News Articles
U.S. Environmental Protection Agency (EPA)
Renovation, Repair & Painting Program
THE RRP RULE – REQUIREMENTS AND REASONS
On April 22, 2008, (amended on May 6, 2010) the EPA Rule, 40 CFR Part 745, Part II, Lead; Renovation, Repair and Painting; Lead Hazard Information Pamphlet; Notice of Availability; Final was published in the Federal Register.
Requirements:
- This Rule requires that any contractor firm working on pre-1978 residential properties or child occupied facilities with known or presumed lead-based paint must become an EPA Lead Certified Renovation Firm. Organizations included in the RRP requirements include, but are not limited to, general contractors; plumbers; electricians; painters; roofers; siding contractors; window & rain gutter installers; flooring contractors; maintenance staff at schools, apartment complexes & hospitals; handypersons, etc. This Rule was originally required by April 22, 2010 and was extended until October 1, 2010. Any organization working on these properties without being a Lead Certified Renovation Firm is in violation of the Rule.
- This Rule requires that at least one Certified Renovator from each organization be assigned to each renovation project of pre-1978 residential properties or child-occupied facilities with known or presumed lead-based paint. A person can become a Certified Renovator by successfully completing an approved course taught by an EPA accredited training provider. (MEC is an EPA accredited training provider).
- This Rule requires that contractors provide the Education and Notification Prior to Renovation pamphlet (The Lead-Safe Certified Guide to Renovate Right).
- This Rule requires the development of an Occupant Protection Plan.
- This Rule requires the use of Lead Safe Work Practices which includes containing the work areas, conducting clearances using either a visual verification card or numerical standards and providing a final report to the client within 30 days of the completion of a project.
- This Rule requires contractors to keep records for at least 3 years.
Reasons:
- There are numerous adverse health effects associated with exposure to lead-based paint hazards. Exposure to lead is especially dangerous to children under the age of six and can affect a child’s brain and developing nervous system which can cause reduced IQ, learning disabilities or behavior problems. Pregnant women who are exposed to lead hazards may transfer lead to their fetuses. Exposure to lead hazards, even at low levels, can be detrimental to adults, as well as to children. Adverse health effects can include: high blood pressure, hypertension, kidney damage, liver dysfunction, attention deficit disorder, birth defects, miscarriage, anemia and others.
- Renovation projects that disturb lead painted surfaces can create dust. Lead in dust is the most common way that people are exposed to lead.
- The RRP Rule ensures that contractors have a basic knowledge of lead safe work practices to protect their clients and their employees. Contractors will have knowledge about work area containment, engineering controls, hygiene practices, waste control, etc.
- The RRP Rule ensures that residents, parents, property owners, and administrators, etc. are informed about lead hazards prior to beginning any work. Contractors are required to provide the EPA pamphlet, The Lead-Safe Certified Guide to Renovate Right, to homeowners and tenants and school/daycare centers before beginning any work.
- The RRP Rule ensures that contractors leave work areas cleaner than when they started because of the cleaning verification requirements.
- The RRP Rule ensures that all contractors bidding on a project should be on the same page. All legitimate bids for a project involving residential properties or child-occupied facilities constructed prior to 1978 with known or presumed lead-based paint should be made by an EPA Certified Renovation Firm and have at least one Certified Renovator assigned to the project. Homeowners, property owners, administrators, etc. should ask to see the certification before hiring a contractor. Note: If a project involves more than one company (i.e. General Contractor, plumber, electrician, painter, etc) each company must have the Firm Certification and at least one Certified Renovator).
- Contractors working on pre-1978 residential properties or child occupied buildings with known or presumed lead-based paint without becoming a EPA Certified Firm and having at least one Certified Renovator assigned to a project or who are not using lead safe work practices as required by the Rule are in violation of Federal Law. Fines for violations can be up to $37,500.00 per violation.
- The State of Minnesota 2010 Legislative Action SF3128 requires municipalities to verify lead certification for the residential builders, remodelers, roofers and manufactured home installers when they are requesting a permit to work on homes constructed prior to 1978. The effective date was originally February 1, 2011, but has been extended to August 1, 2011. This means that contractors must be able to prove that they are in compliance with the Environmental Protection Agency (EPA) Renovation, Repair, and Painting (RRP) Rule prior to pulling a permit to work of pre-1978 residential properties or child occupied facilities with known or presumed lead-based paint.