Lead-Safe Weatherization Updates & RRP Similarities/Differences Rob DeSoto, DOE-Golden Mike Vogel, Montana State University MT Wx Training Center 1
Lead used in paints for many years. Most problems with lead come from old paint & stains in homes built before 1978. 2
Impact on Weatherization: May 10, 2001 WPN 02-1 required LSW Eight elements of LSW defined LSW Benchmark Curriculum developed by POI Montana State University (Pollution Occurrence Insurance) required July 12, 2002 WPN 02-6 3
LSW Lead Studies: 2002 Montana LSW Air Monitoring and Dust Wipe Study 2004-6 DOE funds study conducted by National Center for Healthy Housing (NCHH) 3 states & 58 homes 4
cs6 April 22, 2008 EPA Lead, Renovation, Repair and Painting Program RRP or LRRPP Rule Renovation includes weatherization 5
Slide 5 cs6 Numbering seems "clunky" -- I deleted because it looks odd... but, I'll put it back in for you if you like it! Cynthia Simonson, 12/3/2007
DOE Response to RRP WPN 08-6 September 22, 2008 INTERIM LSW Guidance When the EPA RRP is in full effect, DOE will require as part of its LSW Minimum Standards all additional requirements as outlined in the EPA RRP April 22, 2010, published rule. WPN 09-6 January 7, 2009 LSW Additional Materials and Information with benchmark LSW training curriculum. WPN 10-6 - LSW Training. WPN 11-6 WAP H&S Matrix WPN 12-6 WAP H&S Matrix 6
RRP Requires: Certified Renovators - certified through EPA training Firms to be certified by EPA Training providers to be accredited Lead-safe work practices during renovations Pre-renovation education in target housing and child- occupied facilities EPA may authorize states, territories and tribes to enforce the Rule called Agreement States 7
RRP and WAP Guidance: DOE Guidance (WPN 10-1): Requires all Certified Renovators be trained in LSW Requires all crew workers to be trained in LSW before working on 1978 and earlier homes Requires all Grantee Monitors/Inspectors to be Certified Renovators and trained in LSW 8
Firm Responsibilities: Ensure Overall compliance with the RRP Rule Ensure that all renovation personnel are Certified Renovators or have been trained on-the-job by CRs Assign a Certified Renovator to all renovation jobs Meet pre-renovation education requirements Meet recordkeeping requirements 9
What is the Difference between LSW & RRP? LSW: Lead-Safe Weatherization is Lead-safe work practices that are done by crews or contractors on homes that have lead paint. Under the RRP, an EPA Certified Renovator works for an EPA Certified Firm, and is responsible for overseeing the work (LSW in WAP) done by crews or contractors on homes that have lead paint. 10
Is Training the same for both? No. LSW is taught by DOE or DOE contractors, teaching crews and contractors how to do Lead-safe work by following the DOE Minimum Standards for LSW RRP training for Certified Renovators can be done only by EPA Certified Trainers, and the training teaches how to test for the presence of Lead-paint, how to test if a job is left clean enough to pass EPA standards after renovation work has been completed, and how to oversee the Lead-safe work practices being done by crews and contractors, to ensure that they meet the EPA RRP Rule. 11
12 Core Elements of LSW 1. Worker Training* 2. Pre-1978 Lead Testing or Assuming Presence of Lead 3. Client Notification Pre-Renovation Education 4. Barriers and Signage/Restricting Access 5. Containment* 6. PPE/Respiratory Protection* 7. Safe Work Practices/Tools 8. Work-site cleanup 9. Work-site visual inspection 10. Cleaning Verification 11. Debris Disposal 12. Documentation* * Beyond EPA RRP 12
Training LSW 1. 1. All pre-1978 work must have EPA Certified Renovator (certified renovator must be associated with an EPA Certified Firm ). To be a CR individual must be trained (at least 8-hour EPA course + 11 skill sets (good for 5 years). CR must train & document non-cr workers on the job. 2. Workers and CR must have LSW benchmark training. 13
EPA RRP Training - Skill Sets 1. Using EPA Recognized Test Kits 2. Setting up Barriers, Signs and Flapped Entry Doors 3. Cover or Remove Furniture 4. Establish Interior Containment 5. Establish Exterior Containment 6. Personal Protective Equipment 7. Interior Final Cleaning 8. Exterior Final Cleaning 9. Bagging Waste 10. Visual Inspection 11. Cleaning Verification Procedure 14
Client Education Pre-Renovation Education LSW 2 owners and occupants of a house or apartment built before 1978 must be notified (no greater than 60 days) BEFORE weatherization takes places. 1. Provide Renovate Right Publication 2. Explain LSW Basics & Expectations 3. Documentation of PR Ed 4. File for 3 YRs 15
Lead Surface Testing Options LSW 3 Paint testing must be performed prior to renovation on all surfaces to be affected by the work, or you must presume the paint is lead-based. Any testing must be performed by the appropriate qualified professional. Type of Paint Testing for Renovations EPA-recognized test kits (Lead Check & D-Lead) Paint chip sampling using NLLAP laboratory (as of 10/5/11)* X-Ray Fluorescence instruments (surface-bysurface)* * Must be cost justified. Who can do the testing? Certified Renovators Certified Renovators Certified lead-based paint inspectors or risk assessors 16
RRP Test Option 1. No expiration date p Do not freeze Do not expose to high heat Each swab can be used up to 4 times if not positive sample 17
1/5/2012 RRP Test Option 2 2. TEST STANDARD Solution 1 Solution 2 Negative Test Positive Test 18
EPA RRP Test Option 3. Paint Chip Sampling Requires scraping a sample from each room/component and sent to a lab recognized by National Lead Lab Accreditation Program http://epa.gov/lead/pubs/nllaplist.pdf Sample should include substrate for full thickness of paint. EPA does not currently have sampling procedure contact lab BEFORE taking sample! EPA defines the presence of lead as more than 1.0mg/cm 2. 19
Posting Signs and Barriers Restrict Access LSW 4 CAUTION RENOVATION WORK DO NOT ENTER WORK AREA UNLESS AUTHORIZED NO SMOKING, EATING, OR DRINKING The certified renovator must direct the posting of signs outside the work area (interior 5 ft set-back recommended) to warn occupants and others not involved in the renovation to remain clear of the area. 20
LSW Containment LSW 5 The certified renovator must direct the containment of the work area so that dust or debris does not leave the area while the work is being performed. Objects left in the work area HVAC ducts and floors Objects left in the work area, HVAC ducts, and floors must be covered with taped-down plastic, or other impermeable sheeting. 21
What Is Containment? Containment is a system of temporary barriers used to isolate a work area so that no dust or debris escapes while the renovation is being performed. Typically 6 mil poly, tape and expansion rods Benefits of containment. Protects residents. Prevents spread of dust to rest of house/building or neighboring properties. Easier cleaning at the end of the job. 22
LSW Containment Level 1 Containment (Not required by RRP) Level 1 containment is required in pre-1978 homes when less than 6 ft 2 of interior painted surface per room or 20 ft 2 of exterior painted surface will be disturbed. 23
LSW Level 1 Containment: Measures that may fall within Level 1 include: Installing or replacing a thermostat Drilling and patching test holes Replacing HEPA filters and cleaning HEPA vacuums Changing Furnace Filter Removing caulk or window putty (interior) Removing caulk or window putty (exterior) Removing weather-stripping 24
LSW Level 1 containment consists of methods that prevent dust generation and contains all debris generated during the work process. The containment establishes s the work area which must be kept secure. At a minimum, this may include use of hand tools working wet (water mist or foam) shrouded power tools bubble dust bags catchment poly bags or placing 6 mil polyethylene sheeting immediately below the work area 25
LSW Containment LSW Level 2 Containment (also required by RRP) Level 2 containment is required when Weatherization activities will disturb more than 6 ft 2 of interior surface per room or 20 ft 2 of exterior surfaces in homes built prior to 1978. 26
LSW & RRP Level 2 Containment: Measures requiring level 2 containment may include: Drilling holes in interior walls Drilling holes in exterior walls, removing painted siding Cutting attic access into ceiling or knee walls Planing a door in place Replacing door jambs and thresholds Replacing windows or doors Furnace replacements 27
LSW & RRP Level 2 containment must ALWAYS be used where any of the following is conducted (even if the activities will disturb less than the hazard de minimis levels within the Level 1 category): 1. Window and In-Place Glass Replacement 2. Demolition of painted surface areas 3. Power Tools without HEPA attached Shrouds are Used 28
LSW & RRP Containment t Level 2 containment consists of methods that define a work area that will not allow any dust or debris from work area to spread. Level 2 containment requires the covering of all horizontal surfaces, constructing barrier walls, sealing doorways & windows, covering HVAC registers, etc. to prevent the spread of dust and debris. 29
LSW & RRP Level 2 Containment t Options Tape poly ABOVE baseboards Best to remove all furnishings in LSW work area. 6 6 Tape all edges if carpet 30
LSW & RRP Interior Containments Expansion rods creating containment walls, dividers and work areas taping ceiling is optional. 31
Split Containment Poly-Door 32
Exterior Cover the ground with protective sheeting. Containment If space permits, extend a minimum of 10 feet from the work area. Play special attention and cover nearby vegetable gardens and children's play areas. Limit access, place signs. Establish a 20 foot perimeter around the work area if space permits. 33
Cover windows and doors within 20 feet of work area. 34 34
If 10 feet of containment cannot be achieved, vertical containment is required. Drape poly from eave. Consider neighbor s exposure windows, etc. 35 35
Exterior Containment: Scaffolding Option Work Safely! 36
LSW PPE LSW 6 P-100 HEPA Disposal or Fit-tested respirator Minimum Personal Protective Equipment (PPE): -Disposal suit -Disposal head-cover -Respirator 37
LSW Prohibited Work Activities LSW 7 NEVER use reuse containment materials. NEVER use dry sweep or use shop vac for clean-up. Wet cleaning & HEPA vacs must be used. NEVER use a conventional shop vac with HEPA filters. Only HEPA designed vacuums are acceptable for LSW. NEVER - Turn leaded paint into leaded dust by dry scraping, machine sanding or grinding. NEVER - Use a flame-torch or high-temperature heat gun (above 1100 F). NEVER Leave LSW Debris at work-site. 38
Lead-Safe Work Techniques and Tools: Foam Water Mist HEPA Vacuum HEPA attached Tool Shrouds 39
LSW Cleanup LSW 8 Step 1. Pick-up all visible paint chips and debris Step 2. Clean (vacuum and wet wipe) and remove all tools in work area. Step 3. HEPA Vac work area surfaces from high to low. Step 4. Wet clean 2 ft beyond containment. 40
LSW EXTERIOR CLEANUP Folding exterior poly HEPA vacuum vertical surfaces and windows. Collect and dispose of all paint chips, dust and debris. Mist plastic, fold into itself and place in heavy duty bags. Clean & inspect 2 ft beyond the work area. 41
WX Worksite Visual Inspection LSW 9 Phase 1: Worker visual inspection during the cleaning process; look for any visible paint chips, dust, or debris as you clean, using proper techniques. Phase 2: Certified Renovator must conduct visual inspection after cleanup with bright light. There should be no evidence of settled dust following a cleanup effort. If dust is observed, the Weatherization crew must be required to repeat the cleaning. 42
Interior Cleaning Verification LSW 10 A certified renovator must use wet disposable white cleaning cloths to wipe the windowsills (1/window), countertops, and uncarpeted floors (40 ft2) in the work area. These cloths must then be compared to a cleaning verification card. If the cloth matches or is lighter than the cleaning verification card, that surface has passed the cleaning verification. Surfaces that do not pass the first attempt must be re-cleaned. Surfaces that do not pass on the second attempt must be allowed to dry (or wait 1 hr) and wiped with a dry cleaning cloth. 43
LSW WASTE DISPOSAL Waste may be disposed as household waste; but must be taken off site & secured*. LSW 11 LSW waste may includes: Protective sheeting used for containment HEPA filters All paint chips, work debris & dust Used clean-up cloths, baby wipes and mop heads Protective clothing, respirators, gloves Painted duct work and furnace components Waste water - must be filter and flushed down a toilet *Weatherization crews must be aware of state and local regulations concerning hazardous and solid waste management and disposal. 44
LSW Documentation LSW 12 Recordkeeping: All RRP documents & photos must be retained for 3 years following the completion of a renovation. 45
RRP/LSW Enforcement: EPA may conduct inspections & enforce RRP Rules EPA has approved 13 States to enforce RRP Rules. EPA may suspend, revoke, or modify a firm s certification if the Certified Firm or Certified Renovator is found to be in noncompliance. Those firms found to be non-compliant may be liable for civil penalties of up to $37,500 for each violation. Those firms who knowingly or willfully violate this regulation may be subject to fines of up to an additional $37,500 per violation, or imprisonment, or both. 46
OSHA Even if DOE and EPA did not have rules dealing with lead exposure to workers implementing Lead-Safe Weatherization, the Occupational Safety and Health Administration (OSHA) is an agency of the Department of Labor which writes and enforces rules protecting workers on the job. To protect employees from lead hazards the OSHA Lead To protect employees from lead hazards, the OSHA Lead in Construction Standard (29 CFR 1926.62) was developed. The Standard became law on June 3, 1993. 47
Current Supporting Documents: WPN 08-6 Interim Lead-Safe Weatherization Guidance & Attachments: Minimum Standards for LSW LSW Glossary of Terms WPN 09-6, & WPN 10-6 WPN 11-6 and 6a WPN 12-6 (Not released yet) EPA LRRPP Lead, Renovation, Repair, and Painting Program Final Rule; April 2008 (RRP) FAQs on RRP EPA Website: http://epa.gov/lead/pubs/renovation.htm /l / ti or 1-800-424-LEAD (5323) www.weatherization.org (WXTV) wxtvonline.org Online LSW Refresher Course in review Updated LSW Basic Course in review 48