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Lead Training Confusing…Especially in New York.

New York is known as the North Korea of lead hazard control.  Most of us don’t even know what we’re missing when it comes to basics like standardized State-wide procedures for dealing with lead hazards in housing.

Housing and health professionals are particularly perplexed by disparities between Federal and local lead training and certification requirements.  This has gotten rather confusing since release of the EPA RRP, especially in places like New York City, where existing lead regulation already prescribed training for those involved in hazard control.

First, let’s lay out the basic differences between the Federal agencies requirements.  I started out a history major in college so I tend to look at things from a chronological perspective.  Also, I’m assuming that we’re talking about relevant situations here and won’t spend a lot of ink repeating “pre-1978” or “lead based paint” a million times.

In 1996, EPA set forth standards for lead hazard control professions, including those who perform evaluations (i.e. inspectors & risk assessors), abatement (i.e. workers and supervisors) and design (i.e. project designers).  Certification involves attending accredited training, applying to EPA and for the inspector, risk assessor and supervisor, taking a third party exam.  Firms must also be certified which is accomplished via application to EPA. Those conducting inspections, risk assessments or clearance must be inspector or risk assessor certified, those conducting abatement must be certified as workers or supervisors, and each project must have supervisor oversight.   That was obvious, I know. 

In 1999, HUD’s Lead Safe Housing Rule requires most of those involved in Federally-assisted housing activities that disturb lead based paint to attend an acceptable 8 hour “lead safe work practices” training course.  Those involved in housing rehabilitation projects where the hard cost of rehab exceeds $25,000 must be EPA certified firms using certified lead abatement personnel.  These practices are also generally adopted amongst communities and organizations receiving grant assistance from HUD’s Office of Healthy Homes & Lead Hazard Control.

In 2004, NYC implements Local Law 1 of 2004, which requires that landlords perform repairs to presumed  or known lead based paint using lead safe work practices with personnel who have completed the 8 hour lead safe work practice training consistent with aforementioned HUD LSHR requirements.  LL1 ‘04 further mandates that those conducting lead hazard control in response to a lead violation are EPA abatement certified. 

In 2010, the EPA Renovation, Repair and Painting (RRP) rule takes effect.  RRP mandates that firms conducting renovation in target housing or child occupied facilities obtain firm certification (in addition to the abatement firm certification) and that each firm identify a certified Renovator to take responsibility for compliance with the regulation.  Renovators are certified by attending accredited training.  Note that the Renovator gets certified by completing training and does not have apply to EPA.  Workers are not required to attend the aforementioned HUD lead safe work practices training.  Rather the Renovator is required to provide “non-certified worker” training, which seems to top out at 4 hours, max.  Lead safe work practices training satisfies the RRP non-certified worker training, btw.

Sooo… we’re looking at a situation where HUD funded housing organizations have worked to get their contractors (and their staff) qualified for lead safe work practices and/or abatement, and find themselves non-compliant for the Renovator certification and over compliant for the non-certified worker training.  Same situation in NYC, where the City has undertaken a huge effort to qualify thousand of contractors, workers and building professionals in lead safe work practices, but is now short on EPA qualified Renovators.

To truly satisfy Federal requirements for federally assisted housing a Contractor/Renovator would need to be certified as a Renovator and Supervisor (if conducting abatement) and send all workers to  8 hour lead safe work practices.  Likewise in NYC, except that the vast majority of landlords and contractors would be best served with the Renovators certification, with 8 hour lead safe work practices for their staff.  The City could actually drop the requirement for abatement qualifications for violations, since RRP addresses the concerns that lead to the City mandate  in the first place.  The exception might be elevated blood level situations, wherein EPA mandates abatement.

 Regulatory agencies tend to play leapfrog, whereby an agency, like HUD or NYCHPD for example, adopts standards in the absence of EPA requirements.  Once EPA implements their requirements, aspects of the HUD/HPD standards may be obsolete, although it’s understandable that HUD & NYC wouldn’t backtrack on elements of their rules that are more protective than say, the RRP.  That’s certainly the case for worker training, and clearance (although we’ve already discussed that!).  Bottom line is that HUD and NYC need to update and clarify their rules and requirements. 

 The upside of this process, beyond keeping constituents from breaking Federal and local laws, is a more streamlined process of qualifying individuals and firms who work in this important industry and a less Byzantine process by which housing organizations and property owners can obtain lead hazard control services.  It’s also important to note that the EPA collects application fees for individual evaluation and abatement certifications and for renovation and abatement firm certifications.  That conservatively  amounts to approximately $15,000,000 in fee revenue over every three year period, just for certifications.

 We’ve been encouraging New York State officials to take a look at this, in perhaps the same light as the State’s asbestos training program.  The State does an excellent job of ensuring that individuals are qualified, and that asbestos-related activities are performed in a manner that does not endanger workers, building occupants or the general public.  It’s certainly worth some thought, given the absence of enforcement at EPA for RRP violations in this State.  Take a look at this link from the Fiscal Times that discusses what happens to small businesses when rules aren’t enforced.

 This might not be the sexiest subject matter these days, but these adjustments are critical if we expect to reach our national desire to permanently reduce or eliminate lead poisoning.  It’s a process of refining the good work that’s been done to date and, when complete, ultimately contributes to everyone’s fiscal, social and environmental well-being. 

EPA finalized the changes to the Lead Renovation, Repair and Painting Rule 
Here is a quick summary on the changes that affect Renovators:
1.       Vertical containments (i.e. plastic sheeting) are required when working within 10 feet of property line. The hope is to avoid contaminating the neighbors space.
2.       HEPA shrouds or containment systems req'd on power equipment (ex. drills, sanders) at point of generation. These can often be purchased with the equipment or from and aftermarket distributor. The idea is attach a HEPA vac hose to the "head" of the equipment.
3.       Dust testing can be conducted in lieu of the Cleaning Verification. Testing makes sense for both the contractor, who will know that the work was completed without any lead dust residue, and the occupants, who can be confident that they're living in a lead safe environment. EEA offers the Dust Sampling Technician CertificationContact UNYSE about "do it yourself" lead wipe sampling kits.
4.       Paint chips can be collected to "rebut the presumption" of lead based paint instead of relying on the chemical test kits. UNYSE Labs provides National Lead Laboratory Approval Program (NLLAP) analysis of paint samples.
5.       Prior training (i.e. lead safe work practices, abatment worker/supervisor) can only be used to qualify for Renovator refresher training until Oct 4, 2011.   After that anyone who has completed LSWP or abatement training will have to attend the day long Renovator initial. Check our website for dates of refresher and initial Renovator training. 
Here's a couple new administrative requirements that don't impact Renovators directly but may be of interest as the process evolves, especially in New York.
1.       An EPA approved principal instructor must be present at all EPA accredited Renovator, Worker, Supervisor, Inspector and Risk Assessor courses. The hope here is to maintain the quality of the training. EEA has a full schedule of lead certification courses taught by principal instructors.
2.       States that operate lead programs must be at least as stringent as the EPA program. This includes fine amounts and violations. EPA's Enforcement Guidelines provides detail on the Federal level.
These changes and requirements take effect October 4th, 2011. We have already integrated discussion and hands-on dedicated to the changes.
We'll continue to update on changes as they occur. Let us know how things are going on the job.

EPA Balks on Lead Testing, Leaves Millions at Risk

Last Friday, July 15, 2011, the EPA refused to implement lead dust requirements in spite of a judicial legislative mandate to protect children from exposure to lead contamination.

Lobbyists representing the construction and home improvement industry claimed victory, and continued efforts to disembowel enforcement provisions of the existing Lead Renovation, Repair and Painting (RRP) rule. Toward that end, the US House of Representatives, under intense pressure from NAHB and other construction advocates, is poised to withhold funding for EPA to enforce standards designed to ensure that children and adults living in pre-1978 housing are not lead poisoning.  click here to read more
The ABCs of PCBs in Schools
It seems that school districts are beginning to wake up to the reality that PCB hazards are present in many schools built or renovated in the 60's and 70's. This is especially the case in New York City, where the Bloomberg Administration is caving to federal pressure by dedicating $708 million to a ten year plan to rid the city’s schools of PCBs.
PCBs are most often present in window adhesives and light fixture ballasts. PCB-containing caulk can contaminate surrounding surfaces if it is removed and discarded improperly. Any repair that will disturb old caulk (e.g. removing or replacing a window) should be done by trained workers. PCB-containing lighting ballasts that are damaged can leak onto surrounding surfaces or produce vapors in the air. 
The potential for health effects from PCBs, as with other chemicals, depend on how much, how often, and how long someone is exposed. Studies have shown behavioral and developmental problems among children whose mothers were exposed to large amounts of PCBs. Evidence is limited on PCBs and cancer in humans, but PCBs are classified as probable human carcinogens. Some studies of workers suggest that high-level exposure increases the risk of liver cancer. PCBs have been found to cause cancer and other health effects in laboratory animals. Scientists have looked at PCB exposure as a risk factor for developing disorders of the liver, thyroid, reproductive and immune systems.
In early 2010 the NYC Education Department accepted a Content Agreement with the US EPA to implement a DOE proposed "Remedial Investigation Work Plan". The Board has already addressed leaking ballasts and deteriorated caulk in numerous schools and will begin to eliminate light ballasts and caulks in conjunction with energy retrofits over the next decade. Be that as it may, the ten year time frame doesn't sit well with both EPA and the City Council, who have argued that the work should be completed in a shorter, five year period.
Contractors and those who make contact with or remediate PCBs must be trained under EPA's Hazardous Waste Operations (HazWoper) standard, which involves hazardous materials (HazMat) General Site Worker 40 hour certification training. EEA has scheduled additional "40 hr HazMat" sessions to keep up with demand among contractors working in the City schools.  
Check out the EEA E-library on this and other current environmental health remediation issues.




OSHA Releases New Residential Roofing Fall Protection Standard

Falls are the leading cause of death for workers engaged in residential construction. The “Fall Protection in Residential Construction” guidance document describes various methods that residential construction employers may be able to use to prevent fall-related injuries and fatalities at various points in the residential construction process.   Here is an excerpt from the new rule:

"Under 29 CFR 1926.501(b)(13), workers engaged in residential construction six (6) feet or more above lower levels must be protected by conventional fall protection (in other words, guardrail systems, safety net systems, or personal fall arrest systems) or other fall protection measures allowed elsewhere in 1926.501(b). Although the standard does not mention personal fall restraint systems, OSHA will accept a properly utilized fall restraint system in lieu of a personal fall arrest system when the restraint system is rigged in such a way that the worker cannot get to the fall hazard. If an employer can demonstrate that the fall protection required under 1926.501(b)(13) is infeasible or presents a greater hazard, it must instead implement a written fall protection plan meeting the requirements of 1926.502(k).

  Fall protection used to comply with 1926.501(b)(13), including guardrail systems, safety net systems, and personal fall arrest systems, must meet and be used in accordance with applicable requirements in 1926.502. Requirements for work performed on scaffolds, ladders, and aerial lifts are in Part 1926 – Subpart L, Subpart X, and 1926.453, respectively."
The effective date for the rule is June 16, 2011. OSHA has agreed to postpone enforcement until September 16, 2011.  Residential roofing contractors should consider using this extension to obtain the training and equipment necessary fo comply. 


Nanoparticles Generated by Kitchen Appliances are Major Contributors to Chronic Illnesses

By Jamson S. Lwebuga-Mukasa, MD, PhD.

The Green Kitchen Institute

Often building strategies designed to conserve energy result in homes and public buildings that contribute to unintended, adverse health effects that may account for a myriad of illnesses – particularly chronic illnesses such as asthma, chronic obstructive pulmonary disease (COPD) exacerbations, and pulmonary fibrosis. The burden of these chronic diseases contributes to high health costs and ill health. Particulates released during cooking can cause intense airway inflammation that also travels to many organs and may contribute to multi-organ diseases.

We administered a questionnaire to study participants who all indicated that they only turned on the stove exhaust fan when they were cooking food with a strong smell such as fish, or smelled smoke caused by burnt food. Many homes had kitchens with stoves that were not vented to the outside.

Particulates and gases in homes were measured using WolfPack (GrayWolf, CT) equipped with TG-25, GrayWolf particle counter and P-Trak (TSI). We measured concentrations of particulates and gases in the 23 kitchens at baseline, for 15 minutes, following turning on of gas or electrical stoves (without cooking any food) while the exhaust vents were off. Concentrations of particulates remained elevated for at least 3 hours after the stoves were switched off.

We found that in all cases nanoparticles were consistently elevated while concentrations of particulates 1 micrometer and higher were variable, concentrations of nanoparticles measuring 20 nm to 1 micrometer were consistently elevated to 250,000 to over 500,000 particles per cubic centimeter. These concentration levels could be reduced to 60% if a stove fan was turned on when the stove was turned on. Levels of particulates were reduced to 10% when an Austin air cleaner (Austin Air Systems) was used in conjunction with the hood exhausted to the outside.

In a study of seven cases conducted, we have found a reduction in reported symptoms, hospitalizations and emergency department visits of patient who had previous frequent health care utilization compared to when air filtration was implemented.

We conclude that improving ventilation and, when this is not possible, air filtration does reduce exposure to combustion related particulates and gases that contribute to airway inflammation. Greater attention needs to be applied to measures that reduce harmful exposures in the way we design and build homes and public buildings.

Visit the Green Kitchen Institute for more information.


National Green & Healthy Homes Initiative Comes to Buffalo

EEA participated in the Community Foundation of Buffalo "Green & Healthy Homes Initiative” (GHHI) planning retreat on May 12, 2011 with over 35 other organizations dedicated to healthy and sustainable housing .  Representatives from local health, housing, energy and philanthropic met with coordinators from a national consultant, the Coalition to Prevent Childhood Lead Poisoning, to establish relationships, create local policy and map out a strategy to complete 250 energy efficient, healthy and safe homes by December 2012.  

Buffalo was recently added to the prestigious list of GHHI communities.  12 other cities, including Baltimore, Chicago and Denver and two tribal lands have been designated GHHI for their continued efforts to create sustainable, healthy housing.     These GHHI sites will inform the national agenda by generating best practices and lessons learned in performing integrated green and healthy housing assessment and interventions.

The Green and Healthy Homes Initiative will advance "whole house" strategies for environmental health, safety and energy efficiency and will provide a practical roadmap for coordinating various funding streams in a more efficient and cost-effective manner. Key partners include the Council on Foundations, national and local foundations, the Federal Healthy Homes Work Group, HUD, CDC, the U.S. Environmental Protection Agency, the U.S. Department of Energy, and the 15 project sites.

EEA will begin working immediately with partner GHHI organizations to set the stage for program-specific activities that include outreach & enrollment , workforce development and assessment & intervention.  The Community Foundation of Buffalo (CFGB) will serve as the lead agency, and has pledged $2.1 million in funding provided by the Office of the NYS Attorney General to support ongoing local efforts. 

Check out our e-library <>  for additional information on the Green & Healthy Homes Initiative and CFGB.


Lead Musings

Here in NYC, the week's news about "Geronimo" has everyone recalling where they were on Sept 11, 2001.

 The EEA staff was busy training, and I recall interrupting and then updating our trainees all day. We didn't want to stop the courses for fear of violating training rules.

We then ended up having to delay lead hazard control training in Alaska until the airlines were back and running.  We decided to ship the demo XRFs instead of carrying them on...

The HUD subsidized housing regulations were just beginning to take hold and demand for risk assessors, inspector and lead hazard control training was on the rise. We were dealing with a lot of agencies, organizations and contractors who were struggling with the new requirements. 

Many were convinced that the HUD lead regs would be the end of subsidized housing. A similar lament to those who complained that asbestos regulations in the 80s and early 90s would cripple the building industry.

10 years later we're facing a similar challenge with the EPA Renovator Rules. Lots of naysayers complaining about the negative impact of positive steps to improve public environmental health.

This includes some in the US Senate, who directed comments to EPA in early April on the pending dust testing and clearance rules and the proposal to apply the RRP rule to public and commercial buildings. You can see the Senate comments and our response to the US Senator from NY, Kirsten Gillibrand, a member of the critical Committee on Environment and Public Works on our website library. Check it out and let your elected officials know how you feel.

Recent environmental health history tells us that the introduction of new rules can certainly create some inconveniences and can take some getting used to but that, in relatively quick time, the affected industry integrates the process into normal operations and the end is achieved.

It took 20 years but asbestos is pretty well under control and lead hazards have been effectively eliminated in Federally assisted housing.  There's no reason to believe that a similar result will occur if EPA remains diligent about full implementation of the RRP.

News Release

U.S. Environmental Protection Agency


New England Regional Office


March 23, 2011


Contact: David Deegan, (617) 918-1017


Milford, Conn. Window & Siding Company to Pay Fine for Lead Notification Violations


(Boston, Mass. - March 23, 2011) - A Milford, Conn. company has agreed to pay $30,702 to settle claims by EPA that it failed to provide lead hazard information to home owners or occupants before doing renovations that may have disturbed surfaces coated with lead-based paint. The settlement resolves claims made by EPA’s New England office that Permanent Siding and Windows, a contractor specializing in spray-on vinyl siding and replacing windows and doors, failed to provide EPA’s lead hazard information pamphlet to at least 17 owners or occupants before the company began renovation activities. This pamphlet is required by the federal Pre-Renovation Rule and helps educate home owners or occupants on how to minimize their exposure to hazardous lead dust that is often generated during sanding, cutting, demolition or other renovation activities. The pamphlet also provides resources for more information about lead. The violations in this case took place during renovation work done between January 2006 and March 2009. 


Permanent Siding has certified that it is now in compliance with EPA’s Pre-Renovation rule and will submit a report to EPA later this year to demonstrate their continued compliance with this Rule.


"EPA requires companies to provide these pamphlets in order to protect families from health and safety hazards in the home," said Curt Spalding, regional administrator of EPA’s New England office. "Property owners and occupants have a right to know about the dangers posed by renovations that involve lead."


The federal lead law applies to all pre-1978 housing since, without testing, homes built before 1978 are presumed to contain lead-based paint. The settlement stems from a March 2009 EPA inspection and documentation Permanent Siding provided to the EPA. 


More information: Lead Paint Assistance/Enforcement in New England ( <>




Egypt’s recent news places a significant fascination over what next becomes of a country whose place in history is so rich and contributing. Their history includes the fact that our current interest in the subject of Indoor Air Quality (IAQ) was born in Egypt, around as early as 1500 BC, when they realized that the silicate dust produced by the cutting of construction stone caused home inhabitants respiratory disease. The Egyptians called this inflammatory tissue disease papyrus ebers.

Jump thirty-five hundred years later, and we are at the precipice of a new and startling realization only recently discovered by The Green Kitchen Institute (GKI) of Buffalo, New York. The fact is, according to GKI, the most dangerous and health-effecting change in the human history of architecture, going back over 10,000 years, has taken place in just the last 40 years.

First we must note positively that the EPA just celebrated its first 40 years of the Clean Air Act, with compelling facts and figures of improvements to the outdoor air. The outdoor air improvements, with industrial precautions, and major regulatory clean up efforts have been astoundingly successful. Unfortunately something else has been developing on a more negative, but parallel pathway. In the early 1970’s we were compelled to address the onset of the Energy Crisis by literally tightening up our indoor environment.

We tightened our homes, and we continue to do so. In fact the recently evolved Green Revolution has done more to tighten our homes, addressing the energy consumption in far greater detail than any of the effects effected on behalf of indoor air health concerns. We went full speed into the future 40 years ago in a non-stop introduction of electrical combustible appliances into our homes.

The electrical combustion appliance revolution began with a single light bulb on the front porch, then progressively entered the kitchen with a rush of post-war electrical appliances, and eventually having its heyday overtaking every room in the house with appliances. Green Kitchen Institute’s research shows that these appliances very nature is harboring homes in a nanopartcile sea of toxicity. The combustible appliances act like a cheese grater that with every use is emitting metallic vapors of so many types and nano-sizes in full-home proportions that seize the air quality reaching the entire home. The effective result is a home-filled sea of health-threatening and toxic nanoparticles.

One-thousandth the size of a human hair, these extremely small but ever-prevelant particles will amass at the rate of billions each time we cook (example, a pot of tomato soup), and in their billions over twenty minutes build-up they have no place to go but into our lungs, brains, and multiple organs.

It’s not the tomato soup itself, but the appliance that is burning itself, and cooking itself that triggers the metallic particulates into the air. We can seek to ventilate them, or else they accumulate in patients to assume their seats in lungs, and the entire central nervous system and organs. They will travel ever so small, using their agile force through our organs, to unseat the triggers and/or exacerbations that cause or flare of varied and multiple effected inflammatory tissue disease and illnesses.

The Green Kitchen Institute (GKI) based in Buffallo, New York, works  to address this dilemma to meet the growing need to investigate the health effects of gas and electrical appliances operating in energy-tightened indoor environments along with their inhabitant patients. Nearly every family, everywhere, is somehow affected by this medical and health crisis issue.

While many people spend much of their time in the kitchen, they rarely think of the effects that operating cooking appliances in a poorly ventilated home can have on their health. According to the Green Kitchen Institute, kitchen appliance emissions can be ten times worse than the diesel fumes at a cross section at high peak traffic hour. The Green Kitchen Institute is designed to both inform people of the effects their habits in the kitchen have on their bodies, and generate solutions to create a healthier indoor environment.

GKI is a collaborative project between the Research on Environmental Exposure Consultants, (REEC), Environmental Health Network, Inc. (EHN), and Environmental Education Associates. For close to a decade, this group has been working to study indoor air quality and its impact on patients’ health, and promote those findings to the community at large. Research headed by Jamson Lwebuga-Mukasa, M.D., PhD at REEC has specifically focused on gas and electric appliance release of ultrafine particles into the air.

Ultrafine particles that are emitted into indoor air tend to build up in the body which can trigger the symptoms of inflammatory diseases, such as asthma and COPD and a score of other inflammatory diseases..Dr Jamson Lwebuga-Mukasa, the Chair and Co-Director of Green Kitchen Institute, has led and pioneered the essential field research that has reached many GKI indoor air discoveries. Dr Lwebuga-Mukasa’;s studies have found that using every form of ventilation (range hoods, windows) and a proper air purifier while cooking is an effective way to reduce the particulates in the air and alleviate the inflammation. This is an example of the types of preventative solutions that GKI promotes through their partnerships with research professionals and kitchen appliance manufacturers.

Green Kitchen Institute’s alliance between medical and scientific research professionals and manufacturers of kitchen-related products, enables families to understand and generate viable solutions to the largely heretofore unknown health issues affecting them daily through their kitchens. GKI also works collaboratively with government and industry to create the healthiest kitchens and indoor environments possible for everyone.


The facts add up. Our houses are tightly toxic. We need much more ventilation, better non-emitting appliances, and consistent air purification if we are persistent in using such appliances. Our appliances are literally grating metallic vapors into the air we breathe, the resulting toxic nanoparticles of which rest in our bodies and affect the performance of our energy-building cellular mitochondria.


GKI proposes that if we persist to use electrical combustible appliances, we need to match their negative emissions up with proper ventilation and Consistent Indoor Air Purification (CIAP).™   These remedies begin most simply with the use of qualified air purification units on the market today.


Green Kitchen Institute cites the noted warning by the EPA that “over 50% of illness in America today is either triggered or exacerbated by indoor air pollution.” Green Kitchen Institute argues that our reach for the ultimate cooking kitchens should seek to  protect ourselves in limiting  the degree that our kitchens can harm our health.


In this vibrant Green Revolution, the respectful approach to our indoor air quality requires an insightful revolution of thought and action, and of indoor health choices. The Green Kitchen Institute agrees this will take time to inform the public and engage debate over the facts they have discovered. This is surprising news to many, but the facts are stimulating discussion everywhere.


The Green Kitchen Institute’s research findings, if adapted, will require major changes of indoor environmental ventilation practices and indoor appliance use. They will dramatically alter the choice and habits using appliances indoors. The overall findings from clinical research may in fact ultimately alter the standards of current practices in medicine, architecture, electrical appliance manufacturing.


Change may begin within family household awareness and new approaches to indoor air environmental management. Another historic Egyptian, President Anwar Sadat, well noted: “He who cannot change the very fabric of his thought will never be able to change reality, and will never therefore make any progress.”




We must Clean the Air. Start There.


Asthma, 2011…Clean the Air. Start There.

Bill Zimmermann, Environmental Health Network (EHN

January 11, 2010

The increasing rate of asthma cases over recent decades is cited by many as alarming, even epidemic in proportion. The increase over so relatively short a period of time forces the question whether it could be genetic and/or environmentally induced.

Asthma has come to resemble the canary in the mine, its increasing presence acting as a forewarning of a possible multitude of other tissue related diseases that are also affected by air pollution. These may range from strokes and cardiovascular disease to brain function diseases in early development to old age. The EPA states that “over 50% of illness in America is triggered or affected by indoor air pollution,” where it cites “the air is five to 20 to 100 times worse than outdoor air quality.”

How has our indoor environment changed in recent years? The reasons for the dramatic increase in asthma may vary, but considering that from the onset of the Energy Crisis in the 1970’s, the construction of our homes has focused on air tight designs, cutting back or altogether eliminating ventilation and air exchange. And since we spend up to 90% of our time indoors, where the air we breathe supplies 90% of our life’s energy supply, our polluted indoor air takes its toll on our bodies in numerous ways.

Our active indoor environments create a continual build-up of invisible airborne particulates, deriving from a variety of factors—ranging from cleaning supplies and chemicals, to combustible appliance emissions, as well as from mold, cockroaches, house dust mites, furniture and materials off-gassing, pet dander, and the ongoing indoor absorption of outdoor pollution. 

The first important step is to recognize potential asthma triggers in the indoor environment and reduce your exposure to those triggers. By controlling exposure, we can significantly improve the quality of life of people with asthma. The first step, according to Environmental Health Network: Clean the Air. Start There


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Asbestos Shuts Down Madison Square Garden

Monday, December 7, 2010

Asbestos returned to the limelight early last month when fears of an "uncontrolled fiber release" forced Garden officials to postpone the November 3rd game between the Knicks and the Orlando Magic. Subsequent tests conducted by the City’s Department of Environmental Protection and by independent air monitoring firms concluded that no asbestos had been released into the arena and basketball resumed a couple days later.

The City Department of Environmental Protection (DEP) has been very active over the last year or so, implementing revisions to the City's asbestos regulations. 

Earlier this year, the City introduced new requirements for Asbestos Investigators.  The overhaul of asbestos inspector oversight by DEP was prompted by the recent case of a private asbestos safety inspector who admitted falsifying hundreds of reports that buildings were free of asbestos. Asbestos investigators are now required to follow strict requirements for the submittal of asbestos inspection reports to DEP.  Only individuals certified as asbestos investigators by the Department can engage in building survey and hazard assessment for asbestos. Check out the DEP website at for more information.

Last year, the New York City Council passed, by a unanimous vote, to prohibit demolition activities from starting or continuing in buildings undergoing asbestos abatement procedures. The measures deal with issues that fire investigators came across after two firefighters perished when they answered a fire alarm in a condemned structure in 2007. The skyscraper was going through both demolition and asbestos abatement at the same time. Investigators afterwards stated that performing both processes simultaneously created a dangerous situation for the firefighters.

A related measure would forbid the use of any flammable material, including matches and cigarette lighters, on the floor of a building undergoing asbestos remediation. The new law would also prohibit smoking on those floors, as well as the presence of any tobacco-related products

Another piece of legislation the council passed was to create a new program to grant firms the required permits for asbestos abatement and disposal. The new program would also call for contractors to take extra precautions when handling and removing asbestos-containing materials. Companies who deal with asbestos removal projects would need to pass stiff tests before city building code inspectors would grant such permits.

NYC has one of the most stringent asbestos regulations in the country, based on overlapping City and New York State requirements and serves as the standard of the industry for asbestos abatement oversight. 

EEA is accredited to provide initial certification and recertification for those involved in asbestos-related activities in the City and across the State.  EEA has regular training dates available for the asbestos worker, supervisor, inspector/investigator, manager planner, project monitor, air sampling technician, project designer, operations and maintenance and allied trades certification. 

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Lead Renovator Update & On-Line Approval
Tuesday, June 6th 2010


Lots of drama on the EPA Renovators Rule implementation. The rule took effect, as scheduled, on April 22nd, in spite of protests about capacity and public confusion over the “opt-out” provision. EPA made a case that there was plenty of training available, using statistics from trainers and firm certification applications to demonstrate that there are about 100,000 qualified Renovators in place. We can certainly support that claim, given the number of folks that we’ve seen in our courses. We’ve trained about 6,000 individuals in the last six months or so.

The Agency also set July 6, 2010 as the effective date for the elimination of the opt out provision. Here’s a quote from the Federal Register: “EPA is eliminating the ‘‘opt-out’’ provision that currently exempts a renovation firm from the training and work practice requirements of the rule where the firm obtains a certification from the owner of a residence he or she occupies that no child under age 6 or pregnant women resides in the home and the home is not a child-occupied facility.”

EPA also released a couple brand new items, including provisions for dust sampling at the conclusion of high hazard projects, in 2011, and requirements to apply lead-safe work practices to renovations on public and commercial buildings, sometime after 2014. The Agency is looking for comment on both of these notices, and the public is encourage to submit comments by July 6, 2010. Check out for more detail.

Things really got interesting again in May, when the US Senate voted to withhold enforcement funding for the rule, a measure that was largely symbolic, since EPA had previously stated that they would be focusing on “compliance assistance” instead of enforcement for 2010. Nonetheless, EPA responded with their own “Enforcement Guidance” on June 10, 2010 which extended the enforcement deadline for RRP firm certification requirements until October 1, 2010 and permitted Renovators who have not completed training to register for training by September 30 and complete training by December 31, 2010 without fear of EPA enforcement actions. I’m told that the folks at EPA who actually run the RRP program found out about the extensions at the same time as the general public, much to their dismay.

Mark Twain said “the reports of my death are greatly exaggerated”, in response to a comment in 1897 by President Howard Taft. Similarly, the Renovators rule is alive, healthy and on course for implementation.

Toward that end, EEA is pleased to announce that we have been approved to offer the RRP initial on-line. We’ll have a link at our website in place in the near future that will allow folks to complete the “first half” of the RRP initial training on-line and the attend a 2.5 hour hands-on session and course completion test. Look for that at in July.

Have a great summer.

Andy McLellan

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Monday, January 1th 2010

Here's an interesting excerpt from Pres Obama last night (1/22/10) at a town hall meeting in Ohio. His misuse of the term "abatement" is pretty typical, not unlike me when I'm talking about cars or art. We'll cut him some slack for that. Not so for EPA. Maybe this will light a fire under those tepid RRP outreach efforts. He's had that effect before.... "Q I am a single mother of three, and I have two quick issues that are very important to me -- one being that I have a three-year-old, who has just turned three, who got lead poisoning last year and almost died. And I called everyone, including the EPA of Ohio, and I cannot seem to get any response to thistle PRESIDENT: Well, guess what. I guarantee you that somebody from the EPA is going to call you in about -- (applause) -- in about five minutes. Before you sit down, there's going to be a phone call from the EPA. (Laughter.) All joking aside -- and I know you have a second question, but I just want to focus on this -- lead poisoning, a lot of it from lead paint, from older homes all across the country and all across the Midwest is something that we have to be more aggressive on. This is something that I worked on when I was a U.S. senator, when I was a state senator. I'm working on it as President, and I will find out directly from them how they can help not only with your particular situation but what we're doing in this area in terms of lead abatement"


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Are Green Homes Healthy Homes?
Monday, December 12th 2009

Weatherization is getting a lot of attention these days, as both an opportunity for energy savings and work force development. The latest round of stimulus funded, announced last week by President Obama, provides even more funding for weatherization, on top of nearly one billion dollars in funding from the original American Reinvestment & Recovery Act (ARRA).

Organizations across the country have begun the process of identifying properties and training individuals who will find career opportunities as building analysts and weatherization technicians. This initiate has a tremendous upside, beyond creating jobs and cutting homeowner expenses for heating fuel, which includes creating new business opportunities for suppliers and contractors and, lest we forget, reducing carbon emissions and the threat of significant global warming. You just can’t argue with that.

Consider, nonetheless, the effect that the simple acts of sealing up leaks in the building envelope and replacing windows and other aspects of the building system that often occurs for weatherization. Inhabited residential structures should exchange indoor air at a rate of two air changes every hour, or once a half hour. Ventilation does many wonderful things, not least of which is creating air movement that dries up wet surfaces and expels contaminated, stale air. Allergens and contaminants like mold, tobacco smoke and even carbon monoxide can build to unacceptable levels over an extended period and create serious health hazards for those living in the house when proper ventilation is not established.

Similarly, renovation activities to replace HVAC systems may lead to an unintentional release of asbestos while any disturbance of a building component painted before 1978 could result in lead based paint hazards. Often new building products, like pressed wood and carpeted, can contain contaminants like formaldehyde and volatile organic compounds (VOCs) which can be troublesome in houses that are too “tight”

Fortunately, these unintended consequences can be avoided. Proper understanding of ventilation and assessment of potential hazards is critical to ensuring that this latest “green revolution” creates a permanent change that leads to improved health and environmental outcomes for all Americans. In fact, the push for green housing presents a wonderful opportunity to integrate consideration for healthy homes into housing maintenance, improvement and renovation.

Great things are underway; let’s not let ignorance spoil the success.

Andy McLellan

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Date: 2009-12-21 10:10:10 - Location:

What is this I have heard about firm certification? Does anyone know anything about it, especially if the firm is comprised of one person, me?


Asthma, 2011…Clean the Air. Start There.

Bill Zimmermann (EHN) and Andrew McLellan (EEA)





News Release

U.S. Environmental Protection Agency

New England Regional Office

March 23, 2011

Contact: David Deegan, (617) 918-1017


Milford, Conn. Window & Siding Company to Pay Fine for Lead Notification Violations


(Boston, Mass. - March 23, 2011) - A Milford, Conn. company has agreed to pay $30,702 to settle claims by EPA that it failed to provide lead hazard information to home owners or occupants before doing renovations that may have disturbed surfaces coated with lead-based paint. The settlement resolves claims made by EPA’s New England office that Permanent Siding and Windows, a contractor specializing in spray-on vinyl siding and replacing windows and doors, failed to provide EPA’s lead hazard information pamphlet to at least 17 owners or occupants before the company began renovation activities. This pamphlet is required by the federal Pre-Renovation Rule and helps educate home owners or occupants on how to minimize their exposure to hazardous lead dust that is often generated during sanding, cutting, demolition or other renovation activities. The pamphlet also provides resources for more information about lead. The violations in this case took place during renovation work done between January 2006 and March 2009. 


Permanent Siding has certified that it is now in compliance with EPA’s Pre-Renovation rule and will submit a report to EPA later this year to demonstrate their continued compliance with this Rule.


"EPA requires companies to provide these pamphlets in order to protect families from health and safety hazards in the home," said Curt Spalding, regional administrator of EPA’s New England office. "Property owners and occupants have a right to know about the dangers posed by renovations that involve lead."


The federal lead law applies to all pre-1978 housing since, without testing, homes built before 1978 are presumed to contain lead-based paint. The settlement stems from a March 2009 EPA inspection and documentation Permanent Siding provided to the EPA. 


Green Energy Versus Green Health:
Insights from The Green Kitchen Institute

by Bill Zimmermann, Environmental Health Network