DEPARTMENTS
VIEWPOINT
EPA’s New Clearance Standards for Lead
BY DEREK POPP AND KENNETH T. (KENN) WHITE
In January, an EPA final rule went into effect that established tighter standards for lead in dust on floors and windowsills. The rule lowered the agency’s dust-lead hazard standards from 40 µg/ft2 on floors and 250 µg/ft2 on windowsills to 10 µg/ft2 on floors and 100 µg/ft2 on windowsills. However, the rule left in place the agency’s clearance standards for floors, windowsills, and window troughs. As we noted previously in The Synergist, this discrepancy between the hazard levels and the clearance levels posed potential dilemmas for lead-based paint professionals in situations where lead dust in a building following abatement meets the clearance level but exceeds the hazard level. In such a situation, lead-based paint professionals may have a contractual obligation to clear the space for occupancy even though a lead hazard exists.
This summer, EPA proposed a new rule that addresses this potential conflict.
ALIGNING WITH HUD
The new rule, announced in June, proposes new levels for clearance following lead-based paint activities. This change will bring EPA requirements more in line with the requirements of the Department of Housing and Urban Development for its grantees. Specifically, the proposal would lower the lead clearance levels after lead-based paint activities in settled dust on floors from 40 µg/ft2 to 10 µg/ft2 and on windowsills from 250 µg/ft2 to 100 µg/ft2. The EPA dust-lead clearance level for window troughs remains unchanged in this proposal.
The clearance levels listed in the proposal are a maximum: in other words, results of any testing should be less than 10 µg/ft2 for floors, less than 100 µg/ft2 for windowsills, and less than 400 µg/ft2 for troughs. Assuming EPA finalizes the rule, the hazard and clearance levels will be as shown in Table 1. Also shown are lead hazard and clearance standards from the HUD Office of Lead Hazard Control and Healthy Homes. The HUD standards apply to recipients of grants under HUD’s Lead-Based Paint Hazard Control and Lead Hazard Reduction Demonstration programs.
DEREK POPP is the quality control coordinator at the Wisconsin Occupational Health Laboratory in Madison, Wisconsin. He serves on the AIHA Proficiency Analytical Testing Programs, LLC Board and is a member of AIHA’s Sampling and Laboratory Analysis Committee.
KENNETH T. (KENN) WHITE, MS, MM, CIH, CSP, FAIHA, FASTM, is the principal of Consultive Services in Virginia Beach, Virginia, and a member of the AIHA Sampling and Laboratory Analysis Committee, serving as chair of the Environmental Lead Subcommittee.
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Table 1. Lead Hazard and Clearance Standards
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PLANNED REVISIONS
EPA’s proposed rule is available in the Federal Register. For more information, visit the EPA website. The agency has proposed no changes to the use of the cleaning verification method following renovation, repair, and painting (RRP) activities.
In a related development, HUD plans to revise the HUD Guidelines for the Evaluation and Control of Lead-Based Paint in Public Housing chapter 5 on risk assessment and reevaluation and chapter 15 on clearance for publication in 2021. These guidelines, developed in 1995 and previously revised in 2012, provide technical information on identifying and controlling lead-based paint hazards in residential housing and child-occupied facilities. The HUD guidelines are available on the department's website.
