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Renovation Repair Painting Program Rule. Jim Copeland Compliance Officer Healthy Homes Section Phone: (517) 241-6486 Fax: (517) 335-8800 copelandj3@michigan.gov. Renovation Repair Painting Program Rule . 40 CFR Part 745 Subpart E (Residential Property Renovation) (epa.gov/lead).

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Renovation Repair Painting Program Rule

Jim Copeland

Compliance Officer

Healthy Homes Section

Phone: (517) 241-6486

Fax: (517) 335-8800

copelandj3@michigan.gov


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Renovation Repair Painting Program Rule

40 CFR Part 745

Subpart E

(Residential Property Renovation)

(epa.gov/lead)


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WHY NOW?

  • In 1992 Congress passed the "Residential Lead-Based Paint Hazard Reduction Act (“Title X”) and expected EPA to promulgate rules within 4 years (1996) that would govern renovation and remodeling activities to minimize the creation of lead dust. These rules were completed in 2008!

  • Studies show that typical renovations create substantial amounts of dust. In pre-1978 homes this creates occupant exposure to lead based paint. Approximately 41% of children under the age of 6 who have EBL’s, live in homes that were renovated within the previous year.

  • Studies show that typical clean-up methods i.e. dust pan and broom and vacuuming are ineffective at removing existing lead dust and lead dust created during construction activity.

  • Studies show that RRP cleaning practices significantly lower interior lead levels at the end of the job as compared to baseline cleaning practice of broom, dust pan and shop vac(Dust study)


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US medical authorities diagnose childhood lead poisoning

France, Belgium, and Austria ban “white-lead” interior paint

Pediatric lead-paint poisoning death from eating crib paint is described

League of Nations bans white-lead interior paint; US declines to adopt

1887

1909

1914

1921


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Tunisia and Greece ban white-lead interior paint lead poisoning

Czechoslovakia bans lead-based paint

Great Britain and Sweden ban white-lead interior paint

Poland bans white-lead interior paint

1922

1924

1926

1927


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Spain and Yugoslavia ban white-lead interior paint lead poisoning

Cuba bans lead paint

Lead-Based Paint Poisoning Prevention Act passed

USA bans lead-based paint for residential use; CPSC limits lead content to 0.06%

1931

1934

1971

1978


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CDC SURVEY CONDUCTED FROM 2001-2004 SHOWED 250,000 KIDS AGES 1-5 HAD BLOOD LEAD LEVELS OF 10 MG/DL OR HIGHER…..DOWN FROM 4.7 MILLION CHILDREN IN 1978!!


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Lead effects brain development 1-5 HAD BLOOD LEAD LEVELS OF 10 MG/DL OR HIGHER…..DOWN FROM 4.7 MILLION CHILDREN IN 1978!!

The Cincinnati Lead Study

Cecil KM, Brubaker CJ, Adler CM, Dietrich KN, Altaye M, et al. (2008) Decreased brain volume in adults with childhood lead exposure. PLoS Med 5(5): e112. doi:10.1371/ journal.pmed.0050112


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ENVIRONMENTAL FIELD SAMPLING STUDY RESULTS 1-5 HAD BLOOD LEAD LEVELS OF 10 MG/DL OR HIGHER…..DOWN FROM 4.7 MILLION CHILDREN IN 1978!!

  • STUDY SHOWED THAT THE FOLLOWING ACTIVITIES CREATED DUST THAT COULD MIGRATE UP TO 6FT FROM WORK SURFACE

    • ABRASIVE SANDING TO REMOVE PAINT

    • WINDOW REPLACEMENT

    • HVAC DUCT WORK

    • DEMOLITION OF INTERIOR PLASTER

    • DRILLING INTO WOOD

    • SAWING WOOD

    • SAWING PLASTER


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WHAT IS RRP? 1-5 HAD BLOOD LEAD LEVELS OF 10 MG/DL OR HIGHER…..DOWN FROM 4.7 MILLION CHILDREN IN 1978!!

  • SCOPE

  • Amends Title 40 of the Code of Federal Regulations Part 745 (40 CFR 745)

    • A federal regulatory program affecting contractors, rental property owners and managers and anyone else that disturbs painted surfaces in pre-1978 units; this rule primarily impacts remodeling/home improvement contractors and rental property owners

    • It applies to housing, apartments and child occupied facilities

    • This law presumes the presence of lead in paint unless proven otherwise

  • The Rule is made up of four basic parts:

    • Requires education of owners and occupants of “Target Housing” before work begins

    • Requires firms conducting renovations on target housing to be certified and to use a certified renovator

    • Requires lead safe work standards and practices be performed in order to pass clearance

    • Requiresadequate enforcement

  • The intent of the rule is NOT to require clean-up of existing contamination


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When is RRP Required? 1-5 HAD BLOOD LEAD LEVELS OF 10 MG/DL OR HIGHER…..DOWN FROM 4.7 MILLION CHILDREN IN 1978!!

  • For all renovations that disturb painted surfaces. Renovations include; removal, modification or repair including surface preparation. Renovation does not include minor repair and maintenance activities that disturb 6 square feet or less of painted surface per room for interior activities or 20 square feet or less for exterior activities.

  • Renovations for compensation

  • All pre 1978 homes and child occupied facilities


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WHO IS IN CHARGE? 1-5 HAD BLOOD LEAD LEVELS OF 10 MG/DL OR HIGHER…..DOWN FROM 4.7 MILLION CHILDREN IN 1978!!

  • Right now the EPA is administering and enforcing the Rule

  • EPA wants States to Administer this Rule

  • Michigan is in the process of amending the current Lead Abatement Act to include Lead Abatement and Renovation. When approved the Healthy Homes Section will administer the RRP Rule.


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BALANCING THE LAW 1-5 HAD BLOOD LEAD LEVELS OF 10 MG/DL OR HIGHER…..DOWN FROM 4.7 MILLION CHILDREN IN 1978!!

Abatement vs. Renovation


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“I AM A CONTRACTOR, WHAT SHOULD I BE DOING NOW” 1-5 HAD BLOOD LEAD LEVELS OF 10 MG/DL OR HIGHER…..DOWN FROM 4.7 MILLION CHILDREN IN 1978!!

  • DISTRIBUTE THE CORRECT PAMPHLET!!

  • The old blue pamphlet no longer applies to renovations

  • Maintain a record proving that you provided the pamphlet “when in doubt hand it out!”

  • Get training – become Certified Renovator

  • After Oct 22, 2009 apply to become certified firm


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IMPORTANT DATES 1-5 HAD BLOOD LEAD LEVELS OF 10 MG/DL OR HIGHER…..DOWN FROM 4.7 MILLION CHILDREN IN 1978!!

  • After October 22, 2009 firms can start applying for EPA certification to conduct renovations in Target Housing

  • Our website will list names of training providers

  • Effective April 22, 2010 the entire rule becomes effective – training, certification and work practice requirements

    • Must be a certified firm

    • Must employ a certified renovator to oversee and manage the project

    • Must employ lead safe work practices

    • Must properly clean and clear the work area

    • Must maintain records


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“WHEN WILL THE STATE TAKE OVER?” 1-5 HAD BLOOD LEAD LEVELS OF 10 MG/DL OR HIGHER…..DOWN FROM 4.7 MILLION CHILDREN IN 1978!!

  • Changes to the Act will take about 9-12 months

  • EPA will be in charge until then

  • Once the State takes over…..

    • You will need to obtain Firm Certification

      • Note: the renovator firm Certification fee is waived if you are already a Certified Lead Abatement firm

    • You will need to become a Certified Renovator

    • Enforcement will be conducted by the State

      • Note: EPA wants strict enforcement of this Rule

    • Training and education will be conducted during implementation of this Rule


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WORK PRACTICE STANDARDS 1-5 HAD BLOOD LEAD LEVELS OF 10 MG/DL OR HIGHER…..DOWN FROM 4.7 MILLION CHILDREN IN 1978!!

  • POST SIGNS TO DEFINE THE WORK AREA

  • CONTAIN THE WORK AREA SO NO DUST OR DEBRIS LEAVES THE WORK AREA

  • REMOVE OBJECTS FROM THE WORK AREA OR COVER

  • CLOSE WINDOWS AND DOORS

  • COVER THE FLOOR

  • USE PRECAUSTIONS TO ENSURE THAT PERSONNEL, TOOLS AND OTHER ITEMS ARE FREE OF DUST AND DEBRIS BEFORE LEAVING THE WORK AREA.

  • POST RENOVATION CLEANING AND CLEARANCE


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Set It Up Safely 1-5 HAD BLOOD LEAD LEVELS OF 10 MG/DL OR HIGHER…..DOWN FROM 4.7 MILLION CHILDREN IN 1978!!

Signs

Barrier tape

Plastic on floors and over registers, furniture etc

Flaps to cover doorways

Minimize the Dust

High Efficiency Particulate Air (HEPA) vacuum cleaner (a special vacuum cleaner that can remove very small particles from floors, window sills, and carpets) If purchasing a HEPA vac be sure it meets ASTM standard F1977 or EN standard 1822 or it states unit is a “sealed” unit. HEPA vacs need stronger motors, many vacs say they are HEPA but do not meet EPA regs!!

Prohibited Practices

- open flame burning or torching

- machines that remove paint by high speed operation – power washing

- heat gun above 1100 degrees

- dry sanding or dry scraping

- paint stripping in poorly ventilated areas or using prohibited strippers


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RUNS BETTER UNLEADED 1-5 HAD BLOOD LEAD LEVELS OF 10 MG/DL OR HIGHER…..DOWN FROM 4.7 MILLION CHILDREN IN 1978!!


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CONTACT INFO 1-5 HAD BLOOD LEAD LEVELS OF 10 MG/DL OR HIGHER…..DOWN FROM 4.7 MILLION CHILDREN IN 1978!!

  • STEVE M SMITH

  • (616) 240-3926

  • STEVEMSMITH@PEOPLEPC.COM

  • SMITHS@MICHIGAN.GOV


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