Thursday, March 31, 2011

Restoration & Remediation Magazine - The RRP Rule: One Year Later

In this month's issue of Restoration & Remediation Magazine, Mr. John Banta wrote an excellant article regarding the Environmental Protection Agency's (EPA) Lead Paint regulation - Renovation, Remodeling, & Painting Rule.  The article covers the history of the rule and discusses enforcement issues.

As the article discusses the roll-out period for firms to become certified by filing their paperwork and paying their fees to the EPA, as well as for the Certified Renovators supervising these jobs to be trained, was extended to the end of 2010, but the effective date for using lead safe work practices remained April 22, 2010.  As Mr. Banta indicates in his article "this means...that any firm performing work for hire in target housing or child-occupied facilities built prior to 1978 is required to follow the regulations, even if their paperwork hasn’t been processed or even filed."  However, this grace period is over.

The EPA may audit the records of any firm in violation of the regulation for up to three years after the job is complete and be fined up to $37,500 per occurrence per day. If the violation of the law is willful, the fine can be doubled and jail time may be assigned by the courts.  This law applies in all federal jurisdictions; except states, tribes, and territories that EPA has approved to administer their own RRP programs.  According to the article those states are, Wisconsin, Iowa, North Carolina, Mississippi, Kansas, Rhode Island, Utah, Oregon, Massachusetts, and Alabama have had their programs approved in lieu of the Federal program. Approved State programs must be at least as strict as the EPA regulations.
Don't forget tomorrow is the EPA Information Session at Hofstra and if you have any questions please post them here or at Future Environment Designs Forum, and I will try to get an answer to your questions.


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