Lead-Based Paint Renovation, Repair, and Painting Rule

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Lead-Based PaintRenovation, Repair, and Painting
Rule

• Overview of RRP Rule
• EPA Region 8
• Jim Maley

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Why are we concerned about Lead ?

• Lead is most dangerous to children under the age
  of six
• Childrens systems are more sensitive
• Childrens growing bodies absorb more lead

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How is Lead harmful to Children

• Affects a childs developing Central Nervous
  System
• Reduces a childs IQ and cause learning
  disabilities
• Causes behavioral problems as the child develops
  into adulthood

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Lead effects on Adults

• Harmful to the fetus
• Fertility problems
• High blood pressure

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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

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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.

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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

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The Renovate, Repair and Paint Regulation

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

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Who is affected by the regulation ?

• Renovation contractors
• Maintenance workers
• Painters
• Other specialty trades

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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.

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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.

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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.

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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

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Pre-Renovation Education

• brochure Renovate Right developed for all
  covered renovations
• www.epa.gov/lead/pubs
• Given to owner and possibly tenants
• Post signs

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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.

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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 Rules recordkeeping requirements
  are met.

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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

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Enforcement and Penalties

• EPA may suspend, revoke, or modify a firms
  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.

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For More Information

• U.S. Environmental Protection Agency Region 8
• Lead Program
• 1595 Wynkoop 8ENF-AT Denver, Colorado 80202-1129
• Jim Maley, Lead and Asbestos Inspector,
  303-312-6351
• maley.jim_at_epa.gov
• http//www.epa.gov/region8/toxics/leadpnt/
• http//www.epa.gov/lead

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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
• bahrych.teri_at_epa.gov