Do you own a home or are you thinking about buying a home built pre-1978? If either is the case then the new EPA regulation concerning lead-based surfaces may affect you. The new regulation by the EPA is called the Renovation, Repair, and Painting (RRP) rule. The purpose of the rule is to guard against the possibility of lead poisoning through the use of lead-safe practices.
Prior to 1978 there were many products used in the construction of housing that contained lead, such as paint, stains, varnishes, and other surface coatings. Lead was added to these products to improve durability and color. The use of lead in these building products was banned in 1978 by the Consumer Products Safety Commission as the health risks to humans posed by lead became apparent. Lead exposure causes permanent health damage and is especially hazardous to children and pregnant women.
The activities typically associated with renovation, such as sanding, cutting, and demolition can create large amounts of lead dust and chips when done in homes containing lead-based surfaces. The new RRP rule went into effect on April 22, 2010, and it requires that all contractors who work on projects in pre-1978 housing must be certified and follow specific work practices to prevent lead contamination. Contractors must take an eight-hour EPA approved training course from an EPA-approved training provider which teaches specifically how to test for lead, contain the work area, minimize dust, and clean up thoroughly.
Few exceptions to the new RRP rule exist. Homes that were built pre-1978 and even some built shortly thereafter need to be tested for lead using an EPA-approved lead test wherever renovation activities are to take place. If lead is detected on any surfaces then homeowners can opt to do the work themselves on their own residence, but if they use a contractor to complete the work the contractor must have RRP certification and follow the RRP lead-safe work practices. Rental homes are not exempt from this rule and cannot be worked on with any renovation activities disturbing lead-based surfaces unless the landlord or the contractor has their RRP certification.
The effects of the new RRP rule are far-reaching, and significantly change the cost of renovation to pre-1978 housing. Maximum civil penalties for non-compliance can be up to $32,500 for each violation, regardless of whether firms are certified or not, so ignoring the rule is not a good option. Following lead-safe work practices adds significant time and materials to any project, not to mention the up-front cost of testing to determine if lead is present. Before even developing a scope of work the contractor should test for lead in the areas to be renovated, simply because if lead is found it will significantly change how the scope of work will be performed and the estimated costs. Also, those considering the purchase of a home built pre-1978 may also want to have some spot-testing done on the home that they choose, as the presence of lead-based surfaces will impact their abilities to perform renovation projects in the future. Some projects will become cost-prohibitive if lead is present due to the overwhelming additional cost of meeting the RRP rule standards.
To find out more about the new RRP rule you can go to the EPA website, http://www.epa.gov/lead/pubs/renovation.htm. We are a RRP certified firm so you are also more than welcome to contact us for more information as well.