11 HUD’s Lead Safety Rules and EPA’s Lead in Renovation Rule Dr. Warren Friedman Office of Healthy Homes and Lead Hazard Control www.hud.gov/offices/lead.

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Presentation transcript:

11 HUD’s Lead Safety Rules and EPA’s Lead in Renovation Rule Dr. Warren Friedman Office of Healthy Homes and Lead Hazard Control

22 Two perspectives on changes Changes to HUD Lead Safe Housing Rule (LSHR) as a result of EPA Renovation, Repair and Painting (RRP) Rule Additional requirements for projects covered by HUD’s LSHR as well as the EPA’s RRP Rule

33 Main changes to HUD LSHR projects from EPA RRP Rule Tenant-based rental assistance: –RRP rule covers housing even if no child under 6 lives there Training and certification: –EPA- or State-certification is needed for the renovation firm and at least one supervisor or worker who is at the job or who is available when work is being done.

44 Additional Requirements for projects covered by HUD’s LSHR as well as the EPA’s RRP Rule

55 Determination that LBP is present. EPA: Certified renovators use EPA- recognized test kit to determine presence of LBP. HUD: EPA-recognized test kits may not be used to say paint is not LBP. Evaluation, paint testing or presumption by certified individual. Renovators may evaluate only if certified as LBP inspector or risk assessor.

66 Training and Certification EPA: EPA certifies renovators and firms. Only certified renovator required to have classroom training. Workers may receive on-the-job training from the certified renovator. HUD: All workers and supervisors must complete HUD-approved lead safe work practices course.

77 Treating LBP hazards EPA: Most renovations in target housing performed in a lead-safe manner. HUD: Depending on type and amount of HUD assistance, most lead hazards treated using interim controls, some with ongoing lead-based paint maintenance.

88 Prohibited Work Practices EPA: Prohibits 3 work practices: open flame burning or torching, heat guns above 1100 degrees F, power sanding, etc., without HEPA vacuum attachment. HUD: EPA’s plus: heat guns that char paint, dry scraping farther than 1 ft. of electrical outlets, and use of volatile strippers in poorly ventilated space.

99 De minimis amounts EPA: 6 sq. ft. per interior space; 20 sq. ft. for exterior work. HUD: 2 sq. ft. per interior space; 20 sq. ft. for exterior work.