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What Remodelers Need to Know About the EPA's Lead Paint Rule

The U.S. Environmental Protection Agency's Lead: Renovation, Repair and Painting rule governing the work of professional remodelers in homes where there is lead-based paint took effect April 22, 2010.

The rule addresses remodeling and renovation projects disturbing more than six square feet of potentially contaminated painted surfaces for all residential and multifamily structures built prior to 1978.

It requires a cleaning inspection after the work is completed and grants the remodeler flexibility in determining the size of the work area, which can reduce the size of the area subject to containment.

The EPA rule also lists prohibited work practices including open-torch burning and using high-heat guns and high-speed equipment such as grinders and sanders unless equipped with a HEPA filter.

Additionally, the rule establishes required lead-safe work practices, including posting warning signs for occupants and visitors; using disposable plastic drop cloths; cleaning the work area with HEPA vacuuming and wet washing; and individual certification through a training course.

The full rule and brochures for consumers and renovators can be downloaded from the EPA's Web site.

A 2006 NAHB study on lead-safe work practices showed that a home was better off after a remodel than before, as long as the work was performed by trained remodelers who clean the work area with HEPA-equipped vacuums, wet washing and disposable drop cloths.

Summary of the Rule
Review the points below for a quick summary of the new EPA lead paint rule.

1. Training and Certification
Beginning in April 2010, firms working in pre-1978 homes will need to be certified. Firms need to complete the application for certification and submit a fee of $300 to the EPA.

Along with the firm certification, an employee will also need to be certified as a Certified Renovator. This employee will be responsible for training other employees and overseeing work practices and cleaning. The training curriculum is an eight-hour class with two hours of hands-on training. Find an approved trainer by search the directory of EPA-approved training providers.

Both the firm and Certified Renovator certifications are valid for five years. A Certified Renovator must take a four-hour refresher course to be recertified.

Learn more about the responsibilities of a certified firm and certified renovator.

2. Work Practices
Once work starts on a pre-1978 renovation, the Certified Renovator has a number of responsibilities. Before the work starts this person will educate residents by distributing the Renovate Right pamphlet post warning signs outside the work area and supervise setting up containment to prevent spreading dust. The rule lists specific containment procedures for both interior and exterior projects. It forbids certain work practices including open flame or torch burning, use of a heat gun that exceeds 1100F, and high-speed sanding and grinding unless the tool is equipped with a HEPA exhaust control. Once the work is completed, the regulation specifies cleaning and waste disposal procedures. Clean up procedures must be supervised by a certified renovator.

3. Verification and Record Keeping
After clean up is complete the certified renovator must verify the cleaning by matching a cleaning cloth with an EPA verification card. If the cloth appears dirtier or darker than the card the cleaning must be repeated.

A complete file of records on the project must be kept by the certified renovator for three years. These records include, but aren't limited to: verification of owner/occupant receipt of the Renovate Right pamphlet or attempt to inform, documentation of work practices, Certified Renovator certification, and proof of worker training. NAHB believes that record keeping will be a major enforcement tool for the regulation.

Beginning in July 2010, remodelers are required by EPA to share a copy of records developed under rule requirements with the customer within 30 days of completing the remodeling work.

4. Exemptions
It is important to note that these work practices may be waived under these conditions:
  • The home or child occupied facility was built after 1978.
  • The repairs are minor, with interior work disturbing less than six square feet or exteriors disturbing less than 20 square feet being exempt.
  • If the house or components test lead free by a Certified Risk Assessor, Lead Inspector or Certified Renovator
 
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