Document jgQooDLXZYj4Xv6ZROwDw7OB9
ft E A ~ United States
.._.,.~
Environmental Protectior
,,.,
A9ency
Region 6 - Enforcement & Compliance Assurance Division
INSPECTION REPORT
Inspection Date(s): Media Program: Regulatory Program(s)
Company Name: Facility Name: Facility Physical Location:
(city, state, zip code) Mailing address:
(city, state, zip code) County/Parish: Facility Phone Number Facility Contact:
//2023 Toxic Substance Control Act Renovation Repair and Paint (RRP)
tZtZ tZtZ E'Zd^tW 'Wdy
d dK
ZZZZZ
I I WZ Manager
FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC:
N/A N/A N/A 236220 1541
Personnel participating in inspection:
Angela Hays
EPA Region 6
Stan Lancaster
EPA Region 6
Kiera Hancock
EPA Region 6
dK DZZZ
tZ tZ tZ tZ
EPA Lead Inspector Signature/Date
ANGELA
HAYS
Inspector Inspector Inspector WZ Manager D
Digitally signed by ANGELA HAYS Date: 2024.02.05 10:32:13 -06'00'
Supervisor Signature/Date
Angela Hays /Date
Digitally signed by H
H STUCKEY Date: 2024.02.05 STUCKEY
13:32:02 -06'00'
Troy Stuckey / Date
6ENFORM-019-R8.2 (02/12/2020)
1
Section I - INTRODUCTION
tZtZ /Z
PURPOSE OF THE INSPECTION
The focus of the inspection was to evaluate compliance to the Toxic Substances Control Act (TSCA) Renovation Repair and Paint (RRP) rule, codified at 40 C.F.R. 745, Subpart E. The inspection concentrated on work on properties defined as "target housing", i.e., properties constructed prior to 1978. The facility regularly preforms work on pre-1978 homes located in Environmental Justice areas. The company was investigated due to aZZ complaint received by the region in EZ 202ZZZ
FACILITY DESCRIPTION
tZtZ is located at '^tW'Wdy The facility specializes in window replacement for the &ZtZZZ
Section II - OBSERVATIONS
On /2023 EPA inspectors Angela Hays, Kiera Hancock and Stan Lancaster visited WindowtZ n 'Wdy The inspectors presented their credentials to MdK WZ Manager tZtZ. The inspectors explained the purpose of the TSCA RRP inspection. M. K ZZDZZZDZtZtZZZ ZZDZZZZZDK ZZZDKked to sign a Notice of Inspection (NOI) (Attachment 1) and answer questions about the type of work tZtZ Z
MKwaable to provide documentation of Firm Certification training recordsZ ZZZZZZ at the time of the site visit.
MKwcooperative with the inspectors and answered questions asked by the inspectors. The inspection checklist was filled out and is attached as Appendix 2.
Section III - AREAS OF CONCERN EZZZZZZ
tZtZ /Z
Section IV - FOLLOW UP EZZZZZ.
EZZ/Z >WZZZZW ZZ
tZtZ /Z
Appendix 1
Notice of Inspection
; PA
U111led StAI
ENVIRONMEN AL PROTECTION AGENCY
W -;hlngton, DC 20460
Notice of Inspection
Office of Enforcement and Compliance Assurance
Ir Vl?Si at n Id nt ( cat 011
ln~pectlon, umb r [ Daily Seq Nllmber
C _ _] I.__,__/_ __,I
nspeco ~ Address
_!11J~_Ahc;C1J;ifi('L- - = - - - - - ~
1 4. Facility Address
I 12u1 Clt-n ir..ur-
I ;:;...
4 ,~N?rhd- 5 w /JA::Z{,):t,,/
.,1.tf~O
~4/(A S" '/X
7. ? - -- - - - - = = ~~ ,_a_'rf_a_n_tl r/~dt _.L.:.!.JeQ.~-=- ~-=---:'.'."::-=~
1
or Int mal EPA Use. C.:>p1es may be rro v t d ~ ec,pIent as;kn:;;vledgment of thrs notr.. .
___j
Reason for Inspection
u de 'le authortty of Section 11 of the Toxic Substances Cont1ol Act
For the p u rpose of Inspecting (including taking samples, photographs, statements and other inspection actlv,ttes) an
establ shment, fac1hty or other premrses in which chemical substances or m ixtures, articles containing same are
manufactured , rocessed, stored or held before or after their distr1but1on in commerce (Including records, flies. papers,
t processes, control and facilities) and any conveyances being used to transport chemical substance, mrxtures or articles
conta1n1ng same In connection with their distnbutron tn commerce (including records, fries, papers, processes, controls and
fadht es) beartng on whether the requirements of the Act are applicable to the chemical substances, mixtures or articles, wlthm, or associated with, such premise or conveyance have been complied with.
L In addition, thi s tnspectlon extends to (che<:k appropnate blocks):
O A Financial Data 0 B. SaleS Data
D D. Personnel Data O E. Research Data
O C. Pricing Data
The nature and extent of InspectIon of such data specif red ,n A through Eabove Is as follows
Inspector's SIgnatu1e
S ve Fo1m
Print Form
l 11111oP(lor t<>py l r lty
tZtZ /Z
Appendix 2
RRP Checklist
ft
U.S. EPA
,ector Name ector Telephone
Ins' Ins Ins
Name Address Contact Name Contact Telephone Contact Email Mana Manae:er Telephone
Lead Renovation/Repair/Painting Compliance Checklist - Renovators
US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202
TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION Renovation Firms & Renovators Inspection Checklist
Firm Information
EPA Firm Certification Number Nature/Description of Work
OPENING CONFERENCE Comments
Permission to enter granted
J;;;,;-t,,,1/1~-tf-<.) !f.Je.Jt i / ~
Page 1 of 33
COMPANY NAME. ~a,1kimpectio;o i (/~ W lua, ld
ft
Lead Renovation/Repair/Painting Compliance Checklist - Renovators
US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202
U.S. EPA
TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION
signed Permission to enter document y
y Facility/operator provided copy of
entry document
/ Copy of Lead Base Paint Pamphlet rovided
The items identified in this inspection have the potential to incur civi l penalties in the amount identified. Your finn has 90 days in which to submit
proofthat the items identified have been corrected. These deficiencies are of a serious nature and if left uncorrected could result in formal
enforcement action. Your response should be submitted to:
~ ? - . Gharles lhrnes .A tiv<
1 , l-fL.P/ civarf.u-5 ~~ec..a:/ 1Y7 ~>-1
6EN-HI_
1:'J . tu;'S .
(e-rytotr~r?tPl/t:i-rt://'5 a-1 -1-k 7h {!if.es. Cur~ /db (}J,rbj~cr75.
US Environmental Protection Agency Region 6
0 f~ ~t'wur {;,t,-f,.,L/,,,,_ f
,A - J ,_,_/ / <
/1
,,_j
~ c -t:s _ ,~~ v'<.uf' '<'or? L-?<"b. ~n,,"7 ~
/u~v<->
W1;,,,1;:/ c .
1-4-4-5-R-ess Avenue /:J..()/ Clrr7 Srr,u.,/;-
~ ;. - 1
Dallas, TX 75202
/ofl fV /1151..a1t,~175 cru.. 6tn/4t..Jd/ on. t rlb 511-.c. Ill/ '.Sf4,Lf" /..5 t 5 / {',<1/f!&f_
.. 0 - Zo juh .5/f~.s (!M,.-lv,Y-c:t:I /'r cuo/,
,
C~py of inspection checklist and on-site report sent to:
'
(l) (u;u~f-td ~~ /41 f CV'fy.u./ ~.vt,:,v.1:Av-:5 .
Prmt Name: _ _ _ _ _ _ _ _ _ _
Date ____
f
Email:- - -- -- - - - - - -
#
Reg Ref
1 40 C.F.R.
745.84(a){l)
INFORMATION DISTRIBUTION REQUIREMENTS
Question
Y-N-N/A Mai-Sig-Min
Renovation in Dwelling Unit: Did the
renovator/property owner/property manager provide the
owner of the unit with the EPA-approved lead hazard
information pamphlet?
H-M-L
Potential Penaltv
COMPANY NAME: Bl<mk-lnspettion
Page 2 of 33
lu--01,?w 4,)(1.,/j
ft
U.S. EPA
Lead Renovation/Repair/Painting Compliance Checklist - Renovators
US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202
TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION
Comments
2 40 C.F.R. Renovation in Dwelling Unit: Did the
adult occupant of the unit (if occupant is not the owner) 745.84(a)(2) renovator/property owner/property manager provide the j
with the EPA-approved lead hazard information
pamphlet?
Comments
3 40 C.F.R.
Renovation in Common Area: Did the renovator
745.84(b)(l) provide the property manager/owner of the multi-family
housing with the EPA-approved lead hazard
\1~
information/pamphlet and/or to post informational
siims?
Comments
4 40 C.F.R. Renovation in Common Area: Did the
745.84(b)(2) renovator/property manager/property owner noti fy in
~,~
writing, or ensure written notification of, each unit of
the multi-family housing and make the pamphlet
available upon request prior to the start of the
renovation, and/or post informational signs?
Comments
5 40 C.F.R. Renovation in Child-Occupied Facility: Did the
) building in which the chi ld-occupied facility is located 745.84(c)(l)(i renovator/property manager provide the owner of the ~\~
with the EPA-approved lead hazard information
pamphlet?
Comments
Page 3 of33
COMPANY NAME: Blank lRspeetieFt If ',tN1d"1a l /1 brlef
ft
U.S. EPA
Lead Renovation/Repair/Painting Compliance Checklist - Renovators
US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202
TOXIC SUBSTANCES CONTROL ACT
TITLE IV-LEAD HAZARD REDUCTION
6 40 C.F.R. Renovation in Child-Occupied Facility: Did the
i) adult representative of the child occupied facility with 745.84(C)(1 )(i renovator/property manager/property owner provide an ~{~
the pamphlet, if the owner is not the operator of the
child-occupied facility?
Comments
7 40 C.F.R. Renovation in Child-Occupied Facility: Did the
745.84(c)(2) renovator/property manager/property owner provide the
parents and/or guardians of children using the child- ~!~
occupied facility with the pamphlet and information
describing the general nature and locations of the
renovation and the anticipated completion date, by
mailing or hand-delivering the pamphlet and renovation
information, or by posting informational signs
describing the general nature and locations of the
renovation and the anticipated completion date, posted
in areas where they can be seen by parents or guardians
of the children frequenting the child-occupied facility,
and accompanied by a posted copy of the pamphlet or
information on how interested parents or guardians
can review a copy ofthe pamphlet or obtain a copy from
the renovation firm at no cost to the parents or
guardians?
Comments
l 8 40 C.F.R. 745.85 (1)
all renovations: did the renovator post signs clearly defining the work area and warning occupants and other persons not involved in renovation activities to remain
outside of the work area; to prepare, to the extent
Page 4 of 33
COMPANY NAMF: alaok ln&13cetio11 ,d),J.a1~ lu(jYLJ
ft
U.S. EPA
Lead Renovation/Repair/Painting Compliance Checklist - Renovators
US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202
TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION
Comments
practicable, signs in the primary language of the occupants; and/or to post signs before beginning the renovation and make sure they remain in place and readable until the renovation and the post-renovation cleaning verification have been completed?
TEST KITS
# Reg Ref
Question
Y-N-N/A Mai-Sig-Min H-M-L Potential Penalty
1 40 C.F.R. 745.88
all renovations: did the renovator/firm use an epa
approved dust test kit when determining the presence of ~[ ~
lead? was there a potential where the test kit result
provided a false negative result for lead (i.e., no lead)?
Comments
2 40 C.F.R. 745.88
all renovations: did the renovator/firm use an epa approved dust test kit when determining the presence of lead, where the test kit provided an accurate result for
01~
the oresence of lead?
Comments
FAILURE TO ALLOW ACCESS TO RECORDS OR REFUSAL OF AN INSPECTION
# Re2Ref
Question
Y-N-N/A Ma_j-Sig-Min H-M-L Potential Penaltv
1 40 C.F.R. all renovations: did the renovator/property
745.87(C)
owner/property manager refuse to permit entry or
~
inspection? failure or refusal to pennit entry or
insoection is also a violation of tsca 15 and tsca 409.
Comments
COMPANY NAME .,,Blaflk In
Page 5 of 33
l0s,aD a/r, t,> ()Ja:c(J
ft
U.S. EPA
Lead Renovation/Repair/Painting Compliance Checklist - Renovators
US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202
TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION
2 40 C.F.R. target housing and child-occupied facilities: did the
745.235(C) renovator/property owner/property manager refuse to
permit entry or inspection, as required by 40 c.f.r. 40 C.F.R. 745.237 and section 11 of tsca (15 u.s.c. 2610)? ~
745.237
failure to allow entry and inspection is a prohibited act
under sections 15 and 409 of tsca (15 u.s.c. 2614,
2689).
Comments
FAILURE TO ESTABLISH AND MAINTAIN RECORDS, .FAILURE OR REFUSAL TO MAKE RECORDS AVAILABLE
# Reg Ref 1 40C.F.R.
Question All Renovations: Did the renovator/finn/property
Y-N-N/A Mai-Si2-Min H-M-L Potential Penalty
745.237
0
maintain records, or to make available such records? owner/property manager fail or refusal to establish and ~
Such failure or refusal is a violation of TSCA ~ 409.
Comments
2 40 C.F.R. Target Housing and Child-occupied Facilities: Did
745.225, 745.226,
or refuse to establish, maintain, provide, copy, or permit the renovator/firm/property owner/property manager fail ~
and/or
&745.227
access to records or reports?
Comments
ACKNOWLEDGEMENT AND CERTIFICATION STATEMENT REQUIREMENTS
# Re2 Ref
Question
Y-N-N/A Mai-Sh?:-Min H-M-L Potential Penalty
745.84(a)(l)(i /property manager obtain, from the owner, a written 1 40 C.F.R. Renovation in Dwelling Unit: Did the renovator/firm/ ~
)
acknowledirment that the owner had received the
Page 6 of 33
COMPANY NAME: Blank ln~pilction V),&Ja/4J;; l{ J{[Y1,t1(
ft
U.S. EPA
Lead Renovation/Repair/Painting Compliance Checklist - Renovators
US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202
TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION
40 C.F.R. 745.84(a)(l)
pamphlet, or obtain a certificate of mailing at least 7 days orior to the renovation?
Comments
2 40 C.F.R. Renovation in Dwelling Unit: Did the renovator/firm/
745.84(a)(2) /property manager obtain, from the adult occupant, a
written acknowledgment that the adult occupant has
y
40 C.F.R. received the pamphlet, or obtain a certificate of mailing
745.84(a)(2)(i at least 7 days prior to the renovation?
)
Comments
~w 3 40 C.F.R. 745.84(b)( l) 40 C.F.R.
Renovation in Common Area: Did the renovator/firm/ /property manager obtain, from the owner, a written acknowledgment that the owner has received the pamphlet, or that information signs have been posted,
745.84(b)(l)(i or obtain a certificate of mailing at least 7 days prior to
)
the renovation?
Comments
4 40 C.F.R. 745.84(b)(3)
Renovation in Common Arca: Did the renovator/firm/
/property manager prepare, sign, and date a statement ~l~
describing the steps performed to notify all occupants of
the intended renovation activities and to provide the
oamohlet?
Comments
~\i 5 40 C.F.R. 745.84(b)(4)
renovation in common area: did the renovator/firm/ property manager notify, in writing, the owners and occupants if the scope, locations or expected starting
and ending dates of the planned renovation activities
change after the initial notification, before the renovator
Page 7 of33
COMPANY NAME: -S,lank ln~pection L1_i,1~ , > Wd(!d
ft
U.S. EPA
Lead Renovation/Repair/Painting Compliance Checklist - Renovators
US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202
TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION
initiated work beyond that which was described in the
original notice?
Comments
6 40 C.F.R. renovation in child-occupied facility: did the
J\~ 745.84(c)(l)(i
)
renovator/firm/ property manager obtain, from the owner of the building, a written acknowledgment that the owner had received the pamphlet, or obtained a
certificate of mailing at least 7 days prior to the
renovation?
Comments
7 40 C.F.R. renovation in child-occupied facility: did the
745.84(c)(l)(i renovator/firm/ property owner/property manager obtain
i)
from an adult representative of the child occupied
~\~
faci lity, if the operator of the child-occupied facility is
not the owner of the building, a written
acknowledgment that the operator has received the
pamphlet, or obtained a certificate of mailing at least 7
days prior to the renovation?
Comments
8 40 C.F.R. 745.84(c)(3)
Renovation in Child-Occupied Facility: Did the renovator/firm/ property owner/property manager prepare, sign and date a statement describing the steps
0\t
performed to notify a11 parents and guardians of the
intended renovation activities and to provide the
pamphlet?
Comments
i 9 40 C.F.R. 745.84(d)(l)
All Renovations: Did the renovator/firm/property owner/property manager include a statement recording
Page 8 of33
COMPANY NAME~laRk l11spection 0-)(tY'ltit(l,J l{)<J-flj
ft
U.S. EPA
Lead Renovation/Repair/Painting Compliance Checklist - Renovators
US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202
TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION
the owner/occupant's name and acknowledgment ofthe
pamphlet receipt prior to the start of the renovation, the
address of the unit undergoing renovation, the signature
of the owner or occupant as applicable, and the date of
signature?
Comments
10 40 C.F.R. All Renovations: Did the renovator/firm/property
745.84(d)(2) owner/property manager provide a written
and (3)
acknowledgment of receipt on either a separate sheet or
as part of any written contract or service agreement for ~
the renovation, and be written in the same language as
the text of the contract or agreement or lease or
pamphlet?
Comments
RECORD RETENTION REQUIREMENTS
# Reg Ref
Question
Y-N-N/A Ma.i-Sig-Min H-M-L Potential Penalty
1 40 C.F.R. All Renovations: Did the renovator/firm/property
745.86
demonstrate compliance with the residential property manager/property owner retain all records necessary to ~
renovation for a period of 3 years following completion
of the renovation activities?
Comments
745.225 (i) and make available to EPA upon request, records for a 2 40 C.F.R. All Renovations: Did the training program maintain ~
period of 3 years and 6 months?
Comments
COMPANY NAME:,rBlank lnspecti0M
Page 9 of33
LDa~G(IA) Wacld
ft
U.S. EPA
Lead R'enovation/Repair/Painting Compliance Checkli.st - Renovators
US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 7S202
TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION
3 40 C.F.R. Target Housing and Child-occupied Facilities: did the
i 745.225,
745.226, or 745.227 &
renovator/firm/property manager/property owner/training activity fail or refuse to establish, maintain, provide, copy, or permit access to records or
40 C.F.R. reports?
745.235 (b)
Comments
RENOVATION FIRM, RENOVATOR AND DUST SAMPLING TECHNICIAN CERTIFICATION AND REOUIREMENTS
# Reg Ref
Question
Y-N-N/A Mai-Sig-Min H-M-L Potential Penalty
1 40 C.F.R. All Renovations: Did the renovator/firm that performs,
pursuant to 40 for compensation obtain initial certification from EPA? 745.89(a) offers or claims to perform renovations or dust sampling ~
CFR
745.8l(a)(2)(i
i)
Comments
~~i 2 40 CFR
All Renovations: Did the EPA-certified firm stop
745.89(a& 40 renovations or dust sampling because it did not obtain
C.F.R.
recertification?
745.89(b)(l)(i
ii)
Comments
3 40 C.F.R. All Renovations: Did the EPA-certified firm amend its
745.89(b). & 40 C.F.R. 745.89(c)
certification within 90 days of the date a change occurred to information included in the firm's most recent applications? Did the firm halt renovations or
{\\
dust sampling until its certification was amended?
Page 10 of33
COMPANY NAME:'8'1ank lnspectien U J 1 ~ l.JeJ--rt}
ft
U.S. EPA
Lead Renovation/Repair/Painting Compliance Checklist - Renovators
US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202
TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION
Comments
4 40 C.F.R. 745.89(d)(2)
All Renovations: Did the renovator/fmn fail to carry out its responsibilities during a renovation?
& 40 C.F.R. 745.8l(a)(2)
Comments
5 40 C.F.R. All Renovations: Did the renovator or dust sampling
745.90(b) or technician, perform all renovator or dust sampling
(c)
responsibilities obtain a course completion certificate
40 CFR
(proof ofcertification)?
745.90(a))
~
~!~
40 C.F.R. 745.8 l(a)(3)
Comments
6 40 CFR 745.90(b)(7)
All Renovations: Did the renovator or dust sampling technician, performing renovator or dust sampling responsibilities under 40 C.F.R. 745.90(b) or (c) to maintain copies of their course completion certificate(s) (proof of certification) at the work site?
~
i
Comments
\ 7 40 C.F.R. 745.90(b) or (c)
All Renovations: Did the renovator or dust sampling technician with responsibilities for ensuring compliance with 40 C.F.R. 745.85 at all renovations to which they
are assigned, ensure those activities happened as
required?
Comments
COMPANY NAME:--Blank IAspectio1,
Page 11 of 33
l,{ 4o da1ct> v,)o(lef
ft
U.S. EPA
Lead Renovation/Repair/Painting Compliance Checklist - Renovators
US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202
TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION
8 40 C.F.R. 745.90(c)
All Renovations: Did the dust sampling technician to perform optional dust clearance sampling under 745.85(c)?
~,~
Comments
9 40 C.F.R. Target Housing and Child-occupied Facilities: Did
renovations if he/she did not obtain recertification under 745.8l(a)(3) the previously EPA-certified individual stop directing ~I~
40 CFR 745.90(a)(4)?
Comments
10 40 C.F.R. 745.8l(a)(4)
Target Housing and Child-occupied Facilities: Did
the previously EPA-certified individual stop renovations ~(~
or dust sampling if he/she did not obtain recertification
under 40 CFR 745.90(a)(4)?
Comments
WORK PRACTICE STANDARDS FOR CONDUCTING RENOVATIONS
TN TARGET HOUSING AND CHILD OCCUPlED FACILITIES
# Reg Ref 1 40C.F.R.
Question Interior Renovations: Did the renovation firm remove
Y-N-N/A Mai-Si2-Min H-M-L Potential Penalty
745.85(a)(2)(i all objects from the work area, including furniture, rugs,
J\~ )(A)
and window coverings, or cover them with plastic
sheeting or other impermeable material with all seams
and edges taped or otherwise sealed?
Comments
~\i 2 40 C.F.R. Interior Renovations: Did the renovation firm, before
745.85(a)(2)(i beginning the renovation, close and cover all ducts
)(B)
opening in the work area with taped-down plastic
sheeting or other impermeable material?
Page 12 of33
COMPANY NAME. Bla11k Inspection l?,l,vl,4lzw Wr.rrl4
ft
U.S. EPA
Lead Renovation/Repair/Painting Compliance Checklist- Renovators
US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202
TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION
Comments
3 40 C.F.R. Interior Renovations: Did the renovation firm close
745.85(a)(2)(i windows and doors in the work area, cover doors with
)(C)
plastic sheeting or other impermeable material, and/or
cover doors used as an entrance to the work with plastic ~1~
sheeting or other impermeable material in a manner that
allows workers to pass through while confining dust and
debris to the work area?
Comments
4 40 C.F.R. Interior Renovations: Did the renovation firm, before
745.85(a)(2)(i beginning the renovation, cover the floor surface,
)(D) including installed carpet, with taped-down plastic ~1~
sheeting or other impermeable material in the work area
6 feet beyond the perimeter of surfaces undergoing
renovation or a sufficient distance to contain the dust,
whichever is greater?
Comments
745.85(a)(2)(i precautions to ensure that all personnel, tools, and other 5 40 C.F.R. Interior Renovations: Did the renovation firm use J{~
)(E)
items, including the exteriors of containers of waste, are
free of dust and debris before leaving the work area?
Comments
6 40 C.F.R. Exterior Renovations: Did the renovation firm, before
745.85(a)(2)(i beginning the renovation, close all doors and windows ~1i
i)(A)
within 20 feet of the renovation, close all doors and
windows within 20 feet of the renovation on the same
floor as the renovation on multi-story buildings, and/or
COMPANY NAME:-BlaAI< ln~r.:>ectiorr
Page 13 of 33
u.J,MffW vJ(f(W
ft
e
U.S. EPA
Lead Renovation/Repair/Painting Compliance Checklist - Renovators
US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202
TOXIC SUBSTANCES CONTROL ACT
TITLE IV-LEAD HAZARD REDUCTION
close all doors and windows on all floors below that are
the same horizontal distance from the renovation?
Comments
7 40 C.F.R. Exterior Renovations: Did the renovation firm, before
745.85(a)(2)(i beginning the renovation, to ensure that doors within the
~\ performed are covered with plastic sheeting or other i)(B) work area that wilJ be used while the job is being ~
impermeable material in a manner that allows workers
to pass through while confining dust and debris to the
work area?
Comments
8 40 C.F.R. Exterior Renovations: Did the renovation firm, before
~ 1 ~ 745.85(a)(2)(i
i)(C)
beginning the renovation, cover the ground with plastic sheeting or other disposable impermeable material extending 10 feet beyond the perimeter ofsurfaces
undergoing renovation or a sufficient distance to collect
falling paint debris, whichever is greater, unless the
property line prevents IO feet of such ground covering?
Comments
~\~ 9 40 C.F.R. Exterior Renovations: Did the renovation firm, before
745.85(a)(2)(i beginning the renovations in certain situations, to take
i)(D)
extra precautions in containing the work area to ensure
that dust and debris from the renovation does not
contaminate other buildings or other areas ofthe
property or migrate to adiacent properties?
Comments
Page 14 of33
l ),_) mok lA1tJfltfi.
ft
U.S. EPA
Lead Renovation/Repair/Painting Compliance Checklist- Renovators
US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202
TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION
1~ 10 40 C.F.R. Prohibited and restricted practices: Did the
745.85(a)(3)(i renovator/firm prohibit the use of open-flame burning or ~
)
torching of lead-based paint during renovations?
Comments
11 40 C.F.R. Prohibited and restricted practices: Did the
~1 745.85(a)(3)(i renovator/firm prohibit the use of machines that remove
i) lead-based paint through high speed operation such as ~
sanding, grinding, power planning, needle gun, abrasive
blasting, or sandblasting, unless such machines are used
with HEPA exhaust control?
~It~ Comments
12 40 C.F.R. Prohibited and restricted practices: Did the 745.85(a)(3)(i renovator/firm restrict the operating/use of a heat gun on
ii)
lead-based paint to temperatures below 1100 degrees
Fahrenheit?
Comments
13 to 40 C.F.R. Waste from renovations: Did the renovator/firm
contain waste from renovation activities to prevent
,fJ I~
745.85(a)(4)(i releases of dust and debris before the waste is removed
)
from the work area for storage or disposal and/or failure
to cover a chute if it is used to remove waste from the
work area?
Comments
745.85(a)(4)(i conclusion of each work day and/or at the conclusion of 14 40 C.F.R. Waste from renovations: Did the renovator/firm, at the N{ ~
i)
the renovation, ensure that waste that had been collected
from renovation activities was stored under
containment, in an enclosure, or behind a barrier that
Page 15 of 33
COMPANY NAME: Blank losoecticu:i-- W.<Aden. > V. loir:lef
ft
0
U.S. EPA
Lead Renovation/Repair/Painting Compliance Checklist - Renovators
US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202
TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION
prevents release ofdust and debris out of the work area
and prevents access to dust and debris?
Comments
15 to 40 C.F.R. Waste from renovations: Did the renovation firm
745.85(a)(4)(i contain the waste to prevent release of dust and debris
ii)
during the transport of waste from renovation activities?
~1~
Comments
16 40 C.F.R. 745.85(a)(5)
Cleaning the work area: Did the renovation firm clean the work area until no dust, debris or residue remained
\'J [t
after the renovation had been completed?
Comments
17 40 C.F.R. Cleaning the work area: did the renovation firm
745.85(a)(5)(i collect all paint chips and debris and seal the material in ~ I ~
)(A)
a heavy-duty bag without dispersing any of it?
Comments
18 40 C.F.R. Cleaning the work area: Did the renovation fim1
745.85(a)(5)(i remove the protective sheeting by misting the sheeting
)(B)
before folding it, folding the dirty side inward, and/or
~ I~
either taping shut to seal
or sealing it in heavv-dutv bags?
Comments
19 40 C.F.R. Cleaning the work area: Did the renovation firm keep
745.85(a)(5)(i in place the plastic sheeting used to isolate contaminated Nj~
)(8)
rooms from non-contaminated rooms until after the
cleaning and removal of other sheeting?
Comments
COMPANY NAME~lank Ii ,specttnn
Page 16 of 33
00kn /k&J lA I([fl)
ft
0
U.S. EPA
Lead Renovation/Repair/Painting Compliance Checklist - Renovators
US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202
TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION
20 40 C.F.R. Cleaning the work area: Did the renovation firm 745.85(a)(5)(i dispose of the plastic sheeting, used as occupant
rvl~
)(B)
protection at the renovation site, as waste?
Comments
21 40 C.F.R. Cleaning the work area: Did the renovation firm clean
745.85(a)(5)(i all objects and surfaces in the work area and within 2 tJ/A
i)
feet of the work area, cleaning from higher to lower?
Comments
22 40 C.F.R. Cleaning the work area: Did the renovation firm clean
745.85(a)(5)(i walls in the work area, starting at the ceiling and
i)(A)
working down to the floor, by either vacuuming with a
fJ I~
HEPA vacuum or wiping with a damp cloth?
Comments
/n 23 40 C.F.R. Cleaning the work area: Did the renovation firm
745.85(a)(5)(i thoroughly vacuum all remaining surfaces and objects in ~
i)(B)
the work area, including furniture and fixtures, with a
HEPA vacuum and/or failure to use a HEPA vacuum
equipped with a beater bar when vacuuming carpets and
rugs?
Comments
24 40 C.F.R. Cleaning the work area: Did the renovation firm to 745.85(a)(5)(i wipe all remaining surfaces and objects in the work
?JI~
i)(C)
area, except for carpeted or upholstered surfaces, with a
damp cloth and/or failure to mop uncarpeted floors
thoroughly, using a mopping method that keeps the
wash water separate from the rinse water, such as the 2-
bucket mopping method, or using a wet mopping
system?
Page 17 of 33
COMPANY NAME: .B.. lank...1.gg}eetio Lu ,~tJnw IA )ff(t)
ft
U.S. EPA
Lead Renovation/Repair/Painting Compliance Checklist - Renovators
US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202
TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION
~, Comments
25 40 C.F.R. Standards for post-renovation cleaning verification:
745.85(b)(l)(i Did the renovator perform a visual inspection of the
~
)
interior work area to determine whether dust, debris or
residue is still present, to remove dust, debris or residue
by re-cleaning if necessary, and/or perform another
visual inspection?
Comments
26 40 C.F.R. Standards for post-renovation cleaning verification:
i)(A) the work area has been adequately cleaned using a 745.85(b)(l)(i Did the renovator verify that each interior windowsill in ~ I().
disposable cleaning cloth(s) compared to the cleaning
verification card following the prescribed procedures,
pursuant to 40 C.F.R. 745.85 (b)(l)(ii) (A) or failure
by a certified renovator to arrange for the collection dust
clearance samples as part of optional dust clearance
testing?
Comments
27 40 C.F.R. Standards for post-renovation cleaning verification: 745.85(b)(l)(i Failure by a renovator to verify that each interior floor
~/~
i)(B)
in the work area has been adequately cleaned using a
disposable cleaning cloth(s) compared to the cleaning
verification card following the prescribed procedures
pursuant to 40 C.F.R. 745.85 (b)(l)(ii) (B) or failure by
a certified renovator to arrange for the collection dust
clearance samples as part ofoptional dust clearance
testing?
Comments
COMPANY NAME: Blank Inspection
Page 18 of 33
lJJ.AM aLovJ loBYU
ft
U.S. EPA
Lead Renovation/Repair/Painting Compliance Checklist - Renovators
US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 7S202
TOXIC SUBSTANCES CONTROL ACT
TITLE IV-LEAD HAZARD REDUCTION
28 40 C.F.R. Standards for post-renovation cleaning verification:
745.85(b)(l)(i Did the renovator wait until interior work area passes
ii)
post-renovation cleaning verification before removing
signs?
Comments
29 40 C.F.R. Standards for post-renovation cleaning verification:
745.85(b)(2) Did the renovator perform a v isual inspection of the
exterior work area to determine whether dust, debris or
residue is still present, to remove dust, debris or residue
by re-cleaning if necessary, and/or perform another
visual insoection?
Comments
30 40 C.F.R. Standards for post-renovation cleaning verification:
745.85(b)(2) Did the renovator to wait until exterior work area passes
visual inspection before removing signs?
Comments
31 40 C.F.R. 745.85(c)
Standards for post-renovation cleaning verification: Did the renovation firm arrange for performance of
optional dust clearance testing at the conclusion of the
renovation if required to do so by the person contracting
for the renovation, a Federal, State, Territorial. Tribal,
or local law or regulation?
Comments
32 40 C.F.R. Standards for post-renovation cleaning verification:
745.85(c)(2) Did the renovator have the optional dust clearance
testing performed by a certified inspector, risk assessor
or dust sampling technician at the conclusion of the
renovation?
COM PANY NAME:Jilank.Jtispefl011
Page 19 of 33
lN,t;v\etl(v-? wa-rul
/JI t,..
rJ IAtJ I ft.
rJ (f,
('l/ A
ft
U.S. EPA
Lead Renovation/Repair/Painting Compliance Checklist - Renovators
US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202
TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION
Comments
33 40 C.F.R. Standards for post-renovation cleaning verification:
745.85(c)(3) Did the renovation firm re-clean the work area until dust rJI~
clearance results are below clearance standards?
Comments
WORK PRACTICE STANDARDS FOR CONDUCTING LEAD-BASED PAINT ACTNITIS
IN TARGET HOUSING AND CHILD-OCCUPIED FACILITIES
# Reg Ref
Question
Y-N-N/A Mai-Sig-Min H-M-L Potential Penalty
N 1 40 C.F.R. Target Housing and Child-occupied Facilities: Did
745.227(a)(l) the renovator/firm perform all lead-based paint activities
If\-
pursuant to the work practice standards, appropriate
requirements, methodologies and clearance levels
specified and referenced?
Comments
2 40 C.F.R. Target Housing and Child-occupied FaciJities: Did 745.227(a)(2) the renovator/firm ensure lead-based paint activity
~ /fr
described by the certified individual as an inspection,
lead-hazard screen, risk assessment or abatement, was
perfonned by a certified individual?
Comments 3 40 C.F.R. Target Housing and Child-occupied Facilities: Did
745.227(b)(l) the renovator/firm ensure an inspection was conducted
rJ I ~
only by a person certified by EPA as an inspector or risk
assessor and, if conducted, must be conducted according
'
to the prescribed procedures?
Comments
COMPANY NAME: Blank lnsaeetion
Page 20 of 33
lu mdk , uJoflt!
ft
U.S. EPA
Lead Renovation/Repair/Painting Compliance Checklist - Renovators
US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202
TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION
4 40 C.F .R. Target Housing and Child-occupied Facilities: Did 745.227(b)(2) the renovator/firm conduct an inspection at select locations according to documented methodologies to be
r/11
tested for the oresence of lead-based paint?
Comments
s 40 C.F.R. Target Housing and Child-occupied Facilities: Did
745.227(b)(2) the renovator/finn test for lead-based paint each interior
rJ/ k
(i)
and/or exterior component with a distinct painting
history in a residential dwelling and/or child occupied
facilitv?
Comments
745.227(b)(2) the renovator/firm test for lead-based paint each interior 6 40 C.F.R. Target Housing and Child-occupied Facilities: Did tJ I A
(ii)
and/or exterior component with a distinct painting
history in a multi-family dwelling?
Comments
,_;I 7 40 C.F.R. Target Housing and Child-occupied Facilities: Did 745.227(b)(3) the renovator/firm ensure that paint sampled for analysis fL
(i)
to determine the presence of lead was conducted using
documented methodologies which incorporate adequate
qua litv control procedures?
Comments 8 40 C.F.R. Target Housing and Child-occupied Facilities: Did
745.227(b)(3) the renovator/firm ensure that all collected paint chip
tJ /ft
(ii)
samples were analyzed according to 40 C.F.R.
745.227(-t) to determine if they contain detectable
levels of lead that can be quantified numerically?
Comments
Page 21 of 33
COMPANY NAME: Bfa.RMffi-pectlon
W&J,(Jt,0 Wor lJ
ft
U.S. EPA
Lead Renovation/Repair/Painting Compliance Checklist - Renovators
US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202
TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION
9 40 C.F.R. Target Housing and Child-occupied Facilities: Did 745.227(b)(4) the inspector or risk assessor prepare an inspection r'eport that includes the required infomrntion?
~I ~
Comments
745.227(c)(l) the renovator/firm ensure that a lead hazard screen was 10 40 C.F.R. Target Housing and Child-occupied Facilities: Did ~I~
conducted only by a person certified by EPA as a risk
assessor?
Comments
11 40 C.F.R. Target Housing and Child-occupied Facilities: Did
745.227(c)(2) the renovator/firm ensure that a lead hazard screen
(i)
included the collection of background information
~l~
regarding the physical characteristics of the residential
dwelling or child-occupied facility and occupant use
patterns that may cause lead-based paint exposure to one
or more children age 6 years and under?
Comments
745 .227(C)(2) the renovator/firm ensure a lead hazard screen includes 12 40 C.F.R. Target Housing and Child-occupied Facilities: Did ~!~
(ii)(A)
a visual inspection to determine the presence of
deteriorated paint?
Comments
13 40 C.F.R. Target Housing and Child-occupied Facilities: Did.
745 .227(C)(2) the renovator/firm ensure a lead hazard screen includes
(ii)(B)
a visual inspection to locate at least two dust samples
~\~
performed according to the prescribed methodologies?
Comments
COMPANY NAME: alank-ttrspect1on
Page 22 of33
lAJ 1/CIJ/(l],J (; )(f/ltJI
ft
U.S. EPA
Lead Renovation/Repair/Painting Compliance Checklist - Renovators
US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202
TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION
14 40 C.F.R. Target Housing and Child-occupied Facilities: Did 745.227(c)(3) the renovator/firm ensure a lead hazard screen includes the collection and analysis of dust samples according to the prescribed methodologies?
Comments 15 40 C.F.R. Target Housing and Child-occupied Facilities: Did
745.227(c)(4) the renovator/firm ensure a lead hazard screen includes the collection and analysis of paint samples according to the prescribed methodologies?
Comments 16 40 C.F.R. Target Housing and Child-occupied Facilities: Did
745.227(c)(5) the renovator/firm ensure a risk assessor prepared a lead hazard screen report that includes the required information found in the regulation?
Comments 17 40 C.F.R. Target Housing and Child-occupied Facilities: Did
745.227(d)(l) the renovator/firm ensure a risk assessment was conducted only by a person certified by EPA as a risk assessor?
Comments 18 40 C.F.R. Target Housing and Child-occupied Facilities: Did
745.227(d)(2) the renovator/firm ensure that a risk assessment includes a visual inspection of the residential dwelling or childoccupied facility to locate the existence of deteriorated paint, assess the extent and causes of the deterioration, and other potential lead-based paint hazards?
Comments
~(fl-
~/~
~/r
y({t
~ Ifr
COMPANY NAME: Blank ~
Page 23 of 33
U)&Miow Wr1v-lJ
~
e
U.S. EPA
Lead Renovation/Repair/Painting Compliance Checklist - Renovators
US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202
TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION
19 40 C.F.R. Target Housing and Child-occupied Facilities: Did
745.227(d)(3) the renovator/firm ensure that a lead hazard screen includes the collection of background information
rJ IA,
regarding the physical characteristics of the residential
dwelling or child-occupied facility and occupant use
patterns that may cause lead-based paint exposure to one
or more children age 6 years and under?
Comments
20 40 C.F.R. Target Housing and Child-occupied Facilities: Did 745.227(d)(4) the renovator/firm test for the presence of lead on each
~ I~
surface determined to have a distinct painting history?
Comments
21 40 C.F.R. Residential Dwellings: Did the renovator/firm collect 745.227(d)(5) and analyze for lead concentration dust samples (either composite or single-surface samples) from the interior
~ / ~
window sill(s) and floor(s) in all living areas where one
or more children, age 6 and under, are most likely to
come into contact with dust?
Comments 22 40 C.F.R. Multi-family Dwellings and Child-occupied
745.227(d)(6) Facilities: Did the renovator/firm collect and analyze
~I,~
interior window sill and floor dust samples (either
composite or single-surface samples) for lead
concentration from the prescribed locations?
Comments
23 40 C.F.R. Child-occupied Facilities: Did the renovator/finn 745.227(d)(7) collect and analyze interior window sill and floor dust
~ 1~
samples (either composite or single-surface samples) for
Page 24 of 33
COMPANY NAME: Blan.k-l-flspection WIN'ialrri) Wrflu)
ft
U.S. EPA
Lead Renovation/Repair/Painting Compliance Checklist - Renovators
US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202
TOXIC SUBSTANCES CONTROL ACT
TITLE IV-LEAD HAZARD REDUCTION
lead concentration in each room, hallway or stairwell
utilized by one or more children, age 6 and under, and in
other common areas in the child occupied facilitv?
Comments
24 40 C.F.R. Target Housing and Child-occupied Facilities: Did
745.227(d)(8) the renovator/firm collect and analyze soil samples for
rJ!n
lead concentrations in the prescribed locations?
Comments
25 40 C.F.R. Target Housing and Child-occupied Facilities: Did
745.227(d)(9) the renovator/firm conduct all paint, dust, or soil sampling or testing using documented methodologies
rJ I~
that incoroorate adequate quality control procedures?
Comments
26 40 C.F.R. Target Housing and Child-occupied Facilities: Did
745.227(d)(l0 the renovator/firm analyze any collected paint chip,
)
dust, or soil samples according to 40 C.F.R. 745.227(f)
JJ l,i-
to determine if they contain detectable levels of lead that
can be quantified numerically?
Comments
27 40 C.F.R. Target Housing and Child-occupied Facilities: Did
745.227(d)(l l the renovator/firm/ risk assessor prepare a risk
)
assessment report that includes the required
;p
information?
Comments
28 40 C.F.R. Target Housing and Child-occupied Facilities: Did
745.227(e)(l) the renovator/firm ensure that an abatement is
rJ/fi
conducted only by a person certified by EPA, and, if
Page 25 of 33
wMlldrvJ Wd
ft
U.S. EPA
Lead Renovation/Repair/Painting Compliance Checklist - Renovators
US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202
TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION
conducted, is conducted according to the prescribed
procedures?
Comments
29 40 C.F.R. Target Housing and Child-occupied Facilities: Did
745.227(e)(2) the firm ensure a certified renovator was available to be
onsite for each abatement project during all work site
~/A
preparation, during the post-abatement cleanup of work
areas, and to be onsite at other times during the
abatement or available by telephone, pager or answering
service and able to be present at the work site in no
more than 2 hours?
Comments
30 40 C.F.R. Target Housing and Child-occupied Facilities: Did 745.227(e)(3) the firm ensure a certified renovator was available to direct activities and ensure that all abatement activities
~'"' ( r<
are conducted according to the requirements of 40
C.F.R. 745.227(e) and all other Federal, State and
local requirements?
Comments
31 40 C.F.R. Target Housing and Child-occupied Facilities: Did
745.227(e)(4) the renovation firm notify EPA of lead-based paint
(i-v)
abatement activities or to update notification as
~ 1~
prescribed and by the designated deadline?
Comments
32 40 C.F.R. Target Housing and Child-occupied Facilities: Did
j
745.227(e)(4) the renovation finn include the designated information
{
(vi)
in each notification?
Comments
Page 26 of33
COMPANY NAME:~an!Mnspect1on , [J...vi,Jt&,) Wg{~
ft
U.S. EPA
Lead Renovation/Repair/Painting Compliance Checklist - Renovators
US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202
TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION
r 33 40 C.F.R. Target Housing and Child-occupied Facilities: Did
745.227(e)(4) the certified firm accomplish written or electronic
(vii)
notification via one ofthe prescribed methods?
Comments
34 40 C.F.R. Target Housing and Child-occupied Facilities: Did
745.227(e)(4) the renovation firm begin lead-based paint abatement
i(
(viii)
activities on the date and at the location specified in
either the oritzinal or updated Notification?
Comments .
35 40 C.F.R. Target Housing and Child-occupied Facilities: Did
745.227(e)(4) the certified renovation firm or individual notify EPA
(ix)
before engaging in lead-based paint abatement activities
defined in 40 C.F.R. ~ 745.223?
rJ/~
Comments
36 40 C.F.R. Target Housing and Child-occupied Facilities: Did
745.227(e)(5) the certified renovation firm or individual develop a written occupant protection plan for all abatement
~( ~
projects and in accordance with the prescribed
procedures?
Comments
37 40 C.F.R.
745.227(e)(6) (i)
Target Housing and Child-occupied Facilities: Did the certified firm/renovator prohibit the use of openflame burning or torching of lead-based paint during
fv( A
abatement activities?
Comments
38 40 C.F.R. Target Housing and Child-occupied Facilities: Did 745.227(e)(6) the certified finn/renovator prohibit the use of machines "11 f(
(ii)
that remove lead-based paint through sandintz, grinding,
Page 27 of 33
/)).~ (Jj'rlfl4{
ft
U.S. EPA
-
Lead Renovation/Repair/Painting Compliance Checklist - Renovators
US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 7S202
TOXIC SUBSTANCES CONTROL ACT
TITLE IV-LEAD HAZARD REDUCTION
abrasive blasting, or sandblasting, unless such machines
are used with HEPA exhaust control which removes
particles of 0.3 microns or larger from the air at 99.97
percent or greater efficiency?
Comments
39 40 C.F.R. Target Housing and Child-occupied Facilities: Did
745.227(e)(6) the certified firm/renovator prohibit the dry scraping of
heat guns or around electrical outlets or when treating (iii) lead-based paint unless it is used in conjunction with 1vt ~
defective paint spots totaling no more than 6 square feet
in any one room, hallway, or stairwell or totaling no
more than 20 square feet on exterior surfaces?
Comments
40 40 C.F.R. Target Housing and Child-occupied Facilities: Did
745.227(e)(6) the certified firm/renovator restrict the operating ofa
(iv)
heat gun on lead-based paint at temperatures below
JJ/t-
1100 degrees Fahrenheit?
Comments
41 40 C.F.R. Target Housing and Child-occupied Facilities: Did 745.227(e)(7) the certified firm/renovator conduct soil abatement,
~ (~
when necessary, according to the prescribed methods?
Comments
745.227(e)(8) the certified firm/renovator have a certified inspector or 42 to 40 C.F.R. Target Housing and Child-occupied Facilities: Did ~I ~
risk assessor perform the post-abatement clearance
procedures?
Comments
COMPANY NAME:. B!aok::nsP:@ion
Page 28 of 33
lJJ ia (.,ka-l- > l,v cr1o/
ft
U.S. EPA
Lead Renovation/Repair/Painting Compliance Checklist - Renovators
US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 7S202
TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION
43 40 C.F.R. 745.227(e)(8) (i)
Target Housing and Child-occupied Facilities: Did the certified firm have an inspector or risk assessor to perform a visual inspection after abatement to determine ifdeteriorated painted surfaces and/or visible amounts
~1,~
of dust, debris or residue are still present and to remove
any hazards that still remain?
Comments
44 40 C.F.R. Target Housing and Child-occupied Facilities: Did
(ii) inspection and any necessary post-abatement cleanups 745.227(e)(8) the certified firm/renovator wait until the required visual ~!~
were completed before performing clearance sampling
for lead in dust?
Comments
45 40C.F.R. Target Housing and Child-occupied Facilities: Did 745.227(e)(8) the certified firm/renovator take dust samples for
~IA
(iii)
clearance purposes using documented methodologies
that incoroorate adequate quality control procedures?
Comments
745.227(e)(8) the certified firm/renovator wait a minimum of 1-hour 46 40 C.F.R. Target Housing and Child-occupied Facilities: Did ~1~
(iv)
after completion of final post-abatement cleanup
activities to collect dust samples for clearance purposes?
Comments 47 40 C.F.R. Target Housing and Child-occupied Facilities: Did
745.227(e)(8) the certified firm/renovator collect the required dust
~I~
(v)(A)
~amples from the prescribed surfaces in the designated
rooms after conducting an abatement with containment
between abated and unabated areas?
Page 29 of 33
COMPANY NAME~laok iospectioo
lu.NV\d a'lAJ /~..,
ft
0
U.S. EPA
Lead Renovation/Repair/Painting Compliance Checklist - Renovators
US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202
TOXIC SUBSTANCES CONTROL ACT
TITLE IV-LEAD HAZARD REDUCTION
Comments
48 40 C.F.R. Target Housing and Child-occupied Facilities: Did
745.227(e)(8) the certified firm/renovator collect the required dust
~I~
(v)(B)
samples from the prescribed surfaces in the designated
rooms after conducting an abatement with no
containment?
Comments
49 40 C.F.R. Target Housing and Child-occupied Facilities: Did
745.227(e)(8) the certified firm/renovator conduct a visual inspection
(v)(C)
and clean horizontal, outdoor surfaces of visible dust
~ll
and debris, perfonn visual inspection for paint chips on
the dripline and remove and properly dispose ofany
paint chips found following an exterior paint abatement?
Comments
745.227(e)(8) the certified firm/renovator select the rooms, hallways 50 40 C.F.R. Target Housing and Child-occupied Facilities: Did ~1~
(vi)
or stairwells for sampling according to documented
methodologies?
Comments
JI~ 51 40 C.F.R. Target Housing and Child-occupied Facilities: Did 745.227(e)(8) the certified inspector or risk assessor compare the
(vii)
residual lead level from dust samples with clearance
levels to determine if level exceeds the applicable
clearance level?
Comments
52 40 C.F.R. Target Housing and Child-occupied Facilities: Did a 745.227(e)(8) certified inspector or risk assessor re-clean and retest the
Nii
(vii)
Page 30 of 33
COMPANY NAME:-Sl;rnk ln:.peetion /p/Ald.@W Wd{\d
ft
U.S. EPA
Lead Renovation/Repair/Painting Compliance Checklist - Renovators
US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202
TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION
surface ofcomponents that were determined to have
failed clearance testing after abatement?
Comments
53 40 C.F.R. Target Housing and Child-occupied Facilities: Did
745.227(e)(8) the certified firm/renovator use the standard clearance
(viii)
levels for lead in dust of 40 ~tg/ft2 for -floors, 250 g/ft2
for interior window sills, and 400 g/ft2 for window
troughs to determine if a level in a sample exceeds the
aoolicable clearance level?
Comments
54 40 C.F.R. Target Housing and Child-occupied Facilities: Did a
745.227(e)(9) certified firm/renovator perform random sampling in a
multifamily dwelling with similarly constructed and
maintained residential dwellings according to the
prescribed methods?
Comments
55 40 C.F.R. Target Housing and Child-occupied Facilities: Did a 745.227(e)(10 certified renovator/supervisor or project designer
)
prepare an abatement report that includes the required
information?
Comments
56 40 C.F.R. Target Housing and Child-occupied Facilities: Did a
745.227(f)
certified renovator ensure that all paint chip, dust, or soil
samples obtained are collected by a certified risk
assessor or paint inspector and analyzed by an EPA
recognized laboratory?
Comments
rJ l t
~, ~
rJI~
rJ )r(
c.:ri- a lo coM PANY NAME"fli/;v/fl k) lu{!/rI,I Page 31 of33
.. It lt!S@U~ilA - -@
~~ """- ~.... - ..
ft
U.S. EPA
Lead Renovation/Repair/Painting Compliance Checklist - Renovators
US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202
TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION
57 40 C.F.R. Target Housing and Child-occupied Facilities: Did
745.227(g) the certified renovator limit composite dust sampling to
onlv those situations specified?
Comments
58 40 C.F.R. Target Housing and Child-occupied Facilities: Did
745.227(h) the certified renovator make a determination on the
presence of lead-based paint?
Comments
59 40 CFR
Target Housing and Child-occupied Facilities: Is the
745.233
firm certified performs, offers or claims to perform
renovations or dust sampling for compensation to obtain
initial certification from EPA, under 40 C.F.R.
745.226?
Comments
~I~
rvI fl
~IP
LEAD-BASED PAINT RISK ASSESSMENTS
# Rei! Ref
Question
Y-N-N/A Mai-Sii!-Min H-M-L Potential Penalty
l 40 C.F.R. Is the person performing a risk assessment certified by 745.227(d)( I) EPA as a risk assessor?
/Jf'P,,
Comments
2 40 C.F.R. Did a certified renovator conduct a visual inspection for
N/k 745.227(d)(2) risk assessment of a child-occupied facility to locate the existence of deteriorated paint, assess extent and causes
ofdeterioration, and other potential lead based paint
hazards?
Comments
Total Proposed Penalty Amount:
$0
i;J;tlc/00 We1r1t1 Page 32 of33
COMPANY NAME-~- ..,b..._...... ,. ~ a ' : \ . ~
...-~...,,..-4...... =-
ft
U.S. EPA
Lead Renovation/Repair/Painting Compliance Checklist - Renovators
US ENVIRONMENTAL PROTECTION AGENCY REGION 6, DALLAS, TX 75202
TOXIC SUBSTANCES CONTROL ACT TITLE IV-LEAD HAZARD REDUCTION
Target Housing Major= one or more occupants under age 6 and/or pregnant woman Significant= no information about age of the youngest occupant, or one or more occupants between ages of 6 and 17 Minor= no occupants under age 18
Child Occupied Facility Major = one or more occupants under age 6 (by definition, a child-occupied facility is regularly visited by one or more children under 6) Minor = renovation activities were completed during a period when children did not access the facility (e.g., as summer vacation) and there is no continuity of enrollment (i.e., the same children are not returning after the break).
COMPANY NAME 1::,r~dO~w . {o~ of33
tZtZ Inspection Date /2023
Appendix
Receipts of Documents
Unltl't'I SU1t ~
ENVIRONMENTAL PROTECTION AGENCY
Washington, DC 20460
Receipt for Samples and Documents
Of11ce of [nlotlernent ,llld Compliance /\~s111a1Ke
D~te
lt1-./ b/ ~
I Im l'q ga1 td1 nt f cation
lnsP('c.tron No
Daily Seq No
l_ _....._l_ _-ij1
Company Name
IIw;Adt,W" Wul'vi
I , nspector Adel ess
4 Company Address
---------------
f')..,v I [/,;,-... .SM,..,
V_1.1_1'_-_~...,.._-rl_._~_>_ -.?...;S;...'..l...l;;_/_~____.7;;..s=:...l._7:...o._ _ _ __J Vr~(J.)... "(Jrc.i r('c.
7sv~ 0
For ntema EP use Cop~ of this form rna, be provided to recipient as ~cknowledgment of the docur111::nu -,nd samples of chemical ~.1bstarxe-; ar,d/or M 1ures ~ .senbed below collectoo in connection w th rhe adm,n,stratiOf'l .md enfo,ci>mPnt of the Tox,c Sub-.tances Control
Act
Receipt of Document(sl and/or Sarnple(s) Described 1s Hereby Acknowledged
No
Description
J
I
l ~ c..,,\.. I lt..,.,-I- hv+:Fic d;'--"-
--
.
II - - I..
- . -- -
-
I:
-
-
.
J
-I
I
-I
--
I
i
--
,.....-------,1f. - - - - - - - - - - - - - - - - - - - - -
f _ r:=-_.=::_--=----- _-::-:-=-:::.=;;, ~~==========~======::=======:=========::::::!'1 1
Optional Duplicate or Split Samples Reque5ttc>d and Provided fJ Not Requested D
Clt11mant's
s,gnaturi
Tit e
t actllly l 1711