Know what is in your environment

This is a cautionary warning to homeowners, renovators and contractors about heavy metals being found in tile and understanding the potential risks.  If tile is disturbed during renovation and dust is formed, you are creating a situation that may cause harm to you, your employees or the tenants of the property you are renovating.  Make certain to contain and clean up all dust created by disturbing tile.

On April 22, 2010 the EPAs Renovation Repair and Painting (RRP) Rule went into effect to address lead dust hazards created during renovation of properties older than 1978, this rule only applies to painted surfaces.  Tile is not considered a painted surface, but tile can possess lead and other harmful heavy metals.  If tile is disturbed during renovation, dust can be created that can be potentially harmful. 

Renovators and contractors should be advised to use lead safe work practices if they disturb tile, unless they know what the tile is made of. 

Recently I purchased tile from Home Depot and decided to use an X-Ray Fluorescence (XRF) Analyzer to look for heavy metals in the tile, I own and operate an environmental testing and software business, Essco Safety Check and am a certified HUD Lead Inspector and Risk Assessor.  Using an XRF analyzer I found lead and cadmium in brand new tiles sold today (June 2010).  One of the tiles showed lead over 3mg/cm2, the regulation limit for lead in paint within the RRP Rule is 1mg/cm2, the other showed cadmium over 600 parts per million, there is no regulation for cadmium in the RRP rule.

Tile found with lead and cadmium

In both cases (in the lead and cadmium tile) I suspect that the heavy metals are in the glaze or the coloring of the tile and not the ceramic.  According to the HUD Guidelines, Chapter 7, Lead-Based Paint is defined as;

Any paint, varnish, shellac, or other coating that contains lead equal to or in excess of 1.0mg/cm2 as measured by an x-ray fluorescence analyzer or laboratory analysis or 0.5 percent by weight by laboratory analysis.

Tile is not considered a painted surface and therefore does not meet the qualifications of lead-based paint, even though it is glazed or painted.

In May 2010 I was contacted by a colleague who is a certified lead inspector, EPA approved renovator and general contractor for 25 years.  While performing an inspection for RRP compliance, he used his XRF analyzer on some floor tile that he was going to replace.  The test results from the XRF analyzer showed lead over 5mg/cm2, he called me to ask what to do? 

My first question was would he disturb the tile during his renovation project, and if so, would dust be created?  He said yes.  I suggested that he use lead safe work practices, but he wanted to know the specifics of the law, so I contacted another colleague from the EPAs Region 10 to ask for help finding the specific regulation with the RRP rule and tile.  She searched on the EPAs website under the RRP FAQs and typed in “tile”, but not one response was found in the frequently asked questions page by the EPA.  What is a contractor suppose to do when they disturb tile?

The approved testing method for the average contractor who is not a lead inspector or risk assessor and who does not have access to an XRF analyzer or inspector with such an instrument is to use approved testing “swab” kits.  These kits will not penetrate tile like a drywall painted wall.  In a sample case with tile I purchased from Home Depot, I used an XRF analyzer on the tile and found lead over the 1.0mg/cm2 but when I tested it with the approved lead “swab” testing kits, no lead was found.  How is this protecting the homeowners, renovators or contractors working on their own renovation projects?  What if there are children that live at this work site?

As I have mentioned, the RRP Rule only applies to homes built before 1978, but I was able to find brand new tiles that have lead and cadmium.  To my knowledge and having several discussions with Washington State Officials and EPA personal, there is currently no regulation regarding heavy metals in tile.  Since tile purchased today can contain heavy metals like lead, it may be found in homes newer than 1978.

Homeowners, renovators and contractors need to be aware that tile purchased today, or tile found in homes (of any age) may contain harmful heavy metals.  If you disturb tile and create dust, you could be creating a potential hazard.  You should make sure you contain and clean up all dust created from disturbing tile.  This is only a cautionary warning; there is no regulatory authority behind this.  I wish only to share knowledge that I have obtained by operating my environmental testing and software business, Essco Safety Check.

Additionally, business owners and workers who disturb tile for installation in properties (i.e. bathroom and shower installation companies) should be aware of this and take precautions when doing preparation work and properly contain and cleanup any dust created.  Don’t forget to consider all OSHA regulations, if any lead is found on the property; during a renovation, remodeling or painting of any property.

I would advise using lead-safe work practices if you disturb tile and create any dust.  Or have your local certified lead inspector or risk assessor use their XRF analyzer to check if the tile you are about to disturb has any harmful heavy metals. 

Contact Bob Angeline Lead-Based Paint Assistant Manager at the Washington State Department of Commerce, at 360-725-2929 for questions about the RRP rule in Washington State or contact Seth Goldberg, Essco Safety Check at 425-749-4136 or info@essco-safetycheck.com if you have any questions or comments about this article.

Know what is in your environment and mitigate harm.

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