The Trainer

Complying with New EPA Renovation Rules

In this issue, we covered some important new requirements from the Environmental Protection Agency (EPA) regarding renovations and repairs of housing that was built before 1978. The EPA issued the new rules in an effort to keep renovation projects in older buildings from disturbing lead-based paint and spreading hazardous dust to new areas. Exposure to lead paint is harmful to children and adults.

Under the new rules, contractors, maintenance staff, and other site workers must receive training and certification in lead-safe work practices and follow these practices in renovation or repair projects in housing built before 1978. You can begin the training and certification process as early as October.

Site managers must be sure, beginning in April 2010, that any individual who performs activities that disturb painted surfaces at the site has been trained by a certified renovator and follows EPA work practice standards. This requirement holds for your own employees as well as for employees of firms you hire temporarily.

The EPA mandates that you provide residents with an EPA-authored pamphlet on renovation projects before starting work. You must get confirmation that you delivered or mailed the pamphlet to all residents.

For work in common areas, you must notify residents in advance. The rule applies to work inside the building as well as outside the building. (Exterior paint may contain lead. In addition, soil can be a lead hazard because it absorbs lead from exterior paint as well as from the atmosphere.)

The EPA rule does not alter your responsibility to comply with HUD lead-paint rules and applicable state and local laws. The HUD Lead Safe Housing Rule makes owners and managers of HUD-subsidized housing responsible for ongoing lead-based paint maintenance and reevaluation as part of your regular building operations, unless you have a certification that all lead-based paint has been removed.

TRAINER'S QUIZ

INSTRUCTIONS: Each of the questions below has only one correct answer. On a separate sheet of paper, write down the number of each question, followed by the answer you have chosen—for example, (1) b, (2) a, and so on. The correct answers (with explanations) follow the quiz. Good luck!

Question #1

The new EPA guidelines on renovations cover housing occupied exclusively by the elderly. True or false?

1. True

2. False

Question #2

In HUD-subsidized multifamily housing, the EPA rules take the place of HUD's existing regulations on lead-based paint and lead hazards. True or false?

1. True

2. False

Question #3

If I gave all residents the required lead pamphlet with their leases, I do not have to give them the lead pamphlet before I start a renovation project. True or false?

1. True

2. False

Question #4

Fill in the blank: Except for emergency repairs, I am required, as of ____________, to distribute the EPA pamphlet and notify residents of upcoming renovation work at the site.

1. April 2010

2. now

Question #5

After my renovation project started, the contractor discovered some unexpected foundation problems that will make the whole project longer to complete than we originally planned. Do I have to notify residents of the change?

1. Yes

2. No

Question #6

The training and certification requirements apply to permanent site maintenance employees as well as to short-term contractors like electricians and carpenters the site hires. True or false?

1. True

2. False

Question #7

Fill in the blank: Under the EPA rules, window replacement is always considered a ___________ repair and maintenance activity.

1. major

2. minor

Question #8

My site lets a nonprofit group use our community room and kitchen for an after-school program. Does this use mean I have to notify all the parents of renovation work?

1. Yes

2. No

Question #9

Fill in the blank: The EPA may audit my compliance and assess penalties up to _________ years after the renovation project is complete.

1. 10

2. 5

3. 3

Question #10

The only lead-based paint problem I should be concerned about is chipping, peeling, or flaking paint, and I can solve the problem by painting over the damaged areas. True or false?

1. True

2. False