Common renovation activities like sanding, cutting, and demolition can create hazardous lead dust and chips by disturbing lead-based paint, which can be harmful to adults and children. To protect against this risk, the EPA issued a rule requiring the use of lead-safe practices and other actions aimed at preventing lead poisoning. Under the rule, beginning in April 2010, contractors performing renovation, repair and painting projects that disturb lead-based paint in homes, child care facilities, and schools built before 1978 must be certified and must follow specific work practices to prevent lead contamination.
Last month, Cypress Construction Services sent Mark Steinhauer and Juan Acosta to a training course in Fresno, CA, and they both completed the course and passed the test and were Certified. Last week, we had a company-wide training meeting, in which Mark, Juan, and I taught the crew about the new rule, and how we will work differently to comply with these new standards. We created a 42-minute video of the training, and here you can watch a 2-minute sample of the video:
Requirements for Renovation Contractors Include:
Certification and Training Requirements
■ 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.
■ 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.
■ 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.
Contractors, property managers and others who perform renovations
for compensation in residential houses, apartments, and childoccupied
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.
Renovators must use work-area containment to prevent
dust and debris from leaving the work area.
■ 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 highefficiency
particulate air (HEPA) exhaust control (to collect
dust generated) are prohibited.
■ Thorough cleaning followed by a cleaning verification procedure to
minimize exposure to lead-based paint hazards are required.
■ 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:
■ The renovation will occur in the owner’s residence;
■ No child under age 6 resides there;
■ No woman who is pregnant resides there;
■ The housing is not a child-occupied facility; and,
■ 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.
Feel free to contact us if you have any questions regarding this program, or how to comply with the new regulations.
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04/27/10 - Let the amendments begin!
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From the certified trainer we received our certification from:
The record keeping requirements have been changed. We now must give copies of our records within 30 days of the final invoice or completion of the project to the home owner or resident. The records that we turn over must demonstrate compliance with the training and work practices of the RRP rule, basically the checklist and the results of any testing.
The Opt-Out provision has been eliminated and lead safe work practices will apply to all pre 1978 houses. This is something we have been expecting and most of us were informed during our training this provision would be removed.
Both of these amendments are final and will take effect 60 days after publication in the Federal Register. The Renovate Right brochure will be amended accordingly by the EPA and NARI will alert its members when the new brochure is available.
The EPA also issued a guidance letter on April 20, 2010 to its Enforcement Division Directors in all regions announcing the rule would be fully effective on April 22, 2010. EPA will not take any enforcement action against firms who have applied for firm certification before April 22 and are just waiting for their paperwork, they expect these applications to be processed by June. EPA will still enforce rules about work practices and training requirements for these firms. This letter makes no mention of firms that apply after April 22 for firm certification so they are telling their enforcement people to go to work and begin enforcement.
If your firm is not certified and you do not have trained renovators on staff you will be breaking the law!
The EPA also published two proposed amendments to the RRP that are now open for comment.
Lead: Clearance and Clearance Testing Requirements for RRP will require dust wipe testing after completing the existing cleaning verification procedures for some/most renovations. The EPA will be accepting comments on this proposal for 60 days and expects to finalize the amendment by July 2011.
Lead: RRP for Public and Commercial Buildings will apply lead-safe work practices and training requirements to public and commercial buildings. The EPA has set deadlines to issue a proposal by December 15, 2011 and take final action by July 15, 2013.
Paint Testing - The RRP rule requires contractors to either test paint they will disturb BEFORE beginning a job, or assume that it is lead-based. This testing is to be done using EPA-approved test kits. However, this does not apply in California (see Note).
Note: In California contractors MAY NOT test paint. California law requires contractors to assume all surfaces in all structures built before 1978 contain lead-based paint, unless they have been tested and found to be "lead-free" by a State Certified Lead Inspector/Risk Assessor. No one else can test for lead-based paint in California.
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