LEAD-BASED PAINT HAZARDS

1
LEAD-BASED PAINT HAZARDS

• Topic Agenda
• What is Lead Based Paint (LBP)?
• Health Effects Targeting Children Under the Age
  of 6
• Key Federal Regulations
• Assessments for LBP and Other Residential Lead
  Hazards
• Quality Control on Lead Inspections
• Lead Hazard Control and Abatement

2
TOPIC 1
WHAT IS LEAD BASED PAINT?
3
Lead What is It?

• Chemical Symbol - Pb
• Heavy Gray Metal
• Soft and Pliable
• Galena most common lead-containing ore

4
What Products Contain or Contained Lead?

• Paints and Varnishes
• Pottery
• Gasoline
• Drinking Water System
• Solder
• Flux
• Brass Fixtures
• Hobbies
• Sinkers
• Ammunition
• Stain Glass
• Food Containers
• Storage Batteries

5
What Makes Paint Lead Based?

• Lead-Based Paint (LBP)
• -1.0 mg/cm2 lead on surface
• -0.5 (5,000 ppm) lead by dry weight
• CPSC banned the use of Lead-Based Paint in 1978
  standard set
• at 0.06.
• Paint today may still contain 0.009 lead in
  liquid paint

6
40 CFR Part 745.65Lead-Based Paint Hazard

• Dust Lead-Hazard
• On residential property or child-occupied
  facility
• Floor
• 40 ug/square foot
• Window Sill
• 250 ug/square foot

7
40 CFR Part 745.65Lead-Based Paint Hazard

• Soil-Lead Hazard
• Bare soil on residential property or
  child-occupied property
• Play Area
• 400 ppm
• Rest of yard
• 1,200 ppm

8
Childs Exposure to Lead

• Dust and soil are the major routes of exposure
• Renovations that break surfaces painted with LBP
• Enters soil through deterioration
• Young children ingest through normal hand-mouth
  activity (PICA)

9
Lead in Soil

• Both a direct and indirect source
• children playing in bare soil
• tracked or blown into a dwelling
• Dwellings with exterior lead-based paint
• more likely to have elevated soil lead levels

10
Lead in Water

• In 1986 the federal government in the Lead Safe
  Drinking Water Act set the following standards
• 15 ppb for lead in
• drinking water from water
• distribution systems
• lt0.2 for lead in
• solder or flux
• lt8 in other plumbing
• fixtures today this has
• been reduced to 0.25

11
Lead in Water

• Main causes
• corrosion of lead-containing materials in
  plumbing
• poorly soldered joints
• brass fittings
• private wells
• plumbing equipment

12
Lead in Water

• Amount of lead in drinking water depends on the
• amount and age of lead-containing materials
• amount of time the water is in contact
• Corrosiveness of the water
• hot
• acidic
• soft

13
TOPIC 2
HEALTH EFFECTS
14
Body Systems Affected

• Almost all systems
• within in the body may be affected by lead
  exposure!

15
Body Systems Most Affected
Central nervous system (CNS)
Cardiovascular system (heart)
Kidneys (renal)
Hematopoietic (Blood forming) system
16
Children

• More susceptible to effects of lead
• High levels of lead in the blood may cause
• permanent CNS damage
• Low levels of lead in the blood may cause
• delayed development
• behavioral problems
• May not exhibit any obvioussymptoms!

17
Children most at risk for lead poisoning

• Poor
• Mexican American
• Non-Hispanic Black
• Living in large metropolitan areas
• Living in older housing

18
Where is lead stored in the body? For how long?

• Blood
• ? 5-10, half-life 1 month
• Kidney
• ? 5-10, half-life 1 month
• Bone
• ? 80-90, half-life 25 years

19
Biological Evaluation

• The blood lead level is the best initial
  measurement for evaluating lead exposure.
• The blood lead level
• indicates the amount of lead circulating in the
  blood stream
• may be a measure of recent exposure

20
Level of Concern in Children

• CDC
• 1970 ? 60 ?g/dL
• 1971 ? 40 ?g/dL
• 1975 ? 30 ?g/dL
• 1985 ? 25 ?g/dL
• 1991 ? 10 ?g/dL
• 2012 ? 5 ?g/dL
• (now called Reference Value)

21
TOPIC 3
KEY FEDERAL REGULATIONS
22
Regulatory History

• 1978 CPSC banned the sale of LBP
• LBP defined LBP as 0.06 by weight
• 1992 Lead-Based Paint Hazard Reduction Act
  (Title X)
• 1993 OSHA Lead in Construction Standard
• 1995 HUD Guidelines
• 1996 HUD/EPA Disclosure Rule
• 1998 EPA Pre-renovation Lead Hazard Education
  Rule
• 1999 HUD 24 CFR Part 35

23
Regulatory History

• 2000 EPA Protocols established for
• Inspections, Risk Assessments, Abatement,
  Interim Controls and Training Courses
• 2001 EPA Standards established for
• Lead Hazards
• 2008 EPA Renovation, Repair and
• Painting Rule

24
Residential Lead-Based Paint Hazard Reduction Act
(Title X)

• Title X Mandated
• Training and Certification
• Abatement Contractors
• Inspectors
• Risk Assessors
• Abatement Workers
• Project Designers
• Training-provider accreditation
• Establishment of health-based standards for dust,
  soil, and lead-based paint
• Notification to buyers and renters
• Laboratory accreditation
• Performance standards for testing and abatement
  products
• Action to reduce the risks of creating LBP
  hazards during renovation and remodeling projects

25
40 CFR Part 745.65Lead-Based Paint Hazard

• Lead Paint Hazard
• LBP on a friction surface that is subject to
  abrasion and dust lead levels above hazard levels
• LBP on any damaged or deteriorated LBP on an
  impact surface
• Chewable lead-based paint surface where there is
  evidence of teeth marks
• Any other deteriorated LBP (interior Exterior)
  in any
• Residential building
• Child occupied facility

26
40 CFR Part 745.80Pre-Renovation
Notification Regulation

• Also amended Title IV of TSCA by adding Section
  406(b) which states that
• Those performing renovation or remodeling for
  compensation shall provide the lead hazard
  information pamphlet to the owner and occupant
  prior to conducting such activity

27
40 CFR Part 745.100Disclosure Regulation

• Most pre-78 housing at sale or lease
• Public and privately owned housing
• Requires
• Free educational pamphlet
• Warning statement in contract
• Disclosure of known LBP or LBP hazards
• All available information
• Opportunity for testing
• 24 CFR 35 and 40 CFR 745

28
40 CFR Part 745.225Training and Certification

• Establishes work practices standards and specific
  criteria for
• Certifying lead professionals
• Accrediting training providers
• Pre-requisites and minimum training required for
  the certified disciplines
• Regulations applies to target housing and child
  occupied facilities
• Requirements went into effect in all states that
  have not already enacted similar legislation on
  March 1, 2000.

29
40 CFR Part 745.227 (e)Abatement

• Certified Individuals
• Supervisor
• Workers
• Inspectors
• Risk Assessors
• Project Designers
• Written Occupant Protect Plan prepared by
• Supervisor
• Project Designer

30
40 CFR Part 745.227 (e)Abatement

• Prohibited Activities
• Open Flame Burning
• Torch Cutting
• Following activities without HEPA exhaust
  controls
• Machine Sanding
• Grinding
• Abrasive Blasting
• Sandblasting
• Dry Scraping unless with Heat Guns
• Heat guns lt1,100 degrees Fahrenheit

31
40 CFR Part 745.227 (e)Abatement

• Soils
• Removed
• replaced with soil as close to local background
  as practicable, but no greater than 400 ppm
• Removed soil shall not be used as top soil at
  another residential property or child-occupied
  facility
• Not Removed
• permanently covered

32
40 CFR Part 745.227 (e)Abatement

• Clearances
• Visual Inspection by
• Inspector
• Risk Assessor
• Dust samples collected 1 hour after final
  clean-up
• Containment
• 1 sample each from the floor, a sill, a trough
  within 4 contained rooms, hallways, or stairwells
• 1 sample from floor outside the contained area

33
40 CFR Part 745.227 (e)Abatement

• Clearances (continued)
• No Containment
• Dust samples of no less than 4 rooms. 1 sample
  taken from floor, sill, trough of each selected
  room, hallway, or stairwell.
• Exterior
• Visual Inspection

34
40 CFR Part 745.227 (e)Abatement

• Clearances (continued)
• Dust Clearance levels
• Floor - 40 ug/sq. ft.
• Sill - 250 ug/sq. ft.
• Trough (Well) - 400 ug/sq. ft.

35
Waste Disposal (RCRA)

• Large Abatement produce potentially large
  quantities of solid waste
• Building Components
• Sludges from paint stripping
• Lead paint chips and dust
• Waste water from cleanup
• Used PPE
• Plastic sheeting used for containments
• Characterize between hazardous and non-hazardous
  waste
• Sample gt5 ppm hazardous waste

36
Waste Disposal (RCRA)

• Household Waste Exemption
• Disposal of lead -based paint debris from
  residential properties during renovation may be
  disposed of as household waste
• Debris should not be sent to waste to energy
  facility

37
EPA Certified Lead Renovator

• Renovation, Repair and Painting Work
• Effective April 2010 all RRP work for
  compensation in child-occupied facilities and
  target housing must be done by EPA Certified
  Renovation Firms
• Certified Lead Renovator must supervise project
  work. Requires EPA 8-Hour training course.
• 4-Hour RRP Refresher course required for
  abatement supervisors for certification as Lead
  Renovators.

38
HUDs 1012/1013 Regulation

• Pre-1978 housing receiving HUD or other Federal
  assistance
• Pre-1978 Federally owned housing being sold
• Requirements
• Lead Hazard Control based on program
• Required activities vary by type of assistance
• Effective September 15, 2000
• 24 CFR 35 B-D, F-M, R

39
HUD - Hazard Control Strategies

• Strategies vary in stringency, cost, and
  durability, considering the statute, and
• Amount, type and duration of HUD assistance
• Age of housing
• Occupants (rental or owner-occupied)
• Regulation Preamble

40
Strategies for HUD Programs

• Levels of Protection
• Safe Work Practices during rehabilitation
• Ongoing LBP Maintenance
• Visual Assessment and Paint Stabilization
• LBP Inspection, Risk Assessment, and Interim
  Controls
• Risk Assessment and Abatement of LBP hazards
• LBP Inspection and Abatement of all LBP

41
HUD - Strategies

• Safe Work Practices during rehabilitation
• Prevent low-cost rehabilitation from creating LBP
  hazards
• Ongoing LBP Maintenance
• When a continuing HUD relationship exists
• Paint maintenance
• Includes Safe Work Practices
• Clearance required only at worksite

42
De Minimis Levels

• Exception to Safe Work Practices and Clearance
  Requirements
• Work which disturbs less than
• 20 square feet on exterior surfaces
• 2 square feet in any one interior room or space
• or 10 percent of area of a interior or exterior
  component with a small area (sills, baseboards,
  etc.)
• 24 CFR 35.1350

43
HUD - Exemptions

• Post-1977 housing
• Zero-bedroom units
• Housing exclusively for elderly or disabled
• Property certified as lead-based paint free
• Property where lead-based paint was removed

• Unoccupied property pending demolition
• Nonresidential part of property
• Rehabilitation or maintenance activities that do
  not disturb painted surfaces
• Emergency actions
• 24 CFR 35.115

44
TOPIC 4
SUMMARY OF NEW CT LEAD REGULATIONS
45
Summary Draft Revision of CTDPH Lead Poisoning
Prevention and Control Regulations
Draft Revision

• 19a-111c-1-19a-111c-10
• Prepared by Neal B. Freuden
• January, 2009

46
Definition of Lead Hazard

• Deteriorated LBP.
• LBP on Friction or Impact Surfaces which result
  in creation of Dust or Paint Chips (NEW).
• House Dust, Bare Soil or Drinking Water above
  standards.

47
What is an Inspection?

• It must be comprehensive and follow the testing
  protocols described in the current regulations.
• Any Testing that is not comprehensive will be
  called Limited Testing.
• If lead hazards found and children under 6
  present, inspector does not have to notify state
  and local health departments.

48
Inspections (cont.)

• New state Form Lead Inspection and Testing
  Summary Form must be completed by inspector and
  sent to owner, for All Testing where child is
  present. Owner must give to residents residents
  must acknowledge receipt.

49
Record Keeping

• All Testing reports shall be retained by owner
  and transferred when passing title until property
  is certified by a licensed lead inspector as
  free of toxic levels of lead.
• Lead Consultant Contractor shall retain these
  reports for a minimum of 3 years from day of
  issuance.

50
Dwellings with CHILDREN under 6 WHO ARE NOT Lead
Poisoned

• Abatement not required
• Just Interim controls (a.k.a. Remediation) using
  LEAD SAFE Work Practices to correct Hazards

51
Lead Remediation Plans

• Follow same rules as Abatement Plans.
• Prepared by licensed Planner Project Designer.
• Submit to Local Health Department (LHD) for
  Approval.

52
Abatement/Remediation Changes

• Final clean-up no sooner that 1 Hour after active
  work ceases.
• Replacement Soil lt400 ppm.
• Lead in dust sampling for reoccupancy no sooner
  than 1 Hour after Final Clean-Up.
• Encapsulants of lead painted surfaces can occur
  After reoccupancy if LBP is not disturbed.

53
Abatement/Remediation Changes (cont.)

• Lead Poisoned Child Abatement Plan to LHD within
  15 business days, as it is now, but if more than
  5 days late, the LHD shall refer case to housing
  court prosecutor for enforcement.
• LHD has 20 business days to review plan accept
  or reject. If the latter, LHD shall set timetable
  for resubmission.
• Abatement complete within 90 calendar days of
  Approval of Plan. LHD can grant up to 3
  extensions of 30 calendar days but for very
  specific reasons only.
• (Exterior Work weather issues back order of
  materials, ie. Windows owner doing work himself
  has completed 50 within initial 90 days.)
  

54
Abatement/Remediation Plans (cont.)

• Owner may request further extensions from CTDPH
  commissioner.
• Non Lead Poisoned Child Abatement or Remediation
  plan to LHD within 20 business days, as it is
  now, but if more than 5 days late, refer case for
  enforcement.
• LHD has 20 business days to review plan. If
  rejected,
• set timetable for resubmission.
• In the absence of a lead abatement/remediation
  order, work can commence if LHD does not respond
  to plan within 20 business days of submission.

55
Abatement/Remediation Changes (cont.)

• Abatement complete within 120 calendar days of
  approval of plan. LHD can grant up to 3
  extensions of 30 calendar days but for very
  specific reasons only (Exterior Work weather
  issues back order of materials, i.e. Windows
  Owner doing work himself has completed 50
  within initial 90 days.)
• Worker Protection All current language removed
  and substitutes Appropriate worker protection
  practices shall be followed as specified by U.S.
  Department of OSHA.

56
Lead Management Plans

• Include monitoring of intact LBP including LBP
  which has been abated by encapsulation or
  enclosure
• The plan shall be transferred by owner when
  passing title until such time as property is
  certified by a licensed lead inspector as free
  of toxic levels of lead

57
Lead Management Plans (cont.)

• The plan has to be submitted by owner to LHD if
  abatement or remediation has occurred. Has to be
  submitted within 5 business days of clearance.
  LHD has 15 business days to approve or reject. If
  the latter, timetable for resubmission.

58
TOPIC 4
ASSESSMENTS FOR LBP AND OTHER RESIDENTIAL LEAD
HAZARDS
59
EPA/HUD - Lead-Based Paint Inspection

• Examination of painted or finished surfaces for
  lead-based paint
• Interior and exterior
• Comprehensive
• Includes intact paint and areas not to be
  disturbed
• Performed by a certified LBP inspector
• 40 CFR 745.227(b)

60
Types of Housing

• Single-family
• Any housing with fewer units than a multifamily
  development
• Results cannot be applied to other dwellings

61
Types of Housing

• Multifamily
• Include dwellings with
• 21 or more units if built before 1960 or
• 10 or more units if built from 1960 through 1978
• Use of random sampling

62
XRF Devices
63
The Performance Characteristics Sheets for the
XRFs

• The Performance Characteristics Sheet (PCS) for
  each XRF instrument provides important details
  for the following
• Step 1 Calibration Checks
• Step 2 Testing
• Step 3 Substrate Corrections
• Step 4 Classifying Results

64
Inspections in Multifamily Housing

• Multifamily have the following differences vs.
  single-family inspections
• not every unit, common area or exterior is
  inspected
• representatives of these spaces need to be
  selected in a random manner to test
• classification of XRF results by component is
  required to determine development-wide patterns

65
Compute Sample Size

• Number of units, common areas, and exterior sites
  to be tested is based upon
• total number of units
• similar common areas, or exterior sites in the
  building(s) or on the property, and
• the date of the construction.
• Refer to Table 7-3.

66
NUMBER OF UNITS TO INSPECT
67
Compile the results by component type

• Record measurement for each testing combination
  and classify as
• Positive
• Negative
• Inconclusive

68
Compile the results by component type

• Example
• Component Pos Neg Inc
• Int win sashes 20 75 5
• Int win trim 12 83 5
• Int doors 0 95 5
• Int door trim 2 97 1

69
Decision Analysis

• Result for component type is
• Positive if 15 or more of the components are
  positive
• Negative if
• 100 of tested component types are negative (OR)
• 100 of the tested component types are either
  negative or inconclusive AND all the inconclusive
  samples have XRF readings lt1.0 mg/cm2
• Perform confirmatory testing as required low
  incidence inconclusives and positives

70
EPA- Risk Assessment

• Identification of LBP hazards
• Includes
• Visual inspection for deteriorated paint
• Information on occupant use
• Testing of deteriorated paint and possibly other
  surfaces
• Dust sampling
• Soil sampling
• Report
• Performed by a certified risk assessor
• 40 CFR 745.227(d)

71
EPA Risk Assessment

• Risk Assessment
• Covers the following
• Identification of the existence, nature,
  severity, source, and location of LBP hazards
• Presentations of the various options for
  controlling lead hazards in the event that
  hazards are found
• Interim Controls
• Abatement Measures
• Management and Maintenance changes

72
EPA Risk Assessment

• Lead Hazard Screen
• Used if the probability of finding a LBP hazard
  is low
• Dwelling is in relatively good condition
• No more than five deteriorated surfaces

73
EPA Risk Assessment

• Visual Assessment
• Poor Surfaces
• Considered to be a hazard and should be corrected
• Fair Surfaces
• Should be repaired, but are not yet considered to
  be hazard monitored frequently
• Intact Surfaces
• Monitored to ensure they remain in a
  non-hazardous condition

74
EPA Risk Assessment

• Dust Sampling in Dwelling Units
• 6-8 Samples generally are collected
• Composite samples can be used for properties in
  good condition
• Areas likely to be contacted children
• Play area within rooms
• High-traffic walkways
• Room midpoints
• Areas immediately underneath windows
• Windows
• Most frequently operated
• Most frequently contacted by children

75
EPA Risk Assessment

• Dust Sampling
• Common Areas (Multifamily Housing Only)
• Low-Rise Buildings (4 Stories or less)
• 2 additional samples
• 1 from the entry area floor
• 1 from the floor of the first story landing of a
  common hallway or stairway
• Common window can be substituted for floor on
  landing of common hallway or stairway.

76
EPA Risk Assessment

• Dust Sampling
• Common Areas (Multifamily Housing Only)
• High-Rise Buildings (gt 4 Stories)
• Same as low rise additional plus
• 2 additional from every fourth floor corridor
• Floor area
• Window
• In addition, 2 samples from stairways
• One from Stair treads
• One from the Landing

77
EPA Risk Assessment

• Dust Sampling
• On-Site Community Bldgs., Day Cares, Other Spaces
  Frequented by Children
• Spaces up to 2,000 SF
• Floors 2 Samples widely separated locations in
  high-traffic areas used by children
• Windows 2 from interior windows
• Spaces over 2,000 SF
• Floors 1 additional sample for each increment
  of 2,000 SF
• Windows - 1 additional sample for each increment
  of 2,000 SF

78
EPA Risk Assessment

• Owner Occupied, Single Family Dwellings
• Evaluation should include
• Interview with homeowner about resident use
  patterns and potential lead hazards
• Visual Assessment of the condition of the
  building and painted surfaces
• Environmental sampling of deteriorated paint,
  dust, and soil

79
EPA Risk Assessment

• Multi Family Dwellings
• Do not interview residents
• But complete management and maintenance
  questionnaires with owner
• Use either random, target or worst case dwelling
  unit selection methods
• Environmental sampling of deteriorated paint,
  dust and soil

80
HUD Changes to EPA Risk Assessment
BASIC SAMPLING SCHEME-Single Surface wipes
encouraged. Composites are discouraged for a
variety of reasons including a lack of NLLAP
proficiency program.
81
HUD Changes to EPA Risk Assessment
BASIC SAMPLING SCHEME-Dwelling Unit-Interior
minimum 2 single surface wipes (floor sill) in
4 rooms entryways In addition Optional
Counter tops, drawers and shelving subject to
friction (kitchens and pantries, for ex.)
collect a dust wipe directly on components and
compare to floor standard (40 ug/ft2)
82
HUD Changes to EPA Risk Assessment
COMMON AREAS Samples only collected on floors
and sills adjacent to dwelling units in which
conducting risk assessment plus a sample in
building entryway
83
HUD Changes to EPA Risk Assessment
OTHER CHANGES Categories of Paint Now only
Intact and Deteriorated and deteriorated have to
be assessed for lead safe work practices for HUD
de minimis and EPA minor maintenance and repair
categories.
84
HUD Changes to EPA Risk Assessment
OTHER CHANGES Intact paint subject to friction
must be tested or assumed to be LBP. It is hazard
if dust underneath on horizontal surface is a
hazard If choose not to collect a dust sample,
must assume intact friction surface with
confirmed or assumed LBP is a hazard
85
HUD Changes to EPA Risk Assessment
Dust Wipe QUALITY CONTROL Blind Field Spikes
not required Blanks 1 per property. If doing
multi-family testing, 1 per 20.
86
HUD Changes to EPA Risk Assessment
SAMPLING FOR SOIL HAZARDS -Sample bare soil in
play areas -Bare soil at the driplines at main
house, detached garages, sheds, etc. (0-3 ft.
from foundation) -Bare soil in other areas of
yard if cumulatively gt 9 SF -Sample depth 5/8
inch -Bare soil in vegetable gardens-sample
depth 3-4 inches
87
Reevaluation

• If LBP remains after hazard reduction
• Identify
• Deteriorated paint surfaces
• Deteriorated or failed Interim Controls
• Dust-lead hazards
• Newly bare soil with soil-lead over standards
• Performed by certified risk assessor
• Reevaluation every two years
• Begins two years after hazard reduction
• Opportunity to achieve exemption
• Response to identified hazards

88
Lead in Water

• Drinking water contributes about 20 to total
  lead exposure for an average 2 year old
• Ranges from 5 to greater than 50
• Infants may receive 85 of their total lead
  exposure from drinking water
• Two types of water
• Soft
• More corrosive towards lead (Hot, acidic)
• Hard
• Least Corrosive

89
Sampling Methods

• Water not to be used for at least 6 hours before
  sampling
• Collect one liter sample (1st Draw)
• Collected in plastic (Nalgene) bottles
• Samples should be analyzed within 28 hours
• Standards EPA Water Distribution Systems
  15 ppb
• Standards HUD Individual Faucets in a dwelling
  unit 20 ppb

90
TOPIC 5
QUALITY CONTROL
91
Quality Assurance and Control Measures

• HUD Guidelines recommend the housing owner or
  client evaluate the quality of the LBP inspection
  in one of the following ways
• Direct observation
• On-site results
• Repeated testing
• Time-and-motion analysis

92
TOPIC 6
LEAD HAZARD CONTROL AND ABATEMENT
93
What is a lead-based paint hazard?Controlling
LBP Hazards

• Lead dust from lead-based paint which is damaged
• Lead dust from lead-based paint on any friction
  surface
• Lead dust from lead-based paint on impact surface
• Lead-painted surface that a child can chew
• Lead contaminated dust anywhere in the home that
  is above acceptable EPA or HUD levels
• Lead contaminated soil that is bare soil with
  lead above the acceptable EPA levels

94
CONTROLLING LEAD-BASED PAINT HAZARDS

• Abatement
• Corrects hazards for at least 20 years.
• Paint removal
• Replacement of painted building components
• Enclosure or Encapsulation of painted surfaces
• Interim Controls
• Correct lead-based paint hazards for a shorter
  period of time
• Paint stabilization
• repairing any physical defects, deterioration,
  removing loose paint from the surface to be
  treated using wet methods and applying a new
  protective coating or paint.
• On-going Maintenance

95
ABATEMENT METHODS

• Building component removal and replacement
• Enclosure / encapsulation
• On-site paint removal
• Off-site paint removal
• Removing or permanently covering
  lead-contaminated soil

96
INTERIM CONTROLS

1. Specialized Cleaning
2. Repairs
3. Maintenance
4. Painting
5. Temporary Containment
6. Educational Programs

97
EPA RRP Cleaning Verification

• Wipe each window sill in work area with
  individual wet cloth per sill
• Wipe uncarpeted floors and all countertops in
  work area with individual wet cloth for maximum
  of 40 ft2 per cloth
• Compare each wipe to CV card. If cloth matches
  or is lighter-passes. If darker, e-clean and
  repeat procedure.
• If second wet cloth fails, wait 1 hour or until
  surfaces dry, then wipe with electrostatically-cha
  rged dry cloth designed to clean hard
  surfaces-you are done.