinkler systems are appropriate for large properties.

10. Control water erosion by proper grading and installation of drainage channels (drainage channels may needto be fenced if they are accessible).

11. Control wind erosion by periodic watering, windbreaks, or foot-traffic controls.

12. Provide walk-off doormats at all entryways to reduce the tracking of contaminated dust and soil into thedwelling.

13. Have a certified risk assessor or inspector technician conduct a clearance examination and provide thenecessary documentation.

Step-by-Step Summary

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14. Perform ongoing maintenance and monitoring of soil coverings and land use controls. Reevaluations ofthe surfaces should be conducted by a certified risk assessor or inspector technician based on the specificreevaluation schedule for that property.

15. If ongoing monitoring or reevaluations show that bare soil remains or reappears, interim controls are noteffective. Soil abatement should be conducted (see Chapter 12), unless other interim controls can beshown to be feasible for the specific site.


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Section V

V. Soil Interim Controls

A. Temporary and PermanentSoil Treatments

Interim control measures for lead-contaminatedsoil include surface coverings with grass, gravel,or similar materials, or land use controls, suchas fences, thorny bushes, or decks, for prevent-ing contact with the contaminated soil. Theseinterim controls are designed to temporarilyreduce exposure. How long they remain effec-tive depends on many factors, including thedurability and maintenance of the cover,degree of foot traffic, and climate.

Permanent soil abatement measures are coveredin Chapter 12, Section V. If the control mea-sure includes a permanent cover, such as asphaltor concrete, the method is classified as anabatement, whereas a temporary cover wouldconstitute an interim control measure. If thesoil contains very high amounts of lead (greaterthan 5,000 µg/g), permanent abatement strate-gies should be used.

B. Types of Interim ControlMeasures for Soil

Four categories of measures may be used as partof an interim control plan for soil. These are:

✦ Measures that alter the contaminated soil.

✦ Measures that alter the surface cover.

✦ Land use controls.

✦ Measures to reduce offsite transport of thecontaminated soil.

Each of these activities should be carried out ina manner that prevents further dispersion of thecontamination and prevents the area undergo-ing the interim control treatment from beingcontaminated in the process. Work practices forsoil interim controls are similar to those for soilabatement and are described more fully inChapter 12, Section␣V.

1. Altering Contaminated SoilInterim controls usually involve only mini-mal alterations to the soil. The installationof grass or other plantings, for example, willoften involve surface cultivation or additionof a thin layer of new soil (no more than3 inches) in order for the ground cover tobecome established.

2. Soil Surface CoverA second interim control method involves add-ing a surface covering that will act as a barrierbetween the bare, lead-contaminated soil andpeople and pets. Various types of surface cover-ings may be considered, including:

✦ Grass (either through seeding or plantingof sod).

✦ Other live ground covers (e.g., junipershrubs, ivies).

✦ Artificial turf.

✦ Bark.

✦ Gravel.

The choice of a covering for a particular areadepends on the climate, expected use, plannedmaintenance, and aesthetic preferences. Foraesthetic as well as practical reasons, a propertyowner may choose to improve the surface coverover an entire soil area even though only a por-tion is bare.

The success of grass and other live groundcovers is dependent on proper planting, regularmaintenance, and most importantly, the abilityto control the use of the area. In high-trafficareas use of grass as an interim control is un-likely to succeed. Other surface coverings suchas artificial turf may be more appropriate.Where access to an area can be controlled, orwhere use is expected to be limited, grass andother live ground covers can be successful in-terim controls. Some ground covers, such asjuniper bushes, can also effectively limit trafficthrough an area.

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Table 11.8 Grasses and Their Appropriate Applications

Grasses That Grow From Seeds Texture Climate Durability

Bahia grass Coarse Warm ExcellentColonial Bent grass Fine Cool —Creeping Bent grass Fine Cool —Common Bermuda grass Medium to Fine Warm ExcellentKentucky Bluegrass Fine Cool —Rough-Stalk Bluegrass Fine1 Cool PoorCentipede grass Medium to Fine Warm —Dichondra Coarse Warm —Chewings Fescue Fine Cool PoorCreeping Red Fescue Fine Cool PoorHard Fescue Fine Cool —Tall Fescue Coarse Cool Moderate to ExcellentAnnual Ryegrass Coarse Cool —Perennial Ryegrass Fine Cool Excellent

Grasses That Grow From Sod

Bahia grass Coarse Warm ExcellentHybrid Bermuda grass Fine Warm ExcellentKentucky Bluegrass Fine Cool —Centipede grass Medium to Fine Warm PoorDichondra Coarse Warm —Tall Fescue Coarse Cool —Seashore Paspalum Medium Warm —Perennial Ryegrass Fine Cool ExcellentSt. Augustine grass Coarse Warm —Zoysia grass Fine Warm Excellent

Before using grass or live ground covers as aninterim control measure, a property ownershould consult with a lawn care professionalabout soil preparation, appropriate grasses andplants to use, and future maintenance require-ments. The county cooperative extension ser-vice or a reputable local nursery may be con-tacted for advice on types of grass to be used inspecific geographic areas and for specific soiltypes, slope, and sunlight conditions. Table 11.8offers a brief summary of grass types and theirsuggested uses. The local office of the U.S.Department of Agriculture Soil ConservationService may also be able to provide adviceabout soil conditions in a specific geographicarea. An owner of a large property may considerinstalling a sprinkler system to improve the

maintenance effort. In any event some typeof hose and sprinkler system should be madeavailable.

When planting grass an owner should considerwhether sod or seeding is more appropriate.Both grass seed and sod require restrictions onfoot traffic until root systems and stems becomeestablished. Newly laid sod requires at least 2weeks, while grass seed requires 1 to 2 months(Lane Publishing, 1989; Maryland ExtensionService, 1993). Sod can be laid during most ofthe year (as long as the ground is not frozen)and requires less initial care. However, sod ismore expensive than seeding and is less likelyto develop the deep root systems that will allowthe grass to withstand regular wear and tear. Itis best to lay sod during the growing season.

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At least 6 inches of bark or gravel are necessaryto serve as a temporary ground covering (seeFigure 11.19). There are anecdotal reports ofhigh lead levels in replacement bark. Barkshould be tested by laboratory analysis beforeuse, unless it has been tested previously. Barkshould not be used if it contains more than200␣ µg/g of lead.

Bark or other suitable soft material should beused as surface cover for contaminated soil nearplay equipment. This will offer a degree of pro-tection from injuries that may result from fall-ing. Consumer Product and Safety Commissionregulations dealing with acceptable surface cov-erings in play areas may apply to public areas(CPSC, 1991). Decking can also be used to re-duce a child’s contact with soil, although petsshould be kept off the decking. Artificial turfcan also be used, but may cause drainage prob-lems if it is not permeable.

Rubber cushioning specifically designed forplaygrounds can also be used to cover con-taminated, bare soil in play areas.

3. Land Use ControlsTo temporarily reduce human exposure to bare,contaminated soil, the following land use con-trol measures may be considered:

✦ Fencing.

✦ Decks.

✦ Warning signs.

✦ Creation of alternative play areas forchildren.

✦ Removal of play equipment from bare areas.

✦ Educational efforts.

✦ Planting thorny or dense bushes (seeFigure 11.20).

Preventing access to the bare, contaminatedsoil by fencing is most effective if other en-trances and exits to the housing units can bemaintained for use by residents, guests, commer-cial vehicles, and emergency vehicles (see Fig-ure 11.21 a and b). Fencing may also be used

Figure 11.20 Thorny Bushes as a Land Use Control.

Figure 11.19 Bark Used as an Interim Control.

to reduce exposure during a delay in the imple-mentation of other interim control measuresor soil abatement.

Educational efforts directed towards decreasinguse of bare, lead-contaminated areas; avoidingeating or drinking in these areas; and frequentwashing of hands may serve to reduce ingestionof the contaminated soil. The decision onwhether to plant grass or erect barriers should

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be site-specific and should consider the avail-ability of alternative play areas, the location ofcontaminated soil with respect to entrances orexits, the likelihood that leaded dust may betracked onto sidewalks or directly into thehousing unit, the degree of supervision avail-able, and local preferences.

4. Drainage and Dust ControlsDrainage controls may involve directing waterflow away from the contaminated areas by alter-ations in adjacent grades and/or installationof drainage channels. Drainage channels thatreceive runoff from bare, contaminated soilareas may need to be fenced to reduce access.Dust generation can be reduced by periodicwatering, the creation of windbreaks, or foot-traffic controls.

C. Controls to MinimizeMigration of Soil Lead intoDwellings

Doormats can be used to minimize the entryof soil lead into the house. Doormats should beplaced on the exterior and immediate interiorof the entry doors. Mats should be cleaned bymachine washing or other wet methods, notby beating or sweeping. (See Section V of thischapter for further information.)

Removing shoes at the doorway also greatlyminimizes the amount of leaded soil and dusttracked into the house.

D. Monitoring and Reevaluat-ing Soil Interim Controls

If grass or sod is planted, or if bark, gravel,or other similar covering is used, it should bemonitored visually. The monitoring shouldoccur frequently immediately after installationand can be reduced thereafter.

Figure 11.21b Fencing as an Interim Control for Bare SoilHazards.

Figure 11.21a Fencing as a Soil Interim Control.

Documents

Chapter 11: Interim Controls, Guidelines for the Evaluation and