EPA Region 2 Coordinator Discusses the RRP Rule

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 http://futureenvironmentdesigns.com/news.html 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.

Related articles

• Hofstra is Hosting an Information Session on EPA's Lead RRP Law. (futureenv.blogspot.com)
• EPA's Local Coordinator for the Lead Paint Rule at Hofstra University (futureenv.blogspot.com)
• EPA / Mass DOS Renovation, Repair and Painting (RRP) Safe Practices (unitedallianceservices.typepad.com)
• Restoration & Remediation Magazine - The RRP Rule: One Year Later (futureenv.blogspot.com)
• Girlfriends Talking: Lead Renovations in Older Homes (epa.gov)

New Lead Paint Regulation Goes Into Effect - Happy Earth Day!

Image by wayneandwax via Flickr

Today is the 40th Birthday of Earth Day.  To celebrate the occasion, the Environmental Protection Agency's (EPA) Lead Based Paint (finalized in April 2008) regulation goes into effect today.  The regulation we are talking about is the Renovation, Repair and Painting (RRP) rule.  The purpose of this rule is prevent lead poisoning of children.  Starting today anyone who is paid to perform work that disturbs paint in housing and child-occupied facilities built before 1978, including all general contractors, maintenance staff, and special trade contractors (such as painters, plumbers, carpenters, and electricians), are required to be trained on lead-safe work practices (become certified renovators), requires the firms to be EPA-certified, and requires the use of lead-safe work practices.  In addition, the regulation requires the firms to keep records for three years of reports certifying that lead-based paint is not present, records relating to the distribution of the lead pamphlet, signed and dated opt-out clauses, and documentation of compliance with RRP.  These regulations do not apply if the firm obtained a signed statement from the owner (known as the opt-out provision) or the work is considered a minor repair and maintenance activitiy that disturb six square feet or less of paint per room inside, or 20 square feet or less on the exterior of a home or building.  The rule require firms performing renovations must ensure that:

• All individuals performing activities that disturb painted surfaces 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 use lead safe work practices.
• Pre-renovation education requirements are performed, such as distribution of the Renovate Right pamphlet.
• Recordkeeping requirements are met.

Violators of this regulation can face penalties of up to $32,500 per violation, per day.  Needless to say if you have not taken this training and applied for EPA certification you cannot perform renovation work on housing or child-occupied facilities until you get your certification.  EPA has up to 90 days after receiving a complete request for certification to approve or disapprove the application.  EPA has said "it does not intend to take enforcement actions against firms who applied for firm certification before April 22 and are just waiting for their paperwork."  EPA also said "they anticipate that all applications filed before April 22 will be reviewed by June."  Based on EPA's website they estimate there are 129,000 to 150,000 trained certified renovators by today.  It would seem those certified renovators are going to be very busy. 

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