NAHB Develops Lead Rule Compliance Resources

NAHB Develops Lead Rule Compliance Resources

The U.S. Environmental Protection Agency is stepping up inspections and enforcement action on all types of contractors working in pre-1978 residences subject to the Lead: Renovation, Repair and Painting rule.

Remodelers working in pre-1978 homes must follow the rule or risk fines and litigation for regulation violations.

NAHB has developed member-only resources to help with lead rule compliance atwww.nahb.org/leadcompliance.

Be Aware and Be Ready

The EPA’s regional offices have begun inspections and enforcement under the lead rule. NAHB has learned that inspectors are requesting three years of records from firms under investigation.

Any contractor (remodeler, HVAC contractor, window replacement specialist etc.) working in pre-1978 housing units where painted surfaces are disturbed must understand the requirements of the lead rule and be able to demonstrate compliance to an EPA inspector.

EPA representatives are requesting records including:

• Signed copies (by the home owner/tenant of applicable projects) of EPA’s Pre-Renovation Disclosure Form that affirms they have received pre-renovation education in the form of the EPA's Renovate Right pamphlet. This requirement pre-dates the lead rule and remodelers need to have three years of applicable records on file.
• Copy of “Firm Certification” by the EPA or state (list of EPA-Delegated states) and a copy of “Certified Renovator Certificate” received from the EPA or state. Remodelers must have both these certifications on file and all Certified Renovators must be employed by a Certified Firm. Failure to have both these certifications can result in fines. Learn more about how to achieve these certifications. 
• Copy of the Certified Renovator’s report for each job subject to the lead rule. This includes information on any EPA-Approved Pre-Renovation Test Kits used only by the “Certified Renovator” to determine applicability of the LRRP Rule and the Sample Record Keeping Checklist.

Compliance Resources

NAHB has created resources to help with lead rule compliance and record keeping. The member-only webpage includes downloadable documents, such as a sample lead paint rule compliance checklist, sample contract language, pre-renovation disclosure form, sample record keeping checklist, and more.

For more information on the lead rule, visit www.nahb.org/leadpaint; or email Matt Watkins, or call him at 800-368-5242 x8327.