Exterior renovation activities

Phase II was the Worker Characterization and Blood Lead Study, which from the title had to do with the PbB levels of renovation and repair workers, while Phase III of the field data gathering evaluated children s PbB levels associated with repairs and renovations in units, the Wisconsin Childhood Blood Lead Study. The final Phase IV segment concerned blood lead data gathering in workers doing repairs and renovations in old, historic homes. In the Dust Study, 12 interior and 12 exterior renovation activities were carried out in vacant units in Ohio. 

Exterior renovation activities performed as part of the study included the following ... 

In particular, EPA noted that HUD s Lead Safe Housing Rule, at 20 CFR 35.1350(d), includes a de minimis exception for projects that disturb 2fF or less of painted surface per room for interior projects, 20 fF or less of painted exterior surfaces, and 10% or less of the total surface area on an interior or exterior type of component with a small surface area. If less than this amount of painted surface is disturbed, HUD s lead-safe work practice requirements do not apply. EPA s Lead-Based Paint Activities Regulation incorporates this as an exception for small projects at 40 CFR 745.65(d). EPA requested comment on whether the minor maintenance exception in this regulation should be consistent with other EPA regulations and the HUD Lead Safe Housing Rule. This provision describes the applicability of the Pre-Renovation Education Rule as well as this final rule. 

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