While pondering the already stressed housing situation, please consider What Remodelers Need to Know About the EPA’s Lead Paint Rule.

The U.S. Environmental Protection Agency’s Lead: Renovation, Repair and Painting rule governing the work of professional remodelers in homes where there is lead-based paint was published in the Federal Register on Earth Day, April 22. The rule will take effect in April 2010.

The rule addresses remodeling and renovation projects disturbing more than six square feet of potentially contaminated painted surfaces for all residential and multifamily structures built prior to 1978 that are inhabited or frequented by pregnant women and children under the age of six.

1. Training and Certification

Beginning in April 2010, firms working in pre-1978 homes will need to be certified. Along with the firm certification, an employee will also need to be certified as a Certified Renovator. This employee will be responsible for training other employees and overseeing work practices and cleaning. The training curriculum is an eight-hour class with two hours of hands-on training. Both the firm and Certified Renovator certifications are valid for five years. A Certified Renovator must take a four-hour refresher course to be recertified.

2. Work Practices

Once work starts on a pre-1978 renovation, the Certified Renovator has a number of responsibilities. Before the work starts this person will post warning signs outside the work area and supervise setting up containment to prevent spreading dust. The rule lists specific containment procedures for both interior and exterior projects. It forbids certain work practices including open flame or torch burning, use of a heat gun that exceeds 1100°F, and high-speed sanding and grinding unless the tool is equipped with a HEPA exhaust control. Once the work is completed, the regulation specifies cleaning and waste disposal procedures. Clean up procedures must be supervised by a certified renovator.

3. Verification and Record Keeping

After clean up is complete the certified renovator must verify the cleaning by matching a cleaning cloth with an EPA verification card. If the cloth appears dirtier or darker than the card the cleaning must be repeated.

A complete file of records on the project must be kept by the certified renovator for three years.

I am not sure how many homes still have lead paint (remember paint on top of paint on top of paint, not just fresh paint) , but those that do are going to cost a lot more to remodel starting Earth Day, April 22.


Here are a few comments worth considering.

Black Swan: This looks like a law contrived by the big home builders.

Hell Is Like Newark: I took the certification course for the new EPA rules last week. I figured it will add about $1500 to $2000 in costs to a typical suburban home when I upgrade the insulation in a home.

Hell Is Like Newark: Enforcement hasn’t been worked out yet. Some States like NY are choosing to enforce it on their own. Contractors will likely have to show their EPA certifications when the renew their permits. The EPA could also offer a part of the $32,500 fine for non-compliance to local building departments if they inspect job sites to make sure the rules are being followed.

Taperwood: Speaking with a little knowledge of the building industry, this will be one of the most ignored laws in the business. Like the speed limit, it simply cannot be enforced. The pre-1978 housing stock is enormous, and the government wants these homes upgraded as quickly as possible. They are cutting their legs out from under themselves.

Mish: Not so fast Taperwood. I think you underestimate the willingness of states, especially California, to punish businesses, hoping to bail out BART and other insanities.

Lori In NC: I love great old architecture, especially some of the older homes that we have here in the US. I find it sad to think that this might deter folks from buying older historical homes that need repair and restoration.

Mike “Mish” Shedlock
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