EPA Enacts Renovation, Repair and Painting (RRP) Rule
By Susan G. Fahmy, CSP, Lovell Safety Management Co., LLC
The U.S. Environmental Protection Agency (EPA) has enacted the Reno- vation, Repair and Painting (RRP) Rule, effective April 22, 2010. The rule imposes a new set of require- ments for contractors, property own- ers and managers who renovate, repair or prepare surfaces for painting. The rule applies to all projects in pre-1978 housing, childcare facilities and schools with lead-based paint. This includes home improvement con- tractors, maintenance workers, paint- ers and other specialty trades. The rule does not apply to minor maintenance or repair activities affecting less than six square feet of lead-based paint in a room or less than 20 square feet of lead-based paint on the exterior. Win- dow replacement is not considered a minor maintenance or repair. The Renovation, Repair, and Paint-
ing rule requires that renovators are trained in the use of lead safe work practices, that renovators and firms be certified, that providers of renovation training be accredited, and that reno- vators follow specific work practice standards. Additional information on this rule can be found at
www.epa.gov, or by contacting the Lovell safety of- fice or your local LSM safety repre- sentative.
What Housing or Activities Are Excluded and Not Subject to the Rule? • Housing built in 1978 or later. • Housing for elderly or disabled persons, unless children under 6 reside or are expected to reside there.
• Zero-bedroom dwellings (studio apartments, dormitories, etc.).
• Housing or components declared lead-free by a certified inspector or risk assessor.
• Minor repair and maintenance ac- tivities that disturb 6 square feet or
less of paint per room inside, or 20 square feet or less on the exterior of a home or building.
• Note: minor repair and mainte- nance activities do not include window replacement and projects involving demolition or prohibited practices.
What Does the Program Require Me To Do? Training, Certification, and Work Practice Requirements - Effective April 22, 2010. The EPA must certify firms Renovators must be trained by a certified training agency (at least 1 at each job site) Lead-safe work prac- tices must be followed. The train- ing, certification, and work practice requirements do not apply where the firm obtained a signed statement from the owner that all of the following are met: • The renovation will occur in the owner’s residence;
• No child under age 6 resides there; • No woman who is pregnant re- sides there;
• The housing is not a child-occu- pied facility; and
• The owner acknowledges that the renovation firm will not be re- quired to use the work practices contained in the rule.
How Will a Firm Become Certified? Firms may apply to the EPA for cer- tification to perform renovations or dust sampling. To apply, a firm must submit to the EPA a completed “Ap- plication for Firms,” signed by an authorized agent of the firm, and pay the correct amount of fees. To obtain a copy of the “Application for Firms” contact the NLIC at 1-800-424-LEAD (5323) or visit
www.epa.gov. How Will a Renovator Become Certified? Each job requires at least one RRP
certified renovator. All of your em- ployees do not need to be certified, however, on the job training will be re- quired and documentation of the train- ing must be maintained. To become a certified renovator an individual must successfully complete an eight-hour initial renovator training course of- fered by an accredited training provid- er (training providers are accredited by the EPA). The course completion certificate serves as proof of certifica- tion. Are There Streamlined Require- ments for Contractors with Previ- ous Lead Training? Yes. Individuals who have suc- cessfully completed an accredited lead abatement worker or supervisor course, or individuals who have suc- cessfully completed an EPA, Depart- ment of Housing and Urban Devel- opment (HUD), or EPA/HUD model renovation training course, need only take a four-hour refresher renovator training course instead of the eight- hour initial renovator training course to become certified. How Will Lovell Safety Manage- ment Help You Comply? The Lovell Safety department and
our representatives will assist you in complying with these regulations by helping you get through the paper work, ensuring that safe work practices are being performed at your worksites, assisting you with the on-the-job train- ing aspect of the regulation, providing safe work policies and procedures and facilitating your compliance with both OSHA and EPA requirements. Susan G. Fahmy, CSP is Vice Pres- ident/Director of Safety for Lovell Safety Management, Co., LLC. For more information you may contact Lovell Safety Management at 1-800- 5- LOVELL or visit them online at
www.LovellSafety.com.
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