The EPA regulates the certification of lead abatement contractors for lead-based paint practices during renovations, repair, and painting. This program is different than obtaining a license for full lead abatement which, for contractors in California, the certification and licensing is done through the California Department of Public Health, is mandated by the California Code of Regulations mainly under Title 8 and Title 10, and are outlined by the US Department of Housing and Urban Development (HUD) for dwellings. See the above for details on full lead contractor certification.
On the other hand, the EPA’s program is called the Lead-Based Paint Renovation, Repair, and Painting Program (EPA RRP Rule). The program was first formed in 2008. The majority of the rules were put in place to help protect children under the age of 6 that could come into contact with lead-based paint during or after a renovation, repair, or painting project in a home. Hence, most of the rules are in place for minimizing paint to be left on the ground where children would be crawling. Below is a list of common lead abatement questions and answers pertaining to renovations and emergency water, fire, mold, and trauma remediation work.
Is the EPA RRP Rule different than the requirements for a Certified Lead Abatement Contractor?
The procedures for removal of the lead-based paint are similar for removal of the lead paint but are, in general, more strict when full lead abatement is required. The rule is partly in place to prioritize what should be required to be abated by a certified abatement company and what can be removed by a properly trained technician adhering to the EPA RRP Rule. Both can be seen as “lead certified,” except on different levels.
When is it necessary to test for lead-based paint during a renovation?
The EPA mandates it when the material to be disturbed in a building built before 1978 has not already been tested and see not to contain lead. This lead paint testing can be done by an inspection, which is a service we can provide.
What buildings and building activities must adhere to the EPA lead paint RRP Rule?
In general, any building built before 1978 must adhere to the rule unless it has been tested to not contain lead paint in the area to be worked on. The work activities include maintenance / repair / remodeling, electrical work, plumbing work, painting, replacing windows, and carpentry work.
Are there any exemptions to the EPA lead abatement RRP Rule?
Yes. The following do not require adhering to the rule:
- Buildings built in 1978 or later
- Buildings for the elderly or disabled individuals unless the building is expected to house children under 6 years old
- No-bedroom dwellings (dorms, studio apartments, etc)
- Minor maintenance and repair work that agitates less than 6 square feet of lead paint per inside room, or 20 square feet if the work is being done outside the building
When lead-based paint is tested or known to be present, when is “full” lead contractor certification abatement required and when is just the EPA lead safe practices guidelines required?
- The EPA notes that work under 6 square feet of lead paint inside a building or 20 square feet if the work is done outside the building only requires the use of lead safe practices, not the use of a certified lead abatement.
- Whenever lead is present in any amount, the minimum requirement is to use the EPA lead safe practices guidelines. If the amount of lead is at or above the 6 and 20 square foot rule, full certified lead abatement is required.
What are the general requirements for cleaning for the EPA RRP Rule?
- All workers and individuals in the work area should be wearing proper personal protective equipment (PPE) such as masks, eye protection, light gloves, etc
- Warning signs need to be posted where work is being completed
- Training in compliance with the EPA training program
- Containment (engineering controls) set up to minimize air born lead paint to leave the room that the work is completed
- Plastic should laid below the area to be disturbed to collect any lead paint falling to the ground
- HEPA air cleaning machine(s) used during work
- HEPA vacuuming all exposed surfaces (dry cleaning) to removal all dust from the work area
- Wet wiping all exposed surfaces to remove all dust from the work area
- Bagging and disposing of lead-containing paint (regular disposal similar to normal garbage)
- Visual and/or testing of all lead-containing paint being removed (white cloth method or formal 3rd party testing, depending on the requirements of the agency governing the area or the contract requirements)
What the requirements specific for emergency renovations?
As defined by the EPA, emergency renovations are “activities that were not planned and if not immediately attended to present a safety hazard or threatened equipment and / or property with significant damage.” For emergency restoration work, this would include any water, fire, mold, or trauma remediation activities. To the level of responding to the emergency, the requirements for containment, warning signs, waste handling, training, and certification are not required for emergency renovations. However, emergency renovations still must adhere to the requirements for verification of cleanliness.
If you have a water, fire, mold, or trauma remediation need, give us a call for 24/7 emergency service. Our technicians and project managers are trained for proper EPA lead-based paint procedures and will walk you through the steps, expectations, and address any of your concerns. If the levels of lead-based paint to be disturbed requires full lead abatement, we will assist you in proper removal. Call us for an inspection at 619.597.2003 to determine your options and to take care of your home and family from start to finish.