As a property owner, you have the ultimate responsibility for the safety of your family, tenants, or children in your care. This means properly preparing for renovations and keeping unauthorized people out of the work area. It also means ensuring your contractor uses lead-safe work practices. Federal law requires that contractors performing renovation, repair, and painting projects that disturb painted surfaces in homes, child care facilities, and schools built before 1978 be certified and follow specific work practices to prevent lead contamination.
In addition, “Child Occupied Facilities” that are in Commercial or other buildings are defined as a building where a child under 6 makes 2 visits per week, 3 hours minimum, for a total of 6 hours per week. This portion of the RRP Rule involves more buildings than schools or residences.
This blog will detail the steps you need to take as a property owner to ensure your lead abatement or RRP projects follow federal and state guidelines. Remember, if you have specific questions, contact the EPA or IDPH for pertinent information.
Make Sure Your Contractor is Certified
Be sure to check if your contractor is certified and/or licensed, and can explain clearly the details of the job. Get information on how the contractor will minimize lead hazards during the work.
You can verify that a contractor is RRP certified by checking EPA’s website. You can also ask to see a copy of the contractor’s firm certification. Lead Abatement Contractors can be found at the IDPH website at IDPH.gov/lead. Ask if the contractor is trained to perform lead-safe work practices and to see a copy of their training certificates and license. Ask them what lead-safe methods they will use to set up and perform the job in your home or Child Occupied Facility.
You can also ask for references from at least three recent jobs involving homes built before 1978 that involve LBP.
The USEPA also has a variety of links at their website for the public to educate themselves or find an RRP certified firm, as well as a Frequently Asked Questions link that is very helpful at EPA.GOV/LEAD/RRP.
Always Make Sure the Contractor has a Clear Plan for Abatement Jobs
You should make sure any contract you need to sign is clear about how the work will be set up,
performed, and cleaned. To help before a contract is drawn up, sharing the results of any previous lead tests conducted on your property would be very helpful.
Specify in the contract that the contractor follows any work practices described in state or federal law. Contracts should specify which parts of your property are part of the work area and
specify which lead-safe work practices will be used in those areas. Remember, your contractor should confine dust and debris to the work area within a polyethylene plastic sheeting containment and should minimize spreading that dust to other areas.
Contracts should also specify that the contractor will clean and test the work area by performing the EPA-required Cleaning Verification procedure on RRP jobs. Verify that it was cleaned adequately, and have it re-cleaned if necessary.
Lead abatement jobs have a different process to document that post abatement cleaning was properly conducted; it is called a Clearance Examination and must be performed by a third party IDPH licensed Risk Assessor or Lead Inspector. Keep in mind that HUD-related jobs have more stringent regulations to follow rather than typical abatement or RRP jobs.
What to Do If You Notice Workers Not Following Guidelines
If you have signed a contract and your property is under renovation or is having lead abated, remember to keep an eye on things. If you notice workers not following proper practices or procedures, there are several actions you can take.
- Contact your contractor’s Project Manager
- Call USEPA at 800-424-LEAD
- Call IDPH at 217-782-5830
The first step should always be to speak with your contractor and discuss what is going on. If your contract states that specific guidelines and regulations must be followed, the contractor must comply or face termination. Most contractors carefully follow contracts to avoid things like this happening but it is still important to understand Lead Safe Work Practices, hence the RRP requirement to distribute the EPA’s The Lead-Safe Certified Guide to Renovate Right pamphlet to clients where renovations occur.
Illinois Environmental Contractors Association Resources
For more information on finding a local contractor, check the resources below:
- Illinois Environmental Contractors Association Members
- IECA Common Questions & Answers
- Illinois Environmental Organizations & Related Agencies
If you have further questions, please don’t hesitate to contact one of our associates to find an answer to your situation. With more than 40 Illinois-licensed companies represented by IECA members, we believe that collective action through association is the most effective way to deal with the changing demands of doing business.Tags: Abatement, Environmental Protection Agency, EPA, Guidelines, Recommendations, residential