Lead-Based Paint Abatement Activities

The U.S. Environmental Protection Agency (EPA) requires a written occupant protection plan (OPP) for all abatement projects. The OPP must be completed before work begins.

Minimum Criteria for the Occupant Protection Plan (OPP)

Printable version: Guidance for Writing an Occupant Protection Plan (PDF)

1. Write a unique OPP for each residential dwelling and/or child-occupied facility. Keep the written OPP on site for all permitted projects.
2. If the project includes fewer than five residential dwellings, a certified lead supervisor can prepare the OPP. If there are five or more residential dwellings, a certified lead designer must prepare the OPP.
3. The contractor or operator controlling the project must notify occupants about the project.
4. If the occupants need to leave during the abatement, implement a contingency plan in case clearance fails and the occupants cannot enter their dwelling.
5. If the occupants remain in the dwelling during abatement and there is a breach in the containment, take measures to address the breach and protect the occupants.
6. Protect the occupants' personal belongings inside and outside of the dwelling.
7. Address any special needs, such as occupants who are blind or have low vision, or occupants with other disabilities.
8. Prepare an emergency escape plan for occupants who remain in the dwelling.
9. Protect the occupants' pets inside or outside of the dwelling.
10. Protect playground equipment and lawn furniture.
11. Protect soil in gardens and play areas.
12. The contractor must keep children from neighboring areas from entering the abatement area.

Questions? Contact the Health Hazards Control Unit: 919-707-5950.

Printable version: Guidance for Abatement Work Practices (PDF)

Resident Protection and Worksite Preparation

1. The Resident Protection and Worksite Preparation information (PDF) from Chapter 8 of the Housing and Urban Development (HUD) Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing, Second Edition, July 2012, apply to all abatement projects. Abatement contractors are responsible for protecting the residents’ belongings from becoming contaminated with leaded dust and for preventing leaded dust from migrating beyond the work area.
2. Remove all paint chips on the ground or floor before laying plastic sheeting or other impermeable material.
3. Design containment measures to prevent the release of leaded dust, which can be spread by workers’ shoes or by airborne dust.
4. To ensure containment of contaminants, tape or otherwise secure plastic sheeting used for floor/ground protection to the dwelling's walls. 
5. Repair or replace all damaged substrates before preparing the site for encapsulation and/or enclosure.
6. Do not leave debris, plastic sheeting or impermeable materials outside the dwelling overnight, or in any area where a passerby or a child could come in contact with these materials.
7. Residents should not remain in a dwelling when lead-based paint abatement is performed. If residents must remain inside the dwelling while work is being conducted or must return to the dwelling in the evenings, then collect and analyze a dust sample. Collect the sample at the end of each workday from the living area at greatest risk of contamination.
8. Keep all windows closed during interior or exterior lead hazard control work to prevent dust and chips from migrating into or out of the unit.

Abatement

1. Conduct all lead-based paint abatement activities in accordance with Chapter 12 (PDF) of the Housing and Urban Development (HUD) Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing, Second Edition, July 2012.
2. Keep warning signs posted until clearance is passed. This includes barrier tape.
3. When using a dumpster to store waste, it is not necessary to wrap and bag bulk debris if the dumpster is lined with plastic sheeting, is secured and has warning signs posted. Line all pathways to the dumpster with plastic sheeting to avoid contamination when transporting material from the structure to the dumpster.
4. Label the surface of any item to be enclosed with a warning, horizontally and vertically about every 2 feet: "Danger: Lead-Based Paint.” Seal all seams around the enclosure.
5. Maximum allowable lead concentrations in replacement soil shall not exceed 200 ug/g.
6. Apply encapsulation in a manner that meets the manufacturer’s specifications. Maintain documentation that the encapsulants’ manufacturer specifications have been met, such as results of patch tests and thickness of encapsulant, for all encapsulation projects.
7. The following is a list of prohibited lead-based paint abatement methods:
   • Open flame burning or torching (includes propane-fueled heat grids).
   • Machine sanding or grinding without HEPA local vacuum exhaust tool.
   • Uncontained hydroblasting or high-pressure wash.
   • Abrasive blasting or sandblasting without HEPA local vacuum exhaust tool.
   • Heat guns operating above 1,100 F.
   • Chemical Paint Stripping in poorly ventilated space and methylene chloride paint removal products.
   • Dry scraping (except for limited surface areas).
   • Encapsulation is not an appropriate form of abatement for impact or friction surfaces.
   • Exterior abatement should not be conducted when the winds exceed 20 miles per hour.

Clearance

1. Conduct all lead-based paint clearance sampling in accordance with 40 CFR 745 Subpart D and Subpart L, Subsection .227.
2. Perform clearance dust sampling no sooner than one hour after completion of the final cleanup to permit airborne leaded dust to settle. Use a laboratory accredited by the National Lead Laboratory Accreditation Program (NLLAP) to analyze samples.
3. Conduct a visual examination to determine whether the work on all interior and exterior surfaces to be treated was in fact completed and to ensure that no visible settled leaded dust or debris is present. If dust is observed, repeat the cleaning effort before collecting clearance dust samples to avoid conducting dust sampling twice. Visually examine all grounds around the dwelling to ensure removal of all waste and debris. Confirm that leaded dust or paint chips were not transferred outside the dwelling. 
4. Conduct a visual inspection following any abatement on the exterior of a house to determine that all paint chips have been removed before performing any soil treatment.
5. Conduct a visual clearance after the breathable cloth material (Tyvek™ or an equivalent material) is installed if a non-lead certified siding company is used to install house siding. A certified lead professional (other than a worker) should be on site if a non-lead certified siding contractor installs the siding. A visual clearance is required after completion of the siding installation.
6. Dust and soil sample collection shall be conducted in accordance to 40 CFR 745 Subpart D and Subpart L, Subsection .227.
7. Do not leave waste at the curbside for trash pickup. Remove all waste from the site. Permits should be active until all waste is removed and clearance is achieved.