The following steps have been developed for managing lead-based paint removal projects based on procedures in Trimbler’s Industrial Lead Paint Removal Handbook.
Initial Project Evaluation. In the initial project evaluation, the owner or specifier must determine whether the coating contains lead-based paint either by reviewing earlier plans and specifications for the structure or by sampling and analysis.
Prebid Assessment of Paint Removal Methods and Debris Generated. The owner or specifiers should estimate how much waste will be generated by methods evaluated to be appropriate to the size and circumstances of the project. Designing a testing program to evaluate the toxicity of waste generated may be appropriate for large paint removal projects.
Understanding the Regulations before Preparing the Specifications. The regulations regarding air quality, water quality, soil cleanup, unauthorized releases, worker protection, and hazardous waste generators should be thoroughly understood. How these regulations are enforced should be discussed with both state and local officials.
Preparing the Project Specifications. Both painting and lead removal requirements should be addressed in the specifications. These should identify the methods for surface preparation and the coating system to be applied. The relevant regulations, the degree of containment, and the evaluation of performance criteria should all be specified.
Developing a Worker Protection Plan. Prior to start-up, the contractor should provide a worker safety plan that addresses exposure monitoring, the compliance program, the respiratory protection program, personal protective equipment, housekeeping issues, hygiene facilities and procedures, medical surveillance, employee removal for exposure to lead, employee training, signage, record keeping, and employees’ right to observe and review monitoring information.
Preparing Environmental Protection Monitoring Plans. The procedures developed to verify environmental protection should include high-volume air samplers, tests for visible air emissions (opacity), personal air quality monitors, measurement (and reporting requirements) of unauthorized releases, and pre — and postproject soil quality and water quality sampling.
Developing Procedures for the Control and Handling of Hazardous Waste. Assuming that hazardous waste is to be generated, plans should be developed for identifying the waste, obtaining a hazardous waste generator identification number from the EPA, preparing for proper notification and certifications with each shipment, preparing waste manifests, packaging and labeling waste, implementing contingency plans, conducting waste treatment and analysis for on-site handling, and record keeping.
Designing a Containment and Ventilation Plan. The contractor should develop detailed plans to select appropriate support structures and containment, address ventilation and other worker safety issues, provide emissions control, achieve water and soil protection and debris recovery, and verify the integrity of the containment structure.
Monitoring the Project. The project manager should develop a plan to monitor the adequacy of all of the control measures; visually monitor the project regularly and use approved testing methods to evaluate adequacy of controls; regularly monitor the ventilation system and the integrity of the containment; regularly examine waste storage facilities, and the handling and transportation methods and procedures; and verify worker protection and hygiene procedures. OSHA standards must be observed. Figure 1.2 illustrates a decision tree to aid in the management of lead paint removal.
