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New EPA Rules

EPA Rules

New Renovation, Repair and Painting Rule April 2010

New EPA Rules
  1. On April 22nd, 2010, a new EPA Rule 40 CFR Part 745, commonly referred to as the Renovation, Repair and Painting Rule, went into effect
  2. This states that any contractor working on more than six (6) square feet of painted surface must be a certified lead renovator and practice the lead safe practices handed down by the EPA
  3. With fines starting at $37,000 per occurrence
  4. EPA rule can be read athttp://www.epa.gov/fedrgstr/EPA-TOX/2008/April/Day-22/t8141.pdf

Contractors need to sign up for an EPA Accredited RRP class. Then get free copies of “Renovate Right” and “Small Entity Compliance Guide to Renovate Right” by calling 800-424-5323 or download them from the EPA Publications page

Have a HEPA vacuum

For more information on the new RRP Rule visit EPA RRP Web Page

A federal regulation called the Renovation, Repair, and painting Rule (RRP) went into effect April 2010. It requires renovation and painting contractors and other trades who work in pre-1978 housing and who might disturb painted surfaces to become Lead Certified Renovators by taking a one-day course about using “Lead Safe Work Practices” on the job. 

The rule applies to all jobs in pre-1978 housing (Target Housing) and child occupied facilities where more than 6 square feet per room or 20 square feet outside will be disturbed by workers being compensated for the job.
Target Housing is a house or apartment (including mobile homes) built before January 1, 1978 except for:

  1. Zero bedrooms units like dorm rooms or studio apartments.
  2. Housing that is officially designated for the elderly or the handicapped
  3. Housing that has been tested by a State Certified Lead Inspector and found to be free of lead-based paint. 

Child-Occupied Facility is a building or portion of a building constructed prior to 1978, visited by the same child, 6 years of age or under, on at least 2 different days within any week, provided that each day’s visit lasted at least 3 hours, the combined weekly visit lasts at least 6 hours, and the combined annual visits last at least 60 hours. Such facilities may include but are not limited to, day-care centers, preschools and kindergarten classrooms. 

The RRP Rule requires

1. Pamphlet Distribution Contractors must give clients a pamphlet called “Renovate Right” and get a signed receipt    before beginning a job.

Contractors can call (800) 424-5323 and ask for free copies of “Renovate Right” and the Small Entity Compliance Guide to Renovate Right” or both pamphlets can be downloaded as PDF file from the EPA website. 

2. Individual Certification At least one RRP Certified Renovator is required at each job site. Certification involves           taking a 1 day class from an EPA Accredited Training Provider. Visit RRP Training.

3. Firm Certification In addition to individual certification, each firm, agency or non-profit must also become RRP         certified (note” this includes city agencies and school districts as well as small handymen and owners of rental       property. Firms or “entities” must submit an application and pay EPA a fee ($300) which is good for 5 years. 

4. On the Job Training-RRP certified Renovators are required to train all non-certified people at the job site.

Note Contractors who do business with agencies receiving Federal money for housing rehabilitation, etc. must have everyone trained in a class room.  

5. Paint Testing- The rule required contractors to either test paint they will disturb before beginning a job, or                 assume that it is lead-based paint. In California contractors may not test paint. Instead current law requires that     they must assume that all surfaces in all structures build before 1978 contain lead-based paint. The only people       who can test for lead=based paint in California are State Certified Lead Inspector/Risk Assessors. 

6. Use Lead Safe Work Practices- The RRP Rule requires that “Lead Safe Work Practices” be used when disturbing       6 square feet per room or 20 square feet outside.

7. Cleaning Verification- At the end of each job, contractors are required to do a “cleaning verification” to make           sure they cleaned up properly. They wipe a cleaned area with a white cloth and then compare the cloth against a     picture on a laminated card given to them during training. If the cloth is lighter than the picture on the card, the       area is considered to be clean

Public and private schools are subject to the Renovation, Repair and Painting Rule

Lead was also used in solder to attach older pipes together. Therefore, older plumbing connections can leach lead into drinking water. Lead in solder was banned in 1978

The HUD Guidelines and California Code of Regulations, Title 17, Division 1, Chapter 8Defines X-Ray florescent analyzer (XRF) measurements greater than or equal to 1.0 mg/cm3 (milligrams per square centimeter) or 5,000 ppm (parts per million by weight) (0.5% by dry weight) using laboratory analyses, lead positive. In Los Angeles the measurement is 0.7 mg/cm3 and in San Diego the measurement is 0,5 mg/cm3

About 75 percent of homes built before 1978 contain some lead-based paint. Lead-based paint was used both inside and outside of homes, especially on windows, baseboards, trim and doors. Many layers of lead-based paint can be disturbed during remodeling or home repair. The only way to know for sure if your home contains lead-based paint is to have it tested by a licensed lead professional. 

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