Does my water contain lead?

The water crisis in Flint, MI, has spurred many inquiries about lead in tap water. If you’re curious to know about what can be done about lead in your drinking water, have a look at this FAQ.

What caused the water crisis in Flint?

We’re going to leave the politics at the door here and just focus on the facts, and keep in mind I’m writing very generally here. For up-to-date facts about this crisis, check out the news sources in Michigan.

So here’s what happened: In 2015 officials in the City of Flint decided to switch the source of the city’s drinking water from Detroit to the Flint River. When the switch was made, though, officials neglected to update the water’s treatment regimen. (Unless water is treated with certain chemicals, it will cause plumbing corrosion. The chemical makeup of each water source is always a little different, so if the source is switched the treatment must be altered to match so plumbing will not corrode.) Without the updated treatment procedures, water from the Flint River caused increased corrosion of the city’s pipes. The effects of this fact were made worse since Flint also has a very old and outdated plumbing infrastructure including thousands of water service lines made of lead. The service line is what brings your water from the city’s water main into your home. So the mis-treated water was causing increased corrosion of thousands of lead-based service lines, which resulted in higher concentrations (and discoloration) of lead in the drinking water, which later caused Flint’s citizens to ingest more toxic lead.

The tragedy was made worse by the fact that children, due to their younger development compared with adults, have increased risk of lead poisoning when lead exposure goes up. Children lack a blood-brain barrier, which is a membrane on the back of your neck that is capable of filtering some lead before it reaches the brains of adults.

Do I have lead pipes?

City of Madison lead service line map

City of Madison lead service line map

There are three places there could be lead plumbing affecting your home’s water supply. The first is the service line, which is under the control of your local water utility. This section of pipe is located on the city’s property and brings water from the utility’s water main onto your property. The second place there could be lead plumbing is the section of the service line within your property. Ask your water utility to check records on whether either of those sections is made from lead plumbing. In Madison, you can email Joseph Grande at JGrande@madisonwater.org. If you live outside Madison, contact your local water utility. The last place is inside your home. Depending on construction practices during the time of your home’s construction, it might contain lead plumbing. The water utility will only know about the makeup of the water main and service lines; the utility will not have information about whether your home contains lead plumbing.

For Madison residents, you might read this article from the city’s water utility detailing an ambitious plan begun in 2000 to replace the city’s lead service lines. Prior to 1928, the city had used lead service lines in this areas shown in the map at right.

Can you check if my home has lead plumbing?

Yes. During a lead inspection or risk assessment we can take a look at your pipes to check if they contain lead. Keep in mind that not all the plumbing in your home will be accessible.

Can you test my water for lead?

Testudo can help with that for a fee. When a sampling date is set, let the tap sit dormant for at least 8 hours prior (the longer the better). That way the sample collected will be a kind of worst-case-scenario—the sample should represent the maximum amount of lead exposure that could occur if there is 1) lead in your water supply or 2) lead in your home’s plumbing.

Lead in Little People Toys Confirmed

There was the colorful parking garage with that nifty gas pump near the exit, the barn tote complete with silo, tractor, fencing and animals, the airport terminal COMPLETE WITH A FREAKING AIRPLANE!? If any of these items rings a bell, you—like your author—undoubtedly had a childhood replete with the Little People toys made by the Fisher Price company.

Watch out—there could be lead in that plastic airport!

Watch out—there could be lead in that plastic airport!

So much variety, so much color and so much fun! Unfortunately, researchers at St. Ambrose University in Davenport, Iowa, published research in the most recent Journal of Environmental Health showing that non-vinyl toys—including Little People and also Barbie dolls—from the ’70s and ’80s sometimes contain lead in excess of 1,000 ppm! In case you don’t really know what to make of that figure, 1,000 ppm is 10 times greater than the present allowable lead level in the United States.

Whenever I surprise someone by telling them product _______ (fill in the blank) contains lead (like paint, cosmetics, tile glazing, e.g.), the next question I usually get is, “Why’d they add lead to ______?” Invariably, my answer is always, “For better durability and color.” So it’s no surprise that the researchers, including Gillian Zaharias Miller and Zoe E. Harris, found, “The metals are almost certainly colorants or pigments. Lead chromate, also known as chrome yellow, was a standard plastic colorant in the era in which these toys were made. Lead sulfate and lead oxide were mixed with the chromate in varying amounts to produce a color palette from light yellow to red.” Ahh, those colors …

So why is this a problem? Simply put: There’s no safe level of lead in a child’s body. Furthermore, there’s no safe level of lead in an adult’s body, either. In their article, the researchers dutifully remind readers that “even very low amounts in a child’s body are linked to reduced intelligence.”

So, we’re sorry to rain on your vintage toy parade, but maybe you could put those toys in a nice display case?

Lead in Tile? Yes, There Is!

“There’s lead in tile?”

We get this question quite a bit at Testudo LLC, and the answer is an emphatic “Yes!”

Still, it’s a question that requires a little explaining. When we talk about ceramic tile, the lead we’re concerned about isn’t located in the tile itself—actually, the lead is located in the protective glazing overtop the tile.

Manufacturers put the lead in the glazing since it increased the tile’s color and durability. Firing during the manufacturing process fused the lead and the glazing, which made the tiles safe to handle, install and live with in a home. As a result, when homeowners (or contractors) go about remodeling tile surfaces there is a big opportunity for lead exposure if the tiles are chipped, cracked or shattered. Just like lead in paint, when these surfaces degrade and are disturbed, they could leave behind a microscopic layer of hazardous lead dust. And if the exposure is bad enough it could lead to lead poisoning.

The Ceramic Tile Institute of America provided a great write up on this topic in 2000 with author Judson Bryant. The article is extremely thorough; however, some of the figures he uses are out of date simply due to regulatory updates (e.g., HUD’s outdated lead dust hazard figures are listed). (You can download a PDF of the Institute’s article right here.)

 

Remodeling Lead in Tile

So what’s a contractor to do when faced with the prospect of remodeling ceramic tile? The answer is simple: Treat it exactly like you would lead-based paint. That means following the state of Wisconsin’s Lead Safe Renovator regulation, as well as OSHA’s Lead in Construction Standard. And if you want to save yourself some time and money in complying with the Lead Safe Renovator rule, you could have Testudo come to your job site and test the tile with our XRF analyzer. If the result is negative then you’ve proved you’re not disturbing lead and, therefore, don’t need to follow the work practices outlined in the Lead Safe Renovator rule.

If you have a hankering to discuss lead in tile even more, please don’t hesitate to give us a call at (608) 205-8025.

Lead Safe Renovator Training for Green Bay, Appleton & Oshkosh

Madison, WI-based Testudo LLC is an accredited training provider, offering training for the EPA's Renovation, Repair & Painting (RRP) rule, which in Wisconsin is known as the Lead Safe Renovator rule.Testudo LLC is wicked pumped to bring our trusted Lead Safe Renovator-Refresher education classes to the Fox Valley area in 2015! That’s right remodelers in Green Bay, Appleton or Oshkosh—we’re coming to your neighborhood.

Completing this 4-hour Lead Safe Renovator-Refresher course will earn students 4 credits toward their Dwelling Contractor Qualifier, Master Plumber, or Master Electrician licenses from WI’s Department of Safety & Professional Services, as well as CEUs from the National Association of the Remodeling Industry (NARI). What’s more, this course satisfies training requirements for the Lead Safe Housing Rule from the U.S. Dept. of Housing & Urban Development (HUD).

We’ll be holding these courses in Appleton, WI, at the Country Inn & Suites. Do yourself a favor and sign up online right now—space is always limited at these courses! Just click the date that works best for you and you’ll be taken to our e-commerce website.

Lead Safe Renovator-Refresher Dates

March 5

June 11

Sept. 10

Dec. 10

Not sure whether you’re eligible for the class? Be sure to read our big eligibility guide. Want to read about how you can potentially save hundreds of dollars completing your lead-safe jobs? Read our post about Testudo’s lead paint testing services. And don’t forget—if you have questions just give us a call at (608) 205-8025.

RRP Ranking Puts Wisconsin at No. 3

The Lead Safe Renovator program in Wisconsin ranks 3rd in the nation for implementing the Environmental Protection Agency’s (EPA) Renovation, Repair and Painting (RRP) rule, according to researchers in the Geography Department at Boston University.

Lead program aspects highlighted as being the most important to lead experts interviewed included 1) informing the regulated community of the Lead Safe Renovator rule and liabilities for violating it 2) informing the regulated community on opportunities to become certified, and 3) educating stakeholders—like tenants and landlords—on the rule’s requirements. The state of Wisconsin’s Department of Health Services (DHS), which promulgated the Lead Safe Renovator rule and enforces it, has addressed all of these items, for example.

The experts recommended a number of ways in which governing bodies, including the state of Wisconsin, could improve their lead-safe programs. These included: implementing a reporting mechanism in the building permit process for pre-78 housing, requiring clearance testing for ending jobs (which was discussed in 2010 but ultimately declined), and increasing outreach to daycares and schools.

The research was completed as part of Boston University’s Regulated Community Compliance Project, which receives funding from the EPA. The 2014 survey received input from 49 lead-based paint professionals throughout the U.S., including folks with expertise on state policy, public health, childhood lead poisoning and lead safety. There was just 1 remodeling contractor who participated in the survey. The two states ranked better than Wisconsin were Oregon and Connecticut.

So what’s our take? First, It’s great to see policy researchers taking an interest in the EPA’s RRP rule. The only way the Lead Safe Renovator program can be improved in the Badger state is by gathering feedback from the regulated community. Obviously, it’s too bad the survey administrators couldn’t manage to contact more contractors and get them to participate in the survey. During our Lead Safe Renovator classes there’s a lot of discussion on the rule’s effectiveness, but that’s not really the most constructive venue for getting feedback to DHS. The best way is to reach out to them personally: Go ahead and call (608) 261-6876 or email dhsasbestoslead@wisconsin.gov.

Save Time & Money With Lead Testing

Would you like to save 32 man-hours on your next lead paint remodeling job? If you’re concerned about things like profits and customer service, odds are you answered with a, “Hell yeah!” So how do you do it? The short answer is: lead testing.

Without question, the EPA’s Renovation, Repair and Painting (RRP) rule increased the cost of remodeling pre-1978 homes. To keep job sites cleaner and healthier contractors use more materials and man-hours. But if you can prove beforehand that the components you’ll renovate are not coated in lead-based paint, you can disregard the RRP rule’s work requirements and save those man-hours for profitable work.

Let’s look at an example from a gut and remodel at a Madison, Wis., home built in 1961. Testudo conducted a lead inspection prior to the demolition work and measured the level of lead-based paint on 157 components slated for demo (walls, windows, doors, etc.). In the end we reported to our client that all the lead testing results were negative.

During a follow up discussion, the contractor told us he saved roughly 32 man-hours on the interior gut work since the lead-safe work practices were not required. Had the contractor skipped testing and just assumed the job would disturb lead-based paint, he would have been required to perform roughly 6 lead-safe containment set-ups, perform lead-safe work in those six rooms, thoroughly clean all those rooms, have a certified renovator check that they were cleaned properly, and finally gather all his job records for a post-renovation report. That’s a significant chunk of time!

You could say this contractor was able to get paid for this job 32 man-hours sooner. Or that he saved 32 hours of paid wages to his employees. Or you could say he got to the next job 32 man-hours sooner. However you look at it, this contractor made the right choice.

Enforcement of WI’s Lead Safe Renovator Rule

When we go out and teach the Lead Safe Renovator class throughout Wisconsin, some of the most frequent questions we get are about enforcement—who does it, how many inspectors are there, how much are the fines, how are the authorities finding out about non-compliant job sites? So, let’s get to work answering all those questions and more!

Wisconsin's Department of Health Services is responsible for enforcement and administration of the Lead Safe Renovator rule for remodeling pre-78 homes and child-occupied facilities.

WI Department of Health Services

The only Lead Safe Renovator authority in the state of Wisconsin you need to worry about is the Department of Health Services (DHS). That department is the be all and end all of renovating (or abating) lead (and asbestos) in Wisconsin. It promulgates regulations, administers certifications, collects fees, inspects job sites, levies fines, etc. If you’re doing lead-safe work in Wisconsin, you’d be well served in getting to know the staff in the Lead & Asbestos unit—they’re good people to work with.

In my view, enforcement of the Lead Safe Renovator rule has been incremental. Back in 2010 DHS was focusing on getting remodelers to go through the 8-hour Lead Safe Renovator-Initial class and then getting companies certified. Well, time has passed and today DHS is enforcing much more than just certifications.

Enforcement Data

Today DHS is enforcing the full spectrum of the Lead Safe Renovator rule. According to department records, in 2013 DHS took enforcement actions against contractors and property managers for:

  • certification (for both individuals and companies)
  • pre-renovation education (the act of handing over “Renovate Right“)
  • to setting up containment and containing all dust and debris
  • following the prohibited practices
  • controlling the work area (by using warning signs and perimeter markings)
  • cleaning (for exterior jobs this means cleaning every day).

Here are some other facts and figures of notes: Currently, the minimum fine for a single Lead Safe Renovator violation is $100 and the maximum amount is $1,000. In 2013, according to a DHS presentation on the topic, it conducted 900 inspections on Lead Safe Renovator job sites. I do not know how many of those inspections resulted in fines; however, I do know that the average fine totaled $1,300.

2 Big Fish

The final tally on Lead Safe Renovator fines from DHS does not rival anything levied by the EPA as of late (see:  “Corporate-wide Settlement with Lowe’s Protects Public from Lead Pollution During Home Renovations“). However, there were two companies in 2013 fined far in excess of $1,300.

The first company, a window installation firm, was fined a total of $14,104 for using uncertified subcontractors on multiple projects. The second incidence involved a company that conducted 33 renovation projects on pre-78 housing or child-occupied facilities after its certification was revoked; this firm was fined $7,425.

Going Forward

So what’s the takeaway? It’s obvious that Lead Safe Renovator enforcement is happening. DHS is receiving complaints related to the Lead Safe Renovator rule—from homeowners and professional contractors—and acting on them.

If you’re not certified—get certified. Sign up for the initial 8-hour Lead Safe Renovator class today, or contact us about holding a class in your area. And if you are certified, keep in mind you’re required to take 4-hour refresher education every 4 years, and we can assist you with that, as well. Last, on this topic I always recommend reaching out to DHS with specific enforcement or compliance issues. The folks who work in that department are truly helpful, and they’re very responsive.

The Giganti-Guide to Lead Safe Renovator-Refresher Course Eligibility

This is Testudo LLC’s gigantic, handy-dandy guide for Wisconsin remodeling contractors and property managers to help determine Lead Safe Renovator – Refresher course eligibility. (And if you want to take this guide with you to show your buddies, download and print this beautiful PDF version.)

Welcome, 2014! For thousands of contractors throughout Wisconsin, it’s time to take mandatory 4-hour refresher education in order to remain in compliance with the state’s Lead Safe Renovator (LSR) rule. Here at Testudo, we’ve educated thousands of contractors on Wisconsin’s Lead Safe Renovation rule to date, and we’re excited to continue helping contractors with their refresher education.

Trouble is, some contractors out there are signing up for the Refresher class when they are actually ineligible for it. But by following this guide you’ll learn when you’ll be eligible in the future, or you may learn you’re eligible right now to take a refresher class.

First Things First

First, some ground rules on LSR education. If you’re remodeling pre-78 homes and disturbing painted surfaces in the process, you’re required to take an initial 8-hour LSR class, apply for and maintain an individual certification from DHS (and ensure you’re working for a lead-certified company), and then complete 4-hour refresher education every four years.

DHS realizes we all lead busy lives, so it gives individuals a two-year window to complete refresher education. Thing is, that two-year window begins two years after the date of your initial 8-hour class. For example, if you took your 8-hour class on April 22, 2010, the earliest day you’d be eligible to complete your refresher education would be April 23, 2012. And you would need to have your refresher education completed by April 22, 2014, to ensure no gaps in your LSR compliance.

Following are the most important questions we’d like to ask in order to determine your eligibility.

Question 1: Did you get your blue card?

If your answer is yes, jump ahead to Question 2! If your answer is no, we have one more question for you: Are you a plumber, HVAC installer or sprinkler system installer? If yes, jump ahead to Question 3! If no, continue reading this Question 1 section.

If you never received a “blue card” from DHS after you took your initial 8-hour class—cue the dramatic music here—you are not eligible to take the 4-hour refresher class. (What’s more, you’re out of compliance with the LSR rule altogether if you’ve kept on remodeling pre-78 homes after your initial class … wah, wah. But that’s a discussion for a different time.)

Our next question for you, Mr. or Mrs. No Blue Card, is how long has it been since you took your initial class? If it’s been less than two years, very quickly go on over to the DHS’ website and apply for your initial LSR certification. After that’s completed and paid, you should receive a blue card in the mail. Moving forward, you’ll just have to ensure you take your 4-hour refresher within four years of when you took your initial 8-hour class.

However, if it’s been more than two years since you took your initial class and you don’t have a blue card, DHS requires you to re-take the 8-hour class in order for you to obtain LSR certification. The thinking is that, if you never applied for certification, you haven’t been doing pre-78 jobs and haven’t needed knowledge of the LSR rule, so it is most likely not fresh in your mind. Hence, you’re required to re-take the full 8-hour class. Another wah, wah …

At this point, you might be wondering why on Earth the blue card is so important!? Well, it’s actually physical proof you’re required to keep on your person during pre-78 remodeling jobs that you would show DHS if they entered your job site to conduct a compliance inspection. So, yeah, it’s pretty darn important.

Question 2: You have a blue card, but when does it say your training’s due by?

There are a fA sample Wis. DHS blue card for Lead Safe Renovator contractors, which helps contractors determine refresher course eligibilityew important elements on the oft-cited blue card. There’s your picture, vitals like a b-day, height, weight and LSR number, and also two other dates: an expiration date and a “training due by” date. The expiration date sits between your LSR number and birth date. (See the example image, and then immediately please excuse its blurriness.) This is the date on which your individual certification is set to expire—and if you let your certification lapse you’ll be non-compliant. To keep up-to-date here you need to renew your individual LSR certification every two years by submitting new paperwork and a fee to DHS.

The other important date is the “training due by” date, indicated in the example above with a big, red arrow. This is the deadline by which you must take 4-hour refresher education every four years to keep a valid LSR certification. Again, you actually have a two-year window prior to this date during which you can take an accredited 4-hour refresher class, like those offered by Testudo LLC.

Question 3: Are you a plumber or HVAC installer?

So we’ve established that you are, in fact, a plumber, or HVAC installer or fire sprinkler installer. A Wisconsin Department of Commerce-certified plumber, HVAC or fire sprinkler system installer/servicer working within the scope of his or her Commerce certification is not required to be separately certified by DHS. Therefore, you’re not required to carry a blue card from DHS, and you’re not required to submit an individual certification application to DHS after taking the initial 8-hour LSR class.

That said, Department of Commerce-certified plumbers and HVAC installers are still required to follow the LSR rule when working in pre-78 housing. Plus, you’re still required to take LSR refresher training every four years (and you still have to take refresher training within the two-year window we discussed in the First Things First section above).

However, plumbers and HVAC installers should also keep this in mind: A Commerce-certified plumber, HVAC or fire sprinkler system installer/servicer who conducts renovation work outside the scope of his or her Commerce certification (such as an HVAC installer who also paints houses) is required to comply with the full individual and company certification requirements of the LSR rule. I.e., you would also need to apply to DHS for a LSR certification if you do remodeling work for compensation outside of your usual HVAC and plumbing scope of work.

If you’re a plumber or HVAC installer and you’re still confused, you might want to take a look at this fact sheet, which was prepared by DHS.

Question 4: Still need help? Give us a call!

Still have questions about whether you’re eligible for LSR refresher education? Go ahead and give Testudo a call. We’d be glad to help you better understand this process.

However, it could be a better idea to call DHS at (608) 261-6876. Training companies like Testudo do not have access to all the records DHS maintains, so it could be easier for you to call DHS and get the word straight from them.

Question 5: If you’re eligible, why not sign up today?

So you’ve suffered through nearly 1,000 words discussing all sorts of legalese about the LSR rule, and you’ve determined that you, or your workers, are 100% eligible for the 4-hour LSR refresher class. Why not take a major load off your mind and sign them up for a class right now? We have plenty of dates to fit your schedule—we offer morning classes, night classes, Saturday classes and noon-start classes. And after you’re all signed up, you can rest assured you’ve committed to teaming with Wisconsin’s premier LSR education provider—Testudo LLC.