wearing a Tyvek suit and shoe covering, as well as proper breathing apparatus. The interior cleanup includes wiping down all floors and sills with disposable washcloths or a Washington-based U.S. Department of Housing and Urban Development-approved “double mopping system.” Finally, an in- depth record of the job must be kept on file for three years and made available to EPA at a moment’s notice.
NUANCES OF
COMMERCIAL WORK The residential rule only applies to homes built prior to 1978 because lead was banned from residential paints in 1978. However, lead is still in some paints used for ships, roads and bridges, and some commercial applications (stair treads, industrial floors, metal door primers). Because lead-based paint can still be used in commercial and industrial buildings, the commercial rule would apply to every commercial building in the country regardless of when built.
IMPACTS TO COMMERCIAL REMODELING Currently, the only constraints for commer- cial remodelers when working with lead- based paint are those imposed by OSHA. EPA has only just begun its process for creating these regulations. However, the cost of com- plying with the residential rule has not been trivial. Commercial renovations tend to be on a larger scale than residential, so the cost of the rule could be significantly higher. The residential rule has also created an
“un-level playing field” between professional remodelers and fly-by-night contractors; the lack of consumer awareness only fuels this disparity. Many professional remodelers are being outbid because their prices include compliance with the rule while their com- petitors' bids do not. This same inequity may transfer to the commercial market. Worst of all, EPA applied a broad-brush
approach to housing with the lead paint rule and did not target homes most likely to house the most vulnerable population: poor city kids living in substandard housing. I ex- pect EPA will do the same with a commercial
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remodeling rule, placing the onus on small businesses and doing little to prevent lead poisoning. NAHB will continue to advocate for a rule that makes sense—because that’s what the public deserves.
To learn more about EPA’s lead Renovation, Repair and Paint-
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