Table of Contents I.Introduction II. Health Effects / Sources of Lead III.Essential Maintenance Practices IV.Record Keeping / Disclosure
Manual Page 5 Section I Introduction
Purpose To protect young children from exposure to lead paint hazards and lead-contaminated dust caused by deteriorating paint. To learn how to safely maintain and renovate older housing that contains lead paint.
Purpose Creates a standard of care with respect to lead paint in rental housing and child care facilities. Provides some legal protections for property owners who comply with the law.
What does the Vermont Lead Paint Law Require ? Completion of approved training. Performance of Essential Maintenance Practices (EMPs). Submission of a Compliance Statement. Informational pamphlet & copy of Compliance Statement provided to tenants. Posting a notice for tenants to report deteriorated paint.
Essential Maintenance Practices (EMPs) Visual Inspection of Painted Surfaces Safe Repairs to Problem Areas Do Not Use Prohibited Practices Window Well (Trough) Liners Special Cleaning Practices – including removal of paint chips
About the Course Meets the training requirements of Vermonts Lead Paint Law (Title 18, Chapter 38) Listed as an approved course under federal law (Lead Safe Housing Rule - 24 CRF Part 35)
When does the Law apply? Vermonts law applies to all target residential rental units and child care facilities in buildings constructed before The law applies to ALL pre-1978 target rental property, whether or not children live there.
What Types of Properties or Situations are Exempt? A Vermont-licensed lead paint inspector or risk assessor has certified that the property is lead free.
What Types of Properties or Situations are Exempt? Zero (0) bedroom dwellings like studio or efficiency apartments unless a child under 6 resides there. Dwellings located in multiple unit buildings or projects reserved for the exclusive use of the elderly or persons with disabilities, unless a child under 6 resides there.
What Types of Properties or Situations are Exempt? Units in hotels, motels, or other lodging, including condominiums that are rented for transient occupancy for 30 days or less Renting a single room in your home unless a child age 6 or younger is present.
Recent Changes to Vermonts Lead Paint Law Unsafe work practices are prohibited in pre-1978 housing, rental and owner occupiedUnsafe work practices are prohibited in pre-1978 housing, rental and owner occupied. Specialized cleaning in all common areas at least annually. All visible paint chips must be removed from the property. No cleaning required in occupied units unless work is done.
Recent Changes to Vermonts Lead Paint Law Compliance Statements instead of Affidavits. Tenants must be given copies of Compliance Statements. New requirements for real estate transactions involving pre-1978 residential properties. New enforcement provisions.
Limitations of This Course This training does not qualify individuals for the following: Lead Abatement Work Inspections, Risk Assessments Paint, Dust or Soil Sampling EPA Renovator (new 2010)
Basic Principles Assume lead paint is present. Avoid creating and spreading dust by using safe practices. Protect occupants, especially children, and workers. Clean up after all work. Maintain building in good condition.
Unsafe Work Practices (Prohibited) Anyone disturbing or repairing more than one(1) sq/ft of paint in pre-1978 housing must use Lead Safe Work Practices. Certain unsafe practices are prohibited in all pre-1978 housing.
Unsafe Work Practices (Prohibited) It is illegal to remove Lead-Based Paint by: Open flame burning or torching Heat guns operated at >1100 F Dry scraping / dry sanding Machine sanding or grinding Uncontained hydro-blasting or high pressure washing Abrasive blasting without HEPA exhaust Use of chemical strippers containing Methylene Chloride
Lead Safe Work Practices (Required in all pre-1978 housing) Limiting access to work areas Containing work areas with plastic sheeting Using protective clothing Misting painted surfaces before scraping or sanding Wetting paint debris before sweeping
HEPA Vacuums High Efficiency Particulate Air (HEPA) Filter Type of air filter that removes 99.97% of particles 0.3 microns or larger. Removes all particulates including dust, allergens, pet dander, and lead. Helpful for asthmatics, allergy sufferers.
HEPA Vacuums HEPA filters now available on many vacuum types. Overall quality of vacuum will determine effectiveness. Pre-filters and good bags will extend life of HEPA filters. Caution: bag-less vacuums and shop vacs will become contaminated in collection chamber.
Manual Page 9 Section II Health Effects
What is Lead? A metallic element with a chemical symbol Pb. Does not break down over time. Used widely by humans for thousands of years. Toxic to humans. League of Nations banned lead paint for residential uses in the 1920s.
No Safe Level of Lead There is no safe level of lead in the human body. Even small amounts have been shown to cause damage. Unlike other heavy metals such as iron and zinc, the human body has no use for lead.
Action Levels In February 2007 the Vermont Department of Health lowered the level of concern for lead in childrens blood to 5 micrograms per deciliter (ug/dl). The federal level of concern remains at 10 ug/dl.
Children with Elevated Blood Lead Levels In 2008, at least 1261 Vermont children six or younger had blood lead levels at 5 ug/dl or greater. Not all children are tested, therefore the actual number of children with elevated blood lead levels is unknown.
Children with Elevated Blood Lead Levels Based on the childs blood lead level, the Health Department will take action, up to and including an environmental investigation of the childs home and other environs. In most cases, there is no medical treatment to remove lead from the body. Levels will drop slowly if the source of exposure is removed.
Facts about Lead Poisoning Affects both adults and children Silent / no obvious symptoms Affects virtually every system in the body All cases are preventable Housing-based hazards the most common cause
Leads Effects on Children Damage to the brain and nervous system Behavior and learning problems Slowed growth Hearing problems, headaches Other non-specific symptoms
Leads Effects on Children A child died from lead poisoning in 2001 in Manchester, NH A child died in Minnesota in 2006 after ingesting a toy charm that came with childrens shoes. The charm was 97% lead.
How do Children get Lead in Their Bodies? Ingesting lead-contaminated dust or paint chips from deteriorating paint. Ingesting soil contaminated with lead from paint chips or leaded gasoline. Inhaling lead dust or fumes.
How do Children get Lead in Their Bodies? Normal hand-to-mouth behaviors of young children contribute to ingestion of lead. Children absorb more of the lead they ingest than adults.
Blood Testing for Lead All Children should be tested at ages 1 and 2. If at risk, further testing may be appropriate. Adults should be tested if they believe they have exposure from workplace or hobbies.
Leads Effects on Adults Nerve disorders, muscle & joint pain. Physical fatigue, memory and concentration problems. Loss of sex drive and function. High blood pressure. Digestive problems. Pregnant women can release lead from their bones which can damage fetus.
How do Adults get Lead in Their Bodies? Breathe in lead dust (especially during renovations that disturb painted surfaces). Put their hands or other objects covered with lead dust in their mouths while eating, drinking, or smoking.
How do Adults get Lead in Their Bodies? Working with lead in their occupation or hobbies such as using indoor gun ranges, making stained glass, ceramics, or auto repair, to name a few. Mr. Gregory Blodgett of Bellows Falls, Vermont (manual page 15)
Common Sources of Lead Dust Paint Soil Industrial Emissions Water Keys / Brass Items Ceramics Gasoline Many others
How Widespread is Lead Paint in Housing?
Manual Page 23 Section III Essential Maintenance Practices
Essential Maintenance Practices (EMPs) Lead Safe Work Practices Visual Inspection of Painted Surfaces Paint Stabilization Window Well (Trough) Liners Special Cleaning Practices Removal of Paint Chips
Lead Safe Work Practices (Required in all pre-1978 housing) Limiting access to work areas Containing work areas with plastic sheeting Using protective clothing Misting painted surfaces before scraping or sanding Wetting paint debris before sweeping
Unsafe Work Practices (Prohibited) Removing Lead-Based Paint by: Open flame burning or torching Heat guns operated at >1100 F Dry scraping / dry sanding Machine sanding or grinding Uncontained hydro-blasting or high pressure washing Abrasive blasting without HEPA exhaust Use of chemical strippers containing Methylene Chloride
Benefits of Safe Work Practices Protect your health Protect your family by not bringing dust home with you Protect residents, especially children Simplify daily and final cleanup Enhance reputation for knowledge and professionalism
Dont Spread Lead Video
Protective Clothing Anyone disturbing painted surfaces should take precautions to keep dust and debris off of themselves. Disposable coveralls & shoe covers Gloves / painters hat Pre-moistened disposable wipes for wiping face and hands N-100-rated disposable or other approved respirators
Protect Yourself and Your Family Workers should wear protective clothing; or change out of work clothes before leaving job site. –Disposable coveralls Can be reused if not ripped Repair tears with duct tape Store in plastic bag Wash face and hands frequently –Helps to reduce hand-to-mouth ingestion of lead dust
Protect Yourself and Your Family Failure to follow proper precautions can result in contamination of workers cars and homes. Numerous cases have been documented where children have been exposed to lead from contaminated work clothes.
Control the Spread of Dust When you leave the work site –Remove coveralls or HEPA vacuum clothing –Remove shoe covers or wipe down shoes –Wipe down all tools and equipment. Dont take lead home to your family on your clothes or in your car. Wash hands and face. Shower as soon as possible. Launder work clothes separately from other clothes.
Lead Contamination Facts A pennys weight (2.8 grams) of lead would be enough to contaminate 70,000 square feet of floor space (or x10 rooms). The exterior of an old home may have hundreds of pounds of lead in the paint.
Tools for Proper Work Site Set-Up Barriers & Signs. Heavy Duty (6 mil) plastic sheeting Tape (duct, painters, masking). Utility Knife Tack Mats Shoe Covers
Manual Page 37 Overview of Interior Set-Up Steps Step 1: Limit access Step 2: Cover belongings that can not be moved Step 3: Cover floors Step 4: Close windows, doors, and HVAC system
Interior Set-Up Step 1: Limit Access Instruct residents to stay away from work area Do not allow small children (under 6 years) or pets near work area Place a barrier or tape across entrances Post a sign Do not allow eating, drinking, or smoking in the work area
Insert illustration here Interior Set-Up Step 2: Remove and Cover Belongings Remove belongings like lamps, pictures, toys, tables, etc. Cover large, unmovable furniture and other objects in protective sheeting. Cover floors with protective sheeting.
Interior Set-Up Step 3: Cover Floors Cover floors with protective sheeting. At least five feet on all sides of work area. Place a tack pad at edge of protective sheeting, lay protective sheeting on frequently used walking paths to outdoors and bathrooms. 5 5
Interior Set-Up Step 4: Close Windows, Doors, HVAC Close all windows and doors Close and seal HVAC vents
Manual Page 41 Bad Interior Set-Up Practices Spread Lead-Contaminated Dust Reusable drop cloth Furniture and household objects in the room Open doors and windows Broom or shop vacuum Do not use these practices when lead is present!
Manual Page 43 Overview of Exterior Set-up Steps Step 1: Establish work area Step 2: Close windows and doors Step 3: Weather considerations
Exterior Set-Up Step 1: Establish Work Area Cover the ground with protective sheeting –If space permits, extend at least 10 feet from work area –Cover nearby vegetable gardens and children's play areas Limit work area access –Establish a 20 foot perimeter around work area if space permits 20
Exterior Set-Up Step 2: Close Windows &Doors Close nearby doors and windows within 20 feet of the work area
Exterior Set-Up Step 3: Weather Considerations Exterior paint stabilization should not take place when wind or weather causes dust or debris to escape containment. Rain can quickly wash paint chips from plastic sheeting into yard - clean work areas frequently. Most paints must be applied and dry at temperatures above 50 degrees.
Caution Be aware that on sunny days, grass can be killed in a few hours under plastic (poly) sheeting. A cloth tarp underneath plastic can minimize damage to grass and shrubs. Never use cloth tarp alone.
Bad Exterior Set-Up Practices Spread Lead-Contaminated Dust Ground uncovered Reusable drop cloth Paint chips No barriers Windows and doors open Do not use these practices when lead is present!
EMP Specialized Cleaning Using methods, products and devices shown to be effective at removing lead contaminated dust (both visible & invisible).
Cleaning Supplies Vacuum with HEPA filter Misting bottle and pump sprayer Disposable rags or towels Detergent Mop with disposable heads Buckets for soap, rinse water, and wringing Heavy duty garbage bags Shovel and rake for exterior paint chip removal
What is Effective Clean Up? While working, contain dust and debris in immediate work area Removal of all visible dust and debris Wet wiping all adjacent surfaces, tools, shoes, etc. Using a HEPA-filtered vacuum Safe and secure disposal
Cleaning Hard Floors Use multiple buckets for detergent and rinse water. Change rinse water often.
When is Specialized Cleaning Required? Change of Tenant - clean all horizontal surfaces (including floors, trim, tops of doors, sills, shelves, etc., but not ceilings) Common Areas – at least annually clean all horizontal surfaces After any work that disturbs paint - clean all affected surfaces and areas
Exterior Clean-Up Techniques Clean plastic sheeting –Use wet methods to remove any debris or chips on sheeting –HEPA vacuum sheeting –Fold plastic with dirty side in, seal with duct tape and dispose of properly Visually inspect beyond work area – remove all chips/debris
Keep In Mind Schedule time to clean thoroughly at the end of each day Assign responsibilities to specific personnel Create and maintain a checklist for cleaning procedures Always maintain sufficient cleaning and disposal supplies Dust clearance testing is an option for checking your work
Visual Inspection of Painted Surfaces When? At least once a year (annually) At unit turnover
Interior Visual Inspection Conduct a visual inspection of each room or interior common area of building to which tenants have access. Look for any deteriorated paint. Note location and amount. Example inspection form on Page 25 of course manual.
Interior Visual Inspection If greater than 1 square foot (144 sq. inches) of cumulative deterioration is found in a room or area, it must be repaired within 30 days. Deterioration includes chipping, peeling, flaking, cracking, or otherwise damaged paint.
Interior Visual Inspection Document completion of inspection. Document date of repairs and by whom.
Exterior Visual Inspection Conduct a visual inspection of each exterior side of building, and other painted surfaces like fences and outbuildings. Look for any deteriorated paint. Note location and amount. Example form on Page 31 of course manual.
Exterior Visual Inspection If greater than 1 square foot of cumulative deterioration is found on any exterior wall, porch, or other painted surface, repair within 30 days. If discovered after November 1st, block access and make exterior repairs by the following May 31st.
Exterior Visual Inspection Document completion of inspection. Document date of repairs and by whom.
Paint Repair Tools & Supplies Water Misting Bottle Wet/Dry Sandpaper Disposable Paper Towels / Rags Heavy Duty Garbage Bags Vacuum with HEPA filter Spackle
Paint Stabilization All painted surfaces should be intact: no peeling, chipping, flaking, cracking, blistering, etc. Lightly mist surfaces with water. Scrape areas of deterioration, making sure debris stays within immediate work area.
Paint Stabilization Use wet sandpaper or a wet sanding block to smooth transitions between intact paint and bare wood or substrate. Fill large transitions or gaps with spackle or other suitable material. Wipe stabilized area with wet disposable towel or rag.
Paint Stabilization If airborne dust observed, stop activity and evaluate method. Use only sharp scrapers. Carbide scrapers last longer. Remove dust and debris often using wet methods.
Paint Stabilization Prime areas of bare wood in stabilized area Finish paint area as needed Stabilized surfaces will quickly deteriorate if not primed and painted
Interior Paint Stabilization Clean Up Pick up large debris. HEPA vacuum all surfaces, including plastic sheeting. Fold up plastic from corners. Dispose of all waste in doubled garbage bags.
Interior Paint Stabilization Clean Up Clean work area with cleaning solution. Wipe surfaces with disposable rags or paper towels. HEPA vacuum surfaces again. Wet mop hard floors.
Exterior Paint Stabilization Use same principles as interior. Be aware of external factors: –Wind, rain, people in work area, be sure doors & windows remain closed.
Soil Issues Soil around the perimeters of old homes is often highly contaminated with lead. Contamination from exterior paint and gasoline. Bare soil makes lead accessible to children. Do not grow vegetables in potentially contaminated soil.
Removal of Visible Paint Chips All visible paint chips must be removed from the ground on all outdoor areas of the property. Applies to rental properties and child care facilities.
Removal of Visible Paint Chips Paint chips are often found around the perimeter of old buildings and other painted features like fences. At least once a year, property owners should inspect all outdoor areas for paint chips. Large chips can be picked up by hand (wear gloves). The presence of many small chips may require removal of a few inches of top soil.
Removal of Visible Paint Chips Do not rake chips. Raking will break the chips into smaller pieces and spread them. Paint chips on driveways and other hard surfaces should be misted and carefully swept up. A HEPA vacuum may be used, especially in grassy areas. The manual describes a special hose attachment for outdoor use.
Soil Treatments RECOMMENDATIONS Cover bare areas with mulch, gravel, new soil, etc. Plant grass to cover bare areas. Block children from problem areas with plantings, fencing Otherwise limit access to bare soil
Window Well Liners Must be installed in all double- hung wooden windows, even those painted or nailed shut. Does not apply to windows with no wells like casement, awning, or slider types. Vinyl or aluminum windows exempt.
Remove all furniture and other items from the work area.
Lay plastic sheeting.
Restrict Access to Work Area.
Gather all supplies in work area.
Brace window open if necessary
Typical condition of window wells
Vacuum loose debris from window well
Wet scrape deteriorated paint from window well.
Remove old caulking, hardware, and other debris.
Remove built-up paint to square up corners
If possible, create a gap under window parting bead to allow coil stock to be slid underneath
Wipe up debris with wet disposable towel
Pick-up larger debris with wet disposable towel
Vacuum remaining debris
Measure well length and width
Measure coil stock
Coil stock may be cut by scoring with a utility knife, using a straight edge as a guide. BE CAREFUL!
Bend coil stock as shown to break on scored line.
Coil stock may also be cut using tin snips
Measure for window well depth and cut as previously described
Dry fit to determine if edge cuts are necessary
Mark edge cuts
Cut edges to fit shape of jamb
Dry fit to check accuracy of edge cuts
Apply caulking to window well only, not directly on coil stock
Place coil stock into well & press firmly into caulking
Always use aluminum nails with aluminum coil stock. Steel nails will cause corrosion.
Nail coil stock. Avoid dents or dimples.
Caulk around edges
If caulking lower edge, leave weep holes for water to escape
Vacuum work area and wet wipe all affected surfaces.
Fold up plastic keeping contaminated side turned in
Place all debris in doubled garbage bags and dispose of properly
Check area for any remaining dust or debris, vacuum or wipe if necessary
Special Considerations for Child Care Facilities Regular daily cleaning should be part of every child care centers routine. Efforts should be made to limit exterior dust tracked in (remove shoes, wipe feet, etc.)
Special Considerations for Child Care Facilities More frequent inspections for deteriorated paint (weekly, monthly). Do not let children play in areas of bare soil.
Manual Page 79 Waste What should I do with my waste? At the work site –Place waste in heavy duty plastic bag or doubled garbage bags –Gooseneck Seal the bag with duct tape –Store waste in a secure area
Waste Disposal Secure waste for transfer. Waste generated through EMP activities can be treated as normal household waste. Recent guidance from Vermont Agency of Natural Resources - Waste Management Division (2006) - see course manual Page 80.
Manual Page 83 Section IV Record Keeping / Disclosure
Compliance Statement Documents completion of EMPs. Must be completed every 365 days unless property is proven to be lead free or otherwise exempt. Copies to Health Department, insurance carrier, and tenants. Keep copy for your records. Child care facilities must also send to Department for Children & Families. Compliance Statements in Appendix
Compliance Statement Complete property address information. Check appropriate property type. For each Essential Maintenance Practice listed, provide date of completion and EMP certificate number of person who did work.
Compliance Statement 1.Exterior Inspection 2.Exterior Stabilization 3.Paint Chip Removal 4.Common Area Stabilization 5.Common Area Cleaning 6.Post notice
Compliance Statement 7. Window Well Inserts 8. Interior Inspection/Stabilization 9. Change of Tenant 10. Tenant Disclosure - Protect Your Family Pamphlet - Copy of Compliance Statement 11. Signature
Compliance Statement Different compliance statement forms for: 1. Rental Properties 2. Child Care Facilities Providing false information on Compliance Statement is fraud
Manual Page 84 Notice to Occupants - Example Poster in Manual Appendix Post, in a prominent location, a notice to occupants emphasizing the importance of promptly reporting deteriorated paint to the owner or owners agent. Post in each apartment, or prominently in a common area used by all tenants. Tip: inside kitchen cabinet doors
Keeping Records Remember all records or information about lead paint must be disclosed to tenants and prospective tenants. Keep all lead paint information together in a three-ring binder, including compliance statements, inspection sheets, records of repairs, proof of notifications, etc.
Federal Disclosure Requirements Property owners must disclose the likely presence of lead paint to tenants or potential buyers. Any specific reports or documents about lead or lead hazards in the unit must be disclosed. Provide Protect Your Family From Lead brochure.
Federal Disclosure Requirements Owners should document completion of disclosure requirements and keep records. Example forms provided in course manual appendix. EPA fines for failure to disclose are substantial ($11,000/day).
Real Estate Transactions & the Vermont Lead Law Vermont law requires that sellers of pre-1978 residential real estate provide lead disclosure information and lead education materials to buyers.
Real Estate Transactions & the Vermont Lead Law A current compliance statement has been filed The property is subject to an Assurance of Discontinuance, Administrative Order or Court Order The terms of any such Assurance or Order have been completed Sellers of residential rental properties must disclose whether
Buyers of Residential Real Estate If the residential rental property is not currently in compliance with the EMP requirements: –Buyer must bring property into compliance within 60 days after closing –Failure to comply with this requirement will result in a mandatory civil penalty.
Real Estate Transactions & the Vermont Lead Law Sellers of rental properties must provide educational materials and make disclosures –Prior to the execution of the purchase and sales agreement –Prior to and at the time of sale
Real Estate Transactions & the Vermont Lead Law Download all required forms and pamphlets from: RealEstateTransactions.aspx
REMINDER This training does NOT qualify individuals for the following: Lead Abatement Work Inspections, Risk Assessments Paint, Dust or Soil Sampling EPA Renovator (coming 2010)
Manual Appendix 1. Regulatory Levels for Lead 2.Vermont vs. federal law comparison 3.Lead Dust Testing 4.Lead Contamination Facts 5.Other Sources of Lead 6.Facts about HEPA vacuums 7.VSA 18, Chapter 38 8.Useful Lead Resources 9.Protect Your Family from Lead… 10.Federal Disclosure Forms 11.Example Poster 12.Compliance Statements