U.S. Department of Housing and Urban Development

Office of Housing

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Special Attention of: Notice H 95-15 (HUD)

All Secretary\'s Representatives

All State Coordinators Issued: March 16, 1995

All Area Coordinators Expires: March 31, 1996

All Directors of Housing
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All Directors, Single Family Divisions Cross References:

All Chiefs, Single Family Production and Handbook 4310.5, REV-2

Real Estate Owned Branches

All Regional Contracting Division Directors

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Subject: Single Family Property Disposition Program -

Changes to Procedures for Treatment of

Defective Paint

Existing guidance for the treatment of defective paint

surfaces in properties built before 1978 has been interpreted to

allow dry scraping and/or dry sanding as acceptable methods of

defective paint removal. Dry scraping and/or dry sanding, however,

generates dust which may be a health hazard if the paint is

contaminated with lead.

In an effort to minimize potential hazards, this Notice limits

the use of dry scraping and/or sanding and provides guidance on the

use of wet scraping and wet sanding, which are preferred methods.

The Notice also provides new requirements for protection of the

soil during exterior treatment, specialized cleanup, and waste and

debris collection and disposal. Detailed specifications reflecting

the new limitations and defective paint treatment procedures are

included on the attachment.

At the earliest possible time, action must be initiated where

necessary to amend all existing contracts for defective paint

removal to incorporate the procedures required by this Notice.

REAM contracts incorporating the defective paint removal

specification from the model REAM contract must also be amended.

Contractors are to ensure that subcontracts are appropriately

amended. The attachment may be used for inclusion in contract

amendments or when developing specifications for new contracts. It

is likely that price adjustments will need to be negotiated on

existing contracts due to these changes. Please keep a record of

all amendments as all offices will be surveyed at a later date on

their progress in completing this activity.

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HSIP: Distribution: W-3-1,W-2(OGC)(H)(Z),W-3(A)(H)(ZAOO),W-4(H),R-1,R-2,

R-3,R-3-1(H)(RC),R-3-2,R-3-3,R-6,R-6-1,R-6-2,R-7,

R-7-1,R-7-2,R-8,R-8-1

2

The inspection, treatment and clean-up of defective paint are high

risk activities because of their health-related implications. Failure to

properly carry out these activities places the Department in jeopardy.

Therefore, offices must have effective monitoring procedures in place to

assure that these activities are carried out properly. Handbook 4310.5

REV-2 states that a minimum of 10 percent of properties assigned to each

REAM, in each stage of processing, should be inspected each month. If
this

is not possible, REAMS which are most at risk of nonperformance should
be

targeted first. In addition, a minimum of 25 percent of all repairs

performed by REAMs and REAM subcontractors must be inspected to ensure
that

the work was satisfactorily completed. The REAM is required to inspect
100

percent of all repairs completed by its subcontractors. Inadequate

performance by the REAM or REAM subcontractors should lead to ranking
the

REAM as a high risk, prompting more frequent reviews of their
performance.

The guidance described in this Notice amends Handbook 4310.5, REV-2,

paragraph 13-9, Treatment of Defective paint Surfaces, and will be
included

in a future revision of the handbook.

1.Limitations on Dry Scraping and Dry Sanding: Dry scraping and dry

sanding may be used only for:

A.Limited surface areas around electrical circuits.

B.Defective paint spots totalling no more than two square feet in

any one interior room or space (hallway, pantry, etc.) or

totalling no more than 20 square feet on the exterior surfaces of

a structure.

C.Scraping paint that is softened with an infrared or coil-type

heat gun, provided the temperature of the paint is kept below

1,100 degrees Fahrenheit (to preclude exposure to lead fumes).

2.Acceptable Methods of Defective Paint Removal.

A.Low-tech Methods. Except for scraping with a heat gun, the

following methods do not require electrical power:

(1)Dry scraping, limited as shown above.

(2)Wet scraping or wet sanding. These methods are preferred

because they minimize the generation and spread of dust.

Specifications for procedures which must be used for wet

scraping or wet sanding are attached.

(3)Chemical stripping on or off site provided (1) the stripped

components are thoroughly cleaned to remove leaded and paint

remover residues, and (2) proper precautions are taken to

ensure that, wherever paint remover contains methylene

chloride, workers are not exposed to hazardous fumes. If

some paint-remover residues are not fully removed and

neutralized, it may be impossible to satisfactorily repaint

the surface.

3

B.High-tech Methods. These methods may be cost effective for very

large jobs but require electrical power and will seldom be

necessary for single family properties:

(1)HEPA vacuum sanding (machine sanders or grinders equipped

with High Efficiency Particulate Air (HEPA) exhaust

ventilation);

(2)HEPA vacuum needle gun: (needle gun equipped with HEPA

vacuum);

(3)Contained hydroblasting or high pressure water wash with

HEPA vacuum; and

(4)Abrasive blasting or sandblasting with HEPA vacuum.

3.Prohibited Methods of Defective Paint Removal.

A.Machine sanding without HEPA exhaust ventilation;

B.Use of propane or gasoline torches (open-flame methods);

4.Protection of Soil. Paint removal on exterior surfaces can

contaminate soil unless protective measures are taken. New procedures

intended to protect the soil from contamination are provided in the

attachment.

5.Specialized Cleanup Requirement. Removal of defective paint, even

with acceptable methods, causes some amount of dust and other waste.

Dust particles which are invisible to the naked eye remain on surfaces

after most standard cleaning procedures and may contain unacceptable

levels of dust particles. A thorough cleanup, using the specialized

cleanup procedures described in the attachment, is henceforth required

after removal of defective paint.

6.Waste Collection and Disposal. Waste and debris generated as a result

of treatment of deteriorated paint in single family properties is

generally produced in small quantities and may be exempt from federal

hazardous waste regulations. However, states have differing

requirements for waste management of potentially hazardous debris.

Therefore, HUD offices must ensure that contractors and subcontractors

comply with applicable federal, state and local law to ensure the

proper collection and disposal of defective paint waste and debris.

If you have any questions concerning this Notice, please call Ann M.

Sudduth, Director, Single Family Property Disposition Division, at (202)

708-0740.

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Assistant Secretary for Housing-

Federal Housing Commissioner

Attachment

ATTACHMENT

Page 1 of 2

DEFECTIVE PAINT: LIMITATIONS ON DRY SCRAPING AND DRY SANDING,

PROCEDURES FOR WET SCRAPING AND WET SANDING, SOIL PROTECTION,

SPECIALIZED CLEANUP AND WASTE DISPOSAL

1.LIMITATIONS ON DRY SCRAPING AND DRY SANDING. Dry scraping and dry

sanding may be used only for:

A.Limited surface areas around electrical circuits.

B.Defective paint spots totalling no more than two square feet in

any one interior room or space (hallway, pantry, etc.) or

totalling no more than 20 square feet on the exterior surfaces of

a structure.

C.Scraping paint that is softened with an infrared or coil-type

heat gun, provided the temperature of the paint is kept below

1,100 degrees Fahrenheit (to preclude exposure to lead fumes).

2.ACCEPTABLE METHODS OF DEFECTIVE PAINT REMOVAL.

A.Dry Scraping, limited as shown above.

B.Wet Scraping or wet sanding. These methods are preferred because

they minimize the generation and spread of dust. Specifications

for procedures which must be used for wet scraping or wet sanding

are shown below.

C.Chemical stripping on or off site provided (1) the stripped

components are thoroughly cleaned to remove leaded and

paint-remover residues, and (2) proper precautions are taken to

ensure that, wherever paint remover contains methylene chloride,

workers are not exposed to hazardous fumes.

D.HEPA vacuum sanding. (Machine sanders or grinders equipped with

High Efficiency Particulate Air (HEPA) exhaust ventilation);

E.HEPA vacuum needle gun. (Needle gun equipped with HEPA vacuum);

F.Contained hydroblasting or high pressure water wash with HEPA

vacuum; and

G.Abrasive blasting or sandblasting with HEPA vacuum.

3.PROHIBITED METHODS OF DEFECTIVE PAINT REMOVAL.

A.Machine sanding without HEPA exhaust ventilation;

B.Use of propane or gasoline torches (open-flame methods);

4.WET SCRAPING AND/OR WET SANDING. Prepare the work site with

protective covering on floors, stairs, carpets or the ground area to

prevent damage and ensure that debris is not tracked throughout the

area. Working a few square feet at a time, moisten the surface with

water completely, but not so much that large amounts run onto the

floor or ground. A spray bottle, plant mister, garden sprayer or

similar moistening device is acceptable, as is a wet sponge attached

to the scraper. Do not moisten surfaces near electrical outlets.

ATTACHMENT

Page 2 of 2

5.SOIL PROTECTION. Protective coverings should be used to protect the

ground a minimum of ten feet out from the work area undergoing

defective paint removal. Playground equipment such as toys and

sandboxes must be moved to a minimum of 10 feet from the work area and

covered. Items that cannot be moved should be covered with protective

covering. The exterior site should be cleaned daily and debris and

protective coverings stored in a secure area until disposal. See

paragraph 6.B. for daily cleanup and storage requirements.

6.SPECIALIZED CLEANUP PROCEDURES.

A.Interior:

(1)Wet Wash: The purpose of the wet wash is to dislodge and

remove dust particles. Wet wash all hard, uncarpeted

surfaces (except some wallpapers) in the area of treatment.

Floors are to be wet washed within 10 feet of treated

surfaces. For all other surfaces to be cleaned, wet washing

must extend five feet, at a minimum, in all directions from

the treated surface and is to include walls, window sills

and other horizontal surfaces (excluding the ceiling unless

it was treated). Use appropriate equipment, such as

cleaning solution spray bottles, wringer buckets, mops,

variously-sized hand sponges, brushes or rags. Use a

detergent known to be effective in lead dust removal, such

as trisodium phosphate or another solution of comparable or

better effectiveness. Exercise judgment so as not to cause

water damage to surfaces or substrates or fragile surfaces.

For example, some wallpapers should not be wet washed.

(2)Misted Sweeping. Small defective paint debris not collected

when protective covering is removed must be misted with

water, swept up, collected, and disposed of properly.

B.Exterior. The exterior site should be cleaned daily. Do not

leave debris or plastic out overnight. Store debris and

protective coverings in a secure area until disposal.

7.WASTE COLLECTION AND DISPOSAL. The contractor and any subcontractors

are fully responsible for compliance with all applicable federal,

state or local laws in the collection and disposal of defective paint

waste and debris.

2/95

\*U.S. Government Printing Office: 1995 - 387-734/20040