The U.S. Environmental Protection Agency’s “Lead: Renovation, Repair and Painting” rule governing the work of professional remodelers in homes with lead-based paint took effect April 22, 2010.
The EPA rule requires lead-safe work practices in pre-1978 homes, including posting warning signs; 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 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 use disposable drop cloths.
Summary of the Rule
1. Training and Certification
As of April 2010, remodeling firms working in pre-1978 homes need to be certified. In addition to firm certification, the company must employ a Certified Renovator. When hiring a remodeler, home owners should verify the firm is certified and employs a Certified Renovator to be sure the work is completed properly.
2. Work Practices
The Certified Renovator has a number of responsibilities. The remodeler must distribute the Renovate Right brochure to the homeowner and ask them to sign the pre-renovation form several days before work begins. They must also 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 1100°F, 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 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.
Starting in July 2010, remodeling firms are also required to share with home owners a copy of the records created under the rule within 30 days of completing the renovation.
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 sq. ft. or exteriors disturbing less than 20 sq. ft.
• If the house or components test lead free by a Certified Risk Assessor, Lead Inspector, or Certified Renovator.
• The homeowner may also opt out by signing a waiver if there are no children under age six frequently visiting the property, no one in the home is pregnant, or the property is not a child-occupied facility. The EPA is revoking the opt-out waiver as of July 2010. This means all remodeling work conducted in pre-1978 housing must comply with the regulation after this date.
Learn more about EPA’s lead paint rule by visiting www.epa.gov/lead/pubs/renovation.htm.
Thanks to NAHB for the info.