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					 Exterior Lead Paint Removal                                                                                                                                                                  What is Compliance Certification?
    Certification Program                                                                                                             A Toxic Nightmare:                                 To better safeguard human health and the
                                                                                                                                      Why Regulation is Needed                           environment, contractors can now self-certify
                                                                                                                                     A report published by the National Institutes of
                                                                                                                                     Health (2003) described a case of lead              to the DEM that they are complying with
              A Partnership among the                                                                                                 A report published by the National Institutes of   environmental and worker health protection
     RI Department of Environmental Management,                                                                                      poisoning and environmental contamination
                                                                                                                                      Health (2003) described a case of lead             requirements when conducting exterior lead-
     RI Department of Health, U.S. Environmental                                                                                     that resulted from the improper removal of
                                                                                                                                      poisoning and environmental contamination          based paint removal operations.
 Protection Agency, RI Housing Resources Commission,                                                                                 exterior lead-based paint from a home located
and the University of RI Center for Pollution Prevention                                                                              that resulted from the improper removal of
                                                                                                                                     in a middle-income neighborhood. The
              & Environmental Health                                                                                                  exterior lead-based paint from a home located      This new, common sense approach to
                                                                                                                                     uncontrolled removal of lead paint from
                                                                                                                                      in a middle-income neighborhood. The
                                                                                                                                                              2                          regulation holds great promise for making it
                                                                                                                                     approximately 3,000 ft of exterior siding
                                                                                                                                      uncontrolled removal of lead paint from            easier for paint contractors to understand and
                                                                                                                                     resulted in interior lead 2dust levels ranging
                                                                                                                                      approximately 3,000 ft of exterior siding          comply with Rhode Island’s environmental and
                                                                                                                                     from 390 to 27,600 ug Pb/ft2, yard soil lead
                                                                                                                                      resulted in interior lead dust levels ranging      health regulations. This brochure contains a
                                                                                                                                     levels of 360 to 130,000 ppm, lead poisoning
                                                                                                                                      from 390 to 27,600 ug Pb/ft2, yard soil lead       brief summary of pertinent DEM regulatory
                                                                                                                                     (requiring immediate hospitalization) of three
                                                                                                                                      levels of 360 to 130,000 ppm, lead poisoning       requirements for exterior lead paint removal,
                                                                                                                                     children aged 1, 2, and 4, and the death of a 5-
                                                                                                                                      (requiring immediate hospitalization) of three     as well as disposal guidelines for lead paint
                                                                                                                                     year old family pet (dog) that died with a blood
                                                                                                                                      children aged 1, 2, and 4, and the death of a 5-   contaminated debris.
                                                                                                                                     lead level of 177 ug/dL. The “hard” costs




                                                                                                         Printed on Recycled Paper
                                                                                                                                      year old family pet (dog) that died with a blood
                                                                                                                                     associated with property decontamination were
                                                                                                                                      lead level of 177 ug/dL. The “hard” costs                   Is Certification Mandatory?
Some Important Facts about Lead:                                                                                                     over $195,000 (Jacobs, D.E., Mielke, H., and
                                                                                                                                      associated with property decontamination were
                                                                                                                                     N. Pavur. 2003. The High Cost of Improper           This voluntary program makes good business
                                                                                                                                      over $195,000 (Jacobs, D.E., Mielke, H., and
♦    Lead paint dust is DANGEROUS!                                                                                                   Removal of Lead-Based Paint from Housing: A         sense and is designed to result in improved
                                                                                                                                      N. Pavur. 2003. The High Cost of Improper
                                                                                                                                     Case Report. Environmental Health                   environmental protection at less cost to both
                                                                                                                                      Removal of Lead-Based Paint from Housing: A
♦    Lead poisoning is a serious environmental                                                                                       Perspectives. 111:185-186).
                                                                                                                                      Case Report. Environmental Health
                                                                                                                                                                                         business and government. Participation in the
                                                           Office of Technical and Customer Assistance




     health hazard.                                                                                                                                                                      program is voluntary and makes good
                                                           Department of Environmental Management




                                                                                                                                      Perspectives. 111:185-186).
                                                                                                                                                                                         business sense. Compliance certification
                                                           Providence, Rhode Island 02908-5767




♦    Most houses in Rhode Island built before                                                                                        Similarly, Rhode Islanders are at risk when         helps individuals and contractors avoid
     1978 contain lead based paint.                                                                                                  exterior lead-based paint is improperly             violations and costly penalties, while protecting
                                                                                                                                      Similarly, Rhode Islanders are at risk when
                                                                                                                                     removed. The careless removal and handling          human health, animal welfare, and the
♦    Renovating lead-painted surfaces creates                                                                                         exterior lead-based paint is improperly
                                                                                                                                     of lead paint from exterior surfaces has            environment. Free compliance assistance is
     hazardous dust, fumes, and debris if                                                                                             removed. The careless removal and handling
                                                                                                                                     resulted in enforcement actions taken against       offered to participants by DEM to help meet
                                                                                                                                      of lead paint from exterior surfaces has
                                                           235 Promenade Street




     removed improperly.
                                                                                                                                     individuals and companies by the Rhode Island       environmental regulatory requirements.
                                                                                                                                      resulted in enforcement actions taken against
                                                                                                                                     Department of Environmental Management              Participation in this DEM-led program
♦    According to the RI Department of Health:                                                                                        individuals and companies by the Rhode Island
                                                                                                                                     (DEM), and at least two documented cases of         qualifies individual companies to be placed
     Lead, even at low levels, can cause                                                                                              Department of Environmental Management
     children to have learning disabilities,                                                                                         groundwater contamination. In order to protect      on a list of certified paint contractors
                                                                                                                                      (DEM), and at least two documented cases of
     lower IQ, and behavioral problems.                                                                                              human health and the environment, DEM               posted on DEM’s website. Beyond this
                                                                                                                                      groundwater contamination. In order to protect
                                                                                                                                     enforcement staff continues to inspect sites        program, the Department of Health offers free
                                                                                                                                      human health and the environment, DEM
♦    Lead can also cause: High blood                                                                                                 where painting projects occur.
                                                                                                                                      enforcement staff continues to inspect sites
                                                                                                                                                                                         OSHA health & safety compliance assistance.
     pressure, Anemia, Brain damage,                                                                                                  where painting projects occur.
     Impotence, and Death.                                                                                                                                                               NOTE: All contractors performing exterior lead
                                                                                                                                                                                         paint removal operations in the State of Rhode
Island, must comply with all applicable            Not required for participation, but strongly        all toys, play equipment and furnishings within        Management. This characterization can
environmental and health regulations, whether      recommended, is a Lead Safe Remodeler/              50' of the paint removal project, or cover them        be based on laboratory analysis for TCLP
or not they certify. All persons, including        Renovator training course offered by the            with a leak-proof material. If paint debris is         for lead (and other factors, in the event that
homeowners and other entities as well as           Community College of Rhode Island.                  observed going beyond ground sheeting,                 chemical strippers are used), or on
painting contractors, must comply with DEM         Completion of this course will allow a              additional precautions must be taken.                  knowledge of the material.
Regulation # 24, Removal of Lead Based Paint
                                                   contractor to become RI state-licensed and
from Exterior Surfaces. Federal law requires                                                                Structures other than Buildings: A plan       •   Manually or mechanically removed lead
that contractors renovating pre-1978 housing       certified. For more information or instructions
                                                   on enrolling, please contact DEM’s OTCA.            must be submitted to the DEM's Office of Air           paint and lead painted wood from
(including paint removal) provide the EPA
pamphlet, titled “Protect Your Family from                                                             Resources for approval prior to the removal.           households may be disposed at any
Lead in Your Home” before starting work, and                                                           This plan must describe the type of removal to         licensed solid waste disposal facility.
                                                      Summary of DEM Regulation # 24:                  be utilized and measures to be employed to             However, under the hazardous waste
obtain a signature acknowledging receipt of the      “Removal of Lead Based Paint from
pamphlet. The pamphlet can be viewed at                                                                prevent contamination of the environment with          regulations, this material must be sent
                                                            Exterior Surfaces”
http://www.epa.gov/lead/leadpdfe.pdf.                                                                  lead. The removal plan must be submitted in            directly to such a facility; if it is taken to
                                                                                                       writing to DEM's Office of Air Resources, 235          an intermediate location, then that
   Compliance Certification Workbook &                 Applicable to Whom: Regulation # 24             Promenade Street, Providence, RI 02908-                facility would be considered to be a
          Certification Checklist                  applies to any persons, including contractors       5767, (401) 222-2808.                                  generator of hazardous waste.
                                                   and homeowners, who remove lead-based
To participate in the program, you must                                                                                                                       Arrangements should be made to properly
                                                   paint from exterior surfaces.
complete a “Participation Form & Certification                                                               Lead Paint Contaminated Debris                   contain the material to avoid
Checklist”, and return it to DEM’s Office of       • Exemption from the Regulation:                               Disposal Guidelines                         recontamination, and to take the material
Technical and Customer Assistance (OTCA).          If a contractor or homeowner tests a                                                                       directly to a licensed solid waste landfill.
An easy-to-read workbook has also been             representative sample of paint for lead and                                                                No special transporter permit is required by
                                                                                                       The Department of Environmental Manage-
developed to help you understand lead safe         determines that the concentration of lead in                                                               the Department for transportation of this
                                                                                                       ment's Offices of Compliance & Inspection and
work practices, complete the checklist and         paint (to be removed from any surface) is less                                                             material.
                                                                                                       Waste Management have determined that
comply with the regulations. The certification     than or equal to 0.05% by weight (equivalent to
                                                                                                       manually or mechanically removed lead
form and checklist contain a series of             500 ppm), then Regulation 5 "Fugitive Dust"                                                                                Worker Protection
                                                                                                       paint and lead painted wood removed from
questions that pertain to contractor operating     applies and requires that containment methods
                                                                                                       households fall under the definition of            •   29 CFR 1926.62 (OSHA), relating to Lead,
procedures and regulatory requirements, such       be used during paint removal.
                                                                                                       household waste, as defined in the federal             applies to all employers involved with
as DEM Regulation # 24, “Removal of Lead
                                                                                                       hazardous waste regulations which are                  removal of lead-based paint.
Based Paint from Exterior Surfaces, Effective           Who Must be Notified of Exterior Lead
                                                                                                       referenced in DEM's Rules & Regulations for
27 April 1993”, and the federal Pre-Renovation     Paint Removal: Adults in residences
                                                                                                       Hazardous Waste Management. As such, it is
Education Rule (406(b)). The form is               (including the structure from which lead paint is                                                           Questions regarding the certification
                                                                                                       exempt from the state hazardous waste
submitted every two (2) years to continue          being removed), managers of businesses, and                                                                 program can be directed to the DEM’s
                                                                                                       regulations, so long as the following conditions
participation in the program.                      principals of schools located within 50 feet of                                                               Office of Technical and Customer
                                                                                                       are met:
                                                   the structure undergoing lead paint removal                                                                              Assistance, at
              Project Checklist                    must be notified, in writing, of the removal of                                                                    (401) 222-4700, Ext. 4412
                                                                                                       •   The exemption applies only to material
In addition to submitting the Participation Form   lead based paint at least 5 days prior to the           generated by manual or mechanical                  http://www.dem.ri.gov/programs/benviron/assist/extlead/index.htm

                                                   removal project.                                                                                                        _________________________
& Certification Checklist to DEM, a copy of a                                                              removal at households. Material
completed “Project Checklist” must be given to                                                             generated at commercial or industrial              For information about worker protection,
                                                       Preparation of Site: To collect paint                                                                    contact the RI Department of Health,
the owner or occupant where exterior lead                                                                  property must be properly characterized by
                                                   debris, use adequate ground cover (such as a                                                                    OSHA Consultation Program, at
paint removal operations are being conducted                                                               the generator per DEM’s Rules and
                                                   tarp) and anchor it or weigh it down. Remove                                                                            (401) 222-2438
prior to starting the job. It’s that easy!                                                                 Regulations for Hazardous Waste
                                                                                                                                                              http://www.healthri.org/environment/occupational/consultation.php