Protection Measures For Lead-Based Paint Hazard-Reduction Work

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We’ve reviewed these procedures for general consistency with federal standards for rehabilitating historic buildings and provide them only as a reference. Specifications should only be applied under the guidance of a qualified preservation professional who can assess the applicability of a procedure to a particular building, project or location. References to products and suppliers serve as general guidelines and do not constitute a federal endorsement nor a determination that a product or method is the best alternative or compliant with current environmental regulations and safety standards.

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 protecting the workers, the building environment and the occupants during lead-reduction work. The most important part of any protection plan, which affects all three of these areas, is dust control. The primary source of lead-based paint poisoning comes from lead dust. The presence of lead-based paint is not considered a hazard unless the paint is in poor condition (chipping, peeling, flaking), or covers a type of surface that could present a condition for contamination, such as those considered abrasion, impact and friction surfaces, or chewable surfaces (in the case of children). Some building features are more prone to abrasion, impact or friction. These might include windows, doors, floors, stair treads, risers and balustrade, and trimwork such as baseboards chair rails and door trim.

As a direct result of the Residential Lead-Based Paint Hazard Reduction Act of 1992 (otherwise known as Title X), federal agencies including HUD, Environmental Protection Agency (EPA), and the Occupational Safety and Health Administration (OSHA) have established safety standards and training guidelines for lead abatement workers. OSHA has established regulations to protect workers from dangerous levels of lead exposure. EPA has worked with local authorities to regulate the disposal of hazardous waste. HUD has published guidelines for evaluating and controlling lead-based paint hazards in Housing - a valuable resource for evaluating lead-based paint mitigation strategies (see 09900-03-S for guidance).

Protection should focus on three primary areas: Worker protection, containment of dust and debris, and adequate clean-up of the work areas. General protection measures are listed below. For guidance as it relates more specifically to abatement or interim control techniques, see 09900-02-R, 09900-03-R and 09900-04-R.

Educating and training the workers to use "low-dust" work techniques is vital to reducing airborne dust: Proper paint removal techniques should be followed. See also 09900-02-R, 09900-03-R and 09900-04-R for guidance. Use wet sanding and wet scraping methods instead of dry methods.

Wet sanding consists of misting the surface with water followed by sanding with a sponge block saturated with de-glossing liquid. Wet scraping consists of misting the painted surface before scraping. There are also sanders available designed with integral HEPA vacuums.

Containment of airborne dust and debris is critical to reducing lead-based paint contamination:

For windows, proper containment can be accomplished by sealing the opposite side of the window on which the work is being performed and adhering one layer of plastic sheeting a minimum of five feet beyond the perimeter of the window. Proper clean-up methods are necessary to ensure that a lead-safe environment is maintained:

HEPA vacuums are recommended over dry sweeping or conventional vacuum cleaners, as the latter can spread lead dust rather than remove it from the environment.

Wet cleaning or mopping using a high phosphate cleaner, such as tri-sodium phosphate (TSP) or other cleaner designed for use on surfaces coated with lead-based paint, is recommended. See Chapter 14 of the 1995 HUD Guidelines for more detailed cleaning procedures.

For more extensive guidance concerning all construction, alteration and repair work where an employee may be occupationally exposed to lead, see the U.S. Department of Labor OSHA Regulations (Standards-29 CFR) - 1926.62 - Lead (Occupational Health and Environmental Controls).