Childhood Lead Poisoning Prevention

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Is Lead Certification Required for the type of work I do?

When Certification Is Required...

When Certification Is Not Required...

How to become certified.

You may need to be certified!

There are some situations in which you are legally required to be CDHS Lead-Related Construction (LRC) certified. Even if certification is not required in your situation, CDHS encourages you to become trained and certified to help protect yourself, your family and your clients from lead poisoning. The following questions may help you decide if you need to be certified.

Will you be inspecting for lead or doing clearance testing in California?

If you plan to receive pay for doing lead inspections, lead risk assessments or lead clearance inspections, in residential or public buildings in California, State law requires you to be a CDHS LRC certified Inspector/Assessor. You may be a Certified Lead Project Monitor if you plan to do only clearance inspections (Title 17, CCR, Section 36100(a)(1)). This law does not apply to activities done solely to ensure Cal/OSHA compliance (e.g. paint chip or dust wipe sampling) or representative sampling done for waste segregation and disposal purposes. See the further explanation below in the "You may not need to be certified" section.

Some examples of hazard evaluations that may require certification include:

An owner wants to inspect some housing for lead related to the (Residential Lead-Based Paint Hazard Reduction Act of 1992; Title X, Section 101). In California, this Federal rule also gives home buyers a full 10 days to inspect a home for lead, provided the inspection is conducted by a CDHS LRC certified Inspector/Assessor.
A potential buyer wishes to assess possible environmental liability through a Phase I/II Environmental Site Assessment. If the ESA addresses lead, and the site includes residences, or does or will allow public access, the individual must be a CDHS LRC certified Inspector/Assessor.
A property owner wishes to insure there are no lead hazards in the buildings. The person performing the risk assessment must be a CDHS LRC certified Inspector/Assessor.

Will you be designing lead abatement projects in California?

If you plan to prepare or design plans for abatement, reduction, or elimination of lead-based paint, lead-contaminated dust, or lead-contaminated soil from residential or public buildings in California, State law requires you to be a CDHS LRC certified Lead Supervisor, Project Monitor or Project Designer (Title 17, CCR, Section 36100(a)(1)).

Will you be working to reduce lead in California?

If you plan to do any work designed to reduce or eliminate lead-based paint, lead-contaminated dust, or lead-contaminated soil in or on residential or public buildings in California, State law requires you to be a CDHS LRC certified Lead Supervisor or Worker (Title 17, CCR, Section 36100(a)(1)). Certification is not required for those conducting abatement activities, also known as "interim controls", which are designed to reduce or eliminate lead hazards from a building for less than 20 years. However, other requirements in Title 17 still apply.

Will you be doing lead work in a school?

If you plan to inspect for lead or to reduce or eliminate hazards from lead-based paint, lead-contaminated dust, or lead-contaminated soil on or in a public elementary school, pre-school or daycare center, the California Education Code, Section 32243(b) requires you to be trained and CDHS LRC certified. Public schools are those that are funded by the State or Federal government.

Will you be exposed airborne lead dust?

If you will be working in a residential or public building and the lead-related construction work you plan to do will expose you to airborne lead at or above the 8-hour permissible exposure limit (PEL) of 50 �g/m³, California OSHA's Title 8, California Code of Regulations Section 1532.1 requires you to be trained and CDHS LRC certified. Check with your health and safety supervisor about the air monitoring results for your job site. You can also contact the Department of Health Services, Occupational Lead Poisoning Prevention Branch at (866) 627-1587 for more information about the Cal/OSHA regulations.

Are you doing work on a HUD project?

If the lead-related construction project you plan to do is funded by the U.S. Department of Housing and Urban Development (HUD), or if the work will be done in HUD funded housing, HUD policies may require you to be certified. For example, HUD requires certification for pilot lead abatement projects. Check with your HUD contact person about whether certification is required for your project.

Do your work specifications require certification?

Many private and public agencies, such as city or county governments, lenders and funding agencies, require certification for lead-related construction personnel. Read the specification carefully, or check with your local development agencies, lenders, funders before you bid on a job, to see if certification is required. Remember that training alone does not count as CDHS LRC certification.

You may not need to be certified!

Some work activities involving lead-based paint and lead hazards do not require you or your employees to be CDHS LRC certified. Listed below are some such situations. For more information, call the Lead-Related Construction Information Line at 1-800-597-5323 and ask to speak to a specialist about whether you need to be CDHS LRC certified.

Although CDHS LRC certification may not be required for the type of work you plan to do, you may still have to comply with Cal/OSHA standards, California Health & Safety Codes or other regulations when working with lead hazards.

Commercial/Steel Structure Work

CDHS LRC certification is not required work done on steel structures, unless the structures are public buildings or residences. If you do lead-related construction on industrial buildings, warehouses, factories, storage facilities, ships, bridges, tanks, towers or other buildings that are non-residential and generally not open to the public, you are not required to be CDHS LRC certified.

General Industry Work

California Title 17 regulations apply only to work done in the lead-related construction field. If you work with lead in an industrial setting, such as in battery manufacturing, radiator repair, metal working, electronics manufacturing, foundry work or welding, you are not required to be CDHS LRC certified.

Hobbies

If you use lead in your hobby, such as stained-glass, re-loading, fishing or lead-toy casting, you are not required to be CDHS LRC certified.

Cal/OSHA Compliance Testing

You are not required to be a CDHS LRC certified Lead Inspector/Assessor in order to do testing activities that are designed solely to ensure compliance with Cal/OSHA work practice standards. Examples include:

Collecting air monitoring samples to test potential worker lead-in-air exposure levels; and
Collecting dust wipe samples to ensure containment.

Waste Segregation Sampling

You are not required to be a CDHS LRC certified Lead Inspector/Assessor in order to do representative sampling of worksite debris for lead for waste segregation and hazardous waste disposal purposes. Examples of such sampling include:

Solid waste (SW-846) testing to determine total metal concentration; and
Waste Extraction Testing (WET) or Total Characteristic Leaching Procedure (TCLP) testing to determine soluble metal concentration.

Testing Your Home for Lead

Only those who are paid to do lead inspections are required to be CDHS LRC certified Inspector/Assessors. This means that as a homeowner, you may take paint chip samples, dust wipe samples, soil samples and use lead testing kits to check for lead hazards in your home or yard without being CDHS LRC certified.

Renovation, Repair and Repainting Work

People who are not CDHS LRC certified may do renovation, repair or repainting projects on a home, provided the projects are not specifically designed to abate, reduce or remove lead hazards (including lead-based paint, lead-contaminated dust, and lead-contaminated soil).

Maintenance workers for residential and public buildings, such as apartments, schools, stores, theaters and offices, may perform operations and maintenance work on those buildings without being CDHS LRC certified, provided the work is not specifically designed to abate, reduce or remove lead hazards (including lead-based paint, lead-contaminated dust, and lead-contaminated soil).

Temporary Lead Hazard Control Measures

In some cases, CDHS LRC certification is not required for those who design or work on projects intended to reduce lead-based paint, lead-contaminated dust, or lead-contaminated soil from a residential or public building if the results are designed to last for less than 20 years. Such work, involving methods often called interim controls, is designed to make buildings lead-safe by temporarily controlling, but not permanently removing, the lead-based paint or lead hazards.

The Bottom Line

Many situations involving the identification and removal of lead-based paint, lead contaminated dust, and lead contaminated soil are complex. For example, there may be many reasons why a particular inspection activity is conducted, just as there may be many reasons for removing lead-based paint, lead contaminated dust, and lead contaminated soil. In some of these situations, people may choose not to use CDHS LRC certified professionals. In such cases, the LRC certified professional or other consultant/contractor must be able to fully justify and document their decision. In the real world, consultants and others must be comfortable that they can legally defend their professional decisions.

IMPORTANT

If you perform projects using interim controls to abate lead-based paint or lead hazards, you must follow the guidelines outlined in Chapter 11 of the U.S. Housing & Urban Development, Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing (also available from HUD User at 1-800-245-2691). You must also comply with California's work practice regulations for lead-related construction (Title 17, CCR, Sections 36000 and 36100) including notifying CDHS of abatement activities and using containment and work practices that prevent lead contaminated dust, soil or paint debris from spreading to non-work areas.