WHAT ARE THE SIGNS OF LEAD POISONING?

As like many of you, I have definitely exposed my body to lead over the last 30 plus years I have been involved in remodeling.   As I learn more about lead poisoning and the symptoms of lead poisoning, I flash back to my younger years working for my dad’s remodeling business.   Back then there was little awareness or thought given to the way we worked when disturbing lead paint.   One summer I remember complaining of stomach aches, muscle pains and constantly feeling tired even after having the weekend off.   My parents took me to the doctor but the doctor couldn’t find any reason for these symptoms.  He gave me a terrible tasting medication to take daily and asked me to report back on how I was doing.   The symptoms would seem to come and go all summer long, but then went away when I went back to college after the summer was over.  This same scenario played over again the following summer.

Later I found out from my parents that the doctor had told them my symptoms were psychosomatic.   He made this decision because the medication he gave me was only a placebo but I was reporting improved health.  Looking back what was actually happening was that I was moving in and out of exposure to lead as I was moved from one project to the next.  If I gutted a kitchen and remodeled it I would get sick and the symptoms would appear.  After completing that project I might move to an addition or attic renovation project where I would have little or no exposure to lead.  My symptoms would come and go as I moved from project to project and as my body had time to adjust.

Fortunately for me, in the early days of owning my remodeling business, I learned a lot about lead and lead safe work practices through the NARI/HUD Lead Safe Remodeler training program that came out in the mid 1990’s.  The current Certified Renovator training is only one day and really only teaches attendees how to contain the dust and debris.  Different than the current class, the NARI/HUD class was two days long and actually thought us lead-safe work practices that eliminated or significantly reduced the creation of lead dust and debris.  Attending that class was definitely worth the investment of time and money.  Both I and my employees changed the way we thought about the work we did and the methods we used going forward.

Lead poisoning is a serious concern, often confused with other illnesses:

(Note: The following information comes from the Massachusetts Division of Occupational Safety, Publication: # 17379-13-200-7/93)

Workers can be exposed to lead by breathing in lead dust or fumes from work activities, by eating, drinking or smoking in work areas, or by handling contaminated objects - and accidentally swallowing lead dust. Workers in many workplaces have so much lead in their bodies that they are slowly being poisoned. The symptoms may hardly be noticeable at first. But over time, lead can damage the brain, blood, nerves, kidneys and reproductive organs. This damage can cause serious disability: memory loss, extreme tiredness, emotional problems, even kidney failure, coma or death.

Lead poisoning can occur when people are exposed to large or small amounts of lead over time. Lead builds up in the body and may cause temporary or permanent damage. A blood lead test can show whether your body has absorbed a dangerous amount of lead. A high blood lead level is an indication that lead is building up in the body faster than it can be eliminated.

There are many symptoms or signs that suggest a problem with lead, but they can also be symptoms of other illnesses. It is also possible to have lead poisoning without noticing any symptoms. If you work around lead you should regularly see your doctor, whether or not you are experiencing the following symptoms:

Early Signs and Symptoms of Lead Poisoning:

• Fatigue
• Headache
• Sleeplessness
• Uneasy stomach
• Irritability or nervousness
• Poor appetite
• Metallic taste
• Reproductive problems 

Later Signs and Symptoms:

• Aches or pains in stomach
• Memory problems
• Muscle and joint pains
• Constipation
• Nausea
• Weight loss
• Weak wrists or ankles
• Kidney problems

Note:  The Photo above shows wrist-drop in adult with lead poisoning and renal failure.

What to do if you have been poisoned by lead

RRP and OSHA Requirements; What's Wrong With This Picture?

The picture below was published in a small Massachusetts news service.   I am purposely leaving out the name of the news service and this contractor.  There was no story with the picture, only a caption that gave this person's name, business name and discussed that he was "removing layers of paint from an 1800s historic house on Main Street in preparation for a fresh coat of paint".  The picture was e-mailed around between several association leaders and employees of OSHA as well as the MA Department of Occupational Safety.  The guy in the picture probably thought he had stumbled upon some free advertising....

There are a whole host of OSHA violations and RRP violations in this picture.  I am throwing it out there so you can use the comment section below to tell us what you see.   I am betting together we can find at least 30 seperate violations.  

If you are looking for forms and signage to help you with comply with the EPA RRP rule, I recommend you check out what The Lead Paint Forms Store has to offer.

OSHA Left Out Of RRP Rule Development, Just Getting Up To Speed. 

On Friday Mark Paskell and I attended a half day LEAD Hazard Awareness workshop sponsored by the MA Division of Occupational Safety and OSHA.  (Download the Power Point Presentations)  Mark and I agreed we learned quite a bit of new information related to OSHA requirements that apply to RRP related work at the workshop.  We have been working on developing training programs and workshops to help renovators become aware of and address OSHA rules.  Attending the workshop will definitely help us enhance our future offerings.

At the workshop it became obvious that OSHA and EPA didn’t collaborate on the RRP rule or the content of the required certified renovator training curriculum.  It also became obvious at the workshop on Friday that the OSHA reps in attendance were only just recently getting up to speed on the new RRP rule. When answering several attendee questions about OSHA requirements related to RRP work, I could tell the OSHA employees in the room lacked a true understanding of the required RRP work practices.  Although the RRP rule went into effect on April 22, 2010 these employees said they had only recently attended any training related to the rule.

If RRP instructors follow the EPA created instructor training manual when training renovators, they will be teaching students to do things that violate OSHA rules.  (Read more here) Will it be an adequate defense if fined by OSHA to defend what you did by referring to the content of the training manual?   It appears that the EPA attempted to cover its lack of clarity and understanding of OSHA rules in the training manual by adding this disclaimer where the manual covers the training of non-certified workers by certified renovators; “Note: OSHA rules may require employers to take further steps to protect the health of workers on the job” 

It’s always easy to find fault, but what we need is solutions.  So here are only but a few of my suggestions to EPA and OSHA:

• Rather than use fines and penalties to promote awareness and compliance, use education to help employers and employees identify and understand the health and safety risks of their professions and what laws and regulations they must comply with.  Knowing the why often makes the how easier to embrace.
• Rather than promote compliance with just mandatory reporting, paperwork and or fines, offer and require attendance at strategic training classes that not only explain what is required, but also why.  The classes could also include training on how to fill out the required reporting forms correctly.  Doing so would serve to help complying businesses who do the right things for their workers and customers, only to then get fined due to paperwork errors.
• Allow OSHA and EPA to keep the money collect in fines provided that use of this money is clearly targeted towards developing and supporting education that results in a better educated workforce, improved awareness of related health risks and reducing worker injuries and or illnesses. 
• Perhaps our industry could establish standard designations for workers who satisfactorily complete a predetermined curriculum of classes relevant to specific job duties and work environments.  This would increase the value employees bring to employers and give employers a simple and standard way to assess the knowledge and or experience of job candidates.
• Current OSHA and RRP related rules and training seems to concentrate on what not to do, without enough time and attention on the right way to do things.   With OSHA for example, fall protection rules require a business to put fall protection equipment in place and train workers when and how to use.  Great, but why not also complement it with training on methods for working safely and how to avoid putting yourself in a position to fall?    
• For RRP, the required training teaches how to contain dust and debris so it won’t spread outside the contained work area. Might renovators who follow these instructions only be increasing the health risks to workers by containing and concentrating the dust and debris in the confined work area? Wouldn’t it make sense to also train workers on lead-safe work practices that actually limit or prevent the creation of dust to begin with?  

If you have suggestions to add to this list please share them here.  If some day we have the opportunity to revise these rules and or the strategies used by our government to administer them, we will already have a collection of solutions to consider and offer.

Property Values and Equity Will Drop as a Result of the EPA RRP Rule

Home buyers, investors and realtors will likely drive awareness about lead and the new EPA RRP rule up.  But, at the same time, such awareness will drive the values of pre-1978 properties down.  If unaware of the additional considerations of risks, liability and costs related to the RRP, realtors will likely walk into a hornet’s nest. 

Some home buyers and investors use realtors acting as buyer brokers to assist them when purchasing property.  If making buying decisions based on property pricing and the costs related to bringing the properties they purchase up to par with their desires, these buyers will not be happy if they are blindsided by the RRP rule.  These buyers will also be very unhappy, and may consider legal options, if they feel their realtor should have advised them about such considerations during the buying process. 

A buyer’s willingness to purchase a property that contains lead will definitely be effected as a result of the RRP rule.  First, once word gets out, the health risks of lead paint and related liabilities will cause many buyers to bypass any consideration of pre-1978 properties.  As the supply goes up, the prices of these properties will go down.  Also, investors won’t like the added costs of owning such properties, particularly if the value of those properties is less likely to increase over time as compared to properties without lead.   This too will lower property values to a point where the value of certain properties may only be in the land they sit on, less the cost to get rid of the original lead infused structure.

As a result of the RRP rule, I predict home sellers and realtors will get into uncomfortable negotiations with buyers, and as a result, even some challenging conversations between themselves.  Let’s just say the asking price for a pre-1978 property is $280.000.  I picture scenarios where a buyer will make two different offers for that property.  One offer will be close to the buyer’s asking price, say $270.000.   But, the offer will be conditional upon testing the home for lead to confirm no lead is present.  The second offer will be much lower, say $240.000.  The second offer will reflect the additional costs and risks the buyer feels they will be assuming if the home does have lead and or the seller isn’t willing to allow testing for lead.  In the negotiations, realtors will likely become the punching bag, as buyers and sellers typically never interact, but rather the realtor acts as the middleman.  If the seller is first finding out about lead and the RRP as a result of the offer, as mentioned above, that seller might not be happy with their realtor either.

As a side note, realtors as a whole are typically much more professional and proactive than contractors.  The majority of them are also dues paying members of one single, well funded and very powerful trade association that represents their interests.  I predict that once a good number of realtors catch wind of and understand how the RRP will affect their industry; their association will be working to modify the rule in their favor.  This might be of benefit to renovators, but just as easily, it might not.

For Large RRP Remodels; Renovate or Tear Down and Start Over?

Question from an RRPedia User:


“Shawn, We have met a number of times, most recently at the Rings End event, which was great, informative and overwhelming. I'm not sure where to go for the answer to this question and thought maybe you could direct me. We are bidding a sizable remodel and the architect has note for that bidders are to follow RRP guidelines. Its pre-1978, we will be disturbing 75%+ of the existing structure and it is unoccupied. I'm thinking that we don't need to address the tarping and cleanup because of the magnitude and vacancy. If we do then we need to consider a tear down. Any guidance you can give would be appreciated. I'm sure you get this all the time so I understand if you can't get to it. Best regards, Ray Gaines Sr, Gaines Construction Co. Inc.”

Ray:
Thanks for your message. This question has come up several times already from other contractors like you who are trying to do the right thing and interpret the EPA RRP rule correctly.

The fact that the property is unoccupied during the renovation makes no difference regarding whether the EPA RRP rule applies. This is confirmed on the FAQ page of the EPA web site. Because of the removal of the opt-out provision in July of this year, any residential property where people live or will live (referred to as target housing) now requires the lead-safe practices unless the home tests out negative for lead under the EPA guidelines.

Also under the EPA RRP Rule, unless the entire interior of the structure is gutted down to bare wood, with no coated or painted surfaces remaining, the project must be treated as an RRP project and again the work must be done using lead-safe work practices.  A full removal of all exterior finishes however does require the RRP Lead-safe work practices.  Again, this is confirmed on the FAQ page of the EPA web site.  Keep in mind, all documentation requirements apply as well.

As a side note, your message does say the building is pre 1978; however you do not say whether the property was tested for lead.  If it hasn't been tested, one option to the owner would be to test it.  Of course, if there is no lead, the rule would not apply.

The EPA approved test kits sold by LeadCheck are very accurate.  These tests reliably determine the presence or absence of lead.  If you use these tests the owner would know if any lead is present at all.  However, under the RRP Rule, the EPA says the rule exempts renovations that affect only components that a certified lead inspector or certified risk assessor has determined are free of paint or other surface coatings that contain lead equal to or in excess of 1.0 milligrams per square centimeter (mg/cm2) or 0.5% by weight. EPA further explains that the determination that any particular component is free of lead-based paint may be made as part of a lead-based paint inspection of an entire housing unit or building, or on a component-by-component basis.

So, if the property owner wants to know if there is any lead at all, the EPA approved LeadCheck test kits could be used to do so.  If the owner chooses to use the EPA's action level of lead paint amount to determine if the lead-safe practices would be required, then currently the only way to test for amount of lead would be to use a certified lead inspector or certified lead risk assessor.  

One way to think about this might be to relate it to eating fish.  The government often says that if you fish in certain bodies of polluted water, you can safely eat up to so many of the fish you catch without any health concerns.  If the government says you can eat up to 3 fish a year, how safe would you feel eating even one fish?  Using this analogy, how safe might the owner feel having renovations done if there is any lead present at all at their property?

If you have opportunity to interact with the property owner, I suggest you might find you would stand out from the other bidders if you could share what I have written here with the owners.  It is my opinion that the property owners should know the facts, know their options and then make a decision about how to move forward regarding lead at their homes.

NAHB article regarding Lead Test Kits could be misleading for Renovators and Home Owners

In a recent article about their efforts to address challenges for builders and remodelers due to the new EPA RRP rule, the National Association of Home Builders (NAHB) left out some critical information that causes their article to be very misleading to renovators and home owners unfamiliar with specific details about the RRP rule.   In my opinion, the article also does a disservice to the manufacturer of LeadCheck, the only lead test kit currently approved by the EPA for RRP work.  Although I would stress that the NAHB likely didn’t omit the information on purpose, having done so serves to only add to the already existing wide spread confusion about the new rule.

In the August 9, 2010 article, the NAHB sites an announcement by the EPA.   The article states that; “More accurate, inexpensive test kits will not be available anytime soon.  The kits were expected to be ready by next month and were seen as key to keeping the lead paint rule affordable for home owners”.  The NAHB statement is true, but as stated would give renovators and home owners the impression that the current test kits are not accurate. In fact, the current test kits manufactured by Hybrivet Systems, Inc. of Natick Massachusetts have a twenty year plus proven track record of reliable and consistent accuracy. 

Let me explain:

Here is what was missing from the NAHB article and what renovators and home owners should know so they can make their own decisions about lead testing using the LeadCheck test kits.

The LeadCheck test kits reliably determine the presence or absence of lead.  The test is absolute.   If they used these tests the home owner and the renovator would both know if any lead is present at all.  However, under the RRP Rule, the EPA says the rule exempts renovations that affect only components that a certified lead inspector or certified risk assessor has determined are free of paint or other surface coatings that contain lead equal to or in excess of 1.0 milligrams per square centimeter (mg/cm2) or 0.5% by weight.  

In the rule preamble, the EPA stated; “research on the use of currently available kits for testing lead in paint has been published by the National Institute of Standards and Technology (NIST) (Ref. 26). The research indicates that there are test kits on the market that, when used by a trained professional, can reliably determine that regulated lead-based paint is not present by virtue of a negative result.” 

The EPA also stated; “The NIST research on existing test kits shows that existing test kits cannot reliably determine that lead is present in paint only above the statutory levels because the kits are sensitive to lead at levels below the Federal standards that define lead-based paint, and therefore are prone to a large number of false positive results (i.e., a positive result when regulated lead-based paint is, in fact, not present).”

So, if the property owner wants to know if there is any lead at all, the EPA approved LeadCheck test kits could be used to do so.  If the owner chooses to use the EPA's action level of lead paint amount to determine if the lead-safe practices would be required, then currently the only way to test for amount of lead would be to use a certified lead inspector or certified lead risk assessor.   These individuals have and use testing methods that can determine the presence of lead by amount.

Making better decisions about testing:

One way to think about this might be to relate it to eating fish.  The government often says that if you fish in certain bodies of polluted water, you can safely eat up to so many of the fish you catch without any health concerns.  If the government says you can eat up to 3 fish a year, how safe would you feel eating even one fish?  Using this analogy, how safe might the home owner feel having renovations done without using lead-safe work practices if there is any lead at all present at their property?  The choice should be theirs.

If you have opportunity to interact with a property owner, I suggest you might find you would stand out from other renovators the home owner might be considering if you could share what I have written here with the owners.  It is my opinion that the property owners should know the facts, know their options and then make a decision about how to move forward regarding lead at their homes.  If renovators and home owners are under the impression that the current test kits are not accurate, they would be misinformed.

EPA Cites Company $784,380 for Failing to Warn Residents of Lead-Based Paint Exposures

June 20, 2010

The U.S. Environmental Protection Agency recently filed a complaint and proposed a $784,380 penalty against Hanson’s Window and Construction Inc. of Madison Heights, Mich., for violations of the 1998 federal rule for failure to warn residents of potential lead-based paint exposures.

EPA alleges that in May 2005, Hanson, a window installation firm, failed to provide home owners and tenants of 271 residential properties in Lansing, East Lansing, Haslett, Charlotte, Onondaga, Williamston, Holt, Stockbridge, Mason, Leslie, and Warren with required information warning residents that their construction activities could expose residents to lead. The citation is based in part on information that two children living in renovated Michigan homes had tested positive for elevated blood lead levels.

The Pre-Renovation Lead Information Rule requires that renovators provide homeowners, tenants, and owners of child-occupied facilities with the “Renovate Right” pamphlet and obtain written confirmation that they have received it. The purpose of the rule is to protect families during renovations in housing built before 1978.

Lead exposure can cause reduced IQ, learning disabilities, developmental delays, reduced height, poor hearing, and other health problems in young children.

Lead-based paint dust created during renovations is the most common source of lead exposure to children in the United States. About 75 percent of the nation’s housing built before 1978 contains lead-based paint. When properly managed, lead-based paint poses little risk. If paint is not maintained, however, even low levels of lead exposure can threaten occupants’ health, especially children and pregnant women

This information was found at ohsonline.com

Many remodelers have asked me about resources they can use to find out more about lead, lead poisoning and the EPA RRP rule.  When I ask them why they are looking for this information two common reasons seem to rise to the top.  First, they are looking to better educate themsleves about lead and lead poisoning so they can be better prepared to discuss the health risks of lead with their clients and prospects.  Second, they are looking for resources to share with their prospects and clients, either as part of their marketing efforts or to add to their web sites.

To help remodelers and others, I have collected the following resources.  If you know of additional resources that would be beneficial, please be sure to share them here by posting them to the comment area below. 

Helpful Videos:

-Remodeler Greg Antonioli of Out of the Woods Construction and Cabinetry, Inc posted his own public service announcement on his company's web site.  Click here to view Greg's PSA.  The video was produced by fellow NARI member Chuck Green of Perpetual Motion Pictures 

-In a blog by Monte Smith, Smith has posted 8 videos he found on YouTube.  In his blog, Smith states he assembled eight videos  that, if viewed, will allow the viewer a broad view of the lead/RRP subject from multiple points of view.  He also strongly encourages anyone and everyone to invest a little over an hour of their time to watch the videos and become familiar with this topic.

-Senator Jim Inhofe of Oklahoma says the RRP Rule is a serious problem and a jobs killer.  He offers more information on his website

Information About Working Lead-Safe

A Guide to working safely with residential lead paint

Field Guide for Painting, Home Maintenance and Renovation Work

How to Safely Change a Lead Contaminated HEPA Vac Bag

OSHA standards for cleaning a respirator apply to EPA RRP work

What do I need to know about Respirators when doing EPA RRP work?

Restricted Practices and Prohibited Practices under the EPA RRP Rule

 Web Site List:

(1) Information on Lead for Everyone:

leadfreekids.org

(2) Information regarding the Lead RRP rule on EPA's website:

http://www.epa.gov/oppt/lead/pubs/renovation.htm

(3) Information about all EPA's lead programs:

http://www.epa.gov/lead/

(4) The Federal Register notice for the rule (April 22, 2008):

http://www.epa.gov/fedrgstr/EPA-TOX/2008/April/Day-22/t8141.htm.

(5) Link to Federal Resister notice for opt-out provision removal on RRP rule (May 06, 2010):

http://edocket.access.gpo.gov/2010/pdf/2010-10100.pdf

(6) Pollution Prevention and Toxics Frequently Asked Questions with answers (Note the expandable topics list and key word search feature on the right side of the page):

http://toxics.supportportal.com/ics/support/default.asp?deptID=23019

(7) HUD Lead page:

http://www.hud.gov/offices/lead/

(8) EPA Lead-Safe Certification Program Trade Press Downloadable Materials: EPA is placing ads in various publications and venues to get the word out to contractors and those who influence them about the new Lead Renovation, Repair and Painting Rule requirement that contractors must be lead-safe certified by April 22, 2010. If you are a contractor or someone who interacts regularly with contractors, EPA is seeking help in get the word out about the new rule.   EPA suggests downloading these outreach materials and distributing them by mail, e-mail, your place of business, or by placing them in specialty publications.

http://epa.gov/lead/pubs/lscp-press-materials.htm

(9) There are a variety of Public Service Announcements available for download on the leadfreekids.org web site.  these include announcements for TV, radio, color print, newspaper and web banners.

http://www.leadfreekids.org/materials.html

Question: Does the RRP rule require people working on a renovation to wear respirators, Tyvek(R) suits or other personal protective equipment (PPE)? 

Most renovation contractors have little knowledge or experience with OSHA requirements.  OSHA requirements concentrate on the occupational safety of the worker.  There are many OSHA requirements that contractors should already be following if they use employees or sub contractors on their job sites.  Because lead can create serious health risks for employees and workers, employers would be wise to become familiar with the OSHA requirements related to the work they perform under the EPA RRP rule. 

The required containment methods and work practices have changed the way work gets done in the field.  Even if working within OSHA requirements in the past, new activities and methods used on RRP related projects most likely trigger personal protection considerations under OSHA regulations.

Unfortunately, while creating the EPA RRP rule, the EPA did not include reference to any specific OSHA requirements.  Therefore, renovators need to know and understand both the RRP rule as well as any related OSHA requirements in order to protect workers and avoid potential penalties from OSHA and or EPA.  To learn more about the related OSHA requirements, renovators can refer to the OSHA Lead in Construction Standards.

In the new MA RRP rules, still yet to be enforced as of this posting, many of the OSHA requirements related to RRP work have been included in the regulations.  When I met with employees from the MA Department of Occupational Safety to discuss the proposed rule, they were very helpful in clarifying the reasons for adding these consideration.  So, although the EPA and OSHA may not have collaborated when the EPA RRP rule was created, MA renovation contractors will have the advantage of knowing what OSHA requirements they will need to consider depending on the work they do as well as the methods they use to do the work.  Reading the MA RRP rule would help renovators working under the EPA RRP rule identify many of the related OSHA considerations.

Here is EPA's response to the question at the beginning of this post:

"EPA would like to clarify the requirements for personal protective equipment.  The Occupational Safety and Health Administration (OSHA) has requirements for personal protective equipment, EPA does not.  For many years, EPA has recommended the use of personal protective equipment as a way to protect workers and to help ensure that leaded dust and debris does not leave renovation or abatement work sites.  EPA recommends that renovators make use of the minimum respiratory protection recommended by the National Institute of Occupational Safety and Health (NIOSH) for environments where lead is present, but respiratory protection is not required by the EPA regulations.  In addition, disposable clothing, if removed and disposed of before the workers leave the work site, can provide additional protection for workers' families by ensuring that no leaded dust or debris is carried home on worker clothing.  However, EPA does not require this and allows renovators to use other methods to ensure that dust and debris does not leave the work area, including the HEPA vacuuming of clothing, tools, and other items before they leave the work area."  

In a June 3, 2010 Boston Globe articleby long time "Handyman on Call" Peter Hotton, Mr. Hotton graciously admitted he was not aware of the new EPA RRP rule when he had advised a homeowner regarding sanding of the exterior of his pre 1978 home before painting.  Fortunately for Mr. Hotton and his readers, Rick Cutler, production manager/project developer of Out of the Woods Construction & Cabinetry Inc.of Arlington took the time to inform Mr. Hotton about the law.

Hotton reports that in his message, Cutler suggested to Hutton:

 "... if you haven't read up on the new EPA RRP rule about lead and the updated dust containment procedures, please do before you give anymore inaccurate advice."

In his response to Cutler's message, Mr. Hotton wrote the following:

"That the handyman will do, with thanks to Rick Cutler, and I notice the regulations apply not only to renovation contractors and other professionals, but to homeowners as well."

Sorry Peter, I think you have it wrong again, or maybe need to clarify your message regarding the new EPA RRP Lead Paint Rule.  The EPA is clear that homeowners doing their own work are not required to follow the rule, only those who do it for compensation are subject to the rule.  I definitely am of the opinion this is not very wise, but, under the law, homeowners do have the right to create lead dust at their own homes in the course of renovating.  EPA suggests they use lead safe practices, but does not require they do so. Therefore, they can poison themselves, their own children and even their neighbors in the course of doing so. 

Statistics have shown, including EPA's own research, that more children are poisoned by lead due to renovations as a result of their parents doing the work than by professional remodelers. 

I hope this clarification will help homeowners seek to better understand the risks related to lead paint and how they choose to have work done at their homes, whether doing it themselves or hiring the work out. 

I posted a comment to Mr. Hottonon the Boston Globe's web site as well, to share the above information and my opinion about home owners doing their own work.  It is also my opinion that, unfortunately, Mr. Hotton has become just one more unfortunate example of someone who was unaware and then misinformed about the new RRP rule.  I suggest this is not his fault; he can't know everything and to his credit does provide an open forum for his readers to help clarify and verify the information he shares with his readers.  He also openly recognized the misinformation.  For that, kudos and keep setting a great example!

On the other hand, Mr. Hotton is just one more example of someone who was unaware of the new rule and the serious implications of lead poisoning potentially caused by renovations due to the lack of any public and industry awareness performed by the EPA.