The Environmental Protection Agency’s new federal Lead-Based Paint Renovation, Repair and Painting Rule has gone into effect and roofing contractors need to be aware of the new requirements. The EPA issued a rule requiring the use of lead-safe practices aimed at preventing lead poisoning of children.
When integrating a new metal roof on a home built prior to 1978, contractors may have to cut into fascia boards or dormers. If your installation will require you to disturb more than 20 square feet of painted surface, it is the roofing contractors responsibility to notify the homeowner of the lead abatement process. (Most minor repair and maintenance activities that involve less than 20 square feet on exterior projects are exempt from the work practice requirements.) Failure to comply with the new requirements is a violation of the law and could cost you up to $37,500 per violation, per day.
Approximately three-quarters of the homes built before 1978 contain some lead-based paint. It may be on any surface, but is most commonly found on exterior-painted surfaces, interior woodwork, doors and windows. Common renovation activities like sanding, cutting and demolition can create hazardous lead dust and chips. So the EPA has made remodelers, siding and window replacement and roofing contractors the enforcement agents for addressing this problem.
“We’ve posted a lot of information about this topic on our website, says Bill Hippard, president of the MRA. “It is important for contractors to educate themselves on these new guidelines. Pre-renovation education and notification requirements are now in effect. And the EPA has made renovation and replacement contractors the responsible agent for compliance with these rules. Before you start any work on a pre-1978 residential house, you must distribute the lead information pamphlet entitled “Renovate Right: Important Lead Hazard Information for Families, Child Care Providers and Families.” The pamphlet is available at www.metalroofing.com and www.epa.gov/lead/pubs/renovaterightbrochure.pdf. If your job requires you to disturb 20 square feet of painted material you must conduct the renovation test for the presence of lead and comply with the EPA guidelines.
There are specific EPA guidelines for certification of contracting companies. Furthermore, all renovation companies, regardless of the number of employees, must be certified. To become certified you must have at least one employee complete an EPA or authorized state-approved training course conducted by an EPA or state-accredited training provider. Then all workers must be trained on work practices they will be using during the renovation. Renovation workers can be trained on-the-job by a “certified renovator.”
Requirements of a certified renovator
• Use an EPA approved lead test kit when testing for lead-based paint on painted surfaces and components being disturbed.
• Provide on-the-job training to other workers on the work practices they will be using; be physically present at the jobsite when warning signs are posted, while work-area cleaning is being performed.
• Regularly direct work being performed by others to ensure compliance with work practice standards, including containment requirements.
• Be available onsite or by telephone whenever renovations are being performed.
• Perform project-cleaning verification.
• Have most recent course certificates.
• Prepare required records.
All documents must be retained for a least three years following completion of a regulated renovation, repair or painting activity. This includes reports certifying that lead-based paint was not present, records relating to the distribution of the lead pamphlet, any signed and dated statements from owner-occupants the requirements do not apply to their location and documentation of compliance with the RRP Rules.
Enforcement of these rules begins October 1
Cynthia Giles, assistant administrator, Office of Enforcement and Compliance Assurance of the EPA, recently said in an effort to facilitate the transition to full implementation of the RRP rule, the EPA will offer additional and sufficient time for renovation firms and contractors to obtain the necessary training and certifications to comply. Until October 1, 2010, the EPA will not take enforcement action for violations of the RRP rule. Contractors must apply or be enrolled in a program no later than September 30, 2010. Training must be completed by December 31, 2010. To date, these training providers have offered more than 15,000 classes and have trained 300,000 people.
The EPA issued the Lead RRP rule because a disturbing number of America’s children are still poisoned by lead-based paint in their homes leading to learning and behavioral disorders. For more information, please visit: www.metalroofing.com
Learn more
For more information, please visit the contractor section of our website: www.metalroofing.com or call MRA’s contractor team at 410 534-6900. MR
Tom Black is the executive director of the MRA.
