(C) Permissible Lead Abatement Project
Strategies. Strategies that are permissible for lead abatement projects are as
follows: replacement, enclosure, encapsulation, or removal. Any abatement
strategy not specified herein shall be submitted to the Missouri Department of
Health, Office of Lead Licensing and Accreditation, PO Box 570, Jefferson City,
MO 65102-0570 for evaluation and approval prior to use.
1. Replacement.
A. Non-window component replacement. When
conducting non-window component replacement, these minimum requirements shall
be met-
(I) The site shall be prepared by
first establishing a regulated area using fencing, barrier tape, or other
appropriate barriers. The regulated area shall be defined to prevent unlicensed
and/or unauthorized personnel from approaching closer than twenty feet (20') to
the replacement operation;
(II)
Signs shall be posted at all entrances to the regulated area, and shall include
the words "WARNING: LEAD AREA, POISON-NO SMOKING OR EATING" in bold lettering
not smaller than two (2") inches tall with additional language prohibiting
entrance to the regulated area by unauthorized personnel;
(III) Any heating and cooling systems within
the regulated area shall be shut down and the vents sealed with six (6)-mil
poly to prevent lead dust accumulation within the system;
(IV) All items shall be cleaned within the
regulated area by HEPA vacuuming and/or wet wiping with a cleaning solution.
Items shall then be removed from the area, or covered with six (6)-mil poly and
sealed with duct tape;
(V) At least
one layer of six (6)-mil, or thicker, poly shall be placed on the floor at the
base of the component and extend at least ten feet (10') beyond the perimeter
of the component to be replaced;
(VI) The component, and the area immediately
adjacent to the component, shall be thoroughly wetted using a garden sprayer,
airless mister, or other appropriate means to reduce airborne dust;
(VII) After removal of the component, the
surface behind the removed component shall be thoroughly wetted to reduce
airborne dust;
(VIII) The component
shall be wrapped or bagged completely in six (6)-mil poly and sealed with duct
tape to prevent loss of debris or dust; and
(IX) Prior to installing a new component, the
area of replacement shall be cleaned by HEPA vacuuming. After replacement is
complete, the regulated area shall be cleaned by vacuuming with a HEPA vacuum,
wiping down all surfaces with a cleaning solution, rinsing all surfaces, and
then HEPA vacuuming the area again.
B. Window replacement. When conducting window
replacement, these minimum requirements shall be met-
(I) The site shall be prepared by first
establishing a regulated area using fencing, barrier tape, or other appropriate
barriers. The regulated area shall be defined to prevent unlicensed and/or
unauthorized personnel from approaching closer than twenty feet (20') to the
replacement operation;
(II) Signs
shall be posted at all entrances to the regulated area, and shall include the
words "WARNING: LEAD AREA, POISON-NO SMOKING OR EATING" in bold lettering not
smaller than two (2") inches tall with additional language prohibiting entrance
to the regulated area by unauthorized personnel;
(III) If replacing window from the inside-
(a) Critical barrier containment shall be
established covering the window on the exterior;
(b) A perimeter of five feet (5') shall be
established extending from the base of the interior window to be
replaced;
(c) Items within the
perimeter shall be removed. Items too large to remove shall be covered with
poly sheeting and sealed with duct tape and left in the perimeter;
and
(d) At least one layer of six
(6)-mil poly, or thicker, shall be placed on the ground and extend five feet
(5') out from the base of the window;
(IV) If replacing window from the exterior-
(a) Critical barrier containment shall be
established covering the window on the interior;
(b) A perimeter of five feet (5') shall be
established extending from the base of the exterior window to be
replaced;
(c) Items within the
perimeter shall be removed. Items too large to remove shall be covered with
poly sheeting and sealed with duct tape; and
(d) At least one layer of six (6)-mil poly,
or thicker, shall be placed on the ground and extend five feet (5') out from
the base of the window ensuring that all ground plants and shrubs in the
perimeter are covered;
(V) The component, and the area immediately
adjacent to the component, shall be thoroughly wetted using a garden sprayer,
airless mister, or other appropriate means to reduce airborne dust;
(VI) After removal of the component, the
surface behind the removed component shall be thoroughly wetted to reduce
airborne dust;
(VII) The component
shall be wrapped or bagged completely in six (6)-mil poly and sealed with duct
tape to prevent loss of debris or dust; and
(VIII) Prior to installing a new component,
the area of replacement shall be cleaned by HEPA vacuuming. After replacement
is complete, the regulated area shall be cleaned by vacuuming with a HEPA
vacuum, wiping down all surfaces with a cleaning solution, rinsing all
surfaces, and then HEPA vacuuming the area again.
2. Enclosure. When conducting a
lead abatement project using the enclosure strategy, these minimum requirements
shall be met-
A. The site shall be prepared by
first establishing a regulated area using fencing, barrier tape, or other
appropriate barriers. The regulated area shall be defined to prevent unlicensed
and/or unauthorized personnel from approaching closer than twenty feet (20') to
the enclosure operation;
B. Signs
shall be posted at all entrances to the regulated area, and shall include the
words "WARNING: LEAD AREA, POISON-NO SMOKING OR EATING" in bold lettering not
smaller than two inches (2") tall with additional language prohibiting entrance
to the regulated area by unauthorized personnel;
C. Any heating and cooling systems within the
regulated area shall be shut down and the vents sealed with six (6)-mil poly to
prevent lead dust accumulation within the system;
D. All items shall be cleaned within the
regulated area by HEPA vacuuming and/or wet wiping with a cleaning solution.
Items shall then be removed from the area or covered with six (6)-mil poly and
sealed with duct tape;
E. At least
one layer of six (6)-mil, or thicker, poly shall be placed on the floor at the
base of the component and extend at least ten feet (10') beyond the perimeter
of the component to be enclosed;
F.
The surface to be enclosed shall be labeled (behind the enclosure),
horizontally and vertically, approximately every two feet (2') with a warning,
"Danger: Lead-Based Paint," in permanent ink;
G. The enclosure material shall be applied
directly onto the painted surface, or a frame shall be constructed of wood or
metal, using nails, staples, or screws. Glue may be used in conjunction with
the aforementioned fasteners, but not alone;
H. The material used for the enclosure
barrier shall be solid and rigid enough to provide adequate protection.
Materials including, but not limited to, wall papers, contact paper, films,
folding walls, and drapes do not meet this requirement;
I. Enclosure systems and their adhesives
shall be designed to last at least twenty (20) years;
J. The substrate or building structure to
which the enclosure is fastened shall be sufficient structurally to support the
enclosure barrier for at least twenty (20) years. Deterioration such as mildew,
water damage, dry rot, termite damage, or any significant structural damage may
impair the enclosure from remaining dust tight;
K. Preformed steel, aluminum, vinyl, or other
construction material may be used for window frames, exterior siding, trim
casings, column enclosures, moldings, or other similar components if they can
be sealed dust tight;
L. A material
equivalent to one-fourth inch (1/4") rubber or vinyl may be used to enclose
stairs;
M. The seams, edges, and
fastener holes shall be sealed with caulk or other sealant, providing a
dust-tight system;
N. All equipment
used in the regulated area shall be thoroughly cleaned with a cleaning solution
and/or vacuumed with a HEPA vacuum prior to removal from the regulated
area;
O. Prior to clearance, the
installed enclosure and surrounding regulated area shall be cleaned by
vacuuming with a HEPA vacuum, wiping down all surfaces with a cleaning
solution, rinsing all surfaces, and then HEPA vacuuming the area again.
Cleaning shall begin at the end of the work area farthest from the main
entrance to the area and from the top to the bottom of the regulated area;
and
P. It is recommended that a
visual evaluation of the enclosure's integrity be conducted and documented by
the building owner or the building owner's representative at least every year
or immediately after any fire, water, or structural damage. In child-occupied
facilities, it is recommended that a licensed risk assessor inspect all
enclosures every three (3) years, or whenever the owner's visual evaluation
indicates a potential for increased lead hazard exposure.
3. Encapsulation.
A. The encapsulation strategy of lead
abatement shall not be used on the following:
(I) Friction surfaces-such as window sashes
and parting beads, door jambs and hinges, floors, and door
thresholds;
(II) Deteriorated
components- including rotten wood, rusted metal, spalled or cracked plaster, or
loose masonry;
(III) Impact
surfaces, such as door stops, window wells, and headers;
(IV) Deteriorated surface coatings such that
the adhesion or cohesion of the surface coating is uncertain or indeterminable;
and
(V) Incompatible
coatings.
B. When
conducting a lead abatement project using the encapsulation strategy, these
minimum requirements shall be met-
(I)
Encapsulant selection shall be limited to those that are warranted by the
manufacturer to last for at least twenty (20) years and comply with fire,
health, and environmental regulations;
(II) Surfaces to be encapsulated shall have
sound structural integrity with no loose, chipping, peeling, or chalking paint
and no dust accumulation that cannot be cleaned, and shall be prepared and
applied according to the manufacturer's recommendations;
(III) The site shall be prepared by first
establishing a regulated area using fencing, barrier tape, or other appropriate
barriers. The regulated area shall be designated as to prevent unlicensed
and/or unauthorized personnel from approaching closer than twenty feet (20') to
the encapsulation operation;
(IV)
Signs shall be posted at all entrances to the regulated area, and shall include
the words "WARNING: LEAD AREA, POISON-NO SMOKING OR EATING" in bold lettering
not smaller than two inches (2") tall with additional language prohibiting
entrance to the regulated area by unauthorized personnel;
(V) Any heating and cooling systems within
the regulated area shall be shut down and the vents sealed with six (6)-mil
poly to prevent lead dust accumulation within the system;
(VI) All items shall be cleaned within the
regulated area by HEPA vacuuming and/or wet wiping with a cleaning solution.
Items shall then be removed from the area, or covered with six (6)-mil poly
sheeting and sealed with duct tape;
(VII) At least one layer of six (6)-mil, or
thicker, poly shall be placed on the ground at the base of the component and
extend at least ten feet (10') beyond the perimeter of the component to be
encapsulated;
(VIII) A patch test
shall be conducted prior to general application to determine the adhesive and
cohesive properties of the encapsulant on the surface to be encapsulated (see
the HUD Guidelines for the Evaluation and Control of Lead-Based Paint Hazards
in Housing, Chapter 13);
(IX) After
the manufacturer's recommended curing time, the entire encapsulated surface
shall be inspected by a licensed lead abatement supervisor or a licensed
project designer. Any unacceptable areas shall be evaluated to determine if a
complete failure of the system is indicated, or whether the system can be
patched or repaired. Unacceptable areas are evidenced by delamination,
wrinkling, blistering, cracking, cratering, and bubbling of the
encapsulant;
(X) After the
encapsulation is complete, the regulated area shall be cleaned by vacuuming
with a HEPA vacuum, wiping down all surfaces with a cleaning solution, rinsing
all surfaces, and then HEPA vacuuming the area again. Cleaning shall begin at
the end of the work area farthest from the main entrance to the area and from
the top to the bottom of the regulated area;
(XI) All equipment used in the regulated area
shall be thoroughly cleaned with a cleaning solution and/or vacuumed with a
HEPA vacuum prior to removal from the regulated area; and
(XII) It is recommended that a visual
evaluation of the encapsulant's integrity be conducted and documented by the
building owner or the building owner's representative at least every year or
immediately after any fire, water, or structural damage. In child-occupied
facilities, it is recommended that a licensed risk assessor inspect all
enscapsulations every three (3) years, or whenever the owner's visual
evaluation indicates a potential for increased lead hazard exposure.
4. Removal.
A. Acceptable removal strategies include:
(I) Manual wet strategies-Manual wet scraping
or manual wet sanding is acceptable for removal of lead surface
coatings;
(II) Mechanical removal
strategies-Power tools that are HEPA-shrouded or locally exhausted are
acceptable removal strategies for lead surface coatings. HEPA-shrouded or
exhausted mechanical abrasion devices such as sanders, saws, drills, rotopeens,
vacuum blasters, and needle guns are acceptable;
(III) Chemical removal strategies- Chemical
strippers shall be used in compliance with manufacturer's recommendations;
and
(IV) Soil abatement-When soil
abatement is conducted, the lead-bearing soil shall be removed, tilled, or
permanently covered in place as indicated in the following subparts:
(a) Removed soil shall be replaced with fill
material containing no more than one hundred parts per million (100 ppm) of
total lead. If the fill material exceeds one hundred (100) ppm total lead, the
fill material will be acceptable only if the lead solubility is less than five
(5) ppm. Soil that is removed shall not be reused as topsoil in another
residential yard or child-occupied facility;
(b) If tilling is selected, soil in a
child-accessible area shall be tilled to a depth which results in no more than
four hundred (400) ppm total lead of the homogenized soil, or other
concentrations approved by the department. Soil in an area not accessible to
children shall be tilled to a depth which results in no more than two thousand
(2,000) ppm total lead of the homogenized soil or other concentrations approved
by the department;
(c) Permanent
soil coverings include solid materials such as pavement or concrete, which
separate the soil from human contact. Grass, mulch, and other landscaping
materials are not considered permanent soil covering; and
(d) Soil abatement shall be conducted to
prevent lead contaminated soil from being blown from the site and/or from being
carried away by water run-off or through percolation to groundwater.
B. Interior removal.
When conducting a lead abatement project using the removal strategy on interior
surfaces, these minimum requirements shall be met-
(I) The site shall be prepared by first
establishing a regulated area using fencing, barrier tape, or other appropriate
barriers. The regulated area shall be defined to prevent unlicensed and/or
unauthorized personnel approaching closer than twenty feet (20') to the removal
operation;
(II) Signs shall be
posted at all entrances to the regulated area, and shall include the words
"WARNING: LEAD AREA, POISON-NO SMOKING OR EATING" in bold lettering not smaller
than two inches (2") tall with additional language prohibiting entrance to the
regulated area by unauthorized personnel;
(III) Any heating and cooling systems within
the regulated area shall be shut down and the vents sealed with six (6)-mil
poly to prevent lead dust accumulation within the system;
(IV) All items within the regulated area
shall be cleaned by HEPA vacuuming and/or wet wiping with a cleaning solution.
Items shall then be removed from the area, or covered with six (6)-mil poly and
sealed with duct tape;
(V) All
windows below and within the regulated area shall be closed;
(VI) Critical barrier containment shall be
constructed;
(VII) At least two (2)
layers of six (6)-mil, or thicker, poly shall be placed on the floor at the
base of the component and extend at least ten feet (10') beyond the perimeter
of the component being abated (removal by the chemical strategy may require
chemical resistant floor cover; follow manufacturer's
recommendations);
(VIII) All
equipment used in the regulated area shall be thoroughly cleaned with a
cleaning solution and/or vacuumed with a HEPA vacuum prior to removal from the
regulated area;
(IX) At the end of
each work shift, the top layer of six (6)-mil poly shall be removed and used to
wrap and contain the debris generated by the shift. The six (6)-mil poly shall
then be sealed with duct tape and kept in a secured area until final disposal.
The second layer of six (6)-mil poly shall be HEPA vacuumed, left in place and
used during the next shift. A single layer of six (6)-mil poly shall be placed
on this remaining poly before abatement resumes; and
(X) After the removal is complete, the
regulated area shall be cleaned by vacuuming with a HEPA vacuum, wiping down
all surfaces with a cleaning solution, rinsing all surfaces, and then HEPA
vacuuming the area again. Cleaning shall begin at the end of the work area
farthest from the entrance to the area and from the top to the bottom of the
regulated area.
C.
Exterior removal. When conducting a lead abatement project using the removal
strategy on exterior surfaces, these minimum requirements shall be met-
(I) The site shall be prepared by first
establishing a regulated area using fencing, barrier tape, or other appropriate
barriers. The regulated area shall be designated as to prevent unlicensed
and/or unauthorized personnel from approaching closer than twenty feet (20') to
the removal operation;
(II) Signs
shall be posted at all entrances to the regulated area, and shall include the
words "WARNING: LEAD AREA, POISON-NO SMOKING OR EATING" in bold lettering not
smaller than two inches (2") tall with additional language prohibiting entrance
to the regulated area by unauthorized personnel;
(III) All movable items shall be moved twenty
feet (20') from working surfaces. Items that cannot be readily moved twenty
feet (20') from working surfaces shall be covered with six (6)-mil poly and
sealed with duct tape;
(IV) At
least one layer of six (6)-mil, or thicker, poly shall be placed on the ground
and extend at least ten feet (10') from the abated surface plus another five
feet (5') out for each additional ten feet (10') in surface height over twenty
feet (20'). In addition, the poly shall-
(a)
Be securely attached to the side of the building with cover provided to all
ground plants and shrubs in the regulated area;
(b) Be protected from tearing or
perforating;
(c) Contain any water,
including rainfall, which may accumulate during the abatement; and
(d) Be weighted down to prevent disruption by
wind gusts;
(V) All
windows in the regulated area and all windows below and within twenty feet
(20') of working surfaces shall be closed. It is recommended that the windows
of adjacent structures within twenty feet (20') also be closed;
(VI) Work shall cease if constant wind speeds
are greater than ten (10) miles per hour;
(VII) Work shall cease and cleanup shall
occur if rain begins;
(VIII) All
equipment used in the regulated area shall be thoroughly cleaned with a
cleaning solution and/or vacuumed with a HEPA vacuum prior to removal from the
regulated area; and
(IX) The
regulated area shall be HEPA vacuumed and cleaned of lead-based paint chips,
poly and other debris generated by the abatement project work at the end of
each workday. Debris shall be kept in a secured area until final
disposal.