EPA’s new Lead-Based Renovation, Repair, and Painting Rule
Beginning April 22, 2010, the EPA’s new Lead-Based Renovation, Repair, and Painting Rule (RRP) takes effect. Contractors now have to become EPA Certified Renovators, trained in Lead-Safe Work Practices, to work on homes, child care facilities, and schools built prior to 1978, when lead-based paint was banned from residential use. The rule applies to a broad category of tradesman who might disturb lead-painted surfaces through sanding, sawing, and demolition. This trades effected by the RRP rule are remodeling, painting, window replacement, plumbing, electrical work, heating & air-conditioning, demolition, plus work performed by trades like carpenters, electricians and handymen. The rule also applies to individuals working for rental property owners, schools, and day care providers, non-profits, and governmental agencies.
Lead is a health hazard to both children and adults. Lead poisoning is a serious health condition that may cause effects on the brain, nervous system, cardiovascular, muscular, skeletal, and reproduction. It is especially serious with pregnant women and small children impacting both their physical and mental development. Children are at a greater risk than adults because their bodies are still developing. In children lead can cause decreased intelligence, attention deficit disorder, and other learning disabilities. Pregnant women are especially at risk from exposure to lead because it is easily passed from the mother to the fetus.
Leaded-dust particles are often so small that you cannot see them, yet you can breathe or swallow them. These smaller inhaled or swallowed dust particles are more easily absorbed by the body than larger particles, and can therefore more easily cause poisoning. A few micrograms of lead is enough to poison an adult or child. A microgram is one millionth of a gram. To give some perspective, a sugar packet is approximately one gram. Divide that sugar packet into a million parts, and that is one microgram.
Lead was used as a paint additive for added durability and color until it was banned in the United States in 1978. Lead wasn’t only added to paint but also some other surface coatings, such as varnishes and stains. It’s estimated that 83 million households in the US were built prior to 1979, therefore the amount of people that are potentially exposed to lead paint is a serious issue. During typical home maintenance and certainly during a renovation or remodeling project, lead painted surfaces could be disturbed.
The RRP rule establishes required lead-safe work practices, including: posting warning signs for occupants and visitors by the certified renovator; establishing a containment area; using disposable plastic drop cloths; and cleaning the work area with HEPA vacuuming and wet washing. The rule also 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. In addition, the EPA rule also lists prohibited work practices ― including open-torch burning and using high-heat guns that exceed 1100 F and high-speed equipment such as grinders and sanders unless equipped with a HEPA filter.
After clean-up is completed, the certified renovator will be required to 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. In addition, the certified renovator will be required to keep a complete file of records on the project for three years. These records will include, but will not be limited to: verification that the owner or occupant of the home has received a copy of the “Renovate Right” pamphlet, or an attempt has been made to inform them of the pamphlet and its contents; documentation of work practices used during the project; and the certified renovator’s certification and proof of worker training.
If you have further comments or questions, check out the EPA website or contact them at 800-424-LEAD.
