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EPA offers additional time for the RRP Rule....

In this memorandum from Cynthia Giles, Assistant Administrator from the Office of Enforcement and Compliance Assurance, states:

…Since the RRP Rule became effective on April 22, 2010, concerns have been raised by the regulated community regarding difficulties experienced in obtaining the rule required from certification and renovation worker training. Acknowledging those concerns and to facilitate the transition to full implementation of the RRP Rule, EPA will offer additional and sufficient time for renovation firms and workers to obtain the necessary training and certifications to comply as follows:

o Until October 1, 2010, EPA will not take enforcement action for violations of the RRP Rule’s firm certification requirement.
o For violations of the RRP Rule’s renovation worker certification requirement, EPA will not enforce against individual renovation workers if the person has applied to enroll in, or has enrolled in, by not later than September 30, 2010, a certified renovator class to train contractors in practices necessary for compliance with the final rules. Renovators must complete the training by December 31, 2010.

In view of the paramount importance of ensuring that all contractors follow the lead-safe work practices in the RRP rule, EPA will continue to enforce the work practice requirements in the rule which protect children and reduce lead exposure.”

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Gardening & Lead in Soil...

Spring has sprung in upstate New York. The daffodils are just finishing up and the tulips are just starting to put on their show. With the promise of warmer weather, people turn their sites towards gardening. In these economic hard times, more people are turning towards vegetable gardens. I often think of my garden as my sanctuary, a little place where I can be away from work and be in the great outdoors.

However, my work seems to follow me everywhere. Despite my garden being 150 feet away from the house and a good 50 feet away from the neighbor’s house, I still worry about the soil being contaminated with lead. Next door on the other side of my house is a long since abandoned

Home Grown Tomatoes

apple orchard. Lead arsenate was a common pesticide that apple orchards used up until WWII.

However, most people don’t live near or on old apple orchards. With the majority of the housing stock in the Northeast having been built before 1978, the concern is chipping and peeling lead paint getting into the soil causing contamination. Lead is harmful even in small doses. It readily takes the place of other minerals such as iron, magnesium and calcium in dark green leafy vegetables. So, vegetables grown in a lead contaminated soil can be harmful to eat.

Be wary of where you’re putting your garden. You’ll want to avoid putting a garden right next to the house or garage that’s chipping or peeling. Also, you won’t want to put the garden in an area where cars use to park or near busy roadways. Leaded gasoline may have leaked into the ground.

Get your soil tested for lead. It’s not an expensive test. Think of it as peace of mind. There are quite a few private companies that do lead testing. You may want to get some advice from your local health department or county cooperative extension. If the lead in soil exceeds 400 ppm (in New York State), you’ll want to rethink your gardening plot. Either move the area where you would like to garden or consider making lined raised beds.

A great article to read regarding the matter is:

Other helpful information:


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New RRP Rule – Press Release from EPA...

Press Release from EPA

WASHINGTON – The U.S. Environmental Protection Agency is marking National Lead Poisoning Prevention Week by announcing several actions the agency proposes to take to prevent lead poisoning. Lead poisoning may cause a variety of adverse health effects, including brain and nervous system disorders, high blood pressure, and hypertension. Children six years old and under are most at risk.

EPA has issued a proposed rule to expand the coverage of the 2008 Lead Renovation, Repair and Painting Rule. The new rule proposes to eliminate a provision that exempted some housing from the rule’s requirement that contractors be trained and certified and use lead-safe work practices when renovating, repairing or painting a pre-1978 home.

“This proposed rule will further increase protections for children and their families from lead-based paint hazards associated with home renovation and repair, “ said Steve Owens, assistant administrator for the Office of Prevention, Pesticides and Toxic Substances. “The administration is demonstrating its continued commitment to eliminating childhood lead poisoning and strengthening lead poisoning-prevention efforts with the announcement of these actions during National Lead Poisoning Prevention Week.’
The federal government banned lead-based paint from housing in 1978. However, if a home was built before 1978, it has a higher likelihood of containing lead-based paint. The 2008 rule requires contractors working in pre-1978 housing where children under six or pregnant women reside take the proper precautions to work lead-safe work, including minimizing the dust, containing the work area, and conducting a thorough cleanup to reduce the potential exposure associated with disturbing lead-based paint. This rule would expand such requirements to cover most pre-1978 homes.

EPA also announced that it will propose to modify the regulatory hazard standard for lead in dust so that it is based on the most recent science. The agency also will work with the U.S. Department of Housing and Urban Development to propose to modify the regulatory definition of lead-based paint. The National Center for Healthy Housing and several other citizens groups had petitioned the agency on these issues, making the point that current standards are outdated.

EPA will take comment on the proposal for 30 days and expects to finalize the rule by April 2010.

More information:

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Misconceptions Regarding Lead Paint Hazards...

I’ve been in the environmental industry for 15 years now. I took my first class regarding lead based paint in 1995. Despite this, I can’t convince my mother and my sister that it’s not just children that get lead poisoned and lead poisoning can occur in other ways than eating paint chips. My mom and my sister are rather intelligent people. My mom has a bachelor’s degree in history and my sister has a PhD in biophysics. However, it goes to show how strong the stereotypes and misconceptions are regarding lead.

The first misconception is that “only children get lead poisoned.” This is absolutely false. The one main difference between a child or an adult getting lead poisoned is the amount of lead it takes. Children are considered to have elevated blood leads if their blood lead levels are 5 ug/dl. For adults the amount is 40 ug/dl. Lead is the most dangerous in children under the age of 7 years because their brains are still developing. Lead poisoning in small children can cause permanent brain damage. In many other ways lead affects adults the same way it does children.

The second misconception is that “you can only get lead poisoned by eating paint chips.” This is absolutely false. Unless a child or adult has pica, a condition in which someone eats non-food items, children are usually exposed by “second hand” contact. For example, a cat sits in a window well that has paint chips and dust in it and regularly sleeps with the child; a window is left open and blows the paint chips and dust onto children’s toys or clothes; children play with their toys near a door where paint chips and dust have accumulated. The dust gets on their toys which then gets on the child’s hands. With adults, exposure is usually through hobbies or occupation.

The last misconception is that “lead only occurs in paint.” The term “lead based paint” is somewhat of a misnomer. Lead can occur in any coating including primers, varnish, stains, shellacs, etc. I don’t know how many times I’ve been asked on a job site, “Why are you testing that? It’s not painted,” while I was testing something stained. Indeed, I’ve found lead in primers, varnish, stains and shellac.

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How to Become an EPA Certified Renovator...

There are two ways to become a certified Renovator (Renovation, Remodeling and Painting or EPA RRP
Lead Safe LLC, is accredited to provide this course as well as the Renovator Refresher course. Upon successful completion of the course, students are issued their EPA certificate that is valid for 5 years. To maintain certification, a student must take a refresher course PRIOR to their expiration date or they must take the 8-hour initial course.

The other way a person could get certified is by taking a refresher based on being “grandfathered” in to the system because they have successfully completed training in EPA approved courses. The refresher course is shorter (4 hours) than the initial course but the student is required to provide proof of eligibility prior to enrolling in this course. A copy of the successful completion certificate from the eligible course is required

Eligibility Requirements for Refresher Training.

Individuals who successfully completed one of the following training courses before October 4, 2011, may choose to take the EPA four-hour renovation refresher course in lieu of the initial renovator training course to become a certified renovator.

* Abatement worker or supervisor course accredited by EPA, or an EPA authorized State or Tribal program
* Joint EPA-HUD Lead Safety for Remodeling, Repair and Painting, 2003 (EPA 747-B-03-001).
* EPA Model Training Course Minimizing Lead-Based Paint Hazards During Renovation, Remodeling, and Painting, 2000 (EPA 747-B-00-005).
* HUD Addressing Lead-Based Paint Hazards During Renovation, Remodeling and Rehabilitation in Federally Owned and Assisted Housing Course.
* HUD Lead-Based Paint Training for Remodelers and Renovators Course.
* State of Connecticut Lead-Safe Work Practices for Painting, Remodeling, and Maintenance Course.
* State of Maine Lead-Smart Renovation (a.k.a. Lead-Safe Renovator) Course.
* Commonwealth of Massachusetts Lead-Safe Renovator Worker and Supervisor Course.
* State of Wisconsin Lead Low-Risk Worker Course.
* Craven County, NC, Lead-Safe Work Practices Course.
* Baker Lead-Safe Work Practices Training.
* Connor Interim Controls/Lead-Safe Work Practices and Awareness Manual.
* NESHTA Lead-Based Paint Maintenance Training: Work Smart, Work Wet, Work Clean to Work Lead-Safe.
* Occupational Knowledge Interim Controls/Lead-Safe Work Practices and Awareness Training.

To schedule a class visit the Lead Safe LLC website. For more information on EPA lead training requirements visit EPA.

What’s the Difference Between a Lead Inspect...

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Lead Poisoning and Autism...

I arrived on the job site today to perform a lead based paint risk assessment for a client. The owner opened the door to her home as I came up the front stairs. The owner, a mother of two, stood there nervously as I got my equipment ready and went into my talk about what I was going to do while there. She told me that the whole house was full of lead. She stood there on edge as she told me her child had been lead poisoned as a toddler and was autistic because of the lead poisoning. 859052_43065526

I hadn’t run into this particular scenario before. The owner went through the house with me as I tested, and I told her what I found to be positive for lead as I tested. I think that my being there stirred up a lot of terrible memories of when she first found out her child was lead poisoned. I consistently found lead on some building components. This did not ease the owner‘s nerves, but she also wanted to know.

As I tested throughout the house, I kept thinking about the connection between lead poisoning and autism. I thought it was a viable possibility but hadn’t come across it before. Lead affects the nervous system. In children lead is particularly dangerous since their brain and nervous systems are still developing. It can permanently affect cognitive, communication and social functions.

So I finished my risk assessment. I tried to ease the owner’s mind by telling her that there is a reason for concern but not to be a nervous wreck and worry. I also told her that usually 90% of the battle with lead paint, in particular lead dust and lead paint chips, is to keep a clean house, which she did. Also, she had sealed and plasticized over most of the windows in the house which would greatly reduce the development of paint chips and dust (from opening and closing windows,) and the spread of such from breezes blowing into the house.oldwindow4

When I got home from work, I continued to think about the case. I did some research and started looking up articles about lead poisoning and autism. Lead poisoning can be a cause of autism or autistic symptoms. Lead poisoning can impair the development of both nonverbal and verbal communication. Lead can also exacerbate preexisting symptoms of autism. Lead exposure is particularly dangerous for children ages 3 and under, when autism is most likely to occur.

Unfortunately, there is no quick fix for lead poisoning or autism. The health effects are far-reaching, lasting a life time. At this point in time more research is necessary to better understand autism and the effects of neurotoxins, such as lead.

1. “Autism and Autistic Symptoms Associated with Childhood Lead Poisoning,” by Theodore Lidsky, PhD, Jay Schneider, PhD,
2. “Autism and Our Passion for Simple Causes and Quick Fixes,” by Dan Agin, The Huffington Post, June 18, 2007, passion fo-b-52651.html
3. “Facing Autism in New Brunswick,” October 13, 2007,

Lead Clearance Examination – Capstone of Lea...

The ultimate goal of any lead abatement project is the permanent elimination of all lead hazards. The final evaluation of the lead abatement project is a clearance examination. Most people think only of deteriorated paint when they hear someone talking about lead abatement. While paint that is in poor condition can certainly be an issue, it is well documented that the lead contaminated dust is the most common cause for childhood lead poisoning.

Lead contaminated dust result from:

  • Lead paint that is deteriorated
  • Lead paint that is subjected to impact
  • Lead paint that is subjected to friction
  • Improper renovation or remodeling activities
  • Tracking from bare lead contaminated soil
  • Improper or incomplete post lead hazard control/abatement clean up

An experienced and certified risk assessor can identify those areas where lead paint is being subjected to friction and impact. They will also identify any lead painted components that exhibit signs that a child may be chewing on them. The results of the paint assays, dust wipe and soil samples (if required) can be found in the risk assessment report along with the risk assessor’s recommendations for treating all the identified lead hazards that were found. These recommendations should be the starting point for developing lead abatement project specifications.

Lead abatement in target housing is regulated by the Environmental Protection Agency (EPA). In section 402 of the Toxic Substances Control Act (TSCA) EPA defines target housing thusly:

“…any housing constructed prior to 1978, except housing for the elderly or persons with disabilities (unless any one or more children age 6 years or under resides or is expected to reside in such housing for the elderly or persons with disabilities) or any 0-bedroom dwelling.”

The rule requires all persons working on these type of projects be trained by an accredited training provider and be EPA certified. Additionally these individuals must work for an EPA certified firm.

This can be achieved by utilizing any of four EPA approved methods or a combination of them. Prior to re-occupancy the completed project must have a clearance examination performed be an EPA certified inspector or risk assessor. The approved methods include:

  • Removal of lead-based paint and lead-contaminated dust
  • Replacement of lead-painted surfaces or fixtures and removal or covering of lead-contaminated soil
  • Permanent Enclosure of lead-based paint*
  • Permanent Encapsulation of lead-based paint *

* Use of these methods requires enclosures and encapsulants. HUD has specific testing requirements for encapsulants (See Chapter 13 of the HUD Guidelines)

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Lead in Candy or Candy Wrappers?...

With Halloween fast approaching, I thought it might be a good time to bring up the possibility of lead in candy or candy wrappers. When I was a little kid, Halloween was big with my family. My dad would invent cemeteries in our front yard with scary scenes of floating ghosts and an ax murderer bobbing the head of hiss victim while “blood” spurted from the decapitated body. This was before the time you could go down to the local box store and buy any and all of the above. Quite ironically, as much fun as my dad would have creating his automated concoctions, he would feel terrible if it scared away little kids. He would go running after the crying tot with a bowlful of candy.

All kids had to worry about in my neighborhood was getting egged or toilet papered. I’m happy to report, neither happened to me. My parents insisted on checking our candy before we ate any. Any unwrapped candy got thrown out. As a kid, it took great restraint to wait to eat any candy until we got home.

From 2005 through 2007, there has been scare with some candy imported from Mexico. Certain candy ingredients such as chili powder and lemon may be a source of lead exposure. Lead sometimes gets into the candy when processes such as drying, storing, and grinding the ingredients are done improperly. It has also been found in candy glazes, which may have initially been contaminated from worn lead glazes in ceramics where the candy coatings were stored. Also, lead has been found in some wrappers of imported candies. The ink on these wrappers may contain lead that can leach into the candy. You cannot tell by looking at or tasting a candy whether it contains lead.

Now, please don’t go throwing out your kids Snickers or Hershey’s bar. This was found in imports from Mexico. The Food and Drug Administration (FDA) has set guidelines in place . Lead levels in candy products are not to exceed 0.1 ppm. This is because under good manufacturing practices, this is achievable. How much is 0.1 ppm? One part per million (1 ppm) is roughly equal to 2 drops of food coloring being dropped into a 50 gallon tank; or the equivalent of a penny being divided into a million pieces. One of those pieces is a part (1) per million (ppm.) Divide that one piece into ten more pieces. One of those pieces equals 0.1 ppm.

It should also be noted that the FDA does NOT permit lead-based inks on any part of any food wrapper, including candy. This also includes the exterior of the wrapper.

Happy Halloween!

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2008 National Lead Poisoning Prevention Week...

Lead Safe can guide you safely through the renovation process!

This year’s theme is, “Let’s Wipe Out Lead Poisoning–Renovate Right!” and reflects our commitment to ensuring that all homes are made lead-safe for children, especially during home renovation. As part of National Lead Poisoning Prevention Week, many states and communities plan to offer free lead screening, and to conduct various education and awareness events.

The National Center for Disease Control and Prevention’s (CDC) goals of 2008 National Lead Poisoning Prevention Week are:

  • To raise awareness about this serious health issue;
  • To emphasize the importance of screening the highest risk children younger than 6 years of age, preferably screening them by 1 to 2 years of age;
  • To highlight existing childhood lead poisoning prevention partnering efforts and to increase the establishment of new efforts; and
  • To urge people to take steps to reduce their possible exposure to lead.

The federal government’s goal is to eliminate childhood lead poisoning in the United States as a major public health problem by the year 2010.

As a result of these past and ongoing efforts, children’s blood-lead levels have declined dramatically since the mid-1970s. In 1978, there were about 13.5 million children in the United States with elevated blood-lead levels. Currently, approximately 310,000 children ages 1-5 years in the United States have blood-lead levels greater than the Centers for Disease Control recommended level of 10 micrograms of lead per deciliter of blood.

The United States Department of Environmental Protection Agency (EPA) focuses on the importance of educating parents and children about the dangers of lead exposure, especially lead-paint hazards in housing. EPA’s new Renovation, Repair and Painting Rule (RRP) is designed to protect families from the dangers of lead dust resulting from renovations and everyday painting and repairs. The rule requires the use of lead-safe paint removal practices to ensure that activities such as sanding, cutting, and demolition do not disperse harmful lead dust into a family’s air, food and clothing.

The United States Department of Housing and Urban Development (HUD) goals for this week are in line with CDC’s and EPA’s. HUD is committed to eliminating the threat of childhood lead poisoning from our nation’s housing.

Poster for this event can be downloaded here: English Spanish

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