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Lead Safe Work Practices:

Building Sustainable Capacity

National Lead-Safe Housing and Indoor

Environmental Health Conference 2002

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• Rachel M. Riley, CET

HUD Office of Healthy Homes and Lead Hazard Control

Washington, D.C.

• John R. Zilka

QuanTech, Inc.

Arlington, VA

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Who’s Here?

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Learning Objectives

• After the session attendees will be able to:– Define important terms

– List activities requiring LSWP training

– Describe HUD’s nationwide training initiative

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– List HUD’s recommended LSWP trainer qualifications

– Describe the training market

– List materials and equipment for LSWP training

Learning Objectives

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Background and Regulatory

Requirements

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• 30,000+ individuals trained to date– 780 sessions on LSWP

» In almost every state and territory– Certification training– 5 Train-the-trainer trainings for LSWP

contract• Approved 12 LSWP curricula • Programmatic training courses and meetings

Accomplishments

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Abbreviations

• CFR: Code of Federal Regulations

• HQS: HUD’s Housing QualityStandards

• LSHR: HUD’s Lead Safe HousingRule

• LSWP: Lead safe work practices

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Lead Safe Work Practices (LSWP)

• General term for set of procedures that reduce potential for lead exposure during a broad range of activities

• HUD’s Lead Safe Housing Rule, 24 CFR Part 35

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Reason and Purpose for LSWP

• Reason: Both scientific studies and anecdotal evidence have found a link between traditional renovation practices and blood lead and dust and soil lead.

• Purpose:– Protect occupants– Protect interior and exterior environments– Protect workers

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Types of Non-evaluative Work Mentioned in Title X

•Abatement Regulated by EPA (40 CFR Part 745)

•Interim controls•Rehabilitation•Maintenance

Not regulated by EPA

Regulated by HUD (24 CFR Part 35) but only for housing associated with Federal government

•Renovation and remodeling

May be regulated by EPA

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Basic Federal Requirements

• For non-evaluative work

– Worker qualifications

– Work practice standards, including clearance

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Lead Safe Housing Rule (LSHR)

• 24 Part 35 consolidated all HUD lead requirements

• Significant reliance on LSWP

• Required by many subparts

• Paired with clearance

• Rule supports certification required per EPA 402 rule

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HUD Worker Qualifications

• 24 CFR 35.1330(a)(4)

• Trained in OSHA hazard communication (29CFR 1926.59)

• Supervised by abatement supervisor or trained in lead-safe work practices

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– Certain methods prohibited– Occupant protection and worksite

preparation– Specialized cleaning methods– Required for activities disturbing more

than very small amounts of painted surfaces

Safe Work Practices (§35.1350)

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Prohibited Practices (§35.130)

• Open flame burning• Machine sanding w/o HEPA exhaust• Abrasive blasting w/o HEPA exhaust• Heat gun over 1100° F• Dry sanding or dry scraping (with limited

exceptions)• Paint stripping in poorly ventilated space

using a volatile, hazardous substance

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Activities Using LSWP

– Low-level rehabilitation– Ongoing LBP maintenance – Periodic cleaning of dust or debris– Weatherization, remodeling, renovation– Interim controls – Standard treatments– Paint stabilization, repainting– Moderate and “gut” rehabilitation– Abatement

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Terms

• “Lead Safe Work Practices” are used in a wide range of activities– When known or presumed LBP is

disturbed in Federally assisted housing, procedures must be used by trades

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Terms, cont’d.

• Not the same as “Interim Controls”– Interim controls are overall methods

intended to temporarily reduce lead exposure to lead-based paint hazards (I.e., paint stabilization, lining window troughs with coil stock, covering bare soil).

– Lead safe work practices are methods to control and contain dust that are used during interim controls, maintenance work or other activity.

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“HUD-Approved

LSWP Training”

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Training Required For:

• HUD-approved training is required for individuals who perform interim controls: – Treat friction surfaces– Treat impact surfaces– Treat chewable surfaces– Control contaminated soil– Control lead dust hazards– Perform standard treatments – Perform ongoing LBP maintenance

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• HUD-approved training is required for individuals who:– Perform ongoing LBP maintenance– Treat bare soil – Stabilize paint – Perform regular building maintenance

activities or other maintenance or renovation work impacting known or presumed LBP

Training Required For:

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Training Required For:

• Paint Stabilization:– Is a type of interim control– Is performed as part of owner’s ongoing

LBP maintenance program– Satisfies HUD’s housing quality

standards (HQS) inspection requirements

• Risk Assessment is not necessary to stabilize deteriorated paint

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Training Is Recommended For:

• Low level rehabilitation ( < $5K/unit)• Disturbance of small amount of old

painted surfaces • Volunteer program supervisors

(“house captains”)• Explains reasons and processes

– Purpose and procedures– Cleaning and clearance

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HUD-Approval Process

• HUD approves curricula, not delivery

• Private and public entities have approved courses

• List of approved courses is located at: www.hud.gov/offices/lead/lbptraining.cfm

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• HUD recommends use of existing curricula

• HUD has Interim Training Criteria for Course Approval (see handout)

• Recommended instructor qualifications• Submittals need to include complete

curriculum and all supplemental materials for review and approval

HUD-Approval Process

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HUD’s Recommended Trainer Qualifications

• Background in adult education– Train-the-trainer session important– Have you presented to:

• Neighborhood groups? • Sunday school? • Work meetings?

– Before you train:• Assess your comfort level speaking • Learn from experienced educators

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Trainer Qualifications, cont’d.

• Lead Technical Competence– Risk assessor, Supervisor certification not

required– Evaluation and lead hazard control knowledge

important

• Follow State requirements for LSWP training, if applicable

• Understanding of Federal, State and Local Regulations and Policies

• Provide State contact information

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Training Grants Met Community Needs

• NCHH grants

• Iowa State Fiberoptic Network (ICN)– Health Dept personnel delivered training– Several hundred workers trained– Rural ICN sites

• Public Housing Agency staff deliver LSWP training (Iowa)

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Training Meets Community Needs

• Health/Housing Dept partner to develop training (Conn., N. Car.)

• Tribes – environmental staff deliver training

• Community colleges initiative

• Existing deliveries in community colleges (Pennsylvania, Iowa, Md.)

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Volunteer Programs

• Rehabilitation• Up to $5,000 federal assistance per

unit• Subpart J of Rule• Use LSWP; no formal training

required• “Awareness” of lead hazards and

proper techniques

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Existing Training Sources

• Partnerships key

• Use Lead Listing as resource

• EPA-accredited lead training providers, universities

• NETA-certified instructors (CETs)

• OSHA Training Institutes/other Env. Health and Safety trainers

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Curricula and Training

Delivery

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New Training

• A brand-new type of training• Not for certification• Provides “Notice of Completion” rather

than a “certificate”• No prerequisites• Not OSHA training• Currently only instructor-led; not yet

computer-based or web-based• 8 hours duration

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HUD-Sponsored LSWP Training

• Built capacity: 30,000 workers trained by HUD

• Two courses were taught by HUD:• HUD’s adaptation of EPA’s Model Course

on Renovation and Remodeling• NETA Maintenance Training

• Nine other approved courses are available (see handout or web site)

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HUD-Sponsored Training

• Developed capacity quickly• Targeted large and medium-sized cities• Partnered with housing agencies

– Outreach and marketing– Attendance increased with participation of

local agency• Some Public Housing Agencies and

Community Development Agencies sponsored sessions

• State lead and training rules covered

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Common Elements

• All HUD-approved courses must cover:– Purpose and limitations of training – Background and health effects– Lead Safe Housing Rule requirements

for work practices and clearance– LBP and LBP Hazards– Regulatory overview, worker protection

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Elements, cont’d.

• Prohibited work practices• Containment and dust control• Soil-lead hazard control• Specialized cleaning• Waste handling and disposal• Clearance• Occupant Protection• Test (70% to pass)

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HUD’s Message

• Lead safe work is based on simple concepts – “You can do it!”

• Being careful takes longer and costs a little more

• Numerous success stories are available

• This is not abatement training• This is not a regulations course

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The “Can Do” Approach

• Teach students how to do the “right thing”

• Motivate students to do the “right thing”

• Focus on WHAT to do; what’s different with lead

• Briefly outline OSHA requirements

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Instructor’s Role

• Don’t alter the curriculum except to add state requirements

• Avoid opinion, interpretations– Avoids misstatements and

misunderstanding• Avoid self-promotion• Acknowledge you don’t know an answer,

then find out; no guessing allowed

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Choosing a Curriculum

• Review all model courses– Compare audience needs to HUD

training criteria

– Presentation of policy issues

– Encouraging compliance

– Additional OSHA training

– EPA requirements

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Curriculum, cont’d.

• Speak or meet with State lead regulator– Receptive to LSWP training?– Is State approval required to teach?– Does model course align with State

policy on:• personal protection• work methods• clearance requirements?

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Curricula, cont’d.

• Add State requirements• Does State license non-abatement

personnel? Sampling technicians?• Other modifications• Plan course approval procedure, if

applicable• Send State courtesy copy of

curriculum if no approval procedure

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Training Issues

• Curricula may be “chunked”

• Course delivery issues

• “Do’s and Don’ts” List from HUD

• Mission Statement

• Marketing advance time (no shows)

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Training Impacts

HUD does not regulate courses regarding:• Schedule

– Evening or weekend classes permitted– May divide content into smaller or shorter

segments

• Training location and access– Can use housing or health agency facility– Can accept in-kind contributions– Try to reduce travel distances

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Teaching Regulations

• The most common pitfall• Do your homework• Keep current on changes• Avoid complicated discussions of rules

– Will absorb precious time and derail class

• Refer to Interim Criteria for content items

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Team Teaching

• Some lead experts may be willing to participate on training team:– Childhood Lead Poisoning Prevention

Program Representatives– Health Department personnel– HUD Lead Hazard Control Grantees

• Sections on technical or health issues

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Equipment & Props

• Plastic sheeting• Duct tape• Spray bottles• Rags• Disposable suit• Buckets• HEPA vacuum vs. HEPA-filtered vacuum• N-100 respirator

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So what did we learn? - 1

• HUD’s initiatives are a “drop in the bucket” to what’s needed

• Lot’s of lead related misnomer

• Need to regionalize the training offerings to cover all the players

• Need to be more customer conscious i.e. schedule, segmented sessions

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So what did we learn? - 2

• Better out-reach and marketing efforts are needed

• Local sponsoring agency involvement is a must

• Instructor training is important to deliver the “can do” message

• Specific curricula and delivery issues

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How can we build sustainable LSWP’s training capacity?

• Revise existing LSWP’s curricula to mesh with existing high school construction trade vo-tech programs

• Develop qualified trainers via LSWP’s Train-The-Trainer-Training (T4) courses

• Encourage a regional approach to maximize resources and avoid duplication

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Marketing Lead Safe Work Practices Training

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Training Market

• Housing agencies formerly small part of training market

• Certification training (mostly) available

• Rule requires training, not certification– States may elect to certify trained

individuals

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Marketing, cont’d.

• Analytical approach to marketing• Understand numbers of certified

people needed (low) vs. trained people needed (high)

• Analyze number of certified and trained people in your State

• Know your competition• Find your niche and target needs

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Where’s the Market?

• Community Development Agencies and grantees

• Owners receiving federal assistance - maintenance– Project-based assistance (Subpart H)– Tenant-based assistance (Subpart M)

• Public Housing Agencies (Subpart L)– Former lead regulations required inspection

and abatement by 1994

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Marketing Training

• Investigate partnerships with existing training providers

• Identify housing agencies and HUD field staff: www.hud.gov/offices/lead

• Identify reasons for prior training resistance

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Marketing the Training, cont’d.

• Motivating factors– Contract requirements to bid work – Preparing for regulatory compliance

and monitoring by program offices– Doing “the right thing”

• On front lines of change

• Knowledge reduces liability

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Research

• Existing brochures

• Flyers

• Registration materials

• Confirmation and follow-up strategies to reduce no-shows

• Test materials

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Potential Audience

• The people doing the work and using “hammers and nails”– Note: HUD program staff have their own

training opportunities and should not take LSWP training unless they do the “hammer and nail” work themselves.

• Various types of firms or organizations– Maintenance, rehab, trades, subcontractors,

labor unions

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Audience, cont.

• Has a range of goals and expectations

• Workers with language issues – Foreign language– Literacy

• Exist in urban or rural communities

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Give me Five Good Reasons to Teach LSWP

1.

2.

3.

4.

5.

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Give me Five Good Reasons to Teach LSWP

1. There are still poisoned children in U.S.

2. Community has increasing demand for education and training

3. HUD is moving toward monitoring phase of Rule implementation

4. Delivery costs are low5. Curricula are free

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Resources

Several available for download:

• Course curricula

• List of HUD-approved LSWP courses

• HUD’s interim LSWP training course evaluation criteria– www.hud.gov/offices/lead/lbptraining

• www.leadlisting.org

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Resources

• Lead paint compliance assistance center at 1-866-HUD-1012 (not the information clearinghouse)

• Lead_regulations@hud.gov