Contractor Training Requirements

The Environmental Protection Agency (EPA) was required to issue requirements for training of supervisors and workers dealing with lead abatement as part of Title X legislation. What resulted was development of an "EPA Model Curriculum," which training providors would need to follow.

States were given the option of instituting their own licensing/accreditation programs by 1999 or to follow Federal Guidelines. Maryland enacted training requirements in 1996 and contained in the Maryland Code of Regulations (COMAR) 26.16.01. This code defines categories and methods of accreditation for abatement workers and supervisors.

DETAIL A: TYPES OF ACCREDITATIONS

The Maryland system contains five classes, with details about what class of licensee can do what kind of work.

REMOVAL & DEMOLITION SUPERVISOR
Can provide oversight on residential lead paint abatement projects, including removal, demolition, maintenance and repainting.
MAINTENANCE & REPAINTING SUPERVISOR
Can only provide oversight on maintenance and repainting projects.
STRUCTURAL STEEL SUPERVISOR
Provides oversight on structural steel related projects only.
ABATEMENT WORKER
Allowed to work on building projects.
STRUCTURAL STEEL WORKER
Allowed to work on structural steel projects.

DETAIL B: TRAINING REQUIREMENTS
Initial training course
Refresher course every two years
License application
(Companies are also required to get a Lead Paint Abatement Services Contractor License. Single person operations are not required to get this license)
Fees range from $100-$125 (every two years)

 

DETAIL C: POINTS TO CONSIDER
The important point to consider with the training requirement is that it is for "abatement of lead" which technically includes:

Removal of lead paint
Removal of lead contaminated dust
Containment or encapsulation of lead paint
Replacement of lead painted surfaces or fixtures
Removal or covering of lead contaminated soil
Cleanup activities
Waste disposal

There is still a lot of question as to when work qualifies as abatement under the loose definition on the books. Current interpretations of the Maryland definition is if the "intent" of the work is to abate lead-based paint or hazards, then it is considered abatement.

Putting the Pieces Together

 

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