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)

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.

Related articles

• Hofstra is Hosting an Information Session on EPA's Lead RRP Law. (futureenv.blogspot.com)
• Massachusetts DOS and EPA Begins Enforcement of Lead RRP (unitedallianceservices.typepad.com)
• EPA's Local Coordinator for the Lead Paint Rule at Hofstra University (futureenv.blogspot.com)

AIHA Registry Programs Launches New Program For XRF Field Measurement Registry

Peeling lead-based paint is an indicator that lead dust may be on the floor and surfaces

The American Industrial Hygiene Association (AIHA) Registry Programs LLC officially launched on January 18, 2011 a new registry program for X-ray fluorescence (XRF) Field Measurement.  The XRF Field Measurement Registry (FMR) program allows participants to use their registration status for in-situ XRF measurements.  This registry program does not address accreditation required for recognition by the Environmental Protection Agency (EPA) under the National Lead Laboratory Accreditation Program (NLLAP) as required at 40 CFR Part 745 for environmental lead analyses.
The FMR program is designed to recognize organizations and their affiliated operators that perform in-situ XRF measurements of lead paint surface coatings in the field.  The program maintains minimum standards of conduct for all FMR participants through adherence to the programs policies and registration process.
The FMR program will provide:

• Connections – clients, customers, and employers can find or hire the right kind of professional
• Consistency -- standardization of processes and methods across state lines and country borders
• Continuous improvement – a venue for collaboration and sharing of best practices

The FMR program will raise the competency bar through recognition of high quality organizations and their affiliated operators.  Registries help assure a level of quality among professionals and confidence among regulators and consumers who are looking to identify and then properly control or remove potential health hazards to workers and occupants of buildings.
Registered organizations and enrolled operators perform in-situ field measurements of lead surface coatings utilizing an XRF.  Registered organizations have met the qualifications for inclusion on the registry: personnel training, adherence to an established and documented quality system that is based on the most current version of the FMR Policy.  All enrolled operators must be affiliated with an FMR Registered organization that oversees the Quality Assurance and Quality Control program that monitors the operator and be properly trained and licensed for the work to be performed.
For general information and information detailing the registry program and processes, please visit the web site: http://www.aiharegistries.org/.  For specific inquiries, contact the AIHA Registry Program at info.RegistryLLC@aiha.org.

Related articles

• AIHA Survey Indicates Issues That Concern Industrial Hygiene Profession (futureenv.blogspot.com)
• A Mom Tests Toys for Toxins, Helping to Get the Lead Out (health.change.org)
• BESI Offers First X-Ray Fluorescence (XRF) Certification for Gypsum Products (pr.com)

EPA Revises Lead Ambient Air Monitoring Requirements



Air Quality Testing for several parameters.

On December 14, 2010, the Environmental Protection Agency (EPA) published the final lead (Pb) ambient air monitoring requirements.  The purpose of this revision was to expand the nation’s lead monitoring network to better assess compliance with the revised National Ambient Air Quality Standards (NAAQS) for lead issued in 2008.  In 2008, EPA substantially strengthened the lead NAAQS by revising the level of the primary (health-based) standard from 1.5 micrograms per cubic meter (μg/m3) to 0.15 μg/m3, measured as total suspended particles (TSP).  The agency revised the secondary (welfare-based) standard to be identical to the primary standard.  EPA in this final rule (Dec. 2010) also changed the emission threshold that state monitoring agencies (such as New York State Department of Environmental Conservation [NYS DEC]) must use to determine if an air quality monitor should be placed near an industrial facility that emits lead. The new emission threshold is 0.5 tons per year (tpy), reduced from the previous threshold of 1.0 tpy. Any new monitors located near an emissions source must be operational no later than one year after this rule is published in the Federal Register.  EPA maintained a 1.0 tpy lead emission threshold for airports.  However, EPA is requiring a 1-year monitoring study of 15 additional airports (beyond those currently required to monitor at the existing 1.0 tpy emission threshold) for the New York area this includes Brookhaven and Republic airports. The study will help EPA determine whether airports that emit less than 1.0 tpy have the potential to cause the surrounding areas to exceed the lead NAAQS of 0.15 micrograms per cubic meter (μg/m3).  The monitors participating in the study must be operational no later than one year after this rule is published in the Federal Register.
EPA is also requiring lead monitoring in large urban areas (Core Based Statistical Areas, or CBSAs, with a population of 500,000 people or more).  Monitors will be located along with multi-pollutant ambient monitoring sites (known as the “NCore network”).  Lead monitoring at these sites will begin January 1, 2012.

• The NCore network will consist of approximately 80 monitoring sites, of which 63 will be in large urban areas.  The requirement to add these monitors replaces an existing requirement to place lead monitors in each CBSA with a population of 500,000 or more people.

The above revisions were made based on comments received on EPA’s proposed revisions.

Related articles

• "EPA to study 15 airports for lead levels" and related posts (generalaviationnews.com)
• The Environmental Protection Agency's End-Run Around Democracy (pajamasmedia.com)
• Pennsylvania DEP Secretary Announces Progress Made in Achieving Cleaner Air (prnewswire.com)
• "EPA Identifies Areas Violating Lead Standards" and related posts (aaenvironment.blogspot.com)
• More Protections to Keep Children Safe From Lead (doyourpart.com)
• EPA Announcement on Lead Pollution Monitoring is a Holiday Message to Children: We're Watching Out For You! (switchboard.nrdc.org)
• Major U.S. Cities Violate New EPA Lead Standards (scientificamerican.com)