EPA Region 4 Lead Based Paint Program

Flood Response Guidance for Lead Based Paint Actitivies in Tennessee

Lead dust poses a hazard to children and pregnant women during flood clean up. Lead contaminated dust is the most significant source of lead exposure for children. Common renovation activities like sanding, cutting and demolition can create hazardous lead dust and chips by disturbing lead-based paint, which can be harmful to adults and children. Lead-based paint was used in more than 38 million homes until it was banned for residential use in 1978. Lead exposure can cause reduced IQ, learning disabilities, development delays and behavioral problems in young children.

Due to recent flooding in western and central Tennessee, and because of the many pre-1978 homes, the U.S. Environmental Protection Agency in Region 4 wants to ensure that family members are not at an increased risk for lead poisoning, because of clean up work. They urge that pregnant women and children keep away from work that could disturb lead-based paint and those working on potential lead-based paint surfaces, take precautions to prevent the spread of lead dust. In order to reduce exposure to lead dust the Renovation Repair and Painting Rule (RRP) requires that workers disturbing lead-based paint be trained and certified, notify residents of the lead dust hazard, and follow lead safe work practices, in order to reduce exposure to lead dust. Because of the emergency nature of the flood work, EPA has issued guidance specifically for this situation and agreed that until June 30, 2010 the emergency provisions of the RRP rule are in effect. Work covered under the RRP rule on flood damaged housing will not require advance notice or trained renovators to remove materials from homes. Volunteer workers, who do not receive compensation for the work, are not required to be certified, but should educate themselves about lead-safe work practices, so as not to inadvertently cause hazards for themselves or other family members.

To read about the Lead Based Paint Flood guidance for Tennessee, please click on the following link: Tennessee RRP Lead Based Paint Guidance (PDF, 298k, 5 pgaes, info about PDF)

Freqently asked questions on Renovations for Compensation

Question: Is work done by friends, a brother-in-law, or volunteers covered by the RRP Rule if no one is compensated?

Answer
No. The RRP Rule only applies to renovations performed for compensation. Compensation includes pay for work performed, such as that paid to contractors and subcontractors; wages, such as those paid to employees of contractors, building owners, property management companies, child-occupied facility operators, State and local government agencies, and non-profits; and rent for target housing or public or commercial building space.

Even if you are not required to comply with the RRP Rule, it is important to be aware that renovation activities can create hazardous lead dust and chips. The key to protecting yourself and your family during renovation is to use lead-safe work practices. Information on these practices is available in the EPA Small Entity Compliance Guide to Renovate Right (PDF), en español (PDF).

Question: My non-profit home repair organization performs renovations using mostly volunteers. We do some painting and scraping but we do mostly roof repair and interior work (bathrooms, kitchens, etc.). Obviously, we want to be in compliance with the law and we want our volunteers, staff and homeowners to be safe. Equally, we want to make sure that we are able to continue to offer this valuable service to our community. Is my organization’s work covered by the RRP Rule?
Answer
The RRP rule covers renovations performed for compensation. If the organization is compensating anyone for the work (for example, a paid supervisor), then the renovation is covered by the RRP Rule. This is the case even though the organization has non-profit status.

Question: How will the RRP Rule affect the work of non-profit or not-for-profit groups? Will the rule apply, for example, to church groups who, as part of their missionary work, are making improvements for low-income residents?
Answer
The RRP Rule applies to renovations performed for compensation. Compensation includes pay for work performed, such as that paid to contractors and subcontractors; wages, such as those paid to employees of contractors, building owners, property management companies, child-occupied facility operators, State and local government agencies, and non-profits; and rent for target housing or public or commercial building space. Donations, including donations of materials or of the time of volunteers, are not compensation. If the organization is compensating anyone for the work (for example, a paid supervisor), then the renovation is covered by the RRP Rule. This is the case even though the organization has non-profit or not-for-profit status.

The organization may also need to become certified as a firm. Beginning April 22, 2010, an organization that performs, offers, or claims to perform renovations covered by the RRP Rule must be certified by EPA. A non-profit organization that offers to renovate the property of a third party for compensation, or that performs the renovation, must be certified as a firm. The organization must comply with all the requirements of the rule that apply to firms performing renovations. This includes having a certified renovator direct the work and provide on-the-job training to all uncertified workers, including volunteers.

Question: If a renovator is only reimbursed for materials, would that be considered compensation?
Answer
No. Compensation includes pay for work performed, such as that paid to contractors and subcontractors; wages, such as those paid to employees of contractors, building owners, property management companies, child-occupied facility operators, State and local government agencies, and non-profits; and rent for target housing or public or commercial building space. Reimbursement for the cost of materials is not compensation.

EPA and Lead Poisoning in Children

Lead poisoning is one of the most serious environmental health hazards to children, particularly for children under the age of six. Elevated blood lead levels can impair a young child's mental and physical development. Adults exposed to high levels of lead, usually in the workplace, are also at risk.

Homes built before 1978 may contain lead-based paint. If it is in poor condition, it may pose a hazard if paint chips or lead-contaminated dust or soil is inhaled or ingested.

EPA and other state, federal, and local agencies are working to protect children from exposure to lead-based paint. EPA seeks to reduce and, ultimately, to prevent lead poisoning through outreach and education, along with compliance assistance and enforcement of Federal lead laws.

To combat childhood lead poisoning, the EPA requires landlords and property owners to give renters and buyers of houses built before 1978 a pamphlet titled Protect Your Family from Lead in Your Home. Landlords and sellers must also inform renters and buyers if there is known lead-based paint in the home. Buyers also have the option to have the property inspected by a certified lead-hazards firm at their own expense. Information, including rules and regulations on certified lead inspectors and risk assessors, can be obtained by checking EPA's Lead web page, or by contacting the National Lead Information Center at 1-800-424-LEAD (TDD: 1-800-526-5456).

Download and print this pamphlet.

Are you leasing or selling housing built before 1978?

The Residential Lead-Based Paint Disclosure Rule/Section 1018 requires sellers and landlords of most housing built before 1978 to disclose to potential buyers and renters any knowledge of lead-based paint and/or lead-based paint hazards in the housing and provide a pamphlet titled “Protect Your Family From Lead In Your Home”. Potential buyers must be given a 10-day opportunity to conduct a risk assessment or inspection. Sellers and landlords are required to keep specific disclosure documentation.

Are you renovating housing built before 1978?

Renovation, Repair and Painting Rule (RRP)

On March 31, 2008, EPA issued a new rule aimed at protecting children from lead-based paint hazards (79 pp, 847K). The rule requires contractors and construction professionals that work in pre-1978 housing or child-occupied facilities to follow lead-safe work practice standards to reduce potential exposure to dangerous levels of lead for children in places they frequent. View the effective dates of the rule.

If you would like to learn more about the Renovation, Repair and Painting rule (RRP), please click on RRP .

Pre-Renovation Education Rule

The Pre-Renovation Education Rule/Section 406(b) requires renovators of most housing built before 1978 working for compensation to provide the owner and occupant of the housing a pamphlet titled “Protect Your Family From Lead In Your Home” before beginning the renovation. If the owner does not live in the housing, the occupant must be provided information regarding the nature and timing of the renovation. The renovator is required to keep specific notification documentation.

Do you conduct lead-based paint abatement, inspections or risk assessments in housing or child-occupied facilities built before 1978 or do you provide lead-based paint training?

The Lead-Based Paint Training and Certification Rule/Section402 requires individuals and firms conducting lead-based paint activities in housing and child-occupied facilities built before 1978 to be certified and follow certain work practice standards. Training programs must be accredited to provide or offer to provide lead-based paint activities courses.

Region 4 regulates the Lead-Based Paint Training and Certification Rule in the States of Florida and South Carolina and all Tribal Lands in the Region. The states of Alabama, Georgia, Kentucky, Mississippi, North Carolina, and Tennessee operate lead programs in lieu of EPA. Click on the states to learn about their lead programs.

For more information about the Region 4 Lead-based Paint program, contact Liz Wilde at 404-562-8998.

For pamphlets, applications or other materials please contact the National Lead Information Center (NLIC) at 1(800) 424-LEAD (5323).

Sources of Lead Poisoning

Lead-based paint and lead dust are the major sources of lead poisoning in children. More children are poisoned by exposure to lead dust from lead-based paint in older homes than by any other source. This exposure is usually through normal hand-to-mouth contact. In some areas, soils have been contaminated by exterior lead-based paint chips and dust, and by automobile exhaust from leaded gasoline. Drinking water can also contain lead from older pipes or solder and contribute to childhood lead poisoning when the water is ingested directly or used to mix beverages. Other common sources of lead are: vinyl mini-blinds, lead-glazed pottery, home remedies (e.g., Azarcon and Greta are almost 100 percent lead), and furniture and toys painted with lead-based paint. Parents who work in lead related industries such as the lead abatement industry, home renovators, antique furniture refinishers and battery recyclers, can also bring lead home on their clothes, exposing children to the hazard.

Here's What You Can Do to Identify and Reduce Lead Exposures:

Have your child's blood tested for lead either with your private MD or local health department.
Contact a certified risk assessor - especially if your home was built before 1978 - to identify any lead present in your home and evaluate its risks to you and your family.
Use state or EPA certified professionals to remove lead-based paint in your home.
Maintain a dry home if you know or suspect lead paint may be present in your home. (Moisture problems can cause paint failure. Well maintained paint usually does not pose risks.)
Keep floors, window sills and other painted surfaces clean and dust free.
Clean carpets and rugs well. Using a HEPA vacuum will help reduce potentially hazardous dust when you vacuum.
Avoid ingesting foods and beverages stored in leaded crystal and lead-glazed pottery.
Eat a well balanced diet. A child that has enough iron and calcium will absorb less lead.
Run your tap for one minute if the water has not been used for six hours or more and first thing in the morning to clear the pipes and reduce the risk of contamination.

For information about the contents of this page please contact Andrea Lippitt

EPA Region 4 Lead Based Paint Program

Links

Flood Response Guidance for Lead Based Paint Actitivies in Tennessee

Freqently asked questions on Renovations for Compensation

Here's What You Can Do to Identify and Reduce Lead Exposures:

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