The document outlines the requirements for compliance with the EPA's Renovation, Repair, and Painting (RRP) rule regarding lead-based paint, emphasizing three key steps: obtaining proper certification, following simple lead-safe work practices, and maintaining thorough documentation. It highlights the importance of appropriately training and certifying firms and renovators to prevent lead exposure, with significant potential penalties for non-compliance. The presentation also details the background and enforcement of the RRP rule while encouraging proactive risk management through the application of the 80/20 rule.

2. 3 Simple Steps for Full compliance of
EPA’s Lead Based Paint, Renovation,
Repair and Painting Rule
• Presented by: Lee E. Wasserman, Pres. LEW Corp.
www.LEWCorp.com
800-783-0567

3. • The Background of RRP
• The 80/20 Rule & Risk Management
• Step 1. What it REALLY means to be “Certified”
• Step 2. How to do the work the “KISS” (Keep It
Simple Silly) way
• Step 3. If an “Action” occurs, Its all in the
“Records” – Document, Document….
Learning Objectives

4. • EPA’s Renovation Repair
and Painting Rule (40 CFR
part 745) 4/2010
• Refresher training began
1/23/15 (90days before),
4/23/15 first refreshers
required.
• 4/17/15 EPA publishes 1
Year Extension, Why?
– Smooth out volume (750K)
– Further assess Rule
Requirements
• Rule requires!
– ALL Trades, who disturb
Pre-1978 painted surfaces
for compensation, in
Residential & Child
Occupied facilities MUST
be an EPA Certified firm &
MUST employ an EPA
Certified Lead Safe
Renovator (Supervisor).
The Background
www.RRPTrainer.com

5. • CDC announces &
releases the new Lead
Reference Value of
5ug/dl. (vs. 10)
• Estimated 500k more
children will be
identified with a Blood
lead level of concern.
• 1:53 (CDC)
• HUD releases after 18
years NEW 2012 HUD
Guidelines for the
Evaluation and Control
of Lead Based paint and
Lead paint Hazards.
• Lee Wasserman,
Acknowledged
Since 2010

6. Then and Now
2010 Rule first became effective, EPA was in
Compliance Assistance Mode
2015 – 2016 First Anniversary, EPA is in
Enforcement Mode
12/2014 (EPA) announced 61 enforcement actions
that require renovation contractors and training
providers to protect people from harmful exposure
to lead dust and debris, as required by EPA’s Lead-
based Paint Renovation, Repair, and Painting (RRP)
standards.

7. The settlements led to $213,171 in civil penalties and
the violators coming into compliance with federal law.
These recent actions are in addition to EPA’s
settlement with Lowe’s Home Improvement in April
2014, which included a $500,000 civil penalty as well
as implementation of a corporate-wide RRP
compliance program.
61 Enforcement Actions

8. 80/20 RULE – RISK
MANAGEMENT
• The Pareto principle is used
in occupational health and
safety to underline the
importance of hazard
prioritization (Pb & RRP
Compliance). Assuming 20%
of the hazards (Pb) will
account for 80% of the
injuries and by categorizing
hazards, safety professionals
can target those 20% of the
hazards that cause 80% of
the lead poisoning injuries or
accidents.
Mathematically, the
80–20 rule is roughly
followed by a power
law distribution (also
known as a Pareto
distribution) for a
particular set of
parameters, and many
natural phenomena
have been shown
empirically to exhibit
such a distribution.

9. • If you do 3 Simple Steps (20%) consistently
you will SUBSTANTIALLY minimize (80%) of the
Risk associated with Lead-Based Paint & Lead
Paint disturbances.
• 80% of the Risk to the Trades, is associated
with only 3 simple Steps! “Certification”,
“KISS”, & “Document, Document”..
80/20 RRP rule
The Pareto principle - RRP

10. • Per the RRP Rule, ALL Trades who disturb a
painted surface in pre-1978 residential & Child
Occupied Facilities MUST be;
– An EPA Certified Firm, 5 year Certification
• 4/16/15 EPA Extension NOT for firms!! MUST RENEW!!
• Application to EPA found
http://www2.epa.gov/lead/epa-lead-safe-certification-
program
• Recertification Fee $300.00
– Must employ, “Certified Lead Safe Renovator”
• 4/16/15 EPA Extension applies
• Course fee, ½ Day Refresh, good for 5 years.
Step 1 – “Certified”

11. • Step #1 Being properly,
“CERTIFIED”.
• If you don’t have the
proper FEDERALLY
REQUIRED
certifications, Firm and
Renovator, you are
Negligent & Liable from
inception!!!!!
Step 1 – “Certified”
www.RRPTRainer.com

12. • If you are and they are NOT?
• If they are not, can the consumer
trust them?
• If they are not, what other rules
might they be not complying
with?
• If they are not will they put your
family at Risk of a well know
Environmental Toxic material -
Lead Poisoning.
• If not are you willing to risk a lead
contaminated home?
• Who do you want the person in
your home, doing the work, and
contracting with to be?
“Certified as a Sales Tool”

13. Step 2 – How to do the work the “KISS” way
KISS = Keep It Simple Silly
Checklists Packets (EPA gave & Requires one to be
completed for EACH project) (Double Dipper also Part of
Paper Trail)
Assess project risk: kids <6, kids >7, No kids
Architect/Warden Analogy – Once upon a time…..there was a need for an Architect who had a
specialty in designing Prisons for Environmentally Toxic Bad Dudes. He built both High Risk –
Maximum Security as well as low risk, half way homes. He designed the security and
managed his risk based on who he was trying to protect!
After the Ribbon cutting. The warden takes over. SOLE job is to be “Responsible” for the
Environmentally Toxic Bad dudes within the “Containment” of the prison while
simultaneously protecting all the good outside.

14. Basic RRP KISS Lead Safe Work
Practices (Efficient & Effective)
1. Paper compliance packet
2. Checklist
3. Renovate Right Distribution
4. Assess paint (chemical or presume)
5. Post signs
6. Use 6ml Plastic containment
7. Have a HEPA Vacuum, pre vacuum
8. Remove or cover belongings
9. Contain area of paint disturbances
10. Turn off HVAC (if forced air)
11. Eliminate access to work area(s)
12. Avoid high risk activities
13. Fold Plastic Dirty side in & dispose of
14. HEPA vacuum, Wash, Hepa Vacuum
15. Cleaning verification or Dust Wipe
clearance
16. Verify all completed via Checklist

15. RRP Checklist
• Put in picture of checklist
RRP additionally requires:
§745.86 Recordkeeping and
reporting requirements.
(c)(1) When the final invoice for the
renovation is delivered or within 30
days of the completion of the
renovation, whichever is earlier, the
renovation firm must provide
information pertaining to compliance
with this subpart to the following
persons:
(i) The owner of the building; and, if
different,
(ii) An adult occupant of the
residential dwelling, if the renovation
took place within a residential
dwelling, or an adult representative of
the child-occupied facility, if the
renovation took place within a child-
occupied facility.

16. 2-16
VERTICAL CONTAINMENT

17. 1-17
THINK ABOUT OUR KIDS

18. 1-18
THINK ABOUT YOUR HEALTH

19. Just Think!

20. 2-20
Current Interior Set-Up Practices
that Poison children
• Reusable drop cloth
• Furniture and household
objects in the room
• Open doors and windows
• Broom or shop vacuum
Do not use these practices
when lead is present!

21. • §745.86 Recordkeeping and reporting
requirements.
• http://www.ecfr.gov/cgi-bin/text-
idx?SID=cd05f748c481fd0ec85ffb94b9193066
&node=sp40.31.745.e&rgn=div6#se40.31.745
_186
The Records – “Document, document”

22. • (a) Firms performing renovations must retain
and, if requested, make available to EPA all
records necessary to demonstrate compliance
with this subpart for a period of 3 years
following completion of the renovation.
The Records

23. • (1) Records or reports certifying that a
determination was made that lead-based
paint is not present or Lead Paint is
“Presumed” present.
• (2) Signed and dated acknowledgments of
receipt as described in §745.84(a)(1)(i),
(a)(2)(i), (b)(1)(i), (c)(1)(i)(A), and (c)(1)(ii)(A).
“Renovate Right”
The Records

24. • (6) Documentation of compliance with the
requirements of §745.85
– Training was provided to workers (topics must be
identified for each worker).
– (ii) Warning signs were posted at the entrances to the
work area.
– (iii) If test kits were used, that the specified brand of
kits was used at the specified locations and that the
results were as specified.
– (v) The work area was contained by:

25. • (vi) Waste was contained on-site and while
being transported off-site.
• (vii) The work area was properly cleaned after
the renovation by:
• (viii) The certified renovator performed the
post-renovation cleaning verification

26. • (c)(1) When the final invoice for the renovation is
delivered or within 30 days of the completion of
the renovation, whichever is earlier, the
renovation firm must provide information
pertaining to compliance with this subpart to the
following persons:
– (i) The owner of the building; and, if different,
– (ii) An adult occupant of the residential dwelling, if
the renovation took place within a residential
dwelling, or an adult representative of the child-
occupied facility, if the renovation took place within a
child-occupied facility.

27. RRP Checklist
• Put in picture of checklist
RRP additionally requires:
§745.86 Recordkeeping and
reporting requirements.
(c)(1) When the final invoice for
the renovation is delivered or
within 30 days of the completion
of the renovation, whichever is
earlier, the renovation firm must
provide information pertaining to
compliance with this subpart to
the following persons:
(i) The owner of the building; and,
if different,
(ii) An adult occupant of the
residential dwelling, if the
renovation took place within a
residential dwelling, or an adult
representative of the child-
occupied facility, if the renovation
took place within a child-occupied
facility.

28. • Frequently based on Tips and Complaints.
• When they arrive, they want to see
– Step 1: Proper Certification, “Certified” (firm &
Super)
– Step 2: They want to examine your KISS Safe Work
Practices if accessible at time of visit. (Sign, Plastic,
HEPA Vac.)
– Step 3: They want to examine your “Records”
EPA Enforcement

29. • If you don’t have your “Records”
you are saying to; EPA, HUD,
Local Government and the legal
community:
EPA Enforcement

30. • Step # 1: Be properly “Certified”
– A few bucks and a few minutes!!! Then DONE for 5
years
• Step #2: KISS - Lead Safe Work Practices
– Checklist, Containment, HEPA-Wash-HEPA,
Cleaning Verification or Clearance
• Step #3: Records
– Document, Checklist, Send copy to client with
Invoice or 30 days.
Summarize
3 Simple Steps RRP compliance

31. Thank you!
Lee E. Wasserman
President
Lwasserman@LEWCorp.com
800-783-0567
www.RRPTrainer.com to find the next scheduled
RRP Initial & Refresher course in your community