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Historic Preservation - Technical Procedures

Spectitle:

Evaluating When Lead Paint Mitigation Is Necessary

Procedure code:

0990003S

Source:

1994 Crm, Vol.17, No. 4/1997 Windows Conference Paper

Division:

Finishes

Section:

Painting

Last Modified:

02/24/2012

Details:

Evaluating When Lead Paint Mitigation Is Necessary



EVALUATING WHEN LEAD-BASED PAINT MITIGATION IS NECESSARY


THE 1995 HOUSING AND URBAN DEVELOPMENT (HUD) GUIDELINES REGARDING
THE EVALUATION AND CONTROL OF LEAD-BASED PAINT HAZARDS WERE
DEVELOPED IN ORDER TO PROVIDE GUIDANCE IN LEAD ABATEMENT/REDUCTION
WORK REQUIRED FOR FEDERALLY ASSISTED HOUSING PROJECTS.  THOUGH
THESE GUIDELINES ARE NOT ENFORCED ON PRIVATE HOUSING PROJECTS OR
PROJECTS INVOLVING OTHER BUILDING TYPES, THEY ARE A WELL-RECOGNIZED
REFERENCE FOR MAKING BUILDINGS LEAD-SAFE, AND THEIR USE AS A
RESOURCE IS RECOMMENDED IN ANY CONSTRUCTION PROJECT REQUIRING LEAD-
REDUCTION WORK.  FOR THIS REASON, THESE GUIDELINES ARE FREQUENTLY
REFERENCED IN THIS AND OTHER RELATED PROCEDURES.


This procedure includes guidance on how to evaluate when and if
lead-based paint mitigation is necessary.  Based on the 1995 HUD
Guidelines, mitigation strategies can best be developed by asking
a few questions and evaluating the answers together with a complete
paint inspection and risk assessment.  The following adaptation
summarizes the HUD pathology and should aid in determining what
lead-reduction actions should be taken.

Was the building built before 1978?  
    The use of lead in paint was prohibited in the United States
    after 1978.
    If the building was constructed prior to 1978, it is likely
    that some, if not much of the paint used contained lead.
    HUD has estimated in a 1990 report to Congress that 90% of all
    privately owned dwellings built before 1940 had painted
    surfaces that contained lead-based paint.  A figure of 80% is
    used to summarize the lead-based paint presence in dwellings
    built between 1940 and 1959.  In dwellings built between 1960
    and 1979, the presence of lead-based paint is further reduced
    to 62%.  These statistics for housing may also be
    representative of other building types constructed during
    these time periods.

Are there any known cases of elevated blood-lead levels in building
occupants?
    Ingestion of lead-contaminated dust, is the most common means
    of developing lead-poisoning, especially in older buildings
    where dust levels are naturally higher.  Sources may include
    loose/peeling/chipping lead-based paint or lead accumulations
    in the soil.  
    Adults may become symptomatic with elevated blood-lead levels
    of 40-50 micrograms/deciliter.
    Children under the age of six are at higher risk than adults
    for exposure to low levels of lead.  Therefore, the maximum
    exposure level for children, before intervention, is 10
    micrograms/deciliter.

Is the building historic and are preservation regulations
applicable based on the age and/or significance of the structure?
    Technically, any building fifty years of age or older is
    considered historic and is POTENTIALLY eligible for listing on
    the National Register of Historic Places until it is deemed
    ineligible based on review of its qualifications.
    GSA manages a tremendous number of historic buildings
    throughout the country and has an obligation to administer
    these cultural properties under its control in a spirit of
    stewardship and trusteeship for future generations.  
    In light of the historic preservation concerns associated with
    any building (in this case, GSA buildings), a formal paint
    inspection and risk assessment should be performed by a
    trained and certified lead hazard inspector as described
    below.

Has a paint inspection and/or risk assessment been performed by a
licensed professional?
    A paint inspection investigates the presence of lead-based
    paint on a surface-by-surface basis.  Is there lead-based
    paint present, and where is it?
    A risk assessment evaluates the presence of lead-based paint
    hazards.  This includes identifying sources or potential
    sources of lead contamination (such as friction or impact
    surfaces), locating lead-based paint through testing and
    evaluation of its condition, documenting the building and
    occupant type, and assessing the risks of lead exposure based
    on the building function and occupant make-up.
    The best type of lead-based paint evaluation would combine a
    paint inspection along with a risk assessment in order to
    develop an appropriate mitigation plan.
    Evaluation techniques might include X-Ray Fluorescence
    testing(XRF) or dust-wipe sampling.  
         XRF is useful in determining potential hazardous
         conditions by inspecting the lead content of sound paint.
         Dust-wipe sampling is a method of evaluating existing
         hazards by sampling dust accumulations (typically on the
         floor, window sills and window trough) for lead content.
         The results are then compared with the dust lead level
         guidelines established by HUD to determine if the amount
         of lead measured is considered hazardous.  For floors,
         lead levels above 100 micrograms/sq. ft. is considered
         hazardous; for window sills, the hazardous level is
         anything above 500 micrograms/sq. ft.; for window
         troughs, the hazardous level is anything above 800
         micrograms/sq. ft.

What method of lead-hazard reduction is preferable and/or
acceptable by the Regional Historic Preservation Officer?  Is
abatement required or necessary, or is implementing interim
controls an acceptable strategy?
    Abatement is classified by HUD as any treatment for
    eliminating lead-based paint that is considered permanent, or
    rather, capable of lasting twenty years.  This may include any
    of the following:  Complete removal of the lead-based paint;
    removal and replacement of the lead-based paint component;
    enclosure of the component or surface; or application of an
    encapsulant coating.  For guidance on reducing lead-based
    paint hazards using abatement techniques on windows, see
    09900-02-R.
    Interim controls are temporary methods of controlling lead-
    based paint hazards and include special cleaning and dust
    removal procedures, stabilization of the existing paint film,
    and special treatment of friction and impact surfaces.  These
    less aggressive methods of lead hazard control are typically
    preferred in preservation work since more original material
    can be retained and preserved.  However, regular maintenance
    is required and necessary in order for this type of strategy
    to be successful.  For guidance on reducing lead-based paint
    hazards using interim control techniques on windows, see
    09900-03-R.
    The best approach to lead-based paint reduction usually
    involves a combination of both abatement and interim control
    techniques.  For specific guidance in combining both of these
    techniques to achieve lead hazard reduction, see 09900-04-R.
    For information on general protection measures to reference
    during lead-based paint hazard-reduction work, see 09900-10-S.
    It should be noted that the highest risks of exposure to the
    hazards of lead-based paint are generally associated with
    housing, day care facilities or other building types where
    ingestion is more likely to occur.  In these building types,
    abatement techniques may be a higher priority and may also be
    the only acceptable alternative.  Occupants of office
    environments, on the other hand, are generally at a much lower
    risk of exposure to these hazards.  In these cases, interim
    control methods would often be an acceptable mitigation
    solution.  A complete risk assessment, however, is always
    recommended and would reveal the most important factors to
    consider before making any mitigation plans.

                         END OF SECTION