Issue link: https://hi.iaq.net/i/655416
22 Energy Savings Plus Health | INDOOR AIR QUALITY GUIDELINES FOR MULTIFAMILY BUILDING UPGRADES PRIORITY ISSUE 3.0 LEAD ASSESSMENT PROTOCOLS (AP) MINIMUM ACTIONS (MA) EXPANDED ACTIONS (EA) AP 3.1 Determine Whether There is Lead-Based Paint Assume there is lead-based paint in multifamily residential buildings built before 1978 unless testing shows otherwise. Recognize, however, that lead-based paint may be present in any building. Note: EPA's Lead Renovation, Repair and Painting Rule (RRP Rule) requires that firms performing renovation, repair and painting projects that disturb lead- based paint in homes built before 1978 (including many of the projects envi- sioned in this document) have their firm certified by EPA (or an EPA-authorized state), use certified renovators who are trained by EPA-accredited training providers, and follow specific lead-safe work practices. If unsure whether there is lead-based paint, consider one of the following options: • Hire an RRP-certified contractor to test for lead using an EPA-recog- nized test kit (available at hardware stores). The certified contractor has been directed to follow spe- cific instructions to get accurate results. Note that testing performed by uncertified people, including landlords or property managers, is not sufficient. To learn more about EPA-recognized test kits, visit the EPA Lead Test Kits Web page. • Hire a certified professional to check for lead-based paint. A certified in- spector or risk assessor can conduct an inspection to determine whether a home or a portion of a home has lead-based paint and where it is located. • For help finding a certified risk as- sessor, inspector or RRP contractor, call the National Lead Information Center at 1-800-424-LEAD (5323). MA 3.1 Comply with EPA's Lead RRP Rule if Disturbing More Than 6 Square Feet of Interior or 20 Square Feet of Exterior Painted Surfaces Among the rule's key elements are the following: • Use a trained and certified renovator employed by a lead-safe certified firm. • Follow lead-safe work practices. • Contain the work area to avoid occu- pant exposure. • Minimize lead dust and leave no dust or debris behind. • Achieve visual post-cleaning criteria. • Comply with state and local lead-re- lated 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 in- tent of this Guide is to promote the most health-protective steps that are feasible and practical. The minimum action recommended in this Guide is to comply with whatever the most current version of the RRP Program Rule prescribes and with all local and state regulations that may apply. MA 3.2 Inform Maintenance Staff on Requirements for Lead-Safe Work Practices Inform maintenance staff that if they will be disturbing lead paint, they must be trained and certified under EPA's RRP program for lead-safe work practic- es. This includes ensuring the informa- tion distribution requirements of EPA's RRP program are met. See Small Entity Compliance Guide to Renovate Right: EPA's Lead-Based Paint Renovation, Repair, and Painting Program. EA 3.1 Comply with Expanded Re- quirements Including HUD's Lead-Safe Rehabilitation Practices and EPA Lead Hazard Standards • Follow the U.S. Department of Hous- ing and Urban Development (HUD) lead-safe rehabilitation practices. In addition to EPA's RRP Rule, these HUD practices include: o Lowered thresholds for interior painted surface area, from 6 square feet to 2 square feet. o Requirements for repair of painted surfaces that are dis- turbed when using lead-safe work practices. • Ensure that EPA lead hazard standards are met, including re- quirements for no deteriorated paint and for meeting lead dust clearance testing standards. Dust testing must be done by an EPA- or state-certified inspector or risk assessor. If the job affects an outdoor area, ensure that EPA soil hazard standards also are met. Note: Lead dust clearance testing includes measuring for lead dust on floors, windowsills and window troughs. See EPA Hazard Standards for Lead in Paint, Dust and Soil (TSCA Section 403). EA 3.2 Replace Windows Containing Lead-Based Paint Replace windows that test positive for lead-based paint, complying with EPA's RRP Rule and other regulations that may be applicable to lead hazard reduc- tion activities. See Appendix A: Worker Protection Appendix B: Property Management and Occupant Education