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Community Development

Community Development. January 29, 2014. EPA Renovation, Repair and Painting Rule (RRP Rule). Overview of the EPA Renovation, Repair and Painting Rule (RRP Rule) as it relates to the HUD Lead Safe Housing Rule and Renovations/Repairs. Authorization.

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Community Development

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  1. Community Development January 29, 2014

  2. EPA Renovation, Repair and Painting Rule (RRP Rule) Overview of the EPA Renovation, Repair and Painting Rule (RRP Rule) as it relates to the HUD Lead Safe Housing Rule and Renovations/Repairs

  3. Authorization For a State to become authorized, it must be at least as protective as EPA CT is not authorized to administer or enforce RRP rule CT DPH Provides: • Compliance assistance • Education/outreach • Awareness training

  4. Who Must Follow the Lead Rule’s Requirements? Examples: Residential rental property owners Painters Home Improvement Contractors Renovators & Remodelers Carpenters School Administrators Daycare Owners/Operators Finishing Workers Property Managers Maintenance Staff Electricians and Plumbers Window Replacement Firms And Many Others……

  5. What Activities Are Subject to the RRP Rule? Remodeling and repair/maintenance, electrical work, plumbing, carpentry, etc., (for payment) that disturbs: • > 6 square feet of interior painted surfaces (per room) during projects on housing and child occupied facilities built pre-1978 • > 20 square feet of painted exterior surfaces during projects on housing and child occupied facilities built pre-1978 • Any window replacement (also pre-1978)

  6. Exclusions • Housing built after 1977 • Certified lead free housing • Lead abatement projects • Full demolitions • Housing for the elderly or disabled unless a child under 6 resides or is expected to reside there. • Zero-bedroom dwellings (studio apts., dorms). • Minor repair/maintenance • Emergency renovations

  7. HUD’s Lead Safe Housing Rule • HUD’s Lead Safe Housing Rule (LSHR) is found in HUD’s regulations at 24 CFR Part 35, Subparts B through M • Generally applies to work performed in target housing units receiving: • HUD housing assistance • Rehabilitation assistance • Acquisition assistance • Under LSHR, the program participant (person accepting funding) becomes responsible for compliance with federal laws

  8. HUD’s Lead Safe Housing Rule • Stages of the Job • Planning and Set-up • During the Job • End of Job

  9. HUD’s Lead Safe Housing Rule • Planning and Set-up • Renovators/renovation firms must be certified • Renovators/renovation firms must complete curriculum in lead safe work practices • RRP course is HUD-approved • All workers and supervisors must complete a HUD approved lead safe work practice course • Renovators must hand out “Protect Your Family from Lead in Your Home” brochure • Renovators should hand out “Renovate Right” brochure

  10. Protect Your Family brochure

  11. EPA Renovate Right brochure

  12. HUD’s Lead Safe Housing Rule • During the Job • HUD requires lead hazards be treated using interim controls or ongoing lead-based paint maintenance • Prohibited practices • EPA Prohibited Practices • Open flame burning or torching • Heat guns above 1100 degrees F (in CT 700 degrees F) • Machine removal without HEPA vacuum attachment • HUD Prohibited Practices • Dry scraping or sanding farther than 1 foot of electrical outlet • Volatile stripper in poorly ventilated space ** MUST FOLLOW ALL PROHIBITED PRACTICES **

  13. HUD’s Lead Safe Housing Rule • During the Job • Threshold minimum amount of interior paint disturbance • HUD has a lower “de minimus” than EPA • HUD’s interior • Threshold is 2 square feet per room • 10% of small components • HUD’s exterior • Threshold is 20 square feet for total exterior • 10% of small components

  14. HUD’s Lead Safe Housing Rule • End of Job • HUD requires a clearance examination • Must be done by independent party • Clearance examination includes a • Visual assessment at the end of the work for deteriorated paint, dust, debris, paint chips or other residue • Clearance dust wipe tests of interior floors, window sills and window wells • Independent party must a be a licensed lead inspector/risk assessor • Licensed by the State of CT Department of Public Health

  15. When is a DPH Licensed/Certified Professional Required? Sampling: • Paint (XRF) • Paint Chips • Dust • Soil • Water

  16. DPH Licensed Contractors/Consultants • Lead Abatement Consultant Contractor • Lead Abatement Contractor • Lead Consultant Contractor • Lead Inspector • Lead Risk Assessor • Lead Planner/Project Designer

  17. How to Find a Lead Inspector/Risk Assessor

  18. Paint Chip Sampling

  19. Sample RRP Certificate

  20. How to Find an RRP Certified Renovator

  21. Checklist for Lead Safe Work Practices

  22. When is Abatement Required?

  23. When do the HUD/DPH Requirements Trigger Abatement? DPH • Child under the age of 6 in residence • Elevated Blood Lead Level (poisoned child) • A licensed professional has tested and identified defective lead-based paint • A code enforcement official has identified defective lead-based paint • Additional dwellings in same unit with defective lead-based paint HUD • Projects costing more than $25,000 • When a contract specifies lead abatement

  24. Sample DPH License

  25. Checklist for Lead Abatement Projects

  26. Question and Answer

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