Background
- Cutoff year
- Residential lead-based paint was banned in 1978
- Typical Capitol Hill stock
- Most apartment buildings and houses predate that year by decades
- Federal rule
- EPA's Renovation, Repair and Painting (RRP) rule covers paid work that disturbs paint in pre-1978 housing
- Applies to rentals
- Landlords and the contractors they hire are generally covered when work disturbs painted surfaces
Where smoke work and lead rules meet
Wiping or washing walls with a cleaning solution does not usually disturb paint in the way the lead rules are concerned with. The trouble comes at the next stage. Heavily stained walls are sometimes scuff-sanded before priming. Cracked or peeling paint around windows and radiators gets scraped. Trim that has absorbed odor may be pulled off and replaced. Each of those steps can release lead dust in an older unit.
The RRP rule sets thresholds and requirements for this kind of work, including firm and renovator certification, containment, cleaning and verification. It applies to work done for compensation in pre-1978 housing, which includes most rental turnovers. Some details, such as the size of the area disturbed, affect what is required. Landlords should read the current rule or EPA's summary guidance, or confirm with the contractor, rather than relying on a general description.
Colorado also has its own lead-based paint program and requirements for certain activities. If in doubt, ask the Colorado Department of Public Health and Environment which rules apply to a planned job.
Building lead safety into a smoker-unit turnover
Assume older paint may contain lead
Unless testing shows otherwise, plan as if painted surfaces in a pre-1978 building contain it.
Separate washing from paint disturbance
Plan the cleaning stage first. Then decide whether any sanding, scraping or trim removal is truly needed.
Hire certified help for disturbance work
Ask painters and contractors to confirm their lead-safe certification before they start work that disturbs paint.
Protect neighbors and common areas
Containment should keep dust out of hallways and adjacent units, especially in a building with families.
Keep records
Keep the contractor's certification information and a description of work performed with the unit file.
Questions for a painter or contractor
- Is your firm certified under the EPA RRP rule, and who on site is a certified renovator?
- Will this job disturb painted surfaces, and how much area?
- How will you contain dust and clean up afterward?
- Can you prime over cleaned surfaces without sanding?
- What records will you give me at the end?
General information for Capitol Hill, not a quote or professional advice. In an emergency, call 911.