Does the EPA’s Lead-Based Paint Renovation, Repair and Painting Program apply to you?
- February 27th, 2013
- Wendy Carlisle
- Comments Off on Does the EPA’s Lead-Based Paint Renovation, Repair and Painting Program apply to you?
The United States government enacted a regulation, enforced by the Environmental Protection Agency, requiring the use of lead-safe practices in common renovation activities to prevent lead poisoning. The regulation became fully effective on April 22, 2010.
Is this regulation applicable to the work you are doing in the security industry? The short answer is yes. If you are a security industry installer or contractor, this regulation may apply to you, depending on the work being done and the location. While the regulation is lengthy and quite detailed, here is a basic primer on what you should know about lead and when the regulation applies.
Lead is a soft, metallic chemical element that is mined from rock. It is almost indestructible and highly adaptable. For those reasons, manufacturers have used it to make a variety of useful items such as batteries, gasoline, pipes, solder and pottery. Lead was also once a primary ingredient in oil-based paint. That practice stopped when the Consumer Product Safety Commission banned lead paint in 1977 because of its harmful health effects, including nervous system damage, decreased cognitive development—lower IQ and impaired language, memory and learning ability.
Renovations that disturb lead paint can increase the risk of exposure by distributing the lead dust particles through the air and over household surfaces. Thus, the government has stepped to regulate with the goal of minimizing exposure during renovations. The regulation is implemented through the EPA’s Lead- Based Paint Renovation, Repair and Painting Program.
The EPA’s program applies to contractors that perform activities that disturb painted surfaces in homes and child-occupied facilities, such as schools and day care centers, built before 1978. While the focus of the program is on renovations, the rule is broadly worded so that it actually applies to any activity that disturbs painted surfaces. Thus, the EPA’s program potentially applies to work done when installing security system components.
The program does not apply, however, where the work is performed in the following situations
• Houses or child-occupied facilities built in or after 1978.
• Housing where there is no bedroom, like dormitories or studio apartments.
• Housing for the elderly and disabled (as long as no children under six reside there).
• Housing declared by a certified inspector to be lead-free.
• Emergency renovations
The program also does not apply to minor repair and maintenance activities that disturb less than six square feet of paint per room inside or twenty square feet or less on the exterior. But you should note that the square footage is cumulative. So, even if you have several small areas in which you are disturbing paint, it may add up to be enough square footage to fall within the program. Thus, installation of a small residential alarm system may not fall within the program, depending on what components are installed, but a larger installation in a child-occupied facility or multi-unit housing facility may be a different story. At bottom, whether the program applies to the work you are doing depends on a careful analysis of the type of building (i.e., home or child-occupied facility), the age of the building and the scope of the work being performed.