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Lead-Paint Certification Deadline Approaches EPA law applies to interior renovations Few dispute that lead is toxic and that dust from sanding, cutting, or otherwise disturbing lead paint can cause health problems both for children coming in contact with it and for adults creating the dust when renovating older housing. Most professional contractors are aware of the hazards and take appropriate precautions. But beginning next year, federal law will require contractors to be trained and certified under the U.S. Environmental Protection Agency’s 2008 Lead Renovation, Repair, and Painting Program (RRP). Any renovation activity – including wood flooring installations, repairs and refinishing – that disturbs six square feet on the inside of a house, school, or child-care facility built before 1978 will be subject to the regulations in the EPA program. EPA pamphlet. In fact, one provision of the RRP has been in effect since December 2008. It requires contractors to give property owners and occupants the EPA pamphlet “Renovate Right: Important Lead Hazard Information for Families, Child Care Providers, and Schools click here before starting any work on pre-1978 housing and child-occupied facilities. This pamphlet and other EPA lead-paint publications are available free at the EPA’s web site, click here. Contractors also must document their compliance with this requirement and keep a record of it for three years; a “pre-renovation disclosure form,” (click here for the form located on the EPA's web site) can be used until April 2010 (when a similar form will take its place). The bulk of the program’s provisions, however, will go into effect on April 22, 2010. Then contractors will have to follow EPA-prescribed lead-safe work practices; and company certification, employee training and certification, and additional recordkeeping requirements will kick in. Two pamphlets designed to help contractors comply with the new rules, “Small Entity Compliance Guide to Renovate Right” click here to download the PDF document and “Lead Safety During Renovation,” click here to download the PDF document are available free at the EPA’s Web site. Though the deadline is still several months away, the EPA recommends that anyone disturbing lead paint before then follow lead-safe work practices anyway, such as containing the work area, minimizing dust, and cleaning up thoroughly. Company certification. All firms, including self-employed contractors, working on pre-1978 housing will be required to be certified by the EPA. Initial firm certification will cost $300 and will need to be renewed every five years. Firms can begin applying to the EPA for certification on October 22, 2009, by submitting an “Application for Firms” click here to download the PDF document available from the National Lead Information Center (800-424-5323) and at the EPA’s Web site. Employee training. In preparation for the April 2010 deadline, the EPA has developed new lead-safety certification courses to comply with the RRP rules and currently is accrediting trainers to offer them; a list of accredited trainers is available on the EPA’s Web site. In each firm, at least one employee will need to become a “certified renovator.” This entails taking an eight-hour “Renovator Initial Training Course” from an EPA-, tribal-, or state-accredited trainer and earning a course completion certificate (a copy of which must be carried at any applicable job site). The EPA also has created a four-hour “Renovator Refresher Training Course” for contractors who already have taken an EPA/HUD lead-safety course. At least one certified renovator will have to oversee the job site to ensure compliance with RRP rules. This person will be responsible for testing for lead and containing and cleaning the work area, as well as training other workers in any lead-safe practices that apply to their assigned activities. Recordkeeping. Contractors will need to keep records for three years showing compliance with the RRP. The EPA has posted a sample recordkeeping checklist on its Web site. Examples of required records include lead-paint testing results, documentation that the EPA pamphlet was delivered, and documentation of lead-safe work practices. Some states and localities have requirements for renovations on pre-1978 housing that are stricter than the EPA’s. The National Lead Information Center (800-424-5323) is one source for information about state-specific lead-paint regulations. Adapted with permission, Professional Deck Builder magazine, July/August 2009, www.deckmagazine.com |
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