13.1 Need for Ongoing Monitoring and Evaluation Ongoing monitoring and reevaluation procedures are used in facilities in which potential sources o f lead hazards have not been controlled. These procedures are intended to verify that previously instituted control measures remain effective and new lead hazards are detected in a timely manner. Figure 13.1 provides an overview o f the ongoing monitoring and
reevaluation process. Ongoing monitoring and reevaluation should be conducted in accordance with the HUD Guidelines, Chapter 6.
13.2 Frequency of Reevaluations
Reevaluations occur at specific intervals; these intervals are defined by standard reevaluation schedules. Standard reevaluation schedules are based upon the likelihood that a dwelling contains or will contain leaded paint haTards.
13.2.1 Using Standard Reevaluation Schedules Standard reevaluation schedules are based on the following principles:
Well-defined reevaluation intervals are needed to ensure consistency across dwellings and to provide clear criteria for risk assessors to
determine when a unit should be reevaluated.
9 Dwellings that pass a risk assessment or reevaluation require less frequent reevaluations than dwellings that fail.
The presence o f leaded dust in excess of applicable standards shortens the reevaluation interval since it indicates an immediately available source o f exposure for occupants, especially children.
The expected duration o f hazard control actions affects the reevaluation interval; less frequent reevaluation is needed when more permanent abatement methods are implemented over interim controls that have a shorter life span. For example, a longer reevaluation interval is specified when windows with lead-based paint are
Figure 13.1: Ongoing Monitoring and Reevaluation
Perform ongoing monitoring and reevaluation per HUD Guidelines
Do visual surveys at least annually, on turnover, and upon significant
paint or substmte damage
Reevaluate facilities per HUD Guidelines and protocols o f rules or
compliance statements
Assess encapsulated surfaces per HUD Guidelines and applicable rules
Evaluate new or recurring lead hazards. Perform sampling and
analysis
II
~d
Review classification; as needed, reclassify facility and change baTard
management program
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Copyright 9 2000 by ASTM International www.astm.org
9 replaced since windows are thought to be significant sources o f leaded dust.
If all lead hazards are controlled through encapsulation or enclosure (and leaded dust levels prior to hazard control were below the standard), then only annual visual surveys are recommended because failure o f these methods can usually be visually determined.
Repeated reevaluation failure will result in the assignment o f the shortest possible reevaluation interval and may be an indication that the selected hazard control measures are inadequate for the unit in question.
Full removal o f all lead-based paint requires no reevaluation or monitoring, since new hazards are very unlikely.
Table 6.1 of the HUD Guidelines is a useful reference to determine the reevaluation schedule for each facility or building.
13_3 Conducting the Reevaluation
Reevaluations are used to determine if the following conditions have reappeared:
, Leaded dust above applicable standards.
, Deteriorated paint films with known or suspected lead- based paint.
, Deteriorated or failed interim controls, or encapsulant or enclosure treatments.
, New bare soil with lead levels above applicable standards.
These conditions can be detected through a visual
examination, as well as through the use o f limited dust and soil sampling.
13.3.1 Visual inspection by the certified risk assessor Prior to beginning a visual survey the certified risk assessor should begin by reviewing any past risk assessment, paint inspection, clearance, and reevaluation reports. If any other information regarding lead haTard control actions in use is available, it should also be reviewed. A careful visual examination o f all control measures and any known or suspected lead-based paint should then be conducted to determine if the paint is still intact and the controls are well maintained. If any lead hazard control measure is failing (e.g., an encapsulant is peeling away from the wall, a painted surface is no longer stabilized, or an enclosure has been breached), the risk assessor conducting the reevaluation should identify acceptable options for controlling the hazard.
I f a paint inspection was conducted previously, the risk assessor should use this information to discover whether any o f the surfaces known to contain lead-based paint are now in deteriorated condition. If no inspection has occurred, then the assessor should assume that all painted surface contain lead- based paint and should consider any deteriorated paint to be a newly identified lead hazard. Alternatively, the deteriorated paint can be measured by x-ray fluorescence (XRF) or paint- chip laboratory analysis.
13.3.2 Dust Sampling
When all lead hazard controls have been visually examined and appear to be in place, the risk assessor can begin dust sampling. If lead hazard controls are not in place, they should be repaired before any dust sampling occurs. Dust
measurements are intended not only to determine the effectiveness of the control measures in use, but also to determine if leaded dust has reaccumulated from other sources.
For reevaluations composite dust sampling is sometimes used as a cost-effective measure. At least two composite samples should be taken; one from floors and the other from either interior window sills or window troughs. The rules on composite dust sampling can be found in Chapter 5 o f the HUD Guidelines. Samples should be collected as outlined in Chapter 5 of the HUD Guidelines, or from any other area based on the professional judgment o f the risk assessor, that may contain elevated leaded dust levels.
NOTE TO REVIEWERS: Comments are requested on the use of composite samples for dust samples.
13_3_3 Soil Sampling
Soil sampling is not usually conducted for reevaluation, since the visual examination will discover if previously covered areas are now bare or if the interim controls used to cover soil are not working. If bare spots are identified, the risk assessor should recommend that the owner cover the bare spots and conduct more frequent (e.g., monthly) visual surveys to ensure that the soil stays covered. If the visual surveys indicate that the soil is not staying covered, more permanent soil treatments should be recommended (i.e., paving or removal)
13.3.4 Assessing previously encapsulated surfaces Visual monitoring should be performed one month and six months after application o f the encapsulant, then at the schedule specified in Chapter 6 o f the HUD Guidelines, Table 6.1.
I f during reevaluation examinations signs o f wear and tear are apparent, the monitoring should be increased to a quarterly
basis for the next six months, then annually thereafter.
Residents should be instructed to notify management if there is a need for repairs, on a timely basis, to prevent the
development of a leaded paint hazard due to encapsulant deterioration.
It is important to note that in some cities and states, regulatory reexaminations may be required, including sampling o f settled dust for lead analysis. As always the most stringent
reevaluation procedure should be followed.
With each reassessment o f an encapsulated surface a visual monitoring form should be filled out and kept on record by the owner. This document should include the name o f the person performing the periodic visual monitoring, the date o f the visual monitoring, the condition o f the coating and signs o f wear or deterioration, and results o f any leaded dust tests performed. Ifencapsulant failure is observed or the encapsulant has been repaired, the reasons for failure (if known), corrective actions recommended or taken to repair failures, and any other information pertinent to the
maintenance o f the encapsulant should be included.
13.3.5 Other reevaluation criteria
The risk assessor must evaluate previously controlled hazards, but also identify new hazards. If deteriorated paint is
discovered and no previous information exists about the lead content o f that paint (or the information is inconclusive), the risk assessor should recommend that the spot be either tested or stabilized. If the paint contains lead above the applicable standard, the risk assessor should provide the owner with a range o f interim control and abatement options.
13.4 Interpretation and Reporting of Results The risk assessor conducting the report should produce a report documenting the presence or absence o f leaded paint hazards. The assessor's report should identify any lead hazards previously detected and controlled and the efficacy o f these interventions. Any new haTards should also be described and the risk assessor should present the owner with suggested control options and their accompanying reevaluation
schedules. In all cases the report should identify when the next reevaluation should occur, if further monitoring is necessary.
Based on the revaluation results the facility may be reclassified, as appropriate. Facilities that are reclassified from Class A or B to Class C do not require future evaluations.
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MNL38-EB/Mar. 2000