RENOVATIONS IN HOMES BUILT PRIOR TO 1978 NOW REGULATED
Federal regulations issued in 2008 addressing Renovations, Repairs and Painting (RRP) of painted or coated surfaces containing lead-based paint (LBP) in homes built prior to 1978 became effective in April of this year. These regulations are a major initiative to reduce exposure to lead dust and minimize the potential for lead poisoning in homes and child occupied facilities.
What does this action mean to you? If you are planning on hiring a contractor to do RRP work in your home that may disturb lead-based paint, that contractor needs to comply with the regulations. They must be an EPA Certified Renovation Firm with an EPA Certified Renovator assigned to the project. They must be using lead-safe work practices during renovations and finally, and perhaps most importantly, your contractor needs to provide you with pre-renovation education.
Specifically, no more than 60 days before beginning a renovation, the Certified Renovation Firm must provide you the Renovate Right pamphlet as the owners / residents of the pre-1978 home to be renovated. The firm must either obtain the owner’s written acknowledgment or proof that the pamphlet was received before the renovation began.
Paint testing must be performed prior to renovation on all surfaces to be affected by the work, or you must presume the paint is lead-based. All testing must be performed by a qualified professional. The principal alternatives available are:
Surface-by-Surface or Limited Testing: In this technique, each surface involved in the planned renovation, repair or area to be painted is sampled or tested to determine lead content. The results of this project specific, limited testing shall be reported in a written testing report.
X-Ray Fluorescence Testing: This technique requires a special instrument and a specially-trained Certified Lead Inspector or Certified Lead Risk Assessor. The instrument tests by bombarding the paint film with gamma radiation that causes the lead in the paint to emit x-rays that can be read by a sensor in the instrument. The amount of lead in the paint is directly related to the x-rays read by the sensor. A computer program in the instrument calculates how much lead is in the paint film. This testing method is non-intrusive and is the most used.
The Renovation, Repair, and Painting regulations provide a couple of specific exclusions: first, if the activity only affects components that do not contain lead-based paint; and second, for minor repairs or maintenance consistent with the following guidance. Interior work disturbing less than 6 square feet per room of painted surface is exempt from the work practices requirements in the rule. Exterior work disturbing less than 20 square feet of painted surface is exempt from the work practices requirements in the rule. Finally, renovations performed by homeowners in their own homes are excluded.