URGENT:
Much Garage Door Work Does Not Trigger the Lead Paint Rule

In recent official communications between EPA and DASMA, EPA officials confirmed that a large portion of garage door technician activity is not subject to the Lead Paint Rule, which becomes effective next week, on April 22, 2010. (See the Q&A below.)

Nonetheless, the EPA says garage door dealers "need to have a trained and certified renovator on staff, and their firm needs to be a certified firm." Failure to comply can incur a fine of up to $37,500 per violation, per day.

The Lead Paint Rule applies when you work on pre-1978 homes, child care facilities, and schools. When the Rule applies, you are required to undertake several specific safety measures to ensure that all lead dust is contained and disposed of.

The Official Q&A

In early April, DASMA sent several questions to Dr. Maria Doa, the director of the EPA Lead Paint Program.The EPA's official responses came from Marc Edmonds, Environmental Protection Specialist; his responses were copied to Dr. Doa.

The three scenarios below are expected to cover most garage door-related work affected by the Lead Paint Rule. Text in brackets represents clarifying language added by DASMA.

1. Servicing a Garage Door or Opener

DASMA: Does a garage door technician trigger the Lead Paint Rule if the task involves removing or installing fasteners in a lead-painted surface (e.g., a door section, door trim, jamb, header, or ceiling)?

EPA: The RRP rule does not apply for work that meets the definition of minor repair and maintenance. Removing or installing fasteners may disturb paint but the RRP rule would only apply if the combined area of paint disturbed for the entire renovation exceeds the square footage in the definition of minor repair and maintenance [i.e., 6 square feet for interior space and 20 square feet for exterior space].

2. Replacing a Garage Door

DASMA: Does a garage door technician trigger the rule if the task involves removing a lead-painted garage door section?

EPA: If you are only removing fasteners and not disturbing paint on the doors then the square footage of the doors do not have to be counted toward the 6 square feet [interior] and 20 square feet [exterior] in the definition of minor repair and maintenance.

DASMA: We carry the door sections away from the garage and load them into a truck. Are we correct in viewing this carrying process as not "disturbing paint on the doors"?

EPA: There may be some instances where removing a door could disturb the paint. For example, if the paint is in bad condition and paint chips fall off the door when it is taken off the hinges or carried, then that would be considered disturbing paint.

3. Removing Garage Door Trim

DASMA: Does a garage door technician trigger the rule if the task involves (prying and) removing lead-painted trim from the garage door exterior?

EPA: The removal of painted trim would be considered disturbing paint and would have to be counted toward the square footage of the minor repair and maintenance definition [i.e., 6 sq. ft. for interior and 20 sq. ft. for exterior].

[Note: If the exterior trim is five inches wide and covers the two side jambs and the header of a 16' x 8' door, the total exterior square footage of the trim is 13.3 sq. ft., or not enough to trigger the rule (20 sq. ft.).]

Garage door dealers: If you have comments or questions about the above, please reply to this email. The upcoming summer issue of Door & Access Systems magazine will contain the complete Q&A with the EPA and more Lead Paint Rule details that affect your daily work.