EPA Lead Paint Rules Take Effect – What does it mean for all of us?
As of April 2010, the US EPA’s Renovation, Repair and Painting (RRP) rule 40 CFR, part 745 goes into effect. The new rule requires that contractors working on houses constructed before 1978 become “Certified Renovators” and use lead paint safe renovation practices and procedures.
For centuries, going back to the Romans, the element lead (pb) has been been documented to be a poisonous chemical, particularly for the very young. In this country it has long been used as an additive in oil based paint. In Europe, lead paint was banned in the 1920’s and 30’s, but the US didn’t enact a ban until 1978. (Note that lead paint is still used for certain industrial applications including marine paint and the yellow lines on your neighboood street.)
Homes built before 1978 have a high likelihood of having lead based paint, particularly on woodwork since lead was an additive in oil based paint, not in water based paint. Note that some percentage of homes built after 1978 also have proven to have lead paint, even though lead paint was banned for residential use in 1978.
The new EPA rules require the following:
1 Contractors must provide their customers with the EPA lead brochure. (Not a new rule). http://www.epa.gov/lead/pubs/leadpdfe.pdf
2 Posting warning signs on job sites for homeowners and visitors
3 HEPA and wet vacuuming
4 Bans heat guns, grinders and sanders on woodwork unless equipped with HEPA filter.
5 Individual certification (Managers need to take a class and apply for certification.)
6 Disposable drop cloths
7 Containment areas to prevent spreading dust
8 Cleaning and waste disposal practices.
9 Verification and record keeping (3 years)
a. Notification of owner/occupant receipt of the Renovate Right pamphlet or attempt to inform.
b. Documentation of work practices.
c. Certified Renovator certification, and proof of worker training.
10 Exemptions:
a. Home was built after 1978.
b. Disturbing less than 6 sft.
c. House or components test lead free by a Certified Risk Assessor, Lead Inspector or Certified Renovator
Like asbestos before it, lead represents the proverbial feral cat that got out of the bag and then proliferated and wreaked havoc.
While it should be lauded for its work to finally address head on the issue of what happens when a remodeling contractor rips apart a home draped in lead paint, the resolution is arriving decades after the problem.
While it’s hard to guess what will be the next “lead paint” or “asbestos” you can be sure that at some point there will be something else that we all have in our homes. In the delicate balance between the duty of government to protect its citizens and the duty of industry to turn a profit for its shareholders, don’t hold your breath waiting for the right answer.
Or perhaps you should hold your breath. Formaldehyde is a likely candidate and an example of another widely used chemical which is known to cause serious health effects. It is classified as a known human carcinogen and can cause respiratory distress, depression, coma, renal failure, gastrointestinal damage, etc. Formaldehyde is a naturally occurring in many things including wood and urine. In its man made form, industry widely uses it in all manner of industrial and consumer products. This includes everything from insulation, cigarettes, pressed board cabinets and melamine counters to that wrinkle free shirt on your back. (That’s one of the reasons you wash clothes before you wear them. You wash your fruit before eating it; you should wash your fruit of the loombs before wearing them.) Building products, particularly variants of pressed board contain varying amounts of formaldehyde.
In 1982 US Consumer Safety Product Administration called for a ban of Urea-Formaldehyde, though it did not result in a ban in the U.S. Europe, also, has not banned urea-formaldehyde.
The other variant of formaldehyde used in building products, phenol-formaldehyde, is somewhat less toxic. Urea formaldehyde off-gasses at a slower rate than phenol formaldehyde. However because the less toxic variant is a bit more costly industry often chooses to use the more toxic variant for their resins and additives. A ban of urea formaldehyde would cause small cost increases for construction but should have the opposite effect on health care costs.
Remember those 145,000 formaldehyde laden FEMA trailers purchased by FEMA with $2.7 Billion of no-bid contracts for survivors of the Katrina hurricane? In February of 2010, our Congress came up with the bright idea of sending them to Haiti. Recently they were sold.
http://gsaxcess.gov/htm/fema/doc/CDC%20Formaldehyde%20Exposure%20Reference.pdf
http://www.epa.gov/iaq/formalde.html
http://www.washingtonpost.com/wp-dyn/content/article/2007/03/07/AR2007030702628.html
http://www.washingtontimes.com/news/2010/feb/01/us-lawmakers-push-fema-trailers-for-haiti/
Tags: formaldehyde, lead paint
