|> You're assuming that | > I'm going to be a slob and scrape with no dropcloth, | > then the kids are going to come over and eat the paint? | | I guess that's part of what the EPA is worried about, | because otherwise they wouldn't care what you did with houses | that have old lead paint on the exterior.
Yes. I don't really have a problem with the law. Any contractor with any sense wanted to be careful about lead exposure before the law came into effect, and they still want to now. In general I think the law is about as reasonable as it can be, but it is bureaucratic, and that has its limitations. Following the law is not necessarilly the same thing as being careful about lead exposure.
Rather than looking at me as a contractor who's trying to skirt the requirements, I'd invite you to look at it from your own point of view. The job I'm on right now involves interior painting. There could be lead underneath. I don't know. I know there's none in the top layers because I painted it myself, 12 years ago. The paint is in good shape with almost no loose bits. I can stay under the 6 sq. ft. per room limit on scraping, but not if I sand the woodwork. I could perhaps get by without much sanding, maybe just relying on TSP washing, since the trim is a low sheen. Or I could use toxic methylene chloride sanding liquid and a fumy oil-base underbody if I'm worried about adhesion. Of course, that would also add to the cost of the job. And it's not especially healthy.
Now, imagine you're the customer. You've got a contractor you like and trust. You want him to repaint the interior. There's almost no peeling at all. He tells you, "Sorry, but with this new law it's going to be a lot more expensive. I have to wrap all furniture and HEPA vacuum all surfaces every day." You and he both know that there's no risk of actually being exposed to lead. (You might even know for certain that the house has never had anything but latex paint.) But none of that matters. Neither you nor your contractor has the legal right to make a decision... That's what most of my jobs are like. That's what I was using the opt-out form for.
Next month I need to do repairs and restain on a deck that I built myself. It's on a condo roof. The front half of the condo building is 1800s. The back half, where my customer is, was added in 1983. So I know there's no lead in the condo or on the deck. But according to the law that doesn't matter. The house was built before 1979. But if I work on one of the decks in the other condo building, (there are 2 on the property) which was entirely built in
1983, then I'm in the clear. Same condos. Same wood. Same dates. Same builder. One is subject to deleading-type protocols and the other isn't. A job last month was in an old stone water pump building that was converted to high-end condos about 5 years ago. Every surface inside is new, but the building isn't. So, again, I'd need to cover the whole room in plastic if I want to just, say, change door frame moldings.What if you were those customers? You'd be paying extra costs pointlessly. I'm grateful this topic came up because I need to stay legal, and I'm grateful to you for your research, but it is a very awkward scenario for me, and for people who want work done at a reasonable cost. A bureaucratic solution is limited by the fact that it can only operate by the letter of the law and doesn't allow for common sense. In the future I may get certified for lead work or I may just limit my jobs. I'm not sure. The certification is not a big deal, but the deleading-style work requirements are a pain in the neck. With many of my jobs I can probably stay under the 6/20 sq ft of disturbed paint requirement, so I might just try to do that.... and hire demo crews for larger renovations.
On the other hand, my back isn't getting any younger. Maybe I should just switch to an easier, more lucrative field, like Certified Lead Testing Technician. :)