2010 EPA LEAD-CONTAINMENT RULES FOR RENOVATION, REPAIR AND PAINTING (RRP)

The Environmental Protection Agency (EPA) has instituted a series of new requirements for renovation, repair and painting contractors.

On or after April 22, 2010, firms working in pre-1978 homes and child-occupied facilities must be certified and use ,lead-safe work practices during renovations. The penalty for noncompliance is $37,000 per day, per violation and possible jail time.

Common renovation activities like sanding, cutting, and demolition can create hazardous lead dust and chips by disturbing lead-based paint, which can be harmful to adults and children. Under the rule, beginning in April 2010, contractors performing renovation, repair and painting projects that disturb lead-based paint in homes, child care facilities, and schools built before 1978 must be certified and must follow specific work practices to prevent lead contamination.

Contractors and sub-contractors receiving payment for any lead-related renovation must be both a Certified Firm (complete Certified Firm application linked below and send with fee to EPA. Takes 60-90 days for approval) and a Certified Renovator (complete 8-hour training course). Both are valid for a period of 5 years after which re-certification is required.

NECESSARY AND HELPFUL DOWNLOAD DOCUMENTS AND RESOURCE LINKS:

• Official EPA Website For Lead-Containment Guidelines
• EPA DOCUMENTS FOR EACH JOB
• Renovate Right pamphlet (must be given to customers before job)
• Pre-renovation disclosure form (confirms you gave customer above pamphlet)
• Sample recordkeeping checklist for renovators (must be used to document compliance on each job)
• EPA EDUCATIONAL PUBLICATIONS FOR CONTRACTORS
  • Contractors Lead Safety During Renovation brochure
  • Small Entity Compliance Guide to Renovate Right
  • Steps to Lead-Safe Renovation, Repair and Painting
• EPA APPLICATION
  • Application to become a Certified Firm
• EPA-APPROVED TRAINING
  • List of Pennsylvania Training Providers to become a Certified Renovator
• AMERICAN WINDOW AND DOOR INSTITUTE INFO
  • American Window & Door Institute Website (special rules apply for window and door installers)
  • AWDI Webinar Slide Show for Window Installers

Role of a Certified Firm
• Ensure overall compliance with the RRP Rule
• Ensure that all renovation personnel are Certified Renovators or have been trained on-the-job by certified renovators
• Assign a certified renovator to all jobs
• Meet pre-renovation education requirements
• Meet record keeping requirements
• Accept contract for Lead Containment Work under RRP Rule

Role of a Certified Renovator

• Perform lead-safe work as described in the RRP Rule
• Train all non-certified workers in lead-safe practices
• Provide onsite and regular direction for all non-certified workers during setup and cleanup
• Are available by phone when not physically present at the work site during work
• Maintain onsite proof of certification as a certified renovator and training records for all non-certified renovation workers
• Be a certified firm if accepting payment for contract
• If they are a sub, not an employee of the firm, they also must be a certified firm

Although A.D. Moyer believes all information herein to be correct, official and current information should be obtained from the EPA directly.