New Rule Establishes Requirements to Protect Children During Renovation, Repair and Painting Activities that Disturb Lead-Based Paint
On March 31, 2008, to better protect children from lead-based paint hazards, EPA issued a new rule for home improvement contractors and maintenance professionals who renovate or repair pre-1978 housing, child care facilities or schools. The rule requires that by April 2010 contractors and maintenance professionals be certified, that their employees be trained, and that they follow protective lead-safe work practice standards (see EPA fact sheet).
The covered facilities include residential, public or commercial buildings, and rental housing. The rule applies to renovation, repair or painting activities. It does not apply to minor maintenance or repair activities affecting less than six square feet of lead-based paint in a room or less than 20 square feet of lead-based paint on the exterior. Window replacement is not minor maintenance or repair.
Employees working on a site where lead paint is present may not know these regulations and should be trained to ensure compliance with the law.
Here is the link for OSHA standards. Although it says it’s for the Construction Industry, it applies to anyone:
- Demolishing or salvaging structures where asbestos is present.
- Removing or encapsulating asbestos-containing material (ACM).
- Constructing, altering, repairing, maintaining, or renovating asbestos-containing structures or substrates.
- Installing asbestos-containing products.
- Cleaning up asbestos spills/emergencies.
- Transporting, disposing, storing, containing, and housekeeping involving asbestos or asbestos-containing products on a construction site.
Employers must provide a free training program for all employees who are likely to be exposed in excess of a PEL and for all employees performing Class I through IV asbestos operations. Employees must be trained prior to or at initial assignment and at least annually thereafter. Training courses must be easily understandable.
Here is the training that would apply:
For Class IV operations, training must be equivalent in curriculum and method to EPA awareness training (see 29 CFR Part1926.1101 for more information). Training must focus on the locations of ACM or PACM and the ways to recognize damage and deterioration and avoid exposure. The course must be at least 2 hours in length.
Class IV work includes custodial activities where employees clean up asbestos-containing waste and debris produced by construction, maintenance, or repair activities. This work involves cleaning dust-contaminated surfaces, vacuuming contaminated carpets, mopping floors, and cleaning up ACM or PACM from thermal system insulation or surfacing material.
This is obviously not something that multifamily can ignore. Property management companies need to make sure that proper training and education is a regular part of business. What are you currently doing to make sure your team is compliant?
Posted by Jonathan Saar