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Lead-Based Paint Renovation, Repair, and Painting

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Title: Lead-Based Paint Renovation, Repair, and Painting


1
Lead-Based PaintRenovation, Repair, and Painting
  • Requirements for Renovators and Training
    Providers

2
Session Overview
  • Regulatory Background
  • Final Rule Requirements
  • Enforcement
  • Important dates

3
The Renovation, Repair, and Painting Rule (RRP)
  • 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.

4
Lead is a Hazard Why?
  • Affects brain, CNS, and many other systems in
    body.
  • Leaded dust is often invisible.
  • Exposure through ingestion or inhalation.
  • Can cause permanent damage.
  • Signs and symptoms often go unnoticed.
  • 2008 data show that the EBLLs in a significant
    percentage of young children were related to
    renovation activities.

5
Final Rule (Signed March 2008)
  • Purposes
  • Persons performing renovations and dust sampling
    are properly trained
  • Renovators, dust sampling technicians and firms
    performing these renovations are certified
  • Lead-safe work practices are followed during
    renovations
  • Providers of renovation and dust sampling
    technician training are accredited and
  • Amend Pre-renovation Education Rule to include
    child occupied facilities.

6
Rule Scope
  • Renovation is defined as modification of any
    existing structure that results in the
    disturbance of painted surfaces, unless performed
    as part of an abatement.
  • Applies to renovations of target housing and
    child occupied facilities performed for
    compensation.
  • Child-occupied facilities may be located in
    public or commercial buildings or in target
    housing. Includes kindergarten classrooms and
    daycare facilities.

7
Rule Scope
  • Excludes
  • Renovations that affect only components that have
    been determined to be free of lead-based paint.
  • Minor repair and maintenance activities that
    disturb no more than 6 ft2 interior or 20 ft2
    exterior UNLESS these activities involve window
    replacement, demolition or projects involving
    prohibited practices.
  • Work done by individuals in housing they own and
    occupy.
  • Opt-out provision
  • Homeowners may opt out of rule requirements if
  • they occupy the housing to be renovated,
  • the housing is not a child-occupied facility, and
  • no child under age 6 or pregnant woman resides
    there.
  • Homeowners may still request lead-safe work
    practices.

8
Lead-based Paint Free Determination
  • Written determination by certified inspector or
    risk assessor, or
  • Written determination by certified renovator
    using a lead test kit
  • Acceptable test kits will have to meet the
    following criteria
  • Phase 1 Be capable of determining the presence
    of lead at levels gt/ 1.0 mg/cm2 or gt 0.5 by
    weight and a false negative rate no higher than
    5.
  • Phase 2 Criteria above and a false positive
    rate no higher than 10.
  • EPA has published a list of kits evaluated by
    that National Institute of Standards and
    Technology (NIS) as meeting Phase 1 criteria.
    Phase 1 kits will only be used until the first
    Phase 2 kit is approved.
  • New kits meeting phase 2 criteria are under
    development. New kits will be evaluated and
    approved by EPAs ETV program.

9
Pre-Renovation Education
  • Changes to the Pre-Renovation Education Rule
  • Renovations in common areas.
  • Firms may post informational signs in lieu of
    delivering information directly to each dwelling.
  • Before renovating a Child Occupied Facility
    (COF), renovation firms must
  • Provide Renovate Right to building owner and
    adult representative of COF
  • Provide information about the renovation to
    parents guardians of children under age 6 using
    facility by mail, hand-delivery or informational
    signs.
  • Informational signs must
  • Be posted where they will be seen
  • Describe nature, locations, and dates of
    renovation
  • Be accompanied by Renovate Right or by info on
    how tenants or parents guardians can get a free
    copy

10
Informational Sign
  • For example
  • The following renovation activities will take
    place in the following locations
  • Activity - Window replacement
  • Location 2nd floor foyer
  • The expected starting date is May 1, 2009 and the
    expected ending date is May 8, 2009. Because
    this is an older building built before 1978, some
    of the paint disturbed during the renovation may
    contain lead. You may obtain a copy of the
    pamphlet, Renovate Right, by telephoning me at
    (215) 555-1987. Please leave a message and be
    sure to include you name, phone number and
    address. I will either mail you a pamphlet or
    slide one under your door.
  • Date Printed
    Name of Renovator _
  • Signature of Renovator
    _

11
Pre-Renovation Education
  • New brochure Renovate Right developed for all
    covered renovations
  • As of December 2008, this is the brochure that
    must be used to comply with the Pre-Renovation
    Education Rule.
  • Protect Your Family brochure will still be
    available for other purposes like real estate
    disclosure and general outreach

12
CertificationFirms
  • To be certified to perform renovation or dust
    sampling firms must submit an application and fee
    to EPA.
  • Certifications are good for 5 years.
  • Certification allows the firm to perform
    renovations in any State where EPA regulations
    are in effect.

13
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
  • Certification allows the renovator to perform
    renovations in any State where EPA regulations
    are in effect.

14
CertificationIndividuals
  • Grandfathering
  • Individuals with certain previous training can
    take an accredited 4 hour refresher renovator
    course instead of the 8 hour initial course to
    become a certified renovator.
  • Acceptable training includes
  • an accredited abatement worker or supervisor
    course, or
  • an EPA, HUD, or EPA/HUD model renovation training
    course

15
AccreditationTraining Providers
  • To be accredited to provide renovator or dust
    sampling technician training, trainers must
    submit an application and fee to EPA (fee to be
    determined)
  • Trainers must be re-accredited every 4 years.
  • Accreditation procedures are the same as those
    established for abatement training.
  • Courses must last a minimum of 8 hours, with 2
    hours devoted to hands-on training.
  • EPA has developed model renovator initial and
    refresher courses and the model initial dust
    sampling technician course.
  • Training providers must notify EPA of individuals
    who complete training.
  • Accreditation allows the trainer to conduct
    training in any State where EPA regulations are
    in effect.

16
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/managers/occupants of the
    home or building to be renovated prior to
    starting the work.
  • The rules recordkeeping requirements are met.

17
Work Practice Standards Renovator
Responsibilities
  • Perform project cleaning verification, and
    perform or direct workers who perform all other
    required tasks.
  • Provide training to workers on the work practices
    they will be using in performing their assigned
    tasks.
  • Regularly direct work being performed by other
    individuals to ensure that the work practices are
    being followed, including
  • maintaining the integrity of the containment
    barriers, and
  • ensuring that dust or debris does not spread
    beyond the work area.

18
Work Practice Standards Renovator
Responsibilities
  • Be physically present at the work site
  • When warning signs are posted.
  • While containment is being established.
  • While the work area cleaning is performed.
  • Be available, either on-site or by telephone, at
    all times that renovations are being conducted.
  • When requested, use an EPA-approved test kit to
    determine if lead-based paint is present.
  • Carry copies of their initial course completion
    certificate and most recent refresher course
    completion certificate.
  • Must prepare required records.

19
Work Practice Standards
  • General
  • Interior
  • Exterior
  • Waste
  • Cleaning
  • Cleaning Verification

20
Cleaning Verification
  • Wipe floors, countertops, and windowsills with
    wet cleaning cloth.
  • Use one cloth for each 40ft2 section of floor or
    countertop surface.
  • If the cloth does not match the verification
    card, re-clean that surface and then re-wipe with
    a wet cleaning cloth.
  • If this cloth does not match the cleaning
    verification card, allow the surface to dry
    completely and wipe with a dry cleaning cloth.
  • Dust clearance sampling may be performed instead
    of cleaning verification if the contract between
    the building owner and the renovation firm or
    another Federal, State, or local regulation
    requires dust sampling by a certified
    professional and requires the renovation firm to
    clean the work area until it passes clearance.

21
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
  • Any signed and dated statements received from
    owner-occupants documenting that the requirements
    do not apply (i.e., no child under age 6, no
    pregnant woman, no child occupied facility)
  • Documentation of compliance with the requirements
    of Renovation, Repair, and Painting Rule

22
Fees
  • EPA will charge fees to recover cost of program
    administration.
  • Fees will apply to all firm certification and
    training provider accreditation applications.
  • Fees will not apply to certified RRP individuals
    (who do not apply to EPA)

23
Fees
  • Renovation Firms
  • 300 for certification and recertification
  • Training Providers
  • 560/340 for initial courses
  • 400/310 for refresher courses
  • Individuals
  • No fee

24
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.
  • Contractors who knowingly or willfully violate
    this regulation may be subject to criminal
    penalties of up to an additional 37,500 per
    violation, or imprisonment, or both.

25
Enforcement and Penalties (Contd)
  • How will EPA Enforce RRP?
  • Tips/complaints
  • File Audits
  • On-site Inspections
  • Will be a big challenge!

26
Important Dates
  • December 22, 2008
  • Renovate Right brochure must be used for 406(b)
  • April 22, 2009
  • EPA begins administering program in unauthorized
    states
  • Training providers may begin applying for
    accreditation
  • October 22, 2009
  • Renovation firms may begin applying for
    certification
  • April 22, 2010
  • Training providers must be accredited
  • Renovation firms must be certified
  • Renovators and dust sampling technicians must be
    certified
  • Workers must be trained
  • Work practices must be followed

27
Other Resources
  1. Renovate Right
  2. Small Entity Compliance Guide to Renovate Right
  3. Lead Safety During Renovation

28
For More Information
  • Annie Skidmore
  • (410) 305-2640
  • skidmore.annie_at_epa.gov
  • EPA Website www.epa.gov/lead
  • Toxics Program Branch
  • Land and Chemicals Division
  • US EPA Region III
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