Renovation Repair Painting Program Rule

1
Renovation Repair Painting Program Rule

• 40 CFR Part 745
• Subpart E
• (Residential Property Renovation)
• (epa.gov/lead)

2
WHY NOW?

• Studies show that typical renovations create
  substantial amounts of dust. In pre-1978 homes
  this creates occupant exposure to lead based
  paint. Approximately 41 of children under the
  age of 6 who have EBLs, live in homes that were
  renovated within the previous year.
• Studies show that typical clean-up methods i.e.
  dust pan and broom and vacuuming are ineffective
  at removing existing lead dust and lead dust
  created during construction activity.
• In 1992 Congress passed the "Residential
  Lead-Based Paint Hazard Reduction Act (Title X)
  and expected EPA to promulgate rules within 4
  years (1996) that would govern renovation and
  remodeling activities to minimize the creation of
  lead dust. These rules were completed in 2008!

3
WHAT IS RRP?

• SCOPE
• Amends Title 40 of the Code of Federal
  Regulations Part 745 (40 CFR 745)
• A federal regulatory program affecting
  contractors, rental property owners and managers
  and anyone else that disturbs painted surfaces in
  pre-1978 units this rule primarily impacts
  remodeling/home improvement contractors and
  rental property owners
• It applies to housing, apartments and child
  occupied facilities
• This law presumes the presence of lead in paint
  unless proven otherwise
• The Rule is made up of four basic parts
• Requires education of owners and occupants of
  Target Housing before work begins
• Requires firms conducting renovations on target
  housing to be certified and to use a certified
  renovator
• Requires lead safe work standards and practices
  be performed in order to pass clearance
• Requires adequate enforcement

4
When is RRP Required?

• For all renovations that disturb painted
  surfaces. Renovations include removal,
  modification or repair including surface
  preparation. Renovation does not include minor
  repair and maintenance activities that disturb 6
  square feet or less of painted surface per room
  for interior activities or 20 square feet or less
  for exterior activities.
• Renovations for compensation

5
WHO IS IN CHARGE?

• Right now the EPA is administering and enforcing
  the Rule
• EPA wants States to Administer this Rule
• Michigan is in the process of amending the
  current Lead Abatement Act to include Lead
  Abatement and Renovation. When approved the
  Healthy Homes Section will administer the RRP
  Rule.

6
I AM A CONTRACTOR, WHAT SHOULD I BE DOING NOW

• DISTRIBUTE THE CORRECT PAMPHLET!!
• The old blue pamphlet no longer applies to
  renovations
• Maintain a record proving that you provided the
  pamphlet
• Get training become Certified Renovator
• After Oct 22, 2009 apply to become certified firm

7
IMPORTANT DATES

• After October 22, 2009 firms can start applying
  for EPA certification to conduct renovations in
  Target Housing
• Our website will list names of training providers
• Effective April 22, 2010 the entire rule becomes
  effective training, certification and work
  practice requirements
• Must be a certified firm
• Must employ a certified renovator to oversee and
  manage the project
• Must employ lead safe work practices
• Must properly clean and clear the work area
• Must maintain records

8
WHEN WILL THE STATE TAKE OVER?

• Changes to the Act will take about 18 months
• EPA will be in charge until then
• Once the State takes over..
• You will need to obtain Firm Certification
• Note the renovator firm Certification fee is
  waived if you are already a Certified Lead
  Abatement firm
• You will need to become a Certified Renovator
• Enforcement will be conducted by the State
• Note EPA wants strict enforcement of this Rule
  
• Training and education will be conducted during
  implementation of this Rule

9
WORK PRACTICE STANDARDS

• POST SIGNS TO DEFINE THE WORK AREA
• CONTAIN THE WORK AREA SO NO DUST OR DEBRIS LEAVES
  THE WORK AREA
• REMOVE OBJECTS FROM THE WORK AREA OR COVER
• CLOSE WINDOWS AND DOORS
• COVER THE FLOOR
• USE PRECAUSTIONS TO ENSURE THAT PERSONNEL, TOOLS
  AND OTHER ITEMS ARE FREE OF DUST AND DEBRIS
  BEFORE LEAVING THE WORK AREA.
• POST RENOVATION CLEANING AND CLEARANCE

10
CONTACT INFO

• STEVE M SMITH
• [phone]
• STEVEMSMITH_at_PEOPLEPC.COM