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Working Lead Safe U.S. EPA Renovation, Repair and Painting . The Ohio Department of Health. National Data. Out of 39 states funded by US EPA: Environmental Protection Agency (EPA) Ohio has the 5th highest number of housing units with lead-based paint. Reports from 19 states funded by CDC:

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Working Lead SafeU.S. EPARenovation, Repair and Painting

The Ohio Department of Health


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National Data

Out of 39 states funded by US EPA:

Environmental Protection Agency (EPA)

Ohio has the 5th highest number of housing units with lead-based paint.

Reports from 19 states funded by CDC:

Centers for Disease Control (CDC)

Ohio has the 2nd highest percentage of children under age 6 with EBL (elevated blood lead).


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Health risks associated

with lead poisoning

At Lower Levels

Reduced IQ

Learning Disabilities

Attention deficit disorders

Behavioral Problems

At Higher Levels

Anemia

Impaired hearing

Kidney Damage

Death


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CHILDRENADULTS

Blood Lead

(ug Pb/dl)

150

Death

Encephalopathy

100

Encephalopathy

Frank Anemia

Nephropathy

Frank Anemia

Decreased Longevity

Colic

50

Hemoglobin Synthesis

Peripheral Neuropathies

Infertility (MEN)

HemoglobinSynthesis

40

Nephropathy

Systolic Blood Pressure (MEN)

Vitamin D Metabolism

30

Hearing Acuity

20

Nerve Conduction Velocity

Erythrocyte Protoporphyrin

Erythrocyte Protoporphyrin

(Women)

Vitamin D Metabolism(?)

DEVELOPMENTAL TOXICITY

10

Hypertension (?)

IQ

HEARING

Transplacental Transfer

GROWTH

- Low birth weight

- Miscarriages, Stillbirth

- Premature birth


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Lead Exposure and IQ

  • Each 2.5 ug/dL increase in blood lead level yields a one point decrease in IQ.


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Lead Poisoning Facts

  • Lead in paint intended for residential use was outlawed in 1978.

  • 80-90% of lead poisoning cases are caused by the deterioration of old paint in older residences

  • Ingestion of a lead paint chip can result in very high blood lead levels

  • Degradation of the paint into dust particles is the primary source of childhood lead poisoning


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Small children are at high risk because:

Small children crawl on the floor, touch a lot of things and frequently put their hands in their mouths.

Small children are developing rapidly; small disruptions become big problems during growth

.


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U.S. EPA Lead-Based PaintRenovation, Repair, and Painting Rule


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RRP

The rule was designed to prevent the introduction of new lead hazard created by a renovation, not to address existing lead hazards


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Effective Dates

June 2008:

States and tribes may begin applying for authorization

Some restrictions apply to unaccredited training programs

December 2008:

“Renovate Right” brochure must be used for 406(b)

April 2009:

EPA begins administering program in unauthorized states

Training providers may begin applying for accreditation

October 2009:

Renovation firms may begin applying for certification

April 2010:

Training providers must be accredited

Renovation firms must be certified

Renovators and dust sampling technicians must be certified

Workers must be trained

Work practices must be followed


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2008

  • June 23, 2008 –

    • States may seek authorization to administer and enforce

  • June 23, 2008 –

    • Training programs can not offer or claim to provide training for EPA certification as a renovator or a dust sampling technician with out accreditation from the EPA

  • December 22, 2008 –

    • Renovate Right : Important Lead Hazard Information for Families, Child Care Providers and Schools must be used exclusively


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2009

  • April, 2009 –

    • EPA begins administering the program in unauthorized states (Ohio)

  • April 22, 2009 –

    • Training programs may apply for accreditation to provide training for renovators and dust sampling technician

  • October 22, 2009

    • Firms may apply for certification to the EPA


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    2010

    • April 22, 2010

      • Training providers must be accredited

      • Renovation firms must be certified

      • Renovators and dust sampling technicians must be certified

      • Workers must be trained

      • Work practices must be followed


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    Who is covered under the rule?

    All persons who do renovations for compensation, including renovation contractors, maintenance workers, painters and other specialty trades in target housing and child-occupied facilities.


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    Applicability

    • Target Housing -

      • Any housing constructed prior to 1978

    • Child-Occupied Facilities -

      • A building, or a portion of a building, constructed prior to 1978 where a child under 6 years of age visits;

      • Maybe located in targeted housing or commercial buildings (day care centers, preschools and kindergarten classrooms


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    Firm Certification

    • Firms must pay a $300 fee and apply for certification to perform renovations or dust sampling.

    • Certifications are good for 5 years.

    • Certification allows the firm to perform renovations in any non-authorized state or Indian tribal area.


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    Responsibilities of the Certified Firm

    • All persons performing renovation activities are certified renovators or have received on-the-job-training by a certified renovator;

    • A certified renovator is assigned to each renovation performed by the firm; and

    • All renovations are performed in accordance with applicable work practice standards.


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    Certified Renovator

    • To become a certified renovator a person must successfully complete a training course offered by a training provider accredited by EPA or by an authorized state or tribal program.

    • Course completion certificate serves as proof of certification.

    • Training providers to notify EPA of names of trained renovators.

    • Certification allows the renovator to perform renovations in any non-authorized state or Indian tribal area.


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    Certified Renovator

    • To maintain certification, refresher course must be taken within 5 years of the initial course. If the refresher course is not taken within this time, the initial course must be re-taken.

    • Persons who have a valid abatement supervisor or worker certification issued by EPA or by an authorized state (Ohio) or tribe are also deemed to be certified renovators.


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    Responsibilities of the Certified Renovator

    • Perform or direct uncertified workers who perform regulated renovation activities;

    • Provide training to uncertified workers on lead-safe work practices;

    • Be present at the work site during key stages of a renovation, and at other times be available on-site or by telephone; and

    • Be able to use an acceptable test kit to determine whether lead-based paint is present on components to be affected by a renovation.


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    Dust Sampling Technician

    • RRP also contains provisions for the training and certification of dust sampling technicians- clearance purposes only

    • “Clearance Technician”-Ohio-specific term

    • In Ohio only a licensed Clearance Technician, Lead Risk Assessor or Lead Inspector Can take dust wipe samples for laboratory analysis


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    Interior Renovation Procedures

    • Remove or cover all objects from the work area.

    • Close and cover all ducts in the work area.

    • Close or cover all windows and doors in the work area.

    • Cover the floor surface of the work area with plastic sheeting.

    • Ensure that all personnel, tools, and other items including waste are free of dust and debris when leaving the work area.


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    Renovations Outside

    • Close all doors and windows within 20 feet of the renovation.

    • Cover the ground with plastic sheeting extending out from the edge of the structure a sufficient distance to collect falling paint debris.


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    Waste

    • During renovation waste must be contained to prevent releases of dust and debris.

    • At the end of each work day and at the end of the job, waste must be contained or enclosed to prevent release of dust and debris and prevent access.

    • When the firm transports waste it must be contained to prevent releases of dust and debris.


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    Clean-up

    • After the renovation has been completed, the firm must clean the work area until no visible dust, debris or residue remains.

    • Pick up all paint chips and debris.

    • Remove all protective sheeting.


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    Clean-up

    Clean all objects and surfaces in and around the work area.

    • Clean walls with a HEPA-equipped vacuum or with a damp cloth.

    • Vacuum all remaining surfaces and objects in the work area, including furniture and fixtures, with a HEPA-equipped vacuum.

    • Wipe all remaining surfaces and objects in the work area with a damp cloth.

    • Mop uncarpeted floors.


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    Cleaning Verification

    • The EPA has developed a unique method for post renovation cleaning verification.

    • Must be conducted by certified renovator.

    • Relies on the use of Wet and Dry Disposable Cleaning Cloths.

    • Cloths are to compared to a Cleaning Verification Card developed by EPA.

    • Data shows that this approach provides reliable information on the removal of lead hazards.

    • Laboratory dust sampling may alternatively be used to verify cleaning.


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    Cleaning Verification

    • Wipe the windowsill and/or uncarpeted floor with wet cleaning cloth.

    • If the cloth does not match the verification card, re-clean that windowsill and/or uncarpeted floor and then re-wipe with a wet cleaning cloth.

    • If this cloth does not match the cleaning verification card, re-clean that windowsill and/or uncarpeted floor again, then wipe with a dry cleaning cloth until it matches the verification card.




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    Record Keeping

    • Firms must retain documentation necessary to demonstrate compliance with rule for 3 years following a renovation.

    • Copy of the certified renovator’s training certificate.

    • A signed and dated form that describes:

      • Worker training,

      • Sign posting,

      • Work area containment,

      • Waste handling,

      • Cleaning, and.

      • Post-renovation cleaning verification.


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    Ohio and the RRP Rule Where do we go from here?

    • Must seek delegation of both RRP and Pre Renovation Education (PRE)

    • Modifications to existing Lead Law

      • Legislative support needed

      • Interest group support a challenge

      • Ohio political climate



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    Ohio Department of Health

    Lead Poisoning Prevention Program

    246 North High Street

    Columbus, Ohio

    1-877-668-5323

    www.odh.ohio.gov

    lead@odh.ohio.gov

    Program Staff:

    Dave Holston, Section Chief

    Chris Mizek, Sanitarian II

    Matt Young, Sanitarian II

    Sandra Foster, Customer Service Assistant II