B. Federal Lead-Based Paint Enforcement Bench Book - National ...

“HEPA vacuum” means a vacuum cleaner which has been designed with a high-efficiency
particulate air (HEPA) filter as the last filtration stage. A HEPA filter is a filter that is capable of
capturing particles of 0.3 microns with 99.97% efficiency. The vacuum cleaner must be
designed so that all the air drawn into the machine is expelled through the HEPA filter with
none of the air leaking past it. 374
The rule does not prohibit dry hand-scraping or dry hand-sanding. 375
• Renovation Waste
Waste from renovation activities must be contained to prevent releases of dust and debris:
o Before being removed from the work area for storage or disposal;
o At the end of each work day and end of the renovation; and
o During transport from the renovation site. 376
• Cleaning the Work Area
After the renovation, the firm must clean the work area “until no dust, debris or residue remains.” 377
o Interior and Exterior Renovations
The firm must:
� Collect all paint chips and debris, and seal them in “a heavy-duty bag” without any dispersal;
and
� Properly remove, mist, fold, seal and dispose of protective sheeting. 378
o Interior Renovations - Additional Requirements
The firm also must properly clean all objects and surfaces in, and within 2 feet of, the work area,
cleaning from higher to lower:
� Clean walls, from ceiling to floor, with a HEPA vacuum and damp cloth.
� Vacuum remaining surfaces and objects (e.g., furniture and fixtures) with a properly equipped
HEPA vacuum.
� Wipe remaining surfaces and objects (except carpeted or upholstered surfaces) with a damp
cloth. Properly mop bare (uncarpeted) floors. 379
Post-renovation Visual Inspection
• All Renovations
A certified renovator must perform a visual inspection “to determine whether dust, debris or residue is
still present.” If so, then re-cleaning and another visual inspection are required. 380 All renovations
must pass this visual inspection.
374 40 C.F.R. § 745.83. 73 Fed. Reg. 21692, 21734-21736, supra note 160.
375 73 Fed. Reg. 21692, 21709, 21731, supra note 160. By contrast, the LBP Activities Rule restricts dry scraping. 40 C.F.R. §
745.227(e)(6)(iii).
376 40 C.F.R. § 745.85(a)(4).
377 40 C.F.R. § 745.85(a)(5).
378 40 C.F.R. § 745.85(a)(5)(i).
379 40 C.F.R. § 745.85(a)(5)(ii).
380 40 C.F.R. § 745.85(b)(1)(i), (b)(2).
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