EPA Repair, Renovation, & Painting Rule: An Overview
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EPA Repair, Renovation, & Painting Rule: An Overview. Background. New EPA regulation will require use of certified contractors and lead safe work practices in most pre-1978 residences and child-occupied properties starting April 2010 Some 236,000 individuals need 8-hour training

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Background l.jpg
Background

  • New EPA regulation will require use of certified contractors and lead safe work practices in most pre-1978 residences and child-occupied properties starting April 2010

  • Some 236,000 individuals need 8-hour training

    • Subordinate workers’ training

www.afhh.org


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Why is lead a problem?

  • Critical health issue for young children

  • High levels of lead can result in anemia, hearing loss, GI discomfort, and even encephalopathy, seizures, coma and death

  • Lower, more typical levels, affect neurological development

  • Strong associations between even very low levels of lead as child and IQ later in life

  • Linked to behavioral and learning difficulties

  • Damage is essentially permanent – preventing exposure is crucial

www.afhh.org


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Lead is bad for adults, too

  • Increased chance of miscarriage, complications during pregnancy

  • Fertility problems (men and women)

  • High blood pressure

  • Neurological disorders

  • Memory and concentration problems

  • Potential cancer risks

www.afhh.org


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“Lead Paint: Delicious but Deadly”

  • Pica, while dangerous, is NOT primary source of poisoning

  • Dust from paint accumulates on floors, window sills and sticks to hands and toys which are mouthed

  • Household dust is most important contributor to childhood poisoning

  • Other sources have gotten significant press recently, and they need to be addressed, but are responsible for very few cases

www.afhh.org


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Lead & Housing

  • 24 million U.S. homes have significant lead-based paint hazards

  • 38 million have some lead-based paint

  • Age dependent: 87% of pre 1940, 69% of 1940-1959, and only 24% of 1960-1978 housing has lead (lead banned in 1978)

  • Rental & low-income properties more likely to have hazards

www.afhh.org


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Regulating Lead in Housing (I)

  • Federal strategy based on Residential Lead-based Paint Hazard Reduction Act of 1992 (Title X)

  • Professionalized lead inspection, risk assessment, and abatement work – ensures actions taken with intention of addressing lead are safe and successful by training and testing all abatement workers and mandating strict gov’t oversight

  • Requires disclosure of known lead paint and lead hazards to buyers and tenants (1018) and provision of lead information to occupants prior to renovation (406(b) – pre-renovation education rule)

www.afhh.org


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Regulating Lead in Housing (II)

  • HUD’s Lead Safe Housing Rule (1012/1013) requires varying degrees of action to address lead in federally assisted properties; HUD also provides limited lead abatement grants

  • Result: abatement done well, but abatement is infrequent in private housing

  • No requirement to look for lead hazards, address lead hazards when found, or prevent creation of lead hazards in private housing

  • Lead never became integrated into mainstream (although some localities have done better)

www.afhh.org


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The Need to Address Renovation

  • Beyond 406(b) notifications, Title X instructed EPA to regulate lead hazards produced by renovation

  • Disturbing lead-based paint generates lead dust – can poison children during or after renovation – even poison workers’ children

  • EPA studied the issue and found hazards created during renovation

www.afhh.org


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EPA’s Renovation, Repair, and Painting Rule (RRP)

  • On March 31, 2008, EPA issued a final rule to address lead-based paint hazards created by renovation,

    repair, and painting activities

    that disturb lead-based paint in

    “target housing” and

    “child-occupied facilities.”

www.afhh.org


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Rule Scope

  • Covers renovation, repair and painting activities that disturb painted surfaces in:

    • Target housing, which is housing constructed before 1978 except:

      • housing for elderly or persons with disabilities (unless any child younger than 6 resides or is expected to reside); or

      • any zero-bedroom dwelling.

    • Child-occupied facilities

      • Buildings built before 1978 that are frequented by children under age 6.

      • Includes kindergartens and child care centers.

www.afhh.org


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RRP Rule Exclusions

Excludes:

  • Renovations affecting only components that are free of lead-based paint

    • Determination by certified inspector/risk assessor or certified renovator using an EPA-approved test kit

  • Minor repair and maintenance:

    • 6 ft2 or less per room interior, 20 ft2 exterior.

    • No exemption for prohibited practices, window replacement, or demolition of painted surfaces

  • Renovations performed by homeowners in their own homes

www.afhh.org


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Exclusion of Childless Owner-Occupied Units

Opt-out provision:

  • Homeowners may opt out of the rule’s requirements if they occupy the housing to be renovated, the housing is not a child-occupied facility, and no child under age 6 or pregnant woman resides there.

  • To qualify for opt-out, homeowner must provide the renovation firm with a signed statement.

  • Opt-out does not affect the Pre-Renovation Education Rule requirement (renovation firms provide a lead hazard information pamphlet before beginning work).

www.afhh.org


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Pre-Renovation Education

  • Existing education regulation expanded to cover child-occupied facilities.

  • New “Renovate Right” brochure developed for all covered renovations.

  • Only new brochure may be used for PRE.

  • The old “Protect Your Family” brochure is still used for other purposes like real estate disclosure and general outreach.

www.afhh.org


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CertificationFirms

  • All covered renovations must be performed by certified renovation firms, using certified renovators and other trained workers.

  • To become certified, firms must submit an application and fee to EPA (fee to be determined)

  • Certifications will be good for 5 years.

  • Certification allows the firm to perform renovations in any non-authorized State or Indian Tribal area.

www.afhh.org


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CertificationIndividuals

  • Covered renovation activities must be performed and/or directed by a certified renovator.

  • To become a certified renovator, an individual must take an 8-hour training course from an accredited training provider.

  • The course completion certificate serves as certification (no application to EPA is required).

  • Refresher training is required every 5 years.

  • Other workers do not need certification,

    but they must receive on-the-job training from

    a certified renovator.

  • Certification allows the renovator to perform

    renovations in any non-authorized state or

    Indian tribal area.

www.afhh.org


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Accredited Trainers

  • Trainers must submit an application and fee to EPA

  • Trainers must be re-accredited every 4 years.

  • Accreditation procedures are the same as those for lead abatement training.

  • Course must last a minimum of 8 hours, with 2 hours devoted to hands-on training.

  • EPA is updating model courses.

  • Training providers must notify EPA of individuals who complete training and provide photos.

  • EPA accreditation allows the trainer to conduct training in any non-authorized State or Indian Tribal area.

www.afhh.org


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Work Practice StandardsGeneral

  • Post signs defining the work area.

  • Contain the work area so that no visible dust

    or debris can leave the area.

    • All HVAC ducts, countertops, floors, andobjects left in the work area must becovered with taped-down protectivesheeting.

  • Certain practices are prohibited:

    • open-flame burning or torching

    • machines that remove lead-based paint through high speed operation such as sanding, grinding, power planing, needle gun, abrasive blasting, or sandblasting, unless such machines are used with HEPA exhaust control

    • operating a heat gun above 1100 degrees Fahrenheit

www.afhh.org


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Work Practice StandardsCleaning

  • After the renovation has been completed, the firm must clean the work area until no visible dust, debris or residue remains.

    • Pick up all paint chips and debris.

    • Remove all protective sheeting.

    • Dispose of paint chips, debris and

      sheeting as waste.

www.afhh.org


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Work Practice StandardsCleaning Verification

  • Certified renovator must wipe windowsills, countertops, and uncarpeted floors in work area with wet disposable white cleaning cloths.

  • These cloths must be compared to a cleaning verification card.

  • If the cloth matches or is lighter than the card, that surface has passed the cleaning verification.

  • Surfaces that do not pass the first attempt must be re-cleaned.

  • Surfaces that do not pass on the second attempt must be allowed to dry and wiped with a white electrostatic (dry) cleaning cloth.

  • Dust clearance testing may be performed instead, if the renovation contract or another law or regulation requires the firm to achieve clearance standards.

www.afhh.org


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Recordkeeping and Enforcement

  • Documents demonstrating compliance with the rule must be retained for 3 years following the completion of a renovation.

    • Pamphlet acknowledgment forms, owner opt-out forms, and documentation of work practices

  • EPA may suspend, revoke, or modify a firm’s certification if firm is found to be in non-compliance.

  • Non-compliant contractors may be liable for civil penalties

    of up to $25,000 for each violation.

  • Contractors who knowingly or willfully violate this

    regulation may face fines up to an additional

    $25,000 per violation, or imprisonment, or both.

  • Alliance believes local adoption and enforcementwill be critical to success of rule

www.afhh.org


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State Adoption

  • States, Territories, and Tribes may obtain authorization to administer and enforce their own RRP programs (instead of the EPA).

  • EPA will authorize programs that are at least as protective as the final RRP rule – states may be more protective than the rule

  • EPA will begin implementation of the Federal program in all non-authorized areas in April 2009; states may take over at any point and will assume all aspects of the rule (certifications, fees, etc.)

  • Alliance is encouraging states to add clearance requirements, onsite supervision, and fewer exemptions

www.afhh.org


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Important Dates

  • June 2008:

    • States and tribes may begin applying for authorization

    • PRE (406(b)) applies to child-occupied facilities

    • Some restrictions apply to unaccredited training programs

  • December 2008:

    • “Renovate Right” brochure must be used for the PRE

  • April 2009:

    • EPA begins administering program in unauthorized states

    • Training providers may begin applying for accreditation

  • October 2009:

    • Renovation firms may begin applying for certification

  • April 2010:

    • Renovation firms must be certified

    • Renovators and dust sampling technicians must be certified

    • Workers must be trained

    • Work practices must be followed

www.afhh.org


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Contractor Training

  • A certified Renovator must be assigned to each job and be present for set-up and clean-up

  • EPA estimates that 236,000 individuals will need the 8-hour class before the rule goes into effect, and 47,000/year will need training thereafter

  • General renovators, window replacement contractors, painting contractors likely to be largest groups – specialty trades do not need certifications if working under certified GC

  • Typical participant: minimal lead experience

www.afhh.org


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Optional Participants

  • Unlike for abatement jobs, EPA limited formal training requirement to single “supervisor” due to staff turnover and training cost concerns

  • Certified renovator is responsible for instructing others at work site in RRP requirements

  • Firms may find it advantageous to train larger numbers of workers to ensure compliance and increase flexibility in job assignments

  • Individual workers may find it worthwhile to obtain training to increase their marketability

  • Alliance recommends widest possible training

www.afhh.org


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Training Curriculum

  • Curriculum used by accredited trainers must be approved by EPA

  • Trainings must be minimum of eight hours, include two hours of hands-on activities

  • Required content includes background on Pb, review of regulations, test kit use, work practices, containment, clean-up, clearance/cleaning verification, waste disposal, OTJ training delivery, and record keeping

  • Hands-on requirements limit distance learning

  • Process to get new curricula approved is cumbersome

www.afhh.org


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EPA Model Curriculum

  • “Model” curriculum is pre-approved by EPA – trainers using it will avoid the curriculum approval process

  • The model is based upon the HUD/EPA joint LSWP training widely used for HUD LSHR compliance

  • The model will be available in English & Spanish – other translations require EPA approval

www.afhh.org


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Model Curriculum Contents

  • Eight modules

  • Twelve hands-on exercises are included, each with several “required skills” for which the student must be judged proficient

  • Students must pass a test

www.afhh.org


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Grandfathered & Refresher Training

  • Certified Renovators must take 4 hour refresher class every 5 years

  • Lead abatement workers/supervisors, and those having previously taken eight hour LSWP class, may take refresher class in lieu of 8 hour class to become a renovator

  • Content requirements for refresher are the same and it must include hands-on and a test

  • Model refresher to be developed – will be a challenge to cover it all!

www.afhh.org


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www.Healthy Homes Collaborative.org

Linda Kite

Executive Director

213-689-9170 x 106

617 S. Olive St. Suite 810

Los Angeles, CA 90014

[email protected]

www.afhh.org


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