EPA's Lead-Safe Renovation, Repair, and Painting (RRP) Rules

Lead based paint (LBP) is a recognized health hazard. Such paints were the “standard” until the 1950’s when they began to be replaced by newer, latex paints. The health risks of LBP became better recognized, and the use of LBP was banned for residential use in 1978. However, the EPA and HUD estimate that about 83 percent of homes built in the U.S. prior to 1978 may
still contain LBP.

In April 2010 a host of new training, certification and work practice requirements, specified by the U.S. Environmental Protection Agency's (EPA), “Lead-Based Paint Renovation, Repair and Painting (RRP) Program” went into effect. As of that date, businesses involved in restoration, mitigation, renovation, etc., must apply for and receive EPA certification to disturb paint as part of their work whenever they are in pre-1978 homes or child-occupied facilities. In addition, all of these jobs must be supervised by EPA-certified renovators; individuals who have successfully completed an EPA-accredited, full-day training course. All workers on such a job site must be properly trained and equipped to follow the RRP Program's lead-safe work practices when performing their assigned tasks.

PuroClean PDRS has taken all necessary training to achieve the proper EPA certifications and the North Carolina Department of Health and Human Services, Health Hazards Control Unit issued certification number RRP0448 to PuroClean PDRS on April 23, 2010. If you would like more information regarding the RRP Program, please don't hesitate to call. As with all of our services, PuroClean PDRS continues to stay abreast of rule changes and training requirements in order to better serve all of our clients.

Additional Background

Renovation is broadly defined as any activity that disturbs painted surfaces and includes most repair, remodeling and maintenance activities, including window replacement, as well as emergency services following damage caused by water or fire. Because the term "renovation" is defined so broadly, many Contractors who are not generally considered "Renovators," as that term is commonly used, are considered to be "Renovators" under the RRP Program and must follow the rule's requirements.

Under EPA's RRP Program, both businesses and supervisors who perform (or direct other workers to perform) renovations must be certified by EPA. The certified construction firm is required to ensure (1) that all individuals performing activities that disturb painted surfaces on behalf of the firm are either certified Renovators or have been trained by a certified Renovator; (2) that a certified Renovator is assigned to each renovation project; (3) that the program's recordkeeping requirements are met; and (4) that the pre-renovation educational materials are properly distributed (see below).

To become a certified Renovator, an individual worker must successfully complete an eight-hour initial Renovator training course offered by an accredited training provider. The course completion certificate serves as proof of certification. The certified Renovator is required to ensure that the renovation is performed in accordance with the work practice standards of the RRP Program. These requirements include pre-work testing to ascertain whether there is LBP present. If there is, then the requirements specify the use of warning signs and work area containment, the proper use of necessary Personal Protective Equipment (PPE), the restriction or prohibition of certain practices (e.g., high heat gun, torch, power sanding), proper handling of all waste materials, cleaning and specific, post-renovation cleaning verification.

In addition to specifying safe work practices and procedures, the EPA RRP Program also mandates that all businesses that perform mitigation/restoration, renovation, repairs and painting jobs in pre-1978 housing and child-occupied facilities must, before beginning work, provide owners, tenants and child-care facilities with a copy of EPA's lead hazard information pamphlet, Renovate Right: Important Lead Hazard Information for Families, Child Care Providers, and Schools. A copy of this pamphlet is available at: http://www.epa.gov/lead/pubs/renovaterightbrochure.pdf.

Contractors must document compliance with this requirement using an EPA-approved form. This pamphlet outlines some of the potential hazards that lead paint can pose to individuals, especially children.

In the case of an emergency situation (water damage, fire, etc.) there are a few exemptions from some of the rules. These exemptions focus mostly on the homeowner/occupant-educational requirements (the Renovate Right pamphlet). There are no exemptions from pre-work testing, safe work practices, cleaning requirements, etc. They also, of course, do not exempt a business from the Occupational Safety and Health Administration (OSHA) Duty of Care: the responsibility of every business to ensure a safe work environment for its employees.