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Maintenance of Full or Interim Control Compliance StatusPolicy CLP-10A Rev 1/09, Revised 7/04, Issued 8/95 Page 1 of 12 TO: Private Lead Inspectors/Risk Assessors, Code Enforcement Lead Inspectors/ Risk Assessors, Training Providers FROM: Paul Hunter, Director RE: Maintenance of Full or Interim Control Compliance Status DATE: January 1, 2009 (revision of policy issued August, 1995 and rev. in July 2004) “Compliance” in this document refers to Full Initial or Deleading Compliance and/or Interim Control. For simplicity, the term “inspector” is used to indicate licensed private and code enforcement lead inspectors and licensed risk assessors. For those situations involving interim control, the inspector must also hold a risk assessor’s license. The term “compliance” refers to initial inspection compliance, full deleading compliance, and interim control. Scope of the Policy Statement This policy statement applies to residential premises, including any associated common areas and exteriors, that: 1.) have been issued a Letter of Full Compliance or a Letter of Interim Control and 2.) have met the standards for compliance set forth in the Lead Law and 3.) have met the compliance standards in the Lead Poisoning Prevention Regulations and Childhood Lead Poisoning Prevention Program (CLPPP) policies in effect at the time of issuance of the compliance letter or Letter of Interim Control. For post-compliance maintenance of “grandfathered” residential premises, including any associated common areas and exteriors, please also see policy statement CLP-12, Grandfathered Compliance. “Grandfathered” properties are those that met the pre-April 14, 1988 abatement standards and have been granted “grandfathered status” by CLPPP. The Commonwealth of Massachusetts Executive Office of Health and Human Services Department of Public Health Bureau of Environmental Health Childhood Lead Poisoning Prevention Program 250 Washington St. 7th floor Boston, MA 02108-4619 CLPPP Toll Free: 1-800-532-9571 DEVAL L. PATRICK GOVERNOR TIMOTHY P. MURRAY LIEUTENANT GOVERNOR JUDYANN BIGBY, MD SECRETARY JOHN AUERBACH COMMISSIONER Policy CLP-10A Rev 1/09, Revised 7/04, Issued 8/95 Page 2 of 12 Duty to Ensure that Compliance is Maintained Because the Massachusetts Lead Law does not require property to be lead-free, it is essential that owners ensure that their properties remain free of lead hazards/urgent lead hazards after compliance has been documented. CLPPP requires inspectors to attach the CLPPP “Fact Sheet on Maintaining Full Compliance” to every Letter of Full Initial Inspection Compliance and Letter of Full Deleading Compliance issued. CLPPP recommends that the owner or a representative visually assess the property on a routine basis, and whenever the occupant reports loose paint, removed or loose coverings, damaged encapsulants, loose putty, and/or deteriorated plaster. The property owner may also hire a lead inspector to perform this assessment. Instructions for the inspector and the property owner on how to perform a post-compliance assessment determination (“PCAD”) of a property with a Letter of Full Compliance are in Appendix A of this document For properties with a Letter of Interim Control, refer also to the CLPPP booklet, “Interim Control of Lead Paint Hazards: A Step-by-Step Guide.” Note that Letters of Compliance do not “expire” after any given period of time. CLPPP does not require letters of compliance to be routinely updated. However, property owners may choose to update their letters of compliance to make sure that the property is still free of lead hazards. In order to do this, the owner must hire a lead inspector to perform a Post-Compliance Assessment Determination, or “PCAD.” Procedures for Inspectors Assessing Whether Compliance Has Been Maintained If a lead inspector is hired to perform a post-compliance assessment of a property, he or she should follow the assessment procedure outlined in Appendix A of this document and at 105 CMR 460.760 (E). The assessment will be primarily a visual one, with the additional requirement that whenever loose paint, plaster or putty is located during the assessment, and no previous test result for that surface is documented, the lead inspector must test the loose paint, plaster or putty to determine whether it is leaded, or assume that the surface is positive if it is not accessible for testing. Briefly, the procedure to perform a post-compliance assessment determination consists of : • ensuring that a code enforcement “Order to Correct” has not already been issued for the unit in question • obtaining all available documents relevant to the compliance status of a unit. Documents may include: o a copy of the inspection, risk assessment, and re-inspection reports o a copy of the Letter of Compliance or Letter of Interim Control o a copy of any Certifications of Restored or Maintained Compliance o a copy of any waivers or letters from CLPPP documenting grandfathered status • checking all surfaces with remaining leaded paint or other coating, plaster, and putty to ensure that they remain intact; • checking all coverings, including encapsulants, to ensure that they remain an effective barrier, and • checking all reversed surfaces to ensure that they remain reversed. Policy CLP-10A Rev 1/09, Revised 7/04, Issued 8/95 Page 3 of 12 Errors and Omissions in Original Documentation In every case, a PCAD should be done using original reports and compliance documents. Inspectors contacted to do an inspection or post-compliance assessment should make every attempt to obtain this documentation. However, there will be cases where old documents are unavailable or deficient in some way. In these situations, the following rules apply: 1. Original compliance documentation is not available: a. Original Letter of Compliance is available, but no inspection or reinspection reports are available: In most cases where an original Letter of Compliance is available, but no inspection and reinspection reports are available, the property is still eligible for post-compliance maintenance and restoration rules (for exceptions, see #3, evidence of unauthorized deleading). The owner/inspector should make every attempt to obtain the missing documentation, by contacting the previous owner or real estate agent, where applicable, or by contacting CLPPP. In the event that the inspection/reinspection reports cannot be obtained, the lead inspector must perform a new comprehensive inspection, which will function as a PCAD. The inspector should test and record readings both above and below any demarcation lines. Surfaces that were dipped, stripped, or encapsulated may test positive for lead. Depending on the nature of the available documentation, CLPPP will likely require additional deleading or in rare instances may authorize atomic absorption testing of the surfaces in question. If the Letter of Compliance pre –dated September 1, 2002, then surfaces testing between 1.0 mg/cm2 and 1.3 mg/cm2 would not have to be deleaded. b. No original letter of compliance is available, but other documentation supporting the compliance status of the property is available: Alternative documentation such as deleading contracts, cancelled checks, reinspection reports, deleading notifications, and information in CLPPP’s databases may be used to qualify a property for eligibility for post-compliance rules. In such cases, the owner/inspector must receive a waiver from CLPPP prior to the owner undertaking any corrective work. 2. Surfaces not tested on original report, or surfaces tested but not deleaded as required: In the course of conducting the post-compliance assessment, the inspector may detect situations where the previous inspector(s) erred. The inspector conducting the PCAD is required to immediately report any situation where it appears that the previous inspector(s) erred to the appropriate CLPPP regional inspector. Example 1: The inspector conducting the PCAD notices that an accessible, mouthable surface was never tested. In this situation the inspector would test the surface; if positive, the hazard would need to be corrected. Example 2: The inspector conducting the PCAD notices that an accessible, mouthable surface was documented as being positive on the initial inspection report, but finds no Policy CLP-10A Rev 1/09, Revised 7/04, Issued 8/95 Page 4 of 12 record of deleading on the reinspection report. The inspector should retest the surface, document the results, and require correction if dangerous levels of lead are detected. After consultation with CLPPP, if it is determined that the original compliance document is valid but contained a few minor errors, all identified hazards may be corrected in accordance with the rules of post-compliance work as detailed above. If CLPPP determines that the original compliance document was not legitimate, the property will not be eligible for post- compliance rules and all hazards must be corrected in accordance with standard deleading rules. This would include the use of authorized workers, deleading notifications, and occupant relocation as necessary. 3. Evidence of unauthorized deleading: In cases where an inspector is hired to perform a PCAD following the issuance of a Letter of Initial Compliance, and the inspector observes evidence of deleading work, the inspector must immediately report the situation to the appropriate CLPPP regional inspector. In such cases, CLPPP may deem the original compliance letter not legitimate, and the unit will not be eligible for post-compliance rules. After hazards are corrected by authorized workers in accordance with standard deleading rules (including deleading notification and relocation of occupants when necessary), the inspector must obtain authorization from CLPPP to issue an unauthorized deleading document. See CLPPP Policy on Unauthorized Deleading for further information. Preparation of the Post-Compliance Assessment Determination Report form The inspector must identify any existing lead hazards and document them on a “Post-Compliance Assessment Determination” form. In cases where a new comprehensive inspection is being conducted to serve as a PCAD, the inspector may use an initial inspection report form, but must make a notation on the History page that the report is serving as a PCAD, and attach the appropriate CLPPP waiver document, if applicable, to the report. When using the Post-Compliance Assessment Determination form, the inspector must document each lead violation, labeled in accordance with the initial inspection report, and provide a description of the nature of the violation, e.g., “broken covering” or “loose paint above five feet”. Any codes used, such as “cov” for covering, should be in conformance with existing CLPPP inspection codes, or a key must be provided in the comments section. Any testing done must be documented. If the surface tested is found to be a lead hazard it should be recorded on the PCAD Hazards page. If the surface tested if found not to be a lead hazard, it should still be recorded; however, it belongs on the Addendum form. If the property has been granted “grandfathered” compliance by CLPPP, the inspector would this information in the waiver section of the History page. This means that the property was deleaded and complied prior to the changes to the Lead Law in 1988. Because the deleading standards were different at this time, it may affect how much, if any, additional deleading will be required to maintain/restore compliance. If the owner has not received grandfathered status from CLPPP in writing, the inspector should refer them to CLPPP to discuss how they may apply to have the property grandfathered. See policy CLP-12 for more information on maintaining compliance in grandfathered properties. Policy CLP-10A Rev 1/09, Revised 7/04, Issued 8/95 Page 5 of 12 Notification Procedures No hazards identified: If no lead hazards are identified by the inspector during a PCAD, the inspector should issue to the owner the Certification of Maintained Compliance, which serves as an addendum to and is attached to the Letter of Full Compliance, Letter of Interim Control, or CLPPP waiver. A copy of this document and its attachments must also be provided by the inspector to the occupants. If the property has been grandfathered, the inspector should check off the appropriate area of the Certification of Maintained Compliance form, and also attach the grandfathering approval letter from CLPPP to the Certification. No dust samples are required. EXCEPTION: In some cases, lead hazards are documented by a code enforcement inspector or housing quality standards inspector working on behalf of a housing agency prior to the performance of a formal PCAD by a licensed lead inspector. Inspectors should ask owners to provide them with any such citations prior to completing a PCAD. In such cases, if the hazards previously documented have been corrected prior to the performance of the PCAD, the lead inspector MUST take dust samples and obtain passing results prior to issuing a Certification of Maintained Compliance. Hazards identified: If the inspector identifies lead hazards during a PCAD, he or she must issue to the owner and to the occupants of the assessed dwelling unit the following: • “Notice of Post-Compliance Lead Hazards” form • a copy of the post-compliance assessment determination report (or full inspection acting as a PCAD • “Notice to Property Owner and Occupant’s Rights and Remedies” • “Residential Deleading Advisory” • The inspector must also send to the owner the “Notice to Tenants of Lead Paint Hazards” if hazards are identified in common areas. The private inspector must mail or deliver these documents within ten (10) working days. Who Can Correct Lead Hazards Identified Through a PCAD? 1. In cases where a code enforcement agency has issued an order requiring correction of lead hazards identified during a PCAD and where a child with an elevated or poisoned blood lead level resides, corrective work must be performed in accordance with all requirements for deleading. These requirements include use of appropriately authorized persons, issuance of deleading notifications, and relocation of occupants during interior high or moderate-risk work. This requirement applies even when the work is performed and completed within 30 days. 2. In most cases involving private inspectors, where there is no child with an elevated lead level, work performed within 30 days of the date of the PCAD may be done by anyone over the age of 18. The worker is not required to be trained or authorized, but must perform all corrective work in accordance with the Deleading Regulations, section 454 CMR 22.11, Safety Procedures for Renovation and Rehabilitation. Additional safe Policy CLP-10A Rev 1/09, Revised 7/04, Issued 8/95 Page 6 of 12 work requirements that must also be followed can be found in Appendix B of this document. 3. In cases not involving a poisoned or elevated child, any corrective work taking place after 30 days from the date of the PCAD (including clean up work) must be performed by persons with the appropriate level of authorization. Such work is subject to all other deleading requirements, including the issuance of deleading notifications and occupant relocation during high or moderate risk deleading of the interior. 4. An individual who has not completed training may repair structural defects and clean a property for interim control. 5. In cases in which maintenance or restoration work is not performed by appropriately authorized people, when required, CLPPP will not allow any additional compliance addendums to be issued (Certificates of Maintained or Restored Compliance). Owners will only be eligible for reinspection documentation. CLPPP reserves the right to seek fines and penalties for Unauthorized Deleading. Procedures for Inspectors Assessing Whether Compliance Has Been Maintained/Restored after Hazards Were Identified During a PCAD After hazards identified during a PCAD have been corrected, an inspector must return to the property for a reinspection to determine that all lead hazards have been appropriately corrected and that the premises is cleaned. Next to each lead hazard noted on the PCAD report, the inspector shall note the date the lead hazard was corrected in the “treatment date” column and record a description of the corrective work done in the “treatment method” column. Any time work is performed to maintain or restore compliance following a PCAD, the inspector must take dust samples in accordance with CLPPP’s dust sampling protocol prior to issuing a Certification of Maintained or Restored Compliance. In cases where occupant relocation was required to complete high or moderate risk work in the unit interior (in cases where a child with an elevated blood lead level resides, or when work is being done after the 30 day maintenance period), occupants may not be permitted to reoccupy until dust samples meet post-deleading clearance standards. Once the inspector has determined that all lead hazards have been corrected, there are no signs of paint chips, dust or debris, and dust samples have passed, and the inspector has received the appropriate deleader’s invoice and/or owner/agent work documentation where required, the inspector shall issue the Certification of Maintained or Restored Compliance. This certification will serve as an addendum to the Letter of Full Compliance. In order for a property to receive a Certification of Maintained Compliance, all corrective work must be completed and documented by the inspector as being completed within 30 days of the date of the PCAD (or, in code enforcement cases, within 30 days of receipt of the Order). In addition, passing dust samples must be obtained within the 30-day period. If only part of the work was completed by day 30, the inspector should reinspect and document the work completed up to that point. The inspector will also provide guidance on how to address the “punch list” items which require authorization to complete after the 30th day. In any case in which work is completed after the 30-day period, the property will only be eligible for a Certification of Policy CLP-10A Rev 1/09, Revised 7/04, Issued 8/95 Page 7 of 12 Restored Compliance. Inspectors do not have authority to grant extensions beyond this 30-day period. For cleaning occurring after 30 days, an authorized person must be used. The level of authorization required depends on the nature of the work performed to correct the hazards. For example, if extensive areas of loose paint were made intact, a licensed deleader must perform any clean-up occurring after day 30. In properties that have been granted grandfathered status by CLPPP, those surfaces that are found to be violations during a post-compliance assessment must be deleaded according to CLP-12, Grandfathered Compliance. If window surfaces (or any other surfaces) are deleaded to the current standard, they must also be recorded on the back of the Certification of Maintained or Restored Compliance. The inspector must check off the appropriate area on the Certification indicating that the unit was grandfathered, and attach CLPPP’s grandfathering approval letter to the Certification. The inspector must provide copies of any compliance letter addendum and post-compliance assessment determination reports to CLPPP in accordance with CLPPP’s policy on reporting requirements. Any property which has previously received a Letter of Unauthorized Deleading or Documentation of Environmental Status will never be eligible to receive a Certification of Maintained Compliance or Certification of Restored Compliance. Such properties may document updated lead status through a PCAD report and dust sampling. Any work needed to correct post-unauthorized deleading lead hazards must be performed by authorized persons, even within the 30-day period. Owners who engage in unauthorized deleading at any point in time may be subject to criminal and civil penalties. Any waivers from the requirements of this policy must be approved by CLPPP in writing. Policy CLP-10A Rev 1/09, Revised 7/04, Issued 8/95 Page 8 of 12 Appendix A: Performing a Post-Compliance Assessment Following the Issuance of a Letter of Full Compliance For additional guidance on how to perform Post Compliance Assessment Determinations (PCAD), Full Inspections acting as PCADs and, Partial PCADs, inspector should refer to CLPPP training materials including refresher training manuals from 2004 and 2008. The person who performs a post-compliance assessment will need a copy of the following documents: the lead inspection and reinspection reports; the Letter of Full Compliance; copies of post-compliance documentation, such as a previous Post-Compliance Assessment Determination (PCAD) report; any previous post-compliance certifications such as a Certification of Maintained or Restored Compliance; and any waivers or letters from CLPPP granting grandfathered status to a property. All of this documentation will allow the person assessing the property to fully understand the inspection and deleading history of each surface. Prior to going into the field, the inspector should make a copy of the reinspection report (or initial inspection report indicating that there were no lead hazards and no signs of unauthorized deleading). The copy should be marked working copy and the “original” document should be kept in the office file. 1. Match rooms and surfaces on the inspection report with the property: Using the working copy, refer to the diagrammatic floor plan on the cover page of the inspection report. This plan will contain the relevant location of the rooms and common areas. The diagram is oriented so that the street side of the building that gives the property its address is the “A” side. Each room will also use this building “A” side as its individual “A” side. If you stand with your back to the “A” side, the “B” side will be to your left, the “C” side will be in front of you and the “D” side will be on your right. All bathrooms, kitchens, halls, stairs and porches should be labeled as such on the report. Each additional room will be labeled with a number. Make sure that all of the rooms were identified and if any new rooms exist are added to the diagram. Please refer the 2008 refresher training for suggestions about how to document different (incorrect or changed) floor plans. A previously tested surface will be listed on the room page by the side on which it is located (again, “A”, “B”, “C” and “D”). If there is more than one building component, such as two doors or windows on a given wall, the report will contain a further description such as “left”, “center”, “right” or “1", “2", “3", moving left to right along each particular side. If all surfaces of a particular building component tested identically, they may have been recorded on one line of the report with the room side(s) and the number of surfaces noted (for example, “A(3) doors pos.” or “Bx2, Dx4 window sills neg.”). Using an easily identifiable pen (different color from the ink on the working copy), check off that every component that currently exists in the room was, in fact, identified on the original report. 2. Determine if the surface was found to be leaded during the initial inspection and if and how it was deleaded for compliance: Policy CLP-10A Rev 1/09, Revised 7/04, Issued 8/95 Page 9 of 12 Refer to the key on the inspection report for any codes or abbreviations. In general, a number in the “Lead” or “Pb” column greater than or equal to 1.0 mg/sq cm, or a “pos” notation means that the surface was tested and found to have a dangerous level of lead. (Note: Prior to 9/1/2002, the number 1.3 mg/sq cm or greater indicated a dangerous level of lead. On older reports, there may be surfaces with readings between 1.0 and 1.3 mg/sq cm that were not deleaded; this is acceptable as long as the paint on these surfaces is intact). A number less than 1.0 mg/sq cm, or a “neg” notation means that the surface was tested and not found to have a dangerous level of lead. These surfaces do not need to be corrected for compliance with the Lead Law. If a component exists but has an abbreviation such as “N/A” or “Met” in the lead column, then the surface was not tested and must be assumed to be leaded and must be assessed as a hazard. If the component exists, but there is no test result in the lead column, then the lead inspector must test and assess the surface. If the surface is found to be a hazard, then it is documented on the PCAD hazards page form. If the surface is found to not be a lead hazard, then it is recorded on the Addendum page. Review the deleading methods which should be documented in the “comp method” or “delead method” column of the reinspection report. This is reinspection information that will be useful to determine whether a surface may still contain dangerous levels of lead. The acceptable deleading methods are: removal of paint, usually by scraping or dipping; replacement of the component, such as putting in new vinyl windows; reversal of flat woodwork; covering the surface with an acceptable material, including encapsulants; making surfaces intact. Again, you may refer to the key for abbreviations about the deleading method. If there is no key available, the most common abbreviations are: “scr” for scraped; “dip” for dipped; “cov” for covered; “enc” for encapsulated; “rev” for reversed; “rep” for replaced; “mi” for made intact. 3. Locate surfaces with loose leaded plaster, putty, paint, or other coating: Loose or damaged leaded surfaces need to be made intact for compliance. Determine if the surface was dipped, scraped in its entirety or if it was replaced. If this is the case, then loose paint on this surface is probably not leaded. If the loose surface was originally not tested, was only made intact, or is on header casings, jambs, and stops (wood work above 5 feet), then the paint is most likely leaded and must be repaired using the safe work practices outlined in Appendix B. For deleaded surfaces scraped to five feet (or four feet in grandfathered property), then paint above the demarcation line is most likely leaded and must be made intact, using the safe work practices outlined in Appendix B. 4. Determine that coverings, including encapsulants, forming an effective barrier over lead paint or other materials remain in place: Surfaces that were covered as a deleading method will be documented in the reinspection information and may also be noted on the back of the Letter of Full Deleading Compliance. If coverings are loose, they can be reattached or a new covering may be put up. If encapsulants have failed, try to determine if they can be repaired. Small areas may be patched according to encapsulant manufacturer’s instructions. If there is substantial failure, Policy CLP-10A Rev 1/09, Revised 7/04, Issued 8/95 Page 10 of 12 the surface may need to be deleaded using a different method. Substantial failure should be reported to CLPPP so we can keep track of problems with this technology. 5. Determine that surfaces reversed as a method of deleading remain reversed and securely in place: Surfaces that were reversed as a deleading method will be documented in the reinspection information and may also be noted on the back of the Letter of Full Deleading Compliance. These surfaces should only be flat wood trim, such as a door casing. If components are loose, they can be reattached. Make sure that the owner does not flip the wood trim around and expose the lead-coated side. Doing so would create a new lead hazard that will invalidate the Letter of Full Compliance. Policy CLP-10A Rev 1/09, Revised 7/04, Issued 8/95 Page 11 of 12 Appendix B: Additional Safe-Work Practices for Post-Compliance Correction Work Work to repair post-compliance lead hazards must be done by authorized people whenever a child with an elevated or poisoned blood lead level is in residence, or whenever work is being performed after 30 days of the post-compliance assessment determination (or, in code enforcement cases, after 30 days from receipt of the Order). In cases where the use of authorized people is not required, because work is being performed with in 30 days of the PCAD and there is no child with an elevated/poisoned lead level in residence, the following rules apply: 1. Workers must follow the work practices outlined in the Deleading Regulations, section 454 CMR 22.11, Safety Procedures for Renovation and Rehabilitation, 2. Surfaces in violation because they contain defective lead plaster, putty, paint or other coating may be corrected by repairing to make intact. Loose leaded plaster should be patched. Loose leaded putty should be removed and replaced with non-leaded putty. Loose leaded paint should be made intact by wetting it and then hand-scraping the flaking areas, followed by priming and repainting. Do not sand or dry scrape, because lead dust will be generated. 3. Missing coverings should be replaced. The material should be fastened securely by nailing, cementing or gluing and any sharp edges must be caulked. 4. Power sanders, heat guns, and chemical paint removers should not be used. 5. Encapsulants must not be applied to surfaces that have not been assessed and passed physical tests (x-cut and patch tests) performed by the trained owner/agent who will be applying them. Encapsulants may place a lot of stress on underlying paint layers and substrates. If surfaces are encapsulated without being tested, they may fail to form an effective barrier, the property will not be in compliance, and children living in the unit may become poisoned, exposing the property owner to liability. 6. Work should only be undertaken by persons with previous experience and adequate skills in similar activities. If the owner or agent lacks the expertise or equipment necessary to follow the safety precautions described, or to perform the necessary corrective work in a workmanlike fashion, he or she should hire a licensed deleader to complete the necessary repairs. Furthermore, if the maintenance work is extensive, CLPPP highly recommends that a licensed deleader be hired. Maintenance work performed on leaded surfaces without following the appropriate work practices and safety precautions can contaminate the property and occupant’s belongings with lead dust and chips, lead poison workers and occupants, and expose the property owner to liability. Policy CLP-10A Rev 1/09, Revised 7/04, Issued 8/95 Page 12 of 12 Work Site Preparation When working inside, shut windows and doors to keep lead debris in the work area. Cover vents, air registers, floors, and any furniture or personal belongings with thick plastic and seal with duct tape. Occupants should never be in the work area while work is occurring or before it is cleaned up. Do not track dust and chips from the work area into unprotected areas. When working outside, on the building side where you are working, shut the windows (including storms) and doors to keep lead debris from entering the building. If you are doing a lot of scraping or repainting on the exterior of the house, seal the windows and doors with thick plastic and duct tape to prevent dust from seeping in through the cracks. Protect soil and plants by covering with thick plastic or with disposable tarps. Protect outdoor furniture and play equipment by removing it or covering with thick plastic and sealing with duct tape. Do not do work on windy days. Always follow all local ordinances that pertain to conducting renovation or maintenance work. Some areas require local permitting for certain activities. Work Site Clean-up Clean up of the work site must be performed at the end of each working day. Remove all plastic and tarps without spilling debris and carefully fold them so the debris is folded inside. Seal the plastic and tarps with tape. Clean all indoor surfaces in the work area with a a lead-specific detergent or any general household cleaner. Use a spray bottle for the cleaner and paper towels to scrub the area. The harder you scrub, the better for removing lead dust. Do not vacuum up paint chips or sweep them up with a broom. Rake up any paint chips that may have landed on the ground. Disposal Double bag all items to be disposed of and throw them away in the trash. If you have questions about the owner’s obligation to maintain compliance with the Massachusetts Lead Law, or if you want additional information about hiring a licensed inspector or deleader, obtaining the training necessary to become authorized to perform deleading work, or about performing maintenance work safely, please contact the Childhood Lead Poisoning Prevention Program at (800) 532-9571, or visit our website at www.state.ma.us/dph/clppp.