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.”