Renovation, Remodeling, and Lead

Next to deferred maintenance and unchecked paint deterioration, renovation and remodeling activities are the biggest trigger of lead-contaminated dust and thus a significant contributor to the number of childhood lead poisoning cases nationwide. Anyone engaged in renovation and remodeling activities needs to be aware of the potential presence of lead-based paint in housing built before 1978 and take the appropriate measures, as outlined below.

Federal law now requires that contractors distribute a lead hazard information pamphlet ("Protect Your Family From Lead in Your Home") to residents of pre-1978 housing prior to beginning any renovation or remodeling activities. (Note the following exceptions: jobs involving less than two square feet of paint per component, work on non-residential dwellings, housing designated for the elderly, studio apartments and dormitories.) The EPA pre-renovation education rule also requires written acknowledgement from the client that he/she received the pamphlet. As an alternative, the contractor can send the pamphlet in a timely manner to the client by certified mail and keep the relevant documentation.

Prior to beginning a renovation or remodeling job on a pre-1978 home, it is also critical for the contractor to do some preliminary planning, including inquiring from the occupant and/or the property owner whether or not lead-based paint has already been identified in the dwelling. In addition, it is important for the contractor to set up the worksite in such a manner as to restrict access to and establish containment in the work area, to keep all debris and dust confined in a controlled space, which later will need to be carefully cleaned. These measures are also essential when work is to take place on exterior painted surfaces. It should be noted that these precautionary steps not only protect the dwelling's residents from potential exposure to lead-based paint hazards, but also protect the contractor from potential liability exposures.

Once work begins, the contractor must ensure employees are using the appropriate personal protection equipment and are not engaging in unsafe personal practices, such as eating, drinking, or smoking in the work area, which can result in ingestion of lead dust. Windows, doors and HVAC vents should be closed and sealed, if they are anywhere near the worksite. Through a variety of techniques, dust generation should be minimized, making worksite cleanup less of a challenge— and at the end of each day, the contractor should perform a thorough cleanup. In fact, the best practice is for contractors to clean as they work. For instance, as painted building components are removed, they should immediately be wrapped and disposed of, and horizontal surfaces should be cleaned with a HEPA vacuum at least twice daily. (Note that when the renovation, remodeling, or rehabilitation activities are funded by Federal or State housing program funds, specific regulations apply, including those found in the Code of Federal Regulations [CFR] at 24 CFR 35.1350.)

For exterior work, a disposable ground cloth should be used to prevent dust and debris from settling in the soil. The worksite should be cordoned off to prevent access by neighbors or onlookers, and windows and doors should be shut to prevent lead-contaminated dust from entering the dwelling.

As part of the cleanup process, both on a daily basis and clearly at the end of the job, all waste should be properly disposed of, by placing it in heavy duty plastic bags and then tightly sealing the bags, using duct tape to form a "gooseneck" seal. Contractors need to also check for any relevant Federal or State waste disposal requirements.

See the National Safety Council sections on Lead-Safe Work Practices and on Adult Lead Poisoning for additional potentially relevant information.