On November 16th, IEE held a seminar discussing the changes to CLPPP's Massachusetts Deleading Regulations...effective this Friday, December 1st!!!

Transcription

1 CHANGES TO MASSACHUSETTS DELEADING REGULATIONS EFFECTIVE DECEMBER 1ST!!! On November 16th, IEE held a seminar discussing the changes to CLPPP's Massachusetts Deleading Regulations...effective this Friday, December 1st!!! Below are answers to the questions that came up during the seminar. The answers are in white. 1. Metal hinges and Strike plates on wooden doors need to be deleaded as Friction, but Metal doors and metal jambs (including hinges) only

2 have an intact standard? Or did I misunderstand this and metal door systems are Friction. I would think this Friction/metal rule should be consistent to all metal surfaces. 1. They must be intact. Metal hardware (such as hinges, strike plate, doorknobs, cabinet pulls, window locks) on surfaces/components has never been treated as a separate surface/architectural component. They don't need to be tested or deleaded, but if the door or door jamb is lead they must be intact 2. Interior and exterior masonry window sills, handrails and railing caps of stone, brick, tile, concrete, cement, or stucco, do not need to be deleaded as accessible/mouthable surfaces? 1. Correct 3. When is the bottom edge of the door Friction? 1. When the door opens over a stair system or lower landing 4. Friction Door edge and jamb - Encapsulants: Prohibited surfaces; if a friction door edge and door jamb are scraped bare -can still use encapsulant on the entire door and entire jamb as a paint coating? 1. Once the friction door edge and door jambs have been scraped they would be repainted. You can use any paint or stain, including encapsulant products. Note that this is really not encapsulation. The rest of the door and door jamb would only need to be intact so if you wanted to use an encapsulant, you could. Don't make it confusing by talking about encapsulation in any other way other than as a method of deleading. 5. Sealing Floors: 1. Please confirm that any paint/coating/sealer (including latex paints) may be used to seal leaded floors that are made intact. 1. Any Paint or other coating but not wax. 2. Also, please confirm that leaded floors that are intact at the time of the initial inspection may be sealed with leaded floors that are made intact. 1. Not required, but intact leaded floors can also be sealed with paint or coating, not wax. 6. Rolling garage doors are similar to bi-fold doors, but the folds are horizontal. If the garage is deleaded as an interior room (pass-through to house) are these Friction? I realize the edges would most likely be friction, but I am asking about the folds. 1. It's not impact and it moves so it would have to be deleaded as friction. 7. Common area stairs

3 1. When deleading the 1 st floor unit of a 3 family. The railing cap on the 2 nd floor hall level does not need to be deleaded with the 1 st floor stairs. 1. yes 2. Stop at the newel post where you would step onto the 2 nd floor hall. 1. yes 3. Also, all lead paint 1 floor above (i.e. the 2 nd floor hall and stairs to 3 rd floor) still needs to be intact, correct? 1. Standing on the first floor you look up. If you see loose paint (which can fall to 1 st floor) it needs to be made intact. You do not go up to second floor hallway and look for loose. 4. Exterior stairs (i.e. to a 2 nd floor apartment) would fall under the same rule as the interior stairs. 1. yes ***New CLPPP regulations go into effect on Friday 12/1 for Inspectors and Deleading projects*** Additionally, here is a brief overview of the changes for those that have not seen them yet... When Do the Changes Go into Effect? All changes go into Effect December 1, 2017 Deleading work that began before December 1, 2017 can be completed to the abatement standards in place at the time of the deleading notification if: 1. The submitted deleading notification includes the "start work date" prior to 12/1/17; and 2. The work is completed and passes a final deleading re-inspection on or before January 1, What are the Changes to Deleading Requirements? Accessible, Mouthable Surfaces The following must be deleaded: Window sills that are 5 feet or less from a floor, stair tread, or ground Hand rails and railing caps Surfaces like baseboards, door and window casings, and outside corners of walls that are in good condition no longer require deleading. Friction Surfaces Doors (edges), door jambs, and stair treads are lead hazards. They must be deleaded at all points of potential friction where the components meet. Stair treads need to be abated in their entirety from the balusters to the wall - or they can be covered. What are the Changes to Acceptable Deleading Methods and Re-

4 inspection Requirements? Encapsulation: Can now be used for Exterior Accessible, Mouthable Surfaces if: 1) The existing paint or coating is well adhered and 2) The surfaces assessment requirements are met. Repainting/Sealing: Floors where loose lead paint was made intact for compliance must be repainted and pass a dust wipe sample (alternatively, these surfaces can be covered). Coating Removal Using Chemicals: All doors and woodwork where chemical stripping, including off-site dipping, was utilized, will now be subject to re-inspection to ensure that the components are repainted prior to occupancy. If you need any job-specific guidance or have any other questions regarding these changes and how they may affect you, IEE offers consulting services and we would be happy to assist you. Please call IEE at (978) ATTENTION ROOFERS... Do you know that if you are working on a roof that

5 contains asbestos, you need training? Anyone working on the roof needs to take an 8 Hour Asbestos Class II Roofing course, and the on-site supervisor(s) overseeing the project need(s) to take a 40 Hour Asbestos Contractor/Supervisor course. Do you have questions or would you like to set up a course? Please call Lauren Russo, Sales/Marketing Manager, IEE (978) x234 UPCOMING COURSES 8 HOUR ASBESTOS CONTRACTOR/SUPVR REF 12/2,12/8,12/15,12/22 8 HOUR DELEADER CONTRACTOR/SUP/WRKR REF 12/2,12/15,12/27 40 HOUR ASBESTOS CONTRACTOR/SUPERVISOR 12/4-12/8 40 HOUR ASBESTOS PROJECT MONITOR 12/4-12/8 8 HOUR ASBESTOS PROJECT MONITOR REF 12/19 32 HOUR DELEADER CONTRACTOR/SUPERVISOR 12/11-12/14 24 HOUR DELEADER WORKER 12/11-12/13 8 HOUR MA LEAD-SAFE RENOVATOR- SUPERVISOR 12/2,12/12,12/26 4 HOUR MA LEAD-SAFE RENOVATOR- SUPVR REF 12/5 4 HOUR MODERATE RISK DELEADING OPTION *PREREQUISITE 12/29 12 HOUR MA CONSTRUCTION SUPVR CONTINUING ED 12/13&12/14 40 HOUR HAZARDOUS WASTE OPERATIONS 12/18-12/22 8 HOUR HAZARDOUS WASTE OPERATIONS REF 12/20 24 HOUR ASBESTOS INSPECTOR 12/18-12/20 8 HOUR ASBESTOS COORDINATOR/LEA DES. PERSON 12/18 4 HOUR ASBESTOS INSPECTOR REFRESHER 12/14, 12/28 4 HOUR MANAGEMENT PLANNER REF 12/28 10 HOUR OSHA CONSTRUCTION HEALTH & SAFETY 12/19 & 12/20 16 HOUR ASBESTOS OPERATIONS & MAINTENANCE 12/21 & 12/22 8 HOUR ASBESTOS PROJECT DESIGNER REF 12/29 YOU MAY EITHER CALL IEE OR GO ONLINE TO REGISTER. (978)

6 Institute for Environmental Education 16 Upton Drive Wilmington, MA (978)