all lead safe work practices mandated by RRP


to be


followed, even if the renovators have not yet taken the training. So, you can see, the “delay” does not mean anything and will just cause confusion.


What To Expect


Although the details of the RRP Rule and the Lead Safe Work Practices are covered in detail during training classes, following is a brief overview of a proper renovation of a pre-1978 home with lead-based paint under the RRP Rule.


letterhead, emails, signs, sales presentations, Web site, etc.


Disturbing lead paint is especially dangerous for children.


• First, your company must be a Certified Firm, already approved by the EPA.


• You must to assign a Certified Renovator to each renovation project.


• You and your Certified Renovator must thoroughly KNOW the RRP Rule, as well as when it applies and when it does not apply to your projects.


• You must deliver free copies of the “Renovate Right” pamphlet to specific people, and document that delivery, within a certain amount of days prior to the start of your renovation project.


• Your assigned Certified Renovator must train all non-certified workers and document that training.


• Your Certified Renovator must perform specific tests for lead-based paint in the renovation area or hire a third-party professional to do paint chip sampling or use an X-Ray Fluorescence (XRF) Analyzer to determine if lead is present.


• Your Certified Renovator must put up warning signs and notify the residents to keep out of the work area.


• Your Certified Renovator must supervise the installation of the required containment to keep the dust inside the work area.


• Comply with all recommendations for Personal Protective Equipment for your Certified Renovator and trained workers.


NO dust is taken out of the work area.


• Ensure that the three EPA Prohibited Practices are NOT used at any time. There are three additional Prohibited Practices if HUD rules apply.


• Ensure that your work area is stringently cleaned every day using a HEPA Vacuum and Wet Wipes.


• Ensure that all waste is bagged or 14 It is crucially important that


wrapped in a very special way, then thoroughly cleaned with a HEPA vacuum before leaving the work area and being stored in a secure area.


• After you have disturbed all of the paint you are going to disturb, your Certified Renovator must supervise a final cleaning using special procedures.


• Your Certified Renovator must perform a detailed visual inspection and re- clean if necessary.


• Certified Renovator must perform an official Cleaning Verification, or have a Clearance Examination performed by a Licensed Lead Risk Assessor, Licensed Lead Inspector, or Certified Dust Sampling Technician.


• Provide specific people with a Post- Renovation Report, which will contain the results of your lead paint testing and a checklist of all of the steps of the RRP Rule to which you had to comply.


• Collect and maintain all records for three years as an EPA requirement or more, if you choose, for civil liability.


This is just a taste of the full EPA’s RRP Rule, which contains a multitude of very specific requirements. These are reviewed in detail during training.


It is extremely


important that you know and completely understand these requirements in order to work safely and to avoid fines.


Marketing Yourself


Once you receive your Certified Firm approval from the EPA, it's highly recommended that you actively publicize your Certified Firm status and, after successfully completing the training, let everyone know you are a Certified Renovator. Put it on your business cards,


Once you are certified, if any of your potential clients in pre-1978 target housing or child-occupied facilities are receiving multiple bids, make sure they clearly understand that you are legally compliant with the RRP Rule and that all other contractors who are bidding on the job must be Certified Firms with a Certified Renovator assigned to the job or they are violating the RRP Rule regulations and exposing clients, and their families, to lead-based paint hazards.


Working safely with lead-based paint is very possible when you know the RRP Rule and follow its requirements. Reduce your risk and liability. Avoid costly fines. Do the right thing. Help eliminate lead poisoning from lead-based paint dust.


For helpful information, visit www.epa. gov/lead or call 1-800-424-LEAD (5323). Additionally, great information is available from the National Center for Healthy Housing at www.nchh.org.


Article by Scott von Gonten, CGA, CGP, LLRA, CR, CDST with ConserveIQ LLC. Providing you with licensed lead risk assessments, lead inspections, clearance examinations, and consulting as well as the most accurate, effective, and memorable Certified Renovator Training and Certified Dust Sampling Technician Training available. ConserveIQ is partnering with the National Center for Healthy Housing, an EPA-accredited training provider, to present Certified Renovator and Certified Dust Sampling Technician training nationwide. Scott is a Licensed Lead Risk Assessor and principal instructor for NCHH, and a member of the NAHB Society of Honored Associates, the Faculty of the NAHB University of Housing, the Certified Graduate Builder Board of Governors, the NAHB University of Housing Instructor Review Board, the NAHB Associate Members Committee and Designations and Training Sub- Committee, the GHBA Executive Committee, the boards of directors for NAHB, TAB, BABA and GABRA, as well as many other boards, councils and committees at the national, state and local levels. Scott can be contacted at svongonten@conserveiq.com or (713) 213-1205. Take the “ConserveIQ Quiz” at www.ConserveIQ.com.


AUGUST 2010 | HOUSTON BUILDER | GREATER HOUSTON BUILDERS ASSOCIATION – BUILDING A BETTER FUTURE


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