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continued from page 37The EPA says, “To become a certifiedrenovator, individuals are required to takeeight hours of training, of which two hoursmust be hands-on training.” Firms becomecertified by submitting “a two-page applicationto EPA and pay a fee of $300. Certification isgood for five years.” Certified firms then earnthe “rights to use EPA’s ‘Lead-Safe CertifiedFirm’ logo.”“Once a dealer is trained and certified,they will be better equipped to answer most ofthe questions that arise,” says Naomi Angel,DASMA legal counsel. “Instead of continuallyrelying on input from others, the trainingwill help each dealer become his or her ownbest resource.”Percentage of Homes Likely to Contain LeadHomes BuiltFrom 1960 – 1978Homes BuiltFrom 1940 – 1959Homes BuiltBefore 194024%protection specialist who works with Dr. Doain the EPA’s National Program ChemicalsDivision. He copied Dr. Doa on his response.In his e-mail, Edmunds noted that thekey issue is “whether the work performed isconsidered ‘minor repair and maintenance’ asdefined in the RRP regulations.”He quoted the EPA definition. “‘Minorrepair and maintenance’ is defined as activities… that disrupt six square feet or less ofpainted surface per room for interior activitiesor 20 square feet or less of painted surfacefor exterior activities … When removingpainted components, or portions of paintedcomponents, the entire surface area removed isthe amount of painted surface disturbed.”69%87%Source: National Survey of Lead and Allergens in Housing, as cited in 40 CFR Part 745, published April 22, 2008.Disturbing Lead-Based Paint?Since April 22, Door & Access Systemshas conducted two nationwide surveys thatgenerated much input from garage door dealerson the issue of lead-safe work practices. Sincethe RRP Rule focuses on “renovation, repair,and painting activities that disturb lead-basedpaint,” many dealers questioned why typicalgarage door repair and replacement workshould apply.For example, we received about 25comments like these:• “Removing garage doors does not disturbpaint. Do the EPA inspectors understandour industry?”• “The homeowner ‘disturbs lead paint’ withevery opening of the door. This is muchmore ‘disturbing lead paint’ than when weremove the door. How does removing a doortrigger the RRP Rule?”DASMA’s Three QuestionsRecognizing the potential confusion, DASMAe-mailed three questions to Dr. Doa of theEPA. The questions attempted to focus onthree key activities of garage door technicians.The EPA responded on April 8 in ane-mail from Marc Edmunds, an environmental#1: Repair WorkOur first question asked, “Does a garage doortechnician trigger the rule if the task involvesremoving or installing fasteners in a leadpaintedsurface? (The surface could be a doorsection, door trim, jamb, header, or ceiling).”We figured that this question covered mostresidential garage door repair work as well asgarage door opener repairs and replacements.When Edmunds responded, he did notcharacterize his comments as his personalinterpretation but called them “EPAResponse.” Here’s the first.“EPA Response: The RRP rule does notapply for work that meets the definition ofminor repair and maintenance. Removing orinstalling fasteners may disturb paint but theRRP rule would only apply if the combinedarea of paint disturbed for the entire renovationdoes exceeds [sic] the square footage in thedefinition of minor repair and maintenance.”#2: Removing Garage Door SectionsOur second question asked if the rule wastriggered when “removing a lead-paintedgarage door section.” We explained that“Garage doors typically come in four stackedsections. After removing fasteners, eachsection is simply carried away.”“EPA Response: If you are only removingfasteners and not disturbing paint on the doorsthen the square footage of the doors do not haveto be counted toward the six square feet and20 square feet in the definition of minor repairand maintenance.”Since this response did not specificallyaddress the issue of carrying the sections, wesent a follow-up question. We said:“Yes, we are only removing fasteners, andyes, we believe that we are not ‘disturbing painton the doors.’ However, we ARE carrying thedoors away from the garage and loading themin the technician’s service truck. Does that‘carrying process’ count as ‘disturbing paint onthe doors’? Common sense tells us that this isnot disturbing the paint, but we want to be sure.This action is repeated thousands of times a dayin our industry.”“It Depends …”His response was, “There may be someinstances where removing a door could disturbthe paint. For example, if the paint is in badcondition and paint chips fall off the doorwhen it is taken off the hinges or carried, thenthat would be considered disturbing paint. Itdepends on the situation.”We felt this response was encouraging, butthe phrases “there may be some instances” and“it depends” leave room for doubt. In a typical35-year-old painted garage door, the surfacesof the section joints can be rather brittle anddusty from constant rubbing against theadjacent section.In a later DASMA communication withMarc Edmunds, he acknowledged that garagedoor removal may not be considered a typicalhome renovation. But he added, “Removing adoor may or may not disturb paint. It dependson the job and thus will be a judgment call bythe people working on that job.”EPA Posts an Answer OnlineOn May 21, the EPA posted an answer on itsWeb site to a specific question about replacinggarage doors. The posted question is, “My firmreplaces garage doors. We unbolt the door fromits hardware and remove it without penetrating,scraping, or removing paint. Is this work subjectto the RRP Rule?”The EPA’s answer, available for viewingonline, is, “If unbolting and removing the doordoes not disturb a painted surface in the hinges,door, or frame, the RRP Rule does not apply.”The statement can be found at http://toxics.custhelp.com and searching for “garage.” TheAnswer ID number is 6982.continued on page 4038 Door & Access Systems | Summer 2010