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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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EPA Repair, Renovation, & Painting Rule: An Overview

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  • 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

why is lead a problem
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

lead is bad for adults too
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


“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

lead housing
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

regulating lead in housing i
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)

regulating lead in housing ii
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)

the need to address renovation
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

epa s renovation repair and painting rule rrp
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.”

rule scope
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.

rrp rule exclusions
RRP Rule Exclusions


  • 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

exclusion of childless owner occupied units
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).

pre renovation education
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.

certification firms
  • 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.

certification individuals
  • 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.

accredited trainers
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.

work practice standards general
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

work practice standards cleaning
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.

work practice standards cleaning verification
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.

recordkeeping and enforcement
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

state adoption
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

important dates
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

contractor training
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

optional participants
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

training curriculum
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

epa model curriculum
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

model curriculum contents
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

grandfathered refresher training
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 healthy homes collaborative org
www.Healthy Homes

Linda Kite

Executive Director

213-689-9170 x 106

617 S. Olive St. Suite 810

Los Angeles, CA 90014