The AAF is Working For You! The Florida Building Commission at its April meeting upheld the AAF position that electrical outlets are NOT required in Category I, II, or III Sunrooms. The Commission held the second reading on the Declaratory Statement filed by Joe Belcher on the behalf of AAF. The Declaratory Statement sought to resolve a conflict between two standards adopted by the code, AAMA 2100, Voluntary Specifications for Sunrooms, or NFPA 70, National Electrical Code. The Commission agreed with AAF, by unanimous vote, that the AAMA Standard was specific to sunrooms and therefore prevails. CLICK HERE for the draft order which is the final version once signed by the Chairman of the Florida Building Commission. EPA Lead-Based Paint Renovation, Repair, and Painting Program By Joe Belcher, Code Consultant The EPA Lead-Based Paint Renovation, Repair, and Painting Program (RRP) takes effect nationally April 22, 2010. The program is a federal regulatory program affecting contractors, property managers, workers, and others whose work involves disturbing painted surfaces. The program applies to residential houses, apartments, and child-occupied facilities such as schools and day-care centers. The program applies solely to buildings built prior to 1978. All paint prior to 1978 is assumed to be lead-based paint. The program includes pre-renovation education requirements as well as training, certification, and work practice requirements. Training, certification, and work practice requirements become effective April 22, 2010. As of that date “firms are required to be certified, their employees must be trained in the use of lead-safe work practices, and lead-safe work practices that minimize occupants’ exposure to lead hazards must be followed. Renovation is broadly defined as any activity that disturbs painted surfaces and includes most repair, remodeling, and maintenance activities, including window replacement. In general, any activity that disturbs paint in pre-1978 housing and child-occupied facilities, including: • Remodeling and repair/maintenance • Electrical work • Plumbing • Painting • Carpentry • Window replacement ” [1] Pre-renovation education requirements refer to items to be completed before the renovation begins including: “Pre-renovation education requirements - Effective now. • In housing, you must: • Distribute EPA’s lead pamphlet to the owner and occupants before renovation starts. • In a child-occupied facility, you must: • Distribute the lead pamphlet to the owner of the building or an adult representative of the child-occupied facility before the renovation starts. • For work in common areas of multi-family housing or child-occupied facilities, you must: • Distribute renovation notices to tenants or parents/guardians of the children attending the child-occupied facility. Or you must post informational signs about the renovation or repair job. • Informational signs must: · Be posted where they will be seen; · Describe the nature, locations, and dates of the renovation; and · Be accompanied by the lead pamphlet or by information on how parents and guardians can get a free copy (see page 31 for information on obtaining copies). • Obtain confirmation of receipt of the lead pamphlet (see page 23) from the owner, adult representative, or occupants (as applicable), or a certificate of mailing from the post office. • Retain records for three years. • Note: Pre-renovation education requirements do not apply to emergency renovations. Emergency renovations include interim controls performed in response to a resident child with an elevated blood-lead level. “[2] The impact on companies and contractors installing impact resistant windows is apparent; firms and renovators (i.e. contractors and workers) will require the EPA certification. The certification consists of attending an eight hour course conducted by an EPA certified provider. For the installation of exterior devices such as shutters or panels, or for other work on existing buildings, the application is not clearly stated. The contractor will need to consider whether or not her or his work is disturbing more than 20 square feet of the exterior of the building. It would appear in most cases the installation of hurricane protection would exceed 20 square feet and the requirements would apply. The rule contains exclusions including minor repair and maintenance activities that disturb 6 square feet or less of paint per room inside, or 20 square feet or less on the exterior of a home or building. Regarding windows, the rule contains a note specifically stating window replacement and projects involving demolition or prohibited practices are not considered minor repair and maintenance activities. Effective April 22, 2010, the following training, certification, and work practice requirements must be met: • “Firms must be certified. • Renovators must be trained. • Lead-safe work practices must be followed. Examples of these practices include: • Work-area containment to prevent dust and debris from leaving the work area. • Prohibition of certain work practices like open-flame burning and the use of power tools without HEPA exhaust control. • Thorough clean up followed by a verification procedure to minimize exposure to lead-based paint hazards.”[3] The responsibilities of the certified firm include: “Firms performing renovations must ensure that: 1. All individuals performing activities that disturb painted surfaces on behalf of the firm be either certified renovators or have been trained by a certified renovator. 2. A certified renovator is assigned to each renovation and performs all of the certified renovator responsibilities. 3. 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 (see the flowchart on page 9 for details about the work practice standards). 4. Pre-renovation education requirements of the Lead-Based Paint Renovation, Repair, and painting Program are performed. 5. The program’s recordkeeping requirements are met. “[4] The responsibilities of the certified renovator include: “Certified renovators are responsible for ensuring overall compliance with the Lead-Based Paint Renovation, Repair, and Painting Program’s requirements for lead-safe work practices at renovations they are assigned. A certified renovator (see the flowchart on page 9 for details about the work practice standards): 1. Must use a test kit acceptable to EPA, when requested by the party contracting for renovation services, to determine whether components to be affected by the renovation contain lead-based paint (EPA will announce which test kits are acceptable prior to April 2010. Please check our Web site at www.epa.gov/ lead). 2. Must provide on-the-job training to workers on the work practices they will be using in performing their assigned tasks. 3. Must be physically present at the work site when warning signs are posted, while the work-area containment is being established, and while the work-area cleaning is performed. 4. Must regularly direct work being performed by other individuals to ensure that the work practices are being followed, including maintaining the integrity of the containment barriers and ensuring that dust or debris does not spread beyond the work area. 5. Must be available, either on-site or by telephone, at all times renovations are being conducted. 6. Must perform project cleaning verification. 7. Must have with them at the work site copies of their initial course completion certificate and their most recent refresher course completion certificate. 8. Must prepare required records.”[5] The rule also states the training, certification, and work practice requirements do not apply where the firm obtains a signed statement from the building owner attesting to the following: • “The renovation will occur in the owner’s residence; • No child under age 6 resides there; • No woman who is pregnant resides there; • The housing is not a child-occupied facility; and • The owner acknowledges that the renovation firm will not be required to use the work practices contained in the rule.”[6] One final issue of interest is the EPA definition of child-occupied facility: ” … Under this rule, a child-occupied facility is a building, or a portion of a building, constructed prior to 1978, visited regularly by the same child, under 6 years of age, on at least two different days within any week (Sunday through Saturday period), provided that each day’s visit lasts at least 3 hours and the combined weekly visits last at least 6 hours, and the combined annual visits last at least 60 hours. Child-occupied facilities may be located in public or commercial buildings or in target housing. …”[7] The penalty for violation of the rule may be a fine up to $32,000.00 per day per violation. While the EPA has policies to make certain penalties are calculated fairly, there is considerable authority granted the agency to ensue enforcement. There is no known plan for enforcement inspections; however, the EPA is committed to saving children from lead-based paint. The contractor or firm involved in the work will have to decide if they are willing to risk the penalty for doing such work in violation of the rule as opposed to spending the time to become certified and do the work in accordance with the rules. [1] Small Entity Compliance Guide to Renovate Right — EPA’s Lead-Based Paint Renovation, Repair, and Painting Program, United States Environmental Protection Agency Office of Pollution Prevention and Toxics, EPA- 740-F-08-003, December 2008, p.2. [1] Ibid, p.3. [1] Ibid. [1] Ibid, p.5. [1] Ibid. [1] Ibid, p.3. [1] 40 CFR Part 745 [EPA–HQ–OPPT–2005–0049; FRL–8355–7] RIN 2070–AC83 Lead; Renovation, Repair, and Painting Program AGENCY: Environmental Protection Agency (EPA). ACTION: Final rule.
SPONSORED Glitch Cycle Building Code Modifications ~ 2007 FBC Each of the following code modifications successfully negotiated the FBC Structural Technical Advisory Committee (TAC) October 13 – 15, 2008) 2981: adds language in HVHZ section to permit the use of vinyl windbreaks 2987/2988: updates the 2007 Edition AAF Guide 3215: corrects language in 109.1.2 (residential) and 1609.1.2 (building); Protection of Openings 3220: Changes “either” to “both” in provision 2002.4 3232: eliminates solarium from the exceptions to 1626.1 3234: provides an 88% multiplier for screen design pressures when using 18/14 screen mesh (Table 2002.4) The full text of each modification listed above is available, see News & Events and click on the Code Change button on the left. Protect Your Credit - The Need to KnowIf any information is needed regarding Security Compliance for business owners or Merchant Service questions, please contact Lisa Beneduci, US Data Capture, 727-804-5218. STOP those Credit Card Offers (for free)!Recommended reading: “To Buy or Not To Buy” Visit: http://www.ftc.gov/bcp/edu/pubs/consumer/idtheft/idt05.shtm What is “HVHZ”? The High Velocity Hurricane Zone is defined in Florida law as Dade and Broward counties. The abbreviation is not related to any particular wind velocity but rather a geographic region and is a direct descendent and remnant of the “South Florida Building Code”. Prior to the development and implementation of the Florida Building Code (begun circa 1998), building jurisdictions of Florida could choose which building code to use in their own area. Dade and Broward counties had their own specific building code. During the development of the Florida Building Code, representatives from Dade and Broward lobbied the Florida Building Commission vigorously in defense of their specific provisions and won consideration of these provisions in the FBC. Many chapters of the code have particular HVHZ provisions, typically at the end of each chapter. Contractors (and designers) who may want to do projects in the HVHZ area should be cognizant of the differences and the impact of these area specific provisions. Moreover, within the HVHZ area, there are many different building department jurisdictions which do not necessarily interpret code provisions in a unified or homogenous fashion. Contractors and designers would be well-advised to learn code requirements in the region in which they intend to work (this admonition applies everywhere). FOR MEMBERS ONLY: The AAF logo is a proprietary registered service mark owned by the association. You members must be vigilant, because some non-members consider it so valuable that they are using it in their advertising without our consent. Keep in mind that non-members are not contributing to the sustenance of the association and they may not enhance our image or reputation. It is in our best interest to invite them to join the association or not to use our logo. If you observe advertising with our logo and suspect it is a non-member, please notify the AAF via email for instructions on how to proceed. | 
