EPA's Renovation, Repair, and Painting Rule
The EPA Renovation, Repair, and Painting (RRP) Rule is the most important Federal lead regulation since the HUD Lead-Safe Housing Rule a decade ago. It has the potential to ensure the widespread use of lead-safe work practices in homes and child-occupied facilities and may be extended to public and commercial buildings in the future. By EPA's estimates, 235,000 individuals and 210,000 firms must be certified when the rule goes into effect in April 22, 2010. EPA has proposed rule would add 100,000 to each of those totals that would go into effect on April 22, 2010.
http://www.nchh.org/Policy/National-Pol ... -Rule.aspx
So, Beginning April 22nd the EPA will begin enforcement of the The Renovation, Repair and Painting Program Rule (RRP Program Rule), and requiring yet another inspector charging a fee to get in my space every time that I want to paint or replace a closet door or remodel a bathroom or kitchen, and potentially fining me for some minor infraction.
Most of it makes sense and really is a decent guideline of how to dispose of lead contaminated remodelling debris. I guess that the good news is that contractor's will have more incentive to properly work with toxic lead-based paint. The bad news is "that those contractors and trades people caught not following the new guidelines can face a fine of $32,500." There's a whole new business of lead testing kits and certified lead professionals to evolve out of this new law. I think this has the potential to drive a lot of independent contractors out of business (the straw that broke the camel's back effect.)
I certainly don't trust the EPA, or any federal agency to earnestly enforce any regulation that is truely designed to protect our health. Working in the trades, I can't even tell you all the hazardous stuff that I have been exposed to for the last 30 years. Anyway, it is what it is
http://www.epa.gov/lead/pubs/steps.pdf
The Renovation, Repair and Painting Program Rule (RRP Program Rule)
This section summarizes requirements of EPA’s Lead-Based Paint Renovation, Repair and Painting (RRP) Program Rule for contractors, and provides guidance to homeowners/occupants, so that each may learn to properly address lead-based paint hazards associated with renovation, repair and painting activities.
The RRP rule affects contractors, property managers and others who disturb known or presumed lead-based paint during renovation. The term renovation covers all activities done for compensation that disturb painted surfaces including most repair, remodeling and maintenance activities, such as window replacement, weatherization and demolition. The RRP rule applies to all renovation work performed in residential houses, apartments and child-occupied facilities such as schools and day-care centers built before 1978. Those affected by the RRP rule should read the complete rule, which is available on EPA’s Web site at: http://www.epa.gov/lead/pubs/renovation.htm.
Training, certification, and work practice requirements in the Renovation, Repair and Painting Rule are effective April 22, 2010. Pre-renovation education requirements are effective now.
Requirements for Renovation Contractors Include: Certification and Training Requirements
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All firms performing renovation, repair or painting work must become certified. This can be accomplished by applying to EPA or to the State, if it has an EPA-authorized renovation program, and paying a fee.
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Firms must have one or more “Certified Renovators” assigned to jobs where lead-based paint is disturbed. To become certified, a renovator must successfully complete an EPA or State-approved training course conducted by an EPA or State-accredited training provider.
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All renovation workers must be trained. Renovation workers can be trained on-the-job by a Certified Renovator to use lead safe work practices, or they can become Certified Renovators themselves.
Pre-Renovation Education Requirements
■ Contractors, property managers and others who perform renovations for compensation in residential houses, apartments, and child-occupied facilities built before 1978 are required to distribute EPA’s Renovate Right lead hazard information pamphlet before starting renovation work to occupants and owners of homes, and owners and parents of child-occupied facilities. More information about pre-renovation education requirements can be found on page 33.
Work Practice Requirements
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Renovators must use work-area containment to prevent
dust and debris from leaving the work area.
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Certain work practices are prohibited. Open-flame
burning, using heat guns at greater than 1,100 degrees
Fahrenheit and the use of power tools without high-
efficiency particulate air (HEPA) exhaust control (to collect
dust generated) are prohibited.
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Thorough cleaning followed by a cleaning verification procedure to minimize exposure to lead-based paint hazards are required.
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Generally, minor repair and maintenance activities (less than 6 square feet per interior room or 20 square feet per exterior project) are exempt from the work practices requirements. However, this exemption does not apply to jobs involving window replacement or demolition, or that involve the use of any of the prohibited practices listed above.
Exemption from the RRP Rule
The training, certification and work practice requirements do not apply where the firm obtains a signed statement from the owner that all of the following conditions are met:
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The renovation will occur in the owner’s residence;
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No child under age 6 resides there;
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No woman who is pregnant resides there;
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The housing is not a child-occupied facility; and,
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The owner acknowledges that the renovation firm will not be
required to use the work practices contained in the rule.
Homeowners Working in Their Own Homes
The RRP rule applies only to renovations performed for compensation. If you work on your own home, the rules do not apply. Even so, EPA encourages homeowners to use lead safe work practices, in order to protect themselves, their families, and the value of their homes.
Landlords Working in Their Own Property
Landlords receive rental payments and maintenance personnel in rental property or child-occupied facilities receive wages or salaries derived from rent payments. This is considered compensation under the RRP rule. Therefore, renovation and repair activities performed by landlords or employees of landlords are covered by the rule. Work performed by landlords or their employees in pre-1978 housing and child-occupied facilities must be performed using lead safe work practices, if lead-based paint or presumed lead-based paint is disturbed.
http://blog.seattlepi.com/greenbuilding ... 194266.asp
New EPA LEAD Rules to Effect Residential Renovations
Lead-based paint was used in more than 38 million homes until it was banned for residential use in 1978. For those renting, buying or renovating a pre-1978 home, receiving a copy of the EPA's lead pamphlet is federal law, and duly warns against things like letting your children chew on the windowsills.
Lead has been shown to affect children's brains and developing nervous systems, causing reduced IQ, learning disabilities, and behavioral problems, and is also harmful to adults. Lead in dust, which is often invisible, is the most common way people are exposed to lead.
Beginning in April 2010 the EPA will require contractors performing work which disturbs lead-based paint in homes, child care facilities, and schools built before 1978 to:
• Be EPA certified renovators
• Follow specific lead safe work practices to prevent lead contamination
• Provide homeowners with lead safe work practices documentation
What will being a certified renovator mean?
Common renovation activities like sanding, cutting, and demolition can create hazardous lead dust and chips by disturbing lead-based paint. Certified renovators are trained in the use of lead safe work practices, which include:
• Containing the work area
• Minimizing the generation of lead paint dust
• Thoroughly cleaning up
• Passing a cleaning or "white glove" test
Who needs to be certified?
Anyone who disturbs paint for compensation. It applies to all kinds of contractors including general and specialty contractors such as electricians and plumbers as well as property managers who are conducting their own repairs. Beginning in April 2010, homeowners should ask to see a contractor's lead renovator certification before deciding to hire them.
What documentation should homeowners receive?
Contractors are already required to provide you with a copy of the EPA's lead hazard information pamphlet Renovate Right: Important Lead Hazard Information for Families, Child Care Providers, and Schools. Beginning in April 2010, homeowners will also sign a pre-renovation form documenting that they have received this pamphlet. After completion of work, they will also receive a report that documents the lead safe work practices used and that a cleaning test was passed.
What lead testing will be conducted?
Certified renovators will conduct a final cleaning test which consists of taking a wipe sample from within the work area. If the wipe test fails, recleaning and retesting is required. Homeowners may also elect to have post-renovation clearance testing done, which includes sending dust samples to a lab to ensure compliance with the EPA's lead threshold levels.
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If you are a contractor and would like more information on the EPA's new rules and how to become a certified renovator, please visit http://www.epa.gov/lead/pubs/renovation.htm#contractors
video for realtors:
http://www.realtor.org/government_affai ... t_realtors
more info:
http://www.epa.gov/lead/pubs/renovaterightbrochure.pdf
