Lead Operations and Maintenance Program (OMP)

Transcription

1 Lead Operations and Maintenance Program (OMP) Mixed-Use Commercial Building (Former GNB Battery Manufacturing Plant) 576 Patterson Street NW Salem, Oregon Prepared for: West Salem Storage, LLC 360 Belmont Street NE Salem, Oregon August 2017 PBS Project , Phase SW CORBETT AVENUE PORTLAND, OR MAIN FAX PBSUSA.COM

2 Lead Operations and Maintenance Program West Salem Storage, LLC 576 Patterson Street NW Salem, Oregon TABLE OF CONTENTS OPERATIONS AND MAINTENANCE OVERVIEW... TAB 1 Lead Paint and Dust Overview Tenant Information Operations and Maintenance Document Scope OMP Program Manager Policies Site Specific Hazard Communication LEAD PAINT AND LEAD DUST WORK PRACTICES AND PROCEDURES... TAB 2 Lead Paint and Dust Work Practices and Procedures Training Emergency Response Periodic Surveillance Respiratory Protection Respirator Program Respirator selection Protection Levels Procedures for Controlling and Maintaining Lead-based Paints and Dust Disposal OPERATIONS AND MAINTENANCE BUILDING PLAN... TAB 3 PHOTO DOCUMENTATION... TAB 4 SAMPLE TENANT NOTIFICATION PAMPHLET... TAB 5 The lead-safe Certified Guide to Renovate Right (EPA-740-K , April 2010) SAMPLE PERIODIC INSPECTION FORM... TAB 6 OSHA REGULATIONS... TAB 7 OAR 437 Division 3 Subdivision D Lead (Construction Industry) OAR 437 Division 2 Subdivision Z Lead (General Industry) 2017 PBS Engineering and Environmental Inc. i August 2017 PBS Project Phase 0002

3 TAB 1 Operations and Maintenance Overview Lead Paint and Dust Overview Tenant Information Operations and Maintenance Document Scope OMP Program Manager Policies Site Specific Hazard Communication

4 Lead Operations and Maintenance Program West Salem Storage LLC 576 Patterson Street NW Salem, Oregon OVERVIEW The building located at 576 Patterson Street NW in Salem, Oregon, is the site of the former GNB Battery Manufacturing Plant. Lead paint, dust, and debris have been sampled and identified throughout the facility. The building owner has engaged independent contractors to perform cleaning and encapsulation remediation activities. Clearance dust wipe and air sampling (as applicable) have been performed on readily accessible areas and surfaces associated with the interior of the building. The original painted surfaces, as part of the building s interior and exterior, have had limited lead paint testing to date but should be conservatively presumed to be lead-containing. The Oregon Department of Environmental Quality, Oregon Health Authority, and Oregon Occupational Safety and Health Administration have directly overseen the remediation activities and clearance sampling and have approved tenants use of the building. For the purposes of this Operations and Maintenance Program (OMP) document, it is presumed that all new and old painted and varnished surfaces contain lead and that lead dust is present in or on wall and ceiling cavities/surfaces, abandoned equipment, electrical boxes, or other interstitial spaces. Lead paint is defined in this document as paint pertaining to original painted building components and any surfaces with LBC encapsulant and/or acrylic floor paint. TENANT INFORMATION Tenants are allowed to perform the following without restrictions. This OMP does not apply to these activities: General cleaning and housekeeping within their occupied space. Minor changes, repairs, painting, and decorating may be performed on walls marked in green shown on the building plan in Tab 3 of this OMP. Maintenance activities that do not impact painted surfaces or breach interstitial spaces, such as; changing light bulbs, fixing toilets, unclogging waste lines, replacing light switches, etc. Tenants are to contact the landlord s OMP program manager prior to all other repair, renovation, or maintenance activities that impact painted surfaces within the building. OPERATIONS AND MAINTENANCE Lead Paint and Lead Dust In 1993, Oregon Occupational Safety and Health Administration (OSHA) adopted the federal OSHA Lead in Construction Standard 29 CFR under OAR 437 Division 3 Subdivision D This standard outlines worker exposure limits, personal protection requirements, and employer responsibility for exposure assessment, training, housekeeping, and recordkeeping. OSHA s lead standard applies to all work in which employees may be exposed to lead in construction, alteration, or repair activities. This includes demolition or renovation of structures where lead-containing materials are present. Any occupational exposure to lead outside of the Construction Standard falls within the General Industry standard for Lead OAR 437 Division 2 Subdivision Z Lead Contractors and/or tenants performing demolition, selective demolition, component removal, cutting, sanding, patching, paint preparation, or other tasks on painted surfaces or potentially impacting interstitial spaces presumed to contain accumulated lead dust that could result in occupational exposures to lead, will be required to comply with applicable OSHA standards. Work requirements include, but are not limited to, communications with the building/facility owner in order to ascertain clearly the intent and scope of building material disturbance activities; initial testing; lead safe work practices; development of a written lead 1.1 August 2017 PBS Project Ph. 0002

5 Lead Operations and Maintenance Program West Salem Storage LLC 576 Patterson Street NW Salem, Oregon compliance program; lead awareness training; employee monitoring and exposure assessment; respiratory protection; designated wash facilities; and establishment of a regulated work area with signage. Copies of the Lead in Construction and General Industry standards are presented in Tab 7 of this report This OMP is intended to ensure that: Accessible lead-based paints in the facility are maintained in good condition and are not disturbed; Tenant employers and employees as well as building owner employees have minimal exposure to lead paint or dust; Appropriate control and response measures are undertaken during remodeling or disturbance activities (as applicable); and Information and knowledge of known and presumed lead hazards associated with this property and how to safely manage these materials in-place is conveyed to all responsible parties inclusive of tenant employers and employees and the public that enter the property. This document is intended to provide guidance to persons conducting operations and maintenance and remodeling activities at this particular facility. It is not intended to replace the need for proper training. Applicable OSHA regulations should be reviewed prior to remodel or renovation work that may or will disturb materials that have lead paint or lead dust. Document Scope This document provides the building owner and tenant employers with guidance in achieving an effective OMP to maintain lead paint in good condition, avoid disturbance of painted surfaces and/or lead dust that may have accumulated on surfaces and within interstitial spaces of the building, and prevent unknown or accidental disturbance. Parties responsible for enacting this OMP will be required to read this document and acknowledge by printing and signing their names and documenting the date(s) of OMP review. Additionally, responsible parties will attend appropriate training courses, and receive counsel from sources familiar with the facility. This document is not a substitute for training. Information and guidelines to assist with implementation of the OMP are gained through recommended training courses for the program manager as well as maintenance and custodial workers. This document represents the initial step in the process of full implementation of the OMP. OMP Program Manger Chris D Anderson Clutch Industries Inc. 360 Belmont Street NE Salem, Oregon chrisa@clutchindustries.com One complicated area of program implementation is understanding how much staff training is required without training everyone to be lead-based paint certified workers. The minimum requirement for lead training, as it pertains to the Construction Rule, is OSHA s Standard (l), sections 1, 2, and 3. Additional recommended training is the lead-safe work practices outlined in 40 CFR Part 745, Lead-Based Paint Renovation, Repair, and Painting (RRP) Program. For RRP training information and training visit August 2017 PBS Project Ph. 0002

6 Lead Operations and Maintenance Program West Salem Storage LLC 576 Patterson Street NW Salem, Oregon Policies A building owner should set policies that adhere to state and federal laws as a minimum, and provide specific details for their unique operation and facility. Policies should be set with input from many sources such as the building owner management, legal representation, and consultants (as applicable). Program policies apply to individuals and entities such as building engineers, maintenance personnel, janitorial staff, electricians, painters, carpenters, and other trades personnel working on or in the building who could potentially disturb lead-containing paint or dust in the course of their work. Site Specific Hazard Communication All tenant employers, tenant and building employees, and other contractors working in or on the facility must be made aware of the lead hazards associated with the building/property to assist in preventing disturbance of, or damage to, lead painted materials and/or other building materials or surfaces with lead dust. Anyone performing activities that may or will disturb lead-containing surfaces or equipment, or that access interstitial spaces or abandoned equipment of the building, are required to read this OMP and be appropriately licensed and/or accredited to perform said activities. They must comply with any and all applicable codes, rules, and regulations with jurisdiction. Additionally, personnel must or shall comply with warning labels placed on abandoned equipment and vacuum piping. There shall be no attempt to cut, remove, or access these components without specific written authorization from the building owner management and Lead OMP program manager. Specific equipment where these conditions are known to exist include (but is not necessarily limited to) the following: Abandoned vacuum piping: located in the Capital City Sports tenant space 120 suspended below the roof decking and the Roller Fitness Center tenant space 130 in the tool room loft, in ceiling trusses and within walls or interstitial spaces throughout the facility. This vacuum pipe extends through the exterior wall in the northeast side of the loft tool room and can be seen over the lower roof of Roller Fitness Center entry space 131 Metal hopper within the Capital City Sports tenant space 120 storage room and the Roller Fitness Center tool room loft space 221. Reference the Operations and Maintenance Building Plan in Tab 3 and photo documentation in Tab 4 for additional information. Heating, Ventilation, and Air Conditioning Systems All forced air heating, ventilation, and air conditioning (HVAC) systems within the building shall be fitted with filters that have a minimum efficiency reporting value (MERV) rating of 11 or higher, and changed per the manufacturer s recommendations. 1.3 August 2017 PBS Project Ph. 0002

7 TAB 2 Lead Paint and Lead Dust Work Practices and Procedures Lead Paint and Dust Work Practices and Procedures Training Emergency Response Periodic Surveillance Respiratory Protection Respirator Program Respirator selection Protection Levels Procedures for Controlling and Maintaining Lead-based Paints and Dust Disposal

8 Lead Operations and Maintenance Program West Salem Storage LLC 576 Patterson Street NW Salem, Oregon LEAD PAINT AND LEAD DUST WORK PRACTICES AND PROCEDURES The owner has elected to manage these materials in place following extensive abatement, cleaning, and encapsulation or enclosure of readily accessible surfaces and materials. Left undisturbed and properly managed, painted and varnished surfaces in good condition do not pose a concern. Damaged painted and varnished surfaces should be repaired in accordance with this document and/or applicable standard and methods, whichever is more stringent. If demolition, renovation, repair, or maintenance activities may or will impact or disturb known or suspected lead paints or lead dust, the owner and lead OMP program manager will determine appropriate courses of action needed to prevent lead dust contamination. All building occupants will be notified of the presence of lead paints and lead dust associated with the building. Tenants with small children should be warned of lead present in chewable surfaces. All existing and future tenants shall be provided the Environmental Protection Agency s (EPA) pamphlet The Lead-Safe Certified Guide to Renovate Right 1. This Pamphlet can be found in Tab 5. Additional information is available at The National Lead Information Center ( If at any time a tenant wants to create a childcare facility, that space could become a child-occupied facility as defined by 40 CFR If that were to happen, all RRP and lead-based paint activities regulations and standards would apply for that specific space. All installation or short-term repair workers (i.e., telephone, mechanical, cable, etc.) will be made aware of this document and alerted to the presence of lead paints and lead dust. The building owner and lead OMP program manager will coordinate all renovation, maintenance, or custodial lead paint or lead dust related activities and maintain documentation of such activities. Training The building owner and lead OMP program manager will be responsible for assuring that all maintenance staff, supervisors, and property managers, who may perform any of the tasks included in the OMP, attend a lead-based paint course sponsored or approved either by the EPA, Oregon Health Authority Public Health Division, or Oregon OSHA. The course must include a discussion of the effects of lead exposure, methods of identification, and state-of-the-art abatement and management procedures. Records must be maintained of certification of successful course completion. The minimum requirement for lead training as it pertains to the Construction Rule is OSHA s Standard (l), sections 1, 2, and 3. Additional recommended training would be the Renovation, Repair, and Painting (RRP) course in 40 CFR Part 745. An RRP certified renovator could do on-the-job lead-safe work practice training of non-certified renovators. For RRP training and certification information visit Emergency Response In the event of an accidental disturbance and release, the responsible party and tenants within the affected area are to vacate the area immediately. The responsible party is to then immediately contact the lead OMP program manager and building owner or owner s representative. The lead OMP program manager (with the assistance of an independent third-party consultant) will contact a qualified lead abatement firm to conduct the response. At completion of the response, the independent third-party consultant will collect clearance dust wipe samples and report the results to the Department of Environmental Quality (DEQ) clean-up department in Salem. 2.1 August 2017 PBS Project No Ph. 0002

9 Lead Operations and Maintenance Program West Salem Storage LLC 576 Patterson Street NW Salem, Oregon Periodic Surveillance A certified lead inspector/risk assessor must complete a thorough inspection of painted or encapsulated surfaces one month after application and again in six months. All readily accessible surfaces and building components shall be inspected on an annual basis thereafter. A periodic inspection shall also be performed when renovation or alterations to the building occur or if there is a change of a tenant employer. The inspector must assess the condition of painted surfaces for damage or peeling. Such surfaces must be remediated using appropriate methods that will not release lead paint chips or dust into the environment in an uncontrolled fashion. When building tenant areas or spaces are vacant, painted surfaces must be inspected, repaired, and either repainted or washed. Carpets or mats must be steam-cleaned or HEPA vacuumed. The building owner and designated lead OMP program manager shall maintain the inspection schedule as previously described for the duration of ownership. A sample periodic inspection form is presented in Tab 6 of this report. Respiratory Protection All activities or operations that disturb lead-painted surfaces or building components that contain lead, inclusive of abandoned equipment and interstitial spaces that may or will contain lead dust, will require compliance with any and all codes, rules, and regulations with jurisdiction as it pertains to respiratory protection as well as this OMP until an exposure assessment is performed. Engineering controls and industry standard work practices are the primary means of protecting workers; however, these controls are often not sufficient to control exposure, and airborne lead concentrations may be high or vary widely. Respirators must often be used to supplement engineering controls and work practices whenever these controls are technologically incapable of reducing worker exposures to lead at, or below, 50 μg/m 3. Respirator Program A written respirator program must be established for all personnel disturbing internal building components that contain lead. In Oregon, OAR Lead Respiratory Protection Program applies. The employer must implement a respiratory protection program in accordance with Division 2/I, (b) through (d) (except (d)(1)(iii)), and (e) through (m) and (o), which covers each employee required by Division 3/D, Lead, to use a respirator. NOTE: This is in addition to other respiratory protection and medical surveillance requirements specified in the lead rules. Respirator Selection Lead concentrations may vary substantially throughout a work shift as well as from day-to-day. The highest anticipated lead concentration is to be used in the initial selection of an appropriate respirator. The Assigned Protection Factors table for lead aerosols provides specific recommendations for the type of respirator to use when the actual workplace exposure reaches a certain multiple of a 50 μg/m 3 permissible exposure limit (PEL). When an employer finds that exposures are lower or higher by personal air monitoring, respirator selection can be adjusted accordingly. 2.2 August 2017 PBS Project No Ph. 0002

10 Lead Operations and Maintenance Program West Salem Storage LLC 576 Patterson Street NW Salem, Oregon In addition, if exposure monitoring or experience indicates airborne exposures to contaminants other than lead, such as solvents or polyurethane coatings, these exposures must be considered when selecting respiratory protection. A reevaluation of the respiratory protection program and work practices is required when a worker demonstrates a continued increase in blood lead levels. Type of Respirator 1, 2 Assigned Protection Factors Quarter Mask Half Mask Full Facepiece Helmet / Hood 1. Air-Purifying Respirator Powered Air-Purifying Respirator (PAPR) 50 1,000 25/1, Loose- Fitting Facepiece 3. Supplied-Air Respirator (SAR) or Airline Respirator Demand mode Continuous flow mode Pressure-demand or other positive-pressure mode , /1, Self-Contained Breathing Apparatus (SCBA) Demand mode Pressure-demand or other positive-pressure mode (e.g., open/closed circuit) , ,000 Notes: 1. Employers may select respirators assigned for use in higher workplace concentrations of a hazardous substance, for use at lower concentrations of that substance, or when required respirator use is independent of concentration. 2. The assigned protection factors in the table are only effective when the employer implements a continuing effective respirator program as required by this section (29 CFR ), including training, fit testing, maintenance, and use requirements. 3. This APF category includes filtering face pieces, and half masks with elastomeric face pieces. 4. The employer must have evidence provided by the respirator manufacturer that testing of these respirators demonstrates performance at a level of protection of 1,000 or greater to receive an APF of 1,000. This level of performance can best be demonstrated by performing a WPF or SWPF study or equivalent testing. Absent such testing, all other PAPRs and SARs with helmets/hoods are to be treated as loose-fitting face piece respirators, and receive an APF of These APFs do not apply to respirators used solely for escape. For escape respirators used in association with specific substances covered by 29 CFR 1910 subpart Z, employers must refer to the appropriate substance-specific standards in that subpart. Escape respirators for other IDLH atmospheres are specified by 29 CFR (d)(2)(ii). Protection levels A respirator must be selected that will provide adequate protection to the wearer. According to OSHA regulations, no worker shall be exposed to over 50 micrograms per cubic meter (50 μg/m 3 ) over an eight-hour time-weighted average. When an employee is exposed to lead for more than eight hours in any work day, the time-weighted average (TWA) for that day shall be reduced according to the following formula: Maximum Permissible Limit (in μg/m 3 ) = 400/number of hours worked in that day. 2.3 August 2017 PBS Project No Ph. 0002

11 Lead Operations and Maintenance Program West Salem Storage LLC 576 Patterson Street NW Salem, Oregon Procedures for Controlling and Maintaining Lead-Based Paints and Dust All activities disturbing lead paints or building components that contain lead will require meeting the protocol of the OMP and until a negative exposure assessment is performed, respiratory protection is required using any type of respirator previously listed, as applicable, based on personal monitoring results. The following subsections provide options for task-specific engineering controls: Custodial Activities Minimum custodial lead paint and dust activity controls include using wet manual methods and a HEPA vacuum and wet disposable cloth. Waste material must be packaged in leak-tight containers. Maintenance Activities and Engineering Controls Maintenance activities that impact painted surfaces or breach interstitial spaces may include (but are not limited to) plumbing repairs, equipment maintenance, and installing or changing electrical components. Notifying affected and adjacent tenants of any pending project as part of this OMP is required as an administrative control. Project specific planning is required prior to beginning any work that may disturb lead paint or dust. Minimum engineering controls include: Placing a disposable drop cloth in the work area. Regulating and demarcating the area with appropriate signage and warning tape. Using wet manual methods when cleaning. Collecting debris using a HEPA vacuum and wet disposable cloth. Packaging waste material for disposal in leak-tight containers. Manual Demolition Associated with Renovation or Repair Engineering Controls Prior to beginning any work, project-specific planning is required to minimize disturbance to lead paint or dust and the associated occupational exposures. Minimum controls include: Performing all work practices per OAR 437 Division 3 Subdivision D , as applicable. Performing all work in a negative-pressure enclosure (containment). Designing the containment structure to optimize the flow of ventilation air past the worker(s) so that the airborne concentration of lead is reduced. Maintaining the affected area under negative pressure to reduce potential lead-dust contamination of areas outside the enclosure. Equipping the containment structure with dust collection and an air filtration device (AFD) to control particulate matter emissions to the environment. Regulating and demarcating the area with appropriate signage and warning tape. Using wet, manual methods. Collecting debris using a HEPA vacuum and wet, disposable cloth. Packaging waste material for disposal in leak-tight containers. Hand Scraping and Wet Sanding of Lead-Based Paint Engineering Controls Prior to beginning any work, project specific planning is required to minimize disturbance to lead paint or dust and the associated occupational exposures. Minimum controls include: Placing a disposable drop cloth in the work area. 2.4 August 2017 PBS Project No Ph. 0002

12 Lead Operations and Maintenance Program West Salem Storage LLC 576 Patterson Street NW Salem, Oregon Regulating and demarcating the area with appropriate signage and warning tape. Using wet manual methods. Collecting debris using a HEPA vacuum and wet, disposable cloth. Packaging waste material for disposal in leak-tight containers. Disposal All generated waste as a result of any work associated with this OMP will be required to be maintained in appropriate packaging, and sampled and tested via the toxicity characteristic leaching procedure (TCLP). Any waste containers generating TCLP results of 5.0 parts per million (ppm) will be transferred to an approved dumpster, removed from the site, and disposed of properly. The building owner will be required to maintain records including a waste shipment record or disposal manifest and all other appropriate project related documentation. According to DEQ s Hazardous Waste/Toxics Reduction Policy Clarification, disposal of building demolition waste coated with lead-based paint generally will not require a hazardous waste determination (i.e., TCLP testing) if demolition debris is disposed of at a DEQ-permitted solid waste landfill that meets the current design standards for municipal solid waste disposal facilities of 40 CFR Part 258. Refer to the DEQ hazardous waste reduction policy and follow all requirements under Oregon DEQ, Management of Building Demolition Waste, A for proper disposal of lead-based paint demolition waste. EPA and Resource Conservation and Recovery Act (RCRA) regulations require concentrated or dust-laden lead waste from the remediation activities to have TCLP testing. All such wastes shall be characterized using the TCLP for lead as specified in ASTM Method E1908. TCLP results above the regulatory limit of 5.0 ppm will be handled as hazardous waste. If testing confirms leachable lead at or above 5.0 ppm, disposal at a Subtitle C landfill is required. Hazard communication and sample results should accompany any building components that are recycled. 2.5 August 2017 PBS Project No Ph. 0002

13 TAB 3 Operations and Maintenance Building Plan

14

15 TAB 4 Photo Documentation

16 Lead Operations and Maintenance Program West Salem Storage, LLC 576 Patterson Street NW Salem, Oregon Photo 1. Little Lois Storage Room, Suite 110B. White LBC encapsulated ceiling, trusses, beams, plumbing, electrical, and concrete wall. Treat all old and new painted surfaces as lead-based paint. Photo 2. Xicha Brewery Suite 141. Black LBC encapsulated ceiling, trusses, beams, plumbing, and electrical. Treat all old and new painted surfaces as lead-based paint. 1 June 2017 PBS Project No Ph.0002

17 Lead Operations and Maintenance Program West Salem Storage, LLC 576 Patterson Street NW Salem, Oregon Photo 3. Xicha Brewery Suite 140. Exterior. Treat all old and new painted surfaces as lead-based paint. Photo 4. Crossfit, Suite 180. White LBC encapsulated ceiling, trusses, beams, plumbing, and electrical. Tan LBC encapsulated concrete wall and wood beams. Treat all old and new painted surfaces as lead-based paint. 2 June 2017 PBS Project No Ph.0002

18 Lead Operations and Maintenance Program West Salem Storage, LLC 576 Patterson Street NW Salem, Oregon Photo 5. Lois Storage, Suite 110B. Gray acrylic floor paint. Treat all old and new painted surfaces as lead-based paint. Photo 6. Capital City Sports, Suite 120. Abandon vacuum pipe with lead dust contamination inside. Do not attempt to cut, remove, or gain access inside this pipe. 3 June 2017 PBS Project No Ph.0002

19 Lead Operations and Maintenance Program West Salem Storage, LLC 576 Patterson Street NW Salem, Oregon Photo 7. Capital City Sports, Suite 120, Storage Room. Abandoned mechanical hopper with lead dust contamination inside. Do not attempt to cut, remove, or gain access inside this equipment. Photo 8. Roller Fitness of Salem, Suite 221, Second Floor Storage Room. Abandoned mechanical hopper with lead dust contamination inside. Do not attempt to cut, remove or gain access inside this equipment. 4 June 2017 PBS Project No Ph.0002

20 Lead Operations and Maintenance Program West Salem Storage, LLC 576 Patterson Street NW Salem, Oregon Photo 9. Roller Fitness of Salem Suite 130. Abandoned vacuum pipe with lead dust contamination inside. Do not attempt to cut, remove, or gain access inside this pipe. Photo 10. Capital City Sports Suite 120. Enclosed trusses with lead contamination inside. Do not access or modify these enclosures without training, respiratory protection, and negative pressure containment. 5 June 2017 PBS Project No Ph.0002

21 Lead Operations and Maintenance Program West Salem Storage, LLC 576 Patterson Street NW Salem, Oregon Photo 11. Crossfit Gym Suite 160. Enclosed beam pocket with lead contamination inside. Do not access or modify these enclosures without training, respiratory protection, and negative pressure containment. Photo 12. Xicha Brewery, Suite 200, Second Floor Offices. Mixed new and old walls and hard lid ceilings. Lead dust contamination may be present within the interstitial spaces behind them. Do not access or modify these walls or ceiling without training, respiratory protection, and negative pressure containment. 6 June 2017 PBS Project No Ph.0002

22 Lead Operations and Maintenance Program West Salem Storage, LLC 576 Patterson Street NW Salem, Oregon Photo 13. Commons Offices North of Xicha Brewery. Mixed new and old walls and hard lid ceilings above lay-in ceilings. Lead dust contamination may be present within the interstitial spaces behind them. Do not access or modify these walls or ceilings without training, respiratory protection, and negative pressure containment. Photo 14. Commons Restrooms North of Xicha Brewery. Mixed new and old walls and hard lid ceilings above lay-in ceilings. Lead dust contamination may be present within the interstitial spaces behind them. Do not access or modify these walls or ceilings without training, respiratory protection, and negative pressure containment. 7 June 2017 PBS Project No Ph.0002

23 TAB 5 Sample Tenant Notification Pamphlet The Lead-Safe Certified Guide to Renovate Right (EPA-740-K , April 2010)

24 The Lead-Safe Certified Guide to Renovate right LEAD (5323) EPA-740-K April 2010 Important lead hazard information for families, child care providers and schools. LEAD-SAFE CERTIFIED FIRM

25 It s the Law! Federal law requires contractors that disturb painted surfaces in homes, child care facilities and schools, built before 1978 to be certified and follow specific work practices to prevent lead contamination. Always ask to see your contractor s certification. Federal law requires that individuals receive certain information before renovating more than six square feet of painted surfaces in a room for interior projects or more than twenty square feet of painted surfaces for exterior projects or window replacement or demolition in housing, child care facilities and schools built before Homeowners and tenants: renovators must give you this pamphlet before starting work. Child care facilities, including preschools and kindergarten classrooms, and the families of children under six years of age that attend those facilities: renovators must provide a copy of this pamphlet to child care facilities and general renovation information to families whose children attend those facilities.

26 Who Should Read This Pamphlet? This pamphlet is for you if you: Reside in a home built before Own or operate a child care facility, including preschools and kindergarten classrooms, built before 1978, or Have a child under six years of age who attends a child care facility built before You will learn: Basic facts about lead and your health. How to choose a contractor, if you are a property owner. What tenants, and parents/guardians of a child in a child care facility or school should consider. How to prepare for the renovation or repair job. What to look for during the job and after the job is done. Where to get more information about lead. This pamphlet is not for: Abatement projects. Abatement is a set of activities aimed specifically at eliminating lead or lead hazards. EPA has regulations for certification and training of abatement professionals. If your goal is to eliminate lead or lead hazards, contact the National Lead Information Center at LEAD (5323) for more information. Do-it-yourself projects. If you plan to do renovation work yourself, this document is a good start, but you will need more information to complete the work safely. Call the National Lead Information Center at LEAD (5323) and ask for more information on how to work safely in a home with lead-based paint. Contractor education. Contractors who want information about working safely with lead should contact the National Lead Information Center at LEAD (5323) for information about courses and resources on lead-safe work practices. 1

27 Renovating, Repairing, or Painting? Lead and Your Health Is your home, your building, or the child care facility or school your children attend being renovated, repaired, or painted? Was your home, your building, or the child care facility or school where your children under six years of age attend built before 1978? If the answer to these questions is YES, there are a few important things you need to know about lead-based paint. This pamphlet provides basic facts about lead and information about lead safety when work is being done in your home, your building or the child care facility or school your children attend. The Facts About Lead Lead can affect children s brains and developing nervous systems, causing reduced IQ, learning disabilities, and behavioral problems. Lead is also harmful to adults. Lead in dust is the most common way people are exposed to lead. People can also get lead in their bodies from lead in soil or paint chips. Lead dust is often invisible. Lead-based paint was used in more than 38 million homes until it was banned for residential use in Projects that disturb painted surfaces can create dust and endanger you and your family. Don t let this happen to you. Follow the practices described in this pamphlet to protect you and your family. Lead is especially dangerous to children under six years of age. Lead can affect children s brains and developing nervous systems, causing: Reduced IQ and learning disabilities. Behavior problems. Even children who appear healthy can have dangerous levels of lead in their bodies. Lead is also harmful to adults. In adults, low levels of lead can pose many dangers, including: High blood pressure and hypertension. Pregnant women exposed to lead can transfer lead to their fetuses. Lead gets into the body when it is swallowed or inhaled. People, especially children, can swallow lead dust as they eat, play, and do other normal hand-to-mouth activities. People may also breathe in lead dust or fumes if they disturb lead-based paint. People who sand, scrape, burn, brush or blast or otherwise disturb lead-based paint risk unsafe exposure to lead. What should I do if I am concerned about my family s exposure to lead? Call your local health department for advice on reducing and eliminating exposures to lead inside and outside your home, child care facility or school. Always use lead-safe work practices when renovation or repair will disturb painted surfaces. A blood test is the only way to find out if you or a family member already has lead poisoning. Call your doctor or local health department to arrange for a blood test. For more information about the health effects of exposure to lead, visit the EPA lead website at or call LEAD (5323). There are other things you can do to protect your family every day. Regularly clean floors, window sills, and other surfaces. Wash children s hands, bottles, pacifiers, and toys often. Make sure children eat a healthy, nutritious diet consistent with the USDA's dietary guidelines, that helps protect children from the effects of lead. Wipe off shoes before entering house. 2 3

28 Where Does the Lead Come From? Checking Your Home for Lead-Based Paint Dust is the main problem. The most common way to get lead in the body is from dust. Lead dust comes from deteriorating lead-based paint and lead-contaminated soil that gets tracked into your home. This dust may accumulate to unsafe levels. Then, normal hand to-mouth activities, like playing and eating (especially in young children), move that dust from surfaces like floors and window sills into the body. Home renovation creates dust. Common renovation activities like sanding, cutting, and demolition can create hazardous lead dust and chips. Proper work practices protect you from the dust. The key to protecting yourself and your family during a renovation, repair or painting job is to use lead-safe work practices such as containing dust inside the work area, using dust-minimizing work methods, and conducting a careful cleanup, as described in this pamphlet. Other sources of lead. Remember, lead can also come from outside soil, your water, or household items (such as lead-glazed pottery and lead crystal). Contact the National Lead Information Center at LEAD (5323) for more information on these sources. Age of Homes Between Between Before 1940 Percentage of Homes Likely to Contain Lead 24% 69% 87% Older homes, child care facilities, and schools are more likely to contain lead-based paint. Homes may be single-family homes or apartments. They may be private, governmentassisted, or public housing. Schools are preschools and kindergarten classrooms. They may be urban, suburban, or rural. You have the following options: You may decide to assume your home, child care facility, or school contains lead. Especially in older homes and buildings, you may simply want to assume lead-based paint is present and follow the lead-safe work practices described in this brochure during the renovation, repair, or painting job. You can hire a certified professional to check for lead-based paint. These professionals are certified risk assessors or inspectors, and can determine if your home has lead or lead hazards. A certified inspector or risk assessor can conduct an inspection telling you whether your home, or a portion of your home, has lead-based paint and where it is located. This will tell you the areas in your home where lead-safe work practices are needed. A certified risk assessor can conduct a risk assessment telling you if your home currently has any lead hazards from lead in paint, dust, or soil. The risk assessor can also tell you what actions to take to address any hazards. For help finding a certified risk assessor or inspector, call the National Lead Information Center at LEAD (5323). You may also have a certified renovator test the surfaces or components being disturbed for lead using a lead test kit. Test kits must be EPA-recognized and are available at hardware stores. They include detailed instructions for their use. 4 5

29 For Property Owners For Tenants and Families of Children Under Six years of age in Child Care Facilities and Schools You have the ultimate responsibility for the safety of your family, tenants, or children in your care. This means properly preparing for the renovation and keeping persons out of the work area (see p. 8). It also means ensuring the contractor uses lead-safe work practices. Federal law requires that contractors performing renovation, repair and painting projects that disturb painted surfaces in homes, child care facilities, and schools built before 1978 be certified and follow specific work practices to prevent lead contamination. Make sure your contractor is certified, and can explain clearly the details of the job and how the contractor will minimize lead hazards during the work. You can verify that a contractor is certified by checking EPA s website at epa.gov/getleadsafe or by calling the National Lead Information Center at LEAD (5323). You can also ask to see a copy of the contractor s firm certification. Ask if the contractor is trained to perform lead-safe work practices and to see a copy of their training certificate. Ask them what lead-safe methods they will use to set up and perform the job in your home, child care facility or school. Ask for references from at least three recent jobs involving homes built before 1978, and speak to each personally. Always make sure the contract is clear about how the work will be set up, performed, and cleaned. Share the results of any previous lead tests with the contractor. You should specify in the contract that they follow the work practices described on pages 9 and 10 of this brochure. The contract should specify which parts of your home are part of the work area and specify which lead-safe work practices will be used in those areas. Remember, your contractor should confine dust and debris to the work area and should minimize spreading that dust to other areas of the home. The contract should also specify that the contractor will clean the work area, verify that it was cleaned adequately, and re-clean it if necessary. You play an important role ensuring the ultimate safety of your family. This means properly preparing for the renovation and staying out of the work area (see p. 8). Federal law requires that contractors performing renovation, repair and painting projects that disturb painted surfaces in homes built before 1978 and in child care facilities and schools built before 1978, that a child under six years of age visits regularly, to be certified and follow specific work practices to prevent lead contamination. The law requires anyone hired to renovate, repair, or do painting preparation work on a property built before 1978 to follow the steps described on pages 9 and 10 unless the area where the work will be done contains no lead-based paint. If you think a worker is not doing what he is supposed to do or is doing something that is unsafe, you should: Contact your landlord. Call your local health or building department, or Call EPA's hotline LEAD (5323). If you are concerned about lead hazards left behind after the job is over, you can check the work yourself (see page 10). If you think a worker is not doing what he is supposed to do or is doing something that is unsafe, you should: Direct the contractor to comply with regulatory and contract requirements. Call your local health or building department, or Call EPA's hotline LEAD (5323). If your property receives housing assistance from HUD (or a state or local agency that uses HUD funds), you must follow the requirements of HUD s Lead-Safe Housing Rule and the ones described in this pamphlet. 6 7

30 Preparing for a Renovation During the Work The work areas should not be accessible to occupants while the work occurs. The rooms or areas where work is being done may need to be blocked off or sealed with plastic sheeting to contain any dust that is generated. Therefore, the contained area may not be available to you until the work in that room or area is complete, cleaned thoroughly, and the containment has been removed. Because you may not have access to some areas during the renovation, you should plan accordingly. You may need: Alternative bedroom, bathroom, and kitchen arrangements if work is occurring in those areas of your home. A safe place for pets because they too can be poisoned by lead and can track lead dust into other areas of the home. A separate pathway for the contractor from the work area to the outside in order to bring materials in and out of the home. Ideally, it should not be through the same entrance that your family uses. A place to store your furniture. All furniture and belongings may have to be moved from the work area while the work is being done. Items that can t be moved, such as cabinets, should be wrapped in plastic. To turn off forced-air heating and air conditioning systems while the work is being done. This prevents dust from spreading through vents from the work area to the rest of your home. Consider how this may affect your living arrangements. You may even want to move out of your home temporarily while all or part of the work is being done. Child care facilities and schools may want to consider alternative accommodations for children and access to necessary facilities. Federal law requires contractors that are hired to perform renovation, repair and painting projects in homes, child care facilities, and schools built before 1978 that disturb painted surfaces to be certified and follow specific work practices to prevent lead contamination. The work practices the contractor must follow include these three simple procedures, described below: 1. Contain the work area. The area must be contained so that dust and debris do not escape from that area. Warning signs must be put up and plastic or other impermeable material and tape must be used as appropriate to: Cover the floors and any furniture that cannot be moved. Seal off doors and heating and cooling system vents. These will help prevent dust or debris from getting outside the work area. 2. avoid renovation methods that generate large amounts of lead-contaminated dust. Some methods generate so much lead-contaminated dust that their use is prohibited. They are: Open flame burning or torching. Sanding, grinding, planing, needle gunning, or blasting with power tools and equipment not equipped with a shroud and HEPA vacuum attachment. Using a heat gun at temperatures greater than 1100 F. There is no way to eliminate dust, but some renovation methods make less dust than others. Contractors may choose to use various methods to minimize dust generation, including using water to mist areas before sanding or scraping; scoring paint before separating components; and prying and pulling apart components instead of breaking them. 3. Clean up thoroughly. The work area should be cleaned up daily to keep it as clean as possible. When all the work is done, the area must be cleaned up using special cleaning methods before taking down any plastic that isolates the work area from the rest of the home. The special cleaning methods should include: Using a HEPA vacuum to clean up dust and debris on all surfaces, followed by Wet wiping and wet mopping with plenty of rinse water. When the final cleaning is done, look around. There should be no dust, paint chips, or debris in the work area. If you see any dust, paint chips, or debris, the area must be re-cleaned. 8 9

31 For Property Owners: After the Work is Done For Additional Information When all the work is finished, you will want to know if your home, child care facility, or school has been cleaned up properly. Here are some ways to check. Ask about your contractor s final cleanup check. Remember, lead dust is often invisible to the naked eye. It may still be present even if you cannot see it. The contractor must use disposable cleaning cloths to wipe the floor of the work area and compare them to a cleaning verification card to determine if the work area was adequately cleaned. To order a cleaning verification card and detailed instructions visit the EPA lead website at or contact the National Lead Information Center at LEAD (5323) or visit their website at You also may choose to have a lead-dust test. Lead-dust tests are wipe samples sent to a laboratory for analysis. You should specify in your contract that a lead-dust test will be done. In this case, make it clear who will do the testing. Testing should be done by a lead professional. If you choose to do the testing, some EPA-recognized lead laboratories will send you a kit that allows you to collect samples and send them back to the lab for analysis. Contact the National Lead Information Center at LEAD (5323) for lists of qualified professionals and EPA-recognized lead labs. If your home, child care facility, or school fails the dust test, the area should be re-cleaned and tested again. Where the project is done by contract, it is a good idea to specify in the contract that the contractor is responsible for re-cleaning if the home, child care facility, or school fails the test. You may need additional information on how to protect yourself and your children while a job is going on in your home, your building, or child care facility. The National Lead Information Center at LEAD (5323) or can tell you how to contact your state, local, and/or tribal programs or get general information about lead poisoning prevention. State and tribal lead poisoning prevention or environmental protection programs can provide information about lead regulations and potential sources of financial aid for reducing lead hazards. If your state or local government has requirements more stringent than those described in this pamphlet, you must follow those requirements. Local building code officials can tell you the regulations that apply to the renovation work that you are planning. State, county, and local health departments can provide information about local programs, including assistance for lead-poisoned children and advice on ways to get your home checked for lead. The National Lead Information Center can also provide a variety of resource materials, including the following guides to lead-safe work practices. Many of these materials are also available at Steps to Lead Safe Renovation, Repair and Painting. Protect Your Family from Lead in Your Home Lead in Your Home: A Parent s Reference Guide For the hearing impaired, call the Federal Information Relay Service at to access any of the phone numbers in this brochure