This DHCR memo, dated May 10, 2001 is posted here in full. 

This memo has been updated with the Lead-Safe Weatherization Practices Manual put together by ATC for DHCR

Click Here for new manual

The weatherization assistance program is a residential energy conservation program; it is not a rehabilitation or remodeling program.  However, there are times when some weatherization techniques such as installing window sashes, weatherstripping or blowing sidewalls may cause lead dust to be disturbed as an unintended consequence.  In such circumstances, lead-safe weatherization work practices must be followed.

All costs associated with performing lead-safe weatherization work will be considered eligible weatherization costs.  However, the cost of testing for the presence of lead and actual lead abatement are not allowed by USDOE as eligible weatherization costs.  Therefore, subgrantees should perform lead-save weatherization work in all buildings built prior to 1980 unless documentation is provided that the building has been tested by others and is lead free.

Following is a list of preparations subgrantees need to make and a list of lead-safe work practices for the most common weatherization techniques that would put staff in contact with lead-based paint. 

Preparations:

Employee Testing

• Subgrantees must have lead-level blood tests conducted for all employees who will come in contact with lead-based paint while performing weatherization work.  This test will determine if any staff already have elevated levels (>10 ug/dl) of lead in their blood.  If an employee has a blood level greater than 10 ug/dl, he or she must not perform any tasks where they will come in contact with lead until they have a blood test with results less than 10ug/dl.

• Employees who will come in contact with with lead-based paint while performing weatherization work will also need a pulmonary exam to determine if they can wear a respirator safely.  If an employee cannot pass a pulmonary exam, they must not be allowed to perform any tasks where they will come in contact with lead.

• Both the lead-level blood test and the pulmonary exam must be completed by a doctor, and any expense not covered by health insurance is chargeable as a program support cost to the weatherization contract.  These tests must be completed annually, and the results must be kept on file for 30 years.

Equipment:  Subgrantees must supply employees, who will come in contact with lead-based paint, with the following tools and equipment:

• HEPA vacuum cleaners: 

• Disposable suits:

• Respirators: The half mask type is the most appropriate for weatherization activity.  Certified supervisors can conduct qualitative fit tests using irritant smoke.  Qualitative fit tests must be completed annually.

• Air monitors:  These air monitors must be worn by 25% of a crew.  (Note: this process will be eliminated when NYSWDA performs a state wide NID or if your agency has done the monitoring for your own NID)

• Warning Signs: For posting at any area where lead paint will be disturbed.  The signs must say "WARNING Lead Work Area, Poison, No Smoking, Eating, or Drinking"  The warning signs must be in the language of the occupants and the workers.

• Warning ribbon:  Used to mark off area where lead-safe work practices will take place.

• Spray bottles:  Both small squeeze bottles for smaller jobs and larger pump style bottles for larger jobs.  A lead cleaning detergent (LCD) will also be needed for working wet and clean up.

• 6 mil polyethylene sheeting:  6 mil poly is used to cover floors and ground surfaces around the work area when lead-based paint may be disturbed.

• 6 mil polyethylene bags for disposing of lead-contaminated items.

• Optional:  HEPA vacuum shroud attachments;

• Optional disposable booties for use as alternative to vacuuming feet upon exiting a lead-safe work area.

Lead-Safe Work Practices:

The following procedures must be used when completing weatherization in situations where the possibility of creating lead dust exists.

• Air monitors must be worn by 25% of the people on a crew.  Example, with a three-person crew, one person needs to wear a monitor, with a five-person crew, two have to wear monitors.  Subgrantees must maintain a log of what the monitored people do throughout the day.  This log must include the specific techniques the crew person used and the times they wore the monitor.  Once air samples have been collected with the air monitor for the period and work indicated in the log, the monitor's cassette should be sent to a lab for analysis and the results must be shared with the crew within 5 days from the date that the results are received.

12/2002 - NYSWDA will have more information soon, including templates, on the process of "Logs related to Lead-Safe Work Practices".  Agencies should be doing logs even if they have a NID.  Click Here  for more information.

• A lead-safe work area must be clearly marked off using signs, and the area wher3e lead paint may be disturbed must be isolated.  This can be completed with the use of warning ribbons.  Once a work area is marked off, no unauthorized persons may be allowed in the area, this includes the client, homeowner, and especially children.

• The full crew must wear disposable suits, respirators, goggles, and gloves when they are within the isolated lead-safe work area.  When leaving the work area, crew members must remove booties or vacuum their feet as they step off the poly.  disposable suits and gloves should be disposed of at the end of the workday by folding them into themselves and disposing of them in a 6 mil poly bag.

• At the end of each day each crew member must:

1. Throw away disposable coveralls and booties

2. Clean protective gear and respirator.  Store in a clean area.

3. Wash hands and face

4. Shower as soon as possible

If crew members wear any kind of footwear/gloves outside of protective clothing, they must be taken off and left in the isolated lead-safe work area.  Footwear/gloves can not be taken outside the isolated lead-safe work area if they cannot be cleaned. (Leather and fabric footwear/gloves cannot be cleaned; rubber footwear/gloves without seams can be cleaned.)  Footwear/gloves that cannot be cleaned, must be disposed of.  Footwear/gloves that can be cleaned, may not be worn outside the isolated lead-safe work area unless they are cleaned.

• All debris including but not limited to polyethylene sheeting and bags as well as clothing must be removed from the job site at the end of the workday and may be disposed of as regular household waste.

Page Two
Work Practices