Most people have probably heard by now about the new rules put into place by the EPA concerning lead paint and renovations. The goal of the rules is to increase awareness of the danger of lead paint and decrease the risk of harm to occupants of old homes where lead paint is present. The rules apply to projects that involve renovation or painting of houses built prior to 1978 (when lead paint was banned).
As a historic restoration contracting company here in Massachusetts, almost all of the buildings that we work on contain lead paint so we need to pay close attention to the requirements.
The rules, known as the RRP (Repair, Renovate, and Paint) guidelines have four main components. The first is notification. Contractors must notify their clients to the dangers of lead paint. This is done by giving them a copy of the EPA's Renovate Right booklet.
The second component is certification: any company working on buildings that contain lead paint must be certified. The EPA logo on our home page shows that we have completed this step. In addition, workers must receive training and be individually certified to carry out renovations involving lead paint. Our carpenters have received this training (as have I).
The third component consists of the actual procedures for carrying out the work. If the work involves disturbing more than 6 square feet of lead paint on the interior or 20 square feet on the exterior, the project must follow the guidelines. This includes properly setting up the work area with plastic and sealing off the work area from the rest of the house. The rules indicate correct procedures for using protective clothing, removal and disposal of lead paint-containing items, and for cleaning the site after the work is complete. They also ban certain techniques, such as grinding or burning lead paint.
These procedures are changing how renovation work is carried out. It's now very important to think ahead and take care of any demolition or invasive work while the containment area is set up. Painters must use different techniques, such as wet sanding. And all of us need to know when protective clothing and respirators must be donned.
The final component of the RRP rules is record keeping. From now on, when we carry out a renovation project we must keep records that verify the procedures we carried out for notification, testing, setting up, and cleaning.
A further wrinkle is that some states, including Massachusetts, have taken over the enforcement from the EPA. Contractors in Massachusetts must follow the new regulations written by the state, not the EPA rules.
There is a lot of anger and confusion in the contracting industry over these rules. First, it is an industry that is slow to change and these rules represent a big change, and some contractors are angry because they hate having to change the way they have always done things. I, for one, am in favor of increased protection from lead paint, so our company intends to fully comply with the rules. However, some of the anger out there, quite frankly, is justified because the rules are overly complicated and, in some cases, appear to contradict OSHA regulations. Since both the EPA and OSHA have the power to enforce their rules through fines, what is a contractor to do when it is impossible to be in compliance with both?
I think that eventually the added steps put in place to protect both occupants and workers will become second nature. In fact, I predict that the contractors that are in full compliance with the rules will start turning in contractors that are in obvious violation. Just recently a video surfaced on Youtube of a couple of painters in Maine grinding lead paint off a house and creating a cloud of lead dust. This type of work cannot be tolerated anymore. It's dangerous to the occupants and to the workers.
There is a significant cost to comply with these rules between training classes, certification fees, the materials and protective clothing required, and the extra time involved in setting up. Homeowners owe it to themselves to ensure that their contractors are certified, trained, and following the procedures. Yes, you can get a lower price by hiring a company that ignores the rules, but if they contaminate your home or yard with lead paint dust and endanger you and your family, are those savings worth it? Ask to see the contractor's certification and the training certificates for each individual worker. By law now, these must be on site at all times.
Let us know if you have any questions on the impact of these new rules on potential projects at your home. We're always happy to talk!