EPA Lead Paint Rules
Your Safety is Our Concern
IDA is committed to providing its members with important information about safety issues affecting the garage door industry. Under Renovation, Repair and Painting rule regulations, all contractors performing work that disturbs lead-based paint in housing, childcare facilities and schools built before 1978 must follow specific work practices to prevent lead contamination. IDA strongly encourages our members to obtain Certified Renovator status so they can fully comply with these rules. IDA also encourages consumers to confirm that their home improvement professionals – especially including overhead door installers – are properly trained and certified to comply with the rules.
The presence of lead in the home can be very dangerous, especially to children under six years of age. Lead can cause health and developmental problems, and can even be passed from pregnant women to their fetus. Lead can get into the body from swallowing or inhalation. Lead dust or fumes can be released if lead-based paint is disturbed.
Under RRP regulations, specific work practices include posting warning signs for occupants and visitors, using disposable plastic drop cloths, cleaning the work area with HEPA vacuuming and wet washing. Most importantly, the rules require contractors be certified in lead removal through a training course.
IDA also recommends that members observe the following three threshold items before working on a property:
- Is the property a targeted property? Was it constructed prior to 1978, or using pre-1978 materials that may have contained lead-based paint? If so, is it residential housing or a child-occupied facility?
- If it is a targeted property, then testing should be performed prior to any work if lead-based paint may be a concern. If no testing is performed, the member should assume the presence of LBP as a prophylactic measure.
- The rules only apply (as to external work) if 20 square feet of paint may be disturbed. Because EPA has not conclusively stated otherwise, IDA presently recommends that members assume that if a panel of a door needs to be removed, and that panel has lead-based paint, then the RRP lead-safe work practices should be followed.
Whether or not you plan to work on EPA-targeted properties, the following are additional important practices under the new rules:
- When handing a service calls it is a good idea to add the age of the structure to a customer information sheet as a tip off to the potential of lead based paint. This information may determine to the need for a certified technician from your company.
- Notify customers either verbally and/or via a signed notification form that they may be charged a fee for a lead-based paint verification test and/or remediation work if they choose to proceed with the work. Be sure customers understand that any service company must comply with the same procedures to avoid suspicion of overcharges and comply with the law
- Make it company policy to communicate the dangers associated with lead based paint to all employees. Further, make sure that all employees know and understand the basics of these new regulations regardless of certification status. This could include Toolbox Talks, posters, or employees meetings.
Door dealers should also keep in mind that their employees must continue to observe safety standards, even if the work does not involve properties where young children may be present. In particular, companies should make sure their installers are familiar with Section 1926.62 of the federal OSHA regulations, which applies to all construction work where an employee may be exposed to lead.
IDA and Safran Law Offices (SLO) have worked together to produce a series of forms and checklists, which compiles the information required by the EPA’s RRP regulations. We have also compiled certain critical materials produced by EPA to give members further guidance regarding their obligations before, during and after performing work on pre-1978 residences, schools and child care facilities that have or may have lead-based paint.
Additional Safety Resources
- Renovate Right pamphlet. This is an educational brochure that renovators are required to distribute to potential customers not more than 60 days prior to the beginning of renovation work. At the back of the pamphlet is a form to document receipt by the customer.
- Small Entity Compliance Guide. This pamphlet is intended for renovation firms and lays out information on lead poisoning risks, the educational requirements of RRP, the work practices required by the regulations, and sample forms for meeting the EPA record-keeping requirements. IDA and SLO have modified these forms, as permitted by EPA, and made the modified forms available to members on the IDA website.
- Steps to Lead Safe Renovation, Repair & Paintings. This pamphlet is intended for use by certified renovators as a quick guide for training non-certified workers, as required by the RRP rules.
IDA / SLO Work Forms
The following forms and information are available in the Members Only section of our website. These pamphlets and forms are intended to assist members in doing RRP work in a safe, efficient and compliant manner, as well as making the record keeping as manageable of a task as possible.
- Thumbnail Compilation of the forms, laid out to help you see and understand the purpose for each of the forms.
- Flow Chart of EPA-dictated decision trees for following the RRP protocols.
- Checklist of steps and materials needed for complying with the RRP protocols.
- Definitions sheet, to assist in understanding the EPA-defined scope of “components” and “minor repairs,” especially as they relate to garages and garage doors.
- Training Log for a non-certified worker. After you’ve trained a worker for following the lead-safe protocols, you will need to keep a record of that training, and you must be able to provide copies of proof of training to customers, and to the EPA.
- Lead Hazard Information Pamphlet receipt. This form is used to obtain confirmation of delivery of the Renovate Right pamphlet.
- Renovator Self-Certification Option. This form is used to demonstrate compliance with the obligation to deliver the Renovate Right pamphlet, where a signature from the owner could not be obtained.
- Lead Paint Work Practices Determination Worksheet. This form is used by the renovator to document the reason(s) for not using the lead-safe work practices on a property that would otherwise be covered by the RRP requirements.
- Record of Tenant Notification Procedures. This form is used to document notification of tenants in multi-unit dwellings.
- Notice and Authorization for Lead Paint Testing. This form is used to obtain authorization from property owners for lead paint testing, or to get confirmation that the owner has declined to have the property tested.
- Lead Test Kit Documentation Form. This form captures all of the EPA-required details for documenting any lead tests performed for a project.
- Renovation Notice. This form provides the EPA-required notice to residents that renovation work disturbing lead-based paint will take place.
- Sample warning sign, based on EPA-suggested language.
- Post-Renovation Cleaning Verification form. This form tracks EPA’s regulations for the steps required for a certified renovator to perform the cleaning verification after completion of the renovation work.
- Renovation Checklist. This form tracks EPA’s sample renovation record keeping checklist, while adding in certain information we have obtained in helping members deal with EPA record keeping obligation.