IS LEAD CERTIFICATION REQUIRED FOR THE WORK I DO?
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There are some situations in which you are legally required to be CDPH Lead-Related Construction (LRC) certified. Even if certification is not required in your situation, CDPH encourages you to become trained and certified to help protect yourself, your family, and your clients from lead poisoning. The following questions may help you decide if you need to be certified.
Will you be inspecting for lead or doing clearance testing in California?
If you plan to receive pay for doing lead inspections, lead risk assessments, or lead clearance inspections, in residential or public buildings in California, State law requires you to be a CDPH LRC-certified Inspector/Assessor. You may be a Certified Lead Project Monitor if you plan to do only clearance inspections (Title 17, CCR, Section 36100(a)(1)). This law does not apply to:
- Personal air monitoring done to ensure Cal/OSHA compliance
- Sampling to determine adequacy of containment
- Representative sampling of materials removed from a building done to determine applicability of hazardous waste requirements. See the further explanation below in the "You may not need to be certified" section.
Some examples of hazard evaluations that may require certification include:
- An owner wants to inspect some housing for lead related to the (Residential Lead-Based Paint Hazard Reduction Act of 1992; Title X, Section 101). In California, this Federal rule also gives home buyers a full 10 days to inspect a home for lead, provided the inspection is conducted by a CDPH LRC-certified Inspector/Assessor.
- A potential buyer wishes to assess possible environmental liability through a Phase I/II Environmental Site Assessment (ESA). If the ESA addresses lead, and the site includes residences, or does or will allow public access, the individual must be a CDPH LRC-certified Inspector/Assessor.
- A property owner wishes to ensure there are no lead hazards in the buildings. The person performing the risk assessment must be a CDPH LRC-certified Inspector/Assessor.
Will you be designing lead abatement projects in California?
If you plan to prepare or design plans for abatement, reduction, or elimination of lead-based paint, lead-contaminated dust, or lead-contaminated soil from residential or public buildings in California, State law requires you to be a CDPH LRC-certified Lead Supervisor or Project Monitor (Title 17, CCR, Section 36100(a)(1)).
Will you be working to reduce lead in California?
If you plan to do any work designed to reduce or eliminate lead-based paint, lead-contaminated dust, or lead-contaminated soil in or on residential or public buildings in California, State law requires you to be a CDPH LRC-certified Lead Supervisor or Worker (Title 17, CCR, Section 36100(a)(1)). Certification is not required for those conducting abatement activities, also known as "interim controls," which are designed to reduce or eliminate lead hazards from a building for less than 20 years. However, other requirements in Title 17 still apply.
Will you be doing lead work in a school?
If you plan to inspect for lead or to reduce or eliminate hazards from lead-based paint, lead-contaminated dust, or lead-contaminated soil on or in a public elementary school, pre-school or daycare center, the California Education Code, Section 32243(b) requires you to be trained and CDPH LRC-certified. Public schools are those that are funded by the State or Federal government.
Will you be exposed to airborne lead dust?
If you will be working in a residential or public building and the lead-related construction work you plan to do will expose you to airborne lead at or above the 8-hour permissible exposure limit (PEL) of 50 µg/m3, California OSHA's Title 8, California Code of Regulations Section 1532.1 requires you to be trained and CDPH LRC-certified. Check with your health and safety supervisor about the air monitoring results for your job site. You can also contact the California Department of Public Health, Occupational Lead Poisoning Prevention Branch at (866) 627-1587 for more information about the Cal/OSHA regulations.
Are you doing work on a HUD project?
If the lead-related construction project you plan to do is funded by the U.S. Department of Housing and Urban Development (HUD), or if the work will be done in HUD-funded housing, HUD policies may require you to be certified. For example, HUD requires certification for pilot lead abatement projects. Check with your HUD contact person about whether certification is required for your project.
Do your work specifications require certification?
Many private and public agencies, such as city or county governments, lenders and funding agencies, require certification for lead-related construction personnel. Read the specification carefully, or check with your local development agencies, lenders, and funders before you bid on a job, to see if certification is required. Remember that training alone does not count as CDPH LRC certification.
Some work activities involving lead-based paint and lead hazards do not require you or your employees to be CDPH LRC certified. Listed below are some such situations. For more information, call the Lead-Related Construction Information Line at 1-800-597-5323 and ask to speak to a specialist about whether you need to be CDPH LRC certified.
Although CDPH LRC certification may not be required for the type of work you plan to do, you still have to comply with Cal/OSHA standards, California Health & Safety Codes, or other regulations when working with lead hazards.
Commercial/Steel Structure Work
CDPH LRC certification is not required for work done on steel structures, unless the structures are public buildings or residences. If you do lead-related construction on industrial buildings, warehouses, factories, storage facilities, ships, bridges, tanks, towers, or other buildings that are non-residential and generally not open to the public, you are not required to be CDPH LRC certified.
General Industry Work
California Title 17 regulations apply only to work done in the lead-related construction field. If you work with lead in an industrial setting, such as in battery manufacturing, radiator repair, metal working, electronics manufacturing, foundry work, or welding, you are not required to be CDPH LRC certified.
If you use lead in your hobby, such as stained glass, fishing, or lead-toy casting, you are not required to be CDPH LRC certified.
Cal/OSHA Compliance Testing
You are not required to be a CDPH LRC-certified Lead Inspector/Assessor in order to collect air samples for personal air monitoring to test worker lead-in-air exposure.
Waste Segregation Sampling
You are not required to be a CDPH LRC-certified Lead Inspector/Assessor in order to do representative sampling of materials removed from a building done to determine applicability of hazardous waste requirements. The exemption does not apply to materials or components still affixed to a structure. Examples of such sampling include:
- Solid waste (SW-846) testing of removed components or debris to determine total metal concentration
- Waste Extraction Testing (WET) or Total Characteristic Leaching Procedure (TCLP) testing of removed components to determine soluble metal concentration.
Testing Your Home for Lead
Only those who are paid to do lead inspections are required to be CDPH LRC-certified Inspector/Assessors. This means that as a homeowner, you may take paint chip samples, dust wipe samples, and soil samples, and use lead testing kits to check for lead hazards in your home or yard without being CDPH LRC certified.
Temporary Lead Hazard Control Measures
In some cases, CDPH LRC-certification is not required for those who design or work on projects intended to reduce lead-based paint, lead-contaminated dust, or lead-contaminated soil from a residential or public building if the results are designed to last for less than 20 years. Such work, involving methods often called interim controls, is designed to make buildings lead-safe by temporarily controlling, but not permanently removing, the lead-based paint or lead hazards.
If you perform projects using interim controls to abate lead-based paint or lead hazards, you must follow the guidelines outlined in Chapter 11 of the U.S. Housing & Urban Development (HUD), Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing (also available from HUD User at 1-800-245-2691). You must also comply with California's work practice regulations for lead-related construction (Title 17, CCR, Sections 36000 and 36100) including notifying CDPH of abatement activities and using containment and work practices that prevent lead-contaminated dust, soil, or paint debris from spreading to non-work areas.