Performing lead testing

Guess what I did this weekend? I’ll give you a hint—the headline is a dead giveaway. On Saturday I attended a certified renovator class so I am now an EPA-Certified renovator. So if you have a window business in the Northern Virginia area and you’re short-staffed one day and thus are in need a certified renovator to go to the jobsite of a job for a pre-1978 home, you should give me a call.

Seriously, after writing about the issue of lead-safe work practices for the last seven months, I decided to learn even more about the requirements by attending the class. First, let me say, this is the most-educated I’ve ever felt as I started a class, which was pretty cool, as I’ve been covering this topic in such depth for the last several months.

I almost was tempted to raise my hand on several occasions, but rather sat in the back as one of only two women in a group of more than 50 male contractors (the other woman was my boss). I wanted to tell them I knew all about the opt-out and all about the important dates, etc., but resisted the urge.

So though a lot of this was familiar to me there were several items the instructors shared that were very enlightening and gave me even more to think about related to this complex rule.

So here are some nuggets I found particularly interesting to share:

Agency Variances. While the EPA has rules related to its RRP, according to our instructors, some of these are in direct violation of OSHA rules. And if you work on a project for which you are receiving federal funds, there is a different set of rules set forth by the Department of Housing and Urban Development. That in itself warrants a whole article so check out my column on this topic to appear in DWM’s June issue.

State Variances. The EPA has said that certain states have their own programs related to lead-safe work practices and if these states want to continue running these programs this is fine with the EPA. My instructor wondered what would happen if other states decide to “get in on the action” and run their own programs and I think it will definitely be interesting to see what transpires.

Dust Wipe Sampling. While we’ve all been busy (myself included) talking about the EPA’s lead-safe work practices and lamenting removal of the opt-out, we may be forgetting another issue about to rear its ugly head—dust wipe sampling, to which my instructors alluded. See the June issue of DWM for more on this issue in a column by Jeff Inks of the Window and Door Manufacturers Association. “The proposed final rule for dust-wipe and clearance testing will require those performing many types of renovations, including replacement of doors and windows, to take dust wipe samples and have them tested by an EPA-approved laboratory before the project can be verified as performed in compliance with the law. Those results also must be provided to the homeowner or occupant,” says Inks in that article.

A Picture is Worth a Thousand Words. I don’t know if all instructors are like this, but mine certainly focused on the importance of photos in the recordkeeping process. One made this interesting comment: “If I have a photo, no one can ever come back and say I wasn’t there.” He added that if the rules say to post a sign, say in a school, to inform occupants and/or parents of the lead-safe work practices taking place, and if you take photo of the sign with the date, no one can ever question that you did it. “Even if you test for lead and the test shows no lead, take a photo of the test,” the instructor urged.

Did Lead Paint Exposure Stop in 1978? Although the EPA rules say that lead-safe work practices must be performed in homes prior to 1978, “it’s not as if suppliers threw their lead paint away once it was banned in 1978. So one instructor in the course urged participants to test for it for up to five years after that date.

Focusing on the Children. We all know this rule was set up to protect children from the dangers of lead paint poisoning, but my instructors really focused on this fact. One of the instructors who taught my course actually has a child with lead paint poisoning and recounted the learning difficulties his son has faced, as well as other issues. “I don’t care what reason you use, but you need to follow the rules,” he said. Another instructor added, “I understand your frustration with these rules, but think of the children.” And for those who still debate removal of the opt-out, one instructor said simply, “Can you see why they eliminated the opt-out? Because if they didn’t, [the rule] wouldn’t do the job of preventing lead poisoning.”

Recordkeeping. Yes, I’ve written about recordkeeping and how contractors have to keep various records for three years, but I also realized that this will be a huge part of the EPA’s enforcement. EPA officials may not be popping up on your job site, but it’s a safe bet that they may be requesting to see your records. So if you don’t want a $37,500 fine, you better have them available.

Testing. Prior to taking the class, some contractors told me that if they are working on houses built prior to 1978, they aren’t even testing for lead; rather, they are assuming it is there. Others told me that the EPA even recommends taking this approach in the classes that they have attended. And I saw this to be true as well as our instructors seemed to say this approach comes with fewer headaches and costs.

Disposal. This bullet will be pretty small, but largely alarming. I didn’t know that contractors have to go through all the time and energy to perform lead-safe work practices, but then are allowed to put the lead-ridden items in a garbage bag on the curb as if it’s simple household waste. This seems a little odd to me.

Alarming Fact—Yet Effective Educational Tool. Did you know that if you filled a Sweet and Low packet with lead particles you could contaminate 25 homes?

Applying it all to the Real World

Eight hours of lead training on a Saturday could have spelled boring, but instead it spelled enlightenment. I actually laughed out loud on several occasions and learned a lot in the process.

I’d like to thank for my instructors for being straight with us and others in the course. Here’s one example of that straight-talk from one of our instructors.

“Let’s talk real world for a minute. I know you’re thinking, ‘Why should you do this when you’re going to get underbid by your competition?’ In today’s economy this is going to be a hard sell. But you’ve now educated the customer and any contractor who comes behind you with a lower price or who doesn’t mention these rules will look suspect …. There are always people who are going to go with the lowest bidder …”

I hope everyone else who has taken this training had instructors who did as good of a job as mine did.

And to those who take future classes, if you’re not happy with these rules, don’t take it out on your instructors (as I was told many have). They didn’t make the rules; they’re just trying to help you follow them.

P.S. I would love to hear about what you learned in your own lead-safe courses or if you learned things that are contrary to what I was taught. Contact me at ttaffera@glass.com or give me a call at 540/720-5584, ext. 113.

6 Comments

  1. Tara
    What is the EPA doing to educate the consumer about the dangers of lead and the purpose behind these new regulations? The concern is that many, especially on small jobs, will try to bypass the cost with do-it-yourself installations which are exempt from these new regulations.
    Jim

  2. Jim, Good point which they didn’t really address. Though the instructors did seem to agree that it was pretty crazy that do it yourselfers don’t have to follow these requirements.

  3. Tara,
    Thanks for the article and congratulations on completing the course!

    ZipWall

  4. Tara,

    Great article describing details and consideration beyond the certification requirements – and from a first-hand viewpoint. That’s outstanding that you (and presumably Deb) attended a certification course! I have some friends and family in the D.C. area, so I’ll have them call the offices of Key Communications for quotes on their next renovation projects! 🙂

    Scott

  5. Jim / Tara,

    Tara congrats on taking the class, a very smart and sensible move on your behalf. Now you know just enough information to be dangerous ! (just kidding……).

    Here is one outreach effort that is being made to educate the public: http://www.leadfreekids.org/index.html.

    I have no idea as to how effectively it’s being promoted and utilized, but it’s at least a step in the right direction.

  6. Tara,

    Thrilled to see you step up and take/pass the RRP class. Please expand your insight with a day in the life of a RRP Certified window contractor. The good the bad the ugly. The good no more “You see my dog” The Bad “Henry can install em for twenty bucks”
    The Ugly “Due to your negligence”
    Sleepless in NEPA
    “Wow Daddy got a new shop vac It’s Shiny.”

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