Training Non-Certified Colleagues
The RRP Rule requires that a Certified Renovator should train and instruct noncertified renovation workers in lead safe work practices.
Teaching lead safe work practices means training workers to properly use signs, dust barriers, dust minimizing work practices, and dust cleanup practices during the course of renovation, repair, and painting activities to prevent and/or reduce potentially dangerous dust-lead contamination in the home.
To effectively train workers a Certified Renovator needs to:
Know lead safety yourself.
Show students what you know.
Review the shopping list in Steps to LEAD SAFE Renovation, Repair, and Painting and have appropriate materials at hand.
Role of the Certified Renovator
Certified Renovators perform lead safe work as described in the RRP Rule, train all non-certified workers in lead safe practices, provide onsite and regular direction for all noncertified workers during setup and cleanup, are available by phone when not physically present at the work site during work, and must maintain onsite proof of certification as a Certified Renovator.
The key lead safe work practices a Certified Renovator should keep in mind include:
Must use an EPA-recognized test kit or alternatively collect a paint chip sample for analysis, when requested by the party contracting for renovation services, to determine whether components to be affected by the renovation contain lead-based paint.
Must provide lead-safe work practices training to non-certified workers so those workers can perform assigned tasks safely. This training can be provided by the Certified Renovator on-the-job or in the classroom, provided adequate hands-on practice is available. This training could also be conducted by a third party although the instructor must be a Certified Renovator.
Must be physically present at the work site when warning signs are posted, while the work area containment is being established, and while the work area cleaning is performed. (Note: Use the terms Setup and Cleanup to describe this work).
Must monitor work being performed by non-certified individuals to ensure that lead-safe work practices are being followed. This includes maintaining the integrity of the containment barriers and ensuring that no dust or debris migrates from the work area.
Must be available, either on-site or by telephone, at all times during performance of the renovation.
Must perform project cleaning verification.
Must have copies of their initial course completion certificate and their most recent refresher course completion certificate at the work site. Certification as a Certified Renovator lasts for 5 years. The Certified Renovator must take a refresher course every 5 years in order to maintain certification.
Must prepare required records.
Trained, non-certified renovation workers are persons, working on renovation, repair and painting jobs who have had on-the-job training or similar classroom training from a Certified Renovator to perform tasks in conformance to the EPA RRP Rule.
They must perform lead-safe work practices as described in the RRP rule, including:
Protecting the home by “setting up” the work area.
Protecting themselves.
Performing renovation work safely.
Controlling dust and debris.
Cleaning the work area.
Prohibited Practices must not be used.
It contains a seven step primer on lead safety and can be used as a field text to hand out to non-certified worker trainees in the field. In the “Steps Guide”, steps 2 through 6 contain information specific to work performed by non-certified personnel, while step 1 and step 7 contain information on testing painted surfaces and cleaning verification which are Certified Renovator responsibilities. Step 7 also discusses clearance examination which is performed only by Certified Lead Inspectors, Certified Lead Risk Assessors, and Certified Dust Sampling Technicians.
STEP 1: Determine if the Job Involves Lead-Based Paint
Lead-based paint (LBP) is found many older homes:
1960-1978 homes – 1 in 4 have LBP.
1940-1960 homes – 7 in 10 have LBP.
Pre-1940 homes – 9 in 10 have LBP.
Renovation, repair or painting that disturbs lead-based paint can create significant lead-based paint hazards in homes. Just a little lead-based paint dust can poison kids, their parents and pets, and can cause problems for pregnant women and their unborn children. The Certified Renovator will determine if lead-based paint is present on work surfaces.
If information about lead-based paint is not available for a pre-1978 homes or a child-occupied facility, assume that lead-based paint is present and use lead-safe work practices.
STEP 2: Set It Up Safely
Containment is used to keep dust IN the work area and non-workers OUT!
For Inside Jobs:
Place signs, barrier tape, and/or cones to keep all non-workers, especially children, out of the work area. Keep pets out of the work area for their safety and to prevent them from tracking dust and debris throughout the home.
Remove furniture and belongings from the work area. If an item is too large or too heavy to move, cover it with heavy plastic sheeting and tape the sheeting securely in place.
Use heavy plastic sheeting to cover floors in the work area to a minimum of 6 feet from the area of paint disturbance. Close and seal doors, close windows.
Close and cover air vents in the work area. This will keep dust from getting into the system and moving through the home.
For Outside Jobs:
Keep non-workers away from the work area by marking it off with signs, tape and/or cones. Have owner keep pets out of the work area.
Cover the ground and plants with heavy plastic sheeting to catch debris. The covering should extend at least 10 feet out from the building, unless a property line prevents 10 feet of such ground cover ,in which case the firm must erect vertical containment. Secure the covering to the exterior.
Close windows and doors within 20 feet of the work area to keep dust and debris from going into the home.
Move (if possible) or cover play areas and equipment within 20 feet of the work area.
STEP 3: Protect Yourself
Without the right personal protective equipment (PPE) workers can swallow and inhale lead from the job, and can carry lead on their skin and work clothes home to their families. Things you can do to protect yourself include:
Keep clothes clean or use disposable clothing.
Wear a respirator. The appropriate respirator keeps lead out of the lungs and stomach.
Wash-up each time they leave the work area and especially at the end of the day.
Wear protective clothing. Protective clothing and shoe covers are very important in preventing “take home” lead and to prevent you from tracking lead out of the work area. They can also help prevent contamination of areas that have already been cleaned during final cleanup.
Keep clothes clean. At the end of the work day, vacuum off dust or change out of dusty clothes. Do not use compressed air to blow dust off clothing. Wash dirty work clothes separately from household laundry.
Wear a painter’s hat to protect your head from dust and debris.
Wear respiratory protection. When work creates dust or paint chips, employers should consider respiratory protection, such as a N-100 disposable respirator, to prevent workers from breathing leaded dust.
Post a warning sign at each work area entrance. Signs should read: “Warning, Lead Work Area, Poison, No Smoking or Eating” to remind workers that eating, drinking and smoking in the work area is prohibited.
Workers should wash their hands and faces each time they stop work. It is especially important to wash up before eating and at the end of the day
STEP 4: Control the Spread of Dust
The goal of lead safe work practices is to control the spread of dust that is created by using the right tools, disposable plastic drop cloths, and avoiding prohibited practices.
Other ways to control the spread of dust include:
Keeping the work area closed off from the rest of the home.
Taking care to not spread dust and debris out of the work area.
Staying in the contained work area and on the contained paths.
Vacuuming off suits when exiting the work area so the dust stays inside containment.
Removing disposable shoe covers and make sure your shoes are clean by using tack pads or damp paper towels to wipe off your shoes each time you step off the protective sheeting.
Keeping components in the work area until they are wrapped securely in heavy plastic sheeting or bagged in heavy duty plastic bags. Once wrapped or bagged, HEPA vacuum the exterior and remove them from the work area and store them in a safe area away from residents.
Launder non-disposable protective clothing separate from family laundry.
Do not use Prohibited Practices, which include open-flame burning, high heat removal of paint, and using power tools (e.g. sanders) without HEPA attachments.
STEP 5: Leave the Work Area Clean
The goal of every lead-safe project clean up should be to leave the work area completely free of dust, debris and residue.
On a daily basis, pick up the work area (recommended).
Pick up as you go. Put trash in heavy-duty plastic bags.
Vacuum the work area with a HEPA vacuum several times during the day and for sure at the end of the day. Do not clean with standard household or shop vacuum cleaners. Use only HEPA vacuums.
Clean tools at the end of the day.
Wash your hands each time you leave the work area and especially well before you go home.
Dispose of all disposable personal protective clothing daily. When the job is complete, clean the work area (required).
Make sure all paint chips, dust, trash and debris, including building components, are removed from the area to be cleaned and disposed of properly.
Carefully remove plastic sheeting on the floor, fold it with the dirty side in, tape the edges shut or seal it in a heavy duty plastic bag, and dispose of it. Keep plastic sheeting in doorways and openings that separate the work area from non-work areas in place until the work area is released as clean.
HEPA vacuum or wet wipe all wall surfaces. HEPA vacuum all other surfaces in the work area. Use a beater bar attachment on carpets.
Wet wipe all remaining surfaces in the work area and wet mop all uncarpeted floors until dust, debris and residue are removed.
Visually inspect your work. Look around the work area and two feet beyond, and on paths where debris was carried. You should see no dust, debris or residue.
Re-clean the area thoroughly if you find dust, debris or residue.
STEP 6: Control the Waste
Use heavy plastic sheeting or bags to collect waste.
Bag or wrap your waste at the work site and in the work area. Collect and control all your waste. This includes dust, debris, paint chips, protective sheeting, HEPA filters, dirty water, clothes, mop heads, wipes, protective clothing, respirators, gloves, architectural components, and other waste.
Gooseneck seal the bag with duct tape. Consider double bagging waste to prevent tears.
Large components should be wrapped in protective sheeting and sealed with tape.
Bag and seal all waste before removing it from the work area.
HEPA vacuum the exterior of waste bags and bundles before removing them from the work area.
Store all waste that has been collected from renovation activities preventing access to and release of dust and debris.
Dispose of waste water appropriately.
Water used in the work area to remove paint or to clean surfaces should be filtered through a 5 micron filter. Never dump this water down a sink or tub, in a storm drain, or on the ground. It may be dumped in a toilet if local rules allow. If local regulations do not allow this, you may be required to contain and test the water, and contact a waste disposal company to assist you with disposal. Check with your local water treatment authority, and in Federal and state regulations for more information. Be aware of waste disposal rules. EPA considers most residential renovation, repair and painting activities “routine residential maintenance.” The waste generated by these activities is classified as solid, non-hazardous waste and can be disposed of in an ordinary waste landfill. Some states and localities have more stringent waste disposal requirements that must be followed.
STEP 7: Cleaning Verification or Clearance Testing
Cleaning verification must be performed by a Certified Renovator after most renovations. A dust clearance examination may be requested in place of cleaning verification by the owner, and is required in some cases.
When all the cleaning is complete, and before the space is reoccupied, a cleaning verification procedure or clearance examination must be conducted to make sure leaded dust is not left behind. If the HUD Rule applies, a clearance examination is required in place of the cleaning verification procedure.
The first step to both cleaning verification and a clearance examination is a visual inspection of the work area to determine if dust, debris or residue was left behind. If dust, debris or residue are present in the work area, cleaning must be repeated and the visual inspection repeated until the work area is free of dust, debris and residue.
Once the visual inspection by the Certified Renovator is complete, either the cleaning verification procedure or clearance examination can proceed.
Training Documentation
The Certified Renovator assigned to the job must maintain the following records for on-the-job training :
Written certification of worker training:
Must show which workers have what training;
Must list all training topics covered for each worker; and,
Must be signed by the Certified Renovator who did the training.
All training documentation must be kept for 3 years following completion of the renovation.
Keep a copy of the training guide on-site. Make a list of each lead safe practical skill covered for each individual non-certified worker. A list of the practical skills taught to each non-certified worker with the material covered will provide adequate documentation to meet RRP Rule requirements.