Certified Lead Based Paint Renovator

The Environmental Protection Agency (EPA) has new Lead- based Paint Rules that take effect April 22,2010, relating to lead- based paint that may be encountered during renovation activity.  The EPA notes renovation activities such as sanding, cutting and demolition have the potential to release hazardous lead dust form lead- based paint that harm adults and children.  

Inside a home, dust inhalation is the most common lead exposure among children.  Young children are particularly vulnerable to the effects of lead because their bodies absorb it more readily than adults and their brains and nervous systems are more sensitive to its damaging effects.  The Centers for Disease Control and Prevention (CDC) recommends that states test children ages 1 and 2 years.  Children age 3 to 6 should be tested annually according to the CDC if they have never been tested for lead, live in or frequently visit a building built before 1950, visit a building built before 1978 that has been recently remodeled or have a sibling or friend who has been diagnosed with lead poisoning.

According to the EPA, lead can cause hearing loss, slowed growth and brain damage in children.  Adults may suffer memory loss, high blood pressure, nerve disorders and reproductive problems.  The EPA originally issued these rules in 2008 under the authority of the Toxic Substances Control Act to address lead- based paint hazards created by renovation, repair and painting (RRP) activities in target housing and child occupied facilities.  Full implementation of the rule was deferred until April 22, 2010 to allow states to administer and enforce their own RRP programs and training providers to apply for accreditation of their programs.

Target housing generally is defined as residences constructed before 1978 not including housing for the elderly or people with disabilities.  Child- occupied facilities generally are considered buildings constructed before 1978 and visited regularly by a child under six years of age on two days of any week, such as some schools, daycare centers, preschools or kindergarten classrooms.  The EPA estimates about half of the homes built before 1978 contain lead- based paint and nine out of ten built before 1940 contain lead based paint.  Under the new rules, a contractor (Arrowhead) must assume a home built before 1978 contains lead- based paint or, alternatively, as a Certified Contractor, Arrowhead can use an EPA- recognized chemical spot test kit to determine the presence of lead- based paint.

The EPA's new lead rules call for Certification of any company that performs RRP that disturbs lead- based paint, Certification for renovators (workers who perform and direct renovation activities) and training by a certified renovator of other workers engaged in the renovation, EPA accreditation of training providers and work practices for RRP projects.  

Certification and training is required for those companies and workers performing lead- based paint activities.  EPA regulations define renovation as "the modification of any existing structure, or portion of a structure, that results in the disturbance of any painted surfaces".  The EPA's trigger for regulating renovation activities is the creation of lead- based paint hazards.  This is distinguished from a lead- abatement project, which is designed at the outset to permanently eliminate lead- based paint and lead- based paint hazards from a building.  Roofing, siding, painting and remodeling contractors fall under the RRp rules when working on any project when painted wood surfaces are directly altered or when any painted surface is abutting the project area and painted wood surfaces can be disturbed.

The RRP Certification is a national certification valid in all EPA jurisdictions where EPA administers the RRP program (currently all states except Iowa, North Carolina and Wisconsin).  Arrowhead is properly and legally certified to perform required work according to this act nationwide.

Before beginning work, contractors must provide building owners and tenants with the EPA pamphlet Renovate Right: Important Lead Hazard Information for Families, Child Care Providers, and Schools, which can be accessed at www.epa.gov/apptintr/lead/pubs/renovaterightbrochure.pdf.  Compliance with this pamphlet must be documented by Arrowhead and all contractors.

As a Certified RRP firm, Arrowhead must ensure each renovation project covered by the new RRP rule is performed and/or directed by a certified renovator responsible for ensuring compliance with the work practices standards of the regulation, according to the EPA.  Arrowhead is responsible for "critical tasks" during a renovation, such as posting warning signs, establishing containment of the work area and post renovation cleaning verification.  As a Certified Renovator, Arrowhead was properly trained by an EPA accredited training provider.  Arrowhead completed an initial eight- hour training program and must complete refresher training every five years.

Renovation activities, including critical tasks described, may be performed by other trained workers, not necessarily certified renovators, but only under the direction of a certified renovator.  Such other workers may be provided with on- the- job training in renovation activities by a Certified Renovator.  A Certified Renovator is not required to be on a site at all times but must be present when critical tasks are performed.  According to the EPA, a Certified Renovator must regularly direct work performed by others to ensure EPA's work practices are followed.

EPA notes work practices established under the RRP rules must be followed to minimize lead- based paint exposures.  These include prohibiting the use of power sanders, power planers and high temperature (higher than 1,1oo F), heat guns or torches, waste handling and cleaning requirements, and post- renovation cleaning verification.  In addition, windows and doors within 20 feet of the renovation must be closed and the ground under the renovation where paint debris might fall must be protected by plastic sheeting.  Minor exterior renovations that disturb 20 square feet or less of painted surfaces are exempt from the RRP rules as long as prohibited work practices are not employed.

If you have any additional questions or concerns about the new RRP rule, or would like additional information, please contact our office.