Major changes related to processing old lead paint during home renovations are looming in our not-too-distant future.
The changes are related to 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. The new rules are set to take effect in April 2010. Professional groups such as the Greensboro Builders Association and the National Association of Home Builders (NAHB) are working to spread the word – and understand the ramifications – of this new EPA law.
The Builder’s Association is arranging for speakers on the new law in the next several weeks. In the meantime, the NAHB has assembled a “Lead Paint Fact Sheet” that includes the following points:
1) Training and Certification
Beginning in April 2010, firms working in pre-1978 homes will need to be certified. In addition to firm certification, an employee will also need to be a Certified Renovator. This employee is responsible for training other employees and overseeing work practices and cleaning. The training curriculum for certification, in development with the EPA, will be an eight-hour class with two hours of hands-on training. Both the firm and renovator certifications are valid for five years. A Certified Renovator must take a four-hour refresher course to be recertified.
2) Work Practices
Once work starts on a pre-1978 renovation, the Certified Renovator has a number of responsibilities. Beginning with distributing EPA’s Renovate Right brochure to the homeowner and having them sign the pre-renovation form in the booklet. Before the work starts the Certified Renovator will 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.
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.
- 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.
- If the house or components test lead free by a Certified Risk Assessor, Lead Inspector, or Certified Renovator.
On or after April 22, 2010, no firm may perform, offer, or claim to perform renovations without certification from EPA in the targeted housing or child-occupied facilities, unless the renovation qualifies for one of the exceptions identified by the law.The term renovation is broad, and refers to the modification of any existing structure, or portion thereof, that results in the disturbance of painted surfaces, including the removal, modification or repair of painted surfaces or painted components, modification of painted doors, surface restoration, window repair, surface preparation activity; the removal of building components; weatherization projects, and a long list of other activities.
Builders are cautiously processing what this all means to standard home renovations. The historic preservation community is doing the same. In the end, 2010 might be a watershed year in terms of how we approach renovation and restoration.