A contractor has notified the designer that the existing paint in a space tests positive for lead. What is the correct course of action?

The discovery of lead-based paint requires specialized handling to comply with federal regulations and ensure the health and safety of workers and future occupants. The U.S. Environmental Protection Agency's (EPA) Lead Renovation, Repair and Painting (RRP) Rule (40 CFR Part 745) mandates that any work disturbing lead-based paint in pre-1978 homes and child-occupied facilities must be performed by an EPA-certified firm using certified renovators. These professionals are trained in lead-safe work practices to contain dust and debris, minimizing the risk of lead exposure. Therefore, engaging a professional contractor specifically licensed and certified for lead-paint abatement is the only correct and legally compliant course of action.

A. The lead paint should be encapsulated with oil-based paint

Encapsulation is a valid abatement method, but it requires specific encapsulant coatings, not standard paint, and must be performed by certified professionals.

B. The designer should notify the Environmental Protection Agency (EPA)

The primary responsibility for regulatory compliance and notification lies with the property owner and the certified abatement contractor performing the work, not the designer.

D. A custodian should vacuum with a high-efficiency particulate air (HEPA) filter vacuum

While HEPA vacuums are required for cleanup, this task must be performed by a trained and certified abatement worker as part of a comprehensive abatement plan, not a custodian.

1. U.S. Environmental Protection Agency (EPA). Lead Renovation

Repair and Painting Program Rules. Code of Federal Regulations

Title 40

Part 745

Subpart E ("Residential Property Renovation"). Section 745.81(a)(2)(ii) explicitly requires that "all renovations must be performed by certified renovators."

2. U.S. Environmental Protection Agency (EPA). (2011). Steps to LEAD SAFE Renovation

Repair and Painting. Document EPA-740-K-11-001. Page 5 states

"Renovation firms must be certified by EPA (or an EPA-authorized state program)."

3. Piotrowski

C. M. (2017). Professional Practice for Interior Designers (6th ed.). John Wiley & Sons. In discussions on hazardous materials (Chapter 15)

the text emphasizes the designer's responsibility to advise the client to hire specialized consultants and contractors for abatement

as this work is outside the designer's expertise and requires specific certification.

4. University of Minnesota Extension. Lead-Based Paint. Retrieved from extension.umn.edu. The publication clarifies

"Federal law requires contractors that disturb painted surfaces in homes

child care facilities and schools built before 1978 to be certified and follow specific work practices to prevent lead contamination." This reinforces that specialized

certified contractors are mandatory.