NAHB members were relieved this summer when the Environmental Protection Agency, yielding to recommendations from the association, backed down from implementing a new requirement for lead testing at the completion of a project under the Lead Paint: Renovation, Repair and Painting (LRRP) rule. That clearance testing requirement would have subjected remodeling customers to even more costs and delays.
In a related move, EPA has also added requirements and made clarifications to the original LRRP rule that may change how the lead regulation is enforced. An important article in the latest edition of Nation’s Building News details the changes that were made in areas pertaining to:
- vertical containment;
- HEPA vacuums;
- test kits; and
- online training
For example, for exterior renovations within 10 feet of the property line of adjacent buildings, the EPA had required vertical containment, but has now added the phrase “or equivalent extra precautions in containing the work area,” to the rule, giving renovators the flexibility “to design effective containment systems based on the renovation activity and the work site.”
The EPA has also dropped language suggesting that vertical containment is required on exterior renovations in windy conditions, while for exterior work, the distance from impervious sheeting required on the ground has been reduced from 10 feet to the “edge of the vertical barrier.” For interior containment, plastic sheeting only needs to be laid down to the “edge of the vertical barrier,” and not the six feet beyond the work area that was formerly required.
Meanwhile, EPA has changed its requirement for contractors to go to the unnecessary expense of buying newer HEPA vacuums, when currently owned vacuums purchased to comply with the 2008 version of the rule were designed to work just as effectively when operated correctly. The revised language in the rule now requires that “HEPA vacuums must be operated and maintained in accordance with manufacturer’s instructions.”
Noting this, NAHB is advising remodelers to keep up-to-date records of the operations and maintenance schedules of their HEPA vacuums. Please see this article in Nation’s Building News for further details on these and other changes to the LRRP requirements. Contact: Matt Watkins (800-368-5242, x8327)