Stephen J. Klein President

2. Stephen J. KleinPresident

3. The Toxic Substances Control Act (TSCA) “Lead Paint Law”

4. The April 22, 2010 deadline was real. Follow the law. Enforcement is happening!

5. College Works Painting Seattle, WA $32,508 in FINES

6. Window World of St. Louis $19,529 + $20,048 (73 windows at 3 group homes)

7. But you’re thinking, “I’m a landlord; not a contractor!”

8. Evansville, IN Landlord failed to fix lead paint hazards after child found with elevated blood lead levels.Remediate or demolish house Pay $13K in attorney’s fees

9. Worcester, MASS Landlord: Criminally Indicted for Claiming Property was in Compliance (Forging Forms & Certificates)

10. For New Tenants

11. Use when work is done

12. Give to the residents of any pre-1978 home or apartment prior to beginning work.

13. Get signed acknowledgement & save for 6 years

14.  NON-COMPLIANCE? Civil Penalties Up to $37,500 per violation / per day Criminal fines & imprisonment for up to one year/violation Overseen by EPA & State Agencies

15. Pamphlet & Test for Lead Paint or… Pamphlet but Don’t Test – Assume Lead Paint & Use Lead Safe Work Practices (LSWP) to contain & control the spread of dust & debris

16.  WHAT KIND OF WORK? “Renovation” = Any work that disturbs a painted surface Removal of painted surfaces or painted components Surface preparation on painted surfaces Sanding and scraping Other activities that may generate paint dust

17.  WHAT KIND OF WORK? Removal of large structures that may have paint on them Walls and ceilings Large surface re-plastering Major re-plumbing Weatherization projects Cutting holes in painted surfaces to blow-in insulation or gain access to attics

18.  WHAT KIND OF WORK? Window replacement Window repair (if painted) Windows are a hot button & do not qualify under any exemptions

19. EXEMPTIONS Newer construction (1978 or newer) Date must be from a recognized source Lead-free certified job sites Test shows no lead paint or other surface coatings that contain lead Not in excess of 1.0 mg / sq. cm (or 0.5% by weight)

20. EXEMPTIONS Not removing or disturbing a painted surface Bath liner going over the old New siding over the old A gutter system Removing any part of an old component or disturbing a painted surface triggers the law!

21. COMPANY NEEDS TO BE EPA- CERTIFIED (and/or by state/s) • Pay $300 to EPA (5 Years) • Attest that it will assign a Certified Renovator • Use only certified or properly trained workers • Follow LSWP • Adhere to all recordkeeping requirements

22. Company Certification • EPA Application Takes Time • Kachina has “Shortcut” • Keep copy of Application & Cancelled Check • Send Certified Mail/Return Receipt Requested • Encourage your sub-contractors to certify their companies

23. BECOMING A CERTIFIED RENOVATOR • Complete 8 hour course (includes 2 hours hands-on training) by an EPA-Certified Training Provider • Average cost $250 • Accredited refresher course every 5 years

24. Certified Renovators • Bench strength is important • Only CR can test for lead paint • CR must be present at start of job to ensure proper setup • CR must return to the job site at the end to ensure proper cleanup • Encourage sub-contractors to become Certified Renovators

25. INSTALLERS ON JOB • Supervised or directed by the Certified Renovator • Must have received relevant OJT in LSWP from a Certified Renovator

26. On-the-Job Training • Again…bench strength is key • Document Training – Who, What, Where & When • Consider offering a Certificate of Completion

27. TIGHT PAPER TRAIL “CYYKW”

35. Safety Equipment & Supplies • Lead Test Kits • Warning Signs • Workers Protection • HEPA VAC • Plastic Sheeting & Tape • Swiffer Cloths • Trash Bags • Cones & Caution • Tape

36. Keep a tight paper trail in case of Audit What to do if contacted by EPA or State • Be Pleasant • Ask for the specifics of their request in writing • Contact an Attorney (specialist)

37. Be Proactive…Make Lemonade!

38. Visit: www.KachinaLeadPaintSolutions.com