Picture this: As part of a reroofing project for an old home,
you replace some gutters. During the removal process, some
lead-based paint from the house flakes off and lands on the ground.
Later that day, the homeowner's child is playing in the yard and
puts some paint chips in his mouth, ingesting lead. The child ends
up suffering from permanent disabilities.
Sound far-fetched? Maybe. But the U.S. Environmental Protection
Agency (EPA) wants to ensure such scenarios never occur. As part of
the Toxic Substances Control Act, EPA requires those who engage in
renovation work—including roofing contractors—to
provide a lead hazard information pamphlet to owners and occupants
before beginning work or face fines up to $25,000 per day. Although
EPA's pamphlet requirement dates to 1999, you may be unaware of
it—a consultant recently reminded an NRCA member about the
EPA has several rules regarding distribution of the hazard
pamphlet. First, pamphlets must be distributed to occupants and
owners of single-unit and multiunit residential buildings built
before 1978. Housing for elderly or disabled people is exempt
unless a child younger than 6 years old lives in such a
The pamphlet must be mailed at least seven days before work
begins; it can be hand-delivered any time before work begins.
However, work must begin within 60 days of pamphlet delivery. For
buildings with four units or less, if you deliver pamphlets in
person, you must obtain signed and dated acknowledgements of
delivery. If you mail pamphlets, you must obtain proof of mailing
from the post office. For buildings with more than four units, you
must give the pamphlet to the building owner (and obtain receipt
acknowledgement) and provide occupants of individual units with
written notification of the scope and time frame of work, as well
as a statement that lead-based paint may be disturbed. In addition,
occupants must be made aware of the pamphlet and able to request
one from you. All pamphlet receipt acknowledgements and building
certifications must be retained for three years following a...
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