Lead Abatement Work vs. Work That Disturbs Lead Paint
It is important to know that there is a difference between lead abatement work and working on projects where there is lead paint.
Lead abatement projects are designed to permanently eliminate lead-based paint hazards. Abatement is sometimes ordered by the federal or local government and can involve specialized techniques not typically used by most residential contractors. Lead abatement work can only be done by licensed lead abatement companies using certified abatement workers.
Working on non-abatement projects, such as remodeling and painting, where there is lead paint requires that the work must be done in a lead safe manner. Contractors must be certified, and workers must be trained when working with lead-based paint. These rules are found in the EPA's Lead Renovation, Repair and Painting Rule (RRP).
- Lead abatement projects are designed to permanently eliminate existing lead-based paint hazards.
- Lead abatement may be ordered by the federal or local government in response to a lead-poisoned child or other reason or may be undertaken voluntarily at any time.
- Lead risk assessments are a part of abatement plans and are designed to identify lead hazards and management strategies, and lead inspections are designed to locate all lead-based paint in a home.
- Companies doing lead abatement in Connecticut must be licensed by the Connecticut Department of Public Health.
- Lead abatement workers must be certified by the Connecticut Department of Public Health.
A lead abatement contractor is required when
- Work is required at the residence of a child under the age of 6 that has an elevated blood lead level.
- Work on a HUD property costs more than $25,000 per unit in rehabilitation assistance.
- A town has a local ordinance with abatement requirements.
If abatement is not required, work on lead-based paint must follow the EPA’s Lead Renovation, Repair and Painting (RRP) rules. Click here for RRP information.
In order to do lead abatement work in Connecticut a license is required. There are two licenses available:
- Lead Abatement Contractor
- Lead Consultant Contractor
What is the difference between a lead abatement contractor and a lead consultant?
- The Lead Abatement Contractor is a company that performs lead abatement work.
- The Lead Consultant Contractor is a company that performs lead hazard reduction consultation work, such as lead inspections and design of lead abatement plans.
Lead Abatement Contractor
Lead abatement contracting includes, but is not limited to, the encapsulation, replacement, removal, enclosure or covering of paint, plaster, soil or other material containing toxic levels of lead. To be a lead abatement contractor in Connecticut a company must:
- have a license issued by the Connecticut Commissioner of Public Health,
- have certified lead abatement supervisors, and
- use certified lead abatement workers.
Applying for a lead abatement contractor license is done online. The instructions to apply for a license online can be found to here.
Once a lead abatement contractor application along with the application fee is submitted online, the department shall review the technical, equipment and personnel resources of each applicant to determine if qualifications are met. The commissioner may issue a license under this section to any person who is licensed in another state under a law which provides standards which are equal to or higher than those of Connecticut and is not subject to any unresolved complaints or pending disciplinary actions.
Lead Consultant Contractor
The Lead Consultant Contractor is a company that performs lead hazard reduction consultation work, such as lead inspections and design of lead abatement plans. The lead consultant contractor must be licensed to perform lead hazard reduction consultation work. The Lead Consultant Contractors must utilize Connecticut Department of Public Health certified lead inspector, lead inspector risk assessors and/or planner-project designers.
Applying for a Lead Consultant Contractor license is done online. The instruction to apply for the license online can be found here.
Lead Inspector, Lead Inspector Risk Assessor, Lead Planner Project Designer and Lead Training Provider Certifications
Lead inspector certification is for any person who performs inspections solely for the purpose of determining the presence of lead-based paint and surface coverings and lead in soil, dust and drinking water through the use of on-site testing including, but not limited to, x-ray fluorescence (XRF) analysis with portable analytical instruments, and the collection of samples for laboratory analysis and who collects information designed to assess the level of risk.
Lead inspector risk assessor certification is for any person who (A) performs (i) lead inspection risk assessments for the purpose of determining the presence, type, severity and location of lead-based paint hazards, including lead hazards in paint, dust, drinking water and soil, through the use of on-site testing, including, but not limited to, x-ray (XRF) fluorescence analysis with portable instruments, and (ii) the collection of samples for laboratory analysis, and (B) provides suggested ways to control any identified lead hazards.
Lead planner project designer certification is for any person designs lead abatement and management activities.
Anyone holding one of the above certifications must be employed by a Lead Consultant Contractor who holds a valid license from the Connecticut Department of Public Health.
The application form for these certifications can be found here.
All lead abatement training courses and refresher training courses offered by training providers for persons seeking instruction as a lead consultant, including inspector or planner-project designer, lead abatement supervisor and lead abatement worker has to be approved by the CT Department of Public Health and conducted in accordance with the requirements of Connecticut regulations.
Lead Training Provider Certification
This certification is for entities that offer an approved training course of refresher training course in lead abatement or lead inspection, lead risk assessment, or lead planner project designer services. Applying to become an approved training provider is done online. The instructions to apply online can be found here.
To find an approved trainer and a course, click here.
EPA’s Renovation, Repair and Painting (RRP) Rule
EPA’s RRP Rule aims to protect the public from lead-based paint hazards associated with renovation, repair and painting activities. These activities can create hazardous lead dust when surfaces with lead paint are disturbed. RRP is a federal regulatory program that affects:
- Property managers
- Operators of Child-Care facilities
- Others whose work may disturb surfaces with lead paint
Individuals that conduct renovation, remodeling, or paint removal activities on pre-1978 residential houses, apartments, and child-occupied facilities such as schools and day care centers must meet these EPA requirements:
- Firms must be EPA-certified.
- An EPA-Certified Renovator must be assigned to each lead job.
- Workers must be trained in the use of lead-safe work practices.
These requirements became fully effective April 22, 2010. The information below is intended to help professional contractors and safety professionals understand what certifications are required and how to be certified. Click here to go to EPA’s Renovation, Repair and Painting Program.
EPA Firm Certification
EPA's RRP rule requires both firms and people to be certified. RRP requires all renovation, repair, and painting firms (including sole proprietorships) working in housing, or facilities where children are routinely present, built before 1978, to be certified. Firm certification is a key requirement to ensure the training of individuals and the use of lead-safe work practices. Firms must apply to EPA for certification to perform renovations, painting, remodeling or dust sampling. For more information, click here and then click on Firm Certification Tab.
Examples of the types of firms covered by RRP:
- Residential rental property owners/managers
- General contractors
- Special trade contractors, including
RRP Firm Responsibilities
Firms performing renovations must ensure that:
- All individuals performing activities that disturb painted surfaces on behalf of the firm are either certified renovators or have been trained by a certified renovator.
- A certified renovator is assigned to each renovation and performs all of the certified renovator responsibilities.
- All renovations performed by the firm are performed in accordance with the work practice standards of the Lead-Based Paint Renovation, Repair, and Painting Program.
- Pre-renovation education and lead pamphlet distribution requirements of the Lead-Based Paint Renovation, Repair, and Painting Program are performed.
- The program’s recordkeeping requirements are met.
For more information on EPA’s RRP rules, click here.
To report violations of RRP rule, click here.
In Connecticut licensed abatement contractors can use, in specific circumstances, encapsulants. For more information on approved encapsulants, see below.
- Current Registry of Authorized Encapsulant Products (English) (Spanish) *Updated June 2022*
- A Guide to Apply Liquid Encapsulants - Information on how to properly apply liquid encapsulants.
If you would like your product to be listed on the CT DPH Registry of Authorized Encapsulant Products the Application for Lead Encapsulant Product Authorization will need to be completed.
- Lead Inspection and Testing Summary Form Updated 09/2022
- Model Lead Abatement Plan
- Model Lead Management Plan
- Model Plan of Correction for Child Day Care Facilities
- EPA’s Steps to Lead Safe Renovation, Repair and Painting
- Report violations of RRP rule
- HUD's Lead Paint Safety: A field guide for interim controls in painting and home maintenance