Renovation & the EPA

Remodeling contractors need certification to meet new EPA lead requirements for exposure protection during renovations, repair, and painting. They'll also need PPE.

• By John L. Hierbaum, John Quinn
• Jun 22, 2010

Most remodeling contractors know that renovation of older structures typically involves disturbing lead-based paint and is likely to stir up hazardous lead dust and chips. Such scenarios are ripe for potential lead poisoning of workers, and in response, the U.S. Environmental Protection Agency (EPA) in 2008 issued a rule requiring use of lead-safe practices to combat the possible lead dust hazards common to renovation, repair, and painting activities such as sanding, cutting, and demolition.

As of April 22, 2010, EPA requires contractors performing renovation activities that disturb lead-based paint in pre-1978-built homes, child-care facilities, and schools to be certified and follow specific work practices aimed at preventing lead contamination. Contractors must document compliance with this requirement and provide certification to customers when asked to do so.

Contractors performing work in homes, child-care facilities, schools built before 1978 (the last year in which lead paint was legal for use in painting these structures) also must provide these homeowners, child-care facility owners/operators, schools, and parents/guardians of children under age six attending those facilities with Renovate Right: Important Lead Hazard Information for Families, Child Care Providers and Schools. This pamphlet provides basic information regarding lead safety practices when work is performed and can be downloaded for free at www.msasafetyworks.com/EPAlead. Topics covered include choosing a contractor, renovation and repair preparation, certification and training regulations for contractors, and additional lead exposure informational resources.

Need Certification?
Renovation contractors seeking EPA certification must submit an application and fee payment, with EPA's response expected up to 90 days after certification requests have been received. EPA advises renovation contractors to take the time to understand this rule in order to learn lead-safe job practices and be capable of explaining their procedures to clients. In addition to the usual painters' hats, gloves, shoe covers, and coveralls, EPA-recommended personal protective equipment includes eyewear -- preferably, ANSI-compliant safety glasses or goggles -- and high-efficiency, NIOSH-approved (National Institute for Occupational Safety and Health) disposable respirators.

ANSI- (American National Standards Institute Z87.1 standard) compliant eyewear is advised not only for keeping dust out of workers' eyes, but also for use during lead paint removal via chemical strippers. Chemical splash goggles (ANSI-compliant goggles with indirect ventilation) must be worn to help to prevent chemicals from getting into eyes, as well. Protective clothing helps to protect remodelers on the job, of course, but it also helps to prevent lead from leaving work areas and potentially spreading lead contamination, for example, to workers' homes.

N-100 vs. P-100 Respirators
One specific EPA publication mentions N-100-rated disposable respirators, which are but one respiratory option among many for lead protection, depending upon intended applications. The term N-100 denotes the particular NIOSH air-purifying respirator certification level. NIOSH-approved air-purifying respirators may be certified to various protection levels, as shown here:

As is also shown here, respirator filter N-class is the lowest level. N-rated filters must be used for no more than eight hours before disposal and must not be used for oil vapor protection. The other end of the spectrum concerns P-class filters, which may be used against either oils or non-oils with no time use restriction (beyond that of typical respiratory protection program requirements, such as increased breathing resistance) and are considered to be best in class. N-class and P-class filters provide the same protection against contaminants that do not contain oil. N-100 respirators are not approved for use against contaminants that contain oil because oil can degrade filter performance, reducing respirator efficiency and respiratory protection.

P-100 filters also may be a better choice if lead-containing oil-based paint is disturbed by remodelers (for example, with a heat gun), resulting in aerosolized oil-based paint. To protect wearers from low-level exposures to chemical strippers and lead paint, wearers should use respirators with cartridges that have P-100 filters in combination with special charcoal beds to help to trap gases generated by chemicals that cannot be stopped by particulate-only filters.

Want More Information?
You may have questions related to protecting yourself from lead exposure. EPA has designed several brochures to help address these questions, and OSHA requires respirator training as part of a complete respiratory protection program. Make sure to be ready for EPA's 40 CFR Part 745 Final Rule Lead: Renovation, Repair and Painting (RRP).

For EPA pamphlet Renovate Right: Important Lead Hazard Information for Families, Child Care Providers and Schools, visit www.msasafetyworks.com/EPAlead.