EPA Lead Supervisor cheat sheet

Lead-based paint is paint or surface coating containing lead at or above 1.0 mg/cm², or 0.5 percent (5,000 ppm) lead by weight.

Long-standing dust-lead hazard standards are 10 µg/ft² on floors, 100 µg/ft² on interior window sills, and 400 µg/ft² in window troughs.

EPA's 2024 final rule lowered dust-lead hazard standards to 5 µg/ft² (floors) and 40 µg/ft² (interior sills) and clearance levels to 4, 10, and 100 µg/ft² (floors, sills, troughs).

Bare soil is a lead hazard at 400 ppm in play areas and 1,200 ppm in other bare soil where children are exposed.

Children absorb about 40–50 percent of ingested lead; adults absorb about 10–15 percent, so the same dust loading carries greater child risk.

Lead blocks ALA dehydratase and ferrochelatase in the heme pathway, causing anemia, and competes with calcium in nerve and enzyme function.

No safe blood lead level in children is known; CDC's blood lead reference value is 3.5 µg/dL.

Lead crosses the placenta and damages the developing nervous system; other effects include nephrotoxicity, hypertension, colic, and encephalopathy at high exposure.

Deteriorated paint, friction surfaces (windows, doors), impact surfaces, and chewable surfaces are the principal paint-lead hazard pathways.

TSCA Title IV (15 U.S.C. 2681–2692) is implemented at 40 CFR Part 745 and authorizes EPA's abatement, certification, and disclosure programs.

EPA individual certifications are inspector, risk assessor, abatement supervisor, abatement worker, and project designer; firms must also be certified.

The certified firm must notify EPA or the authorized state program in writing at least 5 working days before abatement begins, unless the state requires a longer period.

The RRP rule covers pre-1978 target housing and child-occupied facilities when renovation disturbs more than 6 ft² interior or 20 ft² exterior; RRP is not abatement.

Pre-renovation education requires delivering the EPA pamphlet 'Protect Your Family from Lead in Your Home' to occupants of pre-1978 housing before work starts.

OSHA 29 CFR 1926.62 governs construction lead exposure: PEL 50 µg/m³ and action level 30 µg/m³, both 8-hour time-weighted averages.

RCRA classifies lead-bearing waste as hazardous when TCLP leachate is at or above 5 mg/L (toxicity characteristic, waste code D008).

EPA-authorized state programs may be stricter than federal rules; where requirements conflict, the more stringent requirement applies.

Sellers and lessors of pre-1978 housing must disclose known lead-based paint and hazards, and buyers get a 10-day period to test.

Abatement methods are component removal, component replacement, enclosure, encapsulation, surface stripping (on- or off-site), and soil removal or replacement.

Containment uses two layers of 6-mil polyethylene on floors, one layer on walls, lapped and taped, with critical barriers sealing doors, windows, HVAC vents, and penetrations.

HEPA-filtered negative air machines exhaust outdoors and hold the containment under negative pressure for the duration of abatement.

Prohibited practices include open-flame burning, uncontrolled abrasive blasting or dry machine sanding without HEPA exhaust, hydroblasting without containment, and methylene chloride stripping.

Heat guns used to strip paint must operate below 1,100 °F to avoid generating lead fume.

Encapsulants may be used only on non-friction, non-impact, non-chewable surfaces and only when the product is listed for that substrate and applied per label.

A certified supervisor must be physically on site whenever abatement is performed and may direct only trained, certified workers.

Workers follow a project-specific work plan; eating, drinking, smoking, and chewing are prohibited inside the work area, and hands and face are washed before breaks.

End-of-shift decontamination and daily cleanup are performed before leaving the work area, with debris bagged and the containment re-secured.

Exposure above the 30 µg/m³ action level triggers medical surveillance eligibility, and blood lead plus ZPP testing at least every 6 months (every 2 months when BLL is 25 µg/dL or higher).

Assigned protection factors: half-mask air-purifying respirator 10, full facepiece 50, powered air-purifying respirator with loose-fitting hood 25.

A written respiratory protection program must include medical evaluation, fit testing, training, cartridge change schedules, cleaning and storage, and program evaluation.

Medical removal is required when blood lead averages 50 µg/dL or higher; the worker may return to lead work after blood lead falls below 40 µg/dL.

PPE for abatement includes disposable coveralls with hood, boot covers, nitrile gloves, and eye protection, removed before leaving the work area.

Showers are required when airborne lead exceeds the PEL more than 30 days per year; otherwise wash-up facilities and separate clean change areas are required.

Engineering controls come first: HEPA vacuums, wet methods, local exhaust ventilation, and containment keep airborne lead below the PEL.

Eating, drinking, smoking, chewing gum, and applying cosmetics are prohibited in the work area; hands and face must be washed before eating or drinking.

Respirator use requires a medical clearance and annual fit testing; facial hair at the sealing surface prevents an adequate tight-fitting seal.

Final cleaning proceeds top-down: HEPA vacuum all surfaces, wet wash with detergent, then HEPA vacuum again before clearance sampling.

Long-standing clearance levels are 40 µg/ft² on floors, 250 µg/ft² on interior window sills, and 400 µg/ft² in window troughs; EPA's 2024 rule set clearance at 4, 10, and 100 µg/ft².

Clearance requires a visual inspection showing no dust, debris, paint chips, or residue, followed by dust wipe sampling by a certified inspector, risk assessor, or clearance technician.

The clearance examiner must be independent of the abatement contractor and may not clear a project on which the person performed abatement work.

If clearance fails, the area is recleaned and retested; reoccupancy is not permitted until clearance is achieved.

Waste goes into sealed, labeled, dust-tight containers (6-mil bags or drums); TCLP testing determines whether the debris is D008 hazardous waste.

Hazardous lead waste requires a manifest, a permitted transporter, and a permitted treatment, storage, and disposal facility; loads must be covered in transit.

The contractor gives the building owner a written abatement report within 10 days of completion, describing methods, dates, and clearance results.

OSHA requires employee exposure and medical records for lead-exposed workers to be retained for 30 years; abatement and certification records are retained per EPA and state schedules.