Lead-Based Paint Inspections

An Inspection of painted surfaces throughout the building or facility is made by a certified inspector to identify those with a unique painting history as determined by scratching through the paint to the substrate if no records of prior painting exist. The condition of the paint and substrate surfaces is recorded. The survey  includes inspection of surfaces above or behind suspended ceilings or other objects or non-permanent construction in order to ensure that no accessible suspect lead-based paint goes undetected.  A written report including survey logs  is prepared.

Sampling

Each surface with an apparent unique painting history is sampled separately.  Paint chip samples are collected by a certified lead-based paint inspector and are analyzed by an independent third party laboratory to identify the presence (greater than 0.5% by weight) or absence of lead.  Samples are analyzed using the Atomic Absorption (AA) Method 7421 in accordance with regulatory guidelines. Sampling locations are recorded on the survey logs  A written report including independent laboratory analysis reports and a listing of confirmed lead-containing painted surfaces is prepared.

Soil sampling is also performed by EHC Associates to monitor lead contamination conditions outside a facility resulting from deteriorating or delaminating exterior painted surfaces.

Risk Assessment

Assessments are performed of confirmed lead-containing painted surfaces in accordance with regulatory guidelines. The condition of painted surfaces and their potential for damage are evaluated along with the potential exposure of the facility occupants and workers.  Dust sampling may be performed to determine the extent of contamination present from damaged or deteriorated paint surfaces.

Prioritized, recommended response actions, based on the assessments, are proposed as the least burdensome method in regard to short-term costs to protect human health and the environment.  These recommended response actions should be considered by the facility owner/manager along with concerns for local circumstances, occupancy by children, renovation/ demolition plans, and long-term costs prior to determining an appropriate course of action. 

Response actions should be determined that are at least equal to the recommended response actions in regard to their adequacy to protect health and the environment. Abatement or adequate preventative measures to reduce disturbance of the painted surfaces should be implemented.  

Management Program 

The facility owner/manager must initiate an operations and maintenance program containing responses,  procedures, and controls to minimize health risk of occupants and workers to asbestos exposure. This program must remain in place until such time as all lead-based paint has been removed. The management program provides assurance that all possible steps are being taken to protect facility occupants and workers and it serves as a legal document by providing detailed evidence of awareness of the problem and steps taken to comply with regulatory requirements and minimize risk. 

Each management program must be designed to suit the occupancy, conditions and owner/manager operational needs.  After a thorough review of the survey and assessment documentation, EHC Associates, in conjunction with the facility owner/manager, develop a concise and detailed written plan which includes the following:

• purpose and approach

• initial decontamination and abatement 

• long-term abatement program

• techniques for minimizing exposure

• operational procedures

• maintenance procedures

• paint damage episodes

• training

• labeling and notification

• periodic surveillance / re-inspection 

• record keeping

The management program should be updated periodically after a re-inspection and assessment of the lead-based paint materials.  

Periodic Surveillance and  Re-inspection

Periodic surveillance of the lead-containing painted surfaces should be performed a minimum of every six months to determine the presence of any deterioration or damage or a potential for damage.  Response actions or updates to the operations and maintenance program should be conducted as required by any changes in condition or in facility utilization.

At three- to five-year intervals the lead-containing painted surfaces should be re-inspected and assessed by a certified inspector and the management program should be updated. The updated program should reflect any response actions and/or operations and maintenance procedures required by changes in the condition of the painted surfaces or building utilization, and to accommodate any re-direction of the facility owner's or manager's lead-based paint control program.

Abatement Design

Bidding Phase  
The bidding phase includes the reproduction of bidding documents for distribution to bidders and assisting the Client in qualifying prospective bidders, obtaining and evaluating bids, and awarding abatement contracts. Administration of the bidding, including issuance of addenda, attendance at a pre-bid conference, and preparation and issuance of minutes are part of this phase.

Abatement Administration 

Abatement Phase  

This phase involves the administration of the abatement contract and generally includes:

• attendance at a pre-abatement conference, and preparation and issuance of minutes;

• review and approval of the contractor's cost breakdown, proposed subcontractors, proposed abatement and safety procedures, progress schedule, material samples, shop drawings, bonds, and other required submissions;

• inspection trips to the site to review the progress of the work and its quality in order to determine if the work is proceeding in accordance with the contract documents.  Formal job conferences will be held as required and will be followed by the issuance of job meeting minutes;  

• review of the contractor's applications for payment, determination and verification of the amounts owed to the contractor and issuance of certificates of payment for such amounts;  

• preparation of all supplemental drawings and sketches that may be required for the abatement sequence and issuance of any supplemental instructions or change orders covering authorized revisions in the work.  The Client is informed of, and his approval obtained, for any changes in the work;  

• complete documentation of the abatement work, including daily logs, monitoring/testing results, narrative description, disposal documents, photographs, etc., is forwarded to the Client upon completion of the contract work.  Copies of all contract related correspondence are forwarded to the Client upon initiation.  

Close-Out Report

A project close-out report including notifications, technician daily reports and inspection reports, air monitoring records, and waste testing and disposal documents will be prepared and submitted to the Client upon completion of the project.

Wipe Sample and Air Monitoring  

The purpose of abatement wipe sampling and air monitoring is to document and ensure that complete decontamination of the work area is achieved, including the specified abatement of lead-containing painted surfaces and removal of dust and debris containing lead in excess of the specified clearance levels.  Air monitoring also documents and ensures that areas of the facility beyond the abatement work area are not contaminated by airborne lead-containing dust or debris released by any of the abatement contract work procedures.

These services include furnishing all labor, supervision, transportation, materials, services, tools, and equipment necessary for complete lead abatement wipe sampling and air monitoring and testing as specified and as otherwise required by all applicable regulations. Analysis of wipe and air samples is performed at an independent laboratory.

Abatement Monitoring

Monitoring is performed to ensure that lead-containing paint is abated in a manner that:

• conforms to the intent of all health and safety laws and regulations; 

• recognizes and takes all reasonable precautions against the biological dangers of lead; 

• causes no contamination to other parts of the building; 

• provides adequate protection for the workers performing this task; 

• creates no short- or long-term threat to the health of other persons in or around the premises now or in the future; and 

• leaves the building documentably safe for occupancy.

Inspections of the work area preparation and containment are performed prior to the actual start of abatement work, and periodically thereafter, to look for any breaches in the containment or conditions that do not meet regulations or the requirements of the abatement contract documents.  In addition to the air and wipe testing hereinbefore described, visual inspections of all surfaces during and after work area cleaning operations are conducted. 

A narrative log is maintained on a work shift basis, that documents all notable events that occur each day and provides a comprehensive picture of conditions, problems, and progress in and around the job site during the course of the lead-containing paint abatement work.  Sample logs, that record all air and wipe sample monitoring tests performed, are maintained on a daily basis.