April 2010 saw a new round of lead regulations from the Environmental Protection Agency (EPA), specifically the Lead Renovation, Repair, and Painting (RRP) rule. The new rule (which Robin Pharo covers in the August 2010 issue of Hardwood Floors) lays out guidelines contractors must follow when renovating certain buildings and homes. But as they all do, regulations come at a cost.
First, the basics: The rule states that the EPA's lead-safe techniques must be applied when disturbing more than six square feet of a coated surface in any pre-1978 child-occupied facility or home. Any coating, not just paint, is included in the term "coated surface," including stains, shellac, or varnish, which of course means flooring contractors are included in this rule. So if you're sanding and resurfacing or replacing flooring in a building that falls within these guidelines, this new lead law applies to you too.
Here are the buildings that fall under the new RRP rule and those that don't:
So how do you comply? The first step is to designate one or more employees "certified renovators." These individuals must attend an eight-hour training session accredited by the EPA (click the link for more information). The cost varies, but you can expect to spend around $300.
Another requirement is for your company to register as a Lead-Safe Certified Firm, which also costs $300 (visit the link for registration info, timelines, etc.).
Both of these certifications are good for five years. Once your certified renovator is in place, he or she must enact the regulations learned at training, including those regarding posting of signs and jobsite setup and clean-up. The certified renovator doesn't have to be at a jobsite 24/7; he or she just must be available by phone when the coatings in question are being worked on.
Flooring is a big part of most reconstruction projects, and older homes that have stain or varnishes that contain lead are a real concern for a contractor, even more so now in light of this new lead law.
While these new regulations may seem inconvenient for the flooring contractor, protecting occupants is of prime importance. And peace of mind for any home or building owner is peace of mind they're willing to invest in.