Complying with new EPA lead-safe remodeling rules is a challenge for many contractors. But for one Rhode Island renovation contractor, it’s a challenge he met several years ago, working under pre-existing Rhode Island state laws and regulations. Rob Cagnetta runs Heritage Restoration in Providence, R.I., specializing in historic preservation. A few years back, he explained to Coastal Connection, he got interested in lead safety when the Rhode Island legislature passed tough new laws for lead safety in rental housing. Rob and his crew took the state’s 8-hour course to become a Lead Safe Remodeler/Renovator in Rhode Island, which is a required credential to work on pre-1978 buildings under the 2005 law. As a high-end remodeler, Heritage Renovations had always practiced scrupulous dust control measures on the job, especially in occupied homes. But after taking the state course, Rob realized that while his job sites in the field were probably safe for his clients, his window restoration paint removal and painting shop almost certainly was not safe for his workers. So he decided to take a closer look — and based on what he learned, to take some action. “Like a typical shop,” says Rob, “I have my wood shop, my window shop, and then an office, and people travel freely through them. So I did some swipe tests starting in my paint room, and I traced all of the lead from there through the hallway, through the wood shop, and into the office, and there was lead everywhere. Incredibly high, off-the-charts levels, like 11,000 or 12,000 parts per million (PPM).” Then Rob has his employees tested for blood levels of lead — and those tests came back high too. “One guy was at 45 [micrograms per deciliter], and one was I think 28.” OSHA’s action level for worker protection is 50 micrograms per deciliter; the Centers for Disease Control (CDC) recommends a 10 microgram-per-deciliter action level for children. “So we put in a steamer box for softening paint and allowing an easy wet scrape,” says Rob, “and we put in a downdraft table ducted to HEPA vacuum filters for sanding. And we cleaned the whole place. We kept all food and drink out of the paint room, because that’s a big path for exposure — putting things in your mouth. And we got everybody on a new diet to clean out their blood — high calcium, high zinc, high iron.” A steam table installed in 2005 (top) softens paint and putty, allowing Heritage Restoration employee Dave the painter to quickly and easily remove the wet material without raising dust (bottom). The shop-built downdraft table, equipped with two high-volume vacuum fans and HEPA filtration, controls dust even when dry-sanding, so that workers wear only a simple dust mask, on a voluntary basis. Then, Rob voluntarily invited OSHA into his clean new shop to inspect. "They did sniff tests of the lead dust exposure of the guys at work, scraping and sanding windows. And they came up with a voluntary respirator program, because with the new control measures we had in place, the lead dust was never getting to the crew's faces." Although they’re certified as lead safe remodelers, Rob and his company still had to take a refresher course when the new EPA requirements came in. But he says, “The instructor used us to demonstrate the hands-on component, because we were already experienced.” Still, teaching was a good learning experience: “Every time we went over it again, we got deeper into it and learned a little more.” These days — unfortunately — few of the company’s jobs are big enough to trigger the EPA or Rhode Island on-site requirements. The company’s bread and butter in slow times is small window restorations. They remove the sash and bring them back to the shop for that work, so only a small amount of material — a few stops and parting strips, and the contact points where the window sash meet the frame — is disturbed. If you measure it, that area typically adds up to less than the six-square-foot threshold. For the occasional large job, says Rob, the rules in Rhode Island haven’t really changed. “Our state reporting requirements were already stricter than federal EPA’s,” he says. On big jobs, containment is key. Typically, the team isolates the work area from the rest of the home entirely — “full containment, without even any dust door,” says Rob. “We open up a window or door to the outside, and we go in and out through that, and we use that for debris removal as well. Even on the second floor, we set up tower staging with stairs to access the space through a window. Because once you get the material outside, the standards for dust control change, and they’re easier to deal with. Outside the home, it’s about visible chips, not invisible dust.”