There has been lots of chatter about lead in tiles and if RRP includes precautions for dealing with proper protections. I finally got a “Forever For Now” straight answer to the million dollar question. It is my long held belief the lead in tiles and other components which is found with XRF technology, is a huge potential problem for renovators. Here is the question and the EPA’s response to that question.
The project is to remodel a child’s bathroom in a home built before 1978. Components to be disturbed include ceramic floor tile, a bathtub and shower stall, drywall and wood trim. The only lead is in the ceramic materials, which will be significantly damaged by impact during removal.
Here is the question – Does the Certified Renovator have to control and clean any lead dust/debris hazards generated from the disturbance of the ceramic components prior to the child or parents re-occupying the bathroom?
The RRP Rule applies only to renovations (i.e., disturbances of “paint or other surface coatings”) in target housing or child-occupied facilities. See 40 CFR 745.82. The term “surface coating,” as defined in the regulations banning lead-based paint, specifically excludes those materials which are actually bonded to the substrate, such as ceramic glazing. See 16 CFR 1303.2. As such, the reach of the RRP Rule does not extend to disturbances of ceramic glaze on tiles, bathtubs, and showers. EPA nevertheless recommends that renovators use lead safe work practices when working with any materials known or likely to contain lead. As a practical matter, contractors should understand that the inapplicability of the RRP Rule will not shield them potential civil liability if they fail to contain, clean or otherwise knowingly expose residents or workers to lead hazards. In addition to the glazed surfaces of the tile, bathtub, and shower, the above fact scenario indicates that drywall and wood trim will also be disturbed. If the project will disturb more than 6 square feet of interior painted surface or other surface coating on the drywall or wood trim, the RRP Rule would apply and the certified renovator would need to implement RRP work practices, including those for containment, cleaning, and cleaning verification.
U.S. Environmental Protection Agency
At Lead Locators we always test the tiles & tubs and explain to renovators and home owners that to do it right, they must treat leaded tiles as if they were any other leaded component. Carefully deconstruct in a dustless way to be safe.