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Using Lead Abatement Contractors for Surface Preparation on Commercial Properties - The Consequences of Sacrificing Quality for Safety

The Federal EPA requires that commercial/residential painting contractors be certified to prepare surfaces containing lead based paint on residential and public structures. As a result, when respirators equipped with HEPA filtration are required to be worn to reduce worker exposure levels to below the permissible exposure limit for lead, the surface preparation work is often subcontracted to a licensed lead abate contractor who holds these types of certifications. 

Product Number: 51216-012-SG
Author: Raymond S. Tombaugh
Publication Date: 2016
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The Federal EPA requires that commercial/residential painting contractors be certified to prepare surfaces containing lead based paint on residential and public structures. As a result, when respirators equipped with HEPA filtration are required to be worn to reduce worker exposure levels to below the permissible exposure limit for lead, the surface preparation work is often subcontracted to a licensed lead abate contractor who holds these types of certifications. Unfortunately, there have been several coating failures on commercial/residential buildings, originally containing lead paint that were the result of surface preparation performed by a lead abatement contractor and painting performed by a commercial painting contractor. These failures are generally catastrophic; with large sheets of paint delaminating from the building façade shortly after application. This paper discusses the applicable regulations that govern lead paint removal, provides insight into the reasons that painting contractors use lead abatement contractors for surface preparation work, and highlights the potential consequences of these partnerships. By bringing these issues to the forefront, painting contractors can realize the value of becoming licensed to perform surface preparation operations on their own, rather than leaving it in the hands of a contractor unfamiliar with its inherent importance. In this manner, safety can be preserved without sacrificing quality. The paper also discusses various surface preparation methods (e.g., chemical stripping, power tools with vacuum shrouds) that can be employed, as engineering controls, to reduce the inherent hazards of lead paint disturbing operations. Recommended practices and controls that can be implemented in the event that a lead abatement contractor must perform surface preparation operations for the painting contractor are also discussed.

The Federal EPA requires that commercial/residential painting contractors be certified to prepare surfaces containing lead based paint on residential and public structures. As a result, when respirators equipped with HEPA filtration are required to be worn to reduce worker exposure levels to below the permissible exposure limit for lead, the surface preparation work is often subcontracted to a licensed lead abate contractor who holds these types of certifications. Unfortunately, there have been several coating failures on commercial/residential buildings, originally containing lead paint that were the result of surface preparation performed by a lead abatement contractor and painting performed by a commercial painting contractor. These failures are generally catastrophic; with large sheets of paint delaminating from the building façade shortly after application. This paper discusses the applicable regulations that govern lead paint removal, provides insight into the reasons that painting contractors use lead abatement contractors for surface preparation work, and highlights the potential consequences of these partnerships. By bringing these issues to the forefront, painting contractors can realize the value of becoming licensed to perform surface preparation operations on their own, rather than leaving it in the hands of a contractor unfamiliar with its inherent importance. In this manner, safety can be preserved without sacrificing quality. The paper also discusses various surface preparation methods (e.g., chemical stripping, power tools with vacuum shrouds) that can be employed, as engineering controls, to reduce the inherent hazards of lead paint disturbing operations. Recommended practices and controls that can be implemented in the event that a lead abatement contractor must perform surface preparation operations for the painting contractor are also discussed.

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