Friday, April 29, 2011

EPA Region 2 Coordinator Discusses the RRP Rule

Environmental journalism supports the protecti...Image via WikipediaOn Friday, April 1, 2011, the Environmental Protection Agency’s (EPA) Region 2 Renovation, Repair , and Painting (RRP) Rule Coordinator Ms. Jeanette Dadusc was discussing the requirements and background of the rule. The topics covered included: introduction to the problem of childhood lead poisoning; Federal government’s response to childhood lead poisoning; how the RRP Rule was developed; the regulated universe of RRP facilities and activities; certification requirements for training providers, individuals, and firms; notification and work practice requirements; cleaning verification card; proposed rule changes; RRP frequent questions; and RRP enforcement strategy.

Her presentation was wide ranging, covered the full time of the presentation, and the handouts supplemented her presentation and were useful. Visit our website at to find a copy of her handouts.  Some of the points regarding the childhood lead problem were:
  • Lead based paint is the number one environmental health threat to children
  • Children absorb 50% of the lead they ingest compared to adults, which absorb only 10%.
  • According to the Centers for Disease Control (CDC), there is no known safe level of lead in blood.
  • Discussions are ongoing regarding dropping the standard of lead blood level to 5 micrograms per deciliter (ug/dl) versus the current 10 ug/dl.
  • Lead bioaccumulates in the body because it mimics calcium
  • Children, who live in homes where renovation & remodeling activities were performed within the past year, are 30% more likely to have a blood lead level that equals or exceeds 10 ug/dl.
Some of the points regarding regulated universe of RRP facilities and activities were:
  • Target housing is defined as housing constructed prior to 1978.  There are only 2 exceptions housing for the elderly or for person with disabilities (unless one or more children under 6 years old resides or is expected to reside in such housing), and 0-bedroom dwellings. Meaning hotels, motels, timeshares, and student housing is not exempt.
  • Child Occupied Facility (COF) is defined as a building or portion of a building built prior to 1978 that is visited by the same child under age six for at least 3 hours per day, or at least 6 hours per week, or at least 60 hours per year. This includes common areas routinely used by the children under age 6 (i.e, restrooms, cafeterias), and adjacent exterior areas.
Other major points she covered were:
  • Delead test kit added to the list of EPA approved test kits. The test kits must be used according to the manufacturer’s directions including materials that the test kits cannot be used on.
  • Lead Based Paint Abatement Contractors require RRP Renovator Certification. Previous certification as a worker/supervisor allows the person to take the ½ day refresher class to become a renovator.
  • Lead Waste – residential (homeowners & contractors) can dispose of lead waste bags with household waste. COFs must follow the hazardous waste regulations.
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