1. Lead-based Paint Overview NARI-San Diego July 2016 Fritzi Gros-Daillon, MS, CSA, CAPS, RRP Renovator www.HouseholdGuardians.com 516-429-4839

2. Lead Bans/Phase-Out Late 20 th Century Residential paint (1978) Solder and pipes for drinking water Solder in food cans Gasoline Huge improvements in air quality in last 50 years but DETERIORATING LEAD-BASED PAINT still a major source of lead pollution today

3. Definitions Lead-based paint: New paint: greater than 0.06% (600 ppm) lead content. Existing paint: greater than 0.5% (5000 ppm) or 1 mg/cm2 lead content. Some counties: 0.7 mg/cm2 lead content. City of SD: Lead-Safe Work Practices (LSWP) required at 0.1% (1000 ppm) or 0.5 mg/cm2. Lead-containing paint: paint with any detectable lead. Presumed lead-based paint. State: Constructed prior to January 1, 1978. San Diego: Constructed prior to January 1, 1979 and ALL steel structures, regardless of construction date. Lead hazards: deteriorating LBP or PLBP, contaminated dust, contaminated soil, disturbance of LBP or PLBP w/o containment.

4. Applicable Regulations (a few) Title X, Lead-Based Paint Poisoning Prevention Act of 1992. HUD Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing California-OSHA Lead in Construction California Title 17, Accreditation, Certification, Work Practices for Lead-Based Paint and Lead Hazards CA SB 460 San Diego Municipal Code, Lead Hazard Prevention and Control Ordinance EPA Lead Renovation Repair and Painting Program

5. Regulations Title X, Lead-Based Paint Poisoning Prevention Act of 1992. The regulation which started it all. Evaluation hazards Risk Assessment Inspection Reduce hazards Interim controls Remediation

6. Regulations HUD Guidelines for Evaluation and Control of Lead-Based Paint Hazards in Housing Step-by-step “how-to” manual Inspection, risk assessment, monitoring, worker protection, waste management, interim controls, abatement, clearance, maintenance Written as guidance document for housing Made mandatory for public and residential buildings by California Title 17

7. Regulations California OSHA Lead in Construction – 8 CCR 1532.1 Applies to all lead exposure in construction, regardless of type of building or lead content in paint Construction includes demolition, renovation, clean-up UCSD puts compliance responsibility onto contractors: Airborne exposure limits Exposure assessment Written compliance program Respiratory protection and PPE Medical surveillance Recordkeeping

8. Regulations California OSHA Lead in Construction – 8 CCR 1532.1 Important for Protecting Workers AND Surrounding Areas: Housekeeping: wet cleaning, HEPA vacuums, prompt clean- up Hygiene facilities, change areas, showers Regulated areas Posting Certified workers if abatement of public or residential OR exposure over PEL

9. Regulations Accreditation, Certification, and Work Practices for Lead- Based Paint and Lead Hazards. Title 17 CCR 35001 - 36100 Applies to all public and residential buildings Certification of training and training providers, workers, supervisors, inspectors, project monitors Defines LPB, PLBP, lead hazards, lead-safe work practices Defines inspection, risk assessment, clearance Makes HUD Guidelines regulatory

10. Regulations Lead Hazard Prevention and Control Ordinance, San Diego Municipal Code, Division 10, 54.1001-54.1015 (2008) Applies to properties, premises, dwelling units, structures, and steel structures Re-states many requirements of Title 17 LEAD HAZARDS are dangerous to life and health and owner must prevent or correct Requires LSWP at lower lead content than LBP Defines presumed LBP one year earlier than Title 17 San Diego City enforcement team – drive-by citations

11. Regulations EPA Lead Renovation Repair and Painting Program, (2008, effective 2010) Applies to residential houses, apartments, child-occupied facilities. Renovation = ANY activity that disturbs paint. Renovation firms must be EPA-certified Workers must be trained in LSWP Pre-renovation education required (pamphlet, signs) LSWP mandatory Recordkeeping CAUTION: STATE-CERTIFIED LEAD WORKERS vs CERTIFIED RENOVATION FIRMS

12. Procedures - Variables Requirements vary based on: Building age Building function (public, commercial, residential, industrial) Lead content in paint Scope of construction/renovation State, County, City

13. Procedures - General Characterize Handling/Management Clearance Disposal

14. Procedures – Characterize Pre-1979 buildings must be inspected prior to renovation Inspection must be by certified inspectors Inspection must follow HUD Guidelines procedures Laboratories must be accredited CDPH 8552 must be submitted to State and City *Some exceptions if buildings not accessible to public.

15. Procedures – Handling/Management OSHA applies for any lead content LSWP required if over criteria Loose/flaky paint returned to intact state (abatement) Renovation/demolition in a manner that adhered paint must remain adhered Worksite preparation, containment, and clearance vary based on use of building and lead content

16. Procedures - LSWP Notice to occupants Regulated area Temporary relocation Containment (App. A, HUD Guidelines) Specialized cleaning (HEPA-wet-HEPA) Daily clean-up Proper waste disposal Clearance (visual or test dep. on building and lead content) Prohibited: burning or torching; heat guns >1100F; scraping, sanding, grinding, or blasting without containment

17. Procedures – Interim Controls Abatement designed for less than 20 years Trained workers Containment Notification Follow HUD Guidelines Chapter 11 Clearance inspection depending on conditions

18. Procedures - Abatement Abatement for 20 years or longer Certified supervisors and workers Abatement plan Notification to CDPH and OSHA HUD Guidelines, Chapter 12 Containment Clearance inspection

19. Procedures - Clearance Certified Inspector/Risk Assessor or Project Monitor Visual Dust Soil CDPH 8552 to City and State

20. Procedures - Disposal Segregate and test each waste stream Firmly adhered paint can be tested as a composite in construction debris TTLC. Total Threshold Limit Concentration. STLC. Soluble Threshold Limit Concentration. (also WET) TCLP. Toxicity Characteristic Leachate Procedure.

22. Important Numbers Presumed LBP: Pre-1979 LBP – New Paint – 0.06%, 600 ppm LBP – Existing Paint – 0.5%, 5000 ppm, 1 mg/cm2 LSWP Required – 0.1%, 1000 ppm, 0.5 mg/cm2 Lead in Air – PEL = 50 µg/m3; AL = 30 µg/m3 Contaminated Soil – 400 ppm play areas; 1000 ppm other Contaminated Dust – 40 µg/ft2 interior floor; 250 µg/ft2 interior horizontal; 400 µg/ft2 exterior Waste

23. Useful Links CA DPH Childhood Lead Poisoning Prevention Branch (lots of useful information and links): http://www.cdph.ca.gov/programs/CLPPB/Pages/default.aspxhttp://www.cdph.ca.gov/programs/CLPPB/Pages/default.aspx Ca DPH List of Certified Individuals: http://www.cdph.ca.gov/programs/CLPPB/Pages/LRCCertList.aspx http://www.cdph.ca.gov/programs/CLPPB/Pages/LRCCertList.aspx EPA’s Resources Related to Lead in Paint, Dust, and Soil: http://www.epa.gov/lead/http://www.epa.gov/lead/ HUD Guidelines: http://www.hud.gov/offices/lead/lbp/hudguidelines/index.cfmhttp://www.hud.gov/offices/lead/lbp/hudguidelines/index.cfm Compliance Guide to EPA LRRP: http://www.epa.gov/lead/pubs/sbcomplianceguide.pdf http://www.epa.gov/lead/pubs/sbcomplianceguide.pdf LRRP: http://www.epa.gov/fedrgstr/EPA-TOX/2008/April/Day-22/t8141.htmhttp://www.epa.gov/fedrgstr/EPA-TOX/2008/April/Day-22/t8141.htm Cal-OSHA Lead in Construction Standard: http://www.dir.ca.gov/Title8/1532_1.htmlhttp://www.dir.ca.gov/Title8/1532_1.html