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Flooring contractors could be affected if more than six square feet of lead-painted areas are disturbed. In most situations, this would include baseboards, in which case, 32 linear feet of 2¼” baseboard would make the law enforceable.
Flooring contractors who perform renovation and repair work in facilities built before 1978 must comply with several mandates in response to this new law: |
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1. ATTEND THE EPA LEAD RENOVATION SCHOOL. Become certified in lead-safe work practices by attending an EPA-accredited training program. Eligible programs can be found on the EPA’s web site at: http://cfpub.epa.gov/flpp/searchrrp_training.htm.
2. APPLY FOR FIRM CERTIFICATION. Forms and instructions are available on the EPA’s web site at: http://www.epa.gov/lead/pub/pdf.
3. CONTACT YOUR INSURANCE AGENT to determine if you need additional liability insurance to cover lead renovation and repair work.
4. PROVIDE EPA PAMPHLET. Give customers in facilities built before 1978 a copy of the EPA “Renovate Right” pamphlet. A copy of the pamphlet is available for download from the EPA’s web site at: http://www.epa.gov/lead/pubs/.brochure.htm.
5. GET PROOF EPA PAMPHLET WAS PROVIDED. Have your customer sign a receipt that the pamphlet was received, and maintain a copy of the receipt for your records per EPA regulations. A receipt form is available on page 23 of the EPA’s “Small Entity Compliance Guide to Renovate Right” brochure at: http://www.epa.gov/lead/pubs/sbcomplianceguide.pdf.
6. PERFORM LEAD-SAFE TEST. Based on instruction received by attending an EPA-accredited training program, perform the lead-safe test to determine if lead paint is present. Tests should be conducted for flooring finish, baseboards, and shoe moldings, and should be performed only by EPA-certified renovators and EPA-certified companies. Information on acceptable lead-testing kits is available from the EPA’s web site at: http://www.epa.gov/lead/pubs/pubs/kits.htm.
7. IF LEAD IS PRESENT, inform customer about renovation and repair procedures and costs before starting any work. You can choose not to perform renovation or repair work if lead is present. If you do choose to perform the work, you have several options available to you.
- IF LEAD IS PRESENT IN FLOORING FINISH, follow renovation and repair procedures from your EPA-accredited lead-safe work practices training program.
- IF LEAD IS PRESENT IN BASEBOARDS and/or shoe moldings, determine if it is possible to perform the renovation or repair without disturbing the lead-painted surfaces. It may be possible to hand-sand the edges and avoid removing or disturbing the baseboards and/or shoe moldings. If this is not possible, follow renovation and repair procedures from your EPA-accredited lead-safe work practices training program.
- IF LEAD IS PRESENT IN BASEBOARDS AND/OR SHOE MOLDINGS, AND CARPET IS BEING REMOVED, determine if it is possible to remove the carpet without disturbing the lead-painted surfaces. If possible, install the new wood flooring 1/8” – 1/4” from the baseboards without removing or disturbing it. This expansion space plus the space included under the existing baseboard should provide the required ¾” expansion space as recommended in the NWFA Installation Guidelines. Then install new shoe molding to cover the combined expansion space. If this is not possible, follow renovation and repair procedures from your EPA-accredited lead-safe work practices training program.
It is important to note that a previously eligible OPT-OUT PROVISION for homes without pregnant women or children under age six in residence was amended on April 23, and is EXPECTED TO BE REVOKED IN JULY 2010. Therefore, all facilities built before 1978 will be required to comply with this new legislation. Failure to do so could result in fines of up to $32,500 per violation, per day. More information about the Lead Renovation, Repair and Painting rule is available on the EPA’s web site at www.epa.gov/lead/pubs/renovation.htm.
Lead in dust is the most common way people are exposed to lead. Projects, such as sanding, that disturb lead-based paint can create dust and endanger you and your customers. Part of lead safety when renovating hardwood floors requires power tools that have high efficiency particulate air (HEPA) filter-equipped vacuum attachments to contain the dust.
Independent of any EPA requirements, Bona has always been concerned for the health of our customers and the environment. In 2006, Bona became the first and only manufacturer in the industry to offer a GREENGUARD certified hardwood floor finishing and floor care system
For detailed information visit:
• EPA: www.epa.gov/lead
• Steps to LEAD SAFE Renovation, Repair and Painting
• Small Entity Compliance Guide to Renovate Right: EPA's Lead-based Paint Renovation, Repair, and Painting Program
• NWFA Lead-Based Paint Action Alert
To learn how to obtain your certification visit:
• http://www.epa.gov/lead/pubs/traincert.htm
Are you ready? Do you have the proper equipment? Bona has a portable dust containment system that meets the EPA criteria.
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• HEPA filter meets EPA lead abatement criteria
• Extremely portable and easy to use
• Complete unit weights less than 100 pounds
• Large, non-marking, locking wheels
• Clear dust collection barrel and filter gauge make it easy to know when the unit is full and/or when it’s time to clean the filter
• A robust dolly system, allows easy loading and unloading of the unit by one person
• Flexible, non-marking, crush proof, anti-static hose equipped with positive locking adapters are standard
• GREENGUARD certified for indoor air quality.
The Bona Portable DCS is the most advanced dust containment system available. By combining a Bona exclusive two-step cyclonic intake system with a hospital-grade HEPA filter, the Portable DCS delivers the dust containment results you need and your customers will demand. The Bona Portable DCS uses a Longopac® system (continuous bag) to collect the dust. This system eliminates the need to expose the collected dust to the job site when emptying the bag. |
More information on the Bona Lease Program >>