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Rrp Power Point 6 09 [Compatibility Mode]


Lead Abatement-Overview of Final Rule

Lead Abatement-Overview of Final Rule

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  • 1. Lead-Based Paint Renovation, Repair, and Painting E nvironmental P rotection A gency Overview of Final Rule June 17, 2009 Gene Burch RTK Environmental Group
  • 2. Abatement vs. Renovation
    • Abatements are intended to permanently eliminate existing lead hazards, and are generally performed in three circumstances:
      • A child with an elevated blood lead level
      • In housing receiving HUD financial assistance
      • Sate and local laws and regulations may require abatements in certain situations associated with rental housing
      • Abatements are not covered by this rule.
  • 3. Abatement vs. Renovation
    • Renovations are performed for many reasons, most having nothing to do with lead-based paint.
    • Renovations involve activities designed to update, maintain, or modify all or part of a building.
    • Renovations are covered by this rule.
    • The rule is designed to prevent the introduction of new lead hazards created by a renovation , not to address existing lead hazards.
  • 4. FINAL RULE (Signed March 31, 2008)
    • Purpose:
      • Persons performing renovations and dust sampling are properly trained;
      • Renovators, dust sampling technicians and firms performing these renovations are certified;
      • Providers of renovation and dust sampling technician training are accredited ; and
      • Update Pre-renovation Education Rule to include child occupied facilities.
  • 5. Rule Scope
    • Renovation is defined as modification of any existing structure that results in the disturbance of painted surfaces , unless performed as part of an abatement.
    • Applies to renovations of target housing and child occupied facilities performed for compensation.
    • Child-occupied facilities may be located in public or commercial buildings or in target housing. Includes kindergarten classrooms and daycare facilities.
  • 6. Rule Scope
    • Excludes:
      • Renovations that affect only components that have been determined to be free of lead-based paint.
      • Activities that disturb under 6 sq. ft interior or 20 sq. ft. exterior. This excludes window replacement and projects involving prohibited practices.
      • Work done by individuals in housing they own and occupy.
  • 7. Lead-Based Paint Determination
    • Written determination by certified inspector or risk assessor, or
    • Written determination by certified renovator using a lead test kit
      • No test kits have been approved at this time
  • 8. Pre-Renovation Education
    • Before renovating a COF, renovation firms must:
    • Distribute new brochure “Renovate Right” developed for all covered renovations
    • From June 2008 until December 2008, either new or old brochure may be used
    • After December 2008, only new brochure may be used
    • “ Protect Your Family” brochure will still be used for other purposes like real estate disclosure
  • 9. Certification Firms
    • To perform a renovation or dust sampling, firms must submit an application and fee to EPA
    • Certifications are good for five years
    • Certification allows the firm to perform renovations
  • 10. Certification Individuals
    • Must take 8-hour accredited training course :
    • Refresher training is required every 5 years
    • Individuals with certain previous training can take an accredited 4 hour refresher renovator course instead of the 8 hour initial course to become a certified renovator
    • All individuals performing renovation activities are either certified renovators or have been trained by a certified renovator
    • A certified renovator is assigned to each renovation
  • 11. Cleaning Verification
    • Wipe floors, countertops and windowsills with wet cleaning cloth
    • If the cloth does not match the verification card, re-clean
    • Alternatively, laboratory dust sampling is an option where the contract or Federal, State or local regulation requires dust sampling by a certified professional
  • 12. Recordkeeping Requirements
    • Documentation of compliance with the requirements of Renovation, Repair, and Painting Rule
    • All documents must be retained for 3 years
  • 13. Enforcement and Penalties
    • EPA may suspend, revoke, or modify a firm’s certification if firm is found to be in non-compliance
    • Non-compliant contractors may be liable for civil penalties of up to $32,500 for each violation
    • Contractors who knowingly or willfully violate the regulation may be subject to fines of up to an additional $32,500 per violation, or imprisonment, or both
  • 14. Important Dates
    • December 2008:
      • “ Renovate Right” brochure must be used
    • April 2009:
      • EPA begins administering program
      • Training providers may begin applying for accreditation
    • October 2009:
      • Renovation firms may begin applying for certification
    • April 2010:
      • Training providers must be accredited
      • Renovation firms must be certified
      • Renovators and Dust Technicians must be certified
      • Workers must be trained
      • Work practices must be followed
  • 15. TRAINING
    • RTK Environmental Group
    • EPA Accredited Training Provider for:
      • Renovator
      • Dust Sampling Technician
    • To be placed on an email notification of upcoming training classes or for questions regarding the new RRP Rule please email
    • Gene Burch [email_address] 800-392-6468
  • 16. Renovation, Repair and Painting Rule
    • For additional information
      • National Lead Information Center 800-424-LEAD
      • RTK Environmental Group