EPA rule requiring the use of lead-safe practices

[goldstar]

Is anyone up to date on this ? Could this possibly affect us in our trade ? Frankly, I don't see how it will unless you're contracting to do more than just the electrical work. Here is a link to the EPA website http://www.epa.gov/lead/pubs/renovation.htm#requirements . It's become a hot topic at our contractors' association meetings.

Here's an excerpt from the EPA site :

The rule will affect paid renovators who work in pre-1978 housing and child-occupied facilities, including:

Renovation contractors
Maintenance workers in multi-family housing
Painters and other specialty trades.
Under the rule, child-occupied facilities are defined as residential, public or commercial buildings where children under age six are present on a regular basis. The requirements apply to renovation, repair or painting activities. The rule does not apply to minor maintenance or repair activities where less than six square feet of lead-based paint is disturbed in a room or where less then 20 square feet of lead-based paint is disturbed on the exterior. Window replacement is not minor maintenance or repair.

I don't see how this rule is going to affect us when installing hi-hats in a given room. The area of a circle [ http://www.mathgoodies.com/lessons/vol2/circle_area.html ] is pi x radius squared. So, for 6" hi-hats it's 3.1417 x 3" x 3" =18.85 square inches per hi-hat. Six square feet is equivalent to 864 square inches. If my calculations are correct you can install 45 - 6" hi-hats before you have to follow the lead handling rules.

Am I off base on this ? Someone please prove me wrong.

 

[iwire]

Is anyone up to date on this ? Could this possibly affect us in our trade ? Frankly, I don't see how it will unless you're contracting to do more than just the electrical work.

Renovation contractors
Maintenance workers in multi-family housing
Painters and other specialty trades.
Under the rule, child-occupied facilities are defined as residential, public or commercial buildings where children under age six are present on a regular basis. The requirements apply to renovation, repair or painting activities. The rule does not apply to minor maintenance or repair activities where less than six square feet of lead-based paint is disturbed in a room or where less then 20 square feet of lead-based paint is disturbed on the exterior. Window replacement is not minor maintenance or repair.

I do not think installing high hats is "minor maintenance or repair" I think the rule will apply to any electrical you install.

 

[goldstar]

Bob,

Installing 6 or 8 hi-hats in a given room doesn't come near disturbing 6 square feet of an area with lead based paint. However, I'm told that the 6' rule is modified to 2 square feet for buildings such as a nursery or day care center where children are present.

From what some of the building contractors are telling me you'll be required to go beyond just tarping the area and sweeping up when you're done. In several discussion I've been in I've been told that aside from becoming certified by authorized agencies at both the state and federal levels you'll have to seal off the area with a plastic tarp, make your cuts, remove and discard the tarps at an approved dump site, sweep up the area and then damp mop the area. In addition you'll have to document the clean-up and keep your records for a given amount of time. There's even some talk about having the residents get a blood test before and after the work to make sure they didn't contract lead poisoning.

Your small $500.00 hi-hat job just became an $800.00-$1,000.00 hi-hat job. It's getting near that time to sell the tools at a garage sale and open up a 7-11.:roll:

Phil

 

[iwire]

Bob,

Installing 6 or 8 hi-hats in a given room doesn't come near disturbing 6 square feet of an area with lead based paint.

I agree 100% but that exception for under 6' square feet only applies to minor maintenance or repair and IMO installing fixtures is not minor maintenance or repair.

 

[Kdog76]

Just curious here guys, what exactly is a high-hat?

 

[iwire]

Just curious here guys, what exactly is a high-hat?

 

[goldstar]

I agree 100% but that exception for under 6' square feet only applies to minor maintenance or repair and IMO installing fixtures is not minor maintenance or repair.

I see your point. That EPA rule puts an ugly burden on all of us if your interpretation is correct and the EPA rule is enforced.