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.
Essential Maintenance Practices to Reduce Lead Hazards
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.).
|Essential Maintenance Practices for Property Owners|
1. Use safe work practices during work that disturbs paint that may contain lead to avoid creating lead-based paint hazards. Do not use unsafe paint removal practices, including:
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 dust.
2. Perform visual examinations for deteriorating paint (unless the paint is found not to be LBP):
3. Promptly and safely repair deteriorated paint and the cause of the deterioration. 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):
4. Provide generic LBP hazard information to tenants per Title X, including the EPA-developed educational pamphlet and any information available about LBP or LBP hazards specific to the unit.
5. Post written notice to tenants 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. Train maintenance staff. 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.