Method Statement: Lead Dust Cleanup, Decontamination, HEPA Vacuuming, Wet Wiping, Encapsulation, Waste Disposal, and Post-Cleanup Lead Wipe Clearance – Method Statement

Work Summary

• Post-demolition lead dust cleanup and decontamination of interior spaces including: containment setup, negative air establishment, HEPA vacuuming, wet wiping, repeat HEPA vacuuming, encapsulation of approved residual surfaces, and management of all lead-containing waste.
• Post-cleanup visual inspection and independent clearance wipe sampling; dismantling containment after clearance achieved.

Areas

• Interior rooms, corridors, stairwells, mechanical rooms, and any connected spaces potentially impacted by demolition dust migration.

Inclusions

• Isolation of HVAC and openings; surface cleaning of floors, walls, ceilings, fixtures, ledges, window sills/troughs, radiators, cabinets, and equipment exteriors.
• Application of lead paint encapsulant to specified residual substrates in sound condition.
• Packaging, labeling, transport, and disposal of lead-containing waste per applicable regulations.
• Documentation: logs, checklists, manometer records, equipment certificates, training records, chain-of-custody, lab results, and waste manifests.

Exclusions

• Structural demolition, abrasive blasting, chemical stripping, and removal of intact LBP systems not designated for encapsulation.
• Restoration of finishes beyond encapsulation unless specified.

Administrative

• Approved method statement and ITP; risk assessment/JHA completed and briefed.
• Notifications submitted to authorities where required (e.g., state/local health department) [Verify].
• Submittals approved: HEPA certification, encapsulant datasheets, PPE program, training records, waste management plan.

Site and Occupancy

• Areas vacated by occupants; access controlled; “Danger—Lead Work Area” signage installed.
• HVAC isolated: shut down impacted AHUs; seal returns/supplies with 6-mil poly and tape.
• Sensitive equipment and finishes protected or removed.

Utilities & Permits

• Electrical supply arranged for NAMs and vacuums; cords routed to avoid trip hazards.
• Permits: hot work N/A unless specified; work-at-height permits if required; waste transport permits [Verify].

Baseline Measurements (if specified)

• Optional pre-clean baseline dust-wipe sampling to inform scope and establish transformation metrics [Verify].
• Initial exposure assessment per OSHA 1926.62(d): personal air sampling to set respiratory protection level.

Emergency Preparedness

• Spill kits for liquid cleaners/encapsulant; first-aid and eyewash; emergency contact list posted.

Key Hazards and Controls

• Lead dust inhalation/ingestion
• Consequence: Acute/long-term toxicity, elevated blood lead levels.
• Engineering/procedural controls: Negative pressure containment (≥ 0.02 in. w.g.), HEPA filtration, wet methods, no dry sweeping, dedicated decon room, hygiene facilities (handwash), no eating/drinking in work area.
• PPE: Half-face elastomeric respirator with P100 filters (upgrade per exposure monitoring), disposable hooded coveralls, nitrile gloves (double-glove), safety glasses/goggles.
• Collective measures: Access control, signage, worker rotation to minimize exposure.

• Inspection/permits/supervision: Initial exposure assessment per OSHA 1926.62(d); respirator program per 1910.134; competent person oversight; medical surveillance where required.

• Containment breach/negative pressure loss

• Consequence: Dust migration, cross-contamination.
• Controls: Continuous manometer with alarm; documented hourly checks; smoke tests at critical barriers; redundant NAM or backup power (if critical) [Verify feasibility].
• PPE: As above.
• Collective: Double-door entry; sticky mats; tool/equipment decon.

• Inspection: Hold point—containment verification before works; log reviews by QA/HSE.

• Slips, trips, and falls (wet floors, cords, poly wrinkles)

• Consequence: Sprains/fractures.
• Controls: Cord management; non-slip shoe covers; staged cleaning to keep egress paths dry; good lighting.
• PPE: Slip-resistant footwear, gloves.
• Collective: Housekeeping schedule; cord covers.

• Inspection: Daily HSE walkdowns; rectify within shift.

• Work at height (ladders/step-ups for high surfaces)

• Consequence: Falls causing serious injury.
• Controls: Only industrial step ladders; maintain 3-point contact; spotter where needed; prohibit overreach; use mobile platforms if duration/height warrants.
• PPE: Fall protection if guardrails absent and exposure > threshold [Verify law]; hard hats.
• Collective: Eliminate need by extendable tools when feasible.

• Inspection: Pre-use ladder inspection; work-at-height permit where applicable.

• Chemical exposure (detergents/encapsulant)

• Consequence: Skin/eye irritation, VOC exposure.
• Controls: Use low-VOC products; ventilation; follow SDS; mixing/dilution per manufacturer; keep containers closed.
• PPE: Chemical-resistant gloves (nitrile), splash goggles, coveralls; respirator if required by SDS/exposure.
• Collective: Spill kits and secondary containment.

• Inspection: SDS available; HAZCOM training per 29 CFR 1910.1200.

• Manual handling and repetitive strain

• Consequence: Musculoskeletal disorders.
• Controls: Team lifts for NAMs; use dollies; job rotation; micro-breaks.
• PPE: Work gloves, supportive footwear.
• Collective: Mechanical aids.

• Inspection: HSE supervision.

• Electrical hazards from equipment

• Consequence: Shock, fire.
• Controls: PAT-tested equipment where applicable; GFCI/RCD-protected circuits; dry handling; cable management.
• PPE: Dielectric gloves if needed; non-conductive footwear.
• Collective: Lockout of non-required circuits [Verify].

• Inspection: Pre-use checks; defective kit tagged out.

• Waste handling and transport

• Consequence: Exposure, spills, regulatory non-compliance.
• Controls: Double-bagging; drum liners; proper labels; sealed containers; dolly use; route planning.
• PPE: As for lead handling.
• Collective: Dedicated waste staging area with secondary containment.

• Inspection: Container integrity checks; manifest verification.

• Noise and vibration (NAMs, vacuums)

• Consequence: Hearing loss, discomfort.
• Controls: Low-noise equipment; limit exposure time.
• PPE: Hearing protection when >85 dBA TWA.
• Collective: Administrative controls.
• Inspection: Spot noise checks [Verify].

[Verify per project HSE plan and local regulations]

Controls to Prevent Pollution and Nuisance

• Dust and Air Emissions
• Maintain negative pressure and HEPA filtration; seal exhaust duct to exterior away from intakes/occupied areas; change pre-filters when ΔP indicates loading per OEM.
• Wastewater
• Collect mop/wash water; do not discharge to storm drains; containerize and dispose per local regulations or sanitary sewer with approval [Verify]. Record volumes.
• Solid Waste
• Segregate lead-containing waste; label containers; perform TCLP for waste classification where required; store under cover with spill pallets; maintain inventory.
• Noise and Working Hours
• Adhere to local noise limits and permitted hours; select low-noise equipment where possible.
• Spills and Leaks
• Secondary containment for liquids/encapsulant; spill kits available; report and remediate immediately.
• Protection of Adjacent Areas
• Block/cover return air paths; seal doors/penetrations; establish clean corridor outside containment; protective floor coverings for egress routes.
• Transport
• Use permitted carriers; secure loads; maintain manifests and weigh tickets.

[Verify per project environmental plan and local regulations]

Submittals

• Equipment HEPA certifications (within 12 months) and NAM/HEPA filter data sheets.
• Encapsulant manufacturer data (application method, WFT/DFT, cure time), color samples.
• Training and certifications (lead worker/supervisor, RRP, respirator fit testing).
• Waste management plan and disposal facility approvals.

Controls and Records

• Differential pressure: log at ≤ 60-min intervals; alarm set at -0.02 in. w.g. threshold.
• Cleaning sequence verification: checklists for first HEPA, wet wipe, second HEPA.
• Encapsulant application: record ambient temperature/RH; WFT readings each coat; coverage rate vs. theoretical; cure verification per TDS.
• Equipment maintenance: pre-use checklists; filter change logs; calibration certificates (manometers within 12 months).
• Sampling QA: independent sampler; use field blanks (≥ 5% of total) [Verify]; NLLAP lab; chain-of-custody.
• Acceptance criteria: visual clean; clearance wipes within jurisdictional standards (e.g., floors ≤ 10 µg/ft²; sills ≤ 100 µg/ft²; troughs ≤ 400 µg/ft²) [Verify].
• Nonconformance: issue NCR for failed clearance; corrective action—re-clean affected rooms; re-sample until pass.

Handover

• Compile QA dossier: approvals, pressure logs, cleaning and inspection checklists, WFT/DFT logs, lab reports, waste manifests, photo records, clearance certificate.

• Manufacturer data sheets: HEPA units, filters, encapsulant (including WFT/DFT targets and cure times).
• Equipment calibration and HEPA/PAO/DOP certificates (≤ 12 months) [Verify].
• Training/competency records, medical surveillance (as required), respirator fit tests.
• Risk Assessment/JHA and emergency response plan.
• Waste management plan, disposal facility acceptance letters, transport permits.
• Sampling plan, chain-of-custody templates, example lab report.
• Daily checklists: containment, cleaning sequence, pressure logs, WFT/DFT logs, corrective actions.