C33 Regulations and Procedures for Lead-Based Paint Abatement 5 — Questions and Answers
Question 1: When encapsulation is chosen as a lead hazard control method in California, what is a required condition for it to be approved?
- The substrate must be stable and the encapsulant must be listed on the EPA's acceptable products list (Correct answer)
- The owner must sign a waiver acknowledging permanent encapsulation
- A soil sample must confirm lead levels below 400 ppm
- The local air district must issue a variance permit
Correct answer: The substrate must be stable and the encapsulant must be listed on the EPA's acceptable products list
Encapsulation is only acceptable when the underlying substrate is stable and the product used is an EPA-recognized encapsulant; deteriorating substrates require abatement.
Question 2: Which agency enforces the California lead RRP regulations for renovation work in child-occupied facilities?
- OSHA California (Cal/OSHA)
- California Department of Public Health (CDPH) (Correct answer)
- California Air Resources Board (CARB)
- Department of Toxic Substances Control (DTSC)
Correct answer: California Department of Public Health (CDPH)
CDPH is the primary state agency that enforces California's lead-safe renovation, repair, and painting rules in child-occupied facilities and pre-1978 housing.
Question 3: What is the California-defined action level for lead in air during abatement that triggers mandatory engineering controls?
- 30 µg/m³ as an 8-hour TWA (Correct answer)
- 50 µg/m³ as an 8-hour TWA
- 100 µg/m³ as an 8-hour TWA
- 200 µg/m³ as an 8-hour TWA
Correct answer: 30 µg/m³ as an 8-hour TWA
Cal/OSHA's lead standard sets an action level of 30 µg/m³ as an 8-hour time-weighted average, which triggers required medical surveillance and additional controls.
Question 4: During lead abatement in an occupied multi-family building, what must be done before residents can return to the work area?
- Visual inspection only by the contractor
- Clearance examination including visual inspection and wipe sampling by a certified independent inspector (Correct answer)
- A 24-hour waiting period after work is complete
- Air monitoring showing zero detectable lead
Correct answer: Clearance examination including visual inspection and wipe sampling by a certified independent inspector
Residents cannot return until a certified, independent inspector performs a clearance examination that includes both a visual inspection and dust wipe samples meeting established clearance standards.
Question 5: A C-33 contractor is using chemical strippers to remove lead paint from interior trim. What is the primary regulatory concern unique to this method?
- Volatile organic compound (VOC) emissions from the stripper (Correct answer)
- Increased dust generation requiring upgraded HEPA filtration
- Worker heat stress from chemical reaction
- Permit required from the local fire marshal
Correct answer: Volatile organic compound (VOC) emissions from the stripper
Chemical strippers used indoors generate VOC emissions subject to California Air Resources Board and local air district regulations, requiring proper ventilation and compliant product selection.
Question 6: What is the EPA dust wipe clearance standard for lead on floors in a residential abatement project?
- 10 µg/ft²
- 40 µg/ft² (Correct answer)
- 100 µg/ft²
- 250 µg/ft²
Correct answer: 40 µg/ft²
The EPA clearance standard for floors is 40 µg/ft², meaning dust wipe samples must show lead loading at or below this level before occupants may return.
Question 7: Under California regulations, a lead abatement supervisor must be on-site:
- Only at the start and end of each work day
- Whenever abatement workers are performing work (Correct answer)
- At least 50% of the total project hours
- Only when air monitoring equipment is being calibrated
Correct answer: Whenever abatement workers are performing work
California requires a certified lead abatement supervisor to be present and actively supervising workers at all times during abatement activities.
C33 Regulations and Procedures for Lead-Based Paint Abatement 5
When encapsulation is chosen as a lead hazard control method in California, what is a required condition for it to be approved?