Frequently Asked Questions
Lead Dust Sampling FAQ's
What's the regulatory difference between dust testing and clearance?
The important difference is examined when the results are in. Dust wipe testing culminates in reporting the results to the owners and occupants, regardless of the values relative to the EPA hazard standards. Clearance, on the other hands, requires that the Renovator “pass” the EPA hazards standards of 40, 250 & 400 ug/f2 for the floors, sill and wells respectively.
The EPA explains that information on results of dust sampling testing is likely to improve landlords and occupants awareness of dust-lead hazards. Per EPA, “It will also greatly improve their ability to make further risk management decisions”. As such, the owner can’t hold the Renovator to the hazard standards unless they’ve specified such in their contract agreement.
DWT and clearance must be performed by someone who was passed the EPA Dust Sampling Technician certification.
How many samples should be submitted to the lab for clearance for a project in 5 rooms?
13 samples plus 1 blank for a renovation clearance Floor, Windowsill, Window Trough from each room (12, if each room has these) and outside work area sample (1) and a blank (1). 13 samples + 1 Blank
Can a Renovator clear his own projects? How?
Yes, a Renovators can conduct post renovation evaluation on his/her own projects but there needs to be sufficient training before the clearance can be done. The dust wipe testing needs to be performed by a person who has successfully completed the EPA Dust Sampling Technician certification, a one day course presented by an EPA accredited trainer. EPA certified Inspectors and a Risk Assessors can also serve as this role.
How does the UNYSE Labs Lead Wipe Kit work?
The kit gives homeowners and contractors the ability to conduct wipe sampling after lead safe work practices that meet HUD & EPA requirements and regulations. The cost is 195$ and everything that is needed for the sampling is included. These items include wipes, tubes, gloves, chain of custody, and other sampling forms; everything you need to perform your sampling quickly and efficiently. EEA also includes a UPS shipping box for easy, convenient, and reliable service. Once the sampling is received at the lab, the results will be analyzed and processed within 72 hours. Once your samples arrive a new kit will be mailed so you never miss an opportunity to perform a clearance. This kit and service is USEPA, NLLAP, and AIHA approved.
The UNYSE Labs do it yourself lead dust sampling kit is a must need item for all contractors and home renovators. This convenient kit makes sampling easy, and know you can rest easy with the UNYSE Lab analysis. The leader in environmental testing analysis throughout New York State.
Lead Renovator FAQ's
Do I have to become a certified Renovator if I am already a certified abatement supervisor?
Yes. As a certified abatement supervisor, you will be required to take a half day (4-hour) "refresher" course. This is also true of those who have completed the lead abatement worker, or any recognized "Lead Safe Work Practices" courses, including the lead based paint maintenance training program "Work Smart, Work Wet and Work Clean to Work Lead Safe," prepared by NATA for EPA and HUD; "The Remodelers and Renovators Led Based Paint Training Program," prepared by HUD and NARI; or other courses previously approved by HUD for this purpose after consultation with EPA.
What do I have to do to become a certified Renovator?
A person can become a certified renovator by either: 1.successfully completing an accredited renovator training course, or 2.successfully completing an accredited refresher renovator training course, if the individual previously completed an accredited abatement worker or supervisor course, or has completed an EPA, HUD, or EPA/HUD model renovation training course (commonly known as Lead Safe Work Practices). Proof of prior training must be submitted and verified by the training provider.
Where can I find this training?
Environmental Education Associates has been accredited by the USEPA to offer training throughout the nation at our fixed locations as well as off-site locations. You can sign up for one of our scheduled courses on-line, or call our training department.
Other than training, what else do I need in order to be in compliance?
In addition to training, your firm must become an accredited Renovation Firm by applying to USEPA.
What are the fees associated with accreditation?
There are 2 certification options from the USEPA. Renovation Firm Certification is $300 and a combined Lead-based Paint Activities and Renovation Firm Certification is $550. There is no fee for individual certification; individuals are certified by the trainer, not the USEPA. Please note that EPA Certification fees do not include any training fees.
What are the responsibilities of a firm?
In addition to obtaining a Renovation Firm License, firms performing renovations must ensure that: All persons performing renovation activities are certified renovators or have received on-the-job training by a certified renovator; A certified renovator is assigned to each renovation performed by the firm; and All renovations are performed in accordance with applicable work practice standards
How long is the accreditation good for?
Firms will have to re-apply for re-certification every 5 years. To maintain individual certification, a person must go through an accredited refresher course every 5 years.
Do all of my workers have to go through this training?
No, but the certified Renovator must give on the job training to other persons performing renovation activities and maintain records of this training. Remember that a certified Renovator must be assigned to each renovation project, so you will likely need more than one certified Renovator if you have multiple jobs going on simultaneously.
Who is responsible for enforcing the rule?
At this point, USEPA is the enforcing agency. States and tribes may (in the future) become authorized to implement this rule. The rule contains procedures for the authorization of states, territories, and tribes to administer and enforce these standards and regulations in lieu of a federal program.
What is the legal status of this guide?
This guide was prepared pursuant to section 212 of SBREFA. EPA has tried to help explain in this guide what you must do to comply with the Toxic Substances Control Act (TSCA) and EPA's lead regulations. However, this guide has no legal effect and does not create any legal rights. Compliance with the procedures described in this guide does not establish compliance with the rule or establish a presumption or inference of compliance. The legal requirements that apply to renovation work are governed by EPA's 2008 Lead Rule, which governs if there is any inconsistency between the rule and the information in this guide.
Is painting considered renovation if no surface preparation activity occurs?
No. If the surface to be painted is not disturbed by sanding, scraping, or other activities that may cause dust, the work is not considered renovation and EPA's lead program requirements do not apply. However, painting projects that involve surface preparation that disturbs paint, such as sanding and scraping, would be covered.
What if I renovate my own home?
EPA's lead program rules apply only to renovations performed for compensation; therefore, if you work on your own home, the rules do not apply. EPA encourages homeowners to use lead-safe work practices, nonetheless, in order to protect themselves, their families, and the value of their homes.
Is a renovation performed by a landlord or employees of a property management firm considered a compensated renovation under EPA's lead program rules?
Yes. The receipt of rent payments or salaries derived from rent payments is considered compensation under EPA's lead program. Therefore, renovation activities performed by landlords or employees of landlords are covered.
Do I have to give out the lead pamphlet 7 days prior to beginning renovation activities?
The 7-day advance delivery requirement applies only when you deliver the lead pamphlet by mail; otherwise, you may deliver the pamphlet anytime before the renovation begins as long as the renovation begins within 60 days of the date that the pamphlet is delivered. For example, if your renovation is to begin May 30, you may deliver the pamphlet in person anytime between April 1 and start of the project on May 30, or you may deliver the pamphlet by mail anytime between April 1 and May 23.
General Course FAQ's
What should I bring to class?
Environmental Education Associates provides all course materials, including course manuals, handouts, specimens and electronic media, where applicable.
You may want to bring a pen and note paper. We will supply pens and highlighters for those attending an initial training course. Those attending courses that are "hands-on" should be prepared for manual labor, and should be outfitted appropriately with long pants and work boots. Environmental Education Associates will provide any additional safety equipment, including safety glasses and hard hats as determined by the circumstances.
I heard that there are special circumstances for asbestos. What exactly are they?
If you are being trained for the first time, you will need to bring your New York State Drivers License. If you are being trained by Environmental Education Associates and you are not a resident of New York State, you will need to contact the New York State Department of Motor Vehicles to obtain a New York ID number.
What if I just need an asbestos refresher?
If you have already received training, you'll need to bring you're a copy of your 2832 (DOSH Form) along with a current government issued pictured identification card.
What's your refund policy, especially if I have to cancel a course I've registered in?
Environmental Education Associates reserves the right to cancel classes due to low enrollment in advance of the course start date. In order to avoid any inconvenience, pre-registration with full payment is the only way to be notified if a class is cancelled. In the event that class is cancelled, refunds will be issued. If a student cancels five business days prior to class start date, refunds will be issued. If student cancels in less than 5 business days, credit will be issued for the next available class. If a student does not cancel their registration, or begins a class and is unable to complete the entire class, the student is ineligible for a refund, and is responsible for the full tuition
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