EPA to Require Glazing Contractors be Certified
for Lead Abatement by April 2010
December 28, 2009
According to the December 2008 Small Entity Compliance Guide
to Renovate Right, EPA's Lead-Based Paint Renovation, Repair and
Painting Program (RRP), contractors (including those who replace
windows) who disturb painted surfaces in pre-1978 homes are required
to be certified in lead abatement before these regulations become
effective in 2010. Companies that don't comply with the regulation
can be fined $32,500 per violation, per day for non-compliance.
Many glazing contractors have remained unaware of the impact the
coming regulations will have on them. And this impact may be even
more severe if a rule proposed in October 2009 by the Environmental
Protection Agency (EPA) goes into effect that would remove an opt-out
clause. The "opt-out" provision currently exempts a renovation
firm from the training and work practice requirements of the rule
where the firm obtains a certification from the owner of a residence
he or she occupies that no child under age six nor pregnant woman
resides in the home and the home is not a child-occupied facility.
These new regulations also have implications for contract glaziers.
While exempt from emergency repair work, for non-emergency repairs
the contract glazier would be held to the same guidelines as anyone
else. According to the RRP, contract glaziers disturbing painted
surfaces on a non-emergency repair in a pre-1978 home that is more
than 6 square feet in any particular room (interior) or more than
20 square feet per side (exterior) must follow lead-safe work practices.
Considerations for contract glaziers working on these jobs include
determining whether the glazing compound was painted over; whether
the glazier would be disturbing any painted surface; and checking
to see whether the painted surface is on the interior or exterior.
In an EPA press release dated October 22, Steve Owens, assistant
administrator for the Office of Prevention, Pesticides and Toxic
Substances, said the proposed rule will further increase protections
for children and their families from lead-based paint hazards associated
with home renovation and repair. In the press release, the EPA said
it expects to finalize the rule by April 2010.
The RRP applies to residential houses, apartments and child-occupied
facilities such as schools and daycare centers built before 1978.
It includes pre-renovation education requirements as well as training,
certification and work practice requirements. According to the RRP
it applies to "anyone who is paid to perform work that disturbs
"Renovation is broadly defined as any activity that disturbs
painted surfaces and includes most repair, remodeling and maintenance
activities, including window replacement," according to the
HERE to read more about the regulations.
to let us know if you are aware of these regulations or have taken
the certified renovator class. The USGNN.com staff would like to
hear about how your company is preparing for these changes.
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