Register March 2010 No. 651
APPENDIX C
CLEANING WHEN LEAD-BASED PAINT HAS BEEN DISTURBED
Chapter 14, HUD Guidelines for the Evaluation and Control of
Lead-Based Paint Hazards in Housing
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Step-by-Step Summary
Cleaning: How To Do It
1. Include step-by-step procedures for precleaning, cleaning during the job, and daily and final cleanings in project design or specifications.
2. Assign responsibilities to specific workers for cleaning and for maintaining cleaning equipment.
3. Have sufficient cleaning equipment and supplies before beginning work.
4. If contamination is extensive, conduct precleaning of the dwelling unit. Move or cover all furniture and other objects.
5. Conduct ongoing cleaning during the job, including regular removal of large and small debris and dust. Decontamination of all tools, equipment, and worker protection gear is required before it leaves containment areas. Electrical equipment should be wiped and high-efficiency particulate air (HEPA) vacuumed, not wetted down, to minimize electrocution hazards.
6. Schedule sufficient time (usually 30 minutes to an hour) for a complete daily cleaning, starting at the same time near the end of each workday after lead hazard control activity has ceased.
7. For final cleaning, wait at least 1 hour after active lead hazard control activity has ceased to let dust particles settle.
8. Use a vacuum cleaner equipped with a HEPA exhaust filter. HEPA vacuum all surfaces in the room (ceilings, walls, trim, and floors). Start with the ceiling and work down, moving toward the entry door. Completely clean each room before moving on.
9. Wash all surfaces with a lead-specific detergent, high-phosphate detergent, or other suitable cleaning agent to dislodge any ground-in contamination, then rinse. Change the cleaning solution after every room is cleaned.
10.
Repeat step 8. To meet clearance standards consistently, a HEPA vacuum, wet wash, and HEPA vacuum cycle is recommended. For interim control projects involving dust removal only, the final HEPA vacuuming step is usually not needed (see Chapter
11). Other cleaning methods are acceptable, as long as clearance criteria are met and workers are not overexposed.
11. After final cleaning, perform a visual examination to ensure that all surfaces requiring lead hazard control have been addressed and all visible dust and debris have been removed. Record findings and correct any incomplete work. This visual examination should be performed by the owner or an owner's representative who is independent of the lead hazard control contractor.
12. If other construction work will disturb the lead-based paint surfaces, it should be completed at this point. If those surfaces are disturbed, repeat the final cleaning step after the other construction work has been completed.
13. Paint or otherwise seal treated surfaces and interior floors.
14.
Conduct a clearance examination (see Chapter
15).
15. If clearance is not achieved, repeat the final cleaning.
16. Continue clearance testing and repeated cleaning until the dwelling achieves compliance with all clearance standards. As an incentive to conduct ongoing cleaning and a thorough final cleaning, the cost of repeated cleaning after failing to achieve clearance should be borne by the contractor as a matter of the job specification, not the owner.
17. Do not allow residents to enter the work area until cleaning is completed and clearance is established.
18. Cleaning equipment list:
* HEPA vacuums.
* Detergent.
* Waterproof gloves.
* Rags.
* Sponges.
* Mops.
* Buckets.
* HEPA vacuum attachments (crevice tools, beater bar for cleaning rugs).
* 6-mil plastic bags.
* Debris containers.
* Waste water containers.
* Shovels.
* Rakes.
* Water-misting sprayers.
* 6-mil polyethylene sheeting (or equivalent).
Chapter 14: Cleaning
I. Introduction
This chapter describes cleaning procedures to be employed following abatement and interim control work. Dust removal as an interim control measure is covered in Chapter
11.
All lead hazard control activities can produce dangerous quantities of leaded dust. Unless this dust is properly removed, a dwelling unit will be more hazardous after the work is completed than it was originally. Once deposited, leaded dust is difficult to clean effectively. Whenever possible, ongoing and daily cleaning of leaded dust during lead hazard control projects is recommended. Ongoing and daily cleaning is also necessary to minimize worker exposures.
Cleaning is the process of removing visible debris and dust particles too small to be seen by the naked eye. Removal of lead-based paint hazards in a dwelling unit will not make the unit safe unless excessive levels of leaded dust are also removed. This is true regardless of whether the dust was present before or generated by the lead hazard control process itself. Improper cleaning can increase the cost of a project considerably because additional cleaning and clearance sampling will be necessary. However, cleaning and clearance can be achieved routinely if care and diligence are exercised.
A. Performance Standard
Although the cleaning methods described in this chapter are feasible and have been shown to be effective in meeting clearance standards, other methods may also be used if they are safe and effective. This performance-oriented approach should stimulate innovation, reduce cost, and ensure safe conditions for both residents and workers.
B. Small Dust Particles
Dust particles that are invisible to the naked eye remain on surfaces after ordinary cleaning procedures. A visibly clean surface may contain high and unacceptable levels of dust particles and require special cleaning procedures.
C. Difficulties in Cleaning
While cleaning is an integral and essential component of any lead hazard control activity, it is also the most likely part of the activity to fail.
Several common reasons for this failure include low clearance standards, worker inexperience, high dust-producing methods, and deadlines.
1. Low Clearance Standards
Because very small particles of leaded dust are easily absorbed by the body when ingested or inhaled, a small amount can create a health hazard for young children. Therefore, “clearance standards" are extremely low for acceptable levels of leaded dust particles on surfaces after hazard control activities, and careful cleaning procedures are required. Although it is not possible to remove all leaded dust from a dwelling, it is possible to reduce it to a safe level.
Clearance standards are described more fully in Chapter
15. The permissible amount of leaded dust remaining on each of the following surfaces following lead hazard work is as follows:
* 100 µg/ft2 on floors.
* 500 µg/ft2 on interior window sills (stools).
