What’s The Big Deal? Dust
Most contractors still don’t know that much about the rules or even about lead and how and why it’s so toxic. In a word, it’s all about dust. Dust, says John Zilka, former contractor, and a teacher and EPA-authorized trainer for KCS, is how lead gets into the body and does what it does. “Some folks believe the exposure pathways are through children eating lead paint chips, or through contaminated drinking water,” he says. “They don’t understand that lead dust is the major perpetrator. And the big issue is the dust created by renovation activity.” Which is why the EPA is adamant about getting the new rules in place for residential home improvement.
Lead enters the body through breathing, touching, tasting, or skin contact, and exposure is most commonly through the dust released during renovation. Lead accumulates in the body’s tissues to the point of toxicity, wreaking havoc on the nervous system. Lead poisoning can result in speech, language, and behavioral problems, even death. It’s especially damaging in a child.Containing and safely removing that dust is the point of the EPA procedures. That sounds simple but it isn’t. Which is why it takes an eight-hour course to explain how to do it.
Assuming your company is registered and has a Certified Renovator on staff, here’s what will be different after April 22:
1) In the first place, you’ll need to know if the house you’re working on or in was built before 1978. If the homeowner doesn’t know, it’s still your responsibility to find out.
2) If it is pre-1978, and the job you’re about to do involves removing or disturbing paint, you’ll probably need to test for the presence of lead in that paint. If the presence of lead is a near-certainty, you could save yourself the time and expense of testing by simply assuming that it is there and operate accordingly. In some markets ? such as the Midwest and the Northeast ? a large percentage of the housing stock pre-dates 1978.
3) In the event that your company is audited, nothing you do on any particular job to practice safe lead removal will mean anything unless it’s documented. (See “The Paper Trail,” page 32.) You are obligated to inform the homeowner if you find lead and have him or her sign off on it. Should the EPA or a state agency come knocking that too should be in the job file. For how long? At least three years. Berenson suggests six.
4) Before beginning work you’ll need to post warning signs indicating that lead-based paint will be disturbed on the jobsite. You’ll then set up the job so as to prevent any lead-bearing dust from spreading through the house. This will involve putting down plastic sheeting on the floor and taping plastic “walls” around the perimeter of the work area, covering HVAC openings, and similarly wrapping or protecting the homeowner’s possessions.
5) Burning or power-sanding lead paint, which releases lead into the air, is forbidden. Remove paint with approved chemical strippers.
6) When the work is complete, thoroughly wet- and dry-mop the area to remove any lingering dust from surfaces. Verify and document.
Prove It To Me
If all this sounds like a red tape nightmare, the fact is that, as Zilka says, contractors who already do maintain a clean jobsite are doing about 85% of what’s required. Before he took the CR course in December, for instance, Lett was half-convinced that the new lead safe-removal regs would put his company out of business by making him unable to compete, especially with small contractors. He, his general manager, and all the company’s installers as well as salespeople took a CR course, taught by KCS and sponsored by Bucks-Mont NARI, in Bucks County, Pa. The course “gives you a better appreciation of the need,” he says. “And a lot of it makes good sense.” He estimates that about half the houses that A.B.E. Doors & Windows works in were built before 1978.
“We had [KCS] come out here and train everybody,” says Brian Elias, president of Hansons Windows & Siding, a Detroit area company. “Everybody,” in this case means anybody having anything to do with production at Hansons. The company has spent about $250 per head, times roughly 100 people. That’s a lot of money, but Elias says he can’t afford not to take the new lead regulations seriously. “You have two choices: follow the law, or don’t do the work for the customer.”
In addition, Hansons paid to have its non-employee installers take the course to become Certified Renovators. “We told them that as a company we will cover the training bill the first time out,” Elias says. “And they could share in the training if they wanted to do this work.”
