[MassHistPres] Restoring windows and lead paint issues

Sun Dec 27 20:40:06 EST 2009

as of april 22, 2010, any contractor who will disrupt 2 square feet or more of surface that contains lead paint where a child under 6 lives or visits 3 hours twice a week (if a child visits 7 days a week for under 3 hours a day, restrictions do not apply--oy) must be certified as having taken the epa renovator course...the contractor must submit an epa lead paint guideline book to the home owner...

the general rules, in my opinion, are over the top...whether you are removing an existing window to be replaced or restored, all openings to the room must be taped and sealed and the exit/entrance covered with a plastic 'door', all wall hangings must be removed...furniture must be draped with plastic with the plastic being taped around the center and securely to the floor...plastic is laid and taped to the walls and floors....warning signs must be placed at all entrances to the area...once the sash/window is removed, it is placed in a bag to be removed from the home...the plastic, walls and adjacent window sills  must be vacuumed (hepa), then damp mopped with a 'swifter'...once that is done, a dry swifter is wiped over all surfaces...the epa has provided a laminated photo of a 'clean' and a 'dirty' swifter with a little viewing window...your dry swifter must be compared to the swifter pictures through that little window...this is the visual inspection....all the perto-chemical plastic must be rolled with the dirty side to the center, deposited in a heavy trash bag(s) and tied with a 'gooseneck' system...the contractor must be protected by a full disposable suit, respirator and booties which also go in the bag....the bag must then be vacuumed and sprayed down with water and wiped off before being moved out of the room...

we've had earlier discussions here about lead safety...common sense is the best protector against lead health issues as is the case with hot stoves and irons, toxic cleaning materials, stairs and toys....the lead flashing on your chimney sloughs off lead every time it rains...jet fuel still contains lead and, as a heavy metal, falls to the earth...a diet heavy in fast foods and gmo's compliments of monsanto and dow will prove to be at least as dangerous as lead paint in a failed condition...

because of the litigation issues that are certain to follow the new regulations, i have made the choice to decline to work in any home where young children live or visit...i do not market myself as a de-leader and, though we too incorporate a steam putty/paint removal system and remove all visible paint from window sash, i cannot guarantee that the completed sash will be lead free...

your questions are valid and pertinent...i'm certain there will be more questions and discussions as we all become more involved and familiar with the many, many new regulations...this listserv will be a prime forum for passing on new information...

jade mortimer
heartwood window restoration

----- Original Message ----- 
  From: Madelyn Mitton 
  To: masshistpres at cs.umb.edu 
  Sent: Sunday, December 27, 2009 2:41 PM
  Subject: [MassHistPres] Restoring windows and lead paint issues

  There have been many postings related to the historic windows vs replacement windows from an energy efficiency standpoint.   

  What I am inquiring about is the difficulty / cost of restoring historic windows compared to using replacement windows to meet compliance with the Massachusetts lead paint laws.    

  In Massachusetts " The Lead Law requires the removal or covering of lead paint hazards in homes built before 1978 where any children under six live."    Reference info  at http://www.mass.gov/?pageID=eohhs2terminal&L=6&L0=Home&L1=Government&L2=Laws%2c+Regulations+and+Policies&L3=Department+of+Public+Health+Regulations+%26+Policies&L4=Regulations+and+Other+Publications+-+I+to+L&L5=Lead+-+The+Massachusetts+Lead+Law+and+Legal+Documents&sid=Eeohhs2&b=terminalcontent&f=dph_environmental_lead_g_lead_law_require&csid=Eeohhs2

  Windows are the most difficult to meet compliance as several parts of the windows are considered movable / impacted surfaces and those components must be "deleaded in entirety."  

  Even if you have your window sash stripped and reglazed, once repainted they will sometimes (potentially often) test positive for lead.    On a recent project of 14 pairs of window sash that where stripped and reglazed by 2 different well-known companies, only 3 windows had lead levels low enough to be considered compliant.    If the windows had been visually inspected by lead inspector when completely stripped, the windows would currently be considered compliant.    Photos and invoices to show this work was done is not sufficient proof per the lead inspector I worked with.  

  You also need to get the fixed parts of the windows that are impacted by the movable sash 'deleaded in entirety'.  In most or all cases this would need to be done by a licensed deleader.  A licensed deleader may hand scrap to bare wood, cover or remove (As I am not a licensed deleader so you would need to refer to a licensed deleader to verify these options and determine if there are other options).

  Questions: 

  1. Is there a cost effective way to get historic windows into compliance with the Massachusetts lead paint laws? 

  2. Is anyone aware of a way to get compliance on a window sash that has previously been stripped to bare wood, but now repainted and when tested with X-Ray, tests over the maximum?          

  3. Is there any plan to inform historic window restoration companies about the benefits of suggesting to clients that they have the windows visually inspected when the windows are stripped?   (potentially saving thousands of dollars when having to have the windows stripped again when a child under 6 moves in or installing replacement windows to comply) 

------------------------------------------------------------------------------

  ******************************
  For administrative questions regarding this list, please contact Christopher.Skelly at state.ma.us directly.  PLEASE DO NOT "REPLY" TO THE WHOLE LIST.
  MassHistPres mailing list
  MassHistPres at cs.umb.edu
  http://mailman.cs.umb.edu/mailman/listinfo/masshistpres
  ********************************
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <http://mailman.cs.umb.edu/mailman/private/masshistpres/attachments/20091227/f6fbc783/attachment.htm>