Transcript What You Should Know About EPA’s Lead Paint; Renovation, Repair, and Painting Rule (RRP) Connecticut Department of Public Health Lead and Healthy Homes Program.

What You Should Know About
EPA’s Lead Paint; Renovation,
Repair, and Painting Rule (RRP)
Connecticut Department of Public Health
Lead and Healthy Homes Program
What Is the Lead-Based Paint
Renovation, Repair and Painting
Program (RRP)?
o RRP is a federal regulatory program affecting
contractors, property managers, and others who
disturb painted surfaces
o It applies to residential houses, apartments, and
child-occupied facilities such as schools and day-care
centers built before 1978
o It includes pre-renovation education requirements
(406b PRE) as well as training, certification, and
work practice requirements
Authorization
For a State to become authorized, it must
be at least as protective as EPA
CT is not authorized to administer
or enforce RRP rule
Target Audiences
CT DPH Provides:
o Compliance assistance – typically conducted as part of a
complaint response/investigation
o Education/outreach – variety of audiences including
contractors, property managers, tenants, daycares, etc.
o Awareness training – audiences include building
officials, housing authorities, professional
organizations, etc.
Who Must Follow the Lead
Rule’s Requirements?
Anyone who receives compensation for performing work on a pre-1978
dwelling and/or child occupied facility.
Examples:
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Residential rental
property owners
Painters
Home Improvement
Contractors
Renovators & Remodelers
Carpenters
School Administrators
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Daycare Owners/Operators
Finishing Workers
Property Managers
Maintenance Staff
Electricians & Plumbers
Window Replacement Firms
And Many Others………
What Activities are Subject
to RRP?
Remodeling and repair/maintenance, electrical work,
plumbing, carpentry, etc., (for payment) that disturbs:
o
> 6 square feet of interior painted surfaces (per room) during
projects on housing and child occupied facilities built pre-1978
o
> 20 square feet of painted exterior surfaces during projects on
housing and child occupied facilities built pre-1978
o
Any window replacement
Exclusions
o Housing built after 1977
o Certified lead free housing
o Lead abatement projects
o Full demolitions
o Housing for the elderly or disabled unless a child under 6
resides or is expected to reside there.
o Zero-bedroom dwellings (studio apts., dorms).
o Minor repair/maintenance
o Emergency renovations
What does the RRP Program
require Firms to do?
Pre-renovation education requirements:
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Give pamphlet to the owner and occupants before
renovation starts
Obtain receipt of the lead pamphlet
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Signed receipt
Self-certification
Certified mail from post office
What does the RRP Program
require Firms to do?
This pamphlet must be
distributed to property
owners, tenants,
daycare & preschool
operators, and parents…
Current Receipt Form
What does the RRP Program
require Firms to do?
For work in common areas of multi-family
housing or child-occupied facilities, you must:
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Distribute renovation notices to tenants or parents/guardians of the
children attending the child-occupied facility
Or you must post informational signs about the renovation or repair job
Informational signs must:
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Be posted where they will be seen
Describe the nature, locations, and dates of the renovation
Be accompanied by the lead pamphlet or by information on how parents
and guardians can get a free copy
Retain records for three years
What are the Training,
Certification, and Work
Practice Requirements?
Trainer Accreditation:
o
The trainer that you take the certification training from must be
accredited through EPA
o
Make sure you verify that the firm is accredited either by
contacting EPA or by visiting their website
o
The link shows all the currently accredited training providers

http://cfpub.epa.gov/flpp/searchrrp_training.htm
What are the Training,
Certification, and Work
Practice Requirements?
Firms:
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A firm must be certified
Application to EPA (or an authorized State)
$ 300 Fee
Application on EPA Web site
What are the Training,
Certification, and Work
Practice Requirements?
Renovators:
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Must be trained & certified by an EPA
accredited training provider
Lead-Safe Work Practices must be followed
Cleaning verification
What are the Training,
Certification, and Work
Practice Requirements?
How can a renovator become trained and certified?
Two options:
o Must pass an eight-hour initial renovator training course
offered by an EPA accredited training provider
o OR, if you have already passed an accredited lead abatement
worker or lead abatement supervisor course; or have passed
an EPA/HUD model Lead Safe Work Practices training
course, you only need to take a four-hour EPA RRP refresher
renovator training course to become certified
What are the Training,
Certification, and Work
Practice Requirements?
Certification:
o The course completion certificate serves as certification
o Renovation activities must be performed and/or directed
by a certified renovator
o Refresher training is required every 5 years
o Other workers do not need certification but they must
receive on-the-job training from a certified renovator
o Certification allows the renovator to perform renovations
in any authorized state, non-authorized state or Indian
territories
What are the Requirements
of a Certified Renovator?
o Can use EPA approved lead test kit for testing
painted surfaces being disturbed
o Provide on-the-job training for other workers
o Must be present when:
 Warning signs are posted
 Work area containment is being established
What are the Requirements
of a Certified Renovator?
o Direct work to ensure compliance with work
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practice standards
Be available on site or by phone
Perform project cleaning verification
Have course certificates available
Provide recordkeeping checklist to customer
Prepare/keep required records
What are Lead Safe
Work Practices?
Examples of these practices include:
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Work-area containment to prevent dust and debris from leaving the work
area
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Wet scraping
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Prohibition of certain work practices like open-flame burning (>1100
degrees F.) and the use of power tools without HEPA exhaust control
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Thorough clean-up followed by a verification procedure to minimize
exposure to lead-based paint hazards
Record Keeping
Written confirmation of
receipt must be kept for
three (3) years after the
completion of the project
Enforcement Penalties for
Non-Compliance
o Maximum 37.5K per violation per day
o 1 year in prison
o EPA can suspend, revoke or modify an
i n d i v i d ua l ’ s o r f i r m ’ s c e r t i f i ca t i o n
Key Points to Remember
Renovations that disturb:
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> 6 square feet of interior painted surfaces (per room)
> 20 square feet of painted exterior surfaces (total)
any window replacement
Give the new “Renovate Right” pamphlet to:
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The residents
Building owners
An adult representative or owner of the child-occupied facility before the renovation
starts
Get receipt:
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Signed receipt
Self-certification
Certificate of mailing from post office
Keep for three years
Key Points to Remember
o Firm must be certified
o Certified Renovator must pass 8 hour approved
renovator course offered by an EPA accredited training
provider
o OR, if you have passed an accredited lead abatement
worker or supervisor course, or have passed an
EPA/HUD lead safe work practices course, you only
need to take a four-hour RRP refresher training course
Websites
EPA RRP Rule
http://www2.epa.gov/lead/renovation-repair-and-painting-program
EPA accredited trainers
http://www2.epa.gov/lead/renovation-repair-and-painting-program-trainingproviders
Renovate Right brochure
http://www2.epa.gov/sites/production/files/documents/renovaterightbooklet
bwsept2011.pdf
How to report a violation- by phone, email, website
http://www2.epa.gov/lead/forms/lead-hotline-national-lead-informationcenter
Frequently asked questions
http://www2.epa.gov/sites/production/files/documents/full_rrp_fqs_ _december_19_2012_with_metadata_2.pdf
DPH Lead and Healthy
Homes Contacts
KIMBERLY PLOSZAJ
o (860) 509-7959
o [email protected]