Issue link: https://hi.iaq.net/i/650064
9 PRIORITY ISSUES ASSESSMENT PROTOCOLS Minimum Actions Expanded Actions Assume there is lead-based paint in homes built before 1978 unless testing shows otherwise. Determine whether paint will be disturbed by the work or the assessment. Consider using an EPA-recognized testing method (e.g., X-ray fluorescence [XRF] testing, or an on-site test kit) on suspect surfaces that will be disturbed in order to determine whether the paint is lead-based. The lead-safe work practices minimum and expanded actions apply only to paint assumed to be or tested to confirm that it is lead-based. Relevant Guidance/Standards HUD Title 24. EPA Renovation, Repair and Painting (RRP) Program Rule: 24 CFR Part 25, subpart J. EPA Lead. EPA Lead-Based Paint Renovation, Repair, and Painting Program: Small Entity Compliance Guide to Renovate Right. If working in a pre-1978 building, see Appendix A: Worker Protection – Lead. Comply with EPA's Lead-Based Paint Renovation, Repair, and Painting (RRP) Program Rule. Among the rule's key elements are: • Use a Certified Renovator. • Follow lead-safe work practices if disturbing more than 6 ft 2 of interior or 20 ft 2 of exterior painted surfaces. • Contain the work area to avoid resident exposure. • Minimize lead dust and leave no dust or debris behind. • Achieve visual post-cleaning criteria. Comply with state and local lead-related regulations, which may be applicable to lead hazard reduction activities and may require additional certified personnel. Note This is not a complete summary of the regulatory requirements. The intent of this protocol is to promote the most health-protective steps that are feasible and practical. The minimum action recommended in this protocol is to comply with whatever the most current version of the RRP Program Rule prescribes. Relevant Guidance/Standards DOL, OSHA, Lead. EPA Renovation, Repair and Painting (RRP) Program Rule: 24 CFR Part 25, subpart J. EPA Renovation, Repair and Painting (RRP) Program Rule: 40 CFR Part 745. EPA Lead Accredited Training Programs. Follow the U.S. Department of Housing and Urban Development (HUD) lead-safe rehabilitation practices. In addition to EPA's RRP, these HUD practices: • Lower the thresholds for interior painted surface area from 6 ft 2 to 2 ft 2 . • Require repair of painted surfaces that are disturbed when using lead-safe work practices. • Require meeting lead dust clearance testing standards if more than 2 ft 2 of paint is disturbed. Note Lead dust clearance testing includes measuring for lead dust on floors, windowsills and window troughs. See NCHH Fact Sheet: Testing for Lead- Contaminated Dust. Relevant Guidance/Standards EPA Renovation, Repair and Painting (RRP) Program Rule: 24 CFR Part 25, subpart J. HUD Lead Safe Work Practices. NCHH Fact Sheet: Testing for Lead- Contaminated Dust. Inspect the interior and exterior of the building for evidence of moisture problems. Document the extent and location of the problems, and the proposed repairs, to avoid exacerbating the problems when the repairs are made. Examples of moisture and mold problems are: • Water damage or stains. • Foundation cracks that leak water. • Visible mold growth. Repair roof leaks before air sealing or insulating the attic. Address surface water pooling near the foundation before insulating basement or crawlspace walls near wet areas. Repair additional moisture problems identified during the assessment (e.g., plumbing leaks, rain leaks including leaks around windows and flashing, and foundation leaks). Retrofit crawlspaces so that they are unvented, sealed, insulated, properly drained and waterproofed, following guidance in section 1.4 of EPA's Indoor airPLUS Construction Specifications. (Continued on next page) LEAD MOISTURE (MOLD AND OTHER BIOLOGICALS)