Frequently Asked Questions Regarding

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4-Hour Lead Hazard Reduction for Maintenance Workers and Painters Course offered by the Environmental Management Institute

What is the significance of HUD approval? HUD approval allows individuals completing the course to perform their work without being supervised by a licensed lead-based paint abatement supervisor. It also gives the individual and his/her employer greater confidence that the individual will acquire the necessary knowledge to safely and legally perform the tasks pursuant to the HUD rule.

What tasks may this person do? An individual successfully completing this course will be permitted under the rule to perform the following activities:

Interim controls pursuant to 35.1330;
Paint stabilization pursuant to 35.1330(b);
On-going lead-based paint maintenance pursuant to 35.1355(a); and
Standard treatments pursuant to 35.1335.

What tasks may this person not do? An individual completing only this course will not be able to perform to following work:

Perform lead abatement work. Abatement work as defined by 35.110 is a set of measures designed to permanently eliminate lead-based paint or lead-based paint hazards. These measures include removal of paint, permanent enclosure or encapsulation of paint, replacement of components or fixtures, and the removal of permanent covering of contaminated soil. A three-day training course and state licensing is required to perform abatement work.
Wear respiratory protection. Respiratory protection should not be required under the situations covered by the training course. If the worker chooses to wear respiratory protection, additional training in the safe use of the equipment is needed.
Conduct clearance sampling. HUD rules at 35.1340(f) prohibit anyone from conducting a clearance examination on hazard reduction work they have completed.

What if there are additional state and local requirements? This training addresses the federal requirements. Where state or local agencies require additional training or work practices, the training must be adapted to include those requirements. In some cases, additional time may be needed to present the course.

Is refresher training required? No, HUD does not require refresher training. However, HUD requires that any work covered by the standard follow the requirements. If the rules are not followed, HUD may take an enforcement action. In addition, OSHA requires that employers ensure that their employees are following the OSHA regulations. Failing to follow the HUD requirements is likely to result in a situation that would cause a violation of the OSHA requirements as well.

Do trainees need to take a test? Yes, trainees will take a brief test near the end of the class. They will turn in their answers to the trainer. Once all of the answers are turned in, the trainer will review the proper answers to the questions with the class so they learn from the exercise. The trainer will make the trainee’s score available to the trainee and his/her employer. Under this system, trainee will not pass or fail the test.