Something recently crossed my desk I thought would be of interest to all installation companies. It is a ruling by the Environmental Protection Agency (EPA) that if not properly followed could have a considerable financial impact on your business.

The Lead Renovation, Repair and Painting Rule (EPA Title 40 CFR Part 745), also known as RRP, is set to go into effect April 22. The fine for not complying with this ruling can cost a company up to $37,500 a day! Now do I have your attention?

OK, so now the question is … What does lead renovation, repair and painting have to do with installing alarm systems? How many times have you retrofitted a system in an old residential or commercial building? If that building is pre-1978 you should take heed to this ruling.

This month I will highlight some of the key areas of this little known but wide-sweeping EPA ruling. I suggest if you are working in any pre-1978 structures you visit EPA’s Web site at http://epa.gov/lead/pubs/renovation.htm#contractors. This information has two benefits; first, it may keep you out of punitive trouble; and secondly, it is a good review of how to work more safely around the hazards of lead and similar dangerous contaminants.

PRESENCE AND DANGERS OF LEAD
Back in 1991, the U.S. Department of Housing and Urban Development (HUD) characterized lead poisoning as the “number one environmental threat to the health of children in the United States.” Lead-based paint was declared a major source of lead poisoning for children and could affect adults. Even low levels of lead in children can result in retarded mental and physical development, learning disorders, behavior problems and reduced attention span. Lead can cause abnormal fetal development in pregnant women. Lead poisoning also may increase blood pressure in adults. Bottom line, the stuff is not \good for you.

The greatest threat is breathing or ingesting dust from lead-based paint as it wears and disintegrates over time. When working around lead-painted surfaces, lead dust can be spread and inhaled without knowing it because you cannot see, taste or smell it. As a result, you may have lead in the dust, paint or soil in and around your worksite. Because lead does not break down naturally it can remain a problem for a long time.

Approximately three-quarters of the homes built before 1978 contain some lead-based paint. It may be found on any surface but is most commonly found on exterior-painted surfaces, interior woodwork, doors and windows. Heavily-leaded paint was used in most homes built before the 1950s, with lower levels of lead used until 1977. In 1978, the U.S. Consumer Product Safety Commission banned the use of lead-based paint in housing.

When properly maintained and managed, this paint poses little risk. The area installers have to be careful of is when drilling, cutting and working in walls, and removing molding. The dust from your work can get on carpets, floors, furniture, toys and other objects, as well as on the hands of children, pregnant mothers, and other adults in the home. It can be inhaled and absorbed by installation people as well.

HOW EPA’S RULING AFFECTS YOU
You might say, “I am not renovating the building, I am only installing an alarm system.” The problem is that the term “renovation” is defined so broadly by the EPA that many contractors who are not generally considered “renovators” are in fact considered so under the RRP ruling and must follow its requirements. However, there is a slight silver lining in this ruling as we will see shortly.

Some of the voluntary actions of this EPA ruling have been in place for some time now. One key element was submitting a pre-renovation form that confirms the owner has received a copy of the pamphlet, Renovate Right: Important Lead Hazard Information for Families, Child Care Providers and Schools. Everyone working in this hazardous environment should be aware that the effects of lead poising are particularly acute with young children under the age of six and pregnant women.

For the contractor, there are a couple of good EPA reference documents. One is the “Small Entity Compliance Guide to Renovate Right EPA’s Lead-Based Paint Renovation, Repair, and Painting Program” and another is “Steps to LEAD SAFE Renovation, Repair, and Painting.” Both can be referenced at the EPA Web site. This documentation will help simplify the RRP requirements.

Remember that the final ruling takes effect in April, so you may have to take some fast action if you have a project in which this applies. Action items include: you will need to now be registered with the EPA and have training for key personnel on the project; you must document that the owner was properly informed and received the RRP pamphlet; and you must have a certified RRP person overseeing the project.

EXEMPTIONS AND EXTENSIONS
Now, as I promised, some good news with reference to this EPA ruling. There are some exemptions that, in many cases, will apply to security system installations since often the amount of lead-painted structure disturbance is limited to the drilling of cabling holes and equipment mounting. One exemption is if you disturb no more than six square feet of painted surface per room for interiors and no more than 20 square feet for exteriors.

The Electronic Security Association (formerly NBFAA) has proposed a revision to this EPA ruling. The organization is supporting an “opt-out” provision allowing exemption if the owner states there are no children under age six or pregnant women residing in the home.

ESA is also requesting the six square foot exemption be raised to 20 square feet per room.

There has also been a request for extending the ruling deadline to April 22, 2011. According to ESA, as of press time, there had been no reply from the EPA on the revision requests. Please also note that your state may have its own RRP type ruling that supersedes the EPA ruling.

Care should be taken to protect installers from lead dust and other similar environmental dangers when working in the many attics, basements and crawlspaces of older dwellings. Some other airborne risks include asbestos from pipe insulation and a once popular granular insulation called Vermiculite, mold, and a deadly disease called Hantavirus Pulmonary Syndrome (HPS) that comes from infected rodent urine and droppings.

Mark Dolph, president of Northeastern Independent Home Inspections Inc. and a Senior Certified Home Inspector, states, “Whenever you enter an attic or crawlspace, I recommend a minimum protection measure of wearing gloves, N-95 or half-face respirator with HEPA filter, and goggles/eye protection. To be frank, of what I observe on a residential level, 99 percent of trade people do not bother to protect themselves at all.”

 

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