|
Beginning April 22, 2010 new EPA regulations take effect for Lead-Safe work
practices. These regulations apply to building contractors and landlords
who work on buildings built before 1978. They apply to both commercial and
residential buildings. Failure to comply with these regulations can lead
to substantial fines, $37,500 per occurrence per day. More information for
contractors can be found Here
and Here
NWC will be providing information on this page regarding Lead-Safe training and tools you as a contractor
can use to maintain compliance with this regulation. A significant EPA requirement is maintaining records
for 3 years of all work you perform on buildings to which these regulations apply.
- Download the application Here and an example of how to fill it out here. If you are a
New Jersey contractor performing weatherization work under ARRA, complete this application and send a copy of this
application to NWC. When you receive your approval letter and certificate from the EPA, send a copy of that to
us as well.
When you perform work on a dwelling, you are required to give the occupants a
copy of This pamphlet. Please
contact your local EPA office (addresses are at the end of this pamphlet which you just downloaded). For New Jersey
and New York this address is:
U.S. EPA Region 2
2890 Woodbridge Avenue
Building 205, Mail Stop 225
Edison, NJ 08837-3679
(732) 321-6671
Note that much like Davis-Bacon payrolls, you (both contractors and
Subgrantees) are required to keep records of all work you do on both residential
and commercial buildings built before 1978. Records must be kept for 3 years. Records currently required
include but are not limited to:
- Giving the dwelling occupants a copy of the previously mentioned pamphlet. We recommend proof that you gave
it to them, a picture or a signature.
- Proof that a lead-safe-practices certified person was on-site during the renovation. We believe that everyone
in the crew does not need to be certified but that at least 1 crew member MUST be certified and that at least 1 certified
member must be on-site during the entire renovation. Note that this applies to Subgrantees and Energy Auditors
as well as building contractors; no certification = doing nothing that could disturb lead paint.
- Proof that lead-safe practices were followed. This may include pictures of the work in progress including dust
barriers and HEPA filters.
- Proof that contractor employees were protected. This may include pictures of crew members wearing the appropriate
clothing and N-100-rated disposable respirators.
- Proof of proper cleanup. This may include pictures of the building after the renovation is complete, close ups
of window sills showing dust-free surfaces.
NWC will assist you in meeting these requirements, we are submitting statewide proposals and will have a nationwide
solution before April 22nd when these regulations take effect. We highly recommend that all contractors have the
following at every work site:
- A GPS-enabled cell phone for every lead-safe certified employee, with software that timestamps and GPS timestamps
when the employee arrived at the work site and when they left. NWC can provide this type of phone and software.
- A digital camera with sufficient resolution configured to timestamp the pictures.
- A computer capable of uploading signatures and digital photographs at every job site. We do not believe that
uploading pictures and documents later in the week is going to be practical as the EPA requirements will be neglected.
It may be possible to complete the uploads at the end of every day if proper procedures are always followed.
- Proper record storage. Keeping these pictures and records on a local computer will not be adequate because
of the 3-year archival requirement. Computers crash or are stolen, local storage for 3 years is not realistic.
NWC plans to have a plan in place before April 22nd that will meet your requirements if you have a contract with us,
either as an individual contractor/subgrantee or through a statewide contract.
- Training and support
Note: All information on this page is subject to change without notification. Please check back regularly for the
latest information.
|
