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EPAs RENOVATION, REPAIR & PAINTING RULE All Pre-1978 Properties That Are Not Lead Free.

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Presentation on theme: "EPAs RENOVATION, REPAIR & PAINTING RULE All Pre-1978 Properties That Are Not Lead Free."— Presentation transcript:

1 EPAs RENOVATION, REPAIR & PAINTING RULE All Pre-1978 Properties That Are Not Lead Free

2 Basics of RRP Rule Title X-Residential Lead-Base Paint Hazard Reduction Act of 1992 (Policy Manual, Volume I, Administrative, Section E, Leasing Procedures, pages E-32 to E-34) Title X-Residential Lead-Base Paint Hazard Reduction Act of 1992 (Policy Manual, Volume I, Administrative, Section E, Leasing Procedures, pages E-32 to E-34) 40CFR to CFR to Published April 22, 2008 in Federal Register Published April 22, 2008 in Federal Register Effective April 22, 2010 Effective April 22,

3 Basics of RRP Rule, Continued Applies to Renovation for Compensation in Pre-1978 Target Housing & Pre-1978 Child-Occupied Facilities; have documentation available establishing age of the property. Applies to Renovation for Compensation in Pre-1978 Target Housing & Pre-1978 Child-Occupied Facilities; have documentation available establishing age of the property. What Triggers the RRP Rule? Lead-Based Paint Disturbance during any renovation, repair and painting activities. What Triggers the RRP Rule? Lead-Based Paint Disturbance during any renovation, repair and painting activities.

4 Impacts of RRP Rule EPA estimates 8.4 million renovation events occur annually. This may drop to 4.4 million since many properties will test for lead-based paint & this rule does not apply to lead-based paint free properties. EPA estimates 8.4 million renovation events occur annually. This may drop to 4.4 million since many properties will test for lead-based paint & this rule does not apply to lead-based paint free properties. The RRP Rule requires certification of Firms by the EPA & Renovators by Accredited Trainers. The RRP Rule requires certification of Firms by the EPA & Renovators by Accredited Trainers. EPA estimates that $35.00 will be added to the cost of each job. EPA estimates that $35.00 will be added to the cost of each job.

5 Other Existing Lead-Based Paint Rules OSHA Lead in Construction Standard (1992) OSHA Lead in Construction Standard (1992) EPA/HUD Lead Disclosure Rule (1996) EPA/HUD Lead Disclosure Rule (1996) EPA/LBP Activities Rule (1996) standards for certification & training for lead abatement, risk assessors & inspectors EPA/LBP Activities Rule (1996) standards for certification & training for lead abatement, risk assessors & inspectors EPA Pre-Renovation Education Rule (1999) EPA Pre-Renovation Education Rule (1999) HUD Lead-Safe Housing Rule (1999) HUD Lead-Safe Housing Rule (1999) EPA Lead Hazard Standards Rule (2001) EPA Lead Hazard Standards Rule (2001) State & local lead-based paint requirements State & local lead-based paint requirements

6 Renovation Means: Modification of any existing structure, or portion thereof, that results in the disturbance of painted surfaces, unless that activity is performed as part of an abatement. Modification of any existing structure, or portion thereof, that results in the disturbance of painted surfaces, unless that activity is performed as part of an abatement.

7 Renovation Means, Continued: Removal, modification or repair of painted surfaces or painted components Removal, modification or repair of painted surfaces or painted components Removal of building components Removal of building components Weatherization projects Weatherization projects Interim controls that disturb painted surfaces Interim controls that disturb painted surfaces Converting a building, or part of a building, into Target Housing or a Child- Occupied Facility Converting a building, or part of a building, into Target Housing or a Child- Occupied Facility

8 Compensation Means: Pay for work performed, i.e., contractors Pay for work performed, i.e., contractors Wages, such as those paid to employees of contractors, building owners, property management companies, child-occupied facility operators Wages, such as those paid to employees of contractors, building owners, property management companies, child-occupied facility operators Rent for Target Housing, public or commercial spaces Rent for Target Housing, public or commercial spaces Excludes: Child care payments, Do-it- Yourself renovations, Realtor fees Excludes: Child care payments, Do-it- Yourself renovations, Realtor fees

9 Target Housing Means: Housing constructed before 1978 Housing constructed before 1978 Exceptions: Housing designed for the elderly or persons with disabilities ( unless a child under 6 years of age resides or is expected to reside there) & Zero-bedroom dwellings Exceptions: Housing designed for the elderly or persons with disabilities ( unless a child under 6 years of age resides or is expected to reside there) & Zero-bedroom dwellings

10 Child-Occupied Facility Means: Constructed prior to 1978 Constructed prior to 1978 Visited regularly by the same child, under 6 years of age, on at least 2 different days within any week, provided: each days visit lasts at least 3 hours & combined weekly visits last at least 6 hours or combined annual visits last at least 60 hours Visited regularly by the same child, under 6 years of age, on at least 2 different days within any week, provided: each days visit lasts at least 3 hours & combined weekly visits last at least 6 hours or combined annual visits last at least 60 hours

11 Basic Exclusions Lead Abatement: designed to permanently eliminate lead-based paint hazard Lead Abatement: designed to permanently eliminate lead-based paint hazard Minor repair & maintenance activities Minor repair & maintenance activities No lead-based paint disturbed: Written documentation by Certified Risk Assessor or Lead Paint Inspector or Proper use of EPA-recognized Test Kit by a Certified Renovator No lead-based paint disturbed: Written documentation by Certified Risk Assessor or Lead Paint Inspector or Proper use of EPA-recognized Test Kit by a Certified Renovator

12 Minor Repair & Maintenance Exclusion Disturb 6 square feet or less of painted surface per room for interior activities Disturb 6 square feet or less of painted surface per room for interior activities Disturb 20 square feet of less of painted surface per side for exterior activities Disturb 20 square feet of less of painted surface per side for exterior activities NOT MINOR if: Using prohibited/restricted work practices or conducting window replacement or demolition of painted surface areas NOT MINOR if: Using prohibited/restricted work practices or conducting window replacement or demolition of painted surface areas

13 Prohibited Work Practices Open-flame burning or torching Open-flame burning or torching Use of a heat gun above 1,100 degrees F. Use of a heat gun above 1,100 degrees F. Power sanding, power grinding, power planning, abrasive blasting, sandblasting without exhaust port connected to a HEPA vacuum Power sanding, power grinding, power planning, abrasive blasting, sandblasting without exhaust port connected to a HEPA vacuum

14 Emergency Renovation Exclusion Sudden, unexpected event that presents an immediate safety or public health hazard and/or that threatens equipment or property with significant damage Sudden, unexpected event that presents an immediate safety or public health hazard and/or that threatens equipment or property with significant damage Exempt from information distribution, warning signs, containment, waste handling, training & certification requirements Exempt from information distribution, warning signs, containment, waste handling, training & certification requirements BUT, final cleaning, cleaning verification & recordkeeping are still required BUT, final cleaning, cleaning verification & recordkeeping are still required

15 Certified Firm Responsibilities Apply for certification on/after 10/22/09; approximately 180 days for EPA completion of application. Frame and post Firm Certificate is office. Apply for certification on/after 10/22/09; approximately 180 days for EPA completion of application. Frame and post Firm Certificate is office. Ensure compliance with RRP Rule Ensure compliance with RRP Rule Ensure all personnel are Certified Renovators or have received on-the-job training Ensure all personnel are Certified Renovators or have received on-the-job training Assign Certified Renovator to all jobs Assign Certified Renovator to all jobs Meet pre-renovation education & recordkeeping requirements Meet pre-renovation education & recordkeeping requirements

16 Certified Renovator Take & pass full-day initial Renovator course from EPA-accredited trainer or Take & pass full-day initial Renovator course from EPA-accredited trainer or Take & pass half-day Renovator Refresher bridge course from EPA-accredited trainer. Frame and post Renovator Certificates in office. Take & pass half-day Renovator Refresher bridge course from EPA-accredited trainer. Frame and post Renovator Certificates in office. Take & pass Refresher training every 5 years Take & pass Refresher training every 5 years

17 Previous Lead-Safe Work Practices Training If the worker previously attended & proves successful completion of an EPA/HUD-approved Lead-Safe Work Practices course, he/she only has to take & pass the half-day Renovator Refresher bridge course If the worker previously attended & proves successful completion of an EPA/HUD-approved Lead-Safe Work Practices course, he/she only has to take & pass the half-day Renovator Refresher bridge course However, if the Lead-Safe Work Practices course was NOT EPA/HUD-approved, the worker must take & pass the full-day initial Renovator course However, if the Lead-Safe Work Practices course was NOT EPA/HUD-approved, the worker must take & pass the full-day initial Renovator course

18 Certified Renovator Responsibilities Perform work, direct Lead-Safe Work Practices Perform work, direct Lead-Safe Work Practices Be physically present while posting signs, containing work areas, cleaning work areas Be physically present while posting signs, containing work areas, cleaning work areas Provide & document on-the-job training to non-certified workers Provide & document on-the-job training to non-certified workers Use EPA-recognized test kits to identify lead-based paint (optional task) Use EPA-recognized test kits to identify lead-based paint (optional task)

19 Certified Renovator Responsibilities Continued Be available by phone when off-site (must be reasonably close) Be available by phone when off-site (must be reasonably close) Maintain containment Maintain containment Personally conduct cleaning verification procedure Personally conduct cleaning verification procedure Prepare & maintain job records; maintain at least 3 years & provide Firm & Owner with copies Prepare & maintain job records; maintain at least 3 years & provide Firm & Owner with copies Recommend all contracts be amended to include Recordkeeping Recommend all contracts be amended to include Recordkeeping

20 Pre-Renovation Notification/Education Provide Renovate Right booklet available on (as of 12/22/08) and on the EMC Intranet (www.emcnet.biz), Custodial, Lead- Based Paint. Provide Renovate Right booklet available on (as of 12/22/08) and on the EMC Intranet (www.emcnet.biz), Custodial, Lead- Based Paint. Obtain signed Pre-Renovation Forms acknowledging receipt from occupants or proof of mailing or unsuccessful delivery; recommend documentation even if less than 6/20. Obtain signed Pre-Renovation Forms acknowledging receipt from occupants or proof of mailing or unsuccessful delivery; recommend documentation even if less than 6/20. Post signage in common areas notifying of intent to perform covered work & keep copies of signs & notices; take pictures of signage for records. Post signage in common areas notifying of intent to perform covered work & keep copies of signs & notices; take pictures of signage for records.

21 Determining If Lead-Based Paint Is Present Assume Lead-Based Paint or Assume Lead-Based Paint or Perform paint testing before working Perform paint testing before working Three available testing methods: Three available testing methods: Paint chip collection for lab analysis (Certified Lead Inspector or Lead Risk Assessor only) Paint chip collection for lab analysis (Certified Lead Inspector or Lead Risk Assessor only) XRF testing (Certified Lead Inspector or Lead Risk Assessor only) XRF testing (Certified Lead Inspector or Lead Risk Assessor only) EPA-recognized test kit (Certified Renovator) EPA-recognized test kit (Certified Renovator) The results of the test must be disclosed; there is a chance for false positive. The results of the test must be disclosed; there is a chance for false positive.

22 Interior Set-Up Establish containment; temporary barriers to isolate work areas to avoid escape of dust & debris Establish containment; temporary barriers to isolate work areas to avoid escape of dust & debris Establish work area Establish work area Limit access & post signs; take pictures of signs for documentation. Limit access & post signs; take pictures of signs for documentation. Remove or cover belongings with 6-mil plastic Remove or cover belongings with 6-mil plastic Cover floors with 6-mil plastic; Close or cover windows, doors, HVAC (recommend turning off) Cover floors with 6-mil plastic; Close or cover windows, doors, HVAC (recommend turning off) Document each step; pictures are recommended. Document each step; pictures are recommended.

23 Exterior Set-Up Establish work area Establish work area Close windows & doors Close windows & doors Create containment by covering ground (include shrubs, bushes, mulch, etc.) at least 10 feet beyond building perimeter with 6-mil plastic Create containment by covering ground (include shrubs, bushes, mulch, etc.) at least 10 feet beyond building perimeter with 6-mil plastic Ensure dust & debris do not contaminate or migrate to adjacent areas or properties Ensure dust & debris do not contaminate or migrate to adjacent areas or properties Document each step; pictures are recommended. Document each step; pictures are recommended.

24 During The Work Ensure worker personal protection, i.e., disposable coveralls, disposable shoe coverings, gloves, etc. If any respirator (half-mask, N-100) is required, the work must be completed by a contractor. Ensure worker personal protection, i.e., disposable coveralls, disposable shoe coverings, gloves, etc. If any respirator (half-mask, N-100) is required, the work must be completed by a contractor. Control spread of dust & debris Control spread of dust & debris Restrict access to residents if occupied Restrict access to residents if occupied Clean during job: Clean during job: HEPA vacuum horizontal surfaces HEPA vacuum horizontal surfaces Remove debris frequently Remove debris frequently Remove paint chips as created Remove paint chips as created Wrap & dispose of building components Wrap & dispose of building components

25 Cleaning After Interior work Collect chips, debris & seal in 6-mil plastic bags Collect chips, debris & seal in 6-mil plastic bags Mist, fold dirty side inward, tape & seal and dispose of all protective plastic sheeting in 6-mil plastic bags Mist, fold dirty side inward, tape & seal and dispose of all protective plastic sheeting in 6-mil plastic bags HEPA vacuum walls & wipe with damp cloth or disposable wipes HEPA vacuum walls & wipe with damp cloth or disposable wipes HEPA vacuum & mop uncarpeted floors HEPA vacuum & mop uncarpeted floors

26 Visual Inspection-Interior Conducted by Certified Renovator-wear disposable shoe covers before entering work area Conducted by Certified Renovator-wear disposable shoe covers before entering work area No visible dust, debris or residue can remain No visible dust, debris or residue can remain Re-clean work area if dust or debris is found Re-clean work area if dust or debris is found Post-Renovation EPA Cleaning Verification Procedure is next Post-Renovation EPA Cleaning Verification Procedure is next

27 EPA Cleaning Verification Procedure Wipe each window sill with a single wet disposable cleaning cloth Wipe each window sill with a single wet disposable cleaning cloth Wipe uncarpeted floors & countertops separately with wet disposable cleaning cloths-up to 40 square feet per cloth Wipe uncarpeted floors & countertops separately with wet disposable cleaning cloths-up to 40 square feet per cloth Compare to EPA-issued Cleaning Verification (CV) Card Compare to EPA-issued Cleaning Verification (CV) Card If cloth is darker than the CV Card, reclean & repeat procedure above If cloth is darker than the CV Card, reclean & repeat procedure above If second wet cloth fails, wait 1 hour & then wipe with electrostatically-charged dry disposable cleaning cloth If second wet cloth fails, wait 1 hour & then wipe with electrostatically-charged dry disposable cleaning cloth This completes the Cleaning Verification; document number of cloths used. This completes the Cleaning Verification; document number of cloths used. Warning signs may be removed Warning signs may be removed Unit must be dust-lead tested in D.C. & Maryland Unit must be dust-lead tested in D.C. & Maryland

28 Cleaning After Exterior Work Look for remaining dust, debris, paint chips Look for remaining dust, debris, paint chips Clean all surfaces in work area until no visible dust, debris, chips or residue remain Clean all surfaces in work area until no visible dust, debris, chips or residue remain Remove dust & debris & seal in 6-mil plastic bags Remove dust & debris & seal in 6-mil plastic bags Mist, fold dirty side inward, tape & seal and dispose of protective plastic sheeting in 6-mil plastic bags Mist, fold dirty side inward, tape & seal and dispose of protective plastic sheeting in 6-mil plastic bags

29 Visual Inspection-Exterior Conducted by Certified Renovator Conducted by Certified Renovator No visible dust or debris must remain No visible dust or debris must remain Perform final cleaning if any dust or debris detected Perform final cleaning if any dust or debris detected When all areas pass visual inspection, warning signs may be removed When all areas pass visual inspection, warning signs may be removed

30 Post-Work Checklist, Reporting & Recordkeeping Certified Renovator name, copy of certification Certified Renovator name, copy of certification Certification from Certified Renovator of non-certified worker training; must include each workers full name, all topics of training & each workers signature. Certification from Certified Renovator of non-certified worker training; must include each workers full name, all topics of training & each workers signature. Certification of posting of warning signs; pictures recommended. Certification of posting of warning signs; pictures recommended. Description of EPA-recognized test kit (if used); keep packaging. Description of EPA-recognized test kit (if used); keep packaging. Description of work area containment, cleaning, EPA Cleaning Verification & proper waste disposal; pictures recommended. Description of work area containment, cleaning, EPA Cleaning Verification & proper waste disposal; pictures recommended. Dust-lead clearance report (if performed) Dust-lead clearance report (if performed) Provide as much information as possible for each item on the Checklist. Provide as much information as possible for each item on the Checklist.

31 Certification Strategy Submit application & fee to EPA to become Certified Renovation Firm Submit application & fee to EPA to become Certified Renovation Firm Certified Renovator for each Firm. Visit for training dates and location for EPA Certified Renovator training. Certified Renovator for each Firm. Visit for training dates and location for EPA Certified Renovator training. Instruct contractors & sub-contractors performing work on your property to submit application & fee to EPA to become Certified Renovation Firms Instruct contractors & sub-contractors performing work on your property to submit application & fee to EPA to become Certified Renovation Firms

32 Recordkeeping Strategy Assign work to Certified Renovator Assign work to Certified Renovator Track or link work activity for property records; maintain for 3 years Track or link work activity for property records; maintain for 3 years Track or link contractors & sub- contractors work activity to property records; maintain for 3 years Track or link contractors & sub- contractors work activity to property records; maintain for 3 years Track Firm & Renovator certification records & renewal dates (5 years) Track Firm & Renovator certification records & renewal dates (5 years)

33 QUESTIONS? Contact Frank Martin (301)


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