Bill's Building Blog

LeadCheck record-keeping forms

Keeping records for all RRP jobs is imperative. And it needn't be difficult if you're organized.

LeadCheck, one of the few test kits recognized by the EPA for testing for lead on wood and metal, makes available a full set of record-keeping forms. 

Download the full set of record-keeping forms

News — 'Lead-safe' certification a must for contractors

From The Poughkeepsie Journal:

Michael Shultz, owner of Millbrook Electric in the Town of Washington, says he carries a test kit to determine if lead-based paint is present before he starts a job. / Lee ferris/poughkeepsie Journal

See the whole story

LeadCheck still not approved for lead testing on drywall and stucco

Last year, I reported that LeadCheck swabs would soon be approved by the EPA for lead testing on drywall (sheetrock), plaster and stucco (in addition to wood and metal).

Unfortunately, that has not yet happened. Below are the EPA-approved test kits for various materials. Note that the State of Massachusetts administers its own program.

See the full EPA announcement

EPA fines painting company $32,508 for violating lead law, failing to inform homeowners of lead-paint dangers

Press release from the EPA:

(Seattle – April 6, 2011) College Works Painting, a company operating in Oregon, has agreed to pay $32,508 penalty for alleged violations of the federal pre-renovation rule. The U.S. Environmental Protection Agency alleged that the Irvine, California based company violated the federal pre-renovation rule while renovating nine properties in Portland, McMinnville, and Hillsboro, Oregon. 

The federal Pre-Renovation Education Rule requires painters, contractors, carpenters, property-management companies and others involved in remodeling or renovation of pre-1978 housing to provide home owners and occupants with an EPA Renovate Right lead hazard information pamphlet. In 1978 lead was banned from paint used for housing.

This pamphlet educates home owners or occupants on how to minimize exposure to hazardous lead dust that is often generated during sanding, cutting, demolition or other renovation activities. The pamphlet also provides resources for more information about lead and minimizing lead hazards.

The violations in this case took place during renovation work done in 2008.

College Works failed to establish and maintain records necessary to demonstrate compliance with Toxic Substances Control Act regulations, according to the EPA. College Works has corrected the violations and is now in compliance with EPA’s Pre-Renovation Education Rule.

“Families have a right to know about possible lead health hazards around the home,” said Rick Albright, Director of EPA’s Office of Air, Waste and Toxics in Seattle. “By reading the Renovate Right pamphlet families can learn how to avoid hazardous lead dust during renovations.”

Lead-based paint can be on walls, ceilings, woodwork, windows, or even floors. When lead-based paint on these surfaces is chipped, sanded, or scraped, it breaks into tiny, barely visible pieces that children can swallow or inhale. Even small repair and renovation jobs, including repainting projects, can create enough lead dust and chips to harm children.

Lead poisoning is a silent disease that can cause serious health consequences for children because of its detrimental effects on both physical and mental development. Nearly one million children in the country are affected by elevated lead levels.

For copies of the Federal pamphlet, Renovate Right, the Federal Rule, or information on the hazards of lead paint, call 1-800-424-LEAD or via the Internet at: www.epa.gov/lead.

Video Q&A — What building practices are prohibited when doing RRP jobs?

Hot Question: Is it a violation of EPA's Renovation, Repair, and Painting Rule (RRP) for a homeowner to hire a firm that is not certified?

From Bill Robinson and Train2Rebuild

RRP Question — Is it a violation of the Renovation, Repair, and Painting Rule (RRP) for a homeowner to hire a firm that is not certified? 

RRP Answer — From the EPA:

The Renovation, Repair, and Painting Rule (RRP) does not impose requirements on homeowners, unless they are performing renovations in rental space. However, the hired firm would be in violation of the RRP Rule if it was uncertified and performing a covered renovation. 

 

Most frequently asked questions about the EPA's RRP Rule on working around lead-based paint

From Bill Robinson and Train2ReBuild

Do you have a lot of questions about EPA's newly enacted RRP Rule? You are not alone.

Listed below are questions most frequently looked up on the EPA's website. Click on the links to find out the answers.

1. How much will it cost contractors to comply with the Renovation, Repair, and Painting (RRP) Rule?

2. Is it a violation of the Renovation, Repair, and Painting Rule (RRP) for a homeowner to hire a firm that is not certified?           

3. Who is covered by the new Renovation, Repair, and Painting (RRP) Rule?   

4. Do test results from a certified renovator using an EPA recognized test kit (40 CFR § 745.83) become an official part of the lead-based paint testing record for that house thus negating the need for a certified lead inspector or certified lead risk assessor to conduct the inspection in that area of the house? Can a certified renovator conduct a complete lead-based paint inspection and give the property owner as an inspection report?

5. If I mist and HEPA vacuum the plastic sheeting used by my firm for interior containment, can I move and re-use plastic sheeting on the same day and job?

 

More fun in an RRP class

This week, I gave another large RRP class for Rebuilding Together in New Orleans. These are AmeriCorps folks and they will be traveling around the country to do rebuilding work.

During the class, I told these young folks about my previous class and the fun we had. I showed them this goofy picture and challenged them to top that. They did, as you can see above.

The take-away: When dealing with young people, you have to make the training fun. It's a fact.

Half a million renovators now certified under EPA's RRP Rule

From Bill Robinson and Train2Rebuild

NAHB — After a somewhat slow start because of a lack of certified trainers and training facilities, the U.S. Environmental Protection Agency has now certified more than 511,000 trained lead-safe renovators and 64,000 remodeling firms to date, putting them in compliance with the Lead: Renovation, Repair, and Painting rule enacted earlier this year, agency officials told NAHB during a meeting at the National Housing Center on Nov.  4.

The agency also reported that it has stepped up its campaign to inform consumers of the need to use certified remodelers when remodeling homes built before 1978.

Read the whole article at www.nbnnews.com

Q&A: Does the EPA RRP Rule apply if an old space has never been painted?

From Bill Robinson and Train2Build

Question: Does the Renovation, Repair, and Painting (RRP) Rule apply where no paint at all is present, such as in a 100-year-old unfinished basement?

Answer: No.The RRP Rule applies to activities that result in the disturbance of painted surfaces.Where there is no paint to disturb, the RRP Rule does not apply.

See more about EPA RRP

Photo Source: Young House Love

Q&A: Can EPA RRP records be kept only on my computer?

Question: Under the RRP Rule, can the required records and documentation be stored electronically rather than as paper copies?

Answer: Yes. The renovation firm is responsible for retaining and making available to EPA all records necessary to demonstrate compliance with the RRP Rule for a period of 3 years following completion of the renovation. The RRP Rule does not specify the format in which records must be kept.

Search for more RRP Q&A

Product Review: D-Lead for EPA RRP jobs

Here at Train2Rebuild, we finally received the sample D-Lead test kits from Esca Tech Inc. the new boys in town for testing lead in homes built before 1978.

Previously, we had LeadCheck but it is not approved by EPA for testing on drywall and plaster.

D-Lead does have the EPA approval for testing on drywall, plaster and ferrous metal. And since D-Lead does not rely on a red color change, it will work on red, pink and black paint. As you may know, LeadCheck is not approved to test for lead on those colors.

My goal here is to use both D-Lead and LeadCheck to test for lead in the same area of an old, painted wooden door.

As you can see above, the D-Lead test kit comes with several components:

• Solution bottle 1
• Solution bottle 2
• D-Wipe towels
• Sample catch trays
• Scoring tool
• Cleaning rod
• Razor blade
• Waste disposal bag

Plus, you get an instruction manual — which is mildly confusing — in English and Spanish.

The first instruction is to read all of the instructions. What a concept. And I reccomend you do read those instructions, paying special attention to the safety guidelines.

After reading all the instructions, I used the D-lead test on an exterior porch door in a home built in the 1940s. It is easy enough:

• Take a sample with the sampling tool
• Place in Test Bottle 1
• Shake for 10 seconds
• Add 5 drops from Solution Bottle 2
• Give it  a shake for 10 more seconds.

According to the instructions the results should appear in 3-10 minutes.

Here is the test bottle after 10 minutes: 

What do you think? If no lead is present, the solution will remain clear. If the level of lead is under the limit that requires RRP practices, the solution will be lighter in color than the color strip on the bottle. If the solution's color matches or exceeds the color strip, lead is definitely present. I found this color a little ambiguous. Is it less than the color strip? Or equal to it?

And here is a comparison with LeadCheck, used on the place where I carved out my sample for D-lead:

This is quite clear: the red means lead.

So you gotta ask yourself, which do you prefer? LeadCheck is easy and quick but does not work on drywall and plaster. And it does not work on red, pink and black paint.

D-Lead takes a little longer and the color change leaves a little to your color sensitivity. However, it does work on drywall, plaster and ferrous metals, as well as all colors of paint.

Plus, it is still not clear how available D-Lead will be in the coming weeks.

The good thing is there is competition in the lead testing market and that can only be good for certified renovators.

In the coming days, I will try this out on other surfaces and I'll show it to my next RRP class to get their opinion and get back with you on how it all shakes out. Stay tuned!

Dispatch from Bill Robinson at Train2Rebuild

EPA's RRP Rule — From the historic restoration contractor's perspective

I, for one, am in favor of increased protection from lead paint, so our company intends to fully comply with the rules.

— Mark Landry, Historic Restoration Contractor

Most people have probably heard by now about the new rules put into place by the EPA concerning lead paint and renovations. The goal of the rules is to increase awareness of the danger of lead paint and decrease the risk of harm to occupants of old homes where lead paint is present. The rules apply to projects that involve renovation or painting of houses built prior to 1978 (when lead paint was banned). 

As a historic restoration contracting company here in Massachusetts, almost all of the buildings that we work on contain lead paint so we need to pay close attention to the requirements.

The rules, known as the RRP (Repair, Renovate, and Paint) guidelines have four main components.  The first is notification. Contractors must notify their clients to the dangers of lead paint. This is done by giving them a copy of the EPA's Renovate Right booklet.

The second component is certification: any company working on buildings that contain lead paint must be certified. The EPA logo on our home page shows that we have completed this step. In addition, workers must receive training and be individually certified to carry out renovations involving lead paint. Our carpenters have received this training (as have I).

Read the whole article at: www.landmarkservices.com

Dispatched from Train2Rebuild and Bill's Building Blog

D-Lead record keeping form for EPA RRP projects

In every EPA RRP-compliant project, part of the process involves keeping excellent records of what you tested and the results. This is called "protecting your assets."

D-Lead — one of the two testing kids approved by EPA for RRP jobs (along with LeadCheck), and the only one authorized for testing for lead on plaster, stucco, sheetrock/drywall — has provided a record keeping form. 

The two pages of the form are below (click to enlarge), or you can download the two-page form in PDF from D-Lead.

More D-Lead downloads:

D-Lead® Paint Test Kit Product Literature

D-Lead® Paint Test Kit Instruction Manual (English)

D-Lead® Paint Test Kit Instruction Manual (Spanish)

Buy your EPA RRP lead supplies all in one place

The cost for the supplies needed to comply with EPA's RRP Rule are not all that expensive. We're talking lead testing swabs for about 5 bucks, plastic sheeting, painter's tape, nitrile gloves, a respirator, protective coveralls, and things like that. 

Your biggest expense will likely be a HEPA vacuum for cleaning up.

What could be more expensive than the stuff itself is the staff time needed to gather it all together. And that's why various retailers have done the work for you.

Protective Products has a special section populated with items needed for RRP-compliant jobs.

See the RRP products here and below:

.	SKU #	Qty.	Description	Unit Price
	NHV-02		HEPA Lead Vacuum 2 Gallon	$324.90
	NHV-10		HEPA Lead Vacuum 10 Gallon	$489.90
	NHV-CB6		Collection Bags (6pk) for NHV-02 & NHV-10	$12.90
	NHV-DFB		Dacron Filter Bag for NHV-02 & NHV-10	$16.90
	NHV-MIF6		Micro Impaction Filters (6pk) for NHV-02 & NHV-10	$16.90
	NHV-HF		HEPA Filter for NHV-02 & NHV-10	$159.90
	NHV-RBB		11" Rotary Beater Brush Carpet Tool w/Wand	$49.90
	PC-5-1X		Non-Woven PP Coveralls with boots and hood 5 per package 1X	$10.90
	PC-5-3X		Non-Woven PP Coveralls with boots and hood 5 per package 3X	$11.90
	PC-5-5X		Non-Woven PP Coveralls with boots and hood 5 per package 5X	$12.90
	R-N100-5		N100 Respirators 5 per package	$29.90
	NG-50-M		Nitrile Gloves 50 pair M	$10.90
	NG-50-L		Nitrile Gloves 50 pair L	$10.90
	NG-50-1X		Nitrile Gloves 50 pair 1X	$10.90
	WS-2-W		Coroplast Lead Work Area Warning Signs (2) White 12" x 18"	$18.90
	WS-2-Y		Coroplast Lead Work Area Warning Signs (2) Yellow 12" x 18"	$18.90
	BT-4-180		Blue Masking Tape 4" x 180'	$14.90
	YT-4-90		Yellow Cloth Tape 4" x 90' x 9 mil	$9.90
	LBT-300		Lead Hazard Barrier Tape 3" x 300' x 1.8 mil	$6.90
	LW-90		Lead Safe TSP Wipes 90 wipes - 8" x 12"	$29.90
	LCS-8		LeadCheck® Swabs - 8 Pack	$24.90
	DL-PTK24		D-Lead Paint Test Kit	$58.90
	LSV-BR1		Lead-Safe Training Video	$68.90
	P6-11-50		Poly-Film 11' x 50' / 6 mil*	$31.90
*Not shown on this page – go to the Poly-Film page for more sizes. 11’ width allows compliance with EPA and HUD Lead-Safe RRP rules.

 

Q&A: Must my firm be EPA RRP certified if the subcontractors are certified?

Question: As a general contractor, we subcontract the entire renovation job to other companies rather than using our own employees. Under the Renovation, Repair, and Painting (RRP) Rule, does my firm need to have a certified renovator at the site?

Answer: Not necessarily. All firms performing renovations, including general contractors, must ensure that all individuals performing renovation activities on behalf of the firm are either certified renovators or have been trained by a certified renovator.

A firm acting as a general contractor may satisfy this requirement by hiring another certified firm that also takes responsibility for ensuring that all individuals performing the renovation activities are either certified renovators or have been trained by a certified renovator.

With respect to assigning a certified renovator who is responsible for any OJT and regularly directing other workers, a firm acting as a general contractor my satisfy this requirement by hiring another certified firm that in turn assigns a certified renovator to the job. However, this does not discharge the general contractor's liability to ensure compliance with the RRP Rule.

See more at ZipWall

RRP and Lead —'It takes as little as a grain of salt to poison a kid' — Kansas City Star

From the Kansas City Star:

Eight-month-old Oskar Ryan-Garrard did not eat paint chips. He didn’t swallow or suck on lead-laden toys either. He simply moved about his early 1900s Westport home and like any baby put his fingers and feet in his mouth. Then an optional blood draw showed a dangerously high level of lead.

A risk assessor found lead-leaden dust on the windowsills of Oskar’s home and on the floor and porch where he plays. Oskar’s dad is a house painter, and lead was on his work clothes, too.

“It takes as little as a grain of salt to poison a kid,” said Shannon Steinbauer of the Kansas Healthy Homes and Lead Hazard Prevention Program in Topeka.

And that grain of salt can find its way into any home: paint, residue from a parent’s occupation or hobby, everyday products.

See the whole story www.kansascity.com

Is lead-safe remodeling worth it? Four perspectives

From Popular Mechanics, the new EPA RRP Rule from four perspectives: contractor, regulator, consumer advocate and homeowner:

As of April 22, 2010, federal law requires that all U.S. contractors be certified to work with lead-based paint in homes, child-care facilities and schools built before 1978. Details of the new RRP (Renovation, Repair and Painting) rule appear in a brochure, “Renovate Right,” which contractors must give homeowners before work begins. The law requires certified renovators to be on-site to ensure that employees follow specific practices to prevent lead contamination. These include posting warning signs, taping up heavy plastic to contain the work area, minimizing dust by wet sanding, then cleaning with a HEPA vacuum and a wet mop. Certification takes 8 hours of training by an EPA- or state-accredited provider and costs from $200 to $400 per trainee. Not every employee of a remodeling firm needs to be certified, but the firm itself pays a $300 fee to obtain EPA certification. Contractors failing to comply could get hit with a civil penalty of up to $37,500 per incident, per day.

Contractor’s Perspective: “Even though it costs money, I actually think it’s a good idea,” electrical contractor and master plumber Pat Porzio says. “But of the 40 people in our training class, I was one of few who thought that.” Porzio estimates the law will add $500 to $1500 in labor costs, depending on the job’s size. The EPA estimates that the cost for containment, cleaning and verification will range up to $170 per job.

See all four perspectives at www.popularmechanics.com

Ask Bill: How do I find an EPA RRP class?

Ask Bill with Bill Robinson

Question: I want to become a Certified Renovator. How do I find an EPA RRP class?

Answer: I have a few suggestions:

1. Do a Google search on: EPA RRP classes (your state). There's a bit of a cottage industry happening with firms and trainers offering classes, so all the information is not necessarily compiled all in one place. This will give you a wide-ranging set of options.

2. Check out the handy directory on the ZipWall website. You just enter your state and a list of providers comes up.

3. Go to the National Center for Healthy Housing and see the array of classes offered through them.

4. Send me an email and let's discuss some options. As an accredited RRP trainer, I've taught hundreds of contractors, business owners and others. I don't want to seem immodest, but I get rave reviews for my ability to make this somewhat dry information a lot more interesting. And when you hire me to provide your RRP training, you get an outrageous deal on my new DVD: On-the-Job Training: RRP Lead-Safe Practices.