Lead – Renovation, Repair & Painting (RRP) Initial

Description

EPA REMODELING, RENOVATION & PAINTING (RRP) RULE (40 CFR 745)

The Renovation, Repair and Painting (RRP) rule affects contractors, property managers and others who disturb known or presumed lead-based paint during renovation. The term renovation covers all activities done for compensation that disturb painted surfaces including most repair, remodeling and maintenance activities, such as window replacement, weatherization and demolition. The RRP rule applies to all renovation work performed in residential houses, apartments and child-occupied facilities such as schools and day-care centers built before 1978. Training, certification, and work practice requirements in the Renovation, Repair and Painting Rule were effective April 22, 2010. Pre-renovation education requirements are effective now.

Requirements for Renovation Contractors Certification and Training

All firms performing renovation, repair or painting work must become certified. This can be accomplished by applying to EPA or to the State, if it has an EPA-authorized renovation program, and paying a fee.

Firms must have one or more "Certified Renovators" assigned to jobs where lead-based paint is disturbed. To become certified, a renovator must successfully complete an EPA or State-approved training course conducted by an EPA or State-accredited training provider. ETI is an approved trainer.

All renovation workers must be trained. Renovation workers can be trained on-the-job by a Certified Renovator to use lead safe work practices, or they can become Certified Renovators themselves.

The U.S. Department of Housing and Urban Development (HUD) Lead Safe Housing Rule

HUD's Lead Safe Housing Rule (24 CFR Part 35) covers pre-1978 federally-owned or assisted housing and federally-owned housing that is being sold. It does not cover child-occupied facilities outside of residential housing. The requirements of HUD's rule are similar to EPA's RRP rule, but there are some differences in the details, including:

Exemptions. HUD's rule does not allow owners of federally-assisted housing to opt out of its requirements.

Training Requirements. HUD does not recognize on-the-job training. To conduct lead hazard control in federally-assisted housing, either all workers must have completed a HUD-approved course, or the crew must be supervised by a Certified Renovator who is also a Certified Lead Abatement Supervisor.

Minor Repair and Maintenance. HUD's definition of minor repair and maintenance that is exempt from its rule is different than EPA's (2 square feet interior and 20 square feet exterior or 10 percent of the surface area of a small building component type).

The RRP course will cover other differences between the EPA and HUD rules (concerning paint testing, prohibited practices, clearance testing and waste disposal) are pointed out in the appropriate places.

"This course has been approved by the Minnesota Department of Labor and Industry for 7 hours for Continuing Residential Building Contractor Education."