Transcript EPA’s Rule on Remodeling & Renovation

Understanding EPA’s
LRRP Program
www.oregonhba.com
Why the new Rule?
 Lead
is especially dangerous to children
under six years of age
Reduced IQ and learning disabilities
 Behavior problems

 Even
children who appear healthy can have
dangerous levels of lead in their system
 Lead is also harmful to adults.
High blood pressure and hypertension
 Transfer to fetus in pregnant women

What’s the problem?
 Dust

is the main problem.
Lead in dust is the most common way
people are exposed to lead.
 Home
renovation creates dust.
 Proper work practices protect you from
the dust.
Lead Paint History
Lead paint was used in more than 38 million
homes until it was banned in 1978.
 Lead was also used in varnishes and shellacs



When you hear the word “paint”, it includes
all of these finishes.
Homes likely to contain lead



87% built before 1940
69% built between 1940-1960
24% built between 1960-1978
Implementation Timeline

April 2008


December 2008


Certified Renovator Training begins
October 2009


Start distributing new pamphlet
April 2009


Final rule published
Firms can apply for certification
April 2010

Full compliance
What is LRRP?
 Lead
Based Renovation, Repair and Paint
Program
A federal regulatory program affecting
anyone who disturbs painted surfaces
 Applies to houses, apartments and child
occupied facilities built before 1978
 Includes pre-renovation education
requirement
 Includes Renovator training and certification

Who must follow the rule?
 In
general, anyone who is paid to perform
work that disturbs paint in housing and
child occupied facilities built before 1978,
such as:
Residential rental property owners
 General contractors
 Special trade contractors

What activities are subject?
 Any
activities that disturb paint in an area
larger than 6 square feet inside or 20
square feet outside.
Remodeling and repair work
 Electrical work
 Plumbing
 Painting
 Carpentry
 All window replacements

Any exclusions?
 Housing
or components declared leadfree by certified renovator
 Housing built after 1978
 Housing for the elderly unless children
reside there
 Zero bedroom dwellings
 Minor repair that disturbs less than 6
square feet
Owner Opt-out Provision
 Provides
the owner the opportunity to
opt out of Lead Safe Work Practices
This opt out lead to a law suit against EPA
 EPA has agreed to remove this sometime
summer 2010
 Other parts of the rule also may change
because of this law suit but no other
changes in the near future

Education Requirement
 Pre-renovation
housing

Distribute new pamphlet


education for all pre-1978
Renovate Right
Distribute no more than 60 days prior work
 To
owner
 To all occupants in multi-family setting
 Post on signs in common areas

Signature of receipt or certification of
attempt
Lead Save Work Practices

Contain the work area



Minimize the dust




Post warning signs
Cover floors and furniture, seal doors and ducts
No open flame burning or torching
No sanding etc with power tools
No heat guns greater than 750 degrees
Clean up thoroughly


Use a HEPA vacuum
Wet mop with plenty of rinse water
Recordkeeping
 Records
must be kept for 3 years
Verification of owner/occupant receipt of
pamphlet or verification of attempt to
inform.
 Verification of lead check test
 Documentation of the use of Lead Safe
Work Practices
 Certified Renovator certification
 Certified Renovator tasks
 Proof of worker training

Firm and Renovator
Two different Certifications under the rule:
 Firm Certification

The company that is responsible for doing
the renovation. The company must apply to
become a Certified Renovation Firm.
 Renovator

Certification
The person on site that is responsible for the
renovation. The Renovator must attend an 8
hour training course.
Firm Certification
 Under
CCB
Called a Contractor’s License not a Firm
Certification
 All CCB licensed contractors that plan to do
work on pre-1978 houses
 Apply to CCB for “Certified Lead Based
Paint Renovation Contractors License”
 $50 per year application fee

Firm Certification
 Under

DHS
Any entity not licensed with CCB that will
do work on pre-1978 houses
 Apply to DHS for Firm Certification
 $250 application fee good for five years
Firm Responsibilities
 Certified





Firms must ensure that
All individuals performing work are certified
renovators or trained by the certified renovator
A certified renovator is assigned to each
renovation and performs all of the renovator
responsibilities
All renovations performed are in accordance
with work practice standards of the LRRP rule
Pre-renovation education requirements are met
Recordkeeping requirements are met
Renovator Certification
 Renovators
must be trained and certified
Individual must complete an 8 hour training
course
 Certification comes from the Training
Instructor

 Certification
good for 5 years
Renovator Responsibilities
Use EPA approved lead test kit
 Provide on the job training for other workers
 Be physically present when signs are posted,
during work area containment & during clean up
 Direct work being preformed by others
 Be available by phone when not required on site
 Have a copy of their Renovator Certification on
hand at the work site
 Prepare required records
 Use lead safe work practices

OHBA Response
Train and certify qualified instructors to
teach:
the entire 8 hour course; 5 hours lecture, 3
hours hands-on
 the 3 hour hands-on course that
accompanies the online lecture course

Create an online course to meet the
lecture requirement of the Renovator
training course
For More Information
 Visit
www.oregonhba.com
 To order Renovate Right call

1-800-424-5323
 For
more information on the EPA rule
 www.epa.gov/lead