Lead Paint Toolbox Talk for Renovation
If the house went up before 1978, treat the paint as lead until a test says otherwise, because the dust from one afternoon of sanding is what gets carried home in a truck seat.
Print this talk with the sign in lines on it
One page to read from, with space for the job, the date, who led it and twelve signatures. Print it, read it, get it signed, file it.
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The talk, read this out
How old is this house? If the answer is before 1978 or you do not know, we are working lead safe today, and that starts before the first piece of trim comes off.
Lead paint was in use in American housing until it was banned for residential use in 1978. The older the house, the more likely it is and the higher the concentration. The hazard is almost never the intact paint. It is the dust and chips made when it is disturbed.
Two sets of rules apply at once. OSHA 1926.62 protects the worker, with exposure limits, monitoring and hygiene requirements. The EPA Renovation, Repair and Painting rule protects the occupants, and it applies to work for compensation in pre 1978 housing and child occupied facilities where you disturb more than six square feet of interior paint, twenty square feet of exterior, or replace a window.
Under RRP, the firm has to be EPA certified, the work has to be supervised by a certified renovator, the occupants have to get the lead pamphlet, and the records have to be kept. Fines for doing it without that are not small.
Three methods are prohibited outright: open flame burning or torching, machine sanding or grinding without HEPA exhaust control, and heat guns above eleven hundred degrees Fahrenheit. Dry scraping and dry sanding are how most of the dust gets made, so wet methods and HEPA attachments are the working answer.
Containment. Plastic on the floor extending out from the work, doors and vents sealed, no occupants in the area, signs up, and the plastic folded inward and disposed of properly at the end. Everything that comes out of the room comes out through that containment.
Hygiene is the part that goes home with you. No eating, drinking or smoking in the work area, wash hands and face before breaks and before leaving, change out of work clothes, and do not take dusty clothes home to be washed with the family laundry. Children in the house of a remodeler have been poisoned this way.
And cleanup. HEPA vacuum, wet wipe, HEPA vacuum again. A shop vac without a HEPA filter blows lead dust straight back into the room, in a finer form than it started.
Point at these before anybody starts
A talk delivered in a trailer is a meeting. Stand where the work is and put a hand on each of these.
- The age of this building, and whether a lead test has been done
- The containment: plastic, sealed doors and vents, and the signs
- The tools: HEPA shrouds, wet methods, and nothing that burns or dry sands
- The hand wash station, and where people are eating and drinking
- The waste bags, and how the plastic is coming out at the end
- Who here has small children at home, because the clothing rule matters most to them
The rules that apply
- Treat paint in pre 1978 housing as lead containing unless testing shows otherwise.
- RRP applies to work for compensation disturbing more than 6 square feet interior, 20 square feet exterior, or any window replacement in pre 1978 target housing.
- Prohibited: open flame burning, machine sanding or grinding without HEPA control, and heat guns above 1100 degrees Fahrenheit.
- Contain the work area with plastic, seal doors and vents, keep occupants out and post warning signs.
- Wash hands and face before eating, drinking, smoking or leaving. Change clothes and never take work clothing home to wash with family laundry.
- Clean with HEPA vacuum and wet methods only. A standard shop vac makes it worse.
Ask the crew
Three questions, answered out loud by name. This is the part that tells you whether anybody was listening.
- Has this house been tested, and if not, why are we treating it as anything other than lead?
- Where is the hand wash station and where are people eating lunch today?
- Who has young kids at home and is changing clothes before they get in the truck?
Close with this
Pre 1978 means lead safe work. Contain it, wet it, HEPA it, and wash before you eat or drive home.
A talk nobody signed for is a talk that, as far as anybody can later prove, never happened. Use the free toolbox meeting sign in sheet in PDF, Word or Excel, or print the PDF above, which already has the signature lines on it.
Questions people ask
When does the EPA RRP rule apply?
To renovation, repair and painting work performed for compensation in housing or child occupied facilities built before 1978, where the job disturbs more than 6 square feet of interior paint per room, more than 20 square feet of exterior paint, or involves window replacement or demolition. The firm must be EPA certified and a certified renovator must direct the work.
What work practices are prohibited on lead paint?
Open flame burning or torching, machine sanding, grinding, planing, needle gunning or blasting without a HEPA exhaust control, and using a heat gun above 1100 degrees Fahrenheit. Dry scraping and dry sanding are strongly discouraged and must be minimized and contained.
Can lead dust be taken home on clothing?
Yes, and it is a documented route of childhood lead poisoning in construction families. Change out of work clothes and shoes before going home, do not wash work clothes with family laundry, and wash hands and face before leaving the site.
More toolbox talks
TOOLBOX TALK: LEAD PAINT IN RENOVATION
Attendance
Everybody who was present signs, including subcontractors and anybody visiting the site.