When the Environmental Protection Agency's Renovation, Repair and Painting regulations went into effect governing containment and clean-up in houses that test positive for lead, Ron Addis, owner of Window Depot USA, in Dayton, Ohio, appointed his office manager, Cassidy, to be the company's compliance manager. In that role, Cassidy gathers every relevant photograph and document from installers to ensure their inclusion in the job file. Window Depot USA in Dayton can prove it contained and cleaned up according to EPA rules on every job it has worked on since.
While many home improvement companies are trying to figure out how to price lead-safe jobs so as not to undercut profit margins, the actual management of those jobs also remains a work-in-progress due to lack of clarity about what's expected. For starters, if the house tests positive for lead and there is any question about the subcontractor's commitment to lead-safe renovation, take the job somewhere else. In essence, what is absolutely required is the presence of someone trained and certified. "I would want to be sure that the company I am subbing to has a [Certified Renovator] on staff and on site at all times," says John Jervis, president of the American Window and Door Institute in Florida. He also suggests a pre-production meeting with subcontractors and homeowners to ensure that all parties are clear about what they need to do.
Varies by State
Requirements for managing the job for lead-safe renovation may vary by state, but whatever the specifics, it's the general contractor's responsibility to make sure that if lead is present, homeowners know it and lead-safe renovation takes place. "The money trail is going to come back to the company," says Chris Zorzy, owner of A&A Services, in Salem, Mass. (See www.leadsafevideosolutions.com for information about Zorzy's lead-safe renovation video guides.)
Enforcement of lead rules is still a matter of self-policing. Paul Toub, vice president of Kachina Contractor Solutions, suggests companies send their own CR at the start of the job to make sure every worker is trained on the lead-safe specifics of that job, document those practices with checklists covering interior and exterior setups, and have a company CR return for verification of proper clean-up. "If you're able to say all that and back it up with proof," Toub says, "you're going to be in a much better position to defend yourself if there's an issue."