Working Lead Safe U.S. EPA Renovation, Repair and Painting

1. Working Lead SafeU.S. EPARenovation, Repair and Painting The Ohio Department of Health

2. National Data Out of 39 states funded by US EPA: Environmental Protection Agency (EPA) Ohio has the 5th highest number of housing units with lead-based paint. Reports from 19 states funded by CDC: Centers for Disease Control (CDC) Ohio has the 2nd highest percentage of children under age 6 with EBL (elevated blood lead).

3. Health risks associated with lead poisoning At Lower Levels Reduced IQ Learning Disabilities Attention deficit disorders Behavioral Problems At Higher Levels Anemia Impaired hearing Kidney Damage Death

4. CHILDRENADULTS Blood Lead (ug Pb/dl) 150 Death Encephalopathy 100 Encephalopathy Frank Anemia Nephropathy Frank Anemia Decreased Longevity Colic 50 Hemoglobin Synthesis Peripheral Neuropathies Infertility (MEN) HemoglobinSynthesis 40 Nephropathy Systolic Blood Pressure (MEN) Vitamin D Metabolism 30 Hearing Acuity 20 Nerve Conduction Velocity Erythrocyte Protoporphyrin Erythrocyte Protoporphyrin (Women) Vitamin D Metabolism(?) DEVELOPMENTAL TOXICITY 10 Hypertension (?) IQ HEARING Transplacental Transfer GROWTH - Low birth weight - Miscarriages, Stillbirth - Premature birth

5. Lead Exposure and IQ • Each 2.5 ug/dL increase in blood lead level yields a one point decrease in IQ.

6. Lead Poisoning Facts • Lead in paint intended for residential use was outlawed in 1978. • 80-90% of lead poisoning cases are caused by the deterioration of old paint in older residences • Ingestion of a lead paint chip can result in very high blood lead levels • Degradation of the paint into dust particles is the primary source of childhood lead poisoning

7. Small children are at high risk because: Small children crawl on the floor, touch a lot of things and frequently put their hands in their mouths. Small children are developing rapidly; small disruptions become big problems during growth .

8. U.S. EPA Lead-Based PaintRenovation, Repair, and Painting Rule

9. RRP The rule was designed to prevent the introduction of new lead hazard created by a renovation, not to address existing lead hazards

10. Effective Dates June 2008: States and tribes may begin applying for authorization Some restrictions apply to unaccredited training programs December 2008: “Renovate Right” brochure must be used for 406(b) April 2009: EPA begins administering program in unauthorized states Training providers may begin applying for accreditation October 2009: Renovation firms may begin applying for certification April 2010: Training providers must be accredited Renovation firms must be certified Renovators and dust sampling technicians must be certified Workers must be trained Work practices must be followed

11. 2008 • June 23, 2008 – • States may seek authorization to administer and enforce • June 23, 2008 – • Training programs can not offer or claim to provide training for EPA certification as a renovator or a dust sampling technician with out accreditation from the EPA • December 22, 2008 – • Renovate Right : Important Lead Hazard Information for Families, Child Care Providers and Schools must be used exclusively

12. 2009 • April, 2009 – • EPA begins administering the program in unauthorized states (Ohio) • April 22, 2009 – • Training programs may apply for accreditation to provide training for renovators and dust sampling technician • October 22, 2009 • Firms may apply for certification to the EPA

13. 2010 • April 22, 2010 • Training providers must be accredited • Renovation firms must be certified • Renovators and dust sampling technicians must be certified • Workers must be trained • Work practices must be followed

14. Who is covered under the rule? All persons who do renovations for compensation, including renovation contractors, maintenance workers, painters and other specialty trades in target housing and child-occupied facilities.

15. Applicability • Target Housing - • Any housing constructed prior to 1978 • Child-Occupied Facilities - • A building, or a portion of a building, constructed prior to 1978 where a child under 6 years of age visits; • Maybe located in targeted housing or commercial buildings (day care centers, preschools and kindergarten classrooms

16. Firm Certification • Firms must pay a $300 fee and apply for certification to perform renovations or dust sampling. • Certifications are good for 5 years. • Certification allows the firm to perform renovations in any non-authorized state or Indian tribal area.

17. Responsibilities of the Certified Firm • All persons performing renovation activities are certified renovators or have received on-the-job-training by a certified renovator; • A certified renovator is assigned to each renovation performed by the firm; and • All renovations are performed in accordance with applicable work practice standards.

18. Certified Renovator • To become a certified renovator a person must successfully complete a training course offered by a training provider accredited by EPA or by an authorized state or tribal program. • Course completion certificate serves as proof of certification. • Training providers to notify EPA of names of trained renovators. • Certification allows the renovator to perform renovations in any non-authorized state or Indian tribal area.

19. Certified Renovator • To maintain certification, refresher course must be taken within 5 years of the initial course. If the refresher course is not taken within this time, the initial course must be re-taken. • Persons who have a valid abatement supervisor or worker certification issued by EPA or by an authorized state (Ohio) or tribe are also deemed to be certified renovators.

20. Responsibilities of the Certified Renovator • Perform or direct uncertified workers who perform regulated renovation activities; • Provide training to uncertified workers on lead-safe work practices; • Be present at the work site during key stages of a renovation, and at other times be available on-site or by telephone; and • Be able to use an acceptable test kit to determine whether lead-based paint is present on components to be affected by a renovation.

21. Dust Sampling Technician • RRP also contains provisions for the training and certification of dust sampling technicians- clearance purposes only • “Clearance Technician”-Ohio-specific term • In Ohio only a licensed Clearance Technician, Lead Risk Assessor or Lead Inspector Can take dust wipe samples for laboratory analysis

22. Interior Renovation Procedures • Remove or cover all objects from the work area. • Close and cover all ducts in the work area. • Close or cover all windows and doors in the work area. • Cover the floor surface of the work area with plastic sheeting. • Ensure that all personnel, tools, and other items including waste are free of dust and debris when leaving the work area.

23. Renovations Outside • Close all doors and windows within 20 feet of the renovation. • Cover the ground with plastic sheeting extending out from the edge of the structure a sufficient distance to collect falling paint debris.

24. Waste • During renovation waste must be contained to prevent releases of dust and debris. • At the end of each work day and at the end of the job, waste must be contained or enclosed to prevent release of dust and debris and prevent access. • When the firm transports waste it must be contained to prevent releases of dust and debris.

25. Clean-up • After the renovation has been completed, the firm must clean the work area until no visible dust, debris or residue remains. • Pick up all paint chips and debris. • Remove all protective sheeting.

26. Clean-up Clean all objects and surfaces in and around the work area. • Clean walls with a HEPA-equipped vacuum or with a damp cloth. • Vacuum all remaining surfaces and objects in the work area, including furniture and fixtures, with a HEPA-equipped vacuum. • Wipe all remaining surfaces and objects in the work area with a damp cloth. • Mop uncarpeted floors.

27. Cleaning Verification • The EPA has developed a unique method for post renovation cleaning verification. • Must be conducted by certified renovator. • Relies on the use of Wet and Dry Disposable Cleaning Cloths. • Cloths are to compared to a Cleaning Verification Card developed by EPA. • Data shows that this approach provides reliable information on the removal of lead hazards. • Laboratory dust sampling may alternatively be used to verify cleaning.

28. Cleaning Verification • Wipe the windowsill and/or uncarpeted floor with wet cleaning cloth. • If the cloth does not match the verification card, re-clean that windowsill and/or uncarpeted floor and then re-wipe with a wet cleaning cloth. • If this cloth does not match the cleaning verification card, re-clean that windowsill and/or uncarpeted floor again, then wipe with a dry cleaning cloth until it matches the verification card.

29. Verification Card

30. Verification Card

31. Record Keeping • Firms must retain documentation necessary to demonstrate compliance with rule for 3 years following a renovation. • Copy of the certified renovator’s training certificate. • A signed and dated form that describes: • Worker training, • Sign posting, • Work area containment, • Waste handling, • Cleaning, and. • Post-renovation cleaning verification.

32. Ohio and the RRP Rule Where do we go from here? • Must seek delegation of both RRP and Pre Renovation Education (PRE) • Modifications to existing Lead Law • Legislative support needed • Interest group support a challenge • Ohio political climate

33. Questions?

34. Ohio Department of Health Lead Poisoning Prevention Program 246 North High Street Columbus, Ohio 1-877-668-5323 www.odh.ohio.gov lead@odh.ohio.gov Program Staff: Dave Holston, Section Chief Chris Mizek, Sanitarian II Matt Young, Sanitarian II Sandra Foster, Customer Service Assistant II