Poisonings from Housing Renovations Containing Lead Paint: e o at o - PowerPoint PPT Presentation

Poisonings from Housing Renovations Containing Lead Paint: e o at o s Co ta g ead a t A Regulatory Update Delaware Healthy Homes Summit March 12, 2014 Presented by: Demian P. Ellis, USEPA Region 3

What will be covered What will be covered • Overview of Renovation, Repair, and Painting (RRP) Rule Requirements • RRP Enforcement/Compliance Assistance • State Authorization • State Authorization

Approximately 34 Million Homes in the U.S. Contain Lead BACKGROUND

OVERVIEW Renovation Studies (2000) • Typical renovation activities that disturb lead-based paint produce d s u b ead based pa p oduce hazardous quantities of lead dust. • Typical clean-up methods (broom Typical clean up methods (broom and shop vacuum) do not eliminate lead dust hazards. • There is a relationship between renovations and elevations in children’s blood lead levels children s blood lead levels.

OVERVIEW The Renovation, Repair, and Painting Rule: What is it? •On March 31, 2008, EPA issued a final rule under the •On March 31 2008 EPA issued a final rule under the authority of §402(c)(3) of the Toxic Substances Control Act (TSCA) to addressed lead-based paint hazards created by renovation, repair, and painting activities t d b ti i d i ti ti iti that disturb lead-based paint. •Renovation Definition •Applies in target housing and child-occupied facilities Applies in target housing and child occupied facilities •Is a delegable program

OVERVIEW Where doesn’t the RRP Rule Apply? Excludes: Excludes: • Renovations that affect only components determined to be free of lead-based paint. Activities that disturb less than or equal to 6 ft 2 interior or 6 ft 2 i t • A ti iti th t di t b l th l t i 20 ft 2 exterior (this excludes window replacement, demolition, and projects involving prohibited practices). • Work done by individuals in housing they own and occupy.

RRP REQUIREMENTS What does RRP require? Firms performing maintenance, repairs or renovations Firms performing maintenance, repairs or renovations that disturb Lead Based Paint (LBP) in homes or Child Occupied Facilities (COFs) built before 1978 must: • Have their firm certified by EPA • Use certified renovators who are trained by EPA- y approved training providers • Follow lead-safe work practices • Distribute information • Keep records Keep records

FIRM CERTIFICATION Have their firm certified by EPA Contractors performing renovations Contractors performing renovations that disturb paint must be EPA certified. RRP RRP

FIRM CERTIFICATION Contractors performing renovations that disturb paint must be EPA certified. that disturb paint must be EPA certified.

FIRM CERTIFICATION CERTIFICATION - ACCREDITATION Certification of Firms If you or your employees conduct renovation or repair activities in a pre- 1978 residential building or child occupied facility: 1978 residential building or child-occupied facility: STEP 1: Submit an application and fee to EPA STEP 2: Make sure your employees are trained in Lead Safe Work Practices STEP 2: Make sure your employees are trained in Lead-Safe Work Practices. STEP 3: Once you receive your EPA Lead-Safe Firm Certification in the mail and logo instructions in your e-mail, update any desired outreach materials. RRP Final Rule - Overview 10

R ENOVATOR TRAINING •Renvoators must receive certification through training by taking an 8-hour course. training by taking an 8 hour course. •Once training completed renovator certified for Once training completed, renovator certified for 5 years.

ON-THE-JOB TRAINING Workers must receive on-the-job training from a certified Renovator from a certified Renovator. RRP RRP RRP RRP RRP RRP RRP RRP RRP

ON-THE-JOB TRAINING Non-Certified Worker Training • Worker’s name. • Description of lead safe work practices the worker is trained to perform. • Completed and signed skills evaluation checklists. • Date(s) of training. • Name and signature of the Certified Renovator who conducted the training.

NOTIFICATION Renovators must provide building owners and occupants pre-renovation notification. p p Renovations in common areas ≤ 60 days before renovation ◦ FIRM gives owner pamphlet and gets written acknowledgement OR gets certificate of mailing 7 days >start AND FIRM Notifies each affected unit Written notice to each unit OR post informational signs  Post pamphlet (or how to obtain a copy) Post pamphlet (or how to obtain a copy)  FIRM prepares written statement describing steps taken Notify if revisions to scope, location and/or dates ot y e s o s to scope, ocat o a d/o dates

RENOVATOR RESPONSIBILITIES RESPONSIBILITIES • Perform or direct work to ensure the work practices are followed. • Be physically present at the work site: – When warning signs are posted, while containment is Wh i i t d hil t i t i established, and during final work area cleaning. – Be available, either on-site or by telephone, at all other times. • Provide on the job training to uncertified workers Provide on the job training to uncertified workers. • When requested, use a test kit to determine if LBP is not present. • Perform cleaning verification. Perform cleaning verification. • Prepare required records.

Safe Work Practices General Work Practice Standards Work Practice Standards • • Post signs defining the work area Post signs defining the work area. • Ensure that all personnel, tools, and other items including waste are free of g dust and debris when leaving the work area. • • Waste must be sealed in bags or Waste must be sealed in bags or plastic sheeting. Dispose of waste in accordance with Federal, State, and Local requirements.

Safe Work Practices Prohibitive Work Practice Standards Prohibited work practices Open flame burning or torching of lead-based paint Using heat gun >1100 o F Using machines without HEPA Using machines without HEPA attachment (sanding, grinding, power planning, needle gun, abrasive blasting or sandblasting) abrasive blasting, or sandblasting)

Safe Work Practices Interior Work Practice Standards Work Practice Standards • Remove or cover all objects from the work area. • Close and cover all ducts in the work area. Cl d ll d t i th k • Close all windows, and cover all doors in the work area. • Cover the floor surface of the work area with plastic sheeting.

Safe Work Practices Exterior Work Practice Standards Work Practice Standards • Close all doors and windows within 20 feet of the renovation. • Cover the ground with plastic sheeting extending out from the edge of the structure a sufficient out from the edge of the structure a sufficient distance to collect falling paint debris.

Safe Work Practices Exterior - Vertical Containment Work Practice Standards • Vertical barrier of plastic sheeting over a rigid frame. • Required for exterior jobs close to property lines. close to property lines. • Can be used to minimize floor or ground contamination.

Safe Work Practices Exterior –Ground Cover Exterior Ground Cover Work Practice Standards • Cover the ground with protective Cover the ground with protective sheeting. – If space permits, extend a minimum of 10 feet from the work area. – P Pay special attention and cover i l tt ti d nearby vegetable gardens and children's play areas. • Limit access, place signs. – Establish a 20 foot perimeter around the work area if space permits. • Erect a vertical containment. – Vertical containment must be erected if renovations occur within 10 feet of the property line

Safe Work Practices Cleaning Work Practice Standards • Pick up paint chips and debris. • Remove all protective sheeting • Remove all protective sheeting. • Clean all objects and surfaces in and around the work area. – Clean walls with a HEPA-equipped vacuum or with a damp cloth. – HEPA vacuum all remaining surfaces and objects in the work area. d bj t i th k – Wipe all remaining surfaces in the work area with a damp cloth. – Mop uncarpeted floors. Mop uncarpeted floors

Safe Work Practices Cleaning Verification Work Practice Standards Work Practice Standards • Wipe floors, countertops, and windowsills with wet cleaning cloth. g • If the cloth does not match the verification card, re- clean that surface and then re-wipe with a wet cleaning cloth cleaning cloth. • If this cloth does not match the cleaning verification card, allow the surface to dry completely and wipe with a dry cleaning cloth with a dry cleaning cloth. 23

Safe Work Practices Work Practice Standards Disposal • What should I do with my waste? Wh t h ld I d ith t ? • At the work site: – Place waste in heavy duty plastic bag. Place waste in heavy duty plastic bag – “Gooseneck seal” the bag. – HEPA vacuum the exterior of the waste bag before removing it from the work area. – Store waste in a secure area. – Carefully dispose of waste in accordance Carefully dispose of waste in accordance with Federal, State and Local regulations. – Always check local waste requirements