1 Lead Safe Work Practices: Building Sustainable Capacity National Lead-Safe Housing and Indoor Environmental Health Conference 2002

2 Rachel M. Riley, CET HUD Office of Healthy Homes and Lead Hazard Control Washington, D.C. John R. Zilka QuanTech, Inc. Arlington, VA

3 Who’s Here?

4 Learning Objectives After the session attendees will be able to: –Define important terms –List activities requiring LSWP training –Describe HUD’s nationwide training initiative

5 –List HUD’s recommended LSWP trainer qualifications –Describe the training market –List materials and equipment for LSWP training Learning Objectives

6 Background and Regulatory Requirements

7 30,000+ individuals trained to date –780 sessions on LSWP »In almost every state and territory –Certification training –5 Train-the-trainer trainings for LSWP contract Approved 12 LSWP curricula Programmatic training courses and meetings Accomplishments

8 Abbreviations CFR:Code of Federal Regulations HQS:HUD’s Housing Quality Standards LSHR:HUD’s Lead Safe Housing Rule LSWP:Lead safe work practices

9 Lead Safe Work Practices (LSWP) General term for set of procedures that reduce potential for lead exposure during a broad range of activities HUD’s Lead Safe Housing Rule, 24 CFR Part 35

10 Reason and Purpose for LSWP Reason: Both scientific studies and anecdotal evidence have found a link between traditional renovation practices and blood lead and dust and soil lead. Purpose: –Protect occupants –Protect interior and exterior environments –Protect workers

11 Types of Non-evaluative Work Mentioned in Title X AbatementRegulated by EPA (40 CFR Part 745) Interim controls Rehabilitation Maintenance Not regulated by EPA Regulated by HUD (24 CFR Part 35) but only for housing associated with Federal government Renovation and remodeling May be regulated by EPA

12 Basic Federal Requirements For non-evaluative work –Worker qualifications –Work practice standards, including clearance

13 Lead Safe Housing Rule (LSHR) 24 Part 35 consolidated all HUD lead requirements Significant reliance on LSWP Required by many subparts Paired with clearance Rule supports certification required per EPA 402 rule

14 HUD Worker Qualifications 24 CFR (a)(4) Trained in OSHA hazard communication (29CFR ) Supervised by abatement supervisor or trained in lead-safe work practices

15 –Certain methods prohibited –Occupant protection and worksite preparation –Specialized cleaning methods –Required for activities disturbing more than very small amounts of painted surfaces Safe Work Practices (§ )

16 Prohibited Practices (§35.130) Open flame burning Machine sanding w/o HEPA exhaust Abrasive blasting w/o HEPA exhaust Heat gun over 1100° F Dry sanding or dry scraping (with limited exceptions) Paint stripping in poorly ventilated space using a volatile, hazardous substance

17 Activities Using LSWP –Low-level rehabilitation –Ongoing LBP maintenance –Periodic cleaning of dust or debris –Weatherization, remodeling, renovation –Interim controls –Standard treatments –Paint stabilization, repainting –Moderate and “gut” rehabilitation –Abatement

18 Terms “Lead Safe Work Practices” are used in a wide range of activities –When known or presumed LBP is disturbed in Federally assisted housing, procedures must be used by trades

19 Terms, cont’d. Not the same as “Interim Controls” –Interim controls are overall methods intended to temporarily reduce lead exposure to lead-based paint hazards (I.e., paint stabilization, lining window troughs with coil stock, covering bare soil). –Lead safe work practices are methods to control and contain dust that are used during interim controls, maintenance work or other activity.

20 “HUD-Approved LSWP Training”

21 Training Required For: HUD-approved training is required for individuals who perform interim controls: –Treat friction surfaces –Treat impact surfaces –Treat chewable surfaces –Control contaminated soil –Control lead dust hazards –Perform standard treatments –Perform ongoing LBP maintenance

22 HUD-approved training is required for individuals who: –Perform ongoing LBP maintenance –Treat bare soil –Stabilize paint –Perform regular building maintenance activities or other maintenance or renovation work impacting known or presumed LBP Training Required For:

23 Training Required For: Paint Stabilization: –Is a type of interim control –Is performed as part of owner’s ongoing LBP maintenance program –Satisfies HUD’s housing quality standards (HQS) inspection requirements Risk Assessment is not necessary to stabilize deteriorated paint

24 Training Is Recommended For: Low level rehabilitation ( < $5K/unit) Disturbance of small amount of old painted surfaces Volunteer program supervisors (“house captains”) Explains reasons and processes –Purpose and procedures –Cleaning and clearance

25 HUD-Approval Process HUD approves curricula, not delivery Private and public entities have approved courses List of approved courses is located at:

26 HUD recommends use of existing curricula HUD has Interim Training Criteria for Course Approval (see handout) Recommended instructor qualifications Submittals need to include complete curriculum and all supplemental materials for review and approval HUD-Approval Process

27 HUD’s Recommended Trainer Qualifications Background in adult education –Train-the-trainer session important –Have you presented to: Neighborhood groups? Sunday school? Work meetings? –Before you train: Assess your comfort level speaking Learn from experienced educators

28 Trainer Qualifications, cont’d. Lead Technical Competence –Risk assessor, Supervisor certification not required –Evaluation and lead hazard control knowledge important Follow State requirements for LSWP training, if applicable Understanding of Federal, State and Local Regulations and Policies Provide State contact information

29 Training Grants Met Community Needs NCHH grants Iowa State Fiberoptic Network (ICN) –Health Dept personnel delivered training –Several hundred workers trained –Rural ICN sites Public Housing Agency staff deliver LSWP training (Iowa)

30 Training Meets Community Needs Health/Housing Dept partner to develop training (Conn., N. Car.) Tribes – environmental staff deliver training Community colleges initiative Existing deliveries in community colleges (Pennsylvania, Iowa, Md.)

31 Volunteer Programs Rehabilitation Up to $5,000 federal assistance per unit Subpart J of Rule Use LSWP; no formal training required “Awareness” of lead hazards and proper techniques

32 Existing Training Sources Partnerships key Use Lead Listing as resource EPA-accredited lead training providers, universities NETA-certified instructors (CETs) OSHA Training Institutes/other Env. Health and Safety trainers

33 Curricula and Training Delivery

34 New Training A brand-new type of training Not for certification Provides “Notice of Completion” rather than a “certificate” No prerequisites Not OSHA training Currently only instructor-led; not yet computer-based or web-based 8 hours duration

35 HUD-Sponsored LSWP Training Built capacity: 30,000 workers trained by HUD Two courses were taught by HUD: HUD’s adaptation of EPA’s Model Course on Renovation and Remodeling NETA Maintenance Training Nine other approved courses are available (see handout or web site)

36 HUD-Sponsored Training Developed capacity quickly Targeted large and medium-sized cities Partnered with housing agencies –Outreach and marketing –Attendance increased with participation of local agency Some Public Housing Agencies and Community Development Agencies sponsored sessions State lead and training rules covered

37 Common Elements All HUD-approved courses must cover: –Purpose and limitations of training –Background and health effects –Lead Safe Housing Rule requirements for work practices and clearance –LBP and LBP Hazards –Regulatory overview, worker protection

38 Elements, cont’d. Prohibited work practices Containment and dust control Soil-lead hazard control Specialized cleaning Waste handling and disposal Clearance Occupant Protection Test (70% to pass)

39 HUD’s Message Lead safe work is based on simple concepts – “You can do it!” Being careful takes longer and costs a little more Numerous success stories are available This is not abatement training This is not a regulations course

40 The “Can Do” Approach Teach students how to do the “right thing” Motivate students to do the “right thing” Focus on WHAT to do; what’s different with lead Briefly outline OSHA requirements

41 Instructor’s Role Don’t alter the curriculum except to add state requirements Avoid opinion, interpretations –Avoids misstatements and misunderstanding Avoid self-promotion Acknowledge you don’t know an answer, then find out; no guessing allowed

42 Choosing a Curriculum Review all model courses –Compare audience needs to HUD training criteria –Presentation of policy issues –Encouraging compliance –Additional OSHA training –EPA requirements

43 Curriculum, cont’d. Speak or meet with State lead regulator –Receptive to LSWP training? –Is State approval required to teach? –Does model course align with State policy on: personal protection work methods clearance requirements?

44 Curricula, cont’d. Add State requirements Does State license non-abatement personnel? Sampling technicians? Other modifications Plan course approval procedure, if applicable Send State courtesy copy of curriculum if no approval procedure

45 Training Issues Curricula may be “chunked” Course delivery issues “Do’s and Don’ts” List from HUD Mission Statement Marketing advance time (no shows)

46 Training Impacts HUD does not regulate courses regarding: Schedule –Evening or weekend classes permitted –May divide content into smaller or shorter segments Training location and access –Can use housing or health agency facility –Can accept in-kind contributions –Try to reduce travel distances

47 Teaching Regulations The most common pitfall Do your homework Keep current on changes Avoid complicated discussions of rules –Will absorb precious time and derail class Refer to Interim Criteria for content items

48 Team Teaching Some lead experts may be willing to participate on training team: –Childhood Lead Poisoning Prevention Program Representatives –Health Department personnel –HUD Lead Hazard Control Grantees Sections on technical or health issues

49 Equipment & Props Plastic sheeting Duct tape Spray bottles Rags Disposable suit Buckets HEPA vacuum vs. HEPA-filtered vacuum N-100 respirator

50 So what did we learn? - 1 HUD’s initiatives are a “drop in the bucket” to what’s needed Lot’s of lead related misnomer Need to regionalize the training offerings to cover all the players Need to be more customer conscious i.e. schedule, segmented sessions

51 So what did we learn? - 2 Better out-reach and marketing efforts are needed Local sponsoring agency involvement is a must Instructor training is important to deliver the “can do” message Specific curricula and delivery issues

52 How can we build sustainable LSWP’s training capacity? Revise existing LSWP’s curricula to mesh with existing high school construction trade vo-tech programs Develop qualified trainers via LSWP’s Train-The-Trainer-Training (T4) courses Encourage a regional approach to maximize resources and avoid duplication

53 Marketing Lead Safe Work Practices Training

54 Training Market Housing agencies formerly small part of training market Certification training (mostly) available Rule requires training, not certification –States may elect to certify trained individuals

55 Marketing, cont’d. Analytical approach to marketing Understand numbers of certified people needed (low) vs. trained people needed (high) Analyze number of certified and trained people in your State Know your competition Find your niche and target needs

56 Where’s the Market? Community Development Agencies and grantees Owners receiving federal assistance - maintenance –Project-based assistance (Subpart H) –Tenant-based assistance (Subpart M) Public Housing Agencies (Subpart L) –Former lead regulations required inspection and abatement by 1994

57 Marketing Training Investigate partnerships with existing training providers Identify housing agencies and HUD field staff: Identify reasons for prior training resistance

58 Marketing the Training, cont’d. Motivating factors –Contract requirements to bid work –Preparing for regulatory compliance and monitoring by program offices –Doing “the right thing” On front lines of change Knowledge reduces liability

59 Research Existing brochures Flyers Registration materials Confirmation and follow-up strategies to reduce no-shows Test materials

60 Potential Audience The people doing the work and using “hammers and nails” –Note: HUD program staff have their own training opportunities and should not take LSWP training unless they do the “hammer and nail” work themselves. Various types of firms or organizations –Maintenance, rehab, trades, subcontractors, labor unions

61 Audience, cont. Has a range of goals and expectations Workers with language issues –Foreign language –Literacy Exist in urban or rural communities

62 Give me Five Good Reasons to Teach LSWP

63 Give me Five Good Reasons to Teach LSWP 1.There are still poisoned children in U.S. 2.Community has increasing demand for education and training 3.HUD is moving toward monitoring phase of Rule implementation 4.Delivery costs are low 5.Curricula are free

64 Resources Several available for download: Course curricula List of HUD-approved LSWP courses HUD’s interim LSWP training course evaluation criteria –

65 Resources Lead paint compliance assistance center at HUD-1012 (not the information clearinghouse)