9.3 Work Plans, Method Selection Documentation, and Pre-Abatement Walkthrough
Key Takeaways
- 745.227 does not number a separate work-plan form. The later abatement report must include a detailed written description of the abatement: methods used, locations of rooms and/or components, the reason for selecting particular abatement methods for each component, and any suggested monitoring of encapsulants or enclosures (745.227(e)(10)(vi)).
- Convert the inspection or risk-assessment report into a component-by-component method matrix with those reasons before the first strip of containment; do not invent reasons at clearance week.
- Restricted practices in 745.227(e)(6) must be planned out of the job (no open-flame torching; machine sanding/grinding/blasting only with HEPA exhaust; dry-scrape limits; heat guns below 1100°F). Chapter 13 teaches the how; this chapter refuses illegal methods in the bid.
- The certified supervisor shall be onsite during all work-site preparation (745.227(e)(2)). The pre-abatement walkthrough confirms components against the report, occupant status against the OPP, utilities, access, and the waste path.
- Write methods first, then the unique occupant protection plan (Chapter 8) and containment (Chapter 10) around those methods. If the walkthrough changes quantity or location, apply Section 9.2's update clocks.
Method-by-component plans, reasons on paper, and the pre-abatement walkthrough
Quick Answer: 40 CFR 745.227 does not number a separate "work plan" form. The abatement report you will sign later must include a detailed written description of the abatement: methods, locations of rooms and/or components, the reason for selecting particular abatement methods for each component, and any suggested monitoring of encapsulants or enclosures (745.227(e)(10)(vi)). Supervisors who wait until the report to invent those reasons fail the job and the exam. Turn the inspection / risk-assessment report into a component-by-component method list before the first strip of containment, plan restricted practices out of the work (745.227(e)(6); Chapter 13), and walk the site as the supervisor who must be on-site during all work-site preparation (745.227(e)(2)).
This section is the bridge from Chapter 7 (reading the reports) and Chapter 8 (occupant protection) into Chapter 10 (containment). Notification told EPA when and where. The work plan — whatever you title the internal document — tells the crew what will be done to which component and why.
There is no 745.227 "Form W," but the report will demand the plan
745.227(e)(10) says an abatement report shall be prepared by a certified supervisor or project designer. Among the required contents, (e)(10)(vi) is the method paragraph:
"A detailed written description of the abatement, including abatement methods used, locations of rooms and/or components where abatement occurred, reason for selecting particular abatement methods for each component, and any suggested monitoring of encapsulants or enclosures."
Read the nouns. Methods (not "we abated the house"). Locations of rooms and/or components (not "interior"). Reason for selecting particular abatement methods for each component (not a single blanket "because the owner said so"). Suggested monitoring if you enclosed or encapsulated.
If those sentences do not exist until Friday afternoon of clearance week, they will be fiction. The professional practice is to write them before mobilization, using the inspection and risk-assessment reports Chapter 7 taught you to read. Call that document a work plan, a scope-of-work attachment, a method matrix, or a job hazard analysis — EPA does not give it a section number. The report is what 745.227 numbers. The plan is how a supervisor makes the report true.
The occupant protection plan is separate and is numbered: 745.227(e)(5) requires a written OPP, unique to each residential dwelling or child-occupied facility, developed prior to the abatement, by a certified supervisor or project designer. Chapter 8 owns OPP uniqueness, relocation, isolation, and re-occupancy. This chapter owns the method choices the OPP has to protect people from.
Turn the risk-assessment report into a component matrix
A risk-assessment report (745.227(d)(11)) already lists hazards and "a description of interim controls and/or abatement options for each identified lead-based paint hazard" plus a suggested prioritization, and if encapsulant or enclosure is recommended, a maintenance and monitoring schedule. An inspection report lists which components are LBP. Neither report is a work order. The supervisor (or project designer) converts options into the method for this contract.
Build a table before the walkthrough, then correct it on site:
| Component / room | Hazard in the RA/inspection | Method selected | Why this method (what you will later put in (e)(10)(vi)) | Restricted-practice check | Monitoring after? |
|---|---|---|---|---|---|
| Living-room lower sash, friction | Paint-lead on friction surface; dust on sill | Component replacement of the window assembly | Friction will grind any remaining film; replacement permanently removes the painted slide | No dry sanding of the old sash on site; score, wet, remove whole | No encapsulant; none |
| Stair-riser, impact, deteriorated | Impact-surface paint-lead hazard | Component replacement of risers | Repeated shoe impact would fail an encapsulant or thin enclosure | Heat gun, if any, below 1100°F; no torching | No |
| Intact living-room wall, no chew marks | LBP present, not a current paint-lead hazard, but in the abatement scope | Enclosure with mechanically fastened rigid material, or encapsulation if the substrate passes | Intact, low-abuse surface; enclosure/encapsulant can be a permanent barrier if monitored | No machine grinding without HEPA exhaust | Yes — suggested monitoring schedule |
| Play-area bare soil 1,800 ppm | Soil-lead hazard (≥ 400 ppm play area) | Remove and replace with soil as close to local background as practicable, ≤ 400 ppm; do not reuse as residential topsoil | Concentration is a play-area hazard; grass/mulch is not permanent covering | Waste path planned so excavated soil does not re-enter the yard | No, if soil is gone; yes if you instead permanently cover with pavement/concrete |
| Kitchen floor dust | Dust-lead hazard (any reportable level on or after Jan. 12, 2026) | Interior dust abatement / specialized cleaning to below action levels (5 / 40 / 100) after other methods | Dust is the remaining reservoir after paint work | HEPA / wet sequence (Chapter 14); no dry sweeping | No encapsulant |
Reasons must be particular. "Replacement because it is abatement" is not a reason. Friction surfaces fail film-forming products because abrasion recreates dust. Chewable sills fail encapsulants that a toddler can mouth through. Deteriorated plaster may not hold an encapsulant. Historic-window owners may still choose replacement of stops and parting beads rather than the whole frame — that is a component-level reason, and it still has to be written for each component. Soil gets remove-and-replace or permanent cover (pavement/concrete), not landscaping dressed up as abatement (Chapter 15).
Plan restricted practices out of the job
745.227(e)(6) is not a cleanup rule. It is a method rule, so it belongs in the plan:
- Open-flame burning or torching of LBP is prohibited. Do not put a torch on the method matrix "for paint that will not scrape."
- Machine sanding, grinding, abrasive blasting, or sandblasting is prohibited unless used with HEPA exhaust control that removes particles of 0.3 microns or larger at 99.97% or greater efficiency.
- Dry scraping is permitted only with heat guns, around electrical outlets, or when treating defective paint spots totaling no more than 2 ft² in any one room, hallway, or stairwell, or no more than 20 ft² on exterior surfaces.
- Heat guns only below 1100°F.
Chapter 13 teaches the how. Chapter 9's job is to refuse a bid that assumes torching, open blasting, or whole-room dry scraping. If the only way the crew knows to get paint off a masonry lintel is a torch, that component's method is wrong before notification is even filed. Put the legal method on the matrix (wet scrape, chemical, heat gun below 1100°F, replacement) and make sure the brief description on the EPA notice in 9.1 matches that matrix. A notice that says "wet scrape and replace windows" while the truck is loaded with abrasive pots is a documentation problem waiting for an inspector.
Pre-abatement walkthrough — supervisor's body on site
745.227(e)(2) requires a certified supervisor for each abatement project and requires that supervisor to be onsite during all work-site preparation. The walkthrough is the last chance to make the plan true before preparation starts, and the first hours of preparation are not a telephone job.
Walk with the RA/inspection in one hand and the method matrix and draft OPP in the other. Punch at least this list:
| Check | What you are confirming | If it fails |
|---|---|---|
| Components vs report | The sash, radiators, soil patches, and stair parts on the report still exist, still match the XRF/chip IDs, and were not replaced since the inspection | Stop and get the inspector/risk assessor, or treat untested look-alikes under the inspection rule for similar painting history — do not invent XRF numbers |
| Occupant status vs OPP | Who is in the building, who is relocating, who is isolated, pregnant occupants, children under 6, pets, and the re-entry ban during work (Chapter 8) | Rewrite the unique OPP before prep; a copied OPP with yesterday's address fails uniqueness |
| Utilities | Water for wet methods and decon, power for HEPA vacuums and AFUs, HVAC shutdown points so you do not blow dust through the rest of the dwelling | You cannot start wet scrape or negative air on a dead panel you never looked at |
| Access | Crew entry, occupant exclusion, inspector's later path, elevator/stair use in multi-family | Containment in Chapter 10 has to match this path |
| Waste path | How bagged debris, filters, wastewater, and soil leave the regulated area without tracking through occupied rooms or over play-area soil | RCRA characterization is Chapter 17; the route is a walkthrough item now |
| Exterior / weather | Ground sheeting layout, wind, and whether the noticed acreage still matches (Chapter 11) | A bigger facade than noticed can become a more than 20% update under 9.2 |
| Clearance logistics | Who the certified inspector or risk assessor will be, and that the supervisor will not self-clear | Schedule independence now, not after final wet wash |
Worked example — report says three windows, field has five. The RA listed living-room windows A, B, and C as friction hazards. The walkthrough finds two additional original sash in the same room that were never XRF'd because a bookcase hid them. You do not assume they are lead-free. You also do not silently add them to the 1,000 ft² notice if the extra work pushes quantity more than 20%. Get testing or treat them as LBP under the inspection "similar painting history" rule as appropriate, revise the method matrix, check the notice quantity, and revise the OPP if isolation zones change. That is the walkthrough earning its keep.
Worked example — OPP says vacant, crib in the corner. The unique OPP assumed relocation. A toddler's crib is still in the adjacent room with a blanket over the doorway. Preparation cannot start on the strength of a PDF. Occupant protection is prior to abatement (745.227(e)(5)). Fix occupancy, then build containment (Chapter 10). The supervisor who is required on site for prep is the person who has to see the crib.
How this feeds Chapters 8 and 10
Write methods first, then write the OPP around those methods: replacement of windows produces whole-unit debris and a different isolation plan than spot encapsulation of a closet. Then design containment (critical barriers, negative air, decon — Chapter 10) to match both. Notification (9.1–9.2) already told EPA the address, dates, supervisor, and a brief description. The walkthrough is where that brief description either survives contact with the building or gets an updated notice the same day you still legally can.
Keep the paper pack together: inspection/RA, method matrix with reasons, unique OPP, received EPA (or State) notice, firm and supervisor certificates. That pack is what 745.227(e)(10) will turn into the abatement report, including the method-and-reason paragraph you already wrote.
Official sources: 40 CFR 745.227(e)(2), (e)(5), (e)(6), (e)(10)(vi).
Under 40 CFR 745.227(e)(10)(vi), what must the abatement report include about how the work was done?
During the pre-abatement walkthrough the crew wants to start hanging 6-mil polyethylene while the certified supervisor is 45 minutes away on a working cell phone. Is that presence legal?
What is the pre-abatement walkthrough for, before work-site preparation begins?
How should 40 CFR 745.227(e)(6) restricted practices enter the pre-job method plan?