Lead-Based Paint Renovation, Repair, and Painting Rule Overview of RRP Rule EPA Region 8...

Lead-Based PaintRenovation, Repair, and Painting Rule

Overview of RRP RuleEPA Region 8

************Jim Maley

RRP Final Rule - Overview2

Why are we concerned about Lead ?

Lead is most dangerous to children under the age of six

Children’s systems are more sensitive Children’s growing bodies absorb more lead


How is Lead harmful to Children

Affects a child’s developing Central Nervous System

Reduces a child’s IQ and cause learning disabilities

Causes behavioral problems as the child develops into adulthood


Lead effects on Adults

Harmful to the fetus Fertility problems High blood pressure


Exposure to Lead

Lead Dust is the most common way Deteriorating paint creates lead dust Lead contaminated outside soil creates dust Home renovations create lead dust


New RRP Rule April 22, 2010

EPA issued a final rule under the authority of § 402(c)(3) of the Toxic Substances Control Act (TSCA) to address lead-based paint hazards created by renovation,repair, and painting activities that disturb lead-based paint in “target housing” and

“child-occupied facilities.”


Acronyms/Definitions

RRP: Renovate, Repair and Paint Regulation also referred to as “ Renovate Right “

Target Housing: any housing built prior to 1978

Child Occupied Facility – a facility where children under 6 regularly visit


The Renovate, Repair and Paint Regulation

Applies to renovations for compensation in homes, schools and other child occupied facilitys built prior to 1978


Who is affected by the regulation ?

Renovation contractors Maintenance workers Painters Other specialty trades


What does the rule say ?

Contractors, painters, maintenance persons that disturb painted surfaces in pre-1978 homes, schools or other child-occupied facilities must:– be certified, – work for a certified firm – and work in a lead safe manner.


Abatement vs. Renovation

Abatements are intended to permanently eliminate existing lead hazards.

Abatements are not covered by this rule. Renovations involve activities designed to update,

maintain, or modify all or part of a building. The rule is designed to prevent the introduction of

new lead hazards created by a renovation, not to address existing lead hazards.


What activities and buildings are Subject to RRP ?

In general, any activity that disturbs paint in pre-1978 housing, schools and other child-occupied facilities

This would include remodeling and repair/maintenance, electrical work, plumbing, painting carpentry and window replacement

Child-occupied facilities may be located in public or commercial buildings or in target housing. This includes schools, kindergarten classrooms and daycare facilities.


What Activities and Buildings are excluded from the Rule

Excludes:– Homes built in 1978 or later– Housing for the elderly– Zero-bedroom dwellings (studio apartments,

dormitories, etc.). – Activities that disturb less than 6 ft2 interior or 20 ft2

exterior. This excludes window replacement, demolition and projects involving prohibited practices.

– Work done by individuals in housing they own and occupy.

– Public buildings


Pre-Renovation Education

brochure “Renovate Right” developed for all covered renovations

www.epa.gov/lead/pubs Given to owner and

possibly tenants Post signs


CertificationIndividuals

Must take 8-hour accredited training course:– Certified Renovators - perform & direct renovation activities – Dust Sampling Technicians - perform dust sampling not for an

abatement Course certificate serves as certification (no application to

EPA required) Refresher training is required every 5 years Other workers do not need certification but must be trained by

a Certified Renovator on the job Certification allows the renovator to perform renovations in

any non-authorized state or Tribal area.


Work Practice Standards Firm Responsibilities

Firms performing renovations must ensure that: – All individuals performing renovation activities are either

certified renovators or have been trained by a certified renovator.

– A certified renovator is assigned to each renovation and performs all of the certified renovator responsibilities.

– All renovations performed by the firm are performed in accordance with the lead-safe work practice standards.

– The firm supplies lead hazard information pamphlets to owners or managers of the home or building to be renovated prior to starting the work.

– The Lead RRP Rule’s recordkeeping requirements are met.


Recordkeeping Requirements

All documents must be retained for 3 years following the completion of a renovation.

Records to be retained include:– Reports certifying that lead-based paint is not present – Records required by the Pre-Renovation Education Rule– Documentation stating that the requirements do not apply– Documentation of compliance with the requirements


Enforcement and Penalties

EPA may suspend, revoke, or modify a firm’s certification if firm is found to be in non-compliance.

Non-compliant contractors may be liable for civil penalties of up to $37,500 for each violation per day

Contractors who knowingly or willfully violate this regulation may be subject to fines of up to an additional $37,500 per violation, or imprisonment, or both.


For More Information:

U.S. Environmental Protection Agency Region 8Lead Program

1595 Wynkoop 8ENF-AT Denver, Colorado 80202-1129

Jim Maley, Lead and Asbestos Inspector, [email protected]

http://www.epa.gov/region8/toxics/leadpnt/http://www.epa.gov/lead


For More Information

U.S. Environmental Protection Agency Region 8

Lead Program

1595 Wynkoop 8P P3T Denver,

Colorado 80202-1129

Teri Bahrych, Tribal Lead Coordinator, 303.312.6788

[email protected]

Lead-Based Paint Renovation, Repair, and Painting Rule Overview of RRP Rule EPA Region 8...

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