Developing and Implementing 

a Lead Dust Outreach, 

Monitoring, and Education 

Program in Your Community 

The Syracuse Lead Dust Project 

& Community T

EMP A C T

Environmental M

racking 

onitoring for Public Access 
Disclaimer

This document has been reviewed by the U.S. Environmental Protection Agency (EPA) and approved for publication. 

Mention of trade names or commercial products does not constitute endorsement or recommendation of their use. 
EPA/625/R-02/014 

February 2003 

Developing and Implementing 

a Lead Dust Outreach, 

Monitoring, and Education 

Program in Your Community 

The Syracuse Lead Dust Project


U.S. Environmental Protection Agency


National Risk Management Research Laboratory


Office of Research and Development


Cincinnati, OH 45268


2Recycled/Recyclable

Printed with vegetable-based ink on paper that contains a minimum of 

50% postconsumer fiber. 
ii

Contents 

Chapter 1: Introduction 1


1.1 About EPA’s EMPACT Program 1


1.2 About the Syracuse Lead Dust Outreach, Monitoring, and Education Project 2


1.3 Related Lead Dust or Lead Monitoring Programs 3


1.4 Alternative Programs 4


1.5 Are the Practices in this Case Study Consistent with Federal Regulations? 4


1.6 How To Use This Case Study 6


1.7 Acknowledgments 7


1.8 Resources for Additional Information 7


Chapter 2: Lead Dust: Why Is it a Problem? 9


2.1 What Is Lead Poisoning? 9


2.2 Sources of Lead in Dust 10


2.3 Exposure Pathways for Lead Dust 11


2.4 Resources for Additional Information 11


Chapter 3: Lead Dust Project Overview 15


3.1 Steps in the Development of Syracuse’s Lead Dust Project 15


3.2 Project Implementation Steps 18


3.3 Selecting Project Partners 21


Chapter 4: Communicating about Lead Dust 26


4.1 Syracuse’s Outreach Methods and Materials 26


4.2 Approaching and Recruiting Program Participants 28


4.3 Resources for Additional Information 29


Chapter 5: Collecting and Managing Data on Lead Dust 37


5.1 Chronology: From Data Collection to Reporting 37


5.2 Visiting the Home (Step-By-Step In-Home Sampling) 38


5.3 Quality Assurance Project Plan (QAPP) 40


5.4 Resources For Additional Information 40


Chapter 6: Analyzing Lead Dust Samples Using XRF Technology 42


6.1 Advantages of XRF Technology 42


6.2 Requirements and Qualifications 43


6.3 Quality Control 44


6.4 Health and Safety When Using XRF 46


6.5 Maintaining Equipment 47


6.6 Resources For Additional Information 48


iii 
Chapter 7: Mitigation and Maintenance 50


7.1 Lead Dust Mitigation 50


7.2 HEPA Vacuum Loaner Program 52


7.3 Disposal of Lead Dust Debris and Used HEPA Filter 52


7.4 Maintaining Lead-Safe Practices in the Home 53


7.5 Resources for Additional Information 54


Chapter 8: Reporting 57


8.1 Participant Reports 57


8.2 Public Reports 58


8.3 Web Site 59


8.4 Resources For Additional Information 59


Chapter 9: Evaluating Syracuse’s Lead Dust Project 73


Appendix A: Glossary 78


Appendix B: Quality Assurance Project Plan 80


Appendix C: Minneapolis Lead Hazard Control Program 89


Appendix D: EMPACT Lead-Safe Yard Project in Boston, Massachusetts 92


Appendix E: Memorandum from Elizabeth Cotsworth, Director, Office of Solid Waste, on 


“Regulatory Status of Waste Generated by Contractors and Residents from 


Lead-Based Paint Activities Conducted in Households” 95


iv 
1INTRODUCTION


Lead poisoning in children under the age of six continues to be a serious environmental 

health problem in the United States. Children from all socio-economic segments are 

potentially at risk, whether they are members of immigrant families living in old 

apartment buildings in inner cities, or members of well-to-do households living in historic residences. They can be exposed to lead where they live and play, primarily from the lead dust created when lead-based paint rubs off windows and other surfaces inside their homes. The good 

news is that many communities are taking effective action to raise awareness of lead-based paint 

and reduce the hazards of lead exposure to young children. 

The U.S. Environmental Protection Agency (EPA) and the U.S. Department of Housing and 

Urban Development (HUD) share joint responsibilities for the environmental and health risks 

of lead-based paint, and the two agencies are protecting children through issuing grants to localities such as Syracuse with the goal of reducing childhood lead poisoning. 

This technology transfer case study is designed to address two main goals. The first goal is to 

show how the Lead Dust Outreach, Monitoring, and Education Project in Syracuse, New York 

(Syracuse Lead Dust Project), is using a variety of effective, low-cost public information and 

education techniques to reduce children’s exposure to elevated levels of lead dust in their homes 

and day care facilities. The second goal is to provide information, recommendations, suggestions, and tools to assist individuals or groups who are developing similar programs to address 

the problem of lead dust in their communities. The lessons learned are based on the experiences 

of the Syracuse Lead Dust Project and several other programs that are highlighted at various 

points throughout this case study. 

This document is written primarily for community organizers, nonprofit groups, local government officials, tribal officials, and other decision-makers who will implement, or are considering 

implementing, lead dust outreach, monitoring, and mitigation programs. Much of the information will also be useful to tenants and homeowners interested in finding low-cost ways to reduce 

children’s exposure to lead dust. 

Before attempting to implement the process described in this case study, project staff, community organizers, homeowners, and tenants must be aware of the potential hazards associated 

with lead-based paint in housing. Everyone should carefully read those passages of the case 

study that describe lead hazards (Chapter 2). 

1.1 About EPA’s Empact Program 

This case study was developed by EPA’s EMPACT Program (www.epa.gov/empact). EPA created EMPACT (Environmental Monitoring for Public Access and Community Tracking) to promote new and innovative approaches to collecting, managing, and communicating 

environmental information to the public. Working with communities across the country, the 

program takes advantage of new technologies to provide community members with timely, 

accurate, and understandable environmental information they can use to make informed, dayto-day decisions about their lives. EMPACT projects cover a wide range of environmental 

issues, including water quality, ground water contamination, smog, ultraviolet radiation, and 

overall ecosystem quality. 

Introduction 1 
The Technology Transfer and Support Division of the EPA Office of Research and 

Development’s (ORD’s) National Risk Management Research Laboratory initiated the development of this case study to help interested communities learn more about lead dust monitoring 

and education programs, to provide them with the technical information they need to develop 

their own programs, and to minimize the resources needed to implement similar programs in 

other cities. Both print and CD-ROM versions of the case study are available for direct online 

ordering from ORD’s Technology Transfer Web site at <www.epa.gov/ttbnrmrl>. A PDF version 

of the case study can also be downloaded from the Syracuse Lead Dust Outreach, Monitoring, 

and Education Project at <http://www.syracuse-empact.com>. In addition, copies of the case study 

are available by contacting ORD publications at: 

EPA ORD Publications 

26 W. Martin Luther King Drive 

Cincinnati, OH 45268-0001 

EPA National Service Center for Environmental Publications (NSCEP) 

Toll free: 800 490-9198 

Local: 513 489-8190 

Available in hard copy or CD-ROM. 

1.2	 About the Syracuse Lead Dust Outreach, 

Monitoring, and Education Project 

Syracuse initiated its Lead Dust Outreach, Monitoring, and Education Project (the Syracuse 

Lead Dust Project) in 1998. The objective was to establish a community-based effort to provide 

local residents with information to assist them in reducing their exposure to lead dust in residential and public buildings. The project targets minority, immigrant, and low-income residents 

with a focus on families with small children who live in buildings constructed prior to 1978. 

Priority is given to households with children under the age of six. 

Syracuse’s Lead Dust Project collects lead dust level samples, analyzes the samples, reports 

results to the residents, and coordinates community outreach and education. If a lead hazard is 

present in a home, Syracuse staff contacts the participant, provides training in a three-step 

cleaning method, and informs the resident about a High Efficiency Particulate Air (HEPA) vacuum loaner program. If the data indicate that a lead hazard is not present, the participant 

receives a written copy of their individual sample results. 

Syracuse, located in central New York, is a medium-sized city with a 2000 Census population of 

147,000. The city’s housing stock is relatively old—more than 58 percent of the housing units 

were built prior to 1940, more than 22,000 of which are considered substandard. 

Approximately 64 percent of the housing stock is rental property. In the city’s revitalization 

areas, 68 percent of children under age 5 live in poverty, and 1,435 children under the age of 

six have elevated blood levels, according to 1998 data collected by Onondaga County Lead 

Poisoning Control. 

Working cooperatively with the county’s poison control program and its Healthy 

Neighborhoods Division, along with seven community-based organizations (CBOs), Syracuse is 

using grant funding from EPA’s EMPACT program for lead dust outreach, monitoring, and 

mitigation in 350 homes located in the same neighborhoods targeted by the city’s HUD lead 

hazard control program. 

2 Chapter 1 
The city of Syracuse has set up partnerships 

with the following seven CBOs to implement 

its EMPACT Lead Dust Project: 

•	 Boys & Girls Clubs of Syracuse 

<www.bgcsyracuse.org> 

•	 Southeast Asian Center 

<www.irccny.org/programs/seac.shtml> 

• Brighton Family Center 

•	 Girls, Inc. of Central New York 

<www.girlsinc.com> 

•	 Southwest Community Center <Web site 

under construction at time of printing. 

Call 315 474-6823> 

•	 Syracuse Northeast Community Center 

<http://community.syracuse.com/cc/ 

northeastcommunitycenter> 

• Westcott Community Center <www.westcottcc.org> 

These project partners play a critical role in implementing the Syracuse Lead Dust Project. 

CBOs recruit residents in the neighborhood to participate in the HEPA vacuum program, store 

the HEPA vacuums, assist with translation to non-English speakers, and provide critical program feedback from the community. Read more about CBOs and their role in Chapter 3. 

1.3 Related Lead Dust or Lead Monitoring Programs 

In developing this technology transfer case study, EPA contacted several other similar lead dust 

programs to gain their perspectives. EPA gathered information from the following other programs: 

•	 The Minnesota Environmental Health Lead Hazard Control Program 

Minneapolis/St. Paul (See Appendix C) 

The city of Minneapolis Lead Hazard Control Program, in partnership with Atrix International 

Corporation, has developed and implemented a cooperative HEPA vacuum rental program. 

This program is structured to assist homeowners, tenants, rental property owners, and renovators (do-it-yourselfers) in safely removing lead-based paint dust and chips from their homes. 

•	 HELP Lead Safe Center 

Providence, Rhode Island 

Health & Education Leadership for Providence (HELP) is a community partnership of colleges 

and hospitals in Providence, Rhode Island. The HELP Lead Safe Center assists families dealing 

with the complex needs of the lead-poisoned child and works to prevent the poisoning of other 

children in the home. The Lead Center offers medical and nonmedical case management, environmental and nutritional education, child development assessment, housing advocacy, social 

service referrals, and an innovative window replacement program for eligible families. 

Before beginning its lead dust project, Syracuse 

already had a HUD-funded lead hazard reduction 

program in place. Both programs share common goals: 

to identify areas where lead dust presents a hazard, to 

educate homeowners and tenants about lead hazards, 

and to suggest ways to reduce exposure to lead dust. 

Having the HUD lead hazard control program in place 

helped pave the way for the EMPACT Lead Dust 

Project because the Lead Risk Assessors had an existing 

relationship with the community, as well as with the 

Mayor and with other city decision-makers. Since 

HUD’s lead program already had a working office, EPA 

saved on personnel and other resources. In addition, the 

CBOs and residents were already somewhat knowledgeable about the hazards posed by lead in the home. 

Introduction 3 
As part of its comprehensive array of services relating to lead safety, the Lead Center conducts 

home environmental visual assessments. A trained assessor walks through the home with the 

family, room by room, identifying lead hazards. If lead dust is discovered, the Lead Center recommends cleaning techniques and teaches proper cleaning procedures, such as wet-cleaning 

lead dust using trisodium phosphate diluted in water. The organization also makes HEPA vacuums available on a loaner basis and provides instructions for their proper use. 

•	 EMPACT Lead-Safe Yard Project 

Boston, Massachusetts (See Appendix D) 

The EMPACT Lead-Safe Yard Project (LSYP) in Boston used a variety of low-cost techniques 

to reduce children’s exposure to elevated levels of lead in residential soil. The project used innovative field-portable x-ray fluorescence (XRF) technology to communicate data to residents and 

implemented low-cost and sustainable landscape measures in residents’ yards to reduce children’s risk of exposure to contaminated soil. The project also developed a template that other 

communities and public agencies can use to address the issue of lead in residential soil. 

The project improved 61 homes at no cost to the owners; conducted a number of seminars on 

lead-safe yard work; and developed a “Tool Kit” for use by other communities. These methods 

were then incorporated into a handbook titled Lead-Safe Yards: Developing and Implementing 

a Monitoring, Assessment, and Outreach Program for Your Community. 

1.4 Alternative Programs 

Homeowners or tenants living in an area where no lead dust program exists might want to have 

trained and licensed consultants determine whether they have a lead problem in their house. In 

this case, the homeowner or tenant should have dust wipe samples collected by a certified leadbased paint inspector, risk assessor, or sampling technician. For a list of qualified lead professionals, including inspectors, risk assessors, abatement contractors, and analytical laboratories, 

go to <www.epa.gov/lead> and click on “Finding A Qualified Lead Professional for Your Home” 

under “Additional Resources.” For EPA-run states, call 1-800-424-LEAD.* 

Homeowners can contact their state or local childhood lead poisoning prevention program for 

more information about obtaining lead dust testing. The following Web sites list state and local 

lead poisoning prevention contacts: 

•	 The Lead Program of the National Safety Council’s Environmental Health Center: 

<www.nsc.org/ehc/nlic/contacts.htm>. 

The National Conference of State Legislatures’ Directory of State Lead Poisoning Prevention 

Contacts: <www.ncsl.org/programs/ESNR/pbdir.htm>. 

1.5	 Are the Practices in this Case Study Consistent 

with Federal Regulations? 

Syracuse’s Lead Dust Project complies with the Toxic Substances Control Act (TSCA) Title IV 

and the Section 403 rule, under which EPA establishes standards for lead-based paint hazards, 

including hazard levels for lead-contaminated dust in houses. 

*	 EPA-run states are Alaska, Arizona, Florida, Idaho, Montana, North and South Dakota, Nevada, New 

Mexico, New York, South Carolina, Washington, and Wyoming. 

4 Chapter 1 
HUD and EPA set reference levels indicating the amounts of lead that might create adverse 

health effects to pregnant women and children younger than 6 years old. These standards allow 

landlords, tenants, parents, and child care providers to identify problems and make informed 

decisions. The Syracuse project based its own hazardous levels of concern on these standards 

(see table below). 

Syracuse’s Lead Dust 

Project provides residents (particularly lowincome, urban, 

minority residents) with 

practical, low-cost dust 

cleanup measures that 

will reduce exposure to 

lead-contaminated dust 

in the home. These 

Syracuse Reference Levels for Lead Dust Hazards 

Floor 40 μg/ft.2 

Window Sill 250 μg/ft.2 

Window Trough1 400 μg/ft.2 

1 Syracuse’s Lead Dust Project uses EPA’s clearance level of 400 μg/ft.2 for window 

troughs. 

low-cost measures may be used as interim shorter term solutions until permanent, higher cost 

solutions are employed as long as homeowners and/or residents carefully and conscientiously 

follow and continue to practice the recommended cleanup procedures. 

Before applying the Syracuse Lead Dust Project’s model to your situation, consult local regulatory authorities to determine their specific requirements, such as reference levels for lead-contaminated dust. State, tribal, and local government regulations might be more restrictive than 

existing federal guidance. 

Links to Regulations Related to Lead Dust 

• HUD Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing. 

<www.hud.gov/offices/lead/guidelines/hudguidelines/index.cfm> 

• Residential Lead-Based Paint Hazard Reduction Act of 1992. <www.epa.gov/lead/titleten.html> 

• The National Conference of State Legislatures’ Directory of State Lead Poisoning Prevention Contacts 

<www.ncsl.org/programs/esnr/pbdir.htm> 

• The Occupational Safety and Health Administration (OSHA) 

<www.osha-slc.gov/SLTC/lead/index.html> 

• HUD’s Lead Safe Housing Rule <www.hud.gov/offices/lead/leadsaferule> 

• EPA’s final standards (TSCA 403) for lead-based paint hazards (including lead dust). Office of 

Pollution Prevention and Toxics Web site <www.epa.gov/lead/leadhaz.htm> 

• SW-846 is EPA’s Office of Solid Waste’s official compendium of analytical and sampling methods that 

have been evaluated and approved for use in complying with RCRA regulations. 

<www.epa.gov/epaoswer/hazwaste/test/sw846.htm> 

Introduction 5 
1.6 How to Use this Case Study 

This case study provides information communities can use to create and implement a lead dust 

project. It provides examples of program planning and implementation along with important 

background information on lead poisoning. 

•	 Chapter 2 discusses why lead dust is a health hazard; the incidence of lead poisoning; sources 

of lead; and its pathways into the body. 

•	 Chapter 3 describes the steps taken by Syracuse to plan and implement its lead dust project, 

including identifying potential target communities, getting to know the community, and 

selecting program partners. 

•	 Chapter 4 discusses Syracuse’s recommendations for communicating about lead dust to residents and property owners. It covers the language and cultural challenges of communicating 

with immigrant and low-literacy populations and provides examples of effective outreach 

and educational materials used by Syracuse. 

•	 Chapter 5 provides information about collecting and managing data, including how to interact with residents as dust samples are collected from their homes. 

•	 Chapter 6 discusses use of the field-portable X-ray fluorescence (XRF) instruments to collect 

timely data, role of field sampling technicians, testing protocols, quality control, health and 

safety precautions, and equipment maintenance. 

•	 Chapter 7 discusses the mitigation (cleaning) process recommended by Syracuse and the 

HEPA vacuum loaner program and discusses the importance of continued maintenance. 

•	 Chapter 8 discusses data reporting to residents, landlords, and the public. It also covers 

recordkeeping and confidentiality. 

• Chapter 9 provides information on how Syracuse evaluates the performance of its program. 

This case study also includes references to supplementary sources of information, such as Web 

sites, guidance documents, and other written materials. In addition, the case study includes the 

following appendices: 

• Appendix A provides a glossary of technical terms used in this case study. 

• Appendix B comprises Syracuse’s Quality Assurance Project Plan (QAPP). 

• Appendix C provides a case study on the Minneapolis Lead Hazard Control Program. 

•	 Appendix D contains a case study on the EMPACT Lead-Safe Yard Project in Boston, 

Massachusetts. 

•	 Appendix E provides a memorandum from Elizabeth Cotsworth, Director, Office of Solid 

Waste on “Regulatory Status of Waste Generated by Contractors and Residents from LeadBased Paint Activities Conducted in Households.” 

Initiating and managing a lead dust program is a challenging but worthwhile undertaking. This 

case study aims to provide information and resources that will help develop new programs, 

maintain current programs, and educate individuals on how to decrease occurrences of lead dust 

poisoning in children. We hope that you find the case study informative and easy to use. 

6 Chapter 1 
1.7 Acknowledgments 

The development of this case study was managed by Scott Hedges (U.S. Environmental 

Protection Agency, Office of Research and Development, National Risk Management Research 

Laboratory) with the support of Eastern Research Group, Inc., an EPA contractor. Technical 

guidance was provided by the Syracuse Lead Dust Project. EPA would like to thank the following people and organizations for their substantial contributions to the contents of this case study: 

Theresa Bourbon, U.S. EPA, Region 2 EMPACT Project Officer 

Jeremy Giller, Executive Director, HELP Lead-Save Center, Providence, Rhode Island 

Mike Goss, Syracuse Lead Dust Project 

Robert Maxfield, U.S. EPA Region 1 

Pat McLaine, National Center for Healthy Housing 

Johanna Miller, Minnesota Environmental Health Lead-Hazard Control Program 

Betsy Mokrzycki, Syracuse Lead Dust Project 

Donna Ringel, U.S. EPA, Region 2 EMPACT Program Manager 

Patrick Strodel, Lead Safe, LLC 

Robert Vanderslice, U.S. Department of Housing and Urban Development 

Adam VanHoose, Syracuse Lead Dust Project 

1.8 Resources for Additional Information 

The following publications and resources provide a wealth of information on lead and lead-contaminated dust: 

Department of Housing and Urban Development. 1995. HUD Guidelines for the Evaluation 

and Control of Lead-Based Paint Hazards in Housing. Available online at <www.hud.gov/ 

offices/lead/guidelines/hudguidelines/index.cfm>. 

Department of Housing and Urban Development. 2000. Residential Lead Desktop Reference, 

2nd Edition. CD-ROM containing more than 140 documents, including ASTM scopes, 

screening guidance, community outreach materials, lead resources, scientific studies and reports, 

lead statutes and regulations, lead training materials, regulation support documents, reports to 

Congress, HUD guidelines, and other resources. Available for $10 by calling HUDUSER at 

1-800-245-2691. 

Lead-Based Paint Hazard Reduction and Financing Task Force. 1995. Putting the Pieces 

Together: Controlling Lead Hazards in the Nation’s Housing. Available online at 

<www.hud.gov/offices/lead/reports/report.pdf>. 

U.S. Congress. 1992. Residential Lead-Based Paint Hazard Reduction Act of 1992. Title X (42 

USC 4851). Available online at <www.epa.gov/lead/titleten.html>. 

Introduction 7 
U.S. Environmental Protection Agency. 1994. EPA Guidance on Residential Lead-Based Paint, 

Lead-Contaminated Dust, and Lead-Contaminated Soil. EPA540-F-94-045. Order online at 

<www.epa.gov/ncepihom/ordering.htm>. 

U.S. Environmental Protection Agency. 1995. EPA Residential Sampling for Lead: Protocols for 

Dust and Soil Sampling. EPA747-R-95-001. 

U.S. Environmental Protection Agency. 1997. Reducing Lead Hazards When Remodeling Your 

Home. EPA747-K-97-001. Order online at <www.epa.gov/ncepihom/ordering.htm>. 

U.S. Department of Housing and Urban Development. 2001. Lead Paint Safety—A Guide for 

Painting, Home Maintenance, and Renovation Work. HUD-1779-LHC. 

Links 

U.S. EPA National Lead Information Center at <www.epa.gov/lead/nlic.htm>. 

A federally funded hotline and clearinghouse that provides information on lead hazard reduction and exposure prevention. To speak with one of the Center’s clearinghouse specialists, call 

1-800-424-LEAD Monday through Friday, 8:30 a.m. to 6:00 p.m. EST. 

U.S. EPA Office of Pollution Prevention and Toxics (OPPT) at 

<www.epa.gov/opptintr/lead/index.html>. 

Responsible for EPA programs related to lead poisoning prevention and lead regulation. OPPT 

also provides educational packets for parents, teachers, day care providers, and librarians, as well 

as technical information and publications. 

The Department of Housing and Urban Development (HUD) at <www.hud.gov/lead/ 

leahome.html>. 

Sets standards for evaluating and managing lead in federal-assisted housing and promotes efforts 

to reduce lead hazards in privately owned housing. In addition, provides grants to communities 

to reduce lead hazards in housing. 

8 Chapter 1 
2LEAD DUST: 


WHY IS IT A PROBLEM?


This chapter provides an overview of the problems posed by lead dust. The information 

in this chapter should be useful to anyone interested in lead dust hazards and mitigation, including community organizers responsible for implementing a lead dust program or homeowners concerned about elevated lead levels in their own homes. 

• Section 2.1 discusses what lead poisoning is and how it affects children’s health. 

• Section 2.2 discusses the sources of lead in dust. 

• Section 2.3 describes the key pathways for childhood exposure to lead. 

• Section 2.4 lists resources for additional information. 

2.1 What Is Lead Poisoning? 

According to the Centers for Disease Control and Prevention (CDC), nearly 1 million children 

living in the United States in the early 1990s had lead in their blood at levels high enough to 

cause irreversible damage to their health. CDC defines elevated lead levels in children as 10 

micrograms of lead per deciliter of blood (μg/dL) or higher. Although there is no known safe 

level of lead in blood, lead poisoning is entirely preventable. 

The CDC recommends certain actions for various blood lead levels. In its 1991 report, 

“Preventing Lead Poisoning In Young Children,” the CDC recommended an intervention plan, 

which is currently still in use. In general, CDC recommends urgent follow up for children with 

blood lead levels of 45 μg/dL. These children should be taken to a clinic or medical center with 

experience in managing childhood lead poisoning. A child with a blood lead level greater than 

70 μg/dL should be hospitalized immediately. The CDC recommends that treatment for lead 

toxicity, at any level, must always involve removing the child from further exposure. Treating a 

child for lead toxicity is futile unless the child’s exposure can be reduced. 

Although childhood lead exposure has diminished in the past 25 years, the problem is far from 

solved. Deteriorating housing, lack of resources, lack of access to medical care, poor nutrition, 

and language barriers all contribute to poor and minority children being at risk for lead poisoning. However, no economic or ethnic/racial group is free from the risk of lead poisoning. Many 

affluent families renovating older homes, for example, have inadvertently exposed themselves 

and their children to lead hazards through unsafe lead paint removal techniques. 

Health Effects of Lead Poisoning 

Lead poisoning affects nearly every system in the body and often occurs without noticeable 

symptoms. Although lead can affect adults, children under the age of 6 are especially vulnerable 

to the adverse effects of lead. The incomplete development of the blood-brain barrier in fetuses 

and very young children (up to 36 months of age) increases the risk of lead’s entry into the 

nervous system. Low but chronic exposure can affect the developing nervous system in subtle 

but persistent ways. In children, blood lead levels as low as 10 to 15 μg/dL can stunt growth 

rates, affect attention span, cause learning disabilities, lower IQ scores, impair hearing acuity, 

and cause behavioral problems. In addition, fetuses exposed to elevated levels of lead can suffer 

Lead Dust: Why Is It A Problem? 9 
from low birth weight, impaired hearing, and altered gestational age, which can lead to further 

complications. 

In addition to damaging the nervous system, elevated blood lead levels can also affect the kidneys and reproductive system and cause high blood pressure. Very high levels (greater than 80 

μg/dL) can cause convulsions, coma, or death. Levels greater than 150 μg/dL are fatal if not 

treated quickly. Fortunately, exposures resulting in such high levels of lead are rare. 

2.2 Sources of Lead in Dust 

Lead dust from deteriorated paint is the most significant contributor to childhood lead poisoning.1 While the use of lead paint in residential buildings was federally banned in the United 

States in 1978, many homes built prior to 1978 still contain lead-based paint. Paint used in 

homes built between 1950 and 1978 contained between 0.5 and 50 percent lead, and the paint 

used prior to 1950 contained higher concentrations. One estimate is that more than 3 million 

tons of lead-based paint remain in the 57 million homes built prior to 19802

. 

Lead dust forms as lead-based paint peels, chips, chalks, or cracks. Dust also forms when painted surfaces bump or rub together (called friction surfaces, particularly found on doors and windows). The primary sources of lead dust are interior painted building components that receive a 

lot of wear-and-tear: windows, trim, and sills; doors and door frames; columns, stairs, railings, 

and banisters; and porches and fences. Lead dust can also form when lead-based paint is dry 

scraped, dry sanded, or heated during building renovations. Lead dust is especially problematic 

when found on surfaces that children can reach and chew or mouth, such as window sills, railings, and stair edges that are at child height. Another important source of lead dust is lead that 

has been deposited in soil. Lead in residential soil comes from several different sources, including lead-based exterior paint. Before 1978, lead paint was widely used on the exteriors of residential and other buildings. As the paint on a building’s exterior deteriorates, lead paint chips 

and dust concentrate in the surrounding soil. Renovating, remodeling, and performing routine 

home maintenance also will mobilize this lead if proper precautions are not taken. As with interior paint, dry scraping, sanding, and blasting of exterior lead-based paint can mobilize large 

amounts of lead in a short time. Disturbing the old lead-based paint can increase lead concentrations in soil, especially in the “drip zone,” or “drip line,” the area surrounding and extending 

out about 3 feet from the foundation of a building. (See Appendix D for information about an 

EMPACT program that addresses lead in residential soil). 

For additional information refer to an EPA fact sheet entitled, Identifying Lead Hazards in 

Residential Properties, which is included at the end of this chapter. 

1	 While not primarily responsible for childhood lead poisoning, other sources of lead in the environment 

include emissions from industrial sources such as smelters, mining operations, and battery-recycling plants; 

soil contaminated from vehicular emissions (before leaded gasoline was banned in 1986); lead water pipes; 

lead-containing tableware and crystal glassware; some hobbies, such a stained glass-making; some folk 

remedies; and some types of jewelry and pewter-ware. 

2 Centers for Disease Control, Preventing Lead Poisoning in Young Children, 1991. 

10 Chapter 2 
2.3 Exposure Pathways for Lead Dust 

The main way that lead enters the body in through ingestion3. The most common way for a 

child to ingest lead is by putting into their mouths objects (e.g., toys or hands) that have leadcontaminated dust or dirt on them. The dust and dirt inside the house may contain lead from 

deteriorating lead-based paint or from lead-contaminated soil tracked in from outside by people 

or pets. In addition, when children play outdoors, lead-contaminated dirt and dust can get on 

hands, toys, and food. Putting these items in the mouth can lead to ingestion of lead. 

Young children tend to ingest more lead than adults in a given environment because of their 

normal hand-to-mouth behavior. They also take in more food and water per kilogram of body 

weight. Children are at higher risk when their nutritional needs are not being met. Calcium, 

iron, zinc, and protein deficiencies, in particular, increase lead absorption rates. 

2.4 Resources for Additional Information 

Publications 

American Academy of Pediatrics Committee on Drugs. 1995. “Treatment Guidelines for Lead 

Exposure in Children.” Pediatrics. 96:155–160. Available online at <www.aap.org/policy/00868.html>. 

Centers for Disease Control and Prevention. 2002. “Managing Elevated Blood Levels Among 

Young Children,” Recommendations from the Advisory Committee on Childhood Lead 

Poisoning Prevention. Available online at <www.cdc.gov/nceh/lead/CaseManagement/casemanage_main.htm>, or call (toll-free) 1-888-232-6789. 

U.S. Environmental Protection Agency. 1997. Risk Analysis To Support Standards for Lead in 

Paint, Dust, and Soil, volumes 1 & 2. EPA747-R-97-006. Available online at 

<www.epa.gov/ncepihom/ordering.htm>. 

U.S. Environmental Protection Agency. 1999. Lead in Your Home: A Parent’s Reference Guide. 

EPA747-B-99-003. 

Links 

The Centers for Disease Control and Prevention (CDC) 


Childhood Lead Poisoning Prevention Program


<www.cdc.gov/nceh/lead/lead.htm>


Provides information about childhood lead poisoning, promotes state and local screening


efforts, and develops improved treatments for lead exposure. 


Lead Poisoning Prevention Outreach Program


<www.nsc.org/ehc/lead.htm> 


The Lead Poisoning Prevention Outreach Program is funded through a cooperative agreement


between the U.S. Environmental Protection Agency and the Environmental Health Center


(EHC).


3	 Children can also inhale lead dust from deteriorating paint, from clothing brought home by parents 

exposed to occupational lead sources, or from fumes from hobbies that use lead. In addition, children can 

breathe lead dust stirred up by conventional vacuuming or during building renovations. These instances are 

not considered significant exposure pathways, however. 

Lead Dust: Why Is It A Problem? 11 
Agency for Toxic Substances and Disease Registry (ATSDR) 


ATSDR conducts a public health assessment at sites on the EPA National Priorities List to


determine if people are being exposed to hazardous substances, which includes lead. The public


can search by region to see which health assessments are currently available in an online data-


base located at: <www.atsdr.cdc.gov/HAC/PHA/>.


National Conference of State Legislatures 


<www.ncsl.org/programs/esnr/pbdir.htm>


Contains NCSLnet Search – a directory of state lead poisoning prevention contacts.


Consumer Product Safety Commission (CPSC) 


<www.cpsc.gov>


Identifies and regulates sources of lead exposure in consumer products.


The Occupational Safety and Health Administration (OSHA) 


<www.osha-slc.gov/SLTC/lead/index.html>


Develops work practice standards and worker exposure limits to protect workers from occupa­


tional lead exposure.


12 Chapter 2 
United States Prevention, Pesticides EPA 747-F-01-002

Environmental Protection and Toxic Substances April 2001

Agency (EPA) (7404) (http://www.epa.gov/lead)

FACT SHEET

Identifying Lead Hazards in Residential Properties 

EPA has developed standards to help property owners, lead paint professionals, and government agencies 

identify lead hazards in residential paint, dust, and soil. These hazards may be paint chips, lead in household 

dust, child-accessible or mouthable painted surfaces, friction surfaces of windows and doors, and lead in 

residential soil. The Agency has released this fact sheet to summarize new standards and recommendations to 

better address lead hazards in and around homes. The complete text of the final rule is available through the 

National Lead Information Center or EPA’s Web site (see For More Information). 

LEAD PAINT HAZARD 

STANDARDS 

WHAT MAKES LEAD PAINT A HAZARD: 

The lead paint is deteriorating. As the paint 

breaks down, it releases paint chips and lead 

dust that can contaminate the home and be 

easily ingested by young children through handto-mouth activity. 

This deteriorated lead paint may be inside 

residential buildings or child-occupied facilities or 

on the exterior of any residential building or childoccupied facility. 

The lead paint is on friction or impact surfaces. 

Impact to surfaces like door frames or stairs can 

damage the paint and release lead. Also, the 

paint on friction surfaces like windows, stairs, 

and floors can break down during normal use 

and release lead. 

The lead paint is on child-accessible surfaces 

that show evidence of teeth marks. Beware of 

lead paint on surfaces such as window sills, 

railings, and stair edges that are at child height 

and have been or may be chewed on or mouthed 

by a child. 

All testing for, and identification of, lead 

hazards should be completed per EPA 

regulations. 

Lead paint is usually not a hazard if the paint: 

- Is in good condition. 

- Is not on an impact or friction surface (like a 

window, door, or a stair). 

Lead Dust: Why Is It A Problem? 13 
LEAD DUST HAZARD 

STANDARDS 

The following two standards have been set 

for lead hazards in dust: 

* 40 micrograms per square foot (g/ft2) for 

floors (including carpeted floors). 

* 250 g/ft2 for interior window sills. 

LEAD SOIL HAZARD 

STANDARDS 

The following two standards have been set 

for lead hazards in soil: 

* 400 parts per million (ppm) in play areas of 

bare residential soil. 

* 1,200 ppm (average) in bare soil in the 

remainder of the yard. 

LEAD ABATEMENT 

CLEARANCE 

REQUIREMENTS 

Following lead abatement, dust cleanup 

activities must be repeated until testing 

indicates that lead dust levels are below the 

following: 

* 40 g/ft2 for floors (including carpeted floors). 

* 250 g/ft2 for interior window sills. 

* 400 g/ft2 for window troughs. 

THIS REGULATION AFFECTS... 

The standards established in this regulation apply 

to most pre-1978 housing and child-occupied 

facilities (pre-1978 non-residential properties 

where children under the age of six spend a 

significant amount of time such as daycare 

centers and kindergartens). 

Anyone who must comply with other Title X 

regulations, whether issued by EPA, HUD, or by a 

State under an authorized program, may be 

affected by this regulation. The following list 

identifies some of the groups potentially affected 

by these standards: 

- Residential and child-occupied property owners, 

and owners receiving federal housing assistance. 

- Lead paint professionals. 

- Training providers. 

- Federal agencies. 

- Parents. 

WHAT HAPPENS IFA LEAD HAZARD IS IDENTIFIED? 

Property are required to notify occupants if they 

are aware of lead, whether or not it is identified as 

a hazard. However, this regulation does not 

require anyone to identify lead hazards, or that 

any specific action be taken if a lead hazard is 

identified. Please refer to the Protect Your Family 

brochure available through the National Lead 

Information Center for further information on 

disclosure of lead hazards to residents. 

Owners and other decision-makers should 

actively seek to reduce or prevent children’s 

exposure to lead in paint, dust, or soil that equals 

or exceeds these hazard levels. The Protect Your 

Family brochure provides some of these options. 

State, local, or tribal governments may have 

different standards or requirements. EPA 

recommends you contact them before beginning 

any work with lead paint. 

FOR MORE INFORMATION, CONTACT: 

* The National Lead Information Center at 

1-800-424-LEAD (5323). 

* EPA’s Web site at <www.epa.gov/lead>. 

14
 Chapter 2 
3LEAD DUST 

PROJECT OVERVIEW 

This chapter discusses the process followed by Syracuse to start and manage a lead dust 

mitigation program. 

•	 Section 3.1 presents a summary of the program development steps involved in planning and 

launching Syracuse’s Lead Dust Project. It also outlines the roles and responsibilities of program partners and staff. 

• Section 3.2 reviews the steps Syracuse took in implementing its Lead Dust Project. 

•	 Sections 3.3 and 3.4 discusses selecting program partners, provides an overview of the role of 

community-based organizations (CBOs), and discusses how to better understand the target 

community. These topics are covered in greater detail in Chapter 4. 

Outreach, sampling and analysis, mitigation, reporting, and evaluation are discussed briefly in 

this chapter and are covered in more detail in Chapters 4 through 9. 

3.1	 Steps in the Development of Syracuse’s Lead 

Dust Project 

The EPA (EMPACT)-funded Syracuse Lead Dust Project works with both homeowners and 

tenants—particularly those with small children—and provides free and immediate lead dust 

mitigation to significantly reduce lead dust levels where small children live and play. Although 

the program does not eliminate the source of the lead hazard (i.e., deteriorated lead-based 

paint), it treats the problem in part by providing personalized instruction of proper cleaning 

techniques. The program also educates parents and child care providers to teach children about 

the importance of hand washing and keeping their hands out of their mouths. 

The target population for the Syracuse Lead Dust Project are households with small children 

living in the city’s revitalization areas. Syracuse knew from the start that essentially all of the 

inner city rental housing stock had lead dust problems. To inform tenants about the lead hazards and to gain their trust and participation, Syracuse partnered with seven CBOs. The relationship built by the lead dust project with these organizations has been key to the project’s 

development and success. 

The following briefly explains Syracuse’s major programmatic benchmarks in the development 

of its lead dust project: 

Step 1: Project Planning 

First Syracuse developed a project plan with clearly defined goals and objectives, project scope, 

schedule, and identification of possible funding sources. Since Syracuse decided to use XRF 

technology, which is not an EPA-approved method for lead dust analysis, confirmatory laboratory analysis was considered necessary to demonstrate the reliability of the technology. To 

accomplish this, the project was designed in two phases. In Phase I the XRF findings were verified against laboratory analysis. During Phase II the project was implemented based on the 

results of this analysis. 

Lead Dust Project Overview 15 
Step 2: Identifying and Securing Funding 

Syracuse spent considerable time identifying sources of funding and determining grant application 

procedures and schedules. Syracuse allotted time for the application process, which included preparing the grant application, the review process, dealing with grant award procedures, and announcing 

the grant award to the public with a press event (project kickoff). 

Step 3: Establish Quality Assurance Plan and Procedures (QAPP) 

Since Syracuse secured an EMPACT grant, the next step was to draft a Quality Assurance Plan 

and Procedures (QAPP). All work performed or funded by EPA that involves the acquisition of 

environmental data must have an approved QAPP, which documents the planning, implementation, and assessment procedures for a particular project, as well as any specific quality assurance 

and quality control activities. It integrates all the technical and quality aspects of the project in 

order to provide a “blue print” for obtaining the type and quality of environmental data and 

information needed for a specific decision or use. (See Appendix B). 

Step 4: Secure Necessary Equipment and Licenses 

Syracuse then had to secure a New York State radiation license, purchase the HEPA vacuums 

and XRF equipment, and establish other contracts as necessary. Syracuse found that city procurement procedures increased the time needed to finalize this program step. Other programs 

might consider other options, which include renting or leasing the necessary equipment or hiring consultants who have their own equipment. 

Step 5: Hire and Train Staff 

Concurrent with Step 4, Syracuse recruited, hired, and trained qualified staff to perform home 

walk-throughs and to collect lead samples using the XRF At the same time, Syracuse began the 

process of training other project partners, such as CBO staff, about lead dust hazards and in the 

use of the HEPA vacuums. Syracuse’s full-time staff play multiple roles which are shown in the 

table below. Syracuse required that its field sampling technicians be EPA-certified 

inspectors/risk assessors. They also must be licensed by New York State to handle radioactive 

equipment. It is important to check with applicable state and local regulatory agencies to determine the certification and licensing requirements for staff in comparable lead dust programs. 

Roles of Syracuse Lead Dust Project Staff 

Title Role 

Program Manager Secures funding, recruits project partners, hires staff, oversees 

project implementation 

Outreach Coordinator Works with CBOs, educates residents about lead dust hazards, 

and enrolls them in the project. 

Field Sampling Technician Conducts walk-throughs of homes to identify dusty areas; 

collects and analyzes lead dust samples. 

HEPA Vacuum Coordinator Trains residents in three-step cleaning process and 

demonstrates use of HEPA vacuums. 

Data Analyst/Certified Reports site-specific results to residents, interprets significance, 

Risk Assessor and consolidates and reports data for the community. 

16 Chapter 3 
With project staff and equipment in place, Syracuse began to develop outreach and educational 

materials. These included promotional flyers, informational booklets, report templates, and 

“how to” guides for wet cleaning and using the HEPA vacuums. Chapter 4 contains specific 

information and examples of these outreach materials. 

Step 7: Project Implementation 

To get the project underway, staff worked 

with the CBOs to recruit participants, conducted dust sampling and analysis, set up 

home visits for mitigation and training on the 

cleaning process, initiated the HEPA vacuum 

lending program, started conducting postmitigation sampling and reporting, and began 

holding regular meetings with program partners. Syracuse also designed a program Web 

site. See Section 3.2 below for more details 

on the steps taken by Syracuse to implement 

its lead dust project. 

Step 8: Program Evaluation 

Because of EMPACT’s focus on monitoring 

and outreach, measuring the effectiveness of 

the mitigation component of the project has 

not been elaborate. Nonetheless, the project 

conducted a “spot check” of the effectiveness 

of its mitigation intervention (e.g., information about the 3-step cleaning method and 

the HEPA vacuum loaner program). 

In the implementation of its program, 

Syracuse found that its schedule was influenced by many variables—some not anticipated and out of its control. Project staff 

successfully resolved several major implementation hurdles that affected the original project schedule. Two steps, in particular, took 

longer than expected and required significant 

effort to accomplish. The first was the development, refinement, and ultimate approval of 

the Quality Assurance Project Plan (QAPP), 

as required by EPA. The QAPP is discussed 

in Chapters 5 and 6 and is provided in its 

entirety in Appendix B. The second was the 

sequence of steps involved in purchasing the 

X-ray fluorescence (XRF) equipment. A New 

York State radiation license is required for the 

purchase of an XRF. Since Syracuse did not 

already have a radiation safety officer involved 

Mitigation Is Not Abatement 

Using a HEPA vacuum and following the mitigation steps explained in Chapter 7 of this case 

study only cleans the accumulation of lead dust but does 

not abate, or eliminate, the source of lead dust in a 

home. Mitigation helps curb exposure to lead dust but 

will not prevent lead dust from recurring. Residents or 

homeowners who want to determine whether their lead 

dust problem is serious enough to require abatement 

should consult with a certified risk assessor. 

A certified risk assessor is trained to determine the existence, nature, severity, and location of lead-based paint 

hazards in a residential dwelling. A risk assessor can recommend ways to control lead-based paint hazards, 

including abatement. The National Lead Center Hotline 

(800 424-LEAD) can help residents locate a certified 

risk assessor, or visit <www.epa.gov/lead/leadcert.htm> 

and click on “Training and Certification” then scroll 

down to the bottom of this page for an interactive map 

of authorized state lead programs. These links provide 

lists of lead professionals. Untrained individuals should 

never attempt to abate lead-based paint hazards in their 

home without professional help. 

When lead-based paint exists on surfaces such as walls, 

ceilings, woodwork, windows, and sometimes floors, residents and homeowners should take the following precautions to prevent the creation of dust: 

• Do not dry scrape or dry sand on painted surfaces. 

• Avoid puncturing holes in walls with lead-based paint 

or encapsulated or enclosed walls. 

• Do not repeatedly bump furniture or other objects 

into older painted surfaces. 

• Avoid unnecessarily opening and closing windows or 

doors with painted sills or frames; these friction surfaces can cause paint to deteriorate and can cause lead 

dust to be generated. 

Lead Dust Project Overview 17 
in its lead hazard control program, staff first had to undergo training in order to apply for the 

state radiation license. 

3.2 Project Implementation Steps 

The following briefly summarizes the steps taken by the Syracuse Lead Dust Project to implement its program. 

Project Intake (Recruiting Participants) 

Syracuse identified at-risk children by targeting neighborhoods with older, wood-framed housing (generally with wooden clapboard siding). Such houses are likely to have lead-based interior 

or exterior paint. Neighborhoods made up of older housing units, especially homes built before 

1978, when the use of lead paint was federally banned in the United States, are more likely than 

newer communities to have a lead problem. In Syracuse, therefore, officials target buildings 

built before 1978 that house children. In fact, the prevalence of such structures made intake 

screening unnecessary—Syracuse accepts all referrals from CBOs that involve small children. 

First, CBOs work to inform residents about the city’s lead dust project. Then residents or 

property owners fill out a HEPA Vacuum Intake Questionnaire (see copy at end of Chapter 5) 

which is submitted to the Syracuse lead team for evaluation. This questionnaire collects basic 

data, such as household size, number of children under 6, and the age of the building. The 

team then contacts the resident to set up a time to collect dust wipe samples from the property. At the same time they also provide the individual with a clear understanding of how the 

process will work. See Chapter 5 for more information on in-home dust sampling conducted 

by Syracuse. 

Lead Dust Sampling and Analysis 

Once a resident is enrolled in the Syracuse project, a field sampling technician (accompanied by 

a CBO representative, as needed), visits the residence and explains the sampling procedure. 

Prior to sampling, the technician does an initial walk-through to locate the dustiest areas of 

floors, window sills, and window wells that are most accessible or exposed to children. He collects samples in the house using dust wipes. Then the dust wipe samples are analyzed by fieldportable XRF technology. In some cases confirmatory laboratory analyses are also performed, as 

discussed in Chapter 6. 

Lead Dust Mitigation (Cleaning) 

In houses where lead levels exceed minimum reference levels for lead hazards, the Syracuse Lead 

Dust Project provides each participating resident with training in proper cleaning techniques 

and free access to a HEPA vacuum. (See Section 1.5 of this handbook for Syracuse’s reference 

levels for lead hazards). The project provides HEPA vacuums at no cost to all participants who 

wish to use them. The Syracuse Lead Dust Project also provides ongoing training and education 

to the seven participating CBOs to promote the use of the HEPA vacuums. 

The resident signs a free seven-day lease agreement and takes responsibility for proper care and use 

of the vacuum. The HEPA vacuum coordinator trains the resident in a three-step cleaning process, 

and the actual mitigation is completed by the resident. In some cases, the field sampling technician returns to the home for post-mitigation sampling and also to collect the vacuum. The 

18 Chapter 3 
Syracuse Project offers free vacuum pick-up and delivery to residents, making the use of the vacuum convenient and attractive to program participants. See Chapter 7 for more information on 

mitigation and the cleaning process. 

A Word About Lead Dust Cleaning Costs 

As shown below, Syracuse calculated the average unit costs for the various steps involved in lead 

dust sampling and cleaning activities. Once the city had purchased its own XRF equipment and 

had a licensed risk assessor on staff, it discontinued using a consultant to perform many of these tasks. 

Using in-house staff and equipment, Syracuse’s average costs were $181 per home, less than half the cost 

of using a consultant ($375). The single most expensive cost was for laboratory analysis: $54 for precleaning sampling analysis ($9 per sample; 5–6 samples per household) and $27 for post-cleaning analysis ($9 per sample; 2–3 samples per household). 

Syracuse’s Lead Dust Cleaning—Average Unit Costs 

Step Time Cost 

Initial Sample 30 minutes $5.25 

Analyze initial samples via XRF; 1.5 hours $15.75 

submit confirmations to lab 

Generated initial results report 15 minutes $2.60 

Home visit to drop off vacuum; 30 minutes $5.25 

educate occupants on three-step cleaning 

Post-sampling; pick up vacuum 30 minutes $5.25 

Analyze post-cleaning samples via XRF; 1.5 hours $15.75 

submit confirmations to lab 

Laboratory analysis Pre-samples (5–6 samples) $54.00 

Post-samples (2–3 samples) $27.00 

Vacuum bag replacement $15.00 

Vacuum filter replacements $35.00 

*Average cost per home (in-house, City of Syracuse) $181.00 

*Total cost per home (contractor at $50 per hour) $375.00 

*This cost does not include administrative overhead. Syracuse used a consultant and Niton instrument 

until the City was able to purchase its own Niton and train its own risk assessor. 

*Total costs ranged from $181.00 to $375.00 per home 

cont. on next page 

Lead Dust Project Overview 19

A Word About Lead Dust Cleaning Costs, cont. 

Overhead Cost: 

Program Manager: Reviews all aspects of 

program, reports, and development of the QAPP 10% yearly cost $6,032.00 

Purchase of 30 HEPA Vacuums @ $272.00 each $8,160.00 

(One-time purchase) 

Training of staff (risk assessor, $470.00 

EPA Region 2 certification) 

Purchase of XRF machine (one-time purchase) $24,880.00 

Replacement of the radiation source of Niton $7,300.00 

Radiation licensing (New York State) $1,695.00 

Safe for Niton $200.00 

Computer equipment/XRF and office supplies $2,500.00 

Dosimetry badges ($64.00 per quarter) $256.00 

TOTAL $51,473.00 

Reporting 

Each participating resident receives a report stating whether a sampled area was above or below 

the reference levels for lead dust hazard. (See the sample pre-mitigation letter and report at the 

end of Chapter 8). Originally, the Syracuse project team intended to have these report templates 

translated into Spanish and Vietnamese but this was determined to be impractical due to the 

need to communicate site-specific information. Instead, the report is immediately mailed to the 

resident. For those households requiring mitigation, the report is also presented and explained 

by the data analyst/certified risk assessor at the time of the home visit, when the HEPA vacuum 

is delivered and the cleaning process is explained. When necessary, the risk assessor is accompanied by a native speaker who interprets the information for the resident. 

In addition to the report, each resident receives printed information on appropriate use of HEPA 

vacuums, the three-step cleaning process, and a list of suggested cleaning agents. In approximately ten percent of the homes tested, the field sampling technician collects additional samples after 

the resident cleans the home with a HEPA vacuum. These samples are used to present a postmitigation report that compares dust levels after mitigation to the reference levels. To reach a 

larger segment of the public, Syracuse’s Web site at <http:\\www.syracuse-empact.com> posts maps 

and data showing lead levels in the community, while keeping property-specific lead levels confidential. See Chapter 8 for more information on reporting. 

Evaluation 

The Syracuse Lead Dust project ensures program effectiveness in several ways. It solicits a direct 

response from the residents who participated in the cleaning and HEPA vacuuming program. 

20 Chapter 3
The Syracuse lead dust technician asks residents a series of questions, including their thoughts 

on the effectiveness of the program and about using the HEPA vacuum. Another way the 

Syracuse team measures program success is by tracking the number of lead dust walk-throughs 

conducted, and the number of residents that use the HEPA vacuums through the loaner program. In addition, the Syracuse team conducts post-mitigation sampling (see section 5.1) and 

encourages residents to continue lead dust mitigation activities such as using a HEPA vacuum 

(see section 7.1). See Chapter 9 for more information on program evaluation. 

3.3 Selecting Project Partners 

Syracuse has successfully involved people with diverse and specialized skills in its lead dust project. These include people with skills in program management, risk assessment, and communications. Syracuse has effectively partnered with several organizations, including EPA, an analytical 

laboratory, the Onondaga County Health Department, and the seven CBOs. Lead Safe, LLC, a 

contractor, handles coordination and implementation of sampling efforts, and coordinates with 

the contracted laboratory. 

Testing Laboratory 

Syracuse established the following requirements for laboratory 

testing services: 

•	 The selected laboratory must be certified by EPA’s National 

Lead Laboratory Accreditation Program (NLLAP). 

•	 The selected laboratory firm will provide the City of 

Syracuse Lead Dust Project with a copy of its accreditation 

from the American Industrial Hygiene Association (AIHA). 

•	 The laboratory must show proficiency during the past five 

consecutive years in the Environmental Lead Proficiency 

Testing (ELPAT) Program which is administered by the 

AIHA for paint chips, dust wipes, and soils. 

• Laboratories must be New York State Department of Health ELPAT-approved. 

•	 The selected firm is required to comply with the City of Syracuse’s equal employment 

opportunity requirements. A copy of these requirements can be obtained from the Office of 

Economic Development upon request. 

Community-Based Organizations (CBOs) 

Like most urban areas in the United States, the City of Syracuse has experienced a dramatic 

influx of immigrants from Latin America, Asia, and Eastern Europe. These ethnic populations 

have been hard to reach with information about lead exposure, because of language barriers and 

unfamiliarity with the issue. Preoccupied with pressing issues of daily survival, new immigrants 

often fear government agencies or programs. Establishing a link to these people through community organizations that have bilingual members is key to reaching this population. 

The CBOs involved in the Syracuse Lead Dust Project offer a diverse array of services to help 

immigrants, including teaching English as a second language, child care, and job placement 

Samples from potentially lead 

dust-contaminated houses 

should be sent to a testing laboratory 

recognized by EPA’s National Lead 

Laboratory Accreditation Program 

(NLLAP). Labs accredited by the 

NLLAP are proficient in testing for 

lead in air, paint, soil, or dust (see 

Selecting a Laboratory for Lead Analysis: 

The EPA National Lead Laboratory 

Accreditation Program, EPA 747-F-99-

002, April 1999). 

Lead Dust Project Overview 21 
services. Through its existing HUD program, the lead hazard control program already had 

working relationships with some of the CBOs. Thus, when Syracuse launched its lead dust 

program, it involved those CBOs that provided geographic coverage, as well as those that 

already were reaching mothers and families with small children through their other program 

activities. In addition, Syracuse actively advertised the project and recruited additional CBOs 

to participate. 

CBOs Provide Community Access 

As previously mentioned, one of the primary ways that Syracuse’s staff gain trust and access to 

potential program participants is through their involvement in CBOs that typically serve people 

in a two- to three-mile radius around the center. The following CBOs participate in lead dust 

education and outreach activities in Syracuse: 

•	 Boys & Girls Clubs of Syracuse—A youth development agency whose goal is to inspire 

and enable all young people in the Syracuse area, especially those from disadvantaged circumstances, to realize their potential as productive citizens. <www.bgcsyracuse.org> 

•	 Brighton Family Center—A neighborhood center that provides a variety of services in a 

predominantly African-American neighborhood. Services provided include a Young Mothers 

Program for teens who are pregnant or parenting, preschool and after-school programs, and 

teen programs. 

•	 Girls, Inc. of Central New York—Provides opportunities for girls to meet the challenges of 

the future by developing their potential through creative programs for girls and their families. <www.girlsinc.com> 

•	 Syracuse Northeast Community Center—Helps ensure the physical and emotional well 

being of children, families, seniors, and other individuals in the north/northeast section of 

Syracuse. <http://community.syracuse.com/cc/northeastcommunitycenter> 

•	 Southeast Asian Center—Serves the Southeast Asian population in Syracuse, which 

includes more than 3,400 Hmong, Laotian, Vietnamese, Chinese, Korean, and Cambodian 

people. The center provides various supportive community-building activities, programs, and 

services to assist Southeast Asian immigrants in assimilating into the central New York community. <www.irccny.org/programs/seac.shtml> 

•	 Southwest Community Center—Works with individuals, families, and communities to 

promote health and well being through prevention, intervention, and education. 

•	 Westcott Community Center—Provides a safe, accessible community space for activities 

and programs that meet community needs; strengthens and unites the community by bringing together its diverse elements; raises awareness through public education and art; and promotes the full inclusion of all persons. <www.westcottcc.org> 

The CBOs play a primary role in program outreach, and Syracuse’s Lead Dust Project has 

developed strong and cordial working relationships with them. Through the trust and positive 

reputation engendered by these organizations, the city’s lead program has been able to reach a 

segment of the population it had difficulty reaching before. The CBOs have helped translate 

information into Spanish and Vietnamese. The program also intends to produce Bosnian translations to provide that growing population with information about lead safety. 

22 Chapter 3 
Communicating with a Non-English Speaking Audience 

Partnering with agencies and community based organizations (CBOs) that cater to a large nonEnglish speaking audience often presents special challenges, but working with these CBOs provides a vital link to the non-English-speaking community in Syracuse. 

First and foremost, their clientele is often frightened. Arriving from third-world countries and war-torn 

nations, these people are easily intimidated by any type of government intervention. Populations of 

Vietnamese, Bosnians, and Hispanics are more concerned about getting jobs, locating housing, and appropriate schooling for their children. Childhood lead poisoning is not a priority issue as these people are just 

struggling to survive every day in a new and foreign land. Fear of government is another obstacle when 

dealing with immigrants. Syracuse partners with organizations that represent these non-English speaking 

groups since they have already gained the trust of community residents. This makes the job easier—without the CBOs it would be nearly impossible to reach these special groups. CBO representatives serve as 

interpreters during face-to-face meetings with prospective program participants (tenants) to ensure effective 

communications. This involves more time and scheduling to arrange meetings and home visits. 

Many residents near the Southeast Asia Community Center speak Vietnamese, Chinese, and


Korean, so the project conducts outreach and education in those languages. 


Project staff have worked to gain trust, knowing the sensitivities involved in interacting with


residents in their homes. Syracuse staff knew that homeowners or tenants might be reluctant to


participate because cleanliness and housekeeping are generally considered to be private issues.


New immigrants with few alternative housing options might be reluctant to apply, for fear they


could get in trouble with the landlord. By ensuring confidentiality, Syracuse successfully avoid­


ed these pitfalls.


Because the CBOs are located in neighborhoods with high lead levels, they are the logical and


convenient locations from which to operate a HEPA vacuum-loaner program. Each participat­


ing CBO is given wide latitude in the way it recruits residents to participate in the lead dust


monitoring project. The CBOs are encouraged to design creative, effective outreach tactics.


Several CBOs have initiated competitions to increase recruitment. For example, the Boys and


Girls Clubs (of which there are three in the city), rewarded the club with the most lead dust


project applications with a pizza party.


Maintaining the strong personal relationships is also vital to the program’s success. Project staff


visit each CBO at least once a week to touch base about community issues and to restock the


lead information on display there. Syracuse’s outreach


coordinator is invited by the CBOs to many different


community events, including holiday parties, picnics,


and meetings. Often, the Syracuse staff gives the CBOs


crayons, coloring books, pencils, and small bars of soap


to hand out to children. Much of the handout material


is donated by local businesses. The crayons are printed


with an important safety message—they are labeled as


being lead free according to ASTM D-4236. The bars of


soap are a perfect way to remind children of the impor­


tance of hand-washing.


The HELP Lead Safe program in 

Providence, Rhode Island, also has found it 

tremendously important to involve bilingual 

members of the community in program outreach, especially those with lead-sick children 

themselves. Providence also has a Spanish-speaking staff member to build trust with the large 

Latino population targeted by the program. 

Lead Dust Project Overview 23 
Partnerships That Work 

The city of Minneapolis partnered with neighborhood hardware store owners to implement the 

HEPA vacuum loaner program. The city has educated 

and trained hardware store personnel and has established 

Neighborhood Lead Centers in several locations. 

Minneapolis successfully recruits these business owners 

by showing them how they can benefit and how their 

knowledge about lead dust can serve as a marketing tool. 

The program also educates day care providers, who then 

educate the parents. Minneapolis also has enlisted the 

involvement of public health nurses who educate the 

children in day care settings about the importance of 

washing their hands and taking off their shoes. 

Once a month, Syracuse brings all seven 

CBOs together to discuss successes and challenges in signing up community members for 

the HEPA vacuum program. The group discusses performance goals and measures they 

have taken to meet these goals. While attendance at monthly EMPACT meetings is 

good, high CBO staff turnover requires both 

continual and often repeated training. 

The CBOs also recruit bilingual community 

members, who become ambassadors for the 

lead dust effort and help enlist program participants. Chapter 4 has examples of tools the 

Syracuse Lead Dust Project and the CBOs 

have used in conducting outreach. 

Syracuse conducted a CBO survey in the 

Spring of 2002 to assess program effectiveness 

and to determine ways to increase program participation. A copy of the survey questionnaire is 

included in Chapter 9. The survey findings indicate that: 

•	 Tenants can be reluctant to participate in the HEPA vacuum program for a variety of reasons, including not wanting strangers to come in their house, fear of upsetting their landlord, or thinking the program does not pertain to them. 

•	 Tenants often are embarrassed because they feel they are being judged on their housekeeping 

or cleanliness. 

•	 CBOs need more tools like flyers, newsletters, and Web sites to educate the tenants in their 

community. 

Based on the survey findings, Syracuse asked the CBOs to write implementation plans to guide 

their outreach activities and to bolster recruitment. As of July 2002, six of the seven plans had 

been submitted. Syracuse reviews and approves the plans, which then serve as blueprints for 

program implementation. The plan for the Westcott Community Center is shown on page 25 

as an example. 

24 Chapter 3 
Westcott Community Center 

EMPACT Outreach Action Plan 

Activities within the After School Program in the month of June: 

• Poster contest with the After School Program during the month of June as well as viewing the Sesame 

Street video to prepare the kids with information. (Target yield is to have 7-10 kids involved). 

• Dinner with the kids and their parents. We would like to have a showing of a presentation of the 

HEPA VAC. Also at this time, the winner of the poster contest will be honored. (Target yield is 4-6 

families that would get involved in and go through the HEPA program). 

• We plan to follow-up with a letter to the parents and ask them again if they would like to go 

through the process. 

Membership Involvement 

• We plan to target a key group of members through a letter campaign and get them to go through 

the HEPA VAC program. 

Board Involvement 

• During a board meeting, we will request that all board members sign up to go through the HEPA 

VAC process. Target yield is 11 of 15 members. This would include a letter campaign. 

• We would like to have Mike Goss and Adam present on this board. 

Employee Involvement 

• We will request that all employees and stakeholders living within city limits go through the HEPA 

VAC Program. Target yield is 5. (Susan and Gloria) 

Volunteer Involvement during the Fall of 2002 and Spring of 2003 

• Encourage all student volunteers (college, university, high school) to go through HEPA VAC 

Program. We hope to have at least 25 percent of volunteers get involved. 

Local Organization Involvement 

• Attempt to partner with local schools to write articles regarding the HEPA VAC Program. 

• Credit Union: Home Ownership Program. 

• Partner with the Westcott Community Development Corporation in relation to joint marketing 

schemes. He periodically performs outreach to the neighborhood through door hangers. 

Program Involvement 

• We plan to target a small group of key program users and renters to encourage them to go through 

the HEPA VAC Program. (Target yield is 5-6 families). 

• We have put in a grant proposal to become a site for the Parent Success Initiative. Should we 

receive it, we would encourage residents to go through the HEPA VAC Program. 

Direct Outreach 

• Newsletter. 

• Vista Volunteer. 

• Letters to members and program users. 

What we need to assist us in the process: 

• We are hoping to receive a one-page document that can be given to potential HEPA VAC renters 

that would clearly define and explain the process and what they can expect, should they go through 

the process. 

• Be available for the booking of speakers and presentations. 

Lead Dust Project Overview 25 
4 COMMUNICATING 

ABOUT LEAD DUST 

This chapter describes how Syracuse educated residents about the problem of lead dust 

in homes and the benefits of their participation in the project. Information in this 

chapter is designed primarily for managers who are implementing lead dust monitoring 

and outreach programs and for outreach workers who are responsible for communicating about 

lead in the home. 

•	 Section 4.1 describes the outreach methods and materials used by Syracuse to inform and 

involve affected households and community members. 

•	 Section 4.2 discusses the types of skills needed by Syracuse’s outreach workers, dealing with 

language and cultural barriers, interviewing potential program participants, and promoting 

and advertising the lead dust program. 

•	 Section 4.3 provides examples of some of the most effective outreach and educational materials used by Syracuse. 

4.1 Syracuse’s Outreach Methods and Materials 

Syracuse’s strategy for reaching parents and care givers of at-risk children was to utilize the 

CBOs. Through them, the lead dust project tapped into community events. Communities with 

mature lead awareness and abatement programs will probably just need to add specific lead dust 

information to existing lead outreach materials and activities. A municipality without a HUD 

or other lead program in place will need to develop a more comprehensive lead dust outreach 

plan. The following are some of the creative lead dust education and outreach tools developed 

by the city of Syracuse. Several examples are provided at the end of this chapter: 

•	 Milk cartons. Syracuse’s outreach coordinator contacted a local dairy and requested that the 

lead program’s message be printed on the back of its milk cartons. The dairy worked the 

“Got Lead?” message into its rotation of milk carton panels. More than 100,000 households 

in central New York learned about lead dust through this outreach method. 

•	 Ce-LEAD-brity. Syracuse wrote personal letters to more than 100 local and national celebrities asking them to help fight childhood lead poisoning by sending an 8” by 10” autographed 

photo with a personal message, such as “Be a lead fighter,” or “Keep your neighborhood lead 

safe.” The city collected more than 40 autographed photos from TV and radio personalities 

and celebrities, including Whoopi Goldberg, Jim Carrey, Big Bird, Mr. Rogers, the Sesame 

Street gang, Fats Domino, John Travolta, and numerous athletes. Syracuse’s display has been 

exhibited widely in the community, as well as at two national lead safety shows. 

•	 Slide show. The City of Syracuse has created several slide shows for various conferences and 

exhibitions. “Soup to Nuts”, in particular, is a step-by-step sequence of the city’s lead dust 

program. The slide show—a useful tool for communicating to homeowners, landlords, and 

other prospective clients—gives prospective applicants an idea of the various steps required 

to go through the program. 

•	 Free soap. Because the project emphasizes that children keep their hands clean, Syracuse 

puts bars of soap in “goodie bags” handed out to children. The program contacted local 

26 Chapter 4 
hotels and restaurants and persuaded them to donate thousands of small bars of soap. These 

businesses benefit from the positive community relations engendered by their donation, and 

the children receive a real tool that helps reduce their lead exposure. 

•	 Holiday-related outreach. Syracuse developed a “Hol-lead-day Coloring Book” and distributes it to children during the winter holiday season. It also developed another coloring book 

with a St. Patrick’s Day theme. The books included holiday-themed pictures for children to 

color, along with safety messages to help reduce lead exposure. The city also held a pumpkin-painting contest at Halloween to promote National Lead Poisoning Awareness Week and 

distributed information on getting children tested for lead poisoning with Thanksgiving 

food baskets. 

The following table summarizes the various outreach materials, languages, and distribution 

channels used by three lead dust programs to provide a sense of the types of materials that can 

be used to recruit program participants: 

Examples of Communications Materials and Media 

Used To Reach Residents by Several Lead Dust Programs 

Program/City Communications Format/Material Languages Media/Distribution Channels

Syracuse, NY • Coloring/activity books for children English • CBOs 

• Milk cartons Spanish • Directly to residents and 

• Celebrity photos Vietnamese kids 

• “Look Out for Lead” flyer Hmong • Local food markets 

• Parents’ Reference Guide Chinese • Personal contact 

• Video PSA Korean • Web site 

• Publications and pamphlets Laotian • Cable television 

Cambodian • Holiday gift baskets 

Bosnian • Luncheons 

Braille • Special events at the 

convention center 

Providence, RI • Pamphlets English • HELP Lead Safe program 

• Videos Spanish 

Cambodian 

Nigerian 

Liberian 

Minneapolis/St. Pamphlets English • Cable TV 

Paul, MN • Video Somali • Radio 

• Radio announcements Spanish • Transit ads (bus shelters)

• In-store posters, signs, Hmong • Visiting Nursing Association 

counter displays • Public health clinics 

• Libraries 

• Neighborhood retailers 

• Day care providers 

• 

Communica ting about Lead Dust 27 
Minneapolis/St. Paul Plugs into 

Local Media Outlets 

The Minneapolis/St. Paul area has the largest 

Somali immigrant population in the United 

States. Many of these residents are fearful of government and are largely illiterate. In addition to reaching 

them through CBOs and with translated material distributed in public health clinics, the program is also 

using local Somali-language cable TV and radio stations. Minneapolis also is using donated advertising 

space to place informational posters in bus stop shelters within targeted neighborhoods. Minneapolis 

finds that free “remnant” (unsold) transit advertising 

space is often available in low-income neighborhoods. 

• Video Public Service Announcement. 

Syracuse produced a video public service 

announcement (PSA) for the local cable television station. The mayor’s public relations coordinator, who had been a local television news 

anchor, was instrumental in getting the PSA produced and aired. The PSA text is included at the 

end of this chapter. 

4.2	 Approaching and 

Recruiting Program 

Participants 

In Syracuse, one of the biggest challenges has 

been overcoming residents’ discomfort with 

strangers coming into their homes. Some people 

might worry that if inspectors identify a lead 

hazard, the government might make them move 

or might call social services to report lead poisoning in the children. In addition to the frustrations of trying to communicate with limited English language skills, residents might also feel 

anxious about the possibility that their child might be lead-poisoned. Syracuse overcame these 

challenges by hiring non-threatening, sensitive, appropriately dressed staff with strong “people 

skills” to conduct home visits and to teach affected households the proper cleaning methods. 

According to Syracuse’s outreach coordinator, “Many people don’t want someone telling them 

how to clean their homes. It’s like trying to teach an adult how to brush their teeth—they don’t 

want to learn because they’ve been doing it for years.” As an example, a woman in Syracuse who 

was remodeling her home had exposed her child to lead poisoning. She very much feared that if 

she enrolled in the program, something would happen to her child or to her home. She was 

finally persuaded to participate and was so pleased after using the HEPA vacuum and seeing the 

post-intervention results that she purchased her own HEPA vacuum to keep treating her house. 

A warm, friendly disposition goes a long way toward gaining trust. “Be assertive but still friendly, and emphasize that the program promotes children’s health,” representatives from Syracuse 

advise. Thanks to their success in relationship building, Syracuse’s Lead Dust Project staff can 

Minneapolis’ Lead Inspectors Need “People Skills” 

The city of Minneapolis recognizes the important interactive role lead inspectors play. Not only are 

they technical experts and program enforcers, but they also are program ambassadors. Because interpersonal skills are so vital, the city is adding such requirements to its job description for lead inspectors. 

In fact, “people skills” are necessary not only to recruit program participants, but also to interact with 

property owners, who must ultimately remediate the lead contamination in their buildings. The draft job 

description includes the following language: 

Human relations communication and group facilitation skills are of primary importance because of the interaction with large numbers of people and organizations from diverse backgrounds. Excellent oral and written 

communications skills are, therefore, essential, as is the ability to mediate and resolve disputes. 

28 Chapter 4 
walk into any of the CBOs and be greeted 

with a smile and a hug. 

Other Lessons Learned 

Syracuse learned the importance of timing in 

program implementation. Project staff learned 

the hard way to wait until all elements were 

finalized and approved before making public 

announcements. Early outreach efforts drew 

participants who were ready to begin treating 

their homes, but EPA could not allow 

Syracuse to collect dust wipe samples until the 

Quality Assurance Project Plan (QAPP) was 

finalized and approved. Therefore, Syracuse 

staff had to delay the start of the implementa- Syracuse project staff meet with CBO representatives 

tion phase until all program components were


in place, but they felt the wait was worthwhile because of the valuable framework provided by


the QAPP.


Another pitfall of successful outreach occurred when a large number of people wanted to bor­


row the HEPA vacuums without formally joining the program. The solution to this dilemma


was to lend the vacuums to anyone interested but to give first priority to those who had signed


up for the full program.


4.3 Resources for Additional Information 

EPA and the City of Syracuse have developed a variety of resources to help community members learn more about lead dust issues. Several examples of Syracuse’s lead dust materials are 

included at the end of this chapter. Residents can also order the following publications to teach 

them more about safely managing lead dust in their homes: 

A series of pamphlets: City of Syracuse Lead Program for Homeowners and Investor-Owners; 

City of Syracuse Lead Dust Outreach, Monitoring and Education Program (in English and 

Vietnamese), City of Syracuse Department of Community Development. Order by calling 315 

448-8710. 

Lead in Your Home: A Parent’s Reference Guide (in English and Vietnamese), U.S. EPA Office 

of Prevention, Pesticides, and Toxic Substances, EPA 747-B-99-003, May 1999. 

Identifying Lead Hazards in Residential Properties (EPA Fact Sheet), U.S. EPA Office of 

Prevention, Pesticides, and Toxic Substances, EPA 747-F-01-002, April 2001. 

Risk Communication in Action: Environmental Case Studies, U.S. EPA, EPA 625-R-02-011, 

September 2002. 

Testing Your Home for Lead in Paint, Dust, and Soil, U.S. EPA, Office of Pollution Prevention 

and Toxics, EPA 747-K-00-001, July 2000. 

Fight Lead Poisoning with a Healthy Diet, U.S. EPA, Office of Pollution Prevention and 

Toxics, EPA 747-F-01-004, November 2001. 

Communica ting about Lead Dust 29 
Protect Your Family from Lead in Your Home (in English and Spanish) U.S. EPA, U.S. 

Consumer Product Safety Commission, and U.S. Department of Housing and Urban 

Development, EPA 747-K-99-001, September 2001. 

Reducing Lead Hazards When Remodeling Your Home (in English and Spanish) U.S. EPA, 

Office of Pollution Prevention and Toxics, EPA 747-K-97-001, September 1997. 

For more resources, visit EPA’s Office of Pollution Prevention and Toxics (OPPT) Lead Web 

Page at <www.epa.gov/lead/> or call 1-800-LEAD FYI to order EPA publications. 

30 Chapter 4 
Communica ting about Lead Dust Community Partners: Brighton Family Ctr. 424-9378 Girls Inc. of CNY 474-0746 Boys & Girls Clubs of Syracuse 472-6714 Southeast Asian Center 422-1593 Syracuse Northeast Com. Ctr. 472-6343 Southwest Community Ctr. 474-6823 Westcott Community 

478-8634 

Working Together to Create Low 

Cost Solutions 

Ctr. 

Dep

Community 

CITY OF 

Lea

Ou

Monito

Educatio

Matthew J. D

Tel: 

Department of 

Community Development 

Betsy Mokrzycki


Lead Hazard Control Program


201 E. Washington St.


Syracuse, N.Y. 13202


Phone: 448 - 8710


Fax: 448 - 8659


http://www.syracuse-empact.com


EQUAL HOUSING 

OPPORTUNITY 

31
 © 2001 Lead Safe, LLC All Rights Reserved. (315)685-0864 
32
 Chapter 4
 W hat is EMPACT? In 1996 a Presidential initiative charged EPA and its partners with developing a program to improve the measurement, access, understanding and dis­ semination of key environmental information in the US metropolitan areas. What are EMPACT’s goals? 

·� Incorporate improved and upda ted 

tec h nologies for time -relevant enviro nmental measurement and monitoring. 

·� Facilitate public access to comprehe nsive, easily understood environmental 

information. 

·� Provide effective tools for communica ting, interpreting, and applying enviro nmental data and information. ·� Establish partnerships within metro a reas to ensure the information is useful 

and timely for families and communities 

·� Develop a management and data 

fram ework within which communities can work, but which also provide the 

ability to aggregate information on a � local, regional, and n ational scale. 

H ow Does the City of Syracuse fit in? Funded by a grant from USEPA, the City of Syracuse has developed a program designed to measure the lead dust content in homes. Aided by community based organization partners, the City will make available HEPA Vacuums 

that can be borrowed as needed to control leaded dust. Also, the program will provide current data and information on a web site. 

How much of a hazard is lead dust? More children are poisoned by exposure to lead dust from lead-based paint in older homes than by any other source, usually through normal hand-to-mouth activity after getting lead dust on their hands and toys! What is a HEPA Vacuum? A H igh E fficiency P articulate A ir vacuum is a vacuum that is equipped with a filter 

that is capable of trapping 99.97% of the dust that it collects. 

Why can’t I just use my household vacuum? The lead dust is so fine that your regular vacuum cannot contain the dust. It simply flows through the bag only 

to be spread around your home. 

A HEPA vacuum looks just like my shop vacuum, can’t I just use that? No! Shop vacuums are not equipped with HEPA filtering equipment and therefore 

cannot trap the tiny lead particles. 

http://www.syracuse-empact.com 

1 Alliance to End Childhood Lead Poisoning 

How do they measure leprogram will collect sayour home to determists. These samples wportable XRF. What is an XRF? Athat is capable of detein a dust wipe sample. 

technology, some of thlab for confirmatory a

How do I part icipate call the City or the payour area and request uum program. Its easy protect your family fro

CALL T

44

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Communica ting about Lead Dust 33 
34 Chapter 4 
Communica ting about Lead Dust 35 
36 Chapter 4 
5 Collecting and Managing 

Data on Lead Dust 

This chapter describes the steps taken by Syracuse to collect and manage samples on lead 

dust in homes. With a target of 350 homes, Syracuse collects dust wipe samples in a 

way that ensures the quality of the data and that also helps participants understand the 

procedure and findings. 

•	 Section 5.1 outlines the chronology of interactions with participants, including sampling, 

mitigation, and reporting. 

• Section 5.2 discusses step-by-step in-home lead dust sampling. 

• Section 5.3 describes the role of the Quality Assurance Project Plan (QAPP). 

• Section 5.4 offers resources for additional information. 

Syracuse has integrated X-ray fluorescence (XRF) technology into its lead dust program. An 

XRF is a small portable device capable of reading lead dust wipes and determining lead levels in 

seconds. This technology provides significant time savings when compared to sending dust 

wipes away for traditional laboratory analysis. Although XRF technology is not yet an EPAapproved method for analyzing lead dust, it has been demonstrated to provide reliable and representative results when compared with laboratory data. 

Syracuse’s QAPP specifies the procedures for using XRF analysis of lead dust samples. It also outlines the steps necessary to statistically correlate XRF results with laboratory results. Read more 

about how Syracuse established a statistical correlation between XRF and laboratory results in 

Chapter 6. See Section 5.3 below and Appendix B for more information about the QAPP. 

5.1 Chronology: from Data Collection to Reporting 

After a resident signs up for the program, Syracuse staff visits the home and collects lead dust 

data. The protocol used by Syracuse staff to interact with participants is as follows: 

Step 1. Call participant to set up appointment to collect pre-mitigation dust samples. 

Step 2. Gather pre-mitigation samples from the designated sampling locations; leave residence. 

Step 3. Read samples with XRF (see Chapter 6). 

Step 4. If necessary, send pre-mitigation samples to accredited laboratory for confirmatory 

analysis. 

Step 5. Call participant to report results and mail written report. 

Step 6. If necessary, set up appointment to review sample results, drop off HEPA vacuum, and 

explain three-step cleaning procedure. (See Chapter 7 on Mitigation). 

Step 7. Arrange for HEPA vacuum pickup and post-mitigation sampling, if necessary. 

Step 8. Read post-mitigation samples with XRF. 

Collecting and Managing Da t a on Lead Dust 37 
Step 9. If necessary, send post-mitigation samples to accredited laboratory for confirmatory 

analysis. 

Step 10. Mail or deliver final report to participant and landlord. (See Chapter 8 for Reporting.) 

A Syracuse Lead Dust Project staff member interacts with residents during sampling and mitigation. This person is a certified inspector/risk assessor who collects the samples following the 

protocol in the QAPP and ensures that the samples are labeled and recorded correctly before 

sending them off for confirmatory analysis. He also sets up appointments and explains the benefits of the program and the cleaning process to participants. He makes the experience pleasant 

and positive for the resident and assures them that the information is confidential and will not 

jeopardize their tenancy at the property. As soon as results are available they are mailed to the 

resident and project staff visit the home if the resident decides to participate in the HEPA loaner program. 

5.2 Visiting the Home (Step-by-step In-home Sampling) 

Syracuse usually allots about a half-hour for sampling a typical residence. Initially, sampling 

took about an hour, but Syracuse soon halved that time as staff became more familiar with the 

process and began using XRF to analyze samples offsite instead of at the residence. 

As previously discussed in Section 3.2, project staff first interviews the resident using the HEPA 

Vacuum Intake Questionnaire, a copy of which can be found at the end of this chapter. During 

the home visit, staff review the information with the resident and also visually examines the 

house, identifying the principal play areas and determining where children spend most of their 

time. By asking questions and observing current conditions in the house, high-risk or high-use 

areas are identified. 

Syracuse uses the same protocol for collecting samples, whether they are analyzed by traditional 

laboratory analysis, field portable XRF technology, or both. The field sampling technician collects dust wipe samples in accordance with the HUD Guidelines for the Evaluation and Control 

Syracuse Uses Certified Risk Assessors 

New York State is one of 13 states that choose to follow federal regulations for lead hazard control 

activities rather than establish their own state regulatory programs. Syracuse, therefore, requires 

that their field sampling technicians be EPA-certified inspectors/risk assessors. An EPA lead inspector 

conducts a surface-by-surface investigation to determine whether lead-based paint is present in the home, 

how much is present, and where it is located. He determines the existence, nature, severity, and location 

of lead-based paint hazards in a residential dwelling. The assessor performs visual inspections, tests household dust from floors and windows and other locations, and presents a report identifying the location of 

the types of lead-based paint hazards and ways to control them. 

The Syracuse Lead Dust Project initially contracted with an EPA-certified risk assessor but then trained 

one of its own staff to become certified, thereby realizing a substantial cost savings. 

Visit <www.epa.gov/lead/traincert.htm> for a map of the United States with links to state lead programs, 

or call 1-800-424-LEAD for information on the 13 EPA-run states (Alaska, Arizona, Florida, Idaho, 

Montana, North and South Dakota, Nevada, New Mexico, New York, South Carolina, Washington, and 

Wyoming). 

38 Chapter 5 
of Lead-Based Paint in Housing at <www.hud.gov/offices/lead/guidelines/hudguidelines/ 

index.cfm>, and HUD’s Lead Safe Housing Rule at <www.hud.gov/offices/lead/leadsaferule>. 

The results are then compared to the EPA regulations at TSCA Chapter 4, Section 403 lead hazard standards. Although each house is different and must be approached with its unique characteristics in mind, Syracuse’s testing typically focuses on three to four main areas: the principal 

play area, the kitchen, and the bedrooms of the youngest children (there might be more than one 

child’s bedroom to test). 

The most common method for collecting a dust sample is a surface wipe. Because XRF instruments are very sensitive, however, the sampling medium (dust wipe) should meet ASTM E 

1792-96a “Standard Specification for Wipe Sampling Materials for Lead in Surface Dust.” 

Syracuse purchased a Niton XRF, and initially, the sampling media provided by the contract 

laboratory did not meet the Niton specifications for XRF use. The Syracuse team found that 

the moisture content of the various wipes can affect the accuracy of the Niton XRF readings. 

They researched and experimented with several different sampling media before finding the one 

that met its needs. Syracuse found that Palintest and PACE wipes provided the most accurate 

results for use with the XRF. 

Although various testing formats are possible, 

Syracuse’s QAPP calls for the following 10 samples: 

1. Principal play area floor 

2. Principal play area interior window sill 

3. Kitchen floor 

4. Kitchen window sill 

5. Kitchen window and trough 

6. Youngest child’s room floor 

7. Youngest child’s room window sill 

8. Youngest child’s room window trough 

9. Floor of next youngest child’s room 

10. Sill of next youngest child’s room 

Two field blanks, labeled 11 and 12, are submitted to the laboratory with each set of samples. 

At 10 percent of the residences, Syracuse plans post-mitigation sampling (i.e., samples are taken 

after residents have completed the three-step cleaning/HEPA procedure). These samples, plus 

two additional field blanks, are labeled 13 through 24. 

Each sample bag is given a unique number (e.g., 012–07) that identifies the house (range: 001– 

350) and the sampling location within the house (01–10). As inspectors take samples, they 

record the lead level of each sampling location on a site worksheet. Any other relevant descriptive information, such as the general condition of the paint, high levels of dust, or unusual use 

of the area, is noted on the worksheet as well. Finally, the worksheet provides convenient spaces 

to write down any relevant descriptive information such as the condition of paint or excessive 

levels of dust. 

Guarding Against Lead Hazards 

When handling lead dust and samples, lead 

can enter the body through ingestion, 

which occurs as a result of routine hand-tomouth activities such as eating, drinking, and 

smoking. Inspectors needed to wear gloves and 

refrain from hand-to-mouth activities on the job. 

When work is complete, inspectors wash their 

hands upon leaving a site. 

Collecting and Managing Da t a on Lead Dust 39 
5.3 Quality Assurance Project Plan (QAPP) 

A Quality Assurance Project Plan (QAPP) documents the planning, implementation, and 

assessment procedures for a particular project, as well as any specific quality assurance and 

quality control activities. It integrates all the technical and quality aspects of the project in 

order to provide a “blue print” for obtaining the type and quality of environmental data and 

information needed for a specific decision or use. All work performed or funded by EPA that 

involves the acquisition of environmental data must have an approved QAPP. For more information, visit EPA’s Web site at <www.epa.gov/quality>. 

Development of the QAPP required Syracuse to address essential project details. How will the 

data be collected? How will the data be used? Will the data support the decision-making 

process? How will the data be stored and presented? This up-front planning allowed Syracuse to 

work through issues before actually encountering them and saved time during project implementation. 

Syracuse found that the exercise of developing a QAPP imposed an important discipline that 

guided the entire project. Syracuse took six months to develop the QAPP and continues to 

update it as the project matures. Although the initial push can be challenging, Syracuse staff 

believes that the process is worthwhile. A copy of the Syracuse QAPP appears in Appendix B. 

5.4 Resources for Additional Information 

Methods 6200, 6010B, and 7420 from EPA (entitled Test Methods for Evaluating Solid Waste, 

Physical/Chemical Methods). Ordering information or a copy of the text can be obtained 

online by accessing <www.epa.gov/epaoswer/hazwaste/test/sw846.htm>. 

ASTM D1792-96a, Standard Specification for Wipe Sampling Materials for Lead in Surface 

Dust, ASTM, 100 Barr Harbor Drive, West Conshohocken, PA 19428-2959. For individual 

reprints call 610-832-9585; visit www.astm.org; or send an e-mail to service@astm.org. 

40 Chapter 5 
Collecting and Managing Da t a on Lead Dust 41 
6Analyzing Lead Dust Samples 

Using XRF Technology 

This chapter describes the steps taken by the Syracuse Lead Dust Project to incorporate 

cutting-edge technology into its program. The field-portable X-ray fluorescence (XRF) 

instrument is a hand-held, battery-powered device that produces timely data on lead 

levels in household dust, soil, or paint. The XRF user must be trained and certified to meet federal, state, or local requirements for collection of environmental samples. 

• Section 6.1 describes the advantages of XRF technology used by the Syracuse Lead Dust Project. 

•	 Section 6.2 provides information on how Syracuse obtained the XRF equipment and associated licensing, operator training and certification, and laboratory verification of XRF analysis. 

• Section 6.3 discusses the importance of quality control. 

• Section 6.4 covers health and safety precautions for inspectors. 

• Section 6.5 highlights equipment maintenance. 

• Section 6.6 provides resources for more information. 

6.1 Advantages of XRF Technology 

Experience has shown that lead concentrations inside homes vary significantly. The XRF instrument can instantly detect unusually high lead levels and the field sampling technician can tell 

residents where children or other occupants of the household are most likely to be exposed to 

lead. While Syracuse made a substantial capital investment to purchase XRF technology, in the 

long term, the city is saving money with this equipment because it has dramatically reduced 

costs for laboratory analysis. 

To analyze a sample using the XRF, the technician places a folded wipe sample in the XRF sample holder and follows the manufacturer’s procedures to get results. A 30- to 60-second measurement should yield reliable results. An important benefit of XRF analysis is that the sample 

remains intact so that the same samples subsequently can be analyzed by a laboratory. 

Appropriate wipes that meet the requirements 

of ASTM E1792-96a, Standard Specification for 

Wipe Sampling Materials for Lead in Surface 

Dust, should be used. See Chapter 5 for more 

information on the types of wipes that Syracuse 

used for sampling, and for important lessons 

learned about the choice of sampling media. 

The resource section at the end of this chapter 

includes information for obtaining a copy of 

the ASTM standard specification. 

Although an XRF instrument has many advantages, its purchase and use requires careful consideration. Because XRFs contain radioactive 

materials, operators must have valid licenses or 

42 Chapter 6 
permits from the appropriate federal, state, and local regulatory bodies and must meet any 

applicable state or local notification requirements. 

6.2 Requirements and Qualifications 

Depending on the state, operators may be required to hold three forms of proof of competency: 

a manufacturer’s training certificate (or equivalent), a radiation safety license, and a state leadbased paint inspection certificate or license. 

Manufacturer’s Training 

In most states, operators must be trained by the manufacturer or receive equivalent training. 

Syracuse staff took a one-day free training course on the use of the XRF instrument offered by 

the manufacturer, Niton. The course met New York state requirements and covered radiation 

safety, XRF theory, worker exposure, as well as hands-on analysis of dust wipes and paint chips. 

Radiation Licensing and Safety Training 

The U.S. Nuclear Regulatory Commission (NRC) requires radiation safety training for licensing purposes. Radiation safety officer certification is necessary before NRC will grant a license 

to own, operate, transfer, or store an XRF unit. Since Syracuse did not already have a radiation 

safety officer involved, staff first had to undergo a rigorous training program required by the 

state of New York to handle radioactive equipment. Once personnel were trained, Syracuse was 

XRF Use Licenses and Certification 

In addition to training and any required accreditation, a person must have valid licenses or permits 

from the appropriate federal, state, and local regulatory bodies to operate XRF instruments. All 

portable XRF instrument operators should be trained by the instrument’s manufacturer (or equivalent). 

Depending on the state, operators may be required to hold three forms of proof of competency: a manufacturer’s training certificate (or equivalent), a radiation safety license, and a state lead-based paint inspection certificate or license. To help ensure competency and safety, EPA and HUD recommend hiring only 

operators who hold all three. 

The regulatory body responsible for oversight of the radioactive materials contained in portable XRF 

instruments depends on the type of material being handled. Some radioactive materials are federally regulated by the U.S. Nuclear Regulatory Commission (NRC); others are regulated at the state level. States 

are generally categorized as “agreement” and “non-agreement” states. An agreement state has an agreement with NRC to regulate radioactive materials that are generally used for medical or industrial applications. (Most radioactive materials found in XRF instruments are regulated by agreement states). For 

non-agreement states, NRC retains this regulatory responsibility directly. At a minimum, however, most 

state agencies require prior notification that a specific XRF instrument is to be used within the state. Fees 

and other details regarding the use of portable XRF instruments vary from state to state. Contractors 

who provide inspection services must hold current licenses or permits for handling XRF instruments, 

and must meet any applicable state or local laws or notification requirements. 

As an NRC-agreement state, New York regulates the handling of radioactive materials and the Syracuse 

Project is in compliance with all relevant state regulations. 

Anal yzing Lead Dust Samples Using XRF T echnology 43 
EPA Verifies Use of XRF for 

Measurement of Lead in Dust 

In the fall of 2002, EPA’s Environmental Technology 

Verification (ETV) program published a report verifying the use of five field-portable XRF technologies for 

the measurement of lead in dust. The Niton XL-300 

and XL-700 series XRF instruments were among the 

five brands tested. ETV evaluated overall performance 

of the Niton as “ . . . biased slightly high (but within 

the limits of acceptable bias), very precise, and in good 

linear agreement to an NLLAP-laboratory [National 

Lead Laboratory Accreditation Program] result.” 

The ETV program facilitates the deployment of innovative or improved environmental technologies 

through the performance of verification and dissemination of information. The goal of the ETV program 

is to further environmental protection by substantially 

accelerating the acceptance and use of improved and 

cost-effective technologies. For more information visit 

the ETV Web site at <www.epa.gov/etv>. 

able to apply for a New York state radiation license. A special safe had to be purchased to secure 

the XRF with its radioactive source. 

Costs for the Instrument 

In addition to investing in trained, licensed, and certified staff, those seeking to implement an 

extensive lead dust monitoring program may want to buy their own field-portable XRF. 

Syracuse purchased a Niton Model XL309, which costs about $21,000, making it the most substantial expense the project faced. This model costs less than other Niton instruments because it 

tests only for lead rather than a wide range of metals detectable with other models. The same 

model with soil analysis capability would cost an additional $3,000. Programs will face an additional expense to replace the instrument’s radioactive source once every two years, if not more 

frequently. The Niton source costs $7,300. 

Programs committed to a combination of dust, paint, or soil inspection for the long term will 

find that the investment will more than pay for itself. In addition to its EMPACT Lead Dust 

Project, the city of Syracuse also uses XRF technology for its HUD lead abatement program, 

plus a new soil analysis program, making the cost per sample less than it would be for laboratory analysis for each sample. Sending samples to a lab involves not only charges for the analysis 

itself, but also the expenses of shipping and handling. After Syracuse completed Phase I and 

started using only the XRF for most of the analysis, the cost savings became more apparent. 

6.3 Quality Control 

Quality control is an important component of 

the Syracuse Lead Dust Project. The QAPP (See 

Appendix B) ensures that staff follow consistent 

protocols, test methods, and data management 

procedures. Syracuse employs additional quality 

control measures, as described in the following 

section, that help meet its objectives of confirming the capabilities of XRF and training residents to reduce lead dust levels in homes. 

Data Evaluation and 

Confirmatory Analysis 

One objective of the Syracuse Lead Dust Project 

is to validate the accuracy of XRF readings for 

lead dust monitoring by comparing field XRF 

data to laboratory data. Because there is no 

EPA-approved method for lead dust analysis by 

XRF, Syracuse judged XRF results against the 

highest standards of accepted practice; namely, 

inductively coupled plasma/atomic emission 

44 Chapter 6 
(ICP/AE) and atomic absorption (AA) methods, both of which are conducted in a laboratory


and typically take two to four days to get results.4


During Phase I, Syracuse sent all samples from the first 15 homes to the laboratory for analysis


using these methods. In addition, Syracuse provided XRF data for these samples. The laborato­


ry performed a statistical comparison between samples analyzed by XRF and the same samples


analyzed by ICP/AE + AA, yielding a percent difference for each set of values. The EPA Region


2 laboratory reviewed these values and helped establish performance criteria to be used by the


field XRF operators. In conducting this evaluation, Syracuse took into account the fact that


XRF technology tends to have a bias to the low side of laboratory determined values. To protect


against false negative results due to instrument bias, Syracuse reviewed results from tests where


both XRF and laboratory methods were used. Results where the XRF reading taken was above


the laboratory result for the same sample were disqualified from the analysis as outliers. The


remaining data were separated by location type (i.e., floors, window sills or window wells); the


difference between the XRF and laboratory methods were taken for each set of samples; and a


standard deviation calculated for each location type. Results within one standard deviation


below the acceptable level are also considered positive results as a “worst case estimate”. To pro­


tect against false positive results, where the


worst case estimates are within 2 times the


limit of detection, samples are sent to the


laboratory to confirm results.


The project team used these findings during


Phase II to determine which new samples


would be sent for laboratory confirmation.


After establishing a statistical correlation,


Syracuse started sending only those XRF


samples falling within a specific range to the


laboratory for confirmation (See table adja­


cent as well as the post mitigation report


entitled “Settled Dust Sample Results”


included at the end of Chapter 8). Syracuse


expects that the laboratory will continue to


refine this statistical analysis as more data


become available. Current results, however,


show an acceptable correlation between XRF


and laboratory data.


Data Management 

In Syracuse, the XRF instrument is the main data management tool used by the field sampling 

technician. The XRF has pre-loaded software that can read and store up to 3,000 entries 

before data is downloaded to alternative storage. As explained in Chapter 5, each sample bag is 

given a unique number designating the sampling location within the house. Upon completion 

of sampling and analysis, Syracuse downloads the data from the XRF to the City of Syracuse 

computers. 

XRF Readings Requiring Laboratory 

Confirmation 

Sample Type XRF Reading Lab 

Confirmation? 

Floor >40 μg/ft2 (MDL) No 

Floor <40 μg/ft2 Yes 

Window Sill <100 μg/ft2 No 

Window Sill 100 μg/ft2 and 250 μg/ft2 Yes 

Window Sill >250 μg/ft2 No 

Window Well <180 μg/ft2 No 

Window Well 180 μg/ft2 and 400 μg/ft2 Yes 

Window Well >400 μg/ft2 No 

4	 It should be noted that the samplings conducted by the Syracuse project are not regulatory compliance 

tests and therefore do not require the use of an EPA-approved method. 

Anal yzing Lead Dust Samples Using XRF T echnology 45 
Calibration 

Niton XRFs are factory-calibrated, but regular checks are an essential aspect of quality control. 

Before Syracuse’s inspectors begin to test a property, they take readings on standard reference 

materials (SRMs) whose lead levels are known to be within the anticipated range for lead in 

household dust. A manufacturer’s standard is used for this calibration check. If any of these readings fail the quality control criteria, possible problems are investigated and the check is re-run 

until the instrument passes. If the instrument does not pass, it is sent back to Niton to be re-calibrated. These same field checks need to be completed before and after each property is tested to 

ensure that the calibration has remained intact throughout the testing period. 

Laboratory Selection 

Using an accredited laboratory is an important quality control step for Syracuse. The residential 

dust samples are analyzed by a laboratory on EPA’s National Lead Laboratory Accreditation 

Program (NLLAP) list for dust. Each state might have its own lead program and different regulations. For example, the New York State Department of Health requires all labs analyzing samples from the state to be certified under its Environmental Laboratory Approval Program. For 

more information, contact the National Lead Information Center (NLIC) at 1-800-424-LEAD, 

visit <www.epa.gov/lead>, and your state and local health agencies. 

Proficiency Through ELPAT 

The Syracuse Lead Dust Project recommends that programs using XRF participate in the 

Environmental Lead Proficiency Analytical Testing (ELPAT) program. ELPAT is run by the 

American Industrial Hygiene Association and is designed to help a laboratory assess and/or 

improve its analytical performance, by providing it with test samples on a quarterly basis and 

evaluating the results. Participation in the ELPAT program is open to all laboratories, but it is 

mandatory for laboratories seeking accreditation by one of the organizations recognized under 

EPA’s NLLAP program. 

XRF Usage and Radiation Exposure 

An XRF operator must wear a dosimetry badge, which monitors exposure to radiation. Even though 

no radiation dosimetry is required for some isotopes, users should wear a dosimetry badge for the 

following reasons: 

• XRF instrument operators have a right to know the level of radiation to which they are exposed during the performance of the job. In virtually all cases, the exposure will be far below applicable exposure limits. 

• The cost of dosimetry is low. 

• Long-term collection of radiation exposure information can aid both the operator (employee) and the 

employer. The employee gains peace of mind and the employer benefits by having an exposure record 

that can be used in deciding possible health claims. 

• The public benefits by having exposure records available to them. 

• The need for equipment repair can be quickly identified. 

46 Chapter 6 
Safe Operating Distance 

XRF instruments used in accordance with manufacturer’s instructions will not cause significant exposure to ionizing radiation. But the instrument’s shutter should never be pointed at anyone, even if the 

shutter is closed. Also, the operator’s hand should not be placed on the end plate during a measurement. 

The safe operating distance between an XRF instrument and an individual depends on the radiation 

source type, radiation intensity, quantity of radioactive material, and the density of the materials being 

surveyed. As the radiation source quantity and intensity increases, the required safe distance also increases. Placing materials, such as a wall, in the direct line of fire reduces the required safe distance. 

According to NRC rules, a radiation dose to an individual in any unrestricted area must not exceed 2 

millirems per hour. One of the most intense sources currently used in XRF instruments is a 40-millicurie 

57Co (cobalt-57) radiation source. Other radiation sources in current use for XRF testing of lead-based 

paint generally produce lower levels of radiation. Generally, an XRF operator following manufacturer’s 

instructions would be exposed to radiation well below the regulatory level. Typically, XRF instruments 

with lower gamma radiation intensities can use a shorter safe distance, provided that the potential exposure to an individual will not exceed the regulatory limit. 

No one should be near the other side of a wall, floor, ceiling or other surface being tested. The operator 

should verify this prior to initiating XRF testing activities and check on it during testing. 

Finally, the effectiveness of the instrument’s radiation shielding should be assessed every 6 months using a 

leak test. The XRF manufacturer or owner’s manual can be consulted to obtain vendors of leak test kits. 

If these safety practices are observed, the risk of excessive exposure to ionizing radiation is extremely low 

and will not endanger any inspectors or occupants present in the dwelling. 

Each quarter, Syracuse receives sample kits with four concentration levels for each of three 

matrices: paint chips, soil, and dust wipes. The city analyzes these samples and sends the results 

back to ELPAT for evaluation. Performance ratings are based on accumulated results over four 

rounds. The acceptable range is based on consensus values from all laboratories. A laboratory’s 

performance for each matrix is rated as proficient if either of the following criteria are met: in 

the last two rounds, all samples are analyzed and the results are 100 percent acceptable; or, 

three-fourths or more of the accumulated results over four rounds are acceptable. Syracuse has 

consistently been rated as proficient using XRF. 

For more information on the ELPAT Program, visit <www.aiha.org/LaboratoryServices/html/ 

elpat1.htm> or contact the Laboratory Accreditation Department at AIHA, (703) 849-8888. 

6.4 Health and Safety When Using XRF 

Guarding Against Radiation Hazards 

Portable XRF instruments used for lead analyses contain radioactive isotopes that emit X-rays 

and gamma radiation. Proper training and handling of these instruments is needed to protect 

the instrument operator and any other persons in the immediate vicinity during XRF use. The 

XRF instrument should be in the operator’s possession at all times. The operator should never 

defeat or override any safety mechanisms of XRF equipment. The City of Syracuse has 

dosimetry badges that are worn by each of the XRF operators whenever the instrument is in 

Anal yzing Lead Dust Samples Using XRF T echnology 47 
use. These badges are evaluated each quarter to check for 

personal radiation exposure. In addition, in accordance with 

New York State regulations, the instrument is leak-tested 

every six months. 

6.5Maintaining Equipment 

Day-to-day maintenance of the XRF is generally not difficult 

or costly. Operators should clean the instrument’s display 

window with cotton swabs, clean the case with a soft cloth, 

and charge the batteries as directed in the owner’s manual. 

Beyond that, operators usually just need to take care not to 

drop the instrument, get it wet, or neglect the calibration 

checks recommended by the manufacturer. 

Over the long term, however, XRF owners face the very significant maintenance concern of replacing the instrument’s 

radioactive source. All radioactive isotopes decay at a fixed 

rate. The half-life of 109Cd (cadmium-109), for example, is 

about 18 months. After that, the XRF can still be used, but 

the instrument becomes progressively less efficient. Readings 

that once took 30 to 60 seconds take progressively longer. 

Eventually the wait becomes burdensome, and the isotope 

must be replaced. Syracuse sends its instrument back to the 

manufacturer, which disposes of the spent radioactive source, 

installs the new source, upgrades the instrument’s software, 

and provides whatever preventive maintenance is needed. See Chapter 7, Section 7.3 for more 

information on managing and disposing of hazardous wastes generated in a lead dust monitoring and mitigation program. 

6.6 Resources for Additional Information 

XRF Accuracy 

U.S. EPA, Office of Research and Development, Environmental Technology Verification Report 

on Field Portable X-ray Fluorescence Analyzer, Niton XL Spectrum Analyzer, March 1998, 

EPA/600/R-97/150. Visit www.epa.gov/etv/verifications/vcenter1-22.html. 

Midwest Research Institute, XRF Performance Characteristic Sheet, Edition Number 4, Niton 

XL 309, 701-A, 702-A, and 703-A Spectrum Analyzers, April 17, 1998, in accordance with 

EPA Methodology for XRF Performance Characteristic Sheets, September 1997, EPA 747-R95-008. Copies can be obtained from the National Lead Clearinghouse at 1-800-424-LEAD. 

Clark, Scott, William Menrath, Mei Chen, Sandy Roda, and Paul Succop. Use of a Field 

Portable X-Ray Fluorescence Analyzer to Determine the Concentration of Lead and Other 

Metals in Soil and Dust Samples. To order, contact the University of Cincinnati Department of 

Environmental Health at 513 558-1749. 

48 Chapter 6 
Test Methods 

SW-846 is EPA’s Office of Solid Waste’s official compendium of analytical and sampling methods that have been evaluated and approved for use in complying with RCRA regulations. Visit 

<www.epa.gov/epaoswer/hazwaste/test/sw846.htm> to learn more about SW-846 and obtain a 

copy online. 

Methods 6200, 6010B, and 7420 from EPA (entitled Test Methods for Evaluating Solid Waste, 

Physical/Chemical Methods, SW-846). For ordering information, or to obtain a copy online, go 

to <www.epa.gov/epaoswer/hazwaste/test/sw846.htm>. 

ASTM E1792-96a, Standard Specification for Wipe Sampling Materials for Lead in Surface 

Dust, ASTM, 1100 Barr Harbor Drive, West Conshohoken, PA 19428-2959. For individual 

reprints call 610-832-9585; visit www.astm.org or send an e-mail to service@astm.org. 

Anal yzing Lead Dust Samples Using XRF T echnology 49 
7 Mitigation and Maintenance


This chapter describes the mitigation (cleaning) steps for indoor areas identified as having a lead dust hazard. This chapter presents the three-step wet cleaning method and 

explains the use of High Efficiency Particulate Air (HEPA) filter vacuums used by the 

Syracuse Lead Dust Project. Consistent with the goals of EMPACT, this mitigation approach is 

low cost and convenient to the affected community. 

•	 Section 7.1 is written for residents interested in learning how to mitigate (clean) lead dust in 

their homes. 

•	 Section 7.2 is written for managers and decision-makers who might be considering a lead 

dust program in their community and for organizers who are actually implementing a lead 

intervention program. It also describes Syracuse’s HEPA vacuum loaner program. 

•	 Section 7.3 provides information on the proper management and disposal of lead dust 

debris. 

• Section 7.4 contains information on maintaining lead-safe practices in the home. 

• Section 7.5 provides resources for further information. 

7.1 Lead Dust Mitigation 

Residents of homes and apartment buildings built before 1978 (the year a federal ban was 

imposed on lead-based paint used in residential settings) should consider contacting the local 

city or county health department to test for lead dust. In Syracuse, 

once lead dust is detected through inspection and sampling, the 

project allows participants to borrow a HEPA vacuum and recommends a three-step wet cleaning process. 

A HEPA vacuum cleaner is superior to other types of vacuums 

(including shop vacuums and other regular household vacuums) 

because it is equipped with a filter that can trap almost 100 percent 

of the dust that it collects. While the vacuum can be used without 

supervision, training might be necessary to properly and safely 

operate it, especially because lead dust is involved. Household vacuums should never be used to pick up lead dust or paint chips. 

Conventional vacuum filters are not equipped to handle and hold 

fine dust particles, and will simply redistribute lead dust through 

the exhaust. 

An area that contains lead dust or debris should also be wet cleaned with a cleaning agent and 

then rinsed with water; it should never be dry wiped or dry dusted. Syracuse uses paper towels 

or two disposable rags or sponges (one for the cleaning solution, and one for the rinse water). 

This helps avoid recontaminating areas that have already been cleaned. 

In a report published in March 

2002 entitled, Managing 

Elevated Blood Lead Levels Among 

Young Children, CDC’s Advisory 

Committee on Childhood Lead 

Poisoning Prevention states that 

repeated cleaning of household 

lead dust has been associated with 

decreases in children’s mean blood 

lead levels. 

50 Chapter 7 
Cleaning Areas 

Lead dust comes from opening and closing windows and other friction surfaces painted with 

old lead-based paint. Syracuse, therefore, recommends focusing wet cleaning efforts on areas 

such as old windows, floors, and play areas. These areas should be cleaned at least once a week 

or whenever they appear dirty, because windows can continually generate lead paint chips and 

dust on their sills and wells. In addition, lead dust can get on the bottom of shoes by walking 

on bare soil. This can occur if the exterior housepaint is chipping and releasing lead dust onto 

porch areas or other outside surfaces. The Syracuse Lead Dust Project provides residents with 

information to help them target their cleaning efforts on areas where lead dust tends to accumulate in their specific living units. 

Materials 

In addition to the HEPA vacuum, other useful items are a household cleaning agent (such as 

dishwashing soap), waterproof gloves, disposable rags or towels (preferably paper towels), buckets, and trash bags for disposing of any lead dust debris. The following cleaning agents can be 

found in local grocery or hardware stores and are suggested by the Syracuse Lead Dust Project: 

• Pine-Sol 

• Liquid Tide 

• Cascade (granular dishwasher formula) 

• Spic and Span 

• Lead Clean 

Cleaning Process 

Once proper cleaning materials and a HEPA vacuum are obtained, removing lead dust and lead 

debris from homes involves a few simple steps. In Syracuse, the coordinator meets with each 

resident to explain the following cleaning procedure and to answer any potential questions: 

Step 1: Vacuum. Use a vacuum cleaner equipped with a HEPA exhaust filter. Vacuum all surfaces in the room (e.g., ceilings, walls, trim, and floors). Start with the ceiling and work down, 

while moving toward the entry door. Work from the back of the house or apartment and move 

toward the main exit and finish there. Be sure to move slowly to ensure that the HEPA vacuum 

can pick up all the lead dust. Use attachments, such as extension hoses, straight tubes, brushes, 

crevice tools, and angular tools, to reach surfaces other than floors, including ceilings, light fixtures, radiators, built-in cabinets, and appliances. Pay close attention to surfaces such as window 

troughs, porous concrete, old porous hardwood floors, and the corners of rooms, as they require 

additional vacuuming to achieve an acceptable reduction in lead dust. 

Step 2: Wet-clean. Wear plastic or rubber gloves. Wash all surfaces with a lead-specific detergent, high-phosphate detergent, or other suitable cleaning agent to dislodge any ground-in contamination; then rinse. Wash the ceiling first and then proceed to the floors; plan the work so 

you avoid passing through any rooms that have already been cleaned. Be careful not to scrub so 

hard as to remove any intact paint. Consider using three separate buckets: one for the cleaning 

solution, one for the clean rinse water, and one empty one, into which you can squeeze the 

dirty sponge or rag when using the cleaning solution. Use a new batch of cleaning mixture for 

Although high-phosphate detergents such as 

trisodium phosphate (TSP) are effective, 

certain states have restricted the use of TSP 

because of environmental concerns. TSP also is a 

skin and eye irritant and must be used with caution. Non-TSP detergents developed for lead dust 

removal are available at some hardware stores. 

Mitiga tion and Maintenance 51 
HEPA Vacuums Available Through 

Retail Stores in Minneapolis 

The city of Minneapolis’ Lead Hazard Control 

Program has established an innovative and highly 

successful lead education and HEPA vacuum rental program through local retailers. 

Implemented through local community organizations, 

the program provides “turnkey” information and technical assistance to local retailers such as hardware stores, 

paint stores, and gardening centers, as well as neighborhood churches and community centers, to establish and 

run a lead center inside of their establishments. See 

Appendix C for more information about Minneapolis’ 

Lead Dust program. 

each room to avoid recontaminating an area by cleaning it with dirty water. The cleaning mixture can be put into a spray bottle, which will help keep dust levels down. Use paper towels to 

avoid using dirty rags that might recontaminate areas that have already been cleaned. 

Step 3: Vacuum again. Start at the far end of the unit, and again work toward the main exit. 

Vacuum every inch of the windows, and use the attachments to reach difficult areas, such as 

where the floor meets the floor boards. Use the brush attachment for the walls. Move slowly 

and carefully to capture all the remaining dust. 

7.2 HEPA Vacuum Loaner Program 

The Syracuse Lead Dust Project makes HEPA vacuums available, free of charge, to the community through the CBOs, who have trained staff that help residents implement recommended 

cleaning methods. The HEPA vacuum coordinator demonstrates use of the HEPA vacuum and 

instructs CBOs on proper equipment handling and 

storage. Vacuum maintenance is performed by the 

Syracuse staff, as explained in section 7.3 below. 

Each CBO has program applications and lease agreement forms for the HEPA vacuums. (See the back of 

this chapter for a sample HEPA vacuum lease form). 

Syracuse worked to develop a lease that not only covered legal issues, but that also avoided legal jargon that 

might discourage residents from wanting to participate 

in the program. After filling out a questionnaire that 

requires basic information (e.g., name, address, telephone, number of people living in the household), the 

resident signs a lease form agreeing to properly operate 

the vacuum. Syracuse arranges for the pick-up and drop-off of the HEPA vacuums at the residents’ homes. This way, residents can get the vacuum in hand, avoiding the burden of transporting the vacuum back and forth to the CBO storage area. 

7.3 Disposal of Lead 

Dust Debris and Used 

HEPA Filter 

EPA has interpreted federal hazardous waste 

regulations to exclude lead dust and waste 

from lead-based paint activities in residences. 

This means that in states like New York that 

follow federal guidelines, lead dust and debris 

from cleaning activities can be disposed of 

with regular household waste. EPA recommends the following best management practices for the proper handling and disposal of 

lead-based paint waste: 

•	 Collect paint chips and dust, dirt, and 

rubble in plastic trash bags for disposal. 

52 Chapter 7 
• Store larger architectural debris pieces in containers until ready for disposal. 

•	 Consider using a covered mobile dumpster (such as a roll-off container) for storage of leadbased paint debris until the job is done. 

•	 Contact local municipalities or county solid waste offices to determine where and ho 

debris can be disposed of. 

The full text of EPA’s interpretation on the disposal of lead-based paint waste and lead dust is 

included in a memorandum issued by the Office of Solid Waste, which is included in 

Appendix E of this document. 

It is important to note that certain states consider lead dust and debris to be hazardous 

waste. It is imperative to contact your state government, local municipality, county solid 

waste offices, and/or tribal authorities to determine if any restrictions apply to the disposal of such waste. If restrictions do apply, these sources can tell you where lead dust and 

debris can be disposed of, such as a household hazardous waste collection site. 

In Syracuse, residents are instructed to place items used during cleaning (e.g., rags, 

paper towels, paint chips, used cleaners) into a double-thick garbage bag, including the 

HEPA filter if fully used. The waste bag should be sealed tightly and kept out of reach 

of children and pets. In addition, wash water used for wet-cleaning should never be 

poured onto the ground. Syracuse recommends consulting your local water and 

sewage utility for directions on the proper disposal of the wash water in your area. 

The Syracuse Lead Dust Project maintains all the HEPA vacuums. After 10 uses, 

the bags are replaced; after 10 bags, the team replaces the HEPA filter. Syracuse 

staff dampen the filter with water to control the potential spread of dust before 

removing or disturbing it. It is extremely important that the HEPA filter not be 

opened or emptied at anytime during removal as to avoid any exposure to 

lead dust. The Syracuse Lead Dust Project uses triple-layered HEPA bags 

that can be disposed of in the regular waste stream. 

7.4	 Maintaining Lead-safe Practices in 

the Home 

Along with detecting and reducing high lead dust levels, continuing


lead-safe activities in the home is a crucial element in any lead dust program. 


Syracuse HEPA vacuum coordinator provides residents with a comprehensiv


information packet that could be used in addition to, as well as independently of, the lead dust


project. Also, as explained in Chapter 9, Syracuse conducts an interview with residents who


have completed the program, during which they encourage continued lead dust cleaning.


Educating Residents About Continued Regular Maintenance 

Once a resident participates in the lead dust program, Syracuse staff encourages residents not 

only to regularly follow the cleaning procedure for lead dust, but to contact Syracuse’s lead program or the CBO for further assistance. Residents also can request and are encouraged to have 

their home rechecked for lead dust levels and to use the HEPA vacuum again. 

Mitiga tion and Maintenance 53 
Syracuse emphasizes to program participants the importance of regular cleaning and maintenance 

as long as lead-based paint remains in the house. It is especially important to clean windows periodically since lead dust is created every time a window with lead-based paint is opened or closed. 

Paint on doors, door jambs, and walls also can be disturbed, creating paint chips or lead dust. 

Syracuse has had to make clear to residents that if lead-based paint is disturbed by drilling into a 

wall to hang a picture or cutting to access wiring, then the dust should be cleaned up immediately. 

7.5 Resources for Additional Information 

For more information on EPA’s final standards (TSCA 403) for lead-based paint hazards 

(including lead dust), visit the Office of Pollution Prevention and Toxics Web site at 

<www.epa.gov/lead/leadhaz.htm> . 

See Appendix E for a copy of a memorandum from Elizabeth A. Cotsworth, Director, U.S. EPA 

Office of Solid Waste to RCRA Senior Policy Advisors entitled Regulatory Status of Waste 

Generated by Contractors and Residents from Lead-Based Paint Activities Conducted in 

Households., July 31, 2000. This document is also available at <www.epa.gov/lead/fslbp.htm>. 

HUD’s Requirements for Notification, Evaluation and Reduction of Lead-Based Paint Hazards 

in Federally Owned Residential Property and Housing Receiving Federal Assistance (24 CFR 

Part 35) can be found online at <www.hud.gov/lead/> . 

54 Chapter 7 
Mitiga tion and Maintenance 55 
56 Chapter 7 
8 Reporting


This chapter discusses the tools and procedures Syracuse uses to report and disseminate 

the results of its lead dust program. Reports include those to residents, tenants, and to 

the public via the Internet. Since the Syracuse project is not performing formal lead 

hazard screening, it does not need to comply with regulatory reporting requirements, but these 

reports are meeting the project’s communication and data collection objectives. 

• Section 8.1 describes how written results are presented to individual program participants. 

•	 Section 8.2 describes how Syracuse presents written results to the public, while maintaining 

participant confidentiality. 

• Section 8.3 reviews the use of a Web site for posting data. 

• Section 8.4 lists resources for more information. 

8.1 Participant Reports 

Syracuse’s documentation process begins upon accepting applications from potential participants. Once Syracuse staff determine how much lead dust is in the home, they present results to 

the resident. As part of the reporting process, the project teaches the significance of the data, 

identifies probable or potential sources of lead contamination, and recommends cleaning procedures for homes with lead dust levels above the reference levels. 

Syracuse uses two different reports to present findings to participants: a pre-mitigation report 

after the initial sampling and a post-mitigation report for some residents who lease a HEPA vacuum and who agree to a second round of sampling. (Samples of these reports and a copy of 

Syracuse’s transmittal letters are included at the end of this chapter.) The pre-mitigation report 

presents initial lead dust levels for each of the 10 areas sampled and indicates whether they 

passed or failed based on the references levels established for that area (e.g., floors, window sills, 

and window troughs). (See section 1.5). When lead dust levels are over the reference levels, 

Syracuse staff meet with the participant to discuss and interpret the results and explain the use 

of HEPA vacuums and the three-step cleaning process. 

In Phase I of the Syracuse project, all residents who consented to a second round of sampling 

received post-mitigation reports. During Phase II of the project, approximately 10 percent of 

randomly-selected participants receive post-mitigation sampling with their consent. If HEPA 

vacuuming and cleaning is successful in treating the problem, post-mitigation levels are expected to fall below the reference thresholds. In Syracuse, the project mails the final report to the 

participant. If levels remain over the thresholds, staff will schedule another face-to-face meeting 

with the resident. 

When preparing its report format, Syracuse considered what the program participant needed to 

know. Syracuse’s reports present the data in a straightforward way to ensure that residents 

understand the results and are not intimidated by technical jargon. For example, next to the 

actual lead-dust level findings the report shows whether each sampling area passed (green) or 

failed (red), presenting the information in an easy-to-understand manner to residents. 

Reporting 57 
Syracuse also includes a glossary of technical terms such as “lead-based paint hazard,” “friction 

surface,” and “reference level” with these reports. Residents are also informed that, while the 

report covers only those areas sampled, other areas also might contain a lead dust hazard. They 

are advised that if they treat all areas in their home the same as the improved areas, then the risk 

is likely reduced. 

Syracuse staff find that face-to-face reporting in the home is most effective and that translating 

reports into other languages is sometimes necessary. Some CBOs provide translators who 

accompany project staff on site visits to explain the report findings to residents in their native 

languages and to answer questions. As discussed previously, interacting with residents in their 

own language is a tremendous help in building trust and enlisting participation. 

When delivering a report, the field sampling technician locates areas of concern and identifies 

potential sources of lead dust such as paint rubbing off window sills. If necessary, mitigation 

(cleaning) is recommended. (Read about mitigation in Chapter 7). If the participant has been 

randomly selected for post-mitigation sampling, that is also discussed. The resident is also 

encouraged to repeatedly follow the three-step cleaning process to control lead dust levels (see 

Section 7.4 on program maintenance). Residents and property owners also receive printed 

material providing information on how to control lead in their home. 

Property Owner/Landlord Disclosure Requirements 

In addition to providing the tenant with a report on the results of the lead dust mitigation, the 

Syracuse Lead Dust Project provides a copy of the lead dust analysis and cleaning report to the 

property owner (or landlord) after the mitigation is completed. Syracuse project staff learned 

that, because the city already had a separate HUD-funded lead hazard reduction program in 

place, the community was already aware of lead issues, and landlords have been responsive 

when lead hazards are identified in their properties. Landlords are required to disclose this 

information to future tenants when they sign a new lease, and to a purchaser if the property is 

subsequently sold. A sample of Syracuse’s letter to the landlord, and the sample forms used by 

EPA to inform landlords of these disclosure requirements, can be found at the end of this chapter. These forms are also available from EPA in Spanish. 

8.2 Public Reports 

Once Syracuse gathers enough data to determine a trend, it can report that trend to the community. Recording the results on a map to see if a geographical pattern emerges has proven to 

be useful. Some target communities have relatively homogeneous housing types, and other 

homes are likely to contain similar levels of lead dust. Also, homeowners or residents who have 

not participated in the program need to know of potential lead hazards. Syracuse found that 

maps work best when there is data from numerous houses in the community to consolidate, 

because the identity of individual homes is lost in the data, thereby maintaining confidentiality. 

Maps are not a good choice, however, when there are only a few data points. 

Information can also be made available to the public on a Web site, which also serves to promote awareness of the lead dust problem and help homeowners and communities make more 

informed decisions. (See Section 8.3 below for more on Syracuse’s Web site). Other formats 

used by Syracuse to report to the public include the use of posters that rotate though the CBOs, 

a quarterly newsletter, monthly meetings with the CBOs, and broadcasting public service 

announcements on cable television. 

58 Chapter 8 
Syracuse is also in the process of finalizing a “Lead Registry,” a comprehensive database that will 

compile data from all lead-related programs (e.g., Lead Dust Project, HUD Program, and LeadSafe Yards). 

Recordkeeping and Confidentiality 

Generally, homeowners do not want information about their home shared with their neighbors. 

To avoid this, Syracuse consolidates data without divulging specific locations. Consolidating 

data retains the homeowner’s privacy and allows the ability to track trends. One way to convey 

this information is to consolidate the data on a geographical basis. 

Syracuse keeps good records to help track lead dust data and protect its participants’ privacy. 

Staff start a file and keep records of all correspondence as soon as a participant submits an 

application and is accepted into the program. A participant’s file contains the application, raw 

data, final reports, and other correspondence. The project also tracks the progress of each participant by using a simple spreadsheet that includes the resident’s basic information, lab results, 

HEPA use, and disposition of the case. Residents’ files are stamped “confidential” and kept in a 

secure location in the program management office. 

Syracuse staff learned that organizing and filing records by the participant’s address makes them 

easy to find regardless of who is living at the address. The program also keeps the property 

owner’s name and the resident’s name in their files, since in some cases it will not only correspond with the person living in the home, but also with the property owner as well. For example, if the property has exceptionally high lead levels, Syracuse might contact the property 

owner if vacuuming is only a short-term solution to a larger problem. 

8.3 Web Site 

The Syracuse Lead Dust Project Web site is at <http://www.syracuse-empact.com>, To post lead 

dust data, the site uses a map of the city showing the CBO neighborhoods. Syracuse reports average lead dust levels in micrograms per square foot for pre-mitigation and post-mitigation for 

floors, sills, and window wells. Syracuse also presents individual sample points so that users can 

get an impression of the range of values. Although Syracuse reports individual values, the project 

does not report the property address or even the street, keeping that information confidential. 

The site also provides general information about the project and links to participating CBOs and 

posts educational materials and information about lead hazards. Once the web site is fully operational, project staff will be able to correspond with visitors through e-mail to respond to questions 

and comments. 

8.4 Resources for Additional Information 

The following resources will provide more information on reporting the results of lead levels: 

Risk Communication in Action: Environmental Case Studies, U.S. EPA, EPA 625-R-02-011, 

September 2002. 

The Syracuse Lead Dust Project Web site shows how a map of the city linked to the CBOs is 

used to provide neighborhood-specific lead dust data. Visit <http://www.syracuse-empact.com>. 

National Lead Information Center Hotline at 1-800-424-LEAD. 

Reporting 59 
Pre-Mitigation Tenant Letter 

DateName 

Address 

Syracuse, N.Y. 

RE: Lead Dust Test Results 

Dear Ms. XXXX 

Thank you for helping us with our lead dust testing and education program. 

We’ve enclosed the results of the tests we did in your home on –Date-. We 

measured lead in house dust, which we and others have found to be the most 

important source of lead in most homes. However, please be aware that there 

may be other sources of lead in your home, (i.e., paint, soil, water), that this 

report does not address. 

Please read this report carefully and if you have any questions, please 

call Adam VanHoose at 448-8708. The City of Syracuse can let you use a special vacuum that can remove lead dust safely. For more information about the 

HEPA vacuum loaner program call Adam or visit our website at http://syrempact.lead-safe.com. Please be advised that the information collected will be 

kept confidential. 

Sincerely

Betsy Mokrzycki

Program Manager

Enclosures:

Report

Cleaning instructions HUD Chapter 14

“Protect Your Family” EPA Brochure

etc.

60 Chapter 8 
Pre-Mitigation Report 

Syracuse Lead Dust Outreach Monitoring and Education Project 

Funded by EPA 

SETTLED DUST SAMPLE RESULTS 

For The Dwelling Located at: 

-Address­

-DateGENERAL INFORMATION 

The City of Syracuse conducted sampling of settled dust at -Address-, 

Syracuse, New York on –Date-. 

An initial walk-through was conducted in the dwelling to locate the dustiest 

areas of floors, window sills, and window wells, which were accessible or 

exposed. The information contained in this report has been collected in accordance with current regulations. 

PURPOSE 

The settled dust testing was conducted according to chapter 5 of the HUD 

Guidelines. Reference levels are levels listed below: 

DUST WIPE SAMPLES 

Floors 40 μg/ft2 

Window Sills 250 μg/ft2 

Window Troughs 400 μg/ft2 

NARRATIVE 

Ten samples of settled dust were collected from within the dwelling from 

floors and window sills that appeared to be the dirtiest and most accessible to 

the children. Samples results that exceed the reference limits are indicated in 

red type on the quick summary page. Six of the ten wipe samples exceeded the 

reference limits for lead content. It is our recommendation that all window sill 

surfaces be cleaned using the HUD recommended three step cleaning method 

as described in Chapter 14-11 of the HUD Guidelines. 

Reporting 61 
1

2

3

4

5

6

7

8

9

10

QUICK SUMMARY OF LEAD TESTING RESULTS 

Dwelling: -Address- Date: X/XX/XX 

Inspector: XXXXXXXX Job #: XX 

SAMPLE LOCATION RESULT Pass/Fail 

Princ. Play Area Floor <20.0 μg/ft2 Pass 

Princ Play Area Sill 306.2 μg/ft2 Fail 

Kitchen Floor <20.0 μgft2 Pass 

Kitchen Window Sill 667.6 μg/ft2 Fail 

Kitchen Window Trough 2,892.1 μg/ft2 Fail 

Youngest child’s bedroom floor <20.0 μg/ft2 Pass 

Youngest child’s bedroom window sill 264.9 μg/ft2 Fail 

Youngest child’s bedrm. Win. trough 1, 258.0 μg/ft2 Fail 

2nd Youngest child’s bedroom floor <20.0 μg/ft2 Pass 

2nd Youngest child’s bedroom window sill 483.0 μg/ft2 Fail 

REFERENCE LEVELS 

Glossary 

Deteriorated paint means any interior or exterior paint or other coating that is peeling, chipping, chalking 

or cracking, or any paint or coating located on an interior or exterior surface or fixture that is otherwise 

damaged or separated from the substrate. 

Friction surface means an interior or exterior surface that is subject to abrasion or friction, including, but 

not limited to, certain window, floor, and stair surfaces. 

Impact surface means an interior or exterior surface that is subject to damage by repeated sudden force 

such as certain parts of door frames. 

Interior window sill means the portion of the horizontal window ledge that protrudes into the interior of the 

room. 

Lead-based paint hazard 

(a) Paint-lead hazard. A paint-lead hazard is any of the following: (1) Any lead-based paint on a friction surface that is subject to abrasion and where the lead dust levels on the nearest horizontal surface underneath 

the friction surface (e.g., the window sill, or floor) are equal to or greater than the dust-lead hazard levels 

identified in paragraph (b) of this section. (2) Any damaged or otherwise deteriorated lead-based paint on an 

impact surface that is caused by impact from a related building component (such as a door knob that knocks 

into a wall or a door that knocks against its door frame. (3) Any chewable lead-based painted surface on 

which there is evidence of teeth marks. (4) Any other deteriorated lead-based paint in any residential building or child-occupied facility or on the exterior of any residential building or child-occupied facility. 

(b) Dust-lead hazard. A dust-lead hazard is surface dust in a residential dwelling or child-occupied facility 

that contains a mass-per-area concentration of lead equal to or exceeding 40 mg/ft2 on floors or 250 mg/ft2 

on interior window sills based on wipe samples. 

(c) Soil-lead hazard. A soil-lead hazard is bare soil on residential real property or on the property of a childoccupied facility that contains total lead equal to or exceeding 400 parts per million (mg/g) in a play area or 

average of 1,200 parts per million of bare soil in the rest of the yard based on soil samples. 

62 Chapter 8 
Play area means an area of frequent soil contact by children of less than 6 years of age as indicated by, 

but not limited to, such factors including the following: the presence of play equipment (e.g., sandboxes, 

swing sets, and sliding boards), toys, or other children’s possessions, observations of play patterns, or 

information provided by parents, residents, care givers, or property owners. 

Residential building means a building containing one or more residential dwellings. 

Reference Level(s) means levels that have been set by HUD and EPA to indicate surface dust that contains an amount of lead which may pose a threat of adverse health effects in pregnant women or children 

less than the age of six years of age. 

Room means a separate part of the inside of a building, such as a bedroom, living room, dining room, 

kitchen, bathroom, laundry room, or utility room. To be considered a separate room, the room must be separated from adjoining rooms by built-in walls or archways that extend at least 6 inches from an intersecting 

wall. Half walls or bookcases count as room separators if built-in. Movable or collapsible partitions or partitions consisting solely of shelves or cabinets are not considered built-in walls. A screened in porch that is 

used as a living area is a room. 

Window trough means, for a typical double-hung window, the portion of the exterior window sill between 

the interior window sill (or stool) and the frame of the storm window. If there is no storm window, the window trough is the area that receives both the upper and lower window sashes when they are both lowered. 

The window trough is sometimes referred to as the window ‘’well.’’ 

Wipe sample means a sample collected by wiping a representative surface of known area, as determined 

by ASTM E1728, ‘’Standard Practice for Field Collection of Settled Dust Samples Using Wipe Sampling 

Methods for Lead Determination by Atomic Spectrometry Techniques, or equivalent method, with an 

acceptable wipe material as defined in ASTM E 1792, ‘’Standard Specification for Wipe Sampling Materials 

for Lead in Surface Dust.’’ 

XRF means a testing device that is capable of determining the presence of lead in a dust wipe sample. 

Reporting 63 
Post-Mitigation Tenant Letter 

Date

Name

Address

Syracuse, N.Y. 13210

RE: Lead Dust Test Results

Dear Ms.

Thank you for helping us with our lead dust testing and education program. We’ve enclosed the results of the tests we did in your home on -Date-. We 

measured lead in house dust, which we and others have found to be the most 

important source of lead in most homes. However, please be aware that there 

may be other sources of lead in your home, (i.e., paint, soil, water), that this 

report does not address. 

Please be advised that the lead levels in your home were found to be 

below the detection limit, due to the proper use of the HEPA Vacuum. It is our 

recommendation that you continue the 3-step cleaning method recommended 

by HUD as described in Chapter 14 of the HUD Guidelines. 

Please read this report carefully and if you have any questions, please 

call Adam VanHoose at 448-8708. Please be advised that the information collected will be kept confidential. 

Sincerely

Betsy Mokrzycki

Program Manager

Enclosures:

Report

Cleaning instructions HUD Chapter 14

“Protect Your Family” EPA Brochure

etc.

64 Chapter 8 
Post-Mitigation Report 

Syracuse Lead Dust Outreach Monitoring and Education Project 

Funded by EPA 

SETTLED DUST SAMPLE RESULTS 

Post Wipes 

For The Dwelling Located at: 

Address 

Syracuse New York 

-DateGENERAL INFORMATION 

The City of Syracuse conducted post sampling of settled dust at -AddressSyracuse, New York on –Date-. 

The information contained in this report has been collected in accordance 

with current regulations. 

PURPOSE 

The settled dust testing was conducted according to chapter 5 of the HUD 

Guidelines. Reference levels are levels listed below: 

DUST WIPE SAMPLES 

Floors 40 μg/ft2 

Window Sills 250 μg/ft2 

Window Troughs 400 μg/ft2 

NARRATIVE 

Ten samples of settled dust were collected from within the dwelling from 

floors and window sills that appeared to be the dirtiest and most accessible to 

the children. Samples results that exceed the reference limits are indicated in 

red type on the quick summary page. None of these ten wipe samples exceeded the reference limits for lead content. It is our recommendation that you continue to clean all surfaces using the HUD recommended three step cleaning 

method as described in Chapter 14-11 of the HUD Guidelines. 

Reporting 65 
QUICK SUMMARY OF LEAD TESTING RESULTS 

Dwelling: Address, Syracuse N.Y. Date: X/XX/XX 

Inspector:XXXXX Job # XX 

SAMPLE LOCATION RESULT Pass/Fail 

13 Principle .play area floor <20.0 μg/ft2 Pass 

14 Principle Play area sill 34.4 μg/ft2 Pass 

15 Kitchen floor <20.0 μgft2 Pass 

16 Kitchen sill 46.0 μg/ft2 Pass 

17 Kitchen Trough 50.2 2 Pass 

18 Youngest child’s bedroom floor <20.0 μg/ft2 Pass 

19 Youngest child’s bedroom window sill 39.9 2 Pass 

20 Youngest child’s bedrm. Win. trough 64.8 2 Pass 

21 2nd Youngest child’s bedroom floor <20.0 μg/ft2 Pass 

22 2nd Youngest child’s bedroom window sill 42.9 μg/ft2 Pass 

μg/ft

μg/ft

μg/ft

REFERENCE LEVELS 

Floors 40 μg/ft2 

Window Sills 250 μg/ft2 

Window Trough 400 μg/ft2 

Glossary 

Deteriorated paint means any interior or exterior paint or other coating that is peeling, chipping, chalking 

or cracking, or any paint or coating located on an interior or exterior surface or fixture that is otherwise 

damaged or separated from the substrate. 

Friction surface means an interior or exterior surface that is subject to abrasion or friction, including, but 

not limited to, certain window, floor, and stair surfaces. 

Impact surface means an interior or exterior surface that is subject to damage by repeated sudden force 

such as certain parts of door frames. 

Interior window sill means the portion of the horizontal window ledge that protrudes into the interior of the 

room. 

Lead-based paint hazard 

(a) Paint-lead hazard. A paint-lead hazard is any of the following: (1) Any lead-based paint on a friction surface that is subject to abrasion and where the lead dust levels on the nearest horizontal surface underneath 

the friction surface (e.g., the window sill, or floor) are equal to or greater than the dust-lead hazard levels 

identified in paragraph (b) of this section. (2) Any damaged or otherwise deteriorated lead-based paint on an 

impact surface that is caused by impact from a related building component (such as a door knob that knocks 

into a wall or a door that knocks against its door frame. (3) Any chewable lead-based painted surface on 

which there is evidence of teeth marks. (4) Any other deteriorated lead-based paint in any residential building or child-occupied facility or on the exterior of any residential building or child-occupied facility. 

(b) Dust-lead hazard. A dust-lead hazard is surface dust in a residential dwelling or child-occupied facility 

that contains a mass-per-area concentration of lead equal to or exceeding 40 mg/ft2 on floors or 250 mg/ft2 

on interior window sills based on wipe samples. 

66 Chapter 8 
(c) Soil-lead hazard. A soil-lead hazard is bare soil on residential real property or on the property of a childoccupied facility that contains total lead equal to or exceeding 400 parts per million (mg/g) in a play area or 

average of 1,200 parts per million of bare soil in the rest of the yard based on soil samples. 

Play area means an area of frequent soil contact by children of less than 6 years of age as indicated by, 

but not limited to, such factors including the following: the presence of play equipment (e.g., sandboxes, 

swing sets, and sliding boards), toys, or other children’s possessions, observations of play patterns, or 

information provided by parents, residents, care givers, or property owners. 

Residential building means a building containing one or more residential dwellings. 

Reference Level(s) means levels that have been set by HUD and EPA to indicate surface dust that contains an amount of lead which may pose a threat of adverse health effects in pregnant women or children 

less than the age of six years of age. 

Room means a separate part of the inside of a building, such as a bedroom, living room, dining room, 

kitchen, bathroom, laundry room, or utility room. To be considered a separate room, the room must be separated from adjoining rooms by built-in walls or archways that extend at least 6 inches from an intersecting 

wall. Half walls or bookcases count as room separators if built-in. Movable or collapsible partitions or partitions consisting solely of shelves or cabinets are not considered built-in walls. A screened in porch that is 

used as a living area is a room. 

Window trough means, for a typical double-hung window, the portion of the exterior window sill between 

the interior window sill (or stool) and the frame of the storm window. If there is no storm window, the window trough is the area that receives both the upper and lower window sashes when they are both lowered. 

The window trough is sometimes referred to as the window ‘’well.’’ 

Wipe sample means a sample collected by wiping a representative surface of known area, as determined 

by ASTM E1728, ‘’Standard Practice for Field Collection of Settled Dust Samples Using Wipe Sampling 

Methods for Lead Determination by Atomic Spectrometry Techniques, or equivalent method, with an 

acceptable wipe material as defined in ASTM E 1792, ‘’Standard Specification for Wipe Sampling Materials 

for Lead in Surface Dust.’’ 

XRF means a testing device that is capable of determining the presence of lead in a dust wipe sample. 

Reporting 67 
Post-Mitigation Landlord Letter 

July 23, 2002 

Mr John Doe 

123 Sesame Street 

Syracuse, N.Y. 13202 

RE: Lead Dust Test Results 

Dear Mr. Doe: 

Your tenant at 123 Sesame Street recently received lead wipe sampling 

through the City of Syracuse Lead Dust Outreach, Monitoring and Education 

Project. Please be advised that the information collected will be kept confidential. 

We’ve enclosed the results of the monitoring we did on your property on July 15, 

2002. We measured lead in house dust, which we and others have found to be the 

most important source of lead in most homes. However, please be aware that there 

may be other sources of lead in your tenants home, (i.e., paint, soil, water), that this 

report does not address. 

Please keep this report, which will need to be released to any future tenants 

or disclosed to new owners in the event the property goes up for sale in order to 

comply with Section 1018 Real Estate Disclosure Rule. 

Please read this report carefully and if you have any questions, please call 

Adam VanHoose at 448-8708. For more information about the HEPA vacuum loaner 

program call Adam or visit our website at http://www.syracuse-empact.com. 

Sincerely

Betsy Mokrzycki

Program Manager

Enclosures:

Report

Cleaning instructions HUD Chapter 14

“Protect Your Family” EPA Brochure

etc.

68 Chapter 8 
Sample Disclosure Format for Target Housing Sales 

Disclosure of Information on Lead-Based Paint and/or Lead-Based Paint Hazards for Sales 

Property Address: 

Lead Warning Statement

Every purchaser of any interest in residential real property on which a residential dwelling was built prior to 1978 is 

notified that such property may present exposure to lead from lead-based paint that may place young children at risk of 

developing lead poisoning. 

learning disabilities, reduced intelligence quotient, behavioral problems, and impaired memory. 

poses a particular risk to pregnant women. interest in residential real property is required to provide 

the buyer with any information on lead-based paint hazards from risk assessments or inspections in the seller’s 

possession and notify the buyer of any known lead-based paint hazards. 

lead-based paint hazards is recommended prior to purchase. 

Seller’s Disclosure [ Seller should initial both (a) and (b) ]. 

_____ (a) (check one below):

Known lead-based paint and/or lead-based paint hazards are present in the housing (explain). 

Seller has no knowledge of lead-based paint and/or lead-based paint hazards in the housing. 

_____(b) (check one below): 

Seller has provided the purchaser with all available records and reports pertaining to lead-based 

paint and/or lead-based paint hazards in the housing (list documents below). 

Seller has no reports or records pertaining to lead-based paint and/or lead-based 

paint hazards in the housing. 

Purchaser’s Acknowledgment [ Purchaser should initial (c), (d) and (e) ]. 

_____(c) Purchaser has received copies of all information listed above. 

_____(d) Purchaser has received the pamphlet Protect Your Family from Lead in your Home. 

_____(e) Purchaser has (check one below): 

Received a 10-day opportunity (or mutually agreed upon period) to conduct a risk assessment or 

inspection for the presence of lead-based paint and/or lead-based paint hazards; or 

Waived the opportunity to conduct a risk assessment or inspection for the presence of lead-based 

paint and/or lead-based paint hazards. 

Agent’s Acknowledgment [ Seller’s Agent should initial (f) ]. 

_____ (f) 

his/her responsibility to ensure compliance. 

Certification of Accuracy [ Purchaser should be the last person to sign and date this form ]. 

The following parties have reviewed the information above and certify, to the best of their knowledge, that 

the information they have provided by the signatory is true and accurate. 

______________________________________ ______________________________________ 

Seller Date Purchaser Date 

______________________________________ ______________________________________ 

Seller Date Purchaser Date 

______________________________________ ______________________________________ 

Seller’s Agent Date Purchaser’s Agent Date 

Lead poisoning in young children may produce permanent neurological damage, including 

Lead poisoning also 

The seller of any 

A risk assessment or inspection for possible 

Presence of lead-based paint and/or lead-based paint hazards 

Records and reports available to the seller 

Agent has informed the seller of the seller’s obligations under 42 U.S.C. 4852(d) and is aware of 

Reporting 69

Disclosure of Information on Lead-Based Paint and/or Lead-Based Paint Hazards 

Lead Warning Statement 

Housing built before 1978 may contain lead-based paint. 

pose health hazards if not managed properly. 

children and pregnant women. 

presence of lead-based paint and/or lead-based paint hazards in the dwelling. 

receive a federally approved pamphlet on lead poisoning prevention. 

Lessor’s Disclosure [ Landlord or agent should initial both (a) and (b) ]. 

_____ (a) (check one below):

Known lead-based paint and/or lead-based paint hazards are present in the housing 

(explain). 

Lessor has no knowledge of lead-based paint and/or lead-based paint hazards in the 

housing. 

_____ (b) (check one below): 

Lessor has provided the lessee with all available records and reports pertaining to leadbased paint and/or lead-based paint hazards in the housing (list documents below). 

Lessor has no reports or records pertaining to lead-based paint and/or lead-based 

paint hazards in the housing. 

Lessee’s Acknowledgment [ Tenant should initial both (c) and (d) ]. 

_____(c) 

_____(d) Protect Your Family from Lead in your Home. 

Agent’s Acknowledgment [ Agent, if not landlord’s direct employee, should initial (e) ]. 

_____ (e) 

aware of his/her responsibility to ensure compliance. 

Certification of Accuracy [ Tenant should be the last person to sign and date this form ]. 

The following parties have reviewed the information above and certify, to the best of their 

knowledge, that the information they have provided by the signatory is true and accurate. 

______________________________________ ______________________________________ 

Lessor Date Lessor Date 

______________________________________ ______________________________________ 

Lessee Date Lessee 

______________________________________ ______________________________________ 

Agent Date Agent Date 

Lead from paint, paint chips, and dust can 

Lead exposure is especially harmful to young 

Before renting pre-1978 housing, lessors must disclose the 

Lessees must also 

Presence of lead-based paint and/or lead-based paint hazards 

Records and reports available to the lessor 

Lessee has received copies of all information listed above. 

Lessee has received the pamphlet 

Agent has informed the lessor of the lessor’s obligations under 42 U.S.C. 4852(d) and is 

Date 

70 Chapter 8 
SAMPLE DISCLOSURE FORM FOR RENTALS AND LEASES -

Disclosure of Information on Lead-Based Paint and/or Lead-Based Paint Hazards 

Lead Warning Statement 

Housing built before 1978 may contain lead-based paint. 

pose health hazards if not managed properly. 

children and pregnant women. 

presence of lead-based paint and/or lead-based paint hazards in the dwelling. 

receive a federally approved pamphlet on lead poisoning prevention. 

Lessor’s Disclosure [ Landlord or agent should initial both (a) and (b) ]. 

_AL (a) (check one below): 

Known lead-based paint and/or lead-based paint hazards are present in the housing 

(explain). 

A lead inspection found lead-based paint on bannister in hallway. 

Lessor has no knowledge of lead-based paint and/or lead-based paint hazards in the 

housing. 

AL (b) (check one below): 

Lessor has provided the lessee with all available records and reports pertaining to leadbased paint and/or lead-based paint hazards in the housing (list documents below). 

Report is available in office upon request. 

Lessor has no reports or records pertaining to lead-based paint and/or lead-based 

paint hazards in the housing. 

Lessee’s Acknowledgment [ Tenant should initial both (c) and (d) ]. 

FT (c) 

FT (d) Protect Your Family from Lead in your Home. 

Agent’s Acknowledgment [ Agent, if not landlord’s direct employee, should initial (e) ]. 

_____ (e) 

aware of his/her responsibility to ensure compliance. 

Certification of Accuracy [ Tenant should be the last person to sign and date this form ]. 

The following parties have reviewed the information above and certify, to the best of their 

knowledge, that the information they have provided by the signatory is true and accurate. 

_Any Landlord______2/15/02_____ _______________________________ 

Lessor Date Lessor Date 

_First Tenant_______11/15/02______ _SecondTenant_______11/15/02______ 

Lessee Date Lessee 

______________________________________ ______________________________________ 

Agent Date Agent Date 

X

X

CERTIFICATION BY LANDLORD 

Lead from paint, paint chips, and dust can 

Lead exposure is especially harmful to young 

Before renting pre-1978 housing, lessors must disclose the 

Lessees must also 

Presence of lead-based paint and/or lead-based paint hazards 

Records and reports available to the lessor 

Lessee has received copies of all information listed above. 

Lessee has received the pamphlet 

Agent has informed the lessor of the lessor’s obligations under 42 U.S.C. 4852(d) and is 

Date 

Reporting 71 
SAMPLE DISCLOSURE FORM FOR RENTALS AND LEASES - CERTIFICATION BY AGENT 

Disclosure of Information on Lead-Based Paint and/or Lead-Based Paint Hazards 

Lead Warning Statement 

Housing built before 1978 may contain lead-based paint. 

pose health hazards if not managed properly. 

children and pregnant women. 

presence of lead-based paint and/or lead-based paint hazards in the dwelling. 

receive a federally approved pamphlet on lead poisoning prevention. 

Lessor’s Disclosure [ Landlord or agent should initial both (a) and (b) ]. 

AA(a) (check one below): 

Known lead-based paint and/or lead-based paint hazards are present in the housing 

(explain). 

. 

Lessor has no knowledge of lead-based paint and/or lead-based paint hazards in the 

housing. 

AA(b) (check one below): 

Lessor has provided the lessee with all available records and reports pertaining to leadbased paint and/or lead-based paint hazards in the housing (list documents below). 

Lessor has no reports or records pertaining to lead-based paint and/or lead-based 

paint hazards in the housing. 

Lessee’s Acknowledgment [ Tenant should initial both (c) and (d) ]. 

FT (c) 

FT (d) Protect Your Family from Lead in your Home. 

Agent’s Acknowledgment [ Agent, if not landlord’s direct employee, should initial (e) ]. 

AA(e) 

aware of his/her responsibility to ensure compliance. 

Certification of Accuracy [ Tenant should be the last person to sign and date this form ]. 

The following parties have reviewed the information above and certify, to the best of their 

knowledge, that the information they have provided by the signatory is true and accurate. 

______________________________________ ______________________________________ 

Lessor Date Lessor Date 

First Tenant_______11/15/02______ _SecondTenant_______11/15/02_______ 

Lessee Date Lessee Date 

Any Agent_______11/01/02______ ______________________________________ 

Agent Date Agent Date 

X

X

Lead from paint, paint chips, and dust can 

Lead exposure is especially harmful to young 

Before renting pre-1978 housing, lessors must disclose the 

Lessees must also 

Presence of lead-based paint and/or lead-based paint hazards 

Records and reports available to the lessor 

Lessee has received copies of all information listed above. 

Lessee has received the pamphlet 

Agent has informed the lessor of the lessor’s obligations under 42 U.S.C. 4852(d) and is 

72 Chapter 8 
9Evaluating Syracuse’s 

Lead Dust Project 

The goal of the EMPACT-funded Lead Dust Project in Syracuse is to provide environmental information so that the public can make informed decisions to protect themselves and their families from environmental hazards. The program emphasis is on 

monitoring; data delivery and management; and on communication and outreach, not mitigation or treatment. In response to anticipated resident concerns over elevated lead dust levels 

communicated by the project, however, Syracuse also decided to provide information and training about the three-step cleaning process along with a HEPA vacuum lease program, so that residents would have a low-cost measure they could immediately implement, if elevated lead dust 

levels were found. 

Because of EMPACT’s focus on monitoring and outreach, measuring the effectiveness of the 

mitigation component of the project has not been elaborate. Nonetheless, the project did build 

in a “spot check” of the effectiveness of its cleaning and HEPA vacuuming methods. 

To conduct this initial spot check, Syracuse reviewed sample data from a total of 119 individual 

locations where both before- and after-mitigation data was available. Of these 119 locations, 74 

were determined to have “pre-mitigation” lead dust levels below the project action levels, and 45 

were determined to have “pre-mitigation” lead dust levels above the project action levels. After 

mitigation was performed, lead dust levels were reduced below project action levels in 82 percent (37 of 45) of the locations previously determined to have excessive lead dusts levels. 

The following table summarizes the results of this effectiveness evaluation. The post samples 

were taken an average of 37 days after initial mitigation was conducted. Based on these findings, the Syracuse project continues to conduct post sampling for a minimum of 10 percent of 

the locations tested. 

Preliminary Evaluation of Syracuse Project Effectiveness5 

Pre-Samples (119 Total) Percent (%) Post Samples (119 Total) Percent (%)

Below Action Levels - 74 62% Below Action Levels - 70 95% 

Above Action Levels - 4 5% 

Above Action Levels - 45 38% Below Action Levels - 37 82% 

Above Action Levels - 8 18% 

5 The fact that four post-mitigation samples showed increased lead dust levels is possibly attributable to the 

re-accumulation of lead dust during the 37-day lag between pre- and post-sampling. 

Different project goals may require different project evaluation schemes. If a project’s major 

focus is mitigation, as opposed to monitoring and outreach, evaluation measures should be 

designed accordingly. 

Syracuse also regularly solicits feedback from program participants and CBOs through questionnaires and interviews to evaluate project effectiveness, strengths, and weaknesses. Once a 

E v alua ting Syr acuse’s Lead Dust Project 73 
participant completes a cleaning procedure, for example, project staff set up a time to interview the resident to gather feedback. Syracuse developed a brief questionnaire that technicians 

personally administer in the home with residents to learn about their experience with the program. A copy of this questionnaire is included at the end of this chapter. Syracuse staff prefer 

to do face-to-face interviews to more effectively understand residents’ opinions of the program, 

as well as to give the program a more personal touch and perhaps make a more significant connection with residents. This interview also provides an opportunity to encourage residents to 

continue the lead dust cleaning activities they learned through the program. 

Syracuse also found it important to request feedback from CBOs since they interact with both 

residents and landlords. The CBOs can provide a broader perspective of the program and make 

it more accessible to the community. In a brief written survey, Syracuse asks its partner CBOs 

about HEPA vacuum use among residents and how to better market the program to generate 

greater interest. A copy of the questionnaire used to solicit this feedback is included at the end 

of this chapter. 

Syracuse evaluates the outreach portion of its program in a number of ways. First, it quantifies 

how many residents submit a HEPA Vacuum Intake Questionnaire for participating in the project. This shows how effectively information about the program is disseminated to the community. The Syracuse program manager also looks at the number of residents who used the HEPA 

vacuums and will review the number of “hits” to the project Web site. 

74 Chapter 9 
Participant Questionnaire


E v alua ting Syr acuse’s Lead Dust Project 75

CBO Survey 

76 Chapter 9 
E v alua ting Syr acuse’s Lead Dust Project 77 
Appendix A


Glossary 

Community based organizations (CBOs): Organizations that interact with a community on a 

regular basis, and can help educate the community on lead dust hazards. 

Deteriorated paint: Any exterior or interior paint that is peeling, chipping, chalking, or cracking, or any other paint located on an interior or exterior surface or fixture that is otherwise 

damaged or separated from the substrate. 

Dosimetry badges: Used to determine radiation levels reaching a person’s breathing space. It is 

a small, like a luggage tag, and clips on to a person’s clothing, usually around the lapel. 

Dust wipe sample: A sample of lead dust collected from a surface following a specified procedure. 

Friction surface: An interior or exterior surface that is subject to abrasion or friction, including, 

but not limited to, certain window, floor, and stair surfaces. 

Half-life: The amount of time needed for the activity of a radioactive source to decrease by 

one half. 

HEPA vacuum: A High Efficiency Particulate Air (HEPA) vacuum is equipped with an 

enhanced air filtration device that increases the amount of dust captured by the vacuum. 

Impact surface: An interior or exterior surface that is subject to damage by repeated sudden 

force such as certain parts of door frames. 

Interior window sill: The interior ledge of a window; it is the principal area for collecting lead 

dust samples. 

Lead-based paint hazard: Typically results from deteriorated paint and includes lead-based 

paint chips, lead dust, and lead contaminated soil. 

Lead dust hazard: Surface dust in a residential dwelling or child-occupied facility that contains 

a concentration of lead equal to 40 g/ft2 on floors or 250 g/ft2 on interior window sills based 

on dust wipe samples. 

Lead soil hazard: Bare soil on residential property or on property of a child-occupied facility 

that contains total lead equal to or exceeding 400 parts per million (ppm) in a play area, or an 

average of 1,200 ppm of bare soil in the rest of the yard, based on soil samples. 

Lead inspector: An EPA-certified professional who conducts a surface-by-surface investigation 

to determine whether there is lead-based paint in the home and where it is located. Painted surfaces are inventoried and tested. Soil, dust, and water are not typically tested but are reserved 

for a risk assessor. 

Paint chip: A piece of dried paint. As paint deteriorates, paint chips tend to collect along the 

floor or the exterior perimeter of a house. 

Play area: An area of frequent contact by children less than age 6 as indicated by, but not limited to, such factors including the following: the presence of play equipment (e.g., sandboxes, 

78 Appendix A 
swing sets, and sliding boards); toys; or other children’s possessions; observations of play patterns; or information provided by parents, residents, care givers, or property owners. 

Post-intervention sample (also referred to as “post-mitigation” sample: A sample taken after 

residents have completed the three-step cleaning/HEPA vacuum procedure. 

Reference level(s): Levels set by the Department of Housing and Urban Development (HUD) 

and EPA to indicate surface dust that contains an amount of lead that may pose a threat of 

adverse health effects in pregnant women or children less than age 6. 

Residential building: A building containing one or more residential dwellings. 

Risk assessor: An EPA-certified professional who determines the existence, nature, severity, and 

location of lead-based paint hazards in a residential dwelling. 

Wet cleaning: A method for cleaning lead dust in the home; involves washing surfaces with a 

suitable cleaning agent to dislodge any ground-in contamination; then rinsing with clean water. 

Window trough: For a typical double-hung window, the portion of the exterior window sill 

between the interior window sill and the frame of the storm window. If there is no storm window, the window trough is the area that receives both the upper and lower window sashes when 

they are both lowered. The window trough is sometimes called the window “well.” 

X-ray fluorescence (XRF) instrument: A handheld, battery-powered device used to analyze 

dust wipe samples. The device provides timely and accurate data, allowing inspectors to measure 

parts per million (ppm) lead levels for individual dust wipes within seconds. 

Glossary 79 
Appendix B


Quality Assurance Project Plan 

United States Environmental Protection Agency Region II 

Quality Assurance Project Plan 

For Environmental Monitoring Projects

Revision 02

Syracuse Lead Dust Outreach, Monitoring and Education Project

Theresa Bourbon ________________ _________ 

EPA Project Officer Signature/Organization Approval Date 

Marcus Kantz ________________ _________ 

EPA Quality Assurance Manager Signature/Organization Approval Date 

Betsy Mokrzycki ________________ _________ 

Project Manager Signature/Organization Approval Date 

Rebecca Markus ________________ _________ 

Project Quality Assurance Officer Signature/Organization Approval Date 

80 Appendix B 
1. Distribution List: 

Theresa Bourbon (Terry)

U.S. Environmental Protection Agency

Region 2

2890 Woodbridge Avenue

Edison, NJ 08837

Donna Ringel

U.S. Environmental Protection Agency

Region 2

2890 Woodbridge Avenue

Edison, NJ 08837

Betsy Mokrzycki

City of Syracuse, Department of Community Development

Lead Program

201 East Washington Street

Syracuse, New York 13202

Rebecca Markus

Lead-Safe

2410 East Lake Road

Skaneateles, New York 13152

Community Based Organizations - See Attachment 1 for Addresses:

Southwest Community Center

Syracuse Northeast Community Center

Southeast Asian Center

Boys & Girls Clubs of Syracuse

Brighton Family Center

Girls Inc.

Westcott Community Center

2. Project Description/Background: 

The overall goal of the proposed project is the establishment of a community-based outreach, monitoring, and education effort aimed at reducing exposure to lead dust in residential and public buildings throughout the City of Syracuse, New York. Dust samples will be 

collected from buildings and analyzed for lead content and the results will be provided to 

residents and property owners. All sampling will be coordinated through the City of 

Syracuse Lead Division with assistance from the community organizations and shall include 

sampling before and after the education program to examine the resulting improvement, if 

any. The target buildings will be found in one of the City of Syracuse’s revitalization areas 

and in buildings built prior to 1950. Approximately 350 homes will be included in the project. Users of this data include: residents, property owners, City of Syracuse Lead 

Inspectors, and the general public. An EPA certified risk assessor will collect dust wipe 

samples, and analyze them in the field using an XRF instrument. Samples will be collected 

in accordance with the HUD Guidelines for the Evaluation and Control of Lead-Based Paint, 

HUD Lead Safe Housing Regulation, and EPA TSCA 402. Action levels of concern will be 

based on the HUD Guidelines for the Evaluation and Control of Lead-Based Paint protocol: 

Floors - 40 micrograms of lead per square foot sampled (μg/ft.2), Window Sills - 250 μg/ft.2, 

and Window Troughs - 400 μg/ft.2 When action levels are exceeded, residents and properQuality Assur ance Project Pl an 81 
ty owners will be notified. All participants will be trained in dust control methods and will be 

informed of the HEPA-VAC loaner program. 

If it were necessary to change this QAPP, Terry Bourbon and Betsy Mokrzycki would determine what changes were necessary. Changes would be documented in writing and sent to 

the distribution list in section 1. 

This sampling scheme is designed to be flexible and will be adjusted, as needed depending 

on the correlation of the statistical analyses. All samples will be analyzed using the 

portable XRF. To evaluate the data, some samples will be sent to the lab for confirmation by 

atomic adsorption spectroscopy (AA). A two phase process will be used. Phase I will consist of 100% confirmatory testing for the first 12 homes. This will yield approximately 120 

samples including field blanks. The XRF data will be forwarded to the laboratory so that a 

statistical analysis can be performed. The laboratory will be required to perform an appropriate statistical comparison between the XRF and AA values for the three sets of samples 

in phase 1 (floor, sill and well). 

Phase 1 of our sampling scheme has been completed. Based on our review of the XRF 

and laboratory data from phase 1, (see attachment 8), we have revised our sampling and 

analysis scheme to require confirmation analysis as follows: 

Sample Type XRF Reading Lab Confirmation? 

Floor 40 μg/ft2 Yes 

Floor >40 μg/ft2 No 

Window Sill <100 μg/ft2 No 

Window Sill 100 μg/ft2 and 250 μg/ft2 Yes 

Window Sill > 250 μg/ft2 No 

Window Well <180 μg/ft2 No 

Window Well 180 μg/ft2 and 400 μg/ft2 Yes 

Window Well >400 μg/ft2 No 

In addition to the confirmation analysis described in the Table above, we will also confirm 

10% of the XRF data that is within the acceptable ranges, (i.e., XRF readings that would not 

automatically require lab confirmation). 

The XRF analysis will be made available to the program participants in a written report. 

When lab confirmation is required, lab results will replace the XRF results in the written 

report. Post- intervention sampling will be conducted in 10% of the participating residences. 

Post- intervention sampling will be conducted exactly as the pre-intervention sampling 

described above, once the training and HEPA/Loaner aspects of the project have been inplace at the property for approximately one week. Post intervention sample collection will 

use the same numbering scheme as the pre-intervention sampling, only the starting number 

will be 13, (i.e., principle play area - 13, principle play area interior window sill - 14, etc). In 

addition, two field blank samples will also be submitted. These will be samples 23 and 24. 

82 Appendix B 
The XRF analysis, chain of custody, and bagging of samples, will be the same as the preintervention. 

The results from the post-intervention sampling will also be communicated to program participants in a written report. Post-intervention sampling results will also be used to help 

determine the effectiveness of the project in lowering dust levels within the residence. 

In order to address confidentiality of the participants, the public will receive encoded general 

information in a number of ways. These include monthly Internet updates, poster displays, 

quarterly newsletters, monthly meetings and public service announcements on cable network. Also information will be made available through contractual arrangements with 

Community Based Organizations. 

The success of the outreach portion of the project will be determined by the number of individuals who: 1.) Request inspections, 2.) Utilize the HEPA vacuum through the loaner program, and 3.) Utilize the web site. The success of the educational program will also be 

evaluated by the evaluation of pre/post intervention lead dust levels. 

3. Project/Task Technical Design: 

Residents/property owners of the City of Syracuse will be made aware of this program 

through various project outreach campaigns. Residents/property owners then contact their 

local community-based organization, or the City of Syracuse Lead Division, to express their 

interest in participating in the program. These residents are asked to complete an intake 

questionnaire. This questionnaire is provided to the Lead Coordinator at the City of 

Syracuse Lead Division. The Lead Coordinator schedules an appointment for a Lead 

Inspector/Risk Assessor to visit the property and collect the necessary lead dust samples. 

Lead levels in dust will be measured using a Niton portable XRF. Specifically, dust samples 

will be collected from the following residential locations: floor and interior window sill of principle play area, floor, window sill and window trough of kitchen, floor, window sill, and window trough of youngest child’s bedroom, floor and window sill of next youngest child’s 

bedroom. In most instances we anticipate collecting 10 samples per dwelling. 

Prior to the commencement of work on this project, the laboratory will be required to supply 

either a QA Manual or other documentation substantiating the relevance of its QA procedures 

for this project, certifying that it will use the required methods, stating its calibration frequency, 

etc. 

If some Community Based Organizations wish to evaluate lead dust at their facilities, per 

HUD Guidelines for the Evaluation and Control of Lead-Based Paint and HUD Lead Safe 

Housing Regulations, additional samples will need to be collected. We anticipate that dust 

wipe samples collected in the warmer months will yield higher results, as the windows are 

more likely to be open. (See Attachment Number 6 - Niton R factor data). 

A data report is generated for each residence tested. This report is reviewed and a determination made as to whether or not a lead dust hazard is present. Written reports are then 

provided to the program participant. If a lead hazard is present, the program participant is 

contacted, provided training in the 3-step cleaning method, and informed about the HEPA 

Vacuum loaner program. If the data indicate that a lead hazard is not present, the program 

participant is mailed a copy of their individual report. 

Quality Assur ance Project Pl an 83 
4. Project Organization and Task Responsibilities: See Attachment 7 

5. Special Training Requirements and Responsibility: 

The inspectors will need to be USEPA Certified as Lead Inspector and Risk Assessor. The 

City of Syracuse will keep on file copies of the each inspector’s certificate. As a USEPA certified Lead Inspector or Risk Assessor, one is trained in the basic dust sampling procedures, including chain of custody requirements. In addition, those individuals that will be 

performing the XRF analysis are required by New York State law to be trained by the manufacturer in the use of the Niton instrument and on radiation safety. Proof of all training 

required will be kept on file along with the EPA certificates for each individual inspector. In 

addition to these formal training requirements, the Lead Inspectors/Risk Assessors participating in this project, will be required to read this QAPP and participate in a pre- sampling 

briefing to review these project-specific requirements. 

The contract laboratory for this project will be accredited by the American Industrial Hygiene 

Association, (AHA) and will be New York State Department of Health ELAP approved. 

6. Project Schedule: See Attachment 2 

7. Field Sampling Table or Related Information: 

Sample Analyze/ Total # Sample Type of Sample Holding 

Matrix Parameter Samples Volume Container Preservation Time 

Dust wipe Lead (Pb) 4800-5000 N/A Centrifuge tube N/A N/A 

8. Field Sampling Requirements: 

Required materials: Latex gloves, 1ft2 template, a tape measure, a calculator, masking tape, 

dust wipe media, Niton XRF. 

Sample Collection Procedure: 

The sample collection procedure follows ASTM Method 1728-99 for collection of a surface 

dust wipe. At completion, the dust wipe has been folded three times. For floor samples the 

sample will be taken from inside the 1ft2 template. If the surface to be tested is a window 

sill or well, the inspector will tape off an area of the surface to be tested and measure the 

length and width of this area. This measurement, expressed in square inches, will be divided by 144 and will be recorded on the sample chain of custody that is sent to the lab. 

The observations of the Lead Risk Assessors will be made in accordance with the training 

they have received as part of their ISAPI certification. 

XRF Testing Procedure: 

1. Fold wipe neatly twice more for a total of five folds and place in a plastic bag. 

2.	 Place wipe in a sample holder provided by NITON Corporation. The holder will only shut 

tightly if the wipe was folded neatly. 

3. Place sample holder with wipe into filter test stand provided by NITON. 

84 Appendix B 
4.	 The NITON XRF prompts the operator for four tests, each one on different regions of the 

wipe. The test stand and holder is configured to automatically position the wipe in four 

fixed positions. 

See Attached ASTM Method 1728-99. 

9. Sample Handling and Custody Requirements: 

The collected samples will immediately be placed in plastic bags for XRF analysis. These 

bags will be labeled with a unique sample identification number. Samples will be numbered 

as to the residence number and the specific sample location within the residence, (xxx-xx). 

Residences will be identified in numerical sequence, (i.e., 001- 350). Sample location numbers will be as follows: 01 - principle play area floor, 02 - principle play area interior window 

sill, 03 - kitchen floor, 04 - kitchen window sill, 05 - kitchen window trough, 06 - youngest 

child’s room floor, 07 - youngest child’s room window sill, 08 - youngest child’s room window 

trough, 09 - floor of next youngest child’s room, and 10 - sill of next youngest child’s room. 

Sample numbers 11 and 12 are field blanks. (Note: One field blank will be analyzed for 

every 10 samples sent to the lab). After the XRF analysis is complete, the samples (still in 

the plastic bag) will be placed in a plastic centrifuge tube labeled with the same sample 

identification number as the plastic bag. All the centrifuge tubes a given residence will be 

placed in another plastic bag with the Chain of Custody (attached). The Chain of Custody 

shall be signed by the inspector and shipped via common carrier (i.e. Federal Express) to 

the contract laboratory. Samples that are not being sent to the laboratory for analysis will be 

held in the Syracuse Lead Division’s offices until the final reports are issued. Once the final 

reports are issued, the samples will be discarded. The XRF sample bags will be purchased 

from Niton Corporation. The centrifuge tubes will be provided by the laboratory and are precleaned. 

10. Analytical Method Requirements: 

The laboratory will follow EPA Method SW846-3050 for the digestion of the samples and 

EPA Method SW846-7420 for the Atomic Absorption Spectrometry. Field sampling will be 

done with Niton Portable XRF using the manufacturer’s method. 

The detection limit, precision and accuracy of the AA are acceptable for this project, since 

the methods being used are the standard HUD/EPA methods for lead dust analysis. As 

part of this project, we plan to evaluate the detection limit, precision, and accuracy of the 

XRF by comparing it with the AA method, (see discussion in Section 2). Thus the XRF values stated in the Table below are approximate. 

Sample Analyze/ Analytical Detection Estimated Estimate Action 

Matrix Parameter Method Limit Accuracy Precision Levels 

Dust wipe Lead (Pb)/Niton Niton 20 μg/ft2 25% 40±10μg/wipe floor 40μg/ft

2 

Dust wipe Lead (Pb)/AA EPA SW-846-7420 10 ug/ft2 20% 10± 2ug/wipe sill 250 μg/ft

well 400μg/ft

2 

2 

11. Secondary Data (Non-Direct Measurement) Projects: Not Applicable 

12. Other Data Quality Indicators: 

The purpose of the laboratory analysis is to verify the XRF analysis. The laboratory will follow EPA Method SW846-3050 for the digestion of the samples and EPA Method SW846-

Quality Assur ance Project Pl an 85 
7420 for the Atomic Absorption Spectrometry. Field analysis will be done with Niton 

Portable XRF using the manufacturer’s method. 

a. Representativeness: 

The samples collected are representative of the route of exposure to lead poisoned children, based upon the established HUD Guidelines and EPA Regulations at 40 CAR Part 

745, Requirements of Lead-Based Paint Activities in Target Housing for this type of sampling. See section #3. 

b. Comparability: 

The data we collect will be comparable with other lead dust data collected because we are 

following the same sampling protocols. 

c. Completeness: 

The program anticipates participation by 350 residents/property owners. This represents a 

cross-section of the entire affected population and is based on the City of Syracuse’s experience with the ongoing program knowledge of the population affected with lead poisoning. 

For the primary purpose of this project, the minimum number of houses which participate 

has no bearing on the quality of the data generated. However, a minimum of twelve residences must be tested before a comparison is made of the XRF data and the AA data. The 

results of a minimum of 90% of the AA/XRF samples must be provided prior to the issuance 

of a final report to any program participant. 

Evaluation of the XRF as Action levels will be based on the HUD Guidelines for the 

Evaluation and Control of Lead-Based Paint and HUD Lead Safe Housing Regulations. 

Currently the levels are: floors - 40 μg/ft2

, interior window sills - 250 μg/ft2, and window 

troughs - 400 μg/ft2

. 

13. Peer Review: 

The project proposal that was prepared for this EMPACT project has successfully undergone a peer review. No additional reviews are planned. 

14. See Niton Documents - See Attachments 4 & 5 

15. Assessments/Oversight: 

Terry Bourbon, the EPA Project Officer, will be performing various reviews and audits. If any 

issues need attention from the EPA they will be included in the Quarterly Progress Reports 

to the EPA. Midway through our project’s time span, the EPA Project Officer will plan a site 

visit to review the entire project. This review will include an inspection of project files and 

data reports to insure that the project is being conducted in accordance with this QAPP. A 

report detailing the findings of this review will be provided to the Project Manager from the 

City of Syracuse. 

86 Appendix B 
16. Data Review, Validation and Usability: 

We plan to evaluate the results from the blanks against the results for the samples associated with those blanks. The impact of the blank will be assessed and the data will be qualified, as appropriate. If the sample results are less than ten times the blank, the data will be 

flagged and re-sampling will occur. 

Aside from the XRF and AA comparisons described in Section 2, no additional replicate 

sampling or analysis will be conducted. 

Sample results will be reported individually for each location sampled within a dwelling. 

The following limitations should be considered when data is interpreted: limit of detection, 

calibration of equipment, and condition of the paint. The report template will be translated 

into multiple languages. Project participants will receive relevant reports; other citizens may 

see results and updates via the website. In order to maintain the integrity of the data blank 

samples will be sent to the laboratory and read with the XRF. For each dwelling sampled, 

both residents and owners will be provided with a report indicating the individual sample 

results for each location sampled. 

The affected population will be the children who reside in the City of Syracuse. We will be 

following these HUD regulations and guidelines throughout the course of this project. 

Therefore, the standard default assumptions are applicable to our affected population. 

Data and interpretation will be provided to our primary customers (the public). The data 

interpretation, which will be provided, will be based on the action levels described in section 

2. We are hoping that the public will utilize the HEPA vacuum loaner program and that the 

training provided will be effective in controlling lead dust in contaminated homes. A phone 

number and email address will be provided so that any questions can be answered. 

17. Documentation and Records: 

The information and data will be delivered to the public in a number of ways. The project will 

provide the residents and property owners with a copy of the individual inspection report 

when completed. For Phase I it is anticipated that it will take 5 to 7 days from the day of the 

inspection to the individual receiving the report. The inspection report will consist of the 

sample locations and results highlighting those samples that exceed the federal limit. The 

report will also include any observations the Risk Assessor has made about the general 

condition of the paint, and recommendations regarding the findings. Residents and property 

owners will also receive printed material providing information on how to control lead in their 

home. The specific residential data will be kept confidential and only released to the appropriate family by the City of Syracuse, and the inspectors involved in the project. There will 

be poster displays at community centers, newsletter articles and presentations at community meetings. There will be a project web site, which will contain information and data for 

public access in text and map formats. Finally, all this information will be translated into a 

number of languages so that they are understandable to the non-English speaking populations of the community. 

Data and information on the web site will be updated monthly. Poster displays will be rotated 

at least quarterly. In addition, monthly meetings will be held among the Community Based 

Organizations to review progress, results and problems. 

Raw data, (lab reports and XRF reports) will be kept on file at the City of Syracuse. 

Individual reports will be kept in a secure file for a minimum of 3 years. All reports will be 

stamped, “Confidential,” to insure data is not used for other purposes. 

Quality Assur ance Project Pl an 87 
Attachment 1 

Community Based Organizations 

Southwest Community Center 

401 South Avenue 

Syracuse, New York 13204 

Syracuse Northeast Community Center


716 Hawley Avenue


Syracuse, New York 13203


Southeast Asian Center


503 North Prospect Avenue 

Syracuse, New York 13208 

Boys & Girls Clubs of Syracuse 

375 West Onondaga Street 

Syracuse, New York 13202 

Brighton Family Center 

100 Edmund Avenue 

Syracuse, New York 13205 

Girls Inc. 

401 Douglas Street 

Syracuse, New York 13203 

Westcott Community Center 

826 Euclid Avenue 

Syracuse, New York 13210 

Onondaga County Health Department 

421 Montgomery Street 

Syracuse, New York 13202 

88 Appendix B 
Appendix C


Minneapolis Lead Hazard 

Control Program 

About the Program 

Minneapolis, Minnesota, implemented a Lead Hazard Control Program, a comprehensive monitoring, outreach, and education program to control lead dust in homes, day care facilities, and 

other areas where lead dust is a problem. This program educates businesses and the general public about lead dust poisoning and provides “turnkey” information written for local agencies and 

nonprofit organizations interested in setting up lead centers inside of retail stores in their communities. Lead centers offer information and supplies to help protect children from lead poisoning. Minneapolis’s goal is to eliminate lead hazards by the year 2010. 

Established in 1998, the Lead Hazard Control Program has been well received by participating 

retailers and the general public. As a result of the program’s implementation, the general public 

is increasing its knowledge of lead-based paint and has an effective, affordable, and convenient 

way to clean up potentially harmful lead dust in their homes and apartments. People who were 

potentially creating lead hazards, such as painters and home-remodeling contractors, learn about 

lead-safe work practices. Retailers who set up lead centers at locations such as hardware stores, 

paint stores, and garden centers attract additional customers, which increases their business and 

store sales and engenders good will with their customers. Store staff provide guidance on leadsafe work practices and offer products and resources that are needed for working safely with 

lead, beyond the use of a HEPA vacuum. 

Partner Organizations 

The city of Minneapolis’s Lead Hazard Control Program receives funding from the U.S. 

Department of Housing and Urban Development. Minneapolis also collaborates with a number 

of community, city, county, and state organizations to help fund and realize this effort. 

Identifying the Audience 

Since children under age 6 are most susceptible to lead poisoning, the state of Minnesota passed 

guidelines requiring mandatory blood testing of all children in this age group living in the 

Minneapolis/St. Paul metropolitan area. These guidelines were developed and are being implemented by health commissioners, pediatric doctors, and nurses working with the state health 

commissioner and Department of Health. The city is alerted if lead blood levels exceed 10 

micrograms of lead per deciliter of blood (μg/dL). A letter is sent to parents and the property 

owner is notified if a child tests at a “low level” of concern (10 to 19 μg/dL). Members of the 

child’s household are invited to participate in the HEPA vacuum lender program and are 

offered a free lead dust inspection of their premises. They are instructed with simple steps to 

clean and reduce the child’s lead exposure. For children with elevated blood levels (more than 

15 μg/dL for 90 days), lead inspectors visit the home immediately. Minnesota reports a 90 percent success rate in reaching the homes that need treatment. 

Day care providers are another target for lead dust education in Minneapolis. The program educates the day care provider, who then educates the parents. The program also has enlisted the 

involvement of public health nurses who educate the children in day care settings about the 

importance of washing their hands and taking off their shoes before entering their houses. 

Minneapolis Lead Hazard Control Progr am 89 
Outreach Barriers and Strategies 

The Minneapolis/St. Paul area has the largest Somali immigrant population in the United 

States. Many of these residents are fearful of government and are largely illiterate. In addition to 

reaching them through community-based organizations and with translated material distributed 

in public health clinics, the program is also using local Somali-language cable TV and radio stations. Minneapolis is using donated advertising space to place informational posters in bus stop 

shelters within targeted neighborhoods. Minneapolis finds that free “remnant” (unsold) transit 

advertising space is often available in low-income neighborhoods. 

The city of Minneapolis printed a Guide to Setting Up a Lead Center that explains in clear and 

simple terms the steps involved in setting up and operating a lead center. It covers everything 

from identifying suitable locations, approaching local store owners, educating store staff (who 

play a major outreach role), running the HEPA vacuum rental program, disposing of hazardous 

waste, understanding liability issues, and more. Local retailers, such as hardware stores, paint 

stores, and gardening centers, as well as neighborhood churches and community centers, can 

use this guide to establish and run a lead center inside of their establishments and to implement 

the HEPA vacuum loaner program. The city has educated and trained hardware store personnel 

and has established Neighborhood Lead Centers in several locations. Minneapolis successfully 

recruits these business owners by showing them how they can benefit and how their knowledge 

about lead dust can serve as a marketing tool. 

The lead centers display bilingual brochures and videos about lead poisoning and the treatment 

of lead dust. They also manage rentals of HEPA vacuums. Nine lead centers are currently operating in the Minneapolis/St. Paul area, with several more in the planning stages. In addition to 

the actual HEPA vacuums, the centers are supplied with all necessary equipment and accessories 

such as vacuum filters, wet wipes, disposable gloves, and disposable bags. Minneapolis provides 

each center with standard rental agreement forms, vacuum equipment, supply checklists, 

reorder forms, and standard lead center policy notices for posting. It also provides information 

and training for retail store employees on lead-safe work practices and the HEPA loaner program, which the employees, in turn, pass on to their customers. Additionally, the program provides tips on identifying, approaching, and recruiting potential retail partners, as well as tips on 

program publicity, media relations, and general program outreach. 

Minneapolis also recognizes the important interactive role lead inspectors play. Not only are 

they technical experts and program enforcers, but they also are program ambassadors. Because 

interpersonal skills are so vital, the city is adding requirements to its job description for lead 

inspectors, such as “human relations communication” and “group facilitation” skills, as well as 

an ability to work with people of diverse backgrounds and to resolve disputes. 

Lead Clean-up and Prevention 

To give residents the tools and information needed to clean up lead dust and debris, 

Minneapolis’s Lead Hazard Control Program developed a brochure that succinctly describes the 

important steps for cleaning lead dust. 

Minneapolis lends the HEPA vacuums free of charge but residents pay a $10 filter replacement 

fee. Lead centers might request a deposit to cover the replacement cost of the vacuum cleaner 

($175). The deposit can be used to offset the cost of damaged or lost equipment or accessories, 

and is refunded upon the safe return of the equipment. Customers can borrow the machines for 

90 Appendix C 
a 48-hour period, and centers may charge a late fee for each additional day past due. Each filter 

lasts for approximately five uses, and customers may purchase additional filters if necessary at 

cost using the re-order form provided in the lead center program materials. The organizations 

responsible for the lead centers must visit each center periodically to collect and properly dispose of used filters, as defined by municipality guidelines. 

Hennepin County, Minnesota, accepts used filters as residential waste, but in other municipalities, the lead center must check with its local hazardous waste disposal authority. Airtight containers, buckets, or drums may be used by a lead center to temporarily store used filters. The 

organization sponsoring the lead center is responsible for periodically visiting the centers to collect any generated waste. The centers also must track the number of uses for each filter by writing the address of the user with a permanent marker directly on the filter. 

Results 

On average, 150 children per year are found to have blood levels of 20 μg/dL and 300 are 

found to have a level between 10 μg/dL (the current level of concern as defined by the CDC) 

and 19 μg/dL. But these numbers are still not an accurate reflection of the number of children 

who are actually being exposed to and impacted by lead. In fact, the most recent reports show 

that less than 20 percent of Minneapolis children have a blood lead test. And the Minnesota 

Department of Health reports that 40 percent of Minneapolis’s Somali and Laos population are 

tested positive to have blood lead levels over 10 μg/dL. 

Despite limited funds, the Minneapolis project has already made an impact. The project has 

helped create 14 lead centers throughout the Minneapolis area over the last five years. And lead 

programs all over the nation contact the Minneapolis program’s leaders all the time asking for 

guidance and assistance. 

Awards and Recognition 

In May 2001, the Minneapolis Lead Hazard Control Program received the 2001 Lead Star 

Award presented by the National Lead Assessment and Abatement Council. 

For More Information 

Johanna (Jo) Miller 

Project Coordinator 

Children’s Environmental Health 

Minneapolis Environmental Services 

250 South 4th Street, Room 401 

Minneapolis, MN 55415 

612 673-3856 

Minneapolis Lead Hazard Control Progr am 91 
Appendix D


EMPACT Lead-Safe Yard Project in

Boston, Massachusetts 

About the Program 

The EMPACT Lead-Safe Yard Project (LSYP) in Boston, Massachusetts was a three-phased, 

community-based program that used a variety of low-cost techniques to reduce children’s exposure to elevated levels of lead in residential soil. The project’s goals were (1) to generate real-time 

data of lead concentrations in residential yard soils using innovative field-portable x-ray fluorescence (XRF) technology and to communicate these data to residents; (2) to plan and implement 

low-cost and sustainable landscape measures in residents’ yards that would reduce children’s risk 

of exposure to contaminated soil and that residents would be taught to maintain; and (3) to 

develop a template that other communities and public agencies can use to address the issue of 

lead in residential soil. Each partner organization was assigned tasks to implement, including 

outreach and education, safety training, sampling and analysis, soil mitigation, and creation of a 

template for community action. 

Partner Organizations 

During the pilot phases, the project’s community partners in the Boston area were Boston 

University School of Public Health, the Bowdoin Street Community Health Center, and two 

non-profit landscaping companies, Dorchester Gardenlands Preserve and Garden Futures. 

Identifying the Audience 

The initial target community selected for the first two phases of the project was a several-block 

area in the Bowdoin Street neighborhood, consisting of approximately 150 mostly older, woodframed houses in the North Dorchester section of Boston. This is an inner-city community, 

with a large minority and immigrant population. Bowdoin Street is situated in the “lead belt” of 

Boston, where the majority of children in the city with elevated blood levels reside. 

During the third phase of the project, the program targeted a different community—the 

Dudley Street neighborhood—which is also located in the lead belt of Boston. 

Outreach Barriers and Strategies 

In an effort to gain support for the project, EMPACT LSYP followed a model commonly used 

for community education and outreach: a bilingual outreach worker from the community 

health center conducted typical outreach activities, including walking in the neighborhood, 

knocking on doors, distributing flyers, speaking at community meetings, and talking with people one-on-one. These efforts were culturally specific to the neighborhood and conducted at an 

appropriate literacy level. 

After Phase 2 of the project was completed, outreach workers returned to the homes where yard 

work had been performed and interviewed its occupants. They found that people had not really 

comprehended the lead problem, but viewed the project more as a landscaping program. To 

remedy this, the outreach worker underwent more extensive training on the lead issue and then 

returned to the site with a video to teach residents about the hazards of lead. After viewing the 

video, the residents were given a short quiz, and then had the opportunity to discuss the topic 

afterward, thereby utilizing three modes of learning: visual, written, and oral. 

92 Appendix D 
Soil Sampling and Analysis 

After outreach workers completed their interviews and created a list of participants who agreed 

to have their yards tested for lead, the soil sample and analysis began. EMPACT LSYP found 

XRF testing to be an effective tool that gives results on the spot. This process allowed trained 

inspectors to get timely and accurate onsite readings of lead levels in soil with a hand-held, battery-powered device. Onsite inspectors were able to get real parts per million (ppm) lead levels 

for individual soil samples within seconds. This way, lead inspectors could discover any unusually high lead levels right away as opposed to waiting two to four weeks for laboratory results to 

come back. And, if necessary, inspectors could adjust their testing strategy for the property 

accordingly as a whole, taking appropriate precautions. After all readings are taken, inspectors 

produced a color-coded map of a property’s lead levels well before the results of confirmatory 

lab tests were available. 

Once a sizable cross-section of properties was tested, inspectors could record the results on a 

map to see if a geographical pattern emerged. If such a pattern did emerge, then this information could be made accessible to the public. 

Remedial Measures and Yard Treatments 

After a property’s soil had been tested and confirmed for lead hazard, the next step was to set up 

a yard treatment schedule. The EMPACT LSYP targeted areas such as drip zones and removed 

plants and vegetables in those areas, replacing them with raised-perimeter boxes milled with 

mulch or gravel and plantings. The program also improved existing lawns by loosening soil, 

adding a seed mixture of rye, fescue, and bluegrass, topping the new seed with 1⁄4 inch of topsoil. Where appropriate, the program installed new lawns on raised beds and created raised 

mulch beds with or without plantings. Parking areas needed to be graveled or asphalted. 

Children’s play areas needed to be raised and covered with mulch over filter fabric weed barrier. 

Porches with open soil areas underneath had to be barricaded with lattice and trim. EMPACT 

LSYP used only ACQ pressure-treated wood, as opposed to wood treated with chemicals such 

as arsenic and chromium which would have created another soil hazard. 

Results 

The pilot project was funded in two phases, which took place in the summers of 1998 and 

1999. During these two years, the project addressed 42 residences at no cost to the homeowners; conducted a number of seminars on lead-safe yard work; and developed a “Tool Kit” for use 

by other communities, which were then incorporated into a handbook titled Lead-Safe Yards: 

Developing and Implementing a Monitoring, Assessment, and Outreach Program for Your 

Community. 

Phase 3, completed in 2001, addressed 19 homes. And, in conjunction with the EMPACT 

project, the city of Boston completed 24 homes during the same period. 

Awards and Recognition 

Because of the EMPACT LSYP’s innovative approaches and far-reaching impacts, project partners have received several prestigious awards for their work. These include: 

•	 1999 Regional Science Award. Two scientists from EPA’s Office of Environmental 

Measurement and Evaluation also received EPA Bronze Medals for this work. 

EMP ACT Lead-Safe Y ard Project in Boston, MA 93 
• 1999 Harvard Award for Excellence in Children’s Health. 

•	 2000 Boston University School of Public Health Award for Excellence in Public Health 

Practice. 

For More Information 

Visit the EMPACT Lead-Safe Yard Project’s Web site at <www.epa.gov/region01/leadsafe> or 

contact: 

Robert Maxfield 

Environmental Investigation and Analysis


EPA-New England Regional Laboratory


11 Technology Drive


North Chelmsford, MA 01863-2431


617 918-8640


94 Appendix D 
Appendix E


Memorandum from Elizabeth Cotsworth,

Director, Office of Solid Waste 

July 31, 2000 

MEmor andum from Elizabeth Cotsworth 95

96 Appendix E 
MEmor andum from Elizabeth Cotsworth 97 
98 Appendix E 
MEmor andum from Elizabeth Cotsworth 99 
Office of Research and 

Development 

National Risk Management 

Research Laboratory 

Cincinnati, OH 45268 

Official Business Penalty for Private Use $300 

EPA/625/R-02/014 February 2003 

EPA/625/R-02/014 Developing and Implementing a Lead Dust Monitoring, Outreach, and Education Program in Your Community 

Please make all necessary changes on the below label, 

detach or copy, and return to the address in the upper 

left-hand corner. 

If you do not wish to receive these reports CHECK HERE ❒; 

detach, or copy this cover, and return to the address in the 

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EPA 

PERMIT No. G-35