|The concept of “essential maintenance
practices” (EMPs) was developed to deal with lead-based paint in older
housing in recognition that “an ounce of prevention is worth a pound
of cure.” While some homes need dedicated “lead abatement projects”
by certified contractors, in most cases, hazards can be avoided in the first
place through good maintenance and common sense safeguards. Some EMPs are
specific to lead safety, such as avoiding paint removal practices that generate
and spread dangerous lead dust. Others address conditions that can cause
multiple problems. For example, water leaks, water damage, and excessive
moisture can encourage the growth of mold, mildew, and pests, which can
cause asthma and other health problems, in addition to causing paint to
deteriorate. Periodic visual inspections can identify clues to and causes
of water leaks and moisture problems so that low-cost repairs “nip
problems in the bud.” The concept of “enlightened maintenance
practices” is at the foundation of healthy homes. The EPA/HUD five-hour
training course in lead-safe work practices (LSWP) offers a model for conveying
practical information to existing trades and can benefit all those whose
work encounters painted surfaces in older housing.
In 1995, a broad-based national task force chartered by Congress reached
almost unanimous consensus on recommendations for controlling lead-based
paint hazards in private housing. As part of its comprehensive recommendations,
Putting the Pieces Together: Controlling Lead Hazards in the Nation’s
Housing (July 1995), the Task Force on Lead-Based Paint Hazard Reduction
and Financing called for six Essential Maintenance Practices by owners
of pre-1978 rental properties that may contain lead-based paint. These
Essential Maintenance Practices are relatively inexpensive initial steps
property owners need to take to reduce the chances that hazards will develop,
avoid the inadvertent creation of hazards, and provide an early warning
system to alert owners to deteriorating paint.
It is important to understand that Essential Maintenance Practices are
a "floor," not a "ceiling," as these practices were
not designed to control lead hazards in units that are judged to be higher-risk
based on their age or condition (e.g., construction before 1950, extensive
deteriorated paint, deferred maintenance, etc.).
work that disturbs paint that may contain lead to avoid creating
lead-based paint hazards. Do not use unsafe paint removal practices,
- Open flame burning;
- Power sanding or sandblasting (unless a
special vacuum attachment is used to contain dust);
- Water blasting; and
- Dry scraping more than a de minimis surface
area (for example, more than one square foot per room).
Use good work practices and take precautions
to prevent the spread of lead dust (for example, limit access to
the work area to workers only; cover the work area with six mil
polyethylene plastic or equivalent; protect workers; protect occupants’
belongings by covering or removing them from the work area; wet
painted surfaces before disturbing; and wet debris before sweeping).
Perform specialized cleaning of the work area
upon completion of work using methods designed to remove lead-contaminated
2. (unless the paint is
found not to be LBP):
- At unit turnover; and
- Every 12 months (unless the tenant refuses
If more than a de minimis amount of paint (for example, more than
one square foot per room) has deteriorated (unless the paint is
found not to be LBP):
- Follow Essential Maintenance Practice #1
(above) when repairing the surface.
- Diagnose and correct any physical conditions
causing the paint deterioration (for example, structural and moisture
problems causing substrate failure or conditions causing painted
surfaces to be crushed).
- When there is extensive paint deterioration
(for example, more than five square feet per room), the procedures
for dust testing after Standard Treatments apply.
4. , including
the EPA-developed educational pamphlet and any information available
about LBP or LBP hazards specific to the unit.
5. asking tenants to report deteriorating
paint and informing them whom to contact. Promptly respond to tenants’
reports and correct deteriorating paint, with accelerated response
in units occupied by a child under age six or a pregnant woman.
In no case should owners take longer than 30 days to respond. Do
not retaliate against tenants who report deteriorating paint.
6. At a minimum, maintenance supervisors need to complete
a training course based on the HUD/EPA operations and maintenance/interim
control activities curriculum. The maintenance supervisor must ensure
that workers either take the training course or have a clear understanding
of LBP hazards, unsafe practices, occupant protection, and dust
cleanup methods (by such means as on-the-job training and video
instruction). The maintenance supervisor needs to provide adequate
oversight of workers who have not taken the training course.