I.  Client/Job Related
      There are two procedures to follow (1-Giving Client EPA Booklet, 2-having client sign off on Pre-Condition Form)

1. HUD/EPA Regulations, and your DHCR PPM,  requires clients (in most cases) be given a copy  of the EPA Booklet "Protect Your Family From Lead in Your Home" EPA-747-k-94-001. 
    

   Click Here  for copy of EPA Booklet in PDF  format (opens in new window).  Click Here for more information on when you are required to give this pamphlet to clients plus phone number to order copies (opens in new window).  Free pamphlets (for non-profits) can be ordered by calling the National Lead Information Center at 1 (800) 424-5323. By using the EPA’s booklet version, rather than printing and stapling your own, it will be more likely that your clients will read it.  Ask for a few copies printed in Spanish, for your Spanish-speaking clients.   You also need to collect a signature page, for client file, as proof they received the brochure...This booklet must be given to the client before the commencement of work, or mailed at least 7 days prior to starting work. NYSWDA has created a sample template for the client sign off page.  Click here for form in PDF Format Click here for form in MS Word  Note: EPA Regulation - Records should be keep for 3 years.

   
        

2. PRE-Condition Form - It is also imperative that when deteriorated paint is found on the exterior of a home, especially paint chips on the ground, that you have the client sign a release of "pre-condition".  This form is designed to protect your agency from any future problems the client may have regarding contaminated soil. 

    

   Click Here for a copy of the PRE-Condition Form you can use, (will open in new window)..

    

     3. Lead Log Forms - These are the files that should be in the client file.  Click Here for instructions and links to download forms in MS Word and PDF Format.

 

II.  Employee Related

Training of Staff

The federal Residential Lead-Based Paint Hazard Reduction Act of 1992, also known as Title X, requires individuals to pass a proficiency exam in order to become fully certified as a Lead Inspector, Assessor, or Supervisor.  We are only concerned with the "Supervisor" Certification in weatherization.    This is your "competent Person" on the crew

Supervisors have several responsibilities

• Workers Health & Safety
• Security of work site
• Documentation (i.e. Lead Logs)
• Work Practices

DHCR has been providing the 4 day trainings for the EPA Supervisors Certifications as well as allowing contract funds to be expended for the testing and certification. 

• Re-certification is required every 3 years.

Medicals and Bloods

OSHA's Lead Exposure in Construction, Interim Final Rule - 29CFR 1926.62 requires two levels of medical surveillance:

1. Initial Medical Surveillance if an employee is exposed at or above the Action Level for at least one day per year.  Initial tests consists of testing blood for lead and zinc protoporphyrin (ZPP) levels.  OSHA also accepts the free erythrocyte protoporphyrin (FEP) test as equivalent to ZPP testing.
2. Full Medical Surveillance if the employee is exposed at or above the Action Level for more than 30 days in a year.  (Full Surveillance consists of checking blood lead levels frequently, i.e., every 2 months for first 6 months, and twice a year after that)

NOTE:   If NYSWDA's state wide NID data shows negligible exposure to employees, when proper LSW practices are followed, then what level of medical testing is needed?  At a minimum you probably should be getting employees bloods done once a year to monitor lead levels. This will let you know if levels are going up, perhaps from employees not following proper work procedures or from work outside your agency... NOTE:   You do not want an employee working with lead based paint if their lead level is higher than 40 ug/dl.

Respirators

There are a several things you need in place in regards to respirators. 

1. Proper respirators for working around lead dust.
2. Employees need to be medically cleared to wear respirators. 
3. Proper training - employees need to be trained to how to inspect, use, clean, store, and maintain respirators.  We will soon have a training program outline posted here.
4. All above items need to be described in a written respiratory protection program.  We will have a policy template posted here soon

III.  Work Site Related

Tools and Equipment Needed

• HEPA Vacuums
• Disposable Protective Clothing
• Respiratory Protection
• Warning Signs
• Caution Tape
• Lead Cleaning Detergent (LCD)
• Spray Bottles
• 6 mil poly Sheeting and 6 mil Disposal Bags
• Personal Air Monitoring Equipment (will not be needed at each agency when "Statewide NID" is in place)

Follow our NY Lead Safe Weatherization Practices (See link in column on left for the complete LSW practices.

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