Safe Solutions

New rules, new challenges

Residential roofing and renovation projects pose unique demands and challenges to roofing contractors, including protecting houses and landscaping, limited staging and access areas, significant pedestrian traffic and proximity of neighboring structures. New rules from the Environmental Protection Agency (EPA) relating to lead-based paint encountered during renovations will increase challenges to roofing contractors involved with certain residential projects. The rules take effect April 22.

Harmful effects

EPA notes that renovation activities like sanding, cutting and demolition can release dust from lead-based paint that can harm adults and children.

Inside homes, dust inhalation is the most common means of lead exposure among children. Of greater concern to roofing contractors: Lead paint chips and flakes from exterior building elements can contaminate the soil adjacent to a home and be inhaled or ingested by children playing near the home.

Young children are particularly vulnerable to lead's effects because their bodies absorb it more readily than adults' bodies and their brains and nervous systems are more sensitive to its damaging effects.

New rules

EPA regulations define renovation as "the modification of an existing structure, or portion, that results in the disturbance of painted surfaces." According to EPA, the trigger for regulating renovation activities is the creation of lead-based paint hazards. This is distinguished from a lead abatement project, which permanently eliminates lead-based paint and lead-based paint hazards from a building.

EPA's new lead-based paint rules call for the following:

  • Certification of any company that performs renovations, repairs or painting that disturb lead-based paint
  • EPA accreditation of training providers
  • Certification of renovators (workers who perform and direct renovation activities) and training of other workers engaged in the renovations by a certified renovator

EPA originally issued the rules in 2008 to address lead-based paint hazards created by renovation, repair and painting activities in target housing and child-occupied facilities. Target housing generally is defined as residences constructed before 1978 but not including housing for the elderly or persons with disabilities. Child-occupied facilities generally are defined as buildings constructed before 1978 and visited at least two days per week by a child younger than six years old—day care centers, preschools or kindergarten classrooms, for example.

Each renovation project covered by EPA's new renovation, repair or painting rules must be performed and/or directed by a certified renovator responsible for ensuring compliance with the regulation's work practice standards, according to EPA. This individual is responsible for critical tasks during the renovation such as posting warning signs, establishing containment of the work area and cleaning the work area after all work has been completed. Other trained workers (not necessarily certified renovators) may perform these tasks under the direction of the certified renovator.

The rules also establish work practices that must be followed to minimize lead-based paint exposures.


If you expect to encounter lead-based paint during renovation work, you must apply to EPA for certification of your company by completing EPA Form 8500-27 and submitting a $300 fee. Firm renovation, repair and painting certification is valid in all jurisdictions where EPA administers the renovation, repair and painting program. Individual states may establish their own renovation, repair and painting programs; fees to obtain certification in such states vary.

Harry Dietz is NRCA's director of risk management.



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