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In the absence of an inexpensive, reliable lead paint test kit, the Environmental Protection Agency is allowing remodelers to send paint chips to certified testing labs to determine whether lead-safe work practices are necessary in the client’s home or any other residential building in accordance with the Lead: Renovation, Repair and Painting (LRRP) rule.
A detailed description of how to properly take a paint chip sample is provided in the EPA’s new "Paint Chip Sample Collection Guide."
Without the paint chip test or a negative result from a test kit, in homes built before 1978 the remodeler must assume that lead paint is present and work accordingly.
“EPA-certified renovators who choose to take paint chip samples to determine if lead-based paint is present in a work area will find this guide essential,” said NAHB environmental policy analyst Matt Watkins.
The EPA has listed all its recent amendments to the LRRP regulation that are now in effect.
In addition to allowing the contractor to collect paint samples, the agency has:
- Published "Steps to Lead Safe Renovation, Repair and Painting." While the document discusses working in a home using lead-safe work practices, it does not give the remodeler the information needed for proper recordkeeping.
A few suggestions on recordkeeping can be found in the "Small Business Compliance Guide to Renovate Right."
- Made additional edits to the "Renovate Right" brochure, which EPA-certified renovators are required to give to customers no more than 60 days and at least seven days before the actual remodeling work begins.
A revision on page 10 discusses lead-dust testing. If remodelers insert that page into copies of the earlier brochure, they are still considered to be compliant with the pre-renovation education provision of the RRP.
- Made changes to vertical containment requirements. For exterior renovations within 10 feet of the property line, the EPA is requiring vertical containment, but has given remodelers the flexibility “to design effective containment systems based on the renovation activity and the work site.”
For both exterior and interior work, the impervious sheeting on the ground/floor is now required to extend to the “edge of the vertical barrier.”
- Changed its requirements for HEPA vacuums, allowing the use of those purchased to meet 2008 requirements. The EPA’s revised language requires that “HEPA vacuums must be operated and maintained in accordance with manufacturer’s instructions.”
- Related to surface coating, the EPA has refined its definition of “painted surface” to include varnishes and other coatings; however, it does not include enameled surfaces like bathtubs or sinks.
For more information, questions visit the NAHB LRRP Web pages; or email Matt Watkins, or call him at 800-368-5242 x8327.
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