NEW EPA RENOVATION, REPAIR AND PAINTING (RRP) LEAD PAINT REGULATION IN CHILD OCCUPIED FACILITIES
The U.S. Environmental Protection Agency (EPA) has implemented a new regulation that addresses disturbing Lead-Based Paint (LBP) in residences, child care facilities and schools built before 1978. These buildings are referred to as “Child Occupied Facilities.” The EPA estimates that almost a million children have elevated blood lead levels as a result of exposure to lead hazards, which can lead to adverse neurological effects, lower intelligence, learning disabilities, and behavior issues. Adults exposed to lead hazards can suffer from high blood pressure, headaches and other severe symptoms. Young children are most at risk and exposure to these children can cause permanent damage. Common renovation activities like sanding, cutting, and demolition can create hazardous lead dust and chips by disturbing lead-based paint, which can then lead to exposure.
To protect against this risk, on April 22, 2008, EPA issued a rule requiring the use of lead-safe practices and other actions aimed at preventing lead poisoning. This regulation is called the Renovation, Repair, and Painting Program Final Rule (RRP Rule).
Beginning in December 2008, the rule requires that contractors performing renovation, repair and painting projects that disturb lead-based paint provide to owners and occupants of child care facilities and to parents and guardians of children under age six that attend child care facilities built prior to 1978, the lead hazard information pamphlet Renovate Right: Important Lead Hazard Information for Families, Child Care Providers, and Schools (PDF).
Under the rule, beginning April 22, 2010, contractors performing renovation, repair and painting projects that disturb lead-based paint in child occupied facilities built before 1978 must be certified and follow specific work practices to prevent lead contamination.
EPA requires that firms performing renovation, repair, and painting projects that disturb lead-based paint in pre-1978 child occupied facilities be certified by EPA and that they use certified renovators who are trained by EPA-approved training providers to follow lead-safe work practices. Individuals can become certified renovators by taking an eight-hour training course from an EPA-approved training provider. In a memorandum from the EPA this month, the EPA states that they will not enforce violations of the rule’s worker certification requirement as long as the individual is enrolled in the eight-hour training course by September 30, 2010.
Property owners who renovate, repair, or prepare surfaces for painting in pre-1978 rental housing or space rented by child-care facilities must, before beginning work, provide tenants with a copy of EPA's lead hazard information pamphlet Renovate Right: Important Lead Hazard Information for Families, Child Care Providers, and Schools (PDF). Owners of these rental properties must document compliance with this requirement.
After April 22, 2010, property owners who perform these projects in pre-1978 rental housing or space rented by child-care facilities must be certified and must follow the lead-safe work practices required by EPA's Renovation, Repair and Remodeling rule. To become certified, property owners must submit an application for firm certification (PDF) and fee payment to EPA.
Property owners who perform renovation, repairs, and painting jobs in rental property must also:
- Take training to learn how to perform lead-safe work practices.
- Learn the lead laws that apply regarding certification and lead-safe work practices beginning April 22, 2010.
- Keep records to demonstrate workers have been trained in lead-safe work practices and follow those work practices.
The EPA announced earlier this year proposed rulemaking to apply lead-safe work practices to renovations on public and commercial buildings. The advance notice also announces EPA’s investigation into lead-based paint hazards that may be created by renovations on the interior of these public and commercial buildings. If EPA determines that lead-based paint hazards are created by interior renovations, EPA will propose regulations to address the hazards.
The rule does not apply to minor maintenance or repair activities where less than six square feet of lead-based paint is disturbed in a room or where less than 20 square feet of lead-based paint is disturbed on the exterior. Window replacement is not considered minor maintenance or repair.
Gobbell Hays Partners, Inc. is an EPA approved training provider for the 8-Hour RRP Renovator Course. For more information about the RRP class or any of the other asbestos or lead classes that GHP provides please contact Melissa Jones at 303-574-0082 x201 or mjones@ghp1.com or you can also visit our website at http://www.ghp1.com/training.
Written by: Wade Anderson, Vice President
