Lead-Safe Work Practices

Lead paint was common in US homes until the federal government banned it for residential use in 1978. It is still under newer coats in millions of buildings. When you scrape, sand, cut, drill or demolish a painted surface, you can turn old paint into fine dust that you cannot see. That dust harms children most, because it damages the developing brain, and it can harm adults too through the nervous system, kidneys and blood pressure. You can also carry it home on your clothes.

This applies to anyone who disturbs painted surfaces: painters, carpenters, window installers, drywall crews, plumbers, electricians, HVAC techs and maintenance staff. Two sets of rules come into play. EPA's Renovation, Repair, and Painting Rule (RRP) protects the people who live in or use the building. OSHA's lead in construction standard (29 CFR 1926.62) protects you, the worker. Some states run their own programs with stricter rules, and your state's rule wins.

A guide can introduce these rules but cannot certify you. RRP work requires a certified firm and a certified renovator who has completed an accredited course. Removing lead permanently is called abatement, and that is a separate licensed activity.

What You Will Be Able to Do

• Decide whether a job is likely to involve lead paint and whether RRP applies.
• Name the work methods that are banned on RRP jobs.
• Set up containment and clean up a work area correctly.
• Protect yourself from lead dust and keep it out of your home.
• Know when to stop and bring in a certified person.

Does RRP Apply to This Job?

Ask these questions before you disturb any paint:

1. Was the building built before 1978? If you do not know, treat it as pre-1978.
2. Is it a home or a child-occupied facility? The rule covers target housing, which is most pre-1978 homes and apartments, plus places like child care centers and kindergartens that young children visit regularly.
3. Are you being paid? The rule covers contractors, and also landlords, property managers and in-house maintenance staff.
4. Will the work disturb more than a small area? The rule does not apply to minor repair and maintenance that disturbs 6 square feet or less per room inside, or 20 square feet or less outside. However, window replacement, demolition and any banned practice always count, no matter the size.
5. Has the paint been tested? Work is exempt only if a certified inspector or a certified renovator using an EPA-recognized method shows that the components being disturbed are free of lead-based paint.

If you are unsure, assume lead is present and treat the job as covered.

What the Rule Requires

• A certified firm. The company is certified by EPA or an authorized state.
• A certified renovator on the job. This person trains other workers, directs the setup, and verifies the cleaning. They complete an accredited course, and they refresh it before the certification runs out.
• Notice to the owner and occupants. Give them EPA's Renovate Right pamphlet before work starts, and keep proof.
• Lead-safe work practices as described below.
• Records kept for at least 3 years.

Banned Methods

On RRP jobs, these methods are not allowed because they create huge amounts of dust or fumes:

• Open-flame burning or torching of paint.
• Sanding, grinding, planing, needle gunning or blasting with power tools, unless the tool has a shroud and a HEPA vacuum attachment.
• Heat guns at or above 1,100°F.

Other programs can add more rules. Federally assisted housing, for example, also bans dry scraping and dry sanding in most cases, so you should wet the surface first.

Setting Up the Work Area

The goal is to keep dust inside a space you control.

Inside the building:

1. Move everything you can out of the work area. Cover what stays with plastic, taped down.
2. Close and seal windows, doors and vents. Cover the HVAC registers, and turn the system off if it would spread dust.
3. Cover the floor with taped plastic at least 6 feet out from the work in every direction.
4. Post signs telling people to keep out. Keep residents and pets away.
5. Set up a door flap or a sticky mat so dust does not leave on your shoes.

Outside the building:

1. Close doors and windows within 20 feet of the work.
2. Cover the ground with plastic at least 10 feet out from the work, farther if you are working high up or the wind is blowing.
3. Stop work in high wind if you cannot keep dust from blowing away.
4. Keep tools, debris and plastic off neighboring property.

Working Without Making Dust

• Mist the surface with water before you scrape or sand by hand.
• Score paint before you separate painted parts, so it breaks along a line.
• Use tools with HEPA shrouds. Keep the vacuum running.
• Pry and pull rather than breaking or pounding.
• Cut only what you need to cut. Every hole through a painted wall makes dust.
• Do not eat, drink or smoke in the work area.

Cleaning Up

A broom and shop vacuum make the problem worse by throwing fine dust into the air. Use these steps instead.

1. Pick up chips and debris as you go. Keep them in the work area, and seal them in heavy plastic bags.
2. Mist the plastic, fold it dirty side in and tape it, then bag it.
3. Vacuum all surfaces with a HEPA vacuum, working from the top down: walls, trim, windowsills, floors.
4. Wipe surfaces with wet cloths. Mop floors with a two-bucket system or a wet mop.
5. Have the certified renovator check the cleaning. On RRP jobs that means a visual check and a cleaning verification with wet disposable cloths compared to the EPA card, or a dust test by a qualified professional.
6. Keep residents out until the area passes.

Follow state and local rules for waste. On most residential work, bagged debris can go out with regular construction waste. Do not dump wash water on the ground or down a storm drain.

Protecting Yourself

OSHA's construction lead standard sets a permissible exposure limit of 50 micrograms of lead per cubic meter of air over an 8-hour day, with an action level of 30 micrograms. Exposure must be assessed. Until that is done, the employer must treat tasks like manual scraping, manual sanding, heat gun use and manual demolition as exposures above the limit. That means respirators, protective clothing, hand washing facilities, blood lead testing and training are all required.

Your own routine matters as much as the rule:

1. Wear a properly selected respirator when the job calls for it. For lead dust, that usually means one with HEPA (P100) filters. Your employer needs a respirator program with fit testing.
2. Wear disposable coveralls or dedicated work clothes and shoe covers.
3. Wash your hands and face before you eat, drink or smoke, and at the end of the shift.
4. Do not eat, drink or smoke in the work area.
5. Leave the dust at work. Change clothes and shoes before you get in your car. Bag dirty clothes and wash them separately. Never use compressed air to blow dust off your clothing.
6. Ask about blood lead testing if you do this work often, and tell your doctor. If you have symptoms such as stomach pain, headaches, fatigue or irritability, or if you or a partner is pregnant, ask for testing.

Warning: Children in your home can be poisoned by the dust you bring back on your clothes, boots and tools, even if they never go near the job.

When to Stop and Ask

Stop and talk to your supervisor or certified renovator if:

• You find old paint on a pre-1978 building and no one has said whether it was tested.
• You are told to use a banned method to save time.
• Plastic has been torn down, or dust has left the work area.
• Paint chips are in a place where a child could reach them.
• You are asked to remove paint from a large area, which may be abatement and require a different license.

Common Mistakes

Check Your Understanding

1. A 1965 apartment needs a section of painted baseboard replaced, about 3 square feet in one room. Does RRP apply?

It may qualify as minor repair and maintenance, as long as you use no banned methods. You still need to work carefully and clean up well. If the job grows past 6 square feet in that room, it is covered.

2. You are replacing old windows in a 1950 house. How many square feet is the exception?

There is no exception. Window replacement in a covered building always counts, regardless of size.

3. The foreman wants to use a heat gun at its highest setting to strip a door. What should you check?

The heat gun must be under 1,100°F. Open flame is banned outright. Ask the certified renovator how to do the work, and keep a respirator in mind.

4. At the end of the shift, your boots and pants are dusty. What do you do before driving home?

Change clothes and boots, bag the dirty ones, and wash your hands and face. Wash work clothes separately from family laundry.

5. A coworker reaches for a shop vacuum to clean up after scraping. What should you say?

Use a HEPA vacuum and wet wiping. A regular shop vacuum blows the finest dust back into the air.

Key Takeaways

• If a building is from before 1978 and has not been tested, assume there is lead paint.
• RRP work needs a certified firm, a certified renovator and lead-safe practices.
• Never use open flame, unshrouded power sanding or a heat gun at 1,100°F or above.
• Contain the work, keep dust down, and clean with a HEPA vacuum and wet wiping.
• Wash up, change clothes and leave the dust at work.