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I am speaking to common sense. I would be cost prohibitive for any business to have such a lab come and test all the areas that you might have to renovate. Think of the Chinese drywall problems. One 4 X 8 piece contained the problem, but the next one would not (in some homes). Or an unknowing contractor used a contaminated piece to patch a hole in a good piece.
As Ingrid said, It might be ok, but why take the risk. This is not an area where more risk equals more profit potential.
Take a scraping of the area and have it analyzed for lead. If it contains none you have the proof that you are not subject to the lead based rules because you have no lead.
2010 EPA Lead Based Paint Rules Change
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Anyone can question what was done. No problem as you have proof of no need for compliance since there is no lead. With no lead disturbed you are in compliance and any questioning has NO STANDING no matter who it comes from.
But whatever, if a lab can get you off the hook, then where do I find a lab?
You can tell my opinion of this "rule" but which would be cheaper, certification or analyzing each project?
And I am no expert in the EPA regulation. But I did not think you could test it yourself. I really recall the regulation stating that the test had to be done by an EPA licensed "certified renovator" according Nike Coat Black
much all of the time" I was stating that in some way you must document compliance in any pre 1978 home. Unless you are a homeowner doing the work yourself. But if you hire someone then I recall that it was necessary to document the exception to the regulation.
I too am going by my what I recall from the bill AND the intent of the bill. It is that intent that is most often applied by the courts and if you are lead free (according to tests) then you are in complience with the intent.
to 745.82 and that "certified renovator is defined in 745.89 .
Who said skirt the law? The law is based upon lead particles being released as being harmful to those in the area and those working on the area.
Back then it was commonplace to strip off paint, especially peeling paint areas, before painting. Therefore is there any lead based paint left really?
Lets see now. We are talking about disturbing paint that has been there since 1978 and before because it might contain lead.
A responsible business decision demands that you comply or decide to dissolve the business.
It is common sense that checking the entire house would be cost prohibitive and therefore a responsible business will make sure that they comply by only using certified personel to do the renovations. Just as one would ask to see the certification of a CPA before taking his advice on taxes.
If you are still reading and interested in how the remaining two occupied apartments had to be handled I post it. I figured you may be getting bored by now :)
No problem, JCC. No fight intended or accepted, it is all in the discussion realm that we do here.
I am not here for a debate or fight I am just going by how I remember everything and certainly do not feel like reading the whole regulation again this late at night.
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next I immediately signed myself and my Super up for one day courses offered at Rutgers University cost $35.00 each. Course taught the hazards of lead of course, ways to "properly" do repair work and Certifications. This building is 100 years old this year and there are photos on my profile so it is inevitable that I must comply. Once the repairs were completed I had to produce the "Certificate" evidencing we were certified to make such repairs.
I am not really sure about that "certified renovator". I believe that is speaking about the person doing the renovation (contractor) and not the lab personel. I do not remember the bill actually speaking about a lab (it might) but there are several "labs" that are certified by the EPA. They would either train the individuals themselves or just not hire anybody that has not already been trained.
I certainly did not aim my "skirt the law" at you jawsette and I apologize if you took it as such.
Next, I asked the question, which way would be cheaper? That question was rehetoric in that hiring such a lab would be much more expensive on an per job basis, than the certification would be. Therefore the only business decision would be to become certified or only use certified personnel.
With the previous obvious stated, you are in error in some of your conclusions. First of all it is not a person that is certified, but the LAB which does the tests. Second there are several exceptions to the law which makes your claim of pretty much all the time incorrect.
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If there are no lead particles disturbed by the job then there can Nike Womens Hoodies be no contamination and you are in compliance no matter who you use.
I learned about the law the hard way one year ago. In NJ we have State "green card" inspections every five years. At my last inspection the inspector asked "do you have your lead certificate? who does your painting repairs?". Naturally with a super I advised her he made my repairs. She politely informed me of the law. I was given a laundry list of violations and 60 days to make repairs with a Lead Hazard Certified person, NOT the Super.
Where the lab and outside lead remediation contractor come into place is when you are given a specific violation stating this requirement. For example, in 37 units I had about 12 painting violations. There was no rhyme nor reason why those units were selected as many had NO peeling paint. She just wanted them painted because they looked like they hadn been painted in a while. In other units that had minimal peeling paint, the Certfiicate we provided covered these repairs (because the amount of peeled paint was less than 2 square feet). She selected two of these apartments requiring that they be tested by an outside remediation contractor. For the units that required minimal painting repair we were required to produce paperwork evidencing that one certified person took dust samples and the other certified person made the repairs. The same certified person could not do both. Lab tests per apartment dust wipes ended up costing $50 per apartment for 5 dust samples. More paperwork.
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