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Built before 1978 - bulldoze it!

To repair this house by the new EPA standards would exceed the value of the house.
To repair this house by the new EPA standards would exceed the value of the house.
Turn-Key Properties LLC

22 April, 2010 was the end of an age in real estate investing. With the implementation of new sweeping requirements for remodeling or working on homes built before 1978, the federal government has effectively devastated the single largest wealth producing opportunity Americans had.

So you wanted to be a real estate investor, well listen up; you better get certified by the EPA, buy yourself about $10,000 worth of equipment and a lot of plastic. If you "disturb" six square feet of material, in a "target home" you may get fined $37,500 for each occurrence! Even more if you have to work on a window, just one window, you have to be certified!

Of course certification comes with some costs and you must get continuing education at more cost to you.

If you are a contractor, property manager or real estate agent, hiring a contractor to work on the house, you also must be certified! Even if you do not perform the work yourself!

You can read all about lead safe work practices on the EPA site.

Frankly this space is not large enough to even outline all of the requirements, so lets just focus on replacing one window in that old rental house, school or day care.

  1. You must be certified to hire a contractor who is certified to do the work.
  2. You must pay to be certified and so does your contractor.
  3. The tenants must be notified with the appropriate forms prior to the work being done, and they must sign off on the forms.

Notice of Lead Hazard Evaluation (24 CFR 35.125). Under the Lead Safe Housing Rule, an owner must provide or post a notice after a lead hazard evaluation (i.e. a risk assessment, paint inspection, paint testing, or lead hazard screen) is performed. Such a notice must be provided directly to the resident (certified mail is recommended) or posted in a public location. It must be provided/posted within 15 days after the owner receives the evaluation report.

If a grantee chooses to presume lead-based paint and/or lead hazards are present, a Notice of Lead Hazard Presumption is required. This notice must be posted or provided directly to the resident, as required for the Lead Hazard Evaluation Notice.

Under the Lead Safe Housing Rule, a Notice of Lead Hazard Reduction must be provided after any Lead Hazard Reduction (paint stabilization, interim controls, or abatement) is performed. The notice must be provided to or posted for the residents no later than 15 days after the Lead Hazard Reduction is complete. The notice must contain the clearance results.You must seal off the area, with heavy duty plastic to prevent any dust from escaping, this is spelled out thoroughly and will require copious amounts of plastic and tape.

Now I'm sure I'm missing something here, but I will try to remember all of the important training I paid for!

  1. You must cordon off the area to be worked on with heavy duty plastic and copious amounts of tape to prevent any dust from leaving the work area, inside and out!
  2. However, OSHA will not allow you to work on a ladder if it is on plastic sheeting!
  3. You must post your certification where it can be seen by all.
  4. You must post the area to be worked on, warning all others to stay out!
  5. You must wear expensive respirators, approved by the EPA for this work.
  6. You must use a HEPA vac, not a HEPA filter vac but the much more expensive vacuum that is required by the EPA.
  7. You must not sand, grind, sand blast, wire brush, heat gun or needle gun the area.
  8. You must carefully remove the material, wrapping it in plastic and sealing it with tape to be removed from the home.
  9. You must test the area to be worked on with an EPA certified test kit.
  10. You must wear gloves, goggles, disposable shoe covers, disposable coveralls and head gear.
  11. You must fill out the test kit documentation form.
  12. You must take photographs of the work before, during and after to prove that you did all these steps to the EPA's satisfaction.
  13. You must keep records of all work done on hand for viewing by an EPA auditor.
  14. You must clean the entire area and all dust, with the approved cleaning materials in the approved manner.
  15. While wearing gloves wipe each windowsill in the work area with an approved cleaning wipe.
  16. compare the cleaning wipe to the approved EPA post-renovation cleaning verification chart.
  17. If the first wipe is not the same color or lighter than the marginally passing wet disposal cleaning cloth on your verification card then you must re-clean the area with the approved cleaning wipes and repeat #17.
  18. Continue until the cleaning wipe is lighter that the marginally passing wet disposal wipe, being careful to take photographs to prove you did this.
  19. Floors and counter tops: While wearing gloves, wipe each floor or countertop in the work area with an approved damp cleaning wipe. For floors, you must use an approved long handled mop designed to hold an approved wet cleaning wipes.
  20. Do not exceed 40 square feet of space with each approved wet cleaning wipe.
  21. If the approved wet cleaning wipe is not whiter than the marginally passing wet disposable cleaning cloth... WAIT ONE HOUR and do it again!
  22. Continue doing this until the approved wet cleaning wipe is whiter than the marginally passing wet disposable cleaning cloth provided on your EPA post-renovation cleaning verification card.
  23. Then re-clean the surfaces with an approved dry electrostatically charged white disposable cleaning cloth designed for use on hard surfaces.
  24. Document, document, document.
  25. Remove all plastic, tape, foot coverings, coveralls, gloves, cleaning cloths, etc. Place them in large heavy duty contractor trash bags and tie them in the approved "goose-neck" fashion. Take them to an approved landfill and dispose of them properly.
  26. Document, document, document!

Your $150.00 window just cost you $2,500 to install and the rent for the next three months will not cover it

They are from the government and they are here to help you!

If you are thinking about power washing that house, that is fine as long as you recapture ALL of the water and dispose of it in an approved manner. If you figure out how to do that, I would love to know!


  • znammer 5 years ago

    the list of errors in this article is longer than your list of requirements - next time don't sleep through most of the class!

  • Joel 5 years ago

    I think we took the same class, I'm a plumber and I had to get certified because I sometimes remove Sheetrock to work on plumbing.

    This is ridiculous!

  • renovator 5 years ago

    you are an idiot, Joel is absolutely right, it's actually a bit worse than he states!

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