13.3 Selecting Methods, Combining Methods, and Documenting Why

Choose the method that matches the component — then write why

Quick Answer: Combining methods on one dwelling is normal: replace the windows, encapsulate the ceilings, wet-scrape a small interior patch. 40 CFR 745.227(e)(10)(vi) requires the abatement report — prepared by a certified supervisor or project designer — to include a detailed written description of the abatement, including abatement methods used, locations of rooms and/or components where abatement occurred, the reason for selecting particular abatement methods for each component, and any suggested monitoring of encapsulants or enclosures. Restricted practices in 745.227(e)(6) cannot be excepted because the method is faster, cheaper, or demanded by the general contractor. If the right answer is replacement (Chapter 12), do not dry-scrape a friction sash to save a day.

Chapter 9 already told you EPA does not number a separate work-plan form. This section is the decision that fills (e)(10)(vi): pick a legal method per component, combine methods when the hazards differ, and write a reason that would still make sense if an inspector read it without you in the room. The occupant protection plan (Chapter 8) and the 5-business-day notice (Chapter 9) describe the job; they do not replace the report's method-and-reason paragraph.

Paint removal is one abatement tool. It is not the default. 745.223 names removal of paint and dust, permanent enclosure or encapsulation, replacement of painted surfaces or fixtures, and soil removal or permanent covering. Chapter 12 taught when replacement, enclosure, and encapsulant beat a scraper. Use this chapter when the film should come off a piece that is staying — and only with Section 13.1 methods that survive Section 13.2.

Decision table versus replacement, enclosure, and encapsulation

Worked example — mixed parlor. The risk assessment lists operable LBP sashes (friction plus reportable sill dust), an intact high-lead ceiling, 1.5 ft² of deteriorated LBP on one plaster wall, and a mouthed stool. Legal combination: replace the window assemblies and the stool; encapsulate the ceiling after a passed patch test (maintenance and monitoring schedule in the RA under 745.227(d)(11)(xviii) and suggested monitoring in the abatement report); wet-scrape the 1.5 ft² wall patch — or dry-scrape those defective spots, because 1.5 ft² is under 2 ft² in that room — then finish. Do not torch the sashes, dry-scrape the whole parlor, or encapsulate the chewable stool.

Worked example — historic sash that cannot leave. A landmarks commission bars replacement of 1928 sash. That is a real reason to choose on-site or off-site paint removal on the sash, plus jamb liner or enclosure so a friction LBP pair does not remain. It is not a reason to torch muntins, open-blast the frame, or dry-scrape the entire window wall. Heat gun below 1100°F, chemical stripper per the manufacturer with ventilation, wet methods where electrical allows, or take the sash to a stripper and bring it back. Write historic retention plus friction control as the reason, not crew preference.

Combining methods is expected

One dwelling rarely has one hazard type. Nothing in 745.227 requires a single method for the building. Combine when the component changes. Typical legal mixes:

• Replace windows and doors (friction and impact) and enclose stair soffits and encapsulate intact bedroom ceilings and wet-scrape a small interior plaster patch.
• Take kitchen doors off-site for chemical stripping and replace the mouthed stool and use a HEPA-shrouded sander on a porch column.
• Permanently cover soil at the play area (Chapter 15) and use interior methods from Chapters 12–13 on the dwelling.

What you may not combine: a legal method plus a restricted practice just on the hard parts. Replacement of windows plus torching the remaining parting bead is still torching. Encapsulation of a ceiling plus an uncontained belt sander on the cornice is still machine sanding without HEPA. Wet-scraping 1.5 ft² plus dry-scraping the other 80 ft² in the same room is still an illegal dry scrape.

HUD Guidelines treat mixing methods as ordinary project design. EPA's report rule is what makes the mix visible: each component gets a method and a reason. If the file only says abated the unit, you have not met (e)(10)(vi).

Document the reason per component — 745.227(e)(10)(vi)

An abatement report shall be prepared by a certified supervisor or project designer. Among other contents, it shall include:

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.

Chapter 9's pre-abatement walkthrough is when you lock this list — not the night you write the report. If the method changed in the field (the chemical would not lift; you switched a door to replacement), the report must describe what you actually did and why you switched. A notice that said chemical strip parlor trim does not freeze an illegal torch in place when the gel fails. Switch to a legal method and document the new reason.

Worked example — missing reason. Report: Abated all LBP in Unit 2A by paint removal. No rooms, no components, no reasons. Incomplete under (e)(10)(vi). Rewrite: Living room south double-hung: replaced sash, jamb, and stool because of friction and chewable hazards. Living room ceiling: liquid encapsulant X, patch test passed 2026-04-02, because the film was intact, dry, and non-friction; monitoring as in the RA. Hall plaster (1.8 ft² defective): wet-scraped because the component is sound and the area is a limited interior defect.

Worked example — RA options are not your reasons. The risk assessor listed replacement, enclosure, encapsulant, and paint removal as options for the same wall. The supervisor must select and say why. Pasting the RA's full option menu into the abatement report is not a reason for selecting particular methods for each component.

Never choose a restricted practice because it is faster

(e)(6) is not a cost-engineering clause. The following are not reasons that satisfy (e)(10)(vi), and they do not legalize a restricted practice:

• The occupant returns Friday.
• The GC will back-charge delay.
• The heat gun is broken, so we will torch.
• The HEPA shroud is at the shop, so we will needle-gun in open air.
• Dry-scraping the whole room is quicker than misting.
• It is only a little over 2 ft².
• Historic reviewers are slow, so burn the paint off tonight.
• Replacement windows are on backorder, so open-blast the sash in place.

If removal is slow, change to a legal method — replacement, enclosure, encapsulant, off-site strip, wet work, HEPA-shrouded tools, heat gun below 1100°F — and write that reason. If removal is the wrong method for a friction window, Chapter 12 already gave you the better method. Restricted practices cannot be excepted by job pressure, occupant calendars, or missing equipment. Missing equipment is a reason to stop or substitute a legal method, not a reason to torch.

Clearance still follows whatever mix you chose. Interior action levels on or after January 12, 2026 remain 5 / 40 / 100 µg/ft². Visual dust, debris, and deteriorated paint must be gone before sampling (Chapter 18). Choosing paint removal instead of replacement does not buy a lighter clearance.

Official sources: 40 CFR 745.227(e)(6), (e)(10)(vi), and (d)(11)(xviii); 40 CFR 745.223; HUD Guidelines Chapters 12 and 13 as documented methodologies under 745.227(a)(3).