Mark the date April 22, 2010 on your calendar. It is the day when the Environmental Protection Agency’s new rule, “Lead: Renovation, Repair and Painting,” goes into full compliance, and it could have a huge impact on your business.
Electronic systems contractors performing installation work inside homes or buildings built before 1978, which are occupied by children under six years of age, or by a pregnant woman, must be aware of, and comply with, the EPA rule.
To comply with the rule, integrators must earn a new certification by completing an eight-hour, EPA-approved Certified Renovator course.
Half of the course can be taken online, and the other half is “hands-on” training, says Jack E. Leonard, Ph.D., president of the Environmental Management Institute in Indianapolis, Indiana. Two firms currently offer the hands-on training portion, and CEDIA is working in collaboration with the firms to streamline the process for everyone in the CEDIA community.
Integrators can start the certification process online (www.epa.gov/lead/pubs/firmapp.pdf) and by paying the fee. EPA certification is valid for five years, and the fee structure varies. The fee could range from $300 to $550 depending on the jurisdiction and what type of certification for which your firm is applying.
This Old House
The new rule has evolved from the 1992 Lead Poisoning and Prevention Act, and affects renovation, repair, and painting projects that disturb more than six square feet of space on an interior wall, or 20 square feet on an exterior wall.
After April 22, 2010, if your firm is not certified, the EPA can assess fines and you can be subject to liability lawsuits. Ensuring that all workers on the job have been trained by a certified renovator is also important, as is keeping proper documentation and records.
CEDIA recommends that integrators be present during project setup to ensure that access and dust control procedures are in place and that the cleanup removes any dust/debris around the worksite. After the work is done, integrators must notify the homeowner of the cleaning verification. Again, it’s important to keep accurate records and files.
Justifying the Cost
It’s not an ideal time for integrators to pay additional fees out of pocket, but the positives far outweigh the costs, Leonard says.
Lead-based paint is the most common source of lead poisoning for children in the U.S. Lead was widely used in most interior and exterior oil-based paint prior to 1950. Improper renovation of homes with-lead based paint can generate lead in the air, dust, and soil in and around the home.
“Lead poisoning is the most common preventable health problem for children in the United States today,” Leonard said.
National surveys estimate that more than three-million children six years of age and younger have lead poisoning. The condition can lead to learning disabilities and mental retardation.
The EPA awards grants to fund lead poisoning prevention activities in local communities and across the nation. The EPA’s National Community-Based Lead Grant Program, EPA’s Targeted Lead Grant Program, and Tribal Lead Grant Program are three of those grants.
The Fine Print
This is a federal ruling, but some states have submitted to the EPA variations to the federal rule. This means that the state rule, once approved by the EPA, would override the federal rule. If someone is working in a state that has state jurisdiction, they must comply with the state rules, training, and certification.
A table provided by the National Center for Healthy Housing lists the states that have submitted variations. The NCHH is a nonprofit organization dedicated to establishing healthy, green, and safe homes for families across all income levels through research, education, training, and policy efforts.