EPA Makes Lead Monitoring/Abatement a Top Priority

Following the news that the Environmental Protection Agency (EPA) is requiring contractors (including those who perform window replacements) to be trained as a certified renovator if they disturb painted surfaces in pre-1978 homes, the EPA made another announcement regarding lead, proving that the agency has made lead abatement and monitoring a top priority.

Rules at a Glance:
Beginning April 22, 2010, the following rules apply:
1. Firms must be certified;
2. Renovators must be trained;
3. Lead-safe work practices must be followed. 
  
Responsibilities of a Certified Firm:
Firms performing renovations must ensure that:

1. All individuals performing activities that disturb painted surfaces on
behalf of the firm are either certified renovators or have been trained by a certified renovator;
2. A certified renovator is assigned to each renovation and performs all of the certified renovator responsibilities;
3. All renovations performed by the firm are performed in accordance with the work practice standards of the Lead-Based Paint Renovation, Repair and Painting Program;
4. Pre-renovation education requirements of the Lead-Based Paint Renovation, Repair and Painting Program are performed;
5. The program’s recordkeeping requirements are met.

Responsibilities of a Certified Renovator:
To become a certified renovator an individual must successfully complete an eight-hour initial renovator training course offered by an accredited training provider (training providers are accredited by EPA, or by an authorized state or tribal program). The course completion certificate serves as proof of certification.

According to the RRP, certified renovators are responsible for ensuring overall compliance with the RRP’s requirements for lead-safe work practices at renovations they are assigned.

A certified renovator must do the following:
1. Use a test kit acceptable to EPA, when requested by the party contracting for renovation services, to determine whether components to be affected by the renovation contain lead-based paint (EPA will announce which test kits are acceptable prior to April 2010 at www.epa.gov/lead);
2. Provide on-the-job training to workers on the work practices they will be using in performing their assigned tasks;
3. Be physically present at the work site when warning signs are posted,while the work-area containment is being established, and while the work-area cleaning is performed;
4. Regularly direct work being performed by other individuals to ensure that the work practices are being followed, including maintaining the integrity of the containment barriers and ensuring that dust or debris does not spread beyond the work area;
5. Be available, either on-site or by telephone, at all times while the renovations are being conducted;
6. Perform project cleaning verification;
7. Have with them at the work site copies of their initial course completion certificate and their most recent refresher course completion certificate &
8. Prepare required records.

In addition, all documents must be retained for three years from the completion of a renovation.

Records that must be retained include:
1. Reports certifying that lead-based paint is not present;
2. Records relating to the distribution of the lead pamphlet; and
3. Any signed and dated statements received from owner-occupants documenting that the requirements do not apply (i.e., there are neither any children under age six nor pregnant women residing at the home, and it is not a child-occupied facility);and
4. Documentation of compliance with the requirements of the Lead-Based Paint Renovation, Repair and Painting Program.