EPA Lead Based Paint RRP Training Certification

The article below was published in the November/December of the Kentucky Builders Journal (www.HBAK.com).

Are you working on a home renovation, repair or painting project?
Does the project involve a home built before 1978?

About half of homes built before 1978 have lead-based paint. The likelihood of finding lead-based paint increases with the age of the home:

-Two out of three of homes built between 1940 and 1960 have lead-based paint.
-Nine out of ten homes built before 1940 have lead-based paint.

Beginning April 2010, federal law will require contractors that are hired to perform renovation, repair and painting projects in homes, child care facilities, and schools built before 1978 that disturb lead-based paint to be certified and follow specific work practices to prevent lead contamination. Failure to follow the rule can result in severe civil penalties and other unpleasantness. And by severe civil penalties, it could mean fines of up to $37,500 per day per violation, not to mention exposure to civil liability actions with treble damages.

You need to know how to work safely with lead-based paint. Lead safe work practices are a group of techniques that reduce the amount of dust produced by renovation activities. When used correctly, they make the work area safer for workers and the home safe for residents when renovation is complete. Following lead safe work practices will allow you to:

• Set up the job safely;
• Minimize the creation of dangerous lead dust; and
• Leave the work area clean and safe for residents after completing the job.

Conduct Lead Testing Before and/or After the Work is Performed. Pre-job testing can identify any lead paint in the home and allow workers to target lead safe work practices to the areas where there is lead paint. Using the cleaning verification procedure or clearance testing at the end of the job ensures that no dust has been left behind.

The RRP rule affects contractors, property managers and others who disturb known or presumed lead-based paint during renovation. The term renovation covers all activities done for compensation that disturb painted surfaces including most repair, remodeling and maintenance activities, such as window replacement, weatherization and demoli¬tion. The RRP rule applies to all renovation work performed in residential houses, apartments and child-occupied facilities such as schools and day-care centers built before 1978. Those affected by the RRP rule should read the complete rule, which is available on EPA’s Web site at: http://www.epa.gov/lead/pubs/renovation.htm.

The following is from an article by Jon Chandler, CEO of the Oregon Home Builders.  If you haven’t thought that this is serious you will after reading this.

• On or after April 22, 2010, no firm may perform, offer, or claim to perform renovations without certification from EPA under §745.89 in target housing or child-occupied facilities, unless the renovation qualifies for one of the exceptions identified in §745.82(a) or (c).
o As a side note, I’m told that EPA has indicated that they will be monitoring contractor advertising in the yellow pages, online, and on services such as Craig’s List or Angie’s List as part of their enforcement strategy. Not good.

• On or after April 22, 2010, all renovations must be directed by renovators certified in accordance with §745.90(a) and performed by certified renovators or individuals trained in accordance with §745.90(b)(2) in target housing or child-occupied facilities, unless the renovation qualifies for one of the exceptions identified in §745.82(a) or (c).

• Renovation means the modification of any existing structure, or portion thereof, that results in the disturbance of painted surfaces, unless that activity is performed as part of an abatement as defined by this part (40 CFR 745.223). The term renovation includes (but is not limited to): The removal, modification or repair of painted surfaces or painted components (e.g., modification of painted doors, surface restoration, window repair, surface preparation activity (such as sanding, scraping, or other such activities that may generate paint dust)); the removal of building components (e.g., walls, ceilings, plumbing, windows); weatherization projects (e.g., cutting holes in painted surfaces to install blown-in insulation or to gain access to attics, planning thresholds to install weather-stripping), and interim controls that disturb painted surfaces. A renovation performed for the purpose of converting a building, or part of a building, into target housing or a child-occupied facility is a renovation under this subpart. The term renovation does not include minor repair and maintenance activities.

• The required training is an 8 hour class.  The first 6 hours can be done in a group setting with the remaining 2 hrs in a 6:1 ratio.  Kentucky Home Builders & Remodelers with this limited ratio it is imperative that you plan for your training.  Class space will be very limited especially as we get closer to April 2010!  Please make your plans to receive certification now!

Many of Kentucky’s Local HBA’s will be planning classes to meet these EPA requirements.  Watch for this information in your local association’s newletters.

Access Additional Resource Materials. The National Lead Information Center can also provide copies of the following general reference and how-to guidance materials: 

• Renovate Right: Important Lead Hazard Information for Families, Child Care Providers and Schools (EPA-740-F-08-002, March 2008). http://www.epa.gov/lead/pubs/renovaterightbrochure.pdf
• Small Entity Compliance Guide to Renovate Right: A Handbook for Contractors, Property Managers and Maintenance Personnel Working in Homes, Child Care Facilities and Schools Built Before 1978. (EPA-740-F-08-003, December 2008). http://www.epa.gov/lead/pubs/sbcomplianceguide.pdf
• Contractors: Lead Safely During Renovation (EPA 740-F-08-001, March 2008). This short pamphlet provides a quick summary of general information on lead safe work practices to contain, minimize and clean up dust. http://www.epa.gov/lead/pubs/contractor_brochure.pdf
• Lead Paint Safety: A Field Guide for Painting, Home Maintenance, and Renovation Work (HUD-1779-LHC, March 2001). This guide gives step-by-step instruction on lead safe work practices for different jobs in the home. http://www.hud.gov/offices/lead/training/LBPguide.pdf