As of April 22, 2010 all contractors working in a house built in 1978 or before must be aware there is a chance it contains lead paint. The EPA has accredited training firms teaching an 8-hour class on how contractors are to handle renovations that disturb lead paint. The class is broken down into sessions that include a PowerPoint presentation and hands-on activities. At the conclusion of the class there is a 25 question test. The class fee ranges between $150.00 and $400.00. If you pass the written test with a grade of 68% or better and demonstrate the hands-on portion, you may become a Certified Renovator. The responsibilities of the Certified Renovator include: being present for set-up of the containment area, training employees how to use lead safe work practices and to clean up the renovation area.
The Certified Renovator has a choice of performing a test using a lead check swab or by assuming that the house contains lead. If assumed, all lead safe work practices must be followed. If a contractor is caught working in a house that contains lead, he can be fined $32,000. If proven that the contractor willfully knew the house contained lead and still did not use lead safe work practices, the additional fine is $32,000 and imprisonment. All individuals working on a Renovation, Repair and Painting project (RRP) must either be Certified Renovators or be trained by a Certified Renovator in lead safe work practices.
A Certified Renovator must either be employed by a Renovation Firm or if the person is a subcontractor, the firm must be designated as a Renovation Firm. The EPA requires firms to submit an application and pay a fee of $300.00 to become a renovation firm. Certifications are good for 5 years. Any retailer who subcontracts or employs contractors working in target houses, schools and childcare facilities built pre-1978 will be required to become a Renovation Firm. The Renovation Firm requirements are: distributing the Lead Safe Certified Guide to Renovate Right Pamphlet, getting signed confirmation of receipt of this pamphlet from the customer, employment of at least one Certified Renovator and keeping all required RRP records for 3 years. The required records include: Pre-renovation education documentation (proof of receipt, proof of delivery, waivers, etc), documentation of lead-based paint, training and certification records and cleaning verification records. CFI was informed the first of June that, If a company or contractor is not disturbing more than 6 square feet on the interior or 20 square feet on the exterior, the rule does not apply and therefore there is no need to issue the pamphlet.
The RRP rule exclusions include the following: renovations where affected components do not contain lead-based paint, emergency renovations, but still requires cleanup and cleaning verification, minor repair and maintenance activities and renovations performed by homeowners in their own homes. Minor repair and maintenance activities have been defined in the rule as follows:
Interior work disturbing less than 6-square feet per room of painted surface, unless this involves window replacement, demolition, or prohibited practices
Exterior work disturbing less than 20-square feet of painted surface
Or the entire surface area of a removed component is the amount of painted surface disturbed.
Prohibited practices include: open flame burning or torching, heat gun above 1100 degrees Fahrenheit and power tool usage without HEPA vacuum attachment. The HEPA vacuum has not been defined on which specific type is to be used yet, but soon will.
The RRP rule is enforced by the US EPA. The RRP rules apply to RRP activities conducted in target housing, schools and child-occupied facilities. The target housing is defined as any house that has a child 6 years or younger or a pregnant woman. Children under six are most at risk from small amounts of lead because their bodies are developing. During normal and frequent playing or hand-to mouth activity, children may swallow or inhale dust from their hands, toys, food or other objects. In children lead can cause:
Nervous system and kidney damage
Decreased intelligence
Attention deficit disorder
Learning disabilities or speech, language and behavior problems
Among adults,
Pregnant women are especially at risk from exposure to lead. Lead is passed from the mother to the fetus and can cause: miscarriages, premature births, brain damage or low birth weight. Lead exposure can cause permanent damage.
Symptoms of lead poisoning are not always obvious. Symptoms are not always diagnosed by medical personal. This could delay the effective treatment and increasing the likelihood of permanent physical and mental damage. The only way to determine lead poisoning is to take a Blood Lead Level (BLL) test. The amount of lead in blood is measured in micrograms per deciliter of the blood, a very small unit of measurement. A microgram is on millionth of a gram.
Follow these procedures:
Containment of the work area is a system of temporary barriers used to isolate a work area so that no dust or debris escapes while the renovation is being performed. The benefits of containment include: protecting workers and residents, preventing the spread of dust to the rest of the house or building or neighboring properties and easier clean-up.
Interior containment starts by posting signs and limiting access to the work area. You must notify residents to stay away from the work area.
Where practicable, remove all belongings and furniture from the work area. If they cannot be moved, then you are required to move them to a section farthest away from the work area and cover the items with plastic.
Secure protective sheeting to the floor with tape. Cover floors a minimum of 6 in all directions around the paint being disturbed.
If a chemical stripper is used, lay a second layer of plastic.
Lay plastic in all traffic areas leading from outside the containment area to the work area. It is recommended to us a tack pad at the end of the plastic walkway so dust on the bottom of shoes or shoe covers will remain in the containment area.
Make certain that all doors and windows are closed. If a doorway is being used as access, then a plastic entry must be created.
To do this:
o Tape a sheet of plastic three inches wider than the doorway to the frame and floor with painters tape
o Cut a vertical slit down the plastic, 6 from the top and 12 from the bottom in the center of the plastic.
o Next, 12 from the bottom cut a horizontal slit that is 12 from each side.
o All 3 cut edges are to be taped.
o Cut another section of plastic the same length and same width and tape it over the first plastic sheeting, securing only at the top.
o At the bottom, roll a broom handle on the plastic and tape to the bottom of the plastic 2 off the ground to keep the second section taunt.
o Also, seal off the HVAC openings or vents and electrical outlets either with plastic or magnet covers. Now you are ready to proceed with the renovation.
Protecting yourself and your workers is very important. Required clothing and gear and working procedures include:
Disposable painters hat
Disposable coveralls
Disposable n-100, r-100 pr p-100 respirator
Goggles
Shoe covers
Hands and face must be washed at the end of each shift
Workers are forbidden to eat, drink or smoke in the work area
At the end of each shift, workers should HEPA vacuum their clothing and shoes before leaving the containment area.
Remove gloves and face and hands are to be washed
Dispose of all used disposable clothing in plastic bags.
I wont cover exterior containment because as floor covering installers a majority of our work is interior. At the class for Certified Renovators, exterior containment is covered.
After the renovation is completed comes the cleanup. This is the most critical part of the entire job. It is our responsibility to make sure that no lead paint is left behind for the consumer. The clean up begins by first using a HEPA vacuum to clean walls and vertical surfaces from top to bottom. This includes window sills and inside the window box. Even though the window may have been sealed, lead dust may be present. Next wipe from top to bottom with either disposable wipes or clean white cloths with hot water and detergent. Always work from the farthest area away from the entry to the entry. Before any plastic is removed, mist with water to keep the dust from becoming airborne. When you reach the floor and have misted the plastic on the floor fold the top of the plastic dirty side in. Take special precautions for carpets. Seal all plastic into heavy duty garbage bags and seal the top with a gooseneck seal. This means that approximately 12 at the top of the bag is to be twisted and folded over in half and sealed with tape.
Now that clean-up is complete, it is important to check the effectiveness of the cleaning. First is the visual inspection. A thorough visual inspection is the main part of checking your cleanup. Put on disposable foot covers before entering the work area. Make sure there is adequate lighting in the work area. If needed bring in a spotlight or a bright white flashlight. Look for dust and debris on every horizontal surface in the work area and 2-feet beyond. Work from the farthest area from the entry to the entry. If you find visual dust then clean again. The next step is the cleaning verification procedure (CV). Wipe each window sill within the work area, using a single wet disposable cleaning cloth per sill.
Wipe uncarpeted floors and all countertops with wet disposable cleaning cloths. Wipe up to a maximum of 40-square feet per cloth. Compare each wipe to the CV card. If the cloth matches or is lighter than the card, the surface has passed cleaning verification and no further action is required. If the cloth is darker than the CV card, clean again and repeat the CV process. If the second wet cloth fails, wait 1-hour or until the surface is dry and wipe with an electrostatically-charged white disposable cleaning cloth designed to be used for cleaning hard surfaces. This completes the cleaning verification.
We must realize that this not only affects the flooring installers, but those who sell the flooring as well. I also realize this is an involved process and we ask ourselves if the government is getting carried away with rules and regulations. But, lead poisoning is a very serious situation. I look at this in two different ways. First, as a father of four, what would happen if one of my children at an early age was poisoned? What would happen if I as a contractor poisoned a child? I would want to do the right thing and make sure that my jobsite was lead-free. On the other hand as a contractor, I have to wonder what my liability is. I still think the right thing to do is to follow the EPA guidelines by removing lead dust and debris from our jobsite. I also must consider the equipment that must be purchased, the training, the time involved and how the costs will be passed on to those for whom I am working. They cannot be absorbed by the flooring contractor.
One more thing, CFI is in direct contact with the EPA as to the manner in which all of this affects the flooring installers. You may also visit www.epa.gov/lead. On the right side of the page, click Answers to Your Questions. There are only a few concerning flooring, so we suggest that many questions be posed by numerous individuals to encourage dialogue in reference to flooring installation. Consider this; if the flooring installation disturbs no more than 6 square feet of painted surface per room, the job is not covered by the RRP Rule.
Stay tuned, we will have more information in the next few weeks regarding information from the EPA.
Prepared by
Tony Buckhardt, CFI Master-II Installer, Chairman of the CFI Certification Committee, Member of the CFI Executive Board, CFI Trainer for Carpet, Laminate, Wood, Ceramic and Resilient, President of CFI Fort Wayne, IN, Manager of Carpet Cushions and Supplies of Fort Wayne, Head Coach of Pony League Baseball Team, Trainer for 4-H Shooting Sports, father of four and raises horses. 
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