Lead Paint (RRP) Frequently Asked Questions
Lead Paint (RRP) FAQ’s
Q. What is Lead?
Lead is a naturally occurring element found in small amounts in the earth’s crust. While it has some beneficial uses, it can be toxic to humans and animals causing of health effects.
Q. Where is Lead Found?
Lead can be found in all parts of our environment – the air, the soil, the water, and even inside our homes. Much of our exposure comes from human activities including the use of fossil fuels including past use of leaded gasoline, some types of industrial facilities, and past use of lead-based paint in homes. Lead and lead compounds have been used in a wide variety of products found in and around our homes, including paint, ceramics, pipes and plumbing materials, solders, gasoline, batteries, ammunition, and cosmetics.
Lead may enter the environment from these past and current uses. Lead can also be emitted into the environment from industrial sources and contaminated sites, such as former lead smelters. While natural levels of lead in soil range between 50 and 400 parts per million, mining, smelting, and refining activities have resulted in substantial increases in lead levels in the environment, especially near mining and smelting sites.
When lead is released to the air from industrial sources or vehicles, it may travel long distances before settling to the ground, where it usually sticks to soil particles. Lead may move from soil into ground water depending on the type of lead compound and the characteristics of the soil.
Federal and state regulatory standards have helped to minimize or eliminate the amount of lead in air, drinking water, soil, consumer products, food, and occupational settings.
Q. Who is at Risk?
Lead is particularly dangerous to children because their growing bodies absorb more lead than adults do and their brains and nervous systems are more sensitive to the damaging effects of lead. Babies and young children can also be more highly exposed to lead because they often put their hands and other objects that can have lead from dust or soil on them into their mouths. Children may also be exposed to lead by eating and drinking food or water containing lead or from dishes or glasses that contain lead, inhaling lead dust from lead-based paint or lead-contaminated soil or from playing with toys with lead paint.
Adults, Including Pregnant Women
Adults may be exposed to lead by eating and drinking food or water containing lead or from dishes or glasses that contain lead. They may also breath lead dust by spending time in areas where lead-based paint is deteriorating, and during renovation or repair work that disturbs painted surfaces in older homes and buildings. Working in a job or engaging in hobbies where lead is used, such as making stained glass, can increase exposure as can certain folk remedies containing lead. A pregnant woman’s exposure to lead from these sources is of particular concern because it can result in exposure to her developing baby.
Q. What are the Health Effects of Lead?
Lead can affect almost every organ and system in your body. Children six years old and younger are most susceptible to the effects of lead.
Even low levels of lead in the blood of children can result in:
- Behavior and learning problems
- Lower IQ and Hyperactivity
- Slowed growth
- Hearing Problems
In rare cases, ingestion of lead can cause seizures, coma and even death.
Lead can accumulate in our bodies over time, where it is stored in bones along with calcium. During pregnancy, lead is released from bones as maternal calcium and is used to help form the bones of the fetus. This is particularly true if a woman does not have enough dietary calcium. Lead can also cross the placental barrier exposing the fetus the lead. This can result in serious effects to the mother and her developing fetus, including:
- Reduced growth of the fetus
- Premature birth
Lead is also harmful to other adults. Adults exposed to lead can suffer from:
- Cardiovascular effects, increased blood pressure and incidence of hypertension
- Decreased kidney function
- Reproductive problems (in both men and women)
Q. How Do You Lower Your Chances of Exposure to Lead
Simple steps like keeping your home clean and well-maintained will go a long way in preventing lead exposure. You can lower the chances of exposure to lead in your home, both now and in the future, by taking these steps:
- Inspect and maintain all painted surfaces to prevent paint deterioration
- Address water damage quickly and completely
- Keep your home clean and dust-free
- Clean around painted areas where friction can generate dust, such as doors, windows, and drawers. Wipe these areas with a wet sponge or rag to remove paint chips or dust
- Use only cold water to prepare food and drinks
- Flush water outlets used for drinking or food preparation
- Clean debris out of outlet screens or faucet aerators on a regular basis
- Wash children’s hands, bottles, pacifiers and toys often
- Teach children to wipe and remove their shoes and wash hands after playing outdoors
- Ensure that your family members eat well-balanced meals. Children with healthy diets absorb less lead.
Q. What do I do if I think my child or I have been exposed to lead?
Talk to your pediatrician, general physician, or local health agency about what you can do. Your doctor can do a simple blood test to check you or your chiLd for lead exposure. You may also want to test your home for sources of lead.
Q. What Is the Lead-Based Paint Renovation, Repair and Painting Program (RRP)?
- The Lead-Based Paint Renovation, Repair and Painting Program is a federal regulatory program affecting contractors, property managers, and others who disturb painted surfaces.
- It applies to residential houses, apartments, and child-occupied facilities such as schools and day-care centers built before 1978.
- It includes pre-renovation education requirements as well as training, certification, and work practice requirements.
– Pre-renovation education requirements:
- Contractors, property managers, and others who perform renovations for compensation in residential houses, apartments, and child-occupied facilities built before 1978 are required to distribute a lead pamphlet before starting renovation work.
– Training, certification, and work practice requirements:
- Firms are required to be certified, their employees must be trained (either as a certified renovator or on-the-job by a certified renovator) in use of lead-safe work practices, and lead-safe work practices that minimize occupants’ exposure to lead hazards must be followed.
- Renovation is broadly defined as any activity that disturbs painted surfaces and includes most repair, remodeling, and maintenance activities, including window replacement.
- The program includes requirements implementing both Section 402(c) and 406(b) of the Toxic Substances Control Act (TSCA). (www.epa.gov/lead/pubs/titleten.html)
- EPA’s lead renovation regulations can be found at 40 CFR Part 745, Subpart E.
Q. Who must follow the renovation, repair and painting rule’s requirements?
In general, anyone who is paid to perform work that disturbs paint in housing and child-occupied facilities built before 1978, this may include, but is not limited to:
– Residential rental property owners/managers
– General contractors
– Special trade contractors, including
Q. What Activities Are Subject to the Lead Renovation, Repair and Painting Program?
In general, any activity that disturbs paint in pre-1978 housing and child-occupied facilities, including:
• Remodeling and repair/maintenance
• Electrical work
• Painting preparation
• Window replacement
Q. What Housing or Activities Are Excluded and Not Subject to the Rule?
• Housing built in 1978 or later.
• Housing for elderly or disabled persons, unless children under 6 reside or are expected to reside there.
• Zero-bedroom dwellings (studio apartments, dormitories, etc.).
• Housing or components that have been declared lead-free. Such a declaration can be made by a certified inspector or risk assessor. Also, a certified renovator may declare specific components lead-free using an EPA recognized test kit or by collecting paint chip samples and obtaining test results from an EPA recognized laboratory showing the components do not contain lead-based paint.
• Minor repair and maintenance activities that disturb 6 square feet or less of paint per room inside, or 20 square feet or less on the exterior of a home or building.
• Note: minor repair and maintenance activities do not include window replacement and projects involving demolition or prohibited practices.
Q. What Does the Program Require Me To Do?
Pre-renovation education requirements.
In housing built before 1978, you must:
• Distribute EPA’s lead pamphlet (www.epa.gov/lead/pubs/brochure.htm) to the owner and occupants before renovation starts.
In a child-occupied facility, you must:
• Distribute the lead pamphlet to the owner of the building or an adult representative of the child-occupied facility before the renovation starts.
• Either distribute renovation notices to parents/guardians of the children attending the child-occupied facility, or post informational signs about the renovation or repair job.
For work in common areas of multi-family housing, you must:
• Either distribute renovation notices to tenants or post informational signs about the renovation or repair job.
Informational signs must:
• Be posted where they will be seen;
• Describe the nature, locations, and dates of the renovation; and
• Be accompanied by the lead pamphlet or by information on how parents and guardians can get a free copy (see page 29 for information on obtaining copies).
Obtain confirmation of receipt of the lead pamphlet (see page 23) from the owner, adult representative, or occupants (as applicable), or a certificate of mailing from the post office.
• Retain records for three years.
• Note: Pre-renovation education requirements do not apply to emergency renovations.
Emergency renovations include interim controls performed in response to a resident child with an elevated blood-lead level.
Q. What are the Training, Certification, and Work Practice Requirements.
All firms must be certified (even sole-proprietors).
All renovators must be trained.
Lead-safe work practices must be followed.
Examples of these practices include:
• Work-area containment to prevent dust and debris from leaving the work area.
• Prohibition of certain work practices like open-flame burning and the use of power tools without HEPA exhaust control.
• Thorough clean up followed by a verification procedure to minimize exposure to lead-based paint hazards.
Q. How Does a Firm Become Certified?
Firms must apply to EPA for certification to perform renovations or dust sampling. To apply, a firm must submit to EPA a completed “Application for Firms,” signed by an authorized agent of the firm, and pay the correct amount of fees. To obtain a copy of the “Application for Firms” contact the NLIC at 1-800-424-LEAD (5323) or visit www.epa.gov/getleadsafe.
Q. What Are the Responsibilities of a Certified Firm?
Firms performing renovations must ensure that:
1. All individuals performing activities that disturb painted surfaces on behalf of the firm are either certified renovators or have been trained by a certified renovator.
2. A certified renovator is assigned to each renovation and performs all of the certified renovator responsibilities.
3. All renovations performed by the firm are performed in accordance with the work practice standards of the Lead-Based Paint Renovation, Repair, and Painting Program (see the flowchart on page 9 for details about the work practice standards).
4. Pre-renovation education and lead pamphlet distribution requirements of the Lead-Based Paint Renovation, Repair, and Painting Program are performed.
5. The program’s recordkeeping requirements are met.
Q. How Does a Renovator Become Certified?
To become a certified renovator an individual must successfully complete an eight-hour initial renovator training course offered by an accredited training provider (training providers are accredited by EPA, or by an authorized state or tribal program). The course completion certificate serves as proof of certification. To find a trainer in your area contact the NLIC at 1-800-424-LEAD (5323) or visit www.epa.gov/getleadsafe.
Q. Are There Streamlined Requirements for Contractors with Previous Lead Training?
Yes. Individuals who have successfully completed an accredited lead abatement worker or supervisor course, or individuals who have successfully completed certain EPA, Department of Housing and Urban Development (HUD), or EPA/HUD model renovation training courses before October 4, 2011, need only take a four-hour refresher renovator training course instead of the eight-hour initial renovator training course to become certified. For a list of qualified previous training courses contact the NLIC at 1-800-424-LEAD (5323) or visit www.epa.gov/lead/pubs/trainerinstructions.htm#refresher.
Q. What Are the Responsibilities of a Certified Renovator?
Certified renovators are responsible for ensuring overall compliance with the Lead-Based Paint Renovation, Repair, and Painting Program’s requirements for lead-safe work practices at renovations they are assigned (see the flowchart on page 9 for details about the work practice standards). A certified renovator:
- Must provide on the job training to other workers who are not certified renovators on jobs requiring lead safe work practices…
- Must be physically present at the work site when warning signs are posted, while the work are containment is being established, and while the work are cleaning is performed.
- Must regularly direct work being performed by other individuals to ensure that the work practices are being followed, including maintaining the integrity of the containment barriers and ensuring that dust or debris does not spread beyond the work area.
- When requested, must use and EPA recognized test kit or collect paint chip samples, submit them and obtain the test results…
- Must be available, ether on site or by telephone, at all times renovations are being conducted.
- Must, personally, perform project cleaning verification.
- Must have copies of the initial course completion certificate and the most recent refresher course certificate.
- Must prepare required records.