In April 2008, EPA promulgated
regulations governing renovations in target housing (i.e., any housing
constructed prior to 1978) and child-occupied facilities. The rule was designed
to ensure that owners and occupants of target housing and child-occupied
facilities receive information on lead-based paint hazards prior to the
commencement of renovations and to ensure that firms
performing such work are certified and safe work practices followed.
Pre-renovation notice requirements
had been in effect since 1999; the April 2008 simply specified a new pamphlet
to be distributed to owners and occupants as of December 22, 2008.
However, the new regulations also
require that, as of April 10, 2010, all renovations in target housing or
child-occupied facilities be conducted by certified renovators and in
accordance with specified lead-safe work practices. This represents a sea
change in addressing lead paint issues in pre-1978 housing and child-occupied
facilities. The term "renovations" is broadly defined in the regulations
to include any "modification of any existing structure, or portion
thereof, that results in the disturbance of painted surfaces" and includes
such activities as modification of painted doors, window repair, and
weatherization projects.