Hack-Outs Don't Require EPA Certification, Pros Say
May 19, 2010

As of April 22, the Environmental Protection Agency’s (EPA) Lead-Based Paint Renovation, Repair and Painting Program (RRP), has required contractors—including those who replace windows—who disturb painted surfaces in pre-1978 homes to be certified in the EPA’s lead safe work practices. However, numerous questions still surround the requirement, including confusion over whether certification is needed for “hack-outs,” where the glass is removed and then reglazed in but the frame stays in place. In these cases, only the painted putty would be disturbed—but some contractors have wondered whether that is enough to require certification.

“To the best of my knowledge the answer is no, you don't need RRP for this,” says Rob Martin of Glass Protection. “You're not ‘disturbing’ more than 20 square feet of paint (assuming you're installing the glass from the exterior).”

“The only potential exposure a glazing contractor would have is in the retrofit of windows to meet energy requirements,” says Donn Harter, president and director of technical services of the Americas Glass Association. “In this case, our association is opposed to the removal of the existing frame. A retrofit window is installed over the old frame. This then does not disturb the original painted frame.”

Harter adds, “It would seem that the glazing industry has little need for certification. Specialty contractors that do remodeling and demolition are directly in the line of fire.”

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