Lead Safety for Renovation, Repair, and Painting

In the State of Ohio, several laws described by the Administrative Codes provide guidelines for addressing paint that contains lead. These state laws are founded on the Residential Lead Paint Reduction Act of 1992, which is commonly referred to as Title 10.  

From this, the EPA and HUD developed a joint curriculum to provide remodeling contractors and the public with training on working around lead-based paint. This program and the associated laws are described as the Lead Safety for Renovation, Repair, and Painting (RRP rules). 

Any contractor hired to work on homes built before 1978 must have an EPA certification and use lead-safe work practices during their renovations. This EPA RRP Certification does not permit lead-based paint abatement activities (i.e., Lead Hazard Control Orders issued by a local Health Department). 

Any lead-based paint abatement activities must be completed by a state-licensed Lead-Based Paint Abatement Contractor who must also obtain the RRP Certification as well. 

Just to refresh your memory, lead-based paint is any paint (or varnish) that contains more than 1.0 mg/cm² or 5,000 ug/g (also referred to as 0.5 percent) of lead. In 1978, the EPA made it illegal for lead-based paint to be sold for most applications.  

The reason lead was added to paint was because of the wide variety of color pigments that could be created by using lead.   The problem is that the greatest health risk in our population to lead exposure is children under the age of 6 years old.  

This exposure is not from chewing on a windowsill but rather from ingesting dust from hand-to-mouth activity.  Cleaning the window sills, window troughs, and floors keeps this dust to a minimum.

The RRP training is an initial one-day class and a four-hour refresher every five years. The student manual used in the class describes the methods of preparing a work area, removing and stabilizing the paint, and cleaning after the work is completed.  

The student manual is EPA-740-R-09-002. Thus, a homeowner can purchase a copy and learn how to safely complete the work. This manual also provides guidance on methods for simple maintenance.

A homeowner should be aware that a certified RRP company must have an employee who has taken the RRP Renovator Course.  Both the Certified RRP company and the trained employee must have a certification number provided with documentation on any project.  

This employee may act as a site supervisor with other employees who have not had formal RRP training. The site supervisor is expected to train the other employees in safe work practices. The site supervisor must be onsite for the project's setup and cleanup and be available to return to the site within 2 hours of notice in the event of a problem. The site supervisors are not required to remain at the site during all of the project tasks.  

So where does this leave the homeowner?  Many remodeling companies do not know of RRP rules or simply don’t care to comply.  There are heavy fines for choosing to ignore the RRP certification requirements, but it is hard for the state to catch them.  

Hopefully, by reading this, contacting your health department, or your local Building Industry Association, a company or homeowner can discover this certification requirement and learn how it protects them from spreading lead dust contamination throughout their home.  It is very important that a homeowner hire only an RRP-certified firm to complete any remodeling, maintenance, or repairing of their building if it is older than 1978.  

Any contract signed by a homeowner should have the company's RRP registration number identified and the site supervisor’s name and certification number.

Many rental property owners are under the impression that their maintenance staff can maintain these older properties. This is not correct. The rental company must be RRP registered with a certification number, just as any contractor. Also, at least one maintenance person must have the RRP training.  

If homeowners hire a contractor, they should know there are Prohibited Practices on an RRP project to remove or disturb lead-based paint. These are the use of an open flame to burn or torch a painted surface, the use of a heat gun that produces a temperature above 1,100 degrees Fahrenheit, power sanding, grinding, planning, needle guns, and abrasive blasting without a shroud or containment system equipped with a HEPA vacuum.

When talking to a remodeling contractor, the homeowner should confirm that their contractor accepts the responsibility for keeping all records on their PPR project. The following are required:

• Pre-renovation education documentation
• Documentation of lead-based paint
• Training and certification records
• Cleaning verification records

If you have a contractor working on your property, you can require an independent Clearance Test. This method collects dust samples from the window areas and floors for laboratory analysis. The laboratory results are compared to the EPA maximum threshold values to confirm that the home is safe to occupy.  

Please note that the person who completes the test must be a licensed Clearance Test Technician or a Risk Assessor.  These are licenses that are issued by the state.  The results of the Clearance Test are not provided to anyone but the contractor and yourself. 

But if the results of the laboratory analysis exceed the EPA threshold values, then the work area must be recleaned and retested at the expense of the contractor; this should be in your agreement with your contractor.  The Clearance Test is an important step to verify your home is safe to live in.  

Be aware there are exclusions to the RRP rule, these are.

• Renovations performed by a homeowner in their own home.
• Emergency renovations
• Renovations that do not disturb materials that are lead-based paint.
• Minor repair and maintenance activities (6 square feet of interior surfaces or 20 square feet of exterior surfaces).  This does not cover replacing windows.

Millions of homes in the United States have lead paint. Working on these properties is a normal everyday event throughout the country. A homeowner should expect to complete a project using safe work practices, but more education and awareness by both the contractor and homeowner are needed to meet this standard.