EPA Lead Project Designer cheat sheet

Lead-based paint (LBP) is paint or other surface coating with lead concentration ≥1.0 mg/cm² or ≥0.5% by weight.

Target housing: pre-1978 residential structures, excluding housing for elderly or disabled (unless a child under 6 resides or is expected to reside) and zero-bedroom units.

Child-occupied facility: pre-1978 building visited by same child under 6 at least 2 days/week, 3 hours/day, combined 6 hours/week, or 60 hours/year.

EPA certification required for firms performing abatement, renovation, or lead hazard evaluation; individuals must be certified as inspectors, risk assessors, project designers, supervisors, or workers.

Abatement: any measure to permanently eliminate lead-based paint or lead-based paint hazards, including removal, enclosure, encapsulation, replacement, and soil removal.

Interim controls: measures to temporarily reduce lead hazards, including specialized cleaning, paint stabilization, and dust control.

Renovation, Repair, and Painting (RRP) Rule applies to renovations disturbing >6 sq ft interior or >20 sq ft exterior of pre-1978 housing or child-occupied facilities.

Clearance levels: floors 10 µg/ft², interior window sills 100 µg/ft², window troughs 400 µg/ft², and soil 400 ppm (play areas) or 1,200 ppm (other areas).

Project designer certification requires completion of an accredited training course and passing a third-party exam; certification is valid for 3 years.

Lead exposure primarily affects the central nervous system, hematopoietic system, and kidneys; children are more vulnerable due to developing brains and higher absorption rates.

Blood lead level (BLL) reference value: 3.5 µg/dL (CDC, 2021); no safe BLL has been identified.

Lead crosses the placenta and can affect fetal development; maternal exposure is a risk factor for preterm birth and low birth weight.

Acute lead poisoning symptoms include abdominal pain, constipation, fatigue, headache, and in severe cases encephalopathy, seizures, and coma.

Chronic low-level exposure in children is associated with reduced IQ, learning disabilities, attention deficits, and behavioral problems.

Lead hazard recognition includes deteriorated paint, friction and impact surfaces, dust on floors and sills, bare soil, and take-home lead from occupations.

Occupations with potential lead exposure include painting, construction, plumbing, auto repair, battery manufacturing, and smelting; take-home lead can contaminate vehicles and homes.

Chelation therapy is used for severe lead poisoning but does not reverse all cognitive effects; prevention is primary.

Risk assessment identifies lead-based paint hazards (deteriorated paint, dust, soil) and evaluates exposure pathways; inspection identifies presence of lead-based paint.

X-ray fluorescence (XRF) is the primary method for lead-based paint inspection; results are reported in mg/cm² and must be validated with laboratory analysis for inconclusive readings.

Laboratory analysis of paint samples by atomic absorption spectroscopy (AAS) or inductively coupled plasma (ICP) reports percent lead by weight.

Dust sampling uses wipe methods; clearance levels: floors 10 µg/ft², interior sills 100 µg/ft², troughs 400 µg/ft².

Soil sampling: play areas clearance 400 ppm; other areas 1,200 ppm; samples collected from bare soil areas and analyzed by laboratory.

Risk assessment includes visual inspection, dust and soil sampling, and may include paint testing; results guide hazard control recommendations.

Inspection reports must include location, substrate, condition, and testing method for each component; risk assessment reports must include hazard identification and recommended actions.

False negatives can occur with XRF due to substrate interference; false positives may occur with lead-based paint under layers; proper calibration and verification required.

Abatement project design includes scope of work, hazard control methods, worker protection, clearance requirements, and waste management.

Specifications must reference applicable regulations (e.g., EPA, OSHA, state/local) and require certified personnel and firms.

Abatement methods: removal (most permanent), enclosure (covering with rigid material), encapsulation (coating with sealant), replacement (removing component and installing new), and soil abatement.

Design must include containment and engineering controls (e.g., negative air machines, plastic sheeting) to prevent dust migration.

Clearance testing is required after abatement; visual inspection must show no dust, debris, or deteriorated paint.

Specifications should include pre-abatement inspection data, work practices, cleanup procedures, and post-abatement verification.

Project designer must ensure abatement plan is site-specific and addresses occupant protection, notification, and relocation if necessary.

Written specifications must include submittal requirements, quality assurance/quality control, and contingency plans for unexpected hazards.

Interim controls are temporary measures to reduce lead hazards and are not intended to permanently eliminate lead-based paint.

Interim control methods include paint stabilization, specialized cleaning, dust control, soil covering (e.g., mulch, grass), and safe work practices.

Paint stabilization includes repairing substrate, removing loose paint, and applying primer and finish coat.

Specialized cleaning uses HEPA vacuums and wet cleaning methods; cleaning verification may be used instead of clearance for interim controls (if allowed by regulation).

Interim controls require ongoing maintenance and reevaluation; a maintenance plan must be provided to occupants.

Hazard control strategies should prioritize areas with highest risk: friction/impact surfaces, child-accessible areas, and bare soil.

Interim controls are not appropriate for severe hazards; abatement may be required.

Education of occupants on lead-safe cleaning and hygiene is a key component of interim control strategies.

OSHA Lead Standard (29 CFR 1926.62) applies to construction work; permissible exposure limit (PEL) is 50 µg/m³ as an 8-hour time-weighted average.

Employer must conduct exposure monitoring if lead is present; if exposure exceeds PEL, engineering controls, work practices, and respiratory protection are required.

Respiratory protection: half-mask APR with HEPA filters for exposures up to 10× PEL; full-face APR up to 50× PEL; supplied-air for higher levels.

Protective clothing: disposable coveralls, head covers, shoe covers, and gloves; must be removed before leaving work area.

Medical surveillance required for workers exposed above action level (30 µg/m³) for more than 30 days per year; includes blood lead testing and medical exams.

Blood lead level removal criteria: 50 µg/dL for general workers; 30 µg/dL for workers planning to have children; return at 40 µg/dL (general) or 25 µg/dL (workers planning children).

Hygiene facilities: wash hands and face before eating, drinking, or smoking; no eating in work area; change clothes and shower at end of shift if exposed.

Training required annually on lead hazards, safe work practices, and use of personal protective equipment.

Clearance is the process of verifying that abatement or interim controls have been completed and that lead hazards are below regulatory levels.

Clearance testing includes visual inspection and dust sampling (and soil sampling if soil abatement was performed).

Clearance levels: floors 10 µg/ft², interior sills 100 µg/ft², troughs 400 µg/ft², soil 400 ppm (play areas) or 1,200 ppm (other).

Clearance must be performed by a certified inspector or risk assessor (or certified clearance technician if allowed).

If clearance fails, cleanup and retesting are required until clearance is achieved.

Post-abatement verification includes confirming work completion, proper waste disposal, and that containment was removed.

Project closeout documentation includes clearance report, waste disposal manifests, and notification of completion.

Final report must include clearance results, any remaining hazards, and recommendations for ongoing maintenance.

Lead-based paint waste is regulated as hazardous waste under RCRA if it exhibits the toxicity characteristic (TCLP lead ≥5 mg/L) or is corrosive; otherwise it may be managed as solid waste.

Waste must be containerized, labeled, and transported by a licensed hauler to an approved disposal facility.

On-site decontamination: workers must use HEPA vacuums and wet cleaning to remove lead dust from tools, equipment, and PPE before leaving the work area.

Waste water from cleanup must be filtered or treated to remove lead before disposal; never discharge to storm drains.

Containment materials (plastic sheeting, tape) must be disposed of as lead-contaminated waste.

Site decontamination includes cleaning floors, windows, and surfaces outside the work area if contamination spread occurred.

Waste manifests and disposal records must be retained for at least 3 years.

Proper waste handling prevents environmental contamination and take-home lead exposure.

Occupant notification: owners and occupants must receive a lead hazard information pamphlet (EPA/HUD/CDC) before abatement or renovation.

Notification to EPA or authorized state program required at least 5 business days before abatement (or 3 days for emergency).

Records to maintain: certification, training certificates, inspection/risk assessment reports, abatement plans, clearance reports, waste manifests, and medical surveillance records.

Records must be retained for at least 3 years (some states require longer).

Blood lead level reporting: employers must provide employees with written medical opinions and notify them of exposure monitoring results.

Real estate disclosure: sellers and landlords must disclose known lead-based paint hazards to buyers/renters of pre-1978 housing.

Reporting to EPA: certified firms must notify EPA of changes in information (e.g., address, personnel) within 30 days.

All notifications and reports must be in writing and available for inspection by regulatory authorities.