Childhood Lead Prevention Program: Contractor Information

Why do contractors need to know about lead-safe work practice requirements?

1. Most contractors are now required to attain USEPA Lead-Safe Certification



Any contractor, including renovators, electricians, HVAC specialists, plumbers, painters and maintenance staff, who disrupts more than six square feet of lead paint in pre-1978 homes, schools, day care centers and other places where children spend time must now be USEPA Lead-Safe Certified.

• This USEPA flyer, "If You're Not Lead-Safe Certified, Disturbing Just Six Square Feet Could Cost You Big Time (pdf)", informs contractors of the advantages of getting lead-safe renovation training and firm certification and the consequences of not using lead-safe work practices. En español (pdf)


• This USEPA booklet, "EPA Small Entity Compliance Guide to Renovate Right (pdf)", describes the Federal Renovation, Repair and Painting Rule and how to comply. En español (pdf)


2. There is a presumption of lead-based paint for any pre-1979 San Francisco building or structure



San Francisco Building and Health Codes presume that any building built before 1979 has lead-based paint. Owners may hire State-certified lead inspector/assessors to refute this presumption on specific surfaces. Approximately 90% of San Francisco's housing units were built before 1979.



3. San Francisco Building Code requires lead-safe work practices when disturbing paint on any pre-1979 San Francisco building or structure



SF Building Code requires lead-safe work practices for any paint-disturbing repair, remodeling, or renovation work on on the exterior of a pre-1979 building or structure and in the interior of a pre-1979 residential rental property or one used for child care. If you are a painter, renovator, or any other worker who may disturb lead-based paint in their work, you must use lead-safe work practices on building exteriors and interiors to protect yourself and others from exposure to lead.

• This Department of Building Inspection brochure (pdf) describes SF Building Code requirements for lead-safe work practices, and this webpage provides additional guidance and all the materials needed to comply with the SF Building Code.


• The Department of Building Inspection-Housing Inspection Services- responds to complaints and issues violations to property owners and contractors for work practices not complying with the code.

The SF Building Code specifies that you must notify residential occupants at least 3 days before work begins and must provide specific signage to the public warning them of the work in progress.

You must comply with these key requirements for lead-safe work practices:

• Set up the work area to provide containment and prevent migration of all generated paint dust and debris
• Minimize dust-creating work practices
• Clean up carefully and completely
• Do not use prohibited work practices to disturb or remove paint

It is prohibited to use the following methods in San Francisco to disturb or remove paint:

• Scraping, sanding, grinding, abrasive blasting or sand-blasting without containment or a HEPA local vacuum exhaust tool.
• Hydroblasting or high-pressure wash without containment and barrier systems.
• Open flame burning or torching, including propane-fueled heat grids.
• Heat guns operating above 1,100 degrees Fahrenheit.

How can contractors get trained and certified in lead-safe work practices?

1. Become a USEPA Lead-Safe Certified Renovation Firm and establish your firm's Certified Renovator.



Federal law requires all renovation, repair, and painting firms (including sole proprietorships) working in housing, or facilities where children are routinely present, built before 1978, to be certified.

To apply follow the instructions online. Certification is simple and quick for firms intending to comply – just submit an application and fee to EPA.

2. Assign a Certified Renovator to each renovation job the firm performs.



To become a Certified Renovator, a person must complete a renovator training course accredited by EPA or an EPA authorized program which will teach you how to work lead safe.

• Find a training provider in your area.
• Access a calendar of training courses for RRP and other programs on the National Center for Healthy Housing website. To use the calendar to find Certified Renovator courses, type "renovator" in the search field (at the upper right of the calendar) and click the magnifying glass icon.

The certified renovator must perform or direct certain key tasks during the renovation and be present on-site during those key tasks, including while:

• Signs are being posted before the job;
• The work area is being contained; and
• The work area is being cleaned post-renovation.

The certified renovator must perform cleaning verification after the job is finished.

The certified firm and renovator must make sure that other workers on the renovation job follow lead-safe work practices.

The certified firm and renovator must prepare and maintain records. Use EPA's sample recordkeeping checklist (pdf).



3. The Certified Renovator must provide lead-safe work practices training to all non-certified renovation workers on a job site.



Federal law requires that a Certified Renovator be assigned to each job, and that all involved individual workers that you employ are trained in the use of lead-safe work practices.



4. In addition, State law requires further certification for those doing work designed to reduce or eliminate lead-based paint, lead-contaminated dust, or lead-contaminated soil in or on residential or public buildings in California where controls are anticipated to last 20 years or more.



Such work requires employees to be either CDPH Lead-Related Construction-certified Lead Supervisors or Workers. Contact the CDPH Childhood Lead Poisoning Prevention Branch at 1-800-597-LEAD for further information.

What must contractors communicate to customers and affected tenants?

1. Contractors must provide their customers proof that they are a USEPA Lead-Safe Certified Renovation Firm.



Contractors must also provide identification and proof of certification for the assigned Certified Renovator on the renovation job.



2. The firm must notify the homeowner or tenants about lead hazards and the requirements of the USEPA Renovation, Repair and Painting Rule.



The USEPA's Renovate Right: Important Lead Hazard Information for Families, Child Care Providers, and Schools (pdf) booklet may be used to provide customers and affected tenants general information about legal requirements for safe lead practices during renovation activities. En español (pdf).

3. The firm must document compliance with this requirement.



The USEPA's pre-renovation disclosure form (pdf) may be used for this purpose.