EPA Lead Paint Paint Law

What are those of you that own or manage rental property built before 1978 doing to comply with the new EPA law? I understand fines are $32,000 per occurrence.

1st off we are having our buildings tested for lead paint. Then we will go from there.

Training is expensive, but very necessary. Too many property owners/managers are not trained, with many even unaware of the law.

Through our local apartment association we were able to negotiate a very good discount on training for member owners/managers - $100 off the typical ~ $275 in the metro Milwaukee Wisconsin area. It is working well for us and for the trainer in that they have completely full courses without any advertising on their part.

One big thing our industry must address is the latest EPA proposal to require dust sampling and lab testing clearance. The EPA estimates $160 per room in testing cost. In WI testing can only be done by state certified risk assessors and the cost is about $240 per room. So you replace a damaged door and the costs triple.

From the Federal Register (Link Below) #2 and 4 are the getchas

1) Dust wipe testing must be performed after all renovations involving:

(i) Use of a heat gun at temperatures below 1,100 degrees Fahrenheit.
(ii) Removal or replacement of window or door frames.
(iii) Scraping 60 ft² or more of painted surfaces.
(iv) Removing more than 40 ft² of trim, molding, cabinets, or other fixtures.



A link to the proposed rule in the Federal Register is at:
edocket.access.gpo.gov/2010/pdf/2010-10102.pdf
There is a 60 day comment period

From my research the EPA, has several exemptions on this requirement.

•Housing built in 1978 or later.
•Housing for elderly or disabled persons, unless children under 6 reside or are expected to reside there.
•Zero-bedroom dwellings (studio apartments, dormitories, etc.).

from www.homeconstructionimprovement.com/new-...ook-for-contractors/

Exemptions number 2 & 3 are hard for me to understand.
Yes I know children are more susceptible to lead, but I guess if you are elderly, too bad. Also what age is considered elderly? We will redefine all our residents to be elderly, like you probably would too to get out of this requirment.

#3: So if a child lives in a studio the requirment isn't a concern.

If items 2 & 3 are actually correct, then I find it hard to make logical sense out of these aspects of the rules. What were they thinking???????????????

Any which way, the government orginally approved lead paint and now we are going to pay for it. Isn't it a fine country where you can tell someone go ahead and use this, its approved, then turn around later and penalize us for using the product by setting up a system to abate, compounded with a 32K a day fine if we don't deal with it in their prescribed manner.
If it were a just world, gov would pay us to abate what they originally approved. But it is a crazy world, that says studios are exempt, so why apply logic to anything spewed from a gov agency? But maybe I am confused, maybe it makes sense that studios and elderly are exempt????????????????????