The Environmental Protection Agency's Renovation, Repair and Painting (RRP) rule is widely considered a "game changer" for the residential remodeling industry. The rule takes effect April 22, 2010. On or before that date, any company working in a home or child-occupied facility built prior to 1978 must pay to be registered with EPA as a renovation firm. In addition, at least one employee from that company must receive eight hours of training from an EPA-accredited provider, and then pass a test, in order to be a Certified Renovator (CR). A CR will assume responsibility for on-site job supervision, training of other employees, and overseeing work practices, cleaning, and cleaning verification of all work in pre-1978 properties. The rules apply, with some exceptions, to interior work that disturbs 6 square feet or less of lead-painted surfaces, and 20 square feet or less for exterior surfaces. Consequences for not complying with the RRP can include penalties of up to $32,500 per violation, per day. In addition, EPA may suspend, revoke, or modify a company's certification.
Please read an excerpt from an article published on Angie's List.
EPA lead paint law goes into effect April 22
Published on March 25, 2010 by Emily Udell
Is it enough?
No safe lead level
One lead expert thinks the new EPA renovation rule is a good first step, but is concerned the lack of clearance testing provides the illusion of lead safety.
The federal regulation - known as the Renovation, Repair and Painting Program - holds contractors responsible for following strict protocol to minimize and contain lead dust during home improvements on residences built before 1978, the year lead paint was banned in the U.S.
According to EPA estimates, some 37.8 million homes and child-occupied facilities will fall under the aegis of the new rule.
"I think it's really important people know lead dust from renovation can cause elevated blood levels in children and in others," says Maria Doa, director of the EPA's National Program Chemicals Division. "Prevention is so important. You can do that by minimizing exposure to the dust."
While some contractors and homeowners say complying with the new law will drive up costs, many hail it as a positive step toward protecting children, pregnant women and others from lead poisoning.
But lead safety advocates, contractors and public health officials say there isn't enough time to get all affected service providers into compliance, that too few homeowners and contractors know about the law, and that the EPA won't be able to effectively enforce it.
The truth about lead
The law requires contractors to get certified in lead-safe work practices if their work disturbs more than 6 square feet of paint on the interior or a 20-square-foot section on the exterior of a home built before 1978. The older your home is, the more likely it contains lead-based paint, which can turn into a fine, ingestible dust if disturbed.
"There are a lot of misconceptions about lead," says Rebecca Morley, executive director of the Washington, D.C.-based National Center for Healthy Housing. "People think it's a problem of the past. People still believe that kids can only get lead poisoning by eating paint chips and that it's a problem with parenting and not with housing."
Health experts say anyone can be poisoned by lead, though children below the age of 6 are at particular risk. The Centers for Disease Control and Prevention estimates some 250,000 U.S. children between the ages of 1 and 5 suffer from lead poisoning, meaning they have more than 10 micrograms of lead per deciliter of blood. Children who have elevated blood lead levels can experience developmental and behavioral problems down the line.
Too few trained
Companies in some 50 categories on Angie's List - from remodeling to windows to flooring - could be affected by the rule. But advocates, trainers, contractors and public health officials interviewed for this story expressed concern that there were too few instructors to get all contractors trained by the April 22 deadline.
The EPA projects that 212,000 firms and 236,000 people need certification in order to comply with the law. But as of press time, only 817 firms and 13,669 contractors have done so, according to the agency. The EPA had only 133 accredited trainers, though Doa pointed out that some trainers travel out of state to host classes.
"We believe there's sufficient capacity," Doa says. She expects demand to increase as the deadline approaches. "In fact, classes are being canceled because they're not filling up." However, there were several states that had no trainers listed on the EPA's website in late February, including Rhode Island, Louisiana and Arizona. The EPA declined to comment on this point.
In order to get the word out, groups like the National Association of Home Builders, the National Association of the Remodeling Industry and labor unions have held webinars, produced podcasts and distributed information about the rule via print and online publications. The National Center for Healthy Housing has held classes to certify trainers around the country.
"I think the hardest people to reach are going to be the handypeople - the guy who works out of the back of his truck," says Patrick MacRoy, an EPA-certified trainer with the center.
Clearance versus cleaning verification
Many lead safety crusaders say the EPA's program is a reasonable, common-sense approach, but health experts believe it should go further by requiring a clearance test after the renovation is complete instead of cleaning verification.
Clearance testing involves collecting samples and having them analyzed at a lab for lead content while the cleaning verification involves doing a visual inspection, cleaning with a HEPA vacuum and a conducting a wipe test with dry and damp cloths.
Joseph Walseth, who works for the San Francisco Department of Health's childhood lead program, applauds EPA's rules, but doesn't feel the cleaning verification is adequate.
"If there is a dust clearance done at the end of the work, where sampling is done to make sure that there is no residual lead dust, that would be truly a comprehensive approach to the problem of lead hazards generated due to work that disturbs lead-based paint," he says.
But Shelley Bruce, who supervises the Wisconsin Division of Public Health's lead program, says cleaning verification is reasonable because renovators aren't lead abatement professionals.
"They're under the obligation with this rule to leave that house as clean, if not cleaner, than when they entered," she says. "Using the visual inspection and the cleaning pads and that protocol makes pretty sure they are leaving it no dirtier than when they arrived." She adds that the burden is on the homeowners to pursue more stringent testing.
Why it matters
Experts say anyone with concerns about lingering lead-dust hazards should consider hiring professionals licensed to conduct testing and abatement. Member Alison Stevens discovered her son Trevor had an elevated lead blood level after having some exterior painting done on her 1890 home in Arlington, Mass., last year.
After the incident, her family had their home lead tested and abated. "Lead dust hadn't even occurred to me as a source of concern," says Stevens, whose son now has a healthy lead level. She says the new EPA regulation offers peace of mind for future renovations.
"It seems like a smart place for the government to step in, especially in a place where the public is not fully educated, like we weren't."
